Protection Island and San Juan Islands 

National Wildlife Refuges

Draft Comprehensive Conservation Plan,

Draft Wilderness Stewardship Plan, 

and Environmental Assessment

Jefferson, Island, San Juan, Skagit, Whatcom Counties, Washington

Prepared by:

U.S. Fish and Wildlife Service

Washington Maritime National Wildlife Refuge Complex

715 Holgerson Road

Sequim WA, 98382

And 

U.S. Fish and Wildlife Service

Division of Planning and Visitor Services

911 NE 11th Avenue

Portland, OR 97232

August 2010
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Table of Contents i

Table of Contents

Chapter 1. Introduction and Background..........................................................1-1

1.1 Introduction..........................................................................................................................................1-1

1.2 Significance of the Refuges .................................................................................................................1-1

1.3 Proposed Action...................................................................................................................................1-9

1.4 Purpose and Need for the Plan.............................................................................................................1-9

1.5 Content and Scope of the Plan ..........................................................................................................1-10

1.6 Legal and Policy Guidance ................................................................................................................1-10

1.7 Refuge Establishment and Purposes..................................................................................................1-13

1.8 Relationship to other Planning Efforts...............................................................................................1-14

1.9 Issues Addressed in the Draft CCP/WSP/EA ....................................................................................1-15

1.10 Refuge Vision Statements................................................................................................................1-16

1.11 Refuge Goals....................................................................................................................................1-16

1.12 Planning Process..............................................................................................................................1-17

Chapter 2. Alternatives, Goals, Objectives, and Strategies..............................2-1

2.1 Alternative Development ....................................................................................................................2-1

2.2 Actions Considered but Not Developed .............................................................................................2-1

2.3 Similarities Among Alternatives .........................................................................................................2-2

2.4 Summary of Alternatives ....................................................................................................................2-5

2.5 Goals, Objectives, and Strategies ......................................................................................................2-29

 Goal 1. Shoreline ...............................................................................................................................2-29

Goal 2. Sandy Bluffs.........................................................................................................................2-34

Goal 3. Savanna, Grasslands, and Balds ...........................................................................................2-38

Goal 4. Forests and Woodlands.........................................................................................................2-43

Goal 5. Small Wetlands.....................................................................................................................2-46

Goal 6. On-Refuge Visitor Services..................................................................................................2-47

Goal 7. Off-Refuge Visitor Services.................................................................................................2-52

Goal 8. Wilderness............................................................................................................................2-56

Goal 9. Research and Monitoring......................................................................................................2-58

Chapter 3. Physical Environment.......................................................................3-1

3.1 Climate and Climate Change ...............................................................................................................3-1

3.2 Oceanography and Climate Change ....................................................................................................3-5

3.3 Topography and Bathymetry .............................................................................................................3-10

3.4 Recent Geological History and Geomorphology ...............................................................................3-11

3.5 Soils ...................................................................................................................................................3-13

3.6 Hydrology .........................................................................................................................................3-14

3.7 Fire ....................................................................................................................................................3-15

3.8 Air Quality ........................................................................................................................................3-15

3.9 Water Quality ....................................................................................................................................3-16

3.10 Environmental Contaminants ..........................................................................................................3-16
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

ii Table of Contents

Chapter 4. Refuge Biology and Habitats............................................................4-1

4.1 Biological Integrity Analysis...............................................................................................................4-1

4.2 Priority Resources of Concern Selelction and Analysis ......................................................................4-

4.3 Shoreline ............................................................................................................................................4-13

6

4.4 Sandy Bluffs.......................................................................................................................................4-16

4.5 Savanna, Grasslands, and Balds.........................................................................................................4-19

4.6 Forests and Woodlands......................................................................................................................4-23

4.7 Wetlands ............................................................................................................................................4-28

4.8 Seabirds .............................................................................................................................................4-30

4.9 Bald Eagles........................................................................................................................................4-42

4.10 Black Oystercatcher.........................................................................................................................4-45

4.11 Marine Mammals.............................................................................................................................4-47

4.12 Herbivores and Predtors of Management Concern .........................................................................4-52

4.13 Paleontological Resources...............................................................................................................4-54

Chapter 5. Human Environment ........................................................................5-1

5.1 Cultural Resources ..............................................................................................................................5-1

5.2 Refuge Facilities .................................................................................................................................5-6

5.3 Research...............................................................................................................................................5-9

5.4 Refuge Recreation .............................................................................................................................5-12

5.5 Other Refuge Uses ............................................................................................................................5-16

5.6 Regional Recreational Opportunities ................................................................................................5-17

5.7 Regional Recreation Rates and Trends .............................................................................................5-26

5.8 Socioeconomics .................................................................................................................................5-28

Chapter 6. Environmental Consequences..........................................................6-1

6.1 Overview of Effects Analysis..............................................................................................................6-1

6.2 Summary of Effects .............................................................................................................................6-2

6.3 Effects to Physical Environment..........................................................................................................6-7

6.4 Effects to Habitats .............................................................................................................................6-10

6.5 Effects to Wildlife .............................................................................................................................6-13

6.6 Effects to Wilderness Resources........................................................................................................6-17

6.7 Effects to Cultural Resources.............................................................................................................6-18

6.8 Effects to Paleontological Resources.................................................................................................6-19

6.9 Effects to Research Program .............................................................................................................6-20

6.10 Social and Economic Effects ..........................................................................................................6-21

6.11 Cumulative Effects...........................................................................................................................6-25

Appendix A. Lands ...........................................................................................A-1

Appendix B. Island Resources..........................................................................B-1

Appendix C. Habitats and Wildlife .................................................................C-1

Appendix D. Sign Plans ....................................................................................D-1
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Table of Contents iii

Appendix E. Integrated Pest Management Program.....................................E-1

Appendix F. Area Beaches................................................................................F-1

Appendix G. Implementation ...........................................................................G-1

Appendix H. Wilderness....................................................................................H-1

Appendix I. Findings of Appropriateness for Refuge Uses ...........................I-1

Appendix J. Compatibility Determinations.....................................................J-1

Appendix K. Coordination, Consultation, and Compliance .........................K-1

Appendix L. Acronyms and Glossary..............................................................L-1

Figures

1.1 Salish Sea.............................................................................................................................................1-3

1.2 Protection Island National Wildlife Refuge.........................................................................................1-5

1.3 San Juan Islands National Wildlife Refuge .........................................................................................1-7

2.1 Protection Island NWR - Alternative A ............................................................................................2-11

2.2 San Juan Islands NWR, Smith and Minor Islands - Alternative A ...................................................2-13

2.3 San Juan Islands NWR, Matia Island - Alternative A ......................................................................2-15

2.4 San Juan Islands NWR, Turn Island - Alternative A ........................................................................2-17

2.5 Protection Island NWR - Alternatives B and C ................................................................................2-19

2.6 San Juan Islands NWR, Smith and Minor Islands - Alternative B and C .........................................2-21

2.7 San Juan Islands NWR, Matia Island - Alternatives B and C ...........................................................2-23

2.8 San Juan Islands NWR, Turn Island - Alternative B ........................................................................2-25

2.9 San Juan Islands NWR, Turn Island - Alternative C ........................................................................2-27

3.1 Washington State average annual precipitation from 1971 to 2000 ....................................................3-3

3.2 Global ocean (surface) currents ...........................................................................................................3-6

3.3 Global sub-surface currents .................................................................................................................3-7

4.1 Protection Island Current Vegetation...................................................................................................4-9

4.1 Smith and Minor Islands Current Vegetation ....................................................................................4-11
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-1

Chapter 1. Introduction and Background

 

1.1 Introduction

Protection Island National Wildlife Refuge and San Juan Islands National Wildlife Refuge (NWR or 

Refuge or Refuges) are managed by the U.S. Fish and Wildlife Service (USFWS or Service) as part of the 

National Wildlife Refuge System (NWRS or System). They are two of the six refuges that comprise the 

Washington Maritime National Wildlife Refuge Complex. Both of these Refuges are within a geographic 

area now known as the Salish Sea (Figure 1.1). The Salish Sea is a single estuarine ecosystem that extends 

from the north end of the Strait of Georgia to the west end of the Strait of Juan de Fuca and south to the 

southern extent of Puget Sound. It encompasses the inland marine waters of Southern British Columbia, 

Canada, and northern Washington, USA (WWU 2009). 

Protection Island NWR is located in the Strait of Juan de Fuca near the entrance to Discovery Bay in 

Jefferson County, Washington. It includes 659 acres of land and tideland lease. Kanem Point, the part of 

Protection Island closest to the mainland, is 1.4 miles due north of Diamond Point and 5 miles due west of 

Port Townsend, Washington (Figure 1.2). 

Most of the San Juan Islands NWR consists of rocks, reefs, and islands scattered throughout the San Juan 

Archipelago. Two islands, Smith and Minor, however, are located south of the archipelago within the 

Strait of Juan de Fuca. The Refuge consists of approximately 449 acres in Island, San Juan, Skagit, and 

Whatcom Counties, Washington. Most (353 acres) of San Juan Islands NWR is also designated 

wilderness known as the San Juan Islands Wilderness Area (see Figure 1.3).

1.2 Significance of the Refuges 

Protection Island NWR

Protection Island was given its present name by Captain George Vancouver, who visited in May 1792 and 

described the landscape “as enchantingly beautiful as any of the most elegantly finished pleasure grounds 

in Europe” (Meany 1907). An early naturalist, Suckley (1859), referred to Protection Island as a “favored 

breeding ground of the rhinoceros auklet.” Subsequent farming and livestock grazing for over 100 years,

introduction of domestic cats, establishment of a Coast Artillery battery during WWII, major fires that 

burned much of the island during the 1940s and 50s, plus subdivision for summer homes and a resort 

during the late 1960s-70s, took their toll on the native plants and wildlife of Protection Island. Despite 

habitat alteration, local naturalists and conservation organizations recognized the significant wildlife values 

of the island and lobbied for its protection. In 1975 Washington State established the Zella M. Schultz 

Seabird Sanctuary on the southwestern tip of the island, and in 1982 Congress established the Protection 

Island NWR on the remaining portions of the island. 

Native wildlife recovered such that today six species of seabirds (rhinoceros auklets, tufted puffin, pigeon 

guillemot, pelagic cormorant, double-crested cormorant, and glaucous-winged gulls) nest on Protection 

Island. This island continues to be particularly important for rhinoceros auklets. A recent survey indicates 

that the breeding colony on Protection Island may be the third largest in North America (Pearson et al. 

2009) and it is one of just eight islands that support more than 95% of the North American breeding 

population of rhinoceros auklets (Gaston and Deschesne 1996). The island also supports a nesting pair of 

bald eagles, several black oystercatcher territories, resting and feeding areas for harlequin ducks and black 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-2 Chapter 1 – Introduction and Background

brant, and many forest and grassland birds. In 1997, Protection Island became the first location in 

Washington State where a few northern elephant seals were observed to haul-out and have pups (Jeffries et 

al 2000). The island is also a haul-out and pupping site for hundreds of the much smaller harbor seal. 

Paleontological materials, including remains of a mammoth and a giant beaver, have been seen on 

Protection Island and at other nearby sites, indicating there may be much more to learn about prehistoric 

wildlife from this nonrenewable resource. 

Protection Island has been a center for learning and research since before the Refuge was established and 

continues to the present. The Service, along with other Federal and State agencies, as well as university 

professors and their students have conducted many studies on Protection Island. While Protection Island 

remains closed to the public to provide wildlife sanctuary, visitors and local residents can enjoy observing 

and listening to birds and marine mammals at a distance, from boats and points on the mainland. 

San Juan Islands NWR 

Though small in size, the scattered islands, rocks, and reefs of the San Juan Islands NWR are important for 

marine wildlife. An estimated 80% of the breeding population of black oystercatchers in Washington’s 

inland marine waters are using the rocks and islands within the San Juan Islands NWR for nesting 

(Nysewander 2003). There is a rhinoceros auklet colony on Smith Island, which although much smaller 

than the Protection Island colony, is still important for this species. Several pairs of Brandt’s cormorants 

were recently confirmed nesting and tending their young on an island within the Refuge. There are also 11 

bald eagle nesting territories on Refuge islands. A few northern elephant seals and hundreds of harbor 

seals haul-out and care for their pups on Smith Island (Hayward 2003, Jeffries et al 2000). Federally 

threatened Steller sea lions as well as California sea lions haul out on a few Refuge rocks from fall through 

spring. 

Matia Island, the largest within the Refuge, has a magnificent old-growth forest of Douglas-fir, cedars, and 

hemlocks. Refuge rocks and islands are also home to a number of rare and endemic plants including brittle 

prickly-pear cactus, California buttercup, and bear’s foot sanicle. Refuge islands have significantly more 

species of native plants and fewer introduced species compared to adjacent islands (Bennett 2007). 

The natural resources, recreational opportunities, and scenic beauty of the Salish Sea, including the San 

Juan Archipelago, have resulted in several special designations of the area. In addition to establishing the 

San Juan Islands NWR, most of this Refuge is also designated as the San Juan Islands Wilderness and 

therefore part of the National Wilderness Preservation System. The Refuge is within the Cascadia Marine 

Trail which is a National Recreation Trail and one of the premier water trails for non-motorized boaters in 

the United States. Two Refuge islands, one of them a wilderness island, provide opportunities to camp 

overnight. This facilitates wildlife observation and photography via non-motorized boats throughout the 

area. The Refuge is also an important part of the San Juan Islands Scenic Byway. Residents and tourists 

enjoy opportunities to learn about the Salish Sea and its natural resources as well as view wildlife and 

Refuge islands from ferries, commercial tour boats, and private boats. 
Victoria

Vancouver

Powell River

Nanaimo

Courtenay

Campbell River

Seattle

Olympia

Bremerton

Everett

Bellingham

Tacoma

Port Angeles

Figure 1.1 Salish Sea

Data Sources: Populated Places and Country Boundaries from Natural Earth; Imagery from NASA Blue Marble; Elevation from NASA/CGIAR-CSI

Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1. Introduction and Background 1-3

0 Miles 50

0 Kilometers 50

NAD 83

UTM ZONE 10N
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-4 Chapter 1 – Introduction and Background

To preserve the quality of our map, this side was left blank intentionally.
Data Sources: Refuge Boundaries from USFWS/R1; State and County Boundaries from BLM; Imagery from 7/30/2003 WDOT True Color Aerial Photography

Figure 1.2 Protection Island National Wildlife Refuge

Jefferson County

Clallam County

Chapter 1. Introduction and Back

ground 1-5

Land Statu

Appro

USFW

WDN

(from 

WDFW 

(not w

Adjacent A

WDN

(200 Y

0 

0 

Kanem Point
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-6 Chapter 1 – Introduction and Background

To preserve the quality of our map, this side was left blank intentionally.
!

!

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Dungeness

Spit

Griffin

Bay

UNITED STATES

CANADA

Anacortes

Coupeville

Eastsound

Friday Harbor Guemes

Marietta

Oak Harbor

Orcas

Richardson

Roche Harbor

Shaw Island

Thatcher

Urban

Waldron

Washington

Onamac

Point

Point

Demock

British Columbia

Whatcom County

San Juan County

Whatcom County

Skagit County

Skagit County

San Juan County

San Juan County Island County

Island County

Jefferson County

Admiralty

Bay

Bellingham

Bay

Burrows

Bay

Crescent

Harbor

Dugualla

Bay

Dungeness

Bay

Fidalgo

Bay

Kiket

Bay

Lummi

Bay

Oak

Harbor

Padilla

Bay

Penn Cove

Race

Lagoon

Turners

Bay

Allan

Island

Burrows

Island

Center

Island

Henry

Island

Hope

Island

Johns

Island

Jones

Island

Kalamut

Island

Portage

Island

Samish

Island

Spieden

Island

Sucia

Island

Blakely

Island

Cypress

Island

Decatur

Island

Guemes

Island

Lopez

Island

Lummi

Island

Orcas

San Juan

Island

Shaw

Island

Stuart

Island

Waldron

Island

Whidbey

Island

Sinclair

Island

Island

Saturna Island

Pender

Island

Barnes Island Clark Island

Patos Island 44

77

43

48

34 38 39

32 37 65

33

62 31

36

40

42

45

50

53

30

64

68

77

60 61

29

49

70

72

73

54 58

28

55 57 52

56

1

18

25 24 4

3

78

79

84

81

80

5

83

16

6

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8

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7

76 75

13 14

23 26 2

9

19

20

21

35

22 27

46

47

59

66

69

74

82

63

41

71

51

17

15

Figure 1.3 San Juan Islands National Wildlife Refuge

Data Sources: Refuge Boundaries from USFWS/R1; State and County Boundaries from BLM; Elevation from USGS; Bathymetry from UW PRISM,

NOAA, and NWIC; Roads from ESRI

1. Small Island

2. Rum & Rim Islands

3. Fortress Island

4. Skull Island

5. Crab Island

6. Boulder Island

7. Davidson Rock

8. Castle Island

9. Blind Island

10. Aleck Rocks

11. Swirl Island

12. Unnamed Rock

13. Unnamed

14. Unnamed

15. Hall Island

16. Unnamed

17. Secar Rock

18. Unnamed

19. Unnamed

20. Unnamed

21. Mummy Rocks

22. Unnamed

23. Shark Reef

24. Harbor Rock

25. North Pacific Rock

26. Halftide Rocks

27. Unnamed

28. Low Island

29. Pole Island

30. Barren Island

57. Pointer Island

58. Black Rock

59. Spindle Rock

60. Brown Rock

61. Unnamed

62. South Peapod

 (Peapod Rocks)

63. Unnamed

 (Peapod Rocks)

64. North Peapod

 (Peapod Rocks)

65. Eliza Rock

66. Viti Rocks

68. Bird Rock

69. Unnamed

70. Low Island

71. Nob Island

72. Unnamed

73. Unnamed

74. Unnamed

75. Smith Island

76. Minor Island

77. Matia Island

78. Puffin Island

79. Turn Island

80. Bird Rocks

81. Williamson Rocks

82. Colville Island

83. Buck Island

84. Bare Island

31. Battleship Island

32. Sentinel Rock

33. Center Reef

34. Gull Reef

35. Ripple Island

36. Unnamed (Shag Reef)

37. Unnamed (Little Cactus

 Island)

38. Gull Rock

39. Flattop Island

40. White Rock (Danger

 Rock)

41. Mouatt Reef

42. Skipjack Island

43. Unnamed

44. Clements Reef

45. Unnamed

46. Parker Reef

47. Lone Tree Island 

 (The Sisters)

48. Little Sister 

 (The Sisters)

49. Unnamed

50. Tift Rocks

51. Reef Point

52. Turn Rock

53. Shag Rock

54. Flower Island

55. Willow Island

56. Lawson Rock

San Juan Islands Refuge ID and Name

Land Status

Refuge Lands with

Wilderness Designation

Refuge Lands without

Wilderness Designation

WASHINGTON

Area of map

UTM ZONE 10N

NAD 83

Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1. Introduction and Background 1-7

0 Kilometers 4

0 Miles 4
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-8 Chapter 1 – Introduction and Background

To preserve the quality of our map, this side was left blank intentionally.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-9

1.3 Proposed Action

The Service is proposing to adopt and implement a Comprehensive Conservation Plan for Protection 

Island and San Juan Islands NWRs and a Wilderness Stewardship Plan for the San Juan Wilderness. This 

document is the Refuges’ Draft Comprehensive Conservation Plan, Wilderness Stewardship Plan, and 

Environmental Assessment (Draft CCP/WSP/EA, CCP, or plan). This Draft CCP/WSP/EA has been 

prepared pursuant to the National Wildlife Refuge System Administration Act of 1966 (Administration 

Act), the National Environmental policy Act of 1969 (NEPA), and the Wilderness Act of 1964. 

The Administration Act requires CCPs to identify and describe:

• The purposes of the refuge;

• The fish, wildlife, and plant populations, their habitats, and the archaeological and cultural values 

found on the refuge;

• Significant problems that may adversely affect wildlife populations and habitats and ways to 

correct or mitigate those problems;

• Areas suitable for administrative sites or visitor facilities; and 

• Opportunities for fish and wildlife dependent recreation.

The Service developed and evaluated three alternative management approaches which are described in 

Chapter 2 of this Draft CCP/WSP/EA. The proposed action is to implement Alternative B which has been 

identified as the Service’s Preferred Alternative. Among the alternatives evaluated, this alternative appears 

to best achieve the purpose, vision, and goals for the Refuges. The preferred alternative may be modified 

between the draft and final documents depending upon comments received from the public or other 

agencies and organizations. The Service’s Regional Director for the Pacific Region will decide which 

alternative will become the Refuges’ Comprehensive Conservation Plan. 

1.4 Purpose of and Need for the Plan

National Wildlife Refuge System (Refuge System) planning policy (Service Manual Part 602 FW3, June 

21, 2000) states that the purpose of CCPs is to “describe the desired future conditions of a refuge and 

provide long-range guidance and management direction to achieve refuge purposes; help fulfill the 

National Wildlife Refuge System mission; maintain and, where appropriate, restore the ecological integrity 

of each refuge and the Refuge System; . . . and meet other mandates.” The plan is expected to serve as a 

management guide for approximately the next 15 years. 

Long-range management direction for the Refuges is needed to address Refuge management concerns for 

wildlife and habitats, including human-caused wildlife disturbance, the risk of oil spills, marine debris, the 

increasing deer herd on Protection Island, invasive species, and where possible, to anticipate management 

concerns related to climate change including sea level rise. There is a need to re-evaluate the research 

activities and facilities on Protection Island to see if they can be improved in ways that better support 

Refuge management. There is also a need to evaluate the quality, appropriateness, and compatibility of 

visitor services programs and activities. 

Prior management plans for these Refuges were developed in the 1980s. These older plans are now 

outdated both in terms of Refuge resources and conditions, as well as current policies and mandates. Once 

an alternative has been selected and the plan is finalized and approved, it will supersede the Master Plan 

for Protection Island National Wildlife Refuge (USFWS 1985), Refuge Management Plan for San Juan 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-10 Chapter 1 – Introduction and Background

Islands National Wildlife Refuge (USFWS 1986) and the San Juan Islands Wilderness Plan (USFWS 

1978). 

1.5 Content and Scope of the Plan

The content and scope of this plan is based on meeting the requirements of the Administration Act, NEPA, 

and Service policies within the context of the purposes of the Refuges and the natural, cultural, and 

wilderness resources they contain. This plan includes:

• A long-term vision for each Refuge (inside cover and Chapter 1).

• Goals and objectives for Refuge resources, wilderness values, and public use programs, as well as 

strategies for achieving the objectives (Chapter 2). 

• A description of the physical environment including geology and climate change (Chapter 3).

• A description of the Refuge resources, their conditions, and trends on the Refuges and within the 

ecosystem (Chapter 4).

• A description of the cultural resources and public use programs on and near the Refuges, as well as 

Refuge facilities, and local socioeconomic conditions (Chapter 5). 

• The anticipated effects of each alternative (Chapter 6). 

• Detailed information about Refuge establishment, land status, and habitat protection priorities 

(Appendix A). 

• Information regarding specific rocks, islands, and reefs within the San Juan Islands NWR (Appendix 

B).

• Additional information about Priority Resources of Concern and Ecological Systems (Appendix C).

• Sign Plans for each of the Refuges (Appendix D) and an Integrated Pest Management Plan for the 

entire Complex (Appendix E). 

• Memorandum of Understandings with other Agencies (Appendix F).

• Staffing, funding, and partnerships necessary to implement the plan (Appendix G).

• Wilderness Reviews and Minimum Requirements Analyses (Appendix H).

• Appropriateness Findings (Appendix I) and Compatibility Determinations (Appendix J) for Refuge 

uses.

• Summary of public involvement activities as well as legal compliance information (Appendix K).

• Guide to acronyms used in the document and well as some definitions (Appendix L).

1.6 Legal and Policy Guidance

Protection Island NWR and San Juan Islands NWR are managed as part of the National Wildlife Refuge 

System within the legal and policy framework of the U.S. Fish and Wildlife Service within the Department 

of the Interior. The Refuge System Administration Act of 1966, as amended, serves as the primary 

guidance for management of the System. The Wilderness Act also guides the management of the San Juan

Islands NWR because most of this Refuge is included in the designated San Juan Islands Wilderness Area. 

1.6.1 U.S. Fish and Wildlife Service

The U.S. Fish and Wildlife Service is the principal Federal agency responsible for conserving, protecting 

and enhancing fish, wildlife, and plants and their habitats for the continuing benefit of the American 

people. The Service manages the National Wildlife Refuge System which includes Protection Island NWR 

and San Juan Islands NWR. It also operates national fish hatcheries, fishery resources offices, and 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-11

ecological services field stations. The agency enforces federal wildlife laws, administers the Endangered 

Species Act, manages migratory bird populations, restores nationally significant fisheries, conserves and 

restores wildlife habitat such as wetlands, and helps foreign and Native American tribal governments with 

their conservation efforts. It also oversees the Federal Assistance program, which distributes hundreds of 

millions of dollars in excise taxes on fishing and hunting equipment to state fish and wildlife agencies.

The mission of the U.S. Fish and Wildlife Service is:

“Working with others to conserve, protect, and enhance fish, wildlife, and plants and 

their habitats for the continuing benefit of the American people.”

 

1.6.2 National Wildlife Refuge System 

Starting with the first refuge, Florida’s Pelican Island, established in 1903 by President Theodore 

Roosevelt, the National Wildlife Refuge System has grown to more than 150 million acres in size. It 

includes more than 520 refuges, at least one in every state, and thousands of small wetlands and other 

special management areas. The needs of wildlife and their habitats come first on refuges, in contrast to 

other public lands managed for multiple uses.

The National Wildlife Refuge System Administration Act

The National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S.C. 668dd et seq.),

serves as the primary guidance for management of the System. One very important amendment to the 

Administration Act was the National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-

57). This amendment included a unifying mission for the Refuge System; a new process for determining 

compatible uses on refuges; and a requirement that each refuge will be managed under a Comprehensive 

Conservation Plan. It also states that wildlife conservation is the priority of NWRS lands and that the 

Secretary of the Interior shall ensure that the biological integrity, diversity, and environmental health of 

refuge lands are maintained. Each refuge must be managed to fulfill the Refuge System mission and the 

specific purposes for which it was established. The Service is required to monitor the status and trends of 

fish, wildlife, and plants on each refuge. Additionally, the Act identifies six wildlife-dependent 

recreational uses. These uses are hunting, fishing, wildlife observation and photography, environmental 

education and interpretation. As priority public uses of the Refuge System, these uses will receive 

enhanced consideration over other uses in planning and management. Lands within the National Wildlife 

Refuge System are different from other, multiple-use public lands in that they are closed to all public uses 

unless specifically and legally opened. No refuge use may be allowed unless it is determined to be 

compatible with refuge purposes and the System Mission. 

The Mission of the National Wildlife Refuge System is:

“To administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and 

future generations of Americans.” 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-12 Chapter 1 – Introduction and Background

The Goals of the National Wildlife Refuge System are:

 Conserve a diversity of fish, wildlife, and plants and their habitats, including species that are 

endangered or threatened with becoming endangered.

 Develop and maintain a network of habitats for migratory birds, anadromous and interjurisdictional 

fish, and marine mammal populations that is strategically distributed and carefully managed to meet 

important life history needs of these species across their ranges.

 Conserve those ecosystems, plant communities, wetlands of national or international significance, and 

landscapes and seascapes that are unique, rare, declining, or underrepresented in existing protection 

efforts. 

 Provide and enhance opportunities to participate in compatible wildlife-dependent recreation (hunting, 

fishing, wildlife observation and photography, and environmental education and interpretation).

 Foster understanding and instill appreciation of the diversity and interconnectedness of fish, wildlife, 

and plants and their habitats. (Fish and Wildlife Service Manual Part 601 FW 1 sec1.8, June 2006) 

1.6.3 National Wilderness Preservation System 

The Wilderness Act of 1964 (16 U.S.C. 1131-1136, 78 Stat. 890) -- Public Law 88-577, approved 

September 3, 1964, directed the Secretary of the Interior and the Secretary of Agriculture to review every 

roadless area of 5,000 or more acres and every roadless island (regardless of size) within National Wildlife 

Refuges, National Parks, and National Forests and to recommend to the President the suitability of each 

such area or island for inclusion in the National Wilderness Preservation System, with final decisions made 

by Congress. The Act provides criteria for determining suitability and establishes restrictions on activities 

that can be undertaken on a designated area. 

Under the authority of the Wilderness Act, over 20 million acres of land and water in 66 National Wildlife 

Refuges have been designated as part of the National Wilderness Preservation System by special Acts of 

Congress. The San Juan Islands Wilderness area, which includes 353 acres within the San Juan Islands 

NWR, was established in 1976 under Public law 94-557 (USFWS 2009a). The only parts of this Refuge 

that are not designated wilderness are Smith and Minor Islands, Turn Island, and a small portion of Matia 

Island. 

1.6.4 Other laws and mandates 

Many other Federal laws, executive orders, Service policies, and international treaties govern the U.S. Fish 

and Wildlife Service and Refuge System lands. Examples include the Migratory Bird Treaty Act of 1918, 

Refuge Recreation Act of 1962, National Historic Preservation Act of 1966, and the Endangered Species 

Act of 1973. A list and brief description of Federal laws of interest to the Service can be found in the 

Laws Digest at http://www.fws.gov/laws. 

Over the last few years the Service has developed or revised numerous policies to reflect the mandates and 

intent of the Improvement Act. Some of these key policies include Comprehensive Conservation Planning 

process (602 FW 3); Appropriate Refuge Uses (603 FW 1); Compatibility (603 FW 2); WildlifeDependent Recreation (605 FW 1-7); Biological Integrity, Diversity, and Environmental Health (601 FW 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-13

3); and Pesticide Safety (242 FW 7). In addition, the Service has recently revised the Wilderness 

Stewardship policy (610 FW 2). These and many other policies that guide the U.S. Fish and Wildlife 

Service and management of Refuge System lands can be found within the Service Manual which can be 

accessed at http://www.fws.gov/policy/manuals/. 

1.7 Refuge Establishment and Purposes

The Service defines the purposes of a National Wildlife Refuge when the refuge is established or when 

new land is added to an existing refuge. When an addition to a refuge is acquired under an authority 

different from the authority used to establish the original refuge, the addition takes on the purposes of the 

original refuge, but the original refuge does not take on the purposes of the addition. Each refuge must be 

managed to fulfill the Refuge System mission and the specific purposes for which the refuge was 

established. Managers must consider all refuge purposes; however, purposes dealing with the 

conservation, management, and restoration of fish, wildlife and plants, and their habitats, take precedence

over other purposes. If a conflict exists between the Refuge System mission and the refuge purposes, 

the purposes may supersede the mission. The following paragraphs identify refuge purposes with bold 

italics and provide a brief description of refuge establishment history related to those purposes. For more 

details on refuge establishment history, see Appendix A. 

Protection Island NWR Establishment and Purposes (purposes are bold and italicized)

Refuge establishment was authorized by the Protection Island National Wildlife Refuge Act, Public Law 

97 – 333, Oct 15, 1982 (96 Stat. 1623): “The purposes of the refuge are to provide habitat for a broad 

diversity of bird species, with particular emphasis on protecting the nesting habitat of the bald eagle, 

tufted puffin, rhinoceros auklet, pigeon guillemot, and pelagic cormorant; to protect the hauling-out 

area of harbor seals; and to provide for scientific research and wildlife-oriented public education and 

interpretation (96 Stat. 1623)” and applies to all portions of Protection Island NWR. The first 1.42 acres 

of the Refuge were donated by Admiralty Audubon Society “. . in accordance with Public law 97-333 (96 

Stat. 1623) Protection Island National Wildlife Refuge Act (Donation Warranty Deed, December 22, 

1982).” Most of the over 800 tracts that make up the Refuge were authorized by the same act and 

purchased from 1983-1987 with funds authorized by the Land and Water Conservation Fund Act of 1965, 

as amended. Purposes of this fund include “acquisition of ...(d) any areas authorized for the National 

Wildlife Refuge System by specific Acts” (16 U.S.C. 460l-9). The Service also has a 20-year aquatic 

lands lease for the second class tidelands around Protection Island (No 20-013245) from the Washington 

Department of Natural Resources (WDNR). This lease is authorized by the Fish and Wildlife Act of 1956, 

“. . . for the development, advancement, management, conservation, and protection of fish and wildlife 

resources . . .” (16 U.S.C.742 f(a)(4)). 

San Juan Islands NWR Establishment and Purposes (purposes are bold and italicized)

San Juan Islands NWR was first established in 1960 to be “. . . reserved under jurisdiction of the Bureau 

of Sport Fisheries and Wildlife, United States Fish and Wildlife Service. . .” (PLO 2249). In 1975, the 

San Juan Islands NWR was consolidated with Smith Island NWR (est. 1914), Matia Island NWR (est. 

1937) and Jones Island NWR (est. 1937) and additional lands were reserved under the name of San Juan 

Islands NWR (PLO 5515). PLO 5515 does not state a purpose for this newly consolidated Refuge but an 

earlier proposal published in 38 FR 29831 on Oct 29, 1973, stated it was to “. . .facilitate the 

management of migratory birds for which the United States has a responsibility under international 

treaties and to further effectuate the purposes of the Migratory Bird Conservation Act.” Smith and 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-14 Chapter 1 – Introduction and Background

Minor Islands also retain their original establishing purpose from E.O. 1959 “as a preserve, breeding

ground and winter sanctuary for native birds.” Similarly, Matia Island retains its original establishing 

purpose from E.O. 7595 “ . . . as a refuge and breeding ground for migratory birds and other wildlife.”

In October 1976, the San Juan Islands Wilderness was established (P.L. 94-557) which added the purposes 

of the Wilderness Act (P.L. 88-577, Sept. 3, 1964) including “. . .to secure for the American people of 

present and future generations the benefits of an enduring resource of wilderness” to all units of the 

Refuge except for Smith, Minor, Turn, and Jones Islands, and a small portion of Matia Island. Under P.L. 

97-333 (1982) and PLO 6489 (1983) Jones Island was removed from the San Juan Islands NWR and 

transferred to the State of Washington for use as a public recreation area. Under executive orders since the 

mid-to-late 1800s and in the Refuge establishing documents, it was stated that some islands which are now 

units of the San Juan Islands NWR retain “lighthouse purposes.” These “lighthouse purposes” today 

translate into a variety of navigation aids which are maintained under the jurisdiction of the U.S. Coast 

Guard. 

1.8 Relationship to Other Planning Efforts

When developing a CCP, the Service considers the goals, objectives, strategies, and other information 

available in existing national, regional, and ecosystem plans, state fish and wildlife conservation plans, and 

other landscape-scale plans developed for the same watershed or ecosystem in which the Refuges are 

located. To the extent possible, the CCP is expected to be consistent with the existing plans and assist in 

meeting their conservation goals and objectives. The following table identifies some of the key plans 

which were reviewed by members of the core team while developing the CCP. Columns indicate portions 

of the Draft CCP/WSP/EA where these plans were applicable.

Relationship of Other Planning Efforts to the Protection Island 

and San Juan Islands CCP/WSP/EA

Plans Reviewed

Goals, 

Objectives,

& Strategies 

(Chapter 2)

Affected 

Environment

(Chapters 3-5)

Appendices

State of Washington Comprehensive Wildlife Conservation Strategy 

(WDFW 2005)

  

Willamette Valley, Puget Trough, Georgia Basin Ecoregional 

Assessment (Floberg et al 2004) 

 

San Juan County Marine Stewardship Area Plan (Evans and 

Kennedy 2007)

 

Strait of Juan de Fuca Geographic Response Plan (WDOE 2008)  

San Juan Islands and North Puget Sound Geographic Response 

Plans (WDOE 2009)



DRAFT Rising to the Challenge: Strategic Plan for Responding to 

Accelerating Climate Change (USFWS 2009b)



DRAFT Strategic Plan for Inventories and Monitoring on National 

Wildlife Refuges: Adapting to Environmental Change (USFWS 2010) 



The California Current Marine Bird Conservation Plan (Mills et al 

2005) 

 

Seabird Conservation Plan (USFWS 2005)   

Black Oystercatcher (Haematopus bachmani) Conservation Action 

Plan (Tessler et al 2007)

 

National Bald Eagle Management Guidelines (USFWS 2007)  
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-15

Recovery Plan for the Stellar Sea Lion (NMFS 2008)  

2009-2015 Game Management Plan (WDFW 2008) 

Recovery Plan For The Golden Paintbrush (Castilleja levisecta). 

(USFWS 2000)

 

1.9 Issues Addressed in the Draft CCP/WSP/EA

The Service defines an issue as “Any unsettled matter that requires a management decision, e.g., an 

initiative, opportunity, resource management problem, threat to the resources of the unit, conflict in uses, 

public concern, or the presence of an undesirable resource condition (602 FW 1 1.6 K).” The following 

issues are within the scope of the CCP/WSP/EA and are considered by the Service to be the major issues 

to address in this planning process:

Human-caused wildlife disturbance: How do we reduce the incidences of human-caused wildlife 

disturbance? How do we keep people and their pets off closed Refuge islands? How do we encourage 

boaters to stay far enough away from closed shorelines and closed islands to not disturb wildlife? How 

do we discourage low-flying aircraft? 

Oil and other contaminant spills: What can the Service do to reduce the risk of oil and other 

contaminant spills? In the event of a spill, is there anything the Service can do to change or modify the 

impacts? How can we reduce the amount of liquid fuel transported to Protection Island? What can be 

done about local contaminants affecting Refuge resources (i.e., rogue creosote logs and marine pilings)?

Marine debris and derelict fishing gear: What role can the Service play in reducing the presence of 

marine debris and derelict fishing gear from the Refuge and adjacent marine areas?

Invasive Species: What can the Service do to prevent the introduction and dispersal of invasive plants 

and animals and facilitate their removal from the Refuges? 

Climate Change: What monitoring is needed to better prepare for and address climate change impacts 

to species and habitats?

Deer Management: Should the Service eliminate deer on Protection Island to enhance seabird nesting 

habitat and reduce erosion? 

Habitat Restoration: Should we actively restore native plant communities on the bluffs, shoreline, 

grasslands, and forests of the Refuges, and if so, which areas should be restored?

Camping: Should we continue to allow camping on Matia and Turn Islands? Are there ways of 

modifying the camping program to make it more appropriate for San Juan Islands Refuge and to better 

facilitate wildlife-dependent uses? How do we prevent illegal camping? 

Boat Access: What is the best way to manage watercraft access to Refuge islands and still provide 

undisturbed shoreline for wildlife use? How do we reduce the incidences of unauthorized landings and 

trespass on closed shorelines and closed islands? 

Wildlife-Dependent Uses: How do we educate Refuge visitors and the communities around the 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-16 Chapter 1 – Introduction and Background

Refuges about the natural and cultural resources of the Salish Sea? How can we enhance visitors’

abilities and opportunities to observe and photograph wildlife both on- and off-Refuge? 

Community Outreach: How can we use community outreach to enhance Salish Sea conservation 

efforts?

Wilderness: How do we identify Refuge islands or inform the public to maintain a distance from the 

islands to prevent disturbance with Refuge signs and still meet the intent of wilderness? How do we 

maintain or enhance the visitor’s wilderness experience on Matia Island and within the San Juan 

Archipelago?

Research: How can the Service improve coordination with the larger research community? What 

research studies would assist in answering Refuge management questions? How can impacts to wildlife 

and habitats from research activities be minimized? How can the Service encourage off-Refuge research

which benefits Refuge resources?

1.10 Refuge Vision Statements

Protection Island’s unique combination of shoreline, spits, and sandy bluffs are a safe haven for thousands 

of nesting rhinoceros auklets, as well as tufted puffins, pigeon guillemots, and pelagic cormorants. Bald 

eagles roost and nest in the forested uplands while harbor seals and elephant seals haul out and raise their 

pups on the shoreline. Environmental education opportunities are available to dedicated college students 

and volunteers through research and stewardship projects. Staff and partners cooperatively conduct 

monitoring and research on the flora and fauna, providing sound science to inform management. Refuge 

staff and year-round resident caretakers maintain minimal infrastructure. Although the island is located 

close to human population centers, people respect wildlife’s need for refugia and maintain a distance from 

shorelines while viewing the abundant seabird and marine mammals that can be found on the island. 

Amid the cacophony of wildlife, a sense of peace nurtures the desire to care for the natural treasure that is 

Protection Island.

Protection Island NWR

The San Juan Islands NWR is a sanctuary for a dazzling array of marine life, including black 

oystercatchers, pigeon guillemots, tufted puffins, pelagic and double-crested cormorants, glaucous-winged 

gulls, and pinnipeds. Nestled among large islands and marine waters abuzz with human activity, the 

Refuge encompasses many small islands, rocks, and reefs scattered throughout the San Juan Archipelago. 

The breathtaking forces of nature shaped this marine wilderness embracing many miles of shoreline, reefs, 

lichened rocks, bluffs and old-growth forests. These wild lands inhabited by wild creatures and supporting 

healthy breeding seabird colonies provide the backdrop for folks to enjoy, appreciate, and understand the 

Refuge’s valuable place in the Salish Sea ecosystem. Working with partners, we provide opportunities for 

researchers, boaters, birders, and other nature lovers to develop a stewardship ethic for our Refuge islands.

San Juan Islands NWR

1.11 Refuge Goals

Goal 1: Protect, maintain, and restore high quality natural shoreline and rocky cliff habitats for optimum 

productivity and abundance of seabirds, marine mammals, waterfowl, and shorebirds.

Goal 2: Protect, maintain, and restore the native vegetative communities and structure of sandy bluffs to 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-17

maximize habitat for breeding seabirds.

Goal 3: Restore, maintain, and protect high quality native savanna, grasslands, and herbaceous bald habitat 

to increase the species diversity, richness, and population levels of associated flora and fauna. 

Goal 4: Restore, maintain, and protect the species richness and diversity of the forests and woodlands by 

fostering a complex understory and diversity of tree age classes.

Goal 5: Restore, maintain, and protect the biological integrity of natural, small wetlands to increase species 

diversity and productivity.

Goal 6: Increase Refuge visitors’ knowledge of the natural and cultural resources of the Salish Sea 

ecosystem; help visitors understand the role of the National Wildlife Refuge System; and encourage them 

to contribute to the stewardship of Protection Island and San Juan Islands NWRs. 

Goal 7: Increase Salish Sea residents’ and visitors’ knowledge of the natural and cultural resources of the 

ecosystem; help them understand the Refuges’ role in protecting those resources, and learn how they can 

reduce their impacts to those resources.

Goal 8: Promote the wilderness character and experience of the San Juan Islands Wilderness Area.

Goal 9: Encourage and support collection of scientific information that assists in managing Refuge 

resources and contributes to a greater understanding of the natural and cultural resources of the Salish Sea 

ecosystem.

1.12 Planning Process

The Service began the process of gathering information needed in developing a CCP/WSP for these 

Refuges in 2006. The core planning team consists of a project leader, deputy project leader, biologist, 

public use/law enforcement officer, GIS specialist, and a regional planner. An extended team assisted in 

the development of the CCP by providing special expertise and/or by reviewing and commenting on early 

drafts of the plan. The extended team consisted of various professionals from other agencies and within 

the Service. A list of core and extended team members is located in Appendix K. 

The National Wildlife Refuge System Improvement Act requires that the public have an opportunity for 

active involvement in CCP development and revision. Service policy also states that CCPs are to be 

developed in an open, public process and the agency is committed to securing public input throughout the 

process. A Notice of Intent (NOI) was published in the Federal Register on August 14, 2007, to invite the 

public to participate in the planning process and solicit their comments. Additional outreach efforts during 

initial scoping (Aug 2007-April 2008) emphasized face-to-face meetings with key state and federal 

agencies, marine resource committees, federally elected officials, tribal governments, non-governmental

organizations, and the research community. After initial public scoping, preliminary management options 

were presented at two public open house meetings in September 2008, and additional agency coordination 

occurred. The Service also distributed two planning updates, initiated news releases, and gave 

presentations at community and other non-governmental organizations to inform the public, invite 

discussion and solicit feedback. Planning issues, management alternatives and an internal review draft of 

the CCP were developed taking into consideration comments received throughout the planning process. 

Additional information regarding public involvement activities is located in Appendix K. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

1-18 Chapter 1 – Introduction and Background

References

Evens, K. and J. Kennedy. 2007. San Juan County Marine Stewardship Area Plan. Accessed at 

http://www.sjcmrc.org/programs/msaplan_files/msaplan.htm on 2/2/2010.

Bennett, J. 2007. Summary of field work on NWR islands, 2007. Report to USFWS – Washington 

Maritime NWRC. Sequim, WA. 2pp.

Floberg , J., M. Goering, G. Wilhere, C. MacDonald, C. Chappell, C. Rumsey, Z. Ferdana, A. Holt, P. 

Skidmore, T. Horsman, E. Alverson, C. Tanner, M. Bryer, P. Iachetti, A. Harcombe, B. 

McDonald, T. Cook, M. Summers, D. Rolph. 2004. Willamette Valley-Puget Trough-Georgia 

Basin Ecoregional Assessment, Volume One: Report. Prepared by The Nature Conservancy with 

support from the Nature Conservancy of Canada, Washington Department of Fish and Wildlife, 

Washington Department of Natural Resources (Natural Heritage and Nearshore Habitat programs), 

Oregon State Natural Heritage Information Center and the British Columbia Conservation Data 

Centre. 150pp.

Gaston, A. J. and S. B. Dechesne. 1996. Rhinoceros Auklet (Cerorhinca monocerata), The Birds of North 

America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved 2/10/2010 from the 

Birds of North America Online: http://bna.birds.cornell.edu/bna/species/212

Jeffries, S.J.1, P.J. Gearin2, H.R. Huber2, D.L. Saul1, and D.A. Pruett1. 2000. Atlas of Seal and Sea Lion 

Haulout Sites in Washington. Washington Department of Fish and Wildlife, Wildlife Science 

Division, 600 Capitol Way North, Olympia WA. 150pp. Retrieved 2/10/2010 from 

http://wdfw.wa.gov/wlm/research/papers/seal_haulout/seal_atlas.pdf

Meany, Edmond. 1907. Vancouver’s Discovery of Puget Sound: Portraits and Biographies of the Men 

Honored in the Naming of Geographic Features of Northwestern America. The MacMillan 

Company, London.

Mills, K. L., Sydeman, W.J. and Hodum, P. J. (Eds.). 2005. The California Current Marine Bird 

Conservation Plan, v. 1, PRBO Conservation Science, Stinson Beach, CA

NMFS 2008. National Marine Fisheries Service. 2008. Recovery Plan for the Steller Sea Lion 

(Eumetopias jubatus). Revision. National Marine Fisheries Service, Silver Spring, MD. 325 pp.

Nysewander, D. R. 2003. Summary of May 2003 survey of breeding American black oystercatchers in the 

San Juan Island/Bellingham Bay/Deception Pass vicinity, in preparation for May 2005 

oystercatcher breeding surveys. Washington Department of Fish and Wildlife, Olympia, WA. 

Pearson, S.F., P.J. Hodum, M. Schrimpf, J. Dolliver, T.P. Good, and J.K. Parrish. 2009. Rhinoceros 

Auklet (Cerorhinca monocerata) Burrow Counts, Burrow Density, Occupancy Rates, and 

Associated Habitat Variables on Protection Island, Washington: 2008 Research Progress Report. 

Washington Department of Fish and Wildlife, Wildlife Science Division, Olympia, WA.

Suckley, G. 1859. Water birds. Zoological report. In Explorations and surveys for a railroad route from the 

Mississippi River to the Pacific Ocean. Vol. 12, Pt. 3, No. 3, Chap.II. Washington, D.C.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 1 – Introduction and Background 1-19

Tessler, D.F., J.A. Johnson, B.A. Andres, S. Thomas, and R.B. Lanctot. 2007. Black Oystercatcher 

(Haematopus bachmani) Conservation Action Plan. International Black Oystercatcher Working 

Group, Alaska Department of Fish and Game, Anchorage, Alaska, U.S. Fish and Wildlife Service, 

Anchorage, Alaska, and Manomet Center for Conservation Sciences, Manomet, Massachusetts. 

115 pp.

USFWS 1985. Master Plan, Protection Island National Wildlife Refuge. USDI, U.S. Fish and Wildlife 

Service, Region 1.

USFWS 1986. Refuge Management Plan, San Juan Islands National Wildlife Refuge. U.S. Fish and 

Wildlife Service, Region 1. 

USFWS 1978. San Juan Islands Wilderness Plan. U.S. Fish and Wildlife Service, Olympia, WA. 40 pp.

USFWS 2000. Recovery Plan for the Golden Paintbrush (Castilleja levisecta). U.S. Fish and Wildlife 

Service, Portland, Oregon. 51 pp. 

USFWS 2005. Regional Seabird Conservation Plan, Pacific Region. U.S. Fish and Wildlife Service, 

Migratory Birds and Habitat Programs, Pacific Region, Portland, Oregon. 

USFWS 2007. National Bald Eagle Management Guidelines. U.S. Fish and Wildlife Service. Arlington, 

VA. 23 pp.

USFWS 2009a. Annual Report of Lands Under Control of the U.S. Fish & Wildlife Service as of 

September 30, 2009. USDI, USFWS, Division of Realty, January 2010.

USFWS 2009b. DRAFT Rising to the Challenge: Strategic Plan for Responding to Accelerating Climate 

Change. U.S. Fish and Wildlife Service. Accessed Feb 2, 2010 from 

http://www.fws.gov/home/climatechange/strategic_plan.html 

USFWS 2010. DRAFT Strategic Plan for Inventories and Monitoring on National Wildlife Refuges: 

Adapting to Environmental Change. U.S. Fish and Wildlife Service, Washington, D.C. 55

pp.

WDFW 2005. State of Washington Comprehensive Wildlife Conservation Strategy. Washington 

Department of Fish and Wildlife. Olympia, WA.

WDFW 2008. 2009-2015 Game Management Plan. Wildlife Program, Washington Department of Fish 

and Wildlife, Olympia, WA.

WDOE 2008. Strait of Juan de Fuca Geographic Response Plan. Washington Department of Ecology. 

Accessed from http://www.ecywa.gov/programs/spills.preparedness/GRP/strait_juan.htm 

WDOE 2009. San Juan Islands and North Puget Sound Geographic Response Plan. Washington 

Department of Ecology. Accessed from 

http://www.ecywa.gov/programs/spills.preparedness/GRP/san_juan.htm 

WWU 2009. The Salish Sea Map, Stefan Freelan, Western Washington University, 2009. 

 Accessed Feb. 8, 2010 from http://myweb.facstaff.wwu.edu/~stefan/SalishSea.htm
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-1

Chapter 2. Alternatives, Goals, Objectives, and Strategies

The National Environmental Policy Act (NEPA) requires Federal agencies to evaluate a full range of 

reasonable alternatives to a proposed action. This chapter describes the alternatives development process

and three possible alternatives for management of Protection Island and San Juan Islands Refuges. 

2.1 Alternatives Development

During development of the CCP alternatives presented in this chapter, the Service reviewed and 

considered a variety of local and regional physical and biological resource conditions, as well as social, 

economic, and organizational aspects important for managing the Refuges. This background information 

is described more fully in Chapters 3, 4, and 5. As is appropriate for a National Wildlife Refuge, natural 

resource considerations were fundamental in designing alternatives. House Report 105-106

accompanying the National Wildlife Refuge System Improvement Act of 1997 (Pubic Law 105-57) states 

“...the fundamental mission of our System is wildlife conservation: wildlife and wildlife conservation 

must come first.” 

Public involvement was and will continue to be an important part of the planning process. Local, State, 

and Federal agencies and elected officials were contacted by the Refuge planning team to ascertain 

priorities and problems as perceived by others. The team also contacted Refuge users, nonprofit groups, 

and community organizations to ensure that their comments and ideas were considered during the 

development of alternatives. The planning team then developed preliminary management concepts and 

strategies which they presented to the public in a planning update and at two public meetings in 

September 2008. More details regarding public involvement can be found in Appendix K.2. 

Based on all of the information gathered and feedback from others through the public involvement 

process, the Service developed three alternatives for the Comprehensive Conservation Plan for Protection 

Island and San Juan Islands NWRs. Alternative A: Current Management is how the Refuges are being 

managed now and can also be referred to as the “Status Quo” or “No Action” Alternative. Alternatives B 

and C are the “Action” alternatives that reflect changes from current management. Alternative B is the 

Service’s preferred alternative. 

2.2 Actions Considered but Not Developed 

Early in the alternatives development process, the planning team considered including the following 

actions in one or more CCP alternatives. These actions were ultimately eliminated from further 

consideration in this CCP for the reasons provided.

The Service initially considered eliminating camping on both Turn and Matia Islands because the

Service’s Appropriate Refuge Uses policy raised concerns regarding the appropriateness of camping on 

the San Juan Islands Refuge. After hearing the State’s concerns, gathering additional information, and 

conducting a review of the situation, the Service has a better appreciation for how camping on Refuge 

islands facilitates multi-day, non-motorized boat trips to observe wildlife and enjoy nature in the San Juan 

Islands (also see Appendix I – Findings of Appropriateness). Therefore the Service is no longer 

proposing to eliminate all camping as part of Alternatives B and C. Elimination of camping, on Turn 

Island only, is still under consideration in Alternative C and there will be other changes to camping under 

both Alternatives B and C. 

Elimination of Camping from Matia Island
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-2

A Variety of Nearshore Management Tools

The planning team reviewed and considered promoting a large variety of nearshore management tools for 

their potential to provide greater protection for Refuge wildlife and habitats. The tools that were 

considered but are not currently proposed in the CCP include Washington Department of Fish and 

Wildlife (WDFW) designations, including sea urchin exclusion zones and shellfish beach closures; San 

Juan County initiatives, including voluntary bottomfish recovery areas and boat-free zones for orcas; 

United States Coast Guard’s regulated navigation areas; and the International Maritime Organization’s 

Areas to be Avoided. Where they occur around Refuge islands, many of these tools can and do help to 

reduce human disturbance to Refuge wildlife. However, these particular tools were intended primarily for 

purposes other than Refuge wildlife and therefore the Service has decided not to propose initiating new 

designations of these types around Refuge islands. The Service will continue to work with the 

Washington Department of Natural Resources (WDNR) and their aquatic lands designations which are 

appropriate for protecting Refuge wildlife. There are currently two aquatic reserve proposals that include 

areas around Protection Island Refuge and portions of San Juan Islands Refuge. 

Opening More Refuge Islands to Public Access

During public scoping there were a few requests made for allowing public access to closed islands. The 

Service did consider these requests, but ultimately decided not to open any Refuge islands that are 

currently closed to the public. Refuge islands provide some of the last areas where seabirds and marine 

mammals can remain relatively undisturbed. Some of the best Refuge wildlife observation opportunities 

are available not on the islands themselves but by observing from a boat at a distance that does not disturb 

the wildlife. The Service does propose improving their visitor services program on the two Refuge 

islands that are currently open to the public. There will also be some opportunities for limited public

access to closed Refuge islands in association with volunteering for Refuge stewardship projects and 

conducting or assisting with approved research or monitoring studies. 

2.3 Similarities Among Alternatives

Alternatives contain some common features. These are presented below to reduce the length and 

redundancy of the individual alternative descriptions in other portions of this chapter.

2.3.1 Features Common to all Alternatives (A through C)

Under each alternative, actions will be implemented over a period of 15 years as funding becomes 

available. Priorities are identified in Appendix G although special funding initiatives, unforeseeable 

management issues, and other budget issues will likely require adjustments to the implementation 

schedule. The CCP will be reviewed at least every five years and updated as necessary. 

Implementation Subject to Funding Availability

In accordance with Department of the Interior and Service Policies (517 DM 1, 30 AM 12, and 7 RM 14,)

an integrated pest management (IPM) approach would be utilized to eradicate, control, or contain pest, 

nuisance, and invasive species on the Washington Maritime National Wildlife Refuge Complex

(Complex). IPM would involve determining the best control methods based upon effectiveness, cost, and 

minimal ecological disruption. These methods may include physical, cultural, biological, and chemical 

treatments which may be used alone or in combinations. If a pesticide would be needed on a Refuge, the 

most specific (selective) chemical available for the target species would be used unless considerations of 

Integrated Pest Management (IPM)
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-3

persistence or other environmental and/or biotic hazards would preclude it. Appendix E provides more 

details regarding the selective use of pesticides for pest management on the Refuges.

Minimizing Human-caused Wildlife Disturbance

Current staffing and funding levels limit staff presence in this very popular boating area. As a result, 

enforcement of regulations, including no trespassing on closed islands and no harassment of Refuge 

wildlife, is limited. Limited staff also means that there are few contacts with boaters and other visitors 

and limited capacity to educate the public about “why a closer look hurts.” Refuge staff and partners 

have identified the reduction of human disturbance to be one of the highest priorities for seabird and 

marine mammal management (USFWS 2005, WDFW 2005, NMFS 2009, Evans and Kennedy 2007, 

Mills et al 2005). Given the increasing levels of recreation in the area (see Chapter 5) and limited places 

of refuge for wildlife in the San Juan Archipelago, efforts must be made to protect wildlife from human 

disturbance on Refuge islands. Throughout the term of this plan, Refuge staff will continue to prohibit 

public access on Refuge lands except for designated areas of Matia and Turn Islands; work with 

volunteers and partners (U.S. Coast Guard, Washington State Parks and Recreation Commission, WDFW, 

Sheriff’s Office, Sound Watch, commercial cruise boats, etc.) to adequately patrol Refuge islands and to 

report incidences of non-compliance; and cooperate with DNR to maintain a 200-yard conservation lease 

and tideland withdrawal at Protection Island to reduce human disturbance. Also see Chapter 4 for more 

information regarding the threat of human-caused disturbance.

The Complex staff will actively participate in and contribute to planning and conservation efforts for 

ongoing and future land and energy development projects, monitoring and research associated with 

climate change, oil spill response, removal of derelict fishing gear, and other activities that may affect 

Refuge wildlife resources and habitats. Pre-spill planning and preparedness is required by the Federal Oil 

and Pollution Act of 1990. Refuge staff have been involved with Washington State Department of 

Ecology and others in preparing Area Geographic Response Plans, as part of the oil and hazardous 

substance spill prevention and response (

Participation in Regional Planning and Conservation Efforts

RCW Title 90 Chapter 90.56). Participation in the North Pacific 

Coast Landscape Conservation Cooperative will provide Refuge staff with a means to tie in with a larger 

scale assessment of the impacts of climate change (USFWS 2009a). Protecting focal resources by 

supporting partners’ efforts to reduce or eliminate fisheries bycatch and the removal of derelict fishing 

gear continues to be a priority for the Refuges. Complex staff would cultivate working relationships with 

pertinent local, county, State, and Federal agencies to stay abreast of current and potential developments; 

and would utilize outreach, education, and information as needed to raise awareness of Refuge resources 

and their dependence on a healthy local environment.

The Service will continue to uphold Federal laws protecting cultural resources, including the National 

Historic Preservation Act (NHPA), Archaeological Resources Protection Act (ARPA), and Native 

American Graves Protection and Repatriation Act (NAGPRA). These laws also mandate consultation 

with Native American tribes, the State Historic Preservation Office (SHPO), and other preservation 

partners. The NHPA mandates that all projects that use federal funding, permitting, or licensing be 

reviewed by a cultural resource professional to determine if there is the potential to affect cultural 

resources. An inventory will be conducted as necessary, and appropriate actions to mitigate effects will

be identified prior to implementation of the project. A project-specific determination will be conducted

for all undertakings as defined by NHPA, including habitat maintenance and restoration projects as well 

as new or expanded trails, roads, facilities, and public use areas. 

Cultural Resources Protection
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-4

The Service will continue to uphold laws protecting paleontological resources. These include the 

National Environmental Policy Act of 1969 (NEPA), the Paleontological Resources Preservation Act of 

2009 (PRPA), and various sections of Fish and Wildlife Service regulations. If found in direct 

association with archaeological resources they are also protected by the Archaeological Resources 

Protection Act (ARPA Section 3).

Paleontological Resources Protection

Maintaining of Existing Facilities

Periodic maintenance of Refuge buildings and facilities will be necessary regardless of the alternative 

selected. Periodic maintenance and upgrading of facilities is necessary for safety and accessibility and to 

support management and visitor needs, and is incorporated in the Service Asset Management System. 

The Complex will continue to coordinate with Washington State agencies regarding areas of mutual 

interest. This includes communications with WDFW regarding management of state wildlife resources,

and in particular, the state-owned Zella Schultz Seabird Sanctuary on Protection Island; WDNR regarding 

aquatic lands management; Washington State Parks and Recreation Commission regarding Visitor 

Services programs on Turn and Matia Islands. 

State Coordination

Communication with Native American Tribes who have an interest in the Refuges would continue under 

all alternatives. The Service seeks assistance from Tribes in Native American Graves Protection and 

Repatriation Act and National Historic Preservation Act and related issues. The Service is also interested 

in partnering with Tribes to provide cultural resources education and interpretation opportunities. 

Tribal Coordination

2.3.2 Features Common to Action Alternatives (B & C) 

Protection Island Site Plan Development and Implementation

Many Refuge buildings on Protection Island need to be removed, upgraded, or replaced. Expanding solar 

power capabilities and reducing the need to transport liquid fuels to the island is another high priority. 

Several roads associated with prior resort development on the island have been decommissioned while 

others are still being used for Refuge management purposes, however their locations may not be ideal. At 

the same time, some seabird areas have expanded or changed locations and are now in close proximity to 

buildings. Both Alternatives B and C would include the development and implementation of a site plan 

for all Refuge administration and research facilities, buildings, roads, and trails on Protection Island to 

improve Refuge management capability, facilitate research activities, and reduce disturbance to important 

wildlife habitat areas. 

Increase Land and Resource Protection 

Due to the high level of management concern, Refuge staff will work in cooperation with the State to 

increase protection of Refuge islands. Protections include coordinating with WDFW to include Zella M. 

Schultz Seabird Sanctuary in the Protection Island Refuge boundary; allowing the enforcement of Refuge 

laws and regulations throughout the island; cooperating with WDNR in establishing an aquatic reserve 

designation around Protection and Smith/Minor Islands; working with WDNR to acquire tideland and 

bedland leases/withdrawls around Refuge islands; and limiting or eliminating aquaculture activities near 

Refuge islands. 

The overall objective for fire management on the Complex is to promote a program that provides for 

firefighter and public safety, reduces the occurrence of human-caused fires, and ensures appropriate 

Fire Management 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-5

suppression response capability to meet expected wildland fire complexity. A Fire Management Plan was 

completed for the entire Complex, including Protection Island and San Juan Islands Refuges, in 2004. 

The use of prescribed fire as a management tool was not included in that plan. Since Alternatives B and 

C describe habitat restoration projects and IPM techniques that may include the use of prescibed fire, the 

Fire Management Plan would be updated to reflect this. 

Increase Staffing Levels 

Alternatives B and C identify many actions above and beyond those under current management 

(Alternative A). The ability to accomplish those actions depends in part on increased staffing, which is 

also proposed in Alternative B and C. While increased staffing is never guaranteed, it is anticipated that 

over the 15-year life of the CCP there would be some increase in staffing levels. For additional 

information regarding proposed staffing levels, see Appendix G. 

2.4 Summary of Alternatives

Alternative A: Current Management 

Under Alternative A, the Refuges would continue with current management which focuses on 

stewardship, including removing unnecessary roads and human structures; allowing natural processes to 

occur with minimal human intervention; monitoring wildlife species; and working with partners to reduce 

the risk of oil spills, clean up marine debris, and educate boaters to minimize human-caused wildlife 

disturbance. Recreational activities would continue as they have in the past and be facilitated through a 

State Parks partnership.

Alternative B: Preferred Alternative

This alternative would continue many of the activities in Alternative A, but would also include more 

active habitat management projects, such as removing deer from Protection Island to enhance seabird 

nesting habitat and forest habitat; restoration projects on the spits, grasslands, and forests to increase 

native plant diversity; and the facilitation of research studies that answer Refuge management questions. 

Public use changes include enforcing no-pets regulations on all San Juan Islands Refuge lands and closing 

some areas on Turn Island, including all of the rocky shoreline to the east and the south east “pocket” 

beach as well as some of the Island’s interior. Overnight camping on Turn and Matia Islands would be 

limited to visitors arriving by human-powered craft only, and a camping reservation system would be 

initiated. There would be more emphasis on enhancing the public’s understanding and appreciation of the 

Refuges’ natural, cultural, and wilderness resources through both on- and off-Refuge interpretation and 

education programs. There would be fewer large signs but more medium sized signs installed on San 

Juan Islands Refuge units to discourage close approach or trespassing on closed islands. There would 

also be more emphasis on working with existing partners and developing new partnerships to accomplish 

objectives. 

Alternative C

This Alternative is very similar to Alternative B, although there are differences. In Alternative C there 

would be fewer acres of native habitat restoration, as well as fewer research studies and surveys compared 

to Alternative B; camping would continue with fewer campsites on Matia Island, however, Turn Island 

would be limited to day-use only. Compared to Alternative B, fewer and mostly smaller signs would be 

used in Alternative C to identify closed Refuge islands and reduce human-caused wildlife disturbance. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-6

Table 2.1 Summary of CCP Alternatives (PI = Protection Island Refuge and SJ = San Juan Islands Refuge) 

Key Management Topics Alternative A (Current Management) Alternative B (CCP Team Preferred) Alternative C

HABITAT MANAGEMENT 

Multiple Habitats - Work with partners to minimize human 

disturbance to wildlife and habitats.

- WDNR tideland lease and bedland 

withdrawal around PI. 

- Participate in oil spill prevention and 

preparedness planning and activities near PI.

- Opportunistic shoreline clean-up activities 

with volunteers and partners.

- Survey and use integrated pest management 

strategies on invasive species, except no 

prescribed burning. 

Same as Alt A., plus:

- Increase efforts to work with partners to minimize human disturbance to wildlife and 

habitats.

- Work with WDNR to renew and enhance the Service’s ability to manage the tidelands 

and protect bedlands up to 200 yards waterward from the low water line around PI and 

SJ. 

- Participate in oil spill prevention and preparedness planning and activities in PI and SJ 

vicinity. 

- Regularly work with partners and volunteers to conduct yearly shoreline clean-up 

activities on all Refuge islands. Support off-Refuge efforts to remove derelict fishing 

gear from the marine environment surrounding the Refuges.

- Include prescribed burning as a potential restoration and integrated pest management 

tool. 

- Work with WDFW to reduce deer impacts by removing deer from PI.

- Monitor for and remove non-native rats, rabbits, and red fox.

- Conduct a survey of mammalian predators, assess impacts, and develop a management 

plan if necessary.

Shoreline - Occasional mowing of spits on PI. 

- Periodic shoreline nourishment with gravel 

on PI. 

- Restore a total of approximately 41 acres of 

spit habitat on PI, Smith, and Minor Islands to 

native-species-dominated strand community and 

manage spits for more open vegetation. 

- Continue shoreline nourishment with gravel 

stockpiles on PI.

- Remove marine debris and contaminated 

materials.

- Conduct a survey of herbivores and predators 

of management concern, assess impacts, and 

develop a management plan if necessary.

Same as Alt. B, except:

Only up to 15 acres of spit 

restoration.

Sandy Bluffs No specific habitat enhancement actions. - Control invasive plants and increase native plants.

- At end of lease term, remove structures and improve habitat conditions in the 

expanding area of the auklet colony. 

- Enhance vegetation characteristics on up to 20 acres of bluffs on PI. 

Savanna Grasslands and 

Herbaceous Balds

Removal of unnecessary roads and structures 

on PI.

- Restore up to 200 acres of savanna grassland

on PI and up to 20 acres on Smith and Turn 

Islands to increase native species composition to 

Same as Alt. B, except:

- Manage/restore up to 40 acres of 

savanna grassland on PI and up to 10 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-7

Key Management Topics Alternative A (Current Management) Alternative B (CCP Team Preferred) Alternative C

benefit a variety of wildlife. 

- Maintain herbaceous bald patches and where 

appropriate, associated rare plants on 28 islands 

within SJ. 

acres on Smith and Turn Islands.

- Maintain herbaceous bald patches 

on 14-28 islands within SJ. 

Forests and Woodlands Removal of unnecessary roads on PI. - Restore connectivity, crown closure, regeneration, and associated understory of 80 

acres of forest and woodland on PI. 

- Increase protection and maintenance of mature and old-growth forests and associated 

understory on 6 islands within SJ. 

Wetlands No specific habitat enhancement actions. - Determine if it is feasible to restore part of the historic wetlands on PI.

- Conduct hydrologic study, and if needed, restore natural hydrology to Smith and Matia 

Islands wetlands.

- Monitor and control invasive plants and animals. 

RESEARCH AND MONITORING

Research Program 

Management 

- Good collaboration between the Service and 

long-term PI researchers.

- Old buildings used by researchers in 2 

separate locations on PI. 

- Increase collaboration between the Service and the larger research community. 

- Place more emphasis on studies that answer Refuge management questions and species 

information gaps. 

- Replace old buildings with a single bunkhouse relocated on PI to serve researchers and 

short-term volunteers.

-Develop Refuge databases, GIS layers, and integrate data into regional databases. 

Research - Glaucous-winged gull behavior studies.

- Studies on a variety of other topics.

Same as Alt. A, plus more emphasis on the 

following topics:

- Conduct research to determine best 

habitat restoration methods.

- Study erosion rates of bluffs and 

deposition on spits. 

- Research to evaluate wildlife response to 

habitat restoration.

- Demography studies of seabirds and 

marine mammals.

- Hydrology studies of wetlands.

Same as Alt. B, minus:

- Demography study of marine mammals. 

- Study of bluffs erosion and deposition

Surveys - Long-term monitoring of rhinoceros auklets, 

pigeon guillemots, glaucous-winged gulls, and 

marine mammals. 

- Summer wildlife surveys.

Same as Alt. A, plus:

- Refuge and ecosystem-wide monitoring 

of nesting seabirds and black 

oystercatchers.

- Bald eagle surveys.

- Periodic surveys for rare butterflies and 

Same as Alt. B, minus:

- Winter wildlife survey.

- Bald eagle survey.

- Breeding bird survey on PI.
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-8

Key Management Topics Alternative A (Current Management) Alternative B (CCP Team Preferred) Alternative C

rare plants.

-Winter wildlife surveys.

- Breeding bird survey on PI.

Scientific Assessments - Some assessments conducted and species 

lists developed. 

- Systematically complete plant surveys on 

SJ. 

- Determine and map Refuge vegetation 

types to the association level.

- Conduct assessment of reptiles and 

amphibians.

- Conduct assessment of invasive wetland 

species as well as herbivores and predators 

of management concern.

Same as Alt. B, minus:

- Reptile and amphibian assessment.

Cultural and Paleontological 

Resources 

- Cultural resource surveys of mostly projectspecific locations. 

- No paleontological studies conducted.

Same as Alt. A, plus complete prioritized systematic cultural resource surveys of all 

Refuge lands and resurvey known sites approximately every 5 years. 

- Systematic paleontological survey on PI.

- Develop GIS layer for paleontological resources.

Effectiveness Monitoring -Limited monitoring - As strategies are implemented, monitor progress toward meeting CCP objectives under 

Goals 1-8

ON-REFUGE VISITOR SERVICES AND FACILITIES

Protection Island No public access. 

SJ Refuge entry areas and 

open and closed areas.

Turn Island

- All beaches are Refuge entry and boat 

landing areas. 

- All island areas except steep slopes are 

open. 

Turn Island

- West and southwest beaches are the only authorized entry and boat landing areas. 

- Southeast beach is closed to landing and public use. 

- Designated public use area and loop trail are open to visitors; the rest of the island is 

closed. 

Matia Island 

- Rolfe Cove dock and beach are the only authorized entrances to the island.

- Refuge access and camping prohibited at or from the 4 other pocket beaches. 

- 2-acre public use area adjacent to Rolfe Cove is open to day-use and camping. 

- Wilderness loop trail is open to visitors; the rest of the island (wilderness area and island perimeter) is closed.

- All other Refuge islands and rocks are closed.

SJ Public Use Times and 

Other Restrictions 

- Turn and Matia Islands open year-round, 24 

hours per day. 

- Turn - Pets allowed on leash.

- Matia - Pets allowed on leash within 2-acre 

picnic/campground area only. 

- Turn and Matia public use areas open to dayuse. 

- Outside of day-use hours, only authorized 

campers arriving via human-powered boats are 

allowed on Turn and Matia Islands.

Same as Alt. B, except Turn Island is 

only open to day-use; no camping 

allowed. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-9

Key Management Topics Alternative A (Current Management) Alternative B (CCP Team Preferred) Alternative C

- No pets allowed.

SJ - WA State Parks 

Seasonal Dock and Mooring 

Buoys 

Dock on Matia Island at Rolfe Cove from mid-April to mid/late-October.

Turn – 3 buoys off N. beach – available year round.

Matia – 2 buoys in Rolfe Cove - available year round.

SJ - Camping Camping allowed only in designated 

campsites: Turn Is - 13 campsites. 

Matia Is. - 6 campsites.

Visitors arriving by motorized and 

nonmotorized boats are permitted to camp on 

the Refuge. 

Camping allowed only in designated campsites: 

Turn Is. - 8 campsites. 

Matia Is. - 6 campsites.

Only visitors arriving by human-powered boats 

are permitted to camp on the Refuge. 

New camping reservation system initiated.

Same as Alt. B, except

Turn Is - no camping. 

Matia Is. - 4 campsites.

SJ - Campfires Liquid fuel or gel camp stoves allowed. Some 

unauthorized charcoal and wood campfires 

occurring. 

Matia and Turn – Better enforcement of no fires. Liquid fuel or gel camp stoves 

allowed.

SJ - Trails Turn - 0.9 mile loop trail around perimeter.

Matia - 1.2 mile loop trail.

Re-evaluate trail locations for impacts to cultural resources and small meadow. Reroute 

if necessary but continue to provide a loop trail on both Turn and Matia Islands. 

Wildlife Observation, 

Photography, and 

Interpretation

Unstructured opportunities. No interpretive 

signs. Infrequent interpretive walks 

conducted. 

- Design and install informational and interpretive signs at Turn and Matia Islands. 

- Interpretive trail at Turn Island. 

- Local experts and/or trained volunteers provide short “ranger” programs during some

summer weekends. 

Environmental Education -

Scientific Studies

Some students given opportunities to do 

scientific studies on PI and SJ. 

At least 3 college students/5 years given opportunities to do scientific studies on PI and 

SJ.

Environmental Education -

Stewardship Projects

PI - 1 per year.

SJ – less than 1 per year.

PI - 1+ projects per year

SJ - 1+ projects per year

SJ - Commercial Outfitters Allowed for camping and day-use on Turn and Matia Islands. Special use permit required Allowed for camping and day-use on 

Matia Is. and day-use only on Turn

Is. Special use permit required. 

Visitor Services Facilities 

and Maintenance

WA State Parks provides public use facilities (toilets, picnic tables, campsite markers, etc.) and 

maintenance on Turn and Matia Islands. 

Same as Alts. A and B, except:

The Service/other partners would 

provide facilities and maintenance on 

Turn Is. after camping is phased out. 

SJ - Law enforcement for 

public safety/resource 

protection on Turn and 

Matia. 

WA State Parks enforces State Parks 

regulations on Turn Island and on 2 acres of 

Matia Island. The Service enforces 

regulations on all Refuge lands. 

WA State Parks enforces State Parks regulations 

and new Service regulations on all of Turn and 

Matia Islands. The Service enforces regulations 

on all Refuge lands.

Same as Alt. B, except phase out WA 

State Parks law enforcement on Turn 

Is. as camping is phased out. 

OFF-REFUGE VISITOR SERVICES

Wildlife Observation and Some staff coordination with Port Townsend Same as Alt. A, plus additional Refuge staff time, volunteers, and partners facilitate and 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-10

Key Management Topics Alternative A (Current Management) Alternative B (CCP Team Preferred) Alternative C

Photography Marine Science Center (PI) and SoundWatch 

(SJ) to facilitate wildlife observation and 

minimize human-caused wildlife disturbance.

educate many individuals, organizations, and ecotourism businesses to enhance wildlife 

observation and appreciation of Refuge wildlife and minimize human-caused wildlife 

disturbance. 

Natural and Cultural 

Resource Interpretation 

PI - 1 panel at John Wayne Marina and no 

other interpretive activities.

SJ - no interpretive panels or activities. 

Same as Alt. A, plus:

PI – 1 more panel (Port Townsend area) 

and 2 additional interpretive venues.

SJ – Panels at 5 marina locations and 2 

additional interpretive venues.

Same as Alt. B, except:

SJ – Panels at 5 marina locations only. 

Environmental Education 

Materials

SJ - Refuge poster at marinas. Same as Alt. A, plus educational materials prepared for use by local teachers. Provide 

information at local community events, tourist agencies, ferries, etc. 

Boater Education to Reduce 

Human-Caused Wildlife 

Disturbance

PI - Direct boater education. 

SJ - Poster at marinas and some coordination 

with partners to provide boater education 

regarding human-caused disturbance to 

wildlife.

PI - Continue direct boater education. 

PI & SJ - Increase educational materials, working with partners, and direct contacts with 

boaters to improve education regarding human-caused disturbance to wildlife. 

SAN JUAN ISLANDS WILDERNESS

Many of the above actions apply to wilderness as well as non-wilderness lands. The following items are more specific to wilderness concerns. 

Refuge Signs to Reduce 

Human-Caused Wildlife 

Disturbance

Standard text and 11” x 14” size Refuge 

boundary/closure signs used on most islands. 

Very large (4’x 6’) “stay away 200 yds” signs 

on approximately 15 islands.

Improve text and increase size of boundary/ 

closure signs to medium (15’’ x 20’’) on most 

islands and a larger version (22” x 28”) on some 

islands. Use very large “stay away 200 yds” 

signs on up to 10 of the most sensitive islands.

Improve text of boundary/closure 

signs, but use standard 11” x 14” size 

only. Use very large “stay away 200 

yds” signs on up to 10 of the most 

sensitive islands.

Sights and Sounds - Use only tools authorized for wilderness areas (e.g., no chainsaws) to maintain a narrow and natural appearing trail on Matia Island.

- Conduct garbage and marine debris cleanups. 

- Promote 2000-foot aircraft ceiling over wilderness islands.

Solitude and Numbers of 

Visitors

- Boat landing limited to Rolfe Cove only, but 

not well enforced.

- No number limits on commercial day-use 

groups.

- Enhance enforcement of limited landing and camping areas. 

- Limit the size of commercial day-use groups to not more than 20 people. 

Wilderness Education Limited wilderness education. - Integrate wilderness themes and messages in new or updated Refuge information 

products, interpretive panels, volunteer training, and outreach programs whenever 

appropriate. 
Researchers' House

Marina

Maintenance Shop

and Garage

Field/Research Office

Unoccupied Residences

Extended User's Residence

Refuge Caretaker's Cabin

Pumphouse

Tower Water Storage Tank

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 7/30/2003 WDOT True Color Aerial Photography

Figure 2.1 Protection Island NWR - Alternative A (Current Management)

Legen

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Chapter 2. Refu

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Miles

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0 0.4
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-12

To preserve the quality of our map, this side was left blank intentionally.
Large Unused USCG Cistern

Unused USCG Concrete Watch Shack

Unused USCG Wooden Residential Building

NOAA Tower

Unused USCG Concrete Block Light and Foghorn

Metal SST RADAR Tower

USCG Light Tower

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2006 USDA NAIP True Color Aerial Photography

Figure 2.2 San Juan Islands NWR, Smith and Minor Islands - Alternative A (Current Management)

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Smith an

use.

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Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-14

To preserve the quality of our map, this side was left blank intentionally.
Wilderness Loop Trail

1.2 Mile Loop Trail

FWS Partnership with WSPRC for

Management of Public Uses and Facilities

WSPRC Seasonal Dock

Available mid-April

to mid/late-October

6 Fee-Use Campsites

Visitors arriving by motorized

and human-powered boats are

permitted to camp.

Liquid Fuel Camp Stoves Allowed

!]

!]

!]

!] L L

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2004 WDNR True Color Aerial Photography

Figure 2.3 San Juan Islands NWR, Matia Island - Alternative A (Current Management)

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Area Enlarged

Chapter 2. Refu

ge Management Direction 2-15

Year-round 24 hours/day public access.

WSPRC enforces State Parks regulations on 2

acres of Matia Island. FWS enforces regulations

on all refuge lands.

Kilometers

Miles

0 0.2

0 0.2

UTM ZONE 10N

NAD 83
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-16

To preserve the quality of our map, this side was left blank intentionally.
!9

L

L

L

13 Fee-Use Campsites

Visitors arriving by motorized

and human-powered boats

are permitted to camp.

FWS Partnership with WSPRC for

Management of Public Uses and Facilities

Charcoal Fires or Liquid Fuel Campstoves Allowed

0.9 Mile Loop Trail

!]

!9 !9 !9 !g

!9

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!9

!9

!9

!9

!9

!9

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Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2004 WDNR True Color Aerial Photography

Figure 2.4 San Juan Islands NWR, Turn Island - Alternative A (Current Management)

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lands.

Chapter 2. Refu

ge Management Direction 2-17

Miles

Kilometers

0 0.1

0 0.1 UTM ZONE 10N

NAD 83
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-18

To preserve the quality of our map, this side was left blank intentionally.
Relocate and Replace

Researchers' House

with Bunkhouse

Maintain Marina and

Replace Creosote Pilings with

Non-Toxic Pilings

Maintain

Maintenance Shop

and Garage

Replace and Possibly Relocate

Field/Research Office

Remove Unoccupied Residences

As Soon As Possible

Remove Extended User's Residence

at the End of Extended User's Term

Relocate and Replace

Refuge Caretaker's Cabin

Coinciding with End of

Extended User's Term

Maintain Pumphouse

Maintain and Upgrade

Water Storage and Delivery Infrastructure

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 7/30/2003 WDOT True Color Aerial Photography

Figure 2.5 Protection Island NWR - Alternatives B and C

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access 

Chapter 2. Refu

ge Management Direction 2-19

UTM ZONE 10N

NAD 83

Kilometers

Miles

0 0.4

0 0.4
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-20

To preserve the quality of our map, this side was left blank intentionally.
Leave Large Unused USCG Cistern

As Is but Seal Holes

NOAA Tower

Metal SST RADAR Tower

USCG Light Tower

Unused USCG Concrete Block Light and Foghorn

Remove Unused USCG Wooden Residential Building and

Associated Contaminants to the Maximum Extent Possible

Remove Unused USCG Concrete Watch Shack and

Associated Contaminants to the Maximum Extent Possible

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2006 USDA NAIP True Color Aerial Photography

Figure 2.6 San Juan Islands NWR, Smith and Minor Islands - Alternatives B and C

Vic

Sidn

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Chapter 2. Refu

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Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-22

To preserve the quality of our map, this side was left blank intentionally.
Wilderness Loop Trail

1.2 Mile Loop Trail

Reevaluate trail locations for impacts.

Reroute if necessary.

FWS Partnership with WSPRC for

Management of Public Uses and Facilities

WSPRC Seasonal Dock

Available mid-April

to mid/late-October

6 (Alt. B) or 4 (Alt. C) Fee-Use Campsites

Only visitors arriving by human-powered

boats are permitted to camp.

New camping reservation

system initiated.

Design and install informational

and interpretive signs.

Liquid Fuel Camp Stoves Allowed

!]

!]

!]

!] L L

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2004 WDNR True Color Aerial Photography

Figure 2.7 San Juan Islands NWR, Matia Island - Alternatives B and C

Vic

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!x D

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Public use areas open to day-use. Outside of

day-use hours, only authorized campers arriving

via human-powered boats are allowed.

WSPRC enforces State Parks regulations and

new FWS regulations on all of Matia Island.

FWS enforces regulations on all refuge lands. 

Alt. C: Remove 2

campsites

Alt. C: Remove 2

campsites

!

!

Rolfe Cove

!g

!5

!9

!9

!9 !9!9

!9 !_ !x !]

Area Enlarged

Chapter 2. Refu

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Kilometers

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0 0.2

0 0.2

UTM ZONE 10N

NAD 83
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-24

To preserve the quality of our map, this side was left blank intentionally.
L

L

L

8 Fee-Use Campsites

Only visitors arriving by human-powered

boats are permitted to camp.

New camping reservation

system initiated.

FWS Partnership with WSPRC for

Management of Public Uses and Facilities

Liquid Fuel Campstoves Only

0.9 Mile Interpretive Loop Trail

Reevaluate trail locations for impacts.

Reroute if necessary.

Design and install informational

and interpretive signs.

!]

!9 !9 !9 !g

!9

!9

!_

!9

!9

!9 !_

!5

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2004 WDNR True Color Aerial Photography

Figure 2.8 San Juan Islands NWR, Turn Island - Alternative B

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Kilometers

0 0.1

0 0.1 UTM ZONE 10N

NAD 83
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-26

To preserve the quality of our map, this side was left blank intentionally.
L

L

L

Only open to day-use.

No camping allowed.

FWS and other partners

Management of Public Uses and Facilities

0.9 Mile Interpretive Loop Trail

Reevaluate trail locations for impacts.

Reroute if necessary.

Design and install informational

and interpretive signs.

Liquid Fuel Campstoves Only

!]!g

!_

!_

!5

Data Sources: Refuge Boundaries from USFWS/R1; Imagery from 2004 WDNR True Color Aerial Photography

Figure 2.9 San Juan Islands NWR, Turn Island - Alternative C

Vic

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Chapter 2. Refu

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Miles

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NAD 83
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-28

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Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-29

2.5 Goals, Objectives, and Strategies

Goals and objectives are the unifying elements of successful refuge management. They focus and 

describe management priorities and actions that resolve issues and help bring a refuge closer to its 

vision. A vision broadly reflects the refuge purposes, the Refuge System mission and goals, other 

statutory requirements, and larger-scale plans as appropriate. Public use and wildlife/habitat 

management goals then define general targets in support of the vision, followed by objectives that 

direct effort into incremental and measurable steps toward achieving those goals. Finally, strategies

identify specific tools and actions to accomplish objectives.

The goals for Protection Island and San Juan Islands Refuges over the next 15 years under the CCP 

are presented on the following pages. The goal order does not imply any priority. Each goal is 

followed by the objectives that pertain to that goal. Some objectives pertain to multiple goals and 

have simply been placed in the most appropriate spot. Similarly, some strategies pertain to multiple 

objectives. The timeframe for accomplishing CCP objectives is the 15-year life of the CCP, unless 

otherwise specified in the objective. 

In the development of this CCP, the Service has prepared an environmental assessment that evaluates 

three management alternatives. One set of goals applies to all alternatives. The objectives and 

strategies, however, vary by alternative. 

Readers, please note the following:

The objective statement as written, including bulleted items, specifically applies to the Preferred 

Alternative, Alternative B. In some objectives, bolded text is used to show how the preferred 

alternative varies from the other alternatives. How it varies is displayed in the short row that comes 

after each objective statement where text substituting for the bolded text is provided for the other 

alternatives. 

Below each objective statement are the strategies that could be employed in order to accomplish the 

objective. The  marks alongside each strategy show which alternatives include that strategy. If a 

column for a particular alternative does not include a  mark for a listed strategy, it means that 

strategy would not be used in that alternative.

The “Rationale” section provides additional information and the reasoning behind the objectives and 

strategies. 

GOAL 1: Protect, maintain, and restore high quality, natural shoreline and cliff habitats for 

optimum productivity and abundance of seabirds, marine mammals, waterfowl, and 

shorebirds.

Objective 1.1 Restore Spit Habitat

Restore and manage up to 41 acres on Violet Spit, Protection Island, and spits associated with 

Smith/Minor Islands for nesting glaucous-winged gulls, breeding and molting elephant seals, and other 

native wildlife and plant species with the following attributes:

• Sparse (<30% cover), medium to low (max. 3-4 feet in height) grasses interspersed with vegetation 

composed of species associated with the North Pacific Maritime Coastal Sand Dune and Strand 

ecological system (e.g., gum weed, dune grass, sand verbena, plantain, and yarrow).

• Natural screens (e.g., driftwood or variation in topography) for concealment of nearest nests.

• <25% invasive species (e.g., Scotch broom or Spartina grass) on spit habitat.

• Eliminate disturbance and impacts to seabird nesting habitats from deer. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-30

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bold 

type above with the text in this row.

PI and 

Smith/Minor 

0 acres Up to 41 

acres

5-15 acres

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Remove, control, and prevent establishment 

of invasive non-native plant species and treat 

infestations with IPM techniques using 

cultural, mechanical, physical, biological, or 

chemical means.

PI and 

Smith/Minor

---  

b. Restore the strand vegetation community 

using prescribed burns and mechanical 

techniques (e.g., mowing, grading), planting, 

and maintenance. Update the fire 

management plan to include prescribed fires 

and wildfire suppression tactics.

PI ---  

c. Monitor response of glaucous-winged gull 

fledgling rates and predation after restoration.

PI ---  

d. Work with WDFW to remove deer from PI. 

Appropriate methods to remove deer will be 

determined in a step-down planning process. 

PI ---  

e. Continue to survey for presence of nonnative rats, rabbits, red foxes, feral cats and 

dogs, and use appropriate tools to maintain 

zero population levels.

PI and 

Smith/Minor

PI only  

f. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and 

river otter), determine impacts, and if 

necessary develop management actions under 

a separate step-down management plan. 

PI and 

Smith/Minor

PI only  

g. Monitor, and when found, remove marine 

debris and contaminated material.

PI and 

Smith/Minor

PI only  

Rationale: This objective will preserve this rare habitat type in the Salish Sea and restore the plant 

communities found there. These spits are formed when marine currents sweep large volumes of sand 

and gravel from the sandy cliffs and bluffs of Protection and Smith Islands and deposit them onto the 

shoreline. Armoring of the shorelines with jetties, bulkheads, and seawalls has often resulted in the 

alteration or disappearance of these unique habitats in the Salish Sea. The distal end of Violet Spit on 

Protection Island is densely choked with non-native beach grass that fills deep ruts left from machinery. 

Closer to the marina, a remnant population of native plants can be found that are associated with spit 

habitats (called strand communities) such as gum weed, yarrow, beach morning glory, sea plantain, 

thrift, and yellow sand verbena. Strand communities typically grow in sand, have low density of 

vegetation, and provide open spaces between plants. 

This objective will also reduce gull chick mortality through habitat management. An invasion by 

nonnative plant species (i.e., beach grass) has rendered sections of the spit that once supported the 

highest abundance of gull nests as unsuitable. Researchers have noted that gull nests located in or near 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-31

the taller, dense vegetation are more susceptible to bald eagle predation (80%), while those located in 

more open strand communities appear to be more successful (15%, J Galusha, pers. comm.). This is 

due, in part, because the open space allows better access to eagles on the ground by mobbing gulls. In 

addition, research in other colonies has shown that a high degree of heterogeneity (i.e., debris) around 

nests provides concealment from predation and natural screens from nearby nests (Good 2002). These 

components are particularly important in areas with high disturbance and predation pressure, as is the 

case on Violet Spit, where disturbance or predation from bald eagles, other gulls, and deer can limit 

reproductive success (Hayward and Henson 2008, Galusha et al. 2005). Restoration should be 

conducted in a manner that maintains the cohesion of the colony because the colony is less likely to 

shift to new, disjointed areas (J. Galousha, pers. comm.). In addition, this objective will also benefit 

elephant seals which have recently pupped on Protection and Smith/Minor Islands. Replacing the thick 

European beach grass with more open vegetation will provide more habitat for elephant seals, which 

prefer open sandy beaches, dunes, and spits for breeding and molting. 

Approximately 93% of bird species or subspecies that have become extinct since the 1800s were found 

on island habitats and 42% of those occurred due to predation by introduced mammals (Courchamp et 

al. 2003). Rats are present on approximately 80% of the world’s islands and are responsible for at least 

50% of global extinctions and countless local extinctions (Dolan and Heneman, 2007). There is no 

indication that rats are present on Refuge islands, however they could potentially colonize an island via 

a ship wreck or by accessing the island via authorized vessels. Given that they reproduce quickly and 

can have a devastating effect on island breeding seabirds, detection and control must be rapid. Rabbits 

are ubiquitous on San Juan and Lopez Islands and pellets have been observed on Nob Island within the 

San Juan Islands NWR (Murphy pers. comm.), however, they have not been found on Protection 

Island. Rabbits can denude small islands of vegetation leading to erosion and loss of nesting habitat, 

compete for nesting burrows and eject eggs from occupied burrows, and serve as a year-round food 

resource for predators (USFWS 2005, McChesney & Tershy 1998, Hodum & Wainstein 2002, Donlan 

& Heneman 2007). Rabbits also reproduce rapidly and control measures must be rapid to be effective. 

Other non-native mammalian predators include red fox, feral cats, and domestic cats and dogs; native 

mammalian predators of concern are coyote, raccoon, mink, and river otter. 

Deer populations can thrive with an increase in abundance of forage as will be the case with intensive 

revegetation efforts planned for the island. In New Zealand, researchers found that changes caused by 

heavy fallow deer browsing may have permanently altered the ecosystem and suggested that 

maintaining very few or zero deer was the only successful method to assist regeneration of native 

species (Husheer and Frampton 2005). In fact, Simberloff (2008) noted that deer can reduce biological 

diversity in an area while at just 25% of their carrying capacity depending on the habitat type and 

environmental conditions. At the same time, deer can foster the invasion of weedy exotics by ingestion 

and dispersing seed of non-native plants (Donlan et al. 2002, Waller 2008). Given the abundance of 

deer in Northwestern Washington, removing deer from Protection Island in order to protect this unique 

seabird habitat would have little impact on the deer population of the area. Also see rationale for 

objective 2.1 for impacts of deer to seabirds. 

Objective 1.2 Protect and Maintain Sandy/Gravel Shoreline

Increase protection and maintenance of sandy/gravel shoreline on Protection and Smith/Minor Islands 

for the benefit of harbor and elephant seals, pigeon guillemots, black oystercatchers, and Harlequin 

Ducks with the following attributes:

• Continued long shore sandy/gravelly movement and deposition.

• Presence of large continuous expanses of driftwood piles with cavities suitable for pigeon 

guillemot nesting and camouflage of guillemot and oystercatcher chicks. 

• No creosote pilings in marina on Protection Island.

• No marine debris on PI or Smith/Minor shorelines. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-32

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

Objective as written above applies to alternatives 

().

PI and 

Smith/Minor

---  

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Continue nourishing shoreline to the west of 

the marina by using remaining gravel stockpiles 

left from marina dredging.

PI   

b. Facilitate the removal and replacement of the 

creosote pilings used in the marina at Protection 

Island.

PI   

c. Monitor, and when found, remove marine 

debris and contaminated material.

PI and 

Smith/Minor

PI only  

d. Continue to prohibit collection of driftwood 

from shorelines and within marina of Protection 

Island. 

PI ---  

e. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and 

use appropriate tools to maintain zero population 

levels.

PI and 

Smith/Minor

PI only  

f. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

otter), determine impacts, and if necessary 

develop management actions under a separate 

step-down management plan.

PI and 

Smith/Minor

PI only  

g. Monitor, and when found, remove marine 

debris and contaminated material.

PI and 

Smith/Minor

---  

Rationale: Wildlife use this type of shoreline to varying degrees. Pigeon guillemots use the shoreline 

for nesting under driftwood and to roost; black oystercatchers nest and forage here; harbor and elephant 

seals haulout and pup in this habitat. Forage fish, such as sand lance and surf smelt, spawn in the 

gravel within the shallow water adjacent to the shoreline. They in turn provide a rich food source, 

close to the colony, for breeding seabirds. Black brant collect small pieces of gravel that they require 

for grit to digest their food. 

One third of the Salish Sea shoreline has been modified by human use, interrupting the processes that 

move sediment and nourish beaches and vegetation along the shorelines (WDNR 2001, Evens and 

Kennedy 2007). On Protection Island, the marina entrance breakwater impedes the flow of sediment to 

the adjacent shoreline to the west. In 2002, 4000 yd3 of gravel stockpiled from dredging the marina 

were placed on the shoreline to the west to mimic the natural process. Removing the remainder of the 

gravel will both restore the upland spit where it now acts as an impediment to vegetation, and nourish 

the shoreline that is impacted by the marina’s breakwater.

Creosote is of concern because, according to the EPA, it is toxic to fish, shellfish, and aquatic 

invertebrates, all important forage for seabirds, oystercatchers, and marine mammals. There are 

currently creosote coated logs forming old pilings in the marina of Protection Island and creosote 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-33

impregnated logs are relatively common on the shorelines of all islands. More than 100 tons were 

removed from nearby Dungeness Spit in 2006. Marine debris (e.g., Styrofoam, nets, and plastics) 

poses a more direct threat to seabirds and marine mammals as it can entangle seals or be fed to seabird 

chicks causing mortality. Marine debris is removed from the shoreline of Protection Island by staff and 

volunteers annually, but because they are more difficult to access, regular clean-up of debris is limited 

in the San Juan Islands NWR (including Smith/Minor). 

Extensive logging throughout the past century has reduced the supply of large trees with intact roots 

that support the upper shoreline, provide nesting sites for pigeon guillemots and cover for black 

oystercatcher chicks from predators. Harbor development, firewood collection, and human-caused 

beach fires have reduced driftwood on the shorelines of Protection Island. Maintaining the current 

amount of driftwood on the island’s rocky shoreline would provide concealment from predators and 

potentially increase productivity of guillemots and oystercatchers on Protection Island. 

For more information about rats, rabbits, and mammalian predators, see rationale for objective 1.1. 

Objective 1.3 Protect and Maintain Rocky Shoreline and Cliff Habitats

Increase protection and maintenance of rocky shoreline and cliff habitats in the San Juan Islands NWR 

for the benefit of marine mammals, cormorants, and black oystercatchers by managing for the 

following attributes: 

• No marine debris on shorelines on islands of San Juan Island.

• Viable populations of brittle prickly pear cactus are established on 5 Refuge islands.

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter)

• Human disturbance on Matia and Turn Islands is minimized during oystercatcher nesting and brood 

rearing periods (April – Sept).

• Human disturbance is minimized near rocky shoreline and cliff habitats used by breeding 

cormorants, oystercatchers, and marine mammals year-round on all Refuge islands.

Alternatives Refuge/Unit Alt A Alt B Alt C

Objective applies to alternative as written above 

().

SJI  

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Coordinate with DNR to establish appropriate 

shoreline buffers (conservation leases and/or 

withdrawals) to minimize disturbance from boat 

landings and tideland development.

SJI ---  

b. Grow and outplant populations of brittle 

prickly-pear cactus on 5 Refuge islands and 

monitor to ensure success of restoration.

SJI ---  

c. Monitor, and when found, remove marine 

debris and contaminated material.

SJI ---  

d. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and 

use appropriate tools to maintain zero population 

levels.

SJI ---  

e. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

SJI ---  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-34

otter), determine impacts, and if necessary 

develop management actions under a separate 

step-down management plan. 

f. Provide shoreline access 

Matia: Allow shoreline access at Rolfe Cove and 

maintain closure on remainder of shoreline. 

Turn: Allow shoreline access on West and 

Southwest beaches; close Southeast beach and 

remainder of shoreline to protect wildlife and 

habitat.

Matia   

Turn ---  

Rationale: With a few exceptions, most marine birds use the rocky shorelines for foraging and 

roosting and the marine mammals use them to pup and molt. Cormorants primarily nest on cliffs, 

rocky islands, or human-made structures such as towers or navigational aids. They are very sensitive to 

human disturbance during the nesting season and will abandon eggs or young if disturbance is too 

great. Marine mammal pups can be separated from their mothers or crushed during a stampede to the 

water if boaters approach too closely. Brittle prickly-pear cactus was once more common on Refuge 

islands. Given minimal amounts of disturbance due to closed access, Refuge islands would serve as an 

ideal site for reestablishment of this rare plant. Reducing disturbance from humans (shoreline closure 

and creation of buffer zones) in the San Juan Archipelago has also been identified by San Juan County 

as a strategy to conserve two of their conservation target species: black oystercatchers and pelagic 

cormorants (Evans and Kennedy 2007).

The black oystercatcher is considered an obligate species of the rocky shoreline and a strong indicator 

of the ecological integrity of this habitat type. Recent surveys of 95 potential islands in the inner 

marine waters revealed that 40 islands, islets, and rocks within the San Juan Islands NWR supported 

approximately 80% of breeding pairs (Nysewander, 2003b). However, there are no breeding black 

oystercatchers nesting on Turn Island and limited nesting on Matia. In fact, there are very limited 

reports of marine mammal or other wildlife use of Turn Island with the exception of raccoons. 

Growing pressure from recreational activities on and around breeding areas can have negative effects 

on oystercatcher productivity (Tessler et al. 2007). Therefore, special emphasis will be placed on 

reducing human activities (i.e., camping) that may support predators (e.g., raccoons) on Matia and Turn 

Islands to induce black oystercatchers to nest in suitable habitat on those islands. 

For more information about rats, rabbits, and mammalian predators, see rationale for objective 1.1. 

Goal 2: Protect, maintain, and restore the native vegetative communities and structure of 

sandy bluffs to maximize habitat for breeding seabirds.

Objective 2.1 Restore Burrow Nesting Seabird Habitat 

Restore up to 5 acres of sandy bluff habitat on Protection Island in areas where human structures 

(roads, homes, etc.) have been removed for the benefit of nesting rhinoceros auklets with the following 

characteristics: 

• No roads, buildings, or other human structures within the restoration area unless they are essential 

for research or Refuge management purposes. 

• Presence of suitable slope angle and soil compaction to facilitate auklet burrow construction.

• >75% of the vegetation is composed of species associated with the Willamette Valley Upland 

Prairie and Savanna and North Pacific Maritime Coastal Sand Dune and Strand ecological systems. 

• >50% vegetative cover present at the beginning of the rainy season.

• <25% cover of invasive plant species (e.g., cheat grass).

• No Scotch broom or other invasive shrub species. 

• Eliminate disturbance and impacts to seabird nesting habitats from deer. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-35

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bold type 

above with the text in this row. --- Up to 5 

acres

Up to 5 

acres

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Develop a site plan for infrastructure on Protection 

Island that minimizes impacts to wildlife. Consider 

current and future administrative, research, and 

volunteer needs. Establish new transportation routes 

and modes for necessary activities to minimize 

impacts in burrow nesting areas. 

PI

---

 

b. Develop handbook of Refuge guidelines that 

includes maps of breeding areas and distribute to all 

authorized people on islands to prevent unintentional 

disturbance or trampling.

PI ---  

c. Remove buildings associated with the Refuge 

caretaker’s cabin and at the end of the extended 

user’s term, eliminate building and associated access 

roads within the restoration area. 

PI

---

 

d. Expand use of solar energy to reduce transport of 

gas, oil, and propane.

PI ---  

e. Determine the best restoration techniques within 

test plots and monitor prior to full-scale restoration. 

PI ---  

f. Conduct studies to determine which native plant 

species will provide the best erosion control 

throughout the year. 

PI ---  

g. Prevent wildfires by continuing to prohibit public 

access and open fires by all island users. 

PI   

h. Pre-wash equipment before bringing to islands to 

prevent the establishment of invasive plant species. 

Treat existing and new infestations with IPM 

techniques; See Appendix E. 

PI ---  

i. Work with WDFW to remove deer from PI. 

Appropriate methods to remove deer will be 

determined in a step-down planning process. 

PI ---  

j. Search equipment and supplies to prevent the 

establishment of non-native species. 

PI   

k. Continue to survey for presence of non-native rats, 

rabbits, red foxes, feral cats and dogs, and use 

appropriate tools to maintain zero population levels.

PI   

l. Conduct a survey of native mammalian predators 

(e.g., coyote, raccoon, mink, and river otter),

determine impacts, and if necessary develop 

management actions under a separate step-down 

management plan. 

PI   
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-36

Rationale: Prior to Refuge establishment, Protection Island was developed as a residential and resort 

area. After Refuge establishment, much of the prior development was removed to improve wildlife 

habitat. Some of the roads and buildings were retained by the Service and retrofitted to serve Refuge 

management or research purposes and are in need of major repair or replacement. A few of the former 

landowners, known as extended users, retained their residences under various terms, but most of the 

terms have or will expire. Now is the ideal time to assess future Refuge management and research 

needs and develop a site plan for building and transportation routes that meets those needs while 

minimizing impact to wildlife and habitats. Refuge staff transport gasoline, oil, and propane for 

Protection Island vehicles, cabin appliances and generators. There is always a risk of spills when 

moving the 50 gallon drums from the boat to the shore. Converting to solar power to produce 

electricity would reduce the amount of fuel needed on the island. 

Approximately 90% of the North American rhinoceros auklet breeding population occurs on 8 islands 

(Gaston and Dechesne 1996), with Protection Island supporting the third largest colony (Pearson et.al. 

2009). However, in recent years the area occupied by the rhinoceros auklet colony has expanded into 

an area of approximately 5 acres that is currently occupied by the Refuge caretaker’s cabin and an 

extended user’s residence. At the end of the extended user’s life term, all buildings and access roads 

will be removed in this area in order to restore burrow-nesting seabird habitat quality, reduce human 

disturbance and physical obstructions. One important feature of all known rhinoceros auklet colonies 

is a well-developed soil to support burrow excavation (Leschner 1976, Speich and Wahl 1989, 

Richardson 1961). Thus, soil compaction will be an important component in habitat restoration. 

Specific measures are currently not available; however, research has been initiated to qualify soil 

characteristics of burrows on the island. In addition, Wilson (1977) and Leschner (1976) note that 

auklets do not burrow far into the level, interior portion of the islands, primarily because slope aids 

take-off. Wilson and Manuwal (1988) noted that burrow density was ‘significantly correlated with 

angle of slope,’ thus where feasible, every effort should be made to establish a slope angle within the 

preferred range for the species or consider placing artificial nest boxes in flat surfaces. 

Vegetation varies greatly among auklet colony sites in North America and serves a key role in 

providing stability and support for burrows and entrances (Leschner 1976). The vegetation on PI has 

been highly altered from an extensive pre-Refuge history of grazing and agriculture (Richardson 1961). 

Further information is needed to determine the best native species to use in revegetation efforts. Those 

providing the best soil stabilizing qualities without impeding burrow construction will be sought. 

These would include a mix of native annual and perennial, bunch and sod-forming grasses, as well cool 

and warm season grasses, interspersed with native low growing shrubs. This heterogeneous plant 

community would provide the bluffs with the greatest adaptive responses to maintain slope stability, 

drought tolerance, and fire resistance. Annual plants which typically have a shorter root system, die 

after reproduction and may not germinate at all if conditions are unfavorable, therefore are not the 

preferred long-term cover for slope stabilization. Perennials, with a more developed root system, can 

persist during unfavorable times and are generally better at holding the soil than annuals. Annuals such 

as cheat grass can also alter natural fire regimes, and wildfires remove standing vegetation which can 

lead to increased erosion (Young 1987). 

On Protection Island, a high-density herd of black-tailed deer are using suitable rhinoceros auklet 

burrow nesting habitat to browse and bed down. Rhinoceros auklet burrows collapsed by deer hoofs 

have been observed by researchers and Refuge staff. When deer bed down on top of rhinoceros auklet 

burrow entrances, they prevent these nocturnal birds from leaving or entering burrows to feed their 

young and have been observed to startle auklets, causing them to lose a beak-load of fish for their 

young. Given the many threats to auklet populations that cannot be addressed by Refuge management 

(e.g., climate change, fisheries interactions, oil spills), the importance of the colony to the North 

American population and its unique location, the Refuge must consider all possible conservation 

actions to protect auklet breeding habitat, including the reduction of deer on Protection Island. Black-
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-37

tailed deer are abundant in Northwestern Washington with the Washington Natural Heritage Program 

ranking of ‘demonstrably secure’ both globally and by state (WDNR 2009). Removing deer from 

Protection Island in order to protect this unique seabird habitat would have little impact on the deer 

population of the area. However, it will benefit the preservation of auklet burrows, increase the success 

of native plant revegetation and the potential for establishing threatened plant species on the island. 

For more information about rats, rabbits, and mammalian predators, see the rationale for objective 1.1. 

Objective 2.2 Enhance Rhinoceros Auklet and Tufted Puffin Nesting Habitat Quality 

Enhance sandy bluff habitat quality on up to 20 acres of Protection Island for the benefit of breeding 

rhinoceros auklets and tufted puffins with the following attributes:

• > 75% of the vegetation is composed of species associated with the Willamette Valley Upland 

Prairie and Savanna and North Pacific Maritime Coastal Sand Dune and Strand ecological systems. 

• >50% vegetative cover at the beginning of the rainy season.

• <25% cover of invasive plant species (e.g., cheat grass).

• No Scotch broom or other invasive shrub species.

• Eliminate disturbance and impacts to seabird nesting habitats from deer. 

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bolded 

type above with the text in this row.

PI --- Up to 20 

acres

Up to 20 

acres

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B

a. Establish vegetation restoration test plots for 

non-native plant removal and develop techniques 

for establishing native vegetation. 

PI ---  

b. Conduct studies to determine which native 

plant species will provide the best erosion control 

throughout the year. 

PI ---  

c. Prevent wildfires by continuing to prohibit 

public access and open fires by island users. 

PI   

d. Pre-wash equipment before bringing to the 

islands to prevent the establishment of invasive 

plant species. Treat existing and new infestations 

with IPM techniques. 

PI ---  

e. Work with WDFW to remove deer from PI. 

Appropriate methods to remove deer will be 

determined in a step-down planning process. 

PI ---  

f. Search equipment and supplies to prevent the 

establishment of non-native species. 

PI ---  

g. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and 

use appropriate tools to maintain zero population 

levels.

PI ---  

h. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

PI ---  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-38

otter), determine impacts, and if necessary 

develop management actions under a separate 

step-down management plan. 

Rationale: This objective is very similar to Objective 2.1; however, it is focused on enhancing 

existing bluff habitat with extremely limited access on foot. Therefore any means that can be 

employed to facilitate successful competition by native species on the sandy bluffs and minimize 

access to the area on foot will be considered for management action. This is primarily because removal 

would be impossible without damaging established burrows. Planting appropriate species on the edge 

of the bluff habitat so that continual beneficial seeding by upwind natives is one option under 

consideration. This option will be especially successful if those natives go to seed during the most 

appropriate season to out-compete invasive species (i.e., cheat grass). Broadcast seeding into sandy 

bluff habitat by helicopter is another option since no access to the colony would be necessary. 

However some species, such as scotch broom, are much more difficult to eliminate and management 

would necessitate access to the colony for removal as soon as it is detected. Aerial application of an 

herbicide may be considered for more abundant invasive species if injury to non-target vegetation is 

acceptable. For further details, see the IPM Strategy. 

For more information on habitat characteristics of interest in this restoration and the effects of deer on 

auklets and their habitat, see objective 2.1. For more information on rats, rabbits, and mammalian 

predators, see the rationale for objective 1.1.

Goal 3: Restore, maintain, and protect high quality, native savanna, grasslands, and 

herbaceous bald habitat to increase the species diversity, richness, and population levels of 

associated flora and fauna.

Objective 3.1 Restore Savanna, Grassland, and Herbaceous Bald Habitat

Manage and/or restore, where necessary, up to 200 acres of the savanna, grassland, and herbaceous 

bald habitat on Protection Island for the benefit of native plants, butterflies, and passerines by 

providing habitat with the following attributes: 

• <15-20% canopy cover of trees (e.g., Douglas fir, madrone, Garry oak) and native shrubs (e.g., 

ocean spray, Nootka rose).

• >50% cover of native grasses (e.g., Roemer’s and red fescue, California oatgrass) and native forbs 

(e.g., camas) of the Willamette Valley Upland Prairie and Savanna ecological system.

• <25% cover of non-native plant species.

• Establish one or more populations of priority resource of concern plant species (e.g., California 

buttercup and golden paintbrush).

• At least three locations of larval host plants and nectar host plants suitable for adult Taylor’s 

checkerspot butterfly. 

• <10% cover of invasive plant species (e.g., Himalayan blackberry, Canada thistle, cheat grass, 

Kentucky bluegrass, and European beach grass).

• No English ivy, Scotch broom, Dalmatian toadflax, or new invasions of noxious weeds. 

• Eliminate disturbance and impacts to seabird nesting habitats from deer. 

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bolded 

type above with the text in this row.

PI 0 acres Up to 200 

acres

20-40 

acres
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-39

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Determine extent and composition of historical 

(pre-farming) savanna, grassland, and herbaceous 

bald habitat. 

PI ---  

b. Evaluate restoration techniques, such as 

prescribed fire or mechanical means for up to 20-

40 acres of grassland. Use results for restoration 

of additional areas on the island. 

PI ---  

c. Update fire plan to outline Refuge response to 

wildfires and use of prescribed burns. All 

prescribed burns will be conducted under an 

approved burn plan.

PI ---  

d. Control or eradicate invasive and non-native 

plants with IPM techniques using cultural, 

mechanical, physical, biological and/or chemical 

means. Prohibit off-road vehicle use to the 

greatest extent possible to prevent the spread of 

noxious weed seed, particularly in restoration 

sites.

PI ---  

e. Re-introduce rare plant species (such as golden 

paintbrush and California buttercup) and Taylor’s 

checkerspot larval host plants and nectar sources 

for adults either from seed sources or live plant 

material.

PI ---  

f. Develop partnerships to propagate difficult to 

obtain plant materials for re-introductions.

PI ---  

g. Standard vegetation surveys conducted preand post-restoration; conduct surveys for 

Taylor’s checkerspot butterfly; continue 

conducting breeding bird and Christmas bird 

count surveys with Refuge volunteers.

PI ---  

h. Work with WDFW to remove deer from PI. 

Appropriate methods to remove deer will be 

determined in a step-down planning process. 

PI ---  

i. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and 

use appropriate tools to maintain zero population 

levels.

PI   

j. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

otter), determine impacts, and if necessary 

develop management actions under a separate 

step-down management plan. 

PI   

Rationale: In 1792, Captain George Vancouver described the island as having luxuriant grasses 

mixed with an abundance of flowers. Pre-Refuge grazing, farming, and development have eliminated 

all but a small remnant of this rare system on the upland plateau. Although a daunting challenge, the 

Service’s policy for Biological Integrity, Diversity, and Environmental Health (601 FW 3.3 [3.6D]) 

establishes historic conditions “prior to substantial human related changes to the landscape” as the 

basic reference for protecting, mimicking, or restoring natural processes. The vegetative community 

now found where the native savanna, grassland and herbaceous bald habitats existed in the past has 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-40

been radically changed through more than a century of grazing and farming. Rare or threatened species 

of savanna, grassland, and herbaceous balds include golden paintbrush, slender crazyweed, Bear’s foot 

sanicle, and California buttercup. The golden paintbrush is threatened by competition with native and 

non-native plant species, habitat conversion by humans and natural succession, and grazing by 

herbivores (Federal Register / Vol. 62, No. 112 / June 1997). Restoration techniques under 

consideration include: 1) cultural—prescribed fire as part of a one-two method with another tool such 

as mechanical or chemical; 2) mechanical —plowing, discing, mowing, and rototilling; 3) physical—

hand plant removal and planting; 4) biological—for non-native plant control using approved and 

proven biological agents (e.g., insects ); 5) chemical—herbicide applications. Prescribed fire would 

also be used once restoration is completed to maintain grassland vigor and diversity. 

Throughout the term of this CCP, management will focus on restoring larval host plants and adult 

nectar sources in the event that rare butterflies should recolonize the islands. Some of these plants 

include mustard, verbena, plantain, and hairy Indian paintbrush. The Taylor’s checkerspot butterfly 

has been a candidate species for Federal listing since 2001 (USFWS 2009b). Currently, this species is 

found at only four sites in Washington and two sites in Oregon, yet it was historically found throughout 

the grasslands of the Willamette Valley, Puget Sound, and south Vancouver Island (Butterfly 

Conservation Initiative 2006, Draft Benton County Taylor’s Checkerspot Management Plan 2009,

Stinson 2005). The site with the largest concentration of this species in Washington can be found on 

the mainland less than two miles from Protection Island. Actions identified in this plan are geared 

toward enhancing habitat on Protection Island given the close proximity of checkerspots on the 

mainland.

For more information about the effects of deer on native vegetation and restoration efforts, see the 

rationale for objective 1.1; for more information on rats and rabbits, see the rationale for objective 1.1. 

Objective 3.2 Protect and Maintain Savanna, Grassland, and Herbaceous Bald Habitat 

Increase protection and maintenance for the characteristics of savanna, grassland, and herbaceous bald 

patches on 28 islands (e.g., Boulder, Peapods) in the San Juan Islands NWR for the benefit of rare 

native plants with the following attributes: 

• > 75% cover of the grasslands support native shrubs, grasses, and forbs associated with the 

Willamette Valley Upland Prairie and Savanna and North Pacific Herbaceous Bald and Bluff 

ecological systems.

• <25% cover of non-native plant species.

• Maintain populations of rare plant species (e.g., California buttercup).

• <10% cover of invasive plant species (e.g., Himalayan blackberry and Canada thistle).

• No presence of English ivy, Scotch broom, yellow toadflax, or St. John’s wort.

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bolded 

type above with the text in this row.

SJI 0 

islands

28 

islands

14-28 

islands

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Where appropriate, use prescribed fire strategies 

to promote native grasses and forbs by removing 

invasive and non-native plants and reducing 

canopy cover.

SJI ---  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-41

b. Use IPM strategies to control or eradicate 

invasive and non-native plants (e.g., Himalayan 

blackberry, Canadian thistle, English Ivy, Scotch 

broom, or yellow toadflax; see IPM Appendix E). 

SJI ---  

c. Use non-motorized hand tools for removal of 

woody species to promote native grasses and forbs 

by reducing canopy cover.

SJI ---  

d. Monitor response of native savanna, grassland,

herbaceous bald plants, and especially rare plant 

species to vegetation management treatments, such 

as reintroduction, controlled burning, clipping, and 

herbicide application. 

SJI ---  

e. Continue baseline vegetation inventories with 

partners (TNC and UW) on Refuge islands. 

Visit 14 of the islands annually to monitor and 

respond with IPM strategies to the presence of 

invasive plants and animals and maintain 

closure signs. 

SJI ---  

f. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and use 

appropriate tools to maintain zero population 

levels.

SJI ---  

g. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

otter), determine impacts, and if necessary develop 

management actions under a separate step-down 

management plan. 

SJI ---  

Rationale: Considered one of the rarest ecosystems in the United States, less than 10% of historic 

native savanna, grassland, and herbaceous bald habitat remains in the Puget Sound (WDFW 2005). 

About 1⁄4 of islands have been surveyed since 2005 for vegetation characterization and composition. 

Although Refuge patch sizes are small (island sizes range from 0.5–30 acres), these relatively intact 

island communities form a mosaic throughout the Archipelago landscape. Trampling, invasive species,

and canopy closure from woody species are serious threats. Herbivores could potentially have a severe 

impact on smaller islands. 

For more information about rats and rabbits, see the rationale for objective 1.1. 

Objective 3.3 Restore and Improve Savanna, Grassland and Herbaceous Bald Habitat

Restore and improve the following savanna/grassland characteristics on up to 20 acres on Smith and 

Turn Islands for the benefit of plant species (e.g., golden paintbrush) and rare native wildlife (e.g.,

Island marble or valley silverspot butterflies) with the following attributes:

• <30% canopy cover of native shrubs (e.g., ocean spray, Nootka rose).

• >50% cover of native grasses (e.g., Roemer’s and red fescue, California oatgrass), native forbs 

(e.g., camas) and butterfly larval host plants and adult nectar sources of the Willamette Valley 

Upland Prairie and Savanna and North Pacific Herbaceous Bald and Bluff ecological systems.

• Maintain populations of rare plant species (e.g., California buttercup).

• <10% cover of invasive plant species (e.g., Himalayan blackberry, Canada thistle, lawn weed).

• <25% cover of other non-native plant species.

• No presence of English ivy, Scotch broom, yellow toadflax, or St. John’s wort. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-42

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bolded 

type above with the text in this row.

SJI 0 acres Up to 20 

acres

10 acres

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Introduce rare plant species (e.g., golden 

paintbrush and California buttercup).

SJI ---  

b. Restore or enhance (where appropriate) 

populations of host plants for rare butterflies 

(e.g., mustard, verbena, plantain, and hairy 

Indian paintbrush).

SJI ---  

c. Use prescribed fire strategies to promote 

native plants by removing invasive and nonnative plants and reducing shrub and tree cover.

SJI ---  

d. Use IPM strategies to control or eradicate 

invasive and non-native plants (e.g., Himalayan 

blackberry, Canada thistle, English Ivy, Scotch 

broom, or yellow toadflax; see IPM Appendix 

E).

SJI ---  

e. Use mechanical removal of woody species to 

promote native grasses and forbs by reducing 

canopy cover.

SJI ---  

f. Monitor response of native savanna, 

grassland, herbaceous bald plants, and 

especially rare plant species to vegetation 

management treatments such as reintroduction, 

prescribed burns, clipping, and herbicide 

application. 

SJI ---  

g. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and 

use appropriate tools to maintain zero 

population levels.

SJI ---  

h. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

otter), determine impacts, and if necessary 

develop management actions under a separate 

step-down management plan. 

SJI ---  

i. Reroute trail system on Turn Island to 

minimize trampling through sensitive camas 

community (see Objective 7.1).

Turn ---  

Rationale: See Objective 3.2. Since 1980, The Nature Conservancy has conducted extensive 

research on applicable grassland restoration methodologies for small islands within the San Juan 

Archipelago at Yellow Island (Dunwiddie 2005). Many rare species, such as golden paintbrush, do not 

compete well with invasive species and closed canopy cover. At Yellow Island, small prescribed fires, 

mechanical clearing, and plant propagation have been used to restore more than 50 species of 

wildflowers native to the Puget Sound grassland community. Refuge islands already have some 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-43

populations of rare species. Enhancing these populations and reintroducing additional populations on 

other appropriate islands would increase their conservation. In addition, about fifty species of native 

butterflies are closely associated with the savanna, grassland, and herbaceous bald habitat in the Puget 

Sound (WDFW 2005). The islands have potential habitat for two rare butterfly species: valley 

silverspot and Island marble (Miskelly and Potter 2009). Although patch sizes may be too small to 

sustain a population, restoration of host plant species on Refuge islands that are adjacent to existing 

populations on larger islands could be beneficial.

For more information about rats and rabbits, see the rationale for objective 1.1. 

Goal 4: Restore, maintain, and protect the species richness and diversity of the forests and 

woodlands by fostering a complex understory and diversity of tree age classes.

Objective 4.1 Restore and Maintain Forest and Woodlands 

Restore continuity of up to 80 acres of historic/potential forest and woodlands on Protection Island 

with the following attributes:

• >25% canopy cover of trees (e.g., Douglas fir, madrone, Garry Oak, lodgepole pine) of the North 

Pacific Douglas-Fir Forest and Woodland and the North Pacific Maritime Dry Mesic Douglas-Fir -

Western Hemlock Forest.

• >50% cover of native shrubs (e.g., ocean spray, Nootka rose) in understory.

• <10% cover of invasive plant species (e.g., Himalayan blackberry and Evergreen blackberry).

• Forest patches are connected.

• No presence of English ivy, English holly, Scotch broom, Dalmatian toadflax, garlic mustard, or

other new noxious weed invaders. 

• Eliminate disturbance and impacts to habitats from deer. 

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).

Alternatives Refuge/Unit Alt A Alt B Alt C

The alternative is modified by replacing bolded 

type above with the text in this row.

PI 49 acres Up to 80 

acres

Up to 80 

acres

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Control or eradicate invasive and non-native 

plants with IPM techniques using cultural, 

mechanical, physical, biological and/or chemical 

means.

PI   

b. Conduct vegetative and wildlife surveys to 

establish baseline diversity and monitor change 

over time. 

PI ---  

c. Implement total wildfire suppression tactics on 

all wildfires on the island. PI   

d. Focus opportunistic restoration activities on the 

shrub layer within the “gap area” between the 

forest patches on the north side of the island.

PI --- 



e. Work with WDFW to remove deer from PI. 

Appropriate methods to remove deer will be 

determined in a step-down planning process. 

PI ---  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-44

f. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and 

use appropriate tools to maintain zero population 

levels.

PI   

g. Conduct a survey of native mammalian 

predators (e.g., coyote, raccoon, mink, and river 

otter), determine impacts, and if necessary 

develop management actions under a separate 

step-down management plan. 

PI   

Rationale: This system has been degraded on Protection Island. A number of fires occurred on the 

island in the past century and private developers constructed dirt roads and an air strip through the 

forest. In recent years, the high density of deer and subsequent heavy browsing has decreased the 

amount of small trees and shrub understory. Those small trees and shrubs provide important nesting 

and roosting habitat for eagles and other migratory birds, such as American kestrels, downy and hairy 

woodpeckers. Small trees also contribute to regeneration of mature forest. 

Opportunistic restoration of this habitat will involve transplanting native stock seedlings to the 

restoration area as funding and logistics allow. Given the long period of time required for re-growth, 

all wildfires would be suppressed to maintain the characteristics of old growth forest and prevent 

erosion along the bluffs to the north. 

All activities on the island will be carried out in accordance with USFWS National Bald Eagle 

Management Guidelines (USFWS 2007). A bald eagle pair has maintained nests on Protection Island 

since prior to Refuge establishment. The stand that the nest trees are in is relatively small, however, 

the size of the forest surrounding a nest tree is less important than isolation from human development 

and disturbance (minimum distance is <328 feet, average distance is >1,640 feet, Buehler 2000). 

Important characteristics of nest and roost areas include availability of trees that are located in forests 

with open canopies providing good visibility, access to the tree (i.e., on the forest edge, near a clearing, 

or above the canopy) and in close proximity to open water foraging habitats. Roost and nest trees are 

usually prominent, large trees 200 to 300 years old in the Pacific Northwest. Most roosts are located in 

areas that are protected from prevailing winter winds. Winter habitat suitability is defined by food 

availability, the presence of roost sites that provide protection from inclement weather, and the absence 

of human disturbance (Buehler 2000). 

For more information about rats, rabbits, and the effects of deer on native vegetation and restoration 

efforts, see the rationale for objective 1.1.

Objective 4.2 Protect and Maintain Forest and Woodlands 

Increase protection and maintenance of forests and woodlands on 10 islands (including Matia, Flattop, 

Ripple, Willow, Turn, and Skipjack) in the San Juan Islands NWR with the following attributes:

• Maintain current acres (~ 127) of North Pacific Dry Douglas-Fir Forest and Woodland 

• Maintain current acres (~105) of North Pacific Maritime Dry Mesic Douglas-Fir -Western 

Hemlock Forest on Matia, including old growth.

• >50% cover of native shrubs (e.g., ocean spray, Nootka rose).

• <10% cover of invasive plant species (e.g., Himalayan and Evergreen blackberry).

• No presence of English ivy, English holly, Scotch broom, or yellow toadflax.

• No non-native rats, rabbits, or red fox.

• No feral cats or trespassing domestic cats or dogs.

• Reduce impacts from other native mammalian predators (e.g., coyote, raccoon, mink, and river 

otter).
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-45

Alternatives Refuge/Unit Alt A Alt B Alt C

Objective applies to alternative as written above 

().

SJI  

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Use IPM strategies to control invasive and nonnative plants.

SJI ---  

b. Re-vegetate removed campsites with trees or 

shrubs.

Matia and 

Turn

---  

c. Implement total wildfire suppression tactics on 

all forested islands. SJ

  SJI   

d. Reduce the risk of fire and the impacts of illegally 

collected firewood by eliminating open fires. Allow 

liquid fuel camp stoves only. Increase fire regulation 

enforcement and education.

Matia and 

Turn

  

e. Continue to survey for presence of non-native 

rats, rabbits, red foxes, feral cats and dogs, and use 

appropriate tools to maintain zero population levels.

SJI ---  

f. Conduct a survey of native mammalian predators 

(e.g., coyote, raccoon, mink, and river otter),

determine impacts, and if necessary develop 

management actions under a separate step-down 

management plan. 

SJI ---  

Rationale: These ecosystems are in precipitous decline due to extensive logging and human 

settlement, resulting in almost no remaining old-growth (200-400 years old) conifer-hardwood stands 

in the westside lowland of Puget Sound (WDFW 2005). Very old stands exhibit multi-layered 

canopies, with western hemlock becoming dominant. Additional old growth characteristics include an 

understory of downed, moss-covered logs, along with salal, ocean spray, sword fern, red currant, and 

dwarf Oregon grape as well as snags. These stands are important for at least 1,000 species (WDFW 

2005). The flora of this ecosystem varies slightly with location, is distinct, and contributes to native 

biodiversity. The old-growth westside lowland conifer-hardwood forest on Matia Island could benefit 

associated old-growth species (e.g., Vancouver ground cone, bald eagle, and pileated woodpecker) and 

other native species, such as bats, pileated, hairy, and downy woodpeckers.

One emphasis of this objective is to sustain active bald eagle territories. Eleven breeding territories 

have been identified on Refuge islands by WDFW (Stofel pers. comm.). All activities on islands 

within eagle territories will be carried out in accordance with USFWS National Bald Eagle 

Management Guidelines (USFWS 2007). For more information on important nesting and roosting 

habitat for this species, see the rationale for Objective 4.1. Other species that will benefit from the 

strategies listed in this objective include amphibians, such as western toads and garter snakes.

Although Matia Island supports a very small fragment of the lowland old growth, it serves as an 

example of a system that is decreasing elsewhere as young and mature stands continue to be intensively 

logged or converted to urban and residential uses. Invasive species are a serious threat to this system.

In 2001, English ivy was observed on Matia Island; it had killed a few trees on the forest edge and was 

rapidly moving into the forest. Since 2001, 3.26 tons of English ivy has been removed from the island 

via mechanical treatment. English ivy has little wildlife value and the berries are toxic to most 

songbirds (No Ivy League, 2009 (http://www.portlandonline.com/shared/cfm/image.cfm?id=201790, 

http://www.calapooia.org/wp-content/uploads/2009/01/seeds_brochure1.pdf)). English holly, which 

will out-compete lower story plants, has been found, but not treated. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-46

For more information about rats and rabbits, see the rationale for objective 1.1. 

Goal 5: Restore, maintain, and protect the biological integrity of natural, small wetlands to 

increase species diversity and productivity.

Objective 5.1 Restore, Maintain, and Protect Brackish Water Wetlands 

Where feasible, restore the biological integrity of brackish wetlands on Protection Island (<5 acres

historic; currently only a remnant) and Smith Island (<0.5 acres current) for the benefit of native 

wildlife species with the following attributes:

• No invasive aquatic species (e.g., green crab or spartina).

Alternatives Refuge/Unit Alt A Alt B Alt C

Objective as written above applies to alternatives 

(). 

 

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Conduct hydrological studies on Protection and 

Smith Islands to identify historical and current 

hydrological processes and wetland functioning 

(e.g., salinity, soils, vegetation, and wildlife uses).

PI and Smith ---  

b. If necessary and feasible, restore hydrological 

processes as a basis for freshwater/brackish wetland 

restoration on Smith.

Smith ---  

c. If feasible, use standard restoration methodology 

to remove fill and recreate the wetland on PI. 

Historic size will not be possible due to creation of 

the marina. 

PI ---  

d. Control and eradicate invasive non-native plant 

and animal species. Treat infestations with IPM

techniques using cultural, physical, biological, 

and/or chemical means.

PI and Smith ---  

Rationale: The extent of these wetlands is limited. The wetland on Smith Island is less than 1 acre 

and the wetland on Protection Island was filled during marina construction prior to Refuge 

establishment. Both of the wetlands on these islands are similar in their location relative to the 

surrounding marine environment, formation, and water salinity (brackish). Protection Island’s wetland 

at the base of Violet Spit was filled about 30 years ago to develop a marina; however, the area still 

retains shallow water during the winter and seepages can be observed in the shoreline of the marina. 

The Service is required to maintain the marina as part of the agreement made with extended users when 

the Refuge was established, but the marina does not cover the entire historic wetland site. Wintering 

and migrating waterfowl continue to use the remnant wetland area during periods of high precipitation. 

The only other known fresh water on Protection Island occurs from small seeps on the north side bluffs. 

The small brackish wetland on Smith Island is located at the base of the east spit. It is intact, but 

possibly human influenced. In 2007, Refuge staff learned that the Coast Guard built cisterns and, 

possibly, drainage channels from the uplands to the wetland. Further investigation is needed to 

establish the nature of this wetland and if restoration is warranted. 

Up to 30,000 shorebirds (e.g., dunlin, western sandpipers) have been observed using this wetland area 

and adjacent shorelines during migration (Sanguinetti pers. comm.). The wetland on Smith Island is at 

risk of invasive green crab or spartina infestations because of its proximity to current control areas on 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-47

Vancouver and Whidbey Island, respectively. 

Objective 5.2 Restore, Maintain and Protect the Freshwater Wetland 

Where feasible, restore the biological integrity of the seasonal, freshwater wetland on Matia Island 

(~0.4 acres) for the benefit of native plant and wildlife species.

• No invasive species (e.g., bull frog, spurge laurel, or purple loosestrife) 

Alternatives Refuge/Unit Alt A Alt B Alt C

Objective applies to alternative as written above 

().

Matia  

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Determine the hydrology of the freshwater 

wetland to identify historical and current 

hydrological processes and wetland functioning. 

Matia ---  

b. If necessary and feasible, restore hydrologic 

processes and use restoration techniques appropriate 

for wilderness areas. 

Matia ---  

c. Control and eradicate invasive non-native plant 

and animal species and treat infestations with IPM

techniques using cultural, physical, biological, 

and/or chemical means.

Matia ---  

Rationale: This small wetland is the only freshwater wetland found on the Refuge. Understanding 

the hydrology of this wetland would assist in managing for biological integrity and diversity on Matia. 

This wetland is within the upland of the island, surrounded by woodlands and is believed to be a 

forested wetland that seasonally recedes (Lane and Taylor, 1997). The study may reveal that the 

wetland is on a natural successional path, meaning that it is naturally filling in and a change in 

vegetation is occurring which is acceptable to management. There is historic evidence of the island

being inhabited, however the extent is unknown. Invasive plant species identified in the objective and 

others listed on the county list (San Juan County weed list 2009) are threats to the Refuge, and the 

wetlands in particular, and are monitored to prevent establishment. 

GOAL 6: Refuge visitors increase their knowledge of the natural and cultural resources of the 

Salish Sea ecosystem; gain an understanding of the role of the National Wildlife Refuge 

System; and contribute to the stewardship of Protection Island and San Juan Islands NWRs. 

Objective 6.1 - Access to Matia and Turn Islands

Allow managed access to Matia and Turn Islands so that people of all ages may learn about and 

experience San Juan Islands NWR habitats. 

• >90% of Refuge visitors know they are on a National Wildlife Refuge.

• >80% of Refuge visitors understand that “wildlife comes first” on wildlife refuges. 

• >80% of Refuge visitors know there are other Refuge islands in the San Juan Archipelago and why 

they are closed.

• >80% of Refuge visitors understand access and other public use regulations, and know that their 

purpose is to protect human safety, wildlife, and habitats.

• 100% of visitors comply with fire regulations.

• Visitors obey access and other public use regulations on Turn and Matia Islands (# of violations 

observed or reported decreases by 50% over 5 years).
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-48

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Maintain and enhance existing trails while 

reducing or eliminating illegal social trails.

Matia: maintain and enhance the existing 

1.2 mile wilderness loop trail and eliminate 

illegal social trails. 

Turn: re-develop the .9 mile loop trail to 

include interpretive component.

Matia ---  

Turn ---  

b. Maintain seasonal dock. Matia State State State

c. Maintain composting toilets. Matia 1, State 1, State 1, State

Turn 2, State 2, State 1, FWS

d. Maintain or provide mooring buoys in 

order to minimize anchoring damage on 

bottom habitat.

Matia 2 buoys in 

Rolfe cove, 

State

2 buoys in 

Rolfe cove, 

State

2 buoys in 

Rolfe cove, 

State

Turn 3 buoys, 

State

3+ buoys, 

State

3+ buoys, 

FWS

e. Provide shoreline access –

Matia: Allow shoreline access at Rolfe Cove 

and maintain closure on remainder of 

shoreline. 

Turn: Allow shoreline access on west and 

southwest beaches, close southeast beach 

and remainder of shoreline to protect 

wildlife and habitat.

Matia Rolfe cove 

only

Rolfe cove 

only

Rolfe cove 

only

Turn Unregulated  

f. Require commercial groups to obtain a 

Refuge special use permit (SUP).

Matia State permit Refuge 

SUP, State 

permit

Refuge 

SUP, State 

permit

Turn State permit Refuge 

SUP, State 

permit

Refuge 

SUP

g. Increase Refuge law enforcement 

presence

Turn & Matia minimal  

h. Reduce the risk of fire and the impacts of 

illegally collected firewood. Allow liquid 

fuel and gel camp stoves only.

Matia & Turn No fires, not 

well 

enforced

No fires 

allowed

No fires 

allowed

i. Pets. Matia& Turn Matia: State 

allows pets 

on leash in 2 

acre rec. 

area.

Turn: State 

allows pets 

on leash.

Federal: no 

pets,

regulations 

not enforced

Enforce 

existing 

Federal 

regulations, 

no pets

Enforce 

existing 

Federal 

regulations, 

no pets
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-49

j. Maintain and update regulatory signage in 

accordance with the comprehensive sign 

plan; see SJI sign plan Appendix D.

Matia & 

Turn

---  

k. Include information on interpretive signs 

that show these Islands are part of a 

larger Refuge within the San Juan 

Islands Archipelago. Indicate where the 

other islands are and explain why they 

are closed to the public. See appendix D.

Matia --- 1 signs 1 sign

Turn --- 3 signs 2 signs

l. Acquire leases (public access and 

conservation) of tidelands and bed-lands 

from DNR to better control unauthorized 

access from inter-tidal areas.

Turn & Matia ---  

Rationale: Protection Island NWR and the majority of the San Juan Islands NWR units (islands) are 

closed to the public to protect wildlife. Opening Refuges to visitation is a tradeoff. Visitors are likely to 

gain a greater understanding and appreciation of the Refuge resources if they have an opportunity to 

learn about and experience island habitats and associated wildlife. Controlling public access and 

minimizing disturbance is critical to providing high quality wildlife viewing experiences because 

wildlife will abandon even suitable habitat if disturbed. Increased law enforcement and working with 

partners is an effective way to manage public access and protect wildlife and their habitat while 

maintaining high quality visitor experiences. 

Objective 6.2 - Wildlife Viewing, Photography, and Interpretation on Matia and Turn Islands

Afford visitors the opportunity to learn about and experience island wildlife and their habitats while 

minimizing adverse impacts to Refuge resources. 

• >80% of Refuge visitors know they are in rare old growth island habitat on Matia Island.

• >60% of Refuge visitors can name at least one species associated with old growth island habitat.

• >60% of Refuge visitors can name at least one species associated with island shoreline habitat.

• >90% of Refuge visitors know that humans and pets disturb wildlife and their habitat and can 

identify at least one negative impact.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Develop wildlife and plant lists. Matia & Turn ---  

b. Develop and install habitat and wildlifespecific interpretive panels in accordance with 

the comprehensive sign plan; see Appendix D.

Matia --- 3 signs 1 sign

Turn --- < 8 signs 3 signs

c. Volunteers provide information to visitors. Matia & Turn ---  

d. Have a multi-function, live-aboard or onisland hosts/caretakers who will explain rules 

and regulations and provide other information to 

visitors 

Matia& Turn --- Seasonal Seasonal

e. Create 2 new positions stationed in the San 

Juan Islands: a full time Refuge Manager 

responsible for planning, law enforcement, 

maintenance, education, public relations, and 

volunteer supervision, and a seasonal ranger 

position. 

SJI 0 staff Refuge 

Manager 

& 

seasonal 

Ranger

Refuge 

Manager 

& 

seasonal 

Ranger

f. Continue working with Refuge partners Matia Partner 

with WA 

State 

Partner 

with WA 

State 

Partner 

with WA 

State 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-50

Parks and 

others

Parks and 

others

Parks and 

others

Turn Partner 

with WA 

State 

Parks and 

others

Partner 

with WA 

State 

Parks and 

others

Partner 

with 

others

Rationale: Because Protection Island NWR and the majority of the San Juan Islands NWR units 

(islands) are closed to the public, Turn and Matia Islands offer a unique opportunity to experience island 

refuge habitats and their associated wildlife. Matia Island in particular offers the public an opportunity 

to visit a wilderness area with primeval island forest and increase their understanding and appreciation 

of the role and purpose of wilderness islands. 

These islands offer unique opportunities within the SJI Refuge for on-site education through interpretive 

panels, trails, and personal contact with knowledgeable staff and volunteers. Working with partners is 

an effective way to continue providing high quality educational experiences.

Objective 6.3 - Camping on Turn and Matia Islands 

The San Juan Island NWR camping program on Turn and Matia Islands is safe, family-friendly, and 

facilitates wildlife observation, photography, and interpretation throughout the San Juan Island NWR. 

• Disturbance to wildlife is minimized by campers using only designated campsites and staying 

off closed areas and shorelines (# of incidents of unauthorized camping and/or entry into closed 

areas). 

• Refuge island camping is safe (# of unsafe incidents; # of undesirable behaviors) and familyfriendly (# of families camping).

• Campers comply with Refuge regulations including no campers arriving by motorized boats, no 

pets, etc. (# of incidents of noncompliance). 

• Campers know to keep their human-powered vessels up to 200 yards from closed Refuge islands 

and closed shorelines in order to not disturb wildlife (% of campers who know). 

• Campers report observing Refuge wildlife from their human- powered boats and from Turn and 

Matia Islands (% of individuals or groups). 

Alternatives Alt A Alt B Alt C

The alternative is modified by replacing bold type 

above with the text in this row.

Turn 

and 

Matia

Turn 

and 

Matia

Matia 

Island 

only

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Establish a reservation system for camping. --  

b. Permit camping only for visitors arriving by 

human-powered boats. 

--  

c. Camping permitted only in designated # of 

campsites with a limit of 8 people per campsite. 

Turn 13 8 0

Matia 6 6 4

d. Eliminate camping and night use of Turn Island. --- -- 

Rationale: Protection Island NWR and the majority of the San Juan Islands NWR units (islands) are 

closed to the public. Turn and Matia Islands, however, are open and offer a unique opportunity to 

experience refuge island habitats and their associated wildlife. Matia Island in particular offers the 

public an opportunity to visit a wilderness area with primeval island forest and increase their 

understanding and appreciation of the role and purpose of wilderness islands. Day use of the islands will 

not be changed by these strategies. In addition, use of mooring buoys by sail- or motor-boats will 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-51

continue. 

Allowing camping to those arriving by human-powered craft affords such visitors the opportunity to 

experience these islands which they may otherwise not have sufficient time to do. Access to Matia and 

Turn Islands by human-powered craft affords visitors traveling in this manner the opportunity to rest and 

to allow wind and inclement weather to abate. Because human-powered craft is generally much smaller 

and slower than sail and motor craft, people traveling by such vessels require more time to reach their 

destinations and have additional safety considerations. Motor and sail vessels have greater capacity to 

seek alternative camping accommodations, including on-board facilities, and therefore do not have the 

same need to camp on refuge islands. Overnight access to visitors traveling by human-powered craft 

provides them with the opportunity to experience wildlife at times when animals are particularly active 

such as dawn and dusk, and to experience the sounds of wildlife at night. 

See strategies and rationale for objective 6.2 for more information on wildlife viewing, interpretation 

and photography. 

Objective 6.4 Education Through Stewardship Opportunities 

Provide stewardship opportunities on both Refuges where participants can learn about seabirds and the 

Salish Sea Ecosystem.

• Complete at least one educational stewardship project per year.

• Participants can identify at least 3 adverse impacts of invasive species, marine debris, and/or 

human-caused wildlife disturbances.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Increase partnerships with schools and volunteer 

groups to assist with clean-up on 1/3 of the islands 

annually.

PI & SJI PI, 

Matia

 

b. Remove invasive plants. PI & SJI   

c. Observe and monitor wildlife. PI & SJI PI  

d. Maintain trails, signs, buildings, and facilities. PI & SJI SJI  

Rationale: Public understanding and awareness is an important and effective way to protect wildlife 

and habitat. Providing stewardship opportunities promotes a greater understanding and appreciation of 

refuge resources by instilling a sense of involvement and the ability to positively affect the outcome. 

Participants in turn will advance that knowledge and appreciation within their communities. The result 

will be a generally better understanding of the needs of wildlife and how various refuge species use the 

islands, and how human disturbance impacts wildlife resources. This greater understanding will allow 

visitors to the area to act with greater sensitivity. 

Objective 6.5 - Environmental Education 

Provide post-secondary environmental education opportunities

• At least 3 college-level students conduct environmental studies over a 5-year period.

• Student projects are designed to contribute measurably to both the student’s and the Service’s

knowledge of Refuge resources.

Strategies Applied to Achieve Objective Refuge Alt A Alt B Alt C

a. Issue 3 or more permits every 5 years to regional 

colleges and universities to allow students to conduct 

environmental studies on PI and the SJIs

PI & SJI PI  

Rationale: Enabling legislation for PI includes providing for wildlife-oriented public education. 

Offering students the opportunity to conduct environmental studies on Protection Island and the San 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-52

Juan Islands will increase both the students’ and the Service’s knowledge and understanding of Refuge 

resources while meeting Refuge purposes. Environmental studies are of limited duration, complexity 

and scale and are geared toward students gaining field experience and knowledge of the National 

Wildlife Refuge System and its management. 

GOAL 7: Residents and visitors to the area increase their knowledge of the natural and 

cultural resources of the Salish Sea ecosystem, understand the Refuges’ role in protecting 

those resources, and learn how they can reduce their impacts to those resources.

Objective 7.1 - Wildlife Observation, Photography, and Interpretation

Promote water and land-based off-Refuge opportunities where visitors to the area can observe and 

photograph Refuge wildlife and habitats. 

• >50% of visitors to the area know that there is a National Wildlife Refuge in the San Juan 

Archipelago and know the conservation mission of the National Wildlife Refuge System.

• >50% of visitors to the area know that Refuge islands provide key habitat for seabirds and 

marine mammals and know how to observe wildlife without causing disturbance.

• >40% of visitors to the area know when and where the best wildlife viewing opportunities are 

and how to maximize those opportunities while minimizing disturbance.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Install interpretive panels in harbors and on 

ferries in accordance with the comprehensive 

sign plan; see Appendix D.

PI 1 panel 2 panels 2 panels

SJI 0 5 panels, 

2+ 

additional 

venues

5 panels

b. Install updated posters at marinas. PI & SJI  10 

marinas

5 marinas

c. Provide ecotourism interpreter training. PI & SJI --- 2 

classes/yr

1 class/yr

d. Install updated posters at island airports. SJI ---  

e. Develop and distribute info packets to 

ecotourism organizations.

PI & SJI ---  

f. Produce an educational video. PI & SJI ---  ---

g. Show video on ferry boats. PI & SJI ---  ---

h. Update and maintain refuge-specific 

websites that can be linked to additional 

technology.

PI & SJI

  

i. Place articles in free tourist magazines,

including Washington Guide.

PI & SJI  10 articles 5 articles

j. Develop Refuge-specific brochures. PI & SJI ---  

Rationale: Some wildlife-dependant recreation activities can be compatible with the primary refuge 

goals to protect wildlife and their habitat. With proper information and education, the public should be 

able to observe and photograph refuge wildlife without causing disturbances. Providing such 

information will result in greater awareness of the refuges, the National Wildlife Refuge System, and 

their purposes, and will foster greater appreciation for their ecological values. When the public knows 

where to view wildlife and understands their needs, how various species use Refuge islands, and how 

human disturbance affects wildlife, they will be able to act with greater sensitivity to minimize impact 

on wildlife populations and habitat when visiting the San Juan Islands and the waters around Protection 

Island. 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-53

Objective 7.2 - Community Awareness 

Promote Refuge understanding and awareness within the community.

• >60% of government and tribal officials and local citizens know of the Protection and San Juan 

Islands NWRs and that they provide key habitat for a variety of wildlife including seabirds and 

marine mammals.

• >60% of government and tribal officials and local citizens understand the conservation mission 

of the National Wildlife Refuge System.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Create a traveling display and take it to 

festivals and other events.

PI & SJI ---  ---

b. Conduct school and community EE 

programs that include information on why 

it is important to obey Refuge regulations.

PI & SJI --- 5 events 3 events

c. Develop a relationship with the local 

press to promote news articles and get 

Refuge information posted.

PI & SJI  10 articles 

and/or 

postings

5 articles 

and/or 

postings

d. Use the “adopt an island” concept to 

promote Refuge awareness.

PI & SJI PI only  

e. Share office with another agency in the 

San Juan Islands (NPS at Friday Harbor; 

BLM on Lopez Island).

SJI ---  

f. Increase Project Leader/staff attendance 

at community and other agency meetings.

SJI 4-6 

meetings

8-10 

meetings

8-10 

meetings

g. Volunteers provide information to area 

visitors.

SJI ---  

h. Have a multi-function, live-aboard or 

on- island hosts/caretakers who will 

explain rules and regulations and provide 

other information.

SJI --- Seasonal Seasonal

PI Year round Year round Year round

i. Staffing commitment: Create a Refuge 

Manager position responsible for planning, 

law enforcement, maintenance, education, 

public relations, and volunteer supervision. 

Create a seasonal staff position. Station 

both in the San Juan Islands.

SJI Current 

Staff, 

approximately 20 

days per 

year

Permanent 

FTE 

Manager & 

seasonal 

FTE 

Ranger,

35-40 staff 

days/yr

Permanent 

FTE 

Manager & 

seasonal 

FTE Ranger,

30-35 staff 

days/yr

Rationale: Community knowledge of the Refuges, their key habitats and wildlife, will assist with 

conservation efforts within the Salish Sea. The strategies for achieving this objective will be undertaken 

primarily off-Refuge where a great many opportunities exist for cooperative actions with a variety of 

organizations that also care about these resources. In order to achieve this objective, additional staff, as 

identified, stationed in the San Juans will be necessary. 

Objective 7.3 - Outreach to the Boating and Aviation Communities 

Help boaters and airplane pilots in the area become more knowledgeable about the Refuges and their 

resources.

• >90% of area boaters know Protection Island is a NWR.

• >90% of pilots know which islands are part of the NWR and maintain a 2,000 foot minimum 

ceiling above Refuge islands.
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-54

• >80% of boaters know why it is important to maintain a 200 yard disturbance buffer around 

Protection Island NWR.

• >60% of area boaters know which rocks, islands, and islets are part of the San Juan Islands 

NWR.

• >70% of area boaters know why it is important to maintain a 200 yard disturbance buffer (or as 

close to 200 yards as possible) around Refuge islands in the San Juan Islands NWR.

• >70% of area boaters know that wildlife comes first in refuges.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Educate boating clubs, wildlife tour 

businesses, charters, and kayak groups, about 

“why a closer look hurts” wildlife.

PI & SJI --- 3 group 

events

1 group 

event

b. Increase boater contacts to teach “why a 

closer look hurts” wildlife.

PI 100 

contacts

200 

contacts

150 

contacts

SJI 20 

contacts

150 

contacts

100 

contacts

c. Promote Refuges in outdoor recreation and 

boating TV shows.

PI & SJI ---  ---

d. Write at least one article per year for a 

popular boating magazine that includes 

information on Refuge regulations. 

PI & SJI ---  

e. Work with entities that develop and update 

integrated navigational software, boater 

guides, and fishing regulations to include 

Refuge information in their products.

PI & SJI ---  

f. Work with NOAA to identify Refuge 

islands on charts and show 200 yard buffers.

PI & SJI ---  

g. Work with volunteers and partners (U.S. 

Coast Guard, Washington State Parks and 

Rec. Comm., WDFW, Sheriffs’ Office, Sound 

Watch, commercial cruise boats, etc.) to 

adequately patrol Refuge islands and to report 

incidences of non-compliance. 

PI & SJI minimal  

h. Distribute brochures and display posters in 

sporting goods and marine stores.

PI & SJI ---  

i. Increase marina visits and boater contacts. PI & SJI 10-20 

visits

150-200 

visits

100-150 

visits

j. Increase number of days per year spent 

maintaining signs (2-3 people).

SJI minimal 5-7 days 3-5 days

k. Implement a comprehensive sign plan 

which includes installation and maintenance 

of signs identifying closed islands where 

feasible. 

SJI No sign

plan

 

l. Implement a comprehensive sign plan 

which includes installation and maintenance 

of large format signs that ask boaters to stay 

200 yards away on up to 10 of the most 

sensitive islands.

SJI 15+ signs.

No sign 

plan

≤10 signs ≤10 signs

m. Increase Refuge law enforcement 

presence.

PI & SJI minimal 70 Days 70 Days

n. Work with partners to educate general 

transportation, military, and tourist aircraft 

PI & SJI minimal  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-55

operators regarding the impact of low-flying 

aircraft on wildlife.

o. Work with the FAA to assure that Refuge 

islands are designated on aeronautical charts.

PI & SJI ---  

Rationale: Because PI and SJI Refuges consist solely of islands and are primarily located in or adjacent 

to navigable waterways, commercial and recreational boaters have the potential to significantly impact 

Refuge resources. Over flights below 2,000 feet can also disturb wildlife (Hatch and Weseloh, 1999). 

Therefore it is important to target these particular audiences. Promoting an awareness of the Refuges’ 

locations and sensitivity to disturbance within the boating and aviation communities will result in greater 

protection of Refuge wildlife. 

Objective 7.4 - Education and Interpretation of Cultural and Paleontological Resources 

In partnership with the interested Tribe(s) and other preservation partners, develop an education and 

interpretation program for Refuge cultural and paleontological resources with the following attributes: 

• At least one Refuge interpretive product or program created that focuses primarily on 

interpretation of cultural and paleontological resources.

• All appropriate Refuge educational products include interpretation of cultural and 

paleontological resources.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Prepare interpretive media (e.g., pamphlets, 

signs, exhibits) that relate the cultural resources 

and Native American perspective as well as the 

Euroamerican settlement and use history for 

visitors.

PI & SJI ---  

b. Prepare environmental/cultural education 

materials for use in local schools covering the 

following cultural resource messages: 

paleontological resources, the discipline of 

archaeology, the perspective of Native Americans, 

the history of the area, and conservation of natural 

and cultural resources. These materials could 

include an artifact replica kit with hands-on 

activities and curriculum prepared in consultation 

with the local school district, historical societies, 

and the Tribe(s).

PI & SJI ---  

c. Consult with the Tribe(s) to identify the type of 

cultural resources information appropriate for 

public interpretation.

PI & SJI ---  

d. Develop an outreach program and materials so 

that the cultural resource message becomes part of 

cultural events in the area, including the State’s 

Archaeology Month, National Wildlife Refuge 

Week, and appropriate local festivals.

PI & SJI ---  

e. Develop partnerships with Tribes, educational 

institutions, and other partners for the 

interpretation of cultural and paleontological 

resources at the Refuge. 

PI & SJI ---  

f. Develop Museum Property inventory. Create 

storage and use plans for museum property.

PI & SJI ---  

Rationale: Interpretation of non-renewable cultural and paleontological resources is critical to instilling 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-56

a stewardship ethic among the public and others who encounter or manage them. The purposes of the 

cultural resource education and interpretive program are fourfold: (1) translate the results of cultural and 

paleontological research into media that can be understood and appreciated by a variety of publics, (2) 

engender an appreciation for the Native American culture and perspective on cultural resources, (3) 

relate the connection between cultural resources and natural resources and the role of humans in the 

environment (which is one of the goals of the National Wildlife Refuge System), and (4) instill an ethic 

for the conservation of our cultural heritage and paleontological resources, including archaeological sites 

and historic structures.

Museum property obtained from the Refuges currently exists at the Refuge headquarters and at the 

Burke Museum, Seattle, Washington. Their usefulness as educational and interpretive tools will be 

enhanced by developing a complete inventory, and a storage and use plan for current and potential future 

museum property. 

GOAL 8: Promote the wilderness character and experience of the San Juan Islands Wilderness 

Area.

Objective 8.1 Signs on Wilderness Islands

Preserve the wilderness character of islands designated as wilderness. 

• The “minimum tool” concept is used in selecting locations and sizes of signs.

• 10 or less islands have large format signs. 

• Signs (and associated education) are effective in identifying Refuge islands and preventing 

trespass. 

Strategies Applied to Achieve Objective Refuge/ Unit Alt A Alt B Alt C

a. Implement a comprehensive sign plan 

which will include number, sizes, locations, 

and text of signs in accordance with the 

comprehensive sign plan; see Appendix D.

PI & SJI ---  

b. Standardize the text and reduce the number 

of islands with large 200 yard “buffer” signs. 

SJI 15 islands, 

variable text

<10 

islands, 

standard 

text

<10 

islands, 

standard 

text

c. Reduce the number of wilderness 

designation signs. 

SJI Many 

Refuge units

Matia 

Island 

only

Matia 

Island only

d. Maintain wilderness sign at Matia 

trailhead. 

Matia   

e. On closed islands (excluding reefs), install 

Refuge boundary signs (with standard Service 

text) paired with a new sign that reads: 

“Island Closed, No Entry”.

SJI --- 15” x 20” 

signs –

most 

islands;

11” x 14” 

signs –

some 

islands.

22” x 28” 

signs –

few select 

islands

11” x 14” 

signs –

most 

islands.

f. Remove old sign posts, unneeded signs, and 

other human evidence. 

SJI   
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-57

Rationale: Section 4(b)(2) of The Wilderness Act of 1964 dictates that wilderness areas shall be 

administered so as to preserve their wilderness character. That includes minimizing non-natural 

features. There is a need to identify closed areas to protect wildlife. The Service will use the minimal 

tool concept and appropriate sight distances when determining the need for signs and their sizes. The 

standard Service sign text, “Area Beyond This Sign Closed,” will be replaced by more applicable 

“Island Closed, No Entry.” 

Objective 8.2 Wilderness Experience

Preserve the visitors’ wilderness experience with the following characteristics:

• Natural sights and sounds predominate.

• Maximum number of visitors at one time on Matia Island is <100.

Objective Management Indicator Refuge/Unit Alt A Alt B Alt C

Objective as written above applies to 

alternatives () or the alternative is modified 

by replacing bolded type above with the text 

in this row.

>100 

visitors 

<100 

visitors

<75 

visitors 

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Maintain a narrow and natural-appearing 

wilderness trail using only tools authorized for 

wilderness areas (e.g., no chainsaws). 

Matia   

b. Promote 2,000 foot aircraft ceiling over 

wilderness islands.

SJI   

c. Better enforcement of boat landings limited 

to Rolfe Cove dock and beach on Matia Island 

only. 

Matia not well 

enforced

 

d. Acquire leases and/or withdrawal of 

tidelands and bed-lands from DNR to better 

control unauthorized access from inter-tidal 

areas.

SJI ---  

e. Conduct garbage and marine debris cleanups.SJI   

f. Limit the size of commercial day-use 

groups to no more than 20 people.

Matia ---  

g. Number of authorized campsites on Matia 

Island.

Matia 6 sites 6 sites 4 sites

h. Maximum number of people per campsite. Matia 8 people 8 people 8 people

Rationale: The Wilderness Act of 1964 notes that the wilderness area should be managed to preserve 

the wilderness character of the area and maintain the purpose for which it was established. Limiting the 

number of visitors on Matia Island will help to maintain the wilderness characteristics. Protecting 

wilderness values enhances visitors’ experiences, promotes the purpose for which the Refuge was 

established, and meets the intent of the Wilderness Act.

Objective 8.3 Wilderness Education 

Integrate wilderness education into Refuge public use program with the following messages:

• Visitors to Matia know that they are on a wilderness Refuge island.

• Visitors to the San Juan Archipelago know that the Refuge has islands that are designated 

wilderness.

• Visitors understand that the Wilderness Act preserves federal lands “...where the earth and its 

community of life are untrammeled by man...” 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-58

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Develop interpretive panels on Matia that 

illustrate the wilderness theme within an 

island ecology.

Matia ---  

b. Develop interpretive panels for off-Refuge 

education about wilderness values of Refuge 

islands.

SJI ---  

c. Promote volunteer opportunities for 

stewardship projects that highlight the 

wilderness character of the Refuge islands.

SJI ---  

d. Develop an outreach component of the 

public use program for schools to connect 

the wildlife resources of the Refuge and the 

wilderness concept.

SJI ---  

Rationale: The San Juan Island Wilderness was one of the first designated island wildernesses which 

are unique in the National Wilderness Preservation System. 

The Wilderness Act of 1964 dictates that wilderness areas shall be devoted to public purposes including 

“...scientific, educational, conservation, and historical use.” Protecting wilderness values enhances 

visitors’ experiences, which promotes the purpose of the Wilderness Act and satisfies the mission of the 

National Wildlife Refuge System. The Fish and Wildlife Service manual 610 FW2 states that 

Interpretation provides opportunities for people to forge intellectual and emotional connections to the 

meanings inherent in wilderness resources. 

Goal 9: Encourage and support collection of scientific information that assists in managing 

Refuge resources and contributes to a greater understanding of the natural and cultural 

resources of the Salish Sea ecosystem.

Objective 9.1 Management of the Scientific Research Program

Enhance the scientific research program while continuing to minimize disturbance to Refuge wildlife 

and habitats.

• 80% of research projects on the Refuge inform management.

• Reduced footprint of research facilities by 30%.

• Enhanced coordination between Refuge staff and research partners.

Strategies Applied to Achieve 

Objective Refuge/Unit Alt A Alt B Alt C

a. Projects with high level of 

applicability to Refuge management 

or scientific knowledge needs

PI & SJI 3 projects 

for both

8 projects 

through the 

term of the 

CCP

6 projects

through the 

term of the 

CCP

b. Establish a research committee to 

develop proposals to meet priority 

information needs identified by 

management.

PI & SJI ---  

c. Reduce footprint of research 

facilities of higher human activity to 

minimize disturbance to wildlife by 

developing a centralized research 

facility.

PI Old research 

housing in 

two 

locations

Updated 

research 

facility in one 

location

Updated 

research 

facility in one 

location

d. Develop handbook of Refuge PI ---  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-59

guidelines and distribute to all 

authorized people on islands to 

prevent disturbance or trampling.

e. Require annual reporting/data on 

all studies on Refuge lands. 

PI & SJI   

f. Hire 1 additional full-time 

biologist to conduct research, 

monitoring, and restoration.

PI & SJI ---  

g. Provide adequate equipment and 

boat support for biological program 

(e.g., boat moored in Sequim and 

seasonally in SJI’s).

PI & SJI Boat 

moored in 

Sequim

 

Rationale: The Protection Island National Wildlife Refuge Act states that scientific research is a refuge 

purpose. Refuge islands provide a relatively undisturbed environment for studies; however, due to the 

physical environment, access is limited. 

Refuge plans and actions based on research and monitoring provide an informed approach to biological 

programs. A research committee would help identify priority studies that contribute to information 

needs of management and research on Refuge lands. The majority of research projects will be designed 

to answer specific Refuge management questions. This committee will consist of staff from the Refuge, 

agencies, academia, research organizations, or Tribes. Research proposals would be reviewed and 

approved by Refuge staff. For the Service to evaluate the effectiveness of management and/or research 

projects, all raw data from studies conducted on the Refuge must be submitted to the Refuge for internal 

use. No raw data will be shared with outside parties without consultation with researchers. 

There currently are two buildings used mainly for research needs that are situated on separate sections of 

the island and are in need of updates. Co-locating researchers in an updated structure would facilitate 

cooperation and maintenance and would help to reduce the human footprint on the island. 

Objective 9.2 Conduct or Facilitate Research Projects

For the term of the CCP, implement or facilitate high quality, standardized feasibility studies and 

research projects that provide the best science for habitat and wildlife management on and off refuges. 

Scientific findings gained through these projects will assist the Service and others in assessing the 

impacts of climate change. In addition, these data would allow managers to identify or refine habitat 

and wildlife management actions and expand knowledge regarding life-history needs of species and 

species groups. Research will also reduce uncertainty regarding wildlife and habitat responses to Refuge 

management actions in order to achieve desired outcomes reflected in resource management objectives 

and to facilitate adaptive management. These research projects have the following attributes:

• Adhere to scientifically defensible protocols for data collection, where available and applicable, 

in order to develop the best science for resource management.

• Data collection techniques should have minimal animal mortality or disturbance and minimal 

habitat destruction.

• Collect the minimum number of samples (e.g., water, plants, macroinvertebrates, vertebrates) 

and repetitions (survey visits) to meet statistical analysis requirements for identification and/or 

experimentation in order to minimize long-term or cumulative impacts.

• Utilize proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary, to minimize the potential spread or introduction of invasive species.

• Often result in peer review articles in scientific journals and publications and/or symposiums.
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-60

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Conduct a pre- and post-deer removal assessment of 

impacts to seabird nesting habitats and other Refuge 

resources. 

PI ---  

b. Conduct island-wide rhinoceros auklet breeding 

success survey before and after habitat restoration.

PI ---  

c. Conduct studies to determine optimal plants for 

restoration of bluff habitat within test plots established 

on the edges of the colony in the grasslands. Monitor 

results using standardized techniques.

PI ---  

d. Establish representative sites to determine vegetation 

types to the Willamette Valley grasslands/savannah 

using standardized techniques, such as transects, and 

monitor every 5 -7 years after that.

PI & SJI ---  

e. Conduct studies to monitor glaucous-winged gull 

breeding success and predation in and around 

restoration areas pre- and post-restoration.

PI ---  

f. Determine hydrology of all Refuge wetlands. PI & SJI ---  

g. Use established and current protocols to collect 

information on demographic parameters that may be 

limited due to threats for the following seabirds: 

rhinoceros auklet, black oystercatcher, pigeon guillemot 

(PIGU), glaucous-winged gull (GWGU), tufted puffin,

double-crested or pelagic cormorants.

PI PIGU 

and 

GWGU

 

SJI ---  

h. Coordinate with NOAA Fisheries and WDFW to 

increase collection of abundance and distribution data 

for harbor and elephant seals, which could include 

tagging breeding elephant seals on Smith, Minor, and 

Protection Islands. 

PI & SJI harbor 

seal

 ---

i. Conduct a study on erosion rates of bluffs and 

deposition on spit habitats on Protection, Smith, and 

Minor islands.

PI, Smith, 

Minor

---  ---

Rationale: Most research on the Refuge will be used to address Refuge-specific wildlife conservation 

questions. Other research has broader applicability, such as grassland restoration methodology on 

islands and documenting and predicting impacts associated with climate change. As our knowledge of 

threats to key ecological attributes increases, management actions become more efficient and effective. 

Seabird conservation and management within the refuges is based upon statistically viable scientific 

research combined with long-term monitoring. Seabirds are relatively easy to study within the breeding 

colony and can be used to strategically monitor and detect changes in ocean conditions that affect 

changes in marine food webs. Long-term, regional, or local research using seabirds as indicators of 

ocean conditions can be used to document change in the larger marine environment as well as track 

change in populations at the regional or local scale. With increasing threats from disturbance, predation,

and habitat destruction or degradation in the Salish Sea, the Refuge’s facilitation of research on 

demographic parameters of focal resources is important in making informed management decisions with 

the best scientific data possible. 

The last three strategies listed above will provide valuable data to the help meet the Service’s 

commitments to address climate change (USFWS 2009a). One of the greatest challenges currently 

facing the National Wildlife Refuge System and wildlife populations in the 21st century is climate 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-61

change. In addition, it is clear that changes in the environment have the potential to have negative social 

and economic impacts. Research focused on qualifying the impacts of climate change on species and 

habitats is complex and difficult, and will require cooperation from numerous public and private 

organizations within the region.

Objective 9.3 Conduct Surveys 

Throughout the life of the CCP, conduct high priority inventory and monitoring (survey) activities 

that evaluate resource management and public-use activities to facilitate adaptive management. These 

surveys may be necessary to assess the status of wildlife and habitats at the local and regional scale. 

Therefore, they should be designed to contribute to the enhancement, protection, use, preservation,

and management of wildlife populations and their habitats on- and off-refuge lands. Specifically, they 

can be used to evaluate achievement of resource management objectives identified under Goals 1-5 in 

this CCP. In addition, the resulting data would allow the Service and partners to track changes 

associated with climate change. These surveys have the following attributes:

• Adhere to scientifically defensible protocols for data collection, where available and 

applicable, in order to develop the best science for resource management.

• Collect the minimum number of samples (e.g., water, plants, macroinvertebrates, vertebrates) 

and repetitions (survey visits) to meet statistical analysis requirements for identification 

and/or experimentation in order to minimize long-term or cumulative impacts.

• Data collection techniques should have minimal animal mortality or disturbance and minimal 

habitat destruction. 

• Utilize proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary, to minimize the potential spreads or introduction of invasive species.

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Continue San Juan Summer Surveys annually 

(June).

SJI   

b. In late May-early June, conduct boat-based surveys 

for breeding black oystercatchers on islands.

PI & SJI ---  

c. Conduct surveys for presence of non-native rats, 

rabbits, red foxes, feral cats and dogs, and use 

appropriate tools to maintain zero population levels 

using visual area searches, track plates, and bait 

stations where necessary.

PI & SJI ---  

d. Conduct a survey of native mammalian predators 

(e.g., raccoon, mink, and river otter), determine 

impacts and if necessary, develop management actions 

under a separate step-down management plan.

PI & SJI ---  

e. Conduct boat-based winter wildlife surveys from 

December through March.

PI & SJI ---  ---

f. Collect distribution and abundance data of burrow 

nesting seabirds (rhinoceros auklet, tufted puffin and 

pigeon guillemot) throughout the Salish Sea ecosystem 

at periodic intervals.

PI & SJI ---  

g. Conduct periodic, ecosystem-wide monitoring 

(presence/absence) for surface nesting seabirds 

(glaucous-winged gull, pelagic and double-crested 

cormorants, black oystercatcher). 

PI and SJI ---  

h. Integrate data into a regional database for trend 

analysis.

PI & SJI ---  

i. Conduct periodic surveys for Taylor’s checkerspot

butterflies on PI and island marble and valley 

PI and SJI ---  
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-62

silverspot butterflies in the San Juan Islands NWR.

j. Continue to conduct Christmas Bird Counts (CBC) 

and initiate breeding bird surveys (BBS) for passerines.

PI CBC  CBC

k. Coordinate with partners to conduct surveys for bald 

eagles according to the Bald Eagle Delisting 

Monitoring Plan.

PI and SJI ---  ---

l. Conduct periodic surveys to ensure success of 

restoration projects.

PI and SJI PI  

m. Conduct study to determine the best restoration 

techniques within test plots and monitor prior to full 

scale restoration. 

PI ---  

n. Conduct studies to determine which native plant 

species will provide the best erosion control 

throughout the year. 

PI ---  

o. Conduct annual surveys for marine debris on or 

around all Refuge islands – annually on PI and 14 

islands in SJI per year.

PI and SJI PI  

Rationale: Under the National Wildlife Refuge System Improvement Act of 1997 (16 USC 668), 

refuges are required to “monitor the status and trends of fish, wildlife, and plants in each refuge.” The 

strategies listed above represent ongoing or new monitoring efforts of value, to the refuge or the 

region, necessary to meet that mandate. These efforts have historically provided a strong foundation 

from which to assess the status of priority species and guide management actions. One goal of 

monitoring is to evaluate, regulate, guide, or investigate the success of the Complex’s wildlife and 

land management actions. To meet this goal, the Service must conduct periodic, long-term 

monitoring of high priority habitats and wildlife. The complexity, costs, and scope required to 

effectively assess the conservation status of a species often exceeds the scale and abilities of 

individual refuges, therefore cooperative programs may be necessary to effectively implement these 

efforts. Working cooperatively assures that data are collected at an adequate scale to assess status and 

trends of focal resources. Survey emphasis will be placed on species, groups of species, or 

communities that are cited in the refuge’s enabling legislation, establishing documentation or 

contained in international, national, regional, state, or ecosystem conservation plans or acts and those 

of importance due to federal or state listing as endangered, threatened, or species of concern (Service 

Policies 620 FW1, 701 FW2). 

In order to meet the Service’s commitments to respond to the threats posed by climate change, field 

stations are charged with identifying species and habitat priorities that must be addressed, 

implementing strategies, and monitoring results (USFWS 2009a). In order to identify priority species 

and habitats across the NWRS and follow through with monitoring results, the Service is developing a 

Strategic Plan for Inventories and Monitoring on NWRs which will guide survey activities on refuges 

(USFWS 2010). Ecosystem-wide surveys and integrating data into a larger database (strategies e-g) 

will help meet that need by providing a bigger picture from which to assess species and habitat trends. 

The Service has conducted seabird surveys within Pacific Coast refuges for over 30 years (Naughton 

et al. 2007). These large-scale studies (colony counts) have proven invaluable in providing managers 

with the data necessary to 1) mitigate effects of oil spill events, 2) close gill net fisheries in California,

and 3) predict effects of climate change on fisheries stocks (e.g., Cassin’s Auklets as covariates in 

forecasting salmon returns). Monitoring of non-listed seabirds and threats to those species is 

prioritized and guided by the Service’s Pacific Regional Seabird Conservation Plan (USFWS 2005). 

A high priority of this plan was to “Design and implement a comprehensive seabird inventory and 

monitoring program that is science based and statistically rigorous” and to recognize the importance 

of refuges to the productivity and survival of seabirds. As a result, a large-scale monitoring plan is 

under development to guide Service inventory and monitoring efforts along the Pacific Coast, several 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-63

islands within these Refuges have been identified as important sample sites for long-term, coordinated 

demographic monitoring.

Objective 9.4 Complete Scientific Assessments

Throughout the life of the CCP, conduct scientific assessments to provide baseline information to 

expand knowledge regarding the status of Refuge resources and better inform management decisions. 

These scientific assessments will contribute to the development of Refuge resource objectives and 

they would also be used to facilitate habitat restoration through selection of appropriated habitat 

management strategies based upon site-specific conditions. In addition, they may provide the first 

step in tracking changes associated with climate change. 

• Utilize accepted standards, where available, for completion of assessments.

• Scale (1/4 of refuge islands annually) and accuracy of assessments would be appropriate for 

development and implementation of Refuge habitat and wildlife management actions. 

Objective Management Indicators Refuge/Unit Alt A Alt B Alt C

The following is a prioritized list of scientific 

assessments to support resource management 

decisions on the Refuges.

PI & SJI

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Continue initial inventory of plant species started 

by TNC and UW in 2005. Map locations of rare 

plants or communities and create overlay. Share 

information with Washington Natural Heritage 

Program and appropriate county extension office 

weed coordinator.

PI & SJI   

b. Coordinate with partners to conduct an inventory 

of reptiles and amphibians in forested and wetland 

habitats to determine presence of rare species, such 

as sharp-tailed or bull snake. Begin survey on 

Matia Island and, if found, document habitat 

conditions used by these species.

SJI FWS 

amphibian 

survey on 

Matia

 ---

c. Integrate data into a regional database for trend 

analysis.

PI & SJI ---  ---

d. Survey all formerly occupied Refuge islands (PI 

and Smith) and islands supporting or formerly 

supporting Aids to Navigation for presence of 

contaminants.

PI & SJI ---  

e. Assess levels of contamination and determine and 

initiate management action if deemed necessary. 

PI & SJI ---  

Rationale: Completion of scientific assessments is necessary to meet the mandate of the National 

Wildlife Refuge System Improvement Act of 1997 to “...ensure that the biological integrity, diversity 

and environmental health of the system are maintained...” (PL 105-57). Focused inventory efforts 

can serve as a base to develop a statistically valid framework for “...monitoring the status and trends 

of fish, wildlife and plants in each refuge...” (PL 105-57, Service Policy 701 FW 2). 

 

Irregular seabird and marine mammal inventories have been conducted in the past. However, little to 

no baseline data is available for other wildlife or plant species found on refuges. Identifying and 

mapping refuge resources is necessary to protect, maintain, and restore biological diversity. Many of 

the habitat types on the refuges are regionally declining, for example less than 10% of the historic 

native grassland/savanna habitat remains in the Puget Sound (WDFW 2005). 
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-64

Collection of baseline data is also necessary to begin the assessment of climate change impacts,

particularly for flora and fauna not previously emphasized by the refuges, yet vulnerable to climate 

change such as reptiles and amphibians (USFWS 2009a). In order to identify priority species and 

habitats across the NWRS and follow through with monitoring results, the Service is developing a 

Strategic Plan for Inventories and Monitoring on NWRs which will guide survey activities on refuges 

(USFWS 2010). 

Objective 9.5 Cultural Resources Inventory

Prioritize and conduct systematic baseline cultural resource surveys using the following guidelines: 

• At least 1/3 of un-surveyed Refuge lands systematically surveyed in 5 years.

• At least 2/3 of un-surveyed Refuge lands systematically surveyed in 10 years.

• All Refuge lands systematically surveyed in 15 years.

• Relocate and resurvey known prehistoric sites at least once every 5 years.

Objective Management indicators Refuge/Unit Alt A Alt B Alt C

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Conduct project-specific surveys of NWR lands. PI & SJI   

b. Conduct systematic survey of NWR lands that have a 

high potential for the existence of archaeological 

materials, based on previous research (e.g., Puffin 

Island, Ripple Island), as well as lands that have high 

public use or potential threats to cultural resources (e.g.,

Protection Island, Turn Island, Matia Island, Smith 

Island, Minor Island). 

PI & SJI ---  

c. Relocate the six known prehistoric sites and update 

documentation, conduct evaluations for eligibility to the 

National Register of Historic Places (NRHP), and 

identify threats and impacts to eligible sites. 

SJI ---  

d. Reevaluate the listing of the Smith Island Light 

Station (which is listed on the NRHP but has since 

collapsed into the ocean) and associated buildings, and 

consult with the Coast Guard and State Historic 

Preservation Office regarding building removal.

SJI ---  

e. Develop a GIS layer for cultural resources that can be 

used with other GIS layers for the Refuges, yet contains 

appropriate security features to protect sensitive 

information.

PI & SJI ---  

f. Develop partnerships with Tribes, educational 

institutions, and other preservation partners for cultural 

resources inventory, evaluation, and project monitoring, 

consistent with the regulations of the National Historic 

Preservation Act. 

PI & SJI ---  

g. Update the list of priority survey sites and research 

projects identified above at least once every 5 years.

PI & SJI ---  

Rationale: Various federal historic preservation laws and regulations require the Service to 

implement the kind of program described under this objective. Proactive survey, inventory, and 

research projects can help ensure that we have the information needed to understand and protect 
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Chapter 2 Alternatives, Goals, Objectives, and Strategies 2-65

cultural resource values and meet the requirements of the National Historic Preservation Act (NHPA). 

Locations and timing of cultural resource surveys will be scheduled to minimize impacts to wildlife 

and habitats. By surveying at least 1/3 of un-surveyed and accessible Refuge acres every 5 years 

until all of the Refuges have been adequately surveyed, it is reasonable to assume that the majority of 

observable cultural resources on the Refuges have been located, surveyed, and evaluated. 

Relocating and resurveying known cultural resource sites at least once every 5 years will enable 

assessment of any changes to the sites and identify mitigation needs. 

Objective 9.6 Paleontological Resources Inventory

Paleontological Resources Inventory 

• Completed paleontological resources survey on Protection Island

Alternatives Refuge/Unit Alt A Alt B Alt C

Strategies Applied to Achieve Objective Refuge/Unit Alt A Alt B Alt C

a. Conduct systematic survey of Protection Island for 

the existence of paleontological resources based on 

what is known.

PI ---  

b. Develop a GIS layer for paleontological resources 

that can be used with other GIS layers for the 

Refuges, yet contains appropriate security features to 

protect sensitive information.

PI ---  

Rationale: The Paleontological Resources Preservation Act of 2009 (PRPA) requires Federal 

agencies to manage and protect paleontological resources on Federal land using scientific principles 

and expertise. Paleontological resources have been identified as eroding out of the margins of 

Protection Island, however, a systematic survey has not been completed. Proactive survey, inventory 

and research projects can help ensure that we have the information needed to understand, protect, and 

manage the paleontological resource values and meet the requirements of the PRPA. Locations and 

timing of paleontological resource surveys will be scheduled to minimize impacts to wildlife and 

habitats. 

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glaucous-winged gulls breeding on Protection Island in 2005. Internal report to the 

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Gaston, A.J., and S.B.C. Dechesne. 1996. Rhinoceros Auklet (Cerorhinca monocerata). In The Birds of 

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Hatch, J.J. and D.V. Weseloh. 1999. Double-crested Cormorant (Phalacrocorax auritus) In The 

Birds of North America, No. 708 (A. Poole and F. Gill, eds.). The Birds of North 

America, Inc., Philadelphia, PA. 

Hayward, J. L. and S. M. Henson. 2008. Basic data on Protection Island biota with possible 

relevance to comprehensive conservation plan (ccp) development. Andrews University, 

Michigan.

Hodum, P., and M. Wainstein. 2002. Biology and conservation of the Juan Fernandez archipelago 

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on October 14, 2009.

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breeding seabirds on the California Channel and Northwestern Baja California Islands. Colonial 

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Accessed from http://www.jstor.org/stable/4000414 on January 15, 2010.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 3. Physical Environment 3-1

Chapter 3. Physical Environment 

3.1 Climate and Climate Change

3.1.1 General Climate Conditions

The climate in the Protection Island and San Juan Islands National Wildlife Refuges (NWRs) is a mild, 

mid-latitude, west coast marine type. The westerly winds from the ocean play a significant role in 

moderating the climate in these refuges. Summers are generally cool and dry while winters are mild but 

moist and cloudy, with most of the precipitation falling between November and January (USDA 1962, 

WRCC 2010a). Extremes in temperature are rare at any season. Annual precipitation in the region is low 

due to the rain shadow cast by the Olympic Mountains and the extension of the Coastal Range on 

Vancouver Island (Figure 3-1). Consequently, when surrounding areas are experiencing moderate 

rainfall, Protection Island and much of the San Juan Archipelago often receive drizzle or light rain. 

Snowfall is rare or light. These islands receive slightly more sunshine and have less cloudiness than 

nearby Salish Sea locations. During the latter half of the summer and in the early fall, fog banks from 

over the ocean and the Strait of Juan de Fuca settle over these low elevation islands, causing considerable 

fog and morning cloudiness (WRCC 2010a).

There is a growing body of scientific evidence demonstrating that the world climate is changing and that 

changes in atmospheric composition due to human activity are the drivers for global warming (Bierbaum 

et al. 2007, IPCC 2007). Average annual global air temperatures on the earth’s surface have increased by 

1.3 degrees F since the mid 19th century. Furthermore, the increasing trend in global temperatures over 

the last 50 years is approximately twice the trend of the previous 50 years. From the years 1995 to 2006, 

global surface temperatures have been the warmest on record since 1850 (IPCC 2007). The global 

climate system, in turn, controls regional and local-scale climate conditions in the Pacific Northwest. 

Detailed in the following sections, projected impacts to the region encompassing the refuges include 

changes in seasonal temperatures, precipitation, extreme weather events, oceanic conditions, and sea level 

rise.

Climate Change Trends

3.1.2 Air Temperatures

It is rare for the San Juan Islands or Protection Island to experience temperatures below freezing. It is 

only in the extreme occurrences that temperatures have been recorded below 32 degrees F; on average, 

they are above freezing. No days are on record with temperatures at or below 0 degrees F (WRCC 2010b, 

WRCC 2010c).

Temperature data have been consistently collected since July 1891 at the Olga 2 SE station (number 

456096), located on the southern shores of Orcas Island. Although Orcas Island is not within the San 

Juan Islands NWR, the proximity of the station provides valuable regional data. Table 3-1 provides a 

summary of the 118-year period of record. 

There is no climate/weather station established on Protection Island; however, data have been consistently 

collected and recorded since October 1891 in Port Townsend, Washington (number 456678), 

approximately 8 miles east of Protection Island. Table 3-1 provides a summary of the 118-year period of 

record. 
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3-2 Chapter 3. Physical Environment 

Data have also been collected for a brief time period at buoy stations. Table 3-1 summarizes data from 

both the Western Regional Climate Center and the National Data Buoy Center for Smith Island, located in 

the southern extreme of the San Juan Islands NWR. 

Temperatures

Table 3-1. Air temperature summaries near the Protection Island and San Juan Islands NWRs

(NOAA 2007a, WRCC 2010b, WRCC 2010c).

(degrees F)

Orcas Island a Smith Island

July 1891 – Dec. 2009 Jan. 1984 – Dec. 2001

Port Townsend b

Oct. 1891 – Dec 2009

Average Monthly Temperature – Low 35 42 37

Average Monthly Temperature – High 70 56 72

Monthly Mean Winter Temperature – High 45.0 56.7 45.4

Monthly Mean Winter Temperature – Low 34.3 12.7 35.2

Monthly Mean Summer Temperature – High 62.3 80.1 64.8

Monthly Mean Summer Temperature – Low 56.2 44.4 57.6

Daily Minimum Extreme – Low -8 N/A 5

Daily Minimum Extreme – High 40 N/A 40

Daily Maximum Extreme – Low 66 N/A 61

Daily Maximum Extreme – High 92 N/A 96

a. Orcas Island air temperature data is representative of northern San Juan Islands air temperature.

b. Port Townsend air temperature data is representative Protection Island air temperature. 

Leung and Qian (2003) modeled the changes in seasonal and extreme temperatures in the Salish Sea for 

the 105-year period from 1995 to 2100. The study area included the drainages around the Strait of 

Georgia, southern Vancouver Island, the British Columbia lower mainland, Puget Sound, the northern 

Olympic Peninsula, and west of the Cascade Range in Washington State. Modeling results, based on a 

110-year high-resolution monthly climate time series, indicate that throughout the Salish Sea, the 

warming trend associated with global climate change is approximately 2.7 to 4.5 degrees F (1.5-2.5

degrees C) (Leung and Qian 2003). Mote et al. (2003) observed that the Pacific Northwest region 

experienced warming of approximately 1.5 degrees F (0.8 degrees C) during the 20th century. Using data 

derived from eight climate models, further warming of 0.9-4.5 degrees F (0.5-2.5 degrees C) was 

projected by the 2020s and 2.7-5.8 degrees F (1.5-3.2 degrees C) by the 2040s. The warming trends 

modeled by Leung and Qian are similar to the average estimated temperature increases modeled by Mote 

et al.

Future Trends

3.1.3 Precipitation

Protection Island and much of the San Juan Islands are located in the “rain shadow” of the Olympic 

Mountains. The rain shadow is an area that extends east from Port Angeles toward Everett and north into 

the San Juan Islands (Bach 2004). The annual average precipitation map of Washington (Figure 3.1) 

depicts this area. 
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Chapter 3. Physical Environment 3-3

Figure 3.1 Washington State average annual precipitation from 1971 to 2000.

The discussion below includes data from the Orcas Island (Olga 2 SE) and the Port Townsend climate 

stations. The Orcas Island station is located just north of the rain shadow and the Port Townsend station 

is located within the rain shadow. Precipitation data have not been recorded at the National Data Buoy 

Center stations; however precipitation data were historically collected for a brief period (nine years) from 

the Richardson 3 SE Lopez station (station 457010), located on the southern shore of Lopez Island. The 

monthly and annual precipitation averages (May 1949 through July 1958) from Lopez Island are similar 

to the Port Townsend data (WRCC 2007). Precipitation data for Orcas Island and Port Townsend is 

summarized in Table 3.2.

The majority of precipitation in the northern San Juan Islands occurs during late fall and early winter, in 

the months of November and December. Nearly 30 percent of the annual precipitation occurs during 

these two months; January, the third wettest month of the year, brings another 13 percent. On average, 

only two days per year experience more than 0.50 inch of precipitation and only one day greater than 1.00 

inch (WRCC 2010c). 

Most precipitation in the southern San Juan Islands and Protection Island falls in November, December, 

and January. Roughly 38 percent of the annual precipitation occurs during these three months. On 

average, only one day each year experiences 0.50 inch or more of precipitation and less than one day in a 

year experiences 1.0 inch or more (WRCC 2010b).
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3-4 Chapter 3. Physical Environment 

Table 3-2. Precipitation summaries near the Protection Island and San Juan Islands NWRs

(WRCC 2010b, WRCC 2010c).

. 

(inches)

Precipitation Orcas Island

July 1891 – Dec. 2009

a Port Townsend

Oct. 1891 – Dec 2009

b

Average Annual Precipitation 28.93 18.74

Average Annual Snowfall 6.7 5.4

Average Monthly Snowfall Range (winter) 0.5 to 2.5 0.5 to 1.7

Highest Annual Snowfall 53.0 (1916) 26.7 (1950)

Highest Monthly Snowfall 35.0 (February 1916) 32.6 (February 1950)

Wettest Year on Record 37.89 (1917) 27.47 (1948)

Driest Year on Record 15.09 (1929) 12.97 (1952)

Wettest Season on Record 21.78 (winter 1918) 11.53 (1916)

Driest Season on Record 0.62 (summer 1938) 0.86 (1945)

a. Orcas Island precipitation data is representative of northern San Juan Islands precipitation.

b. Port Townsend precipitation data is representative of Protection Island precipitation. 

On a global scale, warmer temperatures are predicted to lead to a more vigorous hydrologic cycle, 

translating to more severe droughts and/or floods (IPCC 1996). Observations of Pacific Northwest 

precipitation trends through the 20th century indicate a region-wide increase since 1920 (CIG 2004). The 

median value of the increase throughout the region was 22 percent, with the highest increase in Northeast 

Washington and British Columbia. Mote et al. (2003 as cited in CIG 2004) projected a further regionwide increase in precipitation except in the summer (please refer to the Air Temperature section for 

further discussion). Average projected increases for the 2020s were 8 percent during the October to 

March period and 4 percent for the April to September period. The same average projections for the 

2040s were 9 percent and 2 percent, respectively. However, the regional climate model applied by Leung 

and Qian (2003) to the Salish Sea, a subarea of the Pacific Northwest, predicts an inconsequential change 

in precipitation for the immediate region of the two refuges. It is important to note that the one 

conclusion shared by researchers is that there is greater uncertainty in precipitation projections than that 

of temperature predictions and models (Leung and Qian 2003, CIG 2004, Bach 2004, Salathé et al. 2009). 

As an illustration, a comparison of recent Pacific Northwest climate model simulations indicated a 

weighted annual mean change in precipitation of nearly zero through 2100; however, the individual 

models produced changes ranging from −10 percent to +20 percent by 2080. In addition, there is no 

correlation between temperature change and precipitation change in the Pacific Northwest, although there 

is a correlation with global models. Researchers have consistently found that regional climate model 

simulations yield an increase in the measures of extreme precipitation (Salathé et al. 2009).

Future Trends

3.1.4 Wind

During the spring and summer, the semi-permanent low-pressure cell over the North Pacific Ocean 

becomes weak and moves north beyond the Aleutian Islands. Meanwhile, a high-pressure area spreads 

over the North Pacific Ocean. Air circulates in a clockwise direction around the high-pressure cell 

bringing prevailing westerly and northwesterly winds. This seasonal flow is comparatively dry, cool, and 

stable (WRCC 2010a).

In the fall and winter, the high-pressure cell weakens and moves southward while the Aleutian lowpressure cell intensifies and migrates southward as well. It reaches its maximum intensity in midwinter. 
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Chapter 3. Physical Environment 3-5

Air movement around the low-pressure cell is in a counter-clockwise direction, bringing southwesterly 

and westerly prevailing winds to the region of the northeast Olympic Mountains and the San Juan Islands. 

The air mass over the ocean is moist and near the temperature of the water. As it moves inland, it cools 

and condenses, bringing the beginning of the wet season in October (WRCC 2010a).

The Friday Harbor (FRDW1), New Dungeness (Hein Bank [46088]), and Port Townsend (PTWW1) data 

buoys have not reported usable wind data for the brief periods of record available. Likewise, the climate 

summary data for Orcas Island (Olga 2 SE) and Port Townsend weather stations do not include wind data. 

Therefore, wind data from the Port Angeles and Friday Harbor airports have been used to draw 

generalizations about wind activity in/on Protection Island and the San Juan Islands, respectively. Wind 

data collected from the Smith Island station between 1984 and 2001 provide valuable information specific 

to the Strait of Juan de Fuca and is discussed below as well. Table 3-3 provides a summary of data from 

all three locations.

Prevailing winds at Friday Harbor Airport are typically from the southeast; however, a definite shift takes 

place in April with winds changing to southwesterly through July (WRCC 2010d). Average monthly 

wind speeds are lowest in September and highest in December (WRCC 2010e). Prevailing winds at Port 

Angeles Airport are generally from the west; however, winds come from the southwest during the winter 

months (WRCC 2010d). Average monthly speeds are higher in the summer than in the fall and winter 

(WRCC 2010e). 

The historical data from the Smith Island data buoy cover wind speed data for seventeen years (1984 -

2001). Average monthly speeds were lowest in September and highest in December, and wind gusts up 

to 62.4 knots (71.8 MPH) were recorded in March 1997 (NOAA 2007a).

Table 3-3. Wind data summaries for three locations within the Protection Island and San Juan 

Islands NWRs (NOAA 2007a, WRCC 2010d, WRCC 2010e).

Friday Harbor Port Angeles Smith Island

Prevailing Wind Direction SE/SW W/SW Not Reported

Average Annual Wind Speed 5.8 mph 5.2 mph 9.8 knots

Average Monthly Wind Speed Range 3.6 – 7.9 mph 4.2 – 6.6 mph 6.7 – 12.4 knots

Maximum Monthly Average Wind Speed Not Reported Not Reported 51.1 knots

(Nov. 1991)

Washington does not experience hurricanes, and tornadoes in western Washington are very infrequent, 

especially in these island environments. The state experiences an average of two tornadoes per year. 

Likewise, thunderstorms are generally not severe and do not pose a significant threat.

3.2 Oceanography and Climate Change

3.2.1 Ocean Currents and Upwelling

Ocean currents, horizontal movement of seawater at the ocean’s surface, are a result of frictional stress at 

the interface between the ocean and the winds circulating above its surface. Large ocean currents are 

constrained by the continental landmasses bordering the ocean basins, which cause the currents to 

develop nearly closed circular patterns; these currents flow at relatively high rates. The two major 

currents influencing the waters off the U.S. west coast are the North Pacific Current (also known as the 

North Pacific Drift) and the Alaska Current (Figure 3-2) (Pidwirny 2006, AMS 2005). 
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3-6 Chapter 3. Physical Environment 

Figure 3-2. Global ocean (surface) currents (AMS 2005).

In addition to global surface currents, slower-moving global sub-surface currents are present; they are 

driven by differences in seawater density. In the North Pacific, a sub-surface current flows north from 

Antarctica, bringing deep, cold, nutrient-rich waters to the surface in areas of upwelling, before making a 

clockwise rotation in the Pacific Ocean and moving back to the east (Figure 3-3). During typical 

summers, cold, nutrient-rich waters also intrude upon the coasts of Washington and British Columbia in 

areas of upwelling. Upwelling is an important process that brings cold, nutrient-rich water into coastal 

systems and supports biological processes from microscopic plankton to whales, fishes, and seabirds 

(Banas et al. 1999, Pidwirny 2006). 

Although global ocean currents affect the San Juan Islands and Protection Island, local physical 

oceanography has a great influence on the currents and upwellings in and around the two refuges. Both 

refuges are within the Georgia-Fuca system, a complex waterway comprising the Strait of Georgia, the 

San Juan Channel, and the Strait of Juan de Fuca. The Georgia-Fuca system is the estuarine link between 

freshwater runoff from the continent and saltwater from the Pacific Ocean (Banas et al. 1999).

Estuarine circulation is driven by the pressure gradient created at the freshwater sources. The major 

freshwater inflows occur at the mouth of the Fraser River in the Strait of Georgia and the mouth of the 

Skagit River in north Puget Sound. Lighter freshwater flows into the Georgia-Fuca system and out over 

the denser ocean saltwater. This pressure gradient (created by fresh water over salt water), results in a net 

flow of water out of the estuary and into the ocean (Banas et al. 1999). 

In addition to transporting nutrients to surface waters, upwelled waters along the coast of Washington and 

British Columbia flow into the Strait of Juan de Fuca, affecting density stratification and water properties 

of the Georgia-Fuca system. Atmospheric changes can also affect circulation. Prevailing winds and their

associated pressure systems can cause water to collect at the entrance of the Strait of Juan de Fuca, 

resulting in a reversal in estuarine circulation (Thomson 1994, as cited in Banas et al. 1999).
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Chapter 3. Physical Environment 3-7

Figure 3-3. Global sub-surface currents (Pidwimy 2006).

The complex topography of the Georgia-Fuca system not only includes numerous islands, but many 

banks, constrictions, and sills, resulting in exceedingly complicated and swift tidal currents (up to 2 

meters [6.5 feet] per second) (Banas et al. 1999). These swift tidal currents pose challenges associated 

with safe island access.

It is unknown how global climate change will influence the ocean currents and coastal upwelling 

affecting Protection Island and the San Juan Islands. However, current climate model simulations 

indicate little change in coastal upwelling in the Pacific Northwest (Mote et al. 2008b, Mote and Salathé 

2009).

Future Trends

3.2.2 El Niño Events

A seasonal change in the circulation of the Pacific Ocean often brings an event known as El Niño to a 

wide region, including the Pacific Northwest. A periodic weakening of the trade winds in the central and 

western Pacific, often occurring in December, allows warm water to invade the eastern Pacific. This 

seasonal change in the wind and ocean circulation can have global impacts to weather events. During an 

El Niño event, the winters of the Pacific Northwest tend to be warmer than usual. An El Niño event may 

be followed by La Niña, which results in cooler than normal ocean temperature in the eastern Pacific. La 

Niña also can have significant impacts on global weather. Collectively, the El Niño and La Niña cycle is 

known as the El Niño–Southern Oscillation (ENSO) (Pidwirny 2006). The shift between the two 

conditions of the ENSO cycle takes about four years (Conlan and Service 2000).

El Niño events are not caused by global warming; however, a relationship between global warning and El 

Niño may exist. NOAA (2010a) addresses the relationship as follows:

Clear evidence exists from a variety of sources (including archaeological studies) that El Niños 

have been present for thousands, and some indicators suggest maybe millions, of years. 

However, it has been hypothesized that warmer global sea surface temperatures can enhance the 

El Niño phenomenon, and it is also true that El Niños have been more frequent and intense in 
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3-8 Chapter 3. Physical Environment 

recent decades. Whether El Niño occurrence changes with climate change is a major research 

question.

Future Trends

3.2.3 Tides and Sea Level Rise 

Based on the evidence of the history of El Niño events, it is likely that they will continue to occur far into 

the future. However, the potential influence of climate change on El Niño events is unknown because 

more information is needed by the experts.

Historic records of tides and water levels from three data stations in the San Juan Islands and one in Port 

Townsend are summarized in Table 3-4. Data for each station includes mean ranges, diurnal ranges, and 

the minimum and maximum water levels on record. The mean range is the difference in height between 

the mean high water and the mean low water. The diurnal range is the difference between the mean 

higher high water (MHHW) and the mean lower low water (MLLW) of each tidal day.

Station 

Information

Table 3-4. Historic tidal data summary for San Juan Islands and Port Townsend (NOAA 2010b).

Friday Harbor, 

San Juan Channel

Sta. ID 9449880

Richardson, 

Lopez Island

Sta. ID 9449982

Armitage Island

Sta. ID 9449932

Port Townsend

Sta. ID 9444900

Mean Range (ft) 4.82 4.55 4.9 5.34

Diurnal Range (ft) 7.76 7.17 7.84 8.52

Minimum Water 

Level 

(ft below MLLW)

-4.15

on

01/07/1947

-3.85

on

12/24/1999

-3.65

on

12/25/1999

-4.22

on

12/12/1985

Maximum Water 

Level 

(ft above MHHW)

3.39

on

12/16/1982

2.41

on

12/16/1997

2.61

on

12/16/1997

3.21

on

12/10/1993

While regular tide-related wave action can redistribute sediments along a shoreline, storm surges can have 

more pronounced erosion impacts. A storm surge consists of water that is pushed toward the shore by the 

force of the winds swirling around a storm (NOAA 2007b). The advancing surge combines with the 

normal tides to create a storm tide, which can increase the mean water level 15 feet or more (NOAA 

2007b). In addition, wind waves are superimposed on a storm tide creating a cumulative impact on the 

tide level; the impacts are generally greatest when they occur during the normal high tide. Water weighs 

approximately 1,700 pounds per cubic yard; extended pounding by frequent waves can result in severely 

eroded beaches and coastal resources (NOAA 2007b).

Sea level rise on the Washington coast and inland marine waters of the state is the result of four major 

forces: global mean sea level rise driven by the thermal expansion of the ocean, global mean sea level rise 

driven by the melting of land-based ice, local dynamical sea level rise driven by changes in wind which 

push coastal waters toward or away from shore, and localized vertical land movements driven primarily 

by tectonic forces (Mote et al. 2008a). Mean sea level is defined as the average sea level over a 19-year 

period, about which other fluctuations (e.g., tides, storm surges) occur (Smerling et al. 2005). Global 

mean sea level rise has ranged from 0.05 to 0.09 inch per year from 1961 to 2003 (IPCC 2007). This 

global impact is primarily the result of general thermal expansion of the oceans (as warming occurs, the 

water volume expands) and ice field and glacier melt off (Warrick and Oerlemans 1990 as cited in 

Canning 2001). In addition, vertical land movements are occurring as the North American plate and the 

off-shore Juan de Fuca plate collide. Uplift occurs along the Washington coast while subsidence occurs 
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Chapter 3. Physical Environment 3-9

off-shore. Vertical land movements in the Strait of Juan de Fuca range from approximately 0.1 inch per 

year at Neah Bay to zero at Friday Harbor (Canning 2001).

Based on monthly mean sea level data from 1934 to 2006, the mean sea level trend at Friday Harbor is 

approximately +0.37 feet per century (NOAA 2010b). Data for Port Townsend was recorded from 1972 

to 2006 and indicates a mean sea level trend of +0.65 feet per century (NOAA 2010b). The 95 percent 

confidence interval is ±1.08 feet per century and ±3.77 feet per century for the data trends, respectively. 

Estimates for the rise in sea level at Puget Sound by 2050 range from 0.25 feet under the “very low” 

scenario to 0.5 feet under the “medium” scenario and 1.83 feet under the “very high” scenario. There is a 

low probability for both the “very low” and “very high” scenarios (Mote et al. 2008a).

Future Trends

3.2.4 Sea Temperatures

Based on historical data reported through the National Data Buoy Center (NOAA 2006), sea surface 

temperatures in the Refuge regions range from approximately 46 degrees F in the winter months to 

approximately 54 degrees F in the summer months (NOAA 2006, Emmett et al. 2000, Stephenson and 

Stephenson 1961). Sea surface temperatures are collected at stations located in Friday Harbor and Port 

Townsend. Buoys moored within the Strait of Juan de Fuca also report data with similar seawater 

temperature ranges. 

Summer sea surface temperatures in the Pacific Northwest are projected to increase. Regional climate 

models for the Pacific Northwest project warming in summer sea surface temperature for the 2040s on the 

order of 2.2 degrees F (1.2 degrees C). This change is somewhat less than the warming projected in the 

2040s for Pacific Northwest land areas but is significant relative to the small inter-annual variability of 

the ocean (Mote and Salathé 2009).

Future Trends

3.2.5 Oceanic Chemical Concentrations

The Strait of Juan de Fuca is open to the Pacific Ocean at its western end with a submarine canyon 

crossing the continental shelf just off the strait’s opening. This deep canyon assists in cold bottom-water 

entering the strait. The wide opening to the ocean allows a considerable amount of wave action within 

the Strait of Juan de Fuca and tidal currents are strong. Conversely, the Strait of Georgia is more 

protected from immediate interaction with the Pacific Ocean. Wave action is of primarily local origin, 

tidal currents are important, and salinity is affected by local rivers, the largest of which is the Fraser 

River. In general, the waters of the Georgia-Fuca system are unusually rich in nutrient salts, in part due to 

upwelling at the mouth of the Strait of Juan de Fuca (Stephenson and Stephenson 1961).

Waters of the Georgia-Fuca system contain relatively low salinity, with monthly salinity averaging 

around 31 parts per thousand (ppt) at Race Rocks in the Strait of Juan de Fuca near Victoria, Canada 

(Stephenson and Stephenson 1961). By comparison, salinity in much of the earth’s oceans is 

approximately 34 to 36 ppt. The Fraser River and Puget Sound collectively bring more freshwater 

inflows to the Pacific Ocean than any other individual drainage from British Columbia through California 

(Emmett et al. 2000). This freshwater influx is responsible for the salinity of the waters surrounding both 

refuges, which is relatively low compared to that of many coastal island complexes.

Carbon dioxide flux is another important component of the chemical makeup of the water surrounding the 

refuges. While a large amount of the carbon dioxide concentration within surface seawater is due to 
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3-10 Chapter 3. Physical Environment 

exchange at the interface between the atmosphere and ocean, another strong contribution of carbon 

dioxide to the ocean comes from biological production (Johnson et al. 1979). Thompson and Miller 

(1928) observed carbon dioxide levels from opposing tidal currents within the Georgia-Fuca system. The 

tidewater flowing out of the Strait of Georgia contained 64.48 milligrams carbon dioxide per liter (mg 

CO2/l). Conversely, the tidal water flowing in from the Strait of Juan de Fuca contained 78.79 mg CO2/l 

(Thompson and Miller 1928). 

Although salinity trends related to climate cannot be calculated for the waters around the refuge due to 

insufficient baseline data, there is some regional salinity data that can be used with projected stream data 

to estimate a general trend for salinity in the future. Salinity data collected from Puget Sound in the 

1990s indicate a correlation between lower stream flows and higher sea surface salinity, and vice versa. 

Also, correlations between winter precipitation and slightly decreased salinity have been noted at Race 

Rocks in the Strait of Juan de Fuca (Snover et al. 2005). Changes in runoff of water into streams of 

Washington State have been projected to occur as a result of global warming, with estimated annual 

increases of 2 to 3 percent by the 2040s, and 4 to 6 percent by the 2080s; seasonal changes are expected 

with increases during the cool seasons and smaller decreases during the warm seasons (Littell et al. 2009). 

Based on the noted salinity trends and projected runoff changes, salinity in the Georgia-Fuca system 

could further decrease as a result of the continued warming trend associated with global climate change. 

Future Trends 

Ocean acidity is expected to rise as a result of continued increases in atmospheric carbon dioxide, as the 

additional carbon dioxide is taken up in the ocean, lowering pH. Plankton, fish, and other marine 

organisms that tolerate lower pH may benefit; however, others will not. Important plankton that form 

calcite shells will be negatively affected, and lower pH has been found to decrease calcification rates in 

mussels, clams, and oysters (Feely et al. 2008 as cited in Huppert et al. 2009, Snover et al. 2005). These 

changes are likely to result in cascading effects to other species at higher trophic levels, such as fish, 

birds, and marine mammals. The range and magnitude of biological effects are currently uncertain, but 

are thought to be substantial (NOAA 2008 as cited in Huppert et al. 2009). 

As Kleypas et al. (2006) observed, little attention has been focused on the role of the carbon cycle of 

shallow-water (versus open) ocean within the context of global climate change. In general, increasing 

partial pressure of atmospheric carbon dioxide drives more carbon dioxide into seawater. However, an 

important caveat exists: as seawater temperature rises due to global climate change (warming), its 

capacity to hold carbon dioxide decreases (Kleypas et al. 2006). Sarmiento and Le Quere (1996) 

conducted modeling research that indicates the primary reason for the reduced uptake of carbon dioxide 

in the oceans will be weakened or collapsed density-driven ocean circulation.

3.3 Topography and Bathymetry

Protection Island is crescent shaped with sand spits at the west and the east ends. The western spit is 

Kanem Point and the eastern is Violet Point. Each of the spits has less than 40 feet of elevation. A bluff 

and cliff complex circumscribes the main body of the island, excluding the two spits. The bluff along the 

southern shore is approximately 100 feet high while the cliffs of the northern shore are approximately 150 

feet high. The gently undulating hills of the central plateau of the island range from 120 to 204 feet in 

elevation (USGS 1981a, 1986).

Protection Island is surrounded by Dallas Bank. The bank slopes gently away from the northern shores of 

the island and falls away sharply from the shores to the south. Dallas Bank rises from approximately 100 

feet below sea level to roughly 10 feet below sea level and is generally a triangle-shaped feature (NOAA 
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Chapter 3. Physical Environment 3-11

2010c).

Some of the islands within the San Juan Archipelago have such little relief that they are completely 

submerged at high tide. A review of the 7.5-minute Mount Constitution quadrangle map (USGS 1979) 

indicates that the highest elevation on the largest of the islands within the San Juan Islands NWR 

complex, Matia Island, is approximately 162 feet above mean sea level. The majority of the islands 

within the NWR complex, however, have less than 20 feet of elevation while many of the remaining 

islands have no more than 40 feet of elevation (USGS 1960-1986). 

Deep ice-scoured channels and sounds are the remnant glacial features of the last ice age that define the 

bathymetry surrounding the islands of the San Juan Archipelago. The bathymetry is a complex 

combination of shallows and deep U-shaped channels that form the primary navigational routes between 

the islands (Banas et al. 1999). In addition to the straits of Juan de Fuca and Georgia, the major channels 

within the archipelago include the San Juan Channel, Haro Strait, and Rosario Strait (NOAA 2010c, 

2010d).

3.4 Recent Geological History and Geomorphology

The San Juan Islands represent the highest peaks of a submerged mountain range that formerly connected 

Vancouver Island with the Washington State and British Columbia mainland (USDA 1962). The valleys 

and ravines of the now-submerged range form the channels and harbors surrounding the San Juan Islands 

(McLellan 1927). The mountain range forming the San Juan Islands and channels was likely formed 

during the process of subduction along the boundary of the continental North American Plate and the 

oceanic Juan de Fuca and Pacific plates (Russell 1975). As the continental plate and the ocean plates 

collided, the ocean plates moved under the continental plate, and the sedimentary deposits on the sea floor 

folded against the continental plate (Schultz 1990). The relic left behind by this collision process is the 

San Juan Archipelago, which has been shaped and modified millions of years later by glaciers (Russell 

1975).

Both refuge areas have been highly defined by the glacial activity of past ice ages. Some areas of the 

islands, and in some cases entire island outcrops, have been scoured to their bedrock bases. Others 

became depositional areas for the scoured materials (USDA 1962, 1975). As temperatures warmed and 

the ice retreated, seawater began to enter the Georgia-Fuca system and Puget Sound, eventually 

submerging much of the glaciated landscape (Grimstad and Carson 1981). The channels and straits of the 

Georgia-Fuca system exhibit the telltale steep-walled, U-shaped valleys of a glaciated area. The scoured 

and smoothed island tops are the uppermost visible evidence of the glacial activity. Steep, wave-cut 

bluffs along the straits further define the margins between the submerged and terrestrial landscapes 

(PSAT 2005).

The most recent ice age took place during the Pleistocene epoch (1.8 million to 10,000 years ago) within 

the Quaternary period (USGS 2006a). The Puget Lobe of the Cordilleran Ice Sheet carved much of the 

landscape and seascape within and surrounding the San Juan Islands and Protection Island. Due to 

temperature fluctuations, the Puget Lobe went through a series of four advances/retreats (Grimstad and 

Carson 1981). The final retreat occurred approximately 10,000 years ago (USGS 2006b). The glacial 

activity left behind a landscape of relatively gentle, rolling, elongated, northerly tending hills with steep 

valley sides (USDA 1962, 1975). Fluvial processes further cut some of the valley sides (Grimstad and 

Carson 1981). Table 3-5 summarizes the processes of each formation and some islands associated with 

each.
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3-12 Chapter 3. Physical Environment 

Formation

Table 3-5. Summary of geological formations and representative island associations.

Age

(million 

years ago)

Lithology Process Island Name (number)

Turtleback 

Complex

490–443 intrusive rocks

Crystallized molten magma 

formed beneath an overlying 

structure. In the San Juan 

Islands, glacier activity has 

scoured the overlying 

structures away and left the 

intrusive bedrock exposed.

Fortress Island (3), Skull Island (4), Crab 

Island (5), Castle Island (8), 3 unnamed 

islands (9), Secar Rock (17), Barron Island 

(30), Willow Island (55), Pointer Island (57), 

3 unnamed rocks (59), Bird Rock (68), 

unnamed island (69) Low Island (70), Nob 

Island (71)

Orcas 

290–248 metasedimentary 

rocks, cherty

Deposits laid down as marine 

sediments in fairly deep water 

a considerable distance from 

the shore. Rocks are highly 

metamorphosed and contorted 

as a result of folding and 

intrusions.

Low Island (28), Battleship Island (31), Tift 

Rocks (50)

Constitution

248–65 marine sedimentary 

rocks

Erosion and deposition of 

sediments derived from uplifted 

land areas.

Turn Rock (52), Shag Rock (53), Turn Island 

(79)

Nanaimo

144–65 nearshore sedimentary 

rocks

Deposition laid down upon 

eroded surfaces near sea level.

Ripple Island (35), Little Cactus Island (37), 

Gull Rock (38), Flattop Island (39), White 

Rocks (40), Skipjack Island (42), unnamed 

island (43), Bare Island (84)

Spieden 144–65 nearshore sedimentary 

rocks

Deposition laid down upon 

eroded surfaces upland of sea 

level.

Sentinel Island (32)

Lummi

144–65 marine sedimentary 

rocks

A general withdrawal of the sea 

and an accompanying uplift

exposed marine sedimentary 

rocks.

2 unnamed islands (2), Boulder Island (6), 

Aleck Rocks (10), Swirl Island (11), 4 

unnamed islands (13), Hall Island (15), 

unnamed island (16), 3 unnamed islets (19), 

13 unnamed islets (20), Mummy Rocks (21), 

islets and rocks (22), Shark Reef (23), 

Harbor Rock (24), Flower Island (54), 

unnamed rock (61), S. Peapod Rocks (62), 

Peapod Rocks (63), N. Peapod Rock (64), 

Colville Island (82), Buck Island (83)

Chuckanut

65–1.8

continental 

sedimentary deposits 

or rocks 

With a gradual submergence, 

water began entering both from 

the north and the area now 

occupied by the Strait of Juan 

de Fuca. As submergence 

continued, water encroached 

farther and farther eastward. 

Sediments were laid down 

upon eroded surfaces followed 

by regional uplifting above sea 

level and gentle folding.

2 unnamed islands (2), Boulder Island (6), 

Round Rock (18), Clements Reef (44), The 

Sisters (47), Little Sister Island (48), Black 

Rock (58), 3 unnamed islands (59), Matia 

Island (77), Puffin Island (78), Four Bird 

Rock (80)

Glacial 

Deposits

1.8–present glacial deposits

During glacial advance, ice cut 

deeply into older formations 

scouring material and redepositing it adjacent (lateral) 

to and at the termini of the ice 

sheet and glaciers.

Matia Island (77), Turn Island (79)

Post-glacial 

Sediments 1.8–present post-glacial deposits

During glacial retreat, a thick 

mantle of recessional glacial 

drift was left on many of the 

islands.

Protection Island, Smith Island (78)
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Chapter 3. Physical Environment 3-13

Glacier activity scoured away the overlying structures and left behind exposed bedrock from the 

Turtleback Complex. Portions of the ice sheet at the ocean’s edge actually floated, causing melting and 

glacial till outwash to occur. At the farthest floating edges of the ice sheet, the outwash was laid down as 

marine sediment in fairly deep water that was a considerable distance from the current shorelines. The 

Orcas Formation is the result of folding and intrusion that has highly metamorphosed and contorted these 

deep-water marine sediments. As the ice sheet retreated, uplift occurred. The Constitution Formation 

resulted from the erosion and deposition of sediments derived from the uplifted land. During the same 

period, nearshore sedimentary rocks were formed as erosion and deposition processes laid down 

sediments on eroded surfaces. The Nanaimo Formation consists of sediment deposited upon eroded 

surfaces near sea level while the Spieden Formation left depositional material further upland. A period of 

general sea withdrawal accompanied by further land uplift began. During this period, the Lummi 

Formation resulted in marine sedimentary rocks being uplifted and exposed (Russell 1975).

Eventually, a gradual submergence began as seawater began to enter from the north and through the area 

now occupied by the Strait of Juan de Fuca. As submergence continued, water encroached farther and 

farther eastward. Sediments were laid down upon eroded surfaces followed by another regional uplifting 

above sea level accompanied by gentle folding. This process resulted in the Chuckanut Formation. As 

the ice sheet continued to retreat, glacial deposits were left along the retreating edges to cover many of the 

exposed islands (Russell 1975).

Protection and Smith Islands were also formed during a period of glacier recession and consist primarily 

of postglacial sediments. The bluffs that are present in a circular pattern around the majority of Protection 

Island consist of a mix of undifferentiated glacial deposits (Grimstad and Carson 1981, Dragovich et al. 

2005). 

3.5 Soils

Soils mapped throughout the two refuges are described below. County soil surveys were not conducted 

for the two most northern features, Clements Reef and an unnamed island, and the two most southern 

islands in the refuge, Smith and Minor Islands. 

The Soil Survey of San Juan County, Washington (USDA 1962), maps the majority of the islands within 

the NWR as Rock land, rolling (map unit Ry). These islands are characterized by rock outcrops made up 

primarily of sandstone, argillite, and basalt. Also scattered heavily throughout the refuge are islands 

mapped as Roche-Rock outcrop complex, 8 to 30 percent slopes (map unit RxD). This complex is 

characterized by the rock outcrops described above mixed closely with soils from the Roche series. 

Roche gravelly loam, 3 to 8 percent slopes is the predominant Roche series component of this complex. 

Islands of the refuge located in the southern expanses of San Juan County are predominantly mapped as 

Rock land, steep (map unit Rz). This soil type is similar to Rock land, rolling, but is steeper (USDA 

1962).

Turn Island, adjacent to the western peninsula of San Juan Island, is mapped as Everett gravelly sandy 

loam, 3 to 8 percent slopes (map unit EgB). It contains a number of small patches of cobbly and stony 

areas. Everett soils are composed of sandy, gravelly, and cobbly materials derived from sandstone, 

granite, and basalt. Turn Rock, located close to Turn Island, is primarily mapped as Roche-Rock outcrop 

complex, 8 to 30 percent slopes. Unlike the other islands with this map unit type, Turn Rock is also 

mapped as having Coastal Beaches (map unit Cb) along its western shore. Coastal Beaches consist of 

sandy and gravelly sloping beaches in long narrow strips along island margins (USDA 1962).
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3-14 Chapter 3. Physical Environment 

The easternmost islands within the San Juan Islands NWR, Eliza Rock (Island #65) and Viti Rocks 

(Island #66), are located within Whatcom County. The Soil Survey of Whatcom County Area, 

Washington, maps both islands as Rock Outcrops (map unit 131). Typically, the outcrop is composed of 

sandstone, phyllite, dunite, or metasedimentary rocks. It is generally found on mountainsides and ridges 

and occurs as steep cliffs and irregular formations of unweathered rock. In the case of these features, they 

are found on the ridges of submerged mountains (USDA 1992).

The Soil Survey of Jefferson County Area, Washington (USDA 1975), indicates there are five soil map 

unit types on Protection Island. Kanem and Violet Points are mapped as coastal beaches (Co) (see above 

description). The inland-most portion of Violet Point, at the base of the bluff, is mapped as tidal marsh 

(Td) consisting of nearly level, extremely wet, salty, brackish areas within the overflow limits of high 

tides. Soil materials in tidal marsh areas are deep deposits of heterogeneous alluvium; no true soil 

formation has taken place. The bluff, or escarpment, surrounding the island is mapped as rough broken 

land (Ro) typically consisting of marine bluffs that are 80 feet high and 100 feet or more wide; the slopes 

are generally between 50 and 120 percent. The majority of the upper elevation of the island, 

approximately 155 acres, is mapped as Townsend fine sandy loam, 0 to 15 percent slopes (TIC). These 

soils are formed as strong prevailing winds blow fine sand from the beaches and bluffs and deposit it on 

the surface. Wrapping around the western and southern limits of the TIC area is a band of dune land (Du) 

covering approximately 118 acres and consisting of fine sand (USDA 1975).

3.6 Hydrology

The circulation of the Salish Sea region, which includes the Straits of Georgia, Juan de Fuca, and Puget 

Sound, is driven by tidal currents, the surface outflow of freshwater from major river systems, and the 

deep inflow of saltwater from the ocean. Fresh water originates from the Olympic Mountains, Vancouver 

Island Range, and Cascade Range, both during winter rain events and from the spring melt. The strong 

freshwater influence of the Fraser River from the north, Bellingham, Padilla, and Skagit bays from the 

east, and South Puget Sound occasionally cause large drops in surface salinities.

Lakes, reservoirs, and ponds occur throughout the San Juan Islands and supply much of the domestic 

water used on the larger islands (e.g., San Juan and Orcas Islands). However, the size of the surface water 

impoundments on these islands are limited by topography, precipitation, and glacial sediment overlay. 

Watersheds on the islands are generally small and the streams that drain them are typically seasonal. The 

lack of rivers and snow pack means that groundwater supply and recharge comes wholly from local 

rainfall. However, seawater intrusion affects many glacial drift aquifers as well as some fractured 

bedrock aquifers.

Protection Island NWR

Prior to development from 1968 to 1974, tidal salt and brackish marsh formerly existed on Violet Point. 

Daily and seasonal input of freshwater from the seeps coming down the slopes to the west of the spit 

likely affected the vegetation composition of the marsh. Thus, low marsh species probably quickly 

graded into high marsh species and then into tidal freshwater species. However, the marsh was filled in 

and graded during the construction of the marina and no longer exists.

San Juan Islands NWR

Matia Island is unique among the smaller of the San Juan Islands in that it includes a small freshwateremergent marsh. The amount of water and, consequently, duration of the wetland vary with precipitation. 
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Chapter 3. Physical Environment 3-15

Smith Island contains an interdunal wetland on its eastern spit. Some salt-tolerant wetland species occur 

along the perimeter of a small shallow pond that receives limited freshwater input from seeps coming 

down from the west in addition to direct precipitation. Water levels vary seasonally, typically receding 

and occasionally drying up in the summer. The spit protects the wetland from wave action but is likely to 

allow saltwater intrusion, especially during storm or overwash events. 

3.7 Fire

Protection Island and San Juan Islands NWRs are in the driest area in western Washington (please refer to 

the Precipitation section for further discussion). Consequently, prior to Euroamerican settlement, the 

predominant vegetation on lowlands west of the Cascades, from the Willamette Valley of Oregon north to 

the Georgia Basin of southwest British Columbia, was a mosaic of grasslands, oak and conifer savannas, 

and various types of wetlands (Chappell and Crawford 1997, Sinclair et al. 2006). These forests, savanna, 

grassland, and herbaceous bald ecosystems generally rely on fire to maintain their vegetative structure 

and species composition. In addition to lightning-caused fires, historical accounts have also established 

that Native Americans burned grasslands and oak savannas to create habitat for game animals and to 

promote the growth of weaving materials and food (Agee 1993, Chappell et al. 2001, Sinclair et al. 2006). 

The historic frequency with which a given area burned depended directly upon the number of natural and 

human-ignited fires. Other factors affecting fire frequency and fire intensity include plant community 

types, changes in topography (i.e., slope and aspect), varying fuel accumulations, and variation in 

seasonal precipitation. However, the advent of Euroamerican settlement interrupted Native American 

land management practices and altered the fire regime by eliminating prescribed fires. 

Although there has been little research documenting the pre-settlement fire history of either Protection 

Island or the San Juan Islands Refuges, the influence of fire was likely higher on larger islands such as 

Protection and Smith Islands than on smaller islands, which probably had very little history of burning 

due to their size. In recent history, between 1944 and the 1950s, at least two major fires burned most of 

the uplands on Protection Island, including buildings and forested land, and both Kanem and Violet 

Points (Power 1976, Clark 1995). Alcorn and Alcorn (1966) recorded the occurrence of another major 

fire on Violet Point in 1962. Additionally, fire scars have been noted by refuge staff on several trees on 

Matia Island.

On Protection Island, the general fire season runs from mid-April to mid-October. Depending on the 

specific weather of any particular year, the seasons may be shorter or longer and, therefore, may start 

earlier or last longer. The general fire season recognized by the Washington DNR Olympic Region runs 

from June to September. 

3.8 Air Quality

The San Juan Islands NWR lies within the Georgia Basin airshed and the Protection Island NWR is at the 

very northern edge of the Puget Sound airshed. The combined airshed is referred to as the Georgia 

Basin/Puget Sound airshed. In the Georgia Basin/Puget Sound airshed, air quality is primarily 

determined by weather patterns, which are influenced by the topography of the airshed. Air movements 

in the basin are responsible for dispersing airborne chemicals emitted from a variety of sources 

(Environment Canada 2004).

During the summer and winter, periods of stagnation cause airborne pollutants to buildup and remain in 

the airshed or to drift only slightly downwind of their origins. Episodes of poor air quality generally 

occur during these months. Interactions between airborne pollutants can cause secondary air pollutants to 
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3-16 Chapter 3. Physical Environment 

form in the atmosphere, compounding poor air quality episodes. During the spring, winds off the Pacific 

Ocean carry pollutants from Eurasia and California to the airshed, adding a small but measurable amount 

to the ozone and particulate matter concentrations (Environment Canada 2004). 

Even with these stagnant air events, ozone concentrations measured in rural coastal locations within the 

airshed are often between 40 and 50 parts per billion (ppb) (Environment Canada 2004), nearly half of the 

national ambient air quality standard set by the U.S. Environmental Protection Agency (USEPA). 

Likewise, the average particulate matter mass concentrations are below USEPA standards, although they 

vary considerably by season, week, and day. In general, the overall air quality within and surrounding the 

NWRs is good (Environment Canada 2004).

3.9 Water Quality

The Strait of Juan de Fuca is the primary conduit between the Salish Sea and the Pacific Ocean. Water 

properties within the Strait are influenced by both oceanic and riverine inputs (Newton et al. 2003). In 

general, stratification of fresh to salt water is more evident north of the San Juan Islands in the Strait of 

Georgia than south of the islands closer to Protection Island (Newton et al. 2002). Stratification reduces 

opportunities for vertical mixing within the water column, thereby isolating the various water quality 

indicators to the surface layer with little opportunity for dilution. However, the open waters to the south 

of the Strait of Georgia are well flushed by strong currents, deep channels, and tidal mixing, and thus, less 

stratified (Erickson et al. 1995). Common water quality indicators for the Salish Sea system are dissolved 

oxygen (DO), dissolved inorganic nutrients, and fecal coliform bacteria (Erickson et al. 1995).

Areas sampled near Protection Island NWR indicate moderate, infrequent stratification. Low DO 

concentrations in the waters near Protection Island are typical and reflect the influence of upwelled, 

naturally low-oxygen water from the Pacific Ocean that flows eastward beneath the less-saline surface 

layer flowing westward. Nutrient concentrations and fecal coliform bacteria counts in the waters 

surrounding the San Juan Islands NWR are low, indicating good water quality in the areas surrounding 

Protection Island NWR (Newton et al. 2002).

Overall, water quality in the San Juan Islands NWR area is good (Newton et al. 2002). Sampling 

conducted by Newton et al. (2002) indicates that strong and intermittently stratified, very low DO water 

flows from the Strait of Georgia, influencing waters of the San Juan Islands NWR. The low DO 

concentration in the Strait of Georgia is likely a result of the naturally low DO waters from the Strait of 

Juan de Fuca and waters from the Fraser River plume, which have a high organic load and further reduce 

DO. In general, nutrient concentrations in the waters of the San Juan Islands NWR are not limiting and 

thus, not an indicator of poor water quality. Fecal coliform bacteria counts are low. 

3.10 Environmental Contaminants

3.10.1 Oil Spills

Oil spills are a major concern for refuge wildlife and habitats. Over 41 million gallons of oil are delivered 

over sensitive waterways every day in Washington (WDOE 2009). Washington State has the fifth highest 

refining capacity (by state) within the United States, with Puget Sound being the closest national port in 

the lower 48 states for vessels carrying crude oil out of Valdez, Alaska (Neel et al. 1997). In addition to 

receiving oil via tankers from Alaska, western Washington also receives oil from Canada via a pipeline. 

The Trans Mountain pipeline delivers crude oil from Edmonton, Alberta, to Sumas, British Columbia, at 
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Chapter 3. Physical Environment 3-17

the Washington State/Canada border (Kinder Morgan 2007). From Sumas, the crude oil is delivered to 

refineries in Ferndale and Anacortes, Washington. Oil leaves the refineries bound for other western states 

(i.e., Oregon and California) via pipelines, barges, and tankers (Neel et al. 1997).

The Strait of Juan de Fuca is one of the most critical maritime highways for both the United States and 

Canada. Tanker traffic alone through this area carries over 15 billion gallons of oil each year (WDOE 

2009). There are six refineries in Washington for which vessel traffic is generated through the Strait of 

Juan de Fuca. 

As one of North America’s major gateways to Pacific Rim trade, Puget Sound and the Strait of Juan de 

Fuca are among the busiest waterways in the world; vessel traffic moves to and from busy ports in both 

Washington and Vancouver, British Columbia (Neel et al. 1997, Etkin and Neel 2001). The high volume 

of marine traffic puts Puget Sound and the Strait of Juan de Fuca at risk of substantial oil spills. In 

addition to oil tankers and barges, dry cargo, passenger (cruise ships and ferries), naval, and commercial 

fishing fleet vessels, and a high per capita recreational boat ownership, all add to the risk of spills within 

this transportation corridor (Etkin and Neel 2001).

Heavy fuel and crude oils, recognized as viscous “black” oils, have a tendency to smother animals such as 

birds and mammals, often killing them. These oils are highly persistent and create residues that are 

resistant to natural and biological degradation processes (Neel et al. 1997). Table 3-6 summarizes the 

known oil spills in the Salish Sea area since 1970. 

Incident Date

Table 3-6. Summary of representative vessel oil spills and select other incidents in the Georgia 

Basin/Puget Sound since 1970 (Neel et al. 1997, Islands’ Oil Spill Association, San Juan Co., 2007, 

WDOE 2007).

Incident Name Total Quantity Spilled

(gallons) Product Type

04/26/1971 United Transportation Barge #U 230,000 Diesel fuel

01/01/1972 General M.C. Meiggs 2,300,000 Heavy fuel oil

06/04/1972 World Bond 21,000 Crude oil

12/21/1985 Arco Anchorage 239,000 Crude oil

01/31/1988 MCN #5 Barge 70,000 Heavy fuel oil

07/22/1991 Tenyo Maru 100,000* Heavy fuel, oil, & diesel fuel

12/31/1994 Crowley Barge 101 26,900 Diesel fuel

01/10/2000 Point Wells, Lucky Buck unknown** Diesel fuel

11/05/2000 Columbia 300-500 Diesel fuel

01/29/2001 Prince William Sound, Port 

Angeles 200 Crude oil

06/13/2001 Overseas Boston, TOSCO, 

Ferndale 315-630 Crude oil

10/14/2004 Polar Texas – Conoco Phillips 1,000+ Crude oil

11/11/2004 Thrasyvoulos V cargo ship unknown Light fuel oil

1/28/2005 Dalco Passage Spill unknown unknown

3/17/2006 Elliot Bay Sheen 50 Lubricating oil

April 2006 Mutiny Bay bunker oil 80 tons*** Bunker C oil

08/30/2006 Spill near Edmonds, WA unknown Sheen

*The Tenyo Maru contained more than 400,000 gallons when it sank; at least 100,000 gallons were released during the initial incident.

**To date there has been an unknown quantity of diesel fuel leaked. At the time of the incident, the Lucky Buck had on board 125.000 gallons of 

diesel fuel, 700 gallons of hydraulic oil, and 70 gallons of lube oil.

***80 tons of oil and oil-contaminated sediment was removed from a 100-foot-long section of beach in the Whidbey Island inter-tidal zone.
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3-18 Chapter 3. Physical Environment 

Some of the spills data reported in the sources used to compile the table are incomplete. Therefore, the 

table is a representation of past incidents but should not be viewed as a complete list of incidents over 

time. The Islands’ Oil Spill Association for San Juan County also logged several incidents of 

unrecoverable sheens and other smaller scale incidents that are too numerous to list in the summary table 

but can be viewed on the association’s website: http://www.iosaonline.org/ResponseHistory/index.htm.

3.10.2 Polybrominated diphenyl ethers (PBDE)

Polybrominated diphenyl ethers (PBDEs) are a common flame retardant chemical. PBDEs are in a wide 

variety of products including furniture, electronics, and textiles. They leach out of these products into the 

air, household dust, and eventually into the organisms in contact with the materials. They belong to a 

group of chemicals that dissolve easily in animal fat and do not break down readily, causing them to build 

up or bioaccumulate in the food web, known as persistent bioaccumulative toxics (PBTs) (USEPA 2007). 

PBTs have been found in humans, salmon, seals, and orcas (Manning 2007). 

These organic chemicals, which are soluble in lipids (fats), are known to accumulate in the insulating fat 

of fish and animals, including birds and marine mammals (Raloff 2001, USEPA 2007). Due to 

bioaccumulation, the accumulation of substance up the food chain by transfer of residues of the substance 

from smaller organisms that become food for larger organisms (USEPA 2007), the heaviest 

accumulations of PBDEs have been found in the largest and oldest animals studied (Raloff 2001). 

Studies of concentrations of PBDEs in fish also showed that concentrations rise with the size and age of 

the fish (Raloff 2001). Animal studies have shown that PBDEs alter brain development, affecting 

learning, behavior, and memory; developing fetuses and infants are most at risk (Manning 2007).

Studies conducted by the USEPA (2007) on harbor seals and Pacific herring, a large portion of the seal 

diet, were conducted in the Salish Sea. The study was conducted to compare the levels of PBTs between 

the seals in Puget Sound and the Strait of Georgia. The results indicated that not only were high levels of 

PBDEs present in both seal populations, but that the seals from Puget Sound were twice as contaminated 

as those in the Strait of Georgia. In studies of the seals’ preferred diet, PBDE concentrations were almost 

five times higher in the Puget Sound seal diet than that of the Strait of Georgia. Likewise, Pacific herring 

sampled in Puget Sound had elevated PBDE levels that were nearly three times higher than those sampled 

from the southern Georgia Basin. 

3.10.3 Pesticides

Many industrial and agricultural activities continue to have effects upon lands and the wildlife that use 

them. Although many improvements have been realized since the use of the pesticide DDT has been 

curbed, incidence of eggshell thinning in waterbirds in western Washington is still detectible. Residues of 

DDT (in the form of DDE) and polychlorinated biphenyls (PCBs) have been found in many of the species 

that use the two refuges (Speich et al. 1992, Henny et al. 1989). The levels present, however, were below 

those known to impact reproductive success.

3.10.4 Other contaminants

Over the past 150 years, human activities around the Salish Sea have introduced a variety of persistent, 

bioaccumulative toxic chemicals into the environment at levels that can be harmful to both humans and 

wildlife. These toxic chemicals include heavy metals such as lead, mercury, and copper, as well as 

organic compounds such as polycyclic aromatic hydrocarbons (PAH), PCBs, dioxins, furans, and 

phthalates. These contaminants enter into the aquatic environment through a variety of sources and 

human activities, including industrial and municipal discharges, groundwater seepage, atmospheric 
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Chapter 3. Physical Environment 3-19

deposition, and resuspension of sediments (PSAT 2003). While primarily concentrated in areas around 

urban or industrial developments, these contaminants affect a much larger area of the ecosystem. When 

organisms live in or eat within these areas of contamination, not only are they directly harmed but they 

also accumulate contaminants in their tissues and transfer them throughout the food web. Additionally, 

rogue creosote logs are a source of contamination for all refuge islands and removal is an ongoing 

management activity. 

Protection Island NWR

Historical uses of Protection Island include agriculture, military, research, residential, and recreation 

(Clark 1995). After establishment of the refuge, a solid waste disposal site was removed in 1996. In 

2003, surveys and tests were conducted across the island to establish baseline contamination levels of 

selected chemicals. None of the selected chemicals were detected at any sites (USFWS 2003). Creosote 

pilings were used in the marina, and this source of contamination will require future replacement with 

non-polluting pilings. 

San Juan Islands NWR

In the 1930s Smith Island was used as a naval bombing area by the United States military with aircraft 

from nearby Whidbey Island Air Station. Unarmed bombs and sonar buoys were dropped by naval 

aircraft as practice in hunting submarines (Skiff 2009). Therefore, munitions debris may still be found on 

the island. 

The United States Coast Guard has maintained a presence on the island as a location for aids to 

navigation. A lighthouse station was staffed from 1858 to 1957, when it was abandoned due to erosion 

threatening the structure. In 1998, the last of it disappeared into the sea and only miscellaneous structures 

remain (Butler et al. 2007). Underground and aboveground fuel storage areas as well as the potential for 

lead-based paint and asbestos associated with remaining structures were noted during a survey in 2006 

(USCG 2006). Refuge staff have also observed containers with unknown contents near the powerhouse 

during visits to the island. 

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Richardson 3 SE Lopez, Washington (457010). Available URL: http://www.wrcc.dri.edu/cgibin/cliMAIN.pl?wa7010. Accessed on February 7, 2007.

WRCC. 2010a. Climate of Washington. Available URL: 

http://www.wrcc.dri.edu/narratives/WASHINGTON.htm. Accessed on February 12, 2010.

WRCC. 2010b. Period of record monthly climate summary, Port Townsend, Washington (456678). 

Available URL: http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wa6678. Accessed on February 12, 

2010.

WRCC. 2010c. Period of record monthly climate summary, Olga 2 SE, Washington (456096). Available 

URL: http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wa6096. Accessed on February 12, 2010.

WRCC. 2010d. Average wind speeds by state: Washington. Available URL: 

http://www.wrcc.dri.edu/htmlfiles/westwind.final.html#WASHINGTON. Accessed on February 

12, 2010
Protection Island and San Juan Islands National Wildlife Refuges Admin Draft CCP/WSP/EA

3-26 Chapter 3. Physical Environment 

WRCC. 2010e. Average wind direction by state: Washington. Available URL: 

http://www.wrcc.dri.edu/htmlfiles/westwinddir.html#WASHINGTON. Accessed on February 12, 

2010.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-1

Chapter 4. Refuge Biology and Habitats

This chapter addresses the biological environment of the Protection Island and San Juan Islands National 

Wildlife Refuges (NWRs); however, it is not an exhaustive overview of all species and habitats. The 

chapter begins with a discussion of biological integrity, as required under the National Wildlife Refuge 

Administration Act, as amended. The biological integrity (601 FW3) analysis section introduces the 

biological environment by describing the native wildlife and vegetation that occur on the two Refuges in 

comparison to the surrounding landscape. The bulk of the chapter is then focused on the presentation of 

pertinent background information for the priority habitats and species that the Refuge Complex personnel 

will actively manage to accomplish biological conservation and/or restoration. The priority habitats and 

species are collectively known as the ‘priority resources of concern’ designated under this CCP. 

Background information includes description, location, condition, trends, key ecological attributes, and 

threats associated with each priority resource of concern. The information presented herein was used by 

the CCP team to develop goals and objectives for each of the priority resources of concern. 

4.1 Biological Integrity Analysis

The National Wildlife Refuge System Improvement Act of 1997 directs the Service to ensure that the 

biological integrity, diversity, and environmental health (BIDEH) of the Refuge System are maintained 

for the benefit of present and future generations of Americans. In simplistic terms, elements of BIDEH 

are represented by native fish, wildlife, plants, and their habitats as well as those ecological processes that 

support them. National Wildlife Refuge System Policy on BIDEH (601 FW 3) also provides guidance on 

the consideration and protection of the broad spectrum of fish, wildlife, and habitat resources found on 

refuges and associated ecosystems that represents BIDEH on each refuge. Through the consideration of 

BIDEH, the refuges will provide habitat for all appropriate native species. Refuge management priorities 

may change over time and since the CCP is designed to be a living, flexible document, changes will be 

made as needed and at appropriate times as identified by refuge personnel. 

Protection Island NWR is located in the southeast corner of the Strait of Juan de Fuca approximately 2 

miles from the mouth of Discovery Bay. Approximately 70% of the island’s roughly 370 acres consists 

of an upland plateau surrounded by very high, steep-sloped sandy bluffs. Currently, about 80% of the 

plateau is covered by grassland and 20% by mixed coniferous forest. Sediment derived from the steep 

unvegetated bluffs along the north and south shorelines and transported by longshore currents to the ends 

of the crescent-shaped island results in two sand and gravel spits, Kanem Point on the southwest and 

Violet Point on the southeast.

The San Juan Islands NWR is located within the San Juan Archipelago, at the convergence of the Strait of 

Juan de Fuca and the Strait of Georgia. Geologically, the 83 small rocks, islands, and reefs comprising 

the refuge contain extensive exposures of sedimentary, metamorphic, and/or volcanic bedrock which are 

occasionally overlain with glacial and alluvial deposits, particularly on the larger islands. The 

combination of these soil characteristics, near-drought conditions during the summer months, and highly 

variable topography and aspect results in a diverse assemblage of plant communities and ecological 

systems that range from xeric to mesic (Franklin and Dyrness 1988). 

The BIDEH of the ecosystems, including and surrounding the Refuges, have undergone dramatic 

alterations since pre-settlement times. The most discernible changes are related to: a) the conversion and 

development of large portions of coastal areas into agriculture, housing, commercial, and industrial lands; 

b) human-caused wildlife disturbance; c) the introduction of contaminants into the aquatic environment; 

d) fisheries bycatch and marine debris; e) the alteration of fire regimes; f) the loss of native species 
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4-2 Chapter 4. Refuge Biology and Habitats 

accompanied by a large influx of non-native and invasive plants and animals into the system; and g) 

climate change. This section discusses the connection between these main landscape level changes with 

the current vegetation and wildlife on the lands and waters occupied by the Refuges. This summary is not 

a complete analysis of all factors related to changes in native vegetation, fish and wildlife. For the 

purposes of this document, we define the Salish Sea as encompassing the Strait of Juan de Fuca, Puget 

Sound (Olympia north to Deception Pass and west to Hood Canal), San Juan Archipelago and the Strait 

of Georgia (See Figure 1.1). This area effectively defines the ecosystem that encompasses the refuges. 

We use this term wherever relevant; however, it is a relatively new term and spans international 

boundaries. Therefore, throughout this chapter, we may refer to the sections of the Salish Sea listed 

above when a study, survey, or other source reports only for that section. 

4.1.1 Habitat Loss or Degradation

Habitat conversion for human uses within the Salish Sea, which includes Protection Island and the San 

Juan Islands, has been rapid since the mid-late 1800s and continues today, bringing profound and 

widespread alterations to the watersheds and shorelines of the region. Logging and the milling of logs 

were among the earliest and more defining aspects of early settlement. Lower floodplains and tidal 

wetland areas were diked and drained in order to become prime locations for agricultural settlement. 

Major river delta areas such as Seattle and Tacoma were converted into centers of industrial and urban 

development. Today, over 40% of the region has been converted to urban or agricultural uses while most 

of the remainder is in production forestry (Floberg et al. 2004).

Furthermore, as residential, commercial, and industrial development occurs in close proximity to water, 

spit features and other low-lying sediment depositional areas along the shoreline were modified by 

armoring (bulkheads consisting of rock, concrete and timber), large revetments (sloped face to protect a 

bank or shore structure, usually constructed of rock), causeways (fill corridors that extend across 

embayments), groins (cross-shore structures designed to trap sediment), overwater structures, fill, and 

dredging (Johannessen and MacLennan 2007). Approximately 34 percent, or 805 miles, of the shoreline 

inventoried by the Washington State ShoreZone Inventory has undergone such modifications (WDNR 

2001). Shore modifications, almost without exception, impact the ecological functioning of nearshore 

coastal systems. The proliferation of these structures has been viewed as one of the greatest threats to the 

ecological functioning of coastal systems (PSAT 2003a, Thom et al. 1994).

4.1.2 Human-caused Wildlife Disturbance

Many of our partners have identified this threat in their plans and have identified similar strategies to ours 

to address this threat (USFWS 2005, WDFW 2005, Evens and Kennedy 2007, Mills et al 2005, NMFS 

2008, Tessler et al 2007, USFWS 2007). The counties containing the Refuges (San Juan, Jefferson, 

Whatcom, Skagit, and Island) have experienced rapid (>50% increase) human population growth over a 

twenty year period from 1980 to 2000 (WSDOT 2009). Additionally, this area has become an 

increasingly popular tourist destination, particularly during the summer months. As a result, activities 

such as fishing, boating, recreational aviation, camping, and other economic and recreational activities 

have increased within the coastal areas. These activities often cause stress, reduced productivity, and 

increased predation of seabirds and pinnipeds associated with the Refuges (Rojek et al. 2007). Please 

refer to the Priority Resources of Concern sections for further discussion and detailed descriptions of 

habitat, associated wildlife, and disturbance factors.

4.1.3 Oil Spills and Other Contaminants

These two refuges are particularly vulnerable to the threat of oil spills. Shipping lanes for cargo ships and 
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Chapter 4. Refuge Biology and Habitats 4-3

large oil transport vessels that carry crude oil to refineries are located throughout the Salish Sea with 

primary ports in Seattle, Tacoma, Olympia, Port Angeles, Everett, Bellingham, Anacortes, Washington,

and Vancouver, B.C. Tanker traffic alone through this area carries over 15 billion gallons of oil each year 

(WDOE 2009). Such high vessel presence increases the risk of oil spills that can cause devastation to the 

marine ecosystem. Additionally, other sources of hydrocarbon pollution from diesel, gasoline, kerosene, 

lubricant and various industrial oils are just as toxic to wildlife but can occur at a much smaller scale and 

may not be properly tracked (USFWS 2005). 

In addition to the threat of oil spills, over the past 150 years human activities around the Salish Sea have 

introduced a variety of persistent, bioaccumulative toxic chemicals into the environment at levels that can 

be harmful to both humans and wildlife. These toxic chemicals include heavy metals such as lead, 

mercury, and copper as well as organic compounds such as polycyclic aromatic hydrocarbons (PAH), 

polychlorinated biphenyls (PCB), dioxins, furans, phthalates, and polybrominated diphenyl ethers 

(PBDE). These contaminants enter into the aquatic environment through a variety of sources and human 

activities including industrial and municipal discharges, groundwater seepage, atmospheric deposition, 

and resuspension of sediments (PSAT 2003b). While primarily concentrated in areas around urban or 

industrial developments, these contaminants affect a much larger area of the ecosystem. When organisms 

live in or eat within these areas of contamination, not only are they directly harmed but they also 

accumulate contaminants in their tissues and transfer them throughout the food web. In addition, ballast 

water and other waste dumping from ocean vessels also increase contaminant load in the Salish Sea 

(Puget Sound Water Quality Action Team 2000). 

4.1.4 Fisheries Bycatch and Marine Debris

With the growth of fisheries within the Salish Sea, the incidences of interactions between fisheries and 

seabirds and pinnipeds have increased. Seabird mortalities due to gillnet fisheries have been documented 

in Washington (Thompson et al. 1998). Additionally, the proliferation of derelict (lost or abandoned) 

fishing gear or nets is becoming a problem in the Salish Sea. Derelict gear poses an entanglement hazard 

to invertebrates, fish, waterfowl, seabirds and marine mammals (Natural Resource Consultants 2004, 

Evens and Kennedy 2007, Natural Resource Consultants 2008, Northwest Straits Initiative 2008). During 

one study of 4 derelict nets in the Puget Sound, seabirds (88% of which were cormorants) were caught at 

a rate of 0.24 per day. At this rate, researchers calculated that each net could entangle approximately 7 

seabirds per month. Compound that over the estimated 3,800 derelict nets distributed throughout the area 

and up to 26,600 seabirds per month could be lost to this threat (Natural Resource Consultants 2008). 

Seals have also been observed with wounds and scarring from entanglement with derelict gear and 

interactions with aquaculture (net pen) operations. 

4.1.5 Alteration of Fire Regimes

The predominant pre-Euroamerican settlement vegetation on lowlands west of the Cascades, from the 

Willamette Valley of Oregon north to the Georgia Basin of southwest British Columbia, was a mosaic of 

grasslands, oak and conifer savannas, and various types of wetlands (Chappell and Crawford 1997, 

Sinclair et al. 2006). Oak woodlands and dry Douglas-fir forests were found in dry sites with shallow 

bedrock or deep, gravelly glacial outwash soils, and high growing season moisture stress (Chappell et al. 

2001, Natureserve 2009). Historically, fire was a major component of these habitats. 

In addition to occasional lighting strikes, fires were intentionally set by Native Americans to maintain 

food staples such as camas and bracken fern, prevent oak-dominated stands from converting to Douglasfir forests, keep tree densities lower, and maintain grassy, as opposed to shrubby, understories. Although 

there is no definitive fire history information, evidence suggests that many, if not most, grasslands and 
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4-4 Chapter 4. Refuge Biology and Habitats 

savannas burned every few years. Fire frequency within forest and woodlands probably ranged from 

frequent (every few years) to moderately frequent (once every 50-100 years), and reflected low-severity 

and moderate-severity fire regimes (Chappell et al. 2001). The exclusion of fire from most of these 

habitats over the past 100-130 years has resulted in profound changes. In the absence of fire, trees show a 

tendency to encroach upon grasslands and savannas, eventually converting these areas to mixed conifer 

forests and woodlands. Fire suppression, along with factors such as invasive non-native species, grazing, 

and urban and agricultural conversion, has greatly reduced the amount of native grassland to just a small 

fraction of the pre-Euroamerican settlement extent. Estimates of remaining prairie vary from 10% of the 

pre-settlement extent in south Puget Sound (Crawford and Hall 1997), to less than 5% (including 

savannas) in southwest British Columbia (Garry Oak Ecosystem Recovery Team cited in Sinclair et al. 

2006), to 1% in the Willamette Valley (Wilson et al. 1995).

4.1.6 Influx of Exotic, Invasive, and Other Species of Management Concern

One of the largest threats to the wildlife and habitat of the Refuges is invasive plants and pest animals. 

Invasive plant species displace native vegetation, altering the composition and structure of vegetation 

communities, affecting food webs, and modifying ecosystem processes (Olson 1999). Introduced native 

and non-native animal species are usually in direct competition with native wildlife species for food, 

shelter, and breeding areas and often cause existing native species populations to decline or become 

extirpated. Ultimately, both plant and animal invasive species can result in considerable impacts to native 

wildlife and the habitat upon which they depend.

Invasive marine algae, plants, and wildlife

The ballast water of ships is a vector for the transport of marine invasive species (Carlton and Geller 

1993) which threatens the conservation and sustainable use of biological diversity (Bax et al. 2003). 

These are some of the newest and least understood threats to the refuges due to difficulties in monitoring 

and jurisdictional controls. Plants such as Japanese eelgrass, common cordgrass and the algae Sargassum

seaweed have been recorded within the Salish Sea. Many of these species have infested large areas along 

the outer coast of Washington and removal has been costly. Other species of algae such as Japanese kelp 

and Caulerpa have not yet been found in the Salish Sea. To date, none of the species listed in Puget 

Sound Marine Invasive Species Monitoring Program - Target Species List (Eissinger 2009) are known to 

exist on or near any of the refuge islands. Marine invertebrates are also a threat to refuge resources that 

have not been well understood. The refuge staff has begun monitoring for European green crab and plans 

to expand monitoring efforts to include tunicates, particularly at the Protection Island marina. The 

Service is required to maintain the marina on Protection Island and any infestation of these tunicates will 

impact native marine wildlife which may then affect refuge trust resources. The effects of these threats 

are similar to that of oil spills, marine debris, and derelict fishing gear in that they occur mainly outside 

refuge jurisdictional boundaries, but still affect refuge resources. 

Invasive, non-native terrestrial plants and animals

Non-native invasive plants on the Refuges include European beachgrass, Canada thistle, Himalyan 

blackberry, cheatgrass, Kentucky bluegrass, English ivy, field bindweed, and Scotch broom. This list is 

not all inclusive and includes only the most problematic species; many other exotic plants have been 

introduced.

Herbivores and predators of management concern

Native and non-native mammals that have the potential to negatively affect seabird populations and their 
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Chapter 4. Refuge Biology and Habitats 4-5

habitat on the refuges include black-tailed deer; rabbits, rats and small rodents; raccoons; red fox; feral 

and domestic cats; trespassing dogs; river otter; mink, short and long-tailed weasels. 

Black-tailed deer are native and abundant from the Cascade crest west toward the coast range (WDNR 

2009, WDFW 2009). However, there are no historic records of black-tailed deer on Protection Island 

(Richardson 1961, USFWS 1985). Three adult deer were first observed on the island in 1991 (Hayward 

2008). Due to a high reproductive rate and lack of natural predators on Protection Island, this number has 

increased to a high estimate of 100 deer in 2008/2009 (J. Hayward pers. comm.). The most current 

estimate as of February 2010 consists of approximately 70 deer (P. Davis pers. comm.). Black-tailed deer 

use all habitat types present on Protection Island including forest, grassland, bluff, and shoreline. Refuge 

staff have also observed black-tailed deer on refuge islands in the San Juan Archipelago. For information 

on the effects of deer under current management, see Chapter 6.

European rabbits are one of the fastest colonizing mammals in the world, primarily because of their high 

reproductive rate (Hall and Gill 2005). European rabbits do occur on the larger islands within the San 

Juan Archipelago; however, the only sign of rabbit presence on a refuge island has been rabbit pellets on 

Nob Island within the San Juan Islands NWR (Murphy pers. comm.). Rabbits can potentially compete 

with seabirds for nesting areas and change vegetation at colony sites, affecting the reproductive success of 

seabirds (Courchamp et al. 2003). 

Predation, particularly by non-native predatory mammal species such as rats, have been documented to 

have devastating effects on nesting seabird populations throughout the world (Kadlec 1971, Jehl 1984, 

Atkinson 1985, USFWS 1993, Ashmole et al. 1994, Gaston 1994). Predator impacts on seabirds may 

include direct predation of eggs, young, and adults; reproductive failure due to disturbance during the 

nesting season; and detrimental alteration of habitat, including destruction of nesting burrows. These 

impacts can result in complete abandonment of nesting colonies.

4.1.7 Climate Change

A growing body of scientific evidence has emerged demonstrating that the world climate is changing and 

that changes in atmospheric composition due to human activity are the drivers for global warming 

(Bierbaum et al. 2007, IPCC 2007). Average annual air temperatures on the earth’s surface have 

increased by 1.3 degrees F since the mid-19th century. Furthermore, the increasing trend in global 

temperatures over the last 50 years is approximately twice the trend of the previous 50 years. From 1995 

to 2006, global surface temperatures have been the warmest on record since 1850 (IPCC 2007). The 

global climate system, in turn, controls regional and local-scale climate conditions within the Pacific 

Northwest. Projected impacts to the region encompassing the refuges include changes in seasonal 

temperatures, precipitation, extreme weather events, oceanic conditions, and sea level rise.

Climate change may have drastic effects on these refuges, but due to the complexity of the issue and 

unknown severity of change, the magnitude of the effects of climate change on the BIDEH of the refuges 

during the term of this CCP cannot be predicted. Climate change will further exacerbate all of the 

environmental stressors imposed by the threats listed in this and the following sections as they will likely 

be additive or synergistic. The anticipated effects of climate change on the Priority Resources of Concern 

are addressed in the following sections.
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4-6 Chapter 4. Refuge Biology and Habitats 

4.2 Priority Resources of Concern Selection and Analysis

4.2.1 Priority Resources of Concern Selection

In preparing this plan, the Service reviewed other local, regional, and national plans that pertain to the 

wildlife and habitats of Protection Island and San Juan Islands NWRs (see Appendix C). The Service 

also sought input from Washington State conservation agencies, non-governmental organizations, and the 

general public. The refuges’ purposes, as stated in the enabling legislation for each refuge (see Chapter 1) 

were carefully reviewed as was the refuges’ contribution to maintenance of BIDEH (Appendix C) within 

the ecoregion. As a result of this information gathering and review process, a comprehensive list of 

potential resources of concern was developed. From this list, those species and habitats that are most 

representative of refuge purposes and habitats, BIDEH, as well as other Service and ecosystem priorities, 

were chosen as priority resources of concern (habitat types) and focal resources (plant and animal 

species). Habitats selected as priority resources of concern include shoreline, bluff, 

grassland/savanna/herbaceous bald, forest and woodlands, and wetlands (see Table 4.1). The 

International Terrestrial Ecological System Classification under development by NatureServe and its 

natural heritage program members was used to describe and map refuge vegetation types (see Figures 4.1, 

4.2, and Appendix C) which fall under the more general refuge habitat types. 

Priority resources of concern and focal resources consist of habitats and species whose conservation and 

enhancement will guide refuge management into the future. Potential management actions will be 

evaluated on their effectiveness in achieving refuge goals and objectives for the priority resources of 

concern. However, many native species that are present on the refuges will also benefit. They are 

referred to here as other benefiting species. See Appendix C for a completed list of priority resources of 

concern, focal resources, and other benefiting species.

4.2.2 Priority Resource of Concern Analysis

In the following sections, information is provided on the location, condition, associated wildlife, key 

ecological attributes, and threats for each priority resource of concern. There will be a description of 

location and condition of each priority resource of concern on Protection Island and San Juan Islands 

NWRs within the context of the Salish Sea ecosystem. Next, focal resources and other benefiting species 

are listed in the associated wildlife section. A preliminary analysis is then presented in the form of key 

ecological attributes. Key ecological attributes represent those aspects of the environment, such as 

ecological processes or patterns of biological structure and composition, that are key to sustaining the 

long-term viability of the resource. These key ecological attributes are further divided into measurable 

indicators that strongly correlate with the status of the attribute. The team developed desired conditions 

that were based on scientific literature review, consultation with species or area experts, and the team’s 

professional judgment. Desired condition levels for each measurable indicator were used to help design 

objectives for the priority resource of concern as presented in Chapter 2. The last section includes a 

discussion on threats. Threats are defined as something that destroys, degrades, or impairs a priority 

resource of concern by impacting a key ecological attribute of that resource. Additionally, different 

threats place varying degrees of pressure on the environmental system and can become cumulative. 

Threats are of major concern and are addressed within this plan. A similar analysis is presented for focal 

resources (seabirds, marine mammals, etc.) following the analysis for priority resources of concern. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-7

Table 4.1. Priority Resources of Concern, by Refuge Unit. 

Refuge Unit Shoreline

Sandy 

Bluff

Grassland/

Savanna/

Herbaceous 

Bald

Forest/

Woodland Wetland

Protection Island NWR

Protection Island x x x x

San Juan Islands NWR

1. Small Island x

2. Two Unnamed Islands (Ram Ils.) x x x

3. Unnamed Island (Fortress Island) x x

4. Unnamed Island (Skull Island) x

5. Unnamed Island (Crab Island) x

6. Boulder Island x x

7. Davidson Rock x

8. Castle Island x x

9. 3 unnamed islands x x

10. Aleck Rocks x x

11. Unnamed Island (Swirl Island) x x

12. Unnamed Rock x

13. 4 Unnamed Islands x x

14. 3 Unnamed Islands x

15. Hall Island x x

16. Unnamed Island x

17. Secar Rock x

18. Unnamed Rock (Round Rocks) x

19. 3 unnamed islets x x

20. 13 unnamed islands x x

21. Mummy Rocks x

22. Islets and Rocks associated with 

Deadman Island x

23. Shark Reef x

24. Harbor Rock x

25. Unnamed Rock (North Pacific Rock) x

26. Half Tide Rocks x

27. 7 Unnamed islands x

28. Low Island x

29. Unnamed Island (Pole Island) x x

30. Barren Island x x

31. Battleship Island x x x

32. Unnamed Rock (Sentinel Rock) x

33. Center Reef x

34. Gull Reef x

35. Ripple Island x x x

36. Unnamed Reef (Shag Reef) x

37. Unnamed Island (Little Cactus Isl.) x x

38. Gull Rock x x

39. Flattop Island x x x

40. White Rocks x x

41. Mouatt Reef x

42. Skipjack Island x x x
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4-8 Chapter 4. Refuge Biology and Habitats 

Refuge Unit Shoreline

Sandy 

Bluff

Grassland/

Savanna/

Herbaceous 

Bald

Forest/

Woodland Wetland

43. Unnamed Island x

44. Clements Reef x

45. Unnamed Island x

46. Parker Reef x

47. The Sisters x x

48. Unnamed Island (Little Sister) x x

49. Unnamed Islet x

50. Tift Rocks x x

51. Unnamed Rock(s) x

52. Turn Rock x

53. Shag Rock x

54. Flower Island x x

55. Willow Island x x x

56. Lawson Rock x

57. Pointer Island x

58. Black Rock x

59. 3 unnamed rocks (Spindle Rock) x

60. Brown Rock x x

61. Unnamed Rock x

62. South Peapod Rock x x

63. Peapod Rocks x

64. North Peapod Rock(s) x x

65. Eliza Rock x

66. Viti Rocks x x

68. Unnamed rock (Bird Rock) x

69. Unnamed Islands x

70. Low Island x x

71. Unnamed (Nob Island Group) x x x

72. Unnamed Island x x

73. Unnamed Island x x

74. Unnamed rocks x

75. Smith Island x x x x

76. Minor Island x

77. Matia Island x x x x

78. Puffin Island x x x

79. Turn Island x x x

80. Four Bird Rocks x

81. Three Williamson Rocks x x

82. Colville Island x x

83. Buck Island x x

84. Bare Island x x
Data Sources: Vegetation Classified to NatureServe Ecological Systems Based on 7/30/2003 WDOT True Color Aerial Photography

Figure 4.1 Protection Island Current Vegetation

Chapter 4. Refu

ge Biolog

y and Habitats 4-9

Ecological Systems

North Pacific Dry Douglas-Fir-(Madrone) Forest And Woodland

North Pacific Herbaceous Bald and Bluff

North Pacific Maritime Coastal Sand Dune and Strand

Transitional Vegetation Savanna/Grassland

Transitional Vegetation Coastal Sand Dune and Strand

Transitional Vegetation Tall Shrub

Developed, Low Intensity

Unconsolidated Shore

Water 

Kanem Point

0 

0 
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4-10 Chapter 4. Refuge Biology and Habitats 

To preserve the quality of our map, this side was left blank intentionally.
Data Sources: Vegetation Classified to NatureServe Ecological Systems Based on 2006 NAIP

Figure 4.2 Smith and Minor Islands Current Vegetation

Chapter 4. Refu

ge Biolog

y and Habitats 4-11

Ecological Systems

North Pacific Herbaceous Bald and Bluff

North Pacific Maritime Coastal Sand Dune and Strand

North Pacific Coastal Interdunal Wetland

Transitional Vegetation Grassland

Transitional Vegetation Tall Shrub

Transitional Vegetation Short Shrub

Developed, Low Intensity

Unconsolidated Shore

Water 

Smith Island

0 
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4-12 Chapter 4. Refuge Biology and Habitats 

To preserve the quality of our map, this side was left blank intentionally.
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Chapter 4. Refuge Biology and Habitats 4-13

4.3 Shoreline

4.3.1 Description and Location

This habitat type comprises sandy/gravelly (unconsolidated) shoreline, including spits, rocky 

(consolidated) shoreline, and associated rocky cliffs. Sandy/gravelly shoreline is defined by having 

substrata consisting of components smaller than cobble (10” diameter), including gravel, sand, mud, and 

organic materials (Dethier 1990). The North Pacific Maritime Coastal Sand Dune and Strand ecological 

system is associated with sandy/gravelly shoreline and spits. For more information, see Appendix C. 

Rocky shoreline is defined by having substrata composed of bedrock, boulders (rocks greater than 10” 

diameter that are large enough not to be rolled by moderate wave action), and/or hardpan. Steep, rocky 

cliffs can be associated with rocky shoreline and are generally devoid of vegetation with occasional wind 

sweep shrubs, succulents and grasses growing from fissures.

The amount of shoreline managed by the Service is roughly 4.7 miles at Protection Island and 34 miles in 

the San Juan Islands. Approximately 340 acres surrounding Protection Island from mean high tide to the 

mean low tide are managed by the Service under a WDNR aquatic lands lease. Additionally, the 

bedlands surrounding Protection Island extending to 600 feet beyond the extreme low tide line are 

withdrawn from “conflicting uses” for conservation purposes (WDNR 1988 Withdrawal Order 88 017).

Sandy/gravelly shoreline comprises the entire perimeter around Protection Island. Kanem and Violet 

Point spits at the west and east ends of the island are formed by glacial deposits eroding from the high 

bluffs and transported by longshore currents. At the high water line, a backbone of driftwood helps to 

hold the sediment and provides beach nourishment.

Protection Island NWR

The distribution of vegetation along the spits is affected by disturbance processes such as wave overwash 

during storm tidal surges, sand deposition, erosion, and lateral movement. Currently, on Violet Point, 

native species continue to dominate even when associated with introduced species such as European 

beach grass. Overall, Violet Point has higher native species richness and percent cover and lower 

introduced species richness and cover than the upland plateau (Cowles and Hayward 2008).

The tidelands surrounding Protection Island are considered intertidal mudflats. Since vascular plants are 

unable to persist due to the diurnal tidal flooding of salt or brackish water, algae are the dominant 

vegetation. Occasional small patch occurrences of eelgrass beds also border Protection Island (WDNR 

Nearshore Habitat Program 2001). 

Sandy/gravelly shoreline occurs in the San Juan Islands Refuge as either spits or isolated pocket beaches. 

Smith (#75) and Minor (#76) Islands, located in the eastern Strait of Juan de Fuca, are connected by a low 

spit that is covered at high tide. Small portions of the spit that are not frequently overwashed by tidal 

storm surges have vegetation communities associated with the dune and strand ecological system 

dominated by American dunegrass and other forbs adapted to salty dry conditions. Isolated pocket 

beaches contained by rocky headlands and consisting of sandy and/or gravelly shorelines exist on Turn 

(#79) and Matia (#77) Islands as well as many other small islands.

San Juan Islands NWR 

Rocky shoreline occurs extensively within the San Juan Islands Refuge as most of the islands are small 

rocky benches or outcrops that are sparsely vegetated, unvegetated, or tidally inundated reefs. Reefs are 

usually underwater at high tide and only support marine algae. The substrate is usually bedrock, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

4-14 Chapter 4. Refuge Biology and Habitats 

sometimes in conjunction with boulders. On sparsely vegetated islands, lichens and mosses cover the 

bare rock within the backshore area and are occasionally joined by forbs that occur on small glacial 

outwashes that collect in rock crevices and depressions. Common herbaceous species adapted to the low 

moisture, intense wind, and salt spray experienced by these small rocky outcrops include sea plantain, 

lance-leaved stonecrop, and sea thrift (Atkinson and Sharpe 1993).

Cliffs with rocky ledges, outcroppings, and crevasses can be found on Castle (#8), Hall (#15), Battleship 

(#31), Flattop (#39), Skipjack (#42), Little Sister (#48), Willow (#55), South Peapod (#62), Viti Rocks 

(#66), Matia (#77), and Puffin (#78) Islands.

4.3.2 Associated Wildlife 

Focal resources for this habitat type include the pelagic cormorant, double-crested cormorant, pigeon 

guillemot, glaucous-winged gull, black oystercatcher, and marine mammals. Detailed information on 

these species can be found in the Seabird, Marine Mammals, and Black Oystercatcher sections of this 

chapter. 

Other benefiting species include the brant, harlequin duck, Brandt’s cormorant, black and ruddy 

turnstone, rock sandpiper, surfbird, dunlin, black-bellied plover and sanderling (migration and winter);

wandering tattler and western sandpiper (migration); brown pelican (rare fall migrant); Heermann’s gull, 

and killdeer (breeding), and Caspian terns and peregrine falcon (breeding, though no known nests/eyries 

on refuges); great blue heron, river otter, herring, and sand lance (year-round). 

4.3.3 Conditions and Trends

Prior to Euroamerican settlement, the condition of sandy/gravelly and rocky shorelines within the Salish 

Sea was primarily affected by natural processes and disturbances (i.e., accretion and erosion) and regional 

variations in geology, climate and precipitation, wave action, tidal range currents, and local sea level 

history. Currently, the condition of these shorelines is dramatically affected by human-caused 

modifications such as armoring and slope stabilization, groins and jetties, upland hydrologic changes, and 

fills. These modifications disrupt natural geomorphic processes, leading to altered accretion and erosion 

patterns. 

Marine debris is a continuous source of pollution on the shorelines of both refuges. The only shoreline 

that is regularly cleaned is on Protection Island. The Smith Island shoreline is especially covered in 

marine debris. Creosote pilings that were used to build the docks on Protection and Matia Islands 

continue to leach contaminants into the shoreline sediment. In addition, some refuge shorelines have 

rogue creosote logs that have accumulated and continue to contaminate the sediment above the high tide.

With the exception of the construction of a marina on Protection Island prior to refuge establishment, the 

refuge shorelines have not been directly modified. However, the disruption of geomorphic processes 

resulting from changes to off-refuge shorelines can indirectly affect the morphology of the refuge 

shorelines. Most of the shoreline showed little natural modification between 1956 and 1999 beyond what 

could be accounted for by differences in tides. However, exceptions include Kanem Point, which 

regressed 26 meters in length over this 43-year period due to erosion at the tip and narrowed slightly at 

the base below the bluffs. Violet Point increased from 915 to 957 meters in length and the wide beach that 

formerly spanned the region from the lagoon at the base of the Point north to the sea became vegetated 

due to filling and grading the area (Cowles and Hayward 2008). The marina was created by breaching 

Violet Spit and filling in the existing tidal wetland. The inner harbor shoreline lacks the amount of 

Protection Island NWR
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-15

woody debris and vegetation found on the spit shorelines. An extended user house was recently removed 

from the base of Violet Spit. 

In addition to changes to the physical structure and stability of refuge shorelines, other recent 

anthropogenic impacts include altered vegetation communities and pollution. On Protection Island, 

European beach grass was planted by the 1920s to stabilize dunes. Other non-native species now found 

on the sand dunes, spits, and strand include grasses such as ripgut brome, common velvetgrass, Kentucky 

bluegrass, meadow barley, and orchard grass, and forbs including silver burweed and common sow 

thistle. However, now that agricultural and development activities on Protection Island have ceased, 

native species appear to be making at least a partial recovery (Cowles and Hayward 2008).

The rate of erosion and subsequent supply of sediment on Smith Island continually affects the formation 

and maintenance of Minor Island. However, due to the resistance of the basalt bedrock and the lack of 

significant wave action, the other shorelines and rock cliffs within the San Juan Islands NWR have 

largely undergone negligible erosion and retreat. 

San Juan Islands NWR

Since refuge establishment, all shoreline habitats have been managed to minimize human-caused 

disturbance to nesting seabirds and other wildlife. Rocky cliffs are by their nature resistant to wave action 

erosion, however, projected sea level rise associated with climate change may reduce the quantity of this 

habitat in the future (Huppert et al. 2009).

4.3.4 Key Ecological Attributes

Table 4-2. Shoreline Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Physical 

Structure and 

Stability

1. Presence/absence of human-caused 

alteration of longshore currents or 

sedimentation processes (PI only)

2. Abundance and density of driftwood

1. No structural interference of 

shoreline development on PI 

(exception of the marina)

2. Continuous expanses of 

driftwood

Plant 

Community 

Structure and 

Composition 

1. Presence of native, sparse, short grasses 

on spit habitat

2. Ratio of native to invasive species on spit 

habitat

3. Presence/absence of rare plant species on 

cliff habitats

1. <30% cover and 3- 4 feet in 

height of native grasses

2. <25% of invasive species

3. Presence of brittle prickly pear 

cactus

Security and 

Human Impacts

1. Human activity on or near cliffs, rocky,

and sandy/gravelly shorelines

2. Presence/absence of rabbits or 

mammalian predators

3. Presence/absence of marine debris or 

creosote-covered materials

1. No trespass on all closed 

shorelines and minimal boat 

disturbance within 200 yards of 

closed refuge islands and 

shorelines.

2. No rats, rabbits, red fox, feral or 

domestic pets; few to no other 

mammalian predators

3. No marine debris or creosote on 

shorelines
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

4-16 Chapter 4. Refuge Biology and Habitats 

4.3.5 Threats

Threats facing the shorelines of Protection Island and the San Juan Islands refuges include climate change 

induced sea level rise, geologic events, invasive species, human intrusions and disturbance, and 

contaminants and marine debris.

Likely effects due to sea level rise and other climate-related factors include increased inundation, erosion, 

and overwash during storm events, leading to losses of shoreline habitats (Mote et al. 2008, Huppert et al. 

2009). Additionally, climate-driven changes in ocean currents, sea temperatures, salinity, and the timing 

of resource availability have the potential to affect intertidal communities (Menge et al. 2008), eelgrass 

beds (Snover et al. 2005), seabirds, and marine mammals that use refuge shoreline and adjacent nearshore 

habitats.

Geologic events such as accretion and erosion affect the physical structure and stability of the refuge 

shorelines. Human-caused modifications such as armoring and slope stabilization, groins and jetties, 

upland hydrologic changes, and fills disrupt natural geomorphic processes, leading to altered accretion 

and erosion patterns which may degrade refuge shoreline habitat. Additionally, the presence of driftwood 

plays an essential role in maintaining the structure of refuge shorelines. Natural threats to the driftwood 

piles such as currents, decay, and fire in addition to human-caused threats such as collecting, moving, and 

illegal fires could also affect shoreline structure and stability. Fires, particularly, pose a serious threat as 

they have high potential to ignite vegetation and spread rapidly into adjacent habitats.

Non-native and invasive plant species threaten shoreline habitats by displacing the native sand dune, spit, 

and strand species, altering vegetation communities, and modifying ecosystem processes. Non-native and 

invasive plant and animal species directly compete with native species and often cause existing native 

species populations to decline or become extirpated. 

Although the majority of the refuges’ shorelines are closed to public access, human-caused disturbances 

and trespass still pose direct threats to seabirds and pinnipeds (refer to the Seabird, Black Oystercatcher, 

and Marine Mammal sections of this chapter for more information). Also, seabird nesting colonies and 

pinniped rookeries are extremely vulnerable to the effects of oil and other contaminants. Numerous oil 

tankers, cargo vessels, bulk carriers, and barges use the waters near the refuges as primary transportation 

routes. Any spill from these routes could potentially be devastating to populations of marine wildlife and 

habitat. In addition, non-point source oil tarballs, or slicks periodically wash up and impact wildlife. 

Non-point chronic sources may be products of vessels illegally pumping bilges, recreational outboard 

motors, and improper use of petroleum products in marinas (USFWS 2005).

4.4 Sandy Bluffs

4.4.1 Description and Location 

Sandy bluffs are classified under the North Pacific Coastal Cliff and Bluff ecological system, which 

includes bluffs composed of glacial deposits (NatureServe 2009). Steep, eroding coastal bluffs are 

composed of a sequence of glacial and interglacial sedimentary units (Dragovich et al. 2005) with 

occasional sparse cover of forbs, grasses, lichens, and low shrubs. The area occupied by the sandy bluff 

habitat type within the Protection Island and San Juan Island Refuges has not been surveyed and is 

difficult to quantify. 
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Chapter 4. Refuge Biology and Habitats 4-17

On Protection Island, bluffs completely surround the upland plateau. Large portions of the vegetated 

bluffs above Kanem and Violet Points are covered with non-native grasses including European beach 

grass, ripgut brome, and meadow barley. Occasionally codominant native grasses include Idaho fescue 

and red fescue. Yarrow and gumweed are typical native forbs while non-native forbs distributed in 

patches along the bluffs include hedge mustard, alfalfa, sow thistle, bull thistle, and field bindweed.

Protection Island NWR

On Smith Island, bluffs rise directly landward of the beach on the northwest, west, and southwest sides. 

Between the upland grassland and the unvegetated portion of the bluffs, the shallow soil on the steeply

sloped areas supports some grasses and forbs. 

San Juan Islands NWR

4.4.2 Associated Wildlife

Focal resources associated with sandy bluffs include the rhinoceros auklet and tufted puffin. For more 

detailed information on these species, see the Seabird section in this chapter. Other benefiting species 

that use this habitat type include snowy owl (nonbreeding) and swallows and Canada goose (breeding). 

4.4.3 Condition and Trends

Prior to Euroamerican settlement, the historic condition of the coastal bluffs on Protection Island NWR 

and Smith Island (within the San Juan Islands NWR) was largely driven by the natural, on-going process 

of erosion. The vegetated portions of the bluffs were likely dominated by native grasses such as Idaho 

fescue, California oatgrass, Lemmon’s needlegrass, red fescue, and prairie junegrass and associated with 

a high diversity of forbs. Following Euroamerican settlement, practices associated with agriculture and 

development, including overgrazing, deforestation, and the introduction of non-native species (i.e., 

European beach grass), altered both the vegetative composition and erosional patterns of the islands. 

Coastal bluff erosion is the result of numerous interacting variables including first-order factors such as 

climactic conditions and sea level rise and second-order factors such as geologic composition, surface and 

groundwater hydrology, and the relative rate of erosion at the bluff toe (Bray and Hooke 1997, 

Johannessen and MacLennan 2007). The cyclical process of bluff erosion is initiated when wave action 

removes material at the bluff toe creating an unstable bluff profile that eventually leads to landslides 

(mass-wasting) and the delivery of new material to the base of the slope (Emery and Kuhn 1982). Since 

Protection and Smith Islands both experience significant wave exposures along the Strait of Juan de Fuca, 

bluff erosion and recession rates are higher than at other less exposed areas of the Salish Sea. 

On Protection Island, early residents had reported rapid and extensive erosion of the northwest bluff 

(Cowles and Hayward 2008, Power 1976). This wasting may have resulted from unsustainable land uses, 

including overgrazing and deforestation. Since the 1950s, a slower rate of bluff erosion has occurred on 

the northwest margin where previous slide material was removed from the toe, leading to a steeper bluff 

profile. The northeast bluffs, which are nearly vertical and mainly bordered above by forest and 

woodland, showed little change. The southern bluffs, less steep and more protected from wave action, 

also showed little overall change (Cowles and Hayward 2008). During the 1800s, a road was built up the 

bluff overlooking Kanem Point. The road was used through the 1930s and has since eroded away, 

although some remnants can still be seen. During the 1960s, a dirt road was built at an angle up the bluff 

above Violet Point. Although still in use, it has already eroded away by half or more (Cowles and 

Hayward 2008). Otherwise, the overall physical structure of the vegetated portion of the bluffs 

overlooking both points has remained largely unchanged.

Protection Island NWR
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4-18 Chapter 4. Refuge Biology and Habitats 

At a more localized scale, however, sheep overgrazing during the 1950s led to the formation of slide areas 

of loose soil and sand, which clearly adversely affected nesting seabirds (Richardson 1961). Since the 

early 1990s, black-tailed deer have been found on Protection Island. The abundance of deer steadily 

increased to approximately 80-100 animals by 2007/2008 and appears to have declined to about 70 in

2010 (P. Davis, pers. comm.). They have created deeply eroded pathways through the unstable slopes; 

caused auklet burrows to cave in; laid down on burrow entrances and thus effectively blocked adults from 

entering burrow to feed chicks; and caused disturbance to the gull colony on Violet Spit.

At Smith Island, Keuler (1988) determined erosion rates of over 30 centimeters (11.8 inches) per year. 

The Smith Island lighthouse, built in 1858 about 200 feet away from the island’s western edge, collapsed 

into the water in spring 1998 due to bluff erosion (Nelson 2009).

San Juan Islands NWR

4.4.4 Key Ecological Attributes

Table 4-3. Sandy Bluff Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Physical 

Structure and 

Stability

1. Presence/absence of human structures 

(roads, residences, etc.)

2. Degree of slope and friability of soil

1. No human structures

2. Stable slopes and suitable soils 

for seabirds to build burrows in 

restored areas

Plant 

Community 

Structure and 

Composition 

1. Percentage of vegetative cover at the 

beginning of the rainy season

2. Presence/absence of invasive shrubs

3. Ratio of invasive to native plants

1. At least 50% vegetative cover

2. No invasive shrubs (Scotch 

broom)

3. <25% invasive plants

Security and 

Human Impacts

1. Presence/absence of human activity on or 

near bluffs

2. Presence/absence of deer, rabbits, and 

mammalian predators

1. Low human activity

2. No non-native rats, rabbits, red 

fox, feral or domestic pets on 

any refuge islands; no deer on

Protection Island. 

4.4.5 Threats

Threats facing the sandy bluffs of Protection Island and Smith Island (within the San Juan Islands NWR) 

include climate change, mass-wasting, invasive species, and human intrusions and disturbance.

Long-term climate change is expected to result locally in sea level rise, an increase in winter precipitation, 

and increased storm strength and frequency (Mote et al. 2008, Huppert et al. 2009). Among the key 

factors in bluff erosion are major storm events combined with high tides or elevated sea levels related to 

El Niño events (Shipman 2004). Storm events magnify the wave action on beaches and bluffs by 

increasing wave energy, wave height, and wind speed. Thus, sea level rise and the increase in storm 

severity and frequency will affect the future condition of the Protection and Smith Island bluffs by leading 

to larger and more frequent mass-wasting.

Introduced invasive plants (e.g., European beach grass, field bindweed) are a constant issue within the 

sandy bluff habitat. Many non-native species can directly outcompete native species by reducing light at 

the ground level and aggressively capturing water and nutrients. They also have the potential to alter 

ecosystem processes by producing nitrogen-enhanced litter, changing ground-level microclimates, 

altering fire regimes as a result of their flammability, enhancement of soil moisture deficits, and other 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-19

characteristics. 

Human intrusions, disturbance, and trespass within sandy bluff habitat have the potential to fragment, 

degrade, or destroy the habitat through trampling and erosion, cause tremendous disturbance to wildlife 

(refer to the Seabird section in this chapter for more information), and introduce invasive plant species 

into closed areas of the refuges. 

4.5 Savanna, Grasslands, and Herbaceous Balds

4.5.1 Description and Location 

Savanna, grasslands, and herbaceous balds are associated with dry sites in lowland and mid-montane 

western Washington and Oregon. Approximately 200 acres of Protection Island NWR and a total of 41 

islands within the San Juan Islands NWR currently have these habitats. These areas can be categorized 

into 2 ecological systems: Willamette Valley Upland Prairie and Savanna and North Pacific Herbaceous 

Bald and Bluff (Natureserve 2009). The prairie and savanna system differs from herbaceous balds in the 

following respects: 

• Prairies and savannas occur on relatively level terrain, primarily on deep, well-draining 

gravelly/sandy glacial outwash (Chappell and Crawford 1997, Crawford and Hall 1997, Chappell 

et al. 2001a, Natureserve 2009).

• Herbaceous balds typically occur in small patches on relatively shallow soils with an underlying 

restrictive layer of bedrock, and relatively dry topographic positions (e.g., on slopes) and can be 

intermixed with rock outcrops and fringed by areas of forest and woodland (Chappell et al. 

2001a, Chappell et al. 2001b, Chappell 2006). 

On Protection Island, the Willamette Valley Upland Prairie and Savanna system is associated with the 

deep, coarse, well-draining Townsend series glacial outwash deposits constituting the majority of the 

undulating upland plateau. Currently, the prairie exists in a degraded state with rhizomatous exotic 

grasses dominating throughout the plateau (Cowles and Hayward 2008). Some native herbaceous 

component is still present in the least disturbed areas on the western and eastern fringes of the plateau.

Protection Island NWR

The North Pacific Herbaceous Bald and Bluff system is found along the shallow soil, steep sloped, grassy 

areas on the southern or western aspects between the upland grassland and bluffs. While some native 

plants are still present, these areas are currently dominated by European beachgrass, meadow barley, 

alfalfa, and ripgut brome. 

Similar to Protection Island, the upland plateau of Smith Island is primarily composed of glaciomarine 

drift and till (Dragovich et al. 2005). These well-draining substrates support a degraded prairie 

interspersed with early successional deciduous-dominated forest and woodland. Non-native grasses (i.e., 

orchard grass, cheatgrass, and ripgut brome), forbs (i.e., Canada thistle, bull thistle, and field bindweed), 

and woody plants (i.e., Himalayan blackberry) are found throughout the island, particularly in or near 

heavily disturbed areas.

San Juan Islands NWR

Most of the other islands in the refuge are small rocky benches or outcrops that are unvegetated, tidally 

inundated reefs or only sparsely vegetated. The North Pacific Herbaceous Bald and Bluff ecological

system can be found on these sparsely vegetated islands where lichens and mosses cover the bare rock 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

4-20 Chapter 4. Refuge Biology and Habitats 

and are joined by grasses and forbs that occur on small glacial outwashes that collect in rock crevices and 

depressions. On larger islands, grassy balds are common on southern and western exposures. Matia 

Island, for example, has an extensive grassy bald lining its southern edge including areas with common 

camas and the white flowered death camas. Rocky outcrop species frequently mix with bald species. 

Also, scattered trees such as Garry oak, Pacific madrona, Rocky Mountain juniper and/or Douglas fir are 

present on Ram (#2), Boulder (#6), Castle (#8), Unnamed (#13), Battleship (#31), Ripple (#35), Flattop 

(#39), Skipjack (#42), Tift (#50), Flower (#54), Willow (#55), Nob (#71), and Unnamed (#73) islands in 

localized microsites that have greater late summer soil moisture. However, the majority of islands within 

the refuge are either too vulnerable to the erosion caused by wind and rain, too exposed, or too low in 

nutrient and moisture levels to support much more than lichens, mosses, and low, herbaceous vegetation. 

4.5.2 Associated Wildlife 

The following plants are considered focal resources for savanna, grasslands, and herbaceous balds due to 

high levels of conservation concern (e.g. Federal or state T&E listing): brittle prickly-pear cactus, golden 

paintbrush, California buttercup, and bear’s foot sanicle. All but golden paintbrush can be found on 

Refuge islands. Bennett (2007) has noted that Refuge islands within the San Juan Islands exhibit 

significantly greater species richness of native plants and less introduced species than adjacent islands. 

Osborne et al. (1998) reported that the brittle prickly-pear cactus, reputedly rare in Washington, occurs on 

Refuge lands, including Fortress (#3), Castle (#8), Aleck (#10), and Rum (#2). It has historically been 

found on Protection Island’s Violet spit. California buttercup on Aleck (#10) and Castle (#8), and Bear’s 

foot sanicle on Boulder (#6). Golden paintbrush is not known to occur on Refuge lands, however habitat 

is available (2005 SJI Floristic Survey Results, Refuge Files).

Other benefiting species include the northern harrier, American kestrel, savanna sparrow, purple martin, 

and shrews; Vancouver groundcone, camas , slender crazyweed, Alaska alkaligrass, black lily, white 

meconella, erect pygmy-weed, sharpfruited peppergrass and northern adder’s-tongue (DNR 2004b). The 

following rare butterflies are not known to occur on the refuges, however potential habitat is available, 

thus they are considered as other benefiting species for this plan: Taylor’s checkerspot, island marble, and 

valley silverspot, and plant host species for these butterflies: mustard, verbena, plantain, Viola adunca, 

and paintbrush. 

4.5.3 Conditions and Trends

The predominant pre-Euroamerican settlement vegetation on lowlands west of the Cascades, from the 

Willamette Valley of Oregon north to the Georgia Basin of southwest British Columbia, was a mosaic of 

grasslands, oak and conifer savannas, and various types of wetlands (Chappell and Crawford 1997, 

Sinclair et al. 2006). Estimates of remaining prairie vary from 10% of the pre-settlement extent in south 

Puget Sound (Crawford and Hall 1997), to less than 5% (including savannas) in southwest British 

Columbia (Garry Oak Ecosystem Recovery Team cited in Sinclair et al. 2006). Currently, these places 

have been degraded, fragmented, and lost entirely in many areas. Losses of prairie and savanna were 

primarily due to fire suppression, invasive non-native species, grazing, and urban and agricultural 

conversion (Chappell and Crawford 1997).

Small areas of herbaceous balds can be found scattered throughout the San Juan Archipelago. On a 

regional scale, herbaceous balds cover a small portion of the total area. However, this habitat is 

particularly significant for the conservation of biodiversity since these small areas tend to have high plant 

species diversity and support plant species that typically do not occur elsewhere (Chappell 2006). 

Additionally, some rare or threatened animal species, such as the island marble butterfly, are limited to 

this type of habitat.
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Chapter 4. Refuge Biology and Habitats 4-21

Historically, the dominant vegetation on the upland plateau of Protection Island consisted of native 

perennial bunch grasses and abundant and diverse forbs (Menzies 1792 in Newcombe 1923, GLO 1858, 

Clark 1995). The “few clumps of trees” within the grassland referred to by Captain George Vancouver in 

1792 were likely scattered deciduous and/or coniferous trees that formed a savanna-like structure in small 

patches (Lamb 1984, Clark 1995).

Protection Island NWR

However, the history of Euroamerican settlement, which began in the mid-1800s, has resulted in 

significant changes in vegetation cover and floristics within the former grassland and savanna areas. 

Farming, grazing, dune stabilization, and then attempted development of the upland plateau led to the 

introduction of numerous exotic species. Cowles and Hayward (2008) found that only 41% of the nonwoody grassland species found in transects that they surveyed were native. The least disturbed areas of 

the grassland had some thriving areas of native species; however, aggressive exotic species such has 

quackgrass in plowed areas, ripgut brome in former pastures, Canada thistle, and orchard grass continued 

to persist. In the most disturbed areas, several introduced species of grass had established themselves 

along with some forbs such as false dandelion, black medic, and sheep sorrel. European beach grass, a 

non-native, occurred near the bluffs over Violet Point; lichens were most evident on ground graded for 

the airstrip where much mineral earth was exposed. In the former plowed fields, introduced species 

including field bindweed, quackgrass, orchard grass, and Kentucky bluegrass still dominate. However, 

blue wild rye, a native species, was also widespread and covered substantial areas of former pasture. 

Copses of native snowberry and Nootka rose still could be found scattered throughout the grasslands in 

areas of low disturbance.

In large part due to its relative isolation and the general limitations placed on recreational use and 

visitation, the grasslands and herbaceous balds on most of the refuge islands, except for Smith Island, 

have not been significantly impacted by human use. Natural processes are allowed to predominate 

without human intervention and successional vegetative changes occur naturally. Consequently, some of 

the refuge islands still harbor rare or special status flora including Vancouver groundcone, slender 

crazyweed, Alaska alkaligrass, California buttercup and bear’s foot sanicle (Dunwiddie and Giblin 2005). 

However, the herbaceous bald habitats on the northern edge of Turn Island and the southern edge of 

Matia Island have been adversely affected by recreational use. The proliferation of unofficial trails has 

led to the reduction of vegetation cover, increase of non-native species, and in some cases, the creation of 

bare ground and surface erosion. 

San Juan Islands NWR

On Smith Island, grassland formerly occupied the south and east ends of the upland plateau while 

woodland composed of low conifers and woody vegetation occupied the center, north, and west ends 

(Menzies 1792 in Newcombe 1923, Vancouver 1792 in Blumenthal 2004, USCS 1854). However, a 

lighthouse station was established in 1858 with additional facilities, including 3 residences, a watch 

shack, pump house, cistern, dock, and other utility buildings (Skiff 2009). The T-Sheet of area produced 

by the USC&GS in 1870 shows a road leading up from the spit on the east end of the island to the 

lighthouse had also been built (USC&GS 1870). The dwarf trees and low woody vegetation were largely 

cleared in order to afford a clear horizon in every direction and to open up areas that were fenced for 

cultivation (USCS 1869). The light house was staffed from 1858 until 1957 when it was abandoned due 

to erosion. A new lighthouse was established and it was automated in 1976 which decreased the amount 

of human activity on the island. However, several introduced species of grasses and forbs continue to 

persist and thrive throughout the grassland areas of the island.
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4-22 Chapter 4. Refuge Biology and Habitats 

4.5.4 Key Ecological Attributes

Table 4-4. Savanna, Grassland, and Herbaceous Bald Ecological Attributes, Indicators, and 

Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Disturbance 

Regimes

1. Areal extent, frequency, intensity, 

severity, and return interval of fire

2. Amount of fuel load

1. Every 3-5 years

2. Analysis not completed

Plant 

Community 

Structure and 

Composition 

1. Proportion of shrub/tree cover

2. Proportion of native grasses

3. Ratio of native to non-native species

4. Presence/absence of butterfly host plants

5. Presence/absence of priority resource of 

concern plant species

6. Percent cover of invasive plants 

(Himalayan blackberry, Canada thistle, 

etc.)

7. Presence/absence of new noxious weed 

invaders (not currently present on these 

refuges)

1. <15-20% cover on PI; <30% on 

SJI

2. <50% cover of native grasses

3. <25% cover of non-native 

plant species

4. Larval and adult host plants 

established

5. One or more populations of 

priority resource of concern 

plant species

6. <10% cover of invasive plant 

species

7. No new noxious weeds

Security and 

Human Impacts

1. Presence/absence of human activity on or 

near grassland, savanna or herbaceous 

balds

2. Presence/absence of deer, rabbits, and 

mammalian predators

1. Low human activity

2. No non-native rats, rabbits, red 

fox, feral or domestic pets on 

any refuge islands; no deer on 

Protection Island.

4.5.5 Threats

Some of the threats to the savanna, grassland, and herbaceous bald communities on Protection Island and 

San Juan Islands refuges include climate change, the lack of fire, invasive species competition with native 

plants and animals, and recreational use. Additional threats faced by the grasslands and herbaceous balds 

of the San Juan Islands refuge potentially include overgrazing by native black-tailed deer, Canada goose, 

and European rabbits.

The warming trends within the Salish Sea leading to higher summer temperatures and anticipated minor 

precipitation increases (Mote and Salanthe 2009) will likely increase potential evapotranspiration, 

imposing water stress on native grassland and bald species. Increased stress on native grasses and forbs 

lowers productivity and decreases germination rates and seedling survival, making them more susceptible 

to invasion by invasive species. Additionally, warmer temperatures and summer drought may lead to an 

increased fire frequency and severity.

In pre-Euroamerican settlement times, fires were much more frequent and helped to maintain or expand 

the size of prairies and balds by killing small trees. In the absence of fire, trees show a tendency to 

invade, leading to conversion into forests and woodlands. The influence of fire in the development and 

maintenance of savanna, grassland, or bald communities likely was higher on larger islands such as 

Protection and Smith islands. Smaller islands probably had very little history of burning due to their size.

Currently, invasive species dominate the non-forested areas of the upland plateau on Protection Island. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-23

Invasive grasses are also present on all of the San Juan Islands refuge islands. Invasive species can 

outcompete native species and result in decreased population levels and degraded habitats.

The severity of threat due to recreational use varies depending on the type of recreation and the severity. 

Historically on Protection Island, vehicular use (including aircraft) within grasslands and balds caused 

soil compaction, erosion, and facilitated the spread of invasive species. Trails and trampling created 

similar impacts. Currently, Protection Island is closed to the public, therefore no recreational activities 

occur. Limited vehicle use by staff, a life time user, and researchers have only a small impact on these 

habitat types. However, any forms of recreational use would likely adversely impact wildlife populations 

(See the Seabird section of this chapter).

Prior to the introductions of two large subspecies into the region, Canada geese were not common nesters 

in the San Juan Islands. Their abundance today, especially during the breeding season, may impact 

special status plants and plant communities due to grazing and may increase the dispersal of non-native 

plants (Dunwiddie 2007, pers. obs.). Further assessment and analysis of this threat is needed before 

management action can be taken. 

4.6 Forest and Woodlands

4.6.1 Description and Location

Forests and woodlands currently occupy approximately 49 acres of Protection Island NWR and are found 

on 10 islands within the San Juan Islands NWR (see Table 4-1). These habitat types can be categorized 

into two ecological systems: North Pacific Dry Douglas-Fir (Madrone) Forest and Woodland and North 

Pacific Maritime Dry Mesic Douglas-fir-Western Hemlock Forest. A third ecological system, North 

Pacific Oak Woodland, could possibly have existed on a couple of islands within the San Juan Islands 

NWR during the pre-Euroamerican settlement period (pre-1880).

Forests are defined as stands with crowns overlapping (generally forming 60-100% cover) whereas 

woodlands feature open stands of trees with crowns not usually touching (generally forming 25-60% 

cover). The canopy tree cover of woodlands may be less than 25% in cases where it exceeds shrub, 

dwarf-shrub, forb, and nonvascular cover, respectively (Anderson et al. 1998).

On Protection Island, North Pacific Dry Douglas-Fir (Madrone) Forest and Woodland occurs in two 

stands that occupy the northern edges of the prairie-dominated upland plateau. The forest stands provide 

a natural windbreak from the prevailing wind direction. Common trees occurring with the Douglas-fir are 

Pacific madrona, shore pine, grand fir, and Douglas maple. Red cedar and western hemlock are also 

present but not dominant. Scouler’s willow and Hooker’s willow occur in some areas as understory tree 

species. 

Protection Island NWR

On Matia Island, the North Pacific Dry Douglas-Fir-(Madrone) Forest and Woodland system occurs in a 

mosaic with North Pacific Maritime Dry Mesic Douglas-fir-Western Hemlock forest, typically occupying 

upper slopes or ridgetops, steeper areas, or faces with southern to western aspects. Generally, this system 

is found adjacent to the herbaceous balds on the southern edge of the island. In contrast, the North Pacific 

Maritime Dry-Mesic Douglas-fir-Western Hemlock Forest system is found on north-facing slopes and in 

the protected interior valleys where cooler, humid, and low wind conditions occur. Old trees that predate 

Euroamerican settlement occur there as scattered individuals. These are primarily Douglas-fir, which is 

San Juan Islands NWR
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4-24 Chapter 4. Refuge Biology and Habitats 

the dominant tree across most of the island. Sites where moisture is high, such as in the central valleys, 

are co-dominated by western red cedar, Douglas-fir, and grand fir, with significant amounts of sword fern 

in the understory. Some of the cedars are up to six feet in diameter with 3-4 foot diameter individuals of 

both cedar and Douglas-fir not uncommon (Dunwiddie 2007b). Western hemlock, bigleaf maple, and red 

alder also occur in these areas. North-facing slopes are occupied by western red cedar and Douglas-fir 

with a diverse, yet generally sparse understory typically including salal. Fire scars are common on both 

the cedars and Douglas-fir.

On Turn Island, the North Pacific Dry Douglas-Fir-(Madrone) Forest and Woodland system covers 

almost the entire interior of the island with the exception of remnant North Pacific Oak Woodland 

communities centered around the 8-12 Garry oaks growing as scattered individuals on the southern, 

western, and north-northeastern shores of the island in association with Douglas-fir, Pacific madrone, and 

Rocky Mountain juniper. Most of the oaks are <18” in diameter and most appear to be relatively healthy 

with fairly full, vigorous crowns. In most areas, the canopy (especially of Douglas-firs) is not yet so 

dense as to be severely competing with the oaks, madrones, and junipers. The understory is typically 

comprised of low shrubs including snowberry and orange honeysuckle, grasses including blue wildrye, 

Alaska brome, Alaska oniongrass, and forbs such as Pacific sanicle, yerba buena, and sea blush 

(Dunwiddie 2007a).

The North Pacific Dry Douglas-Fir-(Madrone) Forest and Woodland system also occurs on larger islands 

such as Flattop (#39), Skipjack (#42), Willow (#55), Smith (#75), and Puffin (#78) Islands. Small 

patches of woodland also occur on the Ram Islands (#2) and Battleship Island (#31). Other refuge islands 

where Garry oaks grow include Ram (#2), Flattop (#39), the easternmost refuge island of the Nob Island 

Group (#71), and Unnamed (#73) Islands. However, the dominance and density of oaks is too little for 

those areas to be truly considered oak woodlands. Rather, they are more like herbaceous balds that 

support limited numbers of oak woodland species. Additionally, it is unlikely that lightning-caused fires 

were common on any of these smaller islands due to their size and relative lack of burnable fuels. If fires 

did occur, they probably burned with low intensity and were restricted only to those individual islands. 

Although there is evidence that Native Americans burned oak savannas and grasslands on some of the 

larger islands in the San Juan archipelago, there is no evidence of any cases on the refuge islands.

4.6.2 Associated Wildlife

Bald eagles are considered focal resources for these habitat types and more detailed information can be 

found in the Bald Eagle section of this chapter. Other benefiting species that use forests and woodlands 

include downy, hairy, and pileated woodpeckers, olive-sided flycatcher, American kestrel, great horned 

owl, and bats. 

4.6.3 Condition and Trends

North Pacific Dry Douglas-Fir Forest and Woodland

The current forested areas on Protection Island are smaller, more fragmented, and have more hardwoods 

and other early seral stage species compared to the pre-Euroamerican settlement time period (Cowles and 

Hayward 2008). In 1868, the forest and woodland area on Protection Island was approximately 120 

acres. The acres of pre-settlement forest on Protection Island were probably slightly higher than that, 

since by 1868 some selective logging and agricultural activities had already occurred (USC&GS 1868, 

Power 1976). By the 1930s, the logging activities and conversion to agriculture had decreased the 

forested area to 81 acres. The large continuous forest on most of the north edge of the island became 

divided into two distinct forest stands separated by grassland with a few small patches of trees. The 

Protection Island NWR
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-25

northwest grove consisted primarily of conifers while the northeast grove contained a mixture of conifers, 

deciduous trees, and shrubs (Einarsen 1945). Between 1944 and the 1950s, at least two major fires 

burned most of the uplands and both Kanem and Violet Points, including buildings and forested land 

(Power 1976, Clark 1995). Subsequent photos of the forested areas (Richardson 1961, Larsen 1982) 

show large numbers of snags mixed with shorter, healthy trees. Probably as a result of the fires, by 1956, 

the northwest grove had shrunk by 5% and the northeast grove by 10%, with small patches connecting the 

two groves absent (Cowles and Hayward 2008). The space between the two groves is now primarily 

composed of sand dunes and grassland. By 1974, roads had cut through both the northwest and northeast 

groves while the western end of the northeast grove was cleared and leveled for the airstrip. After refuge 

establishment in 1982, the airstrip and roads within the forest area were removed and the forest over-and 

understory began to recover. By 1999, the forested areas gradually expanded in range and closed over the 

roads built through them with the northwest grove recovering to roughly 82% of its 1930s area and the 

northeast grove 97% of its former extent. However, the composition of both forested areas contain a 

larger proportion of deciduous trees and shrubs which represents an earlier state of succession than the 

1930s forest (Cowles and Hayward 2008).

The current forest stands are relatively healthy but the recruitment of tree saplings may be limited due to 

deer herbivory and/or competition with non-native species. Another important factor in the quantity of 

forested areas on Protection Island is erosion of adjacent bluffs. While the northeast bluff has showed 

little change between 1956 and 1999, the northwest bluffs have eroded and slumped considerably 

(Cowles and Hayward 2008).

Overall, the dry Douglas-fir forest and woodland on Ram (#2), Battleship Island (#31), Skipjack (#42), 

Willow (#55), Puffin (#78), and Turn (#79) Islands appear to be relatively unaltered in extent from the 

late 1880s and 1890s (USC&GS 1888, USC&GS 1889, USC&GS 1894 a,b,c, USC&GS 1895a,b). 

[NOTE: There was no data available for Flattop Island (#39).] In 1892, a homesteader settled on Matia 

Island and cleared a small area near the southeast cove for a home, orchard, garden, and livestock 

(Oldham 2005). The clearing likely temporarily reduced the extents of both the dry Douglas-fir forest 

and woodland and the dry-mesic Douglas-fir-Western Hemlock forest. However, after roughly 30 years, 

the settler passed away and the clearing slowly reverted back to forest.

San Juan Islands NWR

Overall, the forests and woodlands on Turn Island appear to be in good condition. The understory is 

generally intact, and consists primarily of native shrubs, grasses, and forbs under the oaks. However, in 

the immediate vicinity of the campsites, exotic grasses and weeds dominate and provide a striking 

contrast with the understory elsewhere on the island.

On Smith Island, woodland composed of low conifers (likely Douglas-fir) and shrubs formerly occupied 

the center, north, and west ends of the upland plateau (Menzies 1792 in Newcombe 1923, Vancouver 

1792 in Blumenthal 2004, USCS 1854). However, with the establishment of a lighthouse station in 1858, 

the dwarf trees and low woody vegetation were largely cleared in order to afford a clear horizon in every 

direction and to open up areas that were fenced for cultivation (USCS 1869). With the decline in human 

activity on the island since 1976 when the lighthouse was automated, the woodland has somewhat 

expanded; however, the vegetation remains transitional as willows, oceanspray, snowberry, wild rose, and 

grasses still dominate while the Douglas-fir remain stressed and marginal. Around many of the structures 

invasive species, such as field bindweed, Canada thistle, and orchard grass, have become the dominant

vegetation.
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4-26 Chapter 4. Refuge Biology and Habitats 

North Pacific Maritime Dry Mesic Douglas-fir-Western Hemlock

Overall, the dry mesic Douglas-fir-Western Hemlock forest on Matia Island appears to be in good 

condition. The area cleared by the homesteader in the late 1800s and early 1900s has since filled back in. 

The fruit trees are still present though. Additionally, the understory has few invasive species – primarily 

a few holly trees, and a patch of English ivy near the eastern shore. Neither of these invasive species is 

abundant. 

San Juan Islands NWR

The old-growth stands on Matia Island are unique in the San Juan Islands. While there are other oldgrowth forests in the islands, they are few and far between, and primarily consist of Douglas-firs. What is 

remarkable about this stand is the size and abundance of red cedars. This species is considerably less 

common that Douglas-fir in the San Juans, and most large cedars have been logged many years ago in 

areas where they once existed.

Prior to Euroamerican settlement, oak woodlands were found throughout the Salish Sea in dry sites with 

shallow bedrock or deep, gravelly glacial outwash soils, and high growing season moisture stress 

(Natureserve 2009). The historical range of oak woodlands was also greatly affected by Native 

Americans who used low-severity fire, pruning, and knocking to favor oak savannas and woodlands over 

mixed conifer forests and to influence stand configuration and tree shape (Cole 1977, McCarthy 1993). 

However, the advent of Euroamerican settlement interrupted traditional forest management practices and 

further altered plant community dynamics by eliminating prescribed fires, introducing invasive plants, 

and overgrazing. As a result, areas with remnant oak woodlands commonly undergo successional 

changes that result in plant communities that diverge from a historic composition. These changes include 

an increase in conifers, the proliferation of a shrub understory, higher oak densities, and an increasing 

abundance of non-native annuals and perennials in the herbaceous understory (Hosten et al. 2006).

North Pacific Oak Woodlands

Consequently, throughout its range, this Garry oak dominated system is in precipitous decline. While it 

was historically much more abundant in the San Juan Islands Archipelago, it was never likely to be 

abundant on refuge islands. Currently, the presence of the North Pacific Oak Woodlands system within 

the refuge is essentially limited to the perimeter of Turn Island. It is likely however, that there once was a

larger oak woodland on Turn Island and there may have been some full-size oak trees on other small but 

forested refuge islands that currently have only a few shrub-sized oaks. The primary factors responsible 

for oak stands being converted to conifer stands on refuge islands such as Turn Island are natural 

succession and fire suppression, which encouraged conifer growth. Elsewhere in the San Juan 

Archipelago some oak woodlands were undoubtedly lost to land development. On Turn Island, invasive 

species within the vicinity of the campsites, trail proliferation by the public, and grazing by deer all pose 

threats to the integrity of this habitat.

4.6.4 Key Ecological Attributes

Table 4-5. Forest and Woodland Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Disturbance 

Regimes

1. Areal extent, frequency, intensity, 

severity, and return interval of fire

2. Rate of regeneration (saplings/acre)

1. Analysis not completed

2. Analysis not completed
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Chapter 4. Refuge Biology and Habitats 4-27

Key Ecological 

Attributes

Indicators Desired Condition

Plant 

Community 

Structure and 

Composition 

1. Percentage of canopy cover of trees on PI 

(e.g., total canopy openness/closure and 

gap proportions)

2. Amount of snags and woody debris

3. Ratio of cover of native to non-native 

understory species

4. Presence/absence of late-seral or old 

growth stands

5. Percentage of invasive species cover

6. Presence/absence of new noxious weed 

invaders (not currently present on these 

refuges)

1. >25 canopy cover

2. Analysis not completed

3. >50% cover of native 

understory shrubs (ocean spray, 

Nootka rose, etc.)

4. Presence of > 200 year-old 

trees

5. <10% invasive species cover

6. No new noxious weeds

Connectivity 1. Presence/absence of shrub layer between 

forest patches

1. Gap between forest stands 

restored with shrubs to >50% 

shrub cover on PI

Security and 

Human Impacts

1. Presence/absence of human activity on or 

near forest and woodlands on Turn and 

Matia islands

2. Number of illegal fires on Turn and Matia

3. Presence/absence of human activity on or 

near forest and woodlands on PI and other 

closed islands

4. Presence/absence of deer, rats, rabbits, red 

fox, feral or domestic pets

1. Limited access to within 

campsites and designated trails 

2. 100% use of liquid fuel camp 

stoves

3. Low human activity

4. No non-native rats, rabbits, red 

fox, feral cats or dogs on any 

refuge islands; no deer on 

Protection Island.

4.6.5 Threats

Threats facing the forests and woodlands of Protection Island and the San Juan Islands refuge include 

climate change, storm events, invasive species, insect or disease infestation, altered fire regime, 

herbivory, and human intrusions and disturbance.

For the forests and woodlands occurring on Protection Island and the San Juan Islands, the responses to 

climate change will vary according to regional and local topography, forest type, soil moisture, 

productivity rates, species distribution and competition, and disturbance regimes. However, based on the 

projected changes in the spatial and temporal patterns of temperature and precipitation associated with 

climate change, some general patterns can be described (adapted from Aldous et al. 2007):

• Species distributions are likely to change. Cool coniferous forests in the western part of the 

Pacific Northwest will contract and be replaced by mixed temperate forests over substantial areas 

(Mote et al. 2003). Douglas-fir appears relatively sensitive to low soil moisture, especially on 

drier sites (Case 2004; Hessl and Peterson 2004; Holman 2004 citations in UWCIG 2004). 

• Increasing temperature will generally increase forest fire frequency and extent.

• Higher temperatures will increase rates of evapotranspiration, leading to greater water losses from 

forests. 

• The change in seasonality of precipitation could lead to a drier growing season, increasing water 

stress. 

• Warmer temperatures could lead to a change in the timing of reproduction, which may lead to 

asynchronies between flowering and pollinator activity, fruit ripening and foraging by fruit-
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4-28 Chapter 4. Refuge Biology and Habitats 

consumers, or predator behavior by pest-eating species. 

• An increase in extreme weather events (e.g., wind storms) could change the frequency of 

disturbance, leading to a shift to forests that are younger and species that are more fast-growing, 

short-lived, and disturbance-tolerant. 

• Warmer temperatures could increase development of insect and other pathogen outbreaks, as well 

as extend their growing season, potentially leading to an increase in the frequency and extent of 

outbreaks. 

• Some tree species may experience an increase in productivity if carbon dioxide acts as a fertilizer 

and allows trees to increase their water use efficiency. However, this increased productivity, 

coupled with warmer temperatures, longer growing seasons, and prolonged drought, may also 

increase fire frequency and severity.

Introduced invasive plants (e.g., English ivy, holly, Scotch broom) pose a significant threat to the native 

forest and woodland communities on the refuges. By outcompeting native species, these invasive plant 

species can alter vegetation communities and modify ecosystem processes. Non-native animal species 

such as raccoons, feral cats, and rats may cause predation of and competition with native wildlife species 

utilizing the forest and woodland habitat. Additionally, some invasive insects (e.g., winter moth, jumping 

gall wasp, oak leaf phylloxeran, and gypsy moth) and other invasive pathogens have the potential to cause 

serious damage to Garry oaks and other tree species. Other potential insects or diseases that could affect 

the refuges’ forests and woodland include aphids, scale and bark beetles, root rot, leaf cast, and other 

fungi. Sudden Oak Disease, caused by the fungus Phytophthora ramorum

Prior to Euroamerican settlement, oak woodlands were greatly affected by Native Americans who used 

low-severity prescribed burns to influence stand configuration and tree shape (Cole 1977, McCarthy 

1993). Fire suppression within oak woodlands following Euroamerican settlement led to an increase in 

conifers, the proliferation of a shrub understory, higher oak densities, and an increasing abundance of 

non-native annuals and perennials in the herbaceous understory (Hosten et al. 2006). The continued lack 

of fire on Turn Island, the only refuge island containing remnant oak woodland, will likely lead to 

succession towards greater conifer dominance.

, has not yet been detected 

within Washington outside of nurseries; however, it should be considered a potentially significant threat.

Due to lack of predation and hunting pressure, the population of black-tailed deer on Protection Island 

and within the San Juan Islands has also expanded to such densities that they are having an influence on 

vegetative cover. Typically, deer browsing helps to maintain herbaceous dominance by limiting sapling 

recruitment and retarding or delaying succession to forested habitats (Chappell 2006). However, deer 

browsing may impede the restoration of Protection Island’s forest and on the San Juan Islands Refuge, 

researchers are concerned that excessive deer browsing is threatening oak woodlands (Dunwiddie 2007a). 

Human-induced wildfire is a potential catastrophic threat to the late-successional and old-growth forest on 

Matia Island. Additionally, other illegal activities such as firewood collection, trail proliferation, and 

general trespass have the potential to cause tremendous disturbance to wildlife and also have the potential 

for introduction of invasive plant species into closed areas of the refuge. 

4.7 Wetlands

4.7.1 Description and Location 

Wetlands currently occupy a total of 0.9 acres on two islands within the San Juan Islands NWR. The 

wetlands currently occurring on refuge-managed lands can be categorized into two ecological systems: 
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Chapter 4. Refuge Biology and Habitats 4-29

Temperate Pacific Freshwater Emergent Marsh and North Pacific Coastal Interdunal Wetland. 

Prior to development of the marina on Protection Island in the late 1960s, an 8.9 acre North Pacific 

Coastal Interdunal Wetland formerly existed on Violet Point. Daily and seasonal input of freshwater from 

the seeps coming down the slopes to the west of the spit likely affected the vegetation composition of the 

marsh. However, the marsh was filled in and graded during the construction of the marina and no longer 

exists.

Protection Island

Matia Island is unique among the smaller of the San Juan Islands in that it includes a 0.4-acre Temperate 

Pacific Freshwater Emergent Marsh dominated by cattails and slough sedge. The areas of open water 

between the cattails and shore are partially covered by duckweed. Other than these species, there appear 

to be few others growing in the water or on the vegetation mat (Dunwiddie 2007b). The wetlands are 

surrounded primarily by tall red alder.

San Juan Islands

Smith Island contains a 0.5 acre North Pacific Coastal Interdunal Wetland on its eastern spit in a windscoured depression. Pickleweed and other salt-tolerant wetland species occurs along the perimeter of a 

small shallow swale that receives limited freshwater input from seeps coming down from the west in 

addition to direct precipitation. Consequently, water levels vary seasonally, typically receding and 

occasionally drying up in the summer. The spit protects the wetland from wave action but is likely to

allow irregular, limited saltwater intrusion, especially during storm or overwash events. Vegetation has 

not been surveyed; however, a variety of emergent wetland species have been noted by staff. 

4.7.2 Associated Wildlife 

Since this habitat type consists of no more than approximately 1 acre, no focal resources have been 

selected for wetlands; maintaining biological integrity will be the focus for management. However, there 

are several other benefiting species associated with this habitat type including dunlin, northern pintail, 

mallard, Canada goose, great blue heron, amphibians, and bats. Black oystercatchers and glaucouswinged gulls nest in adjacent habitats and may use the wetlands on Smith and Protection islands during 

their lifecycle.

4.7.3 Conditions and Trends

Protection Island NWR

The wetland no longer exists on the island, however small pools of water do form after hard rains during 

the winter months.

The freshwater emergent marsh on Matia Island seems to be unaltered and appears to be in good 

condition. The tidal wetland on Smith Island also seems to be in good condition, however staff are not 

sure if the natural hydrology of the area around the wetland has been altered. 

San Juan Islands NWR
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4-30 Chapter 4. Refuge Biology and Habitats 

4.7.4 Key Ecological Attributes

Table 4-6. Wetland Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Hydrologic 

Regime and 

Water Quality

1. Water source, depth, annual cycle, 

temperature, pH, alkalinity, conductivity, 

dissolved oxygen, and phosphorous

1. Analysis not complete

Disturbance 

Regimes

1. Frequency, depth and duration of 

saltwater intrusion and flooding of Smith 

Island wetland

1. Analysis not complete

Plant 

Community 

Structure and 

Composition 

1. Inventory plant community composition. 

2. Proportion of native plant species

3. Presence/absence of trees and shrubs

1. Analysis not complete

2. Analysis not complete

3. Analysis not complete

Native Species 

Representation

1. Presence/absence of aquatic invasive 

animals and plants.

1. Analysis not complete

Security and 

Human Impacts

1. Presence/absence of human activity on or 

near wetlands.

2. Presence/absence of rats, rabbits, or 

mammalian predators. 

1. Low human activity.

2. No non-native rats, rabbits, red 

fox, feral or domestic pets on 

any refuge islands

4.7.5 Threats

The amount of water and, consequently, duration of wetland on Matia Island varies with precipitation. 

Therefore, the wetland could be sensitive to climate change and altered precipitation patterns. Sea level 

rise could also threaten the current plant communities if the freshwater table is pushed upwards by salt 

water intrusion, leading to a higher salinity within the marsh.

The current plant communities of the Smith Island wetland may be threatened by climate change and sea 

level rise, which would likely increase the amount of tidal inundation and salt water intrusion. Also, any 

significant erosion of the low spit would likely damage or eliminate the wetland. In the event of sea level 

rise, additional threats from invasive species (e.g., European green crab and common cordgrass) could 

alter the present plant community.

4.8 Seabirds

Seabirds spend most of their time on the ocean and return to land only to reproduce and raise their young. 

There are six species of seabirds that commonly nest on the refuges and were selected as focal resources. 

They are rhinoceros auklet (RHAU), tufted puffin (TUPU), pigeon guillemot (PIGU), pelagic cormorant 

(PECO), double-crested cormorant (DCCO) and glaucous-winged gull (GWGU). Four of these species 

are emphasized in the refuge purposes for Protection Island NWR (Public Law 977-333), specifically: 

“The purposes of the refuge are to provide habitat...with particular emphasis on protecting the nesting 

habitat of...tufted puffin, rhinoceros auklet, pigeon guillemot and pelagic cormorant.”

A number of seabirds that may be seen in the vicinity of the refuges are not covered in detail in this plan 

because they do not nest on refuge islands. For instance, common murres (COMU) may be seen flying or 

swimming near the refuges during late summer through spring periods, but they are not known to nest on 

the refuges or anywhere else in the inner waters of Washington (Speich and Wahl 1989). They frequently 
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Chapter 4. Refuge Biology and Habitats 4-31

forage in the waters surrounding refuge islands during the non-breeding season. Marbled murrelets 

(MAMU) nest in old growth forests on the Olympic Peninsula, Washington, and Vancouver Island, 

British Columbia, but have never been found to nest on small islands in the San Juan Archipelago 

(Raphael pers. comm. 2005). Brandt’s cormorants (BRCO) are typically observed in the Salish Sea 

during the breeding season, but very rarely breed here, thus they have not been selected as focal 

resources. 

4.8.1 Description and Location

Many of the seabird species that breed on the refuges are fairly site-faithful, returning to the same colony 

site year-after-year if successful in fledging young the previous breeding season. Seabirds have very 

specific nesting requirements, primarily habitat free of predators and human disturbance, particularly for 

ground or crevice nesting species, and with suitable soils for burrow nesting species (USFWS 2005). 

Protection Island and San Juan Islands NWRs provide some of the last remaining undeveloped seabird 

nesting habitat in the Salish Sea. The suitability of larger islands within the San Juan Archipelago for 

seabird nesting has been reduced due to habitat loss and threats associated with development and 

disturbance. Subsequently, the largest colonies and the vast majority of breeding seabirds are found on 

small (<40ha;100ac) islands on- and off-refuge (USFWS 2005). Protection Island is an exception as it is 

a relatively larger island that supports the third largest RHAU colony in North America and the single 

largest gull as well as one of the larger pigeon guillemot and double-crested cormorant colonies in the 

U.S. portion of the Salish Sea (Pearson et al. 2008, Roby et al. 2007, Cyra et al. 2007, J. Evenson pers.

comm.). Protecting suitable seabird nesting habitat within these refuges is clearly a Service priority. 

The breeding range of the rhinoceros auklet extends from the California coast northward around the 

Pacific Rim through the Aleutian Island to northern Japan (Speich and Wahl 1989). The majority of the 

birds that breed in North America (>95%) are located on islands in southeast Alaska (12%), British 

Columbia (73%) and Washington (13%), with most birds concentrated in 8 colonies (USFWS 2005). Two 

of the 8 key colonies are located in Washington: Destruction Island on the outer coast and Protection 

Island NWR in the Strait of Juan de Fuca (USFWS 2005). Smith Island within the San Juan Islands NWR 

also has a relatively small auklet colony.

Rhinoceros Auklet

Through the breeding season, rhinoceros auklets forage or raft up around Protection Island and within the 

Strait of Juan de Fuca. Wahl and Speich (1994) reported that approximately 59% of the birds within the 

Strait were observed in that area from June through July in 1978. An additional 29% were observed 

foraging near Admiralty Inlet to the east of the island. This data represents a snapshot of distribution 

within the Salish Sea and may vary based on distribution of forage fish. In addition, from early August 

through early September, fledglings can be found in the waters surrounding Protection Island. They 

typically remain close to shore for several days before dispersing (U. Wilson pers. comm.). Outside of 

the breeding season auklets disperse widely. The Service Seabird Conservation Plan notes that some 

birds move south during post-breeding dispersal to important wintering areas off the coast of California. 

A portion can be found within the Salish Sea during the nonbreeding season, in places like southern Puget 

Sound; however, their breeding origin is unknown (USFWS 2005). This species is typically observed at 

sea in mixed feeding flocks of seabirds and sea ducks (Gaston and Jones 1998).

Auklets are present on colony from March through late September. Egg laying is generally initiated in 

early May; hatching spans mid-June through mid-July and fledging follows through August (Wilson 

1977, Richardson 1961). 
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4-32 Chapter 4. Refuge Biology and Habitats 

Tufted puffins breed from California around the Northern Pacific Rim to Japan. Approximately 0.8% of 

the global population of TUPU breeds in Washington (Piatt and Kitaysky 2002). Breeding in the inner 

marine waters of Washington is currently limited to Protection and Smith islands. Speich and Wahl 

(1989) reported low numbers “In the inland waters...at Protection Island, Smith Island, and at Colville and 

Bare Islands.” The last recorded incident of TUPU nesting on Puffin Island was in 1963 with 7 

individuals observed in the area during the breeding season but breeding status was not confirmed (Speich 

and Wahl 1989). In 1977, 6 TUPU were reported at Williamson Rock (Speich and Wahl 1989) and 

refuge staff observed 1 puffin flushed from Williamson Rock in 1985, but nesting status was not 

confirmed. Refuge staff reported 9 TUPU on Colville Island in 1983 and 5 in 1984. In 1984, staff 

observed a puffin flying into a burrow on Colville Island with fish. Recently, partners conducted a survey 

for TUPU on historical breeding islands in the San Juan Archipelago and reported no TUPU observed (S. 

Pearson pers. comm.).

Tufted Puffin

TUPU arrive in April and are last observed in September. Egg laying through fledging spans from May 

through August (Piatt and Kitaysky 2002). This species winters off shore throughout the North Pacific. 

PIGU primarily nest in low abundance at many locations throughout the Salish Sea; however, they do 

concentrate at some sites such as Protection Island, where approximately 16% of the breeding population 

of the inner marine waters of Washington can be found each year (J. Evenson pers. comm.) This species 

nests on more than 1/3 of the islands in the San Juan Island NWR (Sanguinetti 2004). Refuge islands in 

the San Juan Archipelago with >200 PIGU include Castle, Flattop, Skipjack, Matia, and Williamson 

Rock. 

Pigeon Guillemot

This species can be seen throughout the Salish Sea year round, however it is unknown whether PIGU 

observed in the area during the nonbreeding season are the same individuals as those that breed here. 

PIGU can be found on the colony from April through September. Eggs are generally laid beginning in 

mid-May and fledgling runs through September (Speich and Wahl 1989). 

During the most recent comprehensive survey of the inner marine waters of Washington, three locations 

supported 75% of nests; all located off-refuge on unprotected properties. In the 1980s, the largest refuge 

colony, on Protection Island, ranged from 150 to 300 nests (Speich and Wahl 1989, K. Ryan, pers.

comm). Historically, Bare, Castle, Colville, Protection, Smith, Viti, and Williamson islands have 

supported at least 100 nests each through the early 80s (Speich and Wahl 1989). During the 2003 survey, 

refuge islands supported 12% of nests. However, the number of nests observed did not exceed 65 on any 

San Juan Islands NWR islands (Nysewander 2003a). In 2009, refuge staff observed PECO on or near 

Barren Island, Bare Island, Bird Rocks, North Pacific Rock, Sentinel Rock, South Peapod, Unnamed 

Island (# 36), Smith Island, Williamson Rocks, Viti Rocks, and Protection Island; however, breeding 

status was only confirmed for Bird Rocks, Williamson Rocks, Viti Rocks, Smith Island and Protection 

Island. 

Pelagic Cormorant

PECO are on colony from April through October. Sensitive times include egg laying through fledgling 

which occurs from mid-May through September. They can be seen within the Salish Sea year-round.

Similar to PECO, DCCO colony locations vary considerably. Historically, Colville, Williamson, and 

Bird Rocks have supported over 100 breeding birds, and Protection, Smith, Bare, and Viti have supported 

less than 50 (Speich and Wahl 1989). Results from surveys throughout the inner marine waters of 

Double-crested Cormorant
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Chapter 4. Refuge Biology and Habitats 4-33

Washington in 2003 reveal that one location supported 67% of all nests observed in inner marine waters 

of Washington; however, this site is located off-refuge in a non-protected location. Five refuge islands 

(Smith, Protection, Viti, Williamson, and Hall) supported 33% (Nysewander 2003a). In 2009, refuge 

staff observed DCCO adults or nests on Bare Island, Bird Rocks, Barren Island, Crab Island, Gull Reef, 

Minor Island, North Pacific Rock, Smith Island, Small Island, Viti Rocks, and Williamson Rocks.

DCCO can be found on colony from late March through mid-November with egg laying through 

fledgling occurring from April through October. They are resident within the Puget Sound.

This species is found year-round throughout the Salish Sea. A comprehensive aerial survey of gulls 

throughout the Puget Sound in 2007 indicate that the largest GWGU colony with approximately 40% of 

gull nesting in the U.S. portion of the Salish Sea is located on Protection Island (Roby et al 2007, Cyra et 

al. 2007) Within the San Juan Archipelago, 7 refuge islands supported approximately 50% of gull 

colonies. They include Hall Island (11%), Smith Island (10%), Bird Rocks (9%), Viti Rocks (8%), Minor 

Island (5%), Williamson Rock (3%), and Pointer Island (3% Cyra et al. 2007). 

Glaucous-winged Gull

4.8.2 Condition and Trends

A large portion of breeding seabirds in the Strait of Juan de Fuca and San Juan Archipelago nest on the 

refuges where they find relatively undisturbed habitat (J Evenson pers. comm., P Sanguinetti pers.

comm.). However, extensive development and the resulting habitat loss and increased predation on larger 

islands in the Salish Sea (i.e., Whidbey and San Juan Islands) has lead to a decrease in the abundance of 

breeding seabirds on those islands. Further information on the conservation status of each species listed 

below can be found in Appendix C. 

Approximately 66% of the estimated global population (1 million) breeds in North America (USFWS 

2005). Because this species nests underground and is active on the colony primarily at night, determining 

trends in RHAU populations is logistically difficult. Table 4-7 shows the range of abundance on 

Protection Island (both on- and off-Refuge). It should be emphasized that this data represents the 

historical range of abundance of RHAU on the island only. Different methodologies, survey areas, and 

data analysis do not allow for a direct comparison of estimates, therefore the trend is unknown. The 

previous refuge biologist reported a noticeable decline in numbers on Protection Island after the Tenyo 

Maru oil spill in 1991 (K Ryan pers. comm. per Wilson). Currently, Protection and Smith islands support 

the only known RHAU colonies within the inner marine waters of Washington State. 

Rhinoceros Auklet

Table 4-7. Range of Abundance of Breeding RHAU on Protection Island 

Year surveyed Estimated # RHAU Source 

1854 Colony present but no estimate 

provided

Speich and Wahl 1989

1956-1959 3000-4000 breeding pairs Richardson 1961

1973 9,200 breeding pairs Frazer 1973 in Speich and Wahl 1989 

(Robel reported 12,50 br pr in 1973)

1976a 27,549 burrows 

17,108 breeding pairs

Wilson 1977

1983 27,059 burrows Thompson et al. 1985 
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4-34 Chapter 4. Refuge Biology and Habitats 

1985 17,000 breeding pairs USFWS 1985

2000 12,000 breeding pairs Wilson unpublished data cited in 

Wilson 2005

2008 54,113 ± 9,390 burrows

35,715 ± 6,757 breeding pairs

Pearson et al. 2009

Number of burrows x 62% occupancy in 1976 = estimate of breeding pairs (Wilson 1977)

Breeding RHAU on Smith Island have not been counted since 1979 when the estimated abundance was 

2,388 individuals (Speich and Wahl 1989). Refuge staff has reported a rough estimate of 1,500 burrows 

on Smith in 1984 using results from the San Juan Islands NWR Seabird Inventory. In 1983, burrows 

were observed on Bare Island, however surveyors were unable to verify whether they were active or 

occupied by RHAU or TUPU. 

The North American population estimate for TUPU is approximately 2,460,000 breeding birds (Piatt and 

Kitaysky 2002). Of that, approximately 1% breeds in USFWS Region 1. During the past 15 years, 

declines of 3-21% per year have been estimated for California, Oregon, and Washington (USFWS 2005). 

These trends may reflect a response to decadal changes in large scale ocean currents. Because the species 

nests in burrows that are difficult to access and breeding colonies are often located in inaccessible areas, 

current population estimates, and information on productivity is lacking (USFWS 2005). 

Tufted Puffin

Speich and Wahl (1989) estimate approximately 45 tufted puffins were located on Protection Island and 8 

on Smith Island during the breeding season in the late 70s and early 80s. Galusha et al. (1987) reported 

approximately 50 puffins observed on or around Protection Island in 1984. Very little current information 

is available for this species, however incidental observations in 2008 account for approximately 37 birds 

on Protection Island and up to 34 birds on Smith Island (S Pearson pers. comm.). Breeding status was not 

determined, however some of the birds observed were exiting burrows near the top of the sandy bluffs of 

each island. 

The status of PIGU in the Salish Sea is unknown but some comparisons suggest that they may have 

experienced a moderate decline (Nysewander et al. 2001). The North American population estimate is 

88,000 breeding birds (USFWS 2005). Confirmation of status is hindered by lack of comprehensive

overall historic data collected throughout the Salish Sea with which to compare the 1999-2003 surveys. 

Recent surveys of PIGU in the inner marine waters of Washington State produce an estimate of 16,000 

birds within 425 colonies (Evenson et al. 2002). The most current estimate of PIGU breeding on 

Protection Island is approximately 1,500 (J. Evenson pers comm.). This represents the second largest 

concentration of PIGU in the Salish Sea. 

Pigeon Guillemot

The global population estimate is 400,000, with approximately 29,000 in Washington (USFWS 2005). 

Overall populations appear to be stable, however reproductive success declines during El Niño events 

(USFWS 2005). PECO colonies may move from year to year, particularly after years of colony or nest 

failure. This results in a high annual variation in abundance between years. Protection Island supports 

one of the largest colonies in the inner marine waters of Washington with the other three large colonies 

located off refuges. This colony supported 906 individuals (breeding status not confirmed) in 1984 

(Galusha et al. 1987), however abundance has since declined and the colony has been abandoned in recent 

breeding seasons. The cause of abandonment is unknown; it may be due to predation, disturbance, or 

simply reflect a natural shift in colony sites. Protection Island is one of the few larger colony sites that 

Pelagic Cormorant
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Chapter 4. Refuge Biology and Habitats 4-35

has some federal or state protective status associated with it. 

This species is expanding its range and abundance throughout the U.S. A recent survey of the U.S.

Pacific Coast colonies in 2003, including the inner marine waters of Washington, reported an increase in 

abundance since 1991(25,600 pairs in 2003 vs. 12,200 pairs in 1991, USFWS 2005). Results from the 

surveys in 2003 show that sites supporting DCCO in high abundance are located off refuge where 

historically a large portion of the breeding birds in the Salish Sea nested on refuge islands. It is unknown 

if this reflects a population change or a shift in nesting outside of the survey area (Nysewander 2003a).

Double-crested Cormorant

The North American breeding population size is approximately 380,000 breeding pairs (USFWS 2005). 

Protection Island and the San Juan Archipelago are located at the northern end of the Glaucous-winged 

Gull/Western Gull hybrid zone (Bell 1998). Because of the high degree of hybridization, developing 

population estimates for this species in the Salish Sea is difficult. In fact, surveyors participating in the 

comprehensive aerial survey in 2007 did not differentiate between the two species. 

Glaucous-winged Gull

Historically large GWGU colonies including Buck Island, Colville Island, Gull Rock, Puffin Island, 

Skipjack Island, Sisters Islands, and White Rock have disappeared. It is unknown if this reflects a shift in 

the breeding population to urban areas or other factors, such as mammal predation, disturbance, or landfill 

remediation and closure in the past throughout the Salish Sea.

During the first 10 years of refuge establishment, the GWGU colony on Protection Island steadily 

increased, and then steadily decreased through 2006. During the 2005 breeding season an almost 

complete reproductive failure was reported on the largest colony, Violet Spit. This failure appeared to be 

in response to changes in vegetation and bald eagle predation (Galusha 2005). Researchers believe that 

this has caused the bulk of the gull colony on the spit to shift towards the bluff and marina where human 

presence may serve to reduce the abundance of eagles at any given time (J. Hayward and J Galusha pers.

comm.). 

4.8.3 Ecology 

According to the Birds of North America species accounts, the breeding seabirds on these two refuges are 

relatively long-lived (up to 17 years) and begin breeding typically around their third year. Annual 

reproductive output is relatively low with RHAU, TUPU, PIGU laying 1 or 2 eggs, while GWGU, 

DCCO, and PECO will lay from 1-4 eggs (Ewins 1993, Gaston and Dechesne 1996, Hatch and Weseloh 

1999, Piatt and Kitaysky 2002, Hobson 1997, Verbeek 1993). In addition, if disturbed, many of these 

species will abandon eggs or young, thereby further reducing reproductive output for the year. With such 

low clutch sizes and long life spans, adult survival is an important component of the status of each 

species. 

Important characteristics for RHAU nesting habitat include soil, slope, elevation, and vegetation. They 

are further defined below:

Rhinoceros Auklet

Soils- Leschner (1976) noted that few generalizations about habitat preference can be made because of 

the variation in slope, substrate, vegetation, and weather conditions throughout the geographical range of 

the rhinoceros auklet. Nevertheless, the one common feature to all known rhinoceros auklet colonies is a 
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4-36 Chapter 4. Refuge Biology and Habitats 

well-developed soil into which they excavate burrows. Throughout their range and with few known 

exceptions, RHAU nest on islands with well-developed soils into which they dig burrows with their feet 

and beaks (Leschner 1976, Speich and Wahl 1989, Richardson 1961). On Protection Island, burrows 

averaged 2 to 2.4 meters with a range of 1 to 5.2 meters (Richardson 1961). A firm, sandy soil with some 

roots holding it together near the surface is preferred. RHAU burrows are often near the surface of the 

ground and can easily be collapsed (Sowls et al. 1980, Leschner 1976). 

Slope

On Smith Island where moderate slopes are not available, most of the RHAU burrows are located in the 

flat grass-covered upper edge of the island, avoiding the very steep bluffs (Wilson and Manuwal 1986). 

Staff have noted that most burrows are located within the first 100 feet from the edge of the bluffs.

- On both Protection and Smith Islands auklets do not burrow in the level open grass interior portion 

of the islands (Leschner 1976). This is primarily because the slope aids take-off. Birds burrowing on 

level areas must walk to the edge before departing (Leschner 1976). Richardson (1961) found burrows as 

far back as 100 to 200 yards back from the bluffs. Wilson and Manuwal (1986) found that burrow density 

was significantly correlated with angle of slope on Protection Island. From 1956-1959 the majority of the 

burrows were located on or just above the steep slopes (37 degrees to 45 degrees) of Protection Island,

presumably to avoid trampling by domestic livestock (Richardson 1961). In 1975 and 1976 the colony 

expanded with 85% of burrows located on the more moderate southeastern and southwestern bluffs 

(Wilson and Manuwal 1986). In 1983 the colony was estimated to be approximately the same size as in 

the mid 1970s but there was another shift in density of burrows with higher densities on the gentler slopes 

than the bluffs (Thompson et al. 1985). The reason for this shift was unknown, however Thompson noted 

that two factors may be important: 1) over time, burrowing may deteriorate the soil and thus habitat in 

localized areas, and 2) the colony may be expanding into areas in which the soil has stabilized and 

vegetation regenerated after 70 years of overgrazing by sheep (Newcomb 1940, Richardson 1961, Wilson 

1977). Whatever the case, this shift appears to have continued in 2008 (Pearson et al. 2009). In 2008, the 

largest extent of the colony was located on the south-facing slopes, although dense expanses of burrows 

are still located along the western bluff. 

Elevation- On Protection Island, Richardson (1961) noted that auklets drop several feet when taking off 

from land and most burrows were located 30 feet or more above the level of the beach even where 

suitable nesting slopes extended to the bottom. Very few burrows were located as low as six feet above 

and 12 feet back from the mass of logs and flotsam marking the limit of highest water. Auklets leaving 

from these burrows scrambled through the flotsam to take off from the water. Auklets with burrows 

above the two wide spits did not tend to nest so low on the slope (Richardson 1961). 

Vegetation

RHAU are wing-propelled, pursuit divers that typically forage in mixed flocks in waters greater than 20 

meters deep (Wahl and Speich 1994). In the Salish Sea, their diet consists of small fish, such as herring 

and sandlance (Wilson and Manuwal 1988). 

- Vegetation primarily serves to stabilize the soil above-ground from erosion and root 

stabilizing the soil for burrowing activity. Range-wide, RHAU colonies can be found in many different 

habitat types under a variety of vegetative communities. On Protection and Smith islands, RHAU dig 

their burrows under dense grasses. Rhizomatous grasses with well developed root systems appear to 

provide the best stability for burrow construction on the island. 

The upper level of sandy bluffs on Protection and Smith Islands provide high quality nesting habitat for 

TUPU. This species digs burrows on Protection and Smith Islands and congregates in mixed foraging 

flocks on the water around the islands. TUPU are diurnal and feed on small fish, such as herring, salmon 

Tufted Puffin
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Chapter 4. Refuge Biology and Habitats 4-37

smolt, smelt, and sandlance. 

PIGU will nest in a variety of habitats and forage close to land. On the rocky islands of the San Juan 

Archipelago, they nest in cavities and crevices. On Protection Island, the majority of guillemots nest in 

the driftwood on Kanem and Violet Spits, but they also dig burrows in sandy bluffs composed of clay, 

sand, or some combination. On Protection Island, these burrows tend to be near the top of the bluffs. 

This species feeds on small fish, such as blennies and sand lance. They often forage in small groups or 

pairs.

Pigeon Guillemot

Pelagic cormorants nest in small colonies on rocky ledges on steep cliffs. They also use human-created 

structures, such as channel buoys, which offer small cubbyholes or ledges. Some colonies are placed on 

larger, off-refuge islands, such as Henry Island near Roche Harbor, where ledges are completely 

inaccessible to humans. Cormorants are very sensitive to disturbance and will abandon the colony if 

disturbed during the breeding season. They are also sensitive to shifts in sea conditions, such as those 

that occur during El Niño events, and will abandon nesting if an adequate food supply is not available. 

PECO are typically solitary away from the colony and forage by diving for small fish along the rocky 

shore.

Pelagic Cormorant

On the refuges, DCCO build platform nests of sticks on rocky ledges, cliffs, and islands. Like PECO, 

DCCO will use human-created structures such as buoys, towers, and large signs. Although they build on 

the upland, the nests are placed so that the birds can easily access the surrounding water. Biologists 

believe that cormorants are laying later in the year and some colony locations have changed in response to 

eagle disturbance and predation (D. Nysewander pers. comm.). DCCO can be observed roosting on 

shorelines and shoreline pilings throughout the islands. They also dive for small fish among submerged 

rocks.

Double-crested Cormorant

An invasion of non-native plant species (i.e., beach grass) has rendered sections of Violet Spit on 

Protection Island that once supported the highest abundance of gull nests as unsuitable. Closer to the 

marina, a remnant population of native plants remain that are associated with the strand assemblage with 

low vegetative density and ample open spaces between plants. Researchers have noted that gull nests 

located in or near dense vegetation are more susceptible to bald eagle depredation (80%) while those 

located in more open, strand habitats appear to be more successful (15%, J. Galusha, pers. comm.). This is 

due, in part, because the open space allows mobbing gulls better access to eagles that are on the ground. 

Glaucous-winged Gull

In addition, research in other colonies has shown that a high degree of variability in topography (i.e.,

relatively small hillocks or divots in the sand or woody debris) around nests provides concealment from 

predation and natural screens from nearby nests (Good 2002). These components are particularly 

important in areas with high disturbance and predation pressure, such as Violet Spit, where disturbance or 

predation from bald eagles, other gulls, and deer can limit reproductive success (Hayward and Henson 

2008, Galusha et al. 2005). Components of strand communities that support successful gull productivity 

include: 1) sparse <30% grasses; 2) interspersed with gum weed and other natural forms of screening for 

nests such as driftwood. Restoration should be conducted in a manner that maintains the cohesion of the 

colony because the colony is less likely to shift to new, disjointed areas (J. Galusha, pers. comm.).
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4-38 Chapter 4. Refuge Biology and Habitats 

4.8.4 Key Ecological Attributes

Table 4-8. Seabird Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Population 

Levels

1. # of breeding RHAU

2. # of breeding TUPU

3. # of breeding PIGU

4. # of breeding PECO

5. # of breeding DCCO

6. # of breeding GWGU

1. RHAU - maintain current 

population on PI

2. TUPU - reestablishment in SJs

3. PIGU - Increase 

4. PECO - Increase

5. DCCO - Maintain

6. GWGU - Habitat management 

to maintain on the spits of PI

Clean Habitat 1. Presence of marine debris on shoreline 

and derelict gear in the water

2. Presence of creosote pilings and rogue 

logs

3. Presence of oil or other contaminants on 

shorelines

1. No marine debris on shoreline 

or derelict gear in waters

2. No creosote pilings on PI and 

Matia. No creosote rogue logs 

on Smith, PI, and other islands 

when observed

3. No oil or other contaminants on 

shorelines

Security and 

Human Impacts

1. Presence/absence of human activity on or 

near seabird breeding areas

2. Presence/absence of deer, rabbits or 

mammalian predators

1. Access limited to essential 

activities (research or 

management) 

2. No non-native rats, rabbits, red 

fox, feral or domestic pets on 

any refuge islands; no deer on 

Protection Island

4.8.5 Threats

Because seabirds typically have a long life span and low productivity, threats that limit productivity and 

increase adult mortality are of the highest conservation concern. Known and potential threats to seabird 

populations include habitat degradation, climate change, disturbance and trampling, fisheries interactions, 

oil contamination, predation, and competition (USFWS 2005). Many of the threats below are linked. For 

instance, the larger islands within the inner marine waters of Washington, such as Whidbey and San Juan 

Islands, have been extensively developed leading to habitat alteration, higher threats of human 

disturbance, and introduced mammalian predators. These islands no longer support substantial seabird 

breeding colonies.

Greater than 50% of the U.S. seabird population lives within 50 miles of the coastlines, and loss of habitat 

along the coast has been significant (USFWS 2005). Since 1889, approximately 70 percent of estuarine 

wetlands and 50 to 90 percent of riparian habitat throughout Washington have been lost. Habitat 

conversion, fragmentation, and degradation are pervasive threats throughout the Salish Sea and can 

compound the remaining threats below. For instance, removal of driftwood for fires or creation of 

driftwood structures degrades important nesting habitat for pigeon guillemot. Without abundant 

driftwood, chicks have less natural screens for use in camouflage from predators. Flight obstructions 

such as power lines and towers also deteriorate habitat quality, particularly for seabirds that access 

colonies at night. They can prove fatal to both fledglings and adults especially when placed on or near 

Habitat loss and degradation
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Chapter 4. Refuge Biology and Habitats 4-39

colonies. 

On Protection Island, black-tailed deer are impacting auklet habitat and directly and indirectly affecting 

RHAU. RHAU burrows are 1-5 m long, often near the surface of the ground, and are susceptible to 

collapsing. This may cause the egg or chick to be crushed or abandoned and this species rarely re-nests. 

As a result, disturbance or trampling of burrows can reduce reproductive success. Burrows collapsed by 

deer hoofs and deer bedding down in the colony, at times on top of the entrance to a burrow, have been 

observed by staff and researchers. In addition, deer have created deeply eroded pathways through the 

unstable slopes and are foraging in most of the suitable burrow nesting habitat. Cumulative impacts could 

negatively impact RHAU habitat on the island. This species of deer is native to the region, but with the 

recent high density of approximately 70 deer/0.5 mi2

Impacts to burrows from deer have only recently been noted by staff, however, historical instances of 

ungulate trampling have occurred on the island. In 1958, Richardson (1961) found trampling by domestic 

sheep on the island’s slopes led to the formation of many slide areas of loose sand and soil. Observations 

included unstable slopes and auklet burrows buried under slides or caved in by hoofs. During the 1958 

and 1959 auklet breeding seasons, about 46% of the 76 burrows in the study area were buried by slides 

from trampling by sheep. 

, vegetative damage would be expected. Several 

studies in the literature have noted that the impacts of deer on vegetation and soil substrates increase 

substantially with an increase in the density of deer (Albon et al. 2007, Gillingham 2008). 

Seabirds are very sensitive to disturbance during the nesting period (Speich and Wahl 1989). Cormorants 

are particularly susceptible to human disturbance during the nesting season and will desert eggs or young 

if disturbed. Disturbance can be caused by low-flying aircraft or boats approaching too closely to colony 

islands (Hatch and Weseloh, 1999). Studies of seabird colonies in California have revealed that most 

aircraft disturbance occurs when flyovers are less than 1,000 feet above sea level and boat disturbance 

occurred within 164 feet from shore and was most pronounced when boats remained in the area for 

extended periods (Rojek, et al. 2007). Boaters anchoring too closely to the islands, or those who have 

landed on an island and walked through a colony, have also caused colonies to fail. In fact, reports from 

biologists suggest that DCCO and PECO colonies on Viti Rocks have failed over the past several years. 

The cause of this failure possibly relates to bald eagle predation and harassment of breeding birds, but 

declines in forage fish stocks may also have played a role. Since this island is located near frequent boat 

traffic routes and rockfishing areas, biologists also suspect some degree of disturbance from recreational 

boating may have contributed to the failure (D. Nysewander, pers. comm.) In addition, on many of the 

navigational markers within the Salish Sea, GWGU and PECO nests are removed during maintenance. 

Human-caused Disturbance 

Increased ecotourism and shoreline development within the Salish Sea create additional threats to 

breeding seabirds. TUPU are a favored species to see and ecotourism companies schedule cruises during 

the breeding season. With increasing human populations around the Salish Sea and ecotourism, boating 

is becoming an increasing source of disturbance. Fast boats are especially dangerous to alcids since the

birds are slow to take to the wing and slow fliers. This is particularly of concern near Protection Island 

during the fledgling period when juvenile auklets are learning to fly and dive (U. Wilson, pers. comm.). 

Habitat specialists, such as seabirds, face increased threats from climate change since they have a very 

restricted range during the breeding season. For instance, terns and gulls are vulnerable to loss of habitat 

and reproductive failure due to sea level raise and increased incidences of storm events because they 

typically nest on low-laying spits or sandy shorelines. Climate change will further exacerbate all of the 

threats listed in this section as they will likely be additive. Increased incidences of El Niño events, sea 

Climate Change 
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4-40 Chapter 4. Refuge Biology and Habitats 

surface warming and ocean acidification, due in part to climate change, are already affecting seabird 

species by altering forage fish distribution (Walther et al. 2002, Wormworth and Mallon via 

climaterisk.net). Cormorants and alcids (e.g., guillemots) are expected to be highly susceptible to 

population declines due to a mismatch in life cycle events with prey as a result of climate change 

(Wormworth and Mallon via climaterisk.net). For instance, in 2005, seabird colonies failed along the 

west coast when a 2-month delay in northerly winds delayed coastal spring upwelling of nutrient rich 

waters. Delayed upwelling resulted in the lack of phytoplankton and subsequently a lack of fish foraging 

on the phytoplankton near seabird colonies. Without fish, a major prey species for seabirds, many seabird 

colonies failed along the Pacific coast (Wormworth and Mallon via climaterisk.net). 

Environmental conditions in the Salish Sea are already changing with total annual temperatures 

increasing by 13% and annual inflow of freshwater from precipitation and snow melt decreasing. This 

change has lead to increased instances of harmful algal blooms and areas of low dissolved oxygen. This, 

in turn, will reduce plankton, the foundation of the food web in the Salish Sea (Snover et al. 2005). 

Reduced abundance of plankton will reduce forage fish for seabirds. Since seabirds, especially 

cormorants, will not nest or colonies will fail in years of low food resources, climate change has the 

potential to greatly reduce productivity and potentially adult survival of seabirds breeding on these 

refuges. 

Interactions with fisheries results in several different threats. Mortalities have been documented in 

Washington gillnet fisheries especially for RHAU and COMU, but PIGU and MAMU have also been 

affected (Thompson et al. 1998). Declines of RHAU on Protection Island are suspected to be caused, in 

part, by mortality in gill nets. Regulating the use of a visible mesh panel and eliminating dawn fishing 

has reduced bycatch in some fisheries and should be encouraged in all active gillnet fisheries in the Salish 

Sea (Melvin et al. 1999). Entanglement in derelict (lost or abandoned) gear or nets is increasingly 

becoming a problem in the Salish Sea. Cormorants appear to be most susceptible to this threat. During 

one study of 4 derelict nets in the Puget Sound, seabirds (88% of which were cormorants) were caught at 

a rate of 0.24 per day. At this rate, researchers calculated that each net could entangle approximately 7 

seabirds per month. Compound that over the estimated 3,800 derelict nets distributed throughout the area 

and up to 26,600 seabirds per month could be lost to this threat (Natural Resource Consultants 2008). 

Additional threats include overfishing, which reduces prey species for seabirds, and disturbance from 

aquaculture fisheries off refuge islands, such as geoduck diving.

Fisheries interactions

There are 6 oil refineries in the Salish Sea and approximately 15 billion gallons of oil are moved through 

the area each year on over 1,000 tankers (WDOE 2009). Other sources of ‘oil’ pollution stem from 

diesel, gasoline, kerosene, lubricant, and various industrial oils that are just as toxic to wildlife but can 

occur at a much smaller scale (e.g., leaky bilges) and may not be properly tracked (USFWS 2005). 

Oil contamination

Species particularly at risk of contamination are those that roost, haul out, or feed in large flocks or rafts 

near shipping lanes and ports. Protection and Smith Island and many other important seabird nesting 

colonies in the San Juan Islands NWR (e.g., Williamson and Bird Rocks) are directly adjacent to the 

vessel traffic routes into the Salish Sea. Breeding RHAU, TUPU, PIGU and cormorants are highly 

vulnerable to oil spills because they tend to forage in large rafts near colony sites (Speich and Wahl 

1989). In fact, RHAU was the second most common species killed in the Apex Houston oil spill off 

central California (Page et al 1990). Further, oiled birds that return to the nest can then transfer oil to 

eggs or chicks. Laboratory tests have shown that this significantly reduces hatching and fledgling success 

(Speich and Wahl 1989). The Nestucca (1988) and Tenyo Maru (1991) oil spills off the coast of 

Washington are considered as contributing factors to the decline in the common murre breeding 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-41

population (USFWS 2005). 

Predation targets both adult survival and productivity. This threat is especially prevalent on seabird 

colonies where seabirds nest in and on the ground and have not evolved a mechanism for predator 

avoidance. In fact, over 40% of island bird extinctions world-wide have been caused by introduced 

species (Courchamp et al. 2003). Potential introduction of cats, rats, raccoons, or other predators into 

Washington colonies is a primary concern (Speich and Wahl 1989). Raccoons have eliminated seabird 

colonies on two islands in B.C. and caused serious decline on two additional islands (Golumbia et al.

2008).

Predation

Avian predators are also of concern. Mortality has been documented at breeding colonies from bald 

eagles, peregrine falcons, and other avian predators (Harfenist and Ydenberg 1995, Thayer et al. 2000, 

Wilson and Manuwal 1986). Hayward and Henson (2008) observed both indirect and direct mortality of

gulls due to eagle disturbance on Protection Island. As the population of eagles rebounds, incidences of 

seabird mortality may increase. Gulls in turn, prey on RHAU and BLOY chicks. Hayward (2004) noted 

dead RHAU fledglings in gull territories east of the marina and channel on Protection Island where they 

were killed and eaten by gulls. 

Competition for food resources and nesting areas can have serious effects on reproductive success of 

seabirds. Some species compete for nesting space. For instance, rabbits will compete for burrows and 

can change vegetation at colony sites (Courchamp et al. 2003). Rabbits were introduced to San Juan 

Island and have drastically changed the vegetative community on the island. TUPU are less susceptible 

to competition with rabbits since their burrows are typically found within very steep bluffs or cliffs. 

However TUPU may decline at some locations as a result of reestablishment and recovery of RHAU 

since the two species compete for burrows (USFWS 2005). Other species compete with seabirds for food 

in the form of kleptoparasitism. Gulls and raptors are known to steal fish from seabirds returning to the 

colony to feed chicks (Gaston and Deschesne 1996, Speich and Wahl 1989). RHAU almost always enter 

and leave colonies at night when feeding chicks (Speich and Wahl 1989). This predominantly nocturnal 

behavior may have evolved as a means of reducing kleptoparasitism or simply to exploit different prey 

species (Wilson and Manuwal 1988). Wilson (1993) noted that the presence of gulls nesting near auklet 

burrows did not affect auklet burrow use, breeding success or egg-laying dates, however chick growth 

was slower than that of chicks in gull-free areas. 

Competition

4.8.6 Information Gaps/Research Questions

• What additional limitations could climate change impose on breeding seabirds or what limitations 

will be exacerbated by climate change? 

Seabirds

• Is there additional high quality seabird nesting habitat worth protecting through acquisition or 

easement?

• Is availability of forage fish a factor in the decline of seabirds? How far away do they forage? 

How good are the forage resources?

• Was establishment of Cherry Point oil refinery a factor in the disappearance of seabird colonies 

on islands in the northern portion of the archipelago (e.g., puffins on Puffin Island) or the crash of 

the herring fishery north of Lummi Island?

• Are there mammalian predators or herbivores impacting focal resources on any of the San Juan 

NWR islands?
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4-42 Chapter 4. Refuge Biology and Habitats 

• What is the current estimate of RHAU nesting on Smith Island?

Rhinoceros Auklet

• What the population trend of RHAU nesting on PI and Smith Island? 

• Is it feasible to restore and establish other colonies of RHAU in the San Juans?

• Is the area of PI occupied by the RHAU colony shifting (using more of the upland) and if so,

why? 

• What is the best vegetation cover for RHAU nesting habitat?

• What are the current estimates of TUPU nesting on the refuges?

Tufted Puffin

• Is it feasible to restore and establish other colonies? 

• Why has caused the decrease in nesting of PECO and DCCO on PI? 

Pelagic and Double-crested Cormorants

• Why did the large GWGU colony stop nesting on Colville Island?

Glaucous-winged Gull

4.9 Bald Eagles

4.9.1 Description and Location

The enabling legislation for the development of the Protection Island Refuge lists the protection of 

nesting habitat for bald eagles as one of its establishing purposes. Thus, they have been selected as a 

focal resource for this CCP. Three nests and one breeding pair of eagles can be found on Protection 

Island, however many bald eagles forage or roost on the island. In fact, a peak count of 50 bald eagles 

was counted in one day during the breeding season of 2007 on Protection Island (Hayward and Henson 

2008). 

The following table shows current territory counts for San Juan, Island, and Jefferson counties as well as 

the number of refuge islands encompassed by eagle territories (J. Stofel pers. comm.). However, bald 

eagles use all the islands as perches or roosts. 

Table 4-9. Bald eagle nesting territories that encompass refuge islands, by county. 

County County total # Territories that encompass refuge 

islands

San Juan 122 8

Island 81 1

Jefferson 91 1

During the 2009 San Juan Island NWR Summer surveys, 57 bald eagles were observed on refuge islands

throughout the San Juan Archipelago and another 19 were observed on Smith and Minor Islands. 

Nest building begins in early January, egg laying and incubation runs from late January through May, 

hatching and rearing young from February through July, and young fledging from May through August 

(USFWS 2007). Abundance decreases shortly after the breeding season when breeding birds move north 

during the fall to feed on salmon runs in British Columbia and SE Alaska and return in January (WDFW 

2001). 
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Chapter 4. Refuge Biology and Habitats 4-43

4.9.2 Condition and Trends

The bald eagle has undergone significant changes in population. Early 19th

In Washington State, bald eagle occupied territories increased from about 100 in 1980 to about 650 in 

1998 (WDFW 2001). There are approximately 700 resident pairs and abundance swells up to 4,000 

during winter in the state (WDFW 2001). Since receiving protection under the Endangered Species Act 

and the Bald and Golden Eagle Protection Act, bald eagle abundance has increased in the San Juan 

Archipelago (R Milner pers. comm.). Abundance of this species also has increased on Protection Island 

with as many as 50 observed at one time (J. Hayward pers. comm.). As a result, predation by eagles has 

increased and may be limiting abundance of other native wildlife, including cormorants and gulls 

(Galusha et al. 2005). However, due to concerns for maintaining recovery levels and continued 

protection provided by the Bald and Golden Eagle Protection Act, no management actions will be taken 

against eagles. 

Century reports describe the 

bald eagle as common in the Pacific Northwest (Buehler 2000). By the mid-1900’s, the bald eagle 

population was decimated by human persecution and pesticide contamination. In 1978, the species was 

listed as threatened throughout the contiguous United States under the Endangered Species Act of 1973. 

Legal protections under the current Bald and Golden Eagle Protection Act (16 U.S.C. 668-668c) and 

Migratory Bird Treaty Act (16 U.S.C. 703-712) combined with the ban of DDT have led to a dramatic 

recovery of the bald eagle. In 2007, the bald eagle was removed from the Endangered Species List. 

4.9.3 Ecology

Bald eagles build nests in large trees or snags that can support nests that may weigh more than 1,000 

pounds. However, on islands where trees are limited, they can place their nests on the ground. Eagles 

may build additional nests and alternate use between years. They exhibit strong nest site fidelity and will 

return yearly to the same nest locations. 

Hayward (2005) found that the main prey species for bald eagles nesting on Protection Island are gull 

eggs and chicks as well as dead harbor seal pups and afterbirths. 

4.9.4 Key Ecological Attributes

Table 4-10. Bald Eagle Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Population 

Levels

1. # of occupied nests

2. # bald eagles observed using refuges

1. Have an occupied nest in each 

of the ten current territories

2. Maintain # of bald eagles using 

refuges maintain what?

Clean Habitat 1. Marine debris observed on refuge 

shorelines

2. # of oil or other pollutant spills

3. Creosote pilings and rogue logs on 

refuges

1. No marine debris observed on 

shorelines

2. No incidence of spills

3. No creosote pilings and 

creosote rogue logs on refuges
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4-44 Chapter 4. Refuge Biology and Habitats 

Key Ecological 

Attributes

Indicators Desired Condition

Security and 

Human Impacts

1. # of incidents of trespass or other nonauthorized, human-caused disturbance at 

nest sites

2. # of motorized and non-motorized craft 

within 330 feet of nest sites during 

breeding season

3. # of aircraft operating within 1,000 feet of 

a nest during breeding season

4. # of incidents of intentional harming or 

killing eagles

1. Eliminate non-authorized, 

human-caused disturbance to 

nest sites. Reduce need for 

Coast Guard emergency 

maintenance to signal towers 

during the breeding period

2. No watercraft within 330 feet of 

nest sites

3. No aircraft, except by refuge 

authorization, within 1,000 feet 

of a nests during breeding 

season

4. No incidents of harming or 

killing eagles

4.9.5 Threats

Bald eagles nesting or over-wintering in the Salish Sea face the same threats as seabirds. They include:

• Disturbance by human activities such as boats and low-flying aircraft approaching too closely to 

nests during critical time periods: courtship and nest building, egg laying, incubation and 

hatching.

• Decreased food supply brought on by changes in prey availability from over-harvesting or 

climate change; human development that reduces suitable feeding sites; 

• Habitat loss, particularly around nest sites, through human-caused fires on refuge islands or 

increasing development on islands adjacent to refuge islands.

• Mortality or reduced production through contamination from catastrophic events such as oil spills 

or exposure to persistent sources of contaminants such as pesticides and creosote on pilings and 

rogue logs.

• Mortality or injury from entanglement in marine debris or derelict gear.

• Harassment or illegal take of eagles and their parts by uneducated public, disgruntled anglers, or 

others.

According to the National Bald Eagle Management Guidelines (USFWS 2007), buffer zones around a 

nest shall be maintained in the following ways to avoid disturbance: 

• If the activity will be visible from the nest, maintain a buffer of 660 feet 

• For activities not in sight of a nest, maintain a buffer of 330-660 feet depending upon the activity 

and whether there is a similar activity within 1 mile of the nest (e.g., an activity that the eagles 

have become accustomed to). For a more in-depth description of those threats, see the Seabird 

section in this chapter. 

These guidelines will be followed on all refuges in order to avoid disturbance to eagles, a violation of the 

Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act.
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Chapter 4. Refuge Biology and Habitats 4-45

4.10 Black Oystercatchers

4.10.1 Description and Location

The Black Oystercatcher (BLOY) is a large shorebird that ranges from the Aleutian Islands to Baja 

California. The BLOY is a rocky intertidal obligate species that can be found in the Salish Sea yearround. During the last comprehensive survey of 95 islands in the inner marine waters of Washington in 

2003, 40 islands within the San Juan Islands NWR supported approximately 80% of breeding pairs 

(Nysewander 2003b). 

Wintering distribution and seasonal movements are poorly understood, however, birds breeding in the 

San Juan Archipelago appear to be resident. A tracking study to determine if breeding birds do remain on 

or near their territories year-round is currently underway in the San Juan Archipelago. During the winter 

months, BLOY tend to aggregate in groups of tens to hundreds. Winter flocks stay relatively close to 

their general breeding areas, and some individuals may maintain territories year-round (Nysewander 

1977, Hartwick and Blaylock 1979). 

4.10.2 Status and Trends

The global population is estimated at between 8,900 and 11,000 birds (median = 10,000; Morrison et al. 

2006). This estimate, however, is based largely on observations from seabird surveys that do not 

specifically target black oystercatchers. These surveys are not optimal for detecting oystercatchers 

because they are focused on large seabird colonies, not the widely distributed islets and rocky intertidal 

areas where oystercatchers commonly occur. In addition, they are conducted later in the breeding season 

when oystercatchers are less vocal and visible. The population trends for BLOY in the inland marine 

waters appear to be stable (Salo 1975, Speich and Wahl 1989, Golumbia et al. 2009) at approximately 

350–400 total individuals with at least 250 breeding birds (Tessler et al. 2007). BLOY nests on 

Protection Island have decreased from 13 to a low of 4 since Refuge establishment in the 1980s. This is 

believed to be due to an increase in glaucous-winged gulls and bald eagles (P. Sanguinetti, pers. comm.). 

4.10.3 Ecology

Rocky islands, islets, and headlands are favored breeding habitats, although birds will occasionally nest 

on gravel beaches in Washington. There are several islands that support 2 or more nesting territories. 

With few exceptions, all of the refuge islands are within a breeding territory of a black oystercatcher pair 

and used for nesting, foraging, or both. BLOY favor rocky shorelines in areas of high tidal variation to 

forage. They forage exclusively on intertidal macroinvertebrates (e.g., limpets and mussels, Tessler et al. 

2007). Because they are so dependent on marine shorelines, the black oystercatcher is considered a 

sensitive indicator of the health of the rocky intertidal community.

Highly territorial, breeding birds exhibit strong site fidelity to nesting sites. Typically three eggs are laid 

in May. Incubation ranges from 26-28 days, and nestlings are generally observed from mid-June through 

late July. Fledgling occurs approximately 40 days after hatching with chicks remaining in the adults’ 

territory through as late as October. One brood is raised per season; however, when a clutch is lost, pairs 

can lay up to two replacement clutches, which tend to be smaller than initial clutches (Andres and Falxa 

1995). Age of first reproduction is believed to be five years, and their life span ranges from 9-15 years 

(Andres and Falxa 1995). Once individuals reach breeding age, it is generally assumed that they attempt 

to breed every year. 
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4-46 Chapter 4. Refuge Biology and Habitats 

4.10.4 Key Ecological Attributes 

Table 4-11. Black Oystercatcher Ecological Attributes, Indicators, and Condition Parameters.

Key Ecological 

Attributes

Indicators Desired Condition

Population 

Levels

1. # of refuge islands with nests

2. # of BLOY nests 

3. # of BLOY observed foraging on islands

1. Maintain or slightly increase

2. Maintain or increase #s on 

smaller islands; increase nests 

on larger islands, such as Matia, 

Turn, and PI

3. Determine winter 

concentrations on refuge islands

Clean Habitat 1. Marine debris observed on refuge 

shorelines

2. # of oil or other contaminant spills

3. Creosote pilings and rogue logs on 

refuges

1. No marine debris observed on 

refuge shorelines

2. No incidence of spills

3. No creosote pilings and 

creosote rogue logs on refuges

Security and 

Human Impacts

1. # of incidents of trespass or other nonauthorized, human-caused disturbance at 

nest sites

2. # of incidences of disturbance caused by 

boats approaching too closely to nest sites

1. Eliminate non-authorized, 

human-caused disturbance to 

nest sites 

2. Minimal boat disturbance 

within 200 yards of closed 

refuge islands and shorelines 

4.10.5 Threats

Black oystercatcher populations are ultimately regulated by the availability of nesting and foraging 

habitat and the quality habitat is more or less saturated at the moment (Tessler et al. 2007). Habitat 

quality in this sense depends in part on predation risk; some otherwise suitable habitat may remain 

unoccupied in areas exposed to high densities of avian or mammalian predators (i.e., main islands of the 

San Juan Archipelago). 

Due to a restricted breeding range and habitat specialization, oystercatchers are highly vulnerable to 

climate change through habitat loss and/or changes in intertidal prey abundance or distribution. In 

addition, oystercatchers are vulnerable to reproductive failure due to nest flooding as a result of increased 

incidences of storm events because they typically nest on low-laying gravel beaches or rocky shorelines. 

Climate change may further exacerbate all of the threats listed in this section as they will become 

additive. For instance, the predicted increase in the severity and number of storm events caused by 

climate change may lead to an increased threat of a contaminant spill in the Salish Sea. 

Climate Change

Oil spills such as the Exxon Valdez in 1989 can have immediate impacts on local black oystercatcher 

populations, and persisting contamination can slow recovery by depressing breeding efforts and chick 

survival (Andres 1997). Up to 20% of BLOY breeding in the area of the Exxon Valdez spill were killed 

by oiling (Andres and Falxa 1995). Oystercatchers and their prey may be at risk from low-level 

contamination by diesel fuel, gasoline, oil residues, and other contaminants along shorelines resulting 

from tankers or cargo ships expelling water from their ballast tanks and increased recreational activities 

(Tessler et al. 2007). 

Contaminants
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Chapter 4. Refuge Biology and Habitats 4-47

Predation is a primary cause of mortality to oystercatcher eggs and chicks (Tessler et al. 2007, Morse et 

al. 2006). In a study of productivity at four breeding areas in Alaska from 2003 to 2006, predation 

accounted for 48% of all egg losses where a cause could be positively identified. Because 27% of all egg 

losses were of unknown cause, egg depredation could be even higher. Small chicks are particularly 

vulnerable to predation during the first two weeks after hatching (Andres and Falxa 1995). Pinnipeds 

hauling out on land may also cause decreased reproductive success by crushing eggs and chicks and 

causing oystercatchers to leave nest sites during incubation or brooding periods (Warheit et al. 1984). 

Predation and Competition

Growing pressure from recreational activities and development in and around breeding areas can 

negatively impact oystercatcher productivity. For instance, expanding use of the Salish Sea by 

commercial and private vessels may increase the probability that nests will be flooded by large wakes, 

especially when vessel traffic coincides with periods of the highest tides. Increasing human presence may 

directly impact oystercatcher productivity at the nest site through accidentally trampling nests and eggs, 

or indirectly affect them through interference with foraging, parental care, or causing nest abandonment. 

It is important to note that these threats are cumulative, since isolated incidences of low levels of 

recreation have been shown to have no effect on oystercatcher productivity in Kenai Fjords National Park 

(Morse et al. 2006). However, when taken as whole, increased incidences of human disturbance at the 

nest site combined with increases in nest flooding may decrease productivity and subsequent population 

growth of oystercatchers in the Salish Sea. 

Human Disturbance 

In addition, recreational uses of the Refuges can attract predators to campgrounds, picnic areas, and 

nearby shorelines in search of garbage. There are no oystercatchers nesting on Turn Island, despite the 

presence of suitable habitat. This may be the result of predation or because some of the best habitat for 

oystercatcher nesting is used as a landing area for the campground and accessible to dogs daily during the 

breeding season. 

4.11 Marine Mammals

NOAA Fisheries and the Service share responsibility for implementing the Endangered Species Act 

(ESA) of 1973. NOAA Fisheries has jurisdiction over the four species of seals or pinnipeds that occur on 

the refuges (Steller and California sea lion, harbor and northern elephant seal) under the Marine Mammal 

Protection Act (MMPA) of 1972. However, the Service manages land these species use to pup, molt, or 

haul out. For this reason, four marine mammal species were selected as focal resources for this plan.

Although many species of marine mammals can be observed in the waters surrounding the refuge islands, 

four species regularly use the Refuge shorelines and rocks: harbor seals (Phoca vitulina), northern 

elephant seals (Mirounga angustirostris), California sea lions (Zalophus californianus), and Steller 

(Northern) sea lions (Eumetopias jubatus

4.11.1 Description and Location

). Although all pinnipeds forage on fish, they must come to 

shore at various times to breed, have pups, or molt (shed hair and top layer of skin). Coming on shore is 

referred to as “hauling out” and a social group of seals on shore is often referred to as a “haulout.” 

Pinnipeds also haul out to sleep and conserve energy. 

The most abundant, widespread marine mammal on the refuges is the harbor seal. Protection Island and 

Smith/Minor Island both have large haulouts, often peaking above 500 seals. Refuge wildlife surveys 

Harbor seal
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4-48 Chapter 4. Refuge Biology and Habitats 

have documented harbor seals hauled out on most of the islands within the San Juan Islands NWR. The 

highest count of adult harbor seals (725 seals) was on Minor Island in 2009. Other islands with high 

counts of adult harbor seals (>200) included White Rock, Clements Reef, Puffin Island, the North 

Peapod, Unnamed (# 63, Peapod Rocks), South Peapod and Bare Islands. Harbor seal pups counts >35 

were recorded on Flattop Island, Unnamed (#45), Lone Tree Island, Puffin Island, and Colville Island. 

Harbor seals are present year round, but haul out in greatest numbers during their summer/fall pupping 

and molting season. Pupping season begins in mid-June, peaking from mid-July through August, with 

some pups born as late as the end of September (Calambokidis et al. 1978).

A few elephant seals have been documented to breed and pup on Protection Island and Smith Island. 

Like harbor seals, elephant seals also use the refuge islands to breed and molt, but their seasons are very 

different. They can be found on Protection or Smith and Minor islands year-round. Breeding males 

arrive on Protection and Smith/Minor Island in November or December, with females following in 

December. Pups are born late December through January. Breeding occurs from January through early 

February. Adult females and juveniles molt from March through June. Adult males molt from May 

through September. Juveniles will haul out again from July through January (LeBoeuf and Laws 1994).

Elephant seal

The inland waters of Washington State are a foraging area for California sea lions. They do not breed in 

Washington State and primarily are present from September to May. Only male California sea lions are 

observed in the Salish Sea. They tend to haul out on rocky shorelines in the Straits and can often be seen 

on refuge islands that serve as navigational markers. 

California sea lion

Primarily coastal, Steller sea lions (or Northern sea lions) haul out in small numbers in the inner waters of 

Washington State. They have been observed hauled out within the San Juan Islands NWR on Peapod 

Rocks (#s 62-64), which are in Rosario Strait (Jeffries pers. comm.). Refuge staff have observed nonbreeding Steller sea lions on Eliza Rock (#65) and Bird Rocks (#80) within the San Juan Islands NWR

(Sanguinetti 2004).

Steller sea lion

4.11.2 Condition and Trends

Until 1960, Washington State managed population through a “bounty.” This species’ population was 

severely depleted until protected by the MMPA. The population for Washington is estimated at more 

than 35,000 (NOAA Fisheries 2004). Based on summer haulout counts, the population estimate for the 

San Juan Islands is 5,000 seals and the population for the Strait of Juan de Fuca is estimated at 2,000 seals 

(Jeffries et al. 2003). The Strait of Juan de Fuca and San Juan Islands harbor seal populations have 

reached “optimum sustainable population.” Population growth in the Strait of Juan de Fuca has slowed, 

but San Juan Island’s population may still be increasing (Jefferies et al. 2003). Research partners reported 

a large number (>60) of harbor seal pup deaths in 2005 on Smith and Minor Island, but did not indicate 

the causes of death. 

Harbor Seal

This species was almost extinct by 1900. However they have recovered and the species population is 

estimated at 150,000. Northern elephant seals are rapidly colonizing new areas in the Pacific Northwest 

(LeBoeuf and Laws 1994) and are reestablishing themselves in the Northern Puget Sound. In 1977, a 

molting tagged female was identified at Discovery Bay near Protection Island (Everitt et al. 1980), while 

Northern Elephant Seal
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Chapter 4. Refuge Biology and Habitats 4-49

the first elephant seal to be observed on Protection Island was reported in 1989 and appeared to be in 

molt. The recent increase or reestablishment of their breeding range includes small colonies on Protection 

and Smith/Minor Islands. In 2004, a peak year for breeding, three pups were born on Protection Island. 

In 2006, 1 pup was born on Protection Island, but it died with the cause of death unknown.

The California sea lion population estimate for the west coast of the U.S. is roughly 167,000 to 188,000 

(NOAA Fisheries 2004). In 1995, a peak count of 1,100 animals was reported for the Everett area 

(NOAA Fisheries 2004). No trend data available.

California Sea Lion

The Steller sea lion is listed as a threatened species under the ESA. The current population estimate for 

the eastern distinct population segment is between 46,000-58,000. Declines are due, in part, to decreasing 

fish stocks. 

Steller Sea Lion

4.11.3 Ecology

This species exhibits strong site fidelity to their usual haulout locations during pupping and molting 

seasons (Suryan 1998). They use both rocky and sandy/gravely shorelines for haulouts. Haulout 

locations are vital to seals during molt and rearing of young. This species feeds primarily on fish 

including rockfish, cod, herring, flounder, and salmon (Eder 2002).

Harbor Seals

While harbor seals typically pup during the summer months, they can pup at any time of the year. Pups 

are born on land and can swim immediately, but they remain close to their mothers. The first hours after 

pupping are critical for the pup to imprint on the mother. Without proper imprinting, the mother will not 

recognize the pup if separated. Abandonment of pups was found to be the primary cause of pup mortality 

at Grays Harbor (Stein 1989).

During pupping, mother seals haulout for longer periods of time to care for their pups (Stein 1989, Watts 

1991, Kroll 1993). Mothers with nursing pups can spend more than 90% of their time onshore (Huber et 

al. 2001 as reported in Jefferies et al. 2003). Mother-pup pairs usually segregate from main haulout 

groups (Kroll 1993).

Elephant seals spend the majority of their life cycle at sea and return to land only to breed, pup, and molt. 

They use sandy/gravely shorelines to haul out and are known for digging sand and flipping it over their 

backs to regulate their internal temperatures. The largest of the pinnipeds, the males weigh, on average,

4,000 lbs. in contrast to the average female’s 1,800 lbs. (Wynne 1992). The males are easily recognized 

by their distinctive proboscis (snout). Elephant seals feed on a variety of marine life including squid, 

octopus, and large fish (Eder 2002). 

Elephant Seals

This species has a drastic molt where the upper layer of epidermis peels off in patches (Reidman 1990). 

Molting season is determined by gender and age. Elephant seals fast during their time at shore and 

conserve energy by lowering their metabolic rate. As a result, they spend most of their time sleeping and 

moving very little (Reidman 1990). Pups are very dependent on their mothers and are unable to swim 

until weaned at approximately 27 days (Reidman 1990). On Protection Island, elephant seals breed and 

pup on the shores and upland of Violet Spit. Pups on Minor Island have been lost to winter storms. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

4-50 Chapter 4. Refuge Biology and Habitats 

This species hauls out on rocky shorelines and navigational buoys or markers. Only non-breeding males 

are observed in the inner marine waters of Washington. California sea lions feed on a wide variety of 

fish, squid, and octopus; however, within the Puget Sound they consume several different species of 

salmon. They tend to mix with Steller sea lions and can be difficult to differentiate.

California Sea Lion

Steller sea lions use rocky shorelines and navigational buoys or markers to haul out. This species feeds 

opportunistically, often including octopus, squid, and a variety of fish (herring, rockfish, and greenling, 

Eder 2002). Steller sea lions mix with California sea lions and can be difficult to differentiate.

Steller Sea Lion

4.11.4 Key Ecological Attributes

Table 4-12. Marine Mammal Ecological Attributes, Indicators, and Condition Parameters.

HASE=Harbor seal; ELSE=Elephant seal; CASE=California sea lion; STSE=Stellar sea lion

Key Ecological 

Attributes

Indicators Desired Condition

Population 

Levels

1. # of seals using refuge

2. Count of HASE pups in summer survey

3. # of ELSE born

4. # of ELSE weaned

1. HASE - existing

ELSE - increase

CASE - existing

STSE - increase 

2. Maintain

3. Maximize

4. Maximize

Clean Habitat 1. Marine debris on shoreline

2. Creosote-covered logs, oil, or other 

contaminants on shorelines

1. Marine debris removed from 

the Salish Sea

2. Provide quality haulouts with 

no incidence of contamination 

or marine debris

Security and 

Human Impacts

1. Incidents of human-caused injury or 

mortality

1. Public is educated about lone 

pups and pups are left alone 

2. Provide quality haulouts with 

no incidence of human-caused 

injury or mortality

3. Maintain low levels of 

disturbance on PI

4. Reduce disturbance incidences 

in the SJs

4.11.5 Threats 

Although pinnipeds react differently to disturbance depending on their degree of previous experience, 

age, sex, location, and life cycle stage, they are all highly vulnerable to human-caused disturbance (Boren 

et al. 2003, Sanguinetti 2003, Hoover-Miller 1993). Seals and sea lions are popular ecotourism targets, 

which can multiply the disturbance instances in a day. Increasing ecotourism combined with an 

increasing human population and marine recreation in the Salish Sea pose a threat to stable and declining 

populations of pinnipeds in the area. Several studies have noted that pinnipeds have a disproportional, 

negative response to approaches by kayaks in contrast to other recreational vessels (Szaniszlo 2001, 

Grella et al. 2001) potentially due to a kayaks stealthy, low profile approach (Hoover-Miller et al. 2003).
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 4. Refuge Biology and Habitats 4-51

Disturbance can interrupt nursing or cause pups to be separated from their mothers (Fisheries and Oceans 

Canada 2002). Also, well-meaningbut misinformed people will remove pups that have been temporarily 

left by their mothers. Persistent human-caused disturbance can reduce fitness or increase mortality,

especially during molt or nursing. Seals and sea lions repeatedly forced into the water during these time 

periods expend more energy maintaining their body temperature and must then spend more time in the 

water foraging. Pups repeatedly forced into the water have less time to nurse, which decreases blubber 

production. This increases the potential for mortality once pups are weaned and must rely on stored 

energy in blubber to survive while learning to forage. Elephant seal pups are particularly at risk because 

they cannot swim until weaned. During this period, if the mother is disturbed and retreats to the water, 

the pup is vulnerable to predation. In addition, they are unable to retreat from natural or catastrophic 

disturbances such as fire or oil spills. Finally, all seal and sea lion pups are at risk of being crushed by 

adults stampeding to the water when disturbed at a haulout. 

Fisheries interactions also pose direct and indirect threats to marine mammals. Seals and sea lions are 

susceptible to intentional killing or harassment by humans because of the marine mammals’ perceived 

fishery impacts. Roughly 3-6 reports of dead sea lions are reported per year in the Puget Sound due to 

gunshot wounds. However, this number rose to 7 in 2007, including one threatened Steller sea lion 

(Rasmussen 2007). While each species forages on different fish, California sea lions pose a management 

challenge because they forage on salmon. Unfortunately, other pinnipeds in the area are persecuted in the 

mistaken assumption that they are also depleting commercially viable fisheries. Seals and sea lions in the 

Puget Sound are also killed in net fisheries and through entanglement in derelict gear (Natural Resource 

Consultants 2004). Seals have been observed with wounds and scarring from entanglement with derelict 

gear and interactions with aquaculture (net pen) operations. Over-fishing is a threat to pinnipeds to 

varying degrees depending on species and forage fish affected.

Pinnipeds are susceptible to catastrophic events, such as oil spills. Due to their restricted distribution 

within the Salish Sea, elephant seals are particularly susceptible to oil spills. In addition, persistent 

contaminants, such as PCBs and dioxin, accumulate in pinniped blubber and create elevated levels in 

inland harbor seals (Ross et al. 2004). 

Additional threats to pinnipeds include an increased potential for inter-species transfer of diseases, such 

as canine distemper. This threat is particularly relevant on refuge islands which allow dogs access (i.e.,

Matia, Turn, and those close to the main islands in the archipelago). Climate change may produce several 

threats: exacerbating the threat of oil spills; loss of protected haulout habitat due to rising sea levels;

increases in the severity and incidences of storm events; and changes in sea temperatures adversely 

affecting availability of food supply. Finally, rising ocean temperatures or El Niño events may increase 

the potential for bacterial infections. 

4.11.6 Information Gaps

• Use of the San Juan Islands by Steller sea lions (abundance, distribution, phenology).

• Determine the number of elephant seal use days throughout year, especially on Smith Island. 

What is their survival rate and site fidelity to refuge islands?

• What are the migration patterns of the harbor seals? Are the Smith Island stocks more closely 

aligned to PI or to the San Juans? Do the seals move into the Georgia Strait in the winter? Or 

into the Hood Canal? 
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4-52 Chapter 4. Refuge Biology and Habitats 

4.12 Herbivores and Predators of Management Concern

Herbivores and predators of management concern are defined in this document as native or non-native 

species whose expanding abundance or potential presence represents a threat to native wildlife or plants, 

especially breeding seabirds. There are several native and introduced species on refuge islands that pose 

a threat to healthy populations of our focal resources, their habitats, or native plant revegetation efforts. 

They include black-tailed deer, European rabbits, raccoons, mink, otter, Canada geese, and avian 

predators. Rats, red foxes, and feral or domestic pets are not known to exist on refuge islands; however,

they pose a threat and therefore are addressed in this section. 

Species found within island habitats are particularly vulnerable to extinction. Approximately 93% of bird 

species or subspecies that have become extinct since the 1800s were found on island habitats (Courchamp 

et al. 2003). A primary contributing factor to these losses has been the successful establishment of alien 

species. Native species, not typically found on islands, can have just as much of an impact on island 

nesting species as non-native species. This is due, in part, because many island nesting species have not 

developed defenses to avoid or life history traits to accommodate disturbance or predation. Further, nonnative species introduced to seabird nesting islands may become prey to sustain native predators during 

the non-nesting season (Courchamp et al. 2003, Mills et al. 2005). In extreme cases, ecosystems have not 

recovered to historical conditions even after invasive or native species were removed (Ebbert & Byrd, 

2002, Courchamp et al. 2003). 

4.12.1 Black-tailed Deer

Black-tailed deer are abundant in Northwest Washington with a Washington Natural Heritage Program 

ranking of ‘demonstrably secure’ both globally and by state (WDNR 2009). They are native from the 

Cascade crest west toward the coast range. Throughout the state, deer occupy nearly all ecological zones, 

from alpine to valley and have adapted to varied climate regimes. Their average life span is five years 

and few deer live longer than ten years. In general, does breed in their first or second year and two fawns 

are common. 

Historically, this species constituted the highest number of deer harvested in Washington State with an 

average annual harvest of about 14,000 individuals (WDFW 2008). According to models developed by 

WDFW, the black-tailed deer population estimate has nearly doubled over the last 5 years within 

WDFW’s Coastal Region (6), which includes the Olympic Peninsula (WDFW 2009). They occur in high 

numbers on the Quimper and Miller Peninsulas, the closest landmasses to Protection Island, and are 

capable of swimming approximately 1.5 miles from the tip of either peninsula to the island. Black-tailed 

deer use all habitat types present on Protection Island. 

There are no historic records of black-tailed deer on Protection Island. From 1956-59, Richardson (1961) 

made 18 trips to the island and reported that the only native mammals on the island were Townsend 

chipmunk and a shrew. In addition, the Protection Island Master Plan (USFWS 1985) makes no mention 

of deer in the species list. Three adult deer were first observed on the island in 1991 (Hayward 2008). 

Due to a high reproductive rate and lack of natural predators on Protection Island, this number has 

increased to a high estimate of 100 deer in 2008/2009 (J. Hayward pers. comm.). Current estimates are 

approximately 70 deer (P Davis pers. comm.). With approximately 360 acres (0.562 mi2

) on the island, 

that abundance is equivalent to 124 deer/mi2

,which is considered a very high density (A. Clark pers.

comm.). According to ungulate biologists, 10-30 deer/mi2 is considered normal along the Columbia 

River of Washington. No hunting has been allowed on the Refuge since designation and there are no 

natural predators (e.g., mountain lion, bear,and coyotes). In the absence of hunting and predators, 
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Chapter 4. Refuge Biology and Habitats 4-53

population growth is limited only by habitat capacity. Refuge staff have also observed black-tailed deer 

on refuge islands in the San Juan Archipelago. For more information on the effects of deer under current 

management, see Chapter 6.

4.12.2 European Rabbits

Rabbits are one of the fastest colonizing mammals in the world, primarily because of their high 

reproductive rate (Hall and Gill 2005). European rabbits do occur on the larger islands within the San 

Juan Archipelago; however, the sign of rabbits on a refuge island has been of rabbit pellets observed on 

Nob Island within the San Juan Islands NWR (Murphy pers. comm.). 

4.12.3 Canada Geese

The abundance of Canada geese within the San Juan Archipelago has increased over the years and limited 

effects of trampling and introducing non-native plant species to refuge islands have been noted (Bennett 

2007). However, little information exists to assess the extent of their effect on all refuge islands, and 

management may not be warranted given the potential to damage fragile plant communities. Increased 

presence of refuge staff on the islands for other management actions will provide opportunities to monitor 

goose abundance and assess impacts to native vegetation. 

4.12.4 Mammalian Predators

Non-native mammalian predators in this area include rats, red fox, dogs, and cats. Rats are present on 

approximately 80% of the world’s islands and are responsible for at least 50% of global extinctions and 

countless local extinctions (Dolan and Heneman 2007). They can be found primarily on the larger, 

developed islands of the San Juan Archipelago and are non-native; however, they have not been reported 

on refuge islands. Rats have not been observed on Protection Island either, but they could potentially 

colonize the island via a ship wreck or by accessing the island on authorized or unauthorized vessels. Red 

fox are non-native west of the Cascades in Washington and were introduced on San Juan Island in the 

early and mid-20th century (Aubry 1984, R. Milner pers. comm., WA GAP). There have been no reports 

of red fox on refuge islands, although fox are occasionally reported on San Juan Island. Dogs and feral 

and domestic cats are not native in the Salish Sea. Dogs have been allowed on two refuge islands that 

support camping (Turn and Matia islands), but feral and domestic cats are not known to occur on refuge 

islands. 

Native mammalian predators include raccoons, river otters, and mink. Raccoons can be found on islands 

within the San Juan Archipelago, but they have not been observed on Protection Island. River otters have 

been observed on both refuges, and mink have been noted on islands within San Juan Islands NWR. Both 

species are native to this area, however, there are reports of mink introductions to the San Juan 

Archipelago in the early 20th century for fur farming (R. Milner pers. comm.). Due to the close 

proximity of islands within the San Juan Archipelago, these species could be virtually ubiquitous to the 

islands. 

4.12.5 Avian Predators

Native avian predators include crows, ravens, gulls, and bald eagles. These species occur throughout the 

Salish Sea. No management actions have been identified for control of avian predation and limited 

information is available on the effects of native avian predators on the refuges. 
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4-54 Chapter 4. Refuge Biology and Habitats 

4.13 Paleontological Resources

4.13.1 Geological Background

During the late Jurassic and early Cretaceous periods, numerous blocks of exotic terranes were added to 

the western edge of the North American continent to form Washington, British Columbia, and Oregon. 

These terranes consist mostly of rock sequences that formed far from their current location. They include 

volcanic island rocks and fossiliferous marine sediments that originated elsewhere in the Pacific Ocean. 

Jurassic and Cretaceous fossils from these rock sequences occur in the north-central and northwestern part 

of Washington. 

Marine fossiliferous sandstone and siltstone of Cenozoic age cover most of Washington west of the 

Cascades Mountains. The Olympic Mountains consist of marine sedimentary rocks uplifted about 10 

million years ago. The Cascade volcanic chain began to form in the mid-Cenozoic and has been active 

ever since. During the late Cenozoic, the Cordilleran Ice Sheet covered the northern third of the state and 

alpine glaciers covered the higher elevations of the Cascade and Olympic Mountains. 

A variety of rock units ranging in age from early Paleozoic to late Cretaceous are exposed in the San Juan 

archipelago. These rock units are separated by faults and fault zones. The San Juan faults are part of a 

broader fault system that extends 80 km eastward into the North Cascade Mountains.

The landscape of the Puget Lowland and Juan de Fuca Strait is largely the product of repeated glaciations 

by the Cordilleran Ice Sheet during the Pleistocene Epoch (~ 2 million years ago to ~11,000 years ago). 

Dated samples of wood, peat, and shell from southern British Columbia and northern Washington provide 

age control on the growth and decay of this sector of the Cordilleran Ice Sheet during the last (Fraser) 

glaciation (Clague and James, 2002). Starting about 22,000 years ago, the ice sheet first started to form in 

the Coast Mountains and on Vancouver Island of British Columbia, but did not extend south of the 

international border. This advance was followed by a period of climatic amelioration and glacier retreat 

about 19,000 to 18,000 years ago (Hicock et al, 1982). Shortly after 18,000 years ago, the Cordilleran Ice 

Sheet started to advance again. After passing Vancouver Island, it advanced southward as two lobes. At 

its maximum extent 14,500 years ago, the Puget Lobe filled the Puget Lowland, where it was nearly 1000 

m thick over Seattle, and its southern edge extended south to its maximum position near present-day 

Olympia (Thorson, 1980). At about the same time, the Juan de Fuca lobe moved westward along the 

Strait of Juan de Fuca, where the ice sheet covered southern Vancouver Island, filled the Strait of Juan de 

Fuca, and rose against the Olympic Mountains to an elevation of 840 m. Retreat of both lobes began 

shortly after 14,500 yr BP, and by 12,000 yr BP the northeastern Olympic Peninsula and northern Puget 

Lowland were ice free. 

4.13.2 Paleontological Resources

Paleontological resources, also known as fossils, are the remains or traces of prehistoric plant and animal 

life that are found in the geologic formations in which they were originally buried, typically within units 

of limestone, sandstone, mudstone, and shale. Paleontological resources are considered to be 

nonrenewable and sensitive scientific and educational resources.

The major laws protecting paleontological resources on Service lands are the National Environmental 

Policy Act of 1969 (NEPA), the Paleontological Resources Preservation Act of 2009 (PRPA), and various 

sections of Service regulations. 
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Chapter 4. Refuge Biology and Habitats 4-55

Because of their large size and taphonomic durability, mastodon and mammoth remains (mostly molars) 

are the most commonly reported Pleistocene vertebrate fossils in Washington (Barton, 1998). Unlike 

mastodons, which were not elephants, mammoths (genus 

Fossil record in Northwest Washington

Mammuthus

In western Washington, mammoth finds are heavily concentrated in the central and northern Puget 

Lowland. The earliest mammoth finds recovered from western Washington were discovered at Scatchet 

Head on Whidbey Island (located 45 km southeast of Protection Island) around 1860, but these were 

destroyed in the San Francisco earthquake and firestorm of 1906 before they could be identified to species 

level (Lawson 1874, in Barton 1998). Another specimen from the same locality was recovered in the 

1880s and is currently part of the University of California Berkeley paleontology collections. This 

specimen is clearly from a Columbian mammoth. Of two species of mammoth found in Washington 

(

) were large specialized elephants 

that were common during the Pleistocene epoch. This genus first evolved in the early Pliocene (4.0 to 5.0 

Ma) of Africa, and by the early Pleistocene (ca. 1.7 Ma), mammoths had spread throughout Asia and into 

North America (Shoshani and Tassy, 1996; Webb et al., 1989; in Barton, 1998). Mammoths were 

obligate herbivores with a dietary preference for grasses and sedges, herbs, and meadow-bog mosses, 

ferns and aquatic plants.

M.imperator and M. columbi), Barton (1998) states that the Columbian mammoths are by far the most 

common. Of 31 previously reported finds that could be analyzed to species level in the Puget Lowland, 

27 proved to be from Columbian mammoths (Barton, 1992). The Columbian mammoth formally became 

the Washington state fossil in 1998.

A search of the paleontology online collection at Burke Museum of Natural History and Culture was 

completed in May 2009. The records search identified five specimens (B2424, B2436, B2448, B2451, 

B2452) that were collected from Protection Island, but specific location is unknown. These resources are 

all foraminifera (shells) dating to the recent period/epoch. The paleontological site nearest to the Refuge 

on Protection Island is one containing mammoth remains identified in the Zella M. Schultz Seabird 

Sanctuary. Other unprovenienced bones have been collected from other areas of the island as well. In 

addition, a collection of 164 fossils (mostly unidentifiable) from Protection Island which includes a 

mammoth tooth is curated at the offices of the Washington Maritime NWR Complex. In 2008, a partial 

skull of a giant beaver (

Protection Island

Castoroides

Paleontological materials (mammoth tusks and a tooth) have been recovered from Dungeness National 

Wildlife Refuge, located approximately 15 km to the west of Protection Island. Another nearby 

paleontological site which is also known for its archaeological importance is the Manis Mastodon site 

located in Sequim, Washington, approximately 15 km southwest of Protection Island. Mastodon

(

) including incisors was located but has not been formally recorded.

Mammut americanum) and bison (Bison sp.) bones, caribou antlers (Rangifer sp.), and pollen, fruits, and 

seeds were recovered from a colluvial brown, gravelly, silty sand with organic detritus grading upward to 

sandy silt. Radiocarbon dates from fossil pollen and seed assemblages suggest the fossils are 11,000 –

12,000 yr BP (Petersen et al., 1983). 

Although paleontological resources have yet to be identified on the refuge, they are common within the 

broad vicinity of the San Juan Islands, with associated ages ranging from the Paleozoic Era to the 

Holocene Epoch. A search of the paleontology online collection from the Burke Museum of Natural 

History and Culture indentified 60 fossils that have been collected from the San Juan Islands, specifically 

Sucia, Waldron, and Spieden islands. The specimens, primarily mollusca and foraminfera, were collected 

from sandstone, shaly sandstone, and glacial drift deposits from the Pennsylvanian (n=1) and Cretaceous 

(n=25) Periods and the Pleistocene (n=32) and Holocene (n=2) Epochs, ranging in age from 320 million 

San Juan Islands
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

4-56 Chapter 4. Refuge Biology and Habitats 

years to 10,000 years old. 

Other known paleontological resources within the San Juan Islands include those at Deadman Bay on San 

Juan Island, where crinoid debris and fragments of other fossils can be found in limestone pods. Crinoids 

appeared during the Lower Ordovician roughly 490 million years ago and underwent several major 

radiations during the Paleozoic Era. Triassic age (~200 million years) conodont fauna, which are 

elongate worm-like organisms, were identified at Limestone Point on the northwest coast of San Juan 

Island (Savage 1984). On Lopez Island, brownish-red mudstones containing foraminifera dating to the 

mid-Cretaceous (~100 million years) were discovered in a road-cut by Danner (1966). This site is 

important because it provides the youngest dates of the rocks in the San Juan fault system.

A Bison antiquus cranium and partial skeleton dating to 11,760 ± 70 14C yr BP was located in lacustrine 

sediments below peat on Orcas Island. These resources were found unconformably above emergent 

Everson Glaciomarine Drift (>12,000 14C yr BP), which often contains fossil marine shells. Several 

bison finds in similar contexts on Orcas and Vancouver Islands, dating between 11,750 and 10,800 14C 

yr BP, have also been found and indicate an early postglacial land mammal dispersal corridor with 

reduced water barriers between mainland and islands (Wilson et al. 2009). 

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Chapter 5 – Human Environment 5-1 

Chapter 5. Human Environment

5.1 Cultural Resources

5.1.1 Native American Overview

This section provides an overview of the known archaeological and ethnographic uses of the San Juan 

Islands Archipelago region in which the San Juan Islands NWR is located. It is excerpted from a cultural 

resource overview prepared by SWCA (2007) of the study area, which includes all lands in and within 

one mile of the congressionally authorized boundaries of the San Juan Islands NWR. Protection Island 

was not included within the study area for the 2007 cultural resource overview, however much of the 

general history is applicable to that island as well. Information specific to Protection Island is 

summarized from an overview prepared by Daugherty (1988).

Protection Island: Prehistoric and Early Historic Period - Protection Island is located off the northeast 

coast of the Olympic Peninsula. Ethnographic sources indicate that the area was occupied by the 

Chemakuan-speaking Chemakum people (Daugherty 1988). According to early ethnographer Frederick 

Hodge, the Chemakum fought with their Salish neighbors, including the Klallam, and their numbers 

dwindled significantly (Hodge 1907). The ethnohistoric record assigns Protection Island to the territory 

of the Klallam Indians, who ranged over most of the southern shore of the Strait of Juan de Fuca in the 

early historic period. The Klallam followed a seasonal subsistence strategy which included winter 

villages comprised of cedar plankhouses and summer settlements with smaller and more informal 

structures (Daugherty 1988: 46). Their subsistence activities included fishing for salmon and other fish, 

hunting both marine and terrestrial mammals, and gathering plant materials.

San Juan Islands: Prehistoric Period - Native Americans have long utilized the diverse resources (e.g.,

water, fish, wild game, plants, living areas, and burial areas) present in the San Juan Islands to maintain 

many of their cultural lifeways and spiritual connections to the land. Previous archaeological 

investigations have demonstrated the presence of human occupation in the region for a minimum of 

11,500 years.

Several cultural models have been developed in order to explain the history and cultural development of 

Native American peoples in the San Juan Islands. In this region, cultural sequences have been divided 

into five general time periods or phases: Paleo-Indian Period; Cascade or Island Phase; St. Mungo, 

Mayne, and Locarno Beach Phases; Marpole Phase; and San Juan Phase. These periods are based on 

cultural change in the region, including shifts in the organization of subsistence patterns, land-use, and 

technological developments (SWCA, 2007). 

Ethnographic Period - A number of researchers have compiled extensive ethnographic accounts for the 

San Juan Islands. Much of the following ethnographic account relies on Wessen’s (1988) ethnographic 

overview of the study area conducted for the National Park Service, Stern’s (1934) ethnographic study of 

the Lummi, and Suttles’ (1951) unpublished Ph.D. dissertation and subsequent ethnographic accounts 

(Suttles 1990a). 

During the ethnographic period, multiple Native American groups occupied the San Juan Islands 

Archipelago. The inhabitants of the San Juan Islands belong to a more general group of people who 

speak Central Coast Salish languages (Stein 2000, Suttles 1990a, Wessen 1988, 2006). The Salish is a 

broad language family that ranges from Montana to the Pacific Coast (Wessen 1988), and during the 

ethnographic period, Central Coast Salish was spoken from Western Washington to parts of British 

Columbia. The inhabitants of the San Juan Islands belong to one of five language groups of the Central 

Coast Salish, called the Northern Straits Salish (Suttles 1990a, Wessen 1988). 
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The Northern Straits Salish occupied an area that included the southeastern part of Vancouver Island, the 

San Juan Islands, and portions of the southern Gulf Islands and mainland shore. The Northern Straits 

Salish were further divided into seven tribes with distinct but similar dialects. These groups included the 

Lummi, the Samish, the Saanich, the Sooke, the Semiahmoo, the Swinomish, and the Songish (Boxberger 

N.D., Suttles 1990a). Of the seven tribes of the Northern Straits Salish, five occupied the San Juan 

Islands, including the Lummi, the Samish, the Saanich, the Swinomish, and the Songish (Suttles 1990a, 

Wessen 1988). 

In addition to different language dialects, an extensive marine-based economy distinguished the Northern 

Straits Salish from other Coastal Salish groups. Reef-netting for salmon, particularly sockeye, was a 

practice unique to the people living in the San Juan Islands Archipelago (Ames and Maschner 1999; Stein 

2000; Suttles 1990a; Wessen 1988, 2006). In mid-July, sockeye salmon entered the Strait of Juan de 

Fuca and swam up to the San Juan and Gulf Islands and into the Fraser River. Large nets were suspended 

between two canoes along routes taken by the salmon and were situated with anchor lines in order to 

guide the fish into the nets (Suttles 1990a, Wessen 1988). Reef-netting enabled Native American groups 

to collect large quantities of salmon at one time. It was practiced until the 1890s when commercial 

fisheries took control of the resource locations (Boxberger 1980, Marino 1990, Kopperl 2006, Suttles 

1954).

The economic, social, and political organization of the inhabitants of the San Juan Islands was similar to 

other Central Coast Salish groups, characterized by complex and overlapping local lineal groups.

Families held the rights to knowledge and access of reef-netting and other resource locations, as well as 

ceremonial rights and practices, all of which were passed down for generations. Locally, residential 

groupings of the Central Coast Salish included the family, household, local group, winter village, tribe, 

and language group (Suttles 1990a, Wessen 1988).

The Native American groups occupying the San Juan Islands during the ethnographic period practiced a 

seasonal subsistence and settlement pattern. The diversity of subsistence resources on the islands

included camas, deer, elk, salmon, herring, fruit, and shellfish. These resources were accessible at various 

islands during particular times across the seasons. Multiple families gathered in winter villages with 

multiple large split-cedar plank longhouses with either gable or shed roofs (Wessen 1988). In the early 

spring, groups left their winter villages and divided into smaller camps occupying mat lodges, 

rectangular-framed structures covered in cattail rush and cedar bark mats, and procured duck, herring, 

shellfish, camas bulbs, bird, halibut, and spring salmon (Wessen 1988). Both the camas bulbs and the 

fish were dried and processed for storage.

During the summer months, the smaller Native American groups converged into larger communities or 

reef-net camps to prepare for the reef-netting season. The summer camps contained large-pole drying 

racks, which were used to dry large amounts of sockeye salmon (Wessen 1988). In addition to fishing, 

deer and elk were hunted and fruits, shellfish, and sea urchins were collected (Suttles 1990a, Wessen 

1988).

In the fall, the summer camps once again divided into smaller groups and collected and processed clams 

for storage, hunted deer, elk, and duck, and fished for cod. There has been discussion that most Native 

American groups temporarily left the San Juan Islands during the fall for riverine salmon weir camps on 

the mainland and Vancouver Island (Wessen 1988). Wessen (1988) argues that all but the Lummi and the 

Samish departed the San Juan Islands directly after reef-netting season. In some instances, Lummi and 

Samish groups moved into camps on the mainland leaving only a few small groups behind on the San 

Juan Islands. In late November, when the riverine salmon season was over, all Native American groups 

returned to the winter village with food that had been processed and stored, thus commencing the 

subsistence cycle over again.
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Chapter 5 – Human Environment 5-3 

Indian Reservation Era - In the late 18th century, Europeans had started exploring the San Juan Islands 

and the surrounding region. Disease, traders, missionaries, and new technology had severe impacts on the 

Native American people living on the islands at the time. Population numbers declined dramatically due 

to introduced infectious diseases such as smallpox. As a result, surviving Native Americans relocated 

their winter villages from the islands to the mainland. Stein (2000), Wessen (1988), and Schalk (1998) 

suggest that by approximately A.D. 1850, no winter villages remained on the San Juan Islands.

The Treaty of Oregon in 1846 divided the region into British and American jurisdictions, and subsequent 

governmental treatment and recognition depended upon which side of the boundary the Native American 

groups were located. British and Americans both started procuring tribal lands and established treaties 

with Native American groups that were within their own jurisdiction but were not living within the 

disputed area of the San Juan Islands (Suttles 1990a, Wessen 1988).

In 1853, Isaac Stevens became the governor of Washington and the superintendent of Indian affairs. One 

of his tasks as the head of Indian Affairs was to convince Native American groups to sign treaties, 

referred to as the Stevens Treaties. He aimed to quickly consolidate multiple tribes onto a limited number 

of reservations (Richards 2005). Two of Stevens’ treaties, the Point Elliot Treaty and the Treaty of Point 

No Point, pertain to tribes and lands located within the study area. In 1855, Stevens, along with 82 chiefs 

and headsmen of various Native American tribes in the Western Washington region including the Lummi 

and the Samish, signed the Treaty of Point Elliott (Marino 1990, Wessen 1988). 

By signing the treaty, the Lummi subsequently ceded all of their lands to the U.S. Government and were 

required to move onto reservation lands. The reservation included lands around their primary village, the 

Lummi Peninsula, uninhabited Portage Island, and specific fish weir sites. The reservation was also 

shared with the Samish and Nooksack (Kopperl 2006, Suttles 1990a, Wessen 1988). In 1875, the Samish 

were forced to abandon their village on Samish Island. Instead of relocating to the reservation, they 

moved to Guemes Island and established a new village which was later abandoned in the 20th century 

(Wessen 1988, Suttles 1990a).

Despite signing the Treaty of Point Elliott, Native Americans continued to struggle with maintaining their 

rights and access to subsistence locations. In the late 19th to early 20th century, the Lummi struggled to 

keep lands and rights obtained through the treaty. In the 1890s, they lost the use of the reef-netting sites 

at locations such as Point Roberts and Lummi Island due to heavy competition from non-Indian 

commercial fishing companies. Additionally, logjams and flooding prevented access to their village 

(Boxberger 1980, Marino 1990, Suttles 1954).

5.1.2 Euro-American Overview

Protection Island: Early Exploration: The first Europeans recorded visiting the island in 1790, when 

Spanish explorer Manuel Quimper sailed into the Strait of Juan de Fuca for the first time;the island was 

dubbed Isla de Carrasco after his ensign, Juan Carrasco. It was renamed Protection Island by Captain 

George Vancouver, who visited in May 1792 and described the landscape “as enchantingly beautiful as 

any of the most elegantly finished pleasure grounds in Europe” (Meany 1907: 87). Suckley (1859), an 

early naturalist, referred to Protection Island as a favored breeding ground of the rhinoceros auklet.

Euroamerican Settlement: The lands of Protection Island were patented by the United States from the 

public domain to private ownership through presidential actions from 1861 to 1865. Settlers first moved 

onto the island with their cattle, sheep, and horses, and planted alfalfa, barley, and potatoes during the 

mid-to late-1800s. Over the next 100 years, several different families attempted to live on and farm the 

island without success. Heavy grazing caused extensive damage to the native vegetation and severe 

erosion on the slopes.
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From 1937-42, a ring-necked pheasant research project released at least two cats on the island to observe 

the effect of this predator on the isolated pheasant population (Einarsen 1945). Although sheep were not 

on the island during this period, much of the habitat was still recovering from past overgrazing. About 30 

percent of the island was intensively farmed for wheat, alfalfa, and potatoes at this time.

With the onset of World War II, the U.S. Government assumed control of the island and established a 

Coast Artillery battery as a measure to protect the straits.

At least two major fires burned much of the island between 1944 and the 1950s. Prior to 1969, Protection 

Island passed through several ownerships. The major land use during this time was farming, with various 

other uses such as hunting and research. 

In 1969, subdividing and development of the island for homes was initiated. Eventually 580 lots were 

sold and owners began building houses and barging camp trailers to the island. There was no electric or 

telephone service and drinking water had to be transported from the mainland. Although the developers 

did stop the overgrazing, the increased human presence and new activities such as lot development, road 

construction, and gravel pits destroyed some valuable rhinoceros auklet breeding habitat and impacted 

other species. Due to the lack of a drinking water source, the development came to a halt in 1972. In 

1982, Congress established the island as a National Wildlife Refuge, and by 1985 many of the lots had 

been acquired by the Service from willing sellers. A 48-acre parcel at the southwestern tip of the island 

was established as the Zella M. Schultz Seabird Sanctuary.

San Juan Islands: Early Exploration: During the late 18th century, the strait originally discovered by and 

named for 16th century Spanish sailor Juan De Fuca (1592), was explored by numerous expeditions, 

including those of English Captain Charles Barkley (1787) and Spanish Ensign Manual Quimper (1792) 

(Suttles 1990a, Wessen 1988). In 1791, Francisco de Eliza, who gave the San Juan Islands their name, 

explored the southern end of the Straight of Georgia and the San Juan Islands (Wessen 1988). In the 

following year, English Captain George Vancouver sailed through the islands as well. None of these 

early explorers provided accounts of Native American groups in the San Juan Islands. It has been 

suggested that early European contact had great impacts on Native American people on the islands. In the 

18th and 19th centuries, epidemics decimated Native American populations and may have reduced their 

numbers to 20% of the original population (Wessen 1988, Suttles 1990a). 

In addition to disease, other events impacted Native American groups in the region during this time 

period. In the early to middle 19th century, both missionaries and trading companies pursued 

opportunities in the region. Hudson’s Bay Company established two large trading posts in the region, 

Fort Langley in the Fraser Delta and Fort Victoria on Vancouver Island. Traders employed Native 

Americans as trappers, fishermen, mill-hands, loggers, farm hands, sailors and middlemen in the fur trade. 

They also sold items such as fish, shellfish, and fruits to non-Native American peoples (Suttles 1990a). 

While it appears that trading companies did little directly on the islands, they still impacted Native 

Americans within the region, including the San Juan Islands, by instituting changes in their subsistence 

and settlement patterns (Wessen 1988).

Missionaries also had a great impact on the area. In 1841, the first Catholic missionary, Modeste Demers, 

settled at Fort Langley (Suttles 1990a, Wessen 1988). This marked the beginning of the missionary 

movement into the area which continued throughout the late 1800s. Many Native Americans converted to 

these new religions, thus altering their social and religious structures. While there are no accounts of 

missionaries traveling to the San Juan Islands, this does not necessarily mean that people living in the San 

Juan Islands never had contact with them. 
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During the 19th century, American and British interests grew in the region and tensions continued to rise 

between the two nations over the occupation of the San Juan Islands, leading to the signing of the Oregon 

Treaty in 1846 (National Park Service n.d., Vouri 2004). This treaty gave the US control over land south 

of the 49th parallel and also divided the water channel that separates Vancouver Island from mainland 

Washington. However, the treaty failed to recognize that the channel splits into two straits, the Haro and 

the Rosario, with islands in between them. No references of the San Juan Islands were provided, and due 

to a dramatic increase in military presence from both countries in the area, tensions built on this omission. 

Eventually, conflict escalated between the two nations and reached its climax during the “Pig War,” 

discussed in detail in the overview along with other major historical events in the region (SWCA 2007). 

In 1872, the Treaty of Washington was signed and the boundary was set through the Haro Strait, giving 

the US control of the San Juan Islands and setting the boundary between America and Canada.

There is a general lack of settlement or other development within the San Juan Islands NWR during the 

historic period. One story of interest which occurs on an island within the Refuge is that of the “Hermit 

of Matia Island” (Elvin Smith, 1835-1921), who made his way west after the Civil War and settled on 

Matia Island. He sustained himself on the island with fishing and raising chickens, sheep, and rabbits, 

traveling by boat only periodically to Orcas Island for supplies. In 1921, he and a friend disappeared on 

the return leg of one of these supply trips, and though fragments of the boat were later found, their bodies 

were never recovered.

5.1.3 Current Knowledge of Local Cultural Resources, Archaeological Surveys On and 

Nearby Refuge Lands

Protection Island: Apart from the emergency removal of a human burial in 1980 (see below), only one 

intensive survey and cultural resource overview has been conducted on Protection Island (Daugherty 

1988). A project-specific survey prior to the removal of several structures on the northwest face of the 

island was conducted in 2001 with negative results. 

San Juan Islands: Washington State’s Department of Archaeology and Historic Preservation (DAHP) 

Geographic Information System (GIS) database indicates that 165 inventories have been previously 

conducted in the study area as of March 2007. A complete listing of these studies is included in the 

Overview (SWCA 2007, Appendix A). Of the 165 inventories, five occurred on one or more of the 

islands within the San Juan Islands NWR. Two of the inventories (NADB 1331698 and 1332069), which 

encompassed the San Juan Islands NWR, were part of a series of assessments conducted by the 

University of Washington of archaeological sites on State Parks property. Another archaeological 

inventory (NADB 1331172) was conducted on 189 sites containing shell deposits. The survey examined 

distribution patterns for sites perceived to relate to economic activities or human behavior. Many of the 

189 sites were previously recorded by the University of Washington field schools; although 82 new sites 

were recorded within the San Juan Islands Archipelago. 

A fourth inventory was conducted at least partially within the San Juan Islands NWR (NADB 1332339). 

The survey attempted to relocate and document 271 known prehistoric archaeological sites on 32 islands 

in the San Juan County section of the archipelago as well as obtain micro-environmental samplings of 

previously unexamined settings. An additional 51 new archaeological sites were also recorded during the 

survey efforts. A fifth inventory within the San Juan Islands NWR (NADB 1333658) took place solely 

on Smith Island. The survey was conducted on a small section of Smith Island for the installation of a 

Hyper-Fix Navigational Beacon Antenna, during which only a few historic artifacts were located. The 

project area was located within the NRHP-listed Smith Island Light Station site boundaries. 

A more intensive survey of Smith and Minor Islands conducted by SWCA in 2008 covered 64 acres and 

culminated in a review of the structures associated with the light station in order to assess and update their 

determinations of historic significance (see below). 
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5.1.4 Archaeological Sites on and Nearby Refuge Lands

Protection Island: 

No significant cultural resources were identified as a result of the intensive 1988 surface survey within the 

boundaries of the Refuge, although a prehistoric site (never formally recorded) and a paleontological site 

containing mammoth remains were documented within the Zella M. Schultz Seabird Sanctuary. 

Also in the vicinity of the sanctuary, a human burial encased in sediments that had slumped from the top 

of a bluff was removed from the base of the bluff in 1980. The skull and a long bone were transferred to 

Washington State University. In her reminiscence of eight years spent on the island as a young girl, Mrs. 

Doris Prim Hufford noted that she and her siblings “found many arrowheads and spear points: the Indians 

used to have many feasts but there were no graves” (Hufford MSS 66, n.d.). Daugherty notes that the 

thriving population of the camas plant on the island would make likely the presence of aboriginal camas 

ovens. He also notes that subsurface testing an evaluation could reveal remains of historic or prehistoric 

utilization of the island in areas that have not been previously disturbed.

A National Register Nomination form was prepared for Protection Island in 1970. The Period of 

Significance was cited as the 18th century, specifically 1792, and the Areas of Significance included: 

Historic Aboriginal, Agriculture, Conservation, and Military. Apparently, the form was submitted for 

consideration, but no action was taken. Therefore, there are no listed historic properties on Protection 

Island. 

San Juan Islands: 

The DAHP GIS database search indicated that 457 archaeological sites have been recorded within the 

sections containing and proximate to the study area, including 418 pre-contact or “prehistoric” sites, 13 

sites with both prehistoric and historic components, 15 historic sites, and 11 archaeological sites of 

unknown component (SWCA 2007, Appendix A and Table 2). Seven of the 457 archaeological sites and 

28 historic properties found within the study area are located on 5 different islands within the San Juan 

Islands NWR. Other features are typically earthworks, like trenching or depressions, mounds or hearth 

remnants. In addition to the 457 archaeological sites, 28 historic properties were located within the study 

area in the DAHP WISAARD GIS database (SWCA 2007 Appendix D). In this context, historic 

properties are resources that are eligible for or listed on the National Register of Historic Places (NRHP). 

Only one of the 28 historic properties in the study area is located within the San Juan Islands NWR, and 

that is the light station located on Smith Island, discussed in more detail below. 

5.2 Refuge Facilities

The infrastructure and facilities discussed in this section include buildings, roads, trails, recreational and 

docking facilities, regulatory and interpretive signs, and other physical structures. Refer to Chapter 2, 

Alternative A, Figures 2.1, 2.2, and 2.3 for maps which show the location of existing facilities on

Protection Island NWR and Turn and Matia Islands in the San Juan Islands NWR. 

5.2.1 Entrance and Access Points

Protection Island: Protection Island has a single, non-public, access point located in the man-made 

armored harbor (two rock jetties totaling approximately 500 ln. ft.) on the southeast end of the island. 

The facility consists of a concrete boat ramp and a two-dock floating pier (131 ln. ft. with 40 ln. ft. 

gangway) system capable of accommodating four small vessels . There are no other landing facilities on 

the island. Accessing the island via the shoreline is not allowed. 
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Chapter 5 – Human Environment 5-7 

San Juan Islands: Matia and Turn are the only islands in the San Juan Islands NWR open to the public.

Both are open year-round, however, the majority of Matia is designated as wilderness and is closed to public 

entry. All other islands in the Refuge are closed year-round to provide undisturbed habitat for wildlife. 

Matia Island: The primary and only Federally-approved access point for upland areas on Matia Island is 

Rolfe Cove, on the northeast side of the Island adjacent to the 2-acre, non-wilderness, recreation area 

maintained as a State marine park by Washington State Parks and Recreation Commission (WSPRC). Larger 

vessels can moor to one of 2 seasonal buoys or land on a seasonal dock if space is available (approximately 

70 ln. ft. of dock space including 2 sides and 60 ln. ft. gangway). The dock and buoys are available 

approximately April through September. Installation and removal times vary due to weather and scheduling. 

Smaller vessels such as kayaks can land on the dock or on the adjacent beach. 

Although boaters may access other Matia coves from the water, they are not allowed to access upland areas 

from these “pocket” coves. Island visitors are not allowed to access the water outside Rolfe Cove from 

upland areas. However, the presence of a number of unauthorized “social” trails in wilderness areas suggests 

visitors are accessing the Island from coves located on the north, west, and south sides of the island and are 

accessing closed areas from the wilderness loop trail.

Turn Island: Unlike Matia Island, visitors may currently land anywhere that is suitable on Turn Island. 

While there are no docking facilities, the State does maintain 3 seasonal mooring buoys just off the north 

beach. 

5.2.2 Roads and Trails

Protection Island: Protection Island has approximately three miles of primitive dirt roads. The main 

road begins at the marina, ascends the bluffs on the south side of the island, and circles the island’s high 

plateau. There are three small arterials extending from the main road which provide access to a private

residence and the island caretaker’s cabin, the research station bunkhouse, and the east overlook. 

There is a 4,000 square foot parking area associated with the marina where vehicles used by refuge staff, 

researchers, and extended users are located. Vehicles are brought to the island by an infrequent supply 

barge.

San Juan Islands: There are only two islands with foot trails in the San Juan Islands NWR. Matia Island 

has a 1.2 mile wilderness loop trail which circles the island’s interior, and Turn Island has a 0.9 mile loop 

trail which circles the island’s outer perimeter. Also, both Islands have several short trails which access 

camping, picnic, and restroom areas.

5.2.3 Administrative Buildings and Other Infrastructure

Complex Headquarters: Management of Protection Island NWR and San Juan Islands NWR is carried 

out from the Washington Maritime National Wildlife Refuge Complex headquarters located at 715 

Holgerson Road, Sequim, Washington. The headquarters consists of an administrative building (3756 sq. 

ft.), shop building (3848 sq. ft.), and an equipment storage building (2220 sq. ft). 

Protection Island: There are a total of twelve buildings on the island. See table 5.1. Seven are directly 

related to island management. One building functions as a research station/bunk house and another is a 

shop/storage area for the research station. There is a 140-ft. well, 33,000 gallon water tower, and 10,200 

linear feet of water distribution systems. The office, maintenance shop/garage, and fire cache/storage 

building are all located on the lower level of the island, approximately 10 feet above sea level. 
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Table 5.1 Protection Island NWR Buildings

Refuge Maintained Buildings Size: Sq. Ft. Location Condition

1 Maintenance shop/garage 864 South lowlands Very good

2 Office 468 South lowlands Poor

3 Fire cache/storage 240 South lowlands Poor

4 Pump/well house 80 Central uplands Fair

5 Research station/bunkhouse 768 East uplands Fair

6 Research storage/shop 120 East uplands Poor

7 Caretaker’s cabin 1280 South uplands Good

8 Caretaker’s cabin car port 312 South uplands Fair

9 Caretaker’s cabin generator shed 80 South uplands Fair

Buildings not maintained by the Refuge

10 Private residence 800 South uplands Fair

11, 12 Unoccupied residences (2) 1700 total Central uplands Poor

Because most of the electrical power consumed on the Island is supplied by gasoline generators, there is a 

need to upgrade Island infrastructure to include more solar power. Currently, the caretaker’s cabin and 

research station/bunkhouse utilize solar power; however, these small systems supply only a portion of the

energy requirements.

San Juan Islands: There are no buildings maintained by the Refuge in the San Juan Islands NWR. 

However, there are camping and picnic facilities, including composting toilets, on Matia and Turn Islands 

which are maintained by the WSPRC. These include picnic tables and fee collection equipment such as 

pipe safes and registration envelope dispensers. Matia has a double composting toilet and Turn has two 

single composting toilets. 

5.2.4 Signs

A complete sign inventory for both Protection Island NWR and San Juan Islands NWR can be found in 

Appendix D of this document. The U.S. Fish and Wildlife Service maintains both informational and 

regulatory signage in accordance with standard Service policy; however, due to the nature of these island 

refuges, a series of non-standard signs has been adopted. These include “large format,” heavy duty signs 

approximately 5 feet wide by 4.5 feet tall. Such signs are used in particularly sensitive habitat marine areas 

susceptible to disturbance by watercraft. These signs may be either white or brown and typically warn 

boaters to remain 200 yards from shore to protect wildlife. The size allows for text large enough to be clearly 

legible from a distance. 

Protection Island: Signs on Protection Island include six “large format,” 200-yard boater warning signs, a 

large sign that reads “Protection Island NWR, Established August 26, 1988”, a reflective “Marina Closed” 

sign, various standard 11-inch x 14-inch “Closed Area” signs to warn residents and researchers of sensitive 

habitat and dangerous areas, and a sign maintained by the Washington Department of Fish and Wildlife which 

designates the Zella M. Schultz Seabird Sanctuary. See Protection Island NWR sign plan, Appendix D.

Matia and Turn Islands: Currently there are no interpretive Service signs located on either Matia or Turn 

Islands, the only areas open to the public in the San Juan Islands NWR. However, each island does have 

minimal informational signage such as the island name with agency logo and minimal standard regulatory 

signage. The WSPRC maintains signage on both islands which provides general information such as camping 

and fee information.

San Juan Islands NWR, closed islands: The majority of rocks and islands within the Refuge are marked. 

Areas that are marked generally have standard Service 11-inch x 14-inch “Closed Area” signs in tandem with 
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Chapter 5 – Human Environment 5-9 

similar sized “blue goose NWR” signs. However, 15 islands are marked with “large format,” 200-yard boater 

warning signs. Due to the harsh marine environment a great majority of these signs are worn and need 

replacing. In addition, See San Juan Islands NWR sign plan, Appendix D, for a complete inventory.

Two standard signs are prevalent within the Refuge. Currently these signs measure 11-inch x 14-inch and

read either: “NATIONAL WILDLIFE REFUGE, UNAUTHORIZED ENTRY PROHIBITED” or “AREA 

BEYOND THIS SIGN CLOSED, All Public Entry Prohibited”. Due to the need to place signs outside of 

dynamic boundary areas such as shorelines, the latter text is often rendered confusing and inappropriate for 

island units which are completely closed. In addition, due to their size, they are legible only after an 

individual has trespassed and as such are visually inadequate.

5.3 Research

Research activities have taken place on Protection Island NWR and the San Juan Islands NWR for many 

years, some prior to the Refuges’ establishments. Over 80 research projects reported in published or grey 

literature have been conducted since the late 1930’s with the majority since the mid-1980’s. Primary 

research has been focused on glaucous-winged gulls, rhinoceros auklets, pigeon guillemots, and bald 

eagles.

5.3.1 Research Activities Prior to Refuge Establishment

The Oregon Cooperative Wildlife Research Unit of the U.S. Fish & Wildlife Service conducted ringnecked pheasant studies on Protection Island from 1937 through 1942 for the purpose of accumulating 

information as a guide to their management in the Northwest. A long-term bird banding operation of 

glaucous-winged gulls was conducted by the Western Bird Banders Association. Gulls were banded in 

the trans-boundary area of Canada and the U.S. starting in 1940 and continuing thru 1973. Banding on 

Colville Island in the San Juan Islands NWR was carried out for the longest period of any U.S. gull 

colony followed by Protection Island. 

In the 1960’s, a Cooperative Agreement between the Bureau of Sport Fisheries and Wildlife and the 

University of Washington allowed the University’s Friday Harbor Lab to conduct research studies on 

marine resources on tide flats and shorelines of Colville, Jones, Matia, Turn and Smith Islands. In 1967, 

Colville Island was removed from the agreement to reduce potential adverse impacts to glaucous-winged 

gulls nesting there. Glaucous-winged gull and bird population studies were conducted on Colville, Four 

Bird Rocks, Three Williamson Rocks, Flower Island, Pointer Island and Ram Island by researchers from 

Walla Walla University. 

During the 1970’s, glaucous-winged gull studies and bird population studies continued on Colville 

Island, Williamson and Bird Rocks, and on Protection Island by staff and students of Walla Walla 

University. Additional bird population studies were conducted in 1970 on Flower, Pointer, and Ram 

Islands by the University. 

National Oceanic and Atmospheric Administration (NOAA) biologist Clifford H. Fiscus conducted 

research on harbor seals on Smith and Minor Islands and on Protection Island as part of NOAA’s Marine 

Ecosystem Analysis (MESA) Project from 1977 to 1979. Funded by NOAA and EPA, the MESA Project 

set out to record the distribution and abundance of a wide range of marine species and habitats over the 

northern portion of Washington State’s inland waters. Fiscus’s study characterized marine mammal 

populations and their habitats vulnerable to petroleum-related activities. Regular surveys were used to 

determine times and places for breeding, feeding, and rearing of young as well as timing of entrance and 

departure of seasonal pinniped migrants. 
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Also as part of NOAA’s MESA Project, a SUP was issued to Stephen M. Speich in 1978 and 1979 to 

conduct low level aerial surveys to characterize the distribution, abundance, and time of occurrence of all 

the breeding and non-breeding birds in the Strait of Juan de Fuca, San Juan Islands, and the Strait of 

Georgia. Dr. David Manuwal and Terry Wahl also participated in the study.

5.3.2 Protection Island NWR Research Activities

Dr. Joseph G. Galusha, Walla Walla University, began his work in 1979 and to-date has had 21 graduate 

and 11 undergraduate students work on projects. A majority of his work has dealt with glaucous-winged 

gulls. Research topics include time budgets while in the colony; spatial aspects of territorial behavior; 

parent-chick recognition, social behavior of gulls living in different habitats; behavior of resident and 

intruder gulls; behavior and survival of families of differing size; egg-laying chronology and reproductive 

success of glaucous-winged gulls; and social facilitation of chicks and parents while on territory. He also 

studied the impacts of an increasing bald eagle population on the glaucous-winged gull colony, and 

conducted periodic total gull colony censuses. Dr Galusha and his students studied pigeon guillemot 

breeding success and daily time budgets of this species as it relates to human disturbance. Northwestern

crow population and breeding success and double-crested cormorant colony utilization and flight patterns 

were also studied. 

Thomas A. Lee, Walla Walla University, also conducted research on the natural history and aspects of 

behavioral ecology of the Northwestern Crow on Protection Island. 

Dr. James L. Hayward, Andrews University, has conducted a number of research studies and 

investigations on the Refuge since 1987. Ten graduate and 22 undergraduate students of his have worked 

on projects primarily studying glaucous-winged gulls, including: eggshell taphonomy, bone growth and 

developmental bone histology, egg-laying synchrony, reproductive success, pellet counts, prediction of 

habitat occupancies by gulls in relation to environmental factors, and impacts of bald eagles on gull 

behavior. In addition, Dr. Hayward’s research topics include great-horned owl pellet contents; historical 

changes in island structure and vegetation, prediction of harbor seal haul-out times, Protection Island food 

web, and a Protection Island flora and vegetation map.

Steve Jeffries, WDFW, has conducted marine mammal studies on Protection Island NWR and the San 

Juan Islands NWR since the 1990’s. Studies have included harbor seal and elephant seal census, food 

habits, health monitoring (blood and tissue samples), contaminant research, and mortality event 

investigations. 

Scott Pearson, WDFW, Peter Hodum, University of Puget Sound, Michael Schrimpf, Jane Dolliver

and Julia Parrish, University of Washington, and Thomas Good, NOAA Fisheries, studied long-term 

changes in seabird diet and the potential impacts of these changes on seabird populations since 2006. 

Work on Protection Island has focused on rhinoceros auklets and included burrow counts, burrow density, 

occupancy rates, and associated habitat variables. 

Lee Robinson, Refuge volunteer, has conducted long-term monitoring of pigeon guillemots on Protection 

Island. This work began as part of the Puget Sound Ambient Monitoring Program in 1994. Nest boxes 

were established and are monitored throughout breeding and chick rearing. Data on chick weight and 

wing length measurements are collected.

Ulrich Wilson, retired Refuge wildlife biologist, conducted long-term rhinoceros auklet research that 

spans over 25 years. Studies included burrow use, breeding success, chick growth, chick survival, diet 

studies, population estimates from burrow counts, and effects of El Niño events on Protection Island 

rhinoceros auklets. He also investigated DDE, PCB’s, cadmium, lead, and mercury concentrations in 

rhinoceros auklets from Washington State. 
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Chapter 5 – Human Environment 5-11 

Brent Norburg from NOAA’s National Marine Mammal Laboratory and WDFW was issued SUPs to 

conduct research on harbor seals on Protection Island NWR and San Juan Islands NWR. This research 

included radio tagging harbor seals, food habits, pupping phrenology, and population assessment.

Western Heritage, Inc., of Olympia, Washington, conducted cultural resource surveys on Protection 

Island in 1988. 

5.3.3 San Juan Islands NWR Research Activities

Joe Bennett, University of British Columbia’s Center for Applied Conservation Research, has conducted 

research in support of his doctoral thesis, “Determinants of plant community composition in coastal 

meadow ecosystems of Vancouver Island and adjacent islands,” on a number of Refuge islands in the San 

Juan Archipelago. Floristic surveys and soil samples were collected to assess drivers of savanna 

ecosystem composition and vulnerabilities. 

John Calambokidis of the Cascadia Research Collective, a non-profit research organization, has been 

issued SUPs to continue work begun in the 1970s to determine long-term trends in concentrations of 

chlorinated hydrocarbon contaminants in harbor seals and other environmental components (mussels and 

sculpins) at Smith and Minor islands. In 1977, John conducted research on habits, behavior, and 

population dynamics of harbor seals on Smith and Minor Islands. He has been particularly interested in 

harbor seal pup mortality on the islands, which some years have totaled 60+ animals. John has also 

assisted Steve Jeffries, WDFW, with his work on marine mammals. 

R. Wayne Campbell, British Columbia Provincial Museum, Victoria, B.C., conducted a nest use survey 

of double-crested cormorant colonies on the Sisters Islands, Viti Rocks, and Bird Rocks in 1976. 

Dr. Mark Dybdahl, University of Washington’s Friday Harbor Laboratories, conducted research in the 

San Juan Archipelago in the 1990s, which included a census and some collection of tide pool copepods. 

David Giblin, University of Washington Herbarium, Burke Museum of Natural History, and Peter 

Dunwiddie, TNC, began a systematic effort to collect, archive, and disseminate floristic information 

concerning the smaller islands (<100 hectares) of the San Juan Archipelago in 2005, 2006, and 2009. 

Preliminary results show that the small islands in the San Juan Archipelago harbor substantial numbers of 

rare plant populations. In addition, due to the lack of residential or agricultural development, several 

small islands harbor some of the most pristine examples of Puget Sound prairies in the region. These 

surveys have generated important baseline data in light of anticipated vegetative changes in response to 

climate change. 

Dr. David A. Manuwal conducted studies on dispersal of rhinoceros auklets from disturbed natal colony 

sites on Smith and Minor Islands and Protection Island. 

Ruth Milner, WDFW, lead a research project entitled “Post-breeding movement of the black 

oystercatcher in the North Puget Sound – VHF Tracking Study”. This study extends the VHF tracking 

portion of a larger 2007 study of black oystercatcher movements between breeding, stopover, and over 

wintering sites at Prince William Sound, Middelton Island, Stephens Passage near Juneau, Alaska, 

Kodiak NWR, and along the west coast of Vancouver Island. 

On a larger scale, this effort will increase our understanding of how animals breeding in different 

segments of the black oystercatcher’s range behave in winter and is important to the effective 

management of this species (e.g., oil spill response, habitat conservation, and monitoring response to 

disturbance). Some of the birds captured for this study came from islands within San Juan Islands NWR. 
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 5-12 Chapter 5 – Human Environment 

Sue Thomas (USFWS), Dave Nysewander, Joe Evenson and Tom Cyra (WDFW) also participated in this 

study. Ruth was also issued a SUP in 2007 to ground truth a west-coast-wide aerial survey of gulls. That 

SUP allowed access to Hall Island, Gull Rock, Three Williamson Rocks, and Peapod Rocks in the San 

Juan Islands NWR. 

Dave Nysewander and Joe Everson, WDFW, have conducted pigeon guillemot and black oystercatcher 

censuses on the San Juan Islands NWR since the 1990’s. Their recent surveys have been conducted using 

amplified black oystercatcher calls, a study technique they developed. 

Richard Knight, Coordinator of the Washington Eagle Study for the Washington Department of Game, 

was issued a SUP in 1980 to visit active eagle nests, band and mark young, take blood samples for heavy 

metal and PCB analysis, and collect food habit data. 

Steven Speich was issued a SUP in 1983 to survey the breeding marine birds of the San Juan Islands to 

determine breeding status, stage of nesting, status of tufted puffins and rhinoceros auklets, and to describe 

the habitat.

Research on Refuge lands requires submission of a research proposal, which is reviewed by Refuge staff, 

and if approved, a Special Use Permit with special conditions to ensure compatibility is issued to conduct 

the study.

5.4 Refuge Recreation

5.4.1 Open and Closed Areas

Protection Island: All of Protection Island National Wildlife Refuge is closed to the public year-round. 

San Juan Islands: Turn and Matia Islands are the only units open to the public within the San Juan 

Islands National Wildlife Refuge. The remaining 81 rocks, reefs, and islands are closed to public entry 

year-round to provide undisturbed habitat for wildlife. Currently the whole of Turn Island and 2 acres on 

Matia Island are managed as State Marine Parks under a Memorandum of Understanding (MOU) with the 

WSPRC. Of all the State Parks in Washington, Matia and Turn are the only ones located on a National 

Wildlife Refuge (WSPRC 2007a). These unique Refuge units are the only places in northwest 

Washington State where boating visitors can experience island wildlife and their habitat on a National 

Wildlife Refuge. Both Islands are accessible year-round.

Matia Island: The 2-acre recreation/camping area located adjacent to Rolfe Cove and a 1.2 mile wilderness 

loop trail are the only areas open to the public on Matia Island. The remaining 140 acres of the Island are

designated as a National Wilderness Area. Except for the 1.2 mile loop trail, the wilderness area is closed to 

the public to provide undisturbed habitat for wildlife. Visitors are required to stay on the trail and are not 

allowed to access other areas from the trail. The wilderness trail offers a unique glimpse of protected old 

growth island forest habitat present in only a few places in the region. 

The nearest safe harbor to Matia Island is Sucia Island State Marine Park, approximately 1.3 nautical 

miles to the west (Carlten Tripod 2009). However, Sucia Island and its associated smaller islands 

comprise a large, busy park offering a very different experience at 564 acres, including two docks (660 

feet of space), 48 mooring buoys, and 55 campsites (WSPRC 2009).

Turn Island: There are currently no closed areas on Turn Island and boaters may access all beaches; 

however, future management strategies may include closing some areas to benefit wildlife and vegetation. 
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Chapter 5 – Human Environment 5-13 

Turn Island’s close proximity to busy Friday Harbor makes it an ideal destination for those seeking an 

easily accessible Island experience. At just 35 acres, Turn Island is relatively small, but offers safe and 

easy access for small boats. Unlike Matia Island, Turn is not designated as wilderness. However, much 

of the Island is relatively undisturbed so whether wandering the wide open beaches or hiking the Islands 

0.9 mile perimeter loop trail, there is a very good possibility of encountering some of the Island’s 

protected wildlife.

Because Turn Island has no docking facilities, larger vessels looking for dock access often bypass 

Turn, instead choosing to head for the much larger Jones Island State Marine Park approximately 6 

nautical miles to the north (Carlten Tripod 2009). At 188 acres, Jones Island has 320 feet of 

seasonal dock, 7 mooring buoys, and 21 campsites including the ability to accommodate large 

groups (WSPRC 2009). 

5.4.2 Annual Recreation Visits

Matia Island is remotely located at the far north east corner of the San Juan Islands Archipelago which is

a popular tourist destination. Many Refuge visitors likely come from the nearest large population center, 

Bellingham, Washington. Bellingham is approximately 17 nautical miles to the east (Carlten Tripod 

2009) and has a population of more than 77,000 people (CityData.com 2009). However, Matia Island 

receives visitors from across the region and beyond. 

According to data collected by the WSPRC, it is estimated that Matia Island received 1,868 day use and 

2,228 overnight use visitors in 2008 (WSPRC 2008a). However, recorded figures are likely to be much 

lower than the actual visitation numbers due to limitations of survey timing and techniques. Matia figures 

are calculated by recording the number of boats in the approved landing area in Rolfe Cove multiplied by 

a factor of 5.25 to determine a day count. These figures do not account for vessels landing in other areas. 

WSPRC staff members suggest the actual figures could be as much as four times higher (USFWS 2007a).

Turn Island is located approximately two nautical miles southeast of Friday Harbor, Washington, the 

most populous city in the San Juan Islands with just over 2,000 residents and also the primary 

transportation hub for the Islands (CityDate.com 2009). It is estimated that Turn Island received 10,248 

day use and 3,061 overnight use visitors in 2008 (WSPRC 2008a). As with Matia Island, recorded

visitation figures for Turn Island may be less than 25percent of the actual number of visitors using the 

Island (USFWS 2007a).

WSPRC’s data for visitation between 2002 and 2007 can be interpreted to indicate visitation overall 

remained fairly steady for both islands (WSPRC. 2008a). However, WSPRC staff indicates that kayak 

visitation increased on Turn Island during that time while it remained fairly stable on Matia Island. Staff 

members also indicate that larger vessel use of Matia may be declining (WSPRC. 2007c). This could be, 

in part, due to the limited docking space available in Rolfe Cove, combined with the nearby alternative, 

Sucia Island, which offers considerably more docking facilities. 

5.4.3 Wildlife Observation and Photography 

Wildlife observation and photography are primary uses of Matia and Turn Islands. However, Refuge 

wildlife, especially birds, can also be viewed and photographed from the water near other Refuge islands,

including Protection Island NWR. There are numerous commercial ecotourism charters operating in both 

areas. Wildlife observation and photography is covered more in the following section titled Regional 

Recreation Opportunities and Trends.
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 5-14 Chapter 5 – Human Environment 

Matia Island: Matia Island presents a unique opportunity to walk and camp among old growth trees and 

listen to the sounds of wildlife and waves in one of the most beautiful and peaceful settings in the Salish 

Sea. The 1.2 mile wilderness loop trail provides limited wildlife viewing and photography opportunities,

as well as a peaceful respite from the busier 2-acre recreation area. The wilderness loop trail begins and 

ends in the 2-acre recreation area and is not intended to provide access to other parts of the Island. In 

addition to wildlife viewing and photography, and walking the wilderness trail, Matia provides 

opportunities to experience wildlife by day and at night while camping in one of the 6 primitive sites. 

Turn Island: Turn Island has a 0.9 mile perimeter trail which provides visitors with opportunities to 

view and photograph wildlife. This short walking trail encircles the island passing through a variety of 

wildlife habitat from rocky shorelines to meadows to mixed forests. Future plans for this trail include the 

addition of interpretive information and some changes to protect sensitive vegetation. In addition to the 

loop trail, Turn Island has an extensive open beach area suitable for observing aquatic species and landing 

small craft. The shoreline outside of the beach areas is available for wildlife viewing and photography 

from the water but is not suitable for landing vessels. In addition to wildlife viewing and photography, 

and walking the loop trail, Turn currently provides opportunities to experience nature by day and at night 

while camping in one of the 13 primitive sites. 

5.4.4 Environmental Education and Interpretation

Protection Island NWR: The primary education opportunities on Protection Island NWR are in 

association with volunteers and college students conducting or assisting with research projects.

San Juan Islands NWR: Currently the San Juan Islands NWR has no formal environmental education or 

interpretation programs, and many visitors are not fully aware that Matia and Turn are part of a national 

wildlife refuge. Additionally, information provided via travel websites and elsewhere often neglects to 

mention that these islands are part of the National Wildlife Refuge System. Future plans for both islands 

include increasing interpretation opportunities with the goal of helping visitors understand and appreciate 

their unique value as island national wildlife refuges. 

5.4.5 Hunting and Fishing

Currently there is no hunting on refuge lands; for information regarding nearby hunting see section 5.6.1 

below. There are no fish-bearing water resources on any of the refuge islands. There are, however, fishing 

opportunities in the marine waters that surround refuge islands. For more information about nearby fishing,

see section 5.6.2 below. 

5.4.6 Camping

In 1960, WSPRC began planning and installing camping and picnicking facilities on Matia and Turn Islands

as provided for under MOU’s with the U.S. Fish and Wildlife Service. It was determined that “Seasonal use 

of the islands by wildlife affords an opportunity for controlled recreation use without limiting the function of 

the islands as wildlife sanctuaries; thus, the Bureau of Sport Fisheries and Wildlife (USFWS) has concurred 

in the development of docking and picnicking facilities at designated locations” (Laythe 1959 pers. comm.). 

Since that time, camping, picnicking, restroom, and boating facilities have been developed and maintained by 

the WSPRC. 

Currently, camping is allowed year-round on a “first-come, first-served” basis. Camping fees are $12 – 14 

per night, no reservations required. All fees are collected by the WSPRC. Additionally, mooring buoys are 

$10 per night and overnight dock fees on Matia are 50 cents per foot, $10 minimum.
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Chapter 5 – Human Environment 5-15 

Matia Island: Matia has 6 primitive campsites and one additional picnic site, all with picnic tables. In 

addition, Matia has a composting public toilet, 2 seasonal mooring buoys, and a seasonal dock located in 

Rolfe Cove. 

Turn Island: Turn has 13 primitive campsites and a picnic site, all with picnic tables. In addition, Turn 

has 2 composting toilets and 3 seasonal mooring buoys. 

Camping affords visitors an opportunity to view wildlife at times when animals are particularly active,

such as dawn and dusk, and to experience the sounds of wildlife at night. In addition, visitors who have 

traveled by human-powered craft may be afforded safe refuge to rest, and to allow wind and inclement 

weather to abate. 

5.4.7 Pets 

WSPRC regulations currently allows pets on leashes in the campground areas on Turn and Matia Islands. 

Visitors however, routinely allow pets off-leash and on trials and other areas where they are not allowed. Pets 

other than authorized hunting dogs and service animals are not typically allowed on national wildlife refuges 

because they disturb and/or prey on wildlife; decrease the presence of wildlife; decrease opportunities to view 

wildlife; can be involved in disease transmission to or from wildlife; and can be a safety hazard to humans or 

the pets themselves. 

5.4.8 Unauthorized Refuge Uses

Protection Island NWR

Due to the frequent presence of refuge staff, volunteers, and researchers on Protection Island, unauthorized 

activities are uncommon. 

San Juan Island NWR

Pets are frequently observed off-leash on Turn and Matia Islands. People and their pets also trespass on 

closed refuge islands. Impacts of pets are described above under 5.4.7. People disturb driftwood on closed 

islands to build makeshift sculptures. Disturbing driftwood impacts the wildlife values of this important 

habitat component. Wildlife such as shorebirds, seabirds, and marine mammals require areas of sanctuary 

where they can rest, nest, and forage free from human disturbance. The presence and activities of people 

and/or their pets can make otherwise suitable wildlife habitat unavailable to these species. These activities are 

in violation of chapter 50, section 26.21, of the Code of Federal Regulations.

Matia Island: The shoreline perimeter around Matia Island is closed, with the exception of Rolfe Cove. 

However, due to the inviting nature of Matia Island’s many “pocket” coves and the lack of clear regulatory 

signs, a number of unauthorized “social trails” have developed through closed areas leading from the 

wilderness loop trail to bluff areas and beaches around the Island. These areas are important habitat for 

sensitive species, such as eagles, cormorants, and black oystercatchers, which may be harmed by disturbance. 

Wildlife such as marine mammals, shorebirds, and seabirds will avoid shorelines that are frequented by 

people. This otherwise suitable habitat becomes unavailable to these species due to human activities. 

Unauthorized wood cutting and collection occurs on Matia Island even though open fires are not allowed and 

cooking grills have been removed by the WSPRC. Unauthorized fire rings, where materials such as 

driftwood and cut tree branches are burned, are evidence that refuge regulations are sometimes ignored. An 

important reason for prohibiting open fires is that Matia Island is considered to be at high risk of catastrophic 

wildfire. The incredible old-growth forest on Matia Island might never fully recover its habitat and aesthetic 

values if a stand-replacing forest fire occurred. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-16 Chapter 5 – Human Environment 

Turn Island: WSPRC has reported that Turn Island has among the highest number of incidents of 

unauthorized activities among all of the marine state parks. Refuge staff are concerned that Turn Island has 

become a destination for non-wildlife dependant recreation inappropriate for a National Wildlife Refuge and 

incompatible with the refuge purpose. Its close proximity and easy access to Friday Harbor makes it popular 

with visitors, including those exhibiting undesirable behaviors. Unauthorized wood cutting and collection 

also occurs on Turn Island, even though open fires are not allowed and cooking grills have been removed by 

the WSPRC. Unauthorized cutting and collecting of firewood is resulting in damage to native vegetation. 

Uncontrolled “social trails” have been created on fragile slopes and meadows. 

5.4.9 Law Enforcement and Resource Protection

There is one dual function officer assigned to cover all of the six refuges in the Washington Maritime 

National Wildlife Refuge Complex. That officer is based out of the Refuge Complex headquarters located at 

the Dungeness National Wildlife Refuge near Sequim, Washington. As a result of the geographic distances, 

and their remoteness, Matia and Turn Islands are patrolled very infrequently, less than 5 days per year. 

The Service entered into an MOU with WSPRC in 1959. This MOU with WSPRC was in response to 

“uncontrolled public use” which “created litterbug and sanitation problems” (Laythe 1959 pers. comm.) 

and was designed to convey authority to WSPRC to manage and regulate recreational activities, including 

camping and picnicking, on the non-wilderness portion of Matia Island and on the whole of Turn Island. 

As a result of that and subsequent modified MOUs, WSPRC has served as the primary law enforcement 

agency on Turn and Matia Islands. In a 2007 meeting, WSPRC staff indicated that Turn Island typically 

has a much higher law enforcement incident rate than other State Marine Parks (USFWS 2007a).

5.5 Other Refuge Uses

5.5.1 Proprietary Uses 

United States Coast Guard

The U.S. Coast Guard operates and maintains a number of aids to navigation structures on or immediately 

adjacent to refuge islands in the San Juan Islands and Protection Island. Nineteen of these are covered 

under a 2005/2006 MOU. Also see Appendix A and Appendix E. 

NOAA 

The National Oceanic and Atmospheric Administration’s National Data Buoy Center established the 

Coastal-Marine Automated Network (C-MAN) for the National Weather Service in the early 1980s. A CMAN Station (S1SW1) was established on Smith Island in 1984. The development of C-MAN was in 

response to a need to maintain meteorological observations in U.S. coastal areas. Such observations, 

which had been made previously by USCG personnel, would have been lost as many USCG navigational 

aids were automated under the Lighthouse Automation Modernization Program. 

C-MAN station data typically include barometric pressure, wind direction, speed and gust, and air 

temperature; however, some C-MAN stations are designed to also measure sea water temperature, water 

levels, waves, relative humidity, precipitation, and visibility. The station on Smith Island is mounted on a 

tower and is powered by marine batteries charged with solar cells. Standard meteorological data has been 

collected since 1984 and continuous wind data since 1997. 
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-17 

5.5.2 Non-proprietary Uses

Island Oil Spill Association, San Juan County 

Island Oil Spill Association (IOSA) is a unique, community-based, private non-profit organization that 

provides a range of response services including initial assessment, containment and clean-up, and oiled 

wildlife rescue. The association is volunteer-based with more than 200 trained responders. It is fully 

recognized by the U. S. Coast Guard as a Federal Oil Spill Response Organization and by the Washington 

State Dept. of Ecology as an Approved Primary Response Contractor. It has field-tested and developed 

54 geographic response plans to protect the most sensitive resources in the San Juan Islands area. The 

refuge has worked with this group by providing anchoring points on Fortress, Crab, and Blind Islands to 

help with the deployment of containment booms.

Low Island – Yellow Island Marine Research Preserve

Working with the University of Washington Friday Harbor Lab and The Nature Conservancy, the refuge 

has permitted the placement of two signs on Low Island. These signs inform the public that the area 

around Low and Yellow Islands is a marine research preserve and a no fishing area.

5.6 Regional Recreational Opportunities 

5.6.1 Hunting

The quantity of waterfowl hunting near the refuges is low in comparison to the rest of Washington State 

(Davison 2008 pers. comm.). Dabbling ducks such as mallards, wigeons, and pintails are hunted 

primarily by local residents on bays, inlets, ponds, lakes, and other public and private wetland areas. 

However, due to an increasing interest in hunting sea ducks including scoters, harlequin, and long-tailed 

ducks, the North Puget Sound area has become a “destination” for sea duck hunting (WDFW 2007, 

WDFW 2008b, Nysewander 2008 pers. comm.). Sea duck hunting guides in the area attract a growing 

clientele of domestic and international hunters (Davison 2008 pers. comm.) interested in a “once-in-alifetime” opportunity to hunt these unique species of ducks (Peninsula Sportsman 2008, Wings and 

Waves 2008). Most of the sea duck hunting seems to occur from areas close to the mainland (outfitters 

and guides operate out of Quimper Peninsula and Skagit Valley area shorelines). Boats typically used for 

sea duck hunting are not well equipped to make the often challenging crossing from the mainland to the 

islands.

Island County has the highest sea duck harvest numbers in the state (WDFW 2008b). Skagit and 

Whatcom Counties are also among the highest while Jefferson County has lower sea duck harvest 

averages. In San Juan County, 2007 was the first year that any sea duck harvests were reported since 

mandatory reporting started in 2004. If interest in sea duck hunting continues to grow it is likely to 

increase in this county as well (WDFW 2008b). As resident goose populations rapidly increase in the San 

Juans, goose hunting opportunities are increasing because more private landowners are opening their 

properties to hunters (Davison 2008 pers. comm.).

There are limited opportunities for deer hunting near either refuge. In the vicinity of Protection Island 

NWR, there is a small amount of public land open to deer hunting in the northern portions of Quimper 

and Miller Peninsulas and in the Sequim vicinity. In addition, a few nearby private landowners allow 

hunting on their properties (Schirato 2008 pers. comm.). 

Island County allows public hunting on three of their Whidbey Island properties near Greenbank and 

Penn Cove (Joantha Guthrie 2008). In the San Juan Islands area there are high concentrations of deer, but 

most land is privately owned (WDFW 2008a) and San Juan County requires hunters on private land to 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-18 Chapter 5 – Human Environment 

carry written permission from the landowner to hunt (San Juan County Code 9.08.040). Because public 

hunting is limited and the best opportunities are on private lands, primarily local residents engage in these 

nearby deer hunting opportunities (Milner 2008 pers. comm.). 

5.6.2 Fishing

There are numerous charter operators in the region that specialize in fishing throughout the San Juan 

Islands area. A handful of charters operate out of harbors within the San Juan Islands while others 

operate from harbors in nearby Anacortes and Bellingham. In addition, the waters around the San Juan 

Islands offer endless opportunities to fish from private vessels. While lingcod and other bottomfish are 

the most common targets, fishing for salmon is also popular. Unlike the San Juan Islands, few charter 

fishing operations are based near Protection Island. However, the area is popular with local sport fishers. 

It is estimated that more than 10% of the State’s residents participate in recreational saltwater fishing 

from private vessels while less than 2% do so from charter vessels (RCO, 2007). The peak sport fishing 

season in the San Juan Islands begins in May for most species and continues through September. 

Lingcod, with a very short peak season occurring in May and June, is one of the most popular species. 

Other species with peak seasons from May through September as well as generally good fishing during 

the non-peak months support a year-round draw for the industry. The peak month for participating in 

saltwater fishing from charter vessels is May, while the peak month for fishing from private vessels is 

July (RCO, 2007). 

5.6.3 Diving

There are many popular dive sites throughout the San Juan Islands and associated areas. Attractions in 

the San Juan region often include diving the steep vertical island and rock edges, commonly known as 

walls. There are a few wrecks that also attract divers. WSPRC manages three underwater state parks in 

the region and many of the marine parks that they manage offer shore diving opportunities. Several 

commercial operators offer diving charters throughout the island waters. Purchases related to diving 

needs and services contribute to the local economies, but likely not as strongly as sea kayaking, and 

certainly not as strongly as whale watching. Some of the well-known and/or frequented sites are listed in 

Table 5.2.
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-19 

Table 5.2, Nearby Popular Diving Locations 

Shore diving locations near PINWR Boat diving near PINWR

Port Townsend • North Beach Park

• Fort Worden State Park

• None

Whidbey Island • Fort Casey Underwater 

State Park (Keystone)

Shore diving locations near SJINWR Boat diving near SJINWR

Lopez Island • Odlin County Park

• Spencer Spit State Park

• Agate Beach County 

Park

• Pea Pod Rocks *

• Cone Islands

• Brown Rock

• Brown Rock

• Henry Island

• Spieden Island

• Turn Island *

• Doe Island

• Frost island

• James Island

• Long Island

• Patos Island

• Sucia Island

• Iceberg Island

• Bell Island

• Matia Island *

• Waldron Island

• Jones Island

Orcas Island • Doe Bay

• West Beach 

• Lover’s Cove

San Juan Island • Reuben Tarte Picnic 

Area

• San Juan County Park

• Lime Kiln Point State 

Park

• Deadman Bay 

• Eagle Cove

• South Beach

• Smallpox Bay

Stuart Island • Turn Point

Whidbey Island • Washington 

Park

• Rosario Beach

• Burrows Pass

Sources: Fischnaller 2000. Northwest Diver 2007. Pratt-Johnson 1994, San Juan Islands Directory 2007, Washington State 

Parks and Recreation Commission 2007b

Note: * indicates Service-managed lands where diving activities may be impacting refuge 

wildlife.

5.6.4 Wildlife Observation and Photography

Wildlife Observation and Photography

Washington State offers some of the most fantastic and unique opportunities to view and photograph 

wildlife in the U.S. In particular, the areas around Protection Island and the San Juan Islands offer 

endless opportunities to experience rare sea birds such as tufted puffins, rhinoceros auklets, and black 

oystercatchers. These rich waters are home to large numbers of marine mammals, including seals, 

porpoises, and whales, as well as a myriad of other creatures. It is estimated that nearly 40 percent of 

Washington residents participated in nature and wildlife observation and photography in 2006 (RCO, 

2007), although the actual percentage may be well over that (IAC, 2003). The Washington State 

Recreation and Conservation Office’s 2006 Outdoor Recreation Survey reported such activity occurred 

more than 35 million times that year. Participation in nature-related activities is growing in popularity in 

Washington and is expected to increase significantly in coming years (IAC, 2003).
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-20 Chapter 5 – Human Environment 

San Juan Islands

There are many opportunities for wildlife observation near the refuge. While many of the commercial 

wildlife observation charters focus specifically on whales, most offer seabird viewing when opportunities 

arise. The majority of the charter operators are members of the local whale spotting network and Whale 

Watch Operators Association which includes at least 30 operators. But there are at least another dozen 

operators who are not members of the association. Most companies offer whale watching cruises along 

the west side of San Juan Island, although they will go just about any place where whales are present. In 

addition, destinations for seabird and marine mammal viewing include Spieden, Cactus, Flattop, Goose, 

Long, Yellow, and O’Neill Islands and Whale and Sentinel rocks. Whether commercial or private, 

marine mammal and seabird observation and photography are popular activities throughout the islands.

Whale watching and sightseeing guided tours serve more than 50,000 – and possibly as many as 100,000 

– visitors to the islands each year. Of those completing the 2005 and 2006 San Juan Islands Visitors 

Bureau exit surveys, between 38 and 51 percent marked whale watching as the favorite part of their trip. 

Whale watching is second only to dining and shopping for activities in which visitors completing the 

surveys engaged. Whale watching and sightseeing is likely one of the top economic resources for the 

region.

Protection Island

The Port Townsend Marine Science Center offers opportunities to view seabird colonies on their cruises 

around Protection Island. Observers are also likely to catch a glimpse of seals hauled out to rest along the 

shores of Protection Island. In addition, Protection Island waters are a popular destination for private 

vessels including kayaks, sailboats, and power boats. Although the Island is closed to the public and 

vessels are required to remain a minimum of 200 yards from shore to minimize disturbances, there are 

ample opportunities to view seals and seabirds in the waters around the island and onshore, especially

with the aid of binoculars. 

5.6.5 Environmental Education and Interpretation

Walla Walla University offers summer marine biology courses at its Rosario Beach Marine Laboratory in 

Anacortes; students attending these summer courses routinely examine the marine flora and fauna present 

in the San Juan Islands. For the past 10 years, Professor Jim Nestler has incorporated data produced by 

students studying inter-tidal areas around Swirl Rocks in annual marine invertebrate surveys.

A variety of other natural and cultural education and interpretation programs and facilities are available 

near the refuges (See Table 5.3). They are primarily managed by the WSPRC; the National Park Service, 

and the Port Townsend Marine Science Center. Unfortunately the lack of funding in recent years has 

reduced or eliminated the environmental education opportunities at several State Parks Environmental 

Learning Centers in the region (Graham 2007 pers. comm.). This trend of reduced services at State Parks 

is likely to continue at least into the near future due to budget reductions (Niel 2009 pers. comm.) 
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-21 

Table 5.3, Area Environmental Education & Interpretation Opportunities 

Facility by Location Focus Features

San Juan Island

Lime Kiln Point State Park  Whale watching

 Local history

 Lighthouse tours

 Self-guided, signed interpretive trail

 Interpretive center

 Seasonal guided walks and marine 

mammal programs

American Camp

San Juan Island National 

Historical Park

 Local history  Visitor center

 Environmental education programs

 Signed interpretive walks

 Encampment re-enactments

 Wildlife viewing

English Camp

San Juan Island National 

Historical Park

 Local history  Royal marine barracks contact center

 Environmental education programs

 Signed interpretive walks

 Encampment re-enactments

 Wildlife viewing

Orcas Island

Camp Moran

Moran State Park

 Wetlands

 Old growth forest

 Forest ecology

 Nature programs for youth

 Kayaking

 Backpacking

Moran State Park  Local history

 Beach ecology

 Old growth forest

 Forest ecology

 Jr. Ranger program

 Interpretive story of Robert Moran

 Low tide beach walks

 Self-guided interpretive trail with 

signage

 History talks

 Family nature crafts

 Guided hikes to waterfall and through 

old growth forest

 Campfire program

Blake Island

Blake Island State Park  Native plants

 Trimble Estate history

 Signed nature trail

 Historic interpretive signage

Whidbey Island

Bowman Bay Interpretive 

Center

Deception Pass State Park

 Wetlands and sand 

dunes

 Samish Indian Nation 

story

 Discovery and naming 

of Deception Pass and 

Whidbey Island

 Maiden of Deception Pass story pole

 Historic interpretive signage

 Frequent weekend and evening lectures 

and slide shows

Port Townsend
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-22 Chapter 5 – Human Environment 

Facility by Location Focus Features

Port Townsend Marine 

Science Center

Fort Worden State Park

 Marine ecosystems

 Intertidal ecosystems

 Protection Island wildlife cruises

 Touch tanks

 Marine exhibit

 Natural history exhibit

Fort Worden State Park  Local military history  Coastal Artillery Museum

 Commanding Officer’s Quarters

 Rothschild House

Marrowstone Island

Fort Flagler State Park  Local military history  Military museum

 Historic buildings

Sources: Washington State Parks and Recreation Commission 2008b, National Park Service 2008, Personal Communications: Linda Sheridan 

and John Graham, Washington State Parks and Recreation Commission.

5.6.6 Camping

There are more than 400 public campsites within 15 miles of Turn and Matia Islands (See Tables 5.4 for 

Matia and 5.5 for Turn). Another 400 private campsites are available on San Juan, Orcas, Lopez, and 

Canoe Islands (Doe Bay Resort 2007, Lucas 2004, Mitchell Bay Landing 2007, Mueller and Mueller 

1985, NW Source 2007, San Juan County Parks 2005, San Juan Islands Directory 2007, 

TheSanJuans.com 2007, SanJuansSite.com 2007). Many of these campgrounds are accessible from the 

saltwater shoreline, but a few are located off the water. 

The Washington State Parks and Recreation Commission (WSPRC 2007b) and the Washington 

Department of Natural Resources (WDNR) manage 7,006 acres for parks and recreation within San Juan 

County including Moran State Park, Washington’s largest state park (San Juan County 2005). These 

State-managed properties include 282,886 linear feet of shoreline, 368 camping sites, and 108 day-use 

sites (San Juan County 2005).

San Juan County manages 3 camping facilities with a total 112 campsites (San Juan County 2005). These 

three parks total approximately 152 acres with 11,195 linear feet of shoreline (San Juan County 2005). 

The County also manages several day-use only park facilities.

Table 5.4, Designated Public Camping Facilities Within 15 Miles of Matia Island

Campground

Miles 

to 

Matia

Acres

Saltwater 

Shoreline

(linear feet)

Campsites

Mooring Buoys

Firepits

Water

Toilets

Hiking Trails

Setting

Sucia Island Marine State 

Park 1.5 564 77,700 55 48 ▪ ▪ ▪ ▪ Forest, rock cliffs

Clark Island Marine State 

Park 4 55 11,292 7 9 ▪ ▪

Forest, sandy 

beaches, rock 

outcrops

Patos Island Marine State 

Park 6 207 20,000 7 2 ▪ ▪ ▪

Forest, sandy 

beaches, rock 

outcrops
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-23 

Campground

Miles 

to 

Matia

Acres

Saltwater 

Shoreline

(linear feet)

Campsites

Mooring Buoys

Firepits

Water

Toilets

Hiking Trails

Setting

Moran State Park 5 5,252 - 151 - ▪ ▪ ▪ ▪

Old growth forest, 

lodge pole pine 

forest, freshwater 

lakes and shoreline

Obstruction Pass Park 9 80 450 11 3 ▪ ▪ ▪ Forest, tide pool 

shoreline

Doe Island Marine State 

Park 9 6 2,000 5 - ▪ ▪ ▪ Forest, rock outcrops

Lummi Island DNR 12 ND ND 10 1 ▪ ▪ ▪ Forest

Pelican Beach DNR

(Cypress Is.) 12 * * * * ▪ ▪ ▪ Forest

Cypress Head DNR

(Cypress Is.) 14 * * * * ▪ ▪ ▪ Forest

Strawberry Island DNR 13 * * * * ▪ ▪ Forest

TOTALS 6,164 77,700 246 63

ND = No Data

DNR = WA Department of Natural Resources

*These numbers are included in Table 3.

Sources: Mueller and Mueller 1995, NW Source 2007, San Juan County Parks 2007, San Juan Islands Directory 2007, TheSanJuans.com 2007, 

SanJuansSite.com 2007, Washington State Department of Ecology 2007, Washington State Department of Natural Resources 2007, Washington 

State Parks and Recreation Commission 2007b. 

Table 5.5, Designated Public Camping Facilities Within 15 Miles of Turn Island

Campground

Miles 

to 

Turn 

Island

Acres

Shoreline

(linear feet)

Campsites

Mooring Buoys

Firepits

Water

Toilets

Hiking Trails

Setting

South Beach County Park 

(Shaw Is.) 2 60 4,610 11 - ▪ ▪ ▪ ▪ Woods

Blind Island State Park 2 3 1,280 4 4 ▪ ▪ Rocky, scrub-shrub

Odlin County Park 

(Lopez Is.) 4 80 3,960 30 Y ▪ ▪ ▪ ▪

Old growth forest, 

forest, sandy beach, 

steep cliffs

Griffin Bay State Park 

(San Juan Is.) 4 15 340 4 2 ▪ ▪ ▪ Woods, grassy 

meadow

Jones Island Marine State 

Park 6 188 25,000 21 7 ▪ ▪ ▪ ▪

Forest, sandy 

beaches, rock 

outcrops

Spencer Spit Marine State 

Park 

(Lopez Is.)

8 138 7,800 50 12 ▪ ▪ ▪ Saltwater marsh

San Juan County Park 

(San Juan Is.) 8.5 12 2,700 20 Y ▪ ▪ ▪ Gravel beach, rocky 

bluffs, woods

Posey Island Marine State 

Park 11 1 1,000 2 - ▪ ▪ Woods, rock island

James Island Marine State 

Park 11 113 12,335 13 4 ▪ ▪ ▪ Forest, rock 

outcrops, cliffs

Strawberry Island 11 ND ND 3 - ▪ ▪ Forest
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-24 Chapter 5 – Human Environment 

Campground

Miles 

to 

Turn 

Island

Acres

Shoreline

(linear feet)

Campsites

Mooring Buoys

Firepits

Water

Toilets

Hiking Trails

Setting

Pelican Beach 

(Cypress Is.) 12 ND ND 3 6 ▪ ▪ ▪ Forest

Cypress Head 

(Cypress Is.) 14 ND ND 9 4 ▪ ▪ ▪ Forest

Stuart Island Marine State 

Park 14 153 33,030 22 22 ▪ ▪ ▪ ▪

Forest, meadow, 

sandy beaches, rocky 

shores

TOTALS 763 92,055 192 61+

ND = No Data

Sources: Mueller and Mueller 1995, NW Source 2007, San Juan County Parks 2007, San Juan Islands Directory 2007, TheSanJuans.com 2007, 

SanJuansSite.com 2007, Washington State Department of Ecology 2007, Washington State Department of Natural Resources 2007, Washington 

State Parks and Recreation Commission 2007b. 

5.6.7 Beaches and Beach Activities

There are many public beaches throughout the San Juan Islands and along the shores of the Quimper and 

Miller peninsulas. Among local residents, beachcombing and other beach-related activities are popular.

In a recent survey of residents of San Juan and Island counties, beachcombing was ranked third out of 

fourteen water activities most engaged in by survey participants (RCO 2007). In the same survey, 

swimming or wading at fresh or saltwater beaches was ranked second (RCO 2007). This survey is 

discussed in greater detail in the regional recreation rates and trends section below. Although all of the 

beaches on refuge islands are closed to the public, except Rolfe Cove on Matia Island and a small portion 

of the Turn Island shoreline, there are many open beaches near refuge islands. See the table titled 

Beaches in the Vicinity of Protection Island NWR and San Juan Islands NWR, Appendix D.

5.6.8 Boating

Many areas with boat access throughout the San Juan Islands, Quimper Peninsula, and Whidbey Island 

provide a variety of regional access options. Most of the marinas provide some guest moorage and many 

of the public parks and campgrounds offer mooring buoys and/or anchorages. Limited boat launches are 

scattered throughout the main islands. Powerboat cruising, sailing, and kayaking are all popular means of 

boating throughout the archipelago. 

Motorized boating (including sailboats that typically have auxillary motors)

Motorized boat users visit the refuge from locations throughout the region, including the major 

metropolitan areas around Seattle, Washington, and Vancouver and Victoria, B.C. Popular mainland 

departure locations close to refuge islands include marinas, harbors, and parks in the northeast Olympic 

Peninsula, Anacortes and Bellingham areas. In the San Juan Islands area, motorized boat traffic 

concentrates at towns (e.g., Friday Harbor), harbors (e.g., West Sound), and resorts (e.g., Rosario and 

Lopez Islander). From these locations, motorized boaters explore a variety of campgrounds and beaches 

throughout the San Juan Archipelago.

Human-powered boating (including kayaks and canoes) 

Human-powered boaters also visit major harbors and parks throughout the mainland and San Juan 

Islands, but often prefer launch sites and destinations not frequented by motorized boaters. Smaller state 

and county parks are popular with human-powered boaters, especially sites associated with the Cascadia 

Marine Trail. Short loop trips near cities are especially popular (e.g., Deception Pass and Cypress Island) 
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-25 

“The primary goal of the Cascadia 

Marine Trail is to secure camping 

areas every 5 to 8 miles for the safety 

of non-motorized boaters traveling on 

Puget Sound waters. The length of 

Puget Sound shoreline, according to 

various sources, is between 1,800 

and 2,300 miles. The trail will be 

considered complete at a point in 

time when there are between 225 and 

460 campsites.” Washington Water 

Trails Association.

while paddlers with more time look for more remote places such as Stuart or Sucia Islands. The nature of 

human-powered boating allows for access to many undeveloped areas that are popular for picnicking, 

beachcombing, clamming, and other informal activities. 

Sea kayaking in the San Juan Islands is a favorite local past time and the area is considered one of the top 

ten sea kayaking destinations in the United States (GORP 2008). The Islands are highlighted as a choice 

autumn destination for sea kayaking (Bune 2001 in GeatOutdoors.com 2008). Olinger (2008) describes 

the San Juan Islands as “...a plethora of jewels that touring buffs fervently take to in good and sometimes 

even bad weather.” With islands close together, paddlers can enjoy time both on the water and the 

shoreline throughout a day of paddling (GORP 2008). In addition, the local marine wildlife, unsurpassed 

scenery, and charm of their quiet isolation and small villages make the islands a coveted destination of 

many paddlers (GORP 2008).

Among local residents, kayaking is a popular activity. In a recent survey of residents of San Juan and 

Island counties, kayaking/canoeing/rowing was ranked 4th out of 14 water activities most engaged in by 

survey participants (RCO 2007). In the same survey, the statewide rank for this activity category was 

only slightly lower, at 5th place, indicating that hand-powered boating opportunities are not just a locally 

preferred sport, but rather are valued across the state. This survey is discussed in greater detail in the 

regional recreation rates and trends section below. 

Commercial outfitters

There is no shortage of commercial kayaking outfitters serving the San Juan Islands. More than 25

outfitters, most located within the immediate islands area, offer San Juan Islands paddling trips. Kayak

outfitters and guides favor the west side of San Juan Island, as this is also primary whale watching 

territory. Many offer overnight camping trips to Stuart Island as this is (relatively) easily accessed from 

the west side of San Juan Island. 

There is also a common paddle route from Stuart Island along Spieden Island and through the Cactus 

Islands en route to Jones Island. Jones Island is another common overnight camping stop for multi-day 

paddles. Many of these trips return to San Juan Island at Friday Harbor. Outfitters out of Anacortes tend 

to guide trips through the eastern islands as the outer islands are quite some distance to paddle if a mother 

ship is not utilized. Outfitters are reluctant to report the numbers of visitors served each year, but it is safe 

to say that this activity is very popular. 

Cascadia Marine Trail is one of the premier water trails for human-powered boaters in the United 

States. Designed for kayaks, canoes, and other non-motorized beachable boats, the water trail offers 

unsurpassed views of Northwest scenery and wildlife while providing access to pullouts, campsites, and 

other public amenities along the way (WSPRC 2008c). Since 1993 thousands of state residents and 

visitors have traveled on the water trail that extends the length and width of the Salish Sea from the state 

capitol in Olympia to the Canadian border (WWTA 2008). 

The Cascadia Marine Trail is an inland sea National Recreation Trail and is designated as one of 16 

National Millennium Trails by the White House 

(WWTA 2008). There are over 50 campsites along the 

trail that can be accessed by boating from many public 

and private launch sites or shoreline trailheads 

(WWTA 2008). Within the San Juan Islands, there are 

many campgrounds along the trail, including:

• Blind Island State Park

• Griffin Bay

• James Island State Park
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-26 Chapter 5 – Human Environment 

• Jones Island State Park

• Obstruction Pass

• Odlin County Park

• Point Doughty

• Posey Island State Park

• San Juan County Park

• Shaw County Park

• Spencer Spit State Park

• Stuart Island State Park

5.6.9 Hiking Trails

The National Park Service manages several miles of trails at San Juan Island National Historical Park. 

The WSPRC and WDNR manage approximately 47 miles of trails in San Juan County, including 33 

miles within Moran State Park (San Juan County 2005). San Juan County manages a minimal number of 

walking trails at a few County parks.

5.6.10 Other Recreation

Geocaching is becoming a popular activity throughout the islands. There are several known locations 

throughout the area where caches are located (Geocaching 2007). Other recreation occurring on the main 

islands includes bicycling and visiting historic places.

5.7 Regional Recreation Rates and Trends

The Washington State Recreation and Conservation Office (RCO), formerly the Interagency Committee 

for Outdoor Recreation (IAC), advises the State on matters of outdoor recreation. The RCO conducts 

inventories of outdoor recreation sites and opportunities, conducts studies of recreational participation and 

preferences, and periodically releases documents related to overall state outdoor recreation. The most 

recent release is the 2006 Outdoor Recreation Survey (formerly, the State Comprehensive Outdoor 

Recreation Planning Report – SCORP Report).

5.7.1 Washington Tourism

In 2008, visitors to Washington spent $15.7 billion and travel spending accounted for 3.8% of all jobs

statewide. Tourism is one of the top 5 industries in the state (VS, 2009) and continues to be a critical 

element for the viability of local communities. Local economies where Protection Island NWR and the 

San Juan Islands NWR are located rely heavily on visitors. For example, in San Juan County alone, more 

than 10% of all jobs were directly attributed to the travel industry (WSTC, 2008). Tourism accounted for 

28% of all state and local tax dollars generated countywide in 2006, making it a key segment of the area’s

economy. In addition, local tourism in San Juan County continues to grow faster than almost every other 

county in the state (SJIVB, 2006).

5.7.2 Outdoor Recreation Participation Rates

The most recently released survey report (RCO 2007) identified 15 major categories of outdoor 

recreation, subdivided into 114 activity types or settings. Of these 15 major categories, walking/hiking is 

the number one activity with 74 percent of Washington residents participating in some type or setting of 

walking and/or hiking. Nature activity is the third most popular recreation, with 54 percent of residents 

enjoying some form of this activity. The report indicated observing/photographing nature and wildlife has 
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-27 

a participation rate of 29 percent and that visiting interpretive centers has a participation rate of 15 percent 

among statewide residents.

The RCO also reported regional data for the same activity categories. “The Islands” region is comprised 

of Island and San Juan counties. There were 320 people surveyed in The Islands region and they engaged 

in a total of 94,526 outdoor activity occurrences over the course of the year 2006. The highest average 

participation rates were in sightseeing and nature activities, 35 and 23 percent, respectively. The next 

most popular category, water activities, had a 16 percent average participation rate. The other categories 

all ranged between 12 and 15 percent.

5.7.3 Forecast for Regional Recreation Demand and Key Recreation Needs 

Note: The following information is from the Washington State Recreation and Conservation Committee 

(RCO), formerly known as the Interagency Committee for Outdoor Recreation (IAC).

Overall, outdoor recreation in most categories continues to increase at high growth rates. In a recent 

technical report (IAC 2003), IAC projected future participation in 13 of 14 major outdoor recreation use 

categories over periods of 10 and 20 years. Nine of these activities will experience double digit growth.

These most recent estimates of recreation trends were based on the National Survey on Recreation and the 

Environment Projections for the Pacific Region (NSRE), which includes Washington State. IAC adjusted 

the NRSE projections as necessary based on age group participation, estimates of resource and facility 

availability, user group organization and representation, land use and land designations; and “other 

factors” including the economy and social factors. Table 5.6 shows the percent change expected for 

Washington State by activity as reported by IAC.

The 1995 assessment identified trails and environmental education as the two highest outdoor recreation 

needs in the state. Many outdoor activities generally permitted on Refuges are expected to show increases 

of 20 to 40 percent over the next 20 years. The exception is hunting, in which participation is expected to 

fall at about that same rate. 

Table 5.6, Projected Participation Increases for Selected Outdoor Recreation Activities

Activity

Estimated 

Change, 

10 years (2002-

2012)

Estimated 

Change, 

20 Years 

(2002-2022)

Walking 23% 34%

Hiking 10% 20%

Nature Activities (outdoor photography, wildlife 

observation, gathering and collecting, gardening, 

and visiting interpretive centers)

23% 37%

Fishing -5% -10%

Hunting / Shooting -15% -21%

Sightseeing (includes driving for pleasure) 10% 20%

Camping – developed (RV style) 10% 20%

Canoeing/kayaking 21% 30%

Motor Boating 10% No estimate

Equestrian 5% 8%

Non-pool swimming 19% 29%

Source: IAC 2003. 
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 5-28 Chapter 5 – Human Environment 

In addition, the newly designated San Juan Islands Scenic Byway, which includes routes on both Orcas 

Island and San Juan Island (San Juan Islands Visitors Bureau 2008), may draw more recreation-seeking 

visitors to the vicinity of the San Juan Islands National Wildlife Refuge.

5.8 Socioeconomics 

5.8.1 Socio-economic Baseline Setting

The study area for estimating the economic effects of the recreational use of the refuges is defined as 

Island, Jefferson, San Juan, Skagit, and Whatcom counties. The Protection Island NWR is wholly 

contained within Jefferson County, which was established in 1852. Port Townsend is the county seat and 

the only incorporated city within the County. 

The San Juan Islands NWR is predominantly located in San Juan County with some islands located in 

neighboring Island, Skagit, and Whatcom counties. San Juan County was established in 1873 and 

contains 176 named islands and reefs (with up to 743 at low tides). The largest islands in the County are 

San Juan, Orcas, Lopez, and Shaw, all of which are served by the Washington State Ferry System. The 

nearest major population centers are Victoria and Vancouver, B.C., and Seattle, WA. The County seat is 

Friday Harbor, located on San Juan Island.

Smith and Minor islands, the two most southern of the San Juan Islands NWR islands, are located in 

Island County. Island County was established in 1852 and consists of two large islands (Whidbey and 

Camano) and several smaller islands. The county seat is located on Whidbey Island at Coupeville. The 

largest city is Oak Harbor, also on Whidbey Island.

Eliza Rock, Viti Rocks, and Three Williamson Rocks, the eastern-most features of the San Juan Islands 

NWR, are located in Skagit County. Skagit County was established in 1883. Mount Vernon is the largest 

city and the county seat. Other incorporated cities within Skagit County include Anacortes, Burlington, 

Concrete, Hamilton, La Conner, Lyman, and Sedro Woolley.

The Whatcom County boundary lies at the eastern edge of the San Juan Islands NWR. The county was 

established in 1854. The largest city, Bellingham, is the county seat. Other major communities within 

the county include Lynden, Everson, Ferndale, Sumas, Nooksack, and Blaine.

5.8.2 Population Data and Trends

Growth Rate

Between 1980 and 2000, all five area counties, Island, Jefferson, San Juan, Skagit, and Whatcom, grew at 

a rate well above the Washington State average and substantially above the rate for the United States. 

The one exception is from 1990 to 2000, when Island County grew at a rate slightly less that that for the 

state. The other four counties experienced a higher rate of growth during the 1990 to 2000 period than in 

the 10 years prior (U.S. Census Bureau).

Density

Based on the 2000 census data, of the five-county area containing the refuges, Island County has the 

highest density at 344 people per square mile, nearly four times greater than the state density of 88.6 

people per square mile. Jefferson County density is only 14.3 people per square mile, about 1/6 of the 

state density. Less extreme are San Juan, Skagit, and Whatcom counties with 80.4, 59.4, and 78.7 people 

per square mile, respectively (U.S. Census Bureau).
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-29 

Age Distribution

In general, the five counties follow the state trend with the majority of the population falling between the 

ages of 18 and 65 years old. The next highest percentage age group in the state is persons under 18 years 

of age (23.6 percent). Island, Skagit, and Whatcom counties have similar percentages (22.5, 23.5, and 

21.5, respectively), while Jefferson and San Juan counties differ in the trend. Jefferson and Skagit 

counties have a higher percentage of retiree-age population (21.5 and 21.1, respectively). In all cases, 

county and state, the lowest age category percentage is those under 5 years old (U.S. Census Bureau).

5.8.3 Low Income and Minority Populations

Each of the five counties has a smaller percentage of minority population (86.5 – 95.0 percent) than the 

overall United States percentage (75.1 percent) and the Washington State percentage (81.8 percent). The 

percent of people below the poverty level in the five counties varies from below to above (7.0 percent -

14.2 percent) the national and state values (12.4percent and 10.6percent, respectively) (U.S. Census 

Bureau).

5.8.4 Economic Base of the Surrounding Area

Employment

Among all five counties, the largest employment sectors in both 2000 and 2005 were in construction, 

manufacturing, retail trade, health care and social assistance, and accommodations and food services. 

However, business sectors experiencing the most growth between 2000 and 2005 varied by county. In 

Island County, the highest positive percentage change (growth) was seen in the professional, scientific, 

and technical services sector (29.59 percent) and the highest negative percentage change (decline) was in 

the unclassified establishments sector (-91.89 percent), followed by finance and insurance (-

29.53percent). The most growth in Jefferson County was seen in the real estate and rental and leasing 

sector (55.56 percent) and the largest decline in transportation and warehousing (-28.95 percent). In San 

Juan County, the highest growth was seen in the finance and insurance sector (99.13 percent) and the 

largest decline in the transportation and warehousing sector (-21.11 percent). Between 2000 and 2005, 

Skagit County experienced the most employment growth in the wholesale trade sector (89.03 percent) and 

the most employment decline in the arts, entertainment, and recreation sector (-33.07 percent). Whatcom 

County saw its highest employment growth in the health care and social assistance sector (40.14 percent) 

and its sharpest decline in the management of companies and enterprises sector (-74.82 percent).

Overall, employment growth in Island, Skagit, San Juan, and Whatcom counties outpaced state growth 

from 2000 to 2005. Washington State experienced an overall 2.15 percent growth in employment 

between 2000 and 2005. Island, Skagit, San Juan, and Whatcom counties experienced 5.35, 13.36, 7.03, 

and 14.14 percent growth, respectively, during the same time period. Jefferson County experienced a 

0.64 percent growth in employment from 2000 to 2005, nearly one-fourth of the state growth during that 

same time frame (U.S. Census Bureau).

Personal Income and Employment Earnings

In general, per capita personal incomes (PCPI) for Island, Jefferson, Skagit, and Whatcom county 

residents from 1979 to 1999 mirror the Washington State trend. However, San Juan County had a much 

higher growth rate. From 1979 to 1989, San Juan County PCPI increased more than 45 percent compared 

to the next highest rate of 17 percent and 13 percent for Island and Whatcom counties respectively. 

However, from 1989 to 1999, PCPI increases in the four other counties were similar to San Juan County. 

When PCPI growth is combined for both decades, San Juan County experienced a 112 percent increase 

while the four other counties sustained more moderate increases between 64 and 80 percent averaging 

71.4 percent, just above the Washington State average of 69.82 percent and below the U.S. average of 

76.6 percent for the same 20 year period (U.S. Census Bureau). 
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 5-30 Chapter 5 – Human Environment 

5.8.5 Recreation and Economic Uses of Refuges

The economic significance of refuge visits nationally has been estimated to be nearly $1.4 billion (2004 

US dollars [2004 USD]) (Caudill and Henderson 2005). Caudill and Henderson (2005) report 

approximately $154,000 (2004 USD) from USFWS Region 1 (including Washington, Oregon, California, 

Idaho, and Nevada at the time of publication) contributed to the national economic significance figure. 

More localized studies and modeling of the economic impacts to local communities from the San Juan 

Islands and the Protection Island NWRs has not been undertaken. Some generalizations about recreation 

impact on the local socioeconomics can be drawn based on other readily available information.

Matia and Turn Islands are the only refuge islands which allow camping and day use. Visitation records 

from 1986 through 2004 indicate that each of these two islands averages between 8,000 and 11,000 day 

and overnight visitors each year. Over time, the two islands have consistently been used by more visitors 

for day use activities than for overnight camping.

In addition to Turn and Matia, all of the islands comprising the San Juan Islands and Protection Island 

NWRs provide vessel-based wildlife viewing opportunities for visitors to the area. Some of the most 

popular uses of the surrounding waters include whale and wildlife watching tours. Other regionally 

important recreation occurring in the waters surrounding both refuges includes recreational boating,

including motorized and personal watercraft, deep-sea sport fishing, and underwater diving. Other waterdependent recreation known to occur on islands within the San Juan Archipelago, but not necessarily on 

those that are part of the refuges, include beach-related activities (beachcombing, picnicking, hiking, etc), 

waterfowl hunting, interpretation and environmental education activities, and some geocaching. 

The San Juan Islands Visitors Bureau conducts occasional surveys of people visiting the islands. Tourism 

is a major economic base for the islands. While Washingtonians make up more than 20 percent of the 

visitors to the islands, nearly half the visitors surveyed are from other parts of the Unites States. A small 

percentage of those surveyed arrived by personal watercraft or by airplane but the vast majority of visitors 

to the islands rely on the Washington State Ferry system. Approximately 75 percent of the visitors 

surveyed were there for leisure. 

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Wessen & Associates, Seattle, Washington. Prepared for the National Park Service. 2006. An 

Archaeological Survey and Evaluation of the Gilder Project Area, Lopez Island, Washington. 

Wessen & Associates, Seattle, Washington. Prepared for Ginny Gilder, Point Harmony, Seattle,

Washington.

Wings and Waves. 2008. Available URL: http://www.wingsandwaves.net/index.htm. Accessed on May 

2, 2008.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

 5-36 Chapter 5 – Human Environment 

Williamson, R.J. 1987. National Register of Historic Places Inventory Nomination Form, 45-IS 105H 

Smith Island Light Station. Form on file at the Department of Archaeology and Historic 

Preservation, Olympia, Washington.

2007 Station Search- Smith Island. Electronic document,

http://www.ncdc.noaa.gov/oa/climate/stationlocator.html, accessed April 21, 2008.

1974 Economic Life of the Coast Salish of Haro and Rosario Straits. Ph.D. dissertation,

Garland Publishing Company, New York.

1990a Central Cost Salish. In, Handbook of North American Indians: Volume VII:

Northwest Coast, edited by Wayne P. Suttles, pp. 453-475. Smithsonian Institution,

Washington, D.C.

1990b Introduction. In, Handbook of North American Indians: Volume VII: Northwest

Coast, edited by Wayne P. Suttles, pp. 1-15. Smithsonian Institution, Washington,D.C.

1998 Prehistoric and Early Historic Fisheries in the San Juan Archipelago. Prepared for the National 

Park Service.

Personal Communications 

Davison, Mike. District Wildlife Biologist, Region 4, Washington Department of Fish and Wildlife, 

2008. Personal communication to Staci MacCorkle, SWCA consulting firm, Portland, OR. 

Graham, John. Park Ranger, Camp Ramblewood (Sequim Bay State Park). Personal communication to 

Staci MacCorkle, SWCA consulting firm, Portland, OR. 

Gustafson, Joanne. District Manager, Northwest Region, Washington Department of Natural Resources. 

Personal communication to Staci MacCorkle, SWCA consulting firm, Portland, OR. 

Guthrie, Joantha. Island County, 2008. Personal communication to Staci MacCorkle, SWCA consulting

firm, Portland, OR.

Hopkins, Deborah. Executive Director, San Juan County Visitors Bureau. Personal communication to 

Staci MacCorkle, SWCA consulting firm, Portland, OR. 

Leo L. Laythe. U.S. Department of the Interior, Fish and Wildlife Service, Bureau of Sport Fisheries and 

Wildlife, 1959. Personal communication to John R. Vanderzicht, Director, Washington State 

Parks and Recreation Commission, June 19, 1959.

Meyer, William H. Acting Regional Director, Division of Wildlife Refuges, U.S. Fish and Wildlife 

Service. 1976. Personal communication to Charles H. Odegaard, Director Washington State 

Parks and Recreation Commission, May 5, 1976.

Milner, Ruth. WDFW District 13 Biologist, 2008. Personal communication to Staci MacCorkle, SWCA 

consulting firm, Portland, OR.

Nysewander, Dave. WDFW Biologist, 2008. Personal communication to Staci MacCorkle, SWCA 

consulting firm, Portland, OR.
Protection Island and San Juan Islands National Wildlife Refuges CCP/WSP/EA

Chapter 5 – Human Environment 5-37 

Sheridan, Linda. Interpretive Specialist, Camp Moran (Moran State Park). Personal communication to 

Staci MacCorkle, SWCA consulting firm, Portland, OR. 

Schirato, Greg. WDFW District Biologist, 2008. Personal communication to Staci MacCorkle, SWCA 

consulting firm, Portland, OR.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-1

Chapter 6. Environmental Consequences

6.1 Overview of Effects Analysis

The effects analysis was developed by identifying resources associated with the physical, biological, and 

human environment identified in Chapters 3 through 5 of the Draft CCP/WSP/EA that may be impacted 

by the various alternative strategies presented in Chapter 2. The potential effects to those resources as a 

result of implementing the strategies described under each alternative were then assessed. Alternatives 

are compared within each topic area. In general, Alternatives B and C are compared to Alternative A 

(Current Management), which presents a baseline. However, there are cases in which continuing the 

current management strategies (Alternative A) may also result in impacts.

The information used in this Draft CCP/EA was obtained from relevant scientific literature, existing 

databases and inventories, consultations with other professionals, professional knowledge of resources 

based on field visits, and experience. Subheadings have been included to guide the reader in 

understanding which types of management strategies are likely to affect each resource as not all 

management strategies affect each resource. Additional details on effects are contained within the Draft 

CCP/EA appendices as indicated throughout this chapter.

Cumulative impacts, including impacts to refuge resources from reasonably foreseeable events and 

impacts resulting from interaction of refuge actions with actions taking place outside the refuge, are 

addressed in the final section of this chapter. That discussion includes a brief discussion on potential 

impacts of climate change to refuge resources. 

6.1.1 Terminology

Effects were assessed for scope, scale, and intensity of impacts to resources. Effects may be identified 

further as beneficial or negative as well as long-term or short-term. 

Beneficial and negative effects can be defined on a scale from negligible to major.

• Negligible: Resources would not be affected, or the effects would be at or near the lowest level of 

detection. Resource conditions would not change or would be so slight there would not be any 

measurable or perceptible consequence to a population, wildlife or plant community, recreation 

opportunity, visitor experience, or cultural resource.

• Minor: Effects would be detectable but localized, small, and of little consequence to a population, 

wildlife or plant community, recreation opportunity, visitor experience, or cultural resource. 

Major Intermediate Minor Negligible Minor Intermediate Major

Negative Beneficial
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6-2 Chapter 6. Environmental Consequences 

Mitigation, if needed to offset negative effects, would be easily implemented and likely to be 

successful.

• Intermediate: Effects would be readily detectable and localized with consequences to a population, 

wildlife or plant community, recreation opportunity, visitor experience, or cultural resource. 

Mitigation measures would be needed to offset negative effects and would be extensive, moderately 

complicated to implement, and probably successful.

• Major: Effects would be obvious and would result in substantial consequences to a local area or 

regional population, wildlife or plant community, recreation opportunity, visitor experience, or 

cultural resource. Extensive mitigating measures may be needed to offset negative effects and would 

be large-scale, very complicated to implement, and may not have any guarantee of success. In some 

instances, major effects would include the irretrievable loss of the resource.

Time scales are defined as either short-term or long-term.

• Short-term or Temporary: An effect that generally would last less than a year or season.

• Long-term: A change in a resource or its condition that would last longer than a single year or 

season.

6.1.2 Integrated Pest Management

Potential effects to the biological and physical environment associated with the proposed site-, time-, and 

target-specific use of pesticides (Pesticide Use Proposals [PUPs]) on the refuge would be evaluated using 

scientific information and analyses documented in “Chemical Profiles” (see Appendix E). These profiles 

provide quantitative assessment/screening tools and threshold values to evaluate potential effects to 

species groups (birds, mammals, and fish) and environmental quality (water, soil, and air). PUPs 

(including appropriate Best Management Practices) would be approved where the Chemical Profiles 

provide scientific evidence that potential impacts to refuge biological resources and its physical 

environment are likely to be only minor, temporary, or localized in nature. Along with the selective use 

of pesticides, PUPs would also describe other appropriate IPM strategies (biological, physical, 

mechanical, and cultural methods) to eradicate, control, or contain pest species in order to achieve 

resource management objectives. The term pest species refers to both plant and animal pests (non-native 

rat, rabbit, red fox, domestic dogs and cats). 

The effects of these non-pesticide IPM strategies to address pest species on refuge lands would be similar 

to those effects described elsewhere within this chapter, where they are discussed specifically as habitat 

management techniques to achieve resource management objectives on the refuge. 

Based on scientific information and analyses documented in “Chemical Profiles”, pesticides allowed for 

use on refuge lands would be of relatively low risk to non-target organisms as a result of low toxicity or 

short persistence in the environment. Thus, potential impacts to refuge resources and neighboring natural 

resources from pesticide applications would be expected to be minor, temporary, or localized in nature.

6.2 Summary of Effects

A summary of the effects analysis is presented in Table 6.1 using the terms defined in section 6.1.1 above, 

to describe the magnitude of change from the current condition. Alternative A represents current 

management and therefore effects are often least for this alternative, even though there are many benefits 

to wildlife and habitats. Alternative A also serves as a baseline to compare the other two alternatives. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-3

Table 6.1 Summary of Effects by Alternative.

Alternative A Alternative B Alternative C

Effects to the Physical Environment 

Soils/Substrates Minor negative 

impacts from 

continuing erosion 

associated with deer 

browsing, deer trails, 

and human social 

trails. 

Minor to intermediate 

long-term beneficial 

effects from reduced soil 

erosion due to restoration 

efforts and deer removal

from Protection Island. 

Some minor, short-term, 

negative effects during 

restoration activities.

Minor to intermediate 

long-term benefits but 

slightly less compared to 

Alternative B due to 

fewer acres restored.

Hydrology Negligible effects. Potential for minor to intermediate beneficial effects 

possible with restored wetland hydrology.

Air Quality Minor, beneficial 

effects from wildfire 

suppression. 

Minor beneficial effects from wildfire suppression and 

better enforcement of no open recreational fires. 

Minor short-term and localized, negative effects from 

using prescribed fire for habitat restoration.

Water Quality Minor beneficial 

effects from oil spill 

prevention, marine 

debris clean-up, and 

removal of creosote 

pilings.

Minor to intermediate beneficial effects due to 

restoration efforts that would reduce erosion as well as

enhanced oil and fuel spill prevention, marine debris 

clean-up, removal of creosote pilings, and other 

actions.

Contaminant 

Levels

Minor beneficial 

effects from oil spill 

prevention, marine 

debris clean-up, and 

removal of creosote 

pilings.

Minor beneficial effects but slightly more than 

Alternative A due to actions that will reduce the risk of 

fuel spills from refuge and recreational boats.

Effects to Habitats and Associated Species

Shorelines Negligible to minor 

beneficial effects from 

shoreline nourishment, 

wildfire suppression, 

and prohibition of 

open fires and 

driftwood collection. 

Intermediate, long-term, 

beneficial effects from 

habitat restoration, 

shoreline nourishment, 

wildfire suppression, and 

better enforcement of 

unauthorized activities. 

Minor beneficial effects 

due to fewer acres 

restored compared to 

Alternative B.

Sandy Bluffs Intermediate negative 

effects due to deer 

presence, including 

erosion of bluff 

habitats.

Intermediate beneficial effects from removal of deer

from Protection Island, removal of structures, 

modified transportation routes, habitat restoration and 

better enforcement of unauthorized activities. 

Savanna, 

Grasslands, and 

Balds

Minor negative and 

beneficial impacts 

from deer.

Intermediate beneficial 

effects from habitat 

restoration, rerouting the 

Turn Island trail, and 

removal of deer on 

Protection Island.

Similar to Alternative B 

however there would be 

minor beneficial effects 

due to fewer acres 

restored.
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6-4 Chapter 6. Environmental Consequences 

Alternative A Alternative B Alternative C

Forests and 

Woodlands

Intermediate negative 

impacts from deer 

browsing woody 

vegetation. Minor to 

intermediate beneficial 

effects from wildfire 

suppression, 

prohibition of open 

fires, and prohibition 

on collecting downed 

wood.

Intermediate beneficial 

effects from removal of 

deer browsing impacts 

and habitat restoration of 

the former forest cover on 

Protection Island and 

prevention of wildfire for 

all forests on the Refuges. 

Slightly more beneficial 

effects compared to 

Alternative B due to the 

removal and revegetation 

of some campsites on 

Matia Island.

Wetlands Negligible effects. Minor to intermediate beneficial effects likely if

restoration of wetland hydrology is necessary and 

feasible for any of the 3 small wetlands on the refuges. 

Effects to Wildlife Resources

Seabirds Intermediate negative 

effects to glaucouswinged gulls from 

predation and the 

continued spread of 

invasive plant species,

and to rhinoceros 

auklets and their 

nesting habitat from 

deer. Intermediate 

beneficial impacts 

from prohibition on 

collecting driftwood 

and marine debris 

clean-up.

Intermediate beneficial 

effects from restoration;

deer removal on 

Protection Island; 

prohibition on driftwood 

collection; marine debris 

clean-up; non-native 

mammal predator 

surveys; and limiting 

shoreline access. Some 

temporary negative 

effects during removal of 

deer.

Slightly less beneficial 

effects compared to 

Alternative B due to 

fewer acres restored.

Bald Eagles Minor to intermediate 

beneficial effects from 

wildfire suppression 

tactics.

Intermediate beneficial 

effects from wildfire 

suppression tactics, forest 

restoration, and reduced 

human-caused 

disturbance. 

Slightly less beneficial 

effects compared to 

Alternative B due to less 

staff time dedicated to 

preventing disturbance.

Black 

Oystercatchers 

Intermediate beneficial 

effects from continued 

prohibition on 

collecting driftwood.

Intermediate beneficial effects from continued 

prohibition on collecting driftwood and elimination of 

closed social trails on Matia and Turn Islands. 

Negative effects possible from improved predator 

habitat and respective breeding success.
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Chapter 6. Environmental Consequences 6-5

Alternative A Alternative B Alternative C

Marine 

Mammals 

Minor beneficial 

impacts from 

strategies that benefit 

water quality.

Intermediate beneficial 

impacts from increased 

marine debris cleanup 

activities and increased 

education and 

enforcement of shoreline 

access limitations. 

Intermediate but slightly 

less beneficial effects 

compared to Alternative 

B due to less staff time 

dedicated to preventing 

disturbance.

Deer Negligible short-term 

effects. Negative 

long-term effects from 

high density of deer on 

Protection Island 

leading to poor quality 

of health due to lack of 

food and/or water and 

disease.

Negative effects to deer on Protection Island from 

removal. Negligible effects on the surrounding 

regional deer population from the removal of deer on 

Protection Island. 

Effects to Wilderness, Cultural, and Paleontological Resources 

Wilderness 

Resources 

Minor negative effect 

from unaddressed 

marine debris 

accumulations. 

Negative and 

beneficial effects from 

quantity of very large 

format regulatory 

signs. 

Minor, mostly beneficial 

effects from decreasing 

campsites, eliminating 

illegal trails, reducing 

access, and strategies that 

restore and protect 

habitats.

Negative and beneficial 

effects from very large

and large format 

regulatory signs. 

Similar to Alternative B

except fewer regulatory 

signs would result in 

fewer benefits in terms of 

reducing human-caused 

wildlife disturbance and 

fewer negative impacts 

related to the visual

distraction of regulatory 

signs. 

Cultural 

Resources 

Minor to intermediate 

negative effects of 

erosion, grounddisturbing activities,

and lack of systematic 

surveys. 

Intermediate beneficial effects as potential negative 

disturbances to cultural resources are minimized 

through surveys, research and monitoring, evaluation 

of known sites, and increased awareness. 

Paleontological 

Resources 

Minor to intermediate 

negative effects of 

erosion, grounddisturbing activities,

and lack of systematic 

surveys. 

Intermediate beneficial effects as potential 

disturbances to paleontological resources are 

minimized through surveys, research and monitoring, 

increased awareness, and enforcement. 

Social and Economic Effects

Research and 

Monitoring 

Program

Negligible effects. Intermediate beneficial effects by providing more upto-date, scientifically sound data from monitoring and 

assessments to guide refuge management. Additional 

intermediate beneficial effect from updating facilities, 

increased collaboration emphasizing partnerships, and 

additional outreach.

Overall Negligible effects Overall refuge visitation Beneficial impacts would 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

6-6 Chapter 6. Environmental Consequences 

Alternative A Alternative B Alternative C

Visitation from refuge 

management actions. 

Overall visitation 

however is likely to 

increase due to the 

increasing popularity 

of the area. 

numbers likely to increase 

due to the popularity of 

the area. Intermediate 

beneficial effects to the 

visitor experience from 

establishing camping 

reservation system, 

increasing interpretation 

and visitor contact.

Minor negative effect due 

to reduced Turn Island 

access and number of 

campsites.

be the same as in

Alternative B. There 

would be a minor to 

intermediate negative 

impact due to reduced 

Turn Island access and 

eliminating camping on 

Turn Island as well as 

reducing number of 

campsites on Matia 

Island. 

Opportunities 

for Wildlife 

Observation and 

Photography 

Negligible effects Mostly minor beneficial effects from restoring and 

protecting habitats; decreasing human disturbance, 

enforcing pet regulations, and increased outreach and 

education. 

Opportunities 

for 

Environmental 

Education

Negligible effects Intermediate, beneficial 

effects from strategies to 

foster public outreach and 

education. Also benefits 

from increased student 

opportunities.

Slightly less beneficial 

effects compared to 

Alternative B due to 

fewer staff to provide 

Environmental Ed. 

Programs.

Opportunities 

for 

Interpretation 

Experience

Negligible effects. 

Very little 

interpretation currently 

is provided. 

Minor to intermediate, 

beneficial effects from 

increasing interpretive 

signage; developing the 

interpretive component on 

the Turn Island trail; 

increasing staffing 

commitments; and 

increasing public outreach 

and education.

Slightly less beneficial 

effects compared to 

Alternative B due to 

fewer interpretive signs.

Opportunities 

for Hunting 

Experience

Negligible effects. Negligible to minor benefits from habitat enhancement 

that benefits sea ducks. 

Opportunities 

for Fishing 

Experience 

Negligible effects. Minor beneficial effects from enhanced actions to 

remove marine debris and contaminants from 

shorelines. Negligible to minor negative effects from 

increased education about voluntary boat-free zones 

around refuge islands. 

Opportunities 

for Camping 

Experience

Negligible effects. Intermediate beneficial 

impacts from camping 

management strategies 

that include new 

reservation system. 

Intermediate negative and 

minor beneficial impacts 

from limiting camping to 

Slightly less beneficial 

impacts compared to 

Alternative B due to 

eliminating camping on 

Turn Island. 
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Chapter 6. Environmental Consequences 6-7

Alternative A Alternative B Alternative C

visitors arriving by human 

powered boats and 

reducing the number of 

campsites on Turn Island. 

Human Health Negligible effects. Negligible effects. Negligible effects.

Economy Negligible effects. Minor beneficial impacts 

expected from increased 

refuge expenditures. 

Negligible negative 

effects from reduced 

campsites on Turn Island.

Slightly less beneficial 

impacts compared to 

Alternative B due to 

fewer refuge expenditures 

and intermediate negative 

impact due to elimination 

of camping on Turn 

Island and reducing 

campsites on Matia 

Island. 

Environmental 

Justice 

Negligible effects. Negligible effects. Negligible effects.

6.3 Effects to the Physical Environment

Topics addressed under the physical environment section include the direct and indirect effects to 

soils/substrates, hydrology, air quality, water quality, and contaminant levels. None of the alternative 

actions are expected to have major effects to the physical environment of either Refuge. 

6.3.1 Soils/Substrates

Effects from Habitat Management Strategies: Under all alternatives the continued nourishment of the 

Protection Island shoreline west of the marina would reduce the potential for erosion and improve 

shoreline conditions impacted by the marina’s breakwater. This is expected to result in minor beneficial 

effects to the site-specific substrate for as long as the gravel source stockpiles remain. Cleaner soils and 

substrates are another minor beneficial effect anticipated from continued participation in oil spill 

prevention and preparedness planning. 

Under Alternative A, allowing deer to remain on Protection Island would contribute to soil erosion from 

compaction, especially along deer trails and because of browsing, which reduces vegetation that can 

provide soil stability. Allowing unauthorized social trails to continue on Turn and Matia Islands within 

the San Juan Islands Refuge contributes to compaction and erosion. These are estimated to be minor 

negative effects to soils/substrates. 

Under Alternatives B and C, native vegetation restoration actions on Protection Island are expected to 

decrease soil erosion in the long-term but may increase it slightly in the short-term until native plants are 

established. Soil quality would improve as areas are rehabilitated following structure removal and 

transportation route/mode adjustments. Removal of deer from Protection Island and removal of illegal 

social trails from Matia and Turn islands would decrease soil compaction and increase the quality and 

integrity of the soil. Overall, minor to intermediate long-term benefits are expected. 
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6-8 Chapter 6. Environmental Consequences 

Under Alternative C, the beneficial effects would be similar to but slightly less than Alternative B 

because under Alternative C fewer acres would be restored to native vegetation. 

Effects from Public Use Management Strategies: Allowing unauthorized social trails to continue on 

Turn and Matia Islands within the San Juan Islands Refuge contributes to compaction and erosion. 

Effects to soils/substrates from implementing either Alternative B or C are expected to be predominantly 

beneficial because human disturbance and improper use/entry is limited under these alternatives. As 

access points are enforced and limited on Matia and Turn Islands, and the number of campsites is 

reduced, substrates and soils would be subjected to fewer and less frequent disturbances as a result of boat 

beaching/launching and accompanying foot traffic. Revegetation of removed campsites would also 

protect some soils on these two islands.

Effects from Research and Monitoring Strategies: Research strategies in both Alternatives B and C 

have the potential to indirectly impact soils. Initial plant inventories and studies that address vegetation 

restoration successes and erosion rates would inform future management decisions related to 

soils/substrates. The knowledge gained from these efforts would be applied for beneficial outcomes. In 

addition, standardized surveys for non-native herbivores such as European rabbits have the potential for 

intermediate, long-term, positive effects on soil stability and vegetative community health should 

management act quickly if rabbits are encountered. European rabbits reproduce rapidly and can denude 

small islands of vegetation in very little time. They are ubiquitous on San Juan and Lopez Islands and 

prairie habitats in San Juan Island National Historic Park have been degraded or eliminated as a result.

6.3.2 Hydrology

Effects from Habitat Management Strategies: Due to the lack of related strategies under Alternative 

A, it would have negligible impacts on hydrology. Alternatives B and C include potential restoration of 

wetland hydrology on Protection, Smith, and Matia Islands. If these alternatives are implemented, minor 

to intermediate beneficial effects are expected to result as flow patterns and sources are brought back to 

more natural hydrologic processes.

Effects from Research and Monitoring Strategies: Research strategies in both Alternatives B and C 

have the potential to indirectly benefit hydrology. Studies that address wetland hydrology sources would 

inform future management decisions related to wetland hydrology restoration.

6.3.3 Air Quality

Effects from Habitat Management Strategies: All alternatives include strategies to reduce the risk of 

fire. Effects from these habitat management strategies are expected to have negligible beneficial effects 

to air quality by reducing smoke particulates entering the local airshed. Alternatives B and C also include 

prescribed fire strategies for managing native grasses and forbs, invasive and non-native plants, and 

canopy cover. During any prescribed burning, minor short-term negative air quality effects would be 

experienced. It is likely that these effects would be localized and carried a relatively minimal distance on 

air currents. This analysis assumes small controlled burns of minor fire intensity.

Effects from Public Use Management Strategies: As described above, strategies to eliminate open 

fires on Matia and Turn Islands would reduce the wood-fire smoke particulates from contributing to local 

air quality conditions. However, liquid fuel camp stoves would be allowed; they would contribute to a 

negligible decrease in local air quality.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-9

6.3.4 Water Quality

Effects from Habitat Management Strategies: Minor beneficial effects associated with all alternatives 

include continued involvement in local oil spill prevention and preparedness planning and marine debris 

clean-up activities. Involvement in these local community efforts better positions the refuge to contribute 

to good water quality practices and to benefit from other participants’ efforts. In addition, all of the 

alternatives include facilitating removal and replacement of the creosote pilings at the Protection Island 

marina. As creosote pilings are replaced with non-polluting pilings, water quality that has been 

diminished by the leeching creosote would improve. These effects would be very localized and 

diminished in the context of the Salish Sea.

Alternatives B and C indirectly contribute to a minor to intermediate beneficial impact to water quality 

impacts because restoration efforts would reduce the long-term potential for soil erosion that could 

contribute to increased water turbidity and reduced water quality. 

Effects from Public Use and Facilities Management Strategies: Under Alternatives B and C there 

may be slightly fewer motor boats landing directly on the beaches of Turn and Matia Islands as a result of 

limiting overnight camping to visitors arriving by human-powered boats only. Fewer motor boat landings 

decrease the chances of a fuel spill. Upgrading refuge facilities to include more solar power will reduce 

the need to transport liquid fuel to Protection Island and also decrease the chance of a spill from this 

source. 

6.3.5 Contaminant Levels

Effects from Habitat Management Strategies: All alternatives include continued participation in local 

oil spill prevention and preparedness planning. Oil spill avoidance and immediate action when 

appropriate would limit the risk of oil entering refuge habitats. In addition, marine debris monitoring and 

clean-up would continue on Protection Island, and creosote pilings at the island marina would be replaced 

with non-polluting pilings. Habitat integrity would be maintained or improved as marine debris and 

pilings that contribute to contamination are removed. All of these measures would have minor beneficial 

effects due to reducing contaminant levels. 

Alternatives B and C add the San Juan Islands Refuge to the marine debris monitoring and clean-up 

rotation would reduce contaminants especially along island shorelines. Expanded use of solar energy on 

Protection Island would reduce the need to transport gas, oil, and propane and thereby reduce the potential 

for fuel spills during transportation. Removal of structures on Smith Island will decrease levels of 

contaminants such as asbestos and lead paint on that island.

Short-term use of herbicides to control invasive species may have a minor negative impact by increasing 

contaminant levels. There would be minor to intermediate benefits to reducing contaminant levels in 

Alternative B and C. 

Effects from Public Use Management Strategies: Increased staffing to provide visitor contacts and 

education is expected to reduce the risk of contaminants being transported to or left upon open and closed 

refuge islands. These contaminants include fuel spills, garbage/litter, and other contaminants for which 

humans are a vector of dispersal. Other strategies, including those that educate users about why a closer 

look hurts wildlife, would have indirect results of reducing the risk of contaminants entering refuge 

habitats as vessels keep their distance from refuge islands and the wildlife that use them. These actions 

would have a minor beneficial effect on contaminant levels. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

6-10 Chapter 6. Environmental Consequences 

Effects from Research and Monitoring Strategies: As described in the Compatibility Determination 

appendices, all research and monitoring activities would need to comply with measures to limit the risk of 

contaminants entering the refuge environments and therefore they would have a negligible effect.

6.4 Effects to Habitats 

Topics addressed in this section include the direct and indirect effects to shorelines (including spits, sandy 

and gravel shorelines, and rocky shorelines); sandy bluffs; savanna, grasslands, and balds; forests and 

woodlands; and wetlands. These five habitat types and their associated species make up the priority 

resources of concern for the San Juan Islands and Protection Island Refuges. None of the alternative 

actions are expected to have major effects to these habitats. In general, the strategies contained in 

Alternatives B and C would provide the most benefits to refuge habitats. 

6.4.1 Shoreline

Effects from Habitat Management Strategies: 

All alternatives include continued nourishment of Protection Island’s shoreline west of the marina with 

gravels from marina dredge spoils. This would benefit the integrity of the shoreline. Once the stockpiles 

are completely used, natural processes are likely to result in erosion of the nourished area.

All alternatives include implementing total wildfire suppression tactics for all wildfires on Protection 

Island and continued prohibition of open fires by all island users. Likewise, open fires, including 

charcoal and wood, would be prohibited on Matia and Turn Islands. As a result of these combined 

strategies, shoreline habitats and their associated species would benefit from protection against habitat 

destruction by fire.

Firewood and driftwood collecting is prohibited under all alternatives. These strategies, along with 

prevention and suppression of wildfire, preserve the accumulated woody debris on shorelines which has 

many benefits, including reducing erosion and providing habitat structure for shorebirds and seabirds that 

use the shoreline. 

Alternative A strategies are expected to produce generally negligible to minor beneficial effects compared 

to Alternatives B and C as current management actions, such as those mentioned above, and opportunistic 

removal of marine debris from refuge islands continues. 

The habitat management strategies of Alternatives B and C are generally expected to provide minor to 

intermediate benefits to refuge shoreline habitats and their associated species. With the addition of Smith 

and Minor Islands to the annual marine debris clean-up efforts and the remaining refuge islands on a fiveyear rotation, more shoreline habitats would experience beneficial impacts compared to Alternative A. 

Restoration of as much as 41 acres of Violet Spit strand vegetation under Alternative B is expected to 

have intermediate beneficial effects as the vegetation character is altered toward native strand habitat 

characteristics and, therefore, more optimum glaucous-winged gull nesting habitat. Effects for this action 

under Alternative C are expected to be minor as fewer acres, between 5 and 15, would be restored. 

Effects from Public Use Management Strategies: Public use management strategies in Alternatives B 

and C are expected to result in beneficial impacts to shoreline habitats and their associated species. A 

reduction in campsites on Turn Island and enforcement of unauthorized camping, especially on Matia 

Island shoreline, and unauthorized island access may have minor to intermediate benefits to the habitat 

and to the wildlife species that have been displaced from the habitat due to human activities. Increased 
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Chapter 6. Environmental Consequences 6-11

public stewardship projects that benefit shoreline would have mostly beneficial effects but some shortterm increased disturbance to the habitat and associated species would occur during the project. 

6.4.2 Sandy Bluffs

Effects from Habitat Management Strategies: Under Alternative A, intermediate negative impacts to 

sandy bluff habitat would continue from deer use. Deer trails have been formed on the bluffs, which are 

long and linear, unvegetated, and contain angular ruts. These conditions produce an ideal situation for 

larger erosion events. Other strategies from Alternative A are expected to be have negligible effects. 

Habitat management strategies in Alternatives B and C are expected to result in long-term intermediate 

beneficial impacts to sandy bluff habitats and their associated species. As unnecessary structures are 

removed from Protection Island and the footprint is restored to functioning habitat, species would benefit. 

Strategies designed to ensure restoration success include development of small test plots to determine the 

best restoration techniques, viable native plant species, and methods for non-native plant removal. 

Implementing small test plots would ensure that the larger restoration area is not disturbed more than 

necessary to implement the complete restoration plan. Transportation routes would be adjusted, resulting 

in beneficial effects to habitats in which modifications and road rehabilitation/habitat restoration occur. 

Removal of deer from Protection Island would decrease erosion of sandy bluff habitats by reducing the 

loss of vegetation on deer trails, which will increase soil stability. Deer removal activities would occur 

outside the seabird breeding season and would not occur on the sandy bluffs, therefore, no negative 

impacts to sandy bluffs or associated species are anticipated from the deer removal activities. 

Effects from Public Use Management Strategies: The two refuge islands, Protection and Smith, with 

sandy bluff habitat are closed to the public. There may, however, be some limited amount of 

unauthorized access to these islands, which would be reduced by additional education and visitor contact 

made possible with increased staff, volunteers, and partners under Alternatives B and C. 

Effects from Research and Monitoring Strategies: As indicated above, research that augments the 

success of sandy bluff habitat restoration would benefit both the habitat and the wildlife species that use 

it. In addition, standardized, regular monitoring of wildlife and plant community composition on sandy 

bluff habitats is important to guiding management decisions in the future, particularly after habitat 

restoration.

6.4.3 Savanna, Grasslands, and Balds 

Effects from Habitat Management Strategies: No new impacts to savanna, grassland, or bald habitats 

are expected from implementation of Alternative A. Currently, non-native plant species predominate and 

the large deer herd on Protection Island impacts this habitat from soil compaction and from reducing the 

diversity of forbs. 

Alternatives B and C have similar impacts associated with these habitats and their species; the two 

alternatives differ in the size of habitat management project areas. Like the effects described above for 

sandy bluff habitats, test areas on Protection Island would be used to evaluate the best restoration 

techniques to apply to the larger restoration area on the island. Depending on the number of successfully 

restored acres, this strategy could ultimately have an intermediate beneficial effect. Other strategies 

include measures to promote native grasses and forbs and to remove invasive and non-native species and 

encroaching canopy coverage on the San Juan Refuge islands. Strategies to reintroduce rare plant species 

and plants that support Taylor’s checkerspot butterflies would support habitat integrity and diversity. If 
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used for restoration, prescribed fire would have a beneficial impact on the habitat by reducing non-native 

vegetation, recycling of nutrients, maintaining native plant species that benefit from fire disturbance, and 

prevent encroachment of woody vegetation. 

Removing deer from Protection Island under Alternative B and C would reduce impacts to vegetation 

from browsing and increase the success of native plant restoration. Deer removal is expected to lead to 

increased woody plants within the grasslands. There may be a negligible amount of vegetation 

disturbance from deer removal activities conducted outside the seabird breeding season. 

Effects from Public Use Management Strategies: Impacts from strategies to increase visitor contact 

and education, including increased staffing, volunteers, and partnerships for stewardship projects, would 

be similar to those discussed for shorelines. Rerouting the trail on Turn Island to avoid the sensitive 

camas community would also contribute to improving habitat integrity.

Effects from Research and Monitoring Strategies: Under Alternatives B and C, identified research 

that augments the success of savanna and grassland habitat restoration would benefit both the habitat and 

the wildlife species that use it. Monitoring and research conducted on savanna, grassland, and bald

habitats and their associated species would provide benefits in the form of information for future 

management decisions and directions.

6.4.4 Forests and Woodlands

Effects from Habitat Management Strategies: Under all alternatives, there would be beneficial effects 

to forests, woodlands, and associated species from total wildfire suppression tactics and prohibition of 

open fires and collection of down wood. Allowing downed wood to remain in forested environments 

contributes to wildlife habitat and nutrient cycling. Under Alternative A, continued deer browsing that 

limits natural regeneration of trees and shrubs would have intermediate negative impacts. 

Under Alternatives B and C, the removal of deer from Protection Island would benefit forests and 

woodland habitats by eliminating the heavy browsing of small trees and shrub understory. Negligible 

negative impacts to forests and woodlands are anticipated from deer removal activities. Restoration of the 

former forest cover on Protection Island would join the shrub layer and two forest patches into one 

contiguous forest to benefit associated species. 

Under Alternative C, beneficial effects are also expected as campsites removed on Matia Island are 

revegetated with trees and shrubs. 

Effects from Public Use Management Strategies: Under Alternatives B and C, additional staff and 

volunteers would help reduce unauthorized activities with benefits to forests and woodlands. 

Effects from Research and Monitoring Strategies: Little to no information is currently available on 

reptile, amphibian, or bat species occurrence on the refuges. Assessments and monitoring for these 

species in forests and woodlands would greatly assist management in identifying and prioritizing 

management needs for these species, particularly in response to climate change. 

6.4.5 Wetlands

Effects from Habitat Management Strategies: Negligible effects to wetlands are expected as a result 

of continuing current habitat management strategies under Alternative A.
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Habitat management strategies associated with Alternatives B and C that may impact wetland habitats are 

centered on potential wetland hydrology restoration. If the hydrologic processes can be restored to any 

one of the three refuge wetlands (historic wetland on Protection Island, brackish wetland on Smith Island, 

and forested wetland on Matia Island), it would provide opportunities for long-term beneficial effects 

with intensity levels commensurate with the management action(s) implemented. Wetland habitats are 

limited within the two refuges and have the potential to provide beneficial functions and values within the 

local landscapes.

Effects from Research and Monitoring Strategies: Under Alternatives B and C, research efforts aimed 

at understanding the feasibility of restoring natural hydrologic processes to the refuge wetlands would 

benefit the Refuge. If the staff has a better understanding about the natural processes and feasibility of 

restoration, it would inform their management decisions about that habitat type.

6.5 Effects to Wildlife 

Topics addressed in this section include seabirds (including rhinoceros auklets, tufted puffins, pigeon 

guillemots, glaucous-winged gulls, and cormorants); bald eagles, black oystercatchers, and marine 

mammals (including harbor and elephant seals, Stellar and California sea lions). These are considered 

focal wildlife resources for Protection and San Juan Islands Refuges. Deer are also addressed in this 

section, however they are not considered a focal resource for these refuges because their habitat needs can 

be met in many other locations. Many of the effects discussed in the previous sections regarding habitats 

also impact focal resources, for example black oystercatchers and marine mammals are closely associated 

with shoreline and bald eagles are closely associated with forested habitats. None of the alternative 

actions are expected to have major effects to these wildlife species/groups. In general, the strategies 

contained in Alternatives B and C would provide the most benefits. 

6.5.1 Seabirds

Effects from Habitat Management Strategies: 

Under all alternatives, seabirds that use the Protection Island shoreline where marine debris and 

contaminated materials collect would continue to experience beneficial impacts when their habitat is 

maintained in a cleaner state. Seabirds and their prey species would also benefit from the decreased 

marine toxicity from removal of the creosote piling associated with the marina at Protection Island. 

Seabirds, especially pigeon guillemots, would benefit from continued prohibition of collecting driftwood 

and down wood from all refuge islands. 

Negative impacts associated with Alternative A include continued decline in the quality of glaucouswinged gull nesting habitat on Protection Island’s Violet Spit, due to the presence of dense and tall 

invasive plant species. This will also contribute to continued and possibly increased competition between 

the gulls and the rhinoceros auklets for nesting habitat on the sandy bluffs where vegetation is less dense 

and more desirable to the gulls. Other potential negative impacts may be experienced as the rhinoceros 

auklet colony expands into existing facility locations such as the caretaker’s and extended users’ 

structures and as disturbances from existing transportation routes/modes continue.

Under Alternative A, nesting rhinoceros auklets and glaucous-winged gulls will continue to experience 

negative impacts from the presence of deer on Protection Island. Deer use rhinoceros auklet burrow 

nesting habitat to browse and bed down. When deer bed down on top of rhinoceros auklet burrow 

entrances, they prevent the birds from leaving or entering burrows to feed their young and can startle 
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auklets, causing them to lose a beak-load of fish for their young. In addition, deer hooves can cause the 

collapse of rhinoceros auklet burrows. In the case of the gulls, eggs and young would continue to be 

more susceptible to predation due to disturbance of adults and nests by deer browsing and walking

through the colony.

Under Alternatives B and C, benefits to seabirds from marine debris collection and removal of 

contaminated materials would increase by including Smith and Minor Islands in annual cleanup activities 

and including other islands in the San Juan Islands Refuge on a five-year rotation basis. Development 

and implementation of the Protection Island infrastructure site plan would have beneficial effects to 

seabirds, especially rhinoceros auklets due to removing structures that are in the vicinity of the expanding 

rhinoceros auklet colony, and modification of transportation routes/modes to minimize disturbance to 

seabirds and other refuge wildlife. 

Alternatives B and C include removing deer from Protection Island. This would benefit rhinoceros 

auklets and glaucous-winged gulls and their habitat by preventing disturbance of nesting colonies by deer 

and reduce soil erosion associated with deer trails. Negligible impacts from deer removal are anticipated 

because this activity will not occur directly on the sandy bluffs where rhinoceros auklet nesting burrows 

are found and it will occur outside of the seabird breeding season.

 

Alternatives B and C also include restoration of native strand vegetation on Protection Island to benefit 

glaucous-winged gulls and their preferred nesting habitat. Alternative B includes more acres (up to 41) of 

restoration and is therefore expected to have more benefits than Alternative C, which has fewer acres (5-

15) of restoration. It is anticipated that improving habitat for the gulls on the spit will encourage more 

gulls to nest on the spit and move away from the sandy bluffs where the rhinoceros auklets nest. This 

would benefit both the rhinoceros auklets and the gulls by increasing habitat quality and reducing habitat 

competition. 

Some negligible short-term negative effects to seabirds and their habitats could occur during stewardship 

project activities such as beach clean-up, invasive species removal, and wildlife monitoring. Some minor 

short-term negative effects to seabird habitat may occur during vegetation restoration, however, these 

would be carefully monitored and minimized. 

Effects from Public Use Management Strategies: Under all alternatives, wildlife observation and 

photography, both priority public uses, will continue. The impact of these activities to seabirds would 

depend upon the distance from the animal to the disturbance and the duration of the disturbance. Because 

photographers are more likely to attempt close contact with their subjects, wildlife photography is likely 

to be more disturbing, per occurrence, than wildlife observation. The Compatibility Determination for 

wildlife observation, photography, and interpretation includes a detailed description of effects from 

wildlife observation and photography (Appendix J).

Under Alternatives B and C, it is anticipated that seabirds would benefit from more security to rest, feed, 

and care for their young due to a decrease in human-caused disturbances. This effect is anticipated as a 

result of identified strategies, including increased boater contacts and education, to promote voluntary 

boat-free zones around refuge islands. Other strategies are to increase awareness of the impacts of boats 

on wildlife; better enforcement of closed islands and closed shorelines on Matia and Turn Islands; the 

new prohibition of pets on Turn and Matia Islands; improved regulatory signs; increased partnerships 

with others to protect seabirds; and more opportunities for interpretation and stewardship projects that 

increase awareness of how people can minimize their impacts to wildlife. Effects would be slightly more 

beneficial under Alternative B due to the allocation of greater staff time. 
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Additional benefits to seabirds are expected from the development and distribution of a handbook 

containing refuge guidelines for all people authorized to be on Protection Island. The handbook would 

include maps of breeding areas and best management practices and/or requirements to prevent 

unintentional seabird disturbances or trampling.

Effects from Research and Monitoring Strategies: Under Alternatives B and C, there would be 

benefits to seabirds from surveys and monitoring for rats, rabbits, and mammalian predators. Surveys and 

monitoring of refuge island habitats and equipment brought to the islands would benefit seabirds and their 

habitat from the potential negative consequences of introduced rats and rabbits as well as native and nonnative mammalian predators. These animals can prey on seabirds directly or cause habitat damage and 

breeding nest disturbances. 

In addition, standardized, long-term surveys throughout the Salish Sea will benefit seabirds and 

oystercatchers by providing an ecosystem-wide framework from which to interpret monitoring data and 

implement region-wide management responses if necessary. This is particularly important for seabird 

habitat management as seabird colony locations can shift from year-to-year in response to environmental 

and disturbance factors. 

As test plots for best restoration techniques, including invasive plant removal techniques, erosion control 

methods, and native plant establishment methods, are used to inform future management decisions, 

seabirds would benefit with better nesting habitat. There may be some short-term negative impacts from 

restoration activities due to decreased ground cover as invasive plants are removed and before native 

plants become well established. 

6.5.2 Bald Eagles

Effects from Habitat Management Strategies: Under all alternatives, wildfire suppression efforts 

would continue to have direct benefits to bald eagle habitat as nesting and roosting trees are protected 

from potential destruction from fire. 

Under Alternatives B and C, restoration of forest habitat on Protection Island would benefit bald eagles in 

providing a long-term source of nesting and roosting trees. Habitat improvements aimed at other wildlife 

species such as seabirds and marine mammals on the refuges would indirectly benefit bald eagles by 

enhancing conditions for their prey species. Bald eagles and their prey species would also benefit from 

the decreased marine toxicity from removal of the creosote piling associated with the marina at Protection 

Island. 

Effects from Public Use Management Strategies: Under all alternatives, wildlife observation and 

photography would continue on open refuge islands and from boats at a distance on closed refuge islands. 

Bald eagles are a popular species for wildlife observation and photography. The impact of these activities 

to bald eagles would depend upon the distance from the animal to the disturbance and the duration of the 

disturbance. 

Under Alternatives B and C, it is anticipated that bald eagles would benefit from more security to rest, 

feed, and care for their young due to a decrease in human-caused disturbances. This effect is anticipated 

as a result of identified strategies, including better enforcement of closed islands and closed shorelines on 

Matia and Turn Islands; increased education opportunities to let people know how they can minimize 

human-disturbance to bald eagles and other refuge wildlife, such as staying up to 200 yards away from 

refuge islands. The development of a handbook containing refuge guidelines for Protection Island would 
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benefit bald eagles by reducing unintentional human disturbance to their nesting territory. Beneficial 

effects would be slightly greater under Alternative B compared to Alternative C due to the allocation of 

greater staff time. 

6.5.3 Black Oystercatchers

Effects from Habitat Management Strategies: Black oystercatchers depend on driftwood for cover 

from predators. As driftwood is allowed to accumulate under all alternatives and shoreline habitat is 

enhanced and protected, black oystercatchers would experience beneficial impacts similar to those 

discussed for seabirds. 

Beneficial impacts resulting from strategies under Alternatives B and C for development of a handbook 

containing refuge guidelines for Protection Island would be similar to those discussed for seabirds.

Strategies that increase boater awareness, minimize shoreline disturbance through education of voluntary 

boat-free zones, limit shoreline access areas on Turn and Matia Islands, and eliminate social trails would 

result in impacts similar to those discussed for seabirds and particularly benefit black oystercatchers. 

Under Alternatives B and C, as glaucous-winged gull breeding success improves, black oystercatcher 

chicks are likely to experience increased predation by the gulls, however, increases in cover (accumulated 

driftwood) may offset potential increases in gull predation.

Effects from Public Use Management Strategies: Effects to black oystercatchers from public use 

management strategies would be similar to those described for seabirds. Black oystercatchers would 

benefit from the elimination of social trails and pets on Turn and Matia Islands and from the increased

enforcement of closed islands and closed shorelines of Turn and Matia Islands. 

Effects from Research and Monitoring Strategies: Coordinated, standardized monitoring efforts of 

oystercatchers nesting throughout the Salish Sea will provide a minor, long-term benefit to management 

by providing an ecosystem-wide data on abundance and distribution year-round, especially for assessing 

effects of climate change and sea level raise.

6.5.4 Marine Mammals

Effects from Habitat Management Strategies: Under all alternatives, marine mammals that use the 

Protection Island shoreline where marine debris and contaminated materials collect would continue to 

experience beneficial impacts when their habitat is maintained in a cleaner state. They would also benefit 

from the decreased marine toxicity from removal of the creosote pilings associated with the marina at 

Protection Island. Nourishment of the Protection Island shoreline would also benefit marine mammals 

that use that shoreline. 

Under Alternatives B and C, benefits to marine mammals from marine debris collection and removal of 

contaminated materials would increase due to including Smith and Minor Islands in annual cleanup 

activities and including other islands in the San Juan Islands Refuge on a five-year rotation basis. 

Effects from Public Use Management Strategies: Under all alternatives, wildlife observation and 

photography would continue on open refuge islands and from boats at a distance on closed refuge islands. 

Marine mammals are a popular species for wildlife observation and photography. The impact of these 
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activities on marine mammals would depend upon the distance from the animal to the disturbance and the 

duration of the disturbance. Marine mammals would continue to avoid shorelines that receive substantial 

human activity whether authorized or not, such as on closed islands and closed shoreline areas of Matia 

Island. 

Under Alternatives B and C, marine mammals would benefit from greater security to haul-out and rest on 

refuge islands while experiencing fewer human-caused disturbances as a result of increased boater 

awareness about the refuges and the potential impacts from boating activities; better enforcement of 

closed islands and closed shoreline areas on Matia Island; elimination of pets on Turn and Matia Islands; 

and more staff presence on refuges, on the water, and in nearby communities to encourage wildlife 

observation and photography at a distance that minimizes disturbance. The development of a handbook 

containing refuge guidelines for Protection Island would benefit marine mammals by reducing 

unintentional human disturbance. Beneficial effects would be slightly greater under Alternative B 

compared to Alternative C due to the allocation of greater staff time. 

6.5.5 Deer

Effects from Habitat Management Strategies: Under Alternative A, deer removal is not proposed for 

Protection Island. The very high density (~124 deer/mi2

) of deer on the island noted in 2008/2009 (see 

Chapter 4, section 4.12.1) has already impacted island vegetation and wildlife. Water and forage 

resources could become depleted if the herd size increases and the deer would become malnourished. 

Starvation and/or disease would likely cause a reduction in deer numbers. Negligible impacts to deer on 

both refuges are expected from research and monitoring activities identified under Alternative A. 

Under Alternatives B and C, deer removal from Protection Island in coordination with Washington 

Department of Fish and Wildlife is proposed. Deer removal methods would be evaluated and determined 

in a step-down planning process. More than one removal method may be employed, however the impacts 

to the deer would be similar and will typically result in the death of the deer. This would obviously have 

a negative impact to the deer on Protection Island. However, removal of deer from Protection Island is 

expected to have a negligible impact to the abundance of deer in the area. According to models 

developed by WDFW, the black-tailed deer population estimate has nearly doubled over the last 5 years 

within WDFW’s Coastal Region (6) which includes the Olympic Peninsula (WDFW 2009). 

6.6 Effects to Wilderness Resources

Wilderness character includes consideration of the wildlife and habitats, visual quality, noise intrusions, 

and the general opportunity to experience solitude in an untrammeled environment.

Effects from Habitat Management Strategies: 

Under Alternative A, marine debris would sometimes be removed from wilderness islands, but there 

would often be debris remaining and detracting from the wilderness character of the islands since there is 

no regularly scheduled clean-up. 

Under Alternatives B and C, there would be more regular marine debris clean-up on wilderness islands,

which would benefit maintenance of the wilderness character of the islands. Short-term, minor negative 

effects would result from diminished visual quality due to smoke particulates during prescribed burns 

associated with restoration projects. There would be long-term beneficial effects from the reduction of 

invasive species on wilderness islands. 
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Effects from Public Use Management Strategies: Under all alternatives there are negative effects to 

the visual quality of wilderness islands due to the use of signs to identify refuge islands and reduce 

wildlife disturbance. Alternative A would have the most negative effects to wilderness quality because 15 

islands would have very large format (4’ x 6’) signs compared to only 10 islands in Alternatives B and C. 

Alternative B would be next in terms of reduced visual quality from signs due to the use of additional 

medium and large signs, and Alternative C strategies use mostly small signs and therefore would have the 

least negative impact to visual quality from signs. Alternative B is expected to be the most effective in 

terms of reducing wildlife disturbance. Therefore, the benefits associated with enhanced wildlife 

viewing opportunities on wilderness islands would be greatest under Alternative B because wildlife are 

more likely to be present where there are fewer human-caused disturbances. 

Under Alternatives B and C, the wilderness experience on Matia Island is expected to be enhanced by 

limiting the size of commercial day-use groups to not more than 20 people. This would increase 

opportunities for solitude or near-solitude and decrease the noise that can accompany large groups. This 

would, however, result in a smaller number of people being able to visit Matia Island at any given time. 

Interpretive signs and education would provide knowledge about wilderness islands with the intention of 

enhancing the wilderness experience. The removal of unauthorized “social trails” and enforcement of no 

access, including no camping, on closed shorelines would enhance the wildlife values of Matia Island. 

Under Alternatives B and C, the use of a reservation system for camping, and limiting camping to visitors 

arriving by human-powered craft, is expected to enhance the wilderness experience for campers. 

Under Alternative C, there would be 2 fewer campsites on Matia Island. The reduction of campsites and 

corresponding reduction in the number of people allowed on the island overnight would enhance the 

opportunity for solitude for the remaining overnight users but would limit the number of people who 

could camp on Matia Island and experience it overnight. 

6.7 Effects to Cultural Resources

Under all alternatives, surface-disturbing activities may cause direct negative impacts to cultural 

resources through the damage or destruction of archaeological sites or loss of valuable scientific 

information by the disturbance of the stratigraphic context in which archaeological deposits are found. 

Due to the small percentage of the refuges’ acres that have had a cultural resource survey, it is expected 

that new sites may be found. The probability of finding larger habitation-type sites is low due to the 

small size of the islands and the lack of ready resources. All alternatives assume a cultural resource 

survey would be conducted prior to implementing any ground-disturbing activity in order to avoid 

negative effects to cultural resources. Even with a survey, the presence of buried cultural deposits can 

never be predicted with certainty. If significant resources are discovered during management activities or 

at any other time, the project would be halted immediately until the site can be evaluated. 

Erosion and ongoing public uses are two examples of active impacts to the stability of known sites. 

Allowing natural processes to occur with minimal human intervention could cause negative effects if 

wave action or other erosive activities occur in the vicinity of cultural deposits. Whether permitted or not, 

if public access to sites continues to occur, the stability and integrity of archaeological sites could be 

compromised.

Under Alternative A, negligible effects to cultural resources are anticipated as a result of the Service 

working with partners to reduce the risk of oil spills, clean up of marine debris, and education of boaters 
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to minimize human-caused wildlife disturbance and facilities maintenance. Under this alternative there is 

a higher risk that erosion from wind, wave action, soil compaction, and the actions of people walking 

around the islands may cause some minor to intermediate negative effects to cultural resources due to lack 

of staff to provide erosion intervention and to control unauthorized public activities.

Under Alternatives B and C, facilitating research and monitoring studies to improve understanding of 

wildlife would have negligible effects to cultural resources. Habitat restoration projects that involve 

extensive digging or ground disturbance, including prescribed fire, could negatively impact cultural 

resources. Impacts would be negligible to minor assuming proper cultural resource management 

procedures are followed. Habitat restoration projects that increase vegetation to cover exposed sites, 

stabilize soils, and reduce erosion would have a beneficial effect on cultural resources. There may be 

some minor short-term negative effect from deer removal activities on Protection Island which would 

increase the chances of exposure and degradation of cultural resources. However, there would also be a 

long-term beneficial effect on cultural resources because soil erosion on the bluffs will likely decrease. 

Implementation of a new site plan for Protection Island under Alternatives B and C could have negligible 

to minor negative impacts should cultural resources be present in the vicinity of activities associated with 

destruction and construction of structures/facilities, roads, and trails. 

Other actions under Alternatives B and C that are expected to benefit cultural resources include 

relocating, updating the documentation, and performing NRHP evaluations for the six known prehistoric 

sites. Systematic efforts to survey and evaluate cultural resources in unsurveyed areas with high potential 

for archaeological materials would also benefit cultural resources. Enhancing the public’s understanding 

and appreciation of the natural and cultural resources through on-refuge and off-refuge interpretation and 

education programs would result in beneficial effects to cultural resources. 

6.8 Effects to Paleontological Resources

Paleontological resources of Pleistocene age have been identified as eroding out along the margins of 

Protection Island. Erosion along the margins of Protection Island is expected to continue as a result of sea 

level rise and wave cut erosion processes. Given the large number (n=164) of paleontological resources, 

mostly unidentifiable fragments and mastodon teeth, the potential for additional paleontological resources 

on Protection Island is considered to be high. 

No known paleontological resources have been identified within the San Juan Islands Refuge, however, 

the broader San Juan Islands have yielded a number of Paleozoic to Holocene age fossils (n=60 +), 

including mollusca, foraminifera, crinoids, conodonts and Bison remains. Given that the San Juan Islands 

are comprised of Paleozoic, Mesozoic and Cenozoic era sediments (i.e., limestone, sandstone, siltstone, 

glacial drift), the potential for paleontological resources is considered to be moderate-to-high. 

Paleontological resources, like cultural resources, are found above and below the surface of the ground. 

Also, similar to cultural resources, they are impacted by ground-disturbing activities including erosion, 

digging, prescribed fire, and public uses that alter their stability and integrity. Negative effects to 

paleontological resources would be greatest under Alternative A. The lack of systematic surveys on

Protection Island and other refuge lands to identify and document paleontological resources and under 

each of the CCP Alternatives are expected to be nearly identical to the effects to cultural resources 

described above. Negative impacts to paleontological resources would be minimized by conducting a 

systematic survey prior to any ground-disturbing activity and mitigating potential negative effects. 

Alternatives B and C include proactive systematic surveys for paleontological resources where they are 
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most likely to be found on refuge lands and objectives for enhancing their scientific, educational, and 

recreational values which would benefit this non-renewable resource. 

6.9 Effects to the Research and Monitoring Program

Under Alternative A, the refuge staff works with a limited number of long-term partners. Refuge 

facilities to house and conduct research activities are in need of updating and consolidating. The program 

does result in quality research aimed at improving scientific knowledge. Coordination with refuge staff is 

limited due to lack of refuge staff and results in fewer research topics focused on answering specific 

refuge management questions. Continuing the current program would allow biological studies to provide 

information for several years into the future.

Alternatives B and C include moving, consolidating, and updating the current facilities that house 

researchers in conjunction with the development and implementation of the Protection Island site plan. 

This would improve overall working conditions and encourage more collaboration among research 

groups. The refuge guidebook would contain guidelines and inform people how to engage in behaviors to 

reduce and minimize negative impacts to habitats and species. 

Under Alternatives B and C, greater emphasis would be given to working closely with partners to design 

and implement cooperative research and monitoring activities. Existing cooperative efforts with state 

agencies would be continued and the partnerships expanded to include more activities in support of the 

refuges’ and the Service’s mission and goals. These cooperative efforts would directly contribute toward 

maintaining or restoring the biological integrity, diversity, and environmental health of the refuges. 

Specifically, the establishment of a cooperatively developed GIS-based inventory and monitoring 

program for seabirds; endangered, threatened, and sensitive wildlife species; and other wildlife and plant 

species, as well as pursuit of joint survey and monitoring opportunities and information sharing, would 

substantially increase understanding of wildlife, habitats, and ecosystem processes. This would allow 

implementation of adaptive management techniques, which would result in an expected beneficial effect 

on refuge resources.

An expected long-term beneficial effect on refuge resources may occur under Alternatives B and C with 

the increased emphasis on specific areas of wildlife and habitat research through a collaborative approach. 

This strategy includes cooperative interagency or collaborative efforts with universities to perform 

research. Examples include coordinating with NOAA Fisheries and WDFW to increase collection of 

abundance and distribution data for harbor and elephant seals; coordinating with partners to conduct 

surveys for bald eagles according to the Bald Eagle Delisting Monitoring Plan; and coordinating with 

partners to conduct an inventory of reptiles and amphibians in forested and wetland habitats to determine 

presence of rare species, such as sharp-tailed or bull snake. 

Staff will also focus on implementation of a comprehensive inventory and standardized monitoring 

program for burrow and crevice-nesting seabirds. As a result, a more accurate estimate of populations 

and trends would be obtained. Resource managers would have reliable seabird population census data to 

properly guide management of species and ecosystems. A long-term seabird monitoring program using 

seabirds as biological indicators of ocean conditions and effects of climate change would be established. 

Thus, climate change and its influence on biological processes would be better understood, allowing 

likely scenarios to be factored into habitat management and protection strategies.
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6.10 Social and Economic Effects

6.10.1 Overall Visitation

Under Alternative A, overall visitation experiences and trends are not expected to change as a result of 

current management strategies. The San Juan Archipelago is a popular destination for vacations and 

summer homes. Under all alternatives there may be an increasing number of visitors to refuge islands if 

the popularity of the region continues to grow. 

Under Alternatives B and C, the visitor’s experience would be enhanced from installation of interpretive 

signs on Turn and Matia Islands as well as off-refuge; increased education and outreach about the refuges 

through many different venues; and increased visitor contacts from refuge staff and volunteers. The 

experience would also be enhanced from the expected increase in the quality of wildlife viewing of refuge 

islands from boats at a distance and on Turn and Matia Islands as a result of better enforcement of 

wildlife sanctuary areas off limits to people. 

Under Alternatives B and C, some negative impacts to the visitor’s experience is expected from closing 

some areas of Turn Island, including some shoreline landing sites that have previously been open to 

access. On Matia Island, better enforcement of the already closed shoreline areas and removal/restoration 

of the unauthorized social trails may also be perceived by some visitors as a negative effect. 

Under Alternatives B and C, there would be a new reservation system for camping that would provide 

visitors with assurance that they will have a campsite. It would also discourage unauthorized camping. 

The new stipulation that only visitors arriving by human-powered boats would be able to camp would 

enhance the experience for some by providing a quieter, more primitive camping experience, but it will 

likely be perceived as negative by others. The number of visitors using the refuge at night would be 

reduced some in Alternative B with fewer campsites on Turn Island and reduced quite a bit more in 

Alternative C with camping eliminated on Turn Island and the number of campsites reduced on Matia 

Island. 

6.10.2 Opportunities for Quality Wildlife Observation and Photography

Wildlife observation and photography opportunities throughout most of the refuges should occur from 

outside the voluntary boat-free zone (200 yards). However, it is likely that some observers and 

photographers do approach the islands for a closer look. Visitors to Matia and Turn islands have an 

opportunity for land-based viewing and photographing in the areas specifically open to access. Evidence 

of social trails and illegal shoreline access indicates that some of these visitors are also taking a closer 

look. Unfortunately, a closer look can have negative impacts on wildlife. It may cause birds to flush 

from nests, leaving eggs without necessary incubation attendance; marine mammals can be caused to 

abandon haul-out sites that may provide a necessary resting period.

With habitat improvements that are proposed under Alternatives B and C, wildlife is expected to use the 

restored habitat. Where those restoration projects are within the viewshed, opportunities for observation 

would likewise increase. Other habitat management strategies that would improve opportunities for 

observing/photographing wildlife in a natural setting include prohibiting firewood and driftwood 

collection. Wildlife is likely to be seen using these important habitat features.

Alternatives B and C also include measures for increased environmental education, interpretation, and 

general enforcement of public use restrictions. All of these strategies would improve visitor 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

6-22 Chapter 6. Environmental Consequences 

understanding of how wildlife use the area, how human activities can disturb wildlife, and when, where, 

and how to increase the likelihood of observing wildlife in their natural environment. Strategies to reduce 

the number of visitors to the islands at any one time and limiting overnight access to human-powered

boats will decrease human disturbances during some of the most active wildlife hours and increase the 

opportunity to see wildlife for those visitors who are present. It is expected that the collective measures 

proposed to teach visitors about healthy viewing methods would have a beneficial impact on opportunities 

for wildlife observation and photography at the refuges.

6.10.3 Opportunities for Quality Environmental Education

The current environmental education program for both refuges is limited. Strategies proposed under 

Alternative B would contribute to a better developed program and are expected to have beneficial effects. 

Alternative B strategies include increased emphasis on enhancing the public’s understanding and 

appreciation of the refuges’ natural, cultural, paleontological, and wilderness resources. Programs would 

be offered both on- and off-refuge. Educational programs would also encourage a stewardship ethic 

toward the refuges. Many of the strategies that are described as improving opportunities to observe 

wildlife would be directly linked to the proposed environmental education program changes. For 

example, increasing passive environmental education at marinas, harbors, airports, and on ferries; actively 

training volunteers and ecotourism operators; and increasing interpretation opportunities (see discussion 

below for more details on interpretation) would all have far reaching effects when the public is more 

informed about the refuges and their importance to the ecosystem and its species. Programs that 

specifically reach out to local schools would help to foster local pride in the refuges. 

Similar impacts from Alternative C strategies are expected at a reduced scale.

6.10.4 Opportunities for Quality Interpretation Experience

The current interpretive program for both refuges is limited. Strategies proposed under Alternative B 

would contribute to a better developed program and are expected to have beneficial effects. Alternative B 

strategies are very similar to those described above for environmental education. They emphasize 

enhancing public understanding and appreciation of the refuges’ resources and characters, how wildlife 

can be disturbed by human activity, and how the refuges are an important part of the greater San Juan 

Islands Archipelago. The interpretation program would include adding informative panels along trails, 

training volunteers and hosts/caretakers to provide interpretive information to visitors, providing materials 

to be posted or viewed at local harbors, airports, marinas, and on ferries. 

Similar impacts from Alternative C strategies are expected at a reduced scale.

6.10.5 Opportunities for Quality Hunting Experience

Under Alternative A, no hunting is allowed on any of the refuge islands. Some deer hunting and 

waterfowl hunting does occur on nearby islands and mainland areas. Negligible impact to hunting in the 

area is anticipated under Alternative A. 

Under Alternatives B and C, it is possible that hunting may be one of the chosen methods to remove deer 

from Protection Island. Possible methods would be evaluated and selected in a step-down planning 

process. If hunting is selected, there would be a short-term and limited increase in opportunities for deer 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-23

hunting on Protection Island. There may also be an indirect benefit to off-refuge waterfowl hunting in the 

area from enhancing waterfowl foraging habitat through refuge restoration projects; enhanced shoreline 

protection and marine debris removal; and reducing the risk of contaminants. 

6.10.6 Opportunities for Quality Fishing Experience

There are no fish-bearing water resources on any of the refuge islands. However, there are fishing 

opportunities in the marine waters that surround refuge islands. Under Alternatives B and C, increased 

staffing levels compared to Alternative A would permit more interpretation and education activities both 

on- and off-refuge lands and increase contacts with boaters, including those who are fishing in the area. 

The anticipated increase in knowledge and enjoyment of the Salish Sea would indirectly benefit the 

quality of the fishing experience. Increased education about the voluntary boat-free zone around refuge 

islands in the San Juans is expected to reduce the number of people who fish close to refuge islands. This 

would have a negligible to minor negative effect on fishing because the boat-free zones are voluntary and 

represent a minimal reduction in the area available for fishing in the Salish Sea. Under Alternatives B and 

C, increased involvement in marine debris and contaminants clean-up compared to Alternative A would 

contribute to an improved fishing experience.

6.10.7 Opportunities for Quality Camping Experience

Changes to camping proposed under Alternatives B and C are designed to create a camping experience 

that does a better job of supporting the Service’s priority wildlife-dependant recreational activities 

including wildlife observation and photography. The Refuge System Improvement Act of 1997 and the 

Service’s recent Compatibility and Appropriate Refuge Uses policies indicate that camping on a national 

wildlife refuge is not appropriate unless it is needed to support a priority wildlife-dependent recreational 

activity. Because of the speed of motor-boats, visitors using them can observe and photograph wildlife on 

Turn and Matia Islands as well as throughout the Salish Sea and can easily reach an off-refuge campsite 

before dark. This is much more difficult for visitors using human-powered boats, and thus Alternatives B 

and C allow camping only for visitors arriving by human-powered boats in order to support wildlife 

observation from Turn and Matia Islands as well as to support wildlife observation from a distance on 

closed refuge islands throughout the Salish Sea. For additional information see Appendix I. 

Under current management Alternative A, the number of campsites provided remains the same on Turn 

and Matia Islands within the San Juan Islands NWR, and visitors arriving by both motorized and humanpowered boats are able to use authorized campsites. Due to staff limitations, some unauthorized camping 

would likely continue on closed shoreline areas of Matia Island and on closed refuge islands in the Salish 

Sea. The lack of a camping reservation system means that boaters would continue to have no assurance 

that an authorized campsite will be available for them when they arrive. This likely contributes to 

unauthorized camping, especially among human-powered boaters who, due to boat speed limitations, 

have less flexibility to find another campsite before dark. The quality of the camping experience in terms 

of opportunities to observe wildlife or experience nature in a peaceful atmosphere would be negative,

especially during busy summer weekends due to the number of authorized and unauthorized campers, as 

well as the limited staff available to enforce camping, noise, and disorderly behavior regulations. 

Under Alternative B, fewer people would be able to camp on Turn Island due to eliminating 5 campsites 

(8 campsites would remain). This reduction in campsites is negligible because it represents a loss of less 

than one percent of available campsites in the local area. There are more than 800 public and private 

campsites within 15 miles of Turn and Matia Islands (See Chapter 5 Tables 5.4 and 5.5). The loss of 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

6-24 Chapter 6. Environmental Consequences 

campsites is greater for visitors arriving by motor-boat because they would not be allowed to camp on 

either refuge island; however, that is offset by their greater ability to get to alternate campsites compared 

to visitors arriving by human-powered boats. Unauthorized camping activities would decrease due to 

creation of the reservation system which would allow people to reserve campsites before they arrive and 

from increased staff capacity to patrol refuge islands. Opportunities for wildlife observation and the 

ability to experience nature in a peaceful atmosphere would be enhanced due to fewer overall numbers of 

campers at one time, less noise, and fewer unauthorized activities. These changes would result in an 

intermediate benefit to the quality of the camping experience. 

Alternative C would remove all campsites on Turn Island and two on Matia Island (leaving four Matia 

Island campsites). This would result in fewer campsites being available but still represents a minor 

reduction in the quantity of available campsites found in the local area. It would, however, eliminate a 

popular camping area. The impact would be greatest on individuals, families, organizations, and 

commercial kayak outfitters who have enjoyed the accessibility and convenience of the Turn Island 

campground within a short distance of Friday Harbor, the social and economic center of San Juan County. 

6.10.8 Effects to Human Health

In addition to the effects described in the air quality section (Section 6.3.3); use of herbicides and/or 

pesticides in Alternatives B and C management strategies could have the potential to impact human 

health. However, it is expected that all people performing applications of these chemicals would follow 

instructions and wear appropriate protection to avoid dangerous contact with or respiration of the 

materials. Because most of the refuges are closed to public access, there would be little risk of the public 

coming into contact with herbicides or pesticides used in refuge management (also see Appendix E). 

Replacement of the marina creosote pilings would reduce the toxin and contaminant contributions to the 

food chain. Therefore, no negative impacts to human health are expected as a result of any of the 

management alternatives.

6.10.9 Effects to Economy

Local communities benefit economically from having a national wildlife refuge in the area (Carver and 

Caudill 2007). In the lower 48 states recreational visits to national wildlife refuges in Fiscal Year 2006 

generated $1.7 billion of sales in regional economies; almost 27,000 people were employed; and $542.8 

million in employment income was generated. In the state of Washington, the average for the six refuges 

that were sampled that year (Dungeness and Nisqually were the closest in proximity) indicates $2.05 

million in sales, 30.5 people employed, and $830,000 in employment income (Carver and Caudill 2007).

Implementation of Alternative A would be expected to result in negligible increases in expenditures in the 

local economy because staff levels and visitor programs would remain similar to current conditions. 

Implementation of Alternative B is expected to result in minor beneficial impacts to local economies. 

This alternative would have the greatest economic benefits because expenditures are expected to increase 

in order to implement additional and/or improved educational and interpretive programs and resource 

restoration projects. Refuge visitation and money spent in the community is also expected to increase in 

part from increased knowledge of the refuges and also from the overall increasing popularity of travel to 

the Salish Sea area. The additional volunteer, host/caretaker, and staffing positions would also add 

slightly to the local economy and employment. Under Alternative B, removal of 5 of the 13 campsites on 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-25

Turn Island in Alternative A would decrease State Parks revenue in campground fee collections to the 

degree that would-be campers did not find alternate campsites within the State Park system. The change 

in State Parks revenue is expected to be negligible and there may be increases for county and private 

campgrounds in the area. 

Since Alternative C includes fewer acres of restoration, there will likely be slightly fewer expenditures 

and less economic benefits to the local area associated with restoration projects. Alternative C public use 

strategies include enhancing environmental education and interpretation opportunities, which would be 

expected to have minor economic benefits similar to Alternative B. The elimination of camping on Turn 

Island under Alternative C would have an intermediate negative economic impact to the local area as it is 

popular campground for local residents, visitors, and commercial kayak outfitters. The refuge would also 

incur greater staffing costs as a result of State Parks no longer handling maintenance and law enforcement 

on the island. 

6.10.10 Environmental Justice

The concept of environmental justice has been around since the early 1990s and arose from a need to 

ensure that negative environmental activities from industry or government projects would not endanger 

local communities. The U.S. Environmental Protection Agency (USEPA) oversees environmental justice 

compliance and defines environmental justice as: “the fair treatment and meaningful involvement of all 

people regardless of race, color, national origin, or income with respect to the development, 

implementation, and enforcement of environmental laws, regulations, and policies” (USEPA 2010).

Since CCP implementation of any of the alternatives is expected to result in generally positive effects on 

the human environment, there would be little risk of disproportionate negative effects to low income or 

minority groups. Therefore, negligible effects related to environmental justice are anticipated under all 

CCP alternatives.

6.11 Cumulative Effects

The Council of Environmental Quality defines “cumulative effects” as “the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such 

other actions” (40 CFR Part 1508.7). Within the previous discussions, the direct and indirect effects 

associated with implementing the various alternatives have been evaluated in a comprehensive manner. 

Therefore, the cumulative effects analysis is largely complete. Following a brief summary of past actions, 

the analysis in the following discussion primarily focuses on effects associated with reasonably 

foreseeable future events and/or actions both on- and off-refuge. 

As described in Chapters 3, 4, and 5, there has been very little change to the small uninhabited refuge 

islands, rocks, and reefs within the San Juan Islands. However, there have been some modifications to 

Matia, Turn, Smith, and Minor islands. A few human-made structures were developed on these islands 

and limited habitation has occurred in the past. Substantial habitat alterations have occurred in the past on 

Protection Island and many areas of the larger, nearby, inhabited islands within the San Juan Archipelago; 

the mainland areas that surround the Salish Sea have also experienced substantial changes. Many of these 

modifications have resulted in the loss of important habitats including dry Douglas-fir forest and the 

Willamette Valley grasslands, two habitats which exist in limited acreage within these two refuges. A 

variety of government and non-government agencies, including the National Park Service, The Nature 

Conservancy, Bureau of Land Management, U.S. Forest Service, State of Washington, Tribes, and the 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

6-26 Chapter 6. Environmental Consequences 

Service have protected a large number of natural areas along and within the Salish Sea. However, 

alterations and loss of native habitats along with human pressures on protected areas continue at a 

regional scale due to a growing population and the increase in tourism. Loss of old-growth forest 

structure and the introduction of non-native species into these habitats have altered the ecosystem 

processes within the archipelago and the surrounding mainland.

6.11.1 Reasonably Foreseeable Future Refuge Activities

As protected areas, Protection Island and San Juan Islands NWRs, though relatively small in size, are 

extremely important to the persistence of island wildlife. Under both action alternatives, the Service 

would protect and maintain its island habitats and their associated wildlife and plant species. Invasive 

species are likely to become more prevalent on surrounding lands, but on the refuges, active efforts would 

be made to reduce their populations, especially under the Preferred Alternative. 

Under Alternative B, the Complex would emphasize working closely with partners to research, design, 

and implement cooperative studies that would directly contribute toward understanding and maintaining 

or restoring the biological integrity, diversity, and environmental health of the refuges. The Complex 

would improve the availability of off-refuge education and interpretation under Alternative B. 

Under both action alternatives, the Complex would continue to promote and preserve the wilderness 

characteristics of designated San Juan Islands Wilderness areas. Under Alternative B, there would be a 

greater emphasis placed on partnerships focused on reducing the effects of human disturbance to wildlife,

increasing awareness of the refuges, and appreciation for natural resources of the area. 

Because it is anticipated that human population growth within the Salish Sea region will result in 

continuing loss and degradation of wildlife habitats and open space, refuge habitats will become 

increasingly important over the life of the CCP. In concert with other protected lands, the refuges have an 

important role to conserve resident, threatened, and rare species, as well as migratory wildlife species, and 

to provide places where the public can enjoy and appreciate nature. Implementing the CCP would have 

overall beneficial effects to habitats and species. In the context of all of the factors (both natural and 

human-caused) that negatively affect habitats and species (e.g., food availability, marine currents, marine 

debris, human disturbance, and ocean pollution) the positive contributions associated with CCP 

implementation do not represent a major (significant) effect.

6.11.2 Reasonably Foreseeable Future off-Refuge Activities

Aquatic Reserves

In 2008, the State of Washington Department of Natural Resources (DNR) received nominations for 

several aquatic reserves; the agency selected three for full proposal development and review. Two of the 

current aquatic reserve proposals are for aquatic lands adjacent to the refuges: Protection Island Aquatic 

Reserve and Smith and Minor Islands Aquatic Reserve.

The Planning Advisory Committee is in the process of reviewing proposed goals and objectives for the 

Smith and Minor Islands reserve and the Protection Island reserve and is developing a list of management 

actions in which DNR and the local community will engage. A draft management plan for these reserves 

is due soon (summer 2010). Once these draft plans are developed, they will include allowed uses as well 

as strategies for monitoring, research, and restoration actions and management of existing authorized 

uses. The Service is participating in the planning process for both proposed reserves. It is expected that 

the management actions for each reserve will support the objectives of the refuges and result in overall 

beneficial and synergistic effects.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-27

6.11.3 Potential Effects from Global Climate Change

Global climate change and associated changes to the marine environment will have additional impacts on 

island and reef habitats. These changes could have significant negative effects on these refuges; however, 

due to the complexity and unknown elements associated with the severity of change (e.g., sea level rise), 

the magnitude of effects of climate change on the refuges cannot be predicted. Climate change may 

further exacerbate some of the influences affecting environmental consequences that have already been 

described because they are likely to be additive. For instance, increases in the severity and incidences of 

storm events due to climate change will increase the threat of oil spills in this area.

Signs of climate change can currently be seen in the Salish Sea with total annual temperatures increasing 

by 13 percent and annual inflow of fresh water from precipitation and snow melt decreasing. These 

changes have lead to increased instances of harmful algal blooms and areas of low dissolved oxygen. 

This in turn is expected to reduce plankton, the foundation of the food web in the Salish Sea (Snover et al. 

2005). Reduced abundance of plankton will likely reduce forage fish for wildlife that depend on fish for 

nourishment.

Organisms such as seabirds that require specific habitat types face an increased threat from climate 

change because they have a very restricted range of breeding habitats. For instance, terns and gulls that 

typically nest on low-elevation sand spits, beaches, or rocky shorelines are vulnerable to nest flooding and 

loss of habitat due to sea level rise and increased incidences of storm events. Increased El Niño event 

frequency, sea surface warming, and ocean acidification, all partly due to climate change, are already 

affecting seabird species by altering forage fish distribution (Walther et al. 2002; Wormworth and Mallon 

2009). Because seabirds, especially cormorants, will not nest if the right habitat is not available and 

colonies will fail in years of low food resources, climate change has the potential to greatly reduce seabird 

productivity and adult survival.

Long-term climate change is expected to result in local sea level rise, an increase in winter precipitation, 

and increased storm strength and frequency (Huppert et al. 2009; Mote et al. 2008). These factors may 

lead to increased bluff erosion and sand spit degeneration depending on prevailing currents and storm 

tracks. In fact, inundation of low-lying refuge islands is very likely. With an increase in major storm 

events combined with high tides or elevated sea levels, seabird nests placed low on the shoreline will be 

vulnerable to flooding. 

The warming trends within the Salish Sea leading to higher summer temperatures and anticipated minor 

precipitation increases (Mote and Salathé 2009) will likely increase water stress on native vegetation. 

Such stressors increase vulnerability to competition from invasive species. Additionally, warmer 

temperatures and summer drought may lead to increases in fire frequency and severity.

Species distributions are likely to change. Cool, coniferous forests in the western part of the Pacific 

Northwest will contract and be replaced by mixed temperate forests over substantial areas (Mote et al. 

2003). For example, Douglas-fir appears relatively sensitive to low soil moisture, especially on drier sites 

(Case 2004; Hessl and Peterson 2004; Holman 2004 citations in CIG 2004). 

Warmer temperatures could lead to a change in the timing of reproduction, which may lead to different 

timing between flowering and pollinator activity, fruit ripening and foraging by fruit consumers, or 

predator behavior by pest-eating species. Other examples include the freshwater and precipitation 

changes described above that ultimately may affect the availability of forage fish.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

6-28 Chapter 6. Environmental Consequences 

Warmer temperatures could also increase development of insect and pathogen outbreaks and extend their 

growing season. It would be expected that increases in the frequency and extent of outbreaks would 

accompany such changes. Rising ocean temperatures and increased El Niño event frequency may 

increase the potential for bacterial infections as disease vectors change.

6.12 References

Carver, E., and J. Caudill. 2007. Banking on nature 2006: the economic benefits to local communities of 

National Wildlife Refuge visitation. Division of Economics, U.S. Fish and Wildlife Service. 

Washington, D.C. 357 pp.

Case, M. 2004. Fine-scale variability in growth-climate relationships of Douglas-fir and lodgepole pine, 

North Cascade Range, Washington. Master's thesis, College of Forest Resources, University of 

Washington, Seattle. 

Climate Impacts Group (CIG). 2004. Overview of climate change impacts in the U.S. Pacific Northwest. 

Background paper prepared for the West Coast Governors' Climate Change Initiative. University 

of Washington, Seattle, WA. 353pp. Available at: http://cses.washington.edu/db/pdf/cigoverview 

Hessl, A.E. and D.L. Peterson. 2004. Interannual variability in above ground tree growth in Stehekin 

River Watershed, North Cascades Range, Washington. Northwest Science 78:3 204-213. 

Holman, M. 2004. Forest growth response and sensitivity to climatic variability across multiple spatial 

scales in the Olympic Mountains, Washington. Master's thesis, College of Forest Resources, 

University of Washington, Seattle, WA. 

Huppert, D.D., A. Moore, and K. Dyson. 2009. Impacts of climate change on the coasts of Washington 

State. Chapter 8 in The Washington Climate Change Impacts Assessment: Evaluating 

Washington's Future in a Changing Climate. Climate Impacts Group, University of Washington, 

Seattle, Washington. 

Mote, P.W., E.A. Parson, A.F. Hamlet, W.S. Keeton, D.P. Lettenmaier, N. Mantua, E.L. Miles, D.W. 

Peterson, D.L. Peterson, R. Slaughter, and A.K. Snover. 2003. Preparing for climatic change: 

the water, salmon, and forests of the Pacific Northwest. Climatic Change 61:45-88.

Mote, P., A. Petersen, S. Reeder, H. Shipman, and L. Whitely-Binder. 2008. Sea level rise in the coastal 

waters of Washington State. University of Washington Climate Impacts Group and the 

Washington Department of Oceanography. 11 pp.

Mote, P.W., and E.P. Salathé, Jr. 2009. Future climate in the Pacific Northwest in Littell, J.s., M. 

McGuire Elsner,L.C. Whitely Binder, and A.K. Snover (eds). The Washington Climate Change 

Impacts Assessment: Evaluating Washington’s future in a changing climate. Climate Impacts 

Group, University of Washington. Seattle, WA. Available at: 

www.cses.washington.edu/db/pdf/wacciaexecssummary638.pdf

Snover, A.K., P.W. Mote, L. Whitely-Binder, A.F. Hamlet, and N.J. Mantua. 2005. Uncertain future: 

climate change and its effects on Puget Sound. Prepared for the Puget Sound Action Team. 

Climate Impacts Group (Center for Science in the Earth System, Joint Institute for the Study of 

the Atmosphere and Oceans), University of Washington. Seattle, WA. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Chapter 6. Environmental Consequences 6-29

SWCA Environmental Consultants. 2008. Cultural Resource Inventory for the San Juan Islands National 

Wildlife Refuge, Washington. Prepared for U.S. Fish and Wildlife Service. 

U.S. Environmental Protection Agency (USEPA). 2010. Environmental justice. Available at: 

http://www.epa.gov/compliance/environmentaljustice/index.html. Accessed February 1, 2010.

Walther, G-R., E. Post, P. Convey, A. Menzel, C. Parmesan, T.J.C. Beebee, J-M. Fromentin, O. HoeghGuldberg, and F. Bairlein. 2002. Ecological responses to recent climate change. Nature 

416:389-395.

Washington Department of Natural Resources. 2009. Washington Natural Heritage Information System: 

a partial list of animals in Washington. Accessed from 

http://www1.dnr.wa.gov/nhp/refdesk/lists/animal_ranks.html on 11/24/09.

Wormworth, J., and K. Mallon. Bird species and climate change: the global status report V1. Available 

at: http://climaterisk.net/. Accessed June 2009. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-1

Appendix A. Lands

A.1 Introduction

This appendix includes information about refuge establishment authorities, acquisition history, refuge 

purposes, and land status for Protection Island and San Juan Islands Refuges. It documents research that 

was done early in the planning process. Findings from many sources are summarized in this appendix. 

Research included the following: 

• The Service’s national refuge purposes database was consulted. 

• The Service’s Land Record System was reviewed.

• Realty hardcopy files were searched extensively.

• The Tract Record spreadsheet prepared by the GIS branch was consulted.

• Additional documents related to the establishment history of the San Juan Islands NWR which were 

not found in the Service’s files were obtained from Bonneville Power Administration Library in 

Portland, Oregon, and from the DOI national library. 

This appendix also includes information about navigation aids that are on or near refuge lands, and a 

section on habitat protection needs. 

Section Page

Protection Island National Wildlife Refuge A-2

San Juan Islands National Wildlife Refuge A-5

United States Coast Guard Navigation Aids A-10

Habitat Protection Needs A-12
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-2

Protection Island National Wildlife Refuge

Refuge Establishment and Purposes (purposes are bold and italicized)

Refuge establishment was authorized by the Protection Island National Wildlife Refuge Act, Public Law 

97 – 333, Oct 15, 1982 (96 Stat. 1623). “The purposes of the refuge are to provide habitat for a broad 

diversity of bird species, with particular emphasis on protecting the nesting habitat of the bald eagle, 

tufted puffin, rhinoceros auklet, pigeon guillemot, and pelagic cormorant; to protect the hauling-out 

area of harbor seals; and to provide for scientific research and wildlife-oriented public education and 

interpretation (96 Stat. 1623)” and apply to all portions of Protection Island NWR. The first 1.42 acres of 

the refuge were donated by Admiralty Audubon Society “.... in accordance with Public law 97-333 (96 

Stat. 1623) Protection Island National Wildlife Refuge Act (Donation Warranty Deed, December 22, 

1982).” Most of the over 800 tracts that make up the refuge were authorized by the same act and 

purchased from 1983-1987 with funds authorized by the Land and Water Conservation Fund Act of 1965, 

as amended. Purposes of this fund include acquisition of “(d) any areas authorized for the National 

Wildlife Refuge System by specific Acts (16 U.S.C. 460l-9). The Service also has a 20-year, aquatic lands 

lease for the second class tidelands around Protection Island (No 20-013245) from Washington 

Department of Natural Resources (WDNR). This lease is authorized by the Fish

(16 U.S.C.742 f(a)(4)). Also see Table A.1. 

and Wildlife Act of 1956, 

“. . . for the development, advancement, management, conservation, and protection of fish and wildlife 

resources . . .” 

Table A.1. Protection Island Acquisition History and Land Status Summary 

Date 

acquired

# of 

tracts

Interest Acquisition 

authority

Funding 

authority

12/22/82 6 Fee Public law 97-333 donation

6/20/83 1 Fee Public law 97-333 Land and Water 

Conservation 

Fund (LWCF)

7/25/83 4 Fee Public law 97-333 LWCF

8/10/83 1 Fee Public law 97-333 LWCF

8/19/83 1 Fee Public law 97-333 LWCF

9/8/83 1 Fee Public law 97-333 LWCF

9/19/83 1 Fee Public law 97-333 LWCF

1/17/85 1 Fee Public law 97-333 LWCF

4/12/85 10 Fee Public law 97-333 LWCF

4/18/85 15 Fee Public law 97-333 LWCF

4/19/85 12 Fee Public law 97-333 LWCF 

4/26/85 4 Fee Public law 97-333 LWCF

4/29/85 5 Fee Public law 97-333 LWCF

5/6/85 4 Fee Public law 97-333 LWCF

5/7/85 2 Fee Public law 97-333 LWCF

5/8/85 4 Fee Public law 97-333 LWCF

5/10/85 7 Fee Public law 97-333 LWCF

5/13/85 11 Fee Public law 97-333 LWCF

5/14/85 2 Fee Public law 97-333 LWCF

5/15/85 9 Fee Public law 97-333 LWCF 

5/17/85 11 Fee Public law 97-333 LWCF

5/20/85 4 Fee Public law 97-333 LWCF
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-3

Date 

acquired

# of 

tracts

Interest Acquisition 

authority

Funding 

authority

5/21/85 7 Fee Public law 97-333 LWCF

5/22/85 4 Fee Public law 97-333 LWCF

5/24/85 7 Fee Public law 97-333 LWCF

5/28/85 11 Fee Public law 97-333 LWCF

5/29/85 8 Fee Public law 97-333 LWCF

5/30/85 6 Fee Public law 97-333 LWCF 

5/31/85 4 Fee Public law 97-333 LWCF

6/4/85 4 Fee Public law 97-333 LWCF

6/7/85 1 Fee Public law 97-333 LWCF

6/13/85 2 Fee Public law 97-333 LWCF

6/18/85 11 Fee Public law 97-333 LWCF

6/25/85 2 Fee Public law 97-333 LWCF

6/26/85 1 Fee Public law 97-333 LWCF

7/15/85 2 Fee Public law 97-333 LWCF 

7/19/85 4 Fee Public law 97-333 LWCF

7/30/85 3 Fee Public law 97-333 LWCF

8/13/85 1 Fee Public law 97-333 LWCF

8/26/85 2 Fee Public law 97-333 LWCF

9/30/85 2 Fee Public law 97-333 LWCF

1/13/86 4 Fee Public law 97-333 LWCF

1/15/86 2 Fee Public law 97-333 LWCF

1/21/86 4 Fee Public law 97-333 LWCF 

1/23/86 2 Fee Public law 97-333 LWCF

2/11/86 3 Fee Public law 97-333 LWCF

2/13/86 2 Fee Public law 97-333 LWCF

4/3/86 2 Fee Public law 97-333 LWCF

4/11/86 616 Fee Public law 97-333 LWCF

4/22/86 2 Fee Public law 97-333 LWCF

4/25/86 3 Fee Public law 97-333 LWCF

5/28/86 1 Fee Public law 97-333 LWCF 

6/2/87 1 Fee Public law 97-333 LWCF 

1/12/93 1 Lease from Washington State

(No. 20-013245 expires Dec. 31, 

2013)

Fish and Wildlife 

Act of 1956

Donation

Sources: Excel tract report by GIS branch, Land Record System, Georgia Shirilla verified acquisition and 

funding authorities on 2/27/07. 

Land Status 

Protection Island NWR is entirely on an island by the same name in Jefferson County, Washington. 

There are 316 acres of fee title lands within the refuge and an additional 340-acre aquatic lands lease from 

WDNR. The refuge establishment date is reported as December 22, 1982, concurrent with a donation to 

the Service of the first 1.42 acres by Admiralty Audubon Society. As of June 2, 1987, all lands identified 

as within the Protection Island NWR boundary have been acquired. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-4

Aquatic Lands

The 340-acre tideland lease is due to expire on December 31, 2013. There is also a bedland reservation 

and withdrawal “from conflicting uses for an indefinite term from November 22, 1988” of “ . . . the 

bedlands of navigable water owned by the state of Washington, surrounding Protection Island extending 

waterward 600 feet from the line of extreme low water . . .(WDNR 1988, Withdrawal Order 88 017).” 

This withdrawal order further states that public access may be permitted under conditions mutually agreed 

upon by the DNR and DOI. The Service has maintained both the lease area and the withdrawal area as 

closed to the public to protect refuge wildlife. 

Zella Schultz Seabird Sanctuary

Protection Island NWR boundary does not include 48-acres on the west end of the island known as the 

Zella M. Schultz Seabird Sanctuary, which was protected prior to refuge establishment first through 

purchase by The Nature Conservancy in 1972, then by Washington Department of Game (now WDFW) 

acquisition in 1974. This sanctuary bisects the rhinocerous auklet colony. There is an MOU between the 

Service and WDFW for cooperation between the two agency owners and managers of Protection Island. 

Protection Island Extended Users

A number of people with interest in tracts of land on Protection Island prior to establishment of the NWR 

were given extended use of the tracts and access to Protection Island under a variety of terms. Many of 

these terms have already expired and most of the rest will expire in 2011. All current extended users have 

unimproved lots that receive occasional use with the exception of one lifetime user who has a residence 

on the island. See Table A.2 for additional information. 

Extended users reserved a number of rights when the refuge was established. These include the right to 

use their lots for picnicking and overnight camping; the right for pedestrian (or motor vehicle use for 

lifetime user) use of a road system designated by the United States; the right to use, without expense, 

water of the same quality, as presently available from the existing water system, from a central source 

designated by the United States; the right to use the existing marina and associated facilities for entry/exit 

and boat moorage subject to the right of the United States to provide equivalent substitute facilities; the 

right to fish and crab from the dock and from boats in a portion of the marina and the right to walk the 

beach in designated areas from October through February. 

The use of the lot and designated island facilities is limited to the immediate family of the reservation 

holder. In addition personal guests may be allowed to use the reserved premises and designated island 

facilities only when the reservation holder is present. The only lifetime user has the additional right to 

maintain the grounds, have a dog on the premises, to have gardens, and to store firewood on the lot. 

Table A.2. Protection Island NWR Extended Users

Tract # Acre Term of Use

1241 .26 25 years expires 2011

2042 .21 25 years expires 2011

2069 .26 with home life use

2101 .21 25 years expires 2011

25 years expires 2011

25 years expires 2011

25 years expires 2011

2170 .29 25 years expires 2011
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-5

San Juan Islands National Wildlife Refuge

Refuge Establishment and Purposes (purposes are bold and italicized)

San Juan Islands NWR was first established in 1960 to be “. . . reserved under jurisdiction of the Bureau 

of Sport Fisheries and Wildlife, United States Fish and Wildlife Service. . .” (PLO 2249). In 1975 The 

San Juan Islands NWR was consolidated with Smith Island NWR (est. 1914), Matia Island NWR (est. 

1937) and Jones Island NWR (est. 1937) and additional lands were reserved under the name of San Juan 

Islands NWR (PLO 5515). PLO 5515 does not state a purpose for this newly consolidated refuge but an 

earlier proposal published in 38 FR 29831 on Oct 29, 1973, stated it was to “. . .facilitate the 

management of migratory birds for which the United States has a responsibility under international 

treaties and to further effectuate the purposes of the Migratory Bird Conservation Act.” Smith and 

Minor Islands also retain their original establishing purpose from E.O. 1959 “as a preserve, breeding 

ground and winter sanctuary for native birds.” In October of 1976 the San Juan Islands Wilderness was 

established (P.L. 94-557), which added the purposes of the Wilderness Act (P.L. 88-577, Sept. 3, 1964) 

including “. . .to secure for the American people of present and future generations the benefits of an 

enduring resource of wilderness” to all units of the refuge except for Smith, Minor, Turn, Jones Islands, 

and a small portion of Matia Island. Under P.L. 97-333 (1982) and PLO 6489 (1983) Jones Island was 

removed from the San Juan Islands NWR and transferred to the State of Washington for use as a public 

recreation area. Under executive orders since the mid- to late-1800s and in the refuge establishing 

documents it was stated that some islands which are now units of the San Juan Islands NWR retain 

“lighthouse purposes.” These “lighthouse purposes” today translate into a variety of navigation aids 

which are maintained under the jurisdiction of the U.S. Coast Guard. Also see Table A.3. 

Table A.3. San Juan Islands NWR Establishment Authorities, Acquisition History, and 

Refuge Purposes.

Date Legal 

document 

Refuge Lands Relevant action and refuge purposes (bold and 

italicized) 

9/11/1854 Order Smith Island

Minor Island

Reserved certain islands for lighthouse purposes.

7/15/1875 E.O. (unnumbered 

series)

Matia Island

Puffin Island 

Sister’s Is. 

N Peapod Is.

Turn Island 

Jones Island 

Flattop Is.

Skipjack Is.

Reserved 23 tracts of land in the waters north of Puget 

Sound for lighthouse purposes. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-6

Date Legal 

document 

Refuge Lands Relevant action and refuge purposes (bold and 

italicized) 

6/6/1914 E.O. 1959 Smith Island 

Minor Island

Reserved Smith and Minor Islands for use of the USDA 

“as a preserve, breeding ground and winter sanctuary 

for native birds.” The reserve to be known as Smith 

Island Reservation (65 ac). “This order is not intended 

to abrogate the order of September 11, 1854, reserving 

these islands for lighthouse purposes, . . . in addition to 

such use, shall insure the protection of the native birds 

thereon.”

3/30/1937

4/2/1937

E.O. 7594

2 FR 739

Jones Island Established Jones Island Migratory Bird Refuge, 179.07 

ac in San Juan county.

3/30/1937

4/2/ 1937

E.O. 7595

2 FR 741

Matia Island Reserved Matia Island and established Matia Island 

Migratory Bird Refuge “. . . as a refuge and breeding 

ground for migratory birds and other wildlife.” “The 

Executive order of July 15, 1875, reserving certain 

public lands for lighthouse purposes, is hereby revoked 

in so far as it applies to the above-described land. Matia 

Island is 145 ac in San Juan County. 

7/25/1940

7/30/1940

Proc. 2416

5 FR 147

Jones Island 

Matia Island 

Smith Island 

Minor Island

Changed the names of various reserves and migratory 

bird refuges to National Wildlife Refuges.

12/24/1960

1/10/1961

PLO 2249

26 FR 165 

Williamson

Rocks

Colville Is. 

Bird Rocks 

Turn Island 

Bare Island

Jones Island

Established San Juan Islands NWR 1960 to be “. . . 

reserved under jurisdiction of the Bureau of Sport 

Fisheries and Wildlife, United States Fish and Wildlife 

Service. . .” for a total of 52 acres in San Juan and Skagit 

Counties. Added 9.02 acres to Jones Island NWR for a 

total of 188.09 in San Juan County. Partly revoked 

Executive Order of July 15, 1875 reserving certain 

lands for lighthouse purposes, as far as they affect Turn 

Island and Jones Island. 

1/6/67

1/12/1967

PLO 4148

32 FR 320

Buck Island Added Buck Island (1ac) to San Juan Islands NWR. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-7

Date Legal 

document 

Refuge Lands Relevant action and refuge purposes (bold and 

italicized) 

7/3/1969 Letter Puffin Is. Travis S. Roberts, Acting Regional Director, requested 

concurrence from U.S. Coast Guard on FWS secondary 

withdrawal for wildlife management of Puffin Island “. . . 

to insure protection and maintenance of natural nesting 

habitat for numerous sea birds. The only development 

proposed is posting the island as a National Wildife 

Refuge, no public use will be permitted during the 

nesting season.”

11/6/1969 43 FR 

17972

Puffin Island Notice of Proposed withdrawal of Puffin Island “ as an 

addition to Matia Island National Wildlife Refuge for the 

management of migratory birds and other wildlife.”

9/3/1970 PLO 4889

35 FR 

14317

Puffin Island Added Puffin Island, 10 ac (tract 1a) to Matia Island 

NWR, secondary to U.S. Coast Guard jurisdiction for 

lighthouse purposes. 

10/18/1973

10/19/1973

Notice 

38 FR 

29831

All units Proposed withdrawal of lands and consolidation of 

national wildlife refuges into the San Juan Islands 

National Wildlife Refuge which will “. . .facilitate the 

management of migratory birds for which the United 

States has a responsibility under international treaties 

and to further effectuate the purposes of the Migratory 

Bird Conservation Act.”

8/27/1975

9/4/1975

PLO 5515

40 FR 

40811

All units Reserved lands for the San Juan Islands NWR 388.32 

acres in Island, San Juan, Skagit, and Whatcom Counties. 

Revoked EOs 1959, 7594, 7595, PLO’s 2249 and 4148 

and 4889 insofar as they affect any of the islands 

described in this PLO but does not alter jurisdiction for 

lighthouse purposes provided for by EO of July 15, 

1975. 

7/22/1976

7/29/1976

PLO 5594

41 FR 

31535

Corrected PLO 5515 to delete all reference to EO 1959 

and PLO 2249. Amended PLO 5515 to include an 

additional 69.5 acres of San Juan County islands in the 

San Juan Islands NWR. Total Refuge acres 457.82

10/19/1976 P.L. 94-557 All units 

except Smith, 

Minor, Turn, 

Jones, and 

part of Matia

Designates as wilderness: “(p) certain lands in the San 

Juan Islands National Wildlife Refuge, Washington, 

which comprises approximately three hundred and fifty 

five acres, which are depicted on a map entitled “San 

Juan Islands Wilderness Proposal”, dated August 1971 

(revised July 1976), and which shall be known as the San 

Juan Wilderness.” 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-8

Date Legal 

document 

Refuge Lands Relevant action and refuge purposes (bold and 

italicized) 

10/15/1982 P.L. 97-333 

(96 Stat 

1623)

Jones Island In consideration of the prior transfer of certain properties 

now in the San Juan NWR by Washington State Parks 

and Recreation Commission to DOI, transfers ownership, 

jurisdiction, and control of Jones Island NWR to the State 

of Washington for use as a public recreation area. 

10/14/1983

10/24/1983

PLO 6483

48 FR 

49022

Dot Island Eliminated Dot Island from SJNWR by correcting the 

land description in PLO 5515 to delete No. 67, Dot Island 

which consists of one large island with a small islet 

immediately to the southwest. 

10/27/1983

11/4/1983

PLO 6489

48 FR 

50895

Jones Island Revoked executive order 7594 and in part PLO 2249 

which had established and added to Jones Island NWR. 

Land Status 

The San Juan Islands NWR consists of mostly small islands, islets, rocks, and reefs scattered across a large 

area in Puget Sound. Refuge units are located in four Washington State counties: Island, San Juan, Skagit, 

and Whatcom. As far as we can tell all units currently within the San Juan NWR were always under federal 

ownership ever since they became part of the United States. The Service has primary interest on all refuge 

units except for those withdrawn for lighthouse purposes prior to refuge establishment. In those cases the 

Service is presumably secondary to the U.S. Coast Guard who maintains navigation aids on these islands.

An estimated nineteen of the 83 refuge units have navigation aids, however, we do not have a record of when 

each of the navigation aids was authorizing and therefore we cannot determine if we are primary or 

secondary in all cases. Also see Table A.4. Determining acreage of small islands above the mean high tide 

is inherently difficult. Total refuge acreage is reported as 448.53 and wilderness acres as 353.0 in the Annual 

Report of Lands Under the Control of the USFWS (2008). 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-9

United States Coast Guard Navigation Aids

The U.S. Coast Guard (USCG) operates and maintains a number of aids to navigation structures on or 

immediately adjacent to refuge islands in the San Juan Islands and Protection Island (see Table A.4). 

Nineteen of these are covered under a 2005/2006 Memorandum of Understanding between the Service and 

the USCG. 

Table A.4 USCG Navigation Aids on or immediately adjacent 

to San Juan Islands NWR and Protection Island NWR. 

FWS # Navigation Aid Name LLNR1 Position Year 

Established

Original

Authority2

6 Boulder Reef Lighted Bell Buoy "2" 19500 48 38 17N

122 41 42W

7 Davidson Rock Light "1" 19325 48 24 48 N

122 48 43 W 1933

EO 1875, 

tidal zone

24 Harbor Rock 19680 48 28 18 N

122 58 23 W

25 North Pacific Rock3

29 Pole Pass Light "2" 19655 48 36 06N

122 59 24W

33 Center Island Reef Daybeacon 19385 48 29 04N

122 50 11W

39 Flattop Island4

EO 1875

42 Skipjack Island Light 19805 48 43 58 N

123 02 21 W 1933 EO 1875

44 Clements Reef Danger Buoy 19860 48 45 46N

122 52 07W

46 Parker Reef Light 19840 48 43 33 N

122 53 40 W 1957 tidal zone

47 The Sisters Light "17" 19515 48 41 40 N

122 45 25 W 1972 EO 1875

49 Wasp Passage Light "5" 19660 48 35 71 N

122 58 60 W 1948 tidal zone

52 Turn Rock Light "3" 19590 48 32 06 N

122 57 54 W 1957

EO 1875?, 

tidal zone

53 Shag Rock Daybeacon 19445 48 35 30 N

122 52 31 W 1959 tidal zone

56 Lawson Rock Danger Daybeacon 19410 48 31 48N

122 47 18W 1937 tidal zone

58 Black Rock Light "9" 19455 48 32 45 N

122 45 57 W 1960 tidal zone

59 Peavine Pass Rocks Daybeacon 19460 48 35 19 N

122 48 04 W 1960 tidal zone 

64 Peapod Rocks Light "15" 19490 48 38 32 N

122 44 37 W 1933 EO 1875?
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-10

FWS # Navigation Aid Name LLNR1 Position Year 

Established

Original

Authority2

65 Eliza Rocks Junction Light 19215 48 38 60 N

122 34 70 W 1940

66 Viti Rocks Light 19200 48 38 00 N

122 37 22 W 1939

66 Viti Rocks Lighted Bell Buoy "9" 19205 48 37 48 N

122 37 08 W

68 Bird Rocks Light 19645 48 35 52 N

123 00 53 W 1958

75 Smith Island Light 16375 48 19 06 N

122 50 38 W 1961 EO 1854

76 Minor Island Light 16380 48 19 27 N

122 49 09 W 1931 EO 1854

78 Puffin Island Shoal Light "19" 19530 48 44 36 N

122 49 00 W 1933 EO 1875

80 Belle Rock Sector Light 19395 48 29 35 N

122 45 10 W

81 Williamson Rocks Lighted Gong Buoy "4" 19335 48 26 50 N

122 42 25 W

NA Protection Island Southwest Spit Buoy "1" 16460 48 06 52N

122 57 54W 1 USCG Light List Number

2 According to the USCG, special authority is not needed to establish a navigation aid in tidal areas. 

3 There are no navigation aids at this location however this location is included in the 2005/2006 MOU between the 

Service and the USCG.

4 There are no navigation aids at this location however the authority for one was included in E.O. 1875 which to our 

knowledge has not been revoked. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix A – Lands A-11

Habitat Protection Needs 

Some habitat protection needs have already been identified in Chapter 2 of the Draft CCP. These include 

extending refuge law enforcement authority to WDFW lands on Protection Island and working with WDNR 

and other partners to enhance buffers around refuge islands. These actions are needed to prevent habitat 

damage and reduce human-caused wildlife disturbance. The Service is also participating in meetings and 

plans are underway for establishment of aquatic reserves that would include the waters around Protection 

Island and around Smith/Minor Islands. 

Additional habitat protection above and beyond that identified in Chapter 2 of this CCP is needed to ensure 

the long-term viability of wildlife associated with Protection Island and the San Juan Islands NWR in the 

face of climate change and human population growth. 

The future condition of refuge shorelines is anticipated to be adversely affected by sea level rise associated 

with climate change. Likely effects due to sea level rise and other climate-related factors include increased 

inundation, erosion, and overwash during storm events, leading to losses of shoreline habitats (Mote et al. 

2008, Huppert et al. 2009). Habitat specialists, such as black oystercatchers, face increased threats from 

climate change since they have a very restricted range during the breeding season. Oystercatchers, marine 

mammals, terns, and gulls are particularly vulnerable to loss of habitat and reproductive failure due to sea 

level raise because they typically nest on low-laying spits or sandy shorelines. Identification and protection 

of alternative shorelines would help protect these species. Habitats of interest would include spits, sandy or 

rocky shoreline. 

Due to the scarcity of small islands suitable for nesting seabirds and other marine wildlife, their protection is 

warranted whenever possible. If other islands within the Salish Sea become available they would be 

evaluated for their conservation potential and considered for inclusion into the Refuge System or another 

form of habitat protection. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix B – Rocks, Reefs, and Islands within San Juan National Wildlife Refuge B-1

Appendix B. Rocks, Reefs, and Islands within

 San Juan Islands National Wildlife Refuge

B. Introduction

This appendix provides information on the locations, habitat types, wildlife, wilderness status, and 

physical attributes of the various rocks, reefs, and islands contained within San Juan Islands National 

Wildlife Refuge. Aerial photographs provide an additional identification aid. The numbering system of 

the 83 rocks, reefs, and islands contained within the refuge was first established in the San Juan Islands 

Wilderness Proposal of August 28, 1971, and has been retained and used in several subsequent 

publications and research databases. All units of the refuge lie within the San Juan archipelago, with the 

exception of Smith and Minor Islands, which are located approximately seven miles south of Lopez 

Island. Because of the limited availability of the habitat preserved and the intent to provide an 

undisturbed haven for wildlife, all but Turn and Matia Islands are closed to public use.

 

The San Juan Islands Wilderness was established on October 19, 1976, by public law 94-577. All the 

islands within the refuge, except for Smith, Minor, Turn, and five acres of Matia Island, are designated 

wilderness.

The information within this appendix was gathered from several sources and has been narrowed to 

provide a few of the most vital statistics. Physical descriptions of the islands were obtained from the San 

Juan Islands Wilderness Proposal of August 28, 1971. Data pertaining to wildlife species, plant species, 

and overall habitat types found on the islands were collected through a series of surveys conducted by 

refuge staff between 2000 and 2009. Observations collected by the Whale Museum’s Soundwatch 

program in 1997 were also consulted on these topics. Latitude and longitude coordinates and island 

acreages were provided by the Region 1 Realty and Information Branch of the USFWS. Information on 

navigational aids was compiled from the U.S. Coast Guard 13th District Management Branch 2009 Aid 

Assignment List and verified using National Oceanic and Atmospheric Administration Electronic 

Navigational Charts from 2008-2009 and the observations of refuge staff. Although much of the provided 

information is dynamic and may fluctuate with time, this document was compiled to provide a brief 

reference to the resources managed within the refuge.










































Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-1

Appendix C. Habitats and Wildlife 

C. Introduction

In preparing this plan, the Service reviewed other local, regional, and national plans that pertain to the 

wildlife and habitats of Protection Island and San Juan Islands NWRs. The Service also sought input 

from Washington State conservation agencies, non-governmental organizations, and the general public. 

Refuge purposes, as stated in the enabling legislation for each refuge, were carefully reviewed as was the 

refuges’ contribution to maintenance of Biological Integrity, Diversity, and Environmental Health 

(BIDEH) within the ecoregion. As a result of this information gathering and review process, a 

comprehensive list of resources of concern (Section C.1) was developed. From this list, those species and 

habitats that are most representative of refuge purposes and habitats, BIDEH, as well as other Service and 

ecosystem priorities, were chosen as priority resources of concern (habitat types) and focal resources 

(plant and animal species) (presented in Section C.2). BIDEH considered as Priority Resources of 

Concern are listed below in Section C.3. Important elements of BIDEH are presented according to A 

Marine and Estuarine Habitat Classification System for Washington State (Dethier 1990) and classified 

by vegetation type descriptions according to the International Terrestrial Ecological System Classification 

under development by NatureServe and its natural heritage program members in Section C.4. The last 

section (C.5) in this appendix contains the common and scientific names of plant and animals species 

mentioned in the entire CCP. 
Page 1 of 5

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

A B C D E F G H I J K L M N O P

Comprehensive List of Resources of Concern for Protection Island and San Juan Islands NWRs Potential Resources of Concern Considered PI Purposes SJI+PI Purposes Mig bird1 Fed. ESA Status2 State Status3 State Rank WNHP4 MMPA species5 USFWS Bird of Mgt. Concern or Bird of Conservation Concern6 Pacific Retion Seabird Plan7 N Pacific Coast Shorebird Plan8 WA CWCP Priorities9 WPG EA Tar.10

Refuge Occurance Ecological Significance Selection

SEABIRDS

Rhinocerous Auklet

√ √

S4B S4N HC

√

breeding colonies on PI and Smith 

Island (SJI)

3rd largest colony in NA on PI selected

Tufted Puffin 

√ √

SC C S3S4B, S4N MC

√ √

breeding colonies on PI and Smith 

Island (SJI)

Federal Species of Concern; 

State Candidtate. PI and 

Smith represent last know 

breeding colonies in 

SJI/Puget Sound

selected

Pigeon Guillemot

√ √

S4B S4N MC

√

widely spread nesting colonies on the 

Refuges

represents 30-40% of 

SJ/Puget Sound breeding 

pop. 

selected

Pelagic Cormorant

√ √

S4B,S4N BCR5 HC

√

nests on PI and selected islands in 

SJI, roosts on additional islands 

refuges provide undisturbed 

breeding sites for this species 

that is frequently harassed.

selected

Glaucous-winged/ 

Western Gulls

√

S5B, S5N 

S4B,S4N

NAR

√

large colony on PI -breeds on select 

islands in SJI. 

PI supports one of the largest 

colonies in the Salish Sea 

and other large colonies on 

SJI

selected

Marbled Murrelet

√

T T S3 T/E HC

√ √

not observed on the refuges but 

forage in waters around the refuges

Federal and State 

Threatened species; refuge 

islands not ecologically 

signigicant to this species

not selected because 

species does not use 

the refuges

Double-crested 

Cormorant

√ √

S4S5B NAR

√

nests on PI and select islands in SJI, 

roosts on additional islands 

refuges provide undisturbed 

breeding sites for this species 

that is frequently harassed.

selected, colonies in 

BC and WA have 

declined (USFWS 

2005-seabird plan)

Brandt's Cormorant

√

C S3B,S4N MC

√

very rare breeding, primarily nonbreeding roostsnot selected habitat 

needs will be met by 

management for 

other cormorants

Heermann's Gull √ S5N MC √ summer/fall migrant throughout SJI not selected

Caspian Tern

√

M S3B BCR5 MC

√

none, possible nesting habitat on PI 

and Smith/Minor Islands

Low potential for alternate 

breeding colony sites. 

not selected

Arctic Tern

√

M S2B BCR5 MC

√ √

Low potential for alternate 

breeding colony sites. 

not selected

Brown Pelican

√

SC E S3N HC

√

transient - rare fall use of shorelines Federal Species of Concern; 

State Endangered

not selected

SHOREBIRDS
Page 2 of 5

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A B C D E F G H I J K L M N O P

Potential Resources of Concern ConsideredPI PurposesSJI+PI Purposes Mig bird1Fed. ESA Status2 State Status3 State Rank WNHP4MMPA species5USFWS Bird of Mgt. Concern or Bird of Conservation Concern6Pacific Retion Seabird Plan7N Pacific Coast Shorebird Plan8WA CWCP Priorities9 WPG EA Tar.10

Refuge Occurance Ecological Significance Selection

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

Black Oystercatcher

√

M S4 N, R1, 

BCR5

4

√ √

Refuges provide important habitat 

year round. Many of the refuge rocks 

and islands have breeding pairs. 

indicator species, high 

conservation priority, refuges 

support a high percentage of 

breeding birds

selected

Black Turnstone 

√

S4S5N 4

√

migrant/winter on PI and most SJI refuge does not support a 

significant portion of the 

population.

not selected

Ruddy Turnstone

√

S4N 4

√

migrant refuge does not support a 

significant portion of the 

population.

not selected

Surfbird

√

S4N 4

√

migrant/winter on PI and most SJI refuge does not support a 

significant portion of the 

population.

not selected

Rock Sandpiper

√

S3N N 3

√ √

migrant/winter refuge does not support a 

significant portion of the 

population.

not selected

Wandering Tattler

√

S3N 3

√

migrant refuge does not support a 

significant portion of the 

population.

not selected

Black bellied Plover

√

S4N 3

√

migrant/winter refuge does not support a 

significant portion of the 

population.

not selected

Sanderling

√

S4N 4

√

migrant/winter refuge does not support a 

significant portion of the 

population.

not selected

Dunlin

√

S4S5N 3

√

migrant/winter refuge does not support a 

significant portion of the 

population.

not selected

Western Sandpiper

√

S4S5N 3

√

migrant refuge does not support a 

significant portion of the 

population.

not selected

Killdeer

√

S4S5B 

S4S5N

3

√

breeding refuge does not support a 

significant portion of the 

population.

not selected

WATERFOWL

Black Brant

√

S3N GBBD

C √ √

migrant/winter - PI, Smith, possible 

on other islands

not selected

Harlequin Duck

√

S2B,S3N GBBD

C √

year round, molting, migration to 

Smith, PI

medium priority in Sea duck 

plan

not selected

Mallard

√

S5B,S5N GBBD

C

year-round refuge does not support a 

significant portion of the 

population.

not selected
Page 3 of 5

2

A B C D E F G H I J K L M N O P

Potential Resources of Concern ConsideredPI PurposesSJI+PI Purposes Mig bird1Fed. ESA Status2 State Status3 State Rank WNHP4MMPA species5USFWS Bird of Mgt. Concern or Bird of Conservation Concern6Pacific Retion Seabird Plan7N Pacific Coast Shorebird Plan8WA CWCP Priorities9 WPG EA Tar.10

Refuge Occurance Ecological Significance Selection

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

Canada Goose ssp 

moffita & maxima √

S5B,S5N year-round introduced residents not selected

OTHER WATERBIRDS

Great Blue Heron √ M S4S5B S5N √ year-round not selected

RAPTORS

Bald Eagle

√ √

SC S S4B S4N N, R1, 

BCR5

√

~ 10+ territories encompas refuges, 

immatures, common throughout the 

year, abundant spring - August. 

Refuge purpose species; 

high conservation priority 

dispite recent delisting; 

selected

Peregrine Falcon ssp 

peals 

√

SC S S2B S3N N, R1, 

BCR5

√

forages on the refuges, Observed 

almost daily during the breeding 

season off of PI. 

Federal Species of Concern; 

State Sensitive thought 

refuges do not support a nest

not selected

Great-horned Owl √ S5 1-2 pr. breeding on PI not selected

Short-eared Owl

√

S2S3B S3N N, R1 former breeding on PI, current status 

unknown

not selected

Snowy Owl

√

M S3N eruptive species present on PI in 

some years during the winter

not selected

Northern Harrier

√

S3B S3N 2004 last known active breeding on 

PI

not selected

American Kestrel √ S4S5B 1 pr.breeding on PI not selected

OTHER LANDBIRDS

Streaked Horned Lark

√

C E S1B N, R1, 

BCR5

√

Small remnant pop. In Puget sound - 

not observed on refuges 

Federal Candidate; State 

Endangered, though very 

limited habitat on refuges - sp 

experts believe PI size too 

limited

not selected

Purple Martin

√

C S3B

√

very limited breeding on PI very few breeding pairs in 

WA - citizen recovery effort

not selected

Savanna Sparrow √ S4N,S5B breeding on PI common species not selected

MARINE MAMMALS

Steller Sea Lion T T S2N

√ √ √

Observed in low numbers during the 

nonbreeding period

Threatened and MMPA 

species

selected

CA Sea Lion SNA

√ √

Observed during the nonbreeding 

period

MMPA species selected

Elephant Seal SNA

√

Breeding, pupping, molting on PI MMPA species; recolonizing 

refuges

selected

Harbor Seal

√

M S4

√ √

Abundant species observed on 

almost all refuge islands during 

breeding and non breeding periods

MMPA species selected

Sea otter E S2S3

√ √

Very few sightings historically in 

waters off refuge

not selected

OTHER MAMMALS
Page 4 of 5

2

ABCDEFGHIJKLMNOP

Potential Resources of Concern ConsideredPI PurposesSJI+PI Purposes Mig bird1Fed. ESA Status2 State Status3 State Rank WNHP4MMPA species5USFWS Bird of Mgt. Concern or Bird of Conservation Concern6Pacific Retion Seabird Plan7N Pacific Coast Shorebird Plan8WA CWCP Priorities9 WPG EA Tar.10

Refuge Occurance Ecological Significance Selection

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

Northern River otter S4 Year-round on PI, many observations 

in SJI

not selected

Black-tailed Deer S5 Feb, 2010 count of 71 deer on PI; 

observations noted in the SJI at all 

times of year

very high densities on PI are 

beginning to affect seabird 

breeding habitat

not selected 

AMPHIBIANS AND 

REPTILES

garter snake 3spp S5 On PI and Matia. Study indicated PI species 

are genetically different 

not selected

western toadC S3

√

none known on refuges, despite 

limited surveys (Matia)

not selected

INSECTS

Valley silverspot, 

Speyeria zerene 

bremerii

SCC S2S3

√

no known occurrence but potential 

habitat in SJI

Federal Species of Concern; 

State Canditate 

not selected

Island Marble, Euchloe 

ausonides insulanus

SCC S1

√

no known occurrence but potential 

habitat in SJI

Federal Species of Concern; 

State Canditate 

not selected

Taylor's CheckerspotCE S1

√

no known occurrence but potential 

habitat on PI

Federal Candidate; State 

Endangered - second largest 

population in the state found 

on nearby Miller Penninsula.

not selected

RARE PLANT 

SPECIES

Castilleja levisecta, 

(golden paintbrush)

TE S1 none found on refuges but refuge 

lands might provide suitable habitat

 Threatened Species selected

Opuntia fragilis (brittle 

prickly-pear cactus)

E SNR SJI (Castle, Rum, Aleck, Fortress); 

historically on PI

State Endangered Species selected

Ranunculus californicus 

(California buttercup)

E S1 SJI (Aleck and Castle) State Endangered Species selected

Sanicula arctopoides 

(bear's foot sanicle)

SCE S1 SJI (Boulder) State Endangered Species selected

Boschniakia hookeri 

(Vancouver 

groundcone)

R1 S3 Found on PI only not selected

Oxytropis campestris 

var. gracilis (slender 

crazyweed)

S S2 SJI (Swirl) not selected

Puccinellia nutkaensis 

(Alaska alkaligrass)

S S2 SJI (Swirl Rock, Secar, island w of 

Castle)

not selected
Page 5 of 5

2

A B C D E F G H I J K L M N O P

Potential Resources of Concern ConsideredPI PurposesSJI+PI Purposes Mig bird1Fed. ESA Status2 State Status3 State Rank WNHP4MMPA species5USFWS Bird of Mgt. Concern or Bird of Conservation Concern6Pacific Retion Seabird Plan7N Pacific Coast Shorebird Plan8WA CWCP Priorities9 WPG EA Tar.10

Refuge Occurance Ecological Significance Selection

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

ECOLOGICAL 

SYSTEMS

Shoreline

√

Shoreline common to all refuge 

islands consisting of spit, 

sandy/gravel, rocky or rocky cliff 

habitats

very important marine 

ecosystem component

selected

Sandy Bluff Protection and Smith islands important habitat for 

rhinoceros auklet nesting in 

the Salish Sea

selected

Grasslands,Savannas 

and Herbaceous Bald √

Protection, Smith and select SJI native praires are rare selected

Forests and Woodland

√

old-growth stand on Matia Island (in 

SJI), smaller and younger stands on 

a few other islands in SJI and PI; 

Garry oak on Turn Island (in SJI) and 

possibly other islands

very little old growth left; 

Garry oak is a severely 

declined veg type 

selected

Wetland

√

Currently no more than 1 ac of 

wetlands consisting of: 1 freshwater 

wetland on Matia Island and 1 

brackish wetland on Smith. PI 

supported a brackish wetland prior to 

construction of the marina, however 

that wetland no longer exists

ucommon on islands within 

the Salish Sea

selected

6 USFWS Bird of Management Concer and Birds of Conservation Concern 2008 lists - N = National; R1 = Region 1; BCR5 = Bird Conservation Region 5; GBBDC - 

7 Pacific Region Seabird Conservation Plan status - HC = High Concern; MC = Moderate Concern; NAR = Not at Risk

8 Northern Pacific Coast Regional Shorebird Conservation Plan status - 4 = High Concern; 3 = Moderate Concern

9 Washington Comprehensive Wildlife Conservation Plan priority species

10 Willamette Valley/Puget Trough Ecoregional Assessment Conservation Target

5 Species listed under the Marine Mammal Protection Act

1 Cited in the Refuge Puporse 

2 Status under the Endangered Species Act - E = Endangered; T = Threatened; C = Candidate; SC = Species of Concern

3 State listing status - E = Endangered; T = Threatened; C = Candidate; S = Sensitive; M = Monitor; R1 = More date required to review status

4 Washington Natural Heritage Program state rank - see http://www1.dnr.wa.gov/nhp/refdesk/lists/animal_ranks.html#key for a description of ranks
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-7

C.2 Protection Island and San Juan Islands NWRs Priority Resources of Concern and Focal Resources

Focal 

Resources Habitat Type Habitat Structure and Other Ecological Requirements Life History Other Benefiting Species

Shoreline

Pelagic 

Cormorant Rocky Cliffs

• Human disturbance is minimized near rocky shoreline 

and cliff habitat used by breeding cormorants, 

oystercatcher, and marine mammals year-round on all 

refuge islands.

• PI, Smith, Minor shorelines are cleaned of marine debris 

annually; other San Juan Island NWR shorelines are 

cleaned once every 5 years on a rotational basis.

• No non-native rats or rabbits on any refuge islands.

• Reduce impacts from other mammalian predators.

Year-round Brandt’s cormorant, peregrine falcon, 

swallows

Double-crested 

Cormorant Rocky Cliffs • See Habitat Structure and Other Ecological Requirements 

for Pelagic Cormorant above. Year-round Brandt’s cormorant, peregrine falcon, 

swallows

Pigeon 

Guillemot

Sandy/Gravel 

Shoreline

• Continued long shore sandy/gravelly movement and 

deposition.

• Presence of large continuous expanses of driftwood piles 

with cavities suitable for pigeon guillemot nesting and 

camouflage of guillemot and oystercatcher chicks. 

• Remove creosote pilings from marina on Protection 

Island.

• PI and Smith/Minor shorelines are cleaned of marine 

debris annually.

• No non-native rats or rabbits on any refuge islands.

• Reduce impacts from other mammalian predators.

Year-round

Harlequin duck, brant, dunlin, 

western sandpiper, black and ruddy 

turnstone, surfbird, rock sandpiper, 

wandering tattler, killdeer, great blue 

heron, brown pelican, snowy owl, 

peregrine falcon, river otter, herring,

and sand lance
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-8

Glaucouswinged Gull Spit

• Sparse (<30% cover), medium (3-4 foot) grasses.

• Vegetation associated with North Pacific Maritime 

Coastal Sand Dune and Strand.

• Natural screens (e.g., driftwood or variation in 

topography) for concealment from nearest nests are 

present.

• <25% invasive species (e.g., Scotch broom or Spartina 

grass) on spit habitat.

• Eliminate disturbance and impacts from deer.

• No non-native rates or rabbits on any refuge islands.

• Reduce impacts from mammalian predators.

• PI, Smith/Minor shorelines are cleaned of marine debris 

annually.

Year-round Heermann’s gull, Caspian tern, and 

snowy owl 

Black 

Oystercatcher Rocky Shoreline

• Human disturbance on Matia and Turn is minimized 

during oystercatcher nesting and brood rearing periods 

(April – Sept).

• Plus see Habitat Structure and Other Ecological 

Requirements for Pelagic Cormorant above.

Year-round 

Brant, harlequin duck, black and 

ruddy turnstone, surfbird, rock 

sandpiper, wandering tattler, 

peregrine falcon, brown pelican, great 

blue heron, river otter 

Harbor Seal

Spit, Rocky and 

Sandy/Gravel 

Shorelines

• See Habitat Structure and Other Ecological Requirements 

for Pelagic Cormorant, Pigeon Guillemot, and Glaucouswinged Gull above.

Year-round

Harlequin duck, brant, dunlin, 

western sandpiper, black and ruddy 

turnstone, surfbird, rock sandpiper, 

wandering tattler, killdeer, great blue 

heron, brown pelican, snowy owl, 

peregrine falcon, river otter, herring,

and sand lance

Elephant Seal

Spit, Rocky and 

Sandy/Gravel 

Shorelines

• See Habitat Structure and Other Ecological Requirements 

for Pelagic Cormorant, Pigeon Guillemot, and Glaucouswinged Gull above.

Year-round

Harlequin duck, brant, dunlin, 

western sandpiper, black and ruddy 

turnstone, surfbird, rock sandpiper, 

wandering tattler, killdeer, great blue 

heron, brown pelican, Heermann’s 

gull and Caspian tern, snowy owl, 

peregrine falcon, river otter, herring 

and sand lance

Steller Sea Lion

Spit, Rocky and 

Sandy/Gravel 

Shorelines

• See Habitat Structure and Other Ecological Requirements 

for Pelagic Cormorant, Pigeon Guillemot, and Glaucouswinged Gull above.

Non-breeding

Brant, harlequin duck, black and 

ruddy turnstone, surfbird, rock 

sandpiper, wandering tattler, 

peregrine falcon, brown pelican, great 

blue heron, river otter
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-9

California Sea 

Lion

Spit, Rocky and 

Sandy/Gravel 

Shorelines

• See Habitat Structure and Other Ecological Requirements 

for Pelagic Cormorant, Pigeon Guillemot, and Glaucouswinged Gull above.

Non-breeding

Brant, harlequin duck, black and 

ruddy turnstone, surfbird, rock 

sandpiper, wandering tattler, 

peregrine falcon, brown pelican, great 

blue heron, river otter

Sandy Bluffs 

Rhinoceros 

Auklet Sandy Bluffs

• > 75% of the vegetation is composed of species 

associated with the Willamette Valley Upland Prairie and 

Savanna and North Pacific Coastal Cliff and Bluff

ecological systems. 

• At least 50% vegetative cover at the beginning of the 

rainy season.

• <25% invasive plant species (e.g., cheat grass).

• No Scotch broom or other invasive shrub species.

• Eliminate disturbance and impacts to habitats from deer. 

• No non-native rats or rabbits.

• Reduce impacts from other mammalian predators.

Breeding Canada goose, and snowy owl 

Tufted Puffin Sandy Bluffs • See Habitat Structure and Other Ecological Requirements 

for Rhinoceros Auklet above. Breeding Canada goose, swallows, snowy owl

Savanna, Grassland, and Herbaceous Bald

Golden 

Paintbrush Grassland

• <15-20% canopy cover of trees and native shrubs.

• >50% cover of native grasses and native forbs of the 

Willamette Valley Upland Prairie and Savanna 

ecological system.

• <25% cover of non-native plant species.

• <10% cover of invasive plant species.

• No presence of English ivy, Scotch broom, or other new 

noxious weed invaders. 

• Eliminate disturbance and impacts to habitats from deer 

and rabbits.

Year-round

northern harrier, American kestrel, 

short-eared owl, streaked horned lark, 

swallows, purple martin,, savanna 

sparrow, black-tailed deer, valley 

silverspot, island marble, Taylor’s 

checkerspot

Brittle Pricklypear CactusGrassland and 

Sandy Bluffs

• See Habitat Structure and Other Ecological Requirements 

for Golden Paintbrush above. Year-round

See species listed for golden 

paintbrush above, plus Canada goose, 

swallows, snowy owl

California 

Buttercup

Grassland and 

Sandy Bluffs

• See Habitat Structure and Other Ecological Requirements 

for Golden Paintbrush above. Year-round See species listed for brittle pricklypear cactus

Bear’s Foot 

Sanicle

Grassland and 

Sandy Bluffs

• See Habitat Structure and Other Ecological Requirements 

for Golden Paintbrush above. Year-round

See species listed for brittle pricklypear cactus
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-10

Forests and Woodlands

Bald Eagle Forests and 

Woodlands

• >25% canopy cover of trees (e.g., Douglas fir, madrone, 

Garry Oak, lodgepole pine) of the North Pacific DouglasFir Forest and Woodland and the North Pacific Maritime 

Dry Mesic Douglas-fir -Western hemlock Forest.

• >50% cover of native shrubs (e.g., ocean spray, Nootka 

rose) in understory.

• <10% cover of invasive plant species (e.g., Himalayan 

blackberry and Evergreen blackberry).

• Forest patches are connected.

• No presence of English ivy, English holly, Scotch broom, 

Dalmatian toadflax, garlic mustard, or other new noxious 

weed invaders. 

• Eliminate disturbance and impacts to habitats from deer. 

• No non-native rats or rabbits.

• Reduce impacts from other mammalian predators.

Year-round

Downy, hairy, and pileated 

woodpeckers, olive-sided flycatcher, 

American kestrel, great horned owl, 

and bats

Wetlands

Biological 

Integrity Wetlands

• No invasive aquatic species (e.g., green crab or spartina).

• No non-native rats or rabbits on any refuge islands.

• Reduce impacts from other mammalian predators. 

Year-round in 

brackish; 

potentially 

seasonal in 

freshwater 

Heermann’s gull, Brant, harlequin 

duck, black and ruddy turnstone, 

surfbird, rock sandpiper, wandering 

tattler, great blue heron, river otter, 

dunlin, western sandpiper, northern 

pintail, mallards, Canada geese, 

amphibians, and bats

Definitions for Column Headings

Focal Resources: Species selected as representatives or indicators for the overall condition of the Priority Resources of Concern. In situations 

where the Priority Resources of Concern may include a broad variety of habitat structures and plant associations, several different focal resouces

may be listed. In addition, species with specific “niche” ecological requirements may be listed as focal resources. Management will be focused on 

attaining conditions required by the focal resources. 

:

Habitat Type: The general habitat description utilized by the focal resource. 

Habitat Structure and Other Ecological Requirements: The specific and measurable habitat attributes considered necessary to support the 

focal resource. 

Life History: The general season of use for the focal resources.

Other Benefiting Species: Other species that are expected to benefit from management for the selected focal resources. The list is not 

comprehensive; see the Table of Potential Resources of Concern for the Refuges for a more complete list.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-11

C.3 Summary of BIDEH for Protection Island and San Juan Islands NWRs

Habitats that 

Represent 

Existing 

BIDEH

Population/Habitat Attributes 

(age, class, structure, serial,

species composition)

Natural Processes 

Responsible for 

These Conditions

Limiting Factors

Shoreline

Spit North Pacific Maritime Coastal 

Sand Dune and Strand ecological 

system. Sand and gravelly 

sediment from adjacent bluffs form 

a low elevation (<3' above mean 

high tide) point of land or narrow 

shoal projecting into the marine 

water. American dune grass, 

yellow sandverbena, plantain, 

yarrow, black knotweed.

Eroding glacial-till 

bluffs; salt spray; high 

winds; excessively 

drained soils

Sea level rise; high 

waves and storm 

intensity; armoring 

bluffs; invasive 

species; lack of large 

driftwood, 

contamination 

Rocky 

Shoreline and 

Cliff 

Basalt or meta-sedimentary 

consolidated rock with or without 

minimal soil. Native lichen/sedum 

dominated vegetation sparsely

interspersed with windswept 

shrubs, succulents, or grasses 

growing from fissures.

Volcanic and tectonic 

activities, glacial 

processes, and mean sea 

level 

Sea level raise; 

volcanic and tectonic 

activity; wind, waves, 

and other erosive 

forces; invasive spp.

Sandy/Gravel 

Shoreline

The stratum consists of 

components smaller than cobble 

(10” diameter) including gravel, 

sand mud, and organic materials. 

If vegetation is present, represents 

the North Pacific Maritime Coastal 

Sand Dune and Strand ecological 

system though very sparse.

Eroding glacial-till 

bluffs; salt spray; high 

winds; excessively 

drained soils; volcanic 

and tectonic activities, 

glacial processes, and 

mean sea level 

Sea level rise; high 

waves and storm 

intensity; armoring 

bluffs; invasive 

species; lack of large 

driftwood; 

contamination; 

volcanic and tectonic 

activity

Forest and Woodlands

Forests Westside Lowlands ConiferHardwood (Mature) Forest

ecological system consisting of 

late-succession (>300 years old) 

Douglas fir, western hemlock, 

western red cedar forest with mutilayer canopy and understory of 

sword fern, dwarf Oregon grape 

and salal. 

Configuration of islands 

(interior buffered by 

rock ledges) created a 

deposition area for 

well-developed soils 

and increased retention 

of precipitation 

Invasive species; 

logging; development 

(trails, campsites); 

fire; disease; and 

extreme winds.

Woodlands Westside Oak and Dry Douglas-fir 

Forest and Woodlands includes dry 

Douglas-fir forests, Pacific 

madrone /Douglas-fir/ Grand fir 

forests, and areas of lodgepole 

(shore) pine. Garry oak currently 

Drained soils, low 

precipitation, natural 

fire regimes

Lack of seed 

dispersing animals 

and birds, such as 

Steller’s jay; disease; 

invasive species; fire 

suppression; climate 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-12

Habitats that 

Represent 

Existing 

BIDEH

Population/Habitat Attributes 

(age, class, structure, serial,

species composition)

Natural Processes 

Responsible for 

These Conditions

Limiting Factors

or historically present. change

Sandy Bluffs 

The North Pacific Coastal Cliff and 

Bluff ecological system.

Deposition of glacialtill; well drained soils; 

natural fire regimes 

Erosion; invasive 

species; increasing 

storm events in 

combination with sea 

level raise 

accelerating natural 

erosion 

Savanna, Grassland, and Herbaceous Bald

Willamette Valley Upland Prairie 

and Savanna and North Pacific 

Herbaceous Bald and Bluff 

ecological systems with native 

plants, such as camas and 

Roemer’s fescue.

Drained soils, low 

precipitation, natural 

fire regimes

Invasive species; 

grazing and soil 

disturbance; dune 

stabilization and 

agricultural use 

(seeding of nonnatives); roads and 

structures; fire 

suppression; climate 

change

Small Wetlands 

Temperate Pacific Freshwater 

Emergent Marsh with the 

predominant vegetation of cattails, 

slough sedge and duckweed; North 

Pacific Coastal Interdunal Wetland 

fringed by pickleweed and other 

salt-tolerant wetland species.

Semipermanent to 

seasonal flooding, 

muck or mineral soil, 

and high-nutrient water; 

deflation plain and 

swales of larger active 

and stabilized sand spits 

receives freshwater 

input from precipitation 

runoff and few seeps 

and limited saltwater 

intrusion from storm or 

high tide over wash 

events.

Level of the water 

table; amount of salt 

water intrusion; 

alteration of 

precipitation patterns 

and sea level raise as a 

result of climate 

change
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-13

C.4. Shoreline Habitat and Ecological Systems Descriptions

C.4.1 Shoreline Habitat Descriptions

Physical attributes for the shoreline areas were characterized according to A Marine and Estuarine 

Habitat Classification System for Washington State (Dethier 1990), a hierarchical system based on the 

National Wetland Inventory classification (Cowardin et al. 1979). 

Overview of A Marine and Estuarine Habitat Classification System for Washington State (Dethier 1990).

System Subsystem Class Subclass Energy Water Regime

Marine Intertidal Consolidated Bedrock

Exposed

Partially Exposed

Semi-protected

Protected

Eulittoral

Backshore

Boulder

Hardpan

Unconsolidated Cobble

Mixed Coarse

Gravel

Sand

Mixed Fine

Mud

Organic

Reef

Artificial

Subtidal Consolidated Bedrock

High

Moderate

Low

Shallow

Deep

Boulder

Hardpan

Unconsolidated Cobble

Mixed Coarse

Gravel

Sand

Mixed Fine

Mud

Organic

Reef

Artificial

Estuarine Intertidal Consolidated Bedrock

Open

Partly Enclosed

Lagoon

Channel/Slough

Eulittoral

Backshore

Boulder

Hardpan

Unconsolidated Cobble

Mixed Coarse

Gravel

Sand

Mixed Fine

Mud

Organic

Reef

Artificial

Subtidal Consolidated Bedrock Shallow

Boulder

Hardpan

Unconsolidated Cobble

Mixed Coarse
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-14

System Subsystem Class Subclass Energy Water Regime

Gravel Deep

Sand

Mixed Fine

Mud

Organic

Reef

Artificial

Using the results of the WDNR Nearshore Habitat Program’s ShoreZone Inventory (Berry et al. 2001, 

WDNR 2001) and Puget Sound Intertidal Habitat Inventory (Berry and Ritter 1997, Ritter et al. 1999) in 

combination with field reconnaissance and photo-interpretation of oblique and orthorectified aerial 

photographs (So 2009), shoreline characteristics for the refuges were described at the following 

classification levels: System, Subsystem, Substrate, Energy, and Water Regime.

System-level categorization of each island as either Estuarine or Marine is difficult since salinities are 

generally high (>25 ppt) and the flora and fauna resemble those on the marine outer coast. However, the 

strong influences of the Fraser River from the north and the freshwater runoff into Bellingham, Padilla, 

and Skagit Bays from the east lead to occasional large drops in surface salinities. Consequently, the 

Dethier (1990) classification system arbitrarily considers areas to the east of a line from Green Point 

(Fidalgo Island) to Lawrence Point (Orcas Island) as well as all of the Strait of Georgia and the San Juans 

north of Orcas as Estuarine. Areas to the west of this line are considered Marine.

Rocky (consolidated) shoreline:

Rocky shoreline habitat descriptions adapted from Dethier (1990), Bailey et al. (1993) and Don (2002) 

follow:

Habitat Type Marine: Intertidal: Consolidated: Bedrock: Partially Exposed: Eulittoral

Refuge Units 8, 9, 11, 14, 15, 16, 17, 18, 19, 20, 21, 27, 28, 80, 81, 82

Description Sites not directly exposed to oceanic swell but with substantial wave action. Wave energies are 

less but there is a consequent increase in desiccation and other stresses leading to somewhat lower 

diversities than at the most exposed sites. Low tides on the more inland waters also fall at highly 

stressful hours (nearer midday in the summer and midnight in the winter), contributing to lower 

diversities. Diagnostic species include the kelp Hedophyllum sessile, the surfgrass Phyllospadix 

scouleri, and the chiton Katharina tunicata (all low zones), and the cloning anemone Anthopleura 

elegantissima (mid zone).

Habitat Type Marine: Intertidal: Consolidated: Bedrock: Protected and Semi-protected: Eulittoral

Refuge Units Protected: 2, 3, 4, 5, 10, 26, 29, 50, 51, 52, 54, 55, 57, 61, 68, 69, 70, 71, 72, 73, 74, 79

Semi-protected: 6, 10, 12, 13, 22, 23, 24, 30, 31, 32, 34, 35, 36, 37, 38, 39, 40, 42, 43, 58, 59, 60, 

62, 63, 64, 79, 83, 84

Description Areas that receive neither oceanic swell nor extensive wind fetch but retain their rocky character 

due to steepness of the shore or currents that sweep away most sediment. Siltation, desiccation, 

and temperature stresses all take their toll on rocky-shore organisms in these areas, and diversity is 

correspondingly relatively low. Diagnostic species include the brown rockweed Fucus gardneri

(=distichus), the red algae Porphyra spp. and Mastocarpus papillatus, the snails Littorina spp. (all 

high zones), and the whelk Nucella lamellosa.
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Appendix C – Habitats and Wildlife C-15

Habitat Type Marine: Intertidal: Consolidated: Boulders: Partially Exposed and Semi-protected: Eulittoral

Refuge Units Partially exposed: 81

Semi-protected: 42

Description Boulder shores generally resemble bedrock shores of similar wave exposures. A few species are 

more common in boulder fields than on bedrock shores, probably because the bases of boulders 

provide protection from sun and from predators; these include the red algae Plocamium 

cartilagineum and Prionitis spp., the limpet Tectura persona, the shore crab Hemigrapsus nudus

and the red rock crab Cancer productus, the anemones Metridium senile, and Urticina 

crassicornis, and several tunicates (especially Pyura haustor) and intertidal sponges (Halichondria 

panicea, Haliclona permollis, and Ophlitaspongia pennata). Characteristic species in the gravel 

commonly found at the base of boulders include the northern clingfish, porcelain crabs 

Petrolisthes spp., sipunculid worms, and the polychaete Thelepus spp. 

Habitat Type Marine: Subtidal: Consolidated: Bedrock: Moderate energy: Shallow

Refuge Units 7, 25, 33, 41, 49, 56

Description These habitats, like the rocky intertidal, are productive and diverse. Communities are often patchy, 

containing areas with herbivorous urchins and few kelps, or no urchins and many kelps. Kelp beds 

create a semi-protected habitat used as resting areas by gulls, heron, waterfowl, and cormorants, 

and as feeding sites by surf scoters and white-winged scoters, loons, grebes, goldeneyes, 

buffleheads, and harbor seals. 

Habitat Type Estuarine: Intertidal: Consolidated: Bedrock: Open: Eulittoral

Refuge Units 47, 48, 66, 77, 78

Description In the San Juan Islands refuge, these habitats are very similar to their marine counterparts except 

with higher amount of freshwater dilution. These habitats are exposed to moderate waves or 

currents which keep silt from settling on the substratum and allow an epifauna to develop. The 

plants and animals seen on these rocky substrata are largely a freshwater-tolerant subset of those 

seen on marine shores. These habitats are used at high tide by sculpins and probably other fishes. 

Habitat Type Estuarine: Intertidal: Consolidated: Bedrock: Partially Enclosed: Eulittoral

Refuge Units 45, 46, 65, 77

Description In the San Juan Islands refuge, these habitats are estuarine equivalents to Marine Intertidal 

Consolidated Bedrock Semi-protected habitats, except with higher amounts of freshwater dilution. 

The consolidated bedrock is protected by headlands, bars, or spits which reduce circulation, 

leading to minimal wave action or currents.

Habitat Type Estuarine: Subtidal: Consolidated: Bedrock: Moderate energy: Shallow

Refuge Units 44

Description In the San Juan Islands refuge, these habitats are estuarine equivalents to Marine Subtidal 

Consolidated Bedrock Moderate energy habitats, except with higher amounts of freshwater 

dilution.

Unconsolidated (sandy/gravelly) shoreline:

Sandy/gravelly shoreline habitat descriptions adapted from Dethier (1990), Bailey et al. (1993) and Don 

(2002) follow:

Habitat Type Marine: Intertidal: Unconsolidated: Mixed-coarse: Partially Exposed: Eulittoral

Refuge Units 75, Protection Island

Description Mixed-coarse sediments are those where no one grain size occupies more than 70-75 percent of a 

stretch of beach. Instead, the beach is a mix (in variable quantities) of a few boulders, with cobble, 

gravel, and sand. Most of the shoreline around Smith Island (especially on the southwest spit) and 

the north shoreline of Protection Island are composed of a mixed-coarse substrate. Located in the 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-16

Strait of Juan de Fuca, this shoreline is substantially exposed to wind waves and attenuated 

oceanic swell.

Habitat Type Marine: Intertidal: Unconsolidated: Mixed-coarse: Protected and Semi-protected: Eulittoral

Refuge Units Protected: 1, 6, 10, 15, 29, 38, 53, 54, 70, 73, Protection Island

Semi-protected: 13, 62, 64, Protection Island

Description These habitats are composed of a mix of boulders, cobble, gravel, and sand with no one 

substratum exceeding 70-75 percent cover. The shoreline is to some degree protected from sea 

swell and receives moderate to restricted wave action from wind fetch. Drift algae may 

accumulate in these habitats seasonally, creating anaerobic sediments beneath them but providing 

food and habitat for a variety of small organisms. On Protection Island, this habitat type occurs 

within the protected marina on Violet Point, on the north side of Kanem Point, and along the 

middle portion of the southern shoreline.

Habitat Type Marine: Intertidal: Unconsolidated: Mixed-fine: Partially Exposed: Eulittoral

Refuge Units 75

Description The eastern low spit extending away from Smith Island and towards Minor Island is composed of 

a mixed-fine substrate with sand, mud, and gravel being the most common constituents. Located 

in the Strait of Juan de Fuca, the shoreline is substantially exposed to wind waves and attenuated 

oceanic swell.

Habitat Type Marine: Intertidal: Unconsolidated: Mixed-fine: Protected and Semi-protected: Eulittoral

Refuge Units Protected: 50, 71, 79

Semi-protected: 35, 39, 64

Description Protection from waves allows finer sediments to accumulate, and the substratum is relatively 

stable. The beaches tend to be accretional. The mixed-fine sediments include sand and mud with 

patches of gravel (especially in the higher intertidal). Species are generally a mix of those found 

in sand and in mud habitats. Drift algae and seagrass may be abundant.

Habitat Type Marine: Intertidal: Unconsolidated: Sand: Partially Exposed: Eulittoral

Refuge Units 76

Description The shoreline of Minor Island is largely composed of sand without significant silt or organic 

content. Consequently, the shoreline is well-drained, moderately sloped, and unstable nature. 

They have no permanent vegetation and are low-diversity habitats, although a few species may be 

abundant. These areas are used extensively by loons, scoters, and grebes at high tide, and by gulls, 

sanderling and other sandpipers, and herons at low tide.

Habitat Type Marine: Intertidal: Unconsolidated: Sand: Semi-Protected: Eulittoral

Refuge Units Protection Island

Description These sands begin to have some silt mixed in with them and are more stable, making them a more 

favorable environment for burrowing and for deposit-feeding organisms. These habitats are found 

in bays and inlets with some wave action, and often are bordered at their upper edges by salt 

marshes. The shallow water fish and fauna in these habitats provides food for seals and for a 

variety of local and migratory birds, including mew gulls, grebes, and great blue herons. The 

clams Macoma secta, Tellina bodegensis and Transennella tantilla, the burrowing sea cucumber 

Leptosynapta clarki, the lugworm Abarenicola claparedi, the tanaid crustacean Leptochelia 

savignyi, and sand sole are diagnostic species. Common associates include Zostera marina, the 

sand dollar Dendraster excentricus and the moon snail Polinices lewisii in low zones. Other 

species in these sometimes rich assemblages include the ghost shrimp Callianassa californiensis, 

the clams Tellina modesta, Macoma balthica and others; the polychaetes Malacoceros glutaeus (= 

Rhynchospio arenincola), Axiothella rubrocincta, Owenia fusiformis, and many others. Seines 

tend to catch Cancer magister and gracilis, and diverse shrimp, including Crangon alaskensis, 

Pandalus spp., and Heptacarpus brevirostris. Sole, salmonids, and sculpin (especially Pacific 

staghorn) feed extensively in these habitats. This is a spawning habitat for surf smelt, and is used 
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Appendix C – Habitats and Wildlife C-17

by larvae of sand lance and candlefish.

Habitat Type Estuarine: Intertidal: Unconsolidated: Mixed-fine: Open: Eulittoral

Refuge Units 47

Description In the San Juan Islands refuge, these habitats are estuarine equivalents to Marine Intertidal 

Unconsolidated Mixed-fine Partially Exposed habitats, except with higher amounts of freshwater 

dilution. Located in the Strait of Georgia, Lone Tree Island and its associated rocks are exposed to 

moderate to long fetch and receive some wind waves and/or currents.

Habitat Type Estuarine: Intertidal: Unconsolidated: Mixed-fine: Partly enclosed: Eulittoral

Refuge Units 77

Description The pocket beach in the southeast corner of Matia Island consists of mixed sand and mud with 

small amounts of gravel or with some clay and peat. The substratum is generally stable, firm, and 

organic-rich. Drift algae and seagrass may be abundant seasonally. Detritivores in the sediment 

are very dense, and are preyed upon by other invertebrates as well as by numerous birds and 

fishes. The amphipod Corophium provides a major food resource for numerous fish and 

shorebirds.

Habitat Type Estuarine: Intertidal: Unconsolidated: Sand: Open: Eulittoral

Refuge Units 77

Description The beach at Rolfe Cove is a gently to moderately sloping beach with sandy substrata. Drift algae 

and seagrass may accumulate in high zones seasonally.

Habitat Type Estuarine: Intertidal: Unconsolidated: Sand: Partly enclosed: Eulittoral

Refuge Units 77

Description The smaller pocket beaches on Matia Island, excluding the beach at Rolfe Cove and the 

southeastern beach, are considered partly enclosed. Substrata are sand, silty sand, or gravelly 

sand.

C.4.2 Ecological Systems Descriptions

Vegetation types and nomenclature in the following section are classified according to the International 

Terrestrial Ecological System Classification being developed by NatureServe and its natural heritage 

program members. Ecological systems are being described for the coterminous United States, southern 

Alaska, and adjacent portions of Mexico and Canada and are defined as follows:

“Terrestrial ecological systems are specifically defined as a group of plant community types 

(associations) that tend to co-occur within landscapes with similar ecological processes, 

substrates, and/or environmental gradients. A given system will typically manifest itself in a 

landscape at intermediate geographic scales of tens to thousands of hectares and will persist for 

50 or more years. This temporal scale allows typical successional dynamics to be integrated into 

the concept of each unit. With these temporal and spatial scales bounding the concept of 

ecological systems, we then integrate multiple ecological factors—or diagnostic classifiers—to 

define each classification unit. The multiple ecological factors are evaluated and combined in 

different ways to explain the spatial co-occurrence of plant associations.” (Comer et al. 2003)

Thus, ecological systems link together recurring groupings of U.S. National Vegetation Classification 

(US-NVC) associations and alliances (Grossman et al. 1998, Anderson et al. 1998, Jennings et al. 2003) 

found in similar physical settings and influenced by similar dynamic processes such as fire or flooding. 

The nested US-NVC hierarchy groups associations into alliances based on common dominant or 
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Appendix C – Habitats and Wildlife C-18

diagnostic species in the upper most canopy. By non-hierarchically grouping together associations and 

alliances using larger-scale environmental patterns and concepts, ecological systems form a “meso-scale” 

classification that lies between the finer-scale (floristic) classes and the generalized formation 

(physiognomic) levels of the US-NVC (Comer et al. 2003). As a “meso-scale” classification, ecological 

systems are more readily mapped, identifiable in the field, and practically understood as ecological units 

and wildlife habitats. Consequently, regional GAP analysis efforts have generally adopted them as target 

map units. Given their utility for standardized vegetation type mapping, ecological systems classification 

was performed for Protection, Matia, Turn, Smith, and Minor Islands. 

North Pacific Coastal Sand Dune and Strand:

Coastal dunes include beach strand (not the beach itself but sparsely or densely vegetated areas behind the 

beach), foredunes, sand spits, and active to stabile backdunes and sandsheets derived from quartz or 

gypsum sands. The mosaic of sparse to dense vegetation in dune systems is driven by sand deposition, 

erosion, and lateral movement. Disturbance processes include dune blowouts caused by wind and 

occasional wave overwash during storm tidal surges. Dune vegetation typically includes herbaceous, 

succulent, shrub, and tree species with varying degrees of tolerance for salt spray, wind and sand 

abrasion, and substrate stability. Dune succession is highly variable, so species composition can vary 

significantly among occurrences. These dunes can be dominated by Leymus arenarius (= Elymus 

arenarius), Festuca rubra, Leymus mollis, or various forbs adapted to salty dry conditions. Gaultheria 

shallon and Vaccinium ovatum are major shrub species. Forested portions of dunes are included within 

this system and are characterized by Pinus contorta var. contorta early in succession, Picea sitchensis

somewhat later in the sere, and in some cases Tsuga heterophylla later still (NatureServe 2010).

Coastal Cliff and Bluff:

This ecological system includes unvegetated or sparsely vegetated rock cliffs and very steep bluffs of 

glacial deposits. It is composed of barren and sparsely vegetated substrates, typically including exposed 

sediments, bedrock, and scree slopes. Exposure to waves, eroding and desiccating winds, slope failures 

and sheet erosion create gravelly to rocky substrates that are often unstable. There can be sparse cover of 

forbs, grasses, lichens and low shrubs (NatureServe 2010).

Willamette Valley Upland Prairie and Savanna:

This ecological system occurs within the Puget Lowland and Willamette Valley on relatively level terrain, 

primarily on deep, well-draining gravelly/sandy glacial outwash, and was historically maintained by 

frequent anthropogenic burning practices (Chappell and Crawford 1997, Crawford and Hall 1997, 

Chappell et al. 2001a, NatureServe 2010). Grassland structure is more common than savanna (defined 

here as <30% tree or shrub cover) (Chappell et al. 2001b). Bunch grasses such as Roemer’s fescue 

(Festuca roemeri = Festuca idahoensis var. roemeri), red fescue (Festuca rubra), and California oatgrass 

(Danthonia californica) are frequently dominant or co-dominant. Abundant and diverse native forbs are 

indicative of sites in good condition. 

Prior to Euroamerican settlement, Willamette Valley Upland Prairie and Savanna were the dominant 

landscape features on the glacial outwash soils within the region (Lang 1961). However, the area 

occupied by this system has declined dramatically due to altered fire regimes, invasion of non-native 

species, grazing, and urban and agricultural conversion (Giles 1970, Agee 1993, Clampitt 1993, Chappell 

and Crawford 1997, Crawford and Hall 1997). Remnant grasslands and prairies are typically small 

fragments that have been degraded by invasive non-native species. Scattered deciduous (Quercus 

garryana) and/or coniferous (Pseudotsuga menziesii) trees are rarely found now but formerly formed 

extensive savannas that covered roughly one-third of the historical ecological system acreage 

(NatureServe 2010).
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Appendix C – Habitats and Wildlife C-19

North Pacific Herbaceous Bald and Bluff:

This system is characterized by low-growing vegetation, relatively shallow soils with an underlying 

restrictive layer of bedrock, and relatively dry topographic positions. During the growing season, balds 

can be moist or wet but then dry out to an extreme degree late in the growing season. Balds typically 

occur in small patches and can be intermixed with rock outcrops and fringed by areas of forest and 

woodland (Chappell et al. 2001a, Chappell et al. 2001b, Chappell 2006). 

Dominant or co-dominant native grasses include Roemer’s fescue (Festuca roemeri = Festuca idahoensis 

var. roemeri), red fescue (Festuca rubra), and California oatgrass (Danthonia californica), Lemmon’s 

needlegrass (Achnatherum lemmonii), and prairie junegrass (Koeleria macrantha). Major exotic 

dominant grasses include brome (Bromus sp.), velvet grass (Holcus lanatus), wheatgrass (Agropyron 

dasystachyum), and Kentucky bluegrass (Poa pratensis). Forb diversity can be high. Some typical codominant forbs include common camas (Camassia quamash), great camas (Camassia leichtlinii), 

hyacinth triteleia (Triteleia hyacinthine), rosy plectritis (Plectritis congesta), Martindale’s lomatium 

(Lomatium martindalei), nodding onion (Allium cernuum), Hooker's onion (Allium acuminatum), 

spreading phlox (Phlox diffusa), sea thrift (Armeria maritima), and chocolate lily (Fritillaria lanceolata) 

(Atkinson and Sharpe 1993, NatureServe 2010). Important dwarf-shrubs are kinnikinnick 

(Arctostaphylos uvaursi), pinemat manzanita (Arctostaphylos nevadensis), and common juniper 

(Juniperus communis). Significant portions of some balds, especially on rock outcrops, are dominated by 

bryophytes (mosses) and to a lesser degree lichens (NatureServe 2010). 

With the accumulation and enrichment of soil through the actions of erosion and plant matter decay, 

shrubs and trees scattered may eventually appear within balds forming open savanna-like woodlands. 

Garry oak (Quercus garryana), Rocky Mountain juniper (Juniperus scopulorum), and Pacific madrona 

(Arbutus menziesii) are among the tree species able to anchor in the thin soil of these areas. Other tree 

species which may be found on these sites include Douglas fir (Pseudotsuga menziesii) and shore pine 

(Pinus contorta) (Atkinson and Sharpe 1993). 

North Pacific Dry Douglas-Fir Forest and Woodland 

The North Pacific Dry Douglas-Fir-(Madrone) Forest and Woodland system occupies dry sites with 

shallow soils overlying bedrock, very stony soils, or moderately deep, moderately well-drained glacial 

outwash. These forest and woodland sites tend to be subject to higher winds and higher summer 

temperatures than the North Pacific Maritime Dry-Mesic Douglas-fir-Western Hemlock Forest system 

and also tend to occur on southern or western facing slopes (Chappell et al. 2001).

As the name implies, the North Pacific Dry Douglas-Fir Forest and Woodland ecological system is 

dominated by the long-lived Douglas-fir tree (Pseudotsuga menziesii). A variety of other trees including 

Pacific madrona (Arbutus menziesii), the short-lived shore pine (Pinus contorta), big-leaf maple (Acer 

macrophyllum), and the shade-tolerant grand fir (Abies grandis) occur along with the Douglas-fir 

depending on local site conditions (Atkinson and Sharpe 1993, NatureServe 2010). Small amounts of 

western hemlock (Tsuga heterophylla) or Western red cedar (Thuja plicata) can be present but are unable 

to thrive due to the dryness of the site or due to frequent and extensive fires (NatureServe 2010). 

Deciduous shrubs that dominate or co-dominate the understory include oceanspray (Holodiscus discolor), 

serviceberry (Amelanchier alnifolia), trailing blackberry (Rubus ursinus), Indian plum (Oemleria 

cerasiformis), Nootka rose (Rosa nutkana), and snowberry (Symphoricarpos albus). Evergreen shrubs 

that can sometimes be important in areas that are conifer-dominated include salal (Gaultheria shallon) 

and dwarf Oregon grape (Mahonia nervosa). Native graminoids such as blue wildrye (Elymus glaucus) 

commonly dominate or co-dominate the understory. A diversity of forbs is often abundant. However, 

forbs typically do not dominate (Chappell et al. 2001).
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Appendix C – Habitats and Wildlife C-20

North Pacific Maritime Dry Mesic Douglas-fir-Western Hemlock Forest

This is generally the most extensive forest in the lowlands on the west side of the Cascades and forms the 

matrix within which other systems occur as patches. In dry areas it occurs adjacent to or in a mosaic with 

North Pacific Dry Douglas-fir-(Madrone) Forest and Woodland.

Douglas-fir and western hemlock are the most characteristic species of this ecological system and one or 

both are generally canopy dominant. Other co-dominants include grand fir, western red-cedar, and bigleaf maple. Dominant or co-dominant understory shrub species include salal, dwarf Oregongrape, Pacific 

rhododendron (Rhododendron macrophyllum), twinflower (Linnaea borealis), vanilla leaf (Achlys 

triphylla), and evergreen huckleberry (Vaccinium ovatum). Vine maple (Acer circinatum) is a common 

co-dominant with one or more of these other species. On mesic sites, sword fern can be co-dominant with 

one or more of the evergreen shrubs (NatureServe 2010). 

North Pacific Oak Woodlands

Within the Puget Trough region, this ecological system is found in small patches on dry sites typically 

featuring either shallow bedrock or deep glacial outwash soils. The oak-dominated communities 

comprising this system are strongly associated with a pre-Euroamerican settlement, frequent (every few 

years) to moderately frequent (once every 50-100 years), low-severity fire regime (Chappell et al. 2001, 

NatureServe 2010). The vegetation ranges from open woodland to forest. The deciduous broadleaf Garry 

oak, also known as Oregon white oak (Quercus garryana), is the dominant tree species with the 

coniferous Douglas-fir often being co-dominant. Madrone and lodgepole pine (Pinus contorta) are also 

common associates (WDFW 2005). 

In savanna-like open woodlands, the understory is dominated by long-stolon sedge and camas. This 

community type is most similar in composition to pre-settlement oak savannas (Chappell and Crawford 

2007). In the absence of fire, commonly observed successional changes include an increase in conifers, 

the proliferation of a shrub understory, higher oak densities, and an increasing abundance of non-native 

annuals and perennials in the understory (Agee 1993, Chappell and Crawford 1997, NatureServe 2010). 

The increase in woody trees and shrubs include native species such as Douglas-fir, Oregon grape, 

snowberry, and manzanita, and non-native species such as Scotch broom (Cytisus scoparius). 

Temperate Pacific Freshwater Emergent Marsh

Freshwater emergent marshes are characterized by semipermanent to seasonal flooding, muck or mineral 

soil, and high-nutrient water. Emergent herbaceous graminoids such as Carex spp., Scirpus spp., 

Eleocharis spp., Juncus spp., and Typha latifolia typically dominate. A consistent source of freshwater is 

essential to the function of these systems (NatureServe 2010).

North Pacific Coastal Interdunal Wetland

North Pacific Coastal Interdunal Wetlands occur in the deflation plain and swales of larger active and 

stabilized coastal barrier islands, spits, and coastal dunes, ranging from southern Oregon through the 

Aleutian Islands (NatureServe 2010). These freshwater wetlands form between dunes where wind has 

scoured the sand down to the water table. Consequently, interdunal wetlands are sustained almost 

entirely by groundwater and are flooded seasonally or perennially. Because the water table declines to 

below the bottom of some deflation plains in the dry season (midsummer to early fall), some of these 

wetlands are seasonal (USGS 2010). Vegetation in interdunal wetlands is variable, depending upon 

hydrology and geography. The closer the deflation plain or swale is to the nearby waterbody, the higher 

the likelihood for a hydrologic linkage. For wet dune swales and broad deflation plains, several distinct 
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Appendix C – Habitats and Wildlife C-21

communities have been reported (Wiedemann 1984). Where deposition of wind-blown sand is heavy and 

dune migration is active, interdunal wetlands may become uplands when covered by thick sand deposits.

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Jennings, M., O. Loucks, D. Glenn-Lewin, R. Peet, D. Faber-Langendoen, D. Grossman, A. Damman, M. 

Barbour, R. Pfister, M. Walker, S. Talbot, J. Walker, G. Hartshorn, G. Waggoner, M. Abrams, A. 

Hill, D. Roberts, and D. Tart. 2003. Guidelines for describing associations and alliances of the 

U.S. National Vegetation Classification. The Ecological Society of America, Vegetation 

Classification Panel, Version 3.0 November 2003. 100 pp. (+ Appendices)

Lang, F. A. 1961. A study of vegetation change on the gravelly prairies of Pierce and Thurston Counties, 

western Washington. M.S. thesis, University of Washington, Seattle, Wash.

NatureServe. 2010. International Ecological Classification Standard: Terrestrial Ecological 

Classifications. NatureServe Central Databases. Arlington, VA, U.S.A. Data current as of 26 

February 2010.

Ritter, R.A., Berry, H.D., Bookheim, B.E., & Sewell, A.T. 1999. Puget Sound Habitat Intertidal 

Inventory 1996: Vegetation and Shoreline Characteristics Classification Methods. Olympia, WA: 

DNR Nearshore Habitat Program.

United States Geological Survey. 2010. Oregon Wetland Resources. Available URL: 

http://or.water.usgs.gov/pubs/Html/WSP2425/index.html. Accessed 26 February 2010.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-23

So, K.J. 2009. Protection Island and San Juan Islands National Wildlife Refuges Shoreline Classification 

metadata. U.S. Fish and Wildlife Service, Oregon Coast National Wildlife Refuge Complex, 

Newport, Oregon.

Washington Department of Natural Resources Nearshore Habitat Program. 2001. The Washington State 

ShoreZone Inventory. CD-ROM. Olympia, WA: DNR Nearshore Habitat Program.

WDFW. 2005. Washington’s Comprehensive Wildlife Conservation Strategy. Washington Department 

of Fish and Wildlife. Olympia, WA.

Wiedemann, A.M. 1984. The ecology of Pacific Northwest coastal sand dunes: a community profile. 

US Fish and Wildlife Service Biological Services Program FWS/OBS-84/04. 130 pp.

C.5 Common and Scientific Names of Species mentioned in the CCP

The following tables contain the common and scientific names of plants and animals that are 

mentioned in this CCP. 

Plants 

Common Name Scientific Name Family

Alfalfa Medicago sativa Fabaceae

Alaska alkali grass Puccinellia kamtschatica Poaceae

Alaska brome Bromus sitchensis Poaceae

Alaska oniongrass Melica subulata Poaceae

American dunegrass Leymus mollis Poaceae

Bear’s foot sanicle Sanicula arctopoides Apiaceae

Bigleaf maple Acer macrophyllum Aceraceae

Black lily Fritillaria camschatcensis Liliaceae

Black medic Medicago lupulina Fabaceae

Blue wild rye Elymus glaucous Poaceae

Bracken fern Pteridium aquilinum Dennstaedtiaceae

Brittle prickly-pear cactus Opuntia fragilis Cactaceae

Bull thistle Cirsium vulgare Asteraceae

California buttercup Ranunculus californicus Ranunculaceae

California oat-grass Danthonia californica Poaceae

Camas Camassia quamash Liliaceae

Canada thistle Cirsium arvense Asteraceae

Cattails Typha latifolia Typhaceae

Caulerpa Caulerpa ssp. Caulerpaceae

Cheatgrass Bromus tectorum Poaceae

Common cordgrass Spartina anglica Poaceae

Common mustard Brassica campestris Brassicaceae

Common sow thistle Sonchus Oleraceus Asteraceae

Common velvet-grass Holcus lanatus Poaceae
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-24

Common Name Scientific Name Family

Douglas-fir Pseudotsuga menziesii ssp. 

menziesii

Pinaceae

Douglas maple Acer glabrum Aceraceae

Eel-grass Zostera marina Zosteraceae

English ivy Hedera helix Araliaceae

Erect pygmy-weed Crassula connata Crassulaceae

European beachgrass Ammophila arenaria Poaceae

False dandelion Nothocalais ssp. Asteraceae

Field bindweed Convolvulus arvensis Convolvulaceae

Garry oak Quercus garryana Fagaceae

Golden paintbrush Castilleja levisecta Scrophulariaceae

Grand fir Abies grandis Pinaceae

Gumweed Grindelia integrifolia Asteraceae

Hedge mustard Sisymbrium officinale Brassicaceae

Himalayan blackberry Rubus armeniacus Rosaceae

Hookedspur violet Viola adunca Violaceae

Hooker’s willow Salix hookeriana Salicaceae

Idaho fescue Festuca idahoensis Poaceae

Japanese eelgrass Zostera japonica Zosteraceae

Japanese kelp Undaria pinnatifida Alariaceae

Kentucky bluegrass Poa pratensis Poaceae

Lance-leaved stonecrop Sedum lanceolatum Crassulaceae

Lemmon’s needlegrass Achnatherum lemmonii Poaceae

Meadow barley Hordeum brachyantherum Poaceae

Nootka rose Rosa nutkana Rosaceae

Northern adder’s-tongue Ophioglossum pusillum Ophioglossaceae

Orange honeysuckle Lonicera ciliosa Caprifoliaceae

Orchard grass Dactylis glomerata Poaceae

Pacific madrone Arbutus menziesii Ericaceae

Pacific sanicle Sanicula crassicaulis Apiaceae

Paintbrush Castilleja ssp. Scrophulariaceae

Pickleweed Salicornia virginica Chenopodiaceae

Plantain Plantago ssp. Plantaginaceae

Prairie junegrass Koeleria macrantha Poaceae

Quackgrass Elymus repens Poaceae

Red alder Alnus rubra Betulaceae

Redcedar Thuja plicata Cupressaceae

Red fescue Festuca rubra Poaceae

Ripgut brome Bromus diandrus Poaceae

Rocky Mountain juniper Juniperus scopulorum Cupressaceae

Salal Gaultheria shallon Ericaceae

Sargassum Sargassum ssp. Sargassaceae

Scotch broom Cytisus scoparius Fabaceae
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-25

Common Name Scientific Name Family

Scouler’s willow Salix scouleriana Salicaceae

Sea blush Plectritis congesta Valerianaceae

Sea thrift Armeria maritime Plumbaginaceae

Sharpfruited peppergrass Lepidium oxycarpum Brassicaceae

Sheep sorrel Rumex acetosella Polygonaceae

Shore pine Pinus contorta var. contorta Pinaceae

Silver burweed Ambrosia chamissonis Asteraceae

Slender crazyweed Oxytropis campestris var. 

gracilis

Fabaceae

Slough sedge Carex obnupta Cyperaceae

Snowberry Symphoricarpos albus Caprifoliaceae

Sow thistle Sonchus arvensis Asteraceae

Sword fern Polystichum munitum Dryopteridaceae

Vancouver groundcone Boschniakia hookeri Orobanchaceae

Verbena Verbena ssp. Nyctaginaceae

Western hemlock Tsuga heterophylla Pinaceae

White meconella Meconella oregana Papaveraceae

Yarrow Achillea millefolium Asteraceae

Yerba buena Clinopodium douglasii Lamiaceae

Mammals 

Common Name Scientific Name Family

Bat Chioptera (order)

Black-tailed deer Odocoileus hemionus Cervidae

California sea lion Zalophus californianus Otariidae

Domestic cat Felis catus Felidae

Domestic dog Canis familiaris Canidae

European rabbit Oryctolagus cuniculus Leporidae

Harbor seal Phoca vitulina Phocidae

Mink Mustela vison Mustelidae

Northern elephant seal Mirounga angustirostris Phocidae

Raccoon Procyon lotor Procyonidae

Rat Rattus spp. Muridae

Red fox Vulpes vulpes Canidae

River otter Lutra canadensis Mustelidae

Short and long-tailed 

weasel 

Mustela spp. Mustelidae

Shrew Sorex spp. Soricidae

Steller (northern) sea lion Eumetopias jubatus Otariidae

Townsend’s chipmunk Tamias (Neotamias) 

townsendii

Sciuridae
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-26

Birds 

Common Name Scientific Name Family

American kestrel Falco sparverius Falconidae 

Bald eagle Haliaeetus leucocephalus Accipitridae 

Black-bellied plover Pluvialis squatarola Charadriidae 

Black oystercatcher Haematopus bachmani Haematopodidae

Black turnstone Arenaria melanocephala Scolopacidae

Brant Branta bernicla Anatidae 

Brandt’s cormorant Phalacrocorax penicillatus Phalacrocoracidae 

Brown pelican Pelecanus occidentalis Pelecanidae 

Canada goose Branta Canadensis Anatidae 

Caspian tern Hydroprogne caspia Laridae 

Common murre Uria aalge Alcidae

Double-crested cormorant Phalacrocorax auritus Phalacrocoracidae 

Downy woodpecker Picoides pubescens Picidae

Dunlin Calidris alpina Scolopacidae 

Glaucous-winged gull Larus glaucescens Laridae 

Great blue heron Ardea herodias Ardeidae 

Great horned owl Bubo virginianus Strigidae 

Hairy woodpecker Picoides villosus Picidae 

Harlequin duck Histrionicus histrionicus Anatidae 

Heermann’s gull Larus heermanni Laridae 

Killdeer Charadrius vociferus Charadriidae 

Mallard Anas platyrhynchos Anatidae 

Marbled murrelet Brachyramphus 

marmoratus)

Alcidae 

Northern harrier Circus cyaneus Accipitridae 

Northern pintail Anas acuta Anatidae 

Olive-sided flycatcher Contopus cooperi Tyrannidae 

Pelagic cormorant Phalacrocorax pelagicus Phalacrocoracidae 

Peregrine falcon Falco peregrinus Falconidae 

Pileated woodpeckers Dryocopus pileatus Picidae 

Pigeon guillemot Cepphus columba Alcidae 

Purple martin Progne subis Hirundinidae 

Rhinoceros auklet Cerorhinca monocerata Alcidae 

Rock sandpiper Calidris ptilocnemis Scolopacidae 

Ruddy turnstone Arenaria interpres Scolopacidae 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix C – Habitats and Wildlife C-27

Common Name Scientific Name Family

Surfbird Aphriza virgata Scolopacidae 

Sanderling Calidris alba Scolopacidae 

Savannah sparrow Passerculus sandwichensis Emberizidae 

Snowy owl Bubo scandiacus Strigidae 

Swallow Hirundinidae 

Tufted puffin Fratercula cirrhata Alcidae 

Wandering tattler Tringa incana Scolopacidae 

Western sandpiper Calidris mauri Scolopacidae 

Butterflies

Common Name Scientific Name Family

Island marble Euchloe ausonides Pieridae

insulanus

Taylor’s checkerspot Euphydryas editha taylori Nymphalidae

Valley silverspot Speyeria zerene bremnerii Nymphalidae

Fish and Shellfish 

Common Name Scientific Name Family

Cod Gadus ssp. Gadidae

European green crab Carcinus maenas Portunidae

Flounder Pleuronectidae

Herring Clupea pallasii Clupeidae

Limpets Patellogastropoda (order)

Mussels Mytilus ssp. Mytilidae

Rockfish Sebastes ssp. Scorpaenidae 

Salmon Oncorhynchus ssp. Salmonidae 

Sandlance Ammodytidae

Smelt Osmeridae
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-1

Appendix D. Sign Plans 

D. Introduction

This appendix contains the following two elements:

• Protection Island National Wildlife Refuge Sign Inventory and Maintenance Plan

• San Juan Islands National Wildlife Refuge Sign Inventory and Maintenance Plan

The sign inventory and maintenance plans are intended to guide decisions regarding the type, 

placement, and maintenance of signs within the refuges. No substantial changes to the current 

Protection Island NWR signs and protocol are anticipated, however, a number of changes are 

proposed with this CCP for the San Juan Islands NWR signs. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-2

Protection Island National Wildlife Refuge 

Jefferson County, Washington

 USFWS - Robinson

Sign Inventory and 

Maintenance Plan

U.S. Fish and Wildlife Service

August 2010
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-3

Protection Island National Wildlife Refuge was established in 1988 through the efforts 

of local citizens “to provide habitat for a broad diversity of bird species, with particular 

emphasis on protecting the nesting habitat of the bald eagle, tufted puffin, rhinoceros 

auklet, pigeon guillemot, and pelagic cormorant; to protect hauling-out area of harbor 

seals; and to provide for scientific research and wildlife-oriented public education and 

interpretation” (1). The fact that Protection Island NWR and the attached Zella M. Schulz 

Seabird Sanctuary are closed to the public is somewhat at odds with the wildlife-oriented 

interpretation portion of the establishing purpose. Although it is easy to view wildlife on 

the Island and in the surrounding waters from outside the 200 yard disturbance buffer, 

particularly with the aid of binoculars and telescopes, there is currently no formal 

interpretation program offered by the refuge except for an outdated interpretive panel at 

John Wayne Marina in Sequim, WA. 

Included in the refuge’s Comprehensive Conservation Plan is an objective to increase 

area visitors’ knowledge of the refuge and its wildlife by updating/replacing the 

interpretive panel at John Wayne Marina and installing another panel at a location 

frequented by recreational boaters (to be determined) in Port Townsend. 

The Island lies approximately 2.5 miles north of Diamond Point, a small affluent 

Jefferson County community, and is due north of the mouth of Discovery Bay. The area 

is popular for sightseeing cruises, recreational boating, and commercial fishing and 

crabbing. The area is also known for its wildlife abundance and is a frequent destination 

for kayakers who present a significant disturbance and trespassing issue due to the 

shallow draft of their boats and ability to access areas where wildlife is typically 

unmolested, including sensitive nesting sites. 

 USFWS – Davis
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-4

Protection Island NWR is especially important to seabirds. About 70% of Puget Sound’s 

breeding seabird population nests on the Island. Located near the mouth of Discovery 

Bay on the southeast side of the Strait of Juan de Fuca, the 316-acre refuge consists of 

grassland, shrubland, a small upland forest, and a relatively undisturbed shoreline with

two sandy spits and extensive glacial-till sandy bluffs that support one of North 

America’s largest colonies of rhinoceros auklets. In fact, it is typical to see thousands of 

rhinoceros auklets returning to their burrows to feed their young as the sun sets each 

evening. Furthermore, Protection Island is considered the “last stand” for breeding tufted 

puffins in Salish Sea. In addition to seabirds, harbor and elephant seals haul out to rest 

and have their pups on the Island’s sand spits which extend to the east and west.

Protection Island NWR also includes an additional 340-acre aquatic lands lease from the 

Washington Department of Natural Resources which is due to expire on December 31, 

2013. The tideland lease is overlayed on a WDNR reservation and effectively withdraws 

“ . . . the bedlands of navigable water owned by the state of Washington, surrounding 

Protection Island extending waterward 600 feet from the line of extreme low water . . . 

from conflicting uses for an indefinite term . . . .” (2) This withdrawal order further states 

that public access may be permitted under conditions mutually agreed upon by the 

WDNR and U.S. Department of the Interior.

Zella M. Schultz Seabird Sanctuary: Protection Island NWR encompasses the entirety 

of the Island except for a 48-acre section on the west end of the island on Kanem Point,

known as the Zella M. Schultz Seabird Sanctuary, which was protected prior to refuge 

establishment, first through purchase by The Nature Conservancy in 1972, then by the 

Washington Department of Game (now the Washington State Department of Fish and 

Wildlife) acquisition in 1974. The seabird sanctuary encompasses approximately half of 

the Island’s rhinoceros auklet and tufted puffin colonies. The Service (USFWS) and 

WDFW have a Memorandum of Understanding with the primary objective being the 

protection and enhancement of the wildlife resources on Protection Island. The goal of 

each agency is compatible and complimentary management (3).

This sign plan is not intended to alter or supersede any sign procedures or policies 

established by WDFW or the State of Washington. Rather it is intended as guidance to 

USFWS personnel in regards to regulatory and interpretive signage within the National 

Wildlife Refuge portion of Protection Island. Any reference to signs within the Zella M. 

Schultz Seabird Sanctuary in this document is purely for the purpose of establishing a 

comprehensive sign inventory and maintenance plan for all of Protection Island. 

Currently there is only one non-FWSsign on the island which is located in the Sanctuary. 

It is an informational sign with the sanctuary name.

While the Protection Island NWR establishing purpose includes wildlife-oriented public 

education and interpretation, the refuge is not open to the public except for researchers 

operating under special use permits. However, a number of people with interest in tracts 

Use and Visitation
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-5

of land on Protection Island prior to the establishment of the refuge were granted

extended use privileges, including island access, under a variety of terms. While most of

these terms have already expired, and many of the rest will expire in 2011, there is one 

lifetime user who maintains a primary residence on the island. All other current extended 

users have unimproved lots that receive only occasional use. 

In addition, Walla Walla College, whose extended use term expired years ago, continues 

to use a USFWS-maintained cabin under a special use permit, as does Andrews 

University. Their activities also serve to satisfy the wildlife-oriented education

component of the refuge’s founding purpose. The Service also maintains a year round 

caretaker’s residence. That small cabin is usually occupied by one or two caretakers 

responsible for overseeing island maintenance, interacting with researchers, and 

contacting trespassers to provide information about island regulations and wildlife 

disturbance issues. 

Protection Island lies within the Straights of Juan De Fuca, an area known for high winds, 

strong currents, and rough marine conditions. Although it is closed to the public, on 

occasion vessels in distress seek shelter within the Island’s small protected harbor. In 

addition, there are a number of hazardous shoreline areas with submerged rocks and 

shoals. The island is flanked by two low-lying, partially submerged sand and rock spits, 

Kanem to the west and Violet to the east. The majority of the island is a large open 

plateau surrounded by steep unstable bluffs. These bluffs represent a particularly severe 

hazard for staff, visiting researchers, in-holders, guests, and occasional trespassers. 

Hazards

Regulatory and Entrance Signs 

Signs will meet the specifications set forth in the Service’s Sign Manual (4). Large format 

signs posted on the island will have wooden posts and supports and will be constructed of 

high quality, medium density overlay (MDO), 3⁄4 inch plywood except as otherwise 

indicated. Sign background color will be reflective white and lettering will be black, or, 

in the case of standard Service signs (small format), dark blue. Text font will be 

Helvetica Medium. All signs will have the USFWS reflective shield measuring a 

minimum of 10” wide by 12” tall except as otherwise indicated.

Sign Specification and Mounting Criteria (Regulatory)

Protection Island shoreline areas will utilize large format signs which can be read unaided 

from the water at least 200 yards offshore. These signs may also include the national 

Wildlife Refuge System’s Blue Goose logo. Large format signs are at least 6’ wide and 4 

– 5’ high. These signs should be well supported using at least two 4” x 4” posts to protect 

against high winds common in the area. Examples of signs currently in use:

Large Format Signs
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-6

 New version Old version (still in use)

Standard USFWS closed area signs may be utilized on a limited case-by-case basis as 

determined by the Refuge Manager to warn island visitors and residents to avoid specific 

areas. Such signs will be used sparingly to warn of particularly sensitive habitats or 

hazards. These signs will be posted on standard galvanized steel or wood posts buried at 

least 2’ deep. 

Small Format, Standard Service “closed area” signs

Note: Since the entire island is closed to the public, there is no need to post standard 

boundary and closed area signs. Furthermore, it would be difficult to maintain such signs 

in the dynamic shoreline and unstable cliff environment, installing signs would likely 

have a negative impact on nesting sites, and these small signs would be unreadable from 

outside of the 200 yard disturbance buffer. Also, the unsigned areas to the north and west 

side of the island are bounded by hazardous and rocky waters which tend to serve as an 

approach barrier. 

11” X 14”

Description: Harbor Entrance, Marina Closed Sign

Special Purpose (Regulatory)

Material: Heavy polymetal

- Reflective white with blue lettering and red reflective stop sign symbol

- Text: MARINA CLOSED To Public Entry

 To Protect Wildlife Stay 200 Yards From Shore

 U.S. Fish and Wildlife Service

- Dimensions: 42.5” X 25.5”

- Location: Harbor entrance approach

- No USFWS reflective shield
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-7

 

There is currently only one information sign on Protection Island, the refuge entrance 

sign located due west of the harbor (Sign F). 

Sign Specification and Placement Criteria (Information)

Sign F. USFWS - Davis

Description: Brown painted background with light blue and green lettering

Material : 3⁄4” MDO plywood

- Picture of puffin

- Text: Protection Island National Wildlife Refuge

 Established August 26, 1988

 U.S. Fish and Wildlife Service

 Department of the Interior

- Dimensions: 6’ X 5’

- Location: Approximately 50 yards south west of dock, visible on harbor approach

A. Sign Inventory (entrance and large format regulatory)

Large Format: 6 (signs A – E, H)

Marina Closed: 1 (sign G)

Refuge Entrance: 1 (sign F)

Zella M. Schultz Seabird Sanctuary (WDFW): 1 (sign I)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-8

A.

B.

C.

D.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-9

E.

 

 G. (replaced 4/2009) 

H.

I.

Sign Inventory Table (“entrance” and large format regulator)

200 Yard: 7 (signs A – E and H)

Sign designations: A – I

Entrance: 2, 1 FWS (sign F) and 1 WDFW (sign I)

Harbor Closed: 1 (sign G)

Sign ID / type Location Condition Recommendation Last 

Inspection 

A, regulatory North central Good, decal 

replaced 8/09

None 3/15/10

B, regulatory Violet Spit North Sign damaged Replace sign 3/15/10

C, regulatory Violet Spit SE Good, decal 

replaced 8/09

None 3/1510

D, regulatory Violet Spit SW Good, decal/posts 

replaced 8/09

None 3/15/10

E, regulatory South central Good, decal faded Replace decal 3/15/10

F, information Marina Good None 3/15/10

G, regulatory Marina entrance Very Good, new 

4/2009

None 3/15/10

H, regulatory Kanem Spit Good, decal 

replaced 8/09

None 3/15/10

I, information 

(WDFW sign)

Kanem Spit 

bluff base

Lettering 

repainted 2/2010

None 

(WDFW sign)

3/15/10

B. Sign Inventory (small format regulatory and miscellaneous)

Area Closed: 12 (signs PI 1 -2, 4 – 13)

Signs ID Numbers: PI 1 - 15

Government Property: 1 (sign PI – 3)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-10

Miscellaneous: 1 (Coast and Geodetic Survey Witness Post, sign PI - 15)

Small Format Sign Inventory Table

Sign 

number

Photo Description

(Text)

Location, 

direction

Condition Last 

Inspection

Recommendation

PI 1 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

150 feet 

southeast of 

caretaker 

cabin facing 

southeast

Good 3/21/10 None

PI 2 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

200 ft

southwest of 

caretaker 

cabin facing 

west

Worn, 

faded

3/21/10 Replace
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-11

PI 3 Notice Government 

Property 

Molesting, 

Damaging, or 

Stealing Government 

Property Is 

Punishable By Fine 

And/Or 

Imprisonment 

No Trespassing 

South side of 

caretaker 

shed, faces 

east

Good 3/21/10 None

PI 4 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

Faces 

southeast Worn, 

Faded

3/21/10 Replace

PI 5 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

Faces 

southwest

Good 3/21/10 None

PI 6 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

Faces 

northeast

Faded 3/21/10 None

PI 7 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

Northwest 

side of 

abandoned 

cabin in 

small 

wooded area

Faded 3/21/10 Clean

PI 8 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

In field 150 

feet 

southwest of 

Odegard 

cabin

Worn, 

Faded, 

Damaged

3/21/10 Replace

PI 9 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

Faces 

southwest Worn, 

Faded, 

Post 

rotten

3/21/10 Replace sign 

and post
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-12

PI 10 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

Southeast 

side of water 

tower

Good 3/21/10 None

PI 11 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

100 feet 

from the end 

of road on 

Violet bluff, 

faces north

Good 3/21/10 None

PI 12 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

100 feet 

northwest of 

Walla Walla 

cabin, faces 

northwest

Good 3/21/10 None

PI 13 Area 

Beyond This 

Sign Closed 

All Public 

Entry 

Prohibited

At base of 

Violet bluff 

on old bluff 

road, faces 

northeast.

Faded 3/21/10 None

PI 14 See sign F Refuge 

Entrance 

Sign

West of 

marina Good 3/21/10 None

PI 15 Witness Post Please 

Do Not Disturb 

Nearby Survey 

Marker 

For Information 

Write To The 

Director Coast And 

Geodetic Survey 

Department Of 

Commerce 

Washington D.C. 

20230

(NOT FWS)

East of water 

tower

Bent 3/21/10 None

Interpretive Signs 

There are currently no interpretive signs on Protection Island National Wildlife Refuge 

and only one off-refuge interpretive sign, a panel located at John Wayne Marina. 

However, the Comprehensive Conservation Plan calls for establishing an off-refuge 

interpretive sign program.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-13

Off-Refuge Interpretive Signs (proposed)

* Locations being considered for interpretive panels:

- John Wayne Marina (replace existing)

- Port Townsend Marina

- Miller Peninsula State Park (a future park plan)

* Specific locations to be determined

 

Material: TBD

Future Interpretive Sign Specification and Placement Criteria (Interpretive)

Description: Protection Island Interpretive Panel

Text: TBD

Dimensions: TBD

Signs Inspection and Maintenance

Island caretakers will be responsible for routine inspections and maintenance of all signs. 

Under normal conditions all island signs will be visually inspected on a monthly basis 

and physically inspected on an annual basis. In addition, caretakers and staff will assess 

for sign damage as soon after high wind events as possible to insure signs have not been 

lost or damaged. Any sign damage will be reported immediately to the Refuge Manager

or Deputy Manager. Materials necessary to repair signs will be kept on the island in the 

maintenance building. These materials will include replacement USFWS shields, posts, 

cribbing, tools, and bolts. Due to their size and expense, most replacement signs will be 

stored at the Refuge Complex Headquarters at 715 Holgerson Rd. in Sequim, 

Washington, or made to order as needed. A review of this sign plan will occur every 5 

years unless conditions necessitate an earlier review. 

 

1. Protection Island NWR establishing authority: Protection Island National Wildlife 

References

 Refuge Act, Public Law 977-333, Oct 15, 1982, 96 Stat. 1623 

2. Washington Department of Natural Resources, Withdrawal Order 88 017, 1988

3. Memorandum of Understanding regarding Protection Island between WDFW and 

 USFWS, 1995 

4. U.S. Fish and Wildlife Service Sign Manual, Director’s Memorandum signed by 

 Acting Assistant Regional Director Carolyn Bohan, May 15, 1992, updated 1998
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-14

San Juan Islands National Wildlife Refuge 

Island, San Juan, Skagit, and Whatcom Counties, Washington

 USFWS

Sign Inventory and 

Maintenance Plan

U.S. Fish and Wildlife Service

August 2010
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-15

San Juan Islands National Wildlife Refuge is comprised of 83 rocks, reefs and islands 

located in the San Juan Archipelago, which lies approximately 85 miles northwest of 

Seattle, Washington. The archipelago includes 172 islands in an area encompassing 

about 175 square miles and borders the U.S./Canadian international boundary. The 

refuge is managed by the U.S. Fish and Wildlife Service as part of the National Wildlife 

Refuge System. 

Most (81 islands) of the San Juan Islands NWR are also designated wilderness and are 

known as the San Juan Islands Wilderness Area. The only refuge units (islands) that are 

not designated wilderness are Smith and Minor Islands, Turn Island, and a 2-acre portion 

of the 135 acre Matia Island. 

Note: Many Refuge signs are in poor condition and should be repaired or replaced. 

There is a pressing need to complete a thorough inspection of all refuge signs and begin a 

systematic replacement/repair regime. However, such an effort is complicated by the 

remote nature of the refuge, rugged island terrain, dangerous currents, and short boating 

season. Maintaining signs on islands is inherently more difficult and more expensive 

than maintaining signs on the mainland. This is further complicated by wildlife 

disturbance considerations. The following is intended to be a starting point for the 

further development of a comprehensive sign inventory and maintenance plan. 

The area is popular for sightseeing cruises including wildlife viewing, recreational 

boating and kayaking, diving, and commercial fishing and crabbing. However, only two 

Refuge islands are open to the public, Matia and Turn. The whole of Turn Island and the 

2-acre recreation area on Matia are open year round. Additionally there is a public trail 

through the otherwise closed wilderness area on Matia Island. Both islands allow 

overnight camping in designated sites which are maintained by the Washington State 

Parks and Recreation Commission (WSPRC). The primary recreational activities on both 

islands are hiking, wildlife viewing and photography, and camping. 

Use and Visitation

Matia Island is remotely located in the far northeast corner of the archipelago and 

receives approximately 10,500 visitors annually, while Turn Island is located just outside 

of busy Friday Harbor, the county seat, and receives approximately 13,500 visitors each 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-16

year. Although WSPRC maintains most of the infrastructure on these islands, including 

some signs, an information kiosk on Matia, and camping and restroom facilities, the 

Service maintains all Service signs. 

The following maps show sign locations for Matia and Turn Islands. The round symbol 

shows the location of the Island’s “entrance sign” while square symbols represent 

informational signs. Triangular symbols represent standard service boundary signs and 

the star symbol on Matia Island represents the location of the wilderness trailhead sign. 

In addition, both islands have signs posted and maintained by the WSPRC which are not 

covered under this plan. 

Public Use Areas

Matia Island Signs

 Matia Island “Entrance” sign Matia Island NW Cove
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-17

 Matia Is. Wilderness Trailhead (FWS) Matia Island kiosk (WSPRC)

Turn Island Signs

 Turn Island “Entrance” sign “Entrance” sign and information kiosk

Regulatory Signs
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-18

Signs will meet the specifications set forth in the USFWS Sign Manual. (1) Signs posted 

within the refuge will have galvanized or epoxy coated steel or wooden posts and 

supports and will be constructed of coated steel or high quality, medium density overlay 

(MDO) 3⁄4 inch plywood, except as otherwise indicated. Sign background color will be 

white or brown and lettering will be white or black, or, in the case of standard USFWS 

signs, dark blue. Text font will be Helvetica Medium. All large plywood signs will have 

the UFWS reflective shield measuring a minimum of 10” wide by 12” tall except as 

otherwise indicated.

Sign Specification and Placement Criteria (Regulatory)

Certain sensitive habitat locations such as seabird nesting sites will utilize large format

signs which can be read unaided from the water at least 200 yards offshore. These signs 

may also include the National Wildlife Refuge System’s Blue Goose Logo. Large format 

signs are approximately 6’ wide and 4 – 5’ high. These signs should be well supported to 

protect against high winds common in the area. There are currently 16 islands with large 

format signs. Due to the expense of installing and maintaining large format signs and 

their visually obtrusive nature, the number of islands with such signs will be reduced to 

10 or less in the next 5 years. Each island will be evaluated based on the following 

criteria; habitat/wildlife sensitivity, marine traffic, and trespassing issues to determine 

sign needs.

 

Section 4(b)(2) of The Wilderness Act of 1964 dictates that wilderness areas shall be 

administered so as to preserve their wilderness character. That includes minimizing nonnatural features. The act states no signs will be placed in wilderness areas except those 

which are determined to be absolutely necessary for effective administration. Where the 

Refuge Manager determines signs are necessary in wilderness, such as in wildlife areas 

particularly sensitive to human disturbance, the minimal tool concept will be utilized. 

Wilderness Areas

The concept relies on a minimum requirement analysis, which means that when 

planning necessary actions such as installing signage, management will use the 

minimum methods needed to accomplish the objective. Staff will develop 

alternatives and methods that result in minimum impacts and will utilize tools that 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-19

allow the installation to be accomplished safely with a minimal amount of impairment 

to the wilderness character.

Standard USFWS “closed area” signs will be utilized on a limited case-by-case basis as 

determined by the Refuge Manager to warn visitors to avoid closed and/or hazardous 

areas. On closed islands, these signs will be replaced with special order signs that read: 

“Island Closed, No Entry.” Such signs will otherwise be the same as the current standard 

closed area signs and will be used sparingly in wilderness areas to warn of particularly 

sensitive habitats such as seabird nesting locations. Where practicable these signs will be 

posted on standard galvanized steel or wood posts buried at least 2’ deep. However, 

island terrain may dictate a different attachment system such as hanging signs with steel 

chains. When utilizing such systems, installers should insure that the signs cannot turn 

over or wear against the mounting surface. If “closed area” or “closed island” signs are 

posted at or near boundaries, these signs will be paired with standard refuge boundary 

signs. These signs measure 11” x 14”.

Standard USFWS signs modified for island use paired with refuge boundary signs

In areas determined to be “wildlife sensitive,” such as seabird nesting sites, it is important 

to maintain a larger disturbance buffer. At such locations the Refuge Manager may elect 

to install larger signs that can be read from a greater distance. These signs will measure 

approximately 15” x 20” or 22” x 28”. The specific sign size utilized will be determined 

on a case-by-case basis. See the Wilderness Area section above for more information on 

installing signs on wilderness islands while employing the minimal tool concept. In 

general it is anticipated that the 15” x 20” version will be of adequate size to warn vessels 

at 200 yards. However, because it is not always practicable to mount signs on the 

shoreline, it may be necessary to use the larger 22” x 28” versions where signs are 

installed on the tops or interiors of islands. 

Description: Closed area, Island Closed, Refuge Boundary

Sign Specification and Placement Criteria (Regulatory)

Material: Coated metal

Text:

- Closed Area (Standard): Area Beyond This Sign Closed, All Public Entry Prohibited

- Island Closed (Modified): Island Closed, No Entry, All Public Entry Prohibited

- Refuge Boundary (Standard): National Wildlife Refuge, Unauthorized Entry Prohibited, 

 U.S. Department of the Interior, Fish and Wildlife Service

Color: Blue text on white background

Dimensions: 11” X 14”

Placement criteria for “closed area” and “island closed” signs: used in closed areas 

and/or hazardous locations closed by refuge management adjacent to public access areas. 

 Note: In general, when posted on a refuge boundary these signs will be mounted 

directly below a standard “NWR Boundary” sign.

Placement criteria for boundary signs: used at refuge boundaries in non-wilderness 

areas. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-20

Spacing: Generally not more than 1⁄4 mile distance between signs on a continuous 

boundary. However, terrain may dictate the need for additional signs. On small islands it 

may be sufficient to install a single post with signs facing in opposite directions.

ISLAND

CLOSED

NO

ENTRY

ALL PUBLIC ENTRY PROHIBITED

Description: Large format

Special Purpose (Regulatory)

Material: High quality 3⁄4” MDO plywood

Text: 

- Current: National Wildlife Refuge, To Protect Wildlife Stay Away 200 Yards

- Replacement: National Wildlife Refuge, Island Closed, Keep Off 200 Yards to Protect 

 Wildlife

Color: White or brown background, blue and black text

Dimensions: 6’ X 4 – 5’

Location: Wildlife disturbance sensitive areas

ISLAND CLOSED

KEEP OFF

200 YARDS

TO PROTECT WILDLIFE

NATIONAL

WILDLIFE 

REFUGE

 

Interpretive Signs 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-21

There are currently no truly interpretive signs in the San Juan Islands National Wildlife 

Refuge, although some signs do provide general information. However, the 

Comprehensive Conservation Plan calls for establishing an interpretive sign program. 

- Matia Island, 1 refuge-wide panel, up to 3 island specific signs

Future on-refuge interpretive signs (proposed)

Locations being considered: Rolfe cove, both ends of the wilderness trail

- Turn Island, up to 3 refuge-wide panels, up to 5 island specific signs

Locations being considered: West beach adjacent to mooring area, both ends of 

the outer loop trail, and various locations along the loop trail and camping area 

Future off-refuge interpretive signs

Locations being considered for interpretive panels:

Friday Harbor, Roche Harbor, Lopez Island (2), Orcas Island, and Shaw Island

San Juan Islands locations

Bellingham and Anacortes

Mainland locations

General Information Signs 

 

Material: Wood, 3⁄4” MDO plywood

Sign Specification and Placement Criteria

Description: Matia and Turn Island identifying signs

Text: 

- Matia Island

- Turn Island

- Matia Island Wilderness Trail, This one mile loop takes you through the old 

growth forest of the Matia Island wilderness, Please Stay On The Trail, No Pets 

Allowed
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-22

Sign Inventory 

#15 Hall Island #15 Hall Island

 #68 Bird (Rock) Island #78 Puffin Island

#81 Williamson Island (Rocks)

San Juan IslandsNWR Sign Inventory 2007 (the most recent comprehensive survey) 

 # Island Name Signs and Condition Recommendations

1 Small Island

3 signs on 1 post -- blue goose, 

wilderness (faces North). 

Signs face North and South. All 

Faded.

Replace all signs
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-23

 # Island Name Signs and Condition Recommendations

2A

Rum & Rim 

Islands No signs on North island. 

None

2B

Rum & Rim 

Islands No signs on South island. 

None

3 Fortress Island

Signs on East side - 3 on chain; South 

side- 3 on chain (boundary, blue 

goose, closure). All signs faded.

Replace all signs

4 Skull Island

1 boundary, 1 wilderness sign -- both 

on same post, both down. Post on 

East side.

Replace and repair all signs 

except wilderness

5 Crab Island No sign. None

6 Boulder Island

North side - blue goose, wilderness 

signs on chain. Faded. 

Replace all signs

7 Davidson Rock Under water, no signs. None

8 Castle Island

Area closed, wilderness signs on West 

side. Faded wilderness, OK condition 

for closure sign. Area closed sign on 

North side behind grass, falling down 

on post. East side has 3 signs on

chain - faded blue goose, closure, 

boundary.

Replace and repair all signs

9 Blind Island

3 signs on chain on South side, turned 

over. Unable to read.

Replace all signs

10 Aleck Rocks No signs. None

11 Swirl Island

3 signs on chain on North side, 2 

flipped and 3rd is faded; sign frame on 

top is down

Replace and repair all signs

12 Unnamed Rock No signs. None

13 Unnamed

North island has "Private Property" 

sign. Possible former sign on South 

side is fallen or in grass? SURVEY 

required on North island because 

island is signed "PRIVATE" and 

connected to mainland.

Replace and repair all signs

Survey island

14 Unnamed No signs. None

15 Hall Island

Large sign on North is on side, fallen 

flat.

Replace and repair all signs

16 Unnamed No signs. None

17 Secar Rock No signs. None

18 Unnamed No signs. None

19 Unnamed No signs. None

20 Unnamed No signs. None

21 Mummy Rocks No signs. None

22 Unnamed No signs. None

23 Shark Reef No signs. None

24 Harbor Rock No signs. None

25

North Pacific 

Rock No signs.

None
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-24

 # Island Name Signs and Condition Recommendations

26 Halftide Rocks No signs. None

27 Unnamed No signs. None

28 Low Island

2 large format come together in 

triangle (back to back). 2 small signs 

facing East and West on 1 post 

chained to ground. Blue goose on 

top, wilderness on bottom (faded out 

completely).

Replace all signs except 

wilderness

29 Pole Island

Large "Slow - No wake" signs on both 

sides. 

None

30 Barren Island

Large format sign chained down faces 

South, needs new decal. 2 signs on 

post - faded, face East.

Replace all signs or decals

31 Battleship Island

2 Large format signs chained down to 

ground. Need new decals and are 

faded. 2 signs on chain on West 

including blue goose. 2 additional 

signs - 1 turned. 2 signs faded out. 

Replace all signs or decals

32 Sentinel Rock No signs. None

33 Center Reef No signs. No day beacon. None

34 Gull Reef No signs. None

35 Ripple Island

1) Large format sign. Needs new 

decal. 3 signs in overgrown area on 

post. Blue goose, closure, boundary. 

Sign on West side by beach.

Replace all signs or decals

36

Unnamed 

(Shag Reef) No signs.

None

37

Unnamed 

(Little Cactus 

Island) Metal sign on post lying flat on ground. 

Used to be on high point. 

Replace and repair all signs

38 Gull Rock

Small sign at East side beach. Blue 

goose and closure. Large format sign. 

3 signs on chain on South finger -

Blue goose, wilderness, closure.

Replace all signs or decals 

except wilderness

39 Flattop Island

3 signs on chain, faded; boundary at 

bottom, then closed area and blue 

goose. 2 Large format signs, 1 facing 

NE and 1 facing W – both need 

replacing.

Replace all signs or decals

40 White Rock No signs. None

41 Mouatt Reef No signs. Underwater. None

42 Skipjack Island

Light on NW end. 2 Large format 

older signs, 1 facing SW, 1 facing E. 

Both need new decals. 3 small signs 

on chain. All faded. 

Replace all signs or decals

43 Unnamed No signs. None

44 Clements Reef No signs. Buoy to W of reef. None

45 Unnamed No signs. Danger daymark to E. None

46 Parker Reef No signs. Light & daymark on reef. None
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-25

 # Island Name Signs and Condition Recommendations

47

Lone Tree 

Island (The 

Sisters)

Large format sign facing NW. Newer 

sign, needs new decal. 3 signs on 

chain. All turned around. Light. 

Replace all signs or decals

48

Little Sister 

(The Sisters)

Sign on chain facing W. Turned. 2 

Signs on chain facing N, turned 

around.

Replace all signs

49 Unnamed

No signs. Navigation aid. Wasp 

Passage Light. Made of wood.

None

50 Tift Rocks

3 signs on post. The only readable 

sign Is Area Closed. Top and bottom 

signs faded.

Replace all signs

51 Reef Point No signs. None

52 Turn Rock

No signs. USCG channel marker #3 

Light/daymark

None

53 Shag Rock No signs. Daymark/daybeacon None

54 Flower Island

3 signs on chain west side, bottom is 

boundary, middle is closed area, top is 

blue goose boundary. All faded.

Replace all signs

55 Willow Island

W - 3 signs on chain, faded, turned. 

E- sign on post on ground. Can't see 

text.

Replace and repair all signs

56 Lawson Rock

No signs. Underwater. Navigation 

Aid.

None

57 Pointer Island No signs. None

58 Black Rock No signs. Navigation aid. None

59 Spindle Rock No signs. Daybeacon. None

60 Brown Rock

2 signs. Both faded. Blue goose & 

Wilderness.

Replace all signs

61 Unnamed No signs. None

62

South Peapod 

(Peapod Rocks) Old large format.

Replace decal

63

Unnamed 

(Peapod Rocks) No signs.

None

64

North Peapod 

(Peapod Rocks)

Old style large format sign. Faded. 3 

signs on chain, blue goose, 

wilderness, closed area. All in OK 

condition.

Replace all signs and 

decals

65 Eliza Rock No signs. Junction light/daymark. None

66 Viti Rocks

Large format sign. Needs new decals. 

Small sign turned on channel.

Replace all signs and 

decals

68 Bird Rock

No sign. Bird Rock Light and Danger 

Rock daymark.

None

69 Unnamed No signs. None

70 Low Island

Area closed sign on N. Fallen down. 2 

signs on 1 post facing N, blue goose 

and wilderness. Good condition.

Replace and repair bad 

signs except wilderness

71 Nob Island

Sign on small island on post on 

ground. On big island - 2 signs on 

chain, blue goose on top, Area closed 

Replace all signs
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-26

 # Island Name Signs and Condition Recommendations

on bottom. Area closed sign turned 

around.

72 Unnamed No signs. None

73 Unnamed

Blue goose and wilderness signs 

faded and facing W and falling down 

to NE. Signs located on W tip of 

island.

Replace and repair all signs 

except wilderness

74 Unnamed No signs. None

75 Smith Island Inventory

76 Minor Island Inventory

77 Matia Island

3 Interpretive signs (Matia Island, 

rules, WSPRC). 4 Small faded signs -

can't read. 

Remove faded signs

78 Puffin Island

3 faded small signs on chain. 2) Old 

large format sign faces S. Needs new 

decal. facing S. Light/daymark.

Replace all signs and 

decals

79 Turn Island

6 small faded signs. Large Turn 

Island interpretive sign, Dogs on leash 

sign, Take it in/Take it out signs in 

good condition. Harbor speed sign. 

Small sign facing E faded.

Replace all bad signs

80 Bird Rocks

Large format brown sign facing E 

located on 2nd rock from S. Small 

signs on S rock.

Replace all signs and 

decals

81

Williamson 

Rocks

Large format sign. 2 small signs on 1 

post.

Replace all signs and 

decals

82 Colville Island

2 small signs, blue goose and closed 

area on post on E rock, placed at 90 

degree angles. Small unreadable sign 

over closed area sign on SE side of W 

rock. Both on 1 post. Small blue 

goose sign over closed area sign on 

SW side of W rock. Both on 1 post. 

Large format sign on E side of W rock. 

Good condition. Turned from original 

angle to SE (was facing NE).

Replace and repair all signs

83 Buck Island No signs. None

84 Bare Island

Old large format sign on SW. Needs 

new decal. 3 signs on chain. All 

turned.

Replace all signs and 

decals

All signs will be visually inspected on an annual basis using. In addition, volunteers and 

staff will assess for sign damage as soon after high wind events as possible to insure signs 

have not been lost or damaged. Any sign damage will be reported immediately to the 

Refuge Manager or Deputy Manager. Materials necessary to repair signs will be stored 

at the Refuge Complex Headquarters at 715 Holgerson Rd. in Sequim, Washington, or 

made to order as needed. These materials will include replacement USFWS shields, 

posts, cribbing, tools, and bolts. Due to their size and expense, most large format 

Sign Inspection and Maintenance
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix D – Sign Plans D-27

replacement signs will be manufactured as needed. A review of this sign plan will occur 

every 5 years unless conditions necessitate an earlier review. 

 

1. U.S. Fish and Wildlife Service Sign Manual, Director’s Memorandum signed by 

References

 Acting Assistant Regional Director Carolyn Bohan, May 15, 1992, updated 1998
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-1

Appendix E. Integrated Pest Management Program

E.1 Background

Integrated Pest Management (IPM) is an interdisciplinary approach utilizing methods to prevent, 

eliminate, contain, and/or control pest species in concert with other management activities on refuge lands 

and waters to achieve wildlife and habitat management goals and objectives. It is also a scientificallybased, adaptive management process where available scientific information and best professional 

judgment of the refuge staff as well as other resource experts would be used to identify appropriate 

management strategies that can be modified and/or changed over time for effective, site-specific 

management of pest species. After a pest population threshold is determined, considering the 

achievement of resource objectives and the ecology of pest species, one or more methods or combinations 

thereof would be selected that are feasible, efficacious, and protective of non-target resources, including 

native species (fish, wildlife, and plants) and Service personnel, Service authorized agents, volunteers, 

and the public. Staff time and available funding would be considered when determining the 

feasibility/practicality of various treatments.

The IPM techniques to address pests are presented as CCP strategies (see Chapter 2 of this Draft 

CCP/EA) in an adaptive management context to achieve refuge resource objectives. In order to satisfy 

requirements for IPM planning as identified in the Director’s Memo (dated September 9,2004) entitled 

Integrated Pest Management Plans and Pesticide Use Proposals: Updates,

Guidance, and an Online Database, the following elements of an IPM program have been incorporated 

into this Draft CCP/EA.

• Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to 

indicate the need for and successful implementation of IPM techniques; and

• Monitoring before and/or after treatment to assess progress toward achieving objectives 

including pest thresholds.

Where pesticides would be necessary to address pests, this Appendix provides a structured procedure to 

evaluate potential effects of proposed uses involving ground-based applications to refuge biological 

resources and environmental quality in accordance with effects analyses presented in Chapter 6 

(Environmental Effects) of this Draft CCP/EA. Only pesticide uses that likely would cause minor, 

temporary, or localized effects to refuge biological resources and environmental quality with appropriate 

best management practices (BMPs), where necessary, would be allowed for use on the refuge.

This Appendix does not describe the more detailed process to evaluate potential effects associated with 

aerial applications of pesticides. Moreover, it does not address effects of mosquito control with pesticides 

(larvicides, pupacides, or adulticides) based upon identified human health threats and the presence of 

disease-carrying mosquitoes in sufficient numbers from monitoring conducted on a refuge. However, the 

basic framework to assess potential effects to refuge biological resources and environmental quality from 

aerial application of pesticides or use of insecticides for mosquito management would be similar to the 

process described in this Appendix for ground-based treatments of other pesticides.

E.2 Pest Management Policies

In accordance with Service policy 7 RM 14 (Pest Control), wildlife and plant pests on units of the 

National Wildlife Refuge System can be controlled to assure balanced wildlife and fish populations in 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-2

support of refuge-specific wildlife and habitat management objectives. Pest control on Federal (refuge) 

lands and waters also is authorized under the following legal mandates:

• National Wildlife Refuge System Administration Act of 1966, as amended (16 USC

668dd-668ee);

• Plant Protection Act of 2000 (7 USC 7701 et seq.);

• Noxious Weed Control and Eradication Act of 2004 (7 USC 7781-7786, Subtitle E);

• Federal Insecticide, Fungicide, and Rodenticide Act of 1996 (7 USC 136-136y);

• National Invasive Species Act of 1996 (16 USC 4701);

• Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 USC 4701);

• Food Quality Protection Act of 1996 (7 USC 136);

• Executive Order 13148, Section 601(a);

• Executive Order 13112; and

• Animal Damage Control Act of 1931 (7 USC 426-426c, 46 Stat. 1468).

Pests are defined as “...living organisms that may interfere with the site-specific purposes, operations, or 

management objectives or that jeopardize human health or safety” from Department policy 517 DM 1 

(Integrated Pest Management Policy). Similarly, this policy defines an invasive species as “a species that 

is non-native to the ecosystem under consideration and whose introduction causes or is likely to cause 

economic or environmental harm or harm to human health.” Throughout the remainder of this Draft 

CCP/EA, the terms pest and invasive species are used interchangeably because they both can 

prevent/impede achievement of refuge wildlife and habitat objectives and/or degrade environmental 

quality.

In general, control of pests (vertebrate or invertebrate) on the refuge would conserve and protect the 

nation’s fish, wildlife, and plant resources as well as maintain environmental quality. From 7 RM 14, 

animal or plant species, which are considered pests, may be managed if the following criteria are met:

• Threat to human health and well being or private property, the acceptable level of damage by the 

pest has been exceeded, or State or local government has designated the pest as noxious;

• Detrimental to resource objectives as specified in a refuge resource management plan (e.g.,

comprehensive conservation plan, habitat management plan), if available; and

• Control would not conflict with attainment of resource objectives or the purposes for which the 

refuge was established.

From 7 RM 14, the specific justifications for pest management activities on the refuge are the following:

• Protect human health and well being;

• Prevent substantial damage to important to refuge resources;

• Protect newly introduced or re-established native species;

• Control nonnative (exotic) species in order to support existence of populations of native species;

• Prevent damage to private property; and

• Provide the public with quality, compatible wildlife-dependent recreational opportunities.

Based upon 50 CFR 31.14 (Official Animal Control Operations), animal species, which are surplus or 

detrimental to the management program of a refuge area, may be taken in accordance with Federal and 

state laws and regulations by Federal or state personnel or by permit issued to private individuals. In 

addition, animal species which are damaging or destroying Federal property within a refuge area may be 

taken or destroyed by Federal personnel. Within 7 RM15.3, the following are more specific justifications 

for management of furbearing animals using trapping on a refuge:

• “To maintain furbearer populations at levels compatible with refuge and surrounding habitat and 

with refuge objectives which may involve habitat manipulations.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-3

• To contribute to the attainment of national migratory bird, mammal, nonmigratory bird, and 

endangered species objectives or goals.

• To minimize furbearer damage to physical facilities (e.g., dikes and water control structures).

• To minimize competition with or interaction among wildlife populations and species that conflict 

with refuge objectives.

• To minimize the occurrence of high population densities, which have the potential to transmit 

contagious diseases [to] humans, among furbearer populations, or other wildlife species, or 

domestic animals.

• To provide authorized individuals with quality wildlife-oriented recreational experiences, 

education opportunities, and opportunities to utilize a renewable natural resource.” 

Animal species damaging/destroying federal property and/or detrimental to the management program of a 

refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control Operations). Based 

upon 7 RM 14.7E, a pest control proposal is required, in some cases, to initiate a control program on 

refuge lands. The required elements of a pest control proposal are described in 7 RM 14.7E. However, a 

pest control proposal is not required under the following scenarios:

• Routine protection of refuge buildings, structures (e.g., dikes, levees, water control structures), 

and facilities not involving prohibited chemicals.

• Incidental control of exotics (e.g., non-native rats, non-native rabbits) or feral animals on refuge 

lands that are not protected by either federal or state laws, except where chemicals may be used.

• The use of routine habitat management techniques, selective trapping, on-refuge transfer, and 

physical and mechanical protection such as barriers and fences (including electric fences).

For example, the incidental removal of beavers damaging refuge infrastructure (e.g., clogging with 

subsequent damaging of water control structures) and/or negatively affecting habitats (e.g., removing 

woody species from existing or restored riparian) managed on refuge lands may be conducted without a 

pest control proposal. We recognize beavers are native species and most of their activities or refuge 

lands represent a natural process beneficial for maintaining wetland habitats. Exotic nutria, whose 

denning and burrowing activities in wetland dikes causes cave-ins and breaches, can be controlled using 

the most effective techniques considered site-specific factors without a pest control proposal. Along with 

the loss of quality wetland habitats associated with breaching of impoundments, the safety of refuge staffs 

and public (e.g., auto tour routes) driving on structurally compromised levees and dikes can be threatened

by sudden and unexpected cave-ins.

Trespass and feral animals also may be controlled on refuge lands. In accordance with 7 RM 14.9B(1), 

animals trespassing on refuge lands may be captured and returned to their owners or transferred to 

humane societies or local animal shelters, where feasible. Based upon 50 CFR 28.43 (Destruction of 

Dogs and Cats), dogs and cats running at large on a national wildlife refuge and observed in the act of 

killing, injuring, harassing, or molesting humans or wildlife may be disposed of in the interest of public 

safety and protection of wildlife. In accordance with 7 RM 14.9B(2), feral animals should be disposed 

by the most humane method(s) available and in accordance with relevant Service directives (including 

Executive Order 11643).

Disposed wildlife specimens may be donated or loaned to public institutions. Donation or loans of 

resident wildlife species will only be made after securing state approval (50 CFR 30.11 [Donation and 
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Appendix E – Integrated Pest Management Program E-4

Loan of Wildlife Specimens]). Surplus wildlife specimens may be sold alive or butchered, dressed and 

processed subject to Federal and State laws and regulations (50 CFR 30.12 [Sale of Wildlife Specimens]).

As previously stated for controlling animals damaging/destroying federal property and/or detrimental to 

the management program of a refuge, incidentally removing such animals from refuge lands does not 

require a pest control proposal.

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on the refuge:

• “We are prohibited by Executive Order, law, and policy from authorizing, funding, or carrying 

out actions that are likely to cause or promote the introduction or spread of invasive species in the 

United States or elsewhere.”

• “Manage invasive species to improve or stabilize biotic communities to minimize unacceptable 

change to ecosystem structure and function and prevent new and expanded infestations of 

invasive species. Conduct refuge habitat management activities to prevent, control, or eradicate 

invasive species...”

E.3 Strategies

To fully embrace IPM, the following strategies, where applicable, would be carefully considered on the 

refuge for each pest species:

E.3.1 Prevention

This would be the most effective and least expensive long-term management option for pests. It

encompasses methods to prevent new introductions or the spread of the established pests to infested areas. 

It requires identifying potential routes of invasion to reduce the likelihood of infestation. Hazard Analysis 

and Critical Control Points (HACCP) planning can be used to determine if current management activities 

on a refuge may introduce and/or spread invasive species in order to identify appropriate BMPs for 

prevention. See http://www.haccp-nrm.org/ for more information about HACCP planning.

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill; exclusion 

methods (e.g., barriers); and/or sanitation methods (e.g., wash stations) to prevent reintroductions by 

various mechanisms including vehicles, personnel, livestock, and horses. Because invasive species are 

frequently the first to establish in newly disturbed sites, prevention would require a reporting mechanism 

for early detection of new pest occurrences with quick response to eliminate any new satellite pest 

populations. Prevention would require consideration of the scale and scope of land management activities 

that may promote pest establishment within uninfested areas or promote reproduction and spread of 

existing populations. Along with preventing initial introduction, prevention would involve halting the 

spread of existing infestations to new sites (Mullin et al. 2000). The primary reason of prevention would 

be to keep pest-free lands or waters from becoming infested. Executive Order 11312 emphasizes the 

priority for prevention with respect to managing pests.

The following would be methods to prevent the introduction and/or spread of pests on refuge lands:

• Before beginning ground-disturbing activities (e.g., disking, scraping), inventory and prioritize 

pest infestations in project operating areas and along access routes. Refuge staff would identify 

pest species on site or within reasonably expected potential invasion vicinity. Where possible, the 

refuge staff would begin project activities in uninfested areas before working in pest-infested 

areas.
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Appendix E – Integrated Pest Management Program E-5

• The refuge staff would locate and use pest-free project staging areas. They would avoid or 

minimize travel through pest-infested areas, or restrict to those periods when spread of seed or 

propagules of invasive plants would be least likely.

• The refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. The refuge staff would clean equipment before 

entering lands at on-refuge approved cleaning site(s). This practice does not pertain to vehicles 

traveling frequently in and out of the project area that will remain on roadways. Seeds and plant 

parts of pest plants would need to be collected, where practical. The refuge staff would remove 

mud, dirt, and plant parts from project equipment before moving it into a project area.

• The refuge staff would clean all equipment before leaving the project site, if operating in areas 

infested with pests. The refuge staff would determine the need for, and when appropriate, 

identify sanitation sites where equipment can be cleaned.

• Refuge staffs, their authorized agents, and refuge volunteers would, where possible, inspect, 

remove, and properly dispose of seeds and parts of invasive plants found on their clothing and 

equipment. Proper disposal means bagging the seeds and plant parts and then properly discarding 

them (e.g., incinerating).

• The refuge staff would evaluate options, including closure, to restrict the traffic on sites with ongoing restoration of desired vegetation. The refuge staff would revegetate disturbed soil (except 

travel ways on surfaced projects) to optimize plant establishment for each specific site. 

Revegetation may include topsoil replacement, planting, seeding, fertilization, liming, and weedfree mulching as necessary. The refuge staff would use native material, where appropriate and 

feasible. The refuge staff would use certified weed-free or weed-seed-free hay or straw where 

certified materials are required and/or are reasonably available.

• The refuge staff would provide information, training, and appropriate pest identification materials 

to refuge staffs, permit holders, and recreational visitors. The refuge staff would educate them 

about pest identification, biology, impacts, and effective prevention measures.

• The refuge staff would require grazing permittees to utilize preventative measures for their 

livestock while on refuge lands.

• The refuge staff would inspect borrow material for invasive plants prior to use and transport onto 

and/or within refuge lands.

• The refuge staff would consider invasive plants in planning for road maintenance activities.

• The refuge staff would restrict off road travel to designated routes. 

The following would be methods to prevent the introduction and/or spread of pests into refuge waters:

The refuge staff would inspect boats (including air boats), trailers, and other boatingEquipment. 

Where possible, the refuge staff would remove any visible plants, animals, or mud before leaving 

any waters or boat launching facilities. The refuge staff would drain water from motor, live well, 

bilge, and transom wells while on land before leaving the site. The refuge staff would wash and 

dry boats, downriggers, anchors, nets, floors of boats, propellers, axles, trailers, and other boating 

equipment to kill pests not visible at the boat launch.

• Before transporting to new waters, the refuge staff would rinse boat and boating equipment with 

hot (40°C or 104°F) clean water, spray boat or trailer with high pressure water, or dry boat and 

equipment for at least 5 days, where possible.

• The refuge staff would maintain a l00-foot buffer of aquatic pest-free clearance around boat 

launches and docks or quarantine areas when cleaning around culverts, canals, or irrigation sites. 

The refuge staff would clean equipment before moving to new sites. Inspect and clean 

equipment before moving from one project area to another. These prevention methods to 

minimize/eliminate the introduction and/or spread of pests were taken verbatim or slightly 

modified from Appendix E of U.S. Forest Service (2005).
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Appendix E – Integrated Pest Management Program E-6

E.3.2 Mechanical/Physical Methods

These methods would remove and destroy, disrupt the growth of, or interfere with the reproduction of 

pest species. For plants species, these treatments can be accomplished by hand, hand tool (manual), or 

power tools (mechanical) and include pulling, grubbing, digging, tilling/disking, cutting, swathing, 

grinding, sheering, girdling, mowing, and mulching of the pest plants. Thermal techniques such as 

steaming, super-heated water, and hot foam may also be viable treatments.

For animal species, the refuge staff could use mechanical/physical methods that can include trapping. In 

some cases, non-lethally trapped animals could be relocated to off-refuge sites with prior approval from 

the state. Lethal trapping also can occur on a refuge as a wildlife management tool. Non-native animals 

(rats, rabbits, red fox, dogs, and cats) can be trapped at any time without further approval. Native 

predators (otter, raccoon, mink, etc.) can also be trapped, but these actions would require a trapping plan 

and annual trapping proposals with prior approval and coordination with the state as specified in 7 RM 

15. In accordance with 7 RM 15.8E, a refuge with a current furbearer management plan or programmatic 

management documents (e.g., CCP) with the required information (7 RM 15.8B) would fulfill refuge 

trapping plan requirements.

Each of these tools would be efficacious to some degree and applicable to specific situations. In general, 

mechanical controls can effectively control annual and biennial pest plants. However, to control 

perennial plants, the root system has to be destroyed or it will resprout and continue to grow and develop. 

Mechanical controls are typically not capable of destroying a perennial plant’s root system. Although 

some mechanical tools (e.g., disking, plowing) may damage root systems, they may stimulate regrowth,

producing a denser plant population that may aid in the spread depending upon the target species (e.g., 

Canada thistle). In addition, steep terrain and soil conditions would be major factors that can limit the use 

of many mechanical control methods.

Some mechanical control methods (e.g., mowing), which would be used in combination with herbicides, 

can be a very effective technique to control perennial species. For example, mowing perennial plants 

followed sequentially by treating the plant regrowth with a systemic herbicide often would improve the 

efficacy of the herbicide compared to herbicide treatment only.

E.3.3 Cultural Methods

These methods would involve manipulating habitat to increase pest mortality by reducing its suitability to 

the pest. Cultural methods would include water-level manipulation, mulching, winter cover crops, 

changing planting dates to minimize pest impact, prescribed burning (facilitate revegetation, increase 

herbicide efficacy, and remove litter to assist in emergence of desirable species), flaming with propane 

torches, trap crops, crop rotations that would include nonsusceptible crops, moisture management, 

addition of beneficial insect habitat, reducing clutter, vacuuming, proper trash disposal, planting or 

seeding desirable species to shade or out compete invasive plants, applying fertilizer to enhance desirable 

vegetation, prescriptive grazing, and other habitat alterations.

E.3.4 Biological Control Agents

Classical biological control would involve the deliberate introduction and management of natural enemies 

(parasites, predators, or pathogens) to reduce pest populations. Many of the most ecologically or 

economically damaging pest species in the United States originated in foreign countries. These newly 

introduced pests, which are free from the natural enemies found in their country or region of origin, may 

have a competitive advantage over cultivated and native species. This competitive advantage often 
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Appendix E – Integrated Pest Management Program E-7

allows introduced species to flourish, and they may cause widespread economic damage to crops or out 

compete and displace native vegetation. Once the introduced pest species population reaches a certain 

level, traditional methods of pest management may be cost prohibitive or impractical. Biological controls 

typically are used when these pest populations have become so widespread that eradication or effective 

control would be difficult or no longer practical.

Biological control has advantages as well as disadvantages. Benefits include reducing pesticide usage, 

host specificity for target pests, long-term self-perpetuating control, low cost/acre, capacity for searching 

and locating hosts, synchronizing biological control agents to hosts’ life cycles, and the unlikelihood that 

hosts will develop resistance to agents. Disadvantages include limited availability of agents from their 

native lands, the dependence of control on target species density, slow rate at which control occurs, 

biotype matching, the difficulty and expense of conflicts over control of the target pest, and host 

specificity when host populations are low.

A reduction in target species populations from biological controls is typically a slow process, and efficacy 

can be highly variable. It may not work well in a particular area although it does work well in other areas. 

Biological control agents would require specific environmental conditions to survive over time. Some of 

these conditions are understood, whereas, others are only partially understood or not at all.

Biological control agents would not eradicate a target pest. When using biological control agents, 

residual levels of the target pest typically are expected; the agent population level or survival would be 

dependent upon the density of its host. After the pest population decreases, the population of the 

biological control agent would decrease correspondingly. This is a natural cycle. Some pest populations 

(e.g., invasive plants) would tend to persist for several years after a biological control agent becomes 

established due to seed reserves in the soil, inefficiencies in the agent’s search behavior, and the natural 

lag in population buildup of the agent.

The full range of pest groups potentially found on refuge lands and waters would include diseases, 

invertebrates (insects, mollusks), vertebrates, and invasive plants (most common group).

Often it is assumed that biological control would address many if not most of these pest problems. There 

are several well documented success stories of biological control of invasive weed species in the Pacific 

Northwest, including Mediterranean sage, St Johnswort (Klamath weed) and tansy ragwort. Emerging 

success stories include the control of Dalmatian toadflax, diffuse knapweed, leafy spurge, purple 

loosestrife, and yellow star thistle. However, historically, each new introduction of a biological control 

agent in the United States has only about a 30 percent success rate (Coombs et al 2006). Refer to Coombs 

etal. (2006) for the status of biological control agents for invasive plants in the Pacific Northwest. 

Introduced species without desirable close relatives in the United States would generally be selected as 

biological controls. Natural enemies that are restricted to one or a few closely related plants in their 

country of origin are targeted as biological controls (Center et al..1997, Hasan and Ayres 1990).

The refuge staff would ensure introduced agents are approved by the applicable authorities.

Except for a small number of formulated biological control products registered by USEPA under

FIFRA, most biological control agents are regulated by the U.S.Department of Agriculture

(USDA) Animal Plant Health Inspection Service, Plant Protection and Quarantine (PPQ). State 

departments of agriculture and, in some cases, county agricultural commissioners or weed districts, have 

additional approval authority. 

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrols agents from another 

state. Form 526 may be obtained by writing:
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Appendix E – Integrated Pest Management Program E-8

USDA-APHIS-PPQ

Biological Assessment and Taxonomic Support

4700 River Road, Unit 113

Riverdale, MD 20737

Or through the internet at URL address:

http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html.

The Service strongly supports the development and legal and responsible use of appropriate, safe, and 

effective biological control agents for nuisance and nonindigenous or pest species.

State and county agriculture departments may also be sources for biological control agents or they may 

have information about where biological control agents may be obtained. Commercial sources should 

have an Application and Permit to Move Live Plant Pests and Noxious Weeds

(USDA-PPQ Form 226 USDA-APHIS-PPQ, Biological Assessment and Taxonomic Support,

4700 River Road, Unit 113, Riverdale, MD 20737) to release specific biological control agents in a state 

and/or county. Furthermore, certification regarding the biological control agent’s identity (genus, specific 

epithet, subspecies, and variety) and purity (e.g., parasite free, pathogen free, and biotic and abiotic 

contaminants) should be specified in purchase orders.

Biological control agents are subject to 7 RM 8 (Exotic Species Introduction and Management).

In addition, the refuge staff would follow the International Code of Best Practice for Classical

Biological Control of Weeds (http://sric.ucdavis.edu/exotic /exotic.htm) as ratified by delegates to the X 

International Symposium on Biological Control of Weeds, Bozeman, MT, July 9, 1999.

This code identifies the following:

• Release only approved biological control agents,

• Use the most effective agents,

• Document releases, and

• Monitor for impact to the target pest, non-target species, and the environment.

Biological control agents formulated as pesticide products and registered by the EPA (e.g., Bti) are also 

subject to PUP review and approval (see below).

A record of all releases would be maintained with date(s), location(s), and environmental conditions of 

the release site(s); the identity, quantity, and condition of the biological control agents released; and other 

relevant data and comments such as weather conditions. Systematic monitoring to determine the 

establishment and effectiveness of the release is also recommended.

NEPA documents regarding biological and other environmental effects of biological control agents

prepared by another Federal agency, where the scope is relevant to evaluation of releases on refuge lands, 

would be reviewed. Possible source agencies for such NEPA documents include the Bureau of Land 

Management, U.S. Forest Service, National Park Service, USDAAPHIS- PPQ, and the military services. 

It might be appropriate to incorporate by reference parts or all of existing document(s) from the review. 

Incorporating by reference (40 CFR 1502.21) is a technique used to avoid redundancies in analysis. It 

also can reduce the bulk of a Service NEPA document, which only must identify the documents that are 

incorporated by reference. In addition, relevant portions must be summarized in the Service’s NEPA 

document to the extent necessary to provide the decision maker and public with an understanding of 

relevance of the referenced material to the current analysis.

E.3.5 Pesticides
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Appendix E – Integrated Pest Management Program E-9

The selective use of pesticides would be based upon pest ecology (including mode of reproduction), the 

size and distribution of its populations, site-specific conditions (e.g., soils, topography), known efficacy 

under similar site conditions, and the capability to utilize best management practices (BMPs) to 

reduce/eliminate potential effects to non-target species, sensitive habitats, and potential to contaminate 

surface and groundwater. All pesticide usage (pesticide, target species, application rate, and method of 

application) would comply with the applicable Federal (FIFRA) and state regulations pertaining to 

pesticide use, safety, storage, disposal, and reporting. Before pesticides can be used to eradicate, control, 

or contain pests on refuge lands and waters, pesticide use proposals (PUPs) would be prepared and 

approved in accordance with 7 RM 14. Pesticide use proposal records would provide a detailed, time-, 

site-, and target-specific description of the proposed use of pesticides on the refuge. All PUPs would be 

created, approved, or disapproved, and stored in the Pesticide Use Proposal System (PUPS), which is a 

centralized database only accessible on the Service’s intranet (https://sds.fws.gov/pups). Only Service 

employees would be authorized to access PUP records for the refuge in this database.

Chemical (baits) control of non-native predators or herbivores maybe considered mainly for relatively 

small infestations. If control of large populations is needed and the use of chemical control methods is 

chosen, then a pesticide use proposal and step-down plan identifying all phases of the activity will be 

developed. Application equipment would be selected to provide site-specific delivery to target pests 

while minimizing/eliminating direct or indirect (e.g., drift) exposure to non-target areas and degradation 

of surface and groundwater quality. Where possible, target-specific equipment (e.g., backpack sprayer, 

wiper) would be used to treat target pests. Other target-specific equipment to apply pesticides would 

include soaked wicks or paint brushes for wiping vegetation and lances, hatchets, or syringes for direct 

injection into stems. Granular pesticides may be applied using seeders or other specialized dispensers. In 

contrast, aerial spraying (e.g., fixed wing or helicopter) would only be used where access is difficult 

(remoteness or fragile habitat) and/or the size/distribution of infestations precludes practical use of 

ground-based methods.

Because repeated use of one pesticide may allow resistant organisms to survive and reproduce, multiple 

pesticides with variable modes of action would be considered for treatments on refuge lands and waters. 

This is especially important if multiple applications within years and/or over a growing season likely 

would be necessary for habitat maintenance and restoration activities to achieve resource objectives. 

Integrated chemical and non-chemical controls also are highly effective, where practical, because 

pesticide resistant organisms can be removed from the site. Cost may not be the primary factor in 

selecting a pesticide for use on the refuge. If the least expensive pesticide would potentially harm natural 

resources or people, then a different product would be selected, if available. The most efficacious 

pesticide available with the least potential to degrade environment quality (soils, surface water, and 

groundwater) as well as least potential effect to native species and communities of fish, wildlife, plants, 

and their habitats would be acceptable for use on the refuge in the context of an IPM approach.

E.3.6 Habitat restoration/maintenance

Restoration and/or proper maintenance of refuge habitats associated with achieving wildlife and habitat 

objectives would be essential for long-term prevention, eradication, or control (at or below threshold 

levels) of pests. Promoting desirable plant communities through the manipulation of species composition, 

plant density, and growth rate is an essential component of invasive plant management (Masters et al. 

1996, Masters and Shelly 2001, Brooks et al. 2004). The following three components of succession 

could be manipulated through habitat maintenance and restoration, site availability, species availability, 

and species performance (Cox and Anderson 2004). Although a single method (e.g., herbicide treatment) 

may eliminate or suppress pest species in the short term, the resulting gaps and bare soil create niches that 

are conducive to further invasion by the species and/or other invasive plants. On degraded sites where 
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Appendix E – Integrated Pest Management Program E-10

desirable species are absent or in low abundance, revegetation with native/desirable grasses, forbs, and 

legumes may be necessary to direct and accelerate plant community recovery, and achieve site-specific 

objectives in a reasonable time frame. The selection of appropriate species for revegetation would be 

dependent on a number of factors including resource objectives and site-specific, abiotic factors (e.g., soil 

texture, precipitation/temperature regimes, and shade conditions). Seed availability and cost, ease of 

establishment, seed production, and competitive ability also would be important considerations.

E.4 Priorities for Treatments

For many refuges, the magnitude (number, distribution, and sizes of infestations) for pest problems is too 

extensive and beyond the available capital resources to effectively address during any single field season. 

To manage pests in the refuge, it would be essential to prioritize treatment of infestations. Highest 

priority treatments would be focused on early detection and rapid response to eliminate infestations of 

new pests, if possible. This would be especially important for aggressive pests potentially impacting 

species, species groups, communities, and/or habitats associated with refuge purpose(s), Refuge System 

resources of concern (federally listed species, migratory birds, selected marine mammals, and 

interjurisdictional fish), and native species for maintaining/restoring biological integrity, diversity, and 

environmental health. The next priority would be treating established pests that appear in one or more 

previously uninfested areas. 

Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of invasive plants 

eventually would infest an area larger than the established, source population. They also found that 

control efforts focusing on the large, main infestation rather than the new, small satellites reduced the 

chances of overall success. The lowest priority would be treating large infestations (sometimes 

monotypic stands) of well established pests. In this case, initial efforts would focus upon containment of 

the perimeter followed by work to control/eradicate the established infested area. If containment and/or 

control of a large infestation is not effective, then efforts would focus upon halting pest reproduction as 

the lowest priority.

Although state-listed noxious weeds would always have high priority for management, other pest species 

known to cause substantial ecological impact would also be considered. For example,

cheatgrass may not be listed by a state as noxious, but it can greatly alter fire regimes in shrub steppe 

habitats resulting in large monotypic stands that displace native bunch grasses, forbs, and shrubs. Pest 

control would likely require a multi-year commitment from the refuge staff. Essential to the long-term 

success of pest management would be pre- and post-treatment monitoring, assessment of the successes 

and failures of treatments, and development of new approaches when proposed methods do not achieve 

desired outcomes.

E.5 Best Management Practices

Best Management Practices (BMPs) can minimize or eliminate possible effects associated with pesticide 

usage to non-target species and/or sensitive habitats as well as degradation of water quality from drift, 

surface runoff, or leaching. Based upon the Department of the Interior’s Pesticide Use Policy (517 DM 1) 

and the Service’s Pest Management Policy and Responsibilities (30 AM 12), the use of applicable BMPs 

(where feasible) would likely ensure that pesticide uses may not adversely affect federally listed species 

and/or their critical habitats through determinations made using the process described in 50 CFR part 402.

The following are BMPs pertaining to mixing/handling and applying pesticides for all groundbased

treatments of pesticides, which would be considered and utilized, where feasible, based upon target- and 
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Appendix E – Integrated Pest Management Program E-11

site-specific factors and time-specific environmental conditions. Although not listed below, the most 

important BMP to eliminate/reduce potential impacts to non-target resources would be an IPM approach 

to prevent, control, eradicate, and contain pests.

E.5.1 Pesticide Handling and Mixing

• As a precaution against spilling, spray tanks would not be left unattended during filling.

• All pesticide containers would be triple rinsed and the rinsate would be used as water in the 

sprayer tank and applied to treatment areas.

• All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be used 

as part of the make-up water in the sprayer tank and applied to treatment areas.

• The refuge staff would empty rinsed pesticide containers for recycling at local herbicide container 

collection facilities.

• All unused pesticides would be properly discarded at a local “safe send” collection facility.

• Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in 

accordance with the label and in a manner safeguarding human health, fish, and wildlife and 

preventing soil and water contaminant.

• The refuge staff would consider the water quality parameters (e.g., pH, hardness) that are 

important to ensure greatest efficacy where specified on the pesticide label.

• All pesticide spills would be addressed immediately using procedures identified in the refuge spill 

respond plan.

E.5.2 Applying Pesticides

• Pesticide treatments would only be conducted by or under the supervision of Service 

personnel and non-Service applicators with the appropriate state or BLM certification to

safely and effectively conduct these activities on refuge lands and waters.

• The refuge staff would comply with all Federal, state, and local pesticide use laws and

regulations as well as Departmental, Service, and Refuge System pesticide-related

policies. For example, the refuge staff would use application equipment and apply rates

for the specific pest(s) identified on the pesticide label as required under FIFRA.

• Before each treatment season and prior to mixing or applying any product for the first

time each season, all applicators would review the labels, Material Safety Data Sheets

(MSDSs), and Pesticide Use Proposal (PUPs) for each pesticide, determining the target

pest, appropriate mix rate(s), Personal Protective Equipment (PPE), and other

requirements listed on the pesticide label.

• A 1-foot no-spray buffer from the water’s edge would be used, where applicable and where it

does not detrimentally influence effective control of pest species.

• Spot treatment would be used rather than broadcast applications of pesticides, where

practical.

• Applicators would use and adjust spray equipment to apply the coarsest droplet size

spectrum with optimal coverage of the target species while reducing drift.

• Applicators would use the largest droplet size that results in uniform coverage.

• Applicators would use drift reduction technologies such as low-drift nozzles, where

possible.

• Where possible, spraying would occur during low (average less than 10 mph and

preferably 3 to 7 mph) and consistent direction wind conditions with moderate

temperatures (typically lower than 85°

• Where possible, applicators would avoid spraying during inversion conditions (often

F).
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Appendix E – Integrated Pest Management Program E-12

associated with calm and very low wind conditions) that can cause large-scale herbicide

drift to non-target areas.

• Equipment would be calibrated regularly to ensure that the proper rate of pesticide is

applied to the target area or species.

• Spray applications would be made at the lowest height for uniform coverage of target

pests to minimize/eliminate potential drift.

• If windy conditions frequently occur during afternoons, spraying (especially boom

treatments) would typically be conducted during early morning hours.

• Spray applications would not be conducted on days with more than a 30 percent forecast

for rain within 6 hours, except for pesticides that are rapidly rain fast (e.g., glyphosate in

1 hour) to minimize/eliminate potential runoff.

• Where possible, applicators would use drift retardant adjuvants during spray applications,

especially adjacent to sensitive areas.

• Where possible, applicators would use a nontoxic dye to aid in identifying target area

treated as well as potential over spray or drift. A dye can also aid in detecting equipment

leaks. If a leak is discovered, the application would be stopped until repairs can be made

to the sprayer.

• For pesticide uses associated with cropland and facilities management, buffers, as

appropriate, would be used to protect sensitive habitats, especially wetlands and other

aquatic habitats.

• When drift cannot be sufficiently reduced through altering equipment set up and

application techniques, buffer zones may be identified to protect sensitive areas

downwind of applications. The refuge staff would only apply adjacent to sensitive areas

when the wind is blowing the opposite direction.

• Applicators would utilize scouting for early detection of pests to eliminate unnecessary

pesticide applications.

• The refuge staff would consider timing of application so native plants are protected (e.g.,

senescence) while effectively treating invasive plants.

• Rinsate from cleaning spray equipment after application would be recaptured and reused

or applied to an appropriate pest plant infestation.

• Application equipment (e.g., sprayer, ATV, tractor) would be thoroughly cleaned and

PPE would be removed/disposed of onsite by applicators after treatments to eliminate the

potential spread of pests to uninfested areas.

E.6 Safety

E.6.1 Personal Protective Equipment

All applicators would wear the specific personal protective equipment (PPE) identified on the pesticide 

label. The appropriate PPE will be worn at all times during handling, mixing, and applying. PPE can 

include the following disposable (e.g., Tyvek) or laundered coveralls; gloves (latex, rubber, or nitrile); 

rubber boots; and/or a respirator approved by the National Institute for Occupational Safety and Health 

(NIOSH). Because exposure to concentrated product is usually greatest during mixing, extra care should 

be taken while preparing pesticide solutions. Persons mixing these solutions can be best protected if they 

wear long gloves, an apron, footwear, and a face shield.

Coveralls and other protective clothing used during an application would be laundered separately from 

other laundry items. Transporting, storing, handling, mixing and disposing of pesticide containers will be 
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Appendix E – Integrated Pest Management Program E-13

consistent with label requirements, EPA, and Occupational Safety and Health Administration (OSHA) 

requirements, and Service policy.

If a respirator is necessary for a pesticide use, then the following requirements would be met in

accordance with Service safety policy—a written Respirator Program, fit testing, physical examination 

(including pulmonary function and blood work for contaminants), and proper storage of the respirator.

E.6.2 Notification

The restricted entry interval (REI) is the waiting period required after pesticide application.

Once the REI ends, individuals may safely enter a treated area without PPE. Refuge staff, authorized

management agents of the Service, volunteers, and members of the public who could be in or near a 

pesticide treated area within the stated re-entry time period on the label would be notified about treatment 

areas. Posting would occur at any site where individuals might inadvertently become exposed to a 

pesticide during other activities on the refuge. Where required by the label and/or state-specific 

regulations, sites would also be posted on its perimeter and at other likely locations of entry. The refuge 

staff would also notify appropriate private property owners of an intended application, including any 

private individuals who have requested notification. Special efforts would be made to contact nearby 

individuals who are beekeepers or who have expressed chemical sensitivities.

E.6.3 Medical Surveillance

Medical surveillance may be required for Service personnel who mix, apply, and/or monitor use of 

pesticides (see 242 FW 7 [Pesiticide Users] and 242 FW 4 [Medical Surveillance]). In accordance with 

draft Service policy (242 FW 7 [Pesticide Users Safety]), medical monitoring would be necessary for 

Service personnel and approved volunteers engaged in “frequent pesticide use” that is defined as a 

“pesticide applicator handling, mixing, and applying pesticides for 8 or more hours in any week or 16 or 

more hours in any 30 day period.” However, refuge cooperators (e.g., cooperative farmers) and other 

authorized agents (e.g., state and county employees) would be responsible for their own medical 

monitoring needs and costs. Standard examinations (at refuge expense) of appropriate refuge staff would 

be provided by the nearest certified occupational health and safety physician as determined by Federal 

Occupational Health.

E.6.4 Certification and Supervision of Pesticide Applicators

Appropriate refuge staff handling, mixing, and/or applying or supervising others engaged in pesticide use 

activities would be trained and state or Federally (BLM) licensed to apply pesticides to refuge lands or 

waters (242 FW 7). Preferably, all refuge staff participating in pest management activities involving 

pesticide usage would attend appropriate training. New staff unfamiliar with proper procedures for 

storing, mixing, handling, applying, and disposing of herbicides and containers would receive orientation 

and training before handling or using any products. Documentation of training would be kept in the files 

at the refuge office.

E.6.5 Record Keeping

E.6.5.1 Labels and material safety data sheets

Pesticide labels and MSDSs would be maintained at the refuge shop with laminated copies located in the 

mixing area. These documents would be carried by field applicators where possible. A written reference 

(e.g., note pad, chalk board, dry erase board) for each tank to be mixed would be kept in the mixing area 
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Appendix E – Integrated Pest Management Program E-14

for quick reference during mixing. In addition, approved PUPs stored in the PUPS database typically 

contain website links to pesticide labels and MSDSs.

E.6.5.2 Pesticide use proposals (PUPs)

A PUP would be prepared for each proposed pesticide use associated with annual pest management on 

refuge lands and waters. A PUP would include specific information about the proposed pesticide use 

including the common and chemical names of the pesticide(s), target pest species, size and location of 

treatment site(s), application rate(s) and method(s), and federally listed species determinations, where 

applicable.

In accordance with 30 AM 12 and 7 RM 14, PUPs would be required for the following:

• Uses of pesticides on lands and facilities owned or managed by the Service, including

properties managed by Service personnel as a result of the Food Security Act of 1985;

• Service projects by non-Service personnel on Service-owned or controlled lands and

facilities and other pest management activities that would be conducted by Service

personnel; and

• Where the Service would be responsible or provides funds for pest management

identified in protective covenants, easements, contracts, or agreements off Service lands.

In accordance with Service guidelines (Director’s memo [December 12, 2007]), a refuge staff may 

receive up to 5-year approvals for Washington Office and field reviewed proposed pesticide uses based 

upon meeting identified criteria, including an approved IPM plan, where necessary (see 

http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan (requirements described 

herein) can be completed independently or in association with a CCP or HMP if IPM strategies and 

potential environmental effects are adequately addressed within appropriate NEPA documentation. 

PUPs would be created, approved or disapproved, and stored as records in the Pesticide Use Proposal 

System (PUPS), which is centralized database on the Service’s intranet (https://sds.fws.gov/pups). Only 

Service employees can access PUP records in this database.

E.6.5.3 Pesticide usage

In accordance with 30 AM 12 and 7 RM 14, the refuge Project Leader would be required to maintain 

records of all pesticides annually applied on lands or waters under refuge jurisdiction. This would 

encompass pesticides applied by other Federal agencies, state and county governments, nongovernment 

applicators, including cooperators and their pest management service providers, with Service permission. 

For clarification, pesticide means all insecticides, insect and plant growth regulators, dessicants, 

herbicides, fungicides, rodenticides, acaricides, nematicides, fumigants, avicides, and piscicides.

The following usage information can be reported for approved PUPs in the PUPS database:

• Pesticide trade name(s)

• Active ingredient(s)

• Total acres treated

• Total amount of pesticides used (lbs or gallons)

• Total amount of active ingredient(s) used (lbs)

• Target pest(s)

• Efficacy (percent control)
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Appendix E – Integrated Pest Management Program E-15

To determine whether treatments are efficacious (eradicating, controlling, or containing the target pest) 

and achieving resource objectives, habitat and/or wildlife response would be monitored both pre- and 

post-treatment, where possible. Considering available annual funding and staffing, appropriate 

monitoring data regarding characteristics (attributes) of pest infestations (e.g., area, perimeter, degree of 

infestation-density, % cover, density) as well as habitat and/or wildlife response to treatments may be 

collected and stored in a relational database, preferably a geo-referenced data management system (e.g., 

Refuge Lands GIS [RLGIS]) to facilitate data analyses. In accordance with adaptive management, data 

analysis and interpretation would allow treatments to be modified or changed over time, as necessary, to 

achieve resource objectives considering site-specific conditions in conjunction with habitat and/or 

wildlife responses.

E.7 Evaluating Pesticide Use Proposals

Pesticides would only be used on the refuge for habitat management as well as croplands/facilities 

maintenance after approval of a PUP. Proposed pesticide uses on the refuge would only be approved 

where there would likely be minor, temporary, or localized effects to fish and wildlife species as well as 

minimal potential to degrade environmental quality. Potential effects to listed and non-listed species 

would be evaluated with quantitative ecological risk assessments. Potential effects to environmental 

quality would be based upon pesticide characteristics of environmental fate (water solubility, soil 

mobility, soil persistence, and volatilization) and a quantitative screening tool for potential to move to 

groundwater. Risk assessments as well as characteristics of environmental fate and potential to degrade 

water quality for pesticides would be documented in Chemical Profiles (see Section 7.5). These profiles 

would include threshold values for quantitative measures of ecological risk assessments and screening 

tools for environmental fate that represent minimal potential effects to species and environmental quality. 

Only pesticide uses with appropriate BMPs (see Section 4.0) for habitat management and 

cropland/facilities maintenance on the refuge that would potentially have minor, temporary, or localized 

effects on refuge biological and environmental quality (threshold values not exceeded) would be 

approved.

E.7.1 Overview of Ecological Risk Assessment

An ecological risk assessment process would be used to evaluate potential adverse effects to biological 

resources as a result of a pesticide(s) proposed for use on the refuge. It is an established quantitative and 

qualitative methodology for comparing and prioritizing risks of pesticides and conveying an estimate of 

the potential risk for an adverse effect. The quantitative methodology would be an efficient way to 

integrate best available scientific information regarding hazard, patterns of use (exposure), and doseresponse relationships in a manner that is useful for ecological risk decision-making. It would provide an 

effective way to evaluate potential effects where there is missing or unavailable scientific information 

(data gaps) to address reasonable, foreseeable adverse effects as required under 40 CFR Part 1502.22.

Protocols for ecological risk assessment of pesticide uses on the refuge were developed through research 

and established by the US Environmental Protection Agency (2004). Assumptions for these risk 

assessments are presented in Section 6.2.3.

The toxicological data used in ecological risk assessments are typically results of standardized laboratory 

studies provided by pesticide registrants to the US Environmental Protection Agency

(USEPA) to meet regulatory requirements under the Federal Insecticide, Fungicide and

Rodenticide Act of 1996 (FIFRA). These studies assess the acute (lethality) and chronic (reproductive) 

effects associated with short- and long-term exposure to pesticides on representative species of birds, 

mammals, freshwater fish, aquatic invertebrates, and terrestrial and aquatic plants, respectively (Table 1). 
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Appendix E – Integrated Pest Management Program E-16

Other effects data publicly available would also be utilized for risk assessment protocols described herein. 

Toxicity endpoint and environmental fate data are available from a variety of resources. Some of the 

more useful resources can be found in Section 7.5.

Table E.1 Ecotoxicity tests used to evaluate potential effects to birds, fish, and mammals to

establish toxicity endpoints for risk quotient calculations. 

Species Group Exposure Measurement endpoint 

Bird

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or

No Observed Adverse Effect Concentration (NOAEC)1

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or

No Observed Adverse Effect Concentration (NOAEC)2

Mammal Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or

No Observed Adverse Effect Concentration (NOAEC)3

1. Measurement endpoints typically include a variety of reproductive parameters (e.g., number of eggs, 

number of offspring, eggshell thickness, and number of cracked eggs).

2. Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time to 

hatch, growth, and time to swim-up.

3. Measurement endpoints include maternal toxicity, teratogenic effects or developmental anomalies, 

evidence of mutagenicity or genotoxicity, and interference with cellular mechanisms such as DNA 

synthesis and DNA repair.

E.7.2 Determining Ecological Risk to Fish and Wildlife

The potential for pesticides used on the refuge to cause direct adverse effects to fish and wildlife would be 

evaluated using EPA’s Ecological Risk Assessment Process (EPA 2004). This deterministic approach, 

which is based upon a two-phase process involving estimation of environmental concentrations and then 

characterization of risk, would be used for ecological risk assessments. This method integrates exposure 

estimates—estimated environmental concentration (EEC)—and toxicological endpoints (e.g., LC50 and 

oral LD50) to evaluate the potential for adverse effects to species groups (birds, mammals, and fish) 

representative of legal mandates for managing units of the Refuge System. This integration is achieved 

through risk quotients (RQs) calculated by dividing the EEC by acute and chronic toxicity values selected

from standardized toxicological endpoints or published effect (Table 1).

RQ = EEC/Toxicological Endpoint

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by EPA (1998) (Table 2). The 

LOC represents a quantitative threshold value for screening potential adverse effects to fish and wildlife 

resources associated with pesticide use. The following are four exposure-species group scenarios that 

would be examined to characterize ecological risk to fish and wildlife on the refuge: acute-listed species, 

acute-nonlisted species, chronic-listed species, and chronic-nonlisted species.

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from LC50 

and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, chronic risks 
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Appendix E – Integrated Pest Management Program E-17

would indicate the potential for adverse effects associated with long-term dietary exposure to pesticides 

from a single application or multiple applications over time (within a season and over years).

For characterization of chronic risks, the no observed concentration (NOAEC) or no observed effect 

concentration (NOEC) for reproduction would be used as toxicological endpoints for RQ calculations. 

Where available, the NOAEC would be preferred over a NOEC value. Listed species are those federally 

designated as threatened, endangered, or proposed in accordance with the Endangered Species Act of 

1973 (16 USC 1531-1544, 87 Stat.884, as amended-Public Law 93-205). For listed species, potential 

adverse effects would be assessed at the individual level because loss of individuals from a population 

could detrimentally impact a species. In contrast, risks to nonlisted species would consider effects at the 

population level. An RQ less than LOC for a taxonomic group would indicate the proposed pesticide use 

is “may affect, not likely to adversely affect” individuals (listed species) or populations (nonlisted 

species) of the taxonomic group (Table 2). In contrast, an RQ greater than LOC, would indicate an 

unacceptable ecological risk considering the potential for adverse effects.

Table E.2 Presumption of unacceptable risk for birds, fish, and mammals (EPA 1998)

Risk Presumption Level of Concern

Listed Species Non-listed Species

Acute Birds 0.1 0.5

Fish 0.05 0.5

Mammals 0.1 0.5

Chronic Birds 1.0 1.0

Fish 1.0 1.0

Mammals 1.0 1.0

E.7.2.1 Environmental exposure

Following release into the environment through application, pesticides would experience several different 

routes of environmental fate. Pesticides which would be sprayed can move through the air (e.g., particle 

or vapor drift) and may eventually end up in other parts of the environment, such as non-target vegetation, 

soil, or water. Pesticides applied directly to the soil may be washed off the soil into nearby bodies of 

surface water (e.g., surface runoff) or may percolate through the soil to lower soil layers and groundwater 

(e.g., leaching) (Baker and Miller 1999, Pope et al. 1999, Buttler et al. 998, Ramsay et al.1995, 

EXTOXNET 1993a). Pesticides which would be injected into the soil may also be subject to the latter 

two fates.

The aforementioned possibilities are by no means complete, but they do indicate that movement of

pesticides in the environment is very complex, with transfers occurring continually among different 

environmental compartments. In some cases, these exchanges occur not only between areas that are close 

together, but it also may involve transportation of pesticides over long distances (Barry 2004, Woods 

2004).

Terrestrial exposure

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be quantified 

using an EPA screening level approach (EPA 2004). This screening level approach is not affected by 

product formulation because it evaluates a pesticide’s active ingredient(s). This approach would vary 

depending upon the proposed pesticide application method, spray or granular.
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Appendix E – Integrated Pest Management Program E-18

Terrestrial-spray application

For spray applications, exposure would be determined using the Kanaga nomogram method

(EPA 2005a, EPA 2004, Pfleeger et al.1996) through the EPA’s Terrestrial Residue Exposure model (TREX) version 1.2.3 (EPA 2005b). To estimate the maximum (initial) pesticide residue on short grass 

(shorter than 20 cm tall) as a general food item category for terrestrial vertebrate species, T-REX input 

variables would include the following from the pesticide label: maximum pesticide application rate 

(pounds active ingredient acid equivalent/acre) and pesticide half-life (days) in soil. Although there are 

other food item categories (tall grasses; broadleaf plants and small insects; and fruits, pods, seeds and 

large insects), short grass was selected because it would yield maximum EECs (240 ppm per pound active 

ingredient/acre) for worst-case risk assessments. Short grass is not representative of forage for 

carnivorous species (e.g., raptors), but it would characterize the maximum potential exposure through the 

diet of avian and mammalian prey items. Consequently, this approach would provide a conservative 

screening tool for pesticides that do not biomagnify.

For RQ calculations in T-REX, the model would require the weight of surrogate species and

Mineau scaling factors (Mineau et al.1996). Body weights of bobwhite quail and mallard are included in 

T-REX by default, but body weights of other organisms (Table 3) would be entered manually. The 

Mineau scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide 

exposure than would be predicted only by body weight. Mineau scaling factors would be entered 

manually with values ranging from 1 to 1.55 that are unique to a particular pesticide or group of 

pesticides. If specific information to select a scaling factor is not available, then a value of 1.15 would be 

used as a default. Alternatively, zero would be entered if it is known that body weight does not influence 

toxicity of pesticide(s) being assessed. The upper bound estimate output from the T-REX Kanaga 

nomogram would be used as an EEC for calculation of RQs. This approach would yield a conservative 

estimate of ecological risk.

Table E.3 Average body weight of selected terrestrial wildlife species frequently used in research to 

establish toxicological endpoints (Dunning 1984).

Species Body Weight (kg) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Common grackle 0.114 

Japanese quail 0.178 

Bobwhite quail 0.178 

Rat 0.200 

Rock dove (aka pigeon) 0.542 

Mammal (1000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 

Terrestrial – granular application
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Appendix E – Integrated Pest Management Program E-19

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units which birds or mammals might 

ingest accidentally with food items or intentionally as in the case of some bird species actively seeking 

and picking up gravel or grit to aid digestion or seed as a food source. Granules may also be consumed 

by wildlife foraging on earthworms, slugs or other softbodied soil organisms to which the granules may 

adhere.

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing the 

maximum milligrams of active ingredient (ai) exposed (e.g., EEC) on the surface of an area equal to 1 

square foot by the appropriate LD50 value multiplied by the surrogate’s body weight (Table 3). An 

adjustment to surface area calculations would be made for broadcast, banded, and in-furrow applications. 

An adjustment also would be made for applications with and without incorporation of the granules. 

Without incorporation, it would be assumed that 100 percent of the granules remain on the soil surface 

available to foraging birds and mammals.

Press wheels push granules flat with the soil surface, but they are not incorporated into the soil.

If granules are incorporated in the soil during band or T-band applications or after broadcast applications, 

it would be assumed only 15 percent of the applied granules remain available to wildlife. It would be 

assumed that only 1 percent of the granules are available on the soil surface following in-furrow 

applications.

The EECs for pesticides applied in granular form and as seed treatments would be determined considering 

potential ingestion rates of avian or mammalian species (e.g., 10-30 percent body weight/day). This 

would provide an estimate of maximum exposure that may occur as a result of granule or seed treatment 

spills such as those that commonly occur at end rows during application and planting. The availability of 

granules and seed treatments to terrestrial vertebrates would also be considered by calculating the loading 

per unit area (LD50/ft2) for comparison to EPA Levels of Concern (EPA 1998). The T-REX version 

1.2.3 (EPA 2005b) contains a submodel which automates Kanaga exposure calculations for granular 

pesticides and treated seed.

The following formulas will be used to calculate EECs depending upon the type of granular pesticide 

application:

• In-furrow applications assume a typical value of 1 percent granules, bait, or seed remain

unincorporated.

mg a.i./ft.2

 ft.

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560

2

or

/acre)/(row spacing (ft.))] / (row spacing (ft.)}

mg a.i./ft.

2

= [(lbs product/1000 ft. row)(% a.i.)(1000 ft row)(453,580 mg/lb.)(1% exposed)

EEC = [(mg a.i./ft.2

)(% of pesticide biologically available)]

• Incorporated banded treatments assume that 15 percent of granules, bait, or seeds are

unincorporated.

mg a.i./ft.2

= [(lbs. product/1000 row ft.)(% a.i.)(453,580 mg/lb.)(1-% incorporated)] / (1,000
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Appendix E – Integrated Pest Management Program E-20

ft.)(band width (ft.))

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)]

• Broadcast treatment without incorporation assumes 100 percent of granules, bait, seeds

are unincorporated.

mg a.i./ft.2

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb.)] / (43,560 ft.2

/acre)

EEC = [(mg a.i./ft.2

)(% of pesticide biologically available)]

Where:

• % of pesticide biologically available = 100% without species specific ingestion rates

• Conversion for calculating mg a.i./ft.2

using ounces: 453,580 mg/lb. /16 = 28,349 mg/oz.

The following equation would used to calculate a RQ based on the EEC calculated by one of the above 

equations. The EEC would be divided by the surrogate LD50 toxicological endpoint multiplied by the 

body weight (Table 3) of the surrogate.

RQ = EEC / [LD50 (mg/kg) * body weight (kg)]

As with other risk assessments, an RQ greater than LOC, would be a presumption of unacceptable 

ecological risk. An RQ less than LOC would be a presumption of acceptable risk with only minor, 

temporary, or localized effects to species.

Aquatic exposure

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) would 

be evaluated separately for ground-based pesticide treatments of habitats managed for fish and wildlife 

compared with cropland/facilities maintenance. The primary exposure pathway for aquatic organisms 

from any ground-based treatments likely would be particle drift during the pesticide application. 

However, different exposure scenarios would be necessary as a result of contrasting application 

equipment and techniques as well as pesticides used to control pests on agricultural lands (especially 

those cultivated by cooperative farmers for economic return from crop yields) and facilities maintenance 

(e.g., roadsides, parking lots, trails) compared with other managed habitats on the refuge. In addition, 

pesticide applications may be done less than 25 feet from the high water mark of aquatic habitats for 

habitat management treatments; whereas, no-spray buffers (25 feet or more) would be used for 

croplands/facilities maintenance treatments.

Habitat treatments

For the worst-case exposure scenario to non-target aquatic habitats, EECs (Table 4) would be would be 

derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, non-target water 

body (1-foot depth) from a treatment less than 25 feet from the high water mark using the max application 

rate (acid basis [see above]). However, use of BMPs for applying pesticides (see Section 4.2) would 

likely minimize/eliminate potential drift to non-target aquatic habitats during actual treatments. If there 

would be unacceptable (acute or chronic) risk to fish and wildlife with the simulated 100 percent 

overspray (RQ greater than LOC), then the proposed pesticide use may be disapproved or the PUP would 

be approved at a lower application rate to minimize/eliminate unacceptable risk to aquatic organisms 

(RQ=LOC).
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Appendix E – Integrated Pest Management Program E-21

Table E.4 Estimated Environmental Concentrations (ppb) of pesticides in aquatic habitats

(1 foot depth) immediately after direct application (Urban and Cook 1986)

Lbs/acre EEC (ppb)

0.10 36.7

0.20 73.5

0.25 91.9

0.30 110.2

0.40 147.0

0.50 183.7

0.75 275.6

1.00 367.5

1.25 459.7

1.50 551.6

1.75 643.5

2.00 735.7

2.25 827.6

2.50 919.4

3.00 1103.5

4.00 1471.4

5.00 1839

6.00 2207

7.00 2575

8.00 2943

9.00 3311

10.00 3678

Cropland/facilities maintenance treatments

Field drift studies conducted by the Spray Drift Task Force, which is a joint project of several agricultural 

chemical businesses, were used to develop a generic spray drift database. From this database, the 

AgDRIFT computer model was created to satisfy EPA’s pesticide registration spray drift data 

requirements and as a scientific basis to evaluate off-target movement of pesticides from particle drift and 

assess potential effects of exposure to wildlife. Several versions of the computer model have been 

developed (i.e., v2.01 through v2.10). The Spray Drift Task Force AgDRIFT® model version 2.01 

(SDTF 2003, AgDRIFT 2001) would be used to derive EECs resulting from drift of pesticides to refuge 

aquatic resources from ground-based pesticide applications greater than 25 feet from the high water mark. 

The Spray Drift Task Force AgDRIFT model is publicly available at http://www.agridrift.com. At this 

website, click “AgDRIFT 2.0” and then click “Download Now” and follow the instructions to obtain the

computer model.

The AgDRIFT model is composed of submodels called tiers. Tier I Ground submodel would be used to 

assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with AgDRIFT 

using the following input variables: max application rate (acid basis [see above]), low boom (20 inches), 

fine to medium/coarse droplet size, 20 swaths, EPA-defined wetland, and a buffer of 25 feet or more from 

the treated area to water.
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Appendix E – Integrated Pest Management Program E-22

E.7.2.2 Use of information on effects of biological control agents, pesticides, degradates, and 

adjuvants

The NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another Federal agency, where the scope would be 

relevant to evaluation of effects from pesticide uses on refuge lands, would be reviewed. Possible source 

agencies for such NEPA documents would include the Bureau of Land Management, U.S. Forest Service, 

National Park Service, U.S. Department of Agriculture-Animal and Plant Health Inspection Service, and 

the U.S. military services. It might be appropriate to incorporate by reference parts or all of existing 

document(s). Incorporating by reference (40 CFR 1502.21) is a technique used to avoid redundancies in 

analysis. It would also reduce the bulk of a Service NEPA document, which would only identify the 

documents that are incorporated by reference. In addition, relevant portions would be summarized in the 

Service’s NEPA document to the extent necessary to provide the decision maker and public with an

understanding of relevance of the referenced material to the current analysis.

In accordance with the requirements set forth in 40 CFR 1506.3, the Service would specifically adopt and 

incorporate through reference ecological risk assessments prepared by the U.S. Forest

Service (http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-AnalyzedInvPlant-EIS.htm) and Bureau of Land Management (http://www.blm.gov/wo/st/en/prog/more/

veg_eis.html). These risk assessments and associated documentation also are available in total with the 

administrative record for the Final Environmental Impact Statement entitled Pacific Northwest Region 

Invasive Plant Program – Preventing and Managing Invasive Plants (U.S. Forest Service 2005) and 

Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States 

Programmatic EIS (PEIS) (BLM 2007).

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, ecological risk 

assessments for the following herbicide and adjuvant uses prepared by the U.S. Forest Service would be 

adopted and incorporated by reference:

• 2,4-D

• Chlorosulfuron

• Clopyralid

• Dicamba

• Glyphosate

• Imazapic

• Imazapyr

• Metsulfuron methyl

• Picloram

• Sethoxydim

• Sulfometuron methyl

• Triclopyr

• Nonylphenol polyethylate (NPE) based surfactants

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, ecological risk 

assessments for the following herbicide uses as well as evaluation of risks associated with pesticide 

degradates and adjuvants prepared by the Bureau of Land Management would be adopted and 

incorporated by reference:

• Bromacil

• Chlorsulfuron

• Diflufenzopyr

• Diquat
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Appendix E – Integrated Pest Management Program E-23

• Diuron

• Fluridone

• Imazapic

• Overdrive

• Sulfometuron methyl

• Tebuthiuron

• Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates,

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals)

E.7.2.3 Assumptions for ecological risk assessments

There are a number of assumptions involved with the ecological risk assessment process for terrestrial 

and aquatic organisms associated with utilization of the EPA’s (2004) process. These assumptions may 

be risk neutral or may lead to an over- or under-estimation of risk from pesticide exposure depending 

upon site-specific conditions. The following describes these assumptions, their application to the 

conditions typically encountered, and whether or not they may lead to recommendations that are risk 

neutral, underestimate, or overestimate ecological risk from potential pesticide exposure.

• Indirect effects would not be evaluated by ecological risk assessments. These effects include the 

mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or small 

mammals); reductions in the availability of prey items; and disturbance associated with pesticide 

application activities.

• Exposure to a pesticide product can be assessed based upon the active ingredient. However, 

exposure to a chemical mixture (pesticide formulation) may result in effects that are similar or 

substantially different compared to only the active ingredient. Non-target organisms may be 

exposed directly to the pesticide formulation or only various constituents of the formulation as 

they dissipate and partition in the environment. If toxicological information for both the active 

ingredient and formulated product are available, then data representing the greatest potential 

toxicity would be selected for use in the risk assessment process (EPA 2004). As a result, this 

conservative approach may lead to an overestimation of risk characterization from pesticide 

exposure.

• Because toxicity tests with listed or candidate species or closely related species are not available, 

data for surrogate species would be most often used for risk assessments. Specifically, bobwhite 

quail and mallard duck are the most frequently used surrogates for evaluating potential toxicity to 

federally listed avian species. Bluegill sunfish, rainbow trout, and fathead minnow are the most 

common surrogates for evaluating toxicity for freshwater fishes. However, sheep’s head minnow 

can be an appropriate surrogate marine species for coastal environments. Rats and mice are the 

most common surrogates for evaluating toxicity for mammals. Interspecies sensitivity is a major 

source of uncertainty in pesticide assessments. As a result of this uncertainty, data is selected for

the most sensitive species tested within a taxonomic group (birds, fish, and mammals) given the 

quality of the data is acceptable. If additional toxicity data for more species of organisms in a 

particular group are available, the selected data will not be limited to the species previously listed 

as common surrogates.

• The Kanaga nomogram outputs maximum EEC values that may be used to calculate an average 

daily concentration over a specified interval of time, which is referred to as a time-weightedaverage (TWA). The maximum EEC would be selected as the exposure input for both acute and 

chronic risk assessments in the screening-level evaluations. The initial or maximum EEC derived 

from the Kanaga nomogram represents the maximum expected instantaneous or acute exposure to 

a pesticide. Acute toxicity endpoints are determined using a single exposure to a known pesticide 

concentration typically for 48 to 96 hours. This value is assumed to represent ecological risk 

from acute exposure to a pesticide. On the other hand, chronic risk to pesticide exposure is a 
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Appendix E – Integrated Pest Management Program E-24

function of pesticide concentration and duration of exposure to the pesticide. An organism’s 

response to chronic pesticide exposure may result from either the concentration of the pesticide,

length of exposure, or some combination of both factors. Standardized tests for chronic toxicity 

typically involve exposing an organism to several different pesticide concentrations for a 

specified length of time (days, weeks, months, years or generations). For example, avian 

reproduction tests include a 10-week exposure phase. Because a single length of time is used in 

the test, time response data is usually not available for inclusion into risk assessments. Without 

time response data it is difficult to determine the concentration which elicited a toxicological 

response.

• Using maximum EECs for chronic risk estimates may result in an overestimate of risk,

particularly for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk 

estimates may underestimate risk if it is the concentration rather than the duration of exposure 

that is primarily responsible for the observed adverse effect. The maximum EEC would be used 

for chronic risk assessments although it may result in an overestimate of risk. TWAs may be 

used for chronic risk assessments, but they will be applied judiciously considering the potential 

for an underestimate or overestimate of risk. For example, the number of days exposure exceeds 

a Level of Concern may influence the suitability of a pesticide use. The greater the number of 

days the EEC exceeds the Level of Concern translates into greater the ecological risk. This is a 

qualitative assessment, and is subject to reviewer’s expertise in ecological risk assessment and 

tolerance for risk.

• The length of time used to calculate the TWA can have a substantial effect on the exposure 

estimates and there is no standard method for determining the appropriate duration for this 

estimate. The T-REX model assumes a 21-week exposure period, which is equivalent to avian 

reproductive studies designed to establish a steady-state concentration for bioaccumulative 

compounds. However, this does not necessarily define the true exposure duration needed to elicit 

a toxicological response. Pesticides, which do not bioaccumulate, may achieve a steady-state 

concentration earlier than 21 weeks. The duration of time for calculating TWAs will require 

justification and it will not exceed the duration of exposure in the chronic toxicity test 

(approximately 70 days for the standard avian reproduction study). An alternative to using the 

duration of the chronic toxicity study is to base the TWA on the application interval. In this case, 

increasing the application interval would suppress both the estimated peak pesticide concentration 

and the TWA. Another alternative to using TWAs would be to consider the number of days that 

a chemical is predicted to exceed the LOC.

• Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as bi-phasic. Field dissipation data would generally be the most 

pertinent for assessing exposure in terrestrial species that forage on vegetation. However, this 

data is often not available and it can be misleading particularly if the compound is prone to 

“wash-off.” Soil half-life is the most common degradation data available. Dissipation or 

degradation data that would reflect the environmental conditions typical of refuge lands would be 

utilized, if available.

• For species found in the water column, it would be assumed that the greatest bioavailable fraction 

of the pesticide active ingredient in surface waters is freely dissolved in the water column.

• Actual habitat requirements of any particular terrestrial species are not considered, and it is 

assumed that species exclusively and permanently occupy the treated area, or adjacent areas 

receiving pesticide at rates commensurate with the treatment rate. This assumption would 

produce a maximum estimate of exposure for risk characterization. This assumption would likely 

lead to an overestimation of exposure for species that do not permanently and exclusively occupy 

the treated area (EPA 2004).

• Exposure through incidental ingestion of pesticide contaminated soil is not considered in the EPA 

risk assessment protocols. Research suggests less than 15 percent of the diet can consist of 
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Appendix E – Integrated Pest Management Program E-25

incidentally ingested soil depending upon species and feeding strategy (Beyer et al. 1994). An 

assessment of pesticide concentrations in soil compared to food item categories in the Kanaga 

nomogram indicates incidental soil ingestion will not likely increase dietary exposure to 

pesticides. Inclusion of soil into the diet would effectively reduce the overall dietary 

concentration compared to the present assumption that the entire diet consists of a contaminated 

food source (Fletcher et al. 1994). An exception to this may be soil-applied pesticides in which 

exposure from incidental ingestion of soil may increase. Potential for pesticide exposure under 

this assumption may be underestimated for soil-applied pesticides and overestimated for foliarapplied pesticides. The concentration of a pesticide in soil would likely be less than predicted on 

food items.

• Exposure through inhalation of pesticides is not considered in the EPA risk assessment protocols. 

Such exposure may occur through three potential sources: spray material in droplet form at time 

of application, vapor phase with the pesticide volatilizing from treated surfaces, and airborne 

particulates (soil, vegetative matter, and pesticide dusts). The EPA (1990) reported exposure 

from inhaling spray droplets at the time of application is not an appreciable route of exposure for 

birds. According to research on mallards and bobwhite quail, respirable particle size (particles 

reaching the lung) in birds is limited to maximum diameter of 2 to 5 microns. The spray droplet 

spectra covering the majority of pesticide application scenarios indicate that less than 1 percent of 

the applied material is within the respirable particle size. This route of exposure is further limited 

because the permissible spray drop size distribution for ground pesticide applications is restricted 

to ASAE medium or coarser drop size distribution. 

• Inhalation of a pesticide in the vapor phase may be another source of exposure for some

pesticides under certain conditions. This mechanism of exposure to pesticides occurs post

appplication and it would pertain to those pesticides with a high vapor pressure. The EPA is 

currently evaluating protocols for modeling inhalation exposure from pesticides including nearfield and near-ground air concentrations based upon equilibrium and kinetics-based models. Risk 

characterization for exposure with this mechanism is unavailable.

• The effect from exposure to dusts contaminated with the pesticide cannot be assessed generically 

as partitioning issues related to application site soils and chemical properties of the applied 

pesticides render the exposure potential from this route highly situation specific.

• Dermal exposure may occur through three potential sources: direct application of spray to 

terrestrial wildlife in the treated area or within the drift footprint, incidental contact with 

contaminated vegetation, or contact with contaminated water or soil. Interception of spray and 

incidental contact with treated substrates may pose risks to avian wildlife (Driver et al. 1991). 

However, available research related to wildlife dermal contact with pesticides is extremely 

limited, except dermal toxicity values are common for some mammals used as human surrogates 

(rats and mice). The EPA is currently evaluating protocols for modeling dermal exposure. Risk 

characterization may be underestimated for this route of exposure, particularly with high risk 

pesticides such as some organophosphates or carbamate insecticides. If protocols are established 

by the EPA for assessing dermal exposure to pesticides, they will be considered for incorporation 

into pesticide assessment protocols.

• Exposure to a pesticide may occur from consuming surface water, dew, or other water on treated 

surfaces. Water soluble pesticides have potential to dissolve in surface runoff, and puddles in a 

treated area may contain pesticide residues. Similarly, pesticides with lower organic carbon 

partitioning characteristics and higher solubility in water have a greater potential to dissolve in 

dew and other water associated with plant surfaces. Estimating the extent to which such 

pesticide loadings to drinking water occurs is complex and would depend upon the partitioning 

characteristics of the active ingredient, soils types in the treatment area, and the meteorology of 

the treatment area. In addition, the use of various water sources by wildlife is highly speciesspecific. Currently, risk characterization for this exposure mechanism is not available. The EPA 
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Appendix E – Integrated Pest Management Program E-26

is actively developing protocols to quantify drinking water exposures from puddles and dew. If 

and when protocols are formally established by the EPA for assessing exposure to pesticides

through drinking water, these protocols will be incorporated into pesticide risk assessment 

protocols.

• Risk assessments are based upon the assumption that the entire treatment area would be subject to 

pesticide application at the rates specified on the label. In most cases, there is potential for 

uneven application of pesticides through such plausible incidents such as changes in calibration 

of application equipment, spillage, and localized releases at specific areas in or near the treated 

field that are associated with mixing and handling and application equipment as well as applicator 

skill. Inappropriate use of pesticides and the occurrence of spills represent a potential 

underestimate of risk. It is likely not an important factor for risk characterization. All pesticide 

applicators are required to be certified by the state in which they apply pesticides. Certification 

training includes the safe storage, transport, handling, and mixing of pesticides, equipment 

calibration and proper application with annual continuing education.

• The EPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife dietary 

items. The EPA (2004) “believes that these residue assumptions reflect a realistic upper-bound 

residue estimate, although the degree to which this assumption reflects a specific percentile 

estimate is difficult to quantify.” Fletcher’s (1994) research suggests that the pesticide active 

ingredient residue assumptions used by the EPA represent a 95th

• Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with LC50 or 

NOEC values expressed as concentrations of pesticides in laboratory feed. These comparisons 

assume that ingestion of food items in the field occurs at rates commensurate with those in the 

laboratory. Although the screening assessment process adjusts dry-weight estimates of food 

intake to reflect the increased mass in fresh-weight wildlife food intake estimates, it does not 

allow for gross energy and assimilative efficiency differences between wildlife food items and 

laboratory feed. Differences in assimilative efficiency between laboratory and wild diets suggest 

that current screening assessment methods are not accounting for a potentially important aspect of 

food requirements.

percentile estimate. However, 

research conducted by Pfleeger et al. (1996) indicates EPA residue assumptions for short grass 

was not exceeded. Behr and Habig (2000) compared EPA residue assumptions with distributions 

of measured pesticide residues for the EPA’s UTAB database. Overall residue selection level 

will tend to overestimate risk characterization. This is particularly evident when wildlife 

individuals are likely to have selected a variety of food items acquired from multiple locations. 

Some food items may be contaminated with pesticide residues whereas others are not 

contaminated. However, it is important to recognize differences in species feeding behavior. 

Some species may consume whole above-ground plant material, but others will preferentially 

select different plant structures. Also, species may preferentially select a food item although 

multiple food items may be present. Without species-specific knowledge regarding foraging

behavior, characterizing ecological risk other than in general terms is not possible.

• There are several other assumptions that can affect non-target species not considered in the risk 

assessment process. These include possible additive or synergistic effects from applying two or 

more pesticides or additives in a single application, co-location of pesticides in the environment, 

cumulative effects from pesticides with the same mode of action, effects of multiple stressors 

(e.g., combination of pesticide exposure, adverse abiotic and biotic factors) and behavioral 

changes induced by exposure to a pesticide. These factors may exist at some level contributing to 

adverse affects to non-target species, but they are usually characterized in the published literature 

in only a general manner limiting their value in the risk assessment process.

• It is assumed that aquatic species exclusively and permanently occupy the water body being 

assessed. Actual habitat requirements of aquatic species are not considered. With the possible 

exception of scenarios where pesticides are directly applied to water, it is assumed that no habitat 
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Appendix E – Integrated Pest Management Program E-27

use considerations specific for any species would place the organisms in closer proximity to 

pesticide use sites. This assumption produces a maximum estimate of exposure or risk 

characterization. It would likely be realistic for many aquatic species that may be found in 

aquatic habitats within or in close proximity to treated terrestrial habitats. However, the spatial 

distribution of wildlife is usually not random because wildlife distributions are often related to 

habitat requirements of species. Clumped distributions of wildlife may result in an under- or 

over-estimation of risk depending upon where the initial pesticide concentration occurs relative to 

the species or species habitat.

• For species found in the water column, it would be assumed that the greatest bioavailable fraction 

of the pesticide active ingredient in surface waters is freely dissolved in the water column. 

Additional chemical exposure from materials associated with suspended solids or food items is 

not considered because partitioning onto sediments likely is minimal. Adsorption and 

bioconcentration occur at lower levels for many newer pesticides compared with older, more 

persistent bioaccumulative compounds. Pesticides with RQs close to the listed species level of 

concern, the potential for additional exposure from these routes may be a limitation of risk 

assessments, where potential pesticide exposure or risk may be underestimated.

• Mass transport losses of pesticide from a water body (except for losses by volatilization,

degradation and sediment partitioning) would not be considered for ecological risk assessment. 

The water body would be assumed to capture all pesticide active ingredients entering as runoff, 

drift, and adsorbed to eroded soil particles. It would also be assumed that pesticide active 

ingredient is not lost from the water body by overtopping or flowthrough, nor is concentration 

reduced by dilution. In total, these assumptions would lead to a near maximum possible waterborne concentration. However, this assumption would not account for potential to concentrate 

pesticide through the evaporative loss. This limitation may have the greatest impact on water 

bodies with high surface-to-volume ratios such as ephemeral wetlands, where evaporative losses 

are accentuated and applied pesticides have low rates of degradation and volatilization.

• For acute risk assessments, there would be no averaging time for exposure. An instantaneous 

peak concentration would be assumed, where instantaneous exposure is sufficient in duration to 

elicit acute effects comparable to those observed over more protracted exposure periods (typically 

48 to 96 hours) tested in the laboratory. In the absence of data regarding time-to-toxic event, 

analyses and latent responses to instantaneous exposure, risk would likely be overestimated.

• For chronic exposure risk assessments, the averaging times considered for exposure are

commensurate with the duration of invertebrate life-cycle or fish-early life stage tests (e.g., 21-28 

days and 56-60 days, respectively). Response profiles (time to effect and latency of effect) to 

pesticides likely vary widely with mode of action and species and should be evaluated on a caseby-case basis as available data allow. Nevertheless, because the EPA relies on chronic exposure 

toxicity endpoints based on a finding of no observed effect, the potential for any latent toxicity 

effects or averaging time assumptions to alter the results of an acceptable chronic risk assessment 

prediction is limited. The extent to which duration of exposure from water-borne concentrations 

overestimate or underestimate actual exposure depends on several factors. These include the 

following: localized meteorological conditions, runoff characteristics of the watershed (e.g., soils,

topography), the hydrological characteristics of receiving waters, environmental fate of the 

pesticide active ingredient, and the method of pesticide application. It should also be understood 

that chronic effects studies are performed using a method that holds water concentration in a 

steady state. This method is not likely to reflect conditions associated with pesticide runoff. 

Pesticide concentrations in the field increase and decrease in surface water on a cycle influenced 

by rainfall, pesticide use patterns, and degradation rates. As a result of the dependency of this 

assumption on several undefined variables, risk associated with chronic exposure may in some 

situations underestimate risk and overestimate risk in others.
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Appendix E – Integrated Pest Management Program E-28

• There are several other factors that can affect non-target species not considered in the risk

assessment process. These would include the following: possible additive or synergistic effects 

from applying two or more pesticides or additives in a single application, collocation of pesticides 

in the environment, cumulative effects from pesticides with the same mode of action, effects of 

multiple stressors (e.g., combination of pesticide exposure, adverse abiotic [not pesticides] and 

biotic factors), and sub-lethal effects such as behavioral changes induced by exposure to a 

pesticide. These factors may exist at some level contributing to adverse affects to non-target 

species, but they are not routinely assessed by regulatory agencies. Therefore, information on the 

factors is not extensive, limiting their value for the risk assessment process. As this type of 

information becomes available, it would be included, either quantitatively or qualitatively, in this 

risk assessment process.

• The EPA is required by the Food Quality Protection Act to assess the cumulative risks of

pesticides that share common mechanisms of toxicity, or act the same within an organism. 

Currently, EPA has identified four groups of pesticides that have a common mechanism of 

toxicity requiring cumulative risk assessments. These four groups are the organophosphate 

insecticides, N-methyl carbamate insecticides, triazine herbicides, and chloroacetanilide 

herbicides.

E.7.3 Pesticide Mixtures and Degradates

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert or other ingredients. The term active ingredient is defined by the

FIFRA as preventing, destroying, repelling, or mitigating the effects of a pest, or it is a plant regulator, 

defoliant, desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must be 

identified by name(s) on the pesticide label along with its relative composition expressed in percentage(s) 

by weight. In contrast, inert ingredient(s) are not intended to affect a target pest. Their role in the 

pesticide formulation is to act as a solvent (keep the active ingredient is a liquid phase), an emulsifying or 

suspending agent (keep the active ingredient from separating out of solution), or a carrier such as clay in 

which the active ingredient is impregnated on the clay particle in dry formulations. For example, if 

isopropyl alcohol would be used as a solvent in a pesticide formulation, then it would be considered an

inert ingredient. FIFRA only requires that inert ingredients identified as hazardous and associated percent 

composition, and the total percentage of all inert ingredients must be declared on a product label. Inert 

ingredients that are not classified as hazardous are not required to be identified.

The EPA (September 1997) issued Pesticide Regulation Notice 97-6, which encouraged manufacturers, 

formulators, producers, and registrants of pesticide products to voluntarily substitute the term “other 

ingredients” for “inert ingredients” in the ingredient statement. This change recognized that all 

components in a pesticide formulation potentially could elicit or contribute to an adverse effect on nontarget organisms and, therefore, are not necessarily inert. Whether referred to as “inerts” or “other 

ingredients,” these constituents within a pesticide product have the potential to affect species or 

environmental quality. The EPA categorizes regulated inert ingredients into the following four lists

(http://www.epa.gov/opprd001/inerts/index.html):

• List 1 – Inert Ingredients of Toxicological Concern

• List 2 – Potentially Toxic Inert Ingredients

• List 3 – Inerts of Unknown Toxicity

• List 4 – Inerts of Minimal Toxicity

Several of the List 4 compounds are naturally-occurring earthen materials (e.g., clay materials, simple 

salts) that would not elicit toxicological response at applied concentrations. However, some of the inerts 
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Appendix E – Integrated Pest Management Program E-29

(particularly the List 3 compounds and unlisted compounds) may have moderate to high potential toxicity 

to aquatic species based on MSDSs or published data. 

Comprehensively assessing potential effects to non-target fish, wildlife, plants, and/or their habitats from 

pesticide use is a complex task. It would be preferable to assess the cumulative effects from exposure to 

the active ingredient, its degradates, and inert ingredients as well as other active ingredients in the spray 

mixture. However, it would only be feasible to conduct deterministic risk assessments for each 

component in the spray mixture singly. Limited scientific information is available regarding ecological 

effects (additive or synergistic) from chemical mixtures that typically rely upon broadly encompassing 

assumptions. For example, the U.S. Forest Service (2005) found that mixtures of pesticides used in land 

(forest) management likely would not cause additive or synergistic effects to non-target species based 

upon a review of scientific literature regarding toxicological effects and interactions of agricultural 

chemicals (ATSDR 2004, EPA-ORD 2000). Moreover, information on inert ingredients, adjuvants, and

degradates is often limited by the availability of and access to reliable toxicological data for these 

constituents.

Toxicological information regarding “other ingredients” may be available from sources such as the 

following:

• TOMES (a proprietary toxicological database including EPA’s IRIS, the Hazardous

• Substance Data Bank, the Registry of Toxic Effects of Chemical Substances [RTECS]).

• EPA’s ECOTOX database, which includes AQUIRE (a database containing scientific

papers published on the toxic effects of chemicals to aquatic organisms).

• TOXLINE (a literature searching tool).

• Material Safety Data Sheets (MSDSs) from pesticide suppliers.

• Other sources such as the Farm Chemicals Handbook.

Because there is a lack of specific inert toxicological data, inert(s) in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the pesticide 

spray mixture, it would be assumed that negligible effects would be expected to result from inert 

ingredient(s).

Although the potential effects of degradates should be considered when selecting a pesticide, it is beyond 

the scope of this assessment process to consider all possible breakdown chemicals of the various product 

formulations containing an active ingredient. Degradates may be more or less mobile and more or less 

hazardous in the environment than their parent pesticides (Battaglin et al. 2003). Differences in 

environmental behavior (e.g., mobility) and toxicity between parent pesticides and degradates would 

make assessing potential degradate effects extremely difficult. For example, a less toxic and more 

mobile, bioaccumulative, or persistent degradate may have potentially greater effects on species and/or 

degrade environmental quality. The lack of data on the toxicity of degradates for many pesticides would 

represent a source of uncertainty for assessing risk.

An EPA-approved label specifies whether a product can be mixed with one or more pesticides.

Without product-specific toxicological data, it would not possible to quantify the potential effects of these 

mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific information 

allowed a determination of whether the joint action of a mixture would be additive, synergistic, or 

antagonistic. Such information would not likely exist unless the mode of action would be common 

among the chemicals and receptors. Moreover, the composition of and exposure to mixtures would be 

highly site- and/or time-specific and, therefore, it would be nearly impossible to assess potential effects to 

species and environmental quality.
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Appendix E – Integrated Pest Management Program E-30

To minimize or eliminate potential negative effects associated with applying two or more pesticides as a 

mixture, the use would be conducted in accordance with the labeling requirements. Labels for two or 

more pesticides applied as a mixture should be completely reviewed, where products with the least 

potential for negative effects would be selected for use on the refuge. This is especially relevant when a 

mixture would be applied in a manner that may already have the potential for an effect(s) associated with 

an individual pesticide (e.g., runoff to ponds in sandy watersheds). Use of a tank mix under these 

conditions would increase the level of uncertainty in terms of risk to species or potential to degrade 

environmental quality. 

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial herbicides, 

adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally applies to 

surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, compatibility 

agents, stickers, and spreaders. Adjuvants are not under the same registration requirements as pesticides 

and the EPA does not register or approve the labeling of spray adjuvants. Individual pesticide labels 

identify types of adjuvants approved for use with it. In general, adjuvants compose a relatively small 

portion of the volume of pesticides applied. Selection of adjuvants with limited toxicity and low volumes 

would be recommended to reduce the potential for the adjuvant to influence the toxicity of the pesticide.

E.7.4 Determining Effects to Soil and Water Quality

The approval process for pesticide uses would consider potential to degrade water quality on and off the 

refuge. A pesticide can only affect water quality through movement away from the treatment site. After 

application, pesticide mobilization can be characterized by one or more of the following (Kerle et al. 

1996):

• Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area;

• Attach to soil and move off-site through erosion from run-off or wind;

• Dissolve in water that can be subjected to run-off or leaching.

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the following: 

persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility.

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50 percent of 

the deposited pesticide to degrade (completely or partially). Persistence in the soil can be categorized as 

the following: non-persistent less than 30 days, moderately persistent 30 to 100 days, and persistent less 

than 100 days (Kerle et al. 1996). Half-life data is usually available for aquatic and terrestrial 

environments.

Another measure of pesticide persistence is dissipation time (DT50). It represents the time required for 

50 percent of the deposited pesticide to degrade and move from a treated site; whereas, half-life describes 

the rate for degradation only. As for half-life, units of dissipation time are usually expressed in days. 

Field or foliar dissipation time is the preferred data for use to estimate pesticide concentrations in the 

environment. However, soil half-life is the most common persistence data cited in the published 

literature. If field or foliar dissipation data is not available, soil half-life data may be used. The average 

or representative half-life value of most important degradation mechanism will be selected for 

quantitative analysis for both terrestrial and aquatic environments. 

Mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic matter, its 

solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to soil particles, 

relatively insoluble in water, and not environmentally persistent wound be less likely to move across the 

soil surface into surface waters or to leach through the soil profile and contaminate groundwater. 

Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water soluble, and are 
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Appendix E – Integrated Pest Management Program E-31

persistent in the environment would have greater potential to move from the application site (off-site 

movement).

The degree of pesticide adsorption to soil particles and organic matter (Kerle et al. 1996) is expressed as 

the soil adsorption coefficient (Koc). The soil adsorption coefficient is measured as micrograms of 

pesticide per gram of soil (μg/g) that can range from near zero to the thousands. Pesticides with higher 

Koc values are strongly sorbed to soil and, therefore, would be less subject to movement.

Water solubility describes the amount of pesticide that will dissolve in a known quantity of water. The 

water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water (mg/l or 

ppm). Pesticide with solubility less than 0.1 ppm are virtually insoluble in water, 100-1,000 ppm are 

moderately soluble, and greater than 10,000 ppm highly soluble (U.S. Geological Survey 2000). As 

pesticide solubility increases, there would be greater potential for off-site movement.

The Groundwater Ubiquity Score (GUS) is a quantitative screening tool to estimate a pesticide’s potential 

to move in the environment. It utilizes soil persistence and adsorption coefficients in the following 

formula.

GUS = log10 (t1⁄2) x [4 - log10 (Koc)]

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a

GUS less than 0.1 would be considered to have an extremely low potential to move toward groundwater. 

Values of 1.0-2.0 would be low, 2.0-3.0 would be moderate, 3.0-4.0 would be high, and greater than 4.0 

would have a very high potential to move toward groundwater.

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it is 

usually measured as mg/l or parts per million (ppm). Solubility is useful as a comparative measure 

because pesticides with higher values are more likely to move by runoff or leaching. The GUS, water 

solubility, t1⁄2, and Koc values are available for selected pesticides from the Oregon State University 

Extension Pesticide Properties Database at http://npic.orst.edu/ppdmove.htm. Many of the values in this 

database were derived from the SCS/ARS/CES Pesticide Properties Database for Environmental Decision 

Making (Wauchope et al.1992).

Soil properties influence the fate of pesticides in the environment. The following six properties are 

mostly likely to affect pesticide degradation and the potential for pesticides to move off-site by leaching 

(vertical movement through the soil) or runoff (lateral movement across the soil surface).

• Permeability is the rate of water movement vertically through the soil. It is affected by soil 

texture and structure. Coarse textured soils (e.g., high sand content) have a larger pore size and 

they are generally more permeable than fine textured soils (i.e., high clay content). The more 

permeable soils would have a greater potential for pesticides to move vertically down through the 

soil profile. Soil permeability rates (inches/hour) are usually available in county soil survey 

reports.

• Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay 

content with smaller pore size would lower the likelihood and rate at which water would move 

through the soil profile. Clay also serves to adsorb (bind) pesticides to soil particles. Soils with 

high clay content would adsorb more pesticide than soils with relatively low clay content. In 

contrast, sandy soils with coarser texture and lower water holding capacity would have a greater 

potential for water to leach through them.
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Appendix E – Integrated Pest Management Program E-32

• Soil structure describes soil aggregation. Soils with a well developed soil structure have looser, 

more aggregated, structure that would be less likely to be compacted. Both characteristics would 

allow for less restricted flow of water through the soil profile resulting in greater infiltration.

• Organic matter would be the single most important factor affecting pesticide adsorption in soils. 

Many pesticides are adsorbed to organic matter which would reduce their rate of downward 

movement through the soil profile. Also, soils high in organic matter would tend to hold more 

water, which may make less water available for leaching.

• Soil moisture affects how fast water would move through the soil. If soils are already wet or 

saturated before rainfall or irrigation, excess moisture would runoff rather than infiltrate into the 

soil profile. Soil moisture also would influence microbial and chemical activity in soil, which 

effects pesticide degradation.

• Soil pH would influence chemical reactions that occur in the soil, which in turn determines 

whether or not a pesticide will degrade, rate of degradation, and, in some instances, which 

degradation products are produced.

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination would be 

sandy soils with low organic matter. In contrast, the least vulnerable soils would be well-drained clayey 

soils with high organic matter. Consequently, pesticides with the lowest potential for movement in 

conjunction with appropriate BMPs (see below) would be used in an IPM framework to treat pests while 

minimizing effects to non-target biota and protecting environmental quality.

Along with soil properties, the potential for a pesticide to affect water quality through run-off and 

leaching would consider site-specific environmental and abiotic conditions including rainfall, water table 

conditions, and topography (Huddleston 1996).

• Water is necessary to separate pesticides from soil. This can occur in two basic ways. Pesticides 

that are soluble move easily with runoff water. Pesticide-laden soil particles can be dislodged and 

transported from the application site in runoff. The concentration of pesticides in the surface 

runoff would be greatest for the first runoff event following treatment. The rainfall intensity and 

route of water infiltration into soil, to a large extent, determine pesticide concentrations and losses 

in surface runoff. The timing of the rainfall after application also would have an effect. Rainfall 

interacts with pesticides at a shallow soil depth (1⁄4 to 1⁄2 inch), which is called the mixing zone 

(Baker and Miller 1999). The pesticide/water mixture in the mixing zone would tend to leach 

down into the soil or runoff depending upon how quickly the soil surface becomes saturated and 

how rapidly water can infiltrate into the soil. Leaching would decrease the amount of pesticide

available near the soil surface (mixing zone) to runoff during the initial rainfall event following 

application and subsequent rainfall events.

• Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper 

slopes would have greater potential for runoff following a rainfall event. In contrast, soils that are 

relatively flat would have little potential for runoff, except during intense rainfall events. In 

addition, soils in lower areas would be more susceptible to leaching as a result of receiving 

excessive water from surrounding higher elevations.

• Depth to groundwater would be an important factor affecting the potential for pesticides to leach 

into groundwater. If the distance from the soil surface to the top of the water table is shallow, 

pesticides would have less distance to travel to reach groundwater. Shallower water tables that 

persist for longer periods would be more likely to experience groundwater contamination. Soil 

survey reports are available for individual counties. These reports provide data in tabular format 

regarding the water table depths and the months during which it is persists. In some situations, a 

hard pan exists above the water table that would prevent pesticide contamination from leaching.
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Appendix E – Integrated Pest Management Program E-33

E.7.5 Determining Effects to Air Quality

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the atmosphere. 

The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure which would be 

affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. Vapor pressure is 

often expressed in mm Hg. To make these numbers easier to compare, vapor pressure may be expressed 

in exponent form (I x 10-7), where I represents a vapor pressure index. In general, pesticides with I less 

than10 would have a low potential to volatilize; whereas, pesticides with I greater than 1,000 would have 

a high potential to volatilize (Oregon State University 1996). Vapor pressure values for pesticides are 

usually available in the pesticide product MSDS or the USDA Agricultural Research Service (ARS) 

pesticide database.

E.7.6 Preparing a Chemical Profile

The following instructions would be used by Service personnel to complete Chemical Profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 

imazapic) that would be contained in one or more trade name products that are registered and labeled with 

EPA. All information fields under each category (e.g., Toxicological Endpoints, Environmental Fate) 

would be completed for a Chemical Profile. If no information is available for a specific field, then “No 

data is available in references” would be recorded in the profile. Available scientific information would 

be used to complete Chemical Profiles. Each entry of scientific information would be shown with 

applicable references.

Completed Chemical Profiles would provide a structured decision-making process utilizing quantitative 

assessment/screening tools with threshold values (where appropriate) that would be used to evaluate 

potential biological and other environmental effects to refuge resources. For ecological risk assessments 

presented in these profiles, the “worst-case scenario” would be evaluated to determine whether a pesticide 

could be approved for use considering the maximum single application rate specified on pesticide labels 

for habitat management and croplands/facilities maintenance treatments pertaining to refuges. Where the 

“worst-case scenario” likely would only result in minor, temporary, and localized effects to listed and 

non-listed species with appropriate BMPs (see Section 5.0), the proposed pesticide’s use in a PUP would 

have a scientific basis for approval under any application rate specified on the label that is at or below

rates evaluated in a Chemical Profile. In some cases, the Chemical Profile would include a lower

application rate than the maximum labeled rate in order to protect refuge resources. As necessary, 

Chemical Profiles would be periodically updated with new scientific information or as pesticides with the 

same active ingredient are proposed for use on the refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and environmental 

effects) would be clearly identified for specific information presented in a completed Chemical Profile. 

Comparison with these threshold values provides an explicit scientific basis to approve or disapprove 

PUPs for habitat management and cropland/facilities maintenance on the refuge. In general, PUPs would 

be approved for pesticides with Chemical Profiles where there would be no exceedances of threshold 

values. However, BMPs are identified for some screening tools that would minimize/eliminate potential 

effects (exceedance of the threshold value) as a basis for approving PUPs.

E.7.6.1 Date

Service personnel would record the date when the Chemical Profile is completed or updated. Chemical 

Profiles (e.g., currently approved pesticide use patterns) would be periodically reviewed and updated, as 
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Appendix E – Integrated Pest Management Program E-34

necessary. The most recent review date would be recorded on a profile to document when it was last 

updated.

E.7.6.2 Trade Name(s)

Service personnel would accurately and completely record the trade name(s) from the pesticide label, 

which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, I, II or 64). The suffix 

often distinguishes a specific product among several pesticides with the same active ingredient. Service 

personnel would record a trade name for each pesticide product with the same active ingredient.

E.7.6.3 Common chemical name(s)

Service personnel would record the common name(s) listed on the pesticide label or material safety data 

sheet (MSDS) for an active ingredient. The common name of a pesticide is listed as the active ingredient 

on the title page of the product label immediately following the trade name, and the MSDS, Section 2: 

Composition/Information on Ingredients. A Chemical Profile is completed for each active ingredient.

E.7.6.4 Pesticide Type

Service personnel would record the type of pesticide for an active ingredient as one of the following: 

herbicide, dessicant, fungicide, fumigant, growth regulator, insecticide, pisicide, or

rodenticide.

E.7.6.5 EPA Registration Number(s)

This number (EPA Reg. No.) appears on the title page of the label and MSDS, Section 1: Chemical 

Product and Company Description. It is not the EPA Establishment Number that is usually located near 

it. Service personnel would record the EPA Reg. No. for each trade name product with an active 

ingredient based upon PUPs.

E.7.6.6 Pesticide Class

Service personnel would list the general chemical class for the pesticide (active ingredient). For example, 

malathion is an organophosphate and carbaryl is a carbamate.

E.7.6.7 CAS (Chemical Abstract Service) Number

This number is often located in the second section (Composition/Information on Ingredients) of the 

MSDS. The MSDS table listing components usually contains this number immediately prior to or 

following the percent composition.

E.7.6.8 Other Ingredients

From the most recent MSDS for the proposed pesticide product(s), Service personnel would include any 

chemicals in the pesticide formulation not listed as an active ingredient that are described as toxic or 

hazardous, or regulated under the Superfund Amendments and Reauthorization Act (SARA), 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Toxic 

Substances Control Act (TSCA), Occupational Safety and Health Administration (OSHA), State Right-toKnow, or other listed authorities. These are usually found in MSDS sections titled “Hazardous 

Identifications,” “Exposure Control/Personal Protection,” and “Regulatory Information.” If 

concentrations of other ingredients are available for any compounds identified as toxic or hazardous, then 

Service personnel would record this information in the Chemical Profile by trade name. MSDS(s) may be 

obtained from the manufacturer, manufacturer’s website or from an online database maintained by Crop 

Data Management Systems, Inc. (see list below).
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Appendix E – Integrated Pest Management Program E-35

E.7.6.9 Toxicological Endpoints

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds,

and fish. Data would be recorded for species available in the scientific literature. If no data are

found for a particular taxonomic group, then “No data available is references” would be recorded

as the data entry. Throughout the Chemical Profile, references (including toxicological endpoint

data) would be cited using parentheses (#) following the recorded data.

E.7.6.10 Mammalian LD50

For test species in the scientific literature, Service personnel would record available data for oral lethal 

dose (LD50) in mg/kg-bw (body weight) or ppm-bw. Most common test species in scientific literature 

are the rat and mouse. The lowest LD50 value found for a rat would be used as a toxicological endpoint 

for dose-based RQ calculations to assess acute risk to mammals (see Table 1 in Section 7.1).

E.7.6.11 Mammalian LC50

For test species in the scientific literature, Service personnel would record available data for dietary lethal 

concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most common test species in scientific 

literature are the rat and mouse. The lowest LC50 value found for a rat would be used as a toxicological 

endpoint for diet-based RQ calculations to assess acute risk (see Table 1 in Section 7.1).

E.7.6.12 Mammalian Reproduction

For test species listed in the scientific literature, Service personnel would record the test results (e.g., 

Lowest Observed Effect Concentration [LOEC], Lowest Observed Effect Level [LOEL],

No Observed Adverse Effect Level [NOAEL], No Observed Adverse Effect Concentration

[NOAEC]) in mg/kg-bw or mg/kg-diet for reproductive test procedure(s) (e.g., generational studies 

[preferred], fertility, newborn weight). Most common test species available in scientific literature are rats 

and mice. The lowest NOEC, NOAEC, NOEL, or NOAEL test results found for a rat would be used as a 

toxicological endpoint for RQ calculations to assess chronic risk (see Table 1 in Section 7.1).

E.7.6.13 Avian LD50

For test species available in the scientific literature, Service personnel would record values for oral lethal 

dose (LD50) in mg/kg-bw or ppm-bw. Most common test species available in scientific literature are the 

bobwhite quail and mallard. The lowest LD50 value found for an avian species would be used as a 

toxicological endpoint for dose-based RQ calculations to assess acute risk (see Table 1 in Section 7.1).

E.7.6.14 Avian LC50

For test species available in the scientific literature, Service personnel would record values for dietary 

lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most common test species 

available in scientific literature are the bobwhite quail and mallard. The lowest LC50 value found for an 

avian species would be used as a toxicological endpoint for dietary-based RQ calculations to assess acute 

risk (see Table 1 in Section 7.1).

E.7.6.15 Avian Reproduction

For test species available in the scientific literature, Service personnel would record test results
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Appendix E – Integrated Pest Management Program E-36

(e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for reproductive test 

procedure(s) (e.g., early life cycle, reproductive). Most common test species available in scientific 

literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, NOEL, or

NOAEL test results found for an avian species would be used as a toxicological endpoint for RQ

calculations to assess chronic risk (see Table 1 in Section 7.1).

E.7.6.16 Fish LC50

For test freshwater or marine species listed in the scientific literature, Service personnel would record a 

LC50 in ppm or mg/L. Most common test species available in the scientific literature are the bluegill, 

rainbow trout, and fathead minnow (marine). Test results for many game species may also be available. 

The lowest LC50 value found for a freshwater fish species would be used as a toxicological endpoint for 

RQ calculations to assess acute risk (see Table 1 in Section 7.1).

E.7.6.17 Fish Early Life Stage (ELS)/Life Cycle

For test freshwater or marine species available in the scientific literature, Service personnel would record 

test results (e.g., LOEC, NOAEL, NOAEC, LOAEC) in ppm for test procedure(s) (e.g., early life cycle, 

life cycle). Most common test species available in the scientific literature are bluegill, rainbow trout, and 

fathead minnow. Test results for other game species may also be available. The lowest test value found 

for a fish species (preferably freshwater) would be used as a toxicological endpoint for RQ calculations to 

assess chronic risk (see Table 1 in Section 7.1).

E.7.6.18 Other

For test invertebrate as well as non-vascular and vascular plant species available in the scientific

literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or EC50

(environmental concentration) values in ppm or mg/L. Most common test invertebrate species available 

in scientific literature are the honey bee and the water flea (Daphnia magna). Green algae (Selenastrum 

capricornutum) and pondweed (Lemna minor) are frequently available test species for aquatic 

nonvascular and vascular plants, respectively.

E.7.7 Ecological Incident Reports

After a site has been treated with pesticide(s), wildlife may be exposed to these chemical(s). When 

exposure is high relative to the toxicity of the pesticides, wildlife may be killed or visibly harmed 

(incapacitated). Such events are called ecological incidents. The EPA maintains a database (Ecological 

Incident Information System) of ecological incidents. This database stores information extracted from 

incident reports submitted by various Federal and state agencies and non-government organizations. 

Information included in an incident report is date and location of the incident, type and magnitude of 

affects observed in various species, use(s) of pesticides known or suspected of contributing to the 

incident, and results of any chemical residue and cholinesterase activity analyses conducted during the 

investigation. 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded.

E.7.8 Environmental Fate
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Appendix E – Integrated Pest Management Program E-37

E.7.8.1 Water Solubility

Service personnel would record values for water solubility (Sw), which describes the amount of pesticide 

that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). Pesticide Sw values would 

be categorized as one of the following: insoluble less than 0.1 ppm, moderately soluble = 100 to 1,000 

ppm, highly soluble greater than 10,000 ppm (U.S. Geological Survey 2000). As pesticide Sw increases, 

there would be greater potential to degrade water quality through runoff and leaching. Sw would be used 

to evaluate potential for bioaccumulation in aquatic species [see Octanol-Water Partition Coefficient 

(Kow) below].

E.7.8.2 Soil Mobility

Service personnel would record available values for soil adsorption coefficient (Koc [μg/g]). It provides a 

measure of a chemical's mobility and leaching potential in soil. Koc values are directly proportional to 

organic content, clay content, and surface area of the soil. Koc data for a pesticide may be available for a 

variety of soil types (e.g., clay, loam, sand). Koc values would be used in evaluating the potential to 

degrade groundwater by leaching (see Potential to Move to Groundwater below). 

E.7.8.3 Soil Persistence

Service personnel would record values for soil half-life (t1⁄2), which represents the length of time (days) 

required for 50 percent of the deposited pesticide to degrade (completely or partially) in the soil. Based 

upon the t1⁄2 value, soil persistence would be categorized as one of the following: non-persistent less than 

30 days, moderately persistent 30 to 100 days, and persistent greater than 100 days (Kerle et al. 1996).

Threshold for Approving PUPs:

If soil t1⁄2 100 days or less, then a PUP would be approved without additional BMPs to protect

water quality.

If soil t1⁄2 is greater than 100 days, then a PUP would only be approved with additional BMPs specifically 

to protect water quality. One or more BMPs such as the following would be included in the 

Specific Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality:

• Do not exceed one application per site per year.

• Do not use on coarse-textured soils where the groundwater table is less than 10 feet and

average annual precipitation greater than 12 inches.

• Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is

saturated.

Along with Koc, soil t1⁄2 values would be used in evaluating the potential to degrade groundwater by 

leaching (see Potential to Move to Groundwater below).

E.7.8.4 Soil Dissipation

Dissipation time (DT50) represents the time required for 50 percent of the deposited pesticide to degrade 

and move from a treated site; whereas, soil t1⁄2 describes the rate for degradation only.

As for t1⁄2, units of dissipation time are usually expressed in days. Field dissipation time would be the 

preferred data for use to estimate pesticide concentrations in the environment because it is based upon 

field studies compared to soil t1⁄2, which is derived in a laboratory. However, soil t1⁄2 is the most common 

persistence data available in the published literature. If field dissipation data is not available, soil half-life 

data would be used in a Chemical Profile. The average or representative half-life value of most important 
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Appendix E – Integrated Pest Management Program E-38

degradation mechanism would be selected for quantitative analysis for both terrestrial and aquatic 

environments.

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of the 

following: Non-persistent less than 30 days, moderately persistent 30 to 100 days, and persistent more 

than 100 days.

Threshold for Approving PUPs:

If soil DT50 is 100 days or less, then a PUP would be approved without additional BMPs to protect water 

quality.

If soil DT50 is greater than 100 days, then a PUP would only be approved with additional BMPs

specifically to protect water quality. One or more BMPs such as the following would be included in the 

Specific Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality:

• Do not exceed one application per site per year.

• Do not use on coarse-textured soils where the ground water table is less than 10 feet and average 

annual precipitation is greater than 12 inches.

• Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is

saturated.

Along with Koc, soil DT50 values (preferred over soil t1⁄2) would be used in evaluating the potential to 

degrade groundwater by leaching (see Potential to Move to Groundwater below), if available.

E.7.8.5 Aquatic Persistence

Service personnel would record values for aquatic t1⁄2, which represents the length of time required for 50 

percent of the deposited pesticide to degrade (completely or partially) in water.

Based upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: nonpersistent

less than 30 days, moderately persistent 30 to 100 days, and persistent more than 100 days (Kerle et. al. 

1996).

Threshold for Approving PUPs:

If aquatic t1⁄2 is 100 days or less, then a PUP would be approved without additional BMPs to protect 

water quality.

If aquatic t1⁄2 is more than 100 days, then a PUP would only be approved with additional BMPs

specifically to protect water quality. One or more BMPs such as the following would be included in the 

Specific Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality:

• Do not exceed one application per site per year.

• Do not use on coarse-textured soils where the ground water table is less than 10 feet and average 

annual precipitation is more than 12 inches.

• Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is

saturated.

E.7.8.6 Aquatic Dissipation

Dissipation time (DT50) represents the time required for 50 percent of the deposited pesticide to degrade 

or move (dissipate); whereas, aquatic t1⁄2 describes the rate for degradation only. As for t1⁄2, units of 
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Appendix E – Integrated Pest Management Program E-39

dissipation time are usually expressed in days. Based upon the DT50 value, environmental persistence in 

aquatic habitats also would be categorized as one of the following:

Non-persistent less than 30 days, moderately persistent 30 to 100 days, and persistent more than

100 days.

Threshold for Approving PUPs:

If aquatic DT50 is 100 days or less, then a PUP would be approved without additional BMPs to protect 

water quality.

If aquatic DT50 is more than 100 days, then a PUP would only be approved with additional BMPs 

specifically to protect water quality. One or more BMPs such as the following would be included in the 

Specific Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality:

• Do not exceed one application per site per year.

• Do not use on coarse-textured soils where the groundwater table is less than 10 feet and average 

annual precipitation is greater than 12 inches.

• Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is

saturated.

E.7.8.7 Potential to Move to Groundwater

Groundwater Ubiquity Score (GUS) = log10(soil t 1⁄2) x [4 – log10(Koc)]. If a DT50 value is available, it 

would be used rather than a t 1⁄2 value to calculate a GUS score. Based upon the GUS value, the potential 

to move toward groundwater would be recorded as one of the following categories: extremely low 

potential less than 1.0, low-1.0 to 2.0, moderate-2.0 to 3.0, high-3.0 to 4.0, or very high more than 4.0.

Threshold for Approving PUPs:

If GUS is 4.0 or less, then a PUP would be approved without additional BMPs to protect water quality.

If GUS is more than 4.0, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the

Specific Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality:

• Do not exceed one application per site per year.

• Do not use on coarse-textured soils where the ground water table is less than 10 feet and average 

annual precipitation is greater than 12 inches.

• Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is

saturated.

E.7.8.8 Volatilization

Pesticides may volatilize (evaporate) from soil and plant surfaces and move off-target into the

atmosphere. The potential for a pesticide to volatilize is a function of its vapor pressure that is affected by 

temperature, sorption, soil moisture, and the pesticide’s water solubility. Vapor pressure is often 

expressed in mm Hg. To make these values easier to compare, vapor pressure would be recorded by 

Service personnel in exponential form (I x 10-7), where I represents a vapor pressure index. In general, 

pesticides with I less than 10 would have low potential to volatilize; whereas, pesticides with I greater 

than 1,000 would have a high potential to volatilize (Oregon State University 1996). Vapor pressure 

values for pesticides are usually available in the pesticide product MSDS or the USDA Agricultural 

Research Service (ARS) pesticide database (see References).
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Appendix E – Integrated Pest Management Program E-40

Threshold for Approving PUPs:

If I is 1,000 or less, then a PUP would be approved without additional BMPs to minimize drift and 

protect air quality.

If I is more than 1,000, then a PUP would only be approved with additional BMPs specifically to

minimize drift and protect air quality. One or more BMPs such as the following would be included in the 

Specific Best Management Practices (BMPs) section to reduce volatilization and potential to drift and 

degrade air quality:

• Do not treat when wind velocities are less than 2 mph or more than 10 mph with existing or 

potential inversion conditions.

• Apply the large-diameter droplets possible for spray treatments.

• Avoid spraying when air temperatures are higher than 85oF.

• Use the lowest spray height possible above target canopy.

E.7.8.9 Octanol-Water Partition Coefficient (Kow)

The octanol-water partition coefficient (Kow) is the concentration of a pesticide in octanol and water at 

equilibrium at a specific temperature. Because octanol is an organic solvent, it is considered a surrogate 

for natural organic matter. Therefore, Kow would be used to assess potential for a pesticide to 

bioaccumulate in tissues of aquatic species (e.g., fish). If Kow is greater than 1,000 or Sw is less than 1 

mg/L AND soil t1⁄2 is greater than 30 days, then there would be high potential for a pesticide to 

bioaccumulate in aquatic species such as fish (U.S. Geological Survey 2000).

Threshold for Approving PUPs:

If there is not a high potential for a pesticide to bioaccumulate in aquatic species, then the PUP would be 

approved.

If there is a high potential to bioaccumulate in aquatic species (Kow greater than 1,000 or Sw less than 1 

mg/L AND soil t1⁄2 is greater than 30 days), then the PUP would not be approved, except under unusual 

circumstances where approval would only be granted by the Washington Office.

E.7.8.10 Bioaccumulation/Bioconcentration

Bioconcentration is the physiological process where pesticide concentrations in tissue would increase in 

biota because they are taken and stored at a faster rate than they are metabolized or excreted. The 

potential for bioaccumulation would be evaluated through bioaccumulation factors BAFs) or 

bioconcentration factors (BCFs). Based upon BAF or BCF values, the potential to bioaccumulate would 

be recorded as one of the following: low–0 to 300, moderate–300 to 1,000, or high greater than 1,000 

(Calabrese and Baldwin 1993).

Threshold for Approving PUPs:

If BAF or BCF is 1,000 or less, then a PUP would be approved without additional BMPs.

If BAF or BCF is greater than 1,000, then a PUP would not approved, except under unusual

circumstances where approval would only be granted by the Washington Office.

E.7.9 Worst-Case Ecological Risk Assessment

E.7.9.1 Max Application Rates (acid equivalent)
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Appendix E – Integrated Pest Management Program E-41

Service personnel would record the highest application rate of an active ingredient (ae basis) for habitat 

management and cropland/facilities maintenance treatments in this data field of a Chemical Profile. 

These rates can be found in Table CP.1 under the column heading “Max Product Rate–Single Application 

(lbs/acre–AI on acid equiv basis)”. This table would be prepared for a chemical profile from information 

specified in labels for trade name products identified in PUPs. If these data are not available in pesticide 

labels, then write “NS” for “not specified on label” in this table.

E.7.9.2 EECs

An estimated environmental concentration (ECC) represents potential exposure to fish and wildlife (birds 

and mammals) from using a pesticide. EECs would be derived by Service personnel using an EPA 

screening-level approach (EPA 2004). For each max application rate [see description under Max 

Application Rates (acid equivalent)], Service personnel would record 2 EEC values in a Chemical Profile; 

these would represent the worst-case terrestrial and aquatic exposures for habitat management and 

croplands/facilities maintenance treatments. For terrestrial and aquatic EEC calculations, see description 

for data entry under Presumption of Unacceptable 

Risk/Risk Quotients, which is the next field for a Chemical Profile.

E.7.9.3 Presumption of Unacceptable Risk/Risk Quotients

Service personnel would calculate and record acute and chronic risk quotients (RQs) for birds, mammals, 

and fish using the provided tabular formats for habitat management and/or cropland/facilities maintenance 

treatments. RQs recorded in a Chemical Profile would represent the worst-case assessment for ecological 

risk. See Section 7.2 for discussion regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be based 

upon selected acute and chronic toxicological endpoints for fish and the EEC would be derived from 

Urban and Cook (1986) assuming 100 percent overspray to an entire 1-foot deep water body using the 

max application rate (ae basis [see above]).

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints for 

fish and an EEC would be derived from the aquatic assessment in AgDRIFT® model version 2.01 under 

Tier I ground-based application with the following input variables: max application rate (acid basis [see 

above]), low boom (20 inches), fine to medium/coarse droplet size, 20 swaths, EPA-defined wetland, and 

25-foot distance (buffer) from treated area to water.

See Section 7.2.1.2 for more details regarding the calculation of EECs for aquatic habitats for habitat 

management and cropland/facilities maintenance treatments.

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service personnel 

based upon dietary exposure, where the “short grass” food item category would represent the worst-case 

scenario. For terrestrial spray applications associated with habitat management and cropland/facilities 

maintenance treatments, exposure (EECs and RQs) would be determined using the Kanaga nomogram 

method through the EPA’s Terrestrial Residue Exposure model (T-REX) version 1.2.3. T-REX input 

variables would include the following: max application rate (acid basis [see above]) and pesticide half-life 

(days) in soil to estimate the initial, maximum pesticide residue concentration on general food items for 

terrestrial vertebrate species in short (shorter than 20 cm tall) grass.
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Appendix E – Integrated Pest Management Program E-42

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see Section 7.2.1.1.2 for the procedure that would be used to 

calculate RQs.

All calculated RQs in both tables would be compared with Levels of Concern (LOCs) established by EPA 

(see Table 2 in Section 7.2). If a calculated RQ exceeds an established LOC value (in brackets inside the 

table), then there would be a potential for an acute or chronic effect (unacceptable risk) to federally listed 

(T&E) species and nonlisted species. See Section 7.2 for detailed descriptions of acute and chronic RQ 

calculations and comparison to LOCs to assess risk.

Threshold for approving PUPs:

If RQs are less than or equal to LOCs, then a PUP would be approved without additional BMPs.

If RQs are greater than LOCs, then a PUP would only be approved with additional BMPs specifically to 

minimize exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs such as the 

following would be included in the Specific Best Management Practices

(BMPs) section to reduce potential risk to nonlisted or listed species:

• Lower application rate and/or fewer number of applications to RQs less than or equal to LOCs

• For aquatic assessments (fish) associated with cropland/facilities maintenance, increase the 

buffer distance beyond 25 feet so RQs less than or equal to LOCs.

E.7.9.4 Justification for Use

Service personnel would describe the reason for using the pesticide based control of specific pests or 

groups of pests. In most cases, the pesticide label will provide the appropriate information regarding 

control of pests to describe in the section.

E.7.9.5 Specific Best Management Practices (BMPs)

Service personnel would record specific BMPs necessary to minimize or eliminate potential effects to 

non-target species and/or degradation of water quality from drift, surface runoff, or leaching. These 

BMPs would be based upon scientific information documented in previous data fields of a Chemical 

Profile. Where necessary and feasible, these specific practices would be included in PUPs as a basis for 

approval.

If there are no specific BMPs that are appropriate, Service personnel would describe why the potential 

effects to refuge resources and/or degradation of environmental quality is outweighed by the overall 

resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See Section 4.0 of 

this document for a complete list of BMPs associated with mixing and applying pesticides appropriate for 

all PUPs with ground-based treatments that would be additive to any necessary, chemical-specific BMPs.

E.7.9.6 Data Resources

Service personnel would record scientific resources used to provide data/information for a chemical 

profile. Use the number sequence to uniquely reference data in a chemical profile. The following on-line 

data resources are readily available for toxicological endpoint and environmental fate data for pesticides:

1. California Product/Label Database. Department of Pesticide Regulation, California

Environmental Protection Agency.

(http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods)
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Appendix E – Integrated Pest Management Program E-43

2. ECOTOX database. Office of Pesticide Programs, US Environmental Protection Agency,

Washington, DC. (http://cfpub.epa.gov/ecotox/)

3. Extension Toxicology Network (EXTOXNET) Pesticide Information Profiles. Cooperative

effort of University of California-Davis, Oregon State University, Michigan State University,

Cornell University and University of Idaho through Oregon State University, Corvallis,

Oregon. (http://extoxnet.orst.edu/pips/ghindex.html)

4. FAO specifications and evaluations for plant protection products. Pesticide Management

Unit, Plant Protection Services, Food and Agriculture Organization, United Nations.

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/)

5. Human health and ecological risk assessments. Pesticide Management and Coordination,

Forest Health Protection, US Department of Agriculture, US Forest Service.

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm)

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center.

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm)

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land

Management, Dept. of Interior; Bonneville Power Administration, U.S. Dept. of Energy; and

Forest Service, US Department of Agriculture. (http://infoventures.com/e-hlth/pesticide/pestfac.

html)

8. Pesticide Fact Sheets. National Pesticide Information Center.

(http://npic.orst.edu/npicfact.htm)

9. Pesticide Fate Database. US Environmental Protection Agency, Washington, DC.

(http://cfpub.epa.gov/pfate/home.cfm).

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems,

Inc. (CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by 

agrichemical companies.

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture.

(http://www.oda.state.or.us/dbs/pest_products/search.lasso)

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada.

(http://www.hc-sc.gc.ca/pmra-arla/)

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment

Canada, Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm)

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and

Registration Fact Sheet. U.S Environmental Protection Agency, Washington, DC.

(http://www.epa.gov/pestidides/factsheets/chemical_fs.htm)

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The

Invasive Species Initiative. The Nature Conservancy.

(http://tnsweeds.ucdavis.edu/handbook.html)
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Appendix E – Integrated Pest Management Program E-44

16. Wildlife Contaminants Online. US Geological Survey, Department of Interior, Washington,

D.C. (http://www.pwrc.usgs.gov/contaminants-online/)

17. One-liner database. 2000. US Environmental Protection Agency, Office of Pesticide

Programs, Washington, D.C.

Chemical Profile

Date:

Trade Name(s): Common Chemical 

Name(s):

Pesticide Type: EPA Registration Number:

Pesticide Class: CAS Number:

Other Ingredients:

Toxicological Endpoints

Mammalian LD50:

Mammalian LC50:

Mammalian Reproduction:

Avian LD50:

Avian LC50:

Avian Reproduction:

Fish LC50:

Fish ELS/Life Cycle:

Other:

Ecological Incident Reports
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Appendix E – Integrated Pest Management Program E-45

Environmental Fate

Water solubility (Sw):

Soil Mobility (Koc):

Soil Persistence (t1⁄2):

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2):

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score):

Volatilization (mm Hg):

Octanol-Water Partition Coefficient 

(Kow):

Bioaccumulation/Biocentration: BAF:`

BCF:

Worst Case Ecological Risk Assessment

Max Application 

Rate 

(ai lbs/acre – ae 

basis)

Habitat Management:

Croplands/Facilities Maintenance:

EECs Terrestrial (Habitat Management):

Terrestrial (Croplands/Facilities Maintenance):

Aquatic (Habitat Management):

Aquatic (Croplands/Facilities Maintenance): 

Habitat Management Treatments:
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Appendix E – Integrated Pest Management Program E-46

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) Species Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Cropland/Facilities Maintenance Treatments:

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) Species Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Justification for Use:

Specific Best 

Management Practices 

(BMPs):

References:
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Appendix E – Integrated Pest Management Program E-47

Table CP.1 Pesticide Name

Trade Name Treatment 

Type

a

Max Product Rate 

– Single 

Application 

(lbs/acre or 

gal/acre)

b

Max Product

Rate -Single 

Application 

(lbs/acre - AI on 

acid equiv basis)

Max Number of 

Applications Per 

Season

Max Product Rate 

Per Season 

(lbs/acre/season or 

gal/acre/season)

a

From each label for a pesticide identified in pesticide use proposals (PUPs), Service personnel would 

record application information associated with possible/known uses on Service lands.

b

Treatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is 

labeled for both types of treatments (uses), then record separate data for H and CF applications. 

E.8 SPECIFIC WEED CONTROL PLANS

1. Bromus tectorum (cheatgrass, downy brome)

Priority: Medium: cheatgrass is widely distributed throughout the Protection Island, along roadways, and 

has invaded remnant native prairie and shrubland communities. Cheatgrass is prolific in dry upland 

habitat and competes with native plant species in especially disturbed soils such as those found in bluff 

and grassland habitat, both future restoration sites. It interferes with primary habitat management goals 

across the landscape, but the infestation is too large to eradicate with available technology. 

Description: Cheatgrass is a cool season annual grass that grows from 4 - 30 inches tall, reproducing by 

seed. Leaf sheaths and flat blades are covered with dense soft hairs. Mature cheatgrass seed heads are 

slender; 2 - 6 inches long and usually droop to one side. It easily competes with more desirable perennial 

grasses for moisture because of its fall, winter semi-dormant, and early spring growth habit. Seeds 

mature in mid to late June and plants dry and cure by the end of June, leading to hazardous fire 

conditions. 

Current Distribution on the Refuge: Cheatgrass is widely distributed throughout Protection Island and 

unknown on other refuge islands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites and other disturbed soil areas.

Objectives:

a. Monitor all newly seeded areas and other disturbed sites (e.g., remediation areas, wildfire areas, road 

cuts) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control cheatgrass to reduce competition with native plants germinating in the spring. Cheatgrass will 

be kept to comprising less than 40% of the live vegetation ground cover and spreading beyond its 

original infestation area. 
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Appendix E – Integrated Pest Management Program E-48

d. Maintain healthy stands of native perennial plants. 

Control Options: 

The chemical treatment of cheatgrass with an appropriate herbicide provides the most effective control. 

Currently, glyphosate (RoundupTM, Roundup ProTM), Clethodim (SelectTM) and imazapic (PlateauTM

Mechanical control of cheatgrass also is conducted on the Refuge with mixed results. Mowing before 

seed ripening probably prevents some re-seeding, but oftentimes the plants produce new stems and seeds 

at the mowed height. Mowing after seed ripening will kill adult plants, but dropped seeds are already 

viable. Repeated mowing during the growing season may be the most effective mechanical treatment, 

but is very labor-intensive and only practical on small infestations. Mowing is not possible in areas 

where cheatgrass starts seeding at height too low for the mower, steep slopes, and inaccessible islands. 

Prescribed burns in the spring or fall also help to control cheatgrass by stimulating native perennial grass 

growth or top killing seedlings. 

) are 

the herbicides used to control cheatgrass on the Refuge. The identified chemical control agents were 

selected on their versatility and selectivity in prairie restoration areas (PlateauTM and SelectTM) and 

complete control in areas requiring devegetation with minimal risk to groundwater contamination 

(RoundupTM). Glyphosate is soil binding, inexpensive, and a low threat to groundwater quality. 

Imazapic (PlateauTM) is used in dry upland sites with low leaching potential. This chemical can be 

broadcast in restoration areas where the establishment of native grasses and herbicide resistant native 

broadleafs are essential for restoration success. Clethodim (SelectTM ) is considered as a selective 

herbicide for use in grasslands, restoration areas, fence lines and rights of way. Other agents indicated 

for cheatgrass control but not selected for use are quizalofop, fluazifop-p-butyl,sethoxydim, sulfometuron 

methyl, and metribuzin. Clethodim is considered less toxic to avian and other wildlife species than other 

selective grass herbicides (quizalofop, fluazifop-p-butyl, sethoxydim and metribuzin). Clethodim has a 

short half life in soil and the EPA considers the chemical a low threat to groundwater quality. Other 

chemicals will be added as needed and be approved at the required level. All chemicals will be used in 

accordance with label recommendations.

The cultural methods of plowing, discing, etc. often cause an initial flush of cheatgrass growth that is 

usually controlled with herbicides before seeding with native perennial species. After restoration, the 

maintenance of healthy native plant communities and the minimization of disturbance help to prevent the 

spread of cheatgrass back into the area.

Treatment Schedule: Cheatgrass should be sprayed in the fall or early spring when plants are less than 

10 cm tall and actively growing, and non-target plants are dormant. 

2. Carduus nutans (musk thistle)

Priority: Medium: musk thistle has a limited distribution throughout the Refuge along roadways, and has 

invaded remnant native prairie and shrubland communities. Musk thistle is prolific in dry upland habitat 

and competes with native plant species in disturbed soils such as those found in recently seeded habitat 

restoration sites. It interferes with primary habitat management goals across the landscape, and the 

infestation is not too large therefore this species is targeted for eradicate.
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Appendix E – Integrated Pest Management Program E-49

Description: Musk thistle is a biennial which grows up to 6 feet tall. Leaves are dark green, deeply 

lobed, spiny, and extend onto the stem. Flowers are 11/2 to 3 inches in diameter and are usually deep 

rose, violet or purple. Musk thistle spreads rapidly to form dense stands that crowd out desirable plants. 

Current Distribution on the Refuge: Musk thistle is widely distributed throughout the Refuge at low 

densities but can be especially prolific in disturbed soils.

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor all newly seeded areas, roadways, and other disturbed sites (e.g., remediation areas, wildfire 

areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species if ground cover is needed. 

c. Control musk thistle to reduce competition with native plants germinating in the spring. Patches of 

musk thistle will be kept to less than one acre in area and less than 40% of live vegetation cover. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Mechanical control of musk thistle has been successful in preventing seed production 

and subsequent spread. Musk thistle is mowed at flowering in habitat restoration sites, along roadways, 

and in disturbed areas undergoing remediation. Dense stands are often mowed twice when new flowers 

appear. Repeated mowing during the growing season may be the most effective mechanical treatment, 

but is very labor-intensive. Small infestations of musk thistle rosettes also are removed by hand digging 

when labor is available. 

The biological control agent, Rhinocyllus conicus (seed head weevil) is established in Washington state, 

but has had limited effect on thistle control and a negative side effect of this bio-controls that it also 

attacks native thistle species. There are no known native thistle species occurring on any refuge unit. 

The larvae of this weevil eat the seeds in mature flower heads. This biocontrol is probably effective in 

reducing musk thistle seed production by up to 50% based on casual observation. Infestations of 

individual plants or widely dispersed individuals will be examined for the presence of the Rinocyllus

conicus larvae and adults and left in place if infected. These infected plants can be used as farm plants 

for the insects with the harvested individuals relocated to larger thistle patches. 

The chemical treatment of musk thistle with an appropriate herbicide also provides effective control. 

Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM) glyphosate (RoundupTM, 

Roundup ProTM, RodeoTM), metsulfuron methyl (EscortTM) and imazapic (PlateauTM) are the herbicides 

that could be used to control small musk thistle infestations on the Refuge. Aminopyralid is very 

selective, provides longer control and can be used at lower rates. Glyphosate is soil binding, 

inexpensive, with low groundwater contamination potential. Imazapic is used in dry upland sites with 

low leaching potential. Metsulfuron is extremely effective on thistle and common mullein plants. 

Imazapic and metsulfuron can be broadcast in restoration areas where native grasses and resistant native 
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Appendix E – Integrated Pest Management Program E-50

broadleafs are essential for restoration success. Other chemicals will be added as needed and be 

approved at the required level. All chemicals will be used in accordance with label recommendations. 

The mechanical methods of plowing, discing, etc., often cause an initial flush of musk thistle rosettes that 

may be controlled with herbicides before seeding with native perennial species. After restoration, the 

maintenance of healthy native plant communities and the minimization of disturbance help to prevent the 

spread of musk thistle back into the area.

Treatment Schedule: Musk thistle should be repeatedly mowed at flowering to prevent seed production

and/or sprayed in the rosette stage in fall or late spring during bolting or when desirable non-target plants 

are dormant. Spraying in the early summer when the plants have bolted or rosettes in the fall are also 

effective control methods other options will be used according to the label recommendations. 

3. Centaurea diffusa (diffuse knapweed)

Priority: High: The spread of diffuse knapweed is an increasing problem in many areas in Washington. 

It is considered one of the most important rangeland weeds in North America. The State of Washington 

considers this species one of the top ten priority weeds targeted for control, particularly for preventing 

new infestations. Diffuse knapweed infests disturbed areas where it forms dense colonies in pastures, 

croplands, waste places, and rights-of-way. It is a prolific seed producer, fast spreading, and highly 

agonistic with native plants often out competing them. 

Description: Diffuse knapweed grows as an annual or short-lived perennial forb. The diffusely 

branched stems of mature plants are 1 to 2 feet tall, rough to the touch, and tipped with numerous slender, 

white to purplish flower heads. Prominent yellow bracts with comb-like margin projections subtend the 

flower. The leaves are pinnately divided near the plant’s base; the leaf margins appear entire towards the 

inflorescence. Flowering occurs from July through September.

Current Distribution on the Refuge: No known infestations are present on any of the refuge islands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of diffuse knapweed plants - targeting for elimination - to reduce competition with native 

plants and prevent establishment of knapweed and knapweed seed bank. Larger infestation patches 

will be mapped and measured using geographic information software and a global positioning system 

device. Patches will be treated to prevent increase in the infestation area.

d. Maintain healthy stands of native perennial plants.
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Appendix E – Integrated Pest Management Program E-51

Control Options: Hand pulling or digging is a feasible control of small infestations and individual plants. 

The taproot will be removed to at least 2 inches below the ground surface.

Insect species that target diffuse knapweed include the seedhead weevils (Larinus minutus), broad-nosed 

seedhead weevil (Bangasternus fausti) are not well established, and seed head fly (Urophora affinis), seed 

head fly (Urophora quadrifasciata), and root boring/gall beetle (Sphenoptera jugoslavica) are available 

for mass collections. These insects reduce seed production which assists in slowing or eliminating 

spread. Biological agent will be an option in areas that are prohibited to other forms of control and 

pending the availability of the insect. Biological control of diffuse knapweed on the Refuge has not been 

attempted in the past. 

The chemical treatment of diffuse knapweed with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone) glyphosate (RoundupTM, Roundup ProTM) and imazapic 

(PlateauTM

Treatment Schedule: Hand removal will be conducted 2 to 3 times during the growing season, the first 

removal occurring early in the season (June) before bolt. Established areas too large to practically 

control by hand, or in areas prohibited to chemical control, will be mowed monthly to prevent floret 

emergence and seed production.

) would be the herbicides used to control diffuse knapweed on the Refuge. Aminopyralid is 

very selective, provides longer control and can be used at lower rates. Glyphosate is soil binding, 

inexpensive, and a low threat to groundwater quality. Imazapic (PlateauTM) is used in dry upland sites 

and on soils with low leaching potential. This chemical can be broadcast in restoration areas where the 

establishment of native grasses and herbicide resistant native broadleafs are essential for restoration 

success. Other recommended chemical treatments for diffuse knapweed are picloram, clopyralid, 

dicamba, and 2,4-D. The Refuge avoids the use of restricted use pesticides like picloram. Clopyralid is 

not recommended for use on permeable soils due to potential groundwater contamination. Dicamba has 

low toxicity for wildlife but is not recommended for use near water. Aquatic formulations of glyphosate 

currently serve for weed control near water. Other chemicals will be added as needed and be approved at 

the required level. All chemicals will be used in accordance with label recommendations.

The release of seed head weevils will occur as the leaves of the plants appear in June to the budding stage. 

Control is less effective if seeds have already formed. 

The application of aminopyralid, glyphosate or imazapic will occur once during the growing season (June 

- November). The most effective time of control is during the rosette or bolt stage before budding. 

Annual treatment is necessary as long as there is a viable seed source.

4. Centaurea maculosa (spotted knapweed)

Priority: High: The State of Washington considers this species one of the top ten priority weeds targeted 

for control. Spotted knapweed infests disturbed areas where it forms dense colonies in pastures, 

croplands, waste places, and rights-of-way. It is a prolific seed producer, fast spreading, and highly 

agonistic with native plants – often out-competing them. Populations enlarge by peripheral expansion of 

existing stands. Biodiversity, livestock and wildlife forage quality are reduced with infestations of 

spotted knapweed. 
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Appendix E – Integrated Pest Management Program E-52

Description: Spotted knapweed is a biennial or short-lived perennial forb with a deep taproot. Plants 

reach 1 to 3 feet with one or more branched stems. The basal leaves vary in morphology from entire to 

pinnate and elliptical to oblanceolate. The principal stem leaves are pinnately divided. Flowers are 

primarily light purple (rarely white). Involucral bracts are stiff with a finely branched, dark tip. 

Flowering occurs from June through September. 

Current Distribution on the Refuge: No known infestations are present on any of the refuge islands.

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

restoration areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of spotted knapweed plants - targeting for elimination - to reduce competition 

with native plants and prevent establishment of knapweed and knapweed seed bank. Larger 

infestation patches will be mapped and measured using geographic information software and a global 

positioning system device. Patches will be treated to prevent increase in the infestation area.

d. Maintain healthy stands of native perennial plants.

Control Options: Hand pulling or digging is a feasible control of small infestations and individual 

plants. The taproot will be removed to at least 2 inches below the ground surface. Entire plants will be 

removed from the site to limit the source of available seeds.

Biological control of spotted knapweed is not effective in eliminating stands. Insect larvae are available 

that target flowers, roots, shoots, and leaves leading to reduced seed production. Two commonly used 

organisms that target spotted knapweed roots are the sulphur knapweed moth (Agapeta zoegana) and the 

knapweed weevil (Cyphocleonus achates). Biological control could be used in new and current 

infestations that cannot be controlled by hand or chemical treatment.

The chemical treatment of spotted knapweed with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM) and imazapic 

(PlateauTM

Treatment Schedule: Hand removal will be conducted 2 to 3 times during the growing season, the first 

removal occurring early in the season (June) before bolt. Established areas too large to practically 

) would be the herbicides used to control spotted knapweed on the Refuge. Aminopyralid is 

very selective, provides longer control and can be used at lower rates. Other recommended chemical 

treatments for diffuse knapweed are picloram, clopyralid, dicamba, and 2,4-D. The Refuge avoids the 

use of restricted use pesticides like picloram. Clopyralid is not recommended for use on permeable soils 

due to potential groundwater contamination. Dicamba has low toxicity for wildlife but is not 

recommended for use near water. Aquatic formulations of glyphosate currently serve for weed control 

near water. Other chemicals will be added as needed and be approved at the required level. All

chemicals will be used in accordance with label recommendations.
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Appendix E – Integrated Pest Management Program E-53

control by hand, or in areas prohibited to chemical control, will be mowed monthly to prevent floret 

emergence and seed production.

Selected biological control insect(s) will be, if used, released during the optimal time for both insect and 

plant to provide the greatest effectiveness for controlling spotted knapweed.

Aminoryralid, glyphosate or imazapic will be applied once during the growing season (June - November). 

The most effective time of control is during the bolt to bud stage. Annual treatment is necessary as long 

as there is a viable seed source. 

5. Centaurea jacea x nigra (Meadow Knapweed)

Priority: High: The State of Washington considers this species one of the top ten priority weeds targeted 

for control. Meadow knapweed invades open, disturbed areas. This species forms monotypic stands, 

suppressing the growth of other vegetation. Reproduction is primarily from seeds and crown.

Description: Meadow knapweed is a perennial growing from a woody root crown, with 20 to 40 inch tall 

upright stems. Its basal leaves can be up to six inches long and 1.25 inches wide, tapering at both ends. 

The stem leaves are lance-shaped, stalkless, and sometimes shallowly lobed, while the uppermost leaves 

are smaller and not lobed. The rose-purple to occasionally white flowers occur in solitary, oval, or almost 

globe-shaped flower heads at the ends of branches. The light to dark brown involucral bracts are 

roundish, with a torn, thin, papery margin, or a comb-like, fringed margin. More apparent on outer 

bracts, the fringes are about equal in width to the central body of the bract. Meadow knapweed flowers 

from July to September, producing ivory-white to light brown seeds that may or may not have a barely

noticeable plume. However, because it is a hybrid, meadow knapweed traits are highly variable.

Current Distribution on the Refuge: No known infestations are present on any of the refuge islands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of Meadow knapweed plants - targeting for elimination - to reduce 

competition with native plants and prevent establishment of knapweed and knapweed seedbank. 

Larger infestation patches will be mapped and measured using geographic information software and a 

global positioning system device. Patches will be treated to prevent increase in the infestation area.

d. Maintain healthy stands of native perennial plants

Control Options: 
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Appendix E – Integrated Pest Management Program E-54

Removal of the above-ground tissue by mowing or hand-scything weakens the plant, reduces root growth, 

and prevents seed production, but will not eliminate the infestation.

Biological control with the seed head gall fly, Urophora quadrifasciata, has had fair success on meadow 

knapweed.

The reseeding of disturbed areas is effective in preventing the infestation of Russian knapweed

The chemical treatment of Meadow knapweed with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM

Treatment Schedule: Top growth will be removed before bolting during the growing season (June - midAugust) to weaken Russian knapweed plants. Plants that re-emerge (mid-August to September) are 

smaller and more vulnerable to further top removal and herbicide effect. 

) and imazapic 

(PlateauTM) would be the herbicides used to control Meadow knapweed on the Refuge. Aminopyralid is 

very selective, provides longer control and can be used at lower rates. Glyphosate is soil binding, 

inexpensive, with low groundwater contamination potential. Glyphosate is a nonspecific herbicide and 

the use of it should be accompanied by seeding, planting, or use in areas where native vegetation is 

prolific. Imazapic (PlateauTM) is used in dry upland sites and on soils with low leaching potential. This 

chemical can be broadcast in restoration areas where the establishment of native grasses and herbicide 

resistant native broadleafs are essential for restoration success. Other chemicals will be added as needed 

and be approved at the required level. All chemicals will be used in accordance with label 

recommendations.

Glyphosate will be applied once or twice during the growing season (June - November). Top-growth of 

Russian knapweed can be controlled by applying herbicide during the bud stage. Root control is 

achieved by timing applications to the late bud and fall growth stage. Other listed chemical will be used 

according to the label recommendations.

6. Polygonum bohemicum (Bohemian knotweed) 

Priority: High: The State of Washington considers this species one of the top ten priority weeds targeted 

for control. The most common invasive knotweeds in western Washington, this species is a hybrid 

between giant and Japanese knotweed and shares characters of both parent species. It was introduced as 

an ornamental in its own right but has become very widespread in our region, especially along rivers and 

roadways. This plant spreads mostly by stem and root fragments and is usually found in disturbed areas 

such as flood zones and roadsides.

Currently, most Bohemian knotweed plants are males and therefore lack seeds. Recent findings have 

found that seed-bearing hybrids have appeared, probably indicating a back-cross with giant or Japanese 

knotweed. The existence of seeding hybrids may allow this plant to spread even more rapidly in the 

future.
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Appendix E – Integrated Pest Management Program E-55

Description: Plants are usually 6.5 to 10 feet tall. Stems are stout, cane-like, hollow between the nodes, 

somewhat reddish-brown and usually branched. The plants die back above ground at the end of the 

growing season. However, the dead reddish brown canes often persist throughout the winter. The stem 

nodes are swollen and surrounded by thin papery sheaths. Leaves

One key identifying feature is the 

can be either spade or heart-shaped, 

usually more heart-shaped lower down on the stems and more spade-shaped near the branch ends. This 

variability in leaf shape is one identifying character since the parent species generally have either heartshaped or spade-shaped leaves. 

hairs on the leaf undersides especially along the midvein. Bohemian 

knotweed has hairs that are short and broad-based (triangular-shaped), compared with long and wavy in 

giant knotweed and reduced to barely noticeable bumps in Japanese knotweed. 

The flowers are small, creamy white to greenish white, and grow in showy plume-like, branched clusters 

from leaf axils near the ends of the stems. Flower clusters are generally about the same length as the 

subtending leaf, unlike the shorter flower clusters found on giant knotweed and the longer clusters found 

on Japanese knotweed. Leaf and flower characters are most reliable when looking near the middle of a 

branch. The fruit

Current Distribution on the Refuge: Only known infestations are on the Dawley unit. 

is 3-sided, black and shiny

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of Bohemian knotweed plants - targeting for elimination - to reduce 

competition with native plants and prevent establishment of knotweed and knotweed seedbank. 

Larger infestation patches will be mapped and measured using geographic information software and a 

global positioning system device. Patches will be treated to prevent increase in the infestation area.

d. Maintain healthy stands of native perennial plants

Control Options: 

Knotweed is very difficult to eradicate once it has become established. It is, therefore, important to 

prevent new infestations and eradicate small patches before they spread. Mechanical and chemical 

control methods can be used on knotweed, often in conjunction with each other. If control is to be 

effective, the sites must be visited throughout several seasons to further control any new growth.

Removal of the above-ground tissue by mowing or hand-scything weakens the plant, but because of the 

extensive root system this method is ineffective as a control method especially on larger infestation. 

The reseeding of disturbed areas is effective in preventing the infestation of Bohemian knotweed.
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The chemical treatment of Bohemian knotweed by injection with an appropriate herbicide provides 

relatively effective control. Currently, imazaypr (Arsenal), and glyphosate (RoundupTM, Roundup ProTM) 

would be the herbicides used to control Bohemian knotweed on the Refuge. Imazaypr is similar to 

glyphosate, has a very low toxicity to most animals, but does remain in the soil longer than glyphosate. 

Mixing two kinds of herbicides together often improves the effectiveness when compared with using each 

herbicide individually. By mixing the glyphosate and imazapyr together, we can reduce the total amount 

of herbicide used. Glyphosate is soil binding, inexpensive, with low groundwater contamination 

potential. Glyphosate is a nonspecific herbicide and the use of it should be accompanied by seeding, 

planting, or use in areas where native vegetation is lacking. Other chemicals will be added as needed and 

be approved at the required level. All chemicals will be used in accordance with label recommendations.

Treatment Schedule: Injection of the herbicide is best done at the end of summer August September just 

prior to seed set. 

7. Cirsium arvense (Canada thistle)

Priority: Low to Medium: The priority for controlling this species is dependent upon location. The State 

of Washington considers this species widespread and detrimental to agriculture. Canada thistle can form 

monocultures, crowding out desirable species. Extensive horizontal roots give rise to shoots. This 

species infests roadsides, pastures, cropland, disturbed areas, and riparian areas. The dense growth 

pattern and spiny leaves of Canada thistle deters passage and consumption by wildlife. 

Description: Canada thistle is a colony-forming perennial forb. Stems reach 1 to 4 feet with branching 

tops. Flowers are purple with spineless bracts. The leaves are irregularly lobed and tipped with tiny 

spines. Flowering occurs July through August.

Current Distribution on the Refuge: Canada thistle is widely distributed on the Protection, found in 

various soil types and vegetation communities. This species tends to invade re-seeded restoration areas. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Canada thistle control applied to keep infestations to less than 1 acre in area and weedy species 

comprising 40% or less of live vegetation cover.

d. Maintain healthy stands of native perennial plants.

Control Options: The nature of the Canada thistle infestation on Protection Island makes it impossible to 

control with simple hand methods. The removal of shoots by mowing is a viable option. The continued 

removal of above ground photosynthetic tissue has been shown to weaken plants and limit their spread 

through carbohydrate starvation.
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Biological control offers many insects, a few nematodes, and the American Goldfinch have been reported 

to feed on various parts of Canada thistle. Most of these do very little damage. Three insects from 

Europe have been studied for biological control - Altica carduorum Guer (flea beetle), a leaf feeder, has 

not established itself well. Adults of the beetle Ceutorhynchus litura F. eat young thistle shoots, but do 

little damage. The fly, Urophora cardui L. is the most promising biological control agent. Eggs are laid 

in the terminal buds and galls develop which divert nutrients and stress the plant. Many microorganisms 

have been found associated with Canada thistle, but no potential biocontrol agents are known.

The chemical treatment of Canada thistle with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM, Rodeo®) and 

imazapic (Plateau ®

Treatment Schedule: Hand pulling or digging of plants in the rosette stage is effective for small 

infestations. Monthly mowing or scything of bolted plants in moist soil areas or areas with a high water 

table (riparian/wetlands) are effective in limiting spread. 

) are the herbicides used to control Canada thistle on the Refuge. Aminopyralid is 

very selective, provides longer control, can be used at lower rates, and be applied near water. Glyphosate 

is soil binding, inexpensive, with low groundwater contamination potential. Glyphosate is a nonspecific 

herbicide and the use of it should be accompanied by seeding, planting, or use in areas where native 

vegetation is prolific. Imazapic (PlateauTM) is used in dry upland sites and on soils with low leaching 

potential. This chemical can be broadcast in restoration areas where the establishment of native grasses 

and herbicide resistant native broadleafs are essential for restoration success. Other herbicides that are 

shown to be effective on Canada thistle are picloram, clopyralid, and 2,4-D. The Refuge avoids the use 

of restricted use pesticides like picloram. Clopyralid is not recommended for use on leachable soils. 

2,4-D will be used on the Refuge with its effectiveness monitored and the use expanded to possibly 

replace imazapic in some capacities. As with all herbicides, 2,4-D has been detected in groundwater 

although the sources of contamination are associated with inappropriate use and spillage. Other 

chemicals will be added as needed and be approved at the required level. All chemicals will be used in 

accordance with label recommendations.

The stem-and-shoot gadfly will be released in June through July for new and existing invaded wetland 

areas where chemical and mechanical controls are not feasible.

Chemical control will occur in spring and fall, 1-2 times per season (June-October), particularly in the fall 

when shoot to root translocation is highest. This species is sensitive to moisture content or drought 

stress. Application of pesticide should occur when moisture condition is higher.

8 Cirsium vulgare (bull thistle)

Priority: Low to Medium: The priority for controlling this species is dependent upon location. Bull 

thistle grows in moist to dry areas, particularly in loamy or clay soils. It is a rapidly proliferating 

transient species in disturbed, open sites. Native vegetation and wildlife habitat value are compromised 

by infestation.

Description: Bull thistle is a biennial forb with a rosette forming the first year. A short tap root supports 

a 2 to 5 foot many-branched stem during the second year. The leaves are pinnatley lobed, prickly, with a 
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Appendix E – Integrated Pest Management Program E-58

cottony underside. The involucre of the light purple flower is covered with long spines. Flowering 

occurs from July through September.

Current Distribution on the Refuge: Bull thistle has not produced major infestations on the Refuge. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control Bull thistle to reduce competition with native plants by preventing seed production and 

keeping infestations to less than 1 acre and less than 40% of live vegetation cover. 

d. Maintain healthy stands of native perennial plants.

Control Options: Small stands of Bull thistle will be mowed, scythed, or hand cut to remove the bolted 

but not flowered stem. Hand cutting will include removing the stem and root crown. 

The bull thistle seedhead gall fly (Urophora stylata) is effective in reducing stand density. Control of 

seed production is effective where the population of gall flies is high. This control method is not 

recommended for small infestations.

The chemical treatment of Bull thistle with an appropriate herbicide provides relatively effective control. 

Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM

Treatment Schedule: Mechanical and hand removal will occur during bolt but before flowering (late 

June - July). Late bolting plants need removal before flowering to prevent seed formation.

, RodeoTM) and imazapic 

(PlateauTM) are the herbicides used to control Bull thistle on the Refuge. Aminopyralid is very selective, 

provides longer control, can be used at lower rates. Glyphosate is soil binding, inexpensive, and a low 

threat to groundwater quality. Imazapic (PlateauTM) is used in dry upland sites and on soils with low 

leaching potential. This chemical can be broadcast in restoration areas where the establishment of native 

grasses and herbicide resistant native broadleafs are essential for restoration success. Other chemicals 

will be added as needed and be approved at the required level. All chemicals will be used in accordance 

with label recommendations.

Herbicides will be applied 1 -2 times during the growing season (April - November). Application will 

occur during the rosette stage or after mowing or scything. 

9. Convolvulus arvensis (field bindweed)

Priority: Low to Medium: Field bindweed is highly competitive species with prodigious powers of 

regeneration from roots and rhizomes. Bindweed can survive a wide range of environmental conditions, 
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but disturbed soil is a necessity for invasion. Bindweed is a threat to the regeneration of native 

vegetation.

Description: Field bindweed is perennial forb growing as a climbing and prostrate vine that forms dense 

mats. The taproot is deep, forming an extensive root system. The leaves are sagittate; flowers are bellshaped and pink to white. Blooming occurs from June until frost.

Current Distribution on the Refuge: Bindweed is widely spread on Protection Island and unknown on

other islands.

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control field bindweed to reduce competition with native plants by keeping any infestation at less than 

40% of live vegetation cover.

d. Maintain healthy stands of native perennial plants.

Control Options: Mechanical and hand methods of control are impractical and ineffective due to the 

species’ distribution and ability to regenerate from severed roots and rhizomes.

The chemical treatment of field bindweed with an appropriate herbicide provides relatively effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM

The field bindweed moth (Tyta luctuosa) and the field bindweed mite (Aceria malherbae) have not been 

used to control field bindweed at the Refuge. These agents have not established well in the Pacific 

Northwest. 

) and imazapic (PlateauTM) are the herbicides 

used to control field bindweed on the Refuge. Glyphosate is soil binding, inexpensive, and a low threat 

to groundwater quality. Imazapic (PlateauTM) is used in dry upland sites and on soils with low leaching 

potential. This chemical can be broadcast in restoration areas where the establishment of native grasses 

and herbicide resistant native broadleafs are essential for restoration success. Other herbicides indicated 

for field bindweed control are picloram, dicamba, and 2,4-D. The uses of restricted use pesticides like 

picloram are avoided at the Refuge. Dicamba has low wildlife toxicity but is not for use near water. 

Aquatic formulations of glyphosate fill that niche. 2,4-D will be used at the Refuge. Its effectiveness 

will be monitored and the herbicide will be considered as a replacement for imazapic in some situations. 

As with all herbicides, 2,4-D has been detected in groundwater although the sources of contamination are 

associated with inappropriate use and spillage. Other chemicals will be added as needed and be approved 

at the required level. All chemicals will be used in accordance with label recommendations.

Treatment Schedule: Herbicides will be applied one to two times during the growing season (June -

November). The period of highest chemical effectiveness is in the early flowering stage. Invaded sites 
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Appendix E – Integrated Pest Management Program E-60

will be monitored to determine the local variation in conditions that lead to the plants’ flowering time. 

Multiple year applications may be necessary.

The field bindweed moth and field bindweed mite would be released to heavily infested bindweed sites 

during the early growing season (June through August). The release of bioagents will be dependent on 

the insects’ availability.

10 Hypericum perforatum (St. Johnswort)

Priority: Low to medium: St. Johnswort invades disturbed sites along roadsides, over-grazed pastures 

and range, and waste places. It prefers dry, sandy to gravelly soil. St. Johnswort forms a deep, laterally 

spreading root system that forms new plants vegetatively from root buds. Dense growth of these plants 

inhibits regeneration of native species.

Description: St. Johnswort is a perennial shrub-like forb. The stems produce numerous branches and 

reach 1 to 3 feet high. Leaves are up to one inch long, opposite, entire, and contain numerous transparent 

dots. Flowers are yellow arranged in open, flat-topped cymes.

Current Distribution on the Refuge: St. Johnswort has not been identified on any of the Refuge 

islands.

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of St. Johnswort plants - targeting for elimination - to reduce competition with native 

plants and stop the spread of infestations.

d. Maintain healthy stands of native perennial plants.

Control Options: Small infestations of new plants can be pulled by hand or dug out. 

Glyphosate (Roundup® and Roundup Pro®) is effective in controlling St. Johnswort. Glyphosate is soil 

binding, inexpensive, and a low threat to groundwater quality. Other herbicides indicated for effective 

St. Johnswort control are picloram and 2,4-D. The use of restricted use pesticides such as picloram is 

avoided on the Refuge. 2,4-D is planned for use on the Refuge to control various broadleaf noxious 

weeds and its use for St Johnswort control could be considered in the future. As with all herbicides, 2,4-

D has been detected in groundwater although the sources of contamination are associated with 

inappropriate use and spillage. Other chemicals will be added as needed and be approved at the required 

level. All chemicals will be used in accordance with label recommendations.
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Biological control of St. Johnswort with the Klamath weed beetle (Chrysolina quadrigemia) has been 

very effective in North America. Two foliage beetles, Chrysolina hyperici and C. quadrigemina were 

released in California from 1945 to 1946, and established within two years. A root-boring beetle Agrilus 

hyperici and a leaf bud gall-forming midge Zeuxidiplosis giardi were released in 1950 to help the 

Chrysolina spp. Recently released in the state and established is the moth Aplocera plagiata. 

Treatment Schedule: Removal and disposal of plants will be done in early spring (before flower 

formation). 

Due to the 

success of these beetles in controlling St. Johnswort, their continued use for established and new 

infestations is the preferred method of control.

Spot spraying with glyphosate (Roundup® and Roundup Pro®) before flowering can be an effective 

control method if repeated applications are made. Bolting and flowering occur early and continue 

through late summer (June - September). Patches need to be monitored for newly sprouted plants 

throughout the summer.

The release of Klamath weed beetles will be made in July to new or non-beetle infested areas. Beetles (if 

available) established in an area on the Refuge will be harvested and used as colonizers. 

11. Linaria genistifolia (dalmatian toadflax)

Priority: High: Dalmation toadflax is an aggressive, colony-forming invasive. This species is

opportunistic in invading disturbed sites, but it can also press into established vegetation communities in 

good condition. Native communities and restored sites may be jeopardized by the creeping expansion of 

Dalmation toadflax adventitious root buds. Competition between natives and toadflax may make the 

community more vulnerable to other invasive species. Dalmation toadflax produces a toxic substance 

and is unpalatable to livestock and wildlife. 

Description: Dalmation toadflax is a perennial forb reaching up to 3 feet in height. Reproduction is by 

seed and underground root stalks. Leaves are alternate and variable in shape - ovate to lanceolate. 

Leaves and stems are robust, glaborous with whitish or bluish cast. Flowers grow at the axils of the 

upper leaves. The spurred-flower is yellow with an orange center. Flowers bloom late June through 

October.

Current Distribution on the Refuge: Currently, no islands are known to have any infestation, but 

Dungeness Spit has a small patch located on Graveyard spit. That site has been treated for several years 

by hand-pulling. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 
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Appendix E – Integrated Pest Management Program E-62

c. Treat 100% of Dalmation toadflax plants - targeting for elimination - to reduce competition with native 

plants.

d. Maintain healthy stands of native perennial plants.

Control Options: Hand pulling individual plants before seed set decreases seed production. Scything or 

mowing of stands before seed set is also effective. These methods do not kill the plant, but over time 

will with repeated pulling, the population will be reduced.

The chemical treatment of dalmation toadflax with an appropriate herbicide provides relatively effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM

Biological control using Calophasia lunula, a defoliating moth, is well-established in Washington and 

reportedly provides good control.

) and imazapic (PlateauTM) are the herbicides 

used to control Dalmation toadflax on the Refuge. Glyphosate is soil binding, inexpensive, and a low 

threat to groundwater quality. Glyphosate is appropriate for spot treatments, but its broad specificity 

precludes broadcast applications. Imazapic (PlateauTM) is used in dry upland sites and on soils with low 

leaching potential. This chemical can be broadcast in restoration areas where the establishment of native 

grasses and herbicide resistant native broadleafs are essential for restoration success. Other chemicals 

will be added as needed and be approved at the required level. All chemicals will be used in accordance 

with label recommendations.

Treatment Schedule: The removal of above ground portions of the plant before seed set will be done in 

April through July. The seeds are long-lived; annual removal of plants for up to ten years is necessary to 

deplete the seed bank.

Applications of glyphosate and imazapic will be made one to two times per growing season (April -

November). Fall applications are particularly effective in decreasing the available stored carbohydrates 

in the roots. 

12. Linaria vulgaris (yellow toadflax)

Priority: High: Yellow toadflax is an aggressive, colony-forming invasive. This species is opportunistic 

in invading disturbed sites, but it can also press into established vegetation communities in good 

condition. Native communities and restored sites may be jeopardized by the creeping expansion of 

yellow toadflax adventitious root buds. Competition between natives and toadflax may make the 

community more vulnerable to other invasive species. Yellow toadflax produces a toxic substance and is 

unpalatable to livestock and wildlife.

Description: Yellow toadflax is a perennial forb, 1 to 2 feet, with pale green, alternate, linear leaves. 

The base of the branched stem is woody. Stems and leaves are pale green. Flowers are spurred and 

yellow with an orange center. 

Current Distribution on the Refuge: No known infestations exist on Refuge lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas.
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Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of yellow toadflax plants - targeting for elimination - to reduce competition with native 

plants.

d. Maintain healthy stands of native perennial plants.

Control Options: Hand pulling individual plants before seed set decreases seed production. Scything or 

mowing of stands before seed set is also effective. These methods do not kill the plant.

The chemical treatment of yellow toadflax with an appropriate herbicide provides relatively effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM

Treatment Schedule: The removal of above ground portions of the plant before seed set will be done in 

April through July. The seeds are long-lived; annual removal of plants for up to ten years is necessary to 

deplete the seed bank.

) and imazapic (PlateauTM) are the herbicides 

used to control yellow toadflax on the Refuge. Glyphosate is soil binding, inexpensive, and a low threat 

to groundwater quality. Glyphosate is appropriate for spot treatments, but its broad specificity precludes 

broadcast applications. Imazapic (PlateauTM) is used in dry upland sites and on soils with low leaching 

potential. This chemical can be broadcast in restoration areas where the establishment of native grasses 

and herbicide resistant native broadleafs are essential for restoration success. Other chemicals will be 

added as needed and be approved at the required level. All chemicals will be used in accordance with 

label recommendations.

Applications of glyphosate and imazapic will be made one to two times per growing season (April -

November). Fall applications are particularly effective in decreasing the available stored carbohydrates 

in the roots. 

13 Onopordum ancanthium (Scotch thistle)

Priority: Low to Medium: Scotch thistle aggressively invades disturbed and moist areas. This thistle, 

due to its size and spinous leaves, presents a passage barrier. Infestation decreases the value and area of 

wildlife habitat. Scotch thistle seeds have a water-soluable germination inhibitor that facilitates its own 

propagation and expansion along irrigation canals and other wet areas. Scotch thistle reproduces by seed. 

Description: Scotch thistle is biennial forb that grows to 12 feet high. Leaves are large, green, and 

spiny. Fine hairs give the leaves a cottony appearance. First-year rosettes are 10 to 12 inches in 

diameter. Leaves of the mature plant may be two feet in length with a prominent white mid-rib. Flower 

heads are numerous and terminal. Flowers are 1 to 2 inches in diameter, pale purple to red in color. 

Current Distribution on the Refuge: No known infestations exist on Refuge lands.
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Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, other disturbed soil areas, and riparian and other moist areas.

Objectives:

a. Monitor known infestation sites, riparian and moist areas, newly seeded areas, roadways, and other 

disturbed sites (e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control Scotch thistle to reduce competition with native plants by keeping infestations to less than 1 

acre and less than 40% of live vegetation cover.

d. Maintain healthy stands of native perennial plants.

Control Options: Mechanical treatment will include hand pulling or cutting of individual plants and 

small stands. The taproot will be cut 1-2 inches below the ground surface. Scything and mowing will be 

options for larger stands. The removal of the top material before flower production decreases the number 

of seeds available for spreading and propagation. Preventing flowering by mechanical means in 

conjunction with herbicide application for root killing is most effective in eliminating and controlling 

Scotch thistle. 

The chemical treatment of Scotch thistle with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM

Treatment Schedule: Mechanical treatment will target plants before flowering (April to mid-June). 

), imazapic 

(PlateauTM), and metsulfron methyl (Escort®) are the herbicides used to control Scotch thistle on the 

Refuge. Aminopyralid is very selective, provides longer control and can be used at lower rates. 

Glyphosate is soil binding, inexpensive, and a low threat to groundwater quality. Glyphosate is 

appropriate for spot treatments, but its broad specificity precludes broadcast applications. Imazapic 

(PlateauTM) is used in dry upland sites and on soils with low leaching potential. This chemical can be 

broadcast in restoration areas where the establishment of native grasses and herbicide resistant native 

broadleafs are essential for restoration success. Metsulfuron methyl is very effective for thistle and 

mullein control and is the preferred treatment in restoration areas with a high infestation level. Other 

chemicals will be added as needed and be approved at the required level. All chemicals will be used in 

accordance with label recommendations.

Herbicides will be applied before bolting in the spring (April to June), possibly in conjunction with 

mechanical control, or to rosettes in fall (September -November). 

14. Spartina anglica (cordgrass, Common)

Priority: High: The State of Washington considers this species one of the top ten priority weeds targeted 

for control, particularly for preventing new infestations. Cordgrass is an aggressive species that 

regenerates from large rootstocks. Excessive proliferation of cordgrass can lower the groundwater level, 

reduce the amount of surface water, reduce habitat for wildlife dependent on open water, reduce bird use 

by as much as 50%, reduce and interfere with water flow through drainages. 
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Description: Cordgrass is a perennial grass with stems reaching 7 feet. The stems have a waxy coating. 

Leaves are flat, 1/4 to 3/4 inch wide. The leaves lack auricles and have ligules that consist of a fringe of 

hairs. The leaf blades, which may be flat or inrolled, are 5 to 12 mm broad and may be persistent or 

falling. The flowers occur in numerous, erect, contracted panicles, which consist of closely overlapping 

spikelets in two rows on one side of the rachis. Reproduction is by seed, rhizomes, tillering, and rhizome 

fragments. The panicle is 3 to 8 inches long, initially compact but opening upon maturity. 

Current Distribution on the Refuge: Common cordgrass’ only known infestation is on graveyard spit 

on Dungeness NWR.

Measurable Objectives and Goal: Prevent competition with newly seeded native plants and established 

native communities in disturbed moist soil, riparian, and wetland environments.

Objectives:

a. Monitor known infestation sites - riparian, wetland, and moist areas for significant adverse effects on 

water flow and wildlife habitat.

b. Seed disturbed sites with native species. 

c. Control common cordgrass to reduce competition with native plants and significantly altering the 

environment. Treatment applied to keep infestation to less than 40% of live vegetation cover and 

prevent infestations from increasing in area. 

d. Maintain healthy stands of native perennial plants.

Control Options: Mowing infestations can contain growth, limit seed set, and eventually kill the plants. 

To be effective, clones must be mowed repeatedly, beginning with initial spring green-up and continued 

until fall die-back. For clones under 10 feet in diameter, one to three mowings during the growing season 

may be effective. Larger clones need to be mowed nine to ten times over two seasons for eradication. In 

some cases, mowing will be required for a third or fourth year (Spartina Task Force 1994). 

Chemical control with glyphosate (Rodeo®) would be used on the Refuge for effective control of 

common cordgrass. Glyphosate is soil binding, inexpensive, a low threat to groundwater quality, and 

used to target numerous weed species. This chemical formulation is approved for aquatic application. 

All chemicals will be used in accordance with label recommendations.

Treatment Schedule: Data from herbicide trials in Willapa Bay suggest chemical control is best 

performed when the plants carbohydrate stores are lowest. Treatment will be conducted 1 to 2 times per 

season - once in the summer (June - August) and/or once in the spring (May) (Norman and Patten 1995). 

15 Rubus armeniacus (Himalayan blackberry) and Rubus laciniatus (Evergreen blackberry)

Priority: High: Although widespread in Washington and control in not required, these species are highly 

invasive and difficult to control. Therefore it is important to protect wilderness areas as well as areas 

being restored to native vegetation. 
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Appendix E – Integrated Pest Management Program E-66

Description: A robust, thicket forming shrub with stout arching canes with large stiff thorns. They can 

grow up to 15 feet tall; canes to 40 feet long. They bloom in the spring and the flowers are small, white 

to pinkish with five petals and Himalayan blackberry leaves are palmately compound with large, rounded 

to oblong, toothed leaflets usually in groups of 5 on main stems, while Evergreen blackberry (also known 

as cut-leaf blackberry) has deeply incised leaflets. They can be distinguished from the native trailing 

blackberry (Rubus ursinus) by its tall, arching reddish-brown canes, much more robust plants, rounder 

leaflets (or deeply incised leaflets for evergreen blackberry), and larger fruits and flowers

Current Distribution on the Refuge: No known infestations exist on any refuge lands. 

Measurable Objectives and Goal: Prevent further spread into newly seeded native restoration sites, 

along other ditches or other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of blackberry plants - targeting for elimination - to reduce competition with native plants.

d. Maintain healthy stands of native perennial plants.

Control Options: Mechanical control includes hand pulling of small infestations, mowing or herbicide 

larger patches. 

The chemical treatment of blackberries with an appropriate herbicide provides relatively effective control. 

Currently, glyphosate (RoundupTM, Roundup ProTM

Cultural control of blackberries is an important control method. The key to controlling spread is by 

decreasing seed production in established patches, and/or preventing the cane tips or nodes from touching 

the ground to produce “daughter’ plants. Methods that assist in these control strategies are minimizing 

soil disturbance, maintaining healthy native vegetation, control seed formation with a combination of 

mechanical and chemical techniques.

), would be used on the Refuge. Glyphosate is soil 

binding, inexpensive, and a low threat to groundwater quality. Glyphosate is appropriate for spot 

treatments. Metsulfuron methyl is very effective for thistle, mullein control and blackberry is the 

preferred treatment in restoration areas with a high infestation level. This chemical can be broadcast in 

restoration areas where the establishment of native grasses and herbicide resistant native broadleafs are 

essential for restoration success. Other chemicals will be added as needed and be approved at the 

required level. All chemicals will be used in accordance with label recommendations.

Treatment Schedule: The pulling can be done anytime. Mowing or cutting midsummer allow plant to 

grow back 18 inches then treat with herbicide is the preferred method.

Chemical application will occur during the Fall (Sept Oct.).

16. Hedera helix (English Ivy)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-67

Priority: Low: Although widespread in western Washington and control in not required, this specie is 

highly invasive but fortunately not too difficult to control. Therefore it is important to protect wilderness 

areas as well as areas being restored to native vegetation. 

Description: Evergreen vine that can trail along the ground or grow veritcally up trees, fences, walls and 

hillsides. Most common type of growth lacks flowers and has dull green, lobed leaves with light veins 

that grow alternately along trailing or climbing stems. Leaf shape and size varies between varieties from 

deeply to shallowly lobed and from small, narrow leaves to large, broadly shaped leaves. Mature form of 

growth has shiny, unlobed leaves that grow in dense, whorl-like clusters and produce umbrella-like 

groups of small yellow-green flowers in the fall, followed by dark purple-black berries in the late winter 

or early spring.

Current Distribution on the Refuge: Only known infestations exist on Matia Island. 

Measurable Objectives and Goal: Prevent further spread into newly seeded native restoration sites, 

along other ditches or other disturbed soil areas.

Objectives:

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites (e.g., 

remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of ivy plants - targeting for elimination - to reduce competition with native plants.

d. Maintain healthy stands of native perennial plants.

Control Options: Mechanical control includes hand pulling and cutting of vines or herbicide larger 

patches. 

The chemical treatment of ivy with an appropriate herbicide provides relatively effective control. 

Currently, glyphosate (RoundupTM, Roundup ProTM

Cultural control of ivy is an important control method. The key to controlling spread is by decreasing 

seed production in established patches, and/or preventing the vegetative spreading of the plants. 

Methods that assist in these control strategies are minimizing soil disturbance, maintaining healthy native 

vegetation, control seed formation with a combination of mechanical and chemical techniques.

), would be used on the Refuge. Glyphosate is soil 

binding, inexpensive, and a low threat to groundwater quality. Glyphosate is appropriate for spot 

treatments. Other chemicals will be added as needed and be approved at the required level. All 

chemicals will be used in accordance with label recommendations.

Treatment Schedule: The pulling can be done anytime. Mowing or cutting midsummer allow plant to 

grow back 18 inches then treat with herbicide is the preferred method. Cutting vines and treating stems

with herbicide or foliar in spring are good alternatives. 

Chemical application will occur during the Spring or Fall.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-68

Other Future species

Oxeye Daisy (Leucanthemum vulgare), and Spurge Laurel (Daphne laureola)

These are species currently not known to occur on the Refuge but are known to occur in surrounding 

areas. These include Purple Loosestrife (Lythrum salicaria), Russian knapweed (Centaurea repens), 

Garlic Mustard (Alliaria petiolata), Japanese Knotweed (Polygonum cuspidatum), and Lawnweed (Soliva 

sessilis). Others may be added as additional information becomes available and new invaders are 

documented. 

Table 1. Summary of invasive plant species and possible control methods to be used, Washington 

Maritime National Wildlife Complex Refuge.

Species Priority Mechanical Biological Chemical Cultural

Blackberrie

s

LowMediumX X

Bull thistle LowMediumX X

Canada 

thistle

Low to 

Medium

X Stem-and-shoot gallfly 

(Urophora cardui)

X

Cheatgrass Medium X X X

Dalmatian 

and yellow 

toadflax

High X X

Diffuse, 

spotted, 

Russian, 

and 

meadow 

knapweed

High X Broad-nosed seedhead 

weevil (Bangasternus 

fausti)

Sulphur knapweed 

moth (Agapeta 

zoegana)

Knapweed weevil 

(Cyphocleonus achates)

Knapweed flowerhead 

weevil

(Larinus minutus)

X

Field 

bindweed

Low to 

Medium

Field bindweed moth 

(Tyta luctuosa)

Field bindweed mite 

(Aceria malherbae)

X

Scotch 

Broom

High X X
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-69

Leafy 

spurge

High Brown-legged spurge 

flea beetle (Apthona 

lacertosa)

Amber spurge flea 

beetle (A. flava)

X

Musk 

thistle

Medium X Seed head weevil 

(Rhinocyllus conicus)

Musk thistle weevil 

(Trichosirocalus 

horridus)

X

Common 

cordgrass

Medium 

to High

X X

Russian 

knapweed

High X X

Scotch 

thistle

Medium 

to High

X X

St. 

Johnswort

Medium 

to High

Klamath weed beetle 

(Chrysolina

quadrigemia)

E.9 Non-native Mammal Control

The animals referred to under this category are the non-native predators (rats, red fox, dogs, and cats) and 

the herbivore (European rabbit). All of these can be controlled using one or methods. Currently, only 

rabbits are known to exist on a limited number of islands and in low numbers, but expanding. For initial 

population control traps would be the preferred method followed by poison bait. Either method would be 

used to eradicate the population in the quickest, most humane, and least impact to other potential nontarget animals.

E.10 References

AgDrift. 2001. A user’s guide for AgDrift 2.04: a tiered approach for the assessment of spray

drift of pesticides. Spray Drift Task Force, PO Box 509, Macon, Missouri.

ATSDR (Agency for Toxic Substances and Disease Registry) U.S. Department of Health and

Human Services. 2004. Guidance Manual for the Assessment of Joint Toxic Action of

Chemical Mixtures. US Department of Health and Human Services, Public Health Service,

ATSDR, Division of Toxicology. 62 plus Appendices.

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use

patterns in the Sacramento Valley, CA. Proceedings of the International Conference on

PesticideApplication for Drift Management. Waikoloa, Hawaii. 15 pages.

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension

Publication PM 1495, Iowa State University Extension, Ames, Iowa. 6 pages.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-70

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and

Transformation Products in Surface Waters of the Midwestern United States. Journal of the

American Water Resources Association (JAWRA) 39(4):743-756.

Brooks, M.L., D'Antonio, C.M., Richardson, D.M., Grace, J.B., Keeley, J.E. and others. 2004.

Effects of invasive alien plants on fire regimes. BioScience 54:77-88.

Bureau of Land Management. 2007. Vegetation treatments using herbicides on Bureau of Land

Management Lands in 17 western states Programmatic EIS (PEIS). Washington Office, Bureau

of Land Management.

Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement

to ground water. Extension Publication PI-2, University of Florida, Cooperative Extension

Service, Gainesville, FL. 4 pages.

Calabrese, E.J. and L.A. Baldwin. 1993. Performing Ecological Risk Assessments. Lewis

Publishers, Chelsea, MI.

Center, T.D., Frank, J.H., and Dray Jr., F.A. 1997. Biological Control. Strangers in Paradise:

Impact and Management of Nonindigenous Species in Florida. P.245-263.

Cox, R.D., and V.J. Anderson. 2004. Increasing native diversity of cheatgrass-dominated

rangeland through assisted succession. Journal of Range Management 57:203-210.

Dunning, J.B. 1984. Body weights of 686 species of North American birds. Western Bird

Banding Association. Monograph No. 1.

EXTOXNET. 1993a. Movement of pesticides in the environment. Pesticide Information

Project of Cooperative Extension Offices of Cornell University, Oregon State University,

University of Idaho, University of California – Davis, and the Institute for Environmental

Toxicology, Michigan State University. 4 pages.

Hasan, S. and P.G. Ayres. 1990. The control of weeds through fungi: principles and

prospects. Tansley Review 23:201-222.

Huddleston, J.H. 1996. How soil properties affect groundwater vulnerability to pesticide

contamination. EM 8559. Oregon State University Extension Service. 4 pages.

Kerle, E.A., J.J. Jenkins, P.A. Vogue. 1996. Understanding pesticide persistence and mobility

for groundwater and surface water protection. EM 8561. Oregon State University Extension

Service. 8 pages.

Masters, R.A, and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for

managing rangeland invasive plants. Journal of Range Manage 54:502-517.

Masters, R.A., S.J. Nissen, R.E. Gaussoin, D.D. Beran, and R.N. Stougaard. 1996.

Imidazolinone herbicides improve restoration of Great Plains grasslands. Weed Technology

10:392-403.

Mineau, P., B.T. Collins, and A. Baril. 1996. On the use of scaling factors to improve
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-71

interspecies extrapolation to acute toxicity in birds. Regulatory Toxicology and Pharmacology

24:24-29.

Moody, M.E., and R.N. Mack. 1988. Controlling the spread of plant invasions: the importance

of nascent foci. Journal of Applied Ecology 25:1009-1021.

Morse, L.E., J.M. Randall, N. Benton, R. Hiebert, and S. Lu. 2004. An Invasive Species

Assessment Protocol: NatureServe.

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. Invasive

Plant Species. Issue Paper (13):1-18.

Norman, M. and K. Patten. 1995. Evaluation of mechanical methods and herbicide/adjuvant treatments 

for the effective control of Spartina spp. Unpublished report on file at Washington State 

University Long Beach Research and Extension Unit, Long Beach, Washington.

Oregon State University. 1996. EXTOXNET-Extension Toxicology Network, Pesticide

Information Profiles. Oregon State University, Corvallis, Oregon.

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, C. Wickliff. 1996. Field evaluation of the EPA

(Kanaga) nomogram, a method for estimating wildlife exposure to pesticide residues on plants. 

Environmental Toxicology and Chemistry 15:535-543.

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know.

Extension Publication PAT 36, Iowa State University Extension, Ames, Iowa and Iowa

Department of Agriculture and Land Stewardship, Des Moines, Iowa. 6 pages.

Ramsay, C.A., G.C. Craig, and C.B. McConnell. 1995. Clean water for Washington –

protecting groundwater from pesticide contamination. Extension Publication EB1644,

Washington State University Extension, Pullman, Washington. 12 pages.

SDTF 2003 Spray Drift Task Force. 2003. A summary of chemigation application studies.

Spray Drift Task Force, Macon, Missouri.

Spartina Task Force. 1994. Spartina Management Program: Integrated Weed Management for Private 

Lands in Willapa Bay, Pacific County, Washington. Unpublished report prepared for the 

Noxious Weed Board and County Commissioners, Pacific County, Washington.

Teske, M.E., S.L. Bird, D.M. Esterly, S.L. Ray, S.G. and Perry. 1997. A User's Guide for

AgDRIFTTM 1.0: A Tiered Approach for the Assessment of Spray Drift of Pesticides, Technical

Note No. 95-10, CDI, Princeton, New Jersey.

Teske, M.E., S.L. Bird, D.M. Esterly, T.B. Curbishley, S.L. Ray, and S.G. Perry. 2002.

AgDRIFT®: a model for estimating near-field spray drift from aerial applications.

Environmental Toxicology and Chemistry 21: 659-671.

Urban, D.J and N.J. Cook. 1986. Hazard evaluation division standard, standard evaluation

procedure, ecological risk assessment. Office of Pesticide Programs, US Environmental

Protection Agency, Washington DC. 101 pages.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix E – Integrated Pest Management Program E-72

EPA (U.S. Environmental Protection Agency). 1998. A Comparative Analysis of Ecological

Risks from Pesticides and Their Uses: Background, Methodology & Case Study.

Environmental Fate & Effects Division, Office of Pesticide Programs, U.S. Environmental

Protection Agency, Washington, D.C. 105 pages.

EPA. 2004. Overview of the ecological risk assessment process in the Office of Pesticide

Programs, US Environmental Protection Agency: endangered and threatened species effects

determinations, Office of Pesticide Programs, Washington, DC. 101 pages.

EPA. 2005a. Technical overview of ecological risk assessment risk characterization;

Approaches for evaluating exposure; Granular, bait, and treated seed applications. US

Environmental Protection Agency, Office of Pesticide Programs, Washington, DC.

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm.

EPA. 2005b. User’s Guide TREX v1.2.3. U.S. Environmental Protection Agency, Office of

Pesticide Programs, Washington, DC. 22 pages.

http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm.

U.S. Geological Survey. 2000. Pesticides in stream sediment and aquatic biota – current

understanding of distribution and major influences. USGS Fact Sheet 092-00, US Geological

Survey, Sacramento, California. 4 pages.

U.S. Forest Service. 2005. Pacific Northwest Region Invasive Plant Program

Preventing and Managing Invasive Plants Final Environmental Impact Statement. 359 pages.

Wauchope, R.D., T.M. Buttler, A.G. Hornsby, P.M. Augustijn-Beckers, and J.P. Burt. 1992.

The SCS/ARS/CES pesticide properties database for environmental decision making. Reviews of 

Environmental Contamination and Toxicology 123:1-155.

Washington State Noxious weed Board, accessed 02/18/10, 

http://www.nwcb.wa.gov/weed_info/Spartina_anglica.html

http://www.nwcb.wa.gov/weed_info/Linaria_dalmatica.html

http://www.nwcb.wa.gov/weed_info/Leucanthemum_vulgare.html

http://www.nwcb.wa.gov/weed_info/Soliva_sessilis.html

Woods, N. 2004. Australian developments in spray drift management. Proceedings of the

International Conference on Pesticide Application for Drift Management, Waikoloa, Hawaii. 8

pages.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix F – Area Beaches F-1

Appendix F. Area Beaches

F. Introduction

This appendix is a table which lists facilities and approved activities for beach areas in the vicinity of the 

refuges. Because beach access within the San Juan Islands NWR is extremely limited and trespassing 

creates wildlife disturbance issues, these beaches offer alternatives for those seeking additional facilities 

and other wildlife and non-wildlife dependant recreation opportunities.

Beaches in the Vicinity of San Juan Islands NWR & Protection Island NWR

Beach Name

Shore

Length

(approx.

linear 

feet)

ToiletsMooring BuoysDockBoat RampPicnic TablesPicnickingBeachcombing / Tide PoolingWalking / HikingMountain Biking / BicyclingSwimming / WadingScuba DivingShellfish HarvestingFishingPaddlingBirdingWildlife Viewing

Agate Beach County Park 

San Juan County Parks, Lopez Island

Other

580 ▪ ▪ ▪ ▪ ▪ ▪

American Camp - 4th

2,640 of July Beach 

National Park Service, San Juan Island ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

American Camp - South Beach 

National Park Service, San Juan Island 10,560 ▪ ▪ ▪ ▪ ▪ ▪ ▪

Beach 407 

WA DNR, Quimper Peninsula 5,016 ▪

Beach 409 

WA DNR, Quimper Peninsula 1,584 ▪

Beach 410 

WA DNR, Miller Peninsula 2,640 ▪

Beach 411 

WA DNR, Miller Peninsula 25,660 ▪

Blackie Brady Memorial Day Park 

San Juan County Parks, Lopez Island 6 ▪ ▪ ▪

Cattle Point Picnic Area 

WA DNR, San Juan Island 2,795 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Clark Island Marine State Park 

WA State Parks, Clark Island 10,560 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Crescent Beach 

San Juan County Land Bank, Orcas Is. 1,161 ▪

Deception Pass State Park 

WA State Parks, Whidbey Is. Fidalgo Is. 77,000 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Eagle Cove Public Access 

San Juan County Parks, San Juan Is. 15,840 ▪ ▪ ▪ ▪ ▪

East Olga County Park 

San Juan County Parks, Orcas Island 633 ▪ ▪

Eastsound Waterfront Park San 

Juan County Land Bank, Orcas Is. 475 ▪ ▪ ▪

English Camp - Garrison Bay 

National Park Service, San Juan Island 7,920 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Fisherman Bay Preserve 

San Juan County Land Bank, Lopez Is. 9,820 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix F – Area Beaches F-2

Beach Name

Shore

Length

(approx.

linear 

feet)

ToiletsMooring BuoysDockBoat RampPicnic TablesPicnickingBeachcombing / Tide PoolingWalking / HikingMountain Biking / BicyclingSwimming / WadingScuba DivingShellfish HarvestingFishingPaddlingBirdingWildlife Viewing

Fort Casey State Park 

WA State Parks, Whidbey Island

Other

10,560 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Fort Ebey State Park 

WA State Parks, Whidbey Island 26,400 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Jackson Beach 

Port of Friday Harbor, San Juan Island 4,300 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Jones Island Marine State Park 

WA State Parks, Jones Island 25,000 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Joseph Whidbey State Park 

WA State Parks, Whidbey Island 3,115 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Lime Kiln Point State Park 

WA State Parks, San Juan Island 2,534 ▪ ▪ ▪ ▪ ▪ ▪ ▪

Mud Bay County Park 

San Juan County Parks, Lopez Island 200 ▪ ▪ ▪

Obstruction Pass Marine Park 

WA State Parks, Orcas Island 450 ▪ ▪ ▪ ▪ ▪ ▪ ▪

Odlin County Park 

San Juan County Parks, Lopez Island 3,960 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Olga Marine State Park 

WA State Parks, Orcas Island 60 ▪

Otis Perkins County Park 

San Juan County Parks, Lopez Island 21 ▪ ▪ ▪ ▪ ▪

Patos Island Marine State Park 

WA State Parks, Patos Island 23,760 ▪ ▪ ▪ ▪ ▪ ▪ ▪

Rueben Tart Park 

San Juan County Parks, San Juan Is. 870 ▪ ▪ ▪ ▪

San Juan County Park 

San Juan County Parks, San Juan Is. 2,470 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Shaw Island Cnty Park - South Beach 

San Juan County Parks, Shaw Island 4,593 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Spencer Spit State Park 

WA State Parks, Lopez Island 7,840 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Sucia Island Marine State Park 

WA State Parks, Sucia Island 77,700 ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Third Lagoon 

San Juan County Land Bank, SJ Is. ND ▪ ▪

Upright Channel Recreation Area 

WA DNR, Lopez Island 11,600 ▪ ▪ ▪ ▪ ▪ ▪ ▪

ND = No Data

Sources: Lucas 2004, Mueller and Mueller 1995, National Park Service 2007, San Juan County Land Bank 2007, San Juan County Parks 2005, 

Washington Department of Natural Resources 2007, Washington State Department of Ecology 2007, Washington State Parks and Recreation 

Commission 2007b
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-1

Appendix G. Implementation

I. Overview

Implementation of the preferred alternative of the CCP will require increased funding, which will 

be sought from a variety of sources. This plan will depend upon additional Congressional 

allocations, partnerships and grants. There are no guarantees that additional federal funds will be 

made available to implement any of these projects. Other sources of funds will need to be 

obtained, both public and private. Activities and projects identified will be implemented as funds 

become available.

The CCP proposes several projects to be implemented over the next fifteen years. Most of these 

projects are included in the Refuge Operational Needs System (RONS - new staff), or Service 

Asset Maintenance and Management System (SAMMS - deferred maintenance projects) which 

are used to request funding from Congress. Currently, a large backlog of maintenance needs 

exists for Protection Island and San Juan Islands Refuges. In 2009, the deferred maintenance 

backlog for Protection Island was $1,156,000, with more projects needing to be added. An 

attempt at reducing this backlog needs to be addressed and is included here in the analysis of 

funding needs. Prioritized staffing needs identified in the RONS will be necessary to implement 

the CCP to meet Refuge goals and objectives and legal mandates.

Annual revenue sharing payments, associated with Protection Island NWR in Clallum and 

Jefferson Counties, will continue. Total payments made in 2008 were $228 for three acres in 

Clallum County and $49,425 for 317 acres in Jefferson County. Land associated with the San 

Juan Islands NWR is public domain. Payment In Lieu of Taxes for these acres are made by the 

Bureau of Land Management to Island, San Juan, Skagit, and Whatcom Counties.

Monitoring activities will be conducted on a percentage of all new and existing projects and 

activities to document wildlife populations and changes across time, habitat conditions and 

responses to management practices. For more details see the monitoring section at the end of this 

appendix. 

II. Costs to Implement the CCP

The following sections detail both one-time and recurring costs for various projects, by 

alternative. One-time costs reflect the initial costs associated with a project, whether it is

purchase of equipment, contracting services, construction, a research project, etc. Recurring costs 

reflect the future operational and maintenance costs associated with the project. The following 

tables primarily document projects with a physically visible, trackable “on-the-ground”

component, such as structures, habitat restoration, research, and monitoring and surveys. The 

scope and costs for “administrative” activities such as MOUs, reporting, and establishment of 

partnerships are difficult to estimate in advance and thus are not accounted for in the tables 

below. 

A. One-time costs

One-time costs are project costs that have a start-up cost associated with them, such as 

purchasing a new vehicle for wildlife and habitat monitoring, or designing and installing an 

interpretive sign. Some are full project costs for those projects that can be completed in three 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-2

years or less. One-time costs can include the cost of temporary or term salary associated with 

a short-term project. Salary for existing and new positions, and operational costs, are 

reflected in operational (or recurring) costs.

Funds for one-time costs will be sought through increases in Refuge base funding, special 

project funds, and grants. Projects listed below in Table G-1 show one-time costs, such as 

those associated with building and facility needs including offices, public use facilities, road 

improvements, and new signs. One-time costs are also associated with projects such as 

habitat restoration, invasive plant and animal control, and research. New research projects, 

because of their short-term nature, are considered one-time projects and include costs of 

contracting services or hiring a temporary for the short-term project. Some project costs are 

taken from 2009 RONS or SAMMS proposals; others are not yet in any project database and 

their costs have been estimated, particularly if the scope of the project is unknown at this time 

due to lack of baseline data. 

Table G-1. One Time Costs (in thousands) for Research and Assessments; Inventories, 

Surveys, and Monitoring; Habitat Management and Restoration, Facilities and Public UseRelated Actions

Project Description Priority Unit Alt A Alt B Alt C Potential Fund 

Source

Research 

Pre and post deer 

removal study of auklet 

habitat an vegetation on 

PI

H Proj. 0 40 40 1261

Pre and post habitat 

restoration glaucouswinged gull breeding 

success study

H Study 30 30 1261, Grants

Research grassland 

restoration 

methodologies in Puget 

Trough ecosystem

H Proj. 0 35 35 1261

Conduct island-wide 

rhinoceros auklet 

breeding success 

studypre and post 

habitat restoration

H Proj. 0 75 75 1261

Hydrological studies on 

Protection (wetland 

restoration phase 1), 

Smith and Matia Islands

M Study 0 25 25 1261

RONS FY10-

1740, 2061

Seabird demographic 

studies

M Study 175 175 1261, Grants

Marine mammal 

demographic studies

M Study 0 100 100 1261, Grants

Geomorphologic L Study 0 10 10 1261, Grants
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-3

study of Smith/Minor 

and Protection Islands

Subtotal (thousands) 0 490 490

Surveys and 

assessments

Establish plant 

herbariums and digital 

photographic library for 

habitats

M Proj. 0 20 10 1261

RONS FY08-

4913, 6020

Research, design, and 

implement GIS-based 

inventory and 

monitoring programs 

for plants and wildlife 

on PI and SJI

H Proj. 0 45 45 1261

RONS FY08-

4913,6020

Conduct biodiversity 

assessments (base line 

inventories)

H # 

inventories

 0 148 120 1261

RONS FY08-

4839, 4913, 6020

Conduct forest health 

assessment

L Proj. 0 25 25 1260

RONS FY08-

6137

Survey occupied, 

formally occupied and 

Aids To Navigation 

sites for presence of 

contaminants

L Proj. 0 80 80 1261

Subtotal (thousands) 0 318 280

Habitat management 

and restoration

Restore PI grasslands to 

native grasses

H acres 0 70 30 1261 RONS 

FY08-5973

Restore PI strand to 

native species

H acres 0 15 5 1261 RONS 

FY08-5973

Subtotal (thousands) 0 85 35

Regulatory and 

enforcement

support new positions 

stationed in the San 

Start up costs needed to 

Juans (boat, vehicle, 

office equipment, office 

rent)

 H 0 250 250 1261,1263

Subtotal (thousands) 0 250 250
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-4

Facilities

Design, fabricate and 

install new “island” 

boundary and area 

closed signs

 H 0 30 30 1262, 1263

Develop site plan for 

infrastructure-PI

 H Proj. 0 20 20 1261

Remove & replace 

caretaker cabin-PI

 H Proj. 0 350 350 1262 SAMMS 

2007705142

Replace caretaker cabin 

septic system-PI

 H Proj. 0 20 20 1262 SAMMS 

2009943883

Remove & replace 

research bunkhouse-PI

 H Proj. 0 550 550 1262 SAMMS 

2008867129

Replace research 

bunkhouse septic 

system-PI

 H Proj. 0 20 20 1262 SAMMS 

2009943880

Remove & replace 

office -PI

 M Proj. 0 200 200 1262 SAMMS

88101548

Replace office septic 

system-PI

 M Proj. 0 20 20 1262 SAMMS 

2009943886

Remove toxic PI marina 

pilings

 H Proj. 87 87 87 1262, refuge 

contaminate 

funds

Construct and replace 

nontoxic PI marina 

pilings

 H 5 at 

$2000 

each

 86 86 86 1262 SAMMS 

2009917570

Establish photovoltaic 

system for PI

 H Proj. 16 150 150 1262 SAMMS 

2009924800

Replace water 

distribution system PI

 M Proj. 0 384 384 1262 SAMMS 

2009943301

Replace boat launch 

ramp at PI

 L Proj. 0 65 65 1262 SAMMS 

2008867122

Remove fire cache and 

two abandoned 

residences on PI

 H Proj. 0 150 150 1262

Remove human 

generated debris form 

Smith and Minor islands

 M Proj. 0 100 100 1262, partner 

w/USCG

Subtotal (thousands) 189 2,232 2,232

Public use

Design construct and 

install interpretive 

panels for PI and SJI

 H 0 120 90 1263 SAMMS 

97122612, 

2009917578

Develop SJI NWR 

brochure, rack cards, 

posters and video

 H 0 80 80 1263 RONS 

FY10-2056
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-5

Develop cultural 

outreach an educational 

material

 M 0 10 10 1263

 

Subtotal (thousands) 0 210 180

Total of all one time 

project costs

 189 3,585 3,467

B. Annual Operational (recurring) costs

Operational costs reflect Refuge spending of base funds allocated each year. These are also 

known as recurring costs and are usually associated with day-to-day operations and projects 

that last longer than three years. Operational costs use base funding in Service fund code 

1260.

Table G-2 displays projected annual operating costs under the CCP. The CCP will require 

increased funding for new or expanded public uses and facilities, habitat restoration and 

conservation activities, and new monitoring needs. This table includes such things as salary 

and operational expenditures such as travel, training, supplies, utilities and maintenance costs. 

Project costs listed in Table G-2 include permanent and seasonal staff needed year after year 

to accomplish each project; these staffing costs are not isolated in this table but are included 

as part of the entire project cost.

Table G-2. Annual operational (recurring) costs

Activity Description CCP

Goals

Alt A

Cost 

est

(K)

Alt B

Cost 

est

(K)

Alt C

Cost 

est

(K)

Potential

fund 

source

Surveys and assessments: Aerial 

phographic surveys; boat-based and land 

survey and assessments; joint wildlife 

surveys with WDFW; implement GIS-based 

inventory and monitoring programs for plants 

and wildlife; mammalian predator and 

invasive species monitoring; monitor 

biodiversity trends; provide administrative 

and material support for all biological 

activities.

63.8 150 120

Research: Facilitate and cooperate in 

specific research projects to benefit 

refuge resources.

7.5 22.3 22.3

Habitat management and restoration: 

inventory, remove, control and prevent 

new establishment of invasive plants and 

treat infestations with IPM; periodic 

31.6 94.3 80.1
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-6

mowing and burning of grassland and spit

restoration areas.

Regulatory and enforcement actions: 

Patrol islands, enforce regulations and 

educate visitors to the sensitivity of 

wildlife resources; replace boundary and 

regulatory signage as needed; conduct 

outreach.

46.7 73.0 65.8

Public use opportunities and 

education: Provide funding for and 

manage a variety of both on-refuge and 

off-refuge interpretive and education 

programs; maintain Protection Island and 

San Juan Islands NWR interpretive 

panels located both on and off-refuge to 

offer interpretation through self-guided 

experience; conduct and manage 

volunteer environmental education 

stewardship projects; manage college 

level environmental studies program; 

initiate volunteer interpretation program 

including logistical and financial support.

43.3 180.3 168.6

Facilities maintenance: Maintain and 

make minor repairs on interpretive 

panels, regulatory signage; maintain 

Protection Island infrastructure and 

facilities; maintain boats, vehicles, 

tractor,equipment and tools for use as 

needed

61.0 87.9 68.6

Total Recurring Costs by Alternative 253.9 607.8 525.4

C. Maintenance costs

The maintenance need over the next 15 years is defined as funds needed to repair or replace 

buildings, equipment, and facilities. Maintenance includes preventative maintenance; cyclic 

maintenance; repairs; replacement of parts, components, or items of equipment; adjustments, 

lubrication, and cleaning (non-janitorial) of equipment; painting; resurfacing; rehabilitation; 

special safety inspections; and other actions to assure continuing service and to prevent 

breakdown. Maintenance costs include the maintenance “backlog”—maintenance needs that 

have come due but are as yet unfunded, as well as the increased maintenance need associated 

with new facilities.

The facilities associated with San Juan Islands and Protection Island NWRs that require 

maintenance include trails, interpretive panels, regulatory signs, roads, water delivery system, 

buildings, dock and marina. Major equipment includes boats, vehicles, tractors, ATVs, and 

generators. Approximately 60% of operational (non-project) maintenance funding for the 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-7

Washington Maritime NWR Complex is expended on the two refuges covered under this 

CCP (also see Table G-2) ; the other approximately 40% is used to maintain the majority of 

facilities, including buildings and equipment, which are located on the other three Complex 

Refuges and are not included in this Implementation Plan. One time costs for buildings and 

associated infrastructure replacement for Protection Island and replacement of island 

boundary and regulatory signs are identified in Table G-1

D. Staffing 

Current (2009) staffing and proposed staffing are shown in Table G-3. Current positions 

below serve all six refuges within the Washington Maritime NWR Complex; because there is 

no separate budget for the individual refuges, we have chosen to present the entire Complex 

staff in table G-3. Approximately 40% of current Complex staff time is expended on the two

refuges covered under this CCP; the other approximately 60% of staff time is expended on 

the other four refuges in the Complex. Two of the four new positions (Wildlife Refuge 

Manager and Park Ranger (.5 FTE)) will work full time on San Juan islands NWR. The 

Wildlife Biologist is anticipated to work 70% of the time on San Juan Islands and Protection 

Island NWRs and the Supervisory Park Ranger 50% of the time. 

Table G-3. Current and Proposed Staffing

Current Position GS & grade Annual Salary 

cost (K)

Annual Salary 

(K) x 40%

RONS project #

Project Leader GS- 0485-12 123.0 49.2 N/A

Deputy Project Leader GS-0485-11 86.8 34.7 N/A

Wildlife Biologist GS-0486-11 89.5 35.8 N/A

Park Ranger (LE) GS-0025-09 71.8 28.7 N/A

Maintenance Worker WG-4749-08 78.9 31.5 N/A

Office Automation 

Clerk

GS-0326-04 43.6 17.4 N/A

 Proposed Position Annual Salary

X (%)

Wildlife Refuge 

Manager

GS-0485-11 78.9 (100%) 78.9 FY08-4801

Supervisory Park 

Ranger (Visitor 

Services)

GS-0025-11 78.9 (50%) 39.5 FY08-5190

Wildlife Biologist GS-0486-9 65.2 (70%) 45.6 FY08-4839

Park Ranger (.5FTE) GS-0025-9 32.9 (100%) 32.9 FY08-4827

Total current annual and proposed staffing cost for 

Protection Island & San Juan Islands NWRs

394.2

* source for cost estimates:

1 = FY 2009 FTE Utilization Table for Washington Maritime NWR Complex

2 

 GS: General Schedule Federal Employee

= OPM General Schedule FY 2009 plus 40% benefits

 WG: Wage Grade Scale
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA 

Appendix G – Implementation G-8 

Table G-4 shows differing staff costs by alternative. The Alternative A column shows the 

current estimated 40% expenditure on these two refuges, in FY09 dollars. Alternative B and 

C columns reflect costs associated with increased staff and % time identified by alternative. 

Table G-4. Annual Costs, Annual Salary and Benefits, Associated w/Staff by Alternative

Staff-Refuge 

Operations 

FTE Staff 

Position 

Annual 

Salary (K) 

Alt A 

(K) 

Alt B 

(K) 

Alt C 

(K) 

Refuge 

Manager * 

1.0 GS-485-12 123.0 49.2 61.5 35.2 

Deputy Ref 

Manager * 

1.0 GS-485-11 86.8 34.7 52.0 40.5 

Wildlife 

Biologist * 

1.0 GS-486-11 89.5 35.8 22.0 22.0 

Park Ranger & 

Vol Coordr * 

1.0 GS-025-9 71.8 28.7 38.7 33.0 

Maintenance 

Worker * 

1.0 WG-4749-

8 

 78.9 31.5 42.0 36.0 

Office Auto 

Clerk * 

1.0 GS-326-4 43.6 17.4 17.4 17.4 

Refuge Manager 

(1) 

1.0 GS-485-

9/11 

 78.9 0 78.9 78.9 

Wildlife 

Biologist (2) 

1.0 GS-486-

7/9 

 65.2 0 45.6 45.6 

Sup Park Ranger 

- VSS(3) 

1.0 GS-025-11 78.9 0 39.5 39.5 

Park Ranger - 

(4) 

 .5 GS-025-

7/9 

 32.9 0 32.9 32.9 

Totals 9.5 749.5 197.3 430.5 381.0 

Costs are based on FY 2009 FTE utilization plans for Washington Maritime NWR Complex and 

OPM General Schedule FY 2009 plus 40% benefits. For new positions ( ) took step one grade 

plus 40%. 

Tables G-3 and G-4 show a 3.5 full-time-equivalent (FTE) increase in staffing over current levels. 

Proposed additions include Wildlife Refuge Manager, Wildlife Biologist, Supervisory Park 

Ranger (Visitor Services Specialist) and Park Ranger. 

The Refuge Manager position is proposed to be stationed in the San Juan Archipelago and will be 

responsible for all refuge programs on San Juan Islands NWR. This position will be a “dual 

function” position meaning the individual will have law enforcement capabilities to enhance 

visitor safety and resource protection. Stationing this position in the San Juans will result in 

continuous Service presence interacting with local government, Federal and State agencies 

present in the San Juans, local NGOs, user groups, citizens and visitors. 

The Wildlife Biologist will work with the Complex Wildlife Biologist in coordination and 

implementation of the overall biological program in the San Juan Islands NWR and assist as 

needed with the biological program on other refuges in the Complex. This position will facilitate 

increased coordination with other Federal and State agencies, Tribes, and will greatly improve the 

Complex’s ability to address the biological complexity of these two Refuges. This position is 

anticipated to devote 70% of its time to Protection Island and San Juan Islands NWRs 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-9

The Supervisory Park Ranger will serve as a visitor services specialist to guide the public use 

program of the Complex including environmental education, interpretation, outreach, and 

volunteer program. This position will facilitate informing the public about the refuges in the 

Complex, educating and interpreting the public on marine dependent wildlife species and the 

impacts of such issues as human disturbance, loss of habitat, marine debris, ocean 

acidification and global climate change. This position is anticipated to spend approximately 

50% of its time on San Juan Islands and Protection Island NWR projects

The Park Ranger will be a 1⁄2 full time equivalent and will provide seasonal assistance to the 

Refuge Manager during those times of the year that these two Refuges are most vulnerable to 

human disturbance. Interacting, educating and interpreting to residents, visitors and user groups is 

anticipated to reduce disturbance incidents and give the public an appreciation of the needs of 

wildlife species in the area and the importance of the National Wildlife Refuges in meeting those 

needs. 

E. Budget summary 

Table G-5 summarizes the data from tables G-1 and G-2and displays the overall funding need 

for the Washington Maritime NWR Complex to implement the CCP in full.

 Table G-5, Budget Summary – One-time projects and annual funding needs for 

 Protection Island and San Juan Islands NWR as identified in the CC

 

Budget Category

Alt A Alt B Alt C

One 

time 

cost 

(K)

Annual 

recurring 

cost 

(K)

One 

time 

cost 

(K)

Annual 

recurring 

cost

(K)

One

Time

Cost

(K) 

Annual 

recurring 

cost

(K)

Research - 7.5 490.0 22.3 490.0 22.3

Surveys and 

assessments

- 63.8 318.0 150.0 280.0 120.0

Habitat management 

and restoration

- 31.6 85.0 94.3 35.0 80.1

Regulatory and 

enforcement actions

- 46.7 250.0 73.0 250.0 65.8

Public use 

opportunities and 

education

- 43.3 210.0 180.3 180.0 168.6

Facilities and 

maintenance

- 61.0 2,232.0 87.9 2,232.0 68.6

Totals - 253.9 3,585.0 607.8 3,467.0 525.4
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-10

Partnership Opportunities

Partnerships are an important component of the implementation of this CCP and are reflected in 

the goals, objectives, and strategies identified in Chapter 2. The Refuges location (Olympic 

Peninsula and San Juan Archipelago) facilitates many opportunities for partnerships. Current and 

past partners include federal and state agencies, Tribes, non-governmental organizations, schools 

volunteers, and individuals. 

Coordinated partnerships efforts will focus on habitat restoration, land protection, environmental 

education, fish and wildlife monitoring, outreach, and quality wildlife-dependent recreation. 

Refuge Complex staff will work to strengthen existing partnerships and will actively look for new 

partnerships to assist in achieving the goals, objectives, and strategies in this CCP/WSP/EA.

U.S. Coast Guard

The Coast Guard maintains aids to navigation on 17 refuge islands within San Juan 

Islands NWR (See Appendix A). The Service has worked with USCG to schedule 

service of these aids during periods of low wildlife use (See Appendix F). In addition the 

Service will work with USCG on debris removal from Smith Island when they abandon 

their facilities there.

National Oceanic and Atmospheric Administration

National Oceanic and Atmospheric Administration – Fisheries conducts research and monitors 

marine mammals in the Salish Sea. These activities are managed under a Special Use Permit 

when conducted on Refuge lands and have involved Steller sea lions, and elephant and harbor 

seals.

Washington Department of Fish and Wildlife (WDFW)

WDFW’s management responsibilities including lands and waters, fish and wildlife, threatened 

and endangered species and other programs, frequently overlap with USFWS resources and 

responsibilities. WDFW and other state agencies are in a unique position to greatly assist the 

Complex in protecting sensitive seabirds and pinnipeds from human disturbance in close 

proximity to the Refuges. WDFW and the Complex share mutual interests in species 

management, wildlife surveys, developing joint research projects, and education and outreach 

programs. WDFW has been closely involved with the Complex in waterfowl surveys, pinniped 

surveys, black oystercatcher and pigeon guillemot surveys, forage fish spawning beach surveys 

and review of Complex projects in the marine environment (Protection Island marina entrance 

dredging and creosote bulkhead removal). 

WDFW and the Service have a unique relationship regarding the management of Protection 

Island. WDFW is the managing agency on the 48 acre Zella M. Schultz Seabird Sanctuary while 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-11

the Service manages the remainder of the island. A Memorandum of Understanding (MOU) 

between the Service and WDFW formalizes both parties commitment to the protection and 

enhancement of the wildlife resources of Protection Island and ensures that each agency’s 

management approach is compatible and complimentary. (See Appendix F)

Washington Department of Natural Resources (WDNR)

WDNR is the agency that manages State-owned aquatic lands. On November 22, 1988, WDNR 

issued a withdrawl order for “The bedlands of navigable water owned by the state of Washington, 

surrounding Protection Island extending waterward 600 feet from the line of extreme low 

water,...” (Withdrawl Order 88 017). Under this withdrawl order these bedlands “shall be 

reserved and withdrawn from conflicting uses...” In January 1994 the Service received a 20 year 

lease for all the tidelands of the second class surrounding Protection Island (Aquatic Lands Lease 

No. 20-013245). “Lessee shall have use of the Property only for the specified purposes of a 

portion of the National Wildlife Refuge System...” This 340 acre tideland lease is due to expire 

on December 31, 2013. The withdrawl and lease have been critical in the Service’s ability to 

manage these areas for the benefit of the islands wildlife and to protect against human 

disturbance. The Service is working with WDNR on renewal of this lease and expanding this 

partnership to the San Juan Islands NWR.

Washington State Parks (WSP)

The Service has had a long term relationship with WSP. In 1959 WSP and the Service entered 

into a 10-year agreement for the State to develop and operate facilities on Turn, Matia , and Jones 

Islands. Jones Island was transferred to the State in 1982. A MOU was established in 1983 

repalcing the original 1959 agreement. This agreement was updated in 1987 and 2010 and 

outlines the Service and State responsibilities in general and specifically for Matia and Turn 

Islands. The MOU will be updated again upon finalization of this CCP to reflect any changes 

required. Washington State Parks manages the camping program and facilities, composting 

toilets, and mooring buoys at Turn and Matia Islands and a seasonal dock at Matia Island and 

conducts law enforcement activities associated with their use. The Service will continue to work 

with State Parks to ensure these activities support wildlife dependent recreation and expand our 

interpretation and environmental education capabilities.

Washington Department of Ecology

One of Washington Department of Ecology’s programs is spill prevention, preparedness, and 

response. This program focuses on prevention of oil spills to Washington State waters and land, 

as well as planning for an effective response to oil and hazardous substance spills whenever they 

occur. The Service will continue it’s partnership with DOE in support of a Response Tug at Neah 

Bay; maintenance of a regional contingency plan that guides how spills are managed in the 

Northwest; and in the development and periodic review of Geographic Response Plans. 

The Whale Museum

The service has long partnered with the Whale Museum in Friday Harbor. The Museum 

promotes stewardship of whales and the Salish Sea ecosystem through education and research. 

The Whale Museum’s Soundwatch Boater Education Program has partnered with the Service for 

close to 15 years. The boundary waters of the U.S. San Juan and Canadian Gulf Islands are one of 

the highest density whale watching areas in the world. Boating traffic is high in the whale 

watching season on May through September. This program was developed to respond to traffic 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-12

and its effects on marine species. While this program primarily educates whale watching boaters 

in proper watching protocol it has also taken on the additional effort of San Juan NWR patrols. 

They educate boaters in the vicinity of Refuge islands about island closures and requested 200 

yard buffers to avoid disturbance and hand out refuge maps. Soundwatch also assists the Service 

by providing information and brochures at marinas, marine parks and visitor areas likely to reach 

boaters and commercial eco-tourism operators in San Juan County.

. 

Port Townsend Marine Science Center

The Port Townsend Marine Science Center is an educational and scientific organization 

promoting coastal education and conservation. They offer off refuge education and interpretation 

for Protection Island NWR through their wildlife cruises. A spring bird migration cruise is 

offered in April; Protection Island puffin cruises in July and August; and fall migration cruises in 

October and November. Naturalists from the Marine Science Center serve as on board 

interpreters and provide commentary on local birds, mammals, geology, history and weather.

Recently the Service has collaborated with the Marine Science Center studying marine debris. 

Bolus from glaucous-winged gulls on Protection Island are collected and given to the Marine 

Science Center. Students dissect the bolus and look for marine debris (plastics).

Islands’ Oil Spill Association

Islands’ Oil Spill Association is a non-profit, community-based oil spill response organization 

that provides prompt, effective, local oil spill response and prevention throughout San Jaun 

County and is the only oil spill response organization in the San Juan Islands. The Refuge has 

worked with IOSA to place rock anchor bolts on Fortress, Crab, and Blind Islands to attach oil 

booms to protect the island’s and associated bay’s resources, should the need arise.

The Nature Conservancy (TNC)

The Service has partnered with TNC on conducting baseline vegetative surveys for many of the 

islands within the Refuge. TNC also manages lands in the San Juan Islands and the Service has 

worked with them at the Yellow – Low island complex. Yellow Island is a TNC property and 

Low Island a Refuge island. The waters surrounding them are a marine protected area 

administered by the University of Washington and closed to salmon and rock fish fishing. 

Working with the Yellow Island caretaker the Service has permitted the installation of 

informational signage on Low Island regarding this closure. The Yellow Island caretaker 

interacts with boaters who come too close or trespass on Low Island and informs them of the 

island’s closed to public use status and disturbance effects.

San Juan County Marine Resource Committee (SJMRC)

The Service has worked with SJMRC for a number of years as the Refuge islands and their 

resources are important components of the marine ecosystem of the San Jauns.

The Service participated in the development of the SJMRC’s Marine Stewardship Plan which 

includes actions to reduce seabird disturbance. Refuge staff participates in Marine Managers 

Workshops hosted by the SJMRC that draw resource managers together to assist the SJMRC with 

action items in the Plan and provide information on issues and work planned by each group for 

the coming year.

Corinthian Yacht Club of Bellingham
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-13

The Corinthians have conducted an annual Matia Island clean up for a number of years as a club 

project. The club has worked with the Service and Washington State Parks on this project which 

has included marine debris removal, wilderness trail maintenance, English ivy removal, and 

campground “spring cleaning”.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-14

Effectiveness Monitoring

Effectiveness monitoring refers to monitoring and evaluation used to determine whether or not implemented strategies are effective in 

making progress toward meeting CCP objectives. Careful monitoring of progress toward meeting CCP objectives provides informed 

support for sound decision-making regarding refuge resource management and is critical to the application of adaptive management 

principles. Monitoring tasks would be implemented as their associated objectives/strategies are implemented. Monitoring techniques 

identified below may change based on funding and personnel availability as well as in response to advancements in monitoring 

methods. 

Effectiveness Monitoring for Habitat Objectives under Goals 1-5 

Note: $ = can accomplish with existing refuge funding; $$ = some additional funding needed; $$$ = significant funding needed such as a special grant. 

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

1.1, 

2.1, 

2.2

Presence/absenc

e or % cover 

non-native and 

native vegetation

Line intercept transect method Excellent, 

standard 

method

1-2 days during 

the non-breeding 

season of birds or 

use by seals

$ Staff, 

volunteers

, research 

partners

1.1, 2.1, 

2.2, 3.1, 

4.1

Disturbance to 

seabird nesting 

habitat and other 

BIDEH on PI 

from deer. 

Island-wide survey of 

deer/season/habitat type); 

observations of deer in auklet 

and gull colonies/24-hr period 

(% time spent in the colonies 

and direct impacts observed); 

degree of wear in deer trails; 

investigate slope failure and 

determine possible causes; 

Conduct deer exclosure studies 

Good to 

excellent

7-10 days per 

season

$$ Staff, 

volunteers

, research 

partners

none
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-15

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

in savannah and forested 

habitats.

1.1, 2.1, 

2.2, 3.1, 

4.1

Presence/absenc

e of rats, rabbits, 

or other 

mammalian 

predators on PI

Look for signs (scat, tracks, 

fur, etc). If suspected, set up 

more formal survey methods 

such as rat boxes, track plates, 

or cameras. 

Good Can routinely look 

for signs while 

doing other work 

on the island. 

$ to 

look 

for 

signs

$$ to 

condu

ct a 

more 

formal 

survey

. 

Staff, 

volunteers

none

1.1,1.2

1.3,

# of islands free 

of debris

Shoreline and trail surveys excellent PI-2X per year (Sp 

Fall)

SJ-Smith/Minor 

Islands annually, 

Matia and Turn2X per year, other 

accessible islands 

1X/5year on 

rotational basis

$

$$

$

Staff and 

volunteers

Staff and 

volunteers

1.2 Spit length, 

increasing 

measured at 

mean low tide

Photo point, marker stake Excellent 2-3 years $ Staff none

1.2,1.3, Presence/absenc Look for signs (scat, tracks, Good Can routinely look $ to Staff, none
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-16

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

3.2, 3.3, 

4.2, 5.1, 

5.2

e of rats, rabbits, 

or other 

mammalian 

predators on SJI

fur, etc). If suspected, set up 

more formal survey methods 

such as rat boxes, track plates, 

or cameras. 

for signs while 

doing other work 

on the island. 

look 

for 

signs

$$ to 

condu

ct a

more 

formal 

survey

. 

volunteers

1.2 # of elephant 

and harbor seals 

on PI

Elephant and harbor seal 

census by boat

Good Breeding and molt 

periods

$ Biologist, 

Boat 

Operator

WDFW, 

NOAA

1.2 # of pigeon 

guillemot and 

black 

oystercatcher 

nests in the 

driftwood on PI 

and Smith

Area nest searches Fair 2-3 days annually $$ Staff, 

volunteers

, research 

partners

None

1.3 # of breeding 

seabirds and 

oystercatchers

per refuge island

Boat Surveys Good 1 Survey/Season –

All Islands

2-3 

Surveys/breeding 

season –

Turn/Matia

$ Biologist, 

1 

volunteer, 

Boat 

Operator

Some 

applicabili

ty with 

the 

California 

Current 

Seabird 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-17

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

Monitorin

g Plan 

(under 

developm

ent)

1.3 # of prickly pear 

cactus 

populations

GPS, photo Excellent Annually $ Staff, 

volunteers

None

1.3, # of trespass 

incidents on 

Turn and Matia 

along shorelines

Boat surveys Good Annually, anytime 

working in the 

area particularly 

April-September

$ Staff, 

volunteers

none

1.3 # of marine 

mammals 

flushed by 

people from any 

rookery islands

incidental observations Fair $ Staff, 

partners, 

volunteers

Sound 

Watch, 

NOAA, 

WDFW

2.1 Miles of road, # 

of buildings, # of 

other structures 

Measure , count Excellent As needed for data 

called and to add 

or delete property

$ staff none

2.1 Degree of slope 

and friability of 

soil

Good Pre and post 

restoration

$$ Staff, 

volunteers

None

2.1, 

2.2

# of burrows per 

square meter 

Measure number and density 

of rhinoceros auklet burrows 

in restoration plots compared 

to adjacent control plots. 

Excellent Before and after 

structural removal 

vegetation 

establishment

$$ Biologist, 

research 

partners

None
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-18

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

2.1, 

2.2

# of plants, 

patches, or 

presence/absence 

of scotch broom 

and other 

invasive shrubs 

on bluffs. 

Boat and land surveys with 

binoculars if they are higher 

Fair to Good 

from Boat, 

Excellent on 

land

Annually as part 

of other surveys or 

maintenance 

projects, if nothing 

planned for the 

particular island 

then once every 3 

years 

$ Staff, 

volunteers

none

2.1 Bluffs have 50% 

vegetative cover 

for rainy season

Photo and boat surveys Good Annually $ Staff, 

volunteers

none

3.1, 

4.1

% cover of 

invasive 

vegetation or 

native vegetation 

line intercept Excellent Monitor before 

and/or after bird 

breeding season. 

$ Staff, 

volunteers

none

3.1, 

3.2, 

3.3, 

4.1, 

4.2

% cover of trees 

and/or shrubs

Line intercept, aerial photos Excellent 5-10 years?? $ Staff, 

volunteers

none

3.1, 

3.2, 

3.3

% cover of 

native and nonnative grasses 

and forbs. 

Line intercept transects or 

quadrats

Excellent TBD $$ Staff, 

volunteers

State of 

Washingt

on, TNC, 

USFWS

3.1, 

3.3

Presence/absenc

e or % cover of 

butterfly host 

GPS, Point counts and Line 

intercept transect method

Excellent Annually $ Staff, 

volunteers

, WDFW

Butterfly 

recovery 

plan 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-19

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

plant species Island 

silver 

spot??

3.1, 

3.3, 

4.1

Map acres 

restored and % 

cover of targeted 

native species 

within restored 

areas 

GPS/GIS, Line intercept 

transects

Excellent TBD $$ Staff, 

volunteers

none

3.1, 

3.2, 

3.3

Presence/absenc

e of 

rare/endemic 

plant populations

GPS, Point counts and Line 

intercept transect method

Excellent Annually $ Staff, 

volunteers

, 

Golden 

paintbrush 

recovery 

plan

3.1, 

3.2, 

3.3, 

4.1

Presence/absenc

e of targeted 

species

Walking surveys, GPS, 

researchers and caretaker 

plant identification training

Good to 

Excellent

Annually $ Staff, 

volunteers

none

4.1,

4.2

# of eagles 

nesting on PI and 

eagle territories 

encompassing 

islands in the SJI 

NWR

TBD TBD Bald 

Eagle 

Delisting 

Monitorin

g Plan

4.2 Acres of Dry 

Douglas Fir 

Forest

Line intercept, aerial photos Excellent 5-10 years?? $ Staff, 

volunteers

4.2 Acres of old- Line intercept, aerial photos Excellent 5-10 years?? $ Staff, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-20

Obj. # Effectiveness 

Measures 

Method Reliability Time Factors Cost 

Factor

s

Personnel Links to 

Regional 

monitorin

g efforts

growth volunteers

5.1, 

5.2

Presence/ 

absence of 

aquatic invasive 

animals or plants 

such as green 

crabs, bullfrogs, 

purple loosestrife 

and spartina 

GPS, Point counts and Line 

intercept transect method and 

crab pots , calling frog survey

Excellent, 

standard 

method

Annually $ staff, 

volunteers

none

5.1, 

5.2

Hydrological 

study completed

Yes/no excellent TBD $$ Hydrologi

st

None

Effectiveness Monitoring for Visitor Services and Wilderness Objectives under Goals 6-8 

Note: $ = can accomplish with existing refuge funding; $$ = some additional funding needed; $$$ = significant funding needed such as a special grant. 

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

6.1 % of visitors who 

know they are on a 

wildlife refuge and 

that wildlife come 

first 

Visitor contacts and 

tracking

Fair Annual, 

ongoing

$$ SJI NWR 

staff. 

complex 

staff, 

volunteers

, partners

6.1 % of visitors who 

know there are 

Visitor contacts and 

tracking

Fair Annual, 

ongoing

$$ SJI NWR 

staff, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-21

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

other Refuge 

islands in the San 

Juan Archipelago 

and why they are 

closed

complex 

staff, 

volunteers

, partners

6.1 % of violations Observation, # 

Violation Notices 

and % change over 

time

Fair 5 Years $$$ State and 

Federal 

Law 

Enforcem

ent 

personnel, 

SJI NWR 

staff. 

complex 

staff, 

volunteers

, partners

USFWS uniform 

crime reporting 

system, State 

Parks incident and 

violation tracking

6.1 # of violations Observation, # 

Violation Notices

Fair Annual,, 

ongoing

$$$ State and 

Federal 

Law 

Enforcem

ent 

personnel, 

SJI NWR 

staff. 

complex 

staff, 

volunteers

USFWS uniform 

crime reporting 

system, State 

Parks incident and 

violation tracking
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-22

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

, partners

6.2 % of visitors who 

know they are in 

an old growth 

forest on Matia 

Island

Visitor contacts and 

tracking

Fair Annual,, 

ongoing

$$ SJI NWR 

staff. 

complex 

staff, 

volunteers

, , partners

FWS uniform 

crime reporting 

system, 

Washington State 

Parks incident 

tracking

6.2 % of visitors that 

can name at least 

one species 

associated with 

old growth island 

habitat

Visitor contacts and 

tracking

Fair Annual, 

ongoing

$$ SJI NWR 

staff. 

complex 

staff, 

volunteers

, , partners

6.2 % of visitors that 

can name at least 

one species 

associated with 

shoreline habitat 

Visitor contacts and 

tracking

Fair Annual, 

ongoing

$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners

6.2 % of refuge 

visitors who know 

that humans and 

pets disturb 

wildlife and their 

habitat and can 

identify at least 

one negative 

impact of such 

Visitor contacts and 

tracking

Fair Ongoing $$ State and 

Federal 

Law 

Enforcem

ent 

personnel, 

SJI NWR 

staff. 

complex 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-23

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

disturbance staff, 

volunteers

, partners, 

visitors

6.3 Number of habitat 

enhancement 

stewardship 

projects completed 

annually

Quantify number of 

projects &,assess 

success through 

monitoring

Very good Annual $$-$$$ SJI NWR 

staff, 

complex 

staff, 

academic 

institution 

staff, 

partners

Academic 

program 

requirements, 

possible project 

specific regional 

monitoring efforts

6.3 Number of 

stewardship 

project 

participants that 

can identify at 

least 3 adverse 

impacts of 

invasive species, 

marine debris 

and/or human 

caused wildlife 

disturbances

Pre and post project 

assessments

Very good Project 

specific

$ SJI NWR 

staff, 

complex 

staff, 

academic 

institution 

staff, 

partners

6.4 Number of student 

research projects 

conducted

Counting Very Good 5Years $$ SJI NWR 

staff, 

complex 

staff, 

Possible project 

specific
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-24

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

academic 

institution 

staff, 

partners

6.4 % of projects that 

contribute to both

student and refuge 

knowledge 

Pre and post project 

assessments

Good 5Years $$ SJI NWR 

staff, 

complex 

staff, 

academic 

institution 

staff, 

partners

Possible project 

specific

7.1 % of visitors to the 

area who know 

there is a National 

Wildlife Refuge in 

the San Juan 

Archipelago and 

know the 

conservation 

mission of the 

National Wildlife 

Refuge System

Contacts, tracking, 

and/or OMB 

approved survey

Good Annual, 

ongoing, 

OPM 

survey 3 

times during 

plan life (15 

years)

$$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners, 

graduate 

student, 

contractor, 

7.1 % of visitors to the 

area who know 

that refuge islands 

provide key 

habitat for 

Contacts and 

tracking

Good Annual, 

ongoing

$ SJI NWR 

staff, 

complex 

staff, 

volunteers
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-25

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

seabirds and 

marine mammals 

and how to 

observe wildlife 

without causing 

disturbance

, partners

7.1 % of Visitors to the 

area who know 

when and where the 

best wildlife 

viewing 

opportunities are 

and how to 

maximize those 

opportunities 

through minimizing 

disturbance

Contacts and 

tracking

Fair Annual, 

ongoing

$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners

7.2 % of government 

and tribal officials 

and local citizens 

who know of the 

San Juan Islands 

NWR and that it 

provides key habitat 

for a variety of 

wildlife including 

seabirds and marine 

mammals

Contacts and 

tracking, possible 

social research 

project and/or OMB 

approved survey 

Very Good Annual, 

ongoing, 

may need to 

allow time 

for OMB 

approval for 

social 

research 

project

$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners, 

graduate 

student

7.2 % of government 

and tribal officials 

Contacts and Very Good Annual, $$ SJI NWR 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-26

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

and local citizens 

who understand the 

conservation 

mission of the 

National Wildlife 

Refuge System

tracking, possible 

social research 

project and/or OMB 

approved survey

ongoing, 

may need to 

allow time 

for OMB 

approval for 

social 

research 

project

staff, 

complex 

staff, 

volunteers

, partners, 

graduate 

student

7.3 % of area boaters 

who know 

Protection Island 

is a NWR 

Contacts and 

tracking, possible 

social research 

project and/or OMB 

approved survey

Fair Annual, 

ongoing, 

may need to 

allow time 

for OMB 

approval for 

social 

research 

project

$-$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners, 

graduate 

student

USFWS uniform 

crime reporting 

system, State 

Parks incident and 

violation tracking

7.3, 8.2 % of pilots who 

maintain a 2,000 

foot minimum 

ceiling above 

refuge islands 

Observation and 

tracking

Fair Annual, 

ongoing

$-$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners

USFWS uniform 

crime reporting 

system, State 

Parks incident and 

violation tracking

7.3 % of area boaters 

who know why it 

is important to 

maintain a 200 

yard disturbance 

Contacts and 

tracking, possible 

social research 

project and/or OMB 

approved survey

Fair Annual, 

ongoing, 

may need to 

allow time 

for OMB 

$-$$ SJI NWR 

staff, 

complex 

staff, 

volunteers
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-27

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

buffer around 

Protection Island 

NWR

approval for 

social 

research 

project

, partners, 

graduate 

student

7.3 % of area boaters 

who know which 

rocks, islands, and 

islets are part of 

the San Juan 

Islands NWR 

Contacts and 

tracking, possible 

social research 

project and/or OMB 

approved survey

Fair Annual, 

ongoing, 

may need to 

allow time 

for OMB 

approval for 

social 

research 

project

$-$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners, 

graduate 

student

7.3 % of area boaters 

know why it is 

important to 

maintain a 200 

yard disturbance 

buffer (or as close 

to 200 yards as 

possible) around 

refuge islands in 

the San Juan 

Islands NWR

Contacts and 

tracking, possible 

social research 

project and/or OMB 

approved survey

Fair Annual,

ongoing, 

may need to 

allow time 

for OMB 

approval for 

social 

research 

project

$-$$ SJI NWR 

staff, 

complex 

staff, 

volunteers

, partners, 

graduate 

student

7.3 % of area boaters 

know that wildlife 

comes first in 

Refuges

Contacts and 

tracking, possible 

social research 

project and/or OMB 

Fair Annual, 

ongoing, 

may need to 

allow time 

$-$$ SJI NWR 

staff, 

complex 

staff, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-28

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

approved survey for OMB 

approval for 

social 

research 

project

volunteers

, partners, 

graduate 

student

7.4 Number of Refuge 

interpretive 

products or

programs created 

that focus 

primarily on 

interpretation of 

cultural and/or 

paleontological 

resources

Quantify number of 

Refuge interpretive 

products that focus 

primarily on cultural 

and/or 

paleontological 

resources

Very Good Annual, 

ongoing

$$-$$$ SJI NWR 

staff, 

complex 

staff, 

volunteers 

, partners, 

contractor

None

7.4 All appropriate 

Refuge 

educational 

products include 

interpretation of 

cultural and 

paleontological 

resources

Quantify number of 

products and % of 

products that 

interpret cultural 

resources and 

paleontological 

resources

Very good Annual, 

ongoing

$$-$$$ SJI NWR 

staff, 

complex 

staff, 

volunteers 

, partners, 

contractor

None

8.1 Total number of 

signs installed 

consistent with 

minimum 

requirement 

Inspect and count all 

signs

Very good Annually 

visit 1⁄4 of 

the islands

$ SJI NWR 

staff, 

volunteers

, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix G – Implementation G-29

Obj. # Effectiveness 

Measures 

Method Reliability Time 

Factors

Cost Factors Personnel Links to Regional 

monitoring 

efforts

analysis. 

8.2 Survey for visitor 

numbers or boats 

during peak 

visitation periods

Boat or land based 

observations

Good Annually $ Refuge 

staff, 

none

8.2 Reduction of nonwilderness 

intrusions on 

wilderness islands

Assess wilderness 

quality through 

observation, 

possible OMB 

approved survey, 

possible audio/video 

recording

Good Monthly, 

annual, 

ongoing

$$ SJI NWR 

staff, 

volunteers

, partners, 

contractor, 

graduate 

student

Wilderness Act 

requirements

8.3 # of visitors know 

that the refuge is 

also a wilderness 

area

Possible OMB 

approved survey

Good Within 3 

years after 

interpretativ

e panels are 

installed

$$ SJI NWR 

staff, 

volunteers

, partners, 

contractor, 

graduate 

student

none
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-1

Appendix H – Wilderness

This appendix includes a number of items related to management of wilderness lands and review of nonwilderness lands to determine their suitability for wilderness designation. 

The following elements are included:

1. Wilderness Stewardship Plan (WSP) Components within CCP/WSP/EA

2. Wilderness Reviews 

3. Minimum Requirement Analysis-Signs

4. Minimum Requirement Analysis- Research, Monitoring, and Management

H.1 Wilderness Stewardship Plan (WSP) Components within CCP/WSP/EA

U.S. Fish and Wildlife Service policy (Part 610, Wilderness Stewardship) provides guidance for 

managing, as well as planning for management of, wilderness areas within national wildlife refuges. 610 

FW 3 Exhibit 1 outlines the required components of a Wilderness Stewardship Plan, which is required for 

every wilderness area under USFWS management.

610 FW 3 describes a Wilderness Stewardship Plan (WSP) as a step-down management plan that guides 

the preservation, stewardship and use of a particular wilderness area. The policy states that where the 

majority of a refuge is designated wilderness, we may prepare a detailed CCP that incorporates the 

required elements of a WSP rather than preparing a separate WSP.” This CCP incorporates the required 

elements of a WSP.

Location of WSP components within Protection Island and San Juan Islands National Wildlife Refuges 

Comprehensive Conservation Plan, San Juan Island Wilderness Stewardship Plan, 

and Associated Environmental Assessment are described by the following wilderness stewardship plan 

outline. 

Wilderness Stewardship Plan Outline

(Exhibit 1, 610 FW 3)

1.1. Introduction.

A. Information on wilderness establishment for the San Jaun Islands Wilderness Area, including contents 

of pertinent laws, date(s) of establishment, and boundary or other legal changes, can be found in Chapter 

1. Pertinent committee report discussion and special provisions can be found in other supporting 

documentation including congressional hearing records and all other documents relating to wilderness 

designation, which are available at the Complex office and incorporated by reference into this CCP/ 

EA/WSP.

B. The goals and objectives for the establishment of these wilderness areas, and their relationship to the 

refuge's purposes and Refuge System mission and goals, are summarized in Chapter 1, section 1.2. 1.6, 

and 1.7.

1.2. Description of the Wilderness Area.

A. The legal and narrative descriptions of the wilderness area is contained in chapter 3 section 3.3 

(topography)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-2

B. Maps displaying Service refuge boundaries, wilderness area boundaries, and other relevant legal, 

administrative, and natural boundaries are located within Chapter 1 (see Figures 1.1, 1.2, 1.3).

C. Descriptions of baseline wilderness resource conditions existing at the time of designation, including a 

description of the wilderness area, natural conditions, cultural resources and values, stewardship 

activities, existing facilities, and public use levels and activities are contained in the original San Jaun 

Islands Wilderness Proposal document which located at refuge office. Current wilderness resource 

conditions are contained in Chapter 3 (Physical Environment), Chapter 4 (Refuge Biology and Habitat), 

and Chapter 5 (Social and Economic Environment).

1..3. Interagency and Tribal Coordination and Public Involvement. A description of coordination 

with States, other Federal agencies, and tribes, as well as a summary of public involvement activities, are 

contained in Chapter 1, section 1.12. Appendix K (not specific to wilderness) includes greater detail on 

agency, tribal and public involvement as well as a summary and analysis of comments received and how 

the plan responds to them.

1.4. Stewardship.

A. A description of stewardship strategies (administrative, natural and cultural resources, public 

recreation, interpretation and education, and commercial services) required to adequately administer the 

area can be found in Chapter 2, Goal 8.

B. Minimum requirement analyses (MRAs) and documentation of National Environmental Policy Act 

(NEPA) compliance for all refuge management activities and commercial services necessary to 

administer the area are found in this appendix.

C. Not Applicable: Descriptions of how we will manage existing private rights, existing rights-of-way, 

activities associated with valid mineral rights, and congressionally authorized uses to protect wilderness 

values. 

D. Not Applicable: An explanation of how we will coordinate with adjoining wilderness units so that 

the wilderness character and natural and cultural resources and values are managed in a complementary 

manner that minimizes the impediments to visitors traveling from one wilderness area to another. 

1.5. Research. Descriptions of past and current research are found in Chapter 5, and identification of 

research needs, are discussed in Chapter 2, Goal 9. Other potential areas of research are mentioned 

throughout Chapter 4. Appropriateness Finding for Research are in Appendix I. Compatibility 

determinations for research, including wilderness-specific stipulations, are in Appendix J. An MRA for 

an activity directly related to a specific research project on San Juan Islands NWR is found in this 

appendix. All the aforementioned documents include discussion of relevant partnerships, funding, and 

staffing requirements, also included in a larger discussion within Appendix G. 

1.6. Funds and Personnel. A discussion of staff and funds needed to administer the wilderness is 

included in Appendix G, Staffing, Funding, and Partnerships.

1.7. Monitoring. To determine if we are meeting our wilderness stewardship objectives and other refuge 

management objectives in wilderness, a WSP is required to identify monitoring requirements; associated 

protocols; partnership, funding, and staffing needs; indicators of change in resource conditions; standards 

for measuring that change; and desired conditions or thresholds that will trigger management actions to 

reduce or prevent impacts on the wilderness. Monitoring requirements are listed in Chapter 2; Goal 3 

Objective 3.2; Goal 4 Objective 4.2; Goal 5 Objective 5.2; Goal 6 Objective 6.1, 6.3, 6.4; and Goal 8 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-3

Objective 8.2. Specific details with regard to protocols, indicators of change and standards for measuring 

change, and desired conditions and thresholds triggering management actions will be detailed in a stepdown Wilderness Monitoring plan following completion and approval of this CCP.

1.8. Implementation Schedule. A schedule of implementation, prioritization of action items, staff 

assignments, and funding requirements to adequately administer the area is contained in Appendix G, 

Staffing, Funding, and Partnerships.

1.9. Appropriateness and Compatibility Determinations are found in Appendices I and J.

1.10. Review and Approval.

1.11. Appendix. All of the supporting documentation below (A. – F.) is available at the Complex office 

and incorporated by reference into this CCP: 

A. A copy of the legislation establishing, modifying the boundary of, or making other changes to the 

wilderness areas. Relevant legislation is also summarized in Chapter 1, Section 1.6 and 1.7.

B. Wilderness study reports for San Juan Islands Wilderness.

C. Wilderness Proposal for San Juan Islands Wilderness (1971)

D. NEPA documentation for wilderness establishment.

E. Public hearing record from the wilderness study and record of review of comments received from 

States, other Federal agencies, tribes, and the public: 

F Congressional hearing record.

G. Congressional committee report accompanying the authorizing legislation. 

H.2 Wilderness Reviews

2.1 Policy for Wilderness Reviews

A wilderness review is the process used to determine whether or not to recommend lands or waters in the 

National Wildlife Refuge System to Congress for designation as wilderness. The Service is required by 

policy to conduct a wilderness review for each refuge as part of the CCP process (Part 602 FW 3.4 

C.(1) (c)). This review includes the re-evaluation of refuge lands existing during the initial 10-

year review period of The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) as well as 

new lands and waters added to the NWRS since 1974. NWRS policy on Wilderness Stewardship 

(610 FW 1-5) includes guidance for conducting wilderness reviews (610 FW 4 – Wilderness 

Review and Evaluation). Lands or waters that meet the minimum criteria for wilderness are identified 

in a CCP and further evaluated to determine whether they merit recommendation to the U.S. Congress for 

inclusion in the National Wilderness Preservation System (NWPS).
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-4

2.2 Criteria for Evaluating Lands for Possible Inclusion in the National 

Wilderness Preservation System

According to the Wilderness Act of 1964, as amended (16 USC 1131-1136), “An area of wilderness is 

further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character 

and influence, without permanent improvements or human habitation, which is protected and managed so 

as to preserve its natural conditions and which (1) generally appears to have been affected primarily by 

the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding 

opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand 

acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired 

condition; and (4) may also contain ecological, geological, or other features of scientific, educational, 

scenic, or historical value.”

Criterion 3 is further defined in Section 3(c) of the Act as 1) a roadless area of 5,000 contiguous acres or more, 

or 2) a roadless island. Roadless is defined as the absence of improved roads suitable and maintained for 

public travel by means of 4-wheeled, motorized vehicles that are intended for highway use.

2.3 The Wilderness Review Process

A wilderness review is the process of determining whether the Service should recommend NWRS lands 

and waters to Congress for wilderness designation. The wilderness review process consists of three 

phases: wilderness inventory, wilderness study, and wilderness recommendation. 

The inventory is a broad look at a refuge to identify lands and waters that meet the minimum criteria for 

wilderness - size, naturalness, and outstanding opportunities for solitude or primitive and unconfined type 

of recreation. All areas meeting the criteria are preliminarily classified as Wilderness Study Areas 

(WSAs). If WSAs are identified, the review proceeds to the study phase. 

Wilderness Inventory

During the study phase, WSAs are further analyzed: 

Wilderness Study

1) for all values of ecological, recreational, cultural, economic, symbolic

2) for all resources, including wildlife, vegetation, water, minerals, soils

3) for existing and proposed public uses

4) for existing and proposed refuge management activities within the area, 

5) to assess the Refuge’s ability to manage and maintain the wilderness character in perpetuity, 

given the current and proposed management activities. Factors for evaluation may include, 

but are not limited to staffing and funding capabilities, increasing development and 

urbanization, public uses, and safety. 

We evaluate at least an “All Wilderness Alternative” and a “No Wilderness Alternative” for each WSA to 

compare the benefits and impacts of managing the area as wilderness as opposed to managing the area 

under an alternate set of goals, objectives, and strategies that do not involve wilderness designation. We 

may also develop “Partial Wilderness Alternatives” that evaluate the benefits and impacts of managing 

portions of a WSA as wilderness.

In the alternatives, we evaluate:

1) the benefits and impacts to wilderness values and other resources

2) how each alternative will achieve the purposes of the Wilderness Act and the NWPS
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-5

3) how each alternative will affect achievement of refuge purpose(s) and the refuge’s contribution 

toward achieving the Refuge System mission

4) how each alternative will affect maintaining and, where appropriate, restoring biological integrity, 

diversity, and environmental health at various landscape scales

5) other legal and policy mandates 

6) whether a WSA can be effectively managed as wilderness by considering the effects of existing 

private rights, land status and service jurisdiction, refuge management activities and refuge uses 

and the need for or possibility of eliminating Sec 4 (c) prohibited uses

If the wilderness study demonstrates that a WSA meets the requirements for inclusion in the National 

Wilderness Preservation System, a wilderness study report should be written that presents the results of the 

wilderness review, accompanied by a Legislative Environmental Impact Statement (LEIS). The wilderness 

study report and LEIS that support wilderness designation are then transmitted through the Secretary of 

Interior to the President of United States, and ultimately to the United States Congress for action. Refuge 

lands recommended for wilderness consideration by the wilderness study report will retain their WSA status 

and be managed as “... wilderness according to the management direction in the final CCP until Congress 

makes a decision on the area or we amended the CCP to modify or remove the wilderness recommendation” 

(610 FW 4.22B). When a WSA is revised or eliminated, or when there is a revision in “wilderness 

stewardship direction, we include appropriate interagency and tribal coordination, public involvement, and 

documentation of compliance with NEPA” (610 FW 3.13).

Wilderness Recommendation 

The following constitutes the inventory phase of the wilderness review for the Protection and San Juan 

Islands National Wildlife Refuges.

2.4 Previous Wilderness Reviews

A wilderness review was conducted for the San Juan Island refuges in 1971, and all were designated 

wilderness with the exception of Smith, Minor, Turn and a small portion of Matia Islands. Protection 

Island has not previously been reviewed for wilderness.

2.5 Lands Considered Under This Wilderness Review

All Service-owned lands within the San Juan Islands and Protection Island (in fee title) National Wildlife 

Refuge not already within wilderness was considered during this wilderness review. 

2.6 Wilderness Inventory 

2.6.1 Unit Size: Roadless areas meet the size criteria if any one of the following standards apply:

• An area with over 5,000 contiguous acres solely in FWS ownership.

• A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or an area that is markedly distinguished from the surrounding lands by 

topographical or ecological features.

• An area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-6

• An area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau of 

Land Management.

Protection Island 

Protection Island NWR is 364 acres and was established in 1982. It is located at the mouth of Discovery 

Bay in the Strait of Juan de Fuca. The island first described in the early 1790’s by explorers has a varied 

history beginning in the mid-1800. That history includes farming, research, military, and urban 

development. The last included the construction of an air strip, roads, marina, and homes by the 

developers. Protection Island does not meet the roadless island requirements for an island wilderness 

area. The Service is required, by written agreement, to maintain these roads and other infrastructure that 

were built as part of the development for the extended users still allowed to use the island.

2.6.2 Naturalness and Wildness: the area generally appears to have been affected primarily by the 

forces of nature, with the imprint of man’s work substantially unnoticeable

This criterion must be evaluated in the context of current natural conditions and societal values and 

expectations without compromising the original intent of the Wilderness Act. It is well recognized that 

there are few areas remaining on the planet that could be truly classified as primeval or pristine, with even 

fewer, if any, existing in the conterminous United States. Likewise, few areas exist that do not exhibit 

some impact from anthropogenic influences, be it noise, light, or air pollution; water quality or 

hydrological manipulations; past and current land management practices; road or trails, suppression of 

wildfires; invasions by non-native species of plants and animals; or public uses. While allowing for the

near-complete pervasiveness of modern society on the landscape, the spirit of the Wilderness Act is to 

protect lands that still retain the wilderness qualities of: 1) natural, 2) untrammeled, 3) undeveloped. 

These three qualities are cornerstones of wilderness character. For areas proposed or designated as 

wilderness, wilderness character must be monitored to determine baseline conditions and thereafter be 

periodically monitored to assess the condition of these wilderness qualities. Proposed and designated 

wilderness areas by law and policy are required to maintain wilderness character through management 

and/or restoration in perpetuity. 

Defining the first two qualities (natural and untrammeled) requires a knowledge and understanding of the 

ecological systems which are being evaluated as potential wilderness. Ecological systems are comprised 

of three primary attributes – composition, structure, function. Composition is the components that make 

up an ecosystem, such as the habitat types, native species of plants and animals, and abiotic (physical and 

chemical) features. These contribute to the diversity of the area. Structure is the spatial arrangement of 

the components that contribute to the complexity of the area. Composition and structure are evaluated to 

determine the naturalness of the area. Function is the processes that result from the interaction of the 

various components both temporally and spatially, and the disturbance processes that shape the landscape. 

These processes include but are not limited to predator-prey relationships, insect and disease outbreaks, 

nutrient and water cycles, decomposition, fire, windstorms, flooding, and both general and cyclic weather 

patterns. Ecological functions are evaluated to determine the wildness or untrammeled quality of the 

area. 

The third quality assessment is whether an area is undeveloped. Undeveloped refers to the absence of 

permanent structures such as roads, buildings, dams, fences, and other man-made alterations to the 

landscape. Exceptions can be made for historic structures or structures required for safety or health 

considerations, providing they are made of natural materials and relatively unobtrusive on the landscape.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-7

General guidelines used for evaluating areas for wilderness potential during this wilderness inventory 

process include:

1. The area should provide a variety of habitat types and associated abiotic features, as well as a 

nearly complete complement of native plants and wildlife indicative of those habitat types. Nonnative and invasive species should comprise a negligible portion of the landscape.

2. The area should be spatially complex (vertically and/or horizontally) and exhibit all levels of 

vegetation structure typical of the habitat type, have an interspersion of these habitats, and 

provide avenues for plant and wildlife dispersal.

3. The area should retain the basic natural functions that define and shape the associated habitats 

including but not limited to flooding regimes, fire cycles, unaltered hydrology and flowage 

regimes, basic predator-prey relationships including herbivory patterns. 

4. Due to their size, islands may not meet the habitat guidelines in 1. and 2. above. Islands should, 

however, exhibit the natural cover type with which it evolved and continue to be shaped and 

modified by natural processes. Islands should be further analyzed during the study portion of the 

review, if they provide habitat for a significant portion of a population, or key life cycle 

requirements for any resources of concern, or listed species. 

5. Potential wilderness areas should be relatively free of permanent structures or man-made 

alterations. Areas may be elevated to the study phase if existing structures or alterations 

can be removed or remediated within a reasonable timeframe, and prior to wilderness 

recommendation to the Secretary of the Interior.

Protection Island 

Protection Island is 364 acres and was established in 1982. It is located at the mouth of Discovery Bay 

in the Strait of Juan de Fuca and is closed to the public to protect nesting sea birds and harbor seals. The 

island first described in the early 1790’s by explorers has a varied history beginning in the mid-1800. 

That history includes farming, research, military, and urban development. The last included the 

construction of an air strip, roads, marina, and homes by the developers. Several of the former residences 

are occupied by the FWS, volunteer caretaker and seasonal researchers under Special Use Permit. One 

lifetime private user still maintains a residence. 

The island habitat is grassland/savanna, forest and woodland, shoreline habitat varies from sandy to 

rocky, and a small remnant brackish wetland remains. Much of the vegetative cover, particularly the 

grassland, is non-native and there is a great need for habitat restoration throughout the island. This 

restoration and all current maintenance require the use of mechanical equipment such as tractors, ATV’s, 

and boats. The in-holding agreements cover various lengths of time. Some will be expiring in 2011, but 

one is a life-time use. The Service uses volunteers as resident caretakers, whose presence is critical to 

help protect the sensitive wildlife from human disturbance. Due to the greatly altered landscape, long 

term human structures, extensive infrastructure and legally required agreements to maintain this 

infrastructure requiring mechanical equipment we have determined Protection Island does not satisfy 

minimum wilderness suitability criteria for ‘naturalness and wildness’ standards for wilderness 

designation.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-8

The Service maintains all refuge islands in the San Juan NWR as closed to the public with the exception 

of Matia and Turn Island. 

This unit of the refuge is 145 acres and was created in 1937. The entire island is already in wilderness 

designation with the exception of the five acre Rolf Cove campground area, which is owned by the 

USFWS, but managed by the Washington State Parks and Recreation Commission under a Memorandum 

of Understanding (MOU). The island habitat consists of grassland/savanna, herbaceous bald, forest and 

woodland, a small freshwater wetland, and shoreline that varies from sandy to rocky. Most of the island 

is dominated by native vegetation, but there is increasing non-native vegetative cover around the campsite 

areas. The campground offers six campsites, floating dock, a sandy beach, one picnic site and a 

compositing toilet. Washington State Parks and Recreation Commission maintains the toilet by removing 

the compost material with a small tractor. The entire island is closed to the public except for the 

campground area, and the 1.2 mile trail the loops through the wilderness area. There are no interpretative 

signs on this trail but there are other permanent regulatory signs that are visible from the trail where it 

nears the outer edges of the island. Just off shore of the island and outside the jurisdiction of the Service, 

there is moorage for watercraft. Here engine-driven electric generators are allowed as well as other 

mechanical equipment. Considering there are permanent structures, mechanical equipment use, permitted 

off-shore activities producing noise and light pollution that affect the wilderness experience we have 

determined that this part of Matia island does not satisfy minimum wilderness suitability criteria for 

‘naturalness and wildness’ standards for wilderness designation. 

Matia Island.

Turn Island

This unit, owned by the Service, is 35 acres but is also managed cooperatively with Washington State 

Parks and Recreation Commission under MOU. The island habitat is grassland/savanna, forest and 

woodland, and shoreline habitat varies from sandy to rocky. There is year round camping and boat 

moorage available for motorboats and other watercraft are allowed to land on the island. There are 

permanent interpretative and regulatory signs along the .9-mile trail and island perimeter. The 

campground offers thirteen campsites, a sandy beach, picnic site and two compositing toilets. 

Washington State Parks and Recreation Commission maintains the toilets by removing the 

compost material with a small tractor. Just off shore of the island and outside the jurisdiction of 

the Service, there is moorage for watercraft. Here visitors can use engine-driven electric 

generators as well as other mechanical equipment. This island is less than two-miles from the 

town of Friday Harbor on San Juan Island and has the highest visitation of all the open refuge 

islands. The refuge proposes to increase interpretation development of Turn Island to education 

the public about the refuge, the National Wildlife Refuge System, and the many issues that 

threaten islands’ habitats and wildlife. Because of the high use due to the proximity to Friday Harbor, 

permanent structures, the permitted use of power equipment just off-shore and using power equipment 

on the island, we have determined Turn Island does not satisfy minimum wilderness suitability criteria 

for ‘naturalness and wildness’ standards for wilderness designation.

. 

Smith and Minor Islands

These units are 65 acres and were established in1914 as an over lay to the U.S. Coast Guard’s primary 

jurisdiction for aids to navigation. A lighthouse was built in 1857 on Smith Island, and the station was 

staffed from 1858 to the 1957 when it was abandoned due to erosion which threatened the structure. In 

the 1930’s Minor Island was used as a naval bombing area by the United States military with aircraft from 

nearby Whidby Island Naval Air Station. Smith Island habitat is grassland/savanna, forest and 

woodland, a small brackish wetland, and shoreline that varies from sandy to rocky. There are several 

permanent structures (residence, maintenance shop, cistern and helicopter landing pad) build by the U.S. 

Coast Guard. Two towers (weather and communications) are also on the island and are serviced and 

. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-9

maintained by USCG and NOAA using motorized equipment. Minor Island habitat is coastal sand strand 

and a concrete engine room and aids to navigation light are located there. Considering the past use of the 

islands and evidence of inadequate fuel storage (historic pictures), there is concern of possible soil 

contamination. Additionally, because of past military use as a bombing area, there is a concern regarding 

the potential for unexploded ordinance. These units do not meet the ‘naturalness and wildness’ standards 

for wilderness designation.

H.3 Minimum Requirement Analysis - Signs

San Juan Islands Wilderness Area

San Juan Islands NWR and Wilderness contain the majority of the seabird nesting colonies and pinniped 

haul-out sites in the Northern portion of the Salish Sea and the San Juan Archipelago. Black 

oystercatchers and pigeon guillemot nest along island shore lines. Pelagic, double-crested, and Brandt’s 

cormorants, glaucous–winged and glaucous-winged/western gulls nest at more upland sites and bald 

eagles nest in refuge trees.

Steller and California sea lions haul-out on refuge islands and harbor seals use the islands for pupping and 

hauling-out. Elephant seals have recently used islands in the southern portion of the refuge to breed. The 

Washington Maritime NWR Complex proposes to install signs appropriate with management actions 

within the San Juan Islands Wilderness. There is a need to determine (1) if this action is necessary in 

wilderness and, (2) if so, what is the minimum required activity (tools and techniques).

Step 1: Determine if any administrative action is necessary.

Briefly describe the situation that may prompt action:

San Juan Islands NWR is a network of 83 islands, rocks, and reefs and all are protected under the 

Wilderness Act with the following exceptions: Smith and Minor Island, the Washington State Park 

managed campground on Matia, and all of Turn Island. Additionally, all the islands are closed to the 

public due to the sensitive wildlife that utilizes these island habitats, and safety concerns for approaching 

the islands. These islands are managed under the administration of the Washington Maritime NWR 

Complex. 

The complex proposes to install closure information signs that are needed to keep the public off of the 

closed islands for public safety and to protect wildlife. These signs will be compatible with the 

surroundings, and as small as possible as stated in 610 FW 2.5D(5). Since these signs are all along 

waterways they will also need to meet any Coast Guard or State requirements

Management actions for this wilderness area include installation and maintenance of informational and 

interpretive signs at a variety of off-site locations adjacent to wilderness, such as Turn Island, a nonwilderness island within the refuge, trailhead to Matia Island wilderness trail, state parks, and marinas. 

On all the islands within the refuge trespass is a serious and recurring problem, necessitating the 

placement of boundary and regulatory signs above the intertidal zone. Installation of these signs is 

necessary for informing the public which of the 172 islands in San Juan County are refuge islands, the 

sensitivity of these areas and that they are closed to public access. These signs are located out of necessity 

just within the boundaries of the wilderness which begin on these islands at mean high tide. 

To determine if administrative action is necessary, answer questions A-F.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-10

A. Describe Options Outside of Wilderness

Is action necessary within wilderness? Yes

The management actions for these closed wilderness areas includes placing signs and information about 

the refuge outside of the wilderness areas. This information will be located at public access points such 

as marinas, equipment rental facilities, watercraft education centers, and wildlife tour operator offices.

There are limitations to the effectiveness of any management action. Therefore, this action is necessary 

within the wilderness since not all boaters read posted information; boaters coming to the refuge from 

other ports or launch locations that don't have this information, including international travelers; the signs 

act as a prevention against the threat of invasive species introductions; due to the marine conditions, 

jurisdictional ownerships, and topography of the islands it is not feasible to place the signs just outside the 

wilderness boundary.

B. Describe Valid Existing Rights or Special Provisions of Wilderness Legislation

Is action necessary to satisfy valid existing rights or a special provision in wilderness legislation (the 

Wilderness Act of 1964 or subsequent wilderness laws) that allows consideration of the Section 4(c) 

prohibited uses? Yes 

Special Provision – from The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) Section 4(b): 

Except as otherwise provided in this Act, each agency administering any area designated as wilderness 

shall be responsible for preserving the wilderness character of the area and shall so administer such area 

for such other purposes for which it may have been established as also to preserve its wilderness 

character. Except as otherwise provided in this Act, wilderness areas shall be devoted to the public 

purposes of recreational, scientific, educational, conservation, and historical use.

Prohibited Uses – from The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) Section 4(c): 

“Except as necessary to meet minimum requirements for the administration of the area for the purpose of 

this Act (including measures required in emergencies involving the health and safety of persons within 

the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, 

no landing of aircraft, no other form of mechanical transport, and no structure (i.e. signs) as stated in 610 

FW 2.5D(5) or installation within any such area.” 

C. Describe Requirements of Other Legislation

Is action necessary to meet the requirements of other laws? Yes

The National Wildlife Refuge System Administration Act of 1966, as amended, in section 4(a)(4)(B) 

directs the FWS to (1) provide for the conservation of fish, wildlife, and plants, and their habitats within 

the NWRS; (2) ensure the biological integrity, diversity, and environmental health of the NWRS are 

maintained (see 610 FW 3); and (3) monitor the status and trends of fish, wildlife, and plants in each 

refuge. These requirements cannot be fully met through conducting research and monitoring actions 

outside the proposed wilderness area.

Executive Order 13112 directs federal agencies to: “subject to the availability of appropriations, and 

within Administration budgetary limits, use relevant programs and authorities to: (i) prevent the 

introduction of invasive species; (ii) detect and respond rapidly to and control populations of such species 

in a cost-effective and environmentally sound manner; (iii) monitor invasive species populations 

accurately and reliably; (iv) provide for restoration of native species and habitat conditions in ecosystems 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-11

that have been invaded; (v) conduct research on invasive species and develop technologies to prevent 

introduction and provide for environmentally sound control of invasive species; and (vi) promote public 

education on invasive species and the means to address them”.

D. Describe Other Guidance 

Is action necessary to conform to direction contained in agency policy, unit and wilderness management 

plans, species recovery plans, or agreements with tribal, state and local governments or other federal 

agencies? Not Applicable

E. Wilderness Character 

Is action necessary to preserve one or more of the qualities of wilderness character including 

untrammeled, undeveloped, natural, outstanding opportunities for solitude or a primitive and unconfined 

type of recreation, or unique components that reflect the character of this wilderness area?

Untrammeled: Yes

San Juan Islands Wilderness resource values include supporting a great variety of sea bird species and 

important haulout areas for pinnipeds. The sea bird habitat includes areas for nesting and roosting, as 

well as migration stopover for many other bird species (San Juan Wilderness Proposal 1976). The 

vegetation habitat of the dry Douglas fir and the dry prairie grasslands are becoming increasingly rare in 

the whole Salish Sea area due to development and other impacts such as invasive species (WDFW, 2005)

Protecting the untrammeled character of these wilderness areas requires protecting the flora and fauna that 

exists there during any season, and the ecological processes that supports the native diversity. The threat 

of invasive species poses serious ecological harm whether to the plant or animal community. Therefore, 

initiation of management actions to control and where possible eliminate, trespassing would also reduce a 

secondary potential negative effect of invasive species introduction, which is critical to protecting these 

wilderness areas.

On Matia there is a trail that loops through the wilderness part of the island right from the campground. 

Spur trails and human built structures have been built in the wilderness area by the public. This 

highlights the importance of the management need to place signs to better inform the public.

Undeveloped: Yes

The undeveloped islands, rocks, and reefs within the San Juan Island Wilderness provide a dramatic 

natural setting within the San Juan archipelago. The area is a popular destination for visitor and residents 

to observe the varied and abundant wildlife. Many communities, on the larger nearby islands, have 

expanded services to accommodate the increased use of the area. Many of the refuge islands are short 

distances away from these developed areas which provide many points of access to view the refuge. 

Providing the public with refuge information and interpretive signage to encourage their participation in 

the protection of this valuable resource is of the utmost importance.

Natural: Yes

Many of the islands and rocks within the San Juan Islands Wilderness are located adjacent to inhabitated 

islands, an area receiving ever-increasing pressure for residential housing, commercial development and 

recreation. Efforts to minimize trespassing violations, by using signs to inform the public, of the 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-12

wilderness ecological systems (plant and animal species and communities) are necessary to maintain the 

natural character of these islands. Because the “natural” quality also refers to the abundance, 

distribution, or number of invasive non-indigenous species, there is a need to protect these islands from 

invasive species. 

Outstanding opportunities for solitude or a primitive and unconfined type of recreation:

Not Applicable

Explain: All rocks, reefs, and islands within the San Juan Island NWR, with the exception to the open 

camping areas on Matia and all of Turn Island, are closed to public entry to protect sensitive wildlife and 

habitat.

Other unique components that reflect the character of this wilderness: No

F. Describe Effects to the Public Purposes of Wilderness

Is action necessary to support one or more of the public purposes for wilderness (as stated in Section 4(b) 

of the Wilderness Act) of recreation, scenic, scientific, education, conservation, and historical use?

Recreation: No

All rocks, reefs, and islands within the San Juan Island NWR, with the exception to the open camping and 

trail areas on Matia and all of Turn Island, are closed to public entry to protect sensitive wildlife and 

habitat.

Scenic: Yes

The control of trespassing and possible introduction of invasive species, and the subsequence preservation 

of seabird and pinniped colonies will maintain the scenic value of the wilderness.

Scientific: Not Applicable:

Education: Yes:

Education about the sensitivity and the importance of undisturbed habitats within these wilderness areas is 

necessary for the continued protection of these island habitats. As residential and commercial 

development of the area continues to grow, it is important that the communities support the closed nature 

of the refuge. The educational information about the refuge needs to “open” the refuge to the public but

from a distance. A win-win situation would be that the public understands and supports the refuge and 

that because of their efforts results in greater abundance of the wildlife for viewing in the area for 

everyone.

Conservation: Yes

These areas cannot be successfully conserved, including its wilderness values, without management 

actions within the wilderness areas. The USFWS cannot fully meet its affirmative responsibilities for 

refuge purposes, endangered and threatened species, invasive species, wilderness management objectives, 

and the NWRS mission without reducing trammeling, protection for critical sea bird and seal habitat, and 

controlling invasive species.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-13

Historical use: No 

Step 1 Decision: Is any administrative action necessary in wilderness? Yes

Explain: Although a large effort will be made to reach the public with information outside the 

wilderness area, there is still a large group of visitors to the area that would not be exposed to the 

educational efforts due to other points of entry. These additional entry points are private 

property, watercraft arriving from other areas in the state or even internationally via Canada. 

The placement of signs on the islands would be kept to a minimum in numbers and size, but 

cannot be totally eliminated. These signs are needed to not only keep the public off of the 

islands but try to maintain the 200 foot buffer around the islands. The buffer is to prevent the 

“take or harassment”, under the Marine Mammal Protection Act of 1972 and the Endangered 

Species Act 1973, of pinniped haulout/pupping sites and other listed wildlife species. Although 

additional signage and information is planned outside the wilderness area, not all boaters would 

be exposed to that information. Therefore, to ensure that all trespassing and other potential 

violations are mitigated signs are necessary. Safety is another reason to keep the public from 

approaching these islands, due to rocky shorelines, submerged hazards, currents and other 

variables.

If action is necessary, proceed to Step 2 to determine the minimum activity.

Step 2: Determine the minimum activity/tools.

Description of Alternatives 

For each alternative, describe what methods and techniques will be used, when the activity will take 

place, where the activity will take place, what mitigation measures are necessary, and the general 

effects to the wilderness resource and character.

Alternative # 1: No Management Activity

Under alternative #1 no management activity whatsoever is conducted in wilderness. Some expected 

results are describe under Step 1 above.

Effects:

 Wilderness Character

“Untrammeled” Repeated trespassing leading to trammeling and introduction of invasive 

species would begin the degradation of the wilderness and increase the disturbance to the 

sensitive wildlife using the islands. 
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Appendix H – Wilderness H-14

“Undeveloped” Maximized. There would be no further installation of signs, but the 

introduction of “home made structures” being brought or built on the island would likely 

increase.

“Natural” Minimized. Invasive species continue to displace native species.

“Outstanding opportunities for solitude or a primitive and unconfined type of recreation” 

Other unique components that reflect the character of this wilderness

 Heritage and Cultural Resources N/A

 Maintaining Traditional Skills N/A

 Special Provisions N/A

 Economic and Time Constraints N/A

 Additional Wilderness-specific Comparison Criteria N/A

 Safety of Visitors, Personnel, and Contractors N/A

 

 Alternative # 2: No Generally Prohibited Uses

Description: 

Sign Placement

Alternative #2 the placement of signs is conducted in wilderness. Some expected results are 

described under Step 1 above.

Effects:

Wilderness Character

“Untrammeled” Maximized. Less trespassing would lead to reduced trammeling and the risk of 

introduction of invasive species. There would also be a reduction of the disturbance to the 

sensitive wildlife using the islands.

“Undeveloped” Minimized. There would be a minimum installation of signs to inform the public 

about the island status and their responsibilities, but the introduction of “home made structures” 

being brought or built on the island could likely be eliminated.

“Natural” Maximized. With the public viewing from an approved distance the invasion of nonnative species could be eliminated from displacing native species.

“Outstanding opportunities for solitude or a primitive and unconfined type of recreation” 

Only Matia Island is open to the public that has any wilderness areas and the limited number of 

signs placed in wilderness will not affect the solitude or primitive wilderness experiences of 

visitors.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-15

 Heritage and Cultural Resources N/A

 Maintaining Traditional Skills N/A

 Special Provisions N/A

 Economic and Time Constraints N/A

 Additional Wilderness-specific Comparison Criteria N/A

Safety of Visitors, Personnel, and Contractors: N/A

Alternative # 3: Installation of Refuge Signs Utilizing Some Generally Prohibited Uses

Description: 

A few generally prohibited uses may be necessary to facilitate installation of signs by the USFWS. In 

order to protect sensitive island habitat, minimize disturbance to wildlife, and for human safety purposes, 

it would be necessary to erect sign structures and the use of some motorized equipment (i.e. post hole 

auger, portable power supply, portable power tools, and chain saw) may be necessary.

Effects:

Wilderness Character

“Untrammeled” – Same as Alternative 2 plus: There is some wildlife disturbance associated with 

installation activities using power supplies and tools. The distance to wildlife and timing are carefully 

considered to minimize impacts to wildlife. Installation and routine maintenance by refuge staff will occur 

only a few days annually resulting in negligible impacts to wilderness values.

“Undeveloped” – Same as Alternative 2 plus: Refuge signs will be limited in number and placed just 

within wilderness boundaries in an effort to minimize development impacts. 

“Natural” – Same as Alternative 2 plus: These signs will result in a minimal negative effect to the 

wilderness viewshed. 

“Outstanding opportunities for solitude or a primitive and unconfined type of recreation” – Only 

Matia Island is open to the public that has any wilderness areas and the limited number of signs placed in 

wilderness will not affect the solitude or primitive wilderness experiences of visitors.

Heritage and Cultural Resources – N/A

Maintaining Traditional Skills – N/A

Special Provisions – N/A

Economic and Time Constraints – N/A
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Appendix H – Wilderness H-16

Additional Wilderness-specific Comparison Criteria – N/A

Safety of Visitors, Personnel, and Contractors – N/A

Step 2 Decision: What is the Minimum Activity?

Selected alternative:

The option selected is Alternative # 3.

Rationale for selecting this alternative (including documentation of safety criterion, if 

appropriate):

Installation of signs identifying refuge islands and informing the public that they are closed to public use 

(except for Matia Island) prevents human trespass and subsequent disturbance of seabirds and marine 

mammals. Use of power equipment will minimize staff presence on-site, thus reducing staff exposure to 

the volatility of the marine environment.

NEPA Compliance and Public Review: This MRA was prepared in association with the Protection 

Island and San Juan Islands National Wildlife Refuges Draft Comprehensive Conservation Plan; San Juan 

Islands Wilderness Plan; and associated Environmental Assessment (CCP/WSP/EA). It was made 

available for public review and comment at the same time as the Draft CCP/WSP/EA. 

List any Wilderness Act Section 4(c) uses approved in this alternative:

1. temporary structure or installation (Signs)

2. motorized equipment (Chain saw, generator, compressor)

Record and report any authorizations of Wilderness Act Section 4(c) uses according to agency 

procedures.

References:

Speich, S.M., and T.R. Wahl. 1989. Catalog of Washington seabird colonies. U.S. Fish and Wildlife 

Service, Service Biological Report 88(6). 510 pp.

USFWS (U.S. Fish and Wildlife Service). 2005a. Regional seabird conservation plan, Pacific Region. 

U.S. Fish and Wildlife Service, Migratory Bird and Habitat Programs. Pacific Region, Portland, OR. 261 

pp.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-17

H.4 Minimum Requirement Analysis – Research, Monitoring, and 

Management

San Juan Islands Wilderness Area

San Juan Islands NWR and Wilderness contain the majority of the seabird nesting colonies and pinniped

haul-out sites in the Northern portion of the Salish Sea and the San Juan Archipelago. Black 

oystercatchers and pigeon guillemot nest along island shore lines. Pelagic, double-crested, and Brandt’s 

cormorants, glaucous–winged and glaucous-winged/western gulls nest at more upland sites and bald 

eagles nest in refuge trees.

Steller and California sea lions haul-out on refuge islands and harbor seals use the islands for pupping and 

hauling-out. Elephant seals have recently used islands in the southern portion of the refuge to breed. The 

Washington Maritime NWR Complex proposes to conduct research, monitoring, and appropriate 

management actions within the San Juan Islands Wilderness. There is a need to determine (1) if this 

action is necessary in wilderness and, (2) if so, what is the minimum required activity (tools and 

techniques).

Research, monitoring, and management actions conducted by the Washington Maritime NWR Complex 

staff and their agents, including Washington Department of Fish and Wildlife, NOAA, universities and 

colleges, contribute to regional, national, and international conservation efforts for these marinedependent species. Access to wilderness areas by USFWS employees or their agents is highly regulated 

and minimized. The refuge wilderness is closed to all public access (except for the wilderness trail on 

Matia Island) to protect sensitive wildlife from disturbance and to prevent trampling and destruction of 

habitats. 

Research and monitoring programs that are not conducted by Refuge staff or their designated agents are 

not covered under this Minimum Requirements Analysis (MRA). These non-Service activities will 

require separate analyses, once specific projects are proposed. Regulatory and informational signage is 

used for public use management. The construction and placement of wilderness signs is addressed in a 

separate MRA. 

Step 1: Determine if any administrative action is necessary.

Briefly describe the situation that may prompt action:

Research and monitoring are essential to document the life-history requirements and needs of seabirds 

and pinnipeds, monitor population trends, determine anthropogenic and natural events that effect the 

populations and develop appropriate management strategies and actions. Failure to conduct adequate 

research and monitoring would leave refuge wildlife populations vulnerable to adverse impacts and 

undetected population declines that may be preventable or mitigated if detected sooner.

Research on refuge lands is inherently valuable to the USFWS because it expands scientific information 

available for resource management decisions. Scientific findings gained through these projects provide 

important information regarding life-history needs of species and species groups. Some research 

proposes to address wildlife conservation issues, such as understanding the causes of reduced or declining 

seabird and/or pinniped populations and addressing response of habitat/wildlife to disturbance from 

public uses adjacent to wilderness. Other research has broader applicability, such as using a suite of 

seabird species as indicators of ocean health conditions, and to document change in the larger marine 

environment and associated impacts associated with climate change and global warming. Projects may be 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-18

species-specific or refuge-specific, or may evaluate the relative contribution of the refuge to larger 

landscape (e.g., ecoregion, region, flyway, national, and international) issues and trends.

The management strategy for San Juan Islands Wilderness is to allow natural processes to occur 

unimpaired by human actions except for the maintenance of the trail on Matia Island and treatment of 

invasive species. Maintenance would include the removal of any vegetation that impacts the use of the 

trail. Monitoring is crucial for early detection and development of management strategies to control these 

invasive species. Invasive mammals that reach the islands can quickly impact nesting birds, destroying 

whole seabird colonies. Invasive plants eliminate native vegetation, alter native flora communities, and 

can eliminate breeding habitat for burrow-nesting seabird species. Since seabirds, pinnipeds, and native 

plants are the primary natural resource components of the San Juan Islands Wilderness, declines or losses 

of populations would significantly reduce the wilderness character and result in the loss of wilderness 

public purposes including scientific, educational, and conservation. A rapid aggressive approach to the 

control or eradication of invasive species is necessary to maintain biological integrity and wilderness 

character. 

To determine if administrative action is necessary, answer questions A-F.

B. Describe Options Outside of Wilderness

Is action necessary within wilderness? Yes

While much of the research and monitoring occurs physically outside of wilderness (e.g., from boats or 

aircraft), the subjects of the research and monitoring are within wilderness. The majority of the seabird 

nesting colonies and pinniped haul-out and pupping sites in Washington State marine waters are National 

Wildlife Refuge lands and wilderness. Opportunities to research or monitor these species outside 

wilderness are extremely limited; therefore conducting this species-specific research on Service lands and 

within wilderness is essential. Currently, the USFWS allows pinniped research by NOAA, WDFW, and 

Cascadia Research Collective (under contract to both), through a Special Use Permit. This research 

includes monitoring of Steller sea lions and elephant seals, radio tagging harbor seals, tracking, and 

retrieval of shed tags, collection of samples for DNA and contaminant analysis, and necropsies. Radio 

receivers are used when tags are installed to ensure working condition and to locate shed tags.

Tools and temporary facilities that might be used to conduct research and monitoring include: remote 

sensing equipment, blinds, temporary access equipment (i.e. ladder), weather station, solar array, 

telemetry equipment.

Detection and monitoring of harmful invasive or non-native plant and animal species is critical to 

accomplish both Refuge and wilderness purposes, goals, and objectives. Although some methods of 

detecting and monitoring these species (e.g., overflights, remote sensing) from outside of the wilderness 

areas exist, these off-site methods may not yield the needed information in a timely or efficient manner. 

Invasive plant and animal control methods from outside wilderness exist (e.g., mechanical and aerial 

spraying, release of biological controls, quarantine protocols), but these methods may unnecessarily 

trammel the wilderness area and other non-target habitats (e.g., pesticide drifting within wilderness and 

resulting death of target and non-target organisms), resulting in a loss of naturalness. The USFWS cannot 

meet its affirmative responsibilities under E.O. 13112 to monitor for, detect and rapidly control, or 

research invasive species solely from outside the wilderness area, nor can native ecosystems already 

impacted by invasive species be solely restored from outside the wilderness area.

B. Describe Valid Existing Rights or Special Provisions of Wilderness Legislation
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Appendix H – Wilderness H-19

Is action necessary to satisfy valid existing rights or a special provision in wilderness legislation (the 

Wilderness Act of 1964 or subsequent wilderness laws) that allows consideration of the Section 4(c) 

prohibited uses? Yes 

Special Provision – from The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) Section 4(b): 

Except as otherwise provided in this Act, each agency administering any area designated as wilderness 

shall be responsible for preserving the wilderness character of the area and shall so administer such area 

for such other purposes for which it may have been established as also to preserve its wilderness 

character. Except as otherwise provided in this Act, wilderness areas shall be devoted to the public 

purposes of recreational, scientific, educational, conservation, and historical use.

Prohibited Uses – from The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) Section 4(c): 

“Except as necessary to meet minimum requirements for the administration of the area for the purpose of 

this Act (including measures required in emergencies involving the health and safety of persons within 

the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, 

no landing of aircraft, no other form of mechanical transport, and no structure or installation within any 

such area.” 

C. Describe Requirements of Other Legislation

Is action necessary to meet the requirements of other laws? Yes

The National Wildlife Refuge System Administration Act of 1966, as amended, in section 4(a)(4)(B) 

directs the FWS to (1) provide for the conservation of fish, wildlife, and plants, and their habitats within 

the NWRS; (2) ensure the biological integrity, diversity, and environmental health of the NWRS are 

maintained (see 610 FW 3); and (3) monitor the status and trends of fish, wildlife, and plants in each 

refuge. These requirements cannot be fully met through conducting research and monitoring actions 

outside the proposed wilderness area.

Research is a specialized use (603 FW1) and, therefore, it is not considered a priority public use by 

NWRS policy. However, two provisions of the National Wildlife Refuge Improvement Act of 1997 are 

to “maintain biological integrity, diversity and environmental health” and to conduct “inventory and 

monitoring.” 

The USFWS and NOAA Fisheries, along with all other federal agencies, have affirmative responsibilities 

under the Endangered Species Act of 1973 to conserve endangered and threatened species at Section 

2(c)(1). Federal agencies are also responsible for cooperating with the States to the maximum extent 

practicable in conserving listed species, under Section 6(a). The USFWS currently authorizes NOAA and 

WDFW, acting as an agent of the USFWS and following the conditions of a Special Use Permit, to enter 

the Refuge wilderness area to conduct research on threatened Steller sea lions and non listed harbor and 

elephant seals. 

Executive Order 13112 directs federal agencies to: “subject to the availability of appropriations, and 

within Administration budgetary limits, use relevant programs and authorities to: (i) prevent the 

introduction of invasive species; (ii) detect and respond rapidly to and control populations of such species 

in a cost-effective and environmentally sound manner; (iii) monitor invasive species populations 

accurately and reliably; (iv) provide for restoration of native species and habitat conditions in ecosystems 

that have been invaded; (v) conduct research on invasive species and develop technologies to prevent 

introduction and provide for environmentally sound control of invasive species; and (vi) promote public 

education on invasive species and the means to address them”.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-20

D. Describe Other Guidance 

Is action necessary to conform to direction contained in agency policy, unit and wilderness management 

plans, species recovery plans, or agreements with tribal, state and local governments or other federal 

agencies? Yes

Currently refuge staff are not actively conducting research, however it is anticipated that in the next 15 

years there would be additional seabird research related to the recently completed Pacific Region Seabird 

Conservation Plan (USFWS 2005a). The Service currently authorizes NOAA and WDFW, via a Special 

Use Permit, to enter the refuge wilderness area to conduct research on threatened Steller sea lions and 

non-listed harbor and elephant seals. 

The USFWS’s Research and Management Studies policy (4 RM 6) and Appropriate Refuge Uses policy 

(603 FW1.10D(4)) indicate priority for scientific investigatory studies that contribute to the enhancement, 

protection, use, preservation, and management of native wildlife populations and their habitat as well as 

their natural diversity. Projects that contribute to refuge-specific and/or wilderness management, where 

applicable, would be given a higher priority over other requests. 

E. Wilderness Character 

Is action necessary to preserve one or more of the qualities of wilderness character including 

untrammeled, undeveloped, natural, outstanding opportunities for solitude or a primitive and unconfined 

type of recreation, or unique components that reflect the character of this wilderness area?

Untrammeled: Yes

San Juan Islands Wilderness values include supporting nesting seabirds and bald eagles and hundreds of 

pinnipeds, and functioning as a botanical reserve for native plants. Protecting the untrammeled character 

of these wilderness areas requires protecting the flora and fauna found within them, and the ecological 

system in which these species and communities exist. Introduced plant species pose serious ecological 

problems, forming vast monospecific zones, lowering biodiversity, outcompeting native plants, and 

eliminating habitat for nesting seabird species. Mammalian predators have the potential for devastating 

impacts to nesting seabirds within San Juan Islands Wilderness. The Complex staff has concluded that 

maintenance of the untrammeled quality necessitates removal of selected plants and animals when it is 

determined that their presence is negatively impacting the wilderness ecological system and processes in a 

manner that will cause irreversible harm to the native species. Initiation of management actions to 

control, and where possible eliminate, invasive species requires monitoring to document infestations and 

evaluate success of control actions. 

Undeveloped: Yes

The undeveloped refuge rocks, reefs, and islands within San Juan Islands Wilderness provide a dramatic 

natural setting in the San Juan Archipelago. Hundreds of thousands of annual visitors to the San Juan 

Archipelago appreciate the scenic natural beauty and the ecological values associated with the abundant 

marine wildlife populations these wilderness areas protect. All of San Juan Islands Wilderness is closed 

to public access (except for the wilderness trail on Matia Island) at all times to prevent disturbance to 

sensitive seabirds and pinnipeds and to prevent destruction of native plants and habitats. 

In some cases, refuge management or research activities may require the use of temporary structures or 

equipment to prevent impacts to the wildlife and habitat while conducting the activities. These actions 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-21

have the potential to degrade the undeveloped quality because they involve generally prohibited uses; 

however, the desired information is essential and cannot be obtained from a location outside of 

wilderness, and the methods used are the minimum tool necessary to accomplish the objective safely and 

successfully. The impossibility of conducting the specific research or management activity by another 

means renders it necessary to utilize these tools to preserve the undeveloped quality of the wilderness 

areas.

Natural: Yes

Many of the rocks and islands within San Juan Islands Wilderness are located immediately adjacent to the 

larger islands in the Archipelago, an area receiving ever-increasing pressure for residential housing and 

commercial development. Monitoring the wilderness ecological systems (plant and animal species and 

communities) and evaluating impacts from internal and external forces is critical for attempting to 

maintain conditions substantially free from the effects of modern civilization. Because the “natural” 

quality also refers to the abundance, distribution, or number of invasive non-indigenous species, there is a 

need to monitor the natural quality of these wilderness areas with respect to invasive species, and develop 

management strategies to control them. Control of plant and animal invasive species, with the intent of 

manipulating habitats and correcting conditions resulting from human influence, is necessary to preserve 

the natural quality of these wilderness areas. 

Outstanding opportunities for solitude or a primitive and unconfined type of recreation:

Yes

Matia Island is open to the public via a State operated public use site. A single trail system from this site 

allows the public to access a small part of the wilderness habitat. All the other rocks, reefs, and islands 

within the San Juan Islands Wilderness areas are closed to public entry to protect sensitive wildlife and 

habitat.

Other unique components that reflect the character of this wilderness: No

F. Describe Effects to the Public Purposes of Wilderness

Is action necessary to support one or more of the public purposes for wilderness (as stated in Section 4(b) 

of the Wilderness Act) of recreation, scenic, scientific, education, conservation, and historical use?

Recreation: Yes

Monitoring the impacts of public use at Matia Island will be needed to ensure that the area retains its 

wilderness character and values.

Scenic: Yes

Control of invasive plant and animal species and the subsequent preservation of seabird and pinniped 

colonies will maintain the scenic value of the wilderness.

Scientific: Yes

Scientific research is necessary to support management actions to protect wilderness values and achieve 

refuge purposes. Examples include studying health and life-history parameters of threatened Steller sea 
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Appendix H – Wilderness H-22

lions, development of non-intrusive survey methods for nesting seabirds, and study of best control 

methods for pest plants and animals. Research supplies necessary information to determine population 

status and trend for sensitive and listed species. Results of the research project will be published and 

shared with the scientific community.

Education: Yes:

Education about the sensitivity of the wildlife and habitats within these wilderness areas is necessary for 

their continued protection and to garner support to further their protection and management. For 

example, education about the effects of disturbance and invasive species on these wilderness resources, 

information gained through research and monitoring and encapsulated in regulatory and interpretive 

signage, may encourage the public to change their behaviors while visiting the Archipelago and cause 

them to be less likely to trespass on rocks and islands. The results of research projects will be 

incorporated into the Complex’s environmental education and interpretation program.

Conservation: Yes

This area cannot be successfully conserved, including its wilderness values, without administrative action 

within the wilderness area. The USFWS cannot fully meet its affirmative responsibilities for endangered 

and threatened species, invasive species, refuge purposes, wilderness management objectives, and the 

NWRS mission without monitoring impacts of research, controlling invasive species to reduce 

trammeling and assisting in endangered species recovery to recover naturalness. 

Historical use: No 

Step 1 Decision: Is any administrative action necessary in wilderness? Yes

Research, monitoring, and management of vulnerable refuge wildlife and habitats are actions necessary to 

achieve and document progress towards fulfillment of the purposes of these refuges as “. . . a preserve and 

breeding ground for native birds and animals”; “. . . as a refuge and breeding ground for wild birds and 

animals”; maintain the wilderness wildlife values on the refuges; and help to fulfill the mission of the 

National Wildlife Refuge System. 

If action is necessary, proceed to Step 2 to determine the minimum activity.

Step 2: Determine the minimum activity/tools.

Description of Alternatives 

For each alternative, describe what methods and techniques will be used, when the activity will take 

place, where the activity will take place, what mitigation measures are necessary, and the general 

effects to the wilderness resource and character.

Alternative # 1: No Management Activity
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Appendix H – Wilderness H-23

Under alternative #1 no management activity whatsoever is conducted in wilderness. Some expected 

results are describe under Step 1 above.

 

 Alternative # 2: No Generally Prohibited Uses

Description: 

Research, Monitoring and Management

Alternative #2 would involve the elimination of low level aerial surveys, and temporary facilities and 

equipment used for research and monitoring. 

Effects:

Wilderness Character

“Untrammeled”– Minimal human manipulation. Many rocks and islands are difficult to access for 

monitoring and invasive species control. Without access and management to control invasive species, the 

unchecked increase in invasives is likely to negatively impact the wilderness ecological system and 

processes in a manner that will cause irreversible harm to the native species. 

“Undeveloped” – Minimized. There would be no temporary placement of facilities or motorized or 

mechanical equipment. The ability of the USFWS to conduct research, monitoring, and management 

activities would be greatly diminished through reduction of tools (i.e. remote sensing equipment, blinds, 

temporary access equipment (i.e. ladder), weather station, and telemetry equipment). 

“Natural” – Minimized. Wildlife disturbance from USFWS activities would be less than in Alternative 

#3. The ability of the USFWS to conduct research, monitoring, and management activities would be 

diminished, threatening the integrity and biological diversity of the refuges. Information gathered would 

be limited and the ability to effectively monitor and document seabird and pinniped population trends 

would be compromised. Undetected wildlife population declines and the subsequent failure to reverse 

those declines would negatively impact the wildlife and other values of the refuge wilderness areas. 

“Outstanding opportunities for solitude or a primitive and unconfined type of recreation” – Matia 

Island retains its current public use trail. All other areas remain closed to public entry.

Heritage and Cultural Resources – N/A

Maintaining Traditional Skills - N/A

Special Provisions – N/A

Economic and Time Constraints – N/A

Additional Wilderness-specific Comparison Criteria – N/A

Safety of Visitors, Personnel, and Contractors – N/A
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-24

 Alternative # 3: Research, Monitoring, and Management Utilizing Some Generally Prohibited 

Uses

Description: 

Research

Refuge Complex staff is not currently conducting independent research within the refuge wilderness 

areas, primarily due to limited staff and funding. It is anticipated that in the next 15 years increases in 

staff and funding will allow refuge staff to conduct important research projects on the highest priority 

species and issues. Research being conducted by refuge agents includes threatened Steller sea lion and 

other pinniped studies by NOAA Fisheries and WDFW, and black oystercatcher research led by WDFW. 

These research projects are controlled through Special Use Permits that contain various restrictions and 

stipulations to ensure that impacts to wildlife and habitats are kept to a minimum. The following is a set 

of criteria that will be used, in part, to determine if research will be permitted to occur within refuge 

wilderness areas.

Research Criteria:

• Research that focuses on conservation, management, and protection of refuge species of concern such 

as seabirds and pinnipeds, control or eradication of invasive plants and animals, and research that 

provides an understanding of island ecology, ecosystem function and climate change impacts.

• Research will be conducted by USFWS employees or their agents. 

• Prohibited uses, per Section 4(c) of the Wilderness Act, will not occur unless they are necessary to 

meet minimum requirements for the administration of these areas.

• Disturbance to wildlife will be minimized and not adversely affect populations.

The Refuge Manager occasionally receives requests from universities and others to conduct additional 

research within the refuge wilderness areas. Each of these situations is considered on a case-by-case basis 

and is evaluated to determine expected benefits of the research to knowledge and/or management of 

refuge flora and fauna as well as possible impacts to the resources, habitats and wilderness character 

resulting from research activities. This type of research is covered under a Compatibility Determination 

(see Appendix J) and prospective non-USFWS researchers will be required to prepare a separate MRA for 

proposed activities within the wilderness areas. The Wilderness Act does not allow outside researchers 

and others who are not direct agents of the USFWS to gain exemptions to the prohibited uses provisions 

(Section 4(c) of the Act).

Several generally prohibited uses may be necessary to facilitate critical research being conducted by 

agents of the USFWS. In order to protect sensitive island habitat, minimize disturbance to wildlife, and 

for human safety purposes, it may occasionally be necessary to erect temporary unobtrusive structures 

such as a blinds, remote sensing and monitoring equpiment, etc., and use of chain saw and power auger 

may be necessary.

Monitoring

Monitoring is conducted by refuge staff and refuge agents in order to determine wildlife population status 

and trends; document wildlife disturbances; document the occurrences of invasive species; and evaluate 

the results of control actions. Most monitoring occurs from off-refuge and outside of the wilderness area 

from boats. This is done to minimize disturbance to wildlife and to the wilderness area. Seabird and 

pinniped trend surveys are conducted using fixed-wing and rotary-winged aircraft generally at an altitude 

of 1,000 feet or more, but occasionally as low as 500 feet one to three times a year. On some occasions, 

refuge staff and agents will enter the refuge wilderness area to obtain data on seabirds, pinnipeds and 

other wildlife and/or survey for invasive species. The wilderness rocks, reefs, and islands are accessed 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-25

from small boats at sea. At some locations, effective monitoring can require utilization of several 

generally prohibited uses including construction of temporary unobtrusive structures such as a boardwalk 

or remote video monitoring system. Use of some motorized equipment such as chain saw and power 

auger may be necessary. 

In all cases the minimum activity and tools will be used to accomplish the work in fulfilling the purposes 

of the refuge and to protect the wilderness character and value. Currently, only a minimum amount of 

monitoring is being conducted by the refuge due to limited staff and funding. It is anticipated that within 

15 years of the completion of the Comprehensive Conservation Plan increases in staff and funding will 

allow refuge staff to initiate and maintain important seabird monitoring projects in accordance with the 

Regional Seabird Conservation Plan (USFWS 2005a) and monitoring of the highest priority species.

Management

The management strategy for San Juan Islands Wilderness is to allow natural processes to occur 

unimpaired by human actions. The exception to this management strategy is the treatment of invasive 

species. Refuge staff and agents will conduct a rapid and aggressive approach to control or eradicate 

invasive plants and animals. Invasive mammals can quickly eliminate entire colonies of nesting seabirds. 

Invasive plants eliminate native vegetation and can alter native flora communities. The spread of some 

invasive plants such as ice plant (Carpobrotus chilensis) can eliminate breeding habitat for burrownesting seabird species. 

Invasive plant and non-native predator control or eradication will be accomplished using integrated pest 

management techniques. Control of native mammalian predators will be undertaken according to a yet to 

be developed step-down management plan. No generally prohibited tools will be used to control invasive 

species within these wilderness areas. Chain saws maybe used to maintain trail on Matia Island

Effects:

Wilderness Character

“Untrammeled” – There is some wildlife disturbance associated with permitted research and monitoring 

activities and occasional unauthorized public entry into the wilderness. The distance to wildlife, timing, 

and frequency of efforts are all carefully considered to minimize impacts to wildlife while maximizing the 

data obtained. 

“Undeveloped” – The majority of the monitoring is conducted with the observers located outside of the 

wilderness area viewing from small boats. During the infrequent visits to some of the rocks and islands in 

the wilderness area for monitoring and/or research purposes wildlife disturbance is minimized, sensitive 

habitats are protected and no permanent structures or equipment are erected. In a very limited number of 

cases it may be necessary to erect temporary facilities and equipment such as blinds to prevent 

disturbance of seabird nesting habitat during research activities or to install remote sensing equipment. 

Used and temporary facilities will minimize impacts to the refuge and to the wildlife, protect wilderness 

character, and leave no trace once removed. Temporary facilities and equipment will be installed prior to 

the breeding season or research project and removed immediately after the breeding season or completion 

of the research project. 

“Natural” – Minimized. Wildlife disturbance from USFWS activities would be slightly greater than in 

Alternative #2. The ability of the USFWS to conduct research, monitoring, and management activities 

would be enhanced. Seabird, pinniped, and invasive species population trends would be more accurately 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-26

tracked. Development of management options to reverse declining wildlife populations or increasing 

invasive species populations would be developed thus maintaining the natural quality. 

“Outstanding opportunities for solitude or a primitive and unconfined type of recreation” – The 

rocks, reefs, and islands of the San Juan Islands wilderness area are not open to the public except for a 1.2 

mile wilderness trail on Matia Island; however, they are extremely important to the recreational experience 

of Archipelago residents and visitors who view these areas from boats or Washington State Ferries. 

Because the duration and frequency of research, monitoring, and management efforts are limited; and 

because most of the refuge and associated wilderness area are closed to public use, the impacts to solitude 

are negligible. 

Heritage and Cultural Resources – N/A

Maintaining Traditional Skills – N/A

Special Provisions – N/A

Economic and Time Constraints – N/A

Additional Wilderness-specific Comparison Criteria – N/A

Safety of Visitors, Personnel, and Contractors – N/A

Step 2 Decision: What is the Minimum Activity?

Selected alternative:

The option selected is Alternative # 3.

Rationale for selecting this alternative (including documentation of safety criterion, if 

appropriate):

Research, monitoring and management of the refuge wilderness rocks, reefs, and islands require 

occasionally accessing these areas approximately ten times per year. Access is from small boats at sea. 

Observations conducted from the water in motorized boats outside of the wilderness areas, infrequent 

aerial surveys above the wilderness, and erection of unobtrusive temporary structures and equipment are 

essential tools needed to conduct research, monitoring, and management activities in support of the 

refuges. The minor amount of wildlife disturbance caused by research, monitoring, and management is 

minimal compared to the importance of collecting data that directly contributes to species conservation. 

If conducted only when absolutely necessary, these activities are all considered the minimum tools 

needed to accomplish refuge purposes including wilderness values. They preserve wilderness character 

and only minimally impact human solitude while benefiting the wildlife values of the wilderness. 

NEPA Compliance and Public Review: This MRA was prepared in association with the Protection 

Island and San Juan Islands National Wildlife Refuges Draft Comprehensive Conservation Plan; San Juan 

Islands Wilderness Plan; and associated Environmental Assessment (CCP/WSP/EA). It was made 

available for public review and comment at the same time as the Draft CCP/WSP/EA. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix H – Wilderness H-27

List any Wilderness Act Section 4(c) uses approved in this alternative:

3. temporary structure or installation (Blinds, weather station, ladders, remote sensing 

equipment and solar array)

4. motorized equipment (Chain saw and power auger)

Record and report any authorizations of Wilderness Act Section 4(c) uses according to agency 

procedures.

References:

National Marine Fisheries Service. 2008. Recovery plan for the Steller sea lion (Eumetopias jubatus). 

Revision. National Marine Fisheries Service. Silver Spring, MD. 325 pp.

Speich, S.M., and T.R. Wahl. 1989. Catalog of Washington seabird colonies. U.S. Fish and Wildlife 

Service, Service Biological Report 88(6). 510 pp.

USFWS (U.S. Fish and Wildlife Service). 2005a. Regional seabird conservation plan, Pacific Region. 

U.S. Fish and Wildlife Service, Migratory Bird and Habitat Programs. Pacific Region, Portland, OR. 261 

pp.
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Appendix H – Appropriateness Findings I-1

Appendix I. Appropriateness Findings

I. Introduction

Under the Appropriate Refuge Uses Policy, 603 FW 1, (2006) refuge managers are directed to determine 

if a new or existing public use is an appropriate refuge use. If an existing use is not appropriate, the refuge 

manager is directed to modify the use to make it appropriate or terminate it, as expeditiously as 

practicable. If a new use is not appropriate, the refuge manager will deny the use without determining 

compatibility. If a use is determined to be appropriate, then a compatibility determination should be 

developed to determine whether the use can be allowed.

An “appropriate use” must meet at least one of the following three conditions.

• The use is a wildlife-dependent recreational use as identified in the Refuge Improvement Act.

• The use involves the take of fish and wildlife under State regulations.

• The use has been found to be appropriate as specified in section 1.11 of the policy and documented on 

FWS Form 3-2319.

During the CCP process the refuge manager reviewed all existing and proposed refuge uses on Protection 

Island and the San Juan Islands Refuges that are associated with the Preferred Alternative (Alternative B). 

Documentation of appropriateness findings for wildlife-dependent uses is not included in this Appendix 

because wildlife-dependent uses are appropriate by definition. They are however evaluated for 

compatibility in the following Appendix J. All other refuge uses were evaluated using the criteria

described in policy and listed on FWS Form 3-2319. The table below shows the uses evaluated and 

appropriateness findings made by the refuge manager. Additional documentation is included in this 

appendix for each use identified in the table. 

Refuge Refuge Use Appropriate Page 

Protection Island Research Yes I-2

San Juan Islands Research Yes I-4

San Juan Islands Camping Yes I-6

San Juan Islands Pets No I-8
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Appendix H – Appropriateness Findings I-2

Finding of Appropriateness of a Refuge Use

Refuge Name: _______Protection Island________________________________

Use: ________Research_________________________________________________

This exhibit is not required for wildlife-dependent recreational uses, forms of take regulated by the State, or uses 

already described in a refuge CCP or step-down management plan approved after October 9, 1997.

Decision criteria: YES NO

(a) Do we have jurisdiction over the use? 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? 

(d) Is the use consistent with public safety? 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document?



(f) Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed?



(g) Is the use manageable within available budget and staff? 

(h) Will this be manageable in the future within existing resources? 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or 

cultural resources, or is the use beneficial to the refuge’s natural or cultural resources?



(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses or 

reducing the potential to provide quality (see section 1.6D. for description), compatible, wildlifedependent recreation into the future? 



Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot 

control the use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be 

found appropriate. If the answer is “no” to any of the other questions above, we will generally not allow the use.

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager 

must justify the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is:

Not Appropriate_____ Appropriate__

Refuge Manager:______________________________________ Date:_____________________

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use.

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence.

If found to be Appropriate, the refuge supervisor must sign concurrence.

Refuge Supervisor:_____________________________________ Date:______________________

A compatibility determination is required before the use may be allowed. 

FWS Form 3-2319 02/06
Protection Island and San Juan Islands National Wildlife Refuges Administrative Draft CCP/WSP/EA

Appendix H – Appropriateness Findings I-3

Finding of Appropriateness of a Refuge Use: Attachment

Refuge Name: _______Protection Island________________________________

Use: ________Research_________________________________________________

Supplemental Information

Description of Use: 

The Washington Maritime NWR Complex receives periodic requests from non-USFWS entities (e.g., 

universities, state agencies, other federal agencies, NGOs) to conduct research, scientific collecting, and 

surveys on Protection Island NWR. The Refuge Manager currently has the authority to issue research 

permits. (603 FW1) 

Projects can involve a broad range of natural resource issues including habitat use and life-history 

requirements for specific species/species groups, practical methods for habitat restoration, extent and 

severity of environmental contaminants, techniques to control or eradicate pest species, effects of climate 

change on environmental conditions and associated habitat/wildlife response, modeling of wildlife 

populations, and assessing response of habitat/wildlife to disturbance. Projects may be species specific, 

Refuge-specific, or evaluate the relative contribution of the Refuge to larger landscape (e.g., ecoregion, 

region, flyway, national, international) issues and trends. The USFWS’s Research and Management 

Studies (4 RM 6) and Appropriate Refuge Uses policies (603 FW1.10D(4)) indicate priority for scientific 

investigatory studies that contribute to the enhancement, protection, use, preservation, and management of 

native wildlife populations and their habitat as well as their natural diversity.

Facilities supporting research on Protection Island NWR include a 468 square foot Refuge office, 768 

square foot research station/ bunkhouse, 120 square foot Research storage/ shop building, marina and 2 

floating piers. In addition there is a 140 foot well, 33,000 gallon water tower, and 10,200 cubic foot water 

distribution system.

Justification: 

(c) Is the use consistent with applicable Executive orders and Department and Service policies?

Research is consistent with Service policy. Protections Island’s Refuge founding purpose includes the 

following provision; “... to provide for scientific research...”. In addition, two provisions of the National 

Wildlife Refuge Improvement Act of 1997 directly support research within the Refuge; to “maintain 

biological integrity, diversity and environmental health” and to conduct “inventory and monitoring.”. 

(i) Does the use contribute to the public’s understanding and appreciation of the Refuge’s natural or 

cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources?

Research not only serves to further the user’s knowledge and understanding of Protection Island NWR, it 

also aids in managing Refuge resources. Seabird and pinniped conservation and management within the 

Refuge are based upon best available scientific information from research combined with long-term 

monitoring. Some research is used to address specific wildlife conservation questions, such as 

understanding the causes of reduced or declining seabird and/or pinniped populations. Other research has 

broader applicability, such as using a suite of seabird species as indicators of ocean health conditions, and 

to document change in the larger marine environment and associated impacts associated with climate 

change and global warming. 
4

Finding of Appropriateness of a Refuge Use

Refuge Name: _______San Juan Islands NWR________________________

Use: ________Research_________________________________________________

This exhibit is not required for wildlife-dependent recreational uses, forms of take regulated by the State, or uses 

already described in a refuge CCP or step-down management plan approved after October 9, 1997.

Decision criteria: YES NO

(a) Do we have jurisdiction over the use? 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? 

(d) Is the use consistent with public safety? 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document?



(f) Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed?



(g) Is the use manageable within available budget and staff? 

(h) Will this be manageable in the future within existing resources? 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or 

cultural resources, or is the use beneficial to the refuge’s natural or cultural resources?



(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses or 

reducing the potential to provide quality (see section 1.6D. for description), compatible, wildlifedependent recreation into the future? 



Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot 

control the use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be 

found appropriate. If the answer is “no” to any of the other questions above, we will generally not allow the use.

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager 

must justify the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is:

Not Appropriate_____ Appropriate_____

Refuge Manager:______________________________________ Date:_____________________

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use.

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence.

If found to be Appropriate, the refuge supervisor must sign concurrence.

Refuge Supervisor:_____________________________________Date:______________________

A compatibility determination is required before the use may be allowed.

FWS Form 3-2319 02/06
5

Finding of Appropriateness of a Refuge Use: Attachment

Refuge Name: _______San Juan Islands________________________________

Use: ________Research_________________________________________________

Supplemental Information

Description of Use: 

The Washington Maritime NWR Complex receives periodic requests from non-USFWS entities (e.g.,

universities, state agencies, other federal agencies, NGOs) to conduct research, scientific collecting, and 

surveys on Refuge lands within the San Juan Islands NWR. The Refuge Manager currently has the 

authority to issue research permits. (603 FW1)

Projects can involve a wide range of natural and cultural resource as well as public-use management 

issues including habitat use and life-history requirements for specific species/species groups, practical 

methods for habitat restoration, extent and severity of environmental contaminants, techniques to control 

or eradicate pest species, effects of climate change on environmental conditions and associated 

habitat/wildlife response, identification and analyses of paleontological specimens, wilderness character, 

modeling of wildlife populations, and assessing response of habitat/wildlife to disturbance from public 

uses. Projects may be species specific, Refuge-specific, or evaluate the relative contribution of the Refuge 

to larger landscape (e.g., ecoregion, region, flyway, national, international) issues and trends. The 

USFWS’s Research and Management Studies (4 RM 6) and Appropriate Refuge Uses policies (603 

FW1.10D(4)) indicate priority for scientific investigatory studies that contribute to the enhancement, 

protection, use, preservation, and management of native wildlife populations and their habitat as well as 

their natural diversity.

Justification: 

(c) Is the use consistent with applicable Executive orders and Department and Service policies?

Research is consistent with Service policy. Two provisions of the National Wildlife Refuge 

Improvement Act of 1997 are to “maintain biological integrity, diversity and environmental 

health” and to conduct “inventory and monitoring.” These provisions support Refuge research. 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or 

cultural resources, or is the use beneficial to the refuge’s natural or cultural resources?

Research not only serves to further the user’s knowledge and understanding of the Refuge, it also aids in 

managing Refuge resources. Wildlife and habitat conservation and management within the Refuge are 

based upon best available scientific information from research combined with long-term monitoring. 

Some research is used to address specific wildlife conservation questions, such as understanding the 

causes of reduced or declining seabird and/or pinniped populations and development of tools and 

techniques to aid recovery of threatened or endangered species. Other research has broader applicability, 

such as using a suite of seabird species as indicators of ocean health conditions, and to document change 

in the larger marine environment and associated impacts associated with climate change and global 

warming. 
6

Finding of Appropriateness of a Refuge Use

Refuge Name: _______ San Juan Islands NWR ________________________

Use: ________Camping_________________________________________________

This exhibit is not required for wildlife-dependent recreational uses, forms of take regulated by the State, or uses 

already described in a refuge CCP or step-down management plan approved after October 9, 1997.

Decision criteria: YES NO

(a) Do we have jurisdiction over the use? 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? 

(d) Is the use consistent with public safety? 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document?



(f) Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed?



(g) Is the use manageable within available budget and staff? 

(h) Will this be manageable in the future within existing resources? 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or 

cultural resources, or is the use beneficial to the refuge’s natural or cultural resources?



(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D. for description), compatible, wildlifedependent recreation into the future? 



Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot 

control the use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be

found appropriate. If the answer is “no” to any of the other questions above, we will generally not allow the use.

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No __

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager 

must justify the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is:

Not Appropriate_____ Appropriate_____

Refuge Manager:______________________________________Date:_____________________

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use.

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence.

If found to be Appropriate, the refuge supervisor must sign concurrence.

Refuge Supervisor:_____________________________________Date:______________________

A compatibility determination is required before the use may be allowed.

FWS Form 3-2319 02/06
7

Finding of Appropriateness of a Refuge Use: Attachment

Refuge Name: _______ San Juan Islands NWR ________________________

Use: ________Camping_________________________________________________

Supplemental Information

Description of Use:

Currently Matia Island has 6 primitive campsites and Turn Island has 13. All camping related facilities 

are managed by the Washington State Parks and Recreation Commission. Under the preferred alternative 

Matia would maintain all 6 sites and Turn would have 8 sites. 

Camping would be allowed only by persons arriving by non-motorized (human powered) vessels and a

camping reservation system would be initiated. Pets and open fires would be prohibited on both islands

however visitors could continue to use liquid fuel camp stoves. Through an agreement with the Service, 

the State Parks and Recreation Commission would continue to manage the camping program including 

collecting fees.

Justification: 

(d) Is the use consistent with public safety?

Due to their remote locations, visitors who travel to these refuge islands by human powered craft may be 

afforded safe refuge to rest, and to allow wind, currents, and inclement weather to abate. Because such 

vessels travel slower than motor powered vessels and have other mobility constraints, these visitors 

require more time to reach these Refuge units, particularly Matia Island. Without the ability to camp 

overnight such visitors may simply not have enough time to reach the islands and then safely reach 

another location before sunset. Thus, these camping sites must be maintained in order to provide this 

recreational opportunity while protecting public safety.

(i) Does the use contribute to the public’s understanding and appreciation of the Refuge’s natural or 

cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources?

Camping affords visitors a unique opportunity to experience wildlife at times when animals are 

particularly active such as dawn and dusk, and to listen to the sounds of wildlife at night. Such 

experiences support the priority public uses of wildlife observation, photography and environmental

education and foster a greater appreciation and understanding of Refuge’s wildlife resources. For 

example, due to its centralized location, Turn Island is an ideally suited staging area for multi-day human 

powered vessel excursions throughout the San Juan Archipelago. Such events promote wildlife dependant 

recreation throughout the geographically separated Refuge units fostering a greater understanding and 

appreciation of Refuge resources. Motorized vessels on the other hand do not have the same travel 

limitations and have other nearby camping opportunities. The opportunity to engage in several priority 

public uses provided through this type of camping experience would outweigh any anticipated negative 

impacts associated with offering this experience.
8

Finding of Appropriateness of a Refuge Use

Refuge Name: _______ San Juan Islands NWR ________________

Use: ________Pets_________________________________________________

This exhibit is not required for wildlife-dependent recreational uses, forms of take regulated by the State, or uses 

already described in a refuge CCP or step-down management plan approved after October 9, 1997.

Decision criteria: YES NO

(a) Do we have jurisdiction over the use? 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? 

(d) Is the use consistent with public safety? 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document?



(f) Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed?



(g) Is the use manageable within available budget and staff? 

(h) Will this be manageable in the future within existing resources? 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or 

cultural resources, or is the use beneficial to the refuge’s natural or cultural resources?



(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D. for description), compatible, wildlifedependent recreation into the future? 



Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot 

control the use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be 

found appropriate. If the answer is “no” to any of the other questions above, we will generally not allow the use.

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No 

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager 

must justify the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is:

Not Appropriate_____ Appropriate_____

Refuge Manager:______________________________________Date:_____________________

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use.

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence.

If found to be Appropriate, the refuge supervisor must sign concurrence.

Refuge Supervisor:_____________________________________Date:______________________

A compatibility determination is required before the use may be allowed.

FWS Form 3-2319 02/06
9

Finding of Appropriateness of a Refuge Use: Attachment

Refuge Name: _______ San Juan Islands NWR ________________________

Use: ________Pets_________________________________________________

Supplemental Information

Description of Use: 

Currently pets are allowed on leashes in the campground areas on both Matia and Turn Islands. However, 

visitors sometimes allow pets to run free in the campgrounds and in areas that are off limits to domestic 

animals. 

Allowing pets to enter Refuge units in the San Juan Islands has been determined not to be appropriate. 

Justification: 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)?

(c) Is the use consistent with applicable Executive orders and Department and Service policies?

The use does not comply with Federal regulations and is inconsistent with Service policy. The presence of 

pets directly results in an absence of wildlife and is at odds with the establishing purpose of the Refuge. In 

addition, allowing pets to enter and roam within a National Wildlife Refuge is a violation of 50 CFR 

26.21 (b).

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses or 

reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), compatible, 

wildlife-dependent recreation into the future?

The use cannot be accommodated without negatively impacting wildlife and impairing or eliminating

wildlife viewing opportunities. Studies indicate that wildlife exhibit a greater response from disturbance

by dogs than from disturbance by pedestrians (MacArthur et al. 1982; Hoopes 1993). In the case of birds, 

the presence of dogs may flush incubating birds from nests (Yalden and Yalden 1990), disrupt breeding 

displays (Baydack 1986), disrupt foraging activity in shorebirds (Hoopes 1993), and disturb roosting 

activity in ducks (Keller 1991). Many of these authors indicated that dogs with people, dogs on- leash, or 

loose dogs provoked the most pronounced disturbance reactions from their study animals.

Baydack, R. K. 1986. Sharp-tailed grouse response to lek disturbance in the Carberry Sand Hills of 

 Manitoba. Colorado State University, Fort Collins, Colorado

Hoopes, E. M.1993. Relationships between human recreation and piping plover foraging ecology and 

 chick survival. Thesis, University of Massachusetts, Amherst, Massachusetts

Keller, V. 1991 Effects of human disturbance on eider ducklings Somateria mollissima in estuarine 

 habitat in Scotland. Biological Conservation 58: 213-228

MacArthur, R. A., V. Geist, R. H. Johnston. 1982. Cardiac and behavioral responses of mountain sheep to 

 human disturbance. Journal of Wildlife Management 46: 351-358

Yalden, P. E., and D. W. Yalden. 1990. Recreational disturbance of breeding golden plovers Pluvialus 

 apricarius. Biol. Conserve. 51: 243-262
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-1

Appendix J. Compatibility Determinations

J. Introduction

Compatibility is a tool refuge managers use to ensure that recreational and other uses do not 

interfere with wildlife conservation - the primary focus of refuges. Under the Compatibility 

policy 603 FW 2 (2000), refuge managers are directed to determine if a proposed or existing 

refuge use is compatible with refuge purposes and the National Wildlife Refuge System mission. 

Refuge uses are defined as recreational or economic/commercial or management use of the 

refuge by the public or a non-Refuge System entity. The Service does not, however, prepare 

compatibility determinations for uses when the Service does not have jurisdiction. Compatibility 

determinations are required to be in writing and the public should have an opportunity to 

comment on them. 

The Service recognizes that compatibility determinations are complex. For this reason, refuge 

managers are required to consider principles of sound fish and wildlife management and best 

available science in making these determinations. If an existing use is not compatible, the refuge 

manager is directed to modify the use to make it compatible or terminate it, as expeditiously as 

practicable. 

In July 2006, the Service published its Appropriate Refuge Uses Policy (603 FW1). Under this 

policy, most proposed uses must also undergo an appropriateness review prior to compatibility. 

If a proposed use is not appropriate, the refuge manager will deny the use without determining 

compatibility. Priority wildlife-dependent activities are automatically considered appropriate. If 

a use is determined to be appropriate, then a compatibility determination is developed to 

determine whether the use can be allowed. Appropriateness findings for Protection Island and 

San Juan Islands Refuges can be found in Appendix I. 

Compatibility Determinations evaluated at this time

This set of compatibility determinations (CDs) evaluates uses projected to occur under the 

Preferred Alternative B in the Draft EA for the Comprehensive Conservation Plan and 

Wilderness Stewardship Plan for Protection Island and San Juan Islands Refuges (Draft 

CCP/WSP/EA). The evaluation of funds needed for management and implementation of each 

use also assumes implementation as described under Alternative B. Compatibility 

determinations are based on the professional judgment of refuge personnel, including 

observations of existing refuge uses. 

Refuge Refuge Use Compatible Page 

Protection Island Research, Scientific Collecting, and Survey 

Activities

Yes J-2

Protection Island Environmental Education Yes J-9

San Juan Islands Research Scientific Collecting, and Survey Activities Yes J-15
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-2

Refuge Refuge Use Compatible Page 

San Juan Islands Environmental Education Yes J-22

San Juan Islands Wildlife Observation, Photography, and 

Interpretation

Yes J-29

San Juan Islands Camping Yes J-39
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-3

Draft Compatibility Determination

Use: Research, Scientific Collecting, and Survey Activities 

Refuge Name: Protection Island National Wildlife Refuge

Refuge Purposes and Establishing/Acquisition Authorities

“The purposes of the refuge are to provide habitat for a broad diversity of bird species, 

with particular emphasis on protecting the nesting habitat of the bald eagle, tufted puffin, 

rhinoceros auklet, pigeon guillemot, and pelagic cormorant; to protect the hauling-out 

area of harbor seals; and to provide for scientific research and wildlife-oriented public 

education and interpretation” (All lands, Protection Island National Wildlife Refuge Act, 

Public Law 977-333, Oct 15, 1982, 96 Stat. 1623).

“. . . for the development, advancement, management, conservation, and protection of 

fish and wildlife resources . . .” (340 acres under tideland lease, 16 U.S.C.742 f(a)(4), 

Fish and Wildlife Act of 1956)

National Wildlife Refuge System Mission

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd-668ee]).

Description of Use

The Washington Maritime National Wildlife Refuge Complex (Complex) receives periodic 

requests from non-Service entities (e.g., universities, state agencies, other federal agencies, 

NGOs) to conduct research, scientific collecting, and surveys on Protection Island. These 

projects can involve a wide range of natural and cultural resources, as well as public-use 

management issues, including habitat use and life-history requirements for specific 

species/species groups, practical methods for habitat restoration, extent and severity of 

environmental contaminants, techniques to control or eradicate pest species, effects of climate 

change on environmental conditions and associated habitat/wildlife response, identification and 

analyses of paleontological specimens, wilderness character, modeling of wildlife populations, 

and assessing response of habitat/wildlife to disturbance from public uses. Projects may be 

species-specific, refuge-specific, or evaluate the relative contribution of the refuge to larger 

landscape (e.g., ecoregion, region, flyway, national, international) issues and trends. 

Facilities supporting research on Protection Island NWR include a 468-square-foot refuge field 

office, 768-square-foot research station/bunkhouse, 120-square-foot research storage/shop 

building, marina and 2 floating piers. In addition, there is a 140-foot well, 33,000 gallon water 

tower, and 10,200 cubic foot water distribution system. All of the above mentioned facilities 

except for the research station/bunkhouse and shop/storage support additional uses other than 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-4

research. Replacement and relocation of the refuge office, research station/bunkhouse, and 

research shop/storage building are proposed to reduce or eliminate impacts to important habitat 

areas.

The Service’s Research and Management Studies (4 RM 6) and Appropriate Refuge Uses 

policies (603 FW1.10D(4)) indicate priority for scientific investigatory studies that contribute to 

the enhancement, protection, use, preservation, and management of native wildlife populations 

and their habitat as well as their natural diversity. Projects that contribute to refuge-specific 

management, where applicable, would be given a higher priority over other requests. Priority 

would also be given to research that documents the understanding and impacts associated with 

climate change and global warming. Research applicants must submit a detailed proposal that 

outlines: 

1) objectives of the study; 

2) justification for the study; 

3) detailed methodology and schedule; include measures to minimize wildlife and habitat 

disturbance or impacts through study design, including location, timing, scope, number of 

permittees, study methods, number of study sites, etc.; 

4) potential impacts on refuge wildlife or habitat, including disturbance (short- and longterm), injury and/or mortality. 

5) costs to the Refuge Complex, if any, including staff time and equipment;

6) expected outcomes or results; and 

7) a timeline for submitting progress reports and final products (i.e., reports, theses, 

dissertations, publications). 

Research proposals would be reviewed by Complex staff and others as appropriate, to weigh the 

anticipated impacts versus the benefits of the research activity to refuge management and 

understanding of natural systems. This would form the basis for allowing the project to proceed 

or be denied. If the proposal is approved, the Project Leader would issue a Special Use Permit 

(SUP) which would set the terms and conditions of the study to avoid and/or minimize the 

impacts on refuge resources, public use activities, and refuge field operations. All research 

projects would be assessed during implementation to ensure that impacts remain within 

acceptable levels. Projects which would result in unacceptable refuge impacts will not be found 

compatible and will not be approved

Research would not be allowed on refuge lands if one or more of the following criteria apply to a 

project proposal: 

• Research that conflicts with other ongoing research, monitoring, or management programs 

will not be granted.

• Research projects that can be accomplished off the refuge are less likely to be approved.

• Highly intrusive and manipulative research or research which causes undue disturbance is 

generally not permitted in order to protect native bird and marine mammal populations. 

• If staffing or logistics make it impossible for Complex staff to monitor the researcher, the 

permit is likely to be denied.

• If the activity is in a sensitive area, the research request may be denied, depending on the 

specific circumstances.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-5

Availability of Resources

Complex staff responsibilities for projects by non-USFWS entities include the following: review 

of proposals, prepare SUPs and compliance documents (e.g., Section 7, Section 106 of the 

National Historic Preservation Act), and monitor project implementation to ensure that impacts 

and conflicts remain within acceptable levels to ensure compatibility over time. Additional 

administrative support, logistical and operational support may also be provided depending on 

each specific request. Estimated costs for one-time (e.g., prepare SUP) and annually reoccurring tasks by refuge staff and other Complex employees will be determined for each 

project. Limited funds for the Complex’s administration of these projects (estimated $3,000 per 

requested project) may be available within the general operating budget of the Washington 

Maritime NWR Complex, which administers Protection Island NWR. In some cases, the 

Complex staff may act as a cooperator on research projects. The funding for these projects may 

be cost-shared and in some cases, specially designated funds may be utilized for the operation 

and administration of the projects. 

The Complex has the following annual staffing and funding to administratively support and 

monitor the three research projects currently taking place on refuge lands (see table below). Any 

substantial increase in the number of projects would create a need for additional resources to 

oversee the administration and monitoring of the investigators and their projects. Any 

substantial additional costs above those itemized below (not including one-time costs associated 

with facility replacement and relocation) will result in finding a project not compatible unless 

expenses are offset by the investigator(s), sponsoring agency, or organization. 

Category One Time Expense Recurring Expense

Administration (Evaluation of Applications, 

Management of Permits, Oversight)

$3,000

Monitoring and participation $6,000 $1,500

Maintenance $2,250

Totals $9,000 $3,750

Anticipated Impacts of the Use

Use of Protection Island NWR to conduct research, scientific collection, and surveys will 

generally benefit plant populations, wildlife, and habitats. The impacts of research activities 

would be project and site-specific, and would vary depending on the scope and type of research 

conducted. Scientific findings gained through these projects provide important information 

regarding life-history needs of species and species groups as well as identify or refine 

management actions to achieve resource management objectives in refuge management plans 

(especially CCPs). Reducing uncertainty regarding wildlife and habitat responses to refuge 

management actions in order to achieve desired outcomes reflected in resource management 

objectives is essential for adaptive management in accordance with 522 DM 1. 

Data collection techniques will generally have negligible animal mortality or disturbance, habitat 

destruction, no introduction of contaminants, or no introduction of non-indigenous species. In 

contrast, projects involving the collection of biotic samples (plants or animals) or requiring 

intensive ground-based data or sample collection will have short-term impacts. To reduce 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-6

impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates) will be collected for identification and/or experimentation and 

statistical analysis. Where possible, researchers would coordinate and share collections to reduce 

sampling needed for multiple projects. For example, if one investigator collects fish for a diet 

study and another researcher examines otoliths, then it may be possible to accomplish sampling 

for both projects with one collection effort. 

Some level of disturbance is expected with all research activities since most researchers will be 

entering areas that are normally closed to the public and, depending on specific research 

activities, may also be collecting samples or handling wildlife. However, minimal impact to 

Refuge wildlife and habitats will be expected with research studies because SUPs will include 

conditions to ensure that impacts to wildlife and habitats are kept to a minimum 

Direct damage or alteration to the habitat from researchers would be minor due to the research 

proposal evaluation process and stipulations imposed through the SUP. However, some increase 

in invasive plants is possible from ground disturbance and/or transportation of source seed on 

research equipment and personnel, and rodents and disease organisms could potentially be 

transferred from boats and trapping equipment. Likewise, there could be localized and 

temporary effects resulting in direct impacts such as vegetation trampling, collecting of soil and 

plant samples, or trapping and handling of wildlife. Other potential, but localized and temporary, 

effects would include wildlife disturbance, which is expected with some research activities. 

Researcher disturbance could result in altering wildlife behavior. However, wildlife disturbance 

(including altered behavior) will be localized and temporary in nature. Only research with 

reasonably certain short-term effects from disturbance would be permitted. . Impacts may also 

occur from infrastructure necessary to support projects (e.g., permanent transects or plot markers, 

exclosure devices, monitoring equipment, solar panels to power unattended monitoring 

equipment). 

Spread of invasive plants and/or pathogens is possible from ground disturbance and/or 

transportation of project equipment and personnel, but it will be minimized or eliminated by 

requiring proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary. If an unacceptable spread of invasive species is anticipated to occur, then the 

project will be found not compatible without a restoration or mitigation plan. 

The combination of stipulations identified below and conditions included in any SUP(s) will 

ensure that proposed projects contribute to the enhancement, protection, conservation, and 

management of native wildlife populations and their habitats on the refuge(s). As a result, these 

projects will help fulfill refuge purposes; contribute to the Mission of the NWRS; and maintain 

the biological integrity, diversity, and environmental health of the refuge.

Public Review and Comment

Public review and opportunity to comment on this compatibility determination will occur in 

conjunction with the release of the Draft CCP/WSP/EA. 

Determination

 The use is not compatible.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-7

 X The use is compatible with the following stipulations.

Stipulations Necessary to Ensure Compatibility

If the proposed research methods would impact or potentially impact refuge resources (habitat or 

wildlife), it must be demonstrated that the research is essential (i.e., critical to survival of a 

species; refuge islands provide only or critical habitat for a species; contributes significantly to 

understanding of impacts from climate change; or assessment and/or restoration after 

cataclysmic events), and the researcher must identify the issues in advance of the impact. Highly 

intrusive or manipulative research is generally not permitted in order to protect native bird and 

marine mammal populations. Stipulation and provisions would include the following: 

User Stipulations: 

• Potential researchers must submit a written, detailed research proposal to the Project Leader 

at least 6 months prior to start of field work. The required proposal format would be 

provided to researchers.

• Researchers are responsible for acquiring and/or renewing any necessary State and Federal 

permits prior to beginning or continuing their project.

• Research will adhere to scientifically defensible protocols for data collection, where available 

and feasible. 

• The refuge staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the project. 

• Upon completion of the project or annually, research sites must be cleaned up to the Project 

Leader’s satisfaction and all physical markers removed. For long-term projects, conditions 

for clean-up and removal of equipment and physical markers would be stipulated in the SUP.

• Investigator(s) and support staff will follow all refuge-specific regulations that specify access 

and travel on the refuge(s). 

Administrative Stipulations: 

• A Section 7 consultation under the Endangered Species Act would be required for research 

activities that may affect a federally threatened, endangered, or proposed species. Only 

projects which have no effect or will result in not likely to adversely affect determinations 

will be considered compatible.

• Research that does not involve birds generally will only be allowed outside of the breeding 

season of avian species using the specific island(s), unless it can be demonstrated that there 

likely will be no impact to those breeding species. If a research project can only be 

conducted during the breeding season, such studies will only be permitted where there are 

specific protocols to minimize disturbance. 

• Approved research projects will be conducted under a Complex-issued Special Use Permit 

which will have additional project-specific stipulations. 

• Annual or other short term SUPs are preferred; however, some permits will be for a longer 

period, if needed, to facilitate the research. All SUPs will have a definite termination date in 

accordance with 5 RM 17.11. Renewals will be subject to Project Leader review of research 

data, status reports, compliance with compatibility determination and permit stipulations, and 

permits. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-8

• If unacceptable impacts or issues arise or are noted by the Complex staff, then the Project 

Leader can suspend/modify conditions/terminate on-refuge research that is already permitted 

and in progress.

• All samples collected on refuge lands are the property of the Service even while in the 

possession of the investigator(s). Any future work with previously collected samples not 

clearly identified in the project proposal will require submission of a subsequent proposal for 

review and approval. In addition, a new SUP will be required for additional project work. 

For samples or specimens to be stored at other facilities (e.g., museums), a Memorandum of 

Understanding will be necessary.

• After approval, all projects also will be assessed during implementation to ensure impacts 

and conflicts remain within acceptable levels.

• Projects which are not covered by the CCP may require additional NEPA documentation.

Justification

Research is not considered a priority public use by NWRS policy (603 FW1); however, 

Protection Island’s refuge purpose includes “...and to provide for scientific research...” Two 

provisions of the National Wildlife Refuge Improvement Act of 1997 are to “maintain biological 

integrity, diversity and environmental health” and to conduct “inventory and monitoring.” 

Refuge plans and actions based on research and monitoring provide an informed approach to 

habitat, wildlife, and public use management programs. Seabird and pinniped conservation and 

management at the Complex are based upon best available scientific information from research 

combined with long-term monitoring. Some research is used to address specific wildlife 

conservation questions, such as understanding the causes of reduced or declining seabird and/or 

pinniped populations and development of tools and techniques to aid recovery of threatened or 

endangered species. Other research has broader applicability, such as using a suite of seabird 

species as indicators of ocean health conditions and to document change in the larger marine 

environment and associated impacts associated with climate change and global warming. 

Research, scientific collecting, and surveys on refuge lands are inherently valuable to the 

USFWS because they will expand scientific information available for resource management 

decisions. In addition, only projects which directly or indirectly contribute to the enhancement, 

protection, use, preservation, and management of refuge wildlife populations and their habitats 

generally will be authorized on refuge lands. In many cases, if it were not for the Complex staff 

providing access to refuge lands and waters along with some support, the project would never 

occur and less scientific information would be available to the USFWS and others to aid in 

managing and conserving these species. By allowing the use to occur under the stipulations 

described above, it is anticipated that wildlife species which may be disturbed during the use of 

refuge habitats, would find sufficient food resources and resting places elsewhere on the refuge 

so their abundance and use will not be measurably lessened. Additionally, it is anticipated that 

monitoring, as needed, will prevent unacceptable or irreversible impacts to fish, wildlife, plants, 

and their habitats. As a result, these projects will not materially interfere with or detract from 

fulfilling refuge purposes and they would contribute to the Mission of the NWRS, as well as 

maintaining the biological integrity, diversity, and environmental health of the refuges.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-9

Mandatory 10- or 15-year Re-evaluation Date

Provide month and year for “allowed” uses only.

 Mandatory 15-year re-evaluation date (for wildlife-dependent public uses).

 X Mandatory 10-year re-evaluation date (for all uses other than wildlife-dependent public 

uses).

NEPA Compliance for Refuge Use Decision

 Categorical Exclusion without Environmental Action Statement

 Categorical Exclusion and Environmental Action Statement

 Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision.

Refuge Determination

Prepared by 

Refuge Manager: _____________________________ ___________ 

(Signature) (Date)

Concurrence

Refuge Supervisor:

_______________________________ __________ 

(Signature) (Date)

Regional Chief, National 

Wildlife Refuge System:

_______________________________ ___________ 

(Signature) (Date)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-10

Draft Compatibility Determination

Use: Environmental Education

Refuge Name: Protection Island National Wildlife Refuge

Refuge Purposes and Establishing/Acquisition Authorities

“The purposes of the refuge are to provide habitat for a broad diversity of bird species, 

with particular emphasis on protecting the nesting habitat of the bald eagle, tufted puffin, 

rhinoceros auklet, pigeon guillemot, and pelagic cormorant; to protect the hauling-out 

area of harbor seals; and to provide for scientific research and wildlife-oriented public 

education and interpretation” (All lands, Protection Island National Wildlife Refuge Act, 

Public Law 977-333, Oct 15, 1982, 96 Stat. 1623).

“. . . for the development, advancement, management, conservation, and protection of 

fish and wildlife resources . . .” (340 acres under tideland lease, 16 U.S.C.742 f(a)(4), 

Fish and Wildlife Act of 1956)

National Wildlife Refuge System Mission

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended, 16 U.S.C. 668dd-668ee).

Description of Use

Environmental Education is a key component of the enabling legislation of Protection Island 

National Wildlife Refuge. Protection Island is closed to public use so most environmental 

education would take place off-refuge. A limited amount of off-refuge environmental education 

currently takes place in partnership with the Port Townsend Marine Science Center. On-refuge 

environmental education will be limited and will consist of providing opportunities for 

volunteers to learn about the refuge and its resources while participating in stewardship projects 

and for college level students to pursue environmental studies in accordance with Service 

policies and criteria.

Refuge staff and others would provide an educational context to stewardship projects which may 

include, but are not limited to, debris clean up from island beaches, invasive vegetative species 

control, observation and monitoring of wildlife, and maintenance of facilities and equipment. 

The Complex will issue permits to allow students from regional colleges and universities to 

conduct environmental studies on Protection Island. Environmental studies will be of limited 

duration, complexity and scale and will be geared toward students gaining field experience and 

knowledge of the National Wildlife Refuge System, Protection Island NWR, and its 

management. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-11

Availability of Resources

Complex staff will identify, and in many cases participate in, educational stewardship 

opportunities for volunteers. Staff responsibilities for projects/studies proposed by students will 

include the following: review of proposals, prepare SUPs and compliance documents, and 

monitor project/study implementation to ensure that impacts and conflicts remain within 

acceptable levels to ensure compatibility over time. Additional administrative support, logistical 

and operational support may also be provided depending on each specific request. Estimated 

costs for one-time (e.g., prepare SUP) and annually re-occurring tasks by Complex staff will be 

determined for each project. Limited funds for the Complex’s administration of these 

projects/studies (estimated $2,500 per requested project) may be available within the general 

operating budget of the Washington Maritime Refuge Complex, which administers Protection 

Island NWR. 

The Complex has the following staffing and funding over a 5-year period to administratively 

support and monitor the minimum number of stewardship projects (5) and environmental studies 

(2) identified in the CCP to take place over that timeframe. Any substantial increase in the 

number of projects/studies would create a need for additional resources to oversee the 

administration and monitoring of the studies. Any substantial additional costs above those 

itemized below will result in finding a project not compatible unless expenses are offset by the 

student(s) and/or the college and university.

Category One Time Expense Recurring Expense

Administration (Evaluation of Applications, 

Management of Permits, Oversight)

$7,000 $3,500

Monitoring and participation $10,500 $3,500

Totals for five year period $17,500 $7,000

Anticipated Impacts of the Use

Protection Island educational stewardship projects will be designed to minimize disturbance to 

wildlife and habitat. Impacts will be site-specific and may include short-term disturbance to 

species using refuge shorelines during beach cleanup projects. Island vegetation may be 

minimally impacted as invasive vegetative species are removed. Wildlife observation and 

monitoring may disturb some species as volunteers move from one monitoring location to 

another. Maintenance of facilities and equipment may also result in very local disturbance 

depending on time and place of need.

Use of Protection Island NWR to conduct college level environmental education will generally 

benefit plant populations, wildlife, and habitats. The impacts of individual studies would be sitespecific, and would vary depending on the scope and type of study. Scientific findings gained 

through these studies will provide additional information for the Service to use in managing the 

refuge. In addition, it is the goal of this use to increase the student’s knowledge and 

understanding of the refuge’s unique wildlife and habitats, its linkage to the marine environment, 

and contribute to its and similar area’s conservation. Data collection techniques will generally 

have minimal impacts on animal mortality or disturbance or habitat destruction; no introduction 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-12

of contaminants; or no introduction of non-indigenous species. Studies involving the collection 

of biotic samples (plants or animals) or requiring intensive ground-based data or sample 

collection will have short-term impacts. To reduce impacts, the minimum number of samples 

(e.g., water, soils, vegetative litter, plants, macroinvertebrates, and vertebrates) will be collected 

for identification and/or experimentation and statistical analysis. 

Some level of disturbance is expected with all study activities since most students will be 

entering areas that are normally closed to the public and, depending on specific study activities, 

may also be collecting samples or handling wildlife. However, minimal impact to refuge 

wildlife and habitats will be expected with studies because SUPs will include conditions to 

ensure that impacts to wildlife and habitats are kept to a minimum.

Direct damage or alteration to the habitat from students would be minor due to the study 

proposal evaluation process and stipulations imposed through the SUP. However, some increase 

in invasive plants is possible from ground disturbance and/or transportation of source seed on 

equipment and personnel, and rodents and disease organisms could potentially be transferred 

from boats and trapping equipment. Likewise there could be localized and temporary effects 

from vegetation trampling, colleting of soil and plant samples, or trapping and handling of 

wildlife. Impacts may also occur from infrastructure necessary to support projects (permanent 

transects or plot markers, exclosure devices, monitoring equipment, etc). 

Spread of invasive plants and/or pathogens is possible from ground disturbance and/or 

transportation of project equipment and personnel, but it will be minimized or eliminated by 

requiring proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary. If an unacceptable spread of invasive species is anticipated to occur, then the 

study will be found not compatible.

There also could be localized and temporary effects from vegetation trampling, collecting of soil 

and plant samples, or trapping and handling of wildlife. Some level of disturbance is expected 

with these studies, especially if students enter areas closed to the public and collect samples or 

handle wildlife. However, wildlife disturbance (including altered behavior) will be localized and 

temporary in nature. Where long-term or cumulative unacceptable effects cannot be avoidrf, the 

project will not be found compatible. 

The combination of stipulations identified below and conditions included in any SUP(s) will 

ensure that proposed studies minimize negative impacts to wildlife and habitats and positively 

contribute to the enhancement, protection, conservation, and management of native wildlife 

populations and their habitats on the refuge. As a result, these studies will help fulfill refuge 

purposes, contribute to the Mission of the NWRS, and maintain the biological integrity, 

diversity, and environmental health of the refuge.

Public Review and Comment

Public review and the opportunity to comment on this compatibility determination will occur in 

conjunction with the release of the Draft CCP/WSP/EA. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-13

Determination

 The use is not compatible.

 X The use is compatible with the following stipulations.

Stipulations Necessary to Ensure Compatibility

Design and conduct educational stewardship projects to minimize impacts to wildlife. Beach 

cleanup projects will be conducted outside seabird and marine mammal breeding/pupping 

seasons. Invasive species control will be conducted at the best time of year to ensure successful 

control efforts balanced against potential wildlife disturbance. Any control around major seabird 

colonies will take place outside the breeding season. Sign, trail, and facility maintenance will 

take place outside breeding and pupping areas except in emergency situations. 

Highly intrusive or manipulative studies generally will not permitted in order to protect native 

bird and marine mammal populations. Stipulation and provisions would include the following:

User Stipulations: 

• Potential students must submit a written, detailed study proposal to the Project Leader at least 

1 month prior to start of field work. The required proposal format would be provided to 

students.

• Students are responsible for acquiring and/or renewing any necessary State and Federal 

permits prior to beginning or continuing their project.

• The Complex staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the study. 

• Upon completion of the study or annually, study sites must be cleaned up to the Project 

Leader’s satisfaction and all physical markers removed. For long-term studies, conditions for 

clean-up, and removal of equipment and physical markers would be stipulated in the SUP.

• Students and support staff will follow all refuge-specific regulations that specify access and 

travel on the refuge(s). 

Administrative Stipulations:

• Design and conduct educational stewardship projects to minimize impacts to wildlife. Beach 

clean up projects will be conducted outside seabird and marine mammal breeding/pupping 

seasons. Invasive species control will be conducted at the best time of year to ensure 

successful control efforts balanced against potential wildlife disturbance. Any control around 

major seabird colonies will take place outside the breeding season. Sign, trail, and facility 

maintenance will take place outside breeding and pupping except in emergency situations. 

• Highly intrusive or manipulative studies generally will not permitted in order to protect 

native bird and marine mammal populations.

• A Section 7 consultation under the Endangered Species Act would be required for studies 

that may affect a federally threatened, endangered, or proposed species. Only projects which 

have no effect or will result in not likely to adversely affect determinations will be 

considered compatible.

• Studies that do not involve birds generally will only be allowed outside of the breeding 

season of avian species using the specific island(s), unless it can be demonstrated that there 

likely will be no impact to those breeding species. If a study can only be conducted during 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-14

the breeding season, such studies will only be permitted where there are specific protocols to 

minimize disturbance. 

• Studies will adhere to scientifically defensible protocols for data collection, where available 

and feasible. 

• Approved studies will be conducted under a Complex-issued SUP which will have additional 

project-specific stipulations. 

• Annual or other short-term SUPs are preferred; however some permits will be for a longer 

period, if needed, to facilitate the study. All SUPs will have a definite termination date in 

accordance with 5 RM 17.11. Renewals will be subject to Project Leader review of research 

data, status reports, compliance with compatibility determination and permit stipulations, and 

permits.

• After approval, all projects also will be assessed during implementation to ensure impacts 

and conflicts remain within acceptable levels.

• If unacceptable impacts or issues arise or are noted by the Complex staff, then the Project 

Leader can suspend/modify conditions/terminate on-refuge studies that are already permitted 

and in progress.

• All samples collected on refuge lands are the property of the Service even while in the 

possession of the students. Any future work with previously collected samples not clearly 

identified in the study proposal will require submission of a subsequent proposal for review 

and approval. In addition, a new SUP will be required for additional project work. For 

samples or specimens to be stored at other facilities (e.g., museums), a Memorandum of 

Understanding will be necessary.

Justification

Wildlife-oriented education is part of the purposes of Protection Island and therefore the 

environmental education program as described here is consistent with refuge purposes. 

Environmental education stewardship projects and studies on refuge lands are inherently 

valuable to the USFWS because they will enhance the public’s knowledge of the refuge and its 

resources and expand scientific information available for resource management decisions. In 

addition, only studies which directly or indirectly contribute to the enhancement, protection, use, 

preservation, and management of refuge wildlife populations and their habitats generally will be 

authorized on refuge lands. In many cases, if it were not for the Complex staff providing access 

to refuge lands and waters along with some support, the study would never occur and less 

scientific information would be available to the USFWS and others to aid in managing and 

conserving these species. By allowing the use to occur under the stipulations described above, it 

is anticipated that wildlife species which may be disturbed during the use would find sufficient 

food resources and resting places elsewhere on the refuge so their abundance and use of refuge 

habitats will not be measurably lessened. Additionally, it is anticipated that monitoring, as 

needed, will prevent unacceptable or irreversible impacts to fish, wildlife, plants, and their 

habitats. As a result, these studies will not materially interfere with or detract from fulfilling 

refuge purposes (including wilderness) and they would contribute to the Mission of the NWRS,

as well as maintaining the biological integrity, diversity, and environmental health of the refuges.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-15

Mandatory 10- or 15-year Re-evaluation Date

Provide month and year for “allowed” uses only.

 Mandatory 15-year re-evaluation date (for wildlife-dependent public uses).

 X Mandatory 10-year re-evaluation date (for all uses other than wildlife-dependent public 

uses).

NEPA Compliance for Refuge Use Decision

 Categorical Exclusion without Environmental Action Statement

 Categorical Exclusion and Environmental Action Statement

 Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision.

Refuge Determination

Prepared by 

Refuge Manager: ________________________________ ___________ 

(Signature) (Date)

Concurrence

Refuge Supervisor:

_______________________________ __________ 

(Signature) (Date)

Regional Chief, National 

Wildlife Refuge System:

_______________________________ ___________ 

(Signature) (Date)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-16

Draft Compatibility Determination

Use: Research, Scientific Collecting, and Survey Activities 

Refuge Name: San Juan Islands National Wildlife Refuge

Refuge Purposes and Establishing/Acquisition Authorities 

“. . . reserved under jurisdiction of the Bureau of Sport Fisheries and Wildlife, United 

States Fish and Wildlife Service. . .” (all lands, PLO 2249). 

“. . .facilitate the management of migratory birds for which the United States has a 

responsibility under international treaties and to further effectuate the purposes of the 

Migratory Bird Conservation Act.” (all lands, Proposal published in 38 FR 29831 on Oct 

29, 1973 prior to PLO 5515, 1975) 

“as a preserve, breeding ground and winter sanctuary for native birds.” (Smith and 

Minor Islands, E.O. 1959 of 1914)

“. . .to secure for the American people of present and future generations the benefits of 

an enduring resource of wilderness” (353 acres, all units of the refuge except for Smith, 

Minor, Turn, and a 5 acre portion of Matia Island, P.L. 94-557 of October 1976 and P.L. 

88-577, the Wilderness Act of 1964.) 

“lighthouse purposes.” Navigation aids maintained under the jurisdiction of the U.S. 

Coast Guard (~19 units, Executive Orders from 1854 and 1875).

National Wildlife Refuge System Mission

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd-668ee]).

Description of Use

The Washington Maritime NWR Complex receives periodic requests from non-USFWS entities 

(e.g., universities, state agencies, other federal agencies, NGOs) to conduct research, scientific 

collecting, and surveys on San Juan Islands NWR. These projects can involve a wide range of 

natural and cultural resources as well as public-use management issues, including habitat use and 

life-history requirements for specific species/species groups, practical methods for habitat 

restoration, extent and severity of environmental contaminants, techniques to control or eradicate 

pest species, effects of climate change on environmental conditions and associated 

habitat/wildlife response, identification and analyses of paleontological specimens, wilderness 

character, modeling of wildlife populations, and assessing response of habitat/wildlife to 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-17

disturbance from public uses. Projects may be species-specific, refuge-specific, or evaluate the 

relative contribution of the refuge to larger landscape (e.g. ecoregion, region, flyway, national, 

international) issues and trends. 

The USFWS’s Research and Management Studies (4 RM 6) and Appropriate Refuge Uses 

policies (603 FW1.10D(4)) indicate priority for scientific investigatory studies that contribute to 

the enhancement, protection, use, preservation, and management of native wildlife populations 

and their habitat as well as their natural diversity. Projects that contribute to refuge-specific 

and/or wilderness management, where applicable, would be given a higher priority over other 

requests. Priority would also be given to research that documents the understanding and impacts 

associated with climate change and global warming. Research applicants must submit a detailed 

proposal that outlines: 

1) objectives of the study; 

2) justification for the study; 

3) detailed methodology and schedule; include measures to minimize wildlife and habitat 

disturbance or impacts through study design, including location, timing, scope, number of 

permittees, study methods, number of study sites, etc;

4) potential impacts on refuge wildlife or habitat, including disturbance (short-and longterm), injury and/or mortality.; 

5) costs to the Refuge Complex, if any, including staff time and equipment;

6) expected outcomes or results; and 

7) a timeline for submitting progress reports and final products (i.e., reports, theses, 

dissertations, publications). 

Research proposals would be reviewed by Complex staff and others as appropriate, to weigh the 

anticipated impacts versus the benefits of the research activity to refuge management and 

understanding of natural systems. This would form the basis for allowing the project to proceed 

or be denied. If the proposal is approved, the Project Leader would issue an SUP which would 

set the terms and conditions of the study to avoid and/or minimize the impacts on refuge 

resources, public use activities, and refuge field operations. All research projects would be 

assessed during implementation to ensure that impacts remain within acceptable levels. Projects 

which would result in unacceptable refuge impacts will not be found compatible and will not be 

approved. 

Research would not be allowed on refuge lands if one or more of the following criteria apply to a 

project proposal: 

• Research that conflicts with other ongoing research, monitoring, or management programs 

will not be granted.

• Research projects that can be accomplished off the refuge are less likely to be approved.

• Highly intrusive and manipulative research or research which causes undue disturbance is 

generally not permitted in order to protect native bird and marine mammal populations and 

wilderness values.

• If staffing or logistics make it impossible for Complex staff to monitor the researcher, the 

permit is likely to be denied.

• If the activity is in a sensitive area, the research request may be denied, depending on the 

specific circumstances.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-18

Availability of Resources

Complex staff responsibilities for projects by non-USFWS entities include the following: review 

of proposals, prepare SUPs and compliance documents (e.g., Section 7, Section 106 of the 

National Historic Preservation Act), and monitor project implementation to ensure that impacts 

and conflicts remain within acceptable levels to ensure compatibility over time. Additional 

administrative support, logistical, and operational support may also be provided depending on 

each specific request. Estimated costs for one-time (e.g., prepare SUP) and annually reoccurring tasks by refuge staffs and other Complex employees will be determined for each 

project. Limited funds for the Complex’s administration of these projects (estimated $3,500 per 

requested project) may be available within the general operating budget of the Washington 

Maritime NWR Complex, which administers San Juan Islands NWR. In some cases, the 

Complex staff may act as a cooperator on research projects. The funding for these projects may 

be cost-shared and in some cases, specially designated funds may be utilized for the operation 

and administration of the projects. 

The Complex has the following funding to annually administratively support and monitor one 

research project on San Juan Islands NWR (see table below). Any substantial increase in the 

number of projects would create a need for additional resources to oversee the administration and 

monitoring of the investigators and their projects. Any substantial additional costs above those 

itemized below (not including one-time costs associated with facility replacement and relocation) 

could result in finding a project not compatible unless expenses are offset by the investigator(s), 

sponsoring agency, or organization. 

Category One-Time Expense Recurring Expense

Administration (Evaluation of Applications, 

Management of Permits, Oversight)

 $1,000 $1,000

Monitoring and participation $2,500 $1,500

Totals $3,500 $2,500

Anticipated Impacts of the Use

Use of San Juan Islands NWR to conduct research, scientific collection, and surveys will 

generally benefit plant populations, wildlife, and habitats. The impacts of research activities 

would be project and site-specific, and would vary depending on the scope and type of research 

conducted. Scientific findings gained through these projects provide important information 

regarding life-history needs of species and species groups, as well as identify or refine 

management actions to achieve resource management objectives in refuge management plans 

(especially CCPs). Reducing uncertainty regarding wildlife and habitat responses to refuge 

management actions in order to achieve desired outcomes reflected in resource management 

objectives is essential for adaptive management in accordance with 522 DM 1. 

Data collection techniques will generally have negligible animal mortality or disturbance, habitat 

destruction, no introduction of contaminants, or no introduction of non-indigenous species. In 

contrast, projects involving the collection of biotic samples (plants or animals) or requiring 

intensive ground-based data or sample collection will have short-term impacts. To reduce 

impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates) will be collected for identification and/or experimentation and 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-19

statistical analysis. Where possible, researchers would coordinate and share collections to reduce 

sampling needed for multiple projects. For example, if one investigator collects fish for a diet 

study and another research examines otoliths, then it may be possible to accomplish sampling for 

both projects with one collection effort. 

Some level of disturbance is expected with all research activities since most researchers will be 

entering areas that are normally closed to the public and, depending on specific research 

activities, may also be collecting samples or handling wildlife. However, minimal impact to 

refuge wildlife and habitats will be expected with research studies because SUPs will include 

conditions to ensure that impacts to wildlife and habitats are kept to a minimum. Only research 

with reasonably certain short-term effects from disturbance would be permitted.

Direct damage or alteration to the habitat from researchers would be minor due to the study 

proposal evaluation process and stipulations imposed through the SUP. However, some increase 

in invasive plants is possible from ground disturbance and/or transportation of source seed on 

equipment and personnel, and rodents and disease organisms could potentially be transferred 

from boats and trapping equipment. Likewise there could be localized and temporary effects 

from vegetation trampling, colleting of soil and plant samples, or trapping and handling of 

wildlife. Impacts may also occur from infrastructure necessary to support projects (permanent 

transects or plot markers, exclosure devices, monitoring equipment, etc). .

 

Spread of invasive plants and/or pathogens is possible from ground disturbance and/or 

transportation of project equipment and personnel, but it will be minimized or eliminated by 

requiring proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary. If an unacceptable spread of invasive species is anticipated to occur, then the 

project will be found not compatible without a restoration or mitigation plan.

 

The combination of stipulations identified below and conditions included in any SUP(s) will 

ensure that proposed projects minimize negative impacts to wildlife and habitats and positively 

contribute to the enhancement, protection, conservation, and management of native wildlife 

populations and their habitats on the refuge. As a result, these projects will help fulfill refuge 

purposes, contribute to the Mission of the NWRS, and maintain the biological integrity, 

diversity, and environmental health of the refuge.

 

Public Review and Comment

Public review and the opportunity to comment on this compatibility determination will occur in 

conjunction with the release of the Draft CCP/WSP/EA. 

Determination

 The use is not compatible.

 X The use is compatible with the following stipulations.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-20

Stipulations Necessary to Ensure Compatibility

If the proposed research methods would impact or potentially impact refuge resources (habitat or 

wildlife), it must be demonstrated that the research is essential (i.e., critical to survival of a 

species; refuge islands provide only or critical habitat for a species; contributes significantly to 

understanding of impacts from climate change; or assessment and/or restoration after 

cataclysmic events), and the researcher must identify the issues in advance of the impact. Highly 

intrusive or manipulative research is generally not permitted in order to protect native bird and 

marine mammal populations and wilderness values. Projects that represent public or private 

economic use of the natural resources of any national wildlife refuge (e.g., bioprospecting), in 

accordance with 16 U.S.C. 715s, must contribute to the achievement of the national wildlife 

refuge purposes or the National Wildlife Refuge System mission to be compatible (50 C.F.R. 

29.1). Stipulations and provisions would include the following: 

User Stipulations: 

• Potential researchers must submit a written, detailed research proposal to the Project Leader 

at least 6 months prior to start of field work. The required proposal format would be 

provided to researchers.

• Researchers are responsible for acquiring and/or renewing any necessary State and Federal 

permits prior to beginning or continuing their project.

• Research will adhere to scientifically defensible protocols for data collection, where available 

and feasible. 

• Research progress reports are required at least annually, and final reports are due within one 

year of the completion of the project, unless negotiated otherwise. The minimum required 

elements for a progress report will be provided to investigator(s). 

• The refuge staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the project. 

• Upon completion of the project or annually, research sites must be cleaned up to the Project 

Leader’s satisfaction and all physical markers removed. For long-term projects, conditions 

for clean-up and removal of equipment and physical markers would be stipulated in the 

Special Use Permit.

• Investigator(s) and support staff will follow all refuge-specific regulations that specify access 

and travel on the refuge(s). 

Administrative Stipulations: 

• Any proposed research by USFWS or their agents within wilderness would have to comply 

with the provisions of the existing Minimum Requirements Analysis (Appendix H). Anyone 

not acting as an agent of USFWS and requesting to conduct research in wilderness must 

prepare an MRA consistent with FWS Policy and adhere to the requirements of the 

Wilderness Act of 1964 (16 U.S.C. 1131-1136). 

• A Section 7 consultation under the Endangered Species Act would be required for research 

activities that may affect a federally threatened, endangered, or proposed species. Only 

projects which have no effect or will result in not likely to adversely affect determinations 

will be considered compatible.

• Research that does not involve birds generally will only be allowed outside of the breeding 

season of avian species using the specific island(s), unless it can be demonstrated that there 

likely will be no impact to those breeding species. If a research project can only be 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-21

conducted during the breeding season, such studies will only be permitted where there are 

specific protocols to minimize disturbance. 

• Approved research projects will be conducted under a Complex-issued SUP which will have 

additional project-specific stipulations. 

• Annual or other short-term SUPs are preferred; however, some permits will be for a longer 

period, if needed, to facilitate the research. All SUPs will have a definite termination date in 

accordance with 5 RM 17.11. Renewals will be subject to Project Leader review of research 

data, status reports, compliance with compatibility determination and permit stipulations, and 

permits. 

• If unacceptable impacts or issues arise or are noted by the Complex staff, then the Project 

Leader can suspend/modify conditions/terminate on-refuge research that is already permitted 

and in progress.

• All samples collected on refuge lands are the property of the Service even while in the 

possession of the investigator(s). Any future work with previously collected samples not 

clearly identified in the project proposal will require submission of a subsequent proposal for 

review and approval. In addition, a new SUP will be required for additional project work. 

For samples or specimens to be stored at other facilities (e.g., museums), a Memorandum of 

Understanding will be necessary

• After approval, all projects also will be assessed during implementation to ensure impacts 

and conflicts remain within acceptable levels.

• Projects which are not covered by the CCP may require additional NEPA documentation.

Justification

Research is not considered a priority public use by NWRS policy (603 FW1); however, it 

contributes to two provisions of the National Wildlife Refuge Improvement Act of 1997, which 

are to “maintain biological integrity, diversity and environmental health” and to conduct 

“inventory and monitoring.” Refuge plans and actions based on research and monitoring provide 

an informed approach to habitat, wildlife, and public use management programs. Migratory bird 

and pinniped conservation and management at the Complex are based upon best available 

scientific information from research combined with long-term monitoring. Some research is 

used to address specific wildlife conservation questions, such as understanding the causes of 

reduced or declining seabird and/or pinniped populations and development of tools and 

techniques to aid recovery of threatened or endangered species. Other research has broader 

applicability, such as using a suite of seabird species as indicators of ocean health conditions and 

to document change in the larger marine environment and associated impacts associated with 

climate change and global warming. 

Research, scientific collecting, and surveys on refuge lands are inherently valuable to the 

USFWS because they will expand scientific information available for resource management 

decisions. In addition, only projects which directly or indirectly contribute to the enhancement, 

protection, use, preservation, and management of refuge wildlife populations and their habitats 

generally will be authorized on refuge lands. In many cases, if it were not for the Complex staff 

providing access to refuge lands and waters along with some support, the project would not 

occur and less scientific information would be available to the USFWS and others to aid in 

managing and conserving these species. By allowing the use to occur under the stipulations 

described above, it is anticipated that wildlife species which may be disturbed during the use 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-22

would find sufficient food resources and resting places elsewhere on the refuge so their 

abundance and use will not be measurably lessened on the refuge. Additionally, it is anticipated 

that monitoring, as needed, will prevent unacceptable or irreversible impacts to fish, wildlife, 

plants, and their habitats. As a result, these projects will not materially interfere with or detract 

from fulfilling refuge purposes (including wilderness) and they would contribute to the Mission 

of the NWRS as well as maintaining the biological integrity, diversity, and environmental health 

of the refuges.

Mandatory 10- or 15-year Re-evaluation Date

Provide month and year for “allowed” uses only.

 Mandatory 15-year re-evaluation date (for wildlife-dependent public uses).

 X Mandatory 10-year re-evaluation date (for all uses other than wildlife-dependent public 

uses).

NEPA Compliance for Refuge Use Decision

 Categorical Exclusion without Environmental Action Statement

 Categorical Exclusion and Environmental Action Statement

 Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision

Refuge Determination

Prepared by 

Refuge Manager: _____________________________ ___________ 

(Signature) (Date)

Concurrence

Refuge Supervisor:

_______________________________ __________ 

(Signature) (Date)

Regional Chief, National 

Wildlife Refuge System:

_______________________________ ___________ 

(Signature) (Date)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-23

Draft Compatibility Determination

Use: Environmental Education

Refuge Name: San Juan Islands National Wildlife Refuge

Refuge Purposes and Establishing/Acquisition Authorities

“. . . reserved under jurisdiction of the Bureau of Sport Fisheries and Wildlife, United 

States Fish and Wildlife Service. . .” (all lands, PLO 2249). 

“. . .facilitate the management of migratory birds for which the United States has a 

responsibility under international treaties and to further effectuate the purposes of the 

Migratory Bird Conservation Act.” (all lands, Proposal published in 38 FR 29831 on Oct 

29, 1973 prior to PLO 5515, 1975) 

“as a preserve, breeding ground and winter sanctuary for native birds.” (Smith and 

Minor Islands, E.O. 1959 of 1914)

“. . .to secure for the American people of present and future generations the benefits of 

an enduring resource of wilderness” (353 acres, all units of the refuge except for Smith, 

Minor, Turn, and a 5 acre portion of Matia Island, P.L. 94-557 of October 1976 and P.L. 

88-577, the Wilderness Act of 1964.) 

“lighthouse purposes.” Navigation aids maintained under the jurisdiction of the U.S. 

Coast Guard (~19 units, Executive Orders from 1854 and 1875).

National Wildlife Refuge System Mission

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd-668ee]).

Description of Use

In the NWRS Improvement Act, the United States Congress declared environmental education as 

one of six priority wildlife-dependent public uses of the NWRS. Environmental education 

activities seek to increase public knowledge and understanding of wildlife and habitats and 

contribute to its conservation. On-refuge environmental education on San Juan Islands NWR 

will consist of interpretive panels, volunteer stewardship projects and opportunities to pursue 

environmental studies in accordance with Service policies and criteria to a limited number of 

college level students. Offering students the opportunity to conduct environmental studies will 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-24

increase their knowledge and understanding of refuge resources and contribute to our knowledge 

base.

 

Interpretive panels will be located on Matia and Turn Islands, which are the only islands open to 

the public. 

Stewardship projects will be geared to accomplishing a management need while at the same time 

educating the participating volunteer(s). Projects may take place on any island and include, but 

are not limited to: debris clean up from island beaches, invasive vegetative species control,

observation and monitoring of wildlife, and maintenance of refuge trails, signs, and facilities.

The Complex will issue permits to allow students from regional colleges and universities to 

conduct environmental studies on San Juan Islands NWR Island. Environmental studies will be 

of limited duration, complexity, and scale, and will be geared toward students gaining field 

experience and knowledge of the NWRS, San Juan Islands NWR, and its management. These 

study activities may take place on any island in the refuge. 

Availability of Resources

Complex staff responsibilities for environmental education that takes place at interpretive panels 

will consist of maintaining the panels and monitoring vegetative impacts associated with 

placement and use.

Stewardship projects will require more intense Complex staff participation. Beach clean up 

projects will need to be coordinated to take advantage of wildlife seasonal use and tides. Some 

islands will require the refuge to transport volunteers to the site and back and facilitate removal 

of debris. Other islands may be cleaned through local “adopt an island” groups which will 

handle transportation and debris removal and disposal. In these cases, Complex staff will have 

limited participation, such as determining the best time of the year to conduct clean up 

operations. Invasive species control and maintenance of trails, signs, and facilities will require 

Complex staff participation. Wildlife observation and monitoring may run the gamut of intense 

to minimal staff participation depending on the area, specie, and complexity of monitoring effort. 

Staff responsibilities for projects/studies proposed by students will include the following: review 

of proposals, prepare special use permits (SUPs) and compliance documents, monitor 

project/study implementation to ensure that impacts and conflicts remain within acceptable 

levels to ensure compatibility over time. Additional administrative support, logistical and 

operational support may also be provided depending on each specific request. Estimated costs 

for one-time (e.g., prepare SUP) and annually re-occurring tasks by Complex staff will be 

determined for each project. Limited funds for the Complex’s administration of these 

projects/studies (estimated $3,000 per requested project) may be available within the general 

operating budget of the Washington Maritime NWR Complex, which administers San Juan 

Islands NWR. 

The Complex has the following staffing and funding to administratively support and monitor the 

minimum number of stewardship projects (5) and environmental studies (1) identified in the 

CCP to take place over a five-year period. Any substantial increase in the number of 

projects/studies would create a need for additional resources to oversee the administration and 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-25

monitoring of the studies. Any substantial additional costs above those itemized below will 

result in finding a project not compatible unless expenses are offset by the student(s) and/or the 

college and university.

Category One Time Expense Recurring Expense

Administration (Evaluation of Applications, 

Management of Permits, Oversight)

$6,000 $3,000

Monitoring and participation $12,000 $3,000

Totals for five year period $18,000 $6,000

Anticipated Impacts of the Use

Environmental education through use of interpretive panels will take place on Matia and Turn 

Islands and will consist of panels placed at strategic locations in areas open to the public. Matia 

Island will have one panel at the Rolfe Cove access point, one at the wilderness trailhead, and 

one at the west end of the campground. Turn will have three large interpretive panels: one 

located at the main access point, one east of the camping area at trail head, and one in the 

camping area. In addition there will be up to five small panels placed at various locations along 

the trail sufficiently spaced as to not concentrate use. Localized effects could include limited 

vegetation trampling and compaction of soils at these locations as the visiting public gathers to

study the panels 

Educational stewardship projects will be designed to minimize disturbance to wildlife and 

habitat. Impacts will be site specific and may include short term disturbance to species using 

refuge shorelines during beach clean up projects. Island vegetation may be minimally impacted 

as invasive vegetative species are removed. Wildlife observation and monitoring may disturb 

some specie as volunteers move from one monitoring location to another. Maintenance of 

facilities and equipment may also result in very local disturbance depending on time and place of 

need.

Use of San Juan Islands NWR to conduct college level environmental education will generally 

benefit plant populations, wildlife, and habitats. The impacts of individual studies would be sitespecific, and would vary depending on the scope and type of study. Scientific findings gained 

through these studies will provide additional information for the Service to use in managing the 

refuge. In addition, it is the goal of this use to increase the student’s knowledge and 

understanding of the refuge’s unique wildlife and habitats, its linkage to the marine environment, 

and contribute to its and similar area’s conservation. Data collection techniques will generally 

have minimal impacts on animal mortality or disturbance, or habitat destruction; no introduction 

of contaminants; or no introduction of non-indigenous species. Studies involving the collection 

of biotic samples (plants or animals) or requiring intensive ground-based data or sample 

collection will have short-term impacts. To reduce impacts, the minimum number of samples 

(e.g., water, soils, vegetative litter, plants, macroinvertebrates, and vertebrates) will be collected 

for identification and/or experimentation and statistical analysis. 

Some level of disturbance is expected with all study activities since most students will be 

entering areas that are normally closed to the public and, depending on specific study activities, 

may also be collecting samples or handling wildlife. However, minimal impact to refuge 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-26

wildlife and habitats will be expected with studies because SUPs will include conditions to 

ensure that impacts to wildlife and habitats are kept to a minimum.

Direct damage or alteration to the habitat from students would be minor due to the study 

proposal evaluation process and stipulations imposed through the SUP. However, some increase 

in invasive plants is possible from ground disturbance and/or transportation of source seed on 

equipment and personnel, and rodents and disease organisms could potentially be transferred 

from boats and trapping equipment. Likewise there could be localized and temporary effects 

from vegetation trampling, colleting of soil and plant samples, or trapping and handling of 

wildlife. Impacts may also occur from infrastructure necessary to support projects (permanent 

transects or plot markers, exclosure devices, monitoring equipment, etc).

Spread of invasive plants and/or pathogens is possible from ground disturbance and/or 

transportation of project equipment and personnel, but it will be minimized or eliminated by 

requiring proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary. If after all practical measures are taken and unacceptable spread of invasive 

species is anticipated to occur, then the study will be found not compatible. 

The combination of stipulations identified below and conditions included in any SUP(s) will 

ensure that proposed studies contribute to the enhancement, protection, conservation, and 

management of native wildlife populations and their habitats on the refuge(s). As a result, these 

studies will help fulfill refuge purposes; contribute to the mission of the NWRS; and maintain 

the biological integrity, diversity, and environmental health of the refuge.

Public Review and Comment

Public review and the opportunity to comment on this compatibility determination will occur in 

conjunction with the release of the Draft CCP/WSP/EA. 

Determination

 The use is not compatible.

 X The use is compatible with the following stipulations.

Stipulations Necessary to Ensure Compatibility

User Stipulations: 

• Potential students must submit a written, detailed study proposal to the Project Leader at least 

1 month prior to start of field work. The required proposal format would be provided to 

researchers.

• Students are responsible for acquiring and/or renewing any necessary State and Federal 

permits prior to beginning or continuing their project.

• The Complex staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the study. 

• Upon completion of the study or annually, study sites must be cleaned up to the Project 

Leader’s satisfaction and all physical markers removed. For long-term studies, conditions for 

clean-up, and removal of equipment and physical markers would be stipulated in the SUP.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-27

• Students and support staff will follow all refuge-specific regulations that specify access and 

travel on the refuge(s). 

Administrative Stipulations:

• Design and conduct educational stewardship projects to minimize impacts to wildlife. Beach 

clean up projects will be conducted outside seabird and marine mammal breeding/pupping 

seasons. Invasive species control will be conducted at the best time of year to ensure 

successful control efforts balanced against potential wildlife disturbance. Any control around 

major seabird colonies will take place outside the breeding season. Sign, trail, and facility 

maintenance will take place outside breeding and pupping areas except in emergency 

situations. 

• Highly intrusive or manipulative studies generally will not be permitted in order to protect 

native bird and marine mammal populations.

• A Section 7 consultation under the Endangered Species Act would be required for studies 

that may affect a federally threatened, endangered, or proposed species. Only projects which 

have no effect or will result in not likely to adversely affect determinations will be 

considered compatible.

• Studies that do not involve birds generally will only be allowed outside of the breeding 

season of avian species using the specific island(s), unless it can be demonstrated that there 

likely will be no impact to those breeding species. If a study can only be conducted during 

the breeding season, such studies will only be permitted where there are specific protocols to 

minimize disturbance. 

• Studies will adhere to scientifically defensible protocols for data collection, where available 

and feasible. 

• Approved studies will be conducted under a Complex-issued SUP which will have additional 

project-specific stipulations. 

• Annual or other short-term SUPs are preferred; however some permits will be for a longer 

period, if needed, to facilitate the study. All SUPs will have a definite termination date in 

accordance with 5 RM 17.11. Renewals will be subject to Project Leader review of research 

data, status reports, compliance with compatibility determination and permit stipulations, and 

permits.

• If unacceptable impacts or issues arise or are noted by the Complex staff, then the Project 

Leader can suspend/modify conditions/terminate on-refuge studies that are already permitted 

and in progress.

• All samples collected on refuge lands are the property of the Service even while in the 

possession of the students. Any future work with previously collected samples not clearly 

identified in the study proposal will require submission of a subsequent proposal for review 

and approval. In addition, a new SUP will be required for additional project work. For 

samples or specimens to be stored at other facilities (e.g., museums), a Memorandum of 

Understanding will be necessary.

Justification

Environmental education stewardship projects and studies on refuge lands are inherently 

valuable to the USFWS because they will enhance the public’s knowledge of the refuge and its 

resources and expand scientific information available for resource management decisions. In 

addition, only studies which directly or indirectly contribute to the enhancement, protection, use, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-28

preservation, and management of refuge wildlife populations and their habitats generally will be 

authorized on refuge lands. In many cases, if it were not for the Complex staff providing access 

to refuge lands and waters along with some support, the study would never occur and less 

scientific information would be available to the USFWS and others to aid in managing and 

conserving these species. By allowing the use to occur under the stipulations described above, it 

is anticipated that wildlife species which may be disturbed during the use would find sufficient 

food resources and resting places elsewhere on the refuge so their abundance and use will not be 

measurably lessened. Additionally, it is anticipated that monitoring, as needed, will prevent 

unacceptable or irreversible impacts to fish, wildlife, plants, and their habitats. As a result, these 

studies/projects will not materially interfere with or detract from fulfilling refuge purposes 

(including wilderness) and they would contribute to the Mission of the NWRS as well as 

maintaining the biological integrity, diversity, and environmental health of the refuges.

Mandatory 10- or 15-year Re-evaluation Date

Provide month and year for “allowed” uses only.

 X Mandatory 15-year re-evaluation date (for wildlife-dependent public uses).

 Mandatory 10-year re-evaluation date (for all uses other than wildlife-dependent public 

uses).

NEPA Compliance for Refuge Use Decision

 Categorical Exclusion without Environmental Action Statement

 Categorical Exclusion and Environmental Action Statement

 Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision.

Refuge Determination

Prepared by 

Refuge Manager: _____________________________ ___________ 

(Signature) (Date)

Concurrence

Refuge Supervisor: _______________________________ __________ 

(Signature) (Date)

Regional Chief, National 

Wildlife Refuge System:

_______________________________ ___________ 

 (Signature) (Date)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-29

Draft Compatibility Determination

Uses: Wildlife observation, photography, and interpretation

Refuge Name: San Juan Islands National Wildlife Refuge

City/County and State: San Juan County, Island County, and Skagit County, Washington 

Refuge Purposes and Establishing/Acquisition Authorities:

“. . . reserved under jurisdiction of the Bureau of Sport Fisheries and Wildlife, United 

States Fish and Wildlife Service. . .” (all lands, PLO 2249). 

“. . .facilitate the management of migratory birds for which the United States has a 

responsibility under international treaties and to further effectuate the purposes of the 

Migratory Bird Conservation Act.” (all lands, Proposal published in 38 FR 29831 on Oct 

29, 1973 prior to PLO 5515, 1975) 

“as a preserve, breeding ground and winter sanctuary for native birds.” (Smith and 

Minor Islands, E.O. 1959 of 1914)

“. . .to secure for the American people of present and future generations the benefits of 

an enduring resource of wilderness” (353 acres, all units of the refuge except for Smith, 

Minor, Turn, and a 5 acre portion of Matia Island, P.L. 94-557 of October 1976 and P.L. 

88-577, the Wilderness Act of 1964.) 

“lighthouse purposes.” Navigation aids maintained under the jurisdiction of the U.S. 

Coast Guard (~19 units, Executive Orders from 1854 and 1875).

National Wildlife Refuge System Mission: 

“The mission of the [National Wildlife Refuge] System is to administer a national network of 

lands and waters for the conservation, management, and where appropriate, restoration of the 

fish, wildlife, and plant resources and their habitats within the United States for the benefit of 

present and future generations of Americans” (National Wildlife Refuge System 

Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Uses:

Conduct and allow access for wildlife-dependent priority public uses (wildlife observation, 

photography, and interpretation) as provided for under the National Wildlife Refuge System 

Improvement Act of 1997. These uses will occur on-refuge on Matia and Turn Islands with 

specific conditions as noted in this determination.

On Matia these uses will occur along the refuge trail and at the access point and shoreline at 

Rolfe Cove. Three proposed interpretive panels will be installed at the access area and trailhead. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-30

Additional regulation signs will be placed at non-permitted access points, which tend to be the 

pocket beaches on the west, south, and east sides of the island. Current facilities include a 1.3 

mile trail, four large refuge information signs, regulatory signage, and trailhead signs maintained 

by the Service; and an information kiosk, picnic tables, composting toilet, seasonal dock (AprilOctober), and two mooring buoys maintained by Washington State Parks under a Memorandum 

of Understanding with the Service. Washington State Parks also assists with trail maintenance.

On Turn Island these uses will occur along the refuge trail and the access areas and associated 

shoreline on the southwest end of the island. Three proposed interpretive panels will be placed 

in the access area and up to five along the trail. A large refuge sign, trailhead signs, and some 

regulatory signs are maintained by the Service along with the trail. A kiosk, two composting 

toilets, picnic tables with grills, and three mooring buoys are maintained by Washington State 

Parks at the access areas under a Memorandum of Understanding with the Service. Washington 

State Parks also assists with trail maintenance. 

Public use access is year-round, day use only, except for camping areas managed by Washington

State Parks at the access areas. Camping is addressed in a separate Appropriateness Finding and 

Compatibility Determination.

Wildlife observation, photography, and interpretive activities seek to increase awareness, 

enjoyment, and understanding of the refuge’s wildlife and plant resources. Interpretive panels 

will be located at the access areas and trailheads at Matia and Turn Islands and at several 

locations along the trail on Turn Island. Wildlife observation and photography will take place 

from refuge trails or from boats circumnavigating the islands.

Availability of Resources:

The following funds will be required to run a program as designed under the CCP. The projected 

need represents an increase of approximately 150% in recurring expenses compared to current 

funding for this program. For the one-time expenses, all available sources will be investigated.

Category 

Onetime

Expense

Recurring 

Expense

Administration and management: $15,000 $1,000 

Maintenance: $2,500 

Monitoring: $2,500 $2,500 

Special equipment, facilities, or improvements: $120,000

Totals: $137,500 $6,000 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-31

Anticipated Impacts of the Use(s):

The refuge wildlife-dependent uses being evaluated (wildlife observation, photography, and 

interpretation) will impose some negative impacts on specific physical resources such as trails 

and on natural resources such as wildlife and vegetation. Impacts may include erosion, 

deterioration, trampling, and disturbance.

Wildlife Observation:

Physical and habitat alteration: The impact of these activities depends upon the size of the 

group(s), the season of use, the location within the Public Use Area on Matia and Turn Islands, 

and the duration of the activity. These two islands receive heavy use for four months of the year 

with very little use the rest of the year. The potential exists for a maximum of approximately 

100 visitors on each island at any one time although this would be a rare occurrence. The 

construction and maintenance of visitor use facilities (i.e. trails, observation points, interpretive 

sites, composting toilets, and picnic tables) would have some effect on soils, vegetation and 

possibly hydrology in specific areas. This could potentially increase erosion and cause localized 

soil compaction (Liddle 1975); reduced seed emergence (Cole and Landres1995); alteration of 

vegetative structure and composition; and sediment loading (Cole and Marion 1988). The fact 

that the islands receive very little use for 8 months of the year ameliorates these impacts.

Human disturbance - general

received less research attention is whether these short term responses, which generally require 

increased energetic expenditures on the part of the individual, ultimately diminish an individual 

or population’s capacity to survive and breed successfully (fitness). Energetic demands of 

responding to disturbance events were measured by Belanger and Bedard (1989). In Quebec, 

they found that if disturbance was severe enough to cause geese to fly and not resume feeding 

upon alighting, hourly energy expenditure increased by 3.4%; hourly metabolized energy intake 

decreased by 2.9 to 19.4%. A 32% increase in nighttime feeding was required to restore the 

energy losses incurred.

: The presence of people observing or photographing wildlife will 

also cause some impact to wildlife. Numerous studies have confirmed that people on foot can 

cause a variety of disturbance reactions in wildlife, including flushing or displacement (Erwin 

1989; Fraser et al. 1985; Freddy 1986), heart rate increases (MacArthur et al. 1982), altered 

foraging patterns (Burger and Gochfeld, 1991), and even, in some cases, diminished reproductive 

success (Boyle and Samson 1985). These studies and others have shown that the severity of the 

effects depends upon the distance to the disturbance and its duration, frequency, predictability, 

and visibility to wildlife (Knight and Cole 1991). The variables found to have the greatest 

influence on wildlife behavior are a) the distance from the animal to the disturbance, and b) the 

duration of the disturbance. Animals show greater flight response to humans moving 

unpredictably than to humans following a distinct path (Gabrielsen and Smith 1995). Short-term 

and immediate responses to disturbance are fairly simple to document. A question that has

Effect of disturbance intensity: Some researchers have attempted to correlate disturbance events 

in wildlife to the intensity, proximity, or loudness of human disturbance. Burger (1986), 

studying shorebirds on an eastern coastal refuge, found that the level of disturbance in the 

shorebirds increased (fewer remained, more flew) as the total number of disturbances and the 

number of children, joggers, people walking, dogs, aircraft, and boats increased, and the duration 

of the disturbance and distance from the disturbance decreased.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-32

Effect of human proximity: Other researchers have looked at the question of proximity. At what 

distance do humans on foot elicit a disturbance response? From an examination of the available 

studies, it appears that the distance varies dramatically from species to species. Burger and 

Gochfeld (1991) found that sanderlings foraged less during the day and more during the night as 

the number of people within 100 m increased. Elk in Yellowstone National Park were disturbed 

when people were at average distances of 573 m (Cassirer 1990). These elk temporarily left the 

drainage and their home range core areas and moved to higher elevations, steeper slopes, and 

closer to forested areas. Average return time to the drainage was 2 days. Erwin [1989] studied 

colonial wading and seabirds in Virginia and North Carolina. Mixed colonies of common ternsblack skimmers responded at the greatest distances, with respective means of 142 and 130m; 

mixed wading bird species were more reluctant to flush (30-50 m average). There were few 

statistically significant relationships between flushing distance and colony size. Similarly, there 

were few differences between responses during incubation compared to post-hatching periods.

An analysis of over 4,000 human activity events near bald eagle nests in Central Arizona (Grubb 

and King 1991) found distance to disturbance to be the most important classifier of bald eagle 

response, followed in decreasing order of discriminatory value by duration of disturbance, 

visibility, number of units per event, position relative to affected eagle, and sound.

Breeding bald eagles in north-central Minnesota (Fraser et al. 1985) flushed at an average 

distance of 476 m at the approach of a pedestrian. A multiple regression model including 

number of previous disturbances, date and time of day explained 82% of the variability in flush 

distance and predicted a maximum flush distance at the first disturbance of 503 m (SE=131). 

Skagen (1980), also studying bald eagles in northwest Washington, found a statistically 

significant decrease in the proportion of eagles feeding when human activity was present within 

200 m of the feeding area in the previous 30 minutes. A statistically significant between-season 

variation occurred in the use of feeding areas relative to human presence, which correlated with 

food availability. Eagles appeared more tolerant of human activity in the season of low food 

availability.

In a review of several studies of the reaction of waterfowl and other wetland birds to people on 

foot, distances greater than 100 meters in general did not result in a behavioral response (DeLong 

2002).

Effects on migrant birds versus resident birds: Klein (1989) studied the effect of visitation on 

migrant and resident waterbirds at Ding Darling National Wildlife Refuge, finding that resident 

birds were less sensitive to human disturbance than migrants. Migrant ducks were particularly 

sensitive when they first arrived on site in the fall. They usually remained more than 80 m from 

[a visitor footpath on a dike], even at very low visitor-levels. Herons, egrets, brown pelicans, and 

anhingas were most likely to habituate to humans, thus exposing them to direct disturbance as 

they fed on or near the dike. Shorebirds showed intermediate sensitivity. Strauss (1990) 

observed piping plover chicks spent less time feeding (50% versus 91%) and spent more time 

running (33% versus 2%), fighting with other chicks (4% versus 0.1%), and standing alert (9% 

versus 0.1%) when pedestrians or moving vehicles were closer than 100 m than when they were 

undisturbed. In addition plover chicks spent less time out on the feeding flats (8% versus 97%) 

and more time up in the grass (66% versus 0.1%) during periods of human disturbance.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-33

Wildlife Photography: 

Wildlife photography is likely more disturbing, per instance, than wildlife observation. Klein 

(1993) observed at Ding Darling NWR, that of all the non-consumptive uses, photographers 

were the most likely to attempt close contact with birds, and that even slow approach by 

photographers disrupted waterbirds.

Dwyer and Tanner (1992) noted that wildlife habituate best to disturbance that is somewhat 

predictable or “background.” Investigating 111 nests of sandhill cranes in Florida, Dwyer and 

Tanner found that nesting cranes seemed to habituate to certain forms of human disturbance and 

nested within 400 m of highways, railroads, and mines; cranes also were tolerant of helicopter 

flyovers. Even so, investigator visits to nests and development-induced alterations of surface 

water drainage were implicated in 24% of the nest failures.

Interpretation:

Enhanced interpretation will take place on refuge on Matia and Turn Islands and consist of 

panels placed at strategic locations. Three interpretive panels will be installed on Matia Island. 

One panel will be placed at the Rolfe Cove access area; one approximately 100 feet west at the 

west end of the campground; and one at the Wilderness Trail trailhead. On Turn Island, three 

larger panels will be installed: one at the main access area, one approximately 150 feet southeast 

in the campground area, and one approximately 200 feet east at eastern trailhead. In addition, up 

to five additional smaller panels will be placed along the island trail at key interpretive locations. 

None of these panels will be located in close proximity to each other. Localized effects could 

include limited vegetation trampling and compaction of soils at these locations as the visiting 

public gathers to study the panels. 

Summary: 

All of the uses described occur in specific footprints on the refuge – Matia and Turn Island trails, 

access areas, and associated beaches. Estimated current use of less than 18,000 visits per year 

(Washington State Parks monthly attendance reports) does cause adverse effects though. The 

fact that all uses are confined to a limited number of areas, means that overall impacts are not 

extensive nor do they impact the greater part of the refuge. Interpretive panels are sufficiently 

spaced so as not to congregate use and impacts. Most use is during the summer months with 

very little use occurring in the spring and winter allowing for some revegetation. 

Access from points other than Rolfe Cove on Matia Island have resulted in illegal spur trails. 

This has resulted in vegetation trampling, deterioration, and some erosion, particularly coming 

from pocket beaches on the west, south, and east sides of the island. Replacement of three 

informational/regulatory signs and installation of three additional signs at these access points is 

expected to curb this use.

The Turn Island trail has been developed from a social trail that follows the perimeter of the 

island. This has resulted in the trail being located in a sensitive meadow area where tramping of 

vegetation occurs. In addition there are two steep trails leading up from a beach area that have 

resulted in erosion. Although these impacts are short-term in the meadow area and long-term at 

the beach access, they can be remediated through rerouting of the trail around sensitive areas, 

interpreting the sensitivity of these areas with interpretive panels, and closure and rehabilitation 

of beach access trails.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-34

The most heavily used areas around the composting toilets and picnic tables result in severely 

trampled or complete absence of vegetation with some erosion. This may also occur at 

interpretive sites when they are established. These areas make up approximately 1% of the total 

Turn and Matia Islands’ acreage. The trampling at picnic table sites can be remediated by 

periodically moving the tables to new locations, however the toilet locations are fixed.

Public Review and Comment:

Public review and the opportunity to comment on this compatibility determination will occur in 

conjunction with the release of the Draft CCP/WSP/EA. 

Determination: (check one below)

 Use is Not Compatible

 X Use is Compatible with Following Stipulations

Stipulations Necessary to Ensure Compatibility:

User stipulations:

 Visitors will be required to access islands only at designated access points/areas, thus 

reducing potential for wildlife disturbance and establishment of illegal trails.

 Visitors will be required to stay on legally established, trails thus limiting the amount of 

area on the islands where impacts may take place.

 Use is restricted to daylight hours outside of camping area.

Administrative stipulations:

 Directional, informational, and interpretive signs will be posted and maintained to help 

keep visitors on trails and help educate the public on minimizing wildlife and habitat 

disturbance.

 Monitor impacts to wildlife, vegetation, and soil and employ adaptive management when 

needed. Management responses may include such actions as moving picnic tables and 

interpretive panels to new locations, rerouting island trails, and rehabilitation of impacted 

sites.

 Promote the “Leave No Trace” philosophy. At least 75 % of the refuge will be managed 

as wildlife sanctuary, free from routine disturbance.

Justification:

Specific areas in the San Juan Islands National Wildlife Refuge (trails and access areas on Matia 

and Turn Islands) have been designated for these uses. These areas will be monitored 

periodically for impacts that would degrade the natural environment specific management 

actions would be implemented if impacts reached unacceptable levels. Wildlife observation, 

photography, and interpretation are three of the six wildlife-dependent recreational uses of the 

National Wildlife Refuge System as stated in the National Wildlife Refuge System 

Administration Act, as amended. Wildlife observation, photography, and interpretation through 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-35

interpretive panels provide an excellent forum for increasing public understanding of the refuge’s 

natural resources. By limiting these activities to a small percentage of the refuge and by 

providing wildlife sanctuary from human disturbance in other areas of the refuge, these programs 

will not interfere with the refuge achieving its purpose to “facilitate the management of 

migratory birds for which the United States has a responsibility under international treaties and 

to further effectuate the purposes of the Migratory Bird Conservation Act” and with regard to all 

by five acres of Matia Island “...to secure for the American people of present and future 

generations the benefits of an enduring resource of wilderness.” These activities are used 

throughout the country to inform and educate visitors to public lands. (Grater1976).

Given the scale of the activity, the stipulations outlined above, as well as the best management 

practices identified, potential impacts relative to wildlife/human interactions will be minimal. 

The opportunity to engage in several priority public uses provided would outweigh any 

anticipated negative impacts associated with implementation of the program.

With the stipulations noted, access trails, interpretive panels, and information/regulatory signs 

activities will be compatible with Refuge purposes, while providing opportunities for visitors to 

use and learn about Refuge and marine resources. Thus allowing the priority public uses in this 

determination will not materially interfere with or detract from the fulfillment of the National 

Wildlife Refuge System mission or the purposes of this Refuge.

References Cited:

Belanger, L. and Bedard, J. 1989. Energetic cost of man-induced disturbance to staging 

snow geese. J. Wildl. Management. 54: 36-41.

Boyle, S.A. and Samson, F.B. 1985. Effects of nonconsumptive recreation on wildlife: a 

review. Wildl. Soc. Bull. 13: 110-116.

Burger, J. 1986. The effect of human activity on shorebirds in two coastal bays in 

northeastern United States. Environ. Conserv. 13:123-130.

Burger, J. and Gochfeld, M. 1991. Human activity influence and diurnal and nocturnal 

foraging of sanderlings (Calidris alba). Condor 93: 259-265.

Cassirer, E. F. 1990. Responses of elk to disturbance by cross-country skiers in northern 

Yellowstone National Park. M.S. Thesis, University of Idaho, Moscow.

Cole, D.N. and J. L Marion. 1988. Recreation impacts in some riparian forests of the 

eastern United States. Env. Mange. 12:99-107.

Cole, D. N. and P. B. Landres. 1995. Indirect effects of recreation on wildlife. Pages 183-

201 in R.L. Knight and K. J. Gutzwiller,ed. Wildlife and Recreationists: 

coexistence through management and research Island Press, Washington, D.C. 

372pp.

DeLong, A. K. 2002. Managing visitor use and disturbance of waterbirds B a literature 

review of impacts and mitigation measures B prepared for Stillwater National Wildlife 

Refuge. Appendix L (114pp.) in Stillwater National Wildlife Refuge Complex final 

environmental impact statement for the comprehensive conservation plan and boundary 

revision (Vol. II). Dept. of the Interior, U.S. Fish and Wildlife Service, Region 1, 

Portland, OR.

Dwyer, N.C. and G.W Tanner. 1992. Nesting success in Florida sandhill cranes. Wilson 

Bulletin 104: 22-31.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-36

Erwin, R. M. 1989. Responses to human intruders by birds nesting in colonies: 

Experimental results and management guidelines. Colon. Waterbirds 12:104-108.

Fraser, James D., L. D. Frenzel, and John E. Mathisen. 1985. The impact of human 

activities on breeding bald eagles in north-central Minnesota.. J. Wildl. Manage. 

49:585-592.

Freddy, D. J. 1986. Responses of adult mule deer to human harasment during winter. Pages 286 

in

Comer, R. D., Baumann, T. G., Davis, P., Monarch, J. W., Todd, J., VanGytenbeek, S., 

Wills, D.,and Woodling, J., eds. Proceedings II. Issues and technology in the 

management of impacted western wildlife: proceedings of a national symposium. Thorne 

Ecol. Inst., Boulder, Colorado.

Gabrielson, G. W. and E. N. Smith. 1995. Physiological responses of wildlife to disturbance. 

Pages 95-107 in R. L. Knight and K. J. Gutzwiller, ed. Wildlife and Recreationists: 

coexistence through management and research. Island Press, Washington, D. C. 372pp.

Grubb, T. G. and King, R. M. 1991. Assessing human disturbance of breeding bald eagles with

classification tree models. J. Wildl. Manage. 55:500-511.

Klein, M.L. 1993. Waterbird behavioral responses to human disturbances. Wildl. Soc. Bull. 

21:31-

39.

Klein, M. L. 1989. Effects of high levels of human visitation on foraging waterbirds at J. N. 

"Ding" Darling National Wildlife Refuge. Final research report. Cooperative Fish and 

Wildlife Research Unit, Univ. of Florida, Gainesville.

Knight, R. L. and D. N. Cole. 1991. Effects of recreational activity on wildlife in wildlands,

inTransactions of the North American Wildlife and Natural Resources Conference. 

56:238-247.

Liddle, M.J. 1975. A selective review of the ecological effects on human trampling on natural

ecosystems. Biol. Conserv. 7:17-36.

MacArthur, R. A., Geist, V., and Johnston, R. H. 1982. Cardiac and behavioral responses of 

mountain sheep to human disturbance. J. Wildl. Manage. 46:351-358.

Skagen, S.S. 1980. Behavioral responses of wintering bald eagles to human activity on 

the Skagit River, Washington. Pages 231-241 in Knight, R.L., Allen, G.T., Stalmaster, 

M.V., and Servheen, C.W., eds.1980. Proceedings of the Washington bald eagle 

symposium; Seattle, Washington.

Strauss, E.G. 1990. Reproductive success, life history patterns, and behavioral variation 

in a population of piping plovers subjected to human disturbances. Ph.D. Dissertation, 

Tufts Univ., Medford, Massachusetts. 

Mandatory 10- or 15-Year Re-evaluation Date: (provide month and year for “allowed” uses 

only)

 X Mandatory 15-year reevaluation date (for wildlife-dependent public uses)

 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent 

public uses)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-37

NEPA Compliance for Refuge Use Decision: (check one below)

 Categorical Exclusion without Environmental Action Statement

 Categorical Exclusion and Environmental Action Statement

 Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision

Refuge Determination

Prepared by 

Refuge Manager: _____________________________ ___________ 

(Signature) (Date)

Concurrence

Refuge Supervisor: _______________________________ __________ 

(Signature) (Date)

Regional Chief, National 

Wildlife Refuge System:

_______________________________ ___________ 

 (Signature) (Date)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-38

Draft Compatibility Determination

Use: Camping

Refuge Name: San Juan Islands National Wildlife Refuge

City/County and State: San Juan County, Island County, and Skagit County, Washington 

Refuge Purposes and Establishing/Acquisition Authorities:

“. . . reserved under jurisdiction of the Bureau of Sport Fisheries and Wildlife, United 

States Fish and Wildlife Service. . .” (all lands, PLO 2249). 

“. . .facilitate the management of migratory birds for which the United States has a 

responsibility under international treaties and to further effectuate the purposes of the 

Migratory Bird Conservation Act.” (all lands, Proposal published in 38 FR 29831 on Oct 

29, 1973 prior to PLO 5515, 1975) 

“as a preserve, breeding ground and winter sanctuary for native birds.” (Smith and 

Minor Islands, E.O. 1959 of 1914)

“. . .to secure for the American people of present and future generations the benefits of 

an enduring resource of wilderness” (353 acres, all units of the refuge except for Smith, 

Minor, Turn, and a 5 acre portion of Matia Island, P.L. 94-557 of October 1976 and P.L. 

88-577, the Wilderness Act of 1964.) 

“lighthouse purposes.” Navigation aids maintained under the jurisdiction of the U.S. 

Coast Guard (~19 units, Executive Orders from 1854 and 1875).

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd-668ee]).

Description of Use:

Matia and Turn Islands are uniquely managed as National Wildlife Refuges and Washington 

State Marine Parks through an agreement between the Service and the Washington State Parks 

and Recreation Commission (WSPRC). The Service first entered into a long-term agreement 

with WSPRC in 1959 in response to uncontrolled public uses which created littering and 

sanitation problems on refuge lands. Washington State Parks established and maintains facilities 

needed for day use and overnight camping to support wildlife-dependent recreation at designated 

areas on Matia and Turn Islands. They also provide information to refuge visitors and enforce 

regulations. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-39

Under the preferred alternative (Alt B) there would be 8 campsites on Turn Island and 6 

campsites on Matia Island; camping would be limited to visitors arriving by human-powered 

watercraft and there would be a new camping reservation system. Motor powered vessels have 

greater flexibility to safely travel to other adjacent State Marine Parks. Changes to the camping 

program would be phased in as soon as practical. 

On Matia Island facilities include 6 primitive campsites, kiosk, pay station, seasonal dock, 

composting toilet, picnic tables, and some signage in an approximately 2-acre area adjacent to

Rolfe Cove. This area is outside the designated wilderness which encompasses most of Matia 

Island. On Turn Island, none of which is wilderness, facilities located on the southwest side of 

the island would include 8 (instead of the current 13) primitive campsites, two composting 

toilets, picnic tables, kiosk, two pay stations, and some signage. Camping is allowed year-round,

however, most occurs from April through September. The heaviest camping usage is expected to 

continue to be during June, July, and August with most campsites occupied on weekends and 

many weekdays during much of this time. Camping fees are charged and collected by WSPRC. 

Because the majority of the San Juan Islands NWR is closed to the public, Matia and Turn 

Islands offer a nonpareil opportunity to the visiting public to observe island wildlife and learn 

about and experience various island habitats. With this in mind, the Service plans to expand its 

interpretation on these two islands to enhance visitors’, including campers’, knowledge, 

enjoyment, and stewardship of wildlife and habitats within the San Juan Islands Refuge and all 

of the Salish Sea. Interpretive panels will be installed at strategic locations on the islands 

including the campground area. Matia Island will have one panel at the Rolfe Cove access point, 

one at the wilderness trailhead, and one at the west end of the campground. Turn will have three 

large interpretive panels: one located at the main access point, one east of the camping area at 

trail head, and one in the camping area. In addition there will be up to five small panels placed at 

various locations along the trail sufficiently spaced as to not concentrate use. 

Availability of Resources:

Current staffing and budget is sufficient to monitor use periodically during the summer camping 

season. Washington State Parks maintains all of the facilities associated with camping and 

performs law enforcement duties, enforcing all state park regulations and the laws of the State of 

Washington. If, for any reason, State Parks decides to terminate the MOU and the Service 

wished to retain camping and associated facilities, existing refuge resources will not be adequate 

to administer the program.

Category 

One-time

($)

Annual

($/yr)

Administration and management: $1,000 $1,000

Maintenance: $0 $750

Monitoring: $0 $2,500

Totals $1,000 $4,250
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-40

Anticipated Impacts of the Use:

The presence of humans on Turn and Matia Islands displaces some wildlife species and is an 

attractant to others. Marine mammals, seabirds, and black oystercatchers will avoid areas where 

people are frequently present and engaging in activities such as landing boats and camping. 

They are displaced to other areas with less human disturbance, including closed islands within 

the San Juan Islands NWR. Ravens and raccoons, on the other hand, are attracted to places 

where people camp and eat because they often have easy access to food. Ravens and raccoons 

also prey on the eggs and young of native passerine birds. When raven and raccoon numbers 

increase due to human activities, predation on native birds likely increases as well. Wildlife 

found on Turn and Matia Islands are likely to experience more incidents of human disturbance in 

general which can distract them from resting, foraging, and caring for their young. These 

negative impacts are considered acceptable because of the presence of “sanctuary” areas on the 

San Juan Island NWR where seabirds, shorebirds, marine mammals, and other wildlife can go to 

avoid human disturbance. Allowing camping on Turn and Matia Islands also provides the 

opportunity to educate visitors and increase their appreciation and stewardship of marine 

wildlife. This would benefit wildlife throughout the refuge and Salish Sea. 

Camping results in some vegetation trampling, soil compaction, and localized denuding of 

vegetation at campsites and where people concentrate. The new reservation system and 

enhanced enforcement is expected to decrease unauthorized camping outside of designated 

campsites. Limiting night use of the island to authorized campers only would also decrease the 

extremely heavy use of the island during popular weekends and holidays such as Independence 

Day. This along with 5 fewer campsites (8 instead of 13) on Turn Island would allow vegetation 

and soils to recover in those areas. Encouraging people to use liquid fuel campstoves and 

enforcing the “no open fires” regulation would minimize unauthorized wood collecting and 

cutting. This would retain more down wood and driftwood, which are important wildlife habitat 

components. Enforcement of “no open fires” would also reduce the risk of an open fire escaping 

and burning refuge habitats. Even after decades of being popular camping areas, the majority of 

habitats on Turn and Matia islands are in very good condition. The impacts of camping are found 

on just a few acres and should continue to be controllable within acceptable limits into the future 

with changes to the program

Public Review and Comment:

Public review and the opportunity to comment on this compatibility determination will occur in 

conjunction with the release of the Draft CCP/WSP/EA. 

Determination:

 Use is Not Compatible

X Use is Compatible with Following Stipulations
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-41

Stipulations Necessary to Ensure Compatibility:

User stipulations: 

• Only visitors arriving by human-powered watercraft are authorized to camp. 

• All commercial operators wishing to use Turn and Matia campgrounds (e.g., kayak tour 

guides) must obtain a special use permit and have a copy in their possession while 

occupying refuge lands. 

• Camping is limited to designated campsites. For example camping is prohibited on 

closed shorelines. 

• Overnight use of refuge limited to authorized campers with a maximum of 8 people per 

campsite. 

• Fires (cooking or camp) are not permitted. Liquid fuel stoves only permitted.

• Pets are not allowed on refuge lands at any time.

Administrative stipulations:

• There is sufficient staff and funding resources available within WSPRC and/or USFWS 

to maintain the facilities associated with camping (composting toilets, campsite markers,

etc.) and administer the program. 

• A reservation system for camping on Matia and Turn Islands is initiated as soon as 

practical. 

• Campers feel safe on refuge lands and the number of reported unsafe incidents and 

undesirable behaviors is minimal

Justification:

This camping program facilitates and supports the priority public uses of wildlife observation, 

photography, interpretation, and environmental education both on-refuge as well as off-refuge. 

Allowing limited camping use offers a nonpareil opportunity to the visiting public to observe 

refuge wildlife and learn about and experience various island habitats at times when animals are 

particularly active, such as dawn and dusk, and to listen to the sounds of wildlife at night. 

Wildlife observation and photography in particular are very popular activities throughout the San 

Juan Archipelago. Many of the closed refuge islands within the San Juan Islands Refuge are 

popular for wildlife observation at a distance from a boat. Because human-powered watercraft 

are slower than motorboats, allowing these visitors to camp on Turn and Matia islands facilitated 

their opportunity to travel greater distances to observe and photograph wildlife throughout the 

San Juan Archipelago including other refuge islands. 

Camping allows visitors arriving by human-powered watercraft to find safe haven to rest, and if 

necessary, to allow wind and inclement weather to abate. Matia Island is at the extreme 

northeast end of the San Juan Archipelago and takes many hours to reach by human-powered 

watercraft. Providing camping allows these users sufficient time to enjoy the refuge’s wildlifedependent recreation once they arrive. Camping on Turn Island allows visitors in the central 

portion of the San Juan Islands Archipelago a similar opportunity. Distances to adjacent safe 

harbor camping locations from Turn Island vary from approximately 6 nautical miles to the north 

to 3 1⁄2 nautical miles to the south.
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix J – Compatibility Determinations J-42

Given the scale of camping, the stipulations outlined above, as well as best management 

practices identified, potential impacts relative to wildlife/human interactions are expected to be 

minimal. By limiting camping to two small areas within the 83 island refuge, the opportunity to 

engage in several priority public uses provided through camping would outweigh any anticipated 

negative impacts associated with implementation of the program. Thus allowing camping to 

occur in the circumstances described above will not materially interfere with the purpose for 

which the refuge was established or the Mission of the National Wildlife Refuge System. 

Mandatory 10- or 15-Year Re-evaluation Date: (provide month and year for “allowed” uses 

only)

 Mandatory 15-year reevaluation date (for wildlife-dependent public uses)

 X Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent 

public uses

NEPA Compliance for Refuge Use Decision: (check one below)

 Categorical Exclusion without Environmental Action Statement

 Categorical Exclusion and Environmental Action Statement

 Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision

Refuge Determination

Prepared by 

Refuge Manager: _____________________________ ___________ 

(Signature) (Date)

Concurrence

Refuge Supervisor: _______________________________ __________ 

(Signature) (Date)

Regional Chief, National 

Wildlife Refuge System:

_______________________________ ___________ 

 (Signature) (Date)
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix K – Coordination, Consultation, and Compliance K-1

Appendix K. CCP Team Members, Public Involvement, 

 and Compliance

CCP Team Members

The CCP was developed and prepared primarily by a core team made up of refuge and regional 

office staff. There was some turnover of refuge staff core team members during the planning 

process. The core team sought technical expertise from other professionals both within and 

outside the Fish and Wildlife Service throughout the CCP process. Portions of the document were 

researched and written with the assistance of a contracting firm, SWCA environmental 

consultations. The List of Preparers below includes the core team members as well as other 

persons responsible for writing specific portions of the plan. Many others provided assistance in 

developing and reviewing the CCP and associated products and in providing advice throughout 

the planning process. These people are captured in the List of Reviewers and Advisors. 

List of Preparers

Name and title CCP Contributions

Kevin Ryan,

Project Leader

Decision-making and document quality reviewer; public involvement

and communications plan lead; researcher/writer, compatibility 

determinations, implementation, compliance with NEPA, ESA, NHPA, 

etc.; Federal and State agency, and Tribal coordination. 

Jane Bardolf , 

Conservation Planner 

CCP Team Leader responsible for regional office coordination, and

process and policy guidance for development of the CCP; CCP 

schedule and status reports; team meeting facilitator; document layout,

management, and review; planning record; refuge purposes research;

public involvement: public meetings, communications plan, and scoping 

report. 

Lorenz Sollmann, 

Deputy Project Leader

Writer/reviewer: biological goals and objectives, affected environment 

and environmental consequences, contaminants, integrated pest 

management plan; research/analysis: invasive species, fire 

management, and habitat restoration; public involvement. 

Sue Thomas, 

Refuge Biologist

Writer/reviewer: biological goals and objectives, affected environment

and environmental consequences; climate change; research/analysis: 

habitats, wildlife, biological integrity, diversity, and environmental 

health; public involvement including outreach to local area and seabird 

biologists and managers. 

Dave Falzetti, 

Refuge Officer and 

Visitor Services 

Manager

Writer/reviewer: visitor services goals and objectives, affected 

environment and environmental consequences; sign inventory and 

maintenance plans; research/analysis: appropriateness findings and 

compatibility determinations; public involvement including planning 

updates.

Khemarith So , 

Geographer

Development of working, public involvement, and document maps; GIS 

data gathering and analysis; researcher/writer: habitats and 

vegetation, rare plants and plant communities, climate change; San 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

K-2 Appendix K – Coordination, Consultation, and Compliance

Name and title CCP Contributions

Juan Island unit descriptions and photographs: public involvement

meetings. 

Staci McCorkle, 

Natural Res. Scientist, 

SWCA Env. 

Consultants

Researcher/writer/editor: physical environment, regional recreation, 

socioeconomics, and environmental consequences; public involvement: 

communication plan, scoping comments compilation, and public 

meetings. 

James Feldman, 

Environmental 

Planner, SWCA Env. 

Consultants

Researcher/writer: socioeconomic environmental consequences

Pam Sanguinetti, 

former Refuge 

Biological Tech.

Researcher/writer: preliminary biological goals, objectives, and 

biological environment, refuge vision statements; research/analysis: 

habitats, wildlife; communications plan and public involvement

including planning updates.

Virginia Parks, 

Archeologist

Researcher/writer: cultural resources objectives, affected environment, 

and environmental consequences. 

Jory Clark, 

Archeologist 

Researcher/writer: paleontological resources objectives, affected 

environment, and environmental consequences.

Nicole Garner, 

Writer/editor

Technical edit review of CCP document and Federal Register Notices; 

design and edit of planning updates. 

Sue Mayo, 

Administrative 

Assistant

Researcher/writer: list of common and scientific species names, San 

Juan Island descriptions; abbreviations and glossary; CCP mailing list 

Annette de Knijf, 

former Deputy Project 

Leader 

Writer: refuge vision statements; research/analysis: contaminants, rare 

plants, county plans

Kay Kier-Haggenjos,

Writer/editor

Technical edit review of Federal Register notices; design and edit of 

planning updates

Pat Stark, Visitor 

Service

CCP cover design and print management

Chris Columbus, 

Maintenance 

Technician

Public involvement: field trip transportation 

List of Reviewers and Advisors

Name and title CCP Contributions

Robyn Thorson, Regional Director Final decision-maker, CCP/EA and Federal 

Register notice approvals

Carolyn Bohan, Regional Chief of Refuges Major decisions on CCP direction, CCP/EA and 

Federal Register notice approvals

Forrest Cameron, Refuge Supervisor Refuge workload assistance; reviewer; decisionmaker

Linda Watters, Assistant Refuge Refuge workload assistance; reviewer; decision-
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix K – Coordination, Consultation, and Compliance K-3

Name and title CCP Contributions

Supervisor maker

Chuck Houghten, Division Chief of Refuge 

Planning

CCP Advisor for planning policy and guidance; 

reviewer; coordination with other divisions and 

WO.

Scott McCarthy, Branch Chief, Planning CCP Advisor for planning policy and guidance; 

Planning workload priorities; coordination with 

other divisions.

Mike Marxen, Branch Chief, Visitor 

Services 

Visitor Services review and guidance design, 

public use goals and objectives; public involvement 

assistance, CD review

Matt Hasti, Visitor Services Visitor Services advice and field trip

Ben Harrison, Division Chief, Natural and 

Cultural Resources

CCP Advisor, wilderness review, policy, 

appropriateness findings, compatibility 

determinations, environmental consequences 

review

Fred Paveglio, Branch Chief, Refuge 

Biology

Development and review of biological goals and 

objectives and biological integrity, diversity, and 

environmental health analysis 

Kevin Kilbride, Wildlife Biologist/ 

Regional IPM Coordinator

Development and review of biological goals and 

objectives and biological integrity, diversity, and 

environmental health analysis

Joe Engler, Wildlife Biologist/Wilderness 

Coordinator

Review of wilderness stewardship plan, wilderness 

reviews, and minimum requirements analyses 

Cathy Sheppard, Division Chief, Realty 

and Refuge Information

Advice on realty issues; CCP Review

Georgia Shirilla, Branch Chief, Refuge 

Acquisition

Advice on realty issues; CCP review

David Patte, ARD External Affairs Communications plan review, assistance with 

tribal coordination meetings

Joan Jewett, External Affairs News release review and distribution

Scott Aikin, Tribal Liaison Identification of Tribes in the planning area, tribal 

coordination planning

Pat Gonzales-Rogers, Tribal Liason Coordination with Tribes 

Maura Naughton, Seabird Biologist Advice on seabirds and development of biological 

goals 

Greg Hagedorn, District Fire 

Management Officer

Advice on fire management

Public Involvement

Public involvement was sought throughout the development of the Draft CCP. During initial 

scoping, summer of 2007 to April of 2008, outreach efforts emphasized face-to-face meetings with 

key state and federal agencies, marine resource committees, federally elected officials, tribal 

governments, and the research community. After initial public scoping, preliminary management 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

K-4 Appendix K – Coordination, Consultation, and Compliance

options were presented at two public open house meetings and additional agency coordination 

occurred. The Service also distributed two planning updates, initiated news releases, and gave 

presentations at community and other non-government organizations to inform the public, invite

discussion and solicit feedback. Below is a brief summary of the meetings and other outreach tools 

that were used in our public involvement efforts.

Federally Elected Officials or their Aides

• March 13, 2008, Port Angeles, WA. Met with Judith Morris, Aide to Congressman Norm Dicks, 

6th

• March 6, 2008, Bellingham, WA. Met with Cherie Little, Aide to Congressman Rick Larson, 2

District 

nd

• March 4, 2008, Federal Building, Seattle, WA. Met with Ardis Dumett, Aide to Senator Patty 

Murray

District 

• April 4, 2008, Federal Building, Seattle, WA. Met with Christine Endersen-State Director; Sally 

Hintz –NW WA Director; and Michael English from Senator Maria Cantwell’s office. 

Tribal Governments 

In July 2007, letters were sent to representatives of 14 federally recognized Tribes associated with 

the Refuges’ 2 treaty areas. The letters invited the tribes to participate in the CCP process and to 

attend their choice of 2 meetings: 

• August 15, 2007 in Mount Vernon, WA 

• August 16, 2007 in Quilcene, WA. 

Follow up calls were made to encourage their participation. No tribes attended these meetings and no 

comments from tribal representatives were received before, during, or after these two meetings. A 

follow-up letter asking if the Tribes wished to participate in the planning process and/or had 

comments to send us was sent along with Planning Update #1 during the first week of October, 2007. 

Planning Update #2 was also sent to the Tribes in August 2008. Some tribal representatives have 

attended Marine Resource Committee and Northwest Straits Commission meetings (see below) when 

the CCP was being discussed. 

State Agency Representatives 

Washington Department of Fish and Wildlife, Region 6, Coastal Washington 

• October 16, 2007, Montesano WA. Met with Regional Director and District Wildlife Biologist 

• July 2008, Field trip to Protection Island with District Wildlife Biologist 

Washington Department of Fish and Wildlife Region 4, North Puget Sound 

• October 22, 2007, Mill Creek, WA. Met with Regional Director, Wildlife Program Manager, 

District Biologist and 5 other biologists. 

Washington Department of Fish and Wildlife Headquarters 

• November 1, 2007, Olympia, WA. Statewide FWS CCP coordination meeting, met with Don 

Kraege, Dave Brittell, and several others.

• September 16, 2009, Olympia, WA. Statewide FWS CCP coordination meeting, met with 

Don Kraege and several others. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix K – Coordination, Consultation, and Compliance K-5

Washington Department of Natural Resources

• November 16, 2007, Seattle, WA. Met with Dave Roberts, Assistant Regional Manager; Larry 

Dominguez, Stewardship Program; Kyle Murphy, Aquatic Reserve Program: Terry Carton, San 

Juan District. 

• July11, 2008, Sedro Woolley, WA. Met with Dave Roberts. 

Washington State Parks, Northwest Regional Office 

• November 27, 2007, Burlington, WA. Met with Terry Doran, NW Regional Director, Jim Neal; 

Supervisor to the San Juan Islands; Dave Castor, Ranger/Manager to Matia Island area.

• July 11, 2008, Burlington, WA. Met with Eric Watilo, NW Regional Director, and Jim Neal.

• July 17, 2008. Field trip to San Juan Islands with Jim Neal to review visitor services.

• October 16, 2009, Burlington, WA. Met with Jim Neal. 

Federal Agency Representatives

NOAA/NMFS, Office of Protected Resources 

• November 16, 2007 Seattle, WA - Met with Donna Darm, Assistant Regional Director and Brent 

Noberg, Marine Mammal Coordinator

USCG, 13th

• January 24, 2008, Seattle, WA. Met with Lieutenant Commander Matthew Walker; Seaton; 

John Moriarty; John Barberi. 

District Aids to Navigation

Marine Resource Committees (MRC) and Northwest Straits Commission

Jefferson County MRC

• June 5, 2007. Briefly introduced CCP at regular MRC meeting. 

• June 9, 2007. Gave boat tour of Protection Island to 2 boat loads (~12 people).

• October 2, 2007. Gave presentation about CCP at regular MRC meeting of approximately 16 

MRC members, guests, and staff. 

Clallam County MRC 

• February 11, 2008, Port Angeles, WA. Met with approximately 20 people met to discuss 

proposed aquatic reserve around Protection Island. 

Island County MRC

• November 6, 2007, Coupeville, WA. Gave presentation about CCP at regular MRC meeting 

with 9 MRC members and 1 State Parks staff. 

Skagit County MRC

• October 11, 2007, Anacortes, WA. Gave presentation about CCP at regular MRC meeting with 

20 MRC members, guests, and staff. 

San Juan County MRC 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

K-6 Appendix K – Coordination, Consultation, and Compliance

• October 17, 2007, Friday Harbor, WA. Gave presentation about CCP at regular MRC meeting 

with 19 MRC members, guests, and staff. 

• May 18, 2009, Friday Harbor, WA. Gave brief update of CCP at Marine managers 

Workshop. 

Northwest Straits Commission 

• January 25, 2008, Jamestown S’Klallam Tribal Office, Sequim, WA. Gave presentation about 

CCP at regular meeting with Ginny Broadhurst and 2 others from Northwest Straits Commission, 

Kathy Fletcher of Puget Sound Initiative, one person from each of the 7 MRCs and a few others. 

Research Community 

Researchers Focus Groups

• December 6, 2007, Washington Maritime NWRC, Port Angeles, WA. Met with WA Department 

of Fish and Wildlife Researchers Scott Pearson and Steve Jeffries. 

• December 6, 2007, Washington Maritime NWRC, Port Angeles, WA. Met with Julia Parrish 

professor at UW; Scott Pearson- WDFW; Peter Hodum, professor at University of Puget Sound, 

Tom Good, NOAA Fisheries.

• March 21, 2008. Met with Jim Hayward, Andrews University; Joe Galusha, Walla Walla 

College; Shandelle Henson, Andrews University.

• September 3, 2009. Conference call with seabird professionals to gather information and advice 

regarding deer impacts on seabird nesting islands, 12 participants representing FWS from other 

refuges and the migratory birds program, U S Geological Survey , Washington Dept. of Fish 

and Wildlife, University of Washington, University of Puget Sound, Andrews University, The 

Nature Conservancy, and Parks Canada.

• June 9, 2010. Met with researchers conducting operations on Protection Island and/or San 

Juan Islands NWR on Protection Island and gave short briefing on status of CCP and range 

of alternatives. Participants included Scott Pearson (WDFW), Tom Good (NOAA), Peter 

Hodum (U of Puget Sound), and Jim Hayward and Shandelle Henson (Andrews U). 

Conferences

• Georgia Basin Puget Sound Research Conference, March 25-29, 2007, Vancouver, BC Canada. 

Refuge biological technician gave a poster presentation about CCP planning issues and invited 

participants to sign up for the CPP mailing list. Audience included Canadian and U.S scientific 

and conservation community interested in Puget Sound including government and tribal 

representatives. 

• Pacific Seabird Conference, February 27- March 1, 2008. Refuge biological technician gave a 

poster presentation about CCP planning issues and invited participants to sign up for the CPP 

mailing list. Audience included people interested in seabirds, including state and federal agency 

staff; university professors and students; and many others. 

Non-government Organizations 

• The Nature Conservancy – Washington Field Office, Seattle WA, January 26, 2007. Met to 

discuss early CCP planning issues and species of concern. Additional informal coordination 

throughout 2007 and 2008 to share information regarding native plant communities especially in 

the San Juans. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix K – Coordination, Consultation, and Compliance K-7

• Admiralty Audubon Society, Port Townsend, WA, January 17, 2008. Gave CCP presentation at 

regularly scheduled meeting with approximately 30 Audubon members and guests. Additional 

coordination August 2008 ith chapter founder Eleanor Stopps. 

• Peninsula College, Museum and Arts Center, Sequim, WA – February 15, 2008. Gave CCP 

presentation to approximately 30 students and instructors. 

• Kiwanis Club, Port Townsend, WA, November 21, 2008. Gave CCP presentation to 35-40 

Kiwanis Club members. 

Public Open House Sessions

September 23, 2008, Mullis Community Center, Friday Harbor, WA

Presented preliminary management options and took comments

September 24, 2008, Fort Worden State Park, Port Townsend, WA

Presented preliminary management options and took comments

U.S. Fish and Wildlife Service Coordination

The core planning team coordinates frequently among themselves during the planning process. The 

core team also relies on specialists from various Service programs for their expertise. Additional 

coordination occurs with the Regional Office Management and the Washington Office at key phases 

in the process including: 

Washington Office briefings

• Scoping briefing statement - April 28, 2008 

• Alternatives briefing statement - March 23, 2009

R1, Pacific Regional Office Management Reviews

• Preplanning Briefing meeting March 13, 2007

• Alternative Briefing meeting June 3, 2008

• Administrative draft Briefing meeting March 10, 2010 

Planning Updates

A mailing list of approximately 500 persons and organizations is maintained at the Refuge and was 

used to distribute planning updates. Additional hardcopy planning updates were provided to refuge 

office visitors, handed out or available at meetings, available at libraries, and mailed to additional 

interested parties. Electronic copies are posted and available for downloading on the Service’s 

Region 1 planning website. 

1. October 2007– Background information on the refuges, preliminary issues and goals, 

and initiation of public scoping including a mail-in comment form.

2. August 2008 – Results of initial scoping, preliminary management options, and 

invitation to public open house meetings. 

3. Summer 2010 – Announces release of Draft CCP/WSP/EA.

Media Outreach and Press Coverage 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

K-8 Appendix K – Coordination, Consultation, and Compliance

Refuge staff sent news releases to local media contacts and made follow up calls to maximize 

likelihood of press coverage. News releases were also electronically sent to Service’s Region 1 list 

of nearly 400 regional and WA state media contacts and were posted on the Service’s Region 1 

Website. Press coverage included the following: 

News release #1: Initial Scoping, September-October 2007 

• October 3, 2007. The Islands’ Sounder.

• October 10, 2007. Port Townsend & Jefferson County Leader

• October 11, 2007. Peninsula Daily News

• February 8, 2008. Whidbey Examiner

News release #2: Preliminary Management Options, August-Sept 2008

• August 24, 2008. Peninsula Daily News 

• September 17, 2008. Journal of the San Juans

News release #3: Draft CCP/WSP/EA – Summer 2010 

Federal Register Notices

• Notice of Intent to prepare a Comprehensive Conservation Plan and Environmental Assessment 

published - August 14, 2007 

• Notice of Availability of a Draft Comprehensive Conservation Plan and Environmental 

Assessment in progress - summer 2010 

Additional Outreach Tools Used 

• A one page flyer was produced to announce the planning process and let people know where to 

get more information and where to send their comments. This was posted in August of 2008 at 

many State Marine Parks including Turn, Matia, and Jones; at The Whale Museum in Friday 

Harbor; at the Port Townsend Marine Science Center; and other locations where both summer 

visitors and residents were likely to see it. 

• Partners including SoundWatch, and State Parks assisted in getting messages out through their 

normal venues regarding CCP public meetings and opportunities to comment. 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix K – Coordination, Consultation, and Compliance K-9

STATEMENT OF COMPLIANCE 

for Implementation of Protection Island and San Juan Islands National Wildlife Refuges, 

Comprehensive Conservation Plan and San Juan Islands Wilderness Stewardship Plan

Jefferson, Clallam, Island, Skagit, and San Juan Counties, Washington

The following executive orders and legislative acts have been reviewed as they apply to implementation 

of Protection Island and San Juan Islands National Wildlife Refuges Comprehensive Conservation Plan

and San Juan Islands Wilderness Stewardship Plan. 

National Environmental Policy Act (1969). The planning process has been conducted in accordance 

with National Environmental Policy Act Implementing Procedures, Department of Interior and Service 

procedures, and has been performed in coordination with the affected public. The requirements of the 

National Environmental Policy Act (42 U.S.C. '4321 et seq.) and its implementing regulations in 40 CFR 

Parts 1500-1508 have been satisfied in the procedures used to reach this decision. These procedures 

included: the development of a range of alternatives for the CCP; analysis of the likely effects of each 

alternative; and public involvement throughout the planning process.

An environmental assessment (EA) was prepared for the project that integrated the CCP management 

objectives and alternatives into the NEPA document and process. The Draft CCP and EA shall be 

released for a 30-day public comment period. The public shall be notified of the availability of these 

documents through a Federal Register notice, news releases to local newspapers, the Service’s refuge 

planning website, and a planning update. Copies of the Draft CCP/EA and/or planning updates shall be 

distributed to an extensive mailing list. The CCP shall be revised based on public comment received on 

the draft documents.

National Historic Preservation Act (1966). The Service will continue to uphold the National Historic 

Preservation Act during implementation of the CCP. If any management actions have the potential to 

affect any historic properties, an inventory will be conducted as necessary and appropriate actions to 

mitigate effects will be identified prior to implementation of the project. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with 

affected Tribal, local and State governments, other Federal agencies, and the landowners has 

been completed through personal contact by Service Planners, Refuge managers and 

Supervisors.

Executive Order 13175. Consultation and Coordination with Indian Tribal Governments. 

As required under Secretary of the Interior Order 3206 American Indian Tribal Rights, FederalTribal Responsibilities, and the Endangered Species Act, the Project Leader and Regional Office 

staff informed the 14 Federally recognized tribes associated with the refuges planning area about 

the planning process and provided opportunities for participation and commenting on the 

proposed action. Specifically, the Service invited Tribes to 2 coordination meeting during initial 

scoping, made phone calls, sent planning updates, and provided other CCP related materials 

throughout the Service's planning process over the past three years during development of the 

Comprehensive Conservation Plan. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority 

and Low-Income Populations. All Federal actions must address and identify, as appropriate, 

disproportionally high and adverse human health or environmental effects of its programs, 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

K-10 Appendix K – Coordination, Consultation, and 

Compliance

policies, and activities on minority populations, low-income populations, and Indian Tribes in 

the United States. The CCP was evaluated and no adverse human health or environmental 

effects were identified for minority or low-income populations, Indian Tribes, or anyone else. 

Wilderness Act (1964). The San Juan Islands Wilderness area which includes 353 acres within the 

San Juan Islands NWR was established in 1976 under Public law 94-557. The only parts of this refuge 

that are not designated wilderness are Smith and Minor Islands, Turn Island, and a small portion of Matia 

Island. This CCP is also the updated San Juan Islands Wilderness Stewardship Plan. Protection Island 

NWR and the portions of San Juan Islands NWR that are not already designated wilderness were 

evaluated for suitability as wilderness. These areas were determined to not be suitable due to their altered 

nature, presence of structures, and/or strong evidence of humans. 

A Minimum Requirement Analysis (MRA) was prepared for research, monitoring and management and 

another MRA was prepared for signs management within the San Juan Islands Wilderness Area. These 

were prepared in a manner consistent with the Wilderness Act of 1964 (16 U.S.C. 1131-1136). The 

MRAs clarify the need for and determines the potential impacts of a proposed action to wilderness 

resources. The Service will authorize an activity within designated wilderness only if it is demonstrated 

that the activity meets the minimum requirement for administering the area as wilderness and 

accomplishes the purposes for which the refuge was established, including Wilderness Act purposes.

National Wildlife Administration Act of 1966, as amended by The National Wildlife Refuge 

System Improvement Act of 1997 (16 U.S.C. 668dd-668ee). During the CCP process the Refuge 

Manager evaluated all existing and proposed refuge uses on Protection Island and San Juan Islands 

Refuges. Priority wildlife-dependent uses (hunting, fishing, wildlife observation and photography, 

environmental education and interpretation) are considered automatically appropriate under Service 

policy and thus exempt from appropriate uses review. Appropriate Use Findings have been prepared for 

the following uses: research, camping, and pets. Research and camping were found to be appropriate but 

pets were not appropriate. Compatibility determinations have been prepared for the following uses: 

wildlife observation and photography, and interpretation; environmental education; research; and 

camping. All of these uses were found to be compatible with Refuge purposes and the System mission 

with stipulations specified in each of the compatibility determinations.

EO 13186. Responsibilities of Federal Agencies to Protect Migratory Birds. The CCP is 

consistent with Executive Order 13186 because the CCP and NEPA analyses evaluate the effects 

of agency actions on migratory birds. Implementation of the CCP is expected to enhance 

conditions for migratory birds on the Refuges 

Endangered Species Act. This Act provides for the conservation of threatened and endangered 

species of fish, wildlife, and plants by federal actions and by encouraging the establishment of state

programs. Section 7 of the Act requires consultation before initiating projects which affect or may affect 

endangered species. The only federally threatened or endangered species know to occur on the refuges is 

the Steller sea lion. Marbled murrelets are not found on refuge islands but forgage in the waters near the 

San Juan Islands NWR. Consultation for Steller sea lion research conducted on refuge lands is covered 

by NOAA as part of their ongoing multi-state research program. The most recent biological opinion for 

Steller seal lion and northern fur seal research activities on the west coast including WA is dated June 

2007. Other research and monitoring activities conducted by refuge staff or partners avoid going near 

areas where Steller sea lions reside and therefore should not affect them or their habitat. Law 

enforcement and educational activities aimed at reducing human disturbance to refuge wildlife including 

T&E species will maintain a low human disturbance environment on and near the refuges. If any 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix K – Coordination, Consultation, and Compliance K-11

research, monitoring, or management actions have the potential to affect Steller sea lions or marbled 

murrelets they will be the subject of separate Endangered Species Act (ESA) section 7 consultations prior 

to commencement. 

Coastal Zone Management Act, Section 307. Section 307(c)(1) of the Coastal Zone 

Management Act of 1972 as amended, requires each Federal agency conducting or supporting 

activities directly affecting the coastal zone, to conduct or support those activities in a manner 

which is, to the maximum extent practicable, consistent with approved state coastal management 

programs. The implementation of the Protection Island and San Juan Islands NWRs CCP is consistent 

with the Coastal Zone Management Act. 

Executive Order 11990. Protection of Wetlands. The CCP is consistent with Executive 

Order 11990 because CCP implementation would protect and potentially enhance existing 

wetlands.

Integrated Pest Management (IPM), 517 DM 1 and 7 RM 14

In accordance with 517 DM 1 and 7 RM 14, an integrated pest management (IPM) approach has 

been adopted to eradicate, control, or contain pest and invasive species on the refuge. In 

accordance with 517 DM 1, only pesticides registered with the US Environmental Protection 

Agency (USEPA) in full compliance with the Federal Insecticide, Fungicide, and Rodenticide 

Act (FIFRA) and as provided in regulations, orders, or permits issued by USEPA may be applied 

on lands and waters under refuge jurisdiction.

_______________________________ _________________________

Chief, Division of Refuge Planning, Date

Visitor Services, and Transportation
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix L – Abbreviations and Glossary L-1

Appendix L. Abbreviations and Glossary

L. Abbreviations

ARPA Archaeological Resources Protection Act

ATBA Area to be avoided

BBS Breeding bird survey

BCC Birds of Conservation Concern

BIDEH Biological Integrity, Diversity and Environmental Health

BLM Bureau of Land Management

BLOY Black oystercatcher

BRCO Brandt’s cormorant

CASE California sea lion

CBC Christmas Bird Count

CCP Comprehensive Conservation Plan

C E Q C ouncil of E nvir onmental Quality

CFR Code of Federal Regulations

C-MAN Coastal-Marine Automated Network 

COMU Common murre

Complex Washington Maritime National Wildlife Refuge Complex

CR Cultural resource

DAHP Department of Archaeology and Historic Preservation 

DCCO Double-crested cormorant

DDE Dichlorodiphenyldichloroethylene

DDT Dichlorodiphenyltrichloroethane

DO Dissolved oxygen 

DOD Department of Defense

EA Environmental Assessment

Ecology Washington State Department of Ecology

EE Environmental education

ELSE Elephant seal

ENSO El Niño – Southern Oscillation 

EO Executive Order

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

FAA Federal Aviation Administration

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FR Federal Register

FTE Full-time employee

GB/PS Georgia Basin/Puget Sound

GIS Geographic information system

GPS Global positioning system

GWGU Glaucous-winged gull

HASE Harbor seal

IAC Interagency Committee for Outdoor Recreation 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix L – Abbreviations and Glossary L-2

Improvement Act National Wildlife Refuge System Improvement Act of 1997

IPCC Intergovernmental Panel on Climate Change

IPM Integrated pest management

IOSA Island Oil Spill Association 

MAMU Marbled murrelet

MESA Marine Ecosystem Analysis 

MHHW Mean higher high water 

MLLW Mean lower low water 

MMPA Marine Mammal Protection Act

MSL Mean sea level 

MOU Memorandum of Understanding

MRA Minimum Requirement Analysis

NADB National Archaeological Database 

NAGPRA Native American Graves Protection and Repatriation Act

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NOAA National Oceanic and Atmospheric Administration (also NOAA 

Fisheries)

NPS National Park Service

NRHP National Register of Historic Places

NSRE National Survey on Recreation and the Environment (Pacific 

Region)

NWR National Wildlife Refuge

NWRS National Wildlife Refuge System

OMB Office of Management and Budget

OSU Oregon State University

PAH Polycyclic aromatic hydrocarbons 

PBDE Polybrominated diphenyl ether

PBT Persistent bioaccumulative toxic

PCB Polychlorinated biphenyl

PECO Pelagic cormorant

PI Protection Island

PIGU Pigeon guillemot 

PL Public Law

PLO Public Land Order

PRPA Paleontological Resources Preservation Act

PSAT Puget Sound Action Team

PSAMP Puget Sound Ambient Monitoring Program

PUP Pesticide Use Proposal

RCO Recreation and Conservation Committee (Washington State)

RCW Revised Code of Washington 

RHAU Rhinoceros auklet 

RONS Refuge Operational Needs System

SCORP State Comprehensive Outdoor Recreation Planning 

Service U.S. Fish and Wildlife Service (also, FWS)

SHPO State Historic Preservation Office
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix L – Abbreviations and Glossary L-3

SJI San Juan Islands

SJIVB San Juan Islands Visitors Bureau

STSE Steller (northern) sea lion

SUP Special use permit

TNC The Nature Conservancy

TUPU Tufted puffin 

USC United States Code

USCG U.S. Coast Guard

USC&GS U.S. Coast and Geodetic Survey

USCS U.S. Coast Survey

USDA United States Department of Agriculture

USEPA U.S. Environmental Protection Agency 

USGS U.S. Geological Survey

UW University of Washington

UWCIG University of Washington Climate Impacts Group

VS Visit Seattle

WAC Washington Administrative Code

WDOE Washington Department of Ecology

WDFW Washington Department of Fish and Wildlife

WDNR Washington Department of Natural Resources

WRCC Western Regional Climate Center

WSDOT Washington State Department of Transportation

WSP Wilderness Stewardship Plan

WSPRC Washington State Parks and Recreation Commission

WWTA Washington Water Trails Association 

WWU Western Washington University

YHONA Yaquina Head Outstanding Natural Area
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix L – Abbreviations and Glossary L-4

Glossary 

Adaptive Management. Refers to a process in which policy decisions are implemented 

within a framework of scientifically driven experiments to test predictions and 

assumptions inherent in a management plan. Analysis of results help managers determine 

whether current management should continue as is or whether it should be modified to 

achieve desired conditions.

Alcid. A family of seabirds that includes tufted puffin, rhinoceros auklet, Cassin’s auklet,

common murre, ancient and marbled murrelet, and pigeon guillemot. They are colonial 

nesters, fish eaters, long-lived, and have low reproductive output.

Alternative. 1. A reasonable way to fix the identified problem or satisfy the stated need 

(40 CFR 1500.2). 2. Alternatives are different means of accomplishing refuge purposes 

and goals and contributing to the System mission (Service Manual 602 FW 1.6).

Anadromous. A fish that hatches in freshwater, migrates to the ocean to live and grow, 

and returns to freshwater to spawn.

Ballast Water. Water added to the ballast tanks of cargo vessels when empty to increase 

propeller immersion, to improve steering, and to control trim and draft.

Bedland. Aquatic lands that are submerged at all times, including all navigable salt and 

fresh waters.

BIDEH. Biological integrity, diversity and environmental health represented by native 

fish, wildlife, plants and their habitats as well as those ecological processes that support 

them.

Bioaccumulative toxin. Contaminants, such as heavy metals, that are accumulated in 

the tissue of organisms that live or forage in the environment. 

Biological Diversity. The variety of life and its processes, including the variety of living

organisms, the genetic differences among them, and the communities and ecosystems in 

which they occur (Service Manual 052 FW 1.12B). The System’s focus is on indigenous 

species, biotic communities, and ecological processes. Also referred to as Biodiversity.

Bycatch. Marine organisms that are incidentally caught, along with the target fish 

species, by commercial and recreational fishing operations. Common bycatch species 

include seabirds, marine mammals, and fish species.

Carrying Capacity. The maximum population of a species a habitat or area can support.

Compatible Use. A proposed or existing wildlife-dependent recreational use or any other 

use of a national wildlife refuge that, based on sound professional judgment, will not 

materially interfere with or detract from the fulfillment of the National Wildlife Refuge 
Protection Island and San Juan Islands National Wildlife Refuges Draft CCP/WSP/EA

Appendix L – Abbreviations and Glossary L-5

System mission or the purposes of the national wildlife refuge (Service Manual 603 FW 

2.6). A compatibility determination supports the selection of compatible uses and 

identifies stipulations or limits necessary to ensure compatibility.

Comprehensive Conservation Plan (CCP). A document that describes the desired 

future conditions of a refuge or planning unit and provides long-range guidance and 

management

direction to achieve the purposes of the refuge; helps fulfill the mission of the Refuge 

System; maintains and, where appropriate, restores the ecological integrity of each refuge 

and the Refuge System; helps achieve the goals of the National Wilderness Preservation 

System; and meets other mandates. (Service Manual 602 FW 1.6).

Concern. See definition of issue.

Cover Type. The type of vegetation in an area. Often referred to as percent cover or the 

% of ground covered by vegetation type (e.g. 20% shrub cover).

Cultural Resources. The remains of sites, structures, or objects used by people in the 

past.

Cultural Resource Inventory. A professionally conducted study designed to locate and

evaluate evidence of cultural resources present within a defined geographic area. 

Inventories may involve various levels, including a background literature search, a 

comprehensive field examination to identify all exposed physical manifestations of 

cultural resources, or a sample inventory to project site distribution and density over a 

larger area. Evaluation of identified cultural resources to determine eligibility for the 

National Register follows the criteria found in 36 CFR 60.4 (Service Manual 614 FW 

1.7).

Demography. The study of life-history parameters such as adult survival, fledgling 

success, number of broods raised per year. 

Disturbance. Significant alteration of wildlife behavior or habitat structure and 

composition. May be natural (e.g., fire) or human-caused events (e.g., aircraft over 

flight).

Ecosystem. A dynamic and interrelating complex of plant and animal communities and 

their associated non-living environment.

Ecosystem Management. Management of natural resources using system-wide concepts 

to ensure that all plants and animals in ecosystems are maintained at viable levels in 

native habitats and basic ecosystem processes are perpetuated indefinitely.

Endangered Species (Federal). A plant or animal species listed under the Endangered 

Species Act that is in danger of extinction throughout all or a significant portion of its 

range.
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Endangered Species (State). A plant or animal species in danger of becoming extinct or

extirpated in Washington within the near future if factors contributing to its decline 

continue. Populations of these species are at critically low levels or their habitats have 

been degraded or depleted to a significant degree.

Environmental Assessment (EA). A concise public document, prepared in compliance 

with the National Environmental Policy Act, that briefly discusses the purpose and need 

for an action, alternatives to such action, and provides sufficient evidence and analysis of 

impacts to determine whether to prepare an environmental impact statement or finding of 

no significant impact (40 CFR 1508.9).

Finding of No Significant Impact (FONSI). A document prepared in compliance with 

the National Environmental Policy Act, supported by an environmental assessment, that 

briefly presents why a federal action will have no significant effect on the human 

environment and for which an environmental impact statement, therefore, will not be 

prepared (40 CFR 1508.13).

Fire Regime. A natural fire regime is a general classification of the role fire would play 

across a landscape in the absence of modern human mechanical intervention, but 

including the influence of aboriginal burning.

Focal Resources. Plant and animal species that are most representative of refuge 

purposes, BIDEH and other FWS and ecosystem priorities. Conservation and 

management of these species will guide refuge management in the future. See Priority 

Resources of Concern and Other Benefiting Species.

Forb. A broad-leaved, herbaceous plant; for example, a columbine.

Gillnet. A fishing net stretched between a weighted leadline on the bottom and a floatline 

on the top to support it vertically in the water column. A pelagic drift gillnet may be 

attached to free floating buoys at one end and a vessel at the other end. The species of 

fish targeted determines the size of the mesh in a gillnet. The fish can get its head through 

the net, but when it tries to back out, the fish is caught on the net by its gills.

Goal. A descriptive, open-ended, and often broad statement of desired future conditions 

that conveys a purpose, but does not define measurable units (Service Manual 602 FW 

1.6).

Habitat. Suite of existing environmental conditions required by an organism for survival 

and reproduction. The place where an organism typically lives.

Habitat Type. See Vegetation Type.

Habitat Restoration. Management emphasis designed to move ecosystems to desired 

conditions and processes, and/or to healthy ecosystems.
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Invasive Species. A nonnative species whose introduction causes or is likely to cause 

economic or environmental harm. Also referred to as exotic or non-native species.

Inventory. A survey that documents the presence, relative abundance, status and/or 

distribution of abiotic resources, species, habitats, or ecological communities at a 

particular time. Often referred to as baseline inventory.

Issue. Any unsettled matter that requires a management decision (e.g., a Service 

initiative, opportunity, resource management problem, a threat to the resources of the 

unit, conflict in uses, public concern, or the presence of an undesirable resource 

condition) (Service Manual 602 FW 1.6).

Lacustrine. Relating to a lake.

Kleptoparasitism. A form of feeding in which one animal takes prey from the animal 

that caught or collected it. 

Management Alternative. See Alternative.

Migration. The seasonal movement from one area to another and back.

Mission Statement. Succinct statement of a unit’s purpose and reason for being.

Monitoring. A survey repeated through time to determine changes in the status and/or 

demographics of abiotic resources, wildlife or plants, habitat, or ecological communities. 

National Environmental Policy Act of 1969 (NEPA). Requires all agencies, including 

the Service, to examine the environmental impacts of their actions, incorporate 

environmental information, and use public participation in the planning and 

implementation of all actions. Federal agencies must integrate NEPA with other 

planning requirements, and prepare appropriate NEPA documents to facilitate better 

environmental decision making (40 CFR 1500).

National Wildlife Refuge. A designated area of land, water, or an interest in land or 

water within the National Wildlife Refuge System.

National Wildlife Refuge System. All lands, waters and interests therein administered 

by the Service as wildlife refuges, wildlife ranges, wildlife management areas, waterfowl

production areas, and other areas for the protection and conservation of fish and wildlife,

including those that are threatened with extinction.

National Wildlife Refuge System Mission. The mission is to administer a national 

network of lands and waters for the conservation, management, and where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans.
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Native Species. Species that normally live and thrive in a particular ecosystem.

Noxious species. Any plant or plant product that can directly or indirectly injure or cause 

damage to crops (including nursery stock or plant products), livestock, poultry, or other 

interests of agriculture, irrigation, navigation, the natural resources of the United States, 

the public health, or the environment. Control of these species is mandated by law.

Objective. An objective is a concise target statement of what will be achieved, how much 

will be achieved, when and where it will be achieved, and who is responsible for the 

work. Objectives are derived from goals and provide the basis for determining 

management strategies. Objectives should be attainable and time-specific and should be 

stated quantitatively to the extent possible. If objectives cannot be stated quantitatively, 

they may be stated qualitatively (Service Manual 602 FW 1.6).

Obligate Species. Species that require a specific habitat type or plant species for their 

existence.

Ocean Acidification. The ongoing decrease in the pH of the Earth's oceans, caused by 

their uptake of anthropogenic carbon dioxide from the atmosphere.

Other Benefiting Species. Native species, other than priority resources of concern and 

focal resources, that will benefit from management actions. 

Paleontology. The study of prehistoric life, including organisms' evolution and 

interactions with each other and their environments.

Passerine. See songbird

Pinniped. A suborder of carnivores that are marine mammals, have flippers, and eat 

mostly fish and marine invertebrates (e.g., sea lions, seals).

Plant Association. A classification of plant communities based on the similarity in 

dominants of all layers of vascular species in a climax community.

Plant Community. An assemblage of plant species unique in its composition; occurs in

particular locations under particular influences; a reflection or integration of the 

environmental influences on the site such as soils, temperature, elevation, solar radiation, 

slope, aspect, and rainfall; denotes a general kind of climax plant community (e.g., Sitka 

spruce).

Preferred Alternative. This is the alternative determined (by the decision maker) to 

best: achieve a refuge’s purpose(s), vision, and goals; contributes to the Refuge System 

mission; addresses the significant issues; and is consistent with principles of sound fish 

and wildlife management.
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Priority Resources of Concern. Habitats that are most representative of refuge BIDEH, 

as well as other FWS and ecosystem priorities that were chosen as resources that will 

guide refuge management in the future. See Focal Resources.

Priority Species. Fish and wildlife species that the Washington Department of Fish and 

Wildlife believe require protective measures and/or management guidelines to ensure 

their perpetuation. Priority species include the following: (1) state listed and candidate 

species; (2) species or groups of animals susceptible to significant population declines 

within a specific area or statewide by virtue of their inclination to aggregate (e.g., seabird 

colonies); and (3) species of recreational, commercial, and/or Tribal importance.

Public. Individuals, organizations, and groups; officials of Federal, state, and local 

government agencies; Indian tribes; and foreign nations. It may include anyone outside 

the core planning team. It includes those who may or may not have indicated an interest 

in Service issues and those who do or do not realize that Service decisions may affect 

them.

Puget Sound. Estuarine system of interconnected marine waterways and basins 

extending from Deception Pass and Admiralty Inlet in the North to Olympia, Washington 

in the south and Hood Canal to the west. 

Purpose(s) of the Refuge. The purpose of a refuge is specified in or derived from the 

law, proclamation, executive order, agreement, public land order, donation document, or

administrative memorandum establishing, authorizing, or expanding a refuge, refuge unit, 

or refuge subunit (Service Manual 602 FW 1.6).

Refuge Goal. See Goal.

Refuge Purposes. See Purposes of the Refuge.

Salish Sea. A single estuarine ecosystem that extends from the north end of the Strait of 

Georgia to the west end of the Strait of Juan de Fuca and south to the southern extent of 

Puget Sound. It encompasses the inland marine waters of Southern British Columbia, 

Canada and northern Washington, USA (WWU 2009).

San Juan Archipelago. The San Juan Archipelago is split into two groups of islands 

based on national sovereignty. The San Juan Islands are part of the U.S. state of 

Washington within San Juan, Whatcom and Skagit counties. The Gulf Islands are part of 

the Canadian province of British Columbia. There are over 450 rocks (with minimal 

vegetation) and islands (with vegetation) in the entire archipelago at high tide. Within 

this document, we refer to the U.S. portion of the archipelago when using this term.

Seabird. A group of birds that obtain at least some food from the ocean by traveling 

some distance over its surface. They also typically breed on islands and along coastal 

areas. Seabirds include: gulls, alcids, penguins, albatrosses, storm-petrels, and 

cormorants, among others.
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Appendix L – Abbreviations and Glossary L-10

Songbirds. (Also Passerines) A category of birds that are medium to small, perching land 

birds. Most are territorial singers and migratory.

Step-down Management Plans. Step-down management plans provide the details 

necessary to implement management strategies identified in the Comprehensive 

Conservation Plan (Service Manual 602 FW 1.6).

Strategy. A specific action, tool, or technique or combination of actions, tools, and 

techniques used to meet unit objectives (Service Manual 602 FW 1.6).

Succession. The observed process of change in the species structure of an ecological 

community over time.

T-sheet. A historic type of topographic map produced by the U.S. Coast and Geodetic 

Survey.

Threatened Species (Federal). Species listed under the Endangered Species Act that are 

likely to become endangered within the foreseeable future throughout all or a significant 

portion of their range.

Threatened Species (State). A plant or animal species likely to become endangered in

Washington within the near future if factors contributing to population decline or habitat

degradation or loss continue.

Tidelands. Submerged lands and beaches that are located between ordinary high tide and 

extreme low tide.

U.S. Fish and Wildlife Service Mission. The mission of the U.S. Fish and Wildlife 

Service is working with others to conserve, protect, and enhance fish and wildlife and 

their habitats for the continuing benefit of the American people.

Vegetation Type, Habitat Type, Forest Cover Type. A land classification system based 

upon the concept of distinct plant associations.

Vision Statement. A concise statement of the desired future condition of the planning 

unit, based primarily upon the System mission, specific refuge purposes, and other 

relevant mandates (Service Manual 602 FW 1.6).

Wilderness. “...an area of undeveloped Federal land retaining its primeval character and 

influence, without permanent improvement or human habitation..." (Wilderness Act 

1964)