San Juan Islands National Monument 

Draft Resource Management Plan and 

Environmental Impact Statement 

. ,..,!!',~'''~·~· ,-.r,..• . 

Estimated Lead A~ YiI[ c;>~ I.Costs 

Associated with Dev~[Slping:c!nd •· 

Producing this EIS .. · 'S< 

$1,990,000 ,,. ·. 

U.S. Department of the Interior 

Bureau of Land Management 

 

 

United States Department of the Interior 

Bureau of Land Management 

Draft Resource Management Plan and Environmental Impact Statement 

for the San Juan Islands National Monument 

September 2018 

Cooperating Agencies: 

City of Anacortes, WA State of Washington 

National Park Service, San Juan Island National Stillaguamish Tribe of Indians 

Historical Park Town of Friday Harbor, WA 

Port Gamble S'Klallam Tribe Tulalip Tribes of Washington 

Samish Indian Nation U.S. Coast Guard 

San Juan County U.S. Fish and Wildlife Service 

Skokomish Indian Tribe U.S. Navy, Naval Air Station Whidbey Island 

Abstract: The Draft San Juan Islands National Monument Resource Management Plan and 

Environmental Impact Statement (Draft RMP/EIS) describes and evaluates a range of potential 

management approaches for approximately 1,000 acres of Bureau of Land Management (BLM) 

administered land in the San Juan Islands. The BLM prepared this document in coordination with 

cooperating agencies and consulting tribes and with input from the Monument Advisory Committee and 

the public. No RMP currently addresses these lands. 

The purpose of this planning effort is to protect the cultural and ecological values for which the 

Monument was designated, to ensure that tribal rights are respected, and to address the growing demand 

for recreational use of the Monument. The BLM analyzed four action alternatives, one sub-alternative, 

and a No Action Alternative. Under the No Action Alternative, the Monument would continue to lack an 

RMP and the BLM’s current custodial management would continue. 

Comments on the Draft RMP/EIS are due within 90 days of publication of the EPA Notice of Availability 

in the Federal Register. The BLM will announce the close of the comment period in news releases, 

newsletters, and on the San Juan Islands National Monument RMP website at https://go.usa.gov/xRphc. 

For more information, contact: 

San Juan Islands National Monument 

BLM Lopez Island Office 

PO Box 3 

Lopez, WA 98261 

Phone: (360) 468-3754 

Email: blm_or_sanjuanislandsnm@blm.gov 

i 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

In reply refer to: 

1610 (ORW000) 

San Juan Islands National Monument Resource Management Plan 

Dear Reader: 

The Draft San Juan Islands National Monument Resource Management Plan and Environmental Impact 

Statement (Draft RMP/EIS) for the Oregon/Washington Bureau of Land Management’s (BLM) Spokane 

District is now available for review. The BLM prepared this document in coordination with cooperating 

agencies and consulting tribes and with input from the Monument Advisory Committee and the public. 

The BLM is undertaking this planning process in accordance with Presidential Proclamation 8947; the 

National Environmental Policy Act of 1969, as amended; the Federal Land Policy and Management Act 

of 1976, as amended; implementing regulations; the BLM’s Land Use Planning Handbook (H-1601-1); 

and other applicable laws and policies. 

This planning process will determine the long-term management of the San Juan Islands National 

Monument, which encompasses approximately 1,000 acres 1 of BLM-administered lands in the San Juan 

Islands. No RMP currently addresses these lands. The Draft RMP/EIS describes and evaluates a range 

of potential management approaches for the Monument. The Draft RMP/EIS and supporting information 

is available at https://go.usa.gov/xRphc. 

Chapter 1 of the Draft RMP/EIS describes the purpose and need for the planning effort and the BLMadministered land that the BLM will manage under the new RMP. Chapter 2 describes the range of 

approaches the BLM is considering for managing the Monument. Chapter 3 describes the effects of the 

RMP alternatives on resources and values. Chapter 4 describes the public involvement and collaboration 

that occurred during the preparation of this Draft RMP/EIS. That collaboration includes engagement 

with cooperating agencies and government-to-government relationships with tribes. This chapter also 

includes a list of BLM staff involved in the planning effort. 

You will have 90 days to provide written comments on the San Juan Islands National Monument Draft 

RMP/EIS; we encourage you to review it and provide feedback. Comments pertaining to the alternatives 

and analysis would be most helpful to ensuring that the range of alternatives is adequate and the analysis 

is credible to the extent they do the following: 

 Present new information relevant to the analysis

 Present reasonable alternatives, other than those already included in the Draft RMP/EIS

 Make suggestions, with a reasonable basis, for the development of a Proposed RMP

1 This includes approximately 189 acres withdrawn to the U.S. Coast Guard that the BLM currently co-manages but 

does not administer. The U.S. Coast Guard is in the process of relinquishing these withdrawals. 

ii 
 

 

 

 

 Question, with reasonable basis, the adequacy of, method for, or assumptions used in the analysis

 Question, with reasons, the accuracy of information contained in the Draft RMP/EIS

The BLM is required to provide written responses to comments that meet one or more of the above 

criteria. The BLM is not required to provide written responses to comments that simply vote on an 

alternative or state support or opposition to BLM policies or proposals without providing reasons. 

The BLM has a variety of structured comment forms that members of the public may use to provide 

input. Members of the public may also provide comments without the aid of a comment form. 

Comments may be submitted in a variety of ways: 

Email: blm_or_sanjuanislandsnm@blm.gov 

Mail: 

San Juan Islands National Monument Comments 

Lopez Island BLM Office 

PO Box 3 

Lopez, WA 98261 

Hand delivery to: 

San Juan Islands National Monument 

BLM Lopez Island Office 

37 Washburn Place 

Lopez Island, WA 98261 

or 

Spokane District BLM Office 

N Fancher Rd 

Spokane Valley, WA 99212 

Before including your address, phone number, e-mail address, or other personal identifying information in 

your comment, know that your entire comment—including your personal identifying information—may 

be made publicly available at any time. While you can ask us in your comment to withhold your personal 

identifying information from public review, we cannot guarantee that we will be able to do so. 

The BLM will hold a series of public meetings to provide information on the Draft RMP/EIS, respond to 

questions, and receive public comments. The BLM will announce all public meetings at least 15 days in 

advance on the RMP website and through announcements to the local media. 

The BLM has sent copies of the Draft RMP/EIS to affected Tribal, Federal, State, and local government 

agencies. Copies of the Draft RMP/EIS are available for review at public libraries throughout the 

planning area, as well as at the BLM office on Lopez Island (37 Washburn Place, Lopez Island, WA) and 

in Spokane (1103 N Fancher Rd, Spokane Valley, WA). 

Thank you for your continued interest in the San Juan Islands National Monument planning process. We 

appreciate the information and suggestions you contribute to the planning process. 

Sincerely, 

Linda Clark 

District Manager 

iii 
Executive Summary ....................................................................................................................................vii 

Chapter 1: Introduction.................................................................................................................................1 

Chapter 2: Alternative Approaches to Managing the San Juan Islands National Monument .......................7 

Cultural Resources...................................................................................................................................12 

Education and Interpretation ...................................................................................................................14 

Grazing ....................................................................................................................................................15 

Habitat and Plants....................................................................................................................................16 

Hazardous Materials................................................................................................................................21 

Lands and Realty .....................................................................................................................................23 

Natural Material Collection.....................................................................................................................25 

Paleontology ............................................................................................................................................26 

Partnerships .............................................................................................................................................27 

Recreation and Visitor Services ..............................................................................................................28 

Science.....................................................................................................................................................32 

Tribal Interests.........................................................................................................................................33 

Travel and Transportation .......................................................................................................................34 

Visual Resources Management ...............................................................................................................36 

Wilderness Characteristics ......................................................................................................................37 

Wildfire Response ...................................................................................................................................39 

Wildlife and Fish .....................................................................................................................................40 

Chapter 3: Affected Environment and Effects Analysis .............................................................................41 

Air Quality .............................................................................................................................................41 

Analytical Issue 1: How would the alternatives affect levels of particulates (PM2.5 and PM10) and 

ozone in the planning area? ................................................................................................................. 41 

Climate Change ....................................................................................................................................45 

Analytical Issue 1: What opportunities would the alternatives provide to respond to the effects of 

climate change?.................................................................................................................................... 45 

Cultural Resources ................................................................................................................................45 

Analytical Issue 1: How would the alternative approaches to shoreline stabilization, vegetation 

management, and recreation management affect archaeological and other cultural resources in the 

Monument?........................................................................................................................................... 50 

Analytical Issue 2: How would the alternatives affect historic properties in the maritime heritage 

areas? ................................................................................................................................................... 61 

Education and Interpretation...............................................................................................................70 

Analytical Issue 1: How would the alternatives affect education/interpretation in the Monument? ... 70 

Habitat and Plants.................................................................................................................................73 

Analytical Issue 1: How would each alternative affect the extent of vegetative communities? ........... 73 

Analytical Issue 2: How would each alternative affect the condition of each plant community? ........ 77 

Analytical Issue 3: How would the alternatives vary in the approximate extent and type of vegetation 

treatments the BLM would apply during their implementation? ....................................................... 110 

Analytical Issue 4: How would the alternatives affect special status plants and lichen and Washington 

Natural Heritage Program priority ecological communities? ........................................................... 117 

iv 
 

 

Analytical Issue 5: How would the alternatives affect invasive plant species presence and spread 

within the Monument and the San Juan Islands?............................................................................... 130 

Analytical Issue 6: How would use of chemical treatments (e.g., herbicides) affect non-target 

resources including vegetation, human health and safety, water quality, wildlife, and soils? .......... 136 

Lands and Realty.................................................................................................................................137 

Analytical Issue 1: How would the alternatives affect the availability of Monument lands for rightsof-way? ............................................................................................................................................... 138 

Analytical Issue 2: How would the alternatives affect the BLM’s ability to engage in land exchanges

that further the protective purposes of Proclamation 8947? ............................................................. 140 

Paleontological Resources...................................................................................................................140 

Analytical Issue 1: How would the alternatives affect paleontological resources in the 

Monument?......................................................................................................................................... 141 

Recreation and Visitor Services ........................................................................................................145 

Analytical Issue 1: How would the alternatives’ approaches to recreation and transportation affect

recreational opportunities?................................................................................................................ 146 

Analytical Issue 2: How would the BLM’s designation of recreation opportunity spectrum classes

across the alternatives affect recreation settings in the Monument? ................................................. 183 

Analytical Issue 3: How would the alternatives indirectly affect the management of human use 

activities on nearby non-BLM-administered lands in the San Juan Islands? .................................... 187 

Scientific Research...............................................................................................................................191 

Analytical Issue 1: How would the alternatives affect the use of the Monument for research? ........ 191 

Socioeconomics ....................................................................................................................................192 

Analytical Issue 1: How would the alternatives affect economic activity in the planning area derived 

from BLM-administered lands?.......................................................................................................... 193 

Analytical Issue 2: How would the alternatives affect the quality of life for local communities in the 

planning area? ................................................................................................................................... 197 

Analytical Issue 3: Would the alternatives result in environmental justice impacts? ........................ 202 

Soils .......................................................................................................................................................206 

Analytical Issue 1: How would the alternatives’ management of human uses and vegetation affect soil

stability and sediment-based water quality issues?............................................................................ 206 

Special Designations ............................................................................................................................212 

Analytical Issue 1: How would the alternatives affect areas of critical environmental concern within 

the Monument?................................................................................................................................... 212 

Analytical Issue 2: How would the alternatives affect the extent of the Cascadia Marine Trail? ..... 213 

Tribal Interests ....................................................................................................................................215 

Analytical Issue 1: How would the alternatives affect tribal interests and activities?....................... 215 

Visual Resources..................................................................................................................................225 

Analytical Issue 1: How would the BLM’s designation of visual resource management classes under

each alternative affect visual resources? ........................................................................................... 226 

Wilderness Characteristics .................................................................................................................231 

Analytical Issue 1: How would the alternatives affect wilderness characteristics in the 

Monument?......................................................................................................................................... 232 

Wildfire.................................................................................................................................................236 

v 
 

 

Analytical Issue 1: How would alternatives affect fire behavior and risks to Monument objects and 

values or adjoining lands? ................................................................................................................. 236 

Wildlife .................................................................................................................................................247 

Analytical Issue 1: How would changes in the quality and quantity of habitat and plant communities 

affect wildlife species and fishes (including sensitive species) under each alternative?.................... 249 

Analytical Issue 2: How would variations in human use/disturbance under each alternative affect 

wildlife species and fishes (including special status species)?........................................................... 265 

Analytical Issue 3: How would the alternatives address the primary threats to island marble 

butterflies identified in the U.S. FWS’ 12 month finding for the species?.......................................... 280 

Analytical Issue 4: How would variations in the control of wildlife of management concern and 

opportunities for hunting using firearms impact wildlife habitat?..................................................... 284 

Chapter 4 – Consultation and Coordination..............................................................................................288 

Appendices 

Appendix A: Alternatives and Issues Considered but not Analyzed in Detail .........................................290 

Appendix B: Analytical Methods .............................................................................................................295 

Appendix C: Area of Critical Environmental Concern Determinations ...................................................344 

Appendix D: Area of Critical Environmental Concern—Existing Management .....................................351 

Appendix E: Background and Supplementary Information on Resources and Uses................................352 

Appendix F: Best Management Practices .................................................................................................407 

Appendix G: Commonly Used Acronyms and Glossary ..........................................................................421 

Appendix H: Draft Travel and Transportation Management Plan............................................................451 

Appendix I: Existing BLM Oregon/Washington Supplementary Rules...................................................581 

Appendix J: Implementation Level Plans and Administrative Actions ....................................................589 

Appendix K: Pertinent Laws and Regulations..........................................................................................591 

Appendix L: Planning Criteria and Planning Issues .................................................................................600 

Appendix M: Preparers of the Draft RMP/EIS.........................................................................................603 

Appendix N: Presidential Proclamation 8947...........................................................................................604 

Appendix O: Recreation Area Management Frameworks ........................................................................608 

Appendix P: References............................................................................................................................659 

Appendix Q: Summary of Tiered and Incorporated by Reference Herbicide Analyses ...........................694 

Appendix R: Table of Objects Identified in Presidential Proclamation 8947...........................................705 

Appendix S: Tables Summarizing Alternatives by Resource and Use .....................................................707 

Appendix T: Timeline and Overview of BLM Planning Process .............................................................720 

Appendix U: Wildlife—Life Histories of Special Status Wildlife ...........................................................723 

Appendix V: Wildlife—Wildlife within the San Juan Islands and their Habitat Associations ................726 

vi 
 

 

 

 

 

Executive Summary 

Background and Introduction 

On March 25, 2013, President Obama signed Presidential Proclamation 8947 designating the San Juan 

Islands National Monument (Monument). The Monument consists of 1,021 acres of land scattered across 

the San Juan Islands, which lie in the heart of the Salish Sea. This acreage includes approximately 842 

acres currently under BLM jurisdiction and approximately 189 acres withdrawn to the U.S. Coast Guard 

(i.e., currently under Coast Guard jurisdiction). The U.S. Coast Guard is in the process of relinquishing 

these withdrawals. The BLM anticipates that all 189 acres will come under BLM administration prior to 

the publication of the record of decision for this planning process. 

The BLM prepared this Draft Resource Management Plan/Draft Environmental Impact Statement (Draft 

RMP/EIS) with input from consulting tribes, cooperating agencies, the Monument Advisory Committee, 

and the public. The Draft RMP/EIS was prepared in accordance with Proclamation 8947; the Federal 

Land Policy and Management Act (FLPMA) of 1976; 43 CFR 1610; and with guidance from the BLM’s

Land Use Planning Handbook (BLM 2005). The Draft RMP/EIS provides the overarching objectives and 

direction for the Monument, as well as identifying prohibited and allowable uses of Monument lands. 

What is the purpose and need for this Draft RMP? 

The “purpose and need” is a formal statement developed for each BLM planning effort. It describes the 

BLM’s purpose and need for action. In this case, the BLM’s need is to develop an RMP for the 

Monument. The purpose of this planning effort is to protect the cultural and ecological values for which 

the Monument was designated, to ensure that tribal treaty rights are respected, and to address the growing 

demand for recreational use of the Monument. 

The need for this RMP arises from the BLM’s requirement to develop RMPs that provide for the use of 

public lands under the FLPMA. The need is also established by Proclamation 8947, which directs the 

BLM to ‘‘prepare and maintain a management plan for the monument.” 

Why is the BLM developing an Environmental Impact 

Statement for this RMP? 

The National Environmental Policy Act requires that the BLM prepare an EIS for all actions that 

significantly affect the quality of the human environment. The BLM planning regulations define the 

approval of an RMP as a major Federal action significantly affecting the quality of the human 

environment. These regulations also require that the BLM undertake the environmental analysis of 

alternatives as part of the RMP process and, wherever possible, publish these components as part of a 

single document. Therefore, the BLM presents this Draft RMP integrated with the Draft EIS. 

What types of coordination did the BLM undertake during Draft 

RMP/EIS Development? 

Public Involvement 

The BLM published the Notice of Intent to prepare the RMP in the Federal Register on March 2, 2015. 

The Notice of Intent began a 30-day initial scoping for commenting on issues and planning criteria. In 

addition to publishing the Notice of Intent, the BLM distributed press releases and sent numerous letters 

and emails to potentially interested individuals, organizations, and agencies. The BLM also held five 

public scoping meetings across the Monument. 

The BLM further solicited input on human uses (i.e., recreation) and travel management (i.e., road and 

trail networks) during the winter and spring of 2016. During that time, the BLM held four workshops 

and one Monument Advisory Committee meeting. The BLM used this input to develop recreation 

management area frameworks and a draft travel and transportation plan (see appendices H and O in the 

Draft RMP/EIS). 

vii 
 

 

 

 

The BLM also emailed multiple newsletters to interested parties during Draft RMP/EIS development. 

Monument Advisory Committee 

Proclamation 8947 required that the BLM “establish an advisory committee under the Federal Advisory 

Committee Act (5 USC App.) to provide information and advice regarding the development [an RMP].” 

The Monument Advisory Committee is composed of twelve members representing a variety of interests. 

The Secretary of the Interior appoints committee members for two year terms. 

During the development of the Draft RMP/EIS, the Monument Advisory Committee met with the BLM 

multiple times to provide input on the Monument’s values, human uses of the Monument, and on public 

involvement methods and opportunities. The BLM announces all committee meetings in advance. 

These meetings are open to the public and include a public comment period. 

Government-to-Government Consultation 

The BLM consulted with twelve federally recognized Native American tribes known to have interests in 

the Monument. This consultation identified areas of mutual interest and concern, as well as helped the 

BLM consider the potential effects of Federal undertakings and actions on tribal rights and interests. 

As part of government-to-government consultation, the BLM notified potentially interested tribes prior 

to the start of the public scoping period. Additionally, the BLM solicited input from and met with tribal 

governments throughout the planning process, providing numerous input and review opportunities on the 

Draft RMP/EIS. 

The twelve federally recognized Native American tribes the BLM is consulting with on this effort are: 

Jamestown S'Klallam Tribe Skokomish Indian Tribe 

Lower Elwha Tribe Stillaguamish Tribe of Indians 

Lummi Nation Suquamish Tribe 

Nooksack Tribe Swinomish Indian Tribal Community 

Port Gamble S'Klallam Tribe Tulalip Tribes of Washington 

Samish Indian Nation Upper Skagit Tribe 

Cooperating Agencies 

In April of 2015, the BLM invited agencies with jurisdiction by law and/or special expertise to 

participate as cooperating agencies in the planning process. A cooperating agency is a Tribal, Federal, 

State, or local government agency with jurisdiction by law or special expertise that assists a lead Federal 

agency in developing an environmental assessment or environmental impact statement. Thirteen Tribal, 

Federal, State, and local agencies responded and developed unique memorandums of understanding to 

aid in development of this RMP. Throughout the planning process, the BLM solicited input from and 

met with cooperators to discuss specific issues and analysis. The BLM also held resource-specific 

conference calls with sub-sets of the cooperating agency group. 

The thirteen cooperating agencies associated with this effort are: 

City of Anacortes Stillaguamish Tribe of Indians 

National Park Service, San Juan Town of Friday Harbor 

Island National Historical Park Tulalip Tribes of Washington 

Port Gamble S'Klallam Tribe U.S. Coast Guard 

Samish Indian Nation U.S. Fish and Wildlife Service 

San Juan County U.S. Navy, Naval Air Station 

Skokomish Indian Tribe Whidbey Island 

State of Washington 

viii 
 

 

 

 

 

 

Regulatory Agency Consultation 

Section 7(a)(2) of the Endangered Species Act requires the BLM to consult with the U.S. Fish and 

Wildlife Service (U.S. FWS) and the National Oceanic and Atmospheric Administration’s National 

Marine Fisheries Service on the effects of the Proposed RMP on species listed as threatened or 

endangered. While there are no listed species that regularly use habitat within the Monument, there are a 

variety of listed species for which the Monument could provide habitat through reintroduction or 

population expansion or that occupy habitat adjacent to the Monument (see the Wildlife Section of 

Chapter 3 beginning on page 247). In addition, the National Historic Preservation Act requires the BLM 

to consult with the Washington State Historic Preservation Officer and with the appropriate Tribal 

Historic Preservation Officers on actions that could affect historic properties. The BLM will complete 

consultation prior to issuing a Record of Decision. 

What Management Approaches is the BLM Analyzing in this 

Draft? 

The BLM developed a range of approaches (alternatives) for managing Monument resources using input 

from the public, the Monument Advisory Committee, cooperating agencies, consulting tribes, and BLM 

resource specialists. 

In Chapter 2 of the Draft RMP/EIS, the BLM considers a No Action Alternative (i.e., continuation of 

current management), four action alternatives (alternatives A, B, C, and D), and a sub-alternative2 (SubAlternative C). The BLM designed these alternatives to meet the purpose and need, to meet direction in 

Proclamation 8947 and the FLPMA, and to address the planning issues identified during scoping and 

other outreach. 

The alternatives (summarized below) detail potential objectives, management tools, and allowable uses 

in the Monument. Table 1, below, summarizes substantial numerical differences between the 

alternatives (e.g., acres to which different visual resource management classes would apply under each 

alternative). 

No Action Alternative 

Monument lands are not now, and have never been, covered by an RMP. Therefore, under the No Action 

Alternative, custodial management would continue with no plan-level objectives and few prohibited uses 

applying to the Monument. Custodial management of the Monument would continue to focus on 

meeting legal and policy mandates and preventing unnecessary and undue degradation. The BLM would 

make decisions about taking actions on a case-by-case basis after completing the appropriate level of 

National Environmental Policy Act analysis and ensuring that actions are consistent with Proclamation 

8947 and the FLMPA. 

With no RMP in place to guide or restrict human uses, Monument lands would remain generally open to 

recreation (including hiking, equestrian use, camping, hunting, and trail-based bicycle use) though 

existing laws and regulations would continue to apply. The one exception would continue to be the area 

of critical environmental concern (ACEC) designation that applies to Chadwick Hill, Iceberg Point, Point 

Colville, and Watmough Bay3. The 1990 ACEC decisions, which prohibit camping and require permits 

for organized groups of 10 or more, would continue to apply to these areas. 

Common to all Action Alternatives 

Under all alternatives, the BLM would manage vegetation as necessary to maintain the current diversity 

of plant communities and wildlife. It would protect cultural resources from damage due to natural and 

human causes. The BLM would facilitate public use of the Monument for educational, scientific, 

cultural, and spiritual uses. It would collaboratively engage with tribal partners to facilitate traditional 

2 A sub-alternative alters discrete aspects of an alternative to allow the BLM to isolate and analyze the effect of 

making small changes. 

3 See Appendix D of the Draft RMP/EIS for specifics of current ACEC management. 

ix 
 

 

 

 

 

 

 

 

 

 

 

activities and the exercise of treaty rights and seek opportunities for co-stewardship and collaboration 

within the Monument. Under all alternatives, the BLM could use a variety of methods—including 

fencing and undertaking temporary closures—as needed to protect the cultural and ecological objects and 

values for which the Monument was designated and sensitive tribal activities. 

During plan implementation, the BLM would develop vegetation treatments, among other 

implementation-level actions, to meet the plan objectives. The locations, sizes, and management tools 

used (within the range of tools allowed under each alternative) would be determined during the 

implementation-level planning and National Environmental Policy Act compliance processes. 

Alternative A 

Under Alternative A, the BLM would allow natural processes to take place without management 

intervention to the extent possible while protecting the cultural and ecological objects and values for 

which the Monument was designated. It would facilitate this by restricting human uses of the Monument 

to the greatest extent possible. To this end, the BLM would facilitate use of the Monument for authorized 

educational, scientific, cultural, and spiritual activities, but not for recreation. The BLM would allow 

mechanical, manual, and biological control treatments to achieve objectives, but would prohibit the use of 

prescribed burning and chemical treatments (e.g., herbicides). Within maritime heritage areas (i.e., the 

land surrounding light stations and associated structures), the BLM would manage to prevent 

deterioration of historic structures from their current condition. 

Alternative B 

Under Alternative B, the BLM would focus on promoting ecological resistance and resilience by 

enhancing plant communities that are relatively scarce within the San Juan Islands. The BLM would 

allow mechanical, manual, biological control, chemical, and fire treatments to achieve objectives. 

Recreational opportunities would include hiking, hunting, designated site and dispersed camping, and 

opportunities for solitude and quiet, which would be provided by expanding the trail network, requiring 

permits to access 167 acres of the Monument, and providing dispersed camping by permit. No trail-based 

equestrian or bicycling opportunities would be available under this alternative. Current hunting activities 

(firearm and non-firearm based) would be likely to continue4. Within maritime heritage areas, the BLM 

would restore historic structures and prohibit the construction of new structures or the rebuilding of 

previously existing structures. 

Alternative C 

Under Alternative C, the BLM would restore plant communities to a state approximating pre-European 

settlement. It would focus on managing for vegetation conditions brought about by the use of fire on the 

landscape by Coast Salish peoples. The BLM would allow mechanical, manual, biological control, 

chemical, and fire treatments to achieve objectives. Recreational opportunities would include hiking, 

equestrian use, and designated site camping. No dispersed camping or trail-based bicycling opportunities 

would be available under this alternative. In areas where members of the public have identified conflict 

between firearm-based hunting and other recreational uses, the BLM would prohibit the discharge of 

firearms except for half of firearm-based hunting seasons5. Within maritime heritage areas, the BLM 

would restore historic structures, allow the rebuilding of previously existing structures, and prohibit the 

construction of new structures. 

4 BLM-administered lands where firearm discharge is not prohibited would continue to be open to this use, though 

may be subject to temporary closures for emergencies and public health and safety concerns. 5 Firearm prohibitions would not affect non-firearm-based hunting (e.g., bow hunting) or use by tribal members for 

the purposes of hunting. 

x 
 

 

 

 

 

 

 

Sub-Alternative C 

Sub-Alternative C is identical to Alternative C with two exceptions. First, the BLM would prohibit 

chemical treatments (e.g., herbicides). Second, it would prohibit the discharge of firearms throughout the 

Monument5. 

Alternative D 

Under Alternative D, the BLM would focus on expanding and enhancing visitor experiences, while 

meeting the protective mandate of Proclamation 8947. It would maintain the current extent and condition 

of plant communities throughout the life of the plan. The BLM would allow mechanical, manual, 

biological control, chemical, and fire treatments to achieve objectives. Recreational opportunities would 

include hunting and increased camping and hiking, equestrian use, and biking on an expanded trail 

network. Current hunting activities (firearm and non-firearm based) would be likely to continue. Within 

maritime heritage areas, the BLM would restore historic structures and allow the rebuilding of previously 

existing structures and the building of new structures to support education and interpretation. 

What is the BLM’s Preferred Alternative?

Alternative B (described above) is the BLM preferred alternative. Regulation (43 CFR 1610) requires 

the BLM to identify a preferred alternative in the Draft RMP/EIS. It is simply the BLM’s starting point 

for gaining public feedback to use in developing the Proposed RMP. 

In developing a Proposed RMP, the BLM will consider making modifications to the preferred alternative 

in response to public comments; advice from consulting tribes, cooperating agencies, and the Monument 

Advisory Committee; and BLM priorities. The Proposed RMP may be a modification of the design of 

Alternative B, a modification of the design of a different alternative analyzed in the Draft RMP/EIS, a 

new alternative developed from within the spectrum of alternatives analyzed in the Draft RMP/EIS, or an 

alternative analyzed in the Draft RMP/EIS as written. 

The identification of the preferred alternative is not a commitment or decision. The BLM will develop a 

Proposed RMP after the end of the public comment period on the Draft RMP/EIS. 

What are the Effects of the Alternatives Analyzed in this Draft? 

The effects analysis is a description of the potential for significant impacts on the human environment 

from the alternatives, as well as of impacts from the alternatives that are pertinent to the purpose and 

need for the RMP. The Council on Environmental Quality regulations for implementing the National 

Environmental Policy Act state that the human environment is the natural and physical environment and 

the relationship of people to that environment (40 CFR 1508.14). 

Chapter 3 (Affected Environment and Effects Analysis) describes the existing resource conditions and 

trends in the Monument. It also describes and the varying direct, indirect, and cumulative effects of the 

alternatives. This includes descriptions of the environmental, social, and economic consequences that 

the BLM projects would occur from implementing the alternatives. The purpose of this chapter is to 

provide BLM decision-makers and the public with an analysis of the environmental consequences of 

implementing any of the alternatives proposed in Chapter 2. 

xi 
 

 

Table 1: Summary Comparison of Alternatives 

No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C 

Alternative 

D 

Areas of Critical Environmental Concern 

(see section beginning on page 8 in Chapter 2) 

Areas of critical 

environmental 

concern (acres) 

503 0 0 0 0 

Cultural and Paleontological Resources 

(see sections beginning on pages 12 and 25 of Chapter 2) 

Hard shoreline 

stabilization allowed 

to protect cultural and 

paleontological values 

(acres). Soft 

stabilization allowed 

under all alternatives. 

1,021 0 1,021 0 789 

Habitat and Plants 

(see section beginning on page 16 in Chapter 2) 

Extent objective for 

forest and woodland 

(percent of 

Monument) 

NA 

(current 

extent: 83%) 

40%* 50% 48% 83% 

Extent objective for 

grassland and 

shrubland (percent of 

Monument) 

NA 

(current 

extent: 12%) 

≥7%* 40% 47% 12% 

Extent objective for 

wetlands (percent of 

Monument) 

NA 

(current 

extent: 4%) 

≥2%* 7% 4% 4% 

Recreation 

(see sections beginning on pages 28 and 34 in Chapter 2) 

Designated recreation 

management areas 

(acres) 

0 0† 1,011 1,014 1,021 

Permit required for 

public access (acres) 0 1,021 167 4 0 

Camping 

214 acres with 

13 designated 

campsites 

517 acres open 

to dispersed 

camping 

Monument 

closed to 

camping 

214 acres with 

13 designated 

campsites 

726 acres open 

to dispersed 

camping by 

permit only 

214 acres with 

13 designated 

campsites 

Remainder of 

Monument 

closed to 

camping 

436 acres open to 

designated site 

camping‡

535 acres open to 

dispersed camping 

Closed to discharge 

of firearms (acres) 0 0 0 

612§ 

(partial closure) 

Sub-Alternative 

C: 1,021 

0 

Road miles open to 

public motorized use 1** 0 1 0.5 0.9 

xii 
 

No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C 

Alternative 

D 

Hiking (trail miles††) 16** 0 20 11.9 (also open 

to equestrian) 

24.5 

(also open to 

equestrian and 

bicycles) 

Equestrian use 

(trail miles††) 16** 0 0 2.6 8.4 

Bicycle use 

(trail miles ††) 16** 0 0 0 8.4 

Visual Resources Management 

(see the section beginning on page of Chapter 2) 

Class I (acres) 0 232 0 3 232 

Class II (acres) 0 789 28 28 789 

Class III (acres) 0 0 992 989 0 

Class IV (acres) 0 0 0 0 0 

Undesignated (acres) 1,021 0 0 0 0 

Wilderness Characteristics 

(see the section beginning on page 

36

of Chapter 2) 

Lands managed for 

wilderness 

characteristics (acres) 

0 232 0 3 232 

37 

* Under Alternative A, the BLM would allow natural succession to take place until one of these specified

thresholds was crossed. For example, the Monument’s grasslands and shrublands would be allowed to 

continue to convert to forests and woodlands until only 7 percent of the Monument was occupied by this

community class (half of what currently exists).

†Under Alternative A, the BLM would facilitate access for authorized scientific, educational scientific,

cultural, and spiritual uses, but not for recreation.

‡The BLM would identify specific designated sites during plan implementation; designated sites would

occur on a fraction of this acreage. Under other alternatives, designated sites would be limited to the

number that already exist within the Monument.

§These areas would be closed to the discharge of firearms except for half of firearm-based hunting season.

The BLM would work with Washington Department of Fish and Wildlife annually to establish the closure

period. This is currently how the San Juan County Land Bank manages Lopez Hill, the only nonMonument public land currently open to hunting on Lopez Island.

**There are currently no officially designated roads or trails in the Monument. All existing roads are

currently open to motorized and non-motorized public access. All existing trails are currently open to all

non-motorized uses (Proclamation 8947 prohibits public motorized access except on designated roads).

††These totals include trails under U.S. Coast Guard jurisdiction on lands at Cattle Point and Iceberg Point

adjacent to the Monument. The BLM does not have jurisdiction over these lands but provides some onthe-ground management and will make recommendations to the U.S. Coast Guard regarding trails.

What are the Next Steps? 

The comment period on this Draft RMP/EIS will extend for 90 days following publication of the EPA’s 

Notice of Availability in the Federal Register (see planning process timeline in Appendix T). Upon 

comment period closure, the BLM will evaluate all written comments and develop responses to 

substantive comments. Substantive comments could lead to changes in one or more of the alternatives or 

in the effects analysis. 

xiii 
With help from consulting tribes and cooperating agencies, the BLM will then develop a Proposed RMP 

from one of the alternatives analyzed in the Draft RMP/EIS, or a newly developed alternative that pulls 

elements from a number of the alternatives analyzed in the Draft RMP/EIS. When developing the 

Proposed RMP, the BLM considers comments received and the analysis of effects from the alternatives, 

as well as agency priorities. The BLM will release the Proposed RMP/Final EIS for a public protest 

period and the Governor’s consistency review. 

Following resolution of any protests and completion of the Governor’s consistency review, the BLM 

will prepare a Record of Decision and Approved RMP. The publication of the Record of Decision will 

represent the completion of the RMP process. 

After the RMP is completed, the BLM will develop site-specific actions that meet the objectives and 

direction outlined in the Approved RMP. As necessary, the BLM will conduct further analysis under 

the National Environmental Policy Act to assess site-specific conditions and impacts from proposed 

actions. 

xiv 
5

10

15

20

25

30

35

40

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 1 

Chapter 1: Introduction 

The Bureau of Land Management’s (BLM) Spokane District Office is developing a resource mana

plan (RMP) for the San Juan Islands National Monument (Monument). This RMP will provide the

overarching objectives and direction for the Monument. There is currently no RMP for this area. 

This Draft RMP/Environmental Impact Statement (EIS) describes the various alternative managem

approaches the BLM is considering for the Monument, along with an analysis of the potential effec

these alternatives. The BLM will consider public comments on the Draft RMP/EIS as it develops 

Proposed RMP/Final EIS. 

For more information about the BLM’s planning process, and for the planning process timeline, se

Appendix T. 

Background on the San Juan Islands National Monument On March 25, 2013, President Obama signed Proclamation 8947 (see Appendix N) designating the

Monument. The Monument consists of 1,021 acres of land scattered across the San Juan Islands, 

lie in the heart of the Salish Sea. This includes approximately 832 acres currently under BLM juris

and approximately 189 acres withdrawn to the U.S. Coast Guard (Coast Guard) (i.e., currently und

Coast Guard jurisdiction). The Coast Guard is in the process of relinquishing these withdrawals. 

BLM is developing the RMP with the assumption that the relinquishment process will be complete

the near future. In the event that the relinquishment process is still ongoing when the planning pro

completed, the RMP will not go into effect for these areas until they are under BLM jurisdiction. 

The President established the Monument on these islands to “maintain their historical and cultural

significance and enhance their unique and varied natural and scientific resources, for the benefit of 

Americans.” Proclamation 8947 provides a description of the objects of historic and scientific inte

which the Monument was designated (see Appendix R for a table of objects). The BLM manages t

Monument as a component of the National Landscape Conservation System. 

Proclamation 8947 prohibits certain activities within the Monument. Subject to valid existing right

withdraws the Monument from all forms of entry, location, selection, sale, leasing, or other disposi

under the public land laws, including withdrawal from location, entry, and patent under the mining

and from disposition under all laws relating to mineral and geothermal leasing, other than by excha

that furthers the protective purposes of the proclamation. It also requires that, except for emergenc

Federal law enforcement, or authorized administrative purposes, motorized vehicle use only occur 

designated roads and mechanized vehicle use (e.g., bicycles) only occur on designated roads and tr

Description of the Decision Area and Planning Area 

The Monument is the “decision area” for this planning effort; in other words, it is the area about w

the BLM will make decisions. The Monument, and thus the decision area, encompasses only BL

administered lands in the San Juan Islands. San Juan County contains the majority of the Monume

small portion is in Skagit and Whatcom counties (see Table 2). 

 

The term “planning area” refers to the broader San Juan Islands, which provide context for the BL 

potential decisions and may be indirectly affected by the actions taken in implementing the RMP. 

shows both the decision area (the Monument) and the planning area (the broader map area). 

The management objectives and direction in Chapter 2 of this document would apply only to the d

gement

ent 

ts of 

a 

e 

which 

diction 

er 

The 

d in 

cess is 

all 

rest for 

he 

s, it 

tion 

 laws, 

nge 

ies, 

on 

ails. 

hich 

Mnt; a 

M’s 

Map 1 

ecision 

area (i.e., the Monument). However, readers can expect to see references to the broader San Juan Islands 

(i.e., the planning area) in Chapter 3 in order to describe the indirect and cumulative effects of the 

management alternatives. For example, the objectives and direction in Chapter 2 only address camping 

within the Monument. In Chapter 3, however, readers will see descriptions of camping opportunities 

1 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 1 

throughout the San Juan Islands to help explain the potential indirect effect of the alternatives on the 

supply and demand for camping within the planning area as a whole. 

Table 2: Acres of Monument land within each county in the planning area 

County BLM-administered Acres Coast Guard-administered Acres Comanaged with BLM* 

San Juan

775

189*

(66 acres at Iceberg Point, 60 acres at Point 

Colville, 63 acres at Kellett Bluff) 

Skagit 1 0

Whatcom 56 0

Total 842 189*

2 

Note: all acres are estimates based on GIS data and rounded to the nearest acre 

* These acres are currently withdrawn to the Coast Guard. For the purposes of this planning effort, the

BLM assumes that they will be relinquished by the Coast Guard and come under BLM administration in 

the near future. These undeveloped lands will undergo an assessment to determine their suitability for 

return to the public domain prior to the Department of the Interior’s determination of whether to accept 

these lands.

Decisions to be Made 

At the conclusion of the planning process the BLM will approve an RMP for the Monument. The BLM’s 

planning regulations make clear that RMPs are a preliminary step in the overall process of managing 

public lands, and are “designed to guide and control future management actions and the development of 

subsequent, more detailed and limited scope plans for resources and uses” (43 CFR 1601.0-2). The 

decisions made through this process will meet the purpose and need and goals for the planning effort (see 

page 4), as well as the BLM’s legal and policy mandates, to the extent consistent with Proclamation 8947. 

The RMP will include the following land use plan decisions: 

 Management objectives for BLM-administered resources and activities.

 Management direction identifies future actions the BLM will take during plan implementation to

meet the management objectives along with restrictions or requirements on those future actions.

 Land use allocations identify allowed, prohibited, and restricted uses for all or part of the

Monument. For example, areas in which motorized vehicle use or camping is prohibited or allowed.

These land use plan decisions will guide the BLM’s administration of the Monument over the next 15 to 

20 years. After the plan is completed, the BLM will develop and implement site-specific actions that 

meet the RMP’s objectives and direction. The BLM calls decisions to undertake such actions projector implementation-level decisions. 

In addition to land use plan decisions, this RMP effort will include implementation-level decisions for 

travel and transportation management. The BLM is undertaking implementation-level planning on this 

topic because of the limited amount of road and trail miles in the Monument (1 mile and 14.9 miles, 

respectively) and the strong public interest expressed during RMP scoping. Implementation decisions 

generally constitute the BLM’s final approval allowing on-the-ground actions to proceed. The Draft 

Travel and Transportation Plan in Appendix H provides maps and descriptions of four potential road 

and trail networks that each meet the objectives of one of the draft alternatives analyzed in this

document. 
1

San Juan Islands National Monument Draft RMP/EIS: Chapter 1 

Map 1: San Juan Islands National Monument Planning Area . 

3 
5

10

15

20

25

30

35

40

45

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

26

27

28

29

31

32

33

34

36

37

38

39

41

42

43

44

46

Purpose and Need The Federal Land Policy and Management Act (FLPMA) and Proclamation 8947 establish the need 

for this action. The FLPMA requires the BLM to develop RMPs that provide for the use of public 

lands. The proclamation specifies that the BLM ‘‘shall prepare and maintain a management plan for 

the monument...” The BLM does not currently manage the Monument under an RMP. 

What is a Purpose and Need 

statement? 

The Purpose and Need for the 

planning effort identifies the 

problem the RMP must solve (i.e., 

the need for the plan) and the 

outcomes it must achieve (i.e., the 

purposes of the planning effort). 

For an alternative to be considered 

in the Draft RMP/EIS, it must 

address the need and achieve the 

purposes described in this 

statement. 

The purpose of this RMP is to provide goals, objectives, and 

management direction to guide the BLM’s management of the 

Monument. These goals, objectives, and management 

direction must conserve, protect, and restore the objects of 

historic and scientific interest identified in Proclamation 8947. 

The purpose of the RMP includes protection and restoration of 

cultural and historical resources identified in the proclamation, 

including traditional use areas of the Coast Salish people and 

archaeological remains of their villages, camps, and processing 

sites throughout the Monument. These include, but are not 

limited to, shell middens, reef net locations, and burial sites. 

Additionally, the purpose of the RMP includes protecting and 

restoring historical resources associated with early EuroAmerican settlement found in the Monument, such as 

lighthouses and associated structures. 

The purpose of the RMP regarding scientific and ecological resources is to protect and restore the wide 

array of habitats described in the proclamation, including forests, fire dependent grasslands, and 

wetlands, as well as bluffs, rocky balds, and shorelines. The RMP will promote the continuation of the 

diversity of habitats critical to supporting a varied collection of native wildlife, including special status 

species. 

 An additional purpose of the RMP is to address increases in human uses of the Monument. The RMP 

will address recreation, education, and scientific uses consistent with the protection and restoration of the 

objects and values described above. 

The RMP will also safeguard tribal treaty rights, and will, as provided for in the proclamation “in 

consultation with Indian tribes, ensure the protection of religious and cultural sites in the monument and 

provide access to the sites by members of Indian tribes for traditional cultural and customary uses, 

consistent with the American Indian Religious Freedom Act (42 USC 1996) and Executive Order 13007 

of May 24, 1996 (Indian Sacred Sites).” 

 In determining the suite of management actions necessary to protect and restore the Monument for 

present and future generations, this RMP responds 

 to three important sources of overarching 

requirements and guidance: 

• Presidential Proclamation 8947 of March 25, 2013, which created the Monument and identified the 

objects for protection and restoration.

• Section 2002 of the Omnibus Public Land Management Act of 2009, which established the National 

Landscape Conservation System, of which the Monument is a unit, “in order to conserve, protect, 

and restore nationally significant landscapes.” This section also provides that the BLM manage 

these lands “in a manner that protects the values for which the components of the system were 

designated.”

• The FLPMA, which provides the basic underpinnings for the BLM’s management of public lands. 

Section 302 of the FLPMA states that the BLM is to manage public lands under the principles of 

multiple use and sustained yield “except that where a tract of such public land has been dedicated to 

specific uses according to any other provisions of law it shall be managed in accordance with such

San Juan Islands National Monument Draft RMP/EIS: Chapter 1 

4 
5

10

15

20

25

30

35

40

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 1 

law.” Therefore, as a general rule, if a presidential proclamation that designates a Monument

conflicts with the FLPMA’s multiple use mandate, the Monument designating language will apply. 

Recognizing these purposes, there is a need for an RMP for the San Juan Island National Monument to 

ensure that the long-term management of these lands achieves a level of protection and restoration 

consistent with the guidance described above. 

Vision and Goals The vision for an RMP is an expression of long-term desired conditions for the decision area from an 

experiential viewpoint. The Monument Advisory Committee6 developed the following vision statement 

for the Monument, which the BLM adopted: 

The San Juan Islands National Monument provides an awe-inspiring experience that connects people to a 

flourishing, intact landscape, rich in natural, cultural, and historical features. 

Goals are broad statements of desired outcomes that usually are not quantifiable. The Draft RMP/EIS 

examines alternative ways to achieve the goals to the extent allowed under laws and land ownership 

patterns. The goals for the RMP are as follows: 

 Protect the cultural and historic values for which the Monument was designated

 Protect the ecological values for which the Monument was designated

Planning Criteria and Planning Issues

The BLM developed preliminary planning criteria before publishing the notice of intent to plan for this 

effort. Planning criteria guide development of the plan by identifying the “sideboards” that define the 

scope of the planning effort; the BLM generally bases them on applicable laws, national and BLM State

Director guidance, and the results of public and government participation (43 CFR 1610.4-2). The BLM 

published an initial list of planning criteria in the Federal Register on March 2, 2015. After revising the 

planning criteria based on internal and external scoping, the BLM published the criteria in the scoping 

report, which can be found on the RMP website: https://go.usa.gov/xRphc. 

Planning issues are disputes or controversies about existing and potential land and resource allocations, 

levels of resource use, and related management practices. The BLM often frames planning issues as 

questions that will be resolved through the planning process. The BLM has received a wide-variety of 

input from consulting tribes, cooperating agencies, and members of the public on how these issues should 

be resolved. The alternatives described in Chapter 2 explore different approaches to resolving these 

issues while meeting the purpose and need for the planning effort. 

The planning criteria and planning issues for this effort can be found in Appendix L. They were initially 

published in the scoping report, which can be found on the RMP website: https://go.usa.gov/xRphc. 

The public also suggested planning issues that the BLM considered but did not analyze in detail. 

Alternatives responsive to these issues that the BLM considered but did not analyze in detail are described 

in Appendix A. 

Partnerships in the San Juan Islands 

Much of the work carried out within the Monument is accomplished through partnerships with other 

governmental agencies, non-profit organizations, and volunteers. These partners are invaluable to the 

management of visitation, the monitoring of Monument lands, and the restoration of historic structures. 

Regardless of the decisions made through the planning effort these partnerships will remain essential to 

the effective management of the Monument. 

6 Proclamation 8947 required that the BLM “establish an advisory committee under the Federal Advisory

Committee Act (5 USC App.) to provide information and advice regarding the development of [the RMP].” More 

information about the Monument Advisory Committee can be found on page 298 in Chapter 4. 

5 
5

10

15

20

25

30

35

40

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 1 

Information about how cooperating agencies, consulting tribes, and members of the public have been 

involved in this planning effort can be found in Chapter 4. 

When developing the Proposed RMP, the BLM will seek to be consistent with, or complementary to, the 

management approaches of its partners. As it moves forward with the planning process, the BLM will 

continue to consider the following plans affecting the San Juan Islands: 

 National Park Service, San Juan Island National Historic Park General Management Plan and

Environmental Impact Statement (2008)

 San Juan Islands Scenic Byway Steering Committee, San Juan Islands Scenic Byway Corridor

Management Plan (2011)

 San Juan County, Community Wildfire Protection Plan (2012)

 San Juan County, Critical Areas Ordinance (2014)

 San Juan County, San Juan County Comprehensive Plan (2010, as revised)

 San Juan County, San Juan County Parks, Trails, and Natural Areas Plan and Non-Motorized

Transportation Plan 2017-2022 (2016)

 San Juan County, Shoreline Master Plan (2017)

 U.S. Fish and Wildlife Service (U.S. FWS), Protection Island and San Juan Islands National Wildlife

Refuges Comprehensive Conservation Plan and San Juan Islands Wilderness Stewardship Plan

(2010)

 U.S. FWS, Recovery Plan for the Golden Paintbrush (2000)

 U.S. FWS, Recovery Plan for the Marbled Murrelet (Washington, Oregon, and California

Populations) (1997)

 U.S. FWS and San Juan Island National Historic Park, National Park Service, Conservation

Agreement and Strategy for the Island Marble Butterfly (2006)

 Washington State Department of Transportation Ferries Division Final Long-Range Plan (2009)

 Washington State Parks, Moran State Park Management Plan (2000)

Legal Obligations 

The BLM will meet all pertinent legal obligations in managing the Monument. These obligations include, 

but are not limited to, tribal treaties, the Endangered Species Act, the National Historic Preservation Act, 

and the protective mandate of Proclamation 8947. The BLM will ensure that any Federal, State, or local 

permit required for any action implementing the RMP is obtained prior to authorizing or conducting the 

action. See Appendix K for further information on pertinent laws and regulations. 

Maps and Acres in this Document 

The BLM developed the maps and acres in this document using its current best geographic information 

system (GIS) data. Boundary information may improve over time. The Approved RMP will apply to all 

areas that the BLM determines are under its jurisdiction within the San Juan Islands. 

The BLM has rounded all numbers in this document according to the following rules: 

 Acres are rounded to the nearest whole acre (e.g., 2 acres rather than 1.8 acres)

 Miles are rounded to the nearest 10th of a mile (e.g., 0.4 miles rather than 0.43 miles)

 Percentages are rounded to the nearest whole number (e.g., 10 percent rather than 10.2 percent)

6 
San Juan Islands National Monument Draft RMP/EIS: Chapter 2

1

1

2

2

3

3

4

1 

2 

3 

4 

5

6 

7 

8 

9 

0

1 

2 

3 

4 

5

6 

7 

8 

9 

0

1 

2 

3 

4 

5

6 

7 

8 

9 

0

1 

2 

3 

4 

5

6 

7 

8 

9 

0

1 

2 

3 

1

1

1

1

1

1

1

1

2

2

2

2

2

2

2

2

3

3

3

3

3

3

3

3

4

4

4

Chapter 2: Alternative Approaches to Managing the San 

Juan Islands National Monument 

Introduction 

The BLM developed the action alternatives using input from the public, the Monument Advisory 

Committee, cooperating agencies, consulting tribes, and BLM staff. Management approaches that meet 

the purpose and need for the RMP, are technically or economically feasible, and are at an appropriate 

scale for a long-term management plan are included in the range of alternatives. Each action alternative 

describes an overarching approach that would guide the BLM’s management actions for 15 to 20 years. 

The BLM could potentially consider endless variations and combinations of plan components in the range 

of alternatives. The four action alternatives and one sub-alternative described in this Draft RMP/EIS do 

not provide all possible combinations but instead span the full spectrum of management approaches that 

would meet the purpose and need for the planning effort (see page 4). 

During the implementation of the plan, the BLM will undertake numerous site-specific actions to achieve 

the objectives of the Approved RMP (e.g., vegetation treatments, archaeological surveys, development 

and placement of signs, maintenance of facilities). These implementation-level actions must conform to 

the Approved RMP, but are not identified in the draft alternatives or the Approved RMP. The BLM will 

conduct additional planning and NEPA compliance during plan implementation. 

Alternatives considered but not analyzed in detail are found in Appendix A. 

Preferred Alternative 

Alternative B (described below) is the BLM preferred alternative. The BLM is required by regulation (43 

CFR 1610) to identify a preferred alternative in the Draft RMP/EIS. It is simply the BLM’s starting point

for gaining public feedback to use in developing the Proposed RMP. 

In developing a Proposed RMP, the BLM will consider making modifications to the preferred alternative 

in response to public comments; advice from consulting tribes, cooperating agencies, and the Monument 

Advisory Committee; and BLM priorities. The Proposed RMP may be a modification of the design of 

Alternative B, a modification of the design of a different alternative analyzed in the Draft RMP/EIS, a 

new alternative from within the spectrum of alternatives considered in the Draft RMP/EIS, or an 

alternative analyzed in the Draft RMP/EIS as written. The identification of the preferred alternative is not 

a commitment or decision. The BLM will develop a Proposed RMP after the end of the public comment 

period on the Draft RMP/EIS. 

Implementation-level Plans and Administrative Actions 

After the completion of the RMP, the BLM will work with its partners to develop implementation-level 

plans and undertake on-the-ground projects to achieve RMP objectives. Under all alternatives, the BLM 

would also continue to implement administrative actions. Administrative actions are routine transactions 

and activities that are required to serve the public and to provide optimum management of resources. All 

actions would be taken only in conformance with the Approved RMP. For a list of example 

implementation-level plans and administrative actions see Appendix J. 

Plan Effectiveness Monitoring 

The BLM will develop a monitoring plan to track the effectiveness of implementation of the Approved 

RMP. The monitoring plan will be an appendix to the Approved RMP. In the Proposed RMP, the BLM 

will identify, as appropriate, adaptive management actions that monitoring findings might trigger. 

Adaptive management actions must be within the range of alternatives described in this Draft RMP/EIS 

and would only be undertaken when specified triggers occur. 

7 
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

 

 

 

 

 

 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2

No Action Alternative 

The No Action Alternative for an RMP/EIS is normally the continuation of the current RMP. The BLMadministered lands encompassing the Monument are unusual in that they are not covered by an RMP. 

Because of this, there are no plan-level objectives, direction, or allocations to describe for the No Action 

Alternative, except for the limited decisions made in the Area of Critical Environmental Concern (ACEC) 

decision (BLM 1990) described below. The ACECs were not developed as part of an RMP. 

Under the No Action Alternative, the BLM would continue to administer Monument lands without the 

guidance of an RMP using a custodial approach. This custodial approach would focus on meeting legal 

and policy mandates— to the extent consistent with Proclamation 8947—and preventing unnecessary and 

undue degradation. The BLM would determine what actions it would take to meet these mandates on a 

case-by-case basis after completing the appropriate level of planning and NEPA compliance. 

Restrictions on recreation within the Monument are currently limited to those explicitly described in 

Proclamation 8947 (see page 1), established in the ACEC decision (BLM 1990), or established under 

existing regulations or supplementary rules. 

The Iceberg Point and Point Colville Areas of Critical Environmental Concern Decision Record (BLM 

1990) provides some management direction for 503 acres of the Monument. The 1990 ACEC decision 

originally applied to the BLM-administered lands at Iceberg Point and Point Colville. The BLM 

extended the ACEC designation to Watmough Bay and Chadwick Hill after its acquisition of these areas. 

Activities prohibited in the ACECs include fires, trail construction, and camping. A full list of prohibited 

uses and management direction established through the ACEC decision can be found in Appendix D. 

The BLM’s special recreation permits regulation (43 CFR 2932) requires permits for any organized, 

commercial, or competitive uses of BLM-administered lands. Supplementary rules applying to all BLMadministered lands in Oregon and Washington prohibit: camping for longer than 14 days, leaving 

personal property unattended for more than 24 hours, leaving pets unrestrained in developed recreation 

sites (e.g., campgrounds and picnic areas with facilities), discharging a firearm into or from a posted noshooting zone or into or from a developed recreation site, discharging or possessing a firearm or explosive 

device in violation of State law, and using non-weed free certified hay (See Appendix I for the 

supplementary rules). The BLM establishes no-shooting zones through an RMP decision, Federal 

Register notification, or other planning process. The Monument currently does not have any no-shooting 

zones. 

Beyond these restrictions, Monument lands are generally open to recreational uses, though existing laws 

and regulations apply. For example, visitors may currently land paddle craft (e.g., kayaks, canoes, 

paddleboards) on all Monument rocks and islands, but must not violate the Marine Mammal Protection 

Act by harassing marine mammals or the Migratory Bird Treaty Act by pursuing, hunting, taking, 

capturing, selling, or killing migratory birds. 

The BLM, working with its partners, currently carries out limited management activities within the 

Monument. These activities include removing hazard trees that pose a threat to safety or property, 

providing basic visitor facilities (e.g., vault toilets) in some locations, protecting cultural resources against 

imminent threats, providing education and interpretation, and restoring aspects of historic structures. No 

mineral extraction, grazing, commercial forestry, or energy production occurs within the Monument. 

A note on ACECs 

The 1990 ACEC decision provided management direction that helped protect the BLM-administered 

lands on the south end of Lopez Island prior to the designation of the Monument in 2013. The 

designation of the Monument broadened and made permanent the protection of the area’s special objects 

and values. 

8 
San Juan Islands National Monument Draft RMP/EIS: Chapter 2

5

10

15

20

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

 

 

As described in Appendix C, the BLM found the entire Monument, including the land composing the 

current ACECs, to possess values meeting the relevance and importance criteria described in the ACEC 

Manual, but did not find that these values meet the criterion of requiring additional special management 

in the context of the alternatives considered in this Draft RMP/EIS. In large part, this was due to the 

overlap between the identified relevant and important values and the Monument objects and values, 

which the alternatives must protect in order to meet the purpose and need. 

The ACECs are analyzed as part of the No Action Alternative. The action alternatives do not include 

ACECs (see page 212 and Appendix C). 

Action Alternatives 

The action alternatives are de

 will m

on the B

scribed below through subsections that address the values and activities 

about which the BLM ake decisions. For example, the cultural resources subsection includes the 

objectives and directi LM would follow regardless of the Approved RMP (common to all action 

alternatives) and the varying objectives and direction the BLM is considering under each alternative. The 

BLM would implement objectives and direction listed under “common to all action alternatives” under all

potential versions of the RMP, i.e., they would be in addition to direction under each individual 

alternative. 

Table 3 provides a summary of major differences between the alternatives. It is a high level summary; it 

includes neither direction common to all action alternatives nor the details of the alternative’s objectives 

and direction, both of which are found in the sub-sections below. Summary tables for the range of 

alternatives pertaining to each resource and use can be found in Appendix S. 

9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2

Table 3: Summary of major elements that differ between alternatives 

No Action Alternative7 Alternative A Alternative B Alternative C Alternative D 

Cultural 

Resources8 

(see page 12 

for more 

details and 

elements that 

do not vary by 

alternative) 

There would continue to 

be no plan-level 

decisions related to 

cultural resources. 

The BLM would 

continue with custodial 

management of cultural 

resources, including 

undertaking stabilization 

and rehabilitation 

projects as necessary to 

protect them. 

Monitor and protect 

existing historic 

structures from 

impairment or loss. 

Do not add structures. 

Take action when 

required by law or 

policy. 

Allow soft shoreline 

stabilization to protect 

cultural resources. 

Prohibit hard 

stabilization methods. 

Restore/rehabilitate 

existing historic 

structures to their 

historic appearance. 

Do not add structures. 

Allow hard 

stabilization methods, 

in addition to soft 

stabilization, to prevent 

damage to cultural 

resources from sea 

level rise and increased 

storm surge. 

Restore/rehabilitate 

historic structures to 

their historic 

appearance. Allow 

the reconstruction of 

historically present, 

but currently absent 

structures. Do not 

otherwise add 

structures. 

Allow soft shoreline 

stabilization to protect 

cultural resources. 

Prohibit hard 

stabilization methods 

Restore/rehabilitate 

structures to their 

historic appearance. 

Allow reconstruction 

and develop new 

structures to allow for 

greater visitor use, 

including, potentially, 

overnight use of some 

facilities by docents. 

Allow soft shoreline 

stabilization to protect 

cultural resources; 

allow hard stabilization 

methods in areas 

without wilderness 

characteristics. 

Habitat/ Manage vegetation Manage vegetation to Restore habitats to Maintain vegetative 

Plant There would continue to minimally to allow enhance the San Juan the approximate communities at the 

Community be no plan-level natural succession. Islands ecological extent and condition approximate current 

Management decisions related to resilience and existing prior to (2016) extent and 

(see page 16 for habitat and plant Monitor and intervene resistance, including Euro-American condition. 

more and community management. when thresholds are enhancing the extent of settlement when 

elements that do crossed to protect the relatively scarce Coast Salish tribes 

not vary by diversity of plant habitats, i.e., grasslands managed the 

alternative) communities. and wetlands. landscape using fire. 

7 Under the No Action Alternative, the BLM would continue to take management actions on a case-by-case basis as necessary to meet law, regulation, and policy 

to the extent compatible with Proclamation 8947. 

8 The Cultural Resources section addresses cultural and historic sites. The Monument’s landscapes also have cultural values associated with plant communities 

and wildlife populations; the management of these values is described under the Habitat and Plants and Wildlife sections. The impact of plant communities on 

tribal interests is described under the Chapter 3 Tribal Interests section beginning on page 224. 

10 
No Action Alternative7 Alternative A Alternative B Alternative C Alternative D 

Habitat/ 

Plant 

Community 

Management 

(continued) 

The BLM would 

continue with custodial 

management of 

vegetation, including 

removing hazard trees 

and limited treatment of 

Prohibit chemical 

treatments (e.g., 

herbicides) and 

prescribed fire. 

Consider all vegetation 

management methods 

when designing 

projects to achieve 

habitat and plant 

Consider all 

vegetation 

management methods 

when designing 

projects to achieve 

habitat and plant 

community 

objectives. 

Consider all vegetation 

management methods 

when designing 

projects to achieve 

habitat and plant 

continued invasive plants. community objectives. Sub-Alternative C: 

prohibit chemical 

treatments (e.g., 

herbicides). 

community objectives. 

Recreation 

(see page 28 for 

more details and 

elements that do 

not vary by 

alternative) 

The 1990 ACEC 

decisions would continue 

for Chadwick Hill, 

Iceberg Point, Point 

Colville, and Watmough 

Bay: BLM would 

prohibit camping and 

require permits for 

organized groups. 

There would continue to 

be no plan-level decisions 

for the rest of the 

Monument. Monument 

would continue to be 

open to all non-motorized 

trail uses, designated and 

Facilitate authorized 

scientific, educational, 

and spiritual and 

traditional uses. 

Prohibit recreational 

use of the Monument 

(e.g., hiking, equestrian 

use, bicycle use, 

camping, etc.). This 

restriction does not 

apply to traditional 

tribal activities. 

Facilitate hiking, 

current designated site 

camping, and dispersed 

camping by permit. 

Manage for quiet and 

solitude by dispersing 

users on an expanded 

trail network and 

managing some areas 

for permit-only 

recreation. Prohibit 

equestrian and bicycle 

use on trails. 

Facilitate hiking, 

some equestrian trail 

use, and current 

designated site 

camping. Reduce 

existing trail network. 

Prohibit bicycle use 

on trails. 

Close lands with 

identified conflicts 

between hunting and 

other visitor uses to 

the discharge of 

firearms for half of 

9 hunting season . 

Facilitate hiking, 

equestrian and bicycle 

trail use, and expanded 

dispersed and 

designated site 

camping. Expand the 

trail network based on 

requests from the 

public for new trails. 

dispersed camping 

(outside of the ACECs), 

and the discharge of 

firearms. 

Sub-Alternative C: 

Close the Monument 

to the discharge of 

9 firearms . 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2

9 BLM-administered lands on which firearm discharge is not prohibited are open to this use, though may be subject to temporary closures for emergencies and 

public health and safety concerns. 

1 

11 
 

 

 

 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

Cultural Resources 

Background 

Proclamation 8947 identifies historic and cultural values as objects for which the Monument was 

established. The cultural importance of the Monument lands to Coast Salish tribes continues today. 

Cultural resources addressed in this section include buildings, structures, places, and archaeological sites 

with historical and/or cultural values, as well as sacred sites and traditional cultural properties and 

landscapes. The Monument also has cultural values associated with plant and wildlife populations; the 

management of these values is described below under Habitat and Plants and Wildlife. 

This document is using the term maritime heritage area to refer to the aids to navigation (i.e., lighthouse) 

facilities and surrounding lands at Turn Point, Patos Island, and Cattle Point (see Map 2 on page 62). 

These total approximately 28 acres of Monument land. 

See Tribal Interests beginning on page 33 and Habitat and Plants beginning on page 16 for management 

objectives and direction related to traditional tribal activities and the exercise of treaty rights and the 

management and harvest of culturally important plant resources. 

See Appendix S for a summary table of the differences between the alternatives for cultural resources. 

For the current cultural resource conditions in the Monument see to the section beginning on page 45. 

No Action Alternative 

There would continue to be no plan-level decisions related to cultural resources. Under the No Action 

Alternative, the BLM would continue to take actions as necessary to meet law, regulation, and policy to 

the extent compatible with Proclamation 8947. This would include continuing to meet basic stewardship 

responsibilities through custodial management. The BLM would make decisions about taking actions on 

a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Identify and protect historically significant cultural resources (i.e., those eligible for listing on the

National Register of Historic Places).

Management Direction: 

 Consult with Tribes and Tribal Historic Preservation Officers (THPOs), the Washington State

Historic Preservation Officer (SHPO), and other interested parties when undertaking actions to

implement the plan.

 Conduct proactive identification and documentation of cultural resources.

 Identify whether cultural resources are present before authorizing ground disturbing activities. Where

cultural resources are identified, modify the project to avoid or reduce impacts.

 Temporarily stabilize cultural or historic sites as necessary to recover cultural data in consultation

with SHPO and tribes.

 Allow excavation and recovery of scientific and/or historic values of cultural or historic sites through

practices such as data recovery (e.g., by excavation, relocation, or documentation), if avoiding

disturbance is not possible or where natural disturbances makes loss of values unavoidable.

 Fence, sign, and/or use natural materials such as driftwood to reduce damage and allow for

stabilization and repair where human activity is causing substantial impairment of cultural resources.

 Allow shoreline stabilization using soft stabilization methods that employ primarily natural materials,

such as live plants, logs, root wads, and vegetative mats where cultural resources are in danger of

being lost due to shoreline erosion.

12 
 

 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

 Allow use of structures within maritime heritage areas for educational and interpretive activities

where compatible with health and safety requirements if the use will not adversely affect the cultural,

historical, or other resource values.

 In collaboration with other governmental and non-governmental entities, identify and implement

actions to address threats to cultural resources due to disasters or disturbances such as sea level rise,

increased storm surges, seismic events/tsunamis, and oil spills.

 Manage vegetation in maritime heritage areas as needed to protect human health and safety and

historic structures (e.g., hazard tree management).

 Complete undertakings affecting historic properties—including Maritime Heritage Properties—in

accordance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties.

Alternative A 

Shoreline Erosion Management Direction: 

 Prohibit the use of hard shoreline stabilization methods, such as riprap.

Maritime Heritage Area Objective: 

 Manage to prevent impairment or loss of cultural resources.

Maritime Heritage Area Management Direction: 

 Undertake projects only as needed to prevent deterioration of cultural resources from current

condition, except to replace a historic structure currently present on the property in the event of its

destruction (e.g., due to an earthquake or tsunami).

 Manage vegetation only to prevent damage to cultural resources and to allow needed maintenance of

structures using manual, mechanical, chemical, or biological vegetation treatments.

 Prohibit chemical treatments (e.g., herbicides) in achieving cultural resource objectives.

Alternative B 

Shoreline Erosion Management Direction: 

 Allow both soft and hard shoreline stabilization methods to protect cultural resources.

Maritime Heritage Area Management Objectives: 

 Manage to prevent impairment of cultural resources, protect the integrity of the setting, and restore

structures to their historic appearance.

 Improve the resilience of cultural resources to disturbances, including sea level rise, increased storm

surge, fire, and seismic activity.

Maritime Heritage Area Management Direction: 

 Restore and/or rehabilitate and maintain existing historic structures.

 Prohibit construction or reconstruction of structures, except to replace a historic structure currently

present on the property after its destruction (e.g., due to an earthquake).

 Undertake projects to increase the stability of buildings and other structures to reduce impacts from

disturbances, including sea level rise, increased storm surge, and seismic activity.

 Manage vegetation to minimize risk to cultural resources from fire and other disturbance using

manual, mechanical, chemical, or biological vegetation treatments. This may include undertaking

projects to remove fuels and potential hazard trees around historic structures even where this is not in

keeping with the historic appearance of the property.

Alternative C 

Shoreline Erosion Management Direction: 

 Prohibit the use of hard shoreline stabilization methods, such as riprap.

13 
Maritime Heritage Area Management Objectives: 

 Manage to prevent impairment of cultural resources, protect the integrity of the setting, and restore 

and rebuild structures to their historic appearance. 

Maritime Heritage Area Management Direction: 

 Restore and/or rehabilitate and maintain existing structures. 

 Allow reconstruction of structures that were present historically. 

 Prohibit restoration, rehabilitation, or construction projects that adversely affect the historic 

properties’ appearance or setting. 

 Manage vegetation to protect the integrity of the setting using manual, mechanical, chemical, or 

biological vegetation treatments. 

Sub-Alternative C (same cultural resource management direction as Alternative C with the 

exception of the direction below) 

Management Direction: 

 Prohibit the use of chemical treatments (e.g., herbicides). 

Alternative D 

Shoreline Erosion Management Direction: 

 Allow both soft and hard (e.g. rip rap) shoreline stabilization methods to protect cultural resources, 

except in areas that have wilderness characteristics. Allow only soft stabilization and prohibit hard 

shoreline stabilization methods in areas that have wilderness characteristics (see page 37). 

Maritime Heritage Area Management Objectives: 

 Manage to prevent impairment of cultural resources and maintain the setting’s historic appearance.

 Provide for greater use of the Maritime Heritage Area by visitors and docents. 

Maritime Heritage Area Management Direction: 

 Restore and/or rehabilitate and maintain existing structures. 

 Allow reconstruction of structures that were present historically. 

 Adapt and/or modify some structures to facilitate greater use by visitors, including, potentially, 

overnight use of some facilities by docents. 

 Build new structures to facilitate recreation, education, interpretation, and facilities support. 

 Manage vegetation to protect the integrity of the setting using manual, mechanical, chemical, or 

biological vegetation treatments. 

Education and Interpretation 

Background 

Proclamation 8947 describes the Monument as “a classroom for generations of Americans.” The BLM 

will continue to work with partners on educational and interpretive efforts under all alternatives. 

See Appendix S for a summary table of the differences between the education and interpretation 

alternatives. For current education and interpretation conditions see the section beginning on page 70. 

No Action Alternative 

There would continue to be no plan-level decisions directly related to education or interpretation. The 

1990 ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay. These decisions direct the BLM to “place signs to control visitor use as necessary.” 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

5

0

5

0

5

0

5

0

1 

2 

3 

4 

6 

7 

8 

9 

1 

2 

3 

4 

6 

7 

8 

9 

1 

2 

3 

4 

6 

7 

8 

9 

1 

2 

3 

4 

6 

7 

8 

9 

1 

2 

1

1

2

2

3

3

4

1

1

1

1

1

1

1

1

2

2

2

2

2

2

2

2

3

3

3

3

3

3

3

3

4

4

14 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Provide high-quality education and interpretation about the Monument and its objects and values. 

Management Direction: 

 Coordinate with partners across to ensure high-quality, effective interpretation and education and to 

seek consistency with other Tribal, Federal, State, and local governments, where possible. 

 Develop educational and interpretive materials, including those that would be available via electronic 

media and off-site, on a variety of themes, including those listed in Appendix J: ImplementationLevel Plans and Administrative Actions. 

Alternative A 

Management Direction: 

 Install signs only as necessary to protect Monument objects and values and public health and safety. 

Alternative B 

Management Direction: 

 Install signs beyond trailheads and landing sites only as necessary to provide directional information 

and to protect Monument objects and values and public health and safety. In order to limit structures 

on the landscape, restrict educational or interpretive information to trailheads and landing sites. 

Alternatives C and D 

Management Direction: 

 Install signs to provide educational and interpretive messages, as well as to provide directional 

information and protect Monument objects and values and public health and safety, except in lands 

managed for their wilderness characteristics. In lands managed for their wilderness characteristics, 

install signs only as necessary to protect Monument objects and values and public health and safety. 

Grazing 

Background 

There is currently no livestock grazing taking place within the Monument. The Monument is not in a 

grazing district or allotment. 

No Action Alternative 

The 1990 ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay. These decisions prohibit the grazing of livestock within these areas. 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

The Monument would be unavailable for preference-based grazing under the authority of the Taylor 

Grazing Act, i.e., the BLM would not issue preference leases or permits for grazing within the Monument 

and would not allocate forage for grazing. In implementing the plan, the BLM may consider using 

biological controls—including grazing by goats or other livestock—to achieve habitat and plant 

community objectives. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

15 
5

10

15

20

25

30

35

40

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

Habitat and Plants10 

Background 

Proclamation 8947 identifies the Monument’s diverse habitats and plant communities as among the 

objects for which it was established. The extent of plant communities is changing due to ecological 

succession and the absence of fire. Prior to Euro-American settlement, Coast Salish tribes used fire to 

maintain grasslands in the San Juan Islands. Due to a discontinuation of these traditional stewardship 

practices and other historic activities, encroaching forest vegetation is gradually reducing grassland 

acreage. Without management intervention, these communities will continue to decline. 

During the 15 to 20-year life of the plan, the BLM will design and execute vegetation treatments—which 

will require additional decisions and public review—to achieve the RMP’s objectives. 

Special status plant species addressed in this document are those that are on the BLM Interagency Special 

Status Sensitive Species Program list (see the section beginning on page 117 for more information). 

The deed to Watmough Bay, which the BLM acquired in 1992, includes a conservation easement. This 

conservation easement restricts the BLM’s management of Watmough Marsh. Since the BLM is bound 

to abide by the terms of this easement, it is only considering the approach identified in the easement 

(described below under common to all action alternatives). 

See Appendix S for a summary table of the differences between the alternatives for habitat and plants. 

For current conditions related to habitat and plants see the section beginning on page 73. 

No Action Alternative 

There would continue to be no plan-level decisions directly related to vegetation management. The 1990 

ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and Watmough 

Bay. These decisions direct the BLM to design actions to protect Federal and State listed species. 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. For 

example, the BLM would continue to address hazard trees and provide some control of invasive plant 

species (currently it undertakes approximately 20 acres of treatment per year). 

Common to All Action Alternatives 

Habitat and Plant Communities Management Objective: 

 Protect the diversity of plant communities described in Proclamation 8947. 

Habitat and Plant Communities Management Direction: 

 Fence and/or sign areas to reduce damage and allow for recovery where human activity is causing 

substantial vegetative degradation. 

 Manage vegetation as needed to protect human health and safety (such as hazard tree management). 

 Seed and plant culturally important plants, such as camas, as part of vegetation management efforts, 

where possible. 

 Select from best management practices for vegetation treatments (Appendix F) to maintain water 

quality when conducting implementation-level projects. 

 Apply BLM mandated standard operating procedures for any application of herbicide.11 Standard 

operating procedures are located in Appendix B (Table B-2) of the BLM’s 2007 Record of Decision 

 

10 The habitat and plants objectives and direction would apply to the Monument except the 28 acres within maritime 

heritage areas; direction for the maritime heritage areas is provided under the Cultural Resources section. 11 Alternative A and Sub-Alternative C would not allow the use of chemical treatments (e.g., herbicides). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

16 
San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 for Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western 

States Programmatic Environmental Impact Statement and Appendix A of the BLM’s 2016 Record of

Decision for Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron on Bureau of 

Land Management Lands in 17 Western States Programmatic Environmental Impact Statement. 

Invasive Plant Species Management Objective: 

 Control invasive plant species within the Monument. 

Invasive Plant Species Management Direction: 

 Eradicate and/or control noxious weed species designated by Washington State for mandatory 

eradication or control. Tools available for control vary by alternative. 

BLM Special Status Plant Management Objective: 

 Manage BLM sensitive plant species to avoid the listing of plants under the Endangered Species Act. 

BLM Special Status Plant Management Direction: 

 Conduct pre-disturbance surveys prior to management actions that might disturb BLM sensitive 

plants in areas where suitable habitat for such plants is suspected. Where BLM sensitive plants are 

found, modify the project to avoid or reduce impacts. 

 Fence and install signs as necessary to protect BLM sensitive plants. 

 Remove encroaching native plants and non-native vegetation where the BLM determines that they are 

negatively affecting nearby BLM sensitive plants and replace with non-competitive native plants. 

Watmough Marsh Management Objective: 

 Manage Watmough Marsh in accordance with the restrictions imposed by the conservation easement. 

Watmough Marsh Management Direction: 

 Prohibit management actions that would change, disturb, alter, or impair the plant and animal 

habitat, ecological value, or scenic qualities of the marsh, in accordance with the easement. This 

includes not building any structures, roads, or trails in the marsh; not draining water into or out of 

the marsh; and not pruning, cutting, defoliating, or extracting any vegetation from the marsh. 

Alternative A 

Habitat and Plant Communities Management Objectives: 

 Allow natural succession and other processes to take place within the Monument while maintaining 

50 percent of the extent of the plant communities described in Proclamation 8947. Specifically12: 

o Maintain grassland and shrubland on ≥ 7 percent of the Monument. 

o Maintain forest and woodland on ≥ 40 percent of the Monument. 

o Maintain wetland on ≥ 2 percent of the Monument. 

Habitat and Plant Communities Management Direction: 

 Undertake vegetation management only as provided under common to all action alternatives or when 

the extent of a plant community within the Monument falls below the threshold in the objectives.13 

 

12These percentages maintain at least 50 percent of the approximate extent of each of the major plant communities 

within the Monument as of 2016. 13 An acre of land would transition from one plant community to another once it has crossed an ecological threshold 

such that substantial time, energy, and effort would be required to return the plant community to its original state, 

e.g., tree saplings—as opposed to just seedlings—have become established in meadow areas. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

17 
Allow mechanical, manual, and biological control methods to achieve habitat and plant communities 

objectives. 

Prohibit the use of chemical treatments (such as herbicides) and prescribed fire to achieve habitat and 

plant communities objectives. 

Require the use of native seed or other native plant propagules from appropriate geographic zones14 

for vegetation projects (including invasive plant treatments, as needed), unless it is unavailable within 

the timeframe of the project. 

nvasive Plant Species Management Direction: 

Control and contain invasive plant species when an average of less than 50 percent cover by native 

vegetation remains in a vegetative community across the Monument (e.g., total Monument grasslands 

and shrublands, not grasslands and shrublands at Iceberg Point). This is in addition to common to all 

action alternatives direction on noxious weed species designated by Washington State. 

Allow mechanical, manual, and biological control methods to control and contain invasive plants. 

Apply biopesticides (a type of non-chemical biological control) where applicable and approved by 

EPA and BLM national programs. 

Prohibit the use of chemical treatments, such as herbicides, and prescribed fire to control and contain 

invasive plants. 

LM Special Status Plants Management Direction 

See common to all management direction 

Alternative B 

abitat and Plant Communities Management Objectives: 

Enhance the San Juan Islands’ ecological resistance and resilience by increasing the extent of native 

plant communities—specifically grasslands and wetlands—that are currently scarce within the San 

Juan Islands relative to past conditions. Specifically: 

o Restore and/or maintain grassland and shrubland on approximately 50 percent of the Monument 

(tree savanna15, such as oak savanna, would contribute to this objective). 

o Restore and/or maintain forest and woodland on approximately 40 percent of the Monument. 

o Create, restore, and/or maintain wetland on approximately 7 percent of the Monument. 

Maintain forest communities identified by Washington Natural Heritage Program (WNHP) as G1S1, 

i.e., critically imperiled globally and in Washington State (this includes approximately 35 acres of 

Monument forest, see page 122). The BLM could undertake treatments to maintain or restore these 

communities, but would not convert them to wetland or grassland and shrubland. For this alternative, 

the BLM determined it was more important to expand grasslands than to maintain the WNHP priority 

ecological communities not ranked G1S1. 

Maximize native species richness and structural component diversity within each of the three major 

plant communities (wetlands, grasslands and shrublands, and forests and woodlands) to the extent that 

doing so is not detrimental to site-scale resilience. Specifically: 

o Within wetland communities, maximize native hydrophytic (i.e., aquatic) plant species richness 

and wetland processes (e.g., water storage, nutrient transformation). 

 

4 Information on seed zones can be found through the U.S. Forest Service’s Seed Zone Mapper tool, which is

vailable here: www.fs.fed.us/wwetac/threat_map/SeedZones_Intro.html 5 According to the BLM Forest Inventory System, savanna has less than 10 percent tree cover. Oak habitat with 

ore than 10 percent tree cover is considered woodland; all oak habitat currently within the Monument is woodland. 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 

2 

3 

4 

5 

6 

7 

8 I

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 B

19 

20 

21 H

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

1

a

1

m

18 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 o Within grassland and shrubland communities, maximize native grassland species richness; the 

objective would not necessarily be to eradicate shrubs, but the emphasis would be to maximize 

species richness and structural diversity of forbs. 

o Within areas of the Monument that would remain non-savanna forest and woodland, manage 

vegetation to achieve late successional characteristics. Maintain a maximum of 5 percent of 

forest in early seral condition (early seral condition is well represented in the San Juan Islands). 

 Manage for vegetation structures and species compositions that increase resistance to and resilience 

from fire, drought, insect pests, disease, and climate change. 

Habitat and Plant Communities Management Direction: 

 Allow mechanical, manual, biological control, chemical, and fire treatment methods to achieve 

objectives. 

o Examples of actions the BLM would take to achieve these objectives include tree removal to 

expand shrub and grasslands, removal of plants within wetlands (e.g., cutting trees in forested 

wetlands to increase species diversity and improve hydrologic conditions), excavation to expand 

wetlands and increase the diversity of wetland depths, and tree topping, tree removal, and other 

silvicultural methods to increase forest late successional characteristics. 

 Allow use of naturally ignited wildfires to help achieve vegetation management objectives, but only 

on islands that are entirely within the BLM’s jurisdiction.

 Work with the U.S. FWS on projects to enhance habitat conditions for federally listed or candidate 

wildlife species that are primarily using non-native host plants, including, as necessary, the 

maintenance or establishment of non-native plant populations16. Such actions would not include 

noxious weed species designated by Washington State for mandatory eradication or control. 

 Require the use of native seed or other native plant propagules from appropriate geographic zones14 

for vegetation projects (including invasive plant treatments, as needed), unless it is unavailable within 

the timeframe of the project, or unless BLM specialists determine that changing climate conditions 

would make seeds from long-lived species from other zones more suitable in the long-term. 

Invasive Plant Species Management Direction: 

 Allow mechanical, manual, biological control, chemical, and fire treatment methods to control and 

contain invasive plant species. Apply biopesticides (a type of non-chemical biological control) where 

applicable and approved by EPA and BLM national programs. 

 Apply early detection and rapid response principles when an invasive plant infestation is identified 

within the Monument. 

BLM Special Status Plants Management Direction: 

 Introduce rare species present in the San Juan Islands ecoregion, such as the federally threatened 

golden paintbrush (Castilleja levisecta), to potential Monument habitat to reduce risk of extinction. 

Introductions could occur even at sites where historic records do not exist for these species. 

 Augment existing BLM sensitive plant occurrences with locally sourced out-plantings on appropriate 

Monument lands. 

Alternative C 

Habitat and Plant Communities Management Objectives: 

 Reestablish the approximate extent and condition of plant communities that existed prior to EuroAmerican settlement of the San Juan Islands (approximately 1860), when Coast Salish peoples used 

fire to manage landscapes. Specifically: 

 

16 E.g., the larval form of the island marble butterfly (Euchloe ausonides insulanus), a species proposed by the U.S. 

FWS for Endangered Species Act listing, currently uses three species of host plants, two of which are non- native. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

19 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 o Restore and maintain native grassland and shrubland on approximately 48 percent of the 

Monument (tree savanna, such as oak savanna, would contribute to this objective). 

o Restore and maintain native forest and woodland on approximately 47 percent of the Monument. 

o Maintain native wetland on approximately 4 percent of the Monument. 

o Restore and maintain grassland and shrubland and forest and woodland in the less densely 

vegetated conditions such as relatively frequent, low intensity fires would have produced. 

 Maintain forest communities identified by WNHP as G1S1, i.e., critically imperiled both globally and 

in Washington State (this includes approximately 35 acres of Monument forest, see page 122). The 

BLM could undertake treatments to maintain or restore these communities, but would not convert 

them to grassland and shrubland. For this alternative, the BLM determined it was more important to 

expand grasslands than to maintain the WNHP priority ecological communities not ranked G1S1. 

 Reduce the threat of high-severity wildland fire or other major disturbance events. 

Habitat and Plant Communities Management Direction: 

 Refer to historical documents, such as historical land and aerial photos, USGS or General Land Office 

survey sheets, descriptions from early settlers and explorers, and traditional ecological knowledge, to 

determine the appropriate vegetation conditions for reestablishment through specific treatment. 

 Allow use of mechanical, manual, biological control, chemical, and fire treatment methods to achieve 

objectives. 

o Examples of actions that the BLM would take to achieve these objectives include removing trees 

to expand shrub and grasslands within the Monument; topping, pruning, and removing trees to 

create more open (i.e., less dense) forest conditions to restore stands to approximate historic tree 

density, composition, and structure, including, in some cases, tree savanna condition; protecting 

and enhancing conditions for large and old trees. 

o Use prescribed fire as the preferred method for maintaining desired conditions once established. 

o Allow use of naturally ignited wildfires to help achieve vegetation management objectives only on 

islands that are entirely within the BLM’s jurisdiction and on the Watmough Bay-Chadwick HillPoint Colville parcel. 

 Require the use of native seed or other native plant propagules from appropriate geographic zones14 

for vegetation projects (including invasive plant treatments, as needed), unless it is unavailable within 

the timeframe of the project. 

 Augment or reintroduce populations of culturally important plants, such as camas (Camassia 

leichtlinii and C. quamash), that were more prevalent in the 1860s. 

Invasive Plant Species Management Direction: 

 Allow use of mechanical, manual, chemical, biological, and fire treatment methods to control and 

contain invasive plant species. Apply biopesticides (a type of non-chemical biological control) where 

applicable and approved by EPA and BLM national programs. 

 Apply early detection and rapid response principles17 when an invasive plant infestation is identified 

within the Monument. 

BLM Special Status Plants Management Direction 

 See common to all management direction. 

Sub-Alternative C (same Habitat and Plant Communities objectives and direction as 

Alternative C, except that the direction below replaces references to chemical treatment methods) 

 

17 See the glossary for more information about early detection and rapid response. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

20 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 Management Direction: 

 Prohibit use of chemical treatments (such as herbicides) to achieve habitat and plant communities and 

invasive plant species objectives. 

Alternative D 

Habitat and Plant Communities Management Objectives: 

 Maintain approximate extent of plant communities that are documented on the landscape as of 2016: 

o Maintain grassland and shrubland on approximately 12 percent of the Monument. 

o Maintain forests and woodland on approximately 83 percent of the Monument. 

o Maintain wetland on approximately 4 percent of the Monument. 

 Reduce the threat of high-severity wildland fire or other major disturbance events. 

 Maintain vegetation structure and species composition in existing conditions. Define existing 

conditions in terms of maintaining current seral stages and plant species composition associated with 

the Monument’s ecological site types. 

Habitat and Plant Communities Management Direction: 

 Allow use of mechanical, manual, biological control, chemical, and fire treatment methods to achieve 

objectives. 

o Allow use of naturally ignited wildfires to help achieve vegetation management objectives only 

on islands that are entirely within the BLM’s jurisdiction. 

 Maintain existing populations of culturally important plants. 

 Require the use of native seed or other native plant propagules from appropriate geographic zones14 

for vegetation projects (including invasive plant treatments, as needed), unless it is unavailable within 

the timeframe of the project. 

Invasive Plant Species Management Direction: 

 Allow use of mechanical, manual, chemical, biological, and fire treatments to control and contain 

invasive plant species. Apply biopesticides (a type of non-chemical biological control) where 

applicable and approved by EPA and BLM national programs. 

 Apply early detection and rapid response principles when an invasive plant infestation is identified 

within the Monument. 

BLM Special Status Plants Management Direction 

 See common to all management direction. 

Hazardous Materials 

Background 

The BLM follows Federal and State law and policy in addressing current and future issues related to 

hazardous materials. 

The BLM is aware of one contaminated area within the Monument. Turn Point Light Station on Stuart 

Island contains lead contaminated soil, generated from decades of lead-based paint weathering and 

flaking from the buildings into the soil. The BLM encapsulated the lead-based paint on the exterior of the 

buildings to ensure the release of this substance from the buildings is contained. The BLM is currently 

evaluating the site under the Comprehensive Environmental Response, Compensation, and Liability Act. 

 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

21 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 No Action Alternative 

There would continue to be no plan-level decisions related to hazardous materials. Under 

the No Action Alternative, the BLM would continue to take actions as necessary to meet law, regulation, 

and policy to the extent compatible with Proclamation 8947. This would include continuing to meet basic 

stewardship responsibilities through custodial management. The BLM would make decisions about 

taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Maintain land health and public health and safety by responding to and remediating contamination 

and restoring natural resources injured by releases of hazardous substances or petroleum products. 

Management Direction: 

 Develop and implement project design features that prevent future hazardous materials incidences. 

 Address new incidences of hazardous materials within the Monument according to procedures in the 

BLM Spokane District’s Contingency Plan for Emergency Preparedness and Response to Oil and 

Hazardous Material Incidents (BLM 2016c). 

 Evaluate, prioritize, and remediate newly discovered or reported hazardous material sites or 

incidences in a timely manner using standard procedures consistent with BLM delegated authority, 

Federal and State laws, and policies. 

 Prohibit unauthorized storage, treatment, or disposal of hazardous materials and hazardous and solid 

wastes within the Monument. 

 For an incident of a magnitude requiring a coordinated Federal response, such as a large oil spill: 

o Provide support to the Department of the Interior’s Regional Environmental Officer, at the Office

of Environmental Policy and Compliance in Portland, OR, who would coordinate the BLM 

response with the Coast Guard Federal On-Scene Coordinator. 

o Follow the Northwest Area Contingency Plan. The Northwest Area Contingency Plan is 

available at: www.rrt10nwac.com/nwacp/ 

 Ensure that BLM employees and contractors who work with and around hazardous materials are 

properly trained and equipped, as prescribed in applicable Federal and State law and BLM policy. 

 Review lands and realty actions involving hazardous materials for compliance with Federal and State 

laws and regulations and BLM policy. Develop special stipulations as necessary as part of the rightof-way, permit, lease, or other action. 

 Review real property transactions prior to the action for recognized environmental conditions using 

applicable Federal and State laws and policy.18 

 Ensure that all actions authorizing subsequent use of previously remediated sites comply with Federal 

and State regulations. Develop necessary special stipulations as part of the permit, lease, or other 

action to protect human health and the environment. 

 Monitor the effectiveness of corrective actions at hazardous material sites. 

 Select from best management practices for vegetation treatments (Appendix F) to maintain water 

quality when conducting implementation-level projects involving hazardous materials. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

18 See BLM Handbook H-2000-01: Pre-Acquisition Environmental Site Assessment for more information 

22 
5

10

15

20

25

30

35

40

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

Lands and Realty 

Background 

Proclamation 8947 withdraws the Monument from all forms of entry, location, selection, sale, leasing, or 

other disposition under the public land laws, including withdrawal from location, entry, and patent under 

the mining laws, and from disposition under all laws relating to mineral and geothermal leasing, other 

than by exchange that furthers the protective purposes of the proclamation. 

See Appendix S for a summary table of the differences between the alternatives for lands and realty. For 

current conditions related to lands and realty see the section beginning on page 137. 

No Action Alternative 

The 1990 ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay. These decisions prohibit new rights-of-way in for additional roads, powerlines, 

pipelines, or communication facilities. They also direct the BLM to survey and clearly mark the 

boundaries of Point Colville and Iceberg Point and acquire public access to these lands. There would 

continue to be no plan-level decisions related to lands and realty outside of the ACECs. 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Land Tenure Management Objectives: 

 Protect and enhance Monument objects and values through land tenure actions. 

Land Tenure Management Direction: 

 Coordinate with the Coast Guard on the relinquishment of the remaining lighthouse withdrawals. 

 Consider acquisitions on a case-by-case basis. When reviewing a potential acquisition or exchange, 

consider criteria that include, but are not limited to: 

o The value or importance of the property to Monument objects and values19 and the likely longterm resource value of the property. 

o The function of the property to expand or secure legal public access to the Monument. 

o The level of threat to the property’s resources (e.g., from development). 

o The potential that the property will diminish in extent over time due to rising sea levels and 

erosion from increased storm surges. 

o The potential for acquired land to support camping and/or facilities for administrative use by 

BLM or its partners. 

o The role of partnering public and governmental entities in the acquisition. 

o The potential for acquired land to contribute to shared conservation objectives across the broader 

San Juan Islands. 

o The uniqueness of the opportunity. 

o The availability of funding. 

 When new lands are incorporated into the Monument—through an acquisition, the identification of 

new lands under BLM jurisdiction within the San Juan Islands, the BLM’s acceptance of lands 

relinquished by the Coast Guard, or the reversion of interests in lands currently held under a 

 

19 Monument objects and values include the Native American/Coast Salish and Maritime Heritage associated 

cultural values, paleontological values, diverse habitats, and diverse wildlife found within the Monument. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

23 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 Recreation and Public Purposes Act patent or a special act patent—these lands would be managed 

under the provisions of this RMP. If new lands include issues not considered under this RMP or 

would exceed the impacts considered in the EIS, the BLM would undertake an RMP revision. 

The BLM is developing this RMP with the assumption that the Coast Guard will complete the 

relinquishment of withdrawals affecting 189 acres and that these lands will come under BLM’s

jurisdiction (see page 1). Because this relinquishment is reasonably foreseeable (i.e., not certain, but 

the most likely outcome), the effects analysis assumes that these lands will be under the BLM’s 

jurisdiction during the implementation of the plan. As a result, the addition of these lands will not 

exceed the impacts considered in this EIS. 

Rights-of-Way and other Land-Use-Authorizations Objectives: 

 Allow authorized uses of the landscape while minimizing impacts to Monument objects and values. 

Rights-of-Way and other Land-Use-Authorizations Management Direction: 

 In addition to uses allowed under other portions of the plan, allow the following uses of the 

Monument under all action alternatives: 

o Valid existing rights. 

o Emergency uses of the Monument, such as search-and-rescue operations, fire response, law 

enforcement actions, and response to oil spills or hazardous materials releases, including staging 

for cleanup operations. Entities undertaking such emergency actions must minimize impacts to 

ecological and cultural values when operating within the Monument. 

o Use, maintenance, repair, and replacement (including access for these purposes) by the Coast 

Guard and other U.S. Department of Homeland Security agencies of Patos Island Light Station, 

Turn Point Light Station, and other aids to navigation for navigational or national security 

purposes. Rights-of-way for these purposes would be allowed regardless of restrictions described 

in the action alternatives. 

Alternative A 

Rights-of-Way Management Objective: 

 Administer rights-of-way while protecting Monument objects and values. 

Rights-of-Way Management Direction: 

 Consider rights-of-way applications that would meet the protective mandate of Proclamation 8947 on 

a case-by-case basis, including as provided under common to all action alternatives. 

Land Tenure Management Direction: 

 Designate all Monument lands as land tenure zone 1 (i.e., retain ownership of all Monument lands). 

Alternatives B and D 

Rights-of-Way Management Objectives: 

 Administer rights-of-way while protecting Monument objects and values. 

Rights-of-Way Management Direction: 

 Designate the Monument as a right-of-way avoidance area. 

o Only consider right-of-way applications that would not impair Monument objects and values and 

as provided under the actions common to all action alternatives. 

o Do not consider applications for wind and solar energy projects or communications towers, as 

they are assumed to require substantial impacts to Monument objects given the small size of the 

individual locations that compose the Monument. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

24 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 Land Tenure Management Direction: 

 Designate all Monument lands acquired through land and water conservation funds as land tenure 

zone 1 (i.e., retain without the possibility of exchange land acquired through land and water 

conservation funds, including Watmough Bay, Chadwick Hill, and parts of Iceberg Point). 

 Designate all remaining Monument lands as land tenure zone 2 (i.e., retain unless the BLM decides to 

participate in a land exchange that furthers the resource protection purposes of Proclamation 8947). 

Alternative C 

Rights-of-Way Management Objectives: 

 Prohibit rights-of-way across the Monument except as provided under common to all action 

alternatives. 

Rights-of-Way Management Direction: 

 Designate the Monument as a right-of-way exclusion area, with exceptions for rights-of-way 

described under common to all action alternatives. 

Land Tenure Management Direction (same as C and D): 

 Designate all Monument lands acquired through land and water conservation funds as land tenure 

zone 1 (i.e., retain without the possibility of exchange land acquired through such funds, including 

Watmough Bay, Chadwick Hill, and parts of Iceberg Point). 

 Designate all remaining Monument lands as land tenure zone 2 (i.e., retain land except consider 

exchanges that would further the resource protection purposes of Proclamation 8947). 

Natural Material Collection 

Background 

Management direction restricting the collection of natural materials under the alternatives would not 

apply to collection by Coast Salish tribal members for spiritual or traditional uses or through the exercise 

of tribal treaty rights. See the Paleontological section for information on the collection of paleontological 

resources and the Science section for information on collection for scientific purposes. 

See Appendix S for a summary table of the differences between the alternatives for natural material 

collection. For a description of the current status of natural material collection in the Monument see the 

section beginning on page 155 in Chapter 3. 

No Action Alternative 

The 1990 ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay. These decisions require members of the public to obtain permits to collect vegetation 

within these areas. There would continue to be no plan-level decisions related to natural material 

collection for Monument lands outside of the ACECs and the BLM could continue to manage natural 

material collection under the FLPMA and BLM Manual 5400-2. 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Manage collection of natural materials, such as rocks, firewood, driftwood, mushrooms, and edible, 

medicinal, and culturally important plants and seeds to ensure the protection of the Monument’s 

ecological values. 

Management Direction: 

 Restrict public collection amounts and activities as necessary to protect the Monument’s values.

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

25 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1  Require authorization from the Monument Manager for collection of natural materials related to 

research (see Science on page 32, below). 

 Allow administrative collection of seed. 

 Removal of trees would only be permitted to achieve objectives for habitats and vegetative 

communities (see Habitat and Plants on page 16, above). 

Alternative A 

Management Direction: 

 Require free use permits for collection of natural materials. This requirement would not apply to 

collection for Coast Salish tribes’ spiritual or traditional use or the exercise of treaty rights. 

 Prohibit collection of natural materials for commercial purposes. 

Alternative B 

Management Direction: 

 Require permits for non-commercial collection of natural materials. This requirement would not 

apply to collection for Coast Salish tribes’ spiritual or traditional use or the exercise of treaty rights. 

 Prohibit collection of all natural materials for commercial purposes. 

Alternative C 

Management Direction: 

 Prohibit all non-scientific collection of natural materials. This prohibition would not apply to 

authorized research or Coast Salish tribes’ spiritual or traditional use or the exercise of treaty rights. 

 Work with interested Coast Salish tribes to develop a voluntary tribal government-based authorization 

and monitoring system for collection of materials for spiritual or traditional use or the exercise of 

treaty rights. 

Alternative D 

Management Direction: 

 Require permits for non-commercial collection of natural materials. This requirement would not 

apply to collection for Coast Salish tribes’ spiritual or traditional use or the exercise of treaty rights. 

 Allow sustainable collection of natural materials for commercial purposes with a paid permit. 

 Prohibit collection of natural materials for commercial purposes within areas that the BLM has 

identified as having wilderness characteristics (see Wilderness Characteristics on page 37, below). 

Paleontology 

Background 

Proclamation 8947 identified paleontological resources as an object for which the Monument was 

designated. The BLM is currently aware of one paleontological resource locality within the Monument. 

It is likely that additional paleontological resources exist. The Approved RMP’s objectives and direction 

would apply to any paleontological resources discovered within the Monument. 

See Appendix S for a summary table of the differences between the alternatives for paleontological 

resources. For the current condition of paleontological resources see the section beginning on page 140. 

No Action Alternative 

There would continue to be no plan-level decisions related to paleontological resources. Casual 

collecting of common invertebrates and plant fossils would continue to be allowed throughout the 

Monument (16 USC 470aaa-3). Under the No Action Alternative, the BLM would continue to take 

actions as necessary to meet law, regulation, and policy to the extent compatible with Proclamation 8947. 

This would include continuing to meet basic stewardship responsibilities through custodial management. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

26 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 The BLM would make decisions about taking actions on a case-by-case basis after completing the 

appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objectives: 

 Protect important paleontological resources where they are found within the Monument. 

Management Direction: 

 Conduct proactive inventories to identify and document paleontological localities. 

 Conduct on the ground inventories in areas where paleontological resources are likely to occur before 

authorizing implementation-level ground disturbing activities. Where important paleontological 

resources are found, modify project to avoid impacts. 

 Fence and/or sign areas to reduce damage and allow for stabilization, repair, and recovery where 

human activity is causing substantial damage to paleontological resources. 

 Prohibit collection of vertebrate or trace fossils for nonscientific purposes except by the BLM where 

they are threatened by natural or human activity. 

 Require a free use permit for collection of common invertebrate and plant fossils. 

 Allow shoreline stabilization using soft stabilization methods that employ primarily natural materials, 

such as live plants, logs, root wads, and vegetative mats where paleontological resources are in 

danger of being lost due to erosion. 

Alternative A and C 

Management Direction: 

 Prohibit shoreline stabilization using hard shoreline stabilization methods, such as riprap. 

Alternative B 

Management Direction: 

 Allow both hard and soft shoreline stabilization methods to protect paleontological resources. 

Alternative D 

Management Direction: 

 Allow both hard and soft shoreline stabilization methods to protect paleontological resources, except 

in areas that have wilderness characteristics. Allow only soft stabilization and prohibit hard shoreline 

stabilization methods in areas that have wilderness characteristics (see page 37). 

Partnerships 

Background 

Under all alternatives, the BLM would continue to collaborate and coordinate with governmental and 

non-governmental partners across the San Juan Islands. Given the dispersed nature of Monument lands, 

partnerships and collaboration are essential to achieving management objectives. 

No Action Alternative 

The 1990 ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay. These decisions direct the BLM to enter into a law enforcement agreement with the 

County Sheriff and enter into a Memorandum of Understanding with interested parties to implement the 

ACEC decisions. There would continue to be no other plan-level decisions related to partnerships. The 

BLM would, however, continue to maintain and develop partnerships related to the Monument. 

Common to All Action Alternatives 

Management Objective: 

 Contribute to a collaborative approach to management across the San Juan Islands. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

27 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 Management Direction: 

 Coordinate and collaborate with Federal, Tribal, State, local, and non-governmental partners when 

undertaking projects to implement the plan. 

 Develop assistance agreements, memoranda of understanding, and other mechanisms to facilitate 

resource sharing and shared goals and objectives. 

Recreation and Visitor Services 

Background 

Proclamation 8947 does not identify recreation as an object or value for which the Monument was 

designated. It does describe continued human appreciation of the area: “These lands are a refuge of 

scientific and historic treasures and a classroom for generations of Americans.” Recreation is a primary

means by which the public can learn to appreciate the Monument’s objects and values. It also has the 

potential to degrade the values that attract visitors to the Monument and the San Juan Islands in general. 

Recreation is defined as the use of leisure time to freely engage in activities in a variety of settings that 

provide personal satisfaction and enjoyment. For the purposes of this planning effort, recreation does not 

include activities undertaken exclusively for educational, scientific, cultural, or spiritual purposes. 

For the purposes of this planning effort, the BLM has divided the Monument up into 16 potential 

recreation management areas (RMAs) (Appendix O includes maps of the RMAs). In most cases, these 

areas are specific Monument locations (e.g., Watmough Bay, Cattle Point, etc.). These locations are 

scattered across the San Juan Islands and in many cases potential RMAs are not in close proximity to 

other Monument lands. The BLM has identified specific recreation objectives for RMAs for each 

alternative under which they would be designated along with allowable and prohibited uses that would be 

established in order to meet these objectives (see Appendix O). The BLM grouped smaller islands and 

rocks into categories based on shared management concerns. Rocks are distinguished from islands by 

their minimal vegetation and small size. In the event that the BLM acquires or identifies additional 

Monument lands, they would be managed within the most similar RMA. The 16 potential RMAs are: 

 Cape Saint Mary (Lopez Island): approximately 2 acres 

 Carter Point (Lummi Island): approximately 43 acres 

 Category A Rocks20: a total of approximately 4 acres encompassing East Sound Blind Island South, 

Kanaka Bay Islands, King Islands, Massacre Bay Rocks, Richardson Rocks (2 smaller rocks), Trinka 

Rock, Unnamed Rock (WNW Kanaka Bay Island) 

 Category B Rocks21: a total of approximately 6 acres encompassing Barnes Rocks, Blind Bay Island 

Rock, Carter Point Rocks, Chuckanut Rocks, Davis Bay Island and Rocks, East Sound Blind Island 

North, John’s Island Rocks, John's Pass Rocks, Leo Reef, Lovers Cove Rocks, MacKaye Harbor

Rocks, Mitchell Bay Rocks, Oak Island Rock, Outer Bay Rocks, Picnic Point Rocks, Prevost Harbor 

Rocks, Reid Harbor Rock, Reservation Bay Rocks, Rock Island, Satellite Island Rocks, Unnamed 

Rocks (Grandma's Cove), Unnamed Rocks (Iceberg Point Rocks), Unnamed Rocks (Jones Bay 

Rock), Unnamed Rocks (Pear Point and Danger Rocks), Unnamed Rock (Seal Rock), Unnamed 

Rocks (Shaw Island), Unnamed Rocks (South Lopez) 

 Cattle Point (San Juan Island): approximately 23 acres 

 Chadwick Hill (Lopez Island): approximately 294 acres 

 Eliza Point (Eliza Point): approximately 4 acres 

 

20 Category A rocks have some known recreational use as of 2016 and generally have less sensitive resources than 

Category B rocks. 21 Category B rocks have limited or no recreational use as of 2016 and generally have more sensitive resources than 

Category A rocks (this includes all rocks formally identified as marine mammal haul-outs). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

28 
 

 

 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

 Iceberg Point (Lopez Island): approximately 97 acres 

 Islands: a total of approximately 43 acres encompassing Blind Island, Broken Point Island, Fauntleroy 

Rock, Freeman Island, Indian Island, Little Patos Island, Lummi Rocks, McConnell Rocks, Mud 

Island, Oak Island, Park Bay Island, Posey Island, Reads Bay Island, Richardson Rocks, Skull Island, 

Twin Rocks, Victim Island 

 Kellett Bluff (Henry Island): approximately 63 acres 

 Lopez Pass (Lopez Island): approximately 1 acre 

 Patos Island: approximately 211 acres 

 Point Colville (Lopez Island): approximately 75 acres 

 President Channel (Orcas Island): approximately 31 acres 

 Turn Point (Stuart Island): approximately 86 acres 

 Watmough Bay (Lopez Island): approximately 37 acres 

See Appendix S for a summary table of the differences between the alternatives for recreation. The full 

details of each alternative’s allowable and prohibited use decisions are in Appendix O. For current 

conditions related to recreation see the section beginning on page 145. 

Note: Monument visitors must follow all pertinent laws protecting marine mammals and migratory birds. 

No Action Alternative 

The 1990 ACEC decisions would continue to apply to Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay. These decisions prohibit fires, trail construction, and camping in these areas. They also 

require organized groups of 10 or more to obtain permits. There would continue to be no plan-level 

decisions on recreation outside of the ACECs. Most forms of recreation would continue to be allowed in 

the Monument, including non-motorized trail uses (hiking, equestrian, bicycling), camping (outside of the 

ACECs), and hunting with firearms and bows (in compliance with State and local regulations). 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

There would continue to be no RMAs or recreation objectives; over time the impact from visitors could 

increase and the visitor experience in the Monument could change. 

Common to All Action Alternatives 

Management Objective: 

 Protect Monument objects and values from loss due to visitation. 

Management Direction: 

 Develop interagency visitor facilities and materials in coordination with agency partners. 

 Prohibit campfires near structures and sensitive resources. 

 Minimize the impacts on dark night skies from all lighting installed within the Monument. 

 Prohibit take-off and landing of manned aircraft except for administrative and emergency purposes 

(recreational use of unmanned aircrafts is addressed in Appendix O: RMA Frameworks). 

 Prohibit use of fireworks on all Monument lands. 

 Prohibit use of metal detectors by the public to avoid potential disturbance of cultural resources from 

digging associated with this activity. 

 Prohibit placement of physical geocaches within Monument to avoid potential disturbance of cultural 

29 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 resources from hiding and uncovering of caches associated with this activity (this would not affect 

geocaching with virtual caches). 

 Undertake temporary closures as necessary to protect the Monument’s ecological and cultural values, 

as well as sensitive tribal activities. 

Alternative A 

Under Alternative A, the BLM would facilitate use of the Monument for authorized research, educational, 

cultural, and spiritual activities, but not for recreation. As a result, the BLM would not designate any of 

the potential RMAs under Alternative A and would prohibit recreation on Monument lands. 

Management Objectives: 

 Facilitate use of the Monument for scientific, educational, cultural, and spiritual uses. 

 Minimize impacts to Monument objects and values from human use. 

Management Direction: 

 Issue written authorizations for research, educational, cultural, and spiritual uses of the Monument to 

the extent consistent with protecting its objects and values. 

 Prohibit recreational use of Monument lands (including recreational boat landing). 

 Do not issue competitive special recreation permits. 

Alternative B 

Under Alternative B, the BLM would designate all potential RMAs except Category A Rocks and 

Category B Rocks. The BLM would prohibit recreation on Category A Rocks and Category B Rocks. In 

order to provide opportunities for solitude and quiet, the Cape Saint Mary, Carter Point, Kellett Bluff, 

Lopez Pass, President Channel, and Islands RMAs would be open for recreation by permit only. 

Management Objectives: 

 Facilitate recreational use that is compatible with protecting Monument objects and values. 

 Facilitate an experience of quiet and solitude. 

 Provide hiking22, picnicking, and camping opportunities within the Monument. 

Management Direction: 

 Do not issue competitive special recreation permits. 

 Apply allowable and prohibited use decisions described in the RMA frameworks to meet RMA 

objectives in Appendix O. These decisions include: 

o Prohibit non-hiking travel (e.g., motorized, bicycle, and equestrian) within of Monument, except 

on existing roads (depicted the travel and transportation alternatives in Appendix H). 

o Require all visitors to stay on designated trails or on un-vegetated shoreline in travel 

management areas with designated trails (see Appendix H), except when gathering natural 

materials, hunting, or other authorized purposes. 

o Do not develop additional visitor facilities (e.g., benches, restrooms, parking areas). See the 

Education and Interpretation section beginning on page 14 for management direction addressing 

signs. 

o Allow existing designated site camping and dispersed, small group camping by permit in 

specified RMAs (see Appendix O). 

o Prohibit pets within the Monument in order to remove the possibility of wildlife disturbance and 

visitor conflict related to pets. This prohibition does not apply to service animals. 

 

22 For the purposes of this document, “Hiking” encompasses all forms of pedestrian recreational travel, including,

but not limited to, walking for pleasure and exercise and trail running. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

30 
San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 o Prohibit the launching and landing of unmanned aircraft (e.g., drones) for recreational purposes 

from Monument land. 

Alternative C 

Under Alternative C, the BLM would designate all potential RMAs except for Category B Rocks. The 

BLM would prohibit recreation, including recreational boat landing, on Category B Rocks. 

Management Objectives: 

 Facilitate recreational use that is compatible with protecting Monument objects and values. 

 Provide hiking, picnicking, equestrian, biking, and camping opportunities within the Monument. 

Management Direction23: 

 Prohibit discharge of firearms24in the following areas (612 acres in total) except for half of modern 

firearm and muzzleloader deer hunting season25: Cattle Point, Chadwick Hill, Iceberg Point, Point 

Colville, Turn Point, and Watmough Bay. Work with the Washington Department of Fish and 

Wildlife (WDFW) annually to establish the period of time during which the prohibition would not 

apply. 

The areas identified for this prohibition are those about which the BLM has received public 

comments expressing concern about discharge of firearms. 

 Do not issue competitive special recreation permits. 

 Apply allowable and prohibited use decisions described in the RMA frameworks to meet RMA 

objectives in Appendix O. These decisions include: 

o Manage specified areas for trail-based equestrian travel, in addition to hiking. 

o Require all visitors to stay on designated trails or on un-vegetated shoreline in travel management 

areas with designated trails (see Appendix H), except for the purpose of gathering natural 

materials, hunting, or other authorized purposes. 

o Allow camping in existing designated sites. 

o Prohibit unleashed pets within the Monument in order to allow pets while minimizing wildlife 

disturbance and visitor conflict. 

o Require a permit for the launching and landing of unmanned aircraft (e.g., drones) by the public 

from Monument land26. 

Sub-Alternative C (same Recreation objectives and direction as Alternative C, except for 

the direction below) 

Management Direction: 

 Prohibit discharge of firearms within the Monument24, except for use by Coast Salish tribal members 

for the purposes of hunting. 

Alternative D 

Under Alternative D, the BLM would designate all potential RMAs. 

Management Objectives: 

 

23 Where a particular use is not prohibited on BLM-administered land it is generally allowed within the constraints 

of law and regulation, though may be subject to temporary closures for emergencies and public health and safety 

concerns. 

24 The firearm prohibition included in this alternative would not affect non-firearm-based hunting (e.g., bow 

hunting); it would also not apply to the use of firearms by Coast Salish tribal members for the purposes of hunting. 25 This is similar to how hunting is managed at Lopez Hill, which is the only other public land on Lopez Island 

where hunting is currently allowed: https://lopezhill.org/hunting-on-lopez-hill/ 26 As is the case throughout the United States, all unmanned aircraft use must comply with Federal Aviation 

Administration laws and regulations (see www.faa.gov/uas) 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

31 
 

 

 

 

 

 

 

 

 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

 Facilitate recreational use that is compatible with protecting Monument objects and values. 

 Provide hiking, picnicking, equestrian, biking, and camping opportunities within the Monument. 

Management Direction: 

 Apply allowable and prohibited use decisions described in the RMA frameworks in Appendix O. 

These decisions include: 

o Manage specified areas for equestrian and/or bicycle uses, in addition to hiking. 

o Manage for dispersed camping except on Category B Rocks, Twin Rocks, Victim Island, 

Watmough Bay, and areas managed for designated site camping. Manage designated site 

camping to support the Cascadia Marine Trail in specified RMAs. Specific locations of sites 

would be determined during plan implementation. The BLM would work with agency partners 

(including Washington State Parks) and the public to identify appropriate locations for these sites. 

o Prohibit unleashed pets within the Monument in order to allow pets while minimizing wildlife 

disturbance and visitor conflict. 

o Allow the launching and landing of unmanned aircraft (e.g., drones) by the public from 

Monument land26. 

Science 

Background 

Proclamation 8947 describes the Monument as a refuge for “scientific and historic treasures” and the 

lands that make it up as “some of the most scientifically interesting lands in the San Juan Islands.”

For current conditions related to science within the Monument see the section beginning on page 33. 

No Action Alternative 

There would continue to be no plan-level decisions related to science. Under the No Action Alternative, 

the BLM would continue to take actions as necessary to meet law, regulation, and policy to the extent 

compatible with Proclamation 8947. This would include continuing to meet basic stewardship 

responsibilities through custodial management and continuing to allow scientific research to take place 

within the Monument to the extent compatible with the proclamation. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objectives: 

 Facilitate scientific assessments, inventory, monitoring, research, and education that would enhance 

the understanding and protection of Monument objects and values. 

 Facilitate opportunities for youth and citizen scientists to participate in the scientific assessments, 

inventory, monitoring, research, and education identified in the Monument science plan, which the 

BLM will develop after the publication of the Approved RMP. 

Management Direction: 

 Require written Monument Manager authorization for all scientific research projects, including any 

collection of materials from the Monument for scientific purposes. 

o Only approve authorizations where they comply with the RMP and applicable laws and 

regulations. Authorization may take a variety of forms, including a special use permit; an 

interagency, assistance, or cooperative agreement; an Archaeological Resources Protection Act 

permit; an Antiquities Act permit; a paleontological resource use permit; or other permit. 

 Permit destructive sampling (i.e., procedures that cause permanent change to sampled material) of 

ecological and cultural values only when: a) sampling is the only viable method for the research and 

b) the research is expected to answer critical questions to benefit long-term protection of Monument 

32 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 objects and values. Specify in the research authorization whether destructive sampling can occur, the 

amount of material that can be destroyed, and proper handling of any samples of human remains. 

 Require Monument Manager approval for any physical installations for scientific purposes—such as 

data loggers and sensors. 

 Require researchers to provide the BLM with an electronic copy of all final reports and scientific 

papers resulting from the research conducted within the Monument. The BLM may share research 

for public use, including in an online format. 

 Require scientists to include a public outreach/education component in research projects, such as 

involving educators, students, or citizen scientists in research, as the Monument Manager deems 

appropriate. 

 Encourage the use of established and reputable citizen science projects, such as data collection 

through bio-blitzes, citizen science apps, Christmas bird counts, and initiatives identified in the 

Federal Crowdsourcing and Citizen Science Toolkit and the Citizen Science Alliance. 

Tribal Interests 

Background 

Native American/Indigenous Peoples have inhabited the region for more than 10,000 years, utilizing 

lands in the San Juan Islands for hunting, fishing, plant gathering, trade and exchange, and other cultural, 

social, and religious activities. Many of these activities occurred within what is now the Monument. The 

Coast Salish peoples continue to live in the San Juan Islands and surrounding areas and utilize the public 

lands and resources—including the Monument—that are part of their aboriginal territory and usual and 

accustomed use area. 

Federally recognized tribes retain rights and/or interests in public lands through treaties, executive orders, 

and/or Federal statutes. Through treaties, Coast Salish tribes granted land and other natural resources to 

the United States while retaining all rights not expressly granted. The BLM, as a Federal land managing 

agency, seeks to provide healthy habitats and water quality for maintaining treaty resources and access to 

public lands for practicing treaty rights, including hunting, fishing, and gathering activities as provided by 

statute and executive order. Federal agencies must consider how their actions affect treaty rights for 

access to usual and accustomed places for fishing and to open and unclaimed lands for hunting and 

gathering, as well as the impacts of actions to the cultural and socioeconomic interests of all federally 

recognized tribes. 

As noted in the legal obligations section on page 6, the BLM will meet all pertinent legal obligations in 

managing the Monument, including those related to Tribal treaties. Under all alternatives, the BLM will 

collaboratively engage with tribal partners to facilitate tribal activities within the Monument. 

For current conditions related to tribal interests refer to the section beginning on page 215. 

No Action Alternative 

There would continue to be no plan-level decisions explicitly related to tribal interests. Under 

the No Action Alternative, the BLM would continue to take actions as necessary to meet law, regulation, 

and policy to the extent compatible with Proclamation 8947. This would include continuing to meet basic 

stewardship responsibilities through custodial management. The BLM would make decisions about 

taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective 

 Collaboratively engage with tribal government partners. 

Management Direction: 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

33 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1  Use temporary closures to facilitate sensitive tribal activities, traditional uses, and the exercise of 

treaty rights, or to avoid safety hazards potentially stemming from such tribal activities. 

 Work with tribes to develop opportunities for co-stewardship of culturally-important plant 

communities and species. 

 Work with tribes to develop opportunities for youth and elder engagement. 

 Seek opportunities to work with tribal partners to research and restore original Coast Salish place 

names whether formally or informally (e.g., as subtitles on outreach materials). 

 Maintain and improve access for exercise of treaty rights and traditional cultural practices. 

Travel and Transportation 

Background 

Proclamation 8947 requires that, except for emergencies, Federal law enforcement, or authorized 

administrative purposes, motorized vehicle use only occur on designated roads and mechanized vehicle 

use (e.g., bicycles) only occur on designated roads and trails. 

The designation of land as open, closed, or limited to public motorized vehicle use is a plan-level 

decision. The BLM is also undertaking implementation-level travel planning concurrent with the 

planning effort. This entails identifying roads and trails that would be available to the public under each 

alternative, as well as what modes of transportation the BLM would allow on these routes. 

For the foreseeable future, the Coast Guard will maintain jurisdiction for a total of 17 acres surrounding 

three aids to navigation at Cattle Point, Iceberg Point, and Kellett Bluff. The Monument’s current trail 

network crosses these areas at Cattle Point and Iceberg Point and the BLM provides some on-the-ground 

management. Because of this, the BLM is considering these trails in its travel and transportation planning 

with the intent of providing the Coast Guard with recommendations on the designation of these trails. 

See the Recreation table in Appendix S for a summary of the differences between the alternatives for 

travel and transportation. For current conditions related to travel and transportation in the Monument, see 

the section beginning on page 145. See Appendix H for site-specific maps and road and trail details. 

No Action Alternative 

Proclamation 8947 would continue to require that public motorized use be restricted to designated roads 

and public mechanized vehicle use (e.g., bicycle use) be restricted to designated roads and trails under the 

No Action Alternative. The 1990 ACECs decisions also prohibit public motorized vehicle use off of 

roads and prohibits trail construction within the ACECs. There would continue to be no plan-level 

decisions related to travel and transportation outside of the ACECs. The existing road and trail network, 

much of which is composed of user created trails, would likely continue. 

Under the No Action Alternative, the BLM would continue to take actions as necessary to meet law, 

regulation, and policy to the extent compatible with Proclamation 8947. This would include continuing to 

meet basic stewardship responsibilities through custodial management. The BLM would make decisions 

about taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Manage travel within the Monument to facilitate uses allowed under each alternative and to protect 

Monument objects and values. 

Management Direction: 

 Designate the whole of the Monument (1,021 acres) as limited to designated roads for public 

motorized vehicle use (i.e., public motorized vehicle use would be restricted to designated roads). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

34 
5

10

15

20

25

30

35

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1  Limit bicycle and equestrian access to designated roads and trails within the Monument (note: the 

BLM would not designate trails for equestrian access under alternatives A and B and would not 

designate trails for bicycle access under alternatives A, B, and C). 

 Select from best management practices for trail development and maintenance (Appendix F) to 

maintain water quality when conducting implementation-level projects. 

Alternative A 

Summary of Implementation-level Road and Trail Designation Decisions for Alternative A (see Appendix 

H for site-specific maps and road and trail details): 

 Close 1 mile of existing road to public motorized access at Point Colville, Turn Point, and Watmough 

Bay. Maintain these roads for motorized administrative and authorized uses27. 

 Maintain non-motorized trails as necessary for administrative and authorized uses. These trails would 

be closed except for administrative or authorized uses. 

Alternative B 

Summary of Implementation-level Road and Trail Designation Decisions for Alternative B (see Appendix 

H for site-specific maps and road and trail details): 

 Designate 1 mile of existing road for public motorized access at Point Colville, Turn Point, and 

Watmough Bay (roads would also continue to be open to all modes of non-motorized transportation). 

 Designate a trail network that would disperse hiking across the Monument in order to provide 

opportunities for a more solitary visitor experience. 

 Require all visitors to stay on designated trails or on un-vegetated shoreline in travel management 

areas with designated trails (see Appendix H), except for the purpose of gathering natural materials, 

hunting, or other authorized purposes. 

 Designate 19.4 miles of trail for hiking28. The BLM would recommend that the Coast Guard maintain 

0.9 miles of trail for hiking. 

 Close approximately 1.1 miles of existing user created trails. The BLM would recommend that the 

Coast Guard close 0.2 miles of existing trail. 

Alternative C 

Summary of Implementation-level Road and Trail Designation Decisions for Alternative C (see Appendix 

H for site-specific maps and road and trail details): 

 Designate 0.6 miles of existing road for public motorized access at Turn Point and Watmough Bay 

(roads would also continue to be open to all modes of non-motorized transportation). 

 Close 0.4 miles of road to public motorized access at Point Colville and Turn Point (west of the 

parking area). Maintain these road segments for administrative and authorized uses27(these road 

segments would also continue to be open to all modes of non-motorized transportation). 

 Designate the minimum trail network to provide for hiking access and equestrian opportunities. 

 

27 Authorized users would include the Coast Guard for the use, maintenance, repair, and replacement of aids to 

navigation and owners of private lands that can only be accessed via BLM-administered road at Point Colville. 28 For the purposes of this document, “Hiking” encompasses all forms of public pedestrian recreational travel, 

including, but not limited to, walking for pleasure and exercise and trail running. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

35 
San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1  Require all visitors to stay on designated trails or on un-vegetated shoreline in travel management 

areas with designated trails (see Appendix H), except when gathering natural materials, hunting, or 

other authorized purposes. 

 Designate 11.3 miles of trail for hiking.29 The BLM would recommend that the Coast Guard maintain 

0.7 miles of trail for hiking. 

 Designate 2.6 miles of trail for equestrian use (all but 0.2 miles would be closed to equestrian use 

during the wet season30). 

 Close 3.6 miles of current user created trails. The BLM would recommend that the Coast Guard close 

0.4 miles of existing trail. 

Alternative D 

Summary of Implementation-level Road and Trail Designation Decisions for Alternative D (see Appendix 

H for site-specific maps and road and trail details): 

 Designate 0.9 miles of road for public motorized access at Point Colville, Turn Point, and Watmough 

Bay (all modes of non-motorized public transportation would be allowed on these roads). 

 Close 0.1 miles of road to public motorized access at Turn Point (west of the parking area). Maintain 

these road segments for administrative and authorized uses (this road segment would also continue to 

be open to all modes of non-motorized transportation). 

 Designate a trail network to provide expanded opportunities for recreation within the Monument 

while still protecting its objects and values. 

 Designate 23.5 miles of trail for hiking. The BLM would recommend that the Coast Guard maintain 

1.2 miles of trail for hiking. 

 Designate 8 miles of trail for equestrian use (7.6 miles of which would be closed to equestrian use 

during the wet season30). The BLM would recommend that the Coast Guard maintain 1.2 miles of 

trail for equestrian use (all 1.2 miles would be closed to equestrian use during the wet season30). 

 Designate 8 miles of trail for bicycle use (7.7 miles of which would be closed to equestrian use during 

the wet season30). The BLM would recommend that the Coast Guard maintain 0.4 miles of trail for 

bicycle use (0.3 miles of which would be closed to equestrian use during the wet season30). 

 Close 3.6 miles of current user created trails. The BLM would recommend that the Coast Guard close 

0.4 miles of existing trail. 

Visual Resources Management 

Background 

The BLM sets visual resource management (VRM) objectives to establish the maximum allowable level 

of contrast that a project can introduce to a particular landscape31 . The BLM would work with the Coast 

Guard to ensure that use, maintenance, repair, and replacement (including access for these purposes) of 

aids to navigation in the Monument are accomplished while meeting visual resources objectives. See the 

Visual Resources section in Appendix E for information on how the BLM inventories and plans for visual 

resources. 

See Appendix S for a summary table of the differences between the alternatives for visual resources. For 

the Monument’s current visual resources inventory see the section beginning on page 225. 

 

29 This includes rerouting a trail at Iceberg Point around a population of white-topped aster, a BLM sensitive plant. 30 The period of the seasonal closure would be based on BLM monitoring and could vary from year to year. 31 Projects have five years to conform to VRM objectives, e.g., a project to stabilize a structure could require 

machinery that would temporarily create substantial visual contrast. As long as this impact is removed within five 

years the project can still conform to restrictive VRM classes. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

36 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 No Action Alternative 

There would continue to be no plan-level decisions related to VRM. Under the No Action Alternative, 

the BLM would continue to take actions as necessary to meet law, regulation, and policy to the extent 

compatible with Proclamation 8947. This would include continuing to meet basic stewardship 

responsibilities through custodial management. The BLM would make decisions about taking actions on 

a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Maintain or improve the current quality of visual resources within the Monument except where doing 

so would conflict with conserving, protecting, or restoring Monument objects and values. 

Alternative A 

Management Direction (See Map 3 on page 230 of Chapter 3): 

 Manage areas managed for their wilderness characteristics under this alternative (232 acres) as VRM 

Class I. 

 Manage all other areas (789 acres) as VRM Class II. 

Alternative B32 

Management Direction (See Map 4 on page 230 of Chapter 3): 

 Manage maritime heritage areas (28 acres) as VRM Class II. 

 Manage all other areas (992 acres) as VRM Class III to allow for extensive vegetation restoration. 

While such projects would not necessarily impair the Monument’s overall scenery, they would 

heighten visual contrast with the characteristic landscape and the BLM assumes that they would need 

to be repeated more than once every 5 years in order to meet the vegetation management objectives. 

Alternative C32 

Management Direction (See Map 5 on page 231 of Chapter 3): 

 Manage lands managed for their wilderness characteristics under this alternative (3 acres) as VRM 

Class I. 

 Manage maritime heritage areas (28 acres) as VRM Class II. 

 Manage all other areas (989 acres) as VRM Class III to allow for extensive vegetation restoration. 

While such projects would not necessarily impair the Monument’s overall scenery, they would 

heighten visual contrast with the characteristic landscape and the BLM assumes that they would need 

to be repeated more than once every 5 years in order to meet the vegetation management objectives. 

Alternative D 

Management Direction (See Map 3 on page 230 of Chapter 3): 

 Manage lands managed for their wilderness characteristics under this alternative (232 acres) as VRM 

Class I. 

 Manage all other areas (789 acres) as VRM Class II. 

Wilderness Characteristics 

Background 

There are no designated wilderness or wilderness study areas within the Monument. The BLM is 

required to inventory Bureau-administered lands to identify those that have wilderness characteristics and 

are not designated as wilderness or wilderness study areas. Through planning processes, the BLM 

determines whether or not to manage such lands for their wilderness characteristics. Other than where 

 

32 VRM designations for alternatives B and C total only 1,020 acres due to a rounding issue (i.e., the acres falling 

into two of the classes round down instead of up while under other alternatives the acres round up). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

37 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 they conflict with the alternatives below, objectives and direction described elsewhere in this chapter 

apply to areas managed for their wilderness characteristics. 

See the Wilderness Characteristics section in Appendix E for information about the wilderness 

characteristics inventory process. 

See Appendix S for a summary table of the differences between the alternatives for wilderness 

characteristics. For a description of current wilderness characteristics within the Monument see the 

section beginning on page 231. 

Lands managed for their wilderness characteristics would be available for Coast Salish tribes’ spiritual or

traditional use or the exercise of treaty rights. 

No Action Alternative 

There would continue to be no plan-level decisions related to wilderness characteristics. Under 

the No Action Alternative, the BLM would continue to take actions as necessary to meet law, regulation, 

and policy to the extent compatible with Proclamation 8947. This would include continuing to meet basic 

stewardship responsibilities through custodial management. The BLM would make decisions about 

taking actions on a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Manage lands with wilderness characteristics for these characteristics except where doing so would 

conflict with management to conserve, protect, or restore Monument objects and values. 

Alternative A 

Management Direction: 

 Manage all approximately 232 acres of land found by the BLM to have wilderness characteristics for 

these characteristics (see Map 6 on page 232 of Chapter 3). 

o Manage these lands as VRM I. 

o Other decisions that apply to the Monument as a whole within this alternative would also protect 

wilderness characteristics, such as minimizing vegetation treatments and not developing signs and 

visitor facilities (such as vault toilets) except as necessary to protect Monument objects and 

values and human health and safety. 

Alternative B 

The BLM would not manage any lands for their wilderness characteristics under Alternative B. Under 

Alternative B, the BLM would allow hard shoreline stabilization to protect cultural resources from 

erosion. This type of stabilization would preclude the protection of wilderness characteristics. 

Alternative C 

Management Direction: 

 Manage all rocks (totaling approximately 3.2 acres) found by the BLM to have wilderness 

characteristics for these characteristics (i.e., areas that are unlikely to be subject to repeated intensive 

vegetation restoration efforts) (See Map 7 on page 234 of Chapter 3). 

o Manage these lands as VRM I. 

o Prohibit signs, except as necessary to protect Monument objects and values and human health and 

safety, and structures (e.g., vault toilets) on lands managed for their wilderness characteristics. 

o Other decisions that apply to the Monument as a whole within this alternative would also protect 

wilderness characteristics, such as making the Monument a rights-of-way avoidance area and 

prohibiting hard shoreline stabilization. 

Alternative D 

Management Direction: 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

38 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1  Manage all approximately 232 acres of land found by the BLM to have wilderness characteristics for 

these characteristics (see Map 6 on page 232 of Chapter 3). 

o Manage these lands as VRM I. 

o Prohibit collection of natural materials for commercial purposes within these lands. 

o Prohibit signs, except as necessary to protect Monument objects and values and human health and 

safety, and structures (e.g., vault toilets) on lands managed for their wilderness characteristics. 

o Prohibit the use of hard shoreline stabilization methods. 

o Other decisions that apply to the Monument as a whole within this alternative would also protect 

wilderness characteristics, such as making the Monument a right of way avoidance area. 

Wildfire Response 

Background 

BLM policy, rather than plan decisions, dictate the majority of the BLM’s wildfire response process. 

Through the planning process, the BLM can determine where naturally ignited wildfires may be managed 

for resource objectives and whether any restrictions on fire management practices are needed, such as the 

use of chemical fire retardants and foam. 

See Appendix S for a summary table of the differences between the alternatives for wildfire response. 

For current conditions related to wildfire see the section beginning on page 236. 

No Action Alternative 

There would continue to be no plan-level decisions related to wildfire response. Under the No Action 

Alternative, the BLM would continue to take actions as necessary to meet law, regulation, and policy to 

the extent compatible with Proclamation 8947. This would include continuing to meet basic stewardship 

responsibilities through custodial management. The BLM would make decisions about taking actions on 

a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 During wildfire response, minimize risks to human health and safety, property, infrastructure 

(including Coast Guard facilities), and Monument resources and values. 

Management Direction: 

 Suppress all human-caused wildfires. 

 Use minimum impact suppression techniques (MIST) in all wildfire responses. MIST guidelines are 

established by the National Interagency Fire Center and are available at: 

www.nifc.gov/PUBLICATIONS/redbook/2003/AppendixU.pdf 

Alternative A 

Management Direction: 

 Allow natural wildfire dynamics within the Monument to the extent that they do not threaten human 

life or safety, private property, infrastructure (including Coast Guard facilities), or historic structures. 

Management Direction: 

 Prohibit suppression of naturally ignited wildfires where they do not threaten human life or safety, 

private property, infrastructure (including Coast Guard facilities), or historic structures. 

 Prohibit use of aerial and ground-based fire chemicals (retardant, foam, or other surfactants). 

Alternatives B, C, and D 

Management Objectives: 

 Minimize wildfire risks to human life or safety, private property, infrastructure (including Coast 

Guard facilities), and historic structures. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

39 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 2 

1 Management Direction: 

 Allow aerial delivery of fire chemicals (retardant, foam, or other surfactants) to protect human health 

and safety, property, and infrastructure (including Coast Guard facilities) on the Watmough BayChadwick Hill-Point Colville parcel only. 

 Allow ground delivery of fire chemicals on all other parcels provided these chemicals could be kept 

out of surface waters (fresh and salt). 

Wildlife and Fish 

Background 

Proclamation 8947 addresses both the diversity of habitats within the Monument and the varied wildlife 

that depend on them. The BLM generally manages the habitat within which wildlife occurs, but does not 

directly manage wildlife. The BLM coordinates closely with State (WDFW) and Federal (U.S. FWS and 

NOAA Fisheries) partners that do manage wildlife. The BLM also closely coordinates with tribal 

governments on actions that would affect wildlife within the Monument. Many tribal governments take 

an active role in the management of wildlife in Washington State. 

See Appendix S for a summary table of the differences between the alternatives for wildlife. For current 

conditions related to wildlife, see the section beginning on page 247. 

No Action Alternative 

There would continue to be no plan-level decisions related to wildlife. Under the No Action Alternative, 

the BLM would continue to take actions as necessary to meet law, regulation, and policy to the extent 

compatible with Proclamation 8947. This would include continuing to meet basic stewardship 

responsibilities through custodial management. The BLM would make decisions about taking actions on 

a case-by-case basis after completing the appropriate level of NEPA analysis. 

Common to All Action Alternatives 

Management Objective: 

 Manage habitats within the Monument such that those habitats contribute to providing for populations 

of native wildlife species within the San Juan Islands. 

 Maintain vulnerable species and habitat components in functional BLM ecosystems. 

 Prevent a need for species listing under the Endangered Species Act. 

Management Direction: 

 See Habitat and Plants beginning on page 16. 

 Work with State and Federal agencies to provide habitat for self-sustaining wildlife populations. 

Alternative A 

Management Direction: 

 No specific direction—follow common to all and do not initiate and/or work with other agencies on 

wildlife augmentation, reintroduction, or control. 

Alternatives B, C, and D 

Management Direction: 

 Work with appropriate agencies to augment or reintroduce populations of locally important wildlife 

species (e.g., federally listed or candidate species, state listed species, etc.). 

 Work with appropriate agencies to control or eradicate species that are adversely affecting Monument 

objects and values. 

o This may include coordinating with the U.S. Department of Agriculture’s Animal and Plant

Health Inspection Service (APHIS) and/or other agencies to control or eradicate wildlife of 

management concern (invasive and/or nonnative wildlife). 

2 

3 

4 

6 

8 

7 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

40 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Chapter 3: Affected Environment and Effects Analysis 

Introduction 

This chapter describes the existing conditions that the Approved RMP would be likely to affect (i.e., the 

affected environment) and the varying consequences of the alternatives. The BLM has combined these 

two topics into this chapter to provide all of the relevant information on a resource in a single discussion. 

This chapter includes sections on each resource that the Approved RMP is likely to affect. Each section 

includes one or more subsections that address a particular question about how the alternatives would 

affect the resource (the BLM refers to these questions as analytical issues). Under each issue, the BLM 

describes the status and trends of the pertinent resource and then answers the question by describing the 

consequences of the alternatives—including the No Action Alternative—to the resource in detail. 

The Council on Environmental Quality’s NEPA regulations direct that “NEPA documents must

concentrate on the issues that are truly significant to the action in question, rather than amassing needless 

detail” (40 CFR 1500.1[b]). Issues are “truly significant to the action in question” if they are necessary to 

make a reasoned choice between alternatives (i.e., the issue relates to how the alternatives respond to the 

purpose and need). Issues are also “truly significant to the action in question” if they relate to significant

direct, indirect, or cumulative impacts of the alternatives. For this analysis, each section identifies the 

issues that are “significant to the action in question” and focuses the analysis on those issues. 

Given the current lack of an RMP, the BLM analyzed the No Action Alternative as the continuation of 

existing management trends. For example, the BLM assumes that it would continue not to use herbicides 

for vegetation management because it does not currently use herbicides within the Monument. While the 

BLM could change this through appropriate planning and NEPA compliance, it analyzed continuation of 

the current approach as the most reasonably foreseeable outcome of the No Action Alternative. 

Analytical issues considered but not analyzed in detail are found in Appendix A. 

Air Quality 

Key Points 

 All alternatives would protect human health and the environment by maintaining air quality according 

to National Ambient Air Quality Standards. 

This section contains one analytical issue: 

1. How would the alternatives affect levels of particulates (PM2.5 and PM10) and ozone in the planning 

area? (Page 41) 

Air Quality Analytical Issue 1: How would the alternatives affect levels of 

particulates (PM2.5 and PM10) and ozone in the planning area? 

See Appendix B for analytical methods used in this analysis. See the Air Quality section in Appendix E 

for background information related to air quality. 

Affected Environment 

Air quality in the Pacific Northwest is relatively good, in part due to the influence of clean air from above 

the Pacific Ocean (Eilers et al. 1994). The San Juan Islands are located in the Puget Sound/Georgia Basin 

airshed, which is influenced by air pollutants from Seattle, Washington, and Vancouver, British Columbia 

(Canada), particularly from the transportation sector (Environment Canada and EPA 2014). Despite the 

region’s growing population, emission reductions have occurred in the region since the mid-1980s 

(Environment Canada and EPA 2005). These reductions are attributed largely to initiatives by regional 

U.S. and Canadian air quality agencies. Population growth may threaten these air quality improvements 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

41 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 in the future (Environment Canada and EPA 2005). As Asia continues to develop, the transport of 

pollution from that region is also a rising concern (Jaffe et al. 2003). 

Large pollution sources that may affect air quality in the San Juan Islands include a large pulp mill in Port 

Townsend and an aluminum smelter and two petroleum refineries near Bellingham. Despite these 

pollution sources, the most recent published comprehensive three-year inventory of air emissions 

indicates that the San Juan Islands rate among the lowest counties in Washington State for the production 

of particulates (PM2.5 and PM10) and pre-cursors to ground-level ozone (NOx and VOC) (WDOE 2011a). 

As reported in the Washington State 2011 County Emissions Inventory (WDOE 2011a), sources of air 

pollutants in San Juan County are few and are predominately from vehicles on public roadways, non-road 

mobile equipment (e.g., agricultural, recreational and construction equipment), aircraft, woodstoves and 

fireplaces, residential outdoor burning, and natural emissions from soil and vegetation. See Table E-1 in 

the Air Quality section of Appendix E for sources and amounts of emissions in San Juan County. 

There are few current activities associated with the Monument that could affect air quality. Motorized 

vehicle use by visitors and staff occurs on 1 mile of BLM-administered road. Staff, volunteers, and 

visitors also use cars and motorboats on non-BLM administered roads and waters to reach Monument 

lands. San Juan County is not a designated non-attainment or maintenance area for particulates or ozone. 

The primary pollutants associated with current and potential BLM management are particulate matter 

(PM2.5 and PM10) and ozone. Ozone is not emitted directly but is created by chemical reactions between 

oxides of nitrogen (NOx) and volatile organic compounds (VOC), which are generated by sources 

including motor vehicle exhaust, gasoline vapors, and chemical solvent (EPA 2015a). 

Emissions from motorized vehicles are the leading source for NOx and the leading anthropogenic source 

of VOC in both Washington State (WDOE 2017) and San Juan County. Wildfires and prescribed fires 

also emit NOx and VOC that react to form ozone within the fire plume. The models typically used to 

estimate NOx and VOC emissions from wildland fires lack the sensitivity for a meaningful 

characterization of changes in surface-level ozone for the small amounts of ozone precursor emissions 

produced by small scale prescribed fires, such as are currently taking place in the San Juan Islands (Baker 

et al 2016; Nolte et al. 2015). The highest levels of ozone occur during summer while the greatest 

activity for prescribed burning is during spring and fall. 

Sources of both coarse (PM2.5) and fine (PM10) particular matter include motor vehicle exhaust, wildland 

fire, and dust from roads and construction (EPA 2015b). The leading sources of PM2.5 in Washington 

State are home heating devices such as woodstoves and fireplaces (WDOE 2011a). In San Juan County, 

home heating devices contribute about 31 percent of the PM2.5 emissions; residential outdoor burning (19 

percent) and paved and unpaved road dust (13 percent) are also major contributors (WDOE 2011a). The 

leading sources of PM10 in San Juan County are road dust and construction dust, which contribute 62 

percent of the county’s total emissions (WDOE 2011a). 

Prescribed burn emission reporting to the Washington Department of Natural Resources (WDNR) for San 

Juan County indicates that private landowners are the largest contributors of particulate emissions. Some 

prescribed burning also occurs on Federal and State lands. Since 1987, the Nature Conservancy has 

periodically used prescribed burning at its Yellow Island preserve to minimize invasive species and 

enhance the long-term viability of native plant communities. The National Park Service implements 

prescribed fires on San Juan Island to meet similar objectives. Prescribed fires on Federal and State lands 

are conducted in accordance to Washington State’s Smoke Management Plan (WDNR 1993). 

Air pollution from wildfire in the region can affect the Monument and the broader San Juan Islands. The 

frequency of fires within the region could increase due to global climate change, changes in plant 

communities, and increases in visitation. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

42 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Effects of the Alternatives 

Effects to air quality would vary little among alternatives. The variation that would occur would be due 

to the differences in the extent of prescribed burning the BLM would undertake under each of the 

alternatives (Table 4, Figure 1). Models that characterize emissions of ozone precursors lack the 

sensitivity to characterize differences from sources as small as the acres the BLM estimates it would burn 

under the alternatives (See Habitat and Plants Issue 3). NOx and VOC emissions from motor vehicle 

activities, campfires, and equipment usage would not vary between alternatives to a detectable degree. 

The BLM assumes that more ozone precursor emissions would be produced in alternatives that implement 

prescribed fire and pile burning but these emissions would likely not be detectable beyond the site and 

would quickly disperse. 

Under all alternatives, the BLM would work with partners to suppress any human caused, unplanned 

ignitions in the Monument and adhere to Washington State Smoke Management Plan to meet the 

requirements of the Washington Clean Air Act (RCW 70.94), Forest Protection laws (RCW 76.04), and 

the United States Clean Air Act (42 USC 7401 et seq.). Under Alternative A, the BLM would only 

suppress naturally ignited wildfires where they threaten human life or safety, private property, 

infrastructure, or historic structures. Under all other action alternatives, the BLM could use naturally 

ignited wildfires to achieve management objectives in parts of the Monument. However, wildland fires of 

natural origin occur very rarely in the San Juan Islands, so the effect of these decisions on air quality 

would likely be minimal under all alternatives. 

No Action Alternative 

Under the No Action Alternative, the BLM assumes it would continue not to conduct prescribed burning 

in the Monument. The BLM would work with partners to suppress any fire occurring in the Monument. 

Alternative A 

Under Alternative A, the BLM would not implement prescribed burning in the Monument and would 

therefore not have any additional emissions or appreciable effects to air quality. 

Alternative B, C and Sub-C 

Alternatives B and C, along with Sub-Alterative C, include ambitious vegetation management objectives. 

The BLM estimates that a suite of treatments (see Habitat and Plants Issue 3), including prescribed fires, 

would be implemented to achieve these objectives. This would result in approximately nine emission 

producing events over 20 years for each alternative (Table 4). Ozone precursor emissions would increase 

compared to the No Action Alternative from prescribed fire activities but would be undetectable beyond 

the site scale. Appreciable differences in ozone emissions between alternatives that implement prescribed 

fire and pile burning would be difficult to measure and are unlikely to be substantial. 

Particulate emissions from prescribed fire can be modeled (Table 4, Figure 1) but are unlikely to be 

detectable at a regional level and would disperse quickly. Prescribed fire activities would occur in the 

spring and fall where weather systems are more likely to quickly disperse emissions and background 

levels of particulates and ozone precursors are lower. Alternative C and Sub-Alternative C would 

produce approximately 60 percent more emissions than Alternative B over nine emission producing 

events over 20 years; these events would include broadcast burning and pile burning. 

Alternative D 

Under Alternative D, the BLM’s objective would be to maintain the current extent and condition of the 

Monument’s plant communities. The implementation of Alternative D would result in the lowest 

emissions of any action alternative that includes prescribe fire or pile burning. Alternative D would 

implement approximately seven emissions producing events that would produce about 17 percent of the 

emissions of Alternative C and Sub-Alternative C and approximately 30 percent of the emissions of 

Alternative B over a 20-year period due to more restricted restoration objectives. While the modeled 

emissions for Alternative D indicate substantial reductions in comparison to alternatives B, C, and Sub-C, 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

43 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 differences in emissions would not likely be measurable beyond the site scale. This is because smoke 

from pile burning typically disperses within between 8 and 24 hours depending on the size of piles and 

the size of piled material. Smoke from prescribed fire activities in grass-dominated areas typically 

disperse within 4 hours but could take longer if weather conditions conducive to long-term burning persist 

or in areas with higher coarse fuel loading. 

Conclusion 

The BLM’s management of the Monument would have the least impacts on air quality under the No 

Action Alternative and Alternative A, due to the continued lack of prescribed fire. Alternative C and 

Sub-Alternative C would have the largest impact on air quality through PM2.5, PM10, and ozone emissions 

followed by Alternative B and Alternative D. As described above, effects on air quality from prescribed 

fire in the Monument would be unlikely to be detected at a regional scale and would disperse quickly. 

Table 4: Estimated composite particulate emissions over 20 years by alternative 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Particulate No Action Alternative Alternative Alternative Sub- Alternative 

Emissions Alternative A B C Alternative D 

(tons) (tons) (tons) (tons) C (tons) (tons) 

PM2.5 from 

Rx Fire 0 0 37 37 37 1 

PM10 from 

Rx Fire 0 0 49 49 49 2 

PM2.5 from 

Pile Burning 0 0 84 168 168 35 

PM10 from 

Pile Burning 0 0 96 192 192 40 

PM2.5 Total 0 0 121 207 207 169 

PM10 Total 0 0 145 241 241 42 

13 Total emissions would be distributed over the approximate number of burning events (entries) by 

alternative over 20 years (Alternative A = 0, Alternative B = 9 entries, Alternative C = 9 entries, 

Alternative Sub-C = 9 entries, Alternative D = 7 entries) 

14 

15 

16

17

18

19

20

21

22

23

24

25

26

27

28

250 

200 

150 

100 

50 

0 

PM 2.5 PM 10 

Tons 

Alternative A Alternative B Alternative C Alternative D 

29 Figure 1: Estimated composite particulate emissions from prescribed fire over 20 years by 

30 alternative 

44 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Cumulative Effects of the Alternatives on Air Quality 

As described in the affected environment section, air quality in the San Juan Islands is relatively good and 

has improved through emissions reductions since the mid-1980s. Prescribed fire is not a primary 

contributor to emissions in the San Juan Islands. The BLM’s management of the Monument would 

continue to contribute negligibly to PM2.5, PM10, and ozone emissions under the No Action Alternative 

and Alternative A. Under alternatives B, C, Sub-C, and D, the BLM’s emissions would increase relative 

to current conditions but would continue to disperse quickly and be unlikely to be detectable at a regional 

scale. When combined with existing emissions in San Juan County and the surrounding area, the 

contribution of emissions from activities in the Monument from any alternative would not be large 

enough to lead to the non-attainment of any National Ambient Air Quality Standard. 

Climate Change 

Key Points 

 Alternatives B, C, and Sub-C would provide the BLM with the greatest ability of the alternatives to 

adapt to potential ecological effects associated with climate change. 

This section contains one analytical issue: 

1. What opportunities would the alternatives provide to respond to the effects of climate change? (Page 

45) 

Background 

The BLM prepared a specialist’s report comparing the extent of carbon stored within the Monument and 

greenhouse gas emissions associated with management under each alternative, as well as the extent to 

which the alternatives would support Washington State’s greenhouse gas emissions and adaptation 

strategies. This report is incorporated here by reference and is available upon request, and its conclusions 

are summarized below. 

The analyses described in the BLM specialist’s report determined that Alternative C and Sub-Alternative 

C would emit the most greenhouse gases from BLM management actions among the alternatives, largely 

due to the frequency of vegetation treatments, including prescribed fire. Alternative A would emit the 

least greenhouse gases of any action alternative. All alternatives would result in a less than 0.25 percent 

increase in statewide emissions originating from other prescribed burning and vegetation management 

actions. These analyses also found that Alternative B would result in the least aboveground carbon 

storage within the Monument of any alternative, although this would be only slightly less than Alternative 

C and Sub-Alternative C. These alternatives would reduce carbon storage in San Juan County by less 

than 1 percent. Because of the small size of the Monument’s potential contribution to both greenhouse 

gas emissions (<0.25 percent increase in statewide emissions from relevant categories) and carbon storage 

(<1 percent reduction in carbon storage in the county) relative to the surrounding area, the BLM has 

determined that these impacts are not likely to be significant. In other words, the intensity of the impacts 

from the alternatives to greenhouse gas emissions and carbon storage, in the context of the planning area 

as well as larger geographic contexts, would be low. Greenhouse gas emissions from BLM management 

actions are expected to increase by the greatest amount under alternatives B and C while carbon storage 

within the Monument would decline. However, alternatives B and C would also provide the BLM with 

the greatest ability of the alternatives to adapt to potential ecological effects associated with climate 

change, and the level of active management allowed under these alternatives would provide the greatest 

support for Washington State’s climate change adaptation strategy. 

Climate Change Analytical Issue 1: What opportunities would the alternatives 

provide to respond to the effects of climate change? 

See Appendix B for analytical methods used in this analysis. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

45 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Affected Environment 

Over time, climate change will likely place Monument objects and values at greater risk of loss or 

damage, particularly shoreline-based resources and plant community species composition and structure. 

Since analyzing potential impacts to all plant species considered a Monument object or value would be 

very difficult, the BLM analyzed potential impacts to camas and Garry oak as representative species of 

interest. Based on the literature, BLM expects that climate change would disfavor camas productivity and 

favor Garry oak extent and productivity. The analysis below evaluates whether and to what degree each 

alternative provides opportunities to maintain or enhance camas and Garry oak populations and 

productivity. 

See the Climate Change section in Appendix E for background on the San Juan County climate. 

Effects of the Alternatives 

The risks posed to Monument objects and values from climate change are largely independent of the 

different alternatives. The alternatives vary in the ability of the BLM to respond to these risks through 

active management and vegetation and cultural resource management. The effects discussed are largely 

cumulative effects of actions the BLM would take over the life of the plan, particularly with respect to 

vegetation since they represent a trajectory for the communities or species arising from the possible 

interaction of management actions with changing climate. 

Common to All Alternatives 

Sea level rise would affect the size of the Monument as smaller and lower rocks and islands fall below 

mean high tide. Non-native plants present in the Monument that are not currently considered invasive 

may become so as climate change makes conditions more favorable (Dukes and Mooney 1999, Hellmann 

et al. 2008, Hoover et al. 2014); however, some existing invasive plants may become less invasive 

(Bradley et al. 2009, Bradley and Wilcove 2009). Given the current state of the science, the BLM cannot 

predict whether and how any plant’s invasive capabilities may change.

Climate change decreases the likelihood that the BLM can achieve its management objectives, regardless 

of which alternative is implemented. Because natural variability remains a part of climate and ecosystem 

responses, changes will not be linear or at a steady rate (IPCC 2013, 2014). 

No Action Alternative 

Under the No Action Alternative, the BLM would continue its current custodial management of the 

Monument, including only undertaking an estimated 20 acres each year of invasive plant control using 

cutting only. Under this alternative, the BLM likely would continue to undertake soft stabilization of the 

shoreline to protect cultural resources; while the BLM has not undertaken hard stabilization as of the date 

of this document, it could occur where high value resources are in imminent risk of loss and soft 

stabilization measures would be ineffective. 

With minimal active management, plant community change would continue in the current direction. 

Disturbances such as windstorms, insect outbreak or wildfire or interactions between one or more 

disturbances and drought would likely result in sudden shifts in plant communities (Allen et al. 2010, 

Clark et al. 2014, Peterson et al. 2014). Mature plants, such as trees, typically tolerate a wider range of 

climate conditions than seedlings, allowing them to persist under conditions that do not permit 

regeneration (Bell et al. 2014). Should a major event result in high mortality of trees, the site potential 

may shift from one general vegetation type to another, such as from woodland to savanna. Species 

composition may change from ones that are less drought tolerant to ones that are more drought tolerant. 

Because detailed information on probable rates of climate and vegetation change does not exist, the BLM 

does not know whether such shifts could or would occur over the expected life of the plan. 

Changing climate would likely favor the continued spread of invasive plants, particularly for species that 

the BLM has not generally treated in the Monument. The success of the limited control measures taken 

might change. Depending on exactly how climate change plays out in specific sites, the combination of 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

46 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 changing temperature and precipitation regimes and increasing atmospheric CO2 concentrations could 

accelerate the spread of some invasive species, such as annual grasses. Nonnative species currently 

present, but not considered invasive, may become invasive over the expected life of the plan. The 

combination of spreading invasive plants in conjunction with climate change would likely disfavor camas 

and Garry oak, even though changing climate alone would be expected to favor Garry oak. Both camas 

and Garry oak may be able to persist on shallow soils, but the productivity of both would be less. Garry 

oak growth form may also change from a tree to brush under certain site conditions. 

Active management under this alternative would continue to be negligible, affording no opportunities to 

apply adaptive measures to reduce the potential impacts of climate change. 

Alternative A 

Under Alternative A, the BLM would minimize active management, while allowing treatments when 

identified thresholds in plant communities are crossed. Assuming climate change has no discernable 

impact, the BLM estimates that only treatment of invasive species would be necessary over the expected 

life of the plan although the allowable methods are limited. The BLM would allow soft shoreline 

stabilization to protect cultural sites, though it would prohibit hard shoreline stabilization. Since active 

management would be minimal, the probable effects of climate change on plant community changes, 

camas, and Garry oak would likely be very similar to the No Action Alternative. However, if climate 

change accelerates plant community shifts, then more active management than estimated in this Draft 

RMP/EIS may be necessary to maintain some plant communities, with the highest probability of change 

likely to be in moist forest. It is also likely that such management could fail to restore moist forest due to 

the changed conditions. 

The BLM estimates that some additional control of invasive plants would occur under Alternative A, but 

the restrictions on methods (i.e., chemical treatments and prescribed fire would be prohibited) in 

combination with changing climate would likely reduce the treatment effectiveness. Whether the spread 

of invasive plants would be less under Alternative A than under the No Action Alternative is not clear, 

but there would likely be little noticeable difference. Soft shoreline stabilization would likely provide 

temporary protection to cultural sites, but the duration and effectiveness of such measures is not known, 

especially given the recent identification of accelerating rates of sea level rise. The BLM would not 

expect soft shoreline stabilization to result in shifting wave energy to adjoining lands. 

Active management under this alternative would be very limited, providing few opportunities to apply 

adaptive management to reduce the risks of undesirable outcome arising from climate change. The 

alternative would allow for management once the extent of a given major plant community type falls 

below specified thresholds, which may or may not occur over the expected life of the plan. The analysis 

assumes that action would be necessary only to reduce invasive plants; however, the BLM lacks the 

necessary data and scientific tools to incorporate climate change into successional models to know 

whether any other major plant community type would fall below identified thresholds. The restrictions on 

management methods further limit the BLM’s ability to take adaptive actions.

Alternative B 

Under Alternative B, the BLM would actively manage vegetation to maintain or enhance the ecological 

resistance to change and resilience from disturbance. The BLM would allow the use of all vegetation 

management methods to meet the alternative’s objectives; it would also allow both hard and soft shoreline 

stabilization. Managing to increase resistance and resilience would result in opening forests, reducing the 

extent of drought intolerant tree and shrub species, increasing the extent of savannas and grasslands, and 

reducing the extent of invasive plants. Sudden changes in plant community extents and species 

composition resulting from disturbance would be less likely. Alternative B would specifically encourage 

the use of assisted migration using seeds and other propagules that provide ecotypes currently not present 

that are likely better adapted to the expected future climate. The extent and overall productivity of camas 

and Garry oak likely would increase. This alternative would allow the BLM to adapt to the loss of 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

47 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 effectiveness of some invasive plant control measures, thereby increasing the likelihood of effective 

control. Hard shoreline stabilization would better protect cultural sites from the effects of sea level rise. 

However, hard shoreline stabilization could also result in narrowing or loss of beaches and associated 

habitat, loss of driftwood and the associated nutrients, steepening of the nearshore environment, and 

increased erosion further downshore from the redirected wave energy (Coyle and Dethier 2010 and 

references therein). 

The level of active management under this alternative would provide opportunities for the BLM to 

include climate change adaptive measures in project planning. While tree planting is not anticipated as a 

regular action following forest and woodland thinning, planting of ecoytpes or genotypes better adapted 

to the expected changes in climate, such as Douglas-fir from a warmer, drier seed zone, could occur to 

meet this alternative’s stated objectives. If climate change occurs more rapidly than currently anticipated, 

Alternative B may allow the introduction of species native to Washington but not presently found on the 

San Juan Islands, such as ponderosa pine, that are better adapted to warmer, drier conditions. 

Alternative C 

Under Alternative C, the BLM would actively manage vegetation to approximate the pre-Euro-American 

extents and conditions of plant communities within the Monument boundaries. The BLM would allow 

the use of all vegetation management methods to meet the alternative’s objectives. Soft shoreline 

stabilization would be allowed, but hard shoreline stabilization would not. Approximating the pre-EuroAmerican extent and condition of plant communities would likely result in similar plant community types 

and structures as under Alternative B, although there may be differences in species compositions because 

Alternative B would allow for use of non-invasive, non-native plant materials where appropriate to 

enhance ecological resistance and resilience. As with Alternative B, the extent and productivity of camas 

and Garry oak would increase. The use of soft shoreline stabilization alone would produce the same 

results as under Alternative A. 

The level of active management under Alternative C provides similar opportunities for taking climate 

change adaptive actions as under Alternative B. A primary difference between the two is that under 

Alternative C, the BLM does not anticipate potentially introducing species native to Washington but not 

currently found on the San Juan Islands. However, the BLM could potentially bring in ecotypes or 

genotypes of species currently present but that are better adapted to warmer, drier conditions. For 

example, the BLM could plant Garry oak seedlings from northwest Oregon if those seedlings were 

expected to be better adapted to future climate conditions than the ecotypes presently found on the San 

Juan Islands. 

Sub-Alternative C 

Sub-Alternative C is the same as Alternative C except that the use of chemical treatments would not be 

allowed. Under this sub-alternative, the BLM would be less likely to effectively control invasive plants 

and less able to adapt as climate change renders some methods less effective and new invasive plants 

emerge or appear. Whether the extent and productivity of camas and Garry oak would increase is less 

certain given the likelihood of increased competition from invasive plants. 

Alternative D 

Under Alternative D, the BLM would manage plant communities to maintain approximately the current 

extent and condition. The BLM would allow the use of all vegetation management methods to meet the 

alternative’s objectives. Soft shoreline stabilization to protect cultural and paleontological sites would be 

allowed throughout the Monument and hard shoreline stabilization would be allowed in areas without 

wilderness characteristics. 

Because this alternative would require the BLM to maintain the present conditions of plant communities 

within the Monument, climate change would make achieving the vegetation management objectives of 

this alternative increasingly difficult over time. Maintaining current conditions means also maintaining 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 current vulnerabilities (see the Wildfire section, for examples). These vulnerabilities increase the 

probability of sudden shifts in plant community extents and conditions, similar to the No Action 

Alternative and Alternative A. Camas and Garry oak would likely see little improvement in extent and 

condition except possibly as a result of invasive plant control. Hard shoreline stabilization would better 

protect cultural and paleontological sites on the large islands, but the effectiveness of soft stabilization on 

areas with wilderness characteristics (including the east side of Patos Island) would be limited, assuming 

cultural or paleontological sites needing protection are present on vulnerable shorelines. Hard shoreline 

stabilization would have the same potential impacts as described under Alternative B. 

Since the BLM would attempt to maintain current conditions under Alternative D, opportunities for active 

management would be limited over the expected life of the plan, affording fewer opportunities to apply 

climate change adaptive actions. This alternative would potentially provide more opportunities than 

Alternative A, but likely far fewer opportunities than alternatives B and C. 

Conclusions 

The level of active management allowed under alternatives B and C would provide the greatest 

opportunities to apply climate change adaptive measures. Under the No Action Alternative, the BLM 

assumes that under its current custodial management approach it would continue not to apply climate 

change adaptive measures. 

Cultural Resources 

Key Points 

 Cultural resources are nonrenewable resources. Once altered, damaged, or destroyed, the values that 

contribute to their cultural and historical significance are forever altered or lost. 

 The Monument contains objects and values of traditional cultural and historical importance to the 

Coast Salish tribes who continue to utilize and value the lands and resources in the region. 

 Under all alternatives, the BLM would identify whether cultural resources are present before 

authorizing ground disturbing projects. Where cultural resources are identified, the BLM would 

modify the project to avoid or reduce impacts. 

 Alternatives B and C would have the greatest potential for disturbance to cultural resources from 

vegetation treatments. 

 The No Action Alternative and alternatives B and D would have the greatest potential for disturbance 

to cultural resources from recreation. 

This section contains two analytical issues: 

1. How would the alternative approaches to shoreline stabilization, vegetation management, and 

recreation management affect archaeological and other cultural resources within the Monument? 

(Page 50) 

2. How would the alternatives affect historic properties within the maritime heritage areas? (Page 61) 

Background 

Proclamation 8947 identifies historic and cultural values as among the objects for which the Monument 

was established. It specifically references sites that are evidence of the area’s current and ancestral

importance to the Coast Salish tribes, including shell middens, reef net locations, and burial sites. It also 

addresses buildings and features associated with the Monument’s rich maritime history, such as the Patos 

Island Lighthouse and the Turn Point Light Station. 

For further background information on cultural resources in the San Juan Islands see Appendix E. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

49 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Cultural Resources Analytical Issue 1: How would the alternative approaches 

to shoreline stabilization, vegetation management, and recreation management 

affect archaeological and other cultural resources within the Monument? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

The age of cultural resources documented in the San Juan Islands extends back more than 10,000 years. 

The BLM has inventoried about a third of the Monument for cultural resources and has documented 25 

cultural sites33 . Additional inventory is likely to identify additional cultural properties associated with 

Native American/Indigenous habitation and use and with Euro-American settlement and development. 

Specific site locations, particularly those associated with archaeological, spiritual, or ceremonial values, 

are often sensitive. The BLM does not disclose these sites in publically available documents, such as this 

Draft RMP/EIS, to protect their values from potential looting, vandalism, or intrusion. 

Few sites in the San Juan Islands have been formally evaluated for listing on the National Register of 

Historic Places. Archaeological and other cultural or historical sites that have the potential to yield 

important information about the past, that have an association with historically important people or 

events, or that are considered a work of a master are considered eligible for listing in the National 

Register of Historic Places in most instances and are avoided during surface disturbing activities. 

The documented archaeological sites in the Monument are predominantly associated with Coast Salish 

occupation and resource procurement, including a rock shelter, campsites, shell middens, and rock 

features. Burials, defensive sites, and modified trees also have been documented in the Monument. 

Archaeological sites are nonrenewable resources affected by numerous natural and cultural processes. 

The following factors affect site condition within the Monument: shoreline erosion, recreational activities, 

animal burrowing, trees encroaching on pre-European settlement managed grasslands, and natural 

weathering and decay. The degree to which sites are affected depends on factors including the nature of 

the site, setting, and the process or activity affecting the site. 

Since prior to BLM administration, cultural sites (including archeological sites) on the lands now within 

the Monument have been adversely impacted by shoreline erosion, natural deterioration, and wildfire, as 

well as by construction and maintenance of aids to navigation facilities, roads, trails, and residential, 

agricultural, and recreational development. Some sites have been affected by visitor use, vandalism, and 

looting. The BLM has sought to minimize impacts to archaeological and cultural sites from construction 

and maintenance of roads and facilities. 

Within the Monument, 96 percent of the documented cultural sites occur within 164 feet34 of the 

shoreline. In consultation with its tribal partners, the Washington SHPO, and other community partners, 

the BLM has reduced risks of resource damage from shoreline erosion and recreational impacts in certain 

vulnerable areas. This has included shoreline stabilization using geotextile fabrics and natural materials 

such as boulders and ballasted logs to reduce erosion and allow natural vegetation to re-establish and 

stabilize eroded site margins. As of the publication of this document, the BLM has only applied soft 

stabilization measures. The BLM and its partners have also recovered important cultural data and 

materials where they could not effectively implement stabilization measures. 

Most Monument shorelines are relatively unaltered pocket beaches, feeder bluffs, and rocky headlands. 

While less altered than shorelines outside of the Monument, lower impact developments have taken place 

on lands now included within the Monument. Developments constructed before BLM administration 

include lighthouses and associated aids to navigation and facilities, recreation sites, and roads and trails 

 

33 Historic properties associated with the Monument’s lighthouses are addressed under Issue 2. 34 Generally, 164 feet is the minimum distance the BLM uses for buffers to avoid potential impacts to cultural 

resource sites. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

50 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 used to access them. Proliferation of user created trails has continued under the BLM’s administration of

the Monument. In addition, filling and development occurred historically in and near the wetland at 

Watmough Bay and agricultural development occurred near Chadwick Hill and at Iceberg Point. 

The BLM conducts proactive cultural resource inventories to identify resources at risk from looting, 

vandalism, or natural processes prior to substantial impact or loss. In addition, the BLM conducts cultural

resources inventories in compliance with Section 106 of the National Historic Preservation Act. When 

undertaking management actions, the BLM seeks to avoid impacts to cultural resources and implement

measures to protect or mitigate effects. Regulatory compliance activities and proactive cultural resources 

management actions in general ensure site conditions in the Monument are stable. 

Effects of the Alternatives 

Under all alternatives, the BLM would address potential impacts to cultural resources at the design or 

implementation phase of future projects through National Historic Preservation Act Section 106 review. 

Section 106 compliance includes identification, evaluation, and mitigation of effects to properties eligible 

for listing on the National Register of Historic Places. The BLM would work with partners, including the 

SHPO and THPOs as necessary, to avoid, minimize, or mitigate potential adverse effects to National 

Register eligible properties. It would undertake temporary closures as necessary to protect the 

Monument’s ecological and cultural values, as well as sensitive tribal activities. 

Impacts from Shoreline Stabilization 

Shoreline stabilization measures would reduce or limit shoreline erosion from large storm events. Storms 

and associated tidal surges can modify spatial relationships of artifacts and alter or destroy physical 

evidence of occupation in those areas. This can cause the loss of information about site function, dates of 

occupation, subsistence, and past environments, each of which is important to understanding past cultures 

and lifeways. In addition, shoreline erosion can damage or destroy cultural and historical values of 

importance to tribes and local communities. Measures to stabilize shorelines could preserve the integrity 

of cultural deposits and prevent further damage to cultural and historical values from natural processes. 

Given that 96 percent of the Monument’s documented cultural sites occur within 164 feet of the shoreline,

the BLM, in consultation with its tribal partners, Washington SHPO, and other community partners, may

need to undertake shoreline stabilization to protect cultural resources within the life of the plan. It is not 

possible to predict the number or location or these projects. Soft stabilization would be allowed under all 

alternatives; the alternatives vary as described below in allowing hard shoreline stabilization. 

Soft stabilization measures generally allow natural processes, such as movement of water, fauna, flora, 

and mineral materials along the beach margins, to continue while reducing the magnitude and severity of 

erosion and sediment removal. Although soft stabilization measures are generally less intrusive to the 

cultural setting and natural processes, they may be less effective than hard shoreline stabilization for 

controlling impacts from high energy events or at locations with steep, unstable slopes or high bank 

erosion (Gianou 2014, NYSDEC 2010). 

The BLM and its partners may determine that all stabilization measures would be ineffective in certain 

locations, such as along some steep, unstable slopes. Because of this, high energy storm surges and other 

events would continue to damage, alter, and destroy cultural resources under all alternatives. 

Both hard and soft stabilization measures can directly and indirectly affect cultural properties. 

Construction of stabilization measures can disturb portions of cultural sites and cause changes in erosion 

and aggradation patterns outside of the stabilized portion of the site. These effects must be balanced 

against the threat to cultural and historical resources from erosion. 

Short-term impacts would occur where stabilization measures temporarily block or impede access to or 

use of a cultural property or where they temporarily affect the historic setting. Stabilization measures that 

disturb a portion of an archaeological site or cultural property or introduce structures incompatible with 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 the historic setting would have long-term or permanent impacts to the site and/or historic setting. The 

51 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 BLM, potentially working with one or more partners, would conduct mitigation to address adverse 

impacts to important cultural and scientific values from stabilization measures. It would also conduct 

mitigation when stabilization measures are determined to be ineffective or impractical. 

Hard stabilization can be more intrusive than soft stabilization, resulting in more marked long-term or 

permanent impacts to the historic setting and natural processes, such as increased sediment delivery, 

reduced sediment retention, reflected wave energy, and modified sand circulation/deposition (WDOE 

2014). Impacts to nearshore habitats are described in Habitat and Plants Issue 2 beginning on page 98. 

No Action Alternative 

Under the No Action Alternative, the BLM could continue to use shoreline stabilization to protect cultura

resources. As a result, it would occasionally undertake soft stabilization measures. Hard shoreline 

stabilization could occur where high value resources are in imminent risk of loss and soft stabilization 

measures would be ineffective. This analysis assumes that the BLM would be less likely to undertake 

hard stabilization than under alternatives B and D due to its current custodial management approach. 

Alternative A and Alternative C 

Under alternatives A and C, the BLM would continue to allow soft shoreline stabilization to protect 

cultural resources. The BLM would prohibit hard shoreline stabilization. Some additional cultural 

resources would be lost compared to alternatives that allow hard shoreline stabilization due to high energ

storm events or in locations that have steep, unstable slopes or that have high bank erosion. 

More cultural resources could be damaged or lost under these alternatives than under the No Action 

Alternative and alternatives B and D where hard stabilization would be allowed. The potential impacts to

cultural resources and natural shoreline processes from implementation of hard shoreline stabilization 

would be less than under these alternatives. 

Alternative B 

Under Alternative B, the BLM would allow hard shoreline stabilization, in addition to soft stabilization, 

to reduce the potential for damage, alteration, or loss of cultural resources from high energy storm surges 

and events. Hard shoreline stabilization would be allowed where the BLM, in consultation with partner 

agencies, determined that soft stabilization measures would be ineffective. Allowing both hard and soft 

stabilization measures would provide a wider range of options for protecting and stabilizing threatened 

cultural sites. Because the BLM would allow all stabilization tools throughout the Monument, it is likely 

that the BLM would protect and stabilize more sites under Alternative B than under any other alternative. 

The BLM expects that impacts to sites and other cultural properties from construction and implementatio

of hard shoreline stabilization would be greater under Alternative B than under alternatives where it 

would prohibit hard shoreline stabilization. 

Alternative D 

Under Alternative D, the BLM would continue to allow soft shoreline stabilization to reduce impacts and 

loss of cultural resources due to increased erosion and impacts from storm surges and human activities. It

would also allow shoreline stabilization in the majority of the Monument when soft stabilization measure

are determined to be ineffective. The BLM would prohibit hard shoreline stabilization in areas with 

wilderness characteristics (232 acres). Allowing both hard and soft stabilization measures would provide 

a wider range of options for protecting and stabilizing threatened cultural sites. The BLM would likely 

protect and stabilize more sites and other cultural properties under Alternative D than under alternatives 

A, C, or Sub-C but less than under Alternative B or the No Action Alternative. 

In areas with wilderness characteristics would damage, alter, or destroy some cultural resources that coul

have been protected through hard stabilization. The BLM expects that impacts to sites and other cultural 

properties from construction and implementation of hard shoreline stabilization would be greater under 

Alternative D than under alternatives where it would not allow hard shoreline stabilization. 

2 

3 

4 

6 

7 

8 

9 l 

11 

12 

13 

14 

16 

17 y 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 n 

32 

33 

34 

36 

37 s 

38 

39 

41 

42 

43 d 

44 

46 

52 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Impacts from Recreation 

Under all alternatives, where the BLM identified conflicts between human uses and cultural resources, it 

would develop implementation-level cultural resource or recreational management plans and take 

measures to reduce potential impacts to cultural sites and properties. These measures must be consistent 

with the Approved RMP. If the BLM identified necessary measures that were not consistent with the 

Approved RMP, it would consider undertaking a plan amendment (e.g., if a permanent and complete 

closure of an area to camping was identified as essential to protecting cultural resources and the RMP 

identifies the area as open to camping). 

Recreational use and access can affect cultural resources through direct disturbance, soil compaction, 

altered surface water drainage, erosion, intrusions to the setting, and access leading to unauthorized 

collection or vandalism. These effects can result in a loss of site integrity, scientific information, and 

associated cultural values. Despite previous archaeological surveys and investigations, there is the 

potential for undiscovered, buried cultural resources and human remains. Surface-disturbing activities 

would directly affect any undiscovered cultural resources and human remains by exposing buried 

material. This would result in inadvertent artifact destruction or scientific context loss, including 

potential illicit collecting of newly exposed materials. 

Management actions that interfere with the exercise of traditional cultural uses and practices or the 

exercise of treaty rights can affect cultural resource values. The historic value and significance of a 

traditional cultural property can be assessed by its associations with the cultural practices, traditions, 

beliefs, lifeways, arts, crafts, or social institutions of a living community. Management actions that 

introduce activities, structures, or features that are incompatible with the setting for traditional practices or 

remove or obscure natural features or resources can affect the values that define or contribute to the 

importance of a traditional cultural property. Some traditional cultural practices may also be associated 

with ceremonies that require privacy and solitude; activities that conflict with privacy and solitude would 

negatively affect these practices. Recreational restrictions would not affect access to the Monument for 

tribal members for the exercise of treaty rights and traditional cultural practices. 

The potential for impacts on cultural resources would increase as recreational use increases or is 

concentrated. Repeated use or visits over time could also increase the intensity of impacts due to natural 

processes, such as erosion. Even where land managers require visitors to remain on trails, repeated visits 

to locations can create new social trails, often leading visitors to or across cultural sites. Prohibiting 

access or restricting visitor use to designated roads and trails would reduce the risk of impact to cultural 

resources from these activities, if access for cultural purposes can be maintained and cultural site 

protections are implemented and maintained. 

Camping could permanently affect cultural resources through direct disturbance of site structure, artifact 

breakage and displacement, vandalism, soil compaction, altered surface water drainage, erosion, creation 

of new routes, and visual and aural intrusions to the setting. Regulating or restricting camping and 

recreational access can reduce the potential for impacts to cultural sites by controlling the amount and 

location of activities in areas with sensitive resources. Restricting camping to designated sites would 

concentrate impacts to those locations and reduce the risk of disturbing cultural resources outside of sites 

though impacts from camping would still occur. Prohibiting camping or restricting it to designated 

campsites would reduce the risk of impact to cultural resources from camping, if access for cultural 

purposes can be maintained and cultural site protections are implemented and maintained. In the analyses 

below, a large cultural site may be located in more than one type of camping designation. 

No Action Alternative 

Under the No Action Alternative, 14.9 miles of existing trails in the Monument would continue to be 

open to non-motorized travel. If current trends continue, visitors would use these trails almost 

exclusively for hiking, with a small amount of equestrian use on Lopez Island. Overland hiking would 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

53 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 continue to be allowed under this alternative. As a result, trail miles in the Monument’s more accessible 

grasslands and shrublands, such as at Iceberg Point and Cattle Point, would likely increase over time. 

Use of the trails would continue to have direct negative short-term and long-term impacts on sites and 

other cultural properties crossed or accessed by trails, through soil compaction, erosion via channeling of 

water, and widening of trails during wet periods. Currently, 76 percent (19 sites) of the Monument’s 

recorded cultural sites are within 164 feet of roads and trails. Under this alternative, measures to reduce 

impacts to sites would continue but the potential for impacts from use and maintenance would grow if 

visitation continues to increase over the next 20 years. 

The BLM would continue to allow dispersed camping in the Monument except where prohibited by the 

current ACEC decisions (Chadwick Hill, Iceberg Point, Point Colville, and Watmough Bay). Areas that 

would continue to be open to this use include 66 acres of grassland potentially associated with traditional 

plant gathering. Twenty-two recorded cultural sites occur within areas open to camping. If current 

recreation patterns continue, participation in this activity would remain relatively low. Camping in 

existing designated sites would continue. Approximately half of the recorded cultural sites within the 

Monument occur in or near designated camping areas. 

Alternative A 

Under Alternative A, the BLM would facilitate use of the Monument for authorized research, and 

educational, cultural, and spiritual activities. The BLM would not designate any of the potential 

recreation management areas (RMAs) under Alternative A and would prohibit recreation on Monument 

lands. This alternative would minimize impacts to cultural sites and values from human use to a greater 

extent than any other alternative. Traditional uses of cultural properties would continue. 

Assuming current visitation trends continue, the closure of the Monument to recreational use would 

increase visitation to non-Monument public lands in the area. Depending on the density of cultural sites 

at the alternative recreation locations, this could increase impacts to non-Monument cultural sites. 

The impacts from recreation described under the No Action Alternative would not continue under this 

alternative, though impacts from access for administrative and authorized uses would continue. Because 

there would be many fewer visitors on the Monument, and the BLM would authorize uses, the BLM 

expects fewer and less severe impacts to cultural resources under this alternative. The BLM would 

continue to maintain roads for authorized and administrative uses. This would include maintaining a road 

that crosses the cultural site associated with the Turn Point Light Station. Impacts to this cultural site 

from maintenance and authorized and administrative use of this road would continue. 

Alternative B 

Under Alternative B, the BLM would designate all potential RMAs except Category A and B Rocks. All 

but 10 acres of the Monument would remain open to recreational use. The impacts from recreation 

described under the No Action Alternative would not continue in those sites closed to recreation use, 

though minor impacts from access for administrative and authorized uses would continue. To provide 

opportunities for solitude and quiet, 168 acres of the Monument would be open for recreation by permit 

only, which would reduce impacts by controlling the amount of recreation allowed in those areas. All 25 

recorded cultural sites would be within designated RMAs in this alternative. 

The BLM would designate 19.3 miles of trail in the Monument for hiking in this alternative; this would 

be a 27 percent increase compared to existing trail miles. This would include 5.2 miles of new trails in 

areas previously without trails, increasing the potential for short-term and long-term direct and indirect 

impacts to cultural sites. Although the BLM has not yet inventoried potential new trail routes for cultural 

resources, there would be approximately an 18 percent increase in the number of previously recorded sites 

that would be near to or crossed by trails under this alternative. The BLM would conduct cultural 

resource inventories prior to constructing new trails and reduce adverse impacts by routing trails away 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

54 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 from cultural sites. Limiting access to designated trails except for authorized uses would reduce impacts 

to cultural sites outside of the designated trail routes. 

Under Alternative B, there would continue to be designated site camping in existing sites. RMAs with 

designated sites would include 13 cultural sites, approximately half of the recorded sites in the 

Monument. Areas where the BLM would allow dispersed camping by permit only include 9 sites. 

Limiting camping to small groups by permit in specified areas would reduce potential impacts to cultural 

sites. When developing the permitting system during plan implementation, the BLM would consult with 

affected tribes and conduct cultural resource surveys of the areas proposed for dispersed camping. It 

could develop the permit system to exclude specific cultural sites and values. 

Areas where camping would be prohibited include 6 sites, which would reduce the potential impact of 

camping compared to the No Action Alternative. 

Alternative C 

Under Alternative C, the BLM would designate all potential RMAs except for Category B Rocks. All but 

7 acres of the Monument would remain open to recreational use. Category B Rocks reportedly receive 

minimal visitation so this closure would likely have minimal effect on cultural resources. The BLM 

would also manage 3 acres of the Monument (Category A Rocks) as open for recreation by permit only, 

which would reduce impacts by controlling the amount of recreation allowed in those areas. As in 

Alternative B, all 25 sites would be within designated RMAs. 

The BLM would designate 11.3 miles of trail in the Monument for hiking; 3.5 of these miles would also 

be open to equestrian use. The BLM would close 3.6 miles of existing trail. The number of recorded 

cultural sites crossed by trails (19) would be similar to the No Action Alternative. Trail access would 

decrease by 25 percent compared to the current route network. Limiting hiking to designated trails except 

for the authorized purposes would reduce the potential for impacts to cultural sites. 

The BLM would only allow camping in existing designated sites under this alternative; there would be 13 

cultural sites in RMAs open to designated site camping. The BLM would prohibit dispersed camping 

throughout the Monument. Approximately half of the recorded sites in the Monument are located in areas 

where camping would be prohibited in this alternative. This alternative would reduce the potential for 

impacts from recreation to cultural sites more than the other analyzed alternatives except Alternative A. 

Alternative D 

Under Alternative D, the BLM would designate all potential RMAs. As under alternatives B and C, all 

25 known cultural sites would be within an RMA. 

The BLM would designate 23.4 miles of trail in the Monument for hiking; approximately 8 of these miles 

would be open to equestrian and bicycling use. Overall, trail access in the Monument would increase by 

54 percent. The BLM would close 0.5 miles of trail existing trail and would develop 8.8 miles of new 

trails; 0.2 miles of existing trail would be widened. Similar to Alternative B, roads and trails in 

Alternative D would cross or be located near 23 recorded cultural sites in the Monument. The BLM 

expects that development of approximately 8.8 miles of new trails would result in at least an 18 percent 

increase in the number of recorded sites crossed by or located near trails. Identifying and surveying for 

cultural resources prior to implementation and rerouting trails to avoid impacts to cultural sites would 

reduce potential impacts to cultural resources in those locations. The acreage of recorded cultural sites 

crossed by roads and trails would be highest in this alternative; it would be slightly higher (3 percent) 

than Alternative B and approximately 30 percent higher than the No Action Alternative. 

As under all alternatives except for A, the BLM would continue to allow camping in designated sites at 

Blind, Patos, and Posey islands. Through implementation-level planning and analysis, the BLM could 

develop additional campsites and visitor facilities in these locations. The BLM would also designate an 

additional 221 acres of Monument land as open to designated site camping. Specific locations for new 

designated sites and new visitor facilities would be identified during plan implementation. Identifying 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

55 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 and surveying for cultural resources prior to implementation and selecting sites to avoid impacts to 

ultural sites would reduce potential impacts to cultural resources in those locations. RMAs open to 

esignated camping would include 20 documented cultural sites. Designated site camping would 

otentially have both short-term and long-term and direct and indirect impacts on approximately 80 

ercent of all recorded cultural sites in the Monument. 

he BLM would continue to allow dispersed camping on 167 acres of Monument land currently open to 

his use and on 370 acres of land currently closed to this use at Chadwick Hill and Point Colville. 

pening areas currently closed to dispersed camping would increase the potential for long-term and direct 

mpacts to cultural resources in these areas. Under Alternative D, RMAs open to dispersed camping 

ould include six recorded cultural sites. The BLM would close the remainder of the Monument (49 

cres) to camping, reducing the potential for adverse impacts to cultural sites. Two recorded sites occur 

n areas where the BLM would prohibit camping. 

mpacts from Vegetative Treatments 

nder all alternatives, the BLM would implement some vegetation treatments to protect human health 

nd safety (i.e., hazard tree removal) and to control invasive plant species designated by Washington State 

or mandatory eradication or control. Where vegetation projects require seeding or planting, the BLM 

ould include culturally important plants, such as camas, where possible. 

egetation management can include mechanical, biological, chemical, and prescribed fire treatments. 

he treatment measures the BLM would allow during plan implementation vary by alternative. While the 

LM would undertake cultural inventory prior to authorizing surface disturbing projects, vegetation 

reatments such as hand pulling, digging, surface scarring, tilling, or tree removal could directly impact 

ndiscovered cultural resources and human remains. Chemical treatments (e.g., herbicide) could alter the 

hemistry of soils and artifact residues and affect the reliability of dating cultural materials if directly or 

ndirectly exposed to the chemical (BLM 1991; BLM 2007). Prescribed fire could affect flammable 

ultural materials and artifacts and cause staining and spalling of lithic artifacts or features such as 

ictographs and distort site or artifact dating analyses. 

ery short-term impacts (i.e., those lasting for the duration of the project) of treatments include temporary 

ffects to the historic setting of a cultural property (e.g., through the presence of machinery); short-term 

mpacts would include alteration of the setting beyond the duration of the project (e.g., recovery of 

egetation). Long-term or permanent impacts would occur when cultural sites and/or artifacts and 

eatures are substantially damaged or destroyed. 

egetation treatments would also affect access to cultural properties. Access would be temporarily 

imited during mobilization, operational, and demobilizing periods for mechanical and fire treatments and 

uring chemical herbicidal applications. Some chemical herbicidal applications may have short-term to 

ong-term impacts to traditional plant gathering activities. 

f the BLM does not implement vegetative treatments, noxious weeds and invasive plants would continue 

o increase and encroachment of grasslands and shrublands would continue, having a long-term impact on 

he historic setting and the availability of plants for traditional uses. Removal of hazard trees or other 

egetation creating fuel ladders may benefit cultural properties threatened by falling trees or fuel loading. 

o Action Alternative 

nder the No Action Alternative, the BLM would continue custodial management; the BLM assumes it 

ould continue very limited vegetation treatments (approximately 20 acres per year). This alternative 

ould have the least potential for disturbance from vegetation treatments to impact cultural resources. 

ver time, continued encroachment by woody shrubs, invasive species, and forest species would diminish 

eadow and grassland areas of traditional cultural importance for plant gathering, other traditional 

ctivities, and the exercise of tribal treaty rights. It is possible that a wildland fire or other disturbance 

ould occur over the next 20 years and slow this trend. However, wildland fires are unusual in the San 

2 c

3 d

4 p

p

6 T

7 t

8 O

9 i

w

11 a

12 i

13 I

14 U

a

16 f

17 w

18 V

19 T

B

21 t

22 u

23 c

24 i

c

26 p

27 V

28 e

29 i

v

31 f

32 V

33 l

34 d

l

36 I

37 t

38 t

39 v

N

41 U

42 w

43 w

44 O

m

46 a

47 w

56 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Juan Islands and, under the No Action Alternative, the BLM would suppress any that occurred. The 

BLM would assess and treat potential hazard trees around administrative facilities or historic structures to 

reduce potential impacts from tree fall on those properties. 

The BLM’s limited approach to managing vegetation under this alternative would continue to create very

few (i.e., affecting at most 20 acres per year) access disruptions during mobilization, operational, and 

demobilizing periods for mechanical treatments. Most treatments the BLM currently undertakes (e.g., 

hand cutting of invasive plants) result in very limited disruption of access. 

Alternative A 

Under Alternative A, the BLM’s management of vegetation would continue to be largely passive; the 

BLM would not allow prescribed burning or chemical (i.e., herbicide and pesticide) treatments under this 

alternative. Given that natural succession and other processes would be allowed to continue to the 50 

percent threshold identified for vegetation treatments prior to treatment (see page 17), the potential for 

direct impacts to cultural resources from vegetation treatments would be limited (i.e., affecting 

approximately 50 acres per year), though greater than under the No Action Alternative. 

Encroachment by native forest species into the grasslands and shrublands would continue and the 

condition of these communities would likely decline over time as a result of limited invasive plant 

treatments undertaken in the absence of herbicides. This would result in a decline in the size and 

condition of grasslands and meadows important for traditional plant gathering and other activities (see 

Table 7 on page 75). 

The BLM’s limited approach to managing vegetation under this alternative would create very few (i.e., 

affecting approximately 50 acres per year) access disruptions during mobilization, operational, and 

demobilizing periods for mechanical treatments. 

Alternative B 

Under Alternative B, the BLM would manage the Monument to enhance the San Juan Islands’ ecological

resistance and resilience by increasing the extent of native plant communities—specifically grasslands 

and wetlands—that are relatively scarce within the San Juan Islands as a whole. To achieve this 

objective, the BLM would conduct extensive grasslands and shrubland restoration within the Monument 

(see Table 18 on page 112). As under alternatives C and D, the BLM would consider all tools in 

designing implementation-level vegetation treatments. 

The magnitude and intensity of the vegetation control and restoration measures under Alternative B 

would increase the potential for short-term and long-term impacts to cultural resources from disturbance, 

chemical treatments, and fire. Treatments have the potential to inadvertently disturb or destroy artifacts 

and cultural features and their scientific context within archaeological sites located within the treatment 

area. Based on the estimated acres of treatment the BLM would undertake under this alternative (see 

Habitat and Plants Issue 3), the potential for long-term or permanent impacts from damage or destruction 

of archaeological and cultural sites, artifacts, or features are greater under this alternative than under the 

No Action Alternative and alternatives A and D. 

Vegetation treatments implemented to enhance native species richness and structural component diversity 

would have a positive long-term effect on diversity and cover of functional/structural group species, 

though some short-term negative impacts would occur. Over the long-term, treatments to enhance 

grasslands and shrublands would expand opportunities for traditional cultural uses. 

Vegetation treatments under Alternative B would cause more very short-term (i.e., for the duration of the 

project) to long-term disruption of access to or use of important traditional plant gathering areas including 

traditional cultural properties than under the No Action Alternative and alternatives A and D. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

57 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative C 

Under Alternative C, the BLM would manage the Monument to approximate the extent and condition of 

plant communities that existed prior to European settlement of the San Juan Islands (approximately 

1860), when Coast Salish people used fire to manage landscapes. To achieve this objective, the BLM 

would undertake extensive grasslands and shrubland restoration (see Table 19 on page 114). The BLM 

estimates that meeting the objectives of this alternative would require the most acres of vegetation 

treatment over the life of the plan of any alternative other than Sub-Alternative C. As under alternatives 

B and D, the BLM would consider all tools in designing implementation-level vegetation treatments. 

The estimated mechanical treatments under this alternative would increase the potential for very shortterm (i.e., duration of the project) to long-term effects on cultural resources. Greater acres of treatment 

would be required to remove non-native plants, woody shrubs, and trees to an extent that would 

approximate historic conditions. Short-term and long-term negative impacts related to ground 

disturbance, prescribed fire, and chemical use would be similar to but greater than those described under 

Alternative B. 

Vegetation treatments implemented to approximate historic conditions would have a major positive longterm effect on diversity and cover of functional/structural group species though some short-term negative 

impacts. Over time, this would benefit properties associated with traditional plant gathering. Treatments 

would include intensive restoration efforts to remove non-native plants and restore native plants, 

including culturally important species, which would benefit traditional cultural properties or landscapes 

important for plant gathering and related activities. 

Vegetation treatments under Alternative C would cause more very short-term (i.e., for the duration of the 

project) to short-term disruption of access to or use of traditional plant gathering areas or traditional 

cultural properties and landscapes than under the No Action Alternative and alternatives A, B, and D. 

Sub-Alternative C 

Effects to cultural resources from vegetation treatments would be similar to, but greater in magnitude 

than, those under Alternative C. Without the use of herbicides, the BLM estimates that it would need to 

increase the repetition of mechanical treatments to meet the habitat and plant community objectives (see 

Table 20 on page 115). Short-term and long-term negative impacts related to ground disturbance would 

be similar to but greater than those described under Alternative C. 

Vegetation treatments under Sub-Alternative C would cause more very short-term (i.e., for the duration of 

the project) to short-term disruption of access to or use of traditional cultural properties or landscapes 

associated with traditional plant gathering than any other alternative. 

Alternative D 

Under Alternative D, the BLM would maintain the approximate extent and condition of plant 

communities that it has documented in the Monument as of 2016. The BLM estimates that this would 

require more acres of vegetation treatment than would occur under the No Action Alternative and 

Alternative A, and substantially fewer acres than would be required to meet objectives and management 

direction under alternatives B, C, and Sub-C. As under alternatives C and B, the BLM would consider all 

tools in designing implementation-level vegetation treatments. The potential for direct impacts to cultural 

resources from vegetation treatments would be limited (i.e., affecting an estimated 66 acres per year), 

though greater than under the No Action Alternative and Alternative A. 

Vegetation treatments would target the edges of grasslands and shrublands to prevent conversion to forest 

and woodlands; they would also target new or expanding invasive plant populations. Through active 

management, the extent of grassland and shrubland plant communities would remain at their approximate 

2016 extent instead of decreasing over the life of the plan as they would under the No Action Alternative 

and Alternative A. The condition of areas of traditional cultural importance for plant gathering would 

remain relatively unchanged. While vegetation treatment would limit encroachment of forest vegetation 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

58 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 into grasslands and shrublands, the condition of cultural properties important for traditional plant 

gathering would not be improved or expanded as under alternatives B and C. 

The BLM’s maintenance of the existing extent and condition of plant communities would create few (i.e., 

an estimated 66 acres per year) access disruptions during mobilization, operational, and demobilizing 

periods for mechanical treatments. 

Conclusion for Cultural Resources Issue 1 

The alternatives would vary in their effects on cultural sites within the Monument.35 Specifically, they 

would vary in terms of the stabilization tools available to the BLM, the potential for short-term and longterm effects from disturbance related to recreation activities and vegetation management, and the extent to 

which they would improve conditions for traditional cultural plant gathering. 

Stabilization of cultural sites threatened by erosion and storm surges would be most effective under 

Alternative B and the No Action Alternative, where the full range of shoreline stabilization measures 

would be available to protect any cultural site in the Monument. Under alternatives A and C, and under 

Alternative D in areas with wilderness characteristics (232 acres), the BLM would not allow hard 

shoreline stabilization. Because soft stabilization measures are less effective than hardening in certain 

situations, the BLM assumes that some additional cultural resources would be damaged, altered, or lost 

under alternatives that do not allow hard shoreline stabilization in some or all of the Monument. 

Under all alternatives, the BLM would identify cultural resources through consultation and cultural 

resource inventory prior to authorizing implementation-level projects that can impact archaeological and 

cultural properties, such as designated campsite development, trail building, tree removal, digging, tilling 

or pulling to remove invasive plants. Where cultural resources are identified, the BLM would modify the 

project to avoid or reduce impacts. Despite these precautions, recreational activities and vegetation 

management create the potential for disturbance and loss of cultural resources. Where important cultural 

and archaeological resources could not be avoided, the BLM, through consultation, would develop 

mitigation to address adverse impacts to affected cultural resources. 

Under Alternative A, the BLM would prohibit recreational use of the Monument and undertake a very 

limited approach to vegetation management. This alternative would have the lowest potential of any 

alternative for disturbance to cultural resources from the recreational activities and vegetation 

management. However, grasslands and shrublands associated with potential traditional cultural properties 

or landscapes would continue to shrink. 

Under the No Action Alternative and Alternative D, potential impacts from camping, off-trail hiking, and 

extensive trail use would occur, but there would be limited potential for disturbance of cultural sites due 

to vegetation management. As a result, the No Action Alternative and Alternative D would both have an 

intermediate potential for disturbance to cultural sites. This intermediate potential would be greater under 

Alternative D than the No Action Alternative due to increases in camping and trail miles. Alternative C 

and Sub-Alternative C would have the greatest potential of any alternative for disturbance to cultural sites 

from vegetation treatments, but more limited potential for disturbance from trail use and camping. 

Because of this mix of high potential for disturbance from vegetation treatments and a moderate potential 

for disturbance from recreational activities, these alternatives would have a higher potential for 

disturbance compared to the No Action Alternative and alternatives A and D. 

Under Alternative B, the BLM would undertake more extensive vegetation treatments than would occur 

under the No Action Alternative and alternatives A and D, though they would be less extensive than 

under Alternative C and Sub-Alternative C. Under this alternative, more than half of the Monument 

would be open to dispersed camping by permit and trail miles would increase. Because of the relatively 

high potential for disturbance from both recreation and vegetation management, the BLM believes this 

 

35 Impacts to maritime heritage resources are covered under Cultural Resources Issue 2. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

59 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 alternative would have a high potential for disturbance to cultural resources. However, having both hard 

and soft shoreline stabilization measures available would reduce potential impacts to cultural sites. 

Vegetation treatments implemented to enhance ecological resilience and resistance and to approximate 

historic conditions would have a major positive long-term effect on diversity and cover of 

functional/structural group species. While these treatments would increase the potential for disturbance 

of cultural sites, over time they would benefit traditional cultural properties and landscapes associated 

with traditional plant gathering. Under the No Action Alternative and Alternative A, grasslands and 

shrublands with the potential for traditional plant gathering would continue to gradually shrink due to 

encroachment by forest species. Under Alternative D, the condition and extent of areas with the potential 

for traditional plant gathering would remain relatively unchanged. 

Cumulative Effects of Alternatives on Archaeological and other Cultural 

Resources in the San Juan Islands 

The Monument’s contribution to the cultural and archaeological site record is relatively small: only about 

6 percent of the recorded sites in the San Juan Islands are located in the Monument. However, the 

scientific and cultural value of the sites within the Monument are of high value, as recognized in the 

designating proclamation (see Appendix N). Sites in the San Juan Islands range from pre-European 

resource procurement areas and defensive sites to aids to navigation facilities of the late nineteenth and 

twentieth centuries. While it lacks historic military installations such as American Camp and English 

Camp and ethnographic village sites, sites within the Monument are largely representative of the range of 

cultural sites identified within the San Juan Islands in general. 

Both within and outside of the Monument, natural erosion and human development have affected 

numerous cultural sites in the San Juan Islands. San Juan County—which makes up the great majority of 

the San Juan Islands—has the lowest shoreline modification level in the Puget Sound region, with around 

5 percent of its shorelines modified (Herrera 2011, Friends of the San Juans 2011). Even with limited 

shoreline modification, development (e.g., marinas, homes, and roads) and some degree of shoreline 

simplification (i.e., a loss of ecosystem complexity) have altered the nearshore environment of all the 

major islands. The most common changes are the reduced presence or loss of bays (Simenstad et al. 

2011), although their number and extent appear to have been limited historically. The BLM assumes that 

these developments have caused the disturbance or loss of an unknown number of cultural sites. 

The condition and extent of plant communities would affect traditional cultural properties and landscapes 

associated with plant gathering and use. Grasslands in the Puget Lowland Ecoregion, which includes the 

San Juan Islands, have declined to an estimated 9 percent of pre-Euro-American settlement levels 

(Chappell et al. 2000). The Monument currently encompasses approximately 1 percent of the Southern 

Vancouverian Lowland Grassland and Shrubland occurring within the San Juan Islands; the great 

majority of lands in the San Juan Islands are in private ownership and are not necessarily available for the 

gathering of culturally important plants. Cumulative effects to grasslands, which have the potential for 

collection of culturally important plants, are discussed under Habitat and Plants Issue 2. 

Reasonably foreseeable actions that would affect cultural sites along coastlines within the San Juan 

Islands over the next 20 years include the rerouting of the road to Agate Beach on Lopez Island36 and the 

construction of docks and other small-scale coastline developments within the San Juan Islands. Because 

development and erosion along shorelines is likely to continue, cultural sites in the San Juan Islands will 

continue to be threatened, damaged, or lost. As a result, the overall number of sites in the San Juan 

Islands (documented and undocumented) will decline over time. While the total number of sites is likely 

to decline, the number of documented sites in the cultural and archaeological site record are likely to 

increase through inventories, unintentional discoveries, and new or ongoing cultural uses. 

 

36 A plan to reroute the road has not been developed, but the current road is experiencing a level of erosion that will 

require some action within the next several years. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

60 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The alternatives would differ in how they affect the Monument’s contribution to the total cultural sites 

(including archaeological sites) in the San Juan Islands. As described in the conclusion, they would differ 

both because of the tools available to protect cultural and archaeological resources and because of the 

magnitude of the potential for these resources to be disturbed or lost due to recreation activities and 

vegetation management. Under all alternatives, there would be some potential for disruption or loss of 

cultural sites due to shoreline erosion and storm surge, visitor use, and vegetation management. 

Based on the analysis above, the Monument’s contribution to cultural sites in the San Juan Islands would 

be most likely to decline under Sub-Alternative C, followed by alternatives C, B, D, and the No Action 

Alternative. Alternative A would have the lowest likelihood of any alternative that the Monument’s 

contribution to cultural sites in the San Juan Islands would decline over the life of the plan. 

Cultural Resources Analytical Issue 2: How would the alternatives affect 

historic properties within the maritime heritage areas (MHA)? 

See Appendix B for analytical methods used in this analysis. Archaeological resources associated with or 

located within MHAs are included in the analysis under Cultural Resources Issue 1. 

Affected Environment 

This document is using the term maritime heritage area to refer to the aids to navigation (i.e., lighthouse) 

facilities and surrounding lands at Turn Point, Patos Island, and Cattle Point (see Map 2). These total 

approximately 28 acres of Monument land. For Cattle Point, the MHA applies only to the BLMadministered land surrounding the lighthouse. The structure itself and approximately 2 acres of land 

immediately surrounding it are under Coast Guard jurisdiction. 

The Monument includes two historic aids to navigation facilities: Patos Island Light Station (Patos Island) 

and Turn Point Light Station (Stuart Island). Both light stations were established in the 1890s and 

operated by light keepers until automated by the Coast Guard in the 1970s. Turn Point Light Station 

includes the historic light and fog signal structures and associated facilities such as keeper’s quarters, 

barn, out buildings, cisterns, roads, trails, walkways, foundations, and associated archaeological remains. 

The facility is eligible for listing on the National Register of Historic Places. Patos Island Light Station 

includes the lighthouse and associated facilities including walkways, trails, access road, foundations, and 

associated archaeological remains located on the lands surrounding the facility. The Patos Island 

Lighthouse is listed on the National Register of Historic Places. 

The Cattle Point Lighthouse, constructed on San Juan Island in 1935, is currently automated and under

the jurisdiction of the Coast Guard. The lighthouse is eligible for the National Register of Historic Places. 

An historic cistern associated with the lighthouse property is located on adjacent Monument land within 

the Cattle Point MHA. Active erosion is occurring near the Cattle Point Lighthouse and along the nearby

shorelines at Cattle Point. The Coast Guard recently completed a stabilization project at the Cattle Point

Lighthouse to counter the effects of eroding sand dunes surrounding the facility. 

In collaboration with its partner organizations—including the Turn Point Lighthouse Preservation Society

and the Keepers of the Patos Light—the BLM has maintained the Patos Island Lighthouse and the Turn 

Point Light Station and its associated structures to preserve and protect them in their historic setting while

providing opportunities for public education and interpretation. Although some structures were removed 

during the operational life of the facilities, the BLM has maintained the historic nature of the properties. 

Many of the historic plantings remain at Turn Point Light Station and Patos Island Lighthouse, including

fruit trees, shrubs, flowering perennials, and lawn. The BLM and its partners have completed the 

restoration and rehabilitation of Patos Island Lighthouse; this work is ongoing for Turn Point Light

Station and its associated structures. Recent restoration and rehabilitation work approximates the mid20th century appearance of the structures. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

61 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Map 2: Maritime heritage areas 

1 Effects of the Alternatives 

Under all alternatives, the BLM would address potential impacts to cultural resources at the design or 

implementation phase of future projects through National Historic Preservation Act Section 106 review. 

Section 106 compliance includes identification, evaluation, and mitigation of effects to properties eligible 

for listing on the National Register of Historic Places. The BLM would work with partners, including the 

SHPO and THPOs as necessary, to avoid, minimize, or mitigate potential adverse effects to National 

Register eligible properties. It would undertake temporary closures as necessary to protect the 

Monument’s ecological and cultural values, as well as sensitive tribal activities where necessary. 

Impacts from Shoreline Stabilization 

Shoreline stabilization measures would reduce or limit erosion from large storm events along shorelines 

with documented maritime heritage resources. Because they are associated with aids to navigation, all 

three MHAs in the Monument are located within 164 feet of shorelines. 

Storm events and related erosion can potentially threaten the MHAs and their adjacent shorelines. This 

could eventually lead to the loss of the integrity of the historic buildings, structures, associated features, 

and settings that contribute to the eligibility of the maritime heritage properties to the National Register of 

Historic Places. Information could be lost that would inform the understanding of lifeways of the light 

station keepers and their families on remote and isolated islands. Examples of the historic architectural 

and engineering design and construction techniques associated with aids to navigation could also be 

impacted or lost. If shoreline erosion threatens these resources, measures to stabilize shorelines could 

preserve the integrity of cultural deposits and historic buildings and facilities and prevent further damage 

to cultural and historical values from natural processes. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

62 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Given the close proximity of the MHAs to the shoreline, the BLM, in consultation with SHPO, THPOs, 

and other interested partners, may need to undertake shoreline stabilization to protect associated cultural 

properties within the life of the plan. It is not possible to identify the number or location of the shoreline 

treatments that may be necessary during the life of the plan, though the Coast Guard recently conducted 

stabilization efforts at the Cattle Point Lighthouse, which the Monument surrounds. 

The effects to historic values in MHAs from shoreline stabilization are the same as those described for 

cultural resources in general starting on page 51 of Cultural Resources Issue 1 (see the conclusion to this 

issue for a summary of effects to MHAs). The exception is that, since none of the MHAs are located in 

areas with wilderness characteristics, both hard and soft shoreline stabilization measures would be 

available to protect all pertinent resources under Alternative D. 

Impacts from Recreation 

Objectives for recreation include protecting the Monument’s objects and values from damage, alteration,

or loss due to visitation. Under all action alternatives, the BLM would prohibit campfires near structures 

and sensitive resources, recreational use of metal detectors, and placement of physical geocaches for the 

protection of cultural resources including MHAs. The types of effects that recreation would have on 

cultural resources associated with MHAs would be similar to those described for cultural resources in 

general on page 53. 

No Action Alternative 

Under the No Action Alternative, the existing 1.23 miles of trail in MHAs would continue. Overland 

hiking would continue to be allowed and trail miles in more accessible grasslands and shrublands, 

including in the Cattle Point MHA, would likely increase over time. There would also continue to be 

0.18 miles of road open to public motorized use in the Turn Point MHA; there would continue to be no 

roads in the other MHAs. 

Use of the roads and trails would continue to have direct negative short-term to long-term impacts on 

MHAs and associated sites, through soil compaction, erosion via channeling of water, and widening of 

trails during wet periods. Under this alternative, measures to reduce impacts to MHAs and associated 

sites would continue but the potential for impacts from use and maintenance would grow if visitation 

continues to increase over the next 20 years. 

Under the No Action Alternative, all MHAs would continue to be open to dispersed camping. If current 

recreation patterns continue, participation in this activity would remain relatively low. There would also 

continue to be camping in existing designated sites on Patos Island. While these designated sites are 

outside of the MHA, visitors participating in this activity are likely to access the MHA. 

Alternative A 

Under Alternative A, the BLM would facilitate use of the Monument for authorized research, and 

educational, cultural, and spiritual activities. The BLM would prohibit recreation on Monument lands. 

This alternative would minimize impacts to MHAs from human use to a greater extent than any other 

alternative. Traditional uses of cultural properties would continue. 

The impacts from recreation described under the No Action Alternative would not continue under this 

alternative, though minor impacts from access for administrative and authorized uses would continue. 

The BLM would continue to maintain the existing 0.18 miles of road in the Turn Point MHA for 

authorized and administrative uses causing continued compaction, erosion, and disturbance due to 

maintenance and use. In all MHAs, the BLM would maintain trails as necessary for administrative and 

authorized uses and would allow motorized use for administrative purposes as necessary, including for 

the Coast Guard to access aids to navigation. 

Assuming current visitation trends continue, the closure of the Monument to recreational use would 

increase visitation to historical and maritime heritage properties on non-Monument public lands in the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

63 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 area. Specifically, this could increase visitation and impacts to Lime Kiln Lighthouse and to the San Juan 

Island National Historical Park, both of which are in relatively close proximity to the Cattle Point MHA. 

Alternative B 

Under Alternative B, all MHAs would be in RMAs and would continue to be open to recreational use. 

The BLM would designate the existing 1.23 miles of trail in MHAs exclusively for hiking. Hiking would 

be limited to designated trails or un-vegetated shoreline except for authorized purposes, which would 

reduce potential impacts to MHA sites outside of the designated trail routes. 

There would continue to be 0.18 miles of road open to public motorized use in the Turn Point MHA. Use 

of roads and trails in MHAs would continue to have direct negative short-term and long-term impacts on 

MHAs and associated sites, through soil compaction, erosion via channeling of water, and widening of 

trails during wet periods. 

While the BLM would not designate any new trails in MHAs, there would be new trail development on 

nearby lands at Patos Island. The designation of 0.74 miles of new trail on Patos Island could attract 

additional visitors to the area; these additional visitors would be likely to access the MHA. 

Camping at existing designated sites would continue under this alternative. This would include camping 

in existing designated sites on Patos Island. While these designated sites are outside of the MHA, visitors 

participating in this activity are likely to access the MHA. The Turn Point MHA would be part of a larger 

RMA that would be open to dispersed camping by groups of five or more individuals by permit only. 

Limiting camping to small groups by permit in specified areas would reduce potential impacts to MHAs 

and associated sites. The Cattle Point MHA and Patos Island MHA would no longer be open to dispersed 

camping under this alternative. 

Alternative C 

Under Alternative C, all MHAs would be in RMAs and would continue to be open to recreational use. 

The BLM would designate 0.96 miles of existing trail in MHAs exclusively for hiking. Hiking would be 

limited to designated trails or un-vegetated shoreline except for authorized purposes, which would reduce 

potential impacts to MHA sites outside of the designated trail routes. The BLM would close 0.27 miles 

of trail in MHAs. 

There would continue to be public motorized use of 0.09 miles of road in the Turn Point MHA. The 

remaining 0.09 miles of road in the Turn Point MHA would be designated exclusively for authorized and 

administrative use (public motorized use of this road segment is currently very infrequent). Use of the 

roads and trails in MHAs would continue to have direct negative short-term and long-term impacts on 

MHAs and associated sites, through soil compaction, erosion via channeling of water, and widening of 

trails during wet periods. 

Under Alternative C, the BLM would prohibit camping within MHAs, which would reduce the potential 

for impacts. Camping at existing designated sites on Patos Island would continue. While these 

designated sites are outside of the MHA, visitors participating in this activity are likely to access the 

MHA. With the exception of Alternative A, the BLM expects that this alternative would reduce impacts 

from recreation to MHAs and associated sites more than the other analyzed alternatives. 

Alternative D 

Under Alternative D, all MHAs would be in RMAs and would continue to be open to recreational use. 

The BLM would designate the existing 1.23 miles of trail in MHAs exclusively for hiking. As under 

Alternative C, there would continue to be public motorized use of 0.09 miles of road in the Turn Point 

MHA, with an additional 0.09 miles of road designated exclusively for authorized and administrative use. 

Use of roads and trails in MHAs would continue to have direct negative short-term and long-term impacts 

on MHAs and associated sites, through soil compaction, erosion via channeling of water, and widening of 

trails during wet periods. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

64 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 While the BLM would not designate any new trails in MHAs, there would be new trail development on 

nearby lands at Patos Island. The designation of 1.82 miles of new trail on Patos Island could attract 

additional visitors to the area; these additional visitors would be likely to access the MHA. 

Under Alternative D, all three MHAs would be in RMAs open to designated site camping. The BLM 

would identify specific locations for new designated sites and visitor facilities during plan 

implementation. Identifying and surveying for cultural resources prior to implementation and selecting 

sites to avoid impacts to cultural sites would reduce potential impacts to cultural resources in those 

locations. Even if the BLM did not designate new sites for camping in MHAs, the designation of new 

sites in the adjacent Monument land would likely draw new visitors to the areas; these additional visitors 

would be likely to access the MHAs. MHAs would not be open for dispersed camping. 

Impacts from Maritime Heritage Area Management 

Objectives for MHAs vary by alternative, but managing these areas to prevent damage, alteration, or loss 

of cultural properties is common to all alternatives. Within the MHAs, the extent to which the BLM 

would allow alteration of the historic property varies across alternatives. 

Very short-term (e.g., for the duration of the project) to short-term impacts to cultural properties would 

occur where access to or use of an MHA or associated sites would be temporarily blocked or impeded 

during projects to stabilize, maintain, or rehabilitate historic buildings or associated structures and 

features. In some cases, the effects may be long-term or permanent. Activities that disturb, alter, or 

destroy a portion of the property or introduce structures incompatible with the historic setting could have 

long-term or permanent impacts to the property and/or its historic setting. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue custodial management of the Monument. The 

BLM would continue managing the cultural properties associated with maritime heritage to prevent 

damage, deterioration, or loss of important cultural or historical values associated with the properties. 

The affected environment section describes recent actions taken by the BLM and its partners in the 

MHAs. Because there are no plan decisions regarding maintenance, repair, rehabilitation, or use of the 

structures (e.g., administrative, recreational, interpretative), some of these actions could continue to occur 

but extensive rehabilitation or restoration, and construction and replacement of structures, would be 

unlikely under the continuation of the BLM’s custodial management approach. 

Alternative A 

Under Alternative A, the BLM would authorize projects in MHAs only as needed to prevent loss or 

deterioration of cultural resources, except to replace an historic structure currently present on the property 

in the event of its destruction (e.g., due to an earthquake or fire). Treatments would be limited to 

maintaining the condition and integrity of the cultural properties associated. Under this alternative, 

potential impacts to MHAs would be largely short-term resulting from routine basic maintenance of 

structures to prevent deterioration or loss. Long-term or permanent impacts could result should structural 

improvements or reinforcements for seismic protection measures or other improvements be necessary, 

which the BLM would not allow under this alternative. 

Alternative B 

Under Alternative B, the BLM would manage the MHAs to prevent deterioration or loss of cultural 

resources, protect the integrity of the setting, and restore structures to their historic appearance. The BLM 

would allow maintenance, restoration, and/or rehabilitation of existing historic structures. It would not 

authorize construction or reconstruction of structures except to replace an historic structure currently 

present on the property after its destruction (e.g., due to an earthquake). Projects to increase the structural 

stability of buildings and other structures to reduce impacts from disturbances, including sea level rise, 

increased storm surge, and seismic activity would be allowed. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

65 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under this alternative, both short-term and long-term impacts would result from maintenance, hazard 

abatement for human health and safety, and restoration or rehabilitation of historic buildings and 

structures to an appropriate time period (e.g., the period of historic significance or the period of the last 

substantial renovation). Short-term impacts would include limitations on access and use of properties 

during projects; limitations on access and use would vary in duration and intensity depending on the 

nature of the treatments. Long-term beneficial impacts could occur from the restoration, rehabilitation, or 

reconstruction of historic properties within the MHAs if the treatments and reconstruction are consistent 

with the Secretary of the Interior’s Standards for Treatment of Historic Properties. The BLM would not

allow reconstruction of structures that were once present historically. 

Under this alternative, short-term negative impacts would be greater than under Alternative A and the No 

Action Alternative. Long-term impacts that would benefit the MHAs would also be greater than under 

Alternative A and the No Action Alternative. 

Alternative C 

Activities allowed at MHAs under this alternative would be similar to Alternative B except that the BLM 

would allow the reconstruction of currently absent—but historically present—structures under Alternative 

C. It would design and approve individual reconstruction projects on a case-by-case basis, in consultation 

with its tribal partners, the SHPO, Coast Guard, and other community partners. The BLM would prohibit 

restoration, rehabilitation, or reconstruction projects that would have an adverse effect on the appearance 

or setting of an historic property. 

Actions to restore buildings, structures, or portions of historic properties to an appropriate time period 

could have both short-term and long-term impacts. As in Alternative B, access and use of the properties 

would be limited during projects. Long-term beneficial impacts would occur from the restoration, 

rehabilitation, or reconstruction of historic properties within the MHAs if the treatments were consistent 

with the Secretary of the Interior’s Standards for Treatment of Historic Properties. 

With the exception of Alternative D, impact from MHA management under Alternative C would be 

greater than under the other alternatives. The BLM would prohibit adverse impacts to the historic setting 

and appearance of the historic property, reducing the potential for negative long-term impacts under 

Alternative C. MHA management under Sub-Alternative C would be the same as under Alternative C. 

Alternative D 

Under Alternative D, the BLM would manage the MHAs to prevent deterioration or loss of cultural 

resources, maintain the setting’s historic appearance, and provide for greater use of these areas by visitors 

and docents. The BLM would allow maintenance, restoration, and/or rehabilitation of existing structures 

as well as the reconstruction of structures that were present historically. Adapting and/or modifying some 

structures would be allowed to facilitate greater use by visitors, including overnight use of some facilities 

by docents. The BLM would allow construction of new structures to facilitate recreation, education, 

interpretation, and facilities support. The BLM would design and approved individual reconstruction and 

new construction projects on a case-by-case basis through implementation-level planning, in consultation 

with its tribal partners, the SHPO, Coast Guard, and other community partners. 

Under this Alternative, short-term and long-term impacts would be greater than under the other 

alternatives. As in Alternative B and Alternative C, access and use of the properties would be limited 

during project. The potential for numerous improvements, adaptations for reuse, construction, and visitor 

use under this alternative would be greater than any other alternative. 

Long-term beneficial impacts to MHAs could result from the restoration, rehabilitation, or reconstruction 

of historic properties if these efforts are consistent with the Secretary of the Interior’s Standards for

Treatment of Historic Properties. Adaptive reuse could negatively affect the historic integrity and 

appearance of the buildings and structures as well as the historic setting unless the treatments adhere to 

these standards. Construction of new structures would have both long-term and short-term benefits and 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

66 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 long-term impacts to the historic appearance, setting, and use of the historic properties associated with the 

MHAs. Alternative D would have the greatest short-term and long-term impacts of any alternative. 

Impacts from Vegetative Treatments 

Under all alternatives, vegetation treatments within MHAs would prevent damage to cultural properties 

and allow needed maintenance of structures. The alternatives otherwise vary as described below. A 

discussion of the types of impacts vegetation management would have on cultural resources can be found 

on page 56. 

If the BLM does not implement vegetative treatments, several impacts to MHAs could occur. Noxious 

weeds and invasive plants would continue to increase and encroach on the landscape both within and 

outside of the MHAs and would have a long-term impact on the historic setting. The character of the 

vegetation in the MHAs could change, affecting the historic setting (e.g., forest species or woody shrubs 

could overrun grassland in the MHAs). Trees and woody shrubs could pose a variety of threats to historic 

structures, including from falling limbs and increased fire risk. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue custodial management of the Monument; the 

BLM assumes it would continue very limited vegetation treatments in the MHAs. Over time, continued 

encroachment by weeds, invasive species, or forest species may diminish the historical landscape and 

historic setting. The BLM would continue to assess and treat potential hazard trees around historic 

structures to reduce potential impacts from tree fall on those properties. This alternative would have the 

least potential for vegetation treatments to impact cultural resources. The condition and integrity of the 

historic setting would continue to be impacted by limited vegetation treatments under this alternative. 

Alternative A 

Under Alternative A, management of vegetation would continue to be largely passive. The BLM would 

authorize vegetation treatments only as needed to prevent damage to cultural properties and to allow 

needed maintenance of structures. It would not allow the use of chemical treatments (e.g., herbicides) to 

achieve cultural resource objectives. Given that natural processes would be allowed to continue and 

treatments would only occur as needed to prevent damage to the cultural properties associated with the 

MHAs, the potential for direct impacts to cultural resources from vegetation treatments would be limited. 

Encroachment by native forest species into the MHAs would continue and the condition of the historic 

vegetation associated with the MHAs would likely decline over time as a result of invasive plant 

treatment being undertaken in the absence of herbicides. As under the No Action Alternative, the 

integrity and condition of the vegetation in the historic setting would continue to decline. 

Alternative B 

Under Alternative B, the BLM would manage vegetation to minimize risk to cultural resources from fire 

and other disturbance. This may include undertaking projects to remove fuels and potential hazard trees 

around historic structures even where this is not in keeping with the historic appearance of the property. 

Under this alternative, the BLM would consider a full range of vegetation treatment tools in designing 

implementation-level treatments. Some chemical herbicidal applications may have short-term or longterm impacts to traditional plant gathering activities that may occur within the MHAs. 

The magnitude and intensity of vegetation treatments would increase the potential for short-term and 

long-term or permanent impacts to cultural resources from disturbance, chemical treatments, and fire. 

Treatments to minimize risk to MHAs from wildfire or other disturbances would have the potential to 

inadvertently disturb or destroy artifacts, cultural features, historic plants and vegetation, and damage 

historic structures contained within the treatment area. Very short-term (i.e., duration of the project) 

effects from vegetation treatments that temporarily block or impede access to or use of the cultural 

property or that would temporarily affect the historic setting would be most likely under this alternative. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

67 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Historic buildings and structures in the MHAs would be better protected from wildfire and other 

disturbances in this alternative compared to the other alternatives. However, the potential for long-term 

or permanent impacts from damage or destruction of historic and cultural structures and features, and 

historic setting from vegetation treatments are also greater under this alternative than under the No Action 

Alternative and Alternative A, Alternative C, and Alternative D. Identification and survey prior to 

implementation and designing treatments to minimize or avoid adverse impacts to MHAs and associated 

sites would reduce potential impacts from vegetation treatments. 

Alternative C and Alternative D 

Under Alternative C and Alternative D, the BLM would manage vegetation in MHAs to protect the 

integrity of the historic setting. This may include maintaining and cultivating historically appropriate 

trees, shrubs and ornamental and edible plants and controlling encroaching forest species and non-native 

plants not in keeping with the historic setting. 

As in Alternative B, the BLM would consider a full range of vegetation treatment tools in designing 

implementation-level treatments. Some chemical herbicidal applications may have short- or long-term 

impacts to traditional plant gathering activities that may occur within the MHAs. Prescribed fire would 

be unlikely to occur within MHAs due to potential risks to the historic properties from fire. 

The magnitude and intensity of the vegetation control and restoration measures would increase the 

potential for short-term and long-term impacts to MHAs and associated properties from disturbance, 

chemical treatments, and fire. Treatments to maintain the integrity of the setting resulting in ground 

disturbance would have the potential to inadvertently disturb or destroy artifacts, cultural and historic 

structures and features, historic plantings, and vegetation within the treatment area. Implementation-level 

vegetation treatments to renovate, restore, or maintain healthy historic plantings would generally have 

short-term (weeks to months) and long-term (year to the life of the plan) effects beneficial to maintaining 

the integrity of the landscape setting. Very short-term (e.g., duration of the project) to short-term impacts 

from vegetation treatments that temporarily block or impede access to or use of the cultural property or 

that would affect the historic setting would be more likely under Alternative C and D than under the No 

Action Alternative and Alternative A, but less likely than under Alternative B. 

The BLM would manage hazard trees to protect human health and safety and the condition and integrity 

of the historic buildings and structures. The integrity of the plantings and vegetation in MHAs and 

associated cultural properties would be better protected under Alternative C and Alternative D but the 

condition of the historic buildings and structures would be better protected from fire and other 

disturbances under Alternative B. The potential for long-term or permanent impacts from damage or 

destruction of artifacts, cultural features, and vegetation within the historic setting would also be less 

under Alternative C and Alternative D than under Alternative B and greater than under the No Action 

Alternative and Alternative A. 

Sub-Alternative C 

Under Sub-Alternative C, the BLM would manage vegetation in MHAs to protect the integrity of the 

historic setting but would prohibit the use of chemical treatments (e.g., herbicides). Effects to cultural 

resources from vegetation treatments would be similar to those under Alternative C but greater in 

magnitude. Without the use of herbicides, the BLM would likely need to increase the number of 

mechanical treatments to maintain the integrity of the historic setting. Short-term and long-term (years to 

life of the plan) negative impacts related to ground disturbance, and prescribed fire would be similar to 

but somewhat greater than those described under Alternative C. Without the use of pesticides, some 

plantings of historic vegetation may not thrive or recover from disease or infestations. 

Conclusion for Cultural Resources Issue 2 

The alternatives would vary in their effects on MHAs and associated cultural properties within the 

Monument. Specifically, they would vary in terms of the stabilization tools available to the BLM, the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

68 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 potential for short-term and long-term effects from disturbance related to recreational activities and 

vegetation management, and the extent to which the BLM would allow the restoration, rehabilitation, and 

rebuilding of structures in the MHAs. 

Stabilization of MHAs threatened by erosion and storm surges would likely be most effective under 

Alternative B, Alternative D, and the No Action Alternative, where the full range of shoreline 

stabilization measures would be available for MHAs. However, there would be greater impacts to the 

historic settings of any MHAs in which the BLM applied hard stabilization measures. Soft shoreline 

stabilization measures would be available to protect MHAs under all of the alternatives where it is 

determined likely to be effective. 

Under both the No Action Alternative and Alternative A, the BLM would continue a custodial 

management approach to MHAs; these alternatives would have a minimal impact on the historic settings 

though long-term impacts could occur from passive management. Potential negative impacts to the 

historic setting of MHAs or to the potential archaeological or cultural values of the associated maritime 

heritage properties from restoration, rehabilitation, and reconstruction, would be greater under Alternative 

C than under the other alternative except Alternative D. However, the BLM would prohibit adverse 

impacts to the historic setting and appearance of the historic property, reducing the potential for negative 

long-term impacts under Alternative C. 

Under Alternative D, short-term and long-term impacts to the historic setting of MHAs or to the potential 

archaeological or cultural values of the associated maritime heritage properties from restoration, 

rehabilitation, reconstruction, and new construction would be greater than under the other alternatives. 

Adapting existing structures or building new ones to facilitate recreation, education, interpretation, and 

facilities support would have both long-term and short-term benefits for increasing visitor engagement in 

the history of the area, but would likely have long-term or permanent impacts to the historic appearance, 

setting, and use of the historic properties associated with the MHAs. 

The potential for negative impacts to the historical setting of MHAs from vegetation treatments would be 

greatest under Alternative B. Reducing fuels and hazard trees under this alternative would change the 

historical setting of the MHA, but would also reduce the risk for damage or loss of sites and structures. 

Passive vegetation management under the No Action Alternative and Alternative A would cause minimal 

disturbance, but the continued presence and/or spread of invasive plants and forest species could have a 

negative impact on the historic setting. Under Alternative C and Alternative D, the potential for 

disturbance of the cultural properties from vegetation treatments would be less than under Alternative B; 

the BLM would manage vegetation to benefit the historical setting of each MHA. Sub-Alternative C 

would have similar results, but would require more frequent disturbance to achieve objectives without the 

use of chemical treatments (e.g., herbicides). Repeated ground disturbance could increase potential longterm impacts to maritime heritage properties. 

Cumulative effects of alternatives on Maritime Heritage Properties in the San 

Juan Islands 

The Monument includes two of the four lighthouses located in the San Juan Islands. The BLM, in 

consultation with its tribal partners, the SHPO, Coast Guard, and other community partners, have actively 

cooperated to maintain and protect the lighthouse properties on or surrounded by Monument land. The 

BLM and its community partners have worked to recover the historic condition and appearance of the 

buildings and structures that remain at the historic light stations after years of weathering, deterioration, 

and disrepair. Public education and interpretation activities offered by the BLM’s community partners at

both Turn Point Light Station and Patos Lighthouse have continually improved and expanded visitor 

experiences at these historic aids to navigation facilities. 

The two lighthouses located outside of the Monument are both on San Juan Island and are owned and 

operated by the Coast Guard (at Cattle Point) and by Washington State Parks (Lime Kiln). Only the Lime 

Kiln Lighthouse provides public education and interpretation outside of the lighthouses managed by the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

69 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 BLM. Surrounded by Monument land, both this historic setting and the recreational use of the Cattle 

Point Lighthouse is directly affected by the BLM’s management of vegetation and recreation. 

Past development and both natural and cultural processes have resulted in the current condition of 

maritime heritage properties. Prior to the BLM’s administration of the Monument, maritime heritage 

properties were adversely impacted by shoreline erosion, natural deterioration, wildfire, construction, 

demolition, and maintenance. Construction and maintenance of aids-to-navigation facilities, including 

fog signals/light stations and ancillary buildings and structures, likely were not consistent with the 

Secretary of the Interior’s Standards for Treatment of Historic Properties. Construction and maintenance 

of roads, trails, and recreational development, in addition to vandalism, and looting likely have 

contributed to adverse impacts to maritime heritage properties. 

The BLM has minimized impacts to maritime heritage properties from construction and maintenance 

within the Monument. Working with partners, it has stabilized, protected, and rehabilitated light station 

facilities. The BLM has implemented measures to reduce the potential for loss or alteration of maritime 

heritage properties from erosion, natural deterioration, and visitor use. 

Decisions made under this planning effort would affect two-thirds of the historic lighthouse facilities in 

the planning area. The BLM assumes that management of the Lime Kiln Lighthouse, which is a popular 

destination for both maritime heritage appreciation and whale watching, would remain unchanged during 

the life of the plan. 

The alternatives would vary in how the Monument would contribute to the protection of maritime 

heritage resources in the San Juan Islands, as well as to the supply of such resources that would be 

available for casual visitation and appreciation. Under the No Action Alternative and alternatives A, B, 

and C, there would likely be limited negative impacts to the historic appearance and setting of the MHAs 

though potential impacts from vegetation treatments would be greater under Alternative B. Under 

Alternative D, construction of new structures to facilitate recreation, education, interpretation, and 

facilities support would have the potential for long-term negative impacts to the historic appearance and 

setting of the MHAs. Unless these impacts were adequately mitigated, this could reduce the overall 

contribution of maritime heritage resources with a high-level of historic integrity, feeling, and association 

of maritime heritage properties in the San Juan Islands. 

Under Alternative A, members of the public could visit the MHAs for educational, scientific, cultural, or 

spiritual purposes, but not for recreational activities. This would reduce by half the maritime heritage 

resources in the San Juan Islands available for casual visitation and appreciation. Under the other 

alternatives, the Monument’s contribution to the supply of maritime heritage resources in the San Juan 

Islands available for casual visitation and appreciation would remain unchanged. 

Education and Interpretation 

Key Points 

 Under all action alternatives, the BLM would develop an implementation-level Interpretation and 

Education Plan. 

This section contains one analytical issue: 

1. How would the alternatives affect education and interpretation within the Monument? (Page 70) 

Education and Interpretation Analytical Issue 1: How would the alternatives 

affect education and interpretation in the Monument? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Proclamation 8947 describes the Monument as “a refuge of scientific and historic treasures and a 

classroom for generations of Americans.” This description is borne out by the current use of the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

70 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Monument for numerous educational programs. In 2016, BLM staff, partners, and volunteers hosted 

5,599 hours of general educational and interpretative programs associated with the Monument, which 

reached over 3,733 participants. There were also 1,755 hours of educational and interpretative programs 

specifically targeted at youth, which reached over 1,170 young people. Approximately half of these

educational and interpretative programs took place in communities in the San Juan Islands rather than the 

Monument. See the Education and Interpretation section in Appendix E for a description of some of these 

programs. 

Table 5: Current interpretive and informational displays within the Monument 

Current Interpretive and Informational Displays Monument Location (s) within the Monument 

Cattle Point (San Juan Island) Three interpretive panels; one informational kiosk. 

Patos Island Free standing panels within the lighthouse 

Interpretive museum in the fog signal building. 

Turn Point Light Station (Stuart Island) Interpretive panels in the oil house. Interpretive 

information in the keeper’s quarters.

Chadwick Hill (Lopez Island), Point 

Colville (Lopez Island), Watmough Bay Informational Kiosks (Lopez Island), Iceberg Point (Lopez 

Island), Blind Island, Posey Island 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

Currently, permits are required for organized groups of 10 or more in the 503 acres in the ACECs 

(Chadwick Hill, Iceberg Point, Point Colville, and Watmough Bay). Outside of these areas, organized 

groups are required by regulation to obtain a special recreation permit from the BLM but no size 

threshold has been established. 

Much of the non-BLM-administered public land within the San Juan Islands provides relatively minimal 

on-site educational and interpretive signage. More actively interpreted visitor experiences are available at 

several locations, including but not limited to the San Juan Island National Historic Park (San Juan 

Island), Lime Kiln Point State Park (San Juan Island), Moran State Park (Orcas Island), Heritage Trust 

Resource Center: Otto Preserve (Lummi Island), and Fishermans Bay Spit (Lopez Island). 

Effects of the Alternatives 

Under all alternatives, educational and interpretive programs would continue within the Monument. The 

BLM would develop an implementation plan addressing how the agency, working with its partners, 

would develop educational and interpretive programs and materials—including those that would be 

available online—around various themes, including, but not limited to those listed in Appendix J. 

The impact of the alternatives on education and interpretation would vary in one primary way. Decisions 

related to signs would affect the delivery of interpretive and educational messages within the Monument. 

Under all alternatives, the BLM would establish signage as necessary to protect human health and safety, 

and prevent resource damage. The wording and placement of signs would be determined during plan 

implementation. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue to develop educational and interpretive signs 

on an ad hoc basis. Table 5 describes current interpretive and informational displays. Given the current 

custodial approach to management, there would likely continue to be minimal educational and 

interpretive signs. There would be no education and interpretive plan guiding the development and 

placement of these signs. 

Educational and interpretive programs would likely continue at approximately the current level and with 

the current restrictions (as described under the affected environment for this section). 

71 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative A 

Under Alternative A, the BLM would not develop any additional interpretive or educational signs within 

the Monument. The BLM would establish signs only as necessary to protect human health and safety and 

prevent resource damage. This would limit the ability of the BLM to provide educational and interpretive 

messages directly on the landscape. The BLM could continue to provide this information online and in 

printed formats distributed outside of the Monument and through in-person programing. 

Under this alternative, public access to the Monument would be limited to authorized access for research, 

educational, cultural, and spiritual uses. All non-BLM sponsored educational and interpretive 

programming within the Monument would require written authorization from the BLM. The 

authorization requirement might cause some decrease from the current level of programing within the 

Monument. There would also be a reduction in competing uses of the Monument and educational and 

interpretive experiences during what are currently higher visitation periods could improve. 

Alternatives B 

Under Alternative B, the BLM would limit development on the landscape by installing signs beyond 

trailheads and landing sites only as necessary to provide directional information and to protect Monument 

objects and values and human health and safety. This would create an opportunity to provide additional 

educational and interpretive information at the entry points to the Monument. The prohibition on 

interpretive and educational signage within the remainder of the Monument would limit the ability of the 

BLM to provide these types of messages directly on the landscape. The BLM could continue to provide 

this information online and in printed formats distributed outside of the Monument. 

Certain locations within the Monument would also require authorization for public access for all group 

sizes37 . This restriction would benefit these programs by ensuring exclusive access to these locations for 

educational and interpretive experiences. 

Alternatives C and D 

Under these alternative, the BLM would allow the installation of interpretation and education signage on 

the landscape. This would create an opportunity to provide educational and interpretive messages about 

the Monument’s objects and values at key locations throughout the landscape. The BLM could continue 

to provide this information online and in printed formats distributed outside of the Monument. 

Conclusion 

The alternatives would have limited effects on educational and interpretive programs within the 

Monument. Alternatives A and B would have the most restrictive approaches to both educational and 

interpretive signage. Alternatives C and D would allow for additional educational and interpretive signs. 

Cumulative Effects of the Interpretation and Education in the San Juan Islands 

The Monument includes approximately 4 percent of public lands in the San Juan Islands; the majority of 

the remaining 96 percent of public lands provide or are available for some level of educational and 

interpretive opportunities. The BLM is not aware of any management changes that would alter this 

situation in the foreseeable future. Under all alternatives, the BLM would continue to sponsor and 

coordinate educational and interpretive programming in the San Juan Islands. 

The alternatives would have limited impacts on educational and interpretive messaging and programing 

within the Monument; similarly, they would have a limited impact on the cumulative educational and 

interpretive messages and programming available in the San Juan Islands. 

 

37 Broken Point Island, Carter Point, Fauntleroy Rock, Kellett Bluff, Little Patos Island, Lopez Pass, Lummi Rocks, 

McConnell Rocks, Mud Island, Oak Island, Parks Bay Island, President Channel, Reads Bay Island, Richardson 

Rocks, Twin Rocks 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

72 
 

 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Habitat and Plants 

Key Points 

 Without management action, forest species would continue to encroach on grasslands and shrublands 

within the Monument. Both the quality and size of Monument grassland and shrublands would 

continue to decline. Forest communities would also become increasingly crowded and canopies 

would continue to close. 

 Under alternatives B and C, the BLM would expand the extent of grasslands and shrublands within 

the Monument and manage for a more open canopy within remaining forests and to enhance the cover 

and diversity of native plant communities. 

1. 

This section contains six analytical issues: 

How would each alternative affect the extent of vegetative communities? (Page 73) 

2. How would each alternative affect the condition of each vegetation plant community? (Page 

3. How would the alternatives vary in the approximate extent and type of vegetation treatments tha

77) 

t 

would be applied during their implementation? (Page 

4. How would the alternatives affect special status plants and lichen and Washington Natural Heritage 

Program priority ecological communities? (Page 117) 

5. How would the alternatives affect invasive plant species presence and spread within the Monument 

and the San Juan Islands? (Page 130) 

6. How would use of chemical treatments (e.g., herbicides) affect non-target resources including 

vegetation, human health and safety, water quality, wildlife, and soils? (Page 136) 

This section addresses the Monument’s habitats and plant communities; wildlife that depend on those 

communities are addressed in the Wildlife section. 

Habitat and Plants Analytical Issue 1: How would each alternative affect the 

extent of vegetative communities? 

See Appendix B for analytical methods used in this analysis.

Affected Environment 

The BLM mapped vegetative communities within the Monument using the Landscape Fire and Resource

Management Planning Tools (LANDFIRE) vegetation classification (NatureServe 2009). The 

LANDFIRE classifications describe terrestrial ecological systems, which are plant community types

(plant associations and/or alliances) that tend to co-occur within landscapes with similar ecological

processes, substrates, and/or environmental gradients (NatureServe 2009). The LANDFIRE program of

the U.S. Department of Agriculture Forest Service and U.S. Department of the Interior have linked their

classification systems based on NatureServe’s Ecological Systems to the group and macrogroup levels of

the National Vegetation Classification, which allows National Vegetation Classification plot data to 

contribute to LANDFIRE’s nationwide mapping efforts (USNVC 2017).

This analysis describes plant communities within the Monument using the National Vegetation 

Classification’s class and macrogroup scales. Table 6 includes the five macrogroups that occur within the

Monument, along with the two broader vegetation classes into which they fall. A given macrogroup may 

include a broad range of vegetative conditions, from areas with an intact native plant community to areas 

that are dominated by introduced vegetation. 

110) 

73 
 

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 6: Current extent of vegetation classes and macrogroups occurring in the Monument 

Class Macrogroup Monument

Acres

San Juan

Islands 

Acres

Percent of total

vegetation type in islands 

in the Monument

Southern Vancouverian 

Dry Foothill Forest 241 32,325 <1% 

Forest & woodland

Wetland: Vancouverian 

Flooded & Swamp Forest 3 299 1% 

Tsuga heterophylla -

Picea sitchensis - Sequoia 603 41,826 1% 

sempervirens Forest 

Southern Vancouverian 

Lowland Grassland & 126 10,474 1% 

Grassland & Shrubland

shrubland Wetland: Vancouverian 

Lowland Wet Shrubland, 39 717 5% 

Wet Meadow, and Marsh 

Unknown–bare rock 9

2 Forest and Woodlands 

Forest and woodlands cover more than 800 acres of the Monument, making them the largest vegetation 

class addressed by this plan. The current lack of fire and other disturbance on the landscape is allowing 

forest species to encroach into grasslands, causing conversion to forest over time (Kruckeberg 1991). 

Across the San Juan Islands, tree density has increased relative to conditions existing prior to EuroAmerican settlement due to a lack of disturbance (Sherck 2013, Bakker et. al. 2016, Spurbeck and 

Keenum 2003, Gray and Daniels 2006, U.S. Congress 1867). Currently, throughout the islands, dense 

forest vegetation fragmented by housing and associated small clearings is common. 

Grassland and Shrubland 

There are approximately 126 acres of non-wetland grassland and shrubland within the Monument. This 

vegetation class is found scattered throughout the Monument, but the majority of the acres addressed by 

this plan are within the Iceberg Point and Point Colville properties at the south end of Lopez Island. 

Throughout the Puget Lowland Ecoregion, which includes the San Juan Islands, both native and nonnative grasslands are at an estimated 9 percent of pre-Euro-American settlement levels (Chappell et al. 

2000). 

Wetlands 

The approximately 42 acres of wetland in the Monument comprise the Vancouverian Flooded and Swamp 

Forest macrogroup and the Vancouverian Lowland Wet Shrubland, Wet Meadow, and Marsh macrogroup 

in Table 6. The size of these wetlands has been relatively stable for decades. The limited freshwater 

resources of the San Juan Islands as a whole enhance the importance of the Monument’s limited wetlands. 

All freshwater wetlands within the Monument are on Lopez Island. At approximately 30 acres, Chadwick 

Marsh is the largest of the Monument’s wetlands. The freshwater wetland behind Watmough Bay is 

approximately 5 acres and the forested wetland at Point Colville is approximately 2 acres. Monument 

lands on Lopez Island support an additional acre of identified scrub-shrub wetland and emergent and open 

water wetland areas, and <0.5 acres of identified palustrine (freshwater) forested wetlands. 

Over time, the size of the Point Colville wetland may shrink due to encroachment by forest vegetation, 

though this decline is likely to be slow. Under current conditions, the extent of the remaining forested 

wetlands (Flooded and Swamp Forest macrogroup) and emergent wetlands (Wet Shrubland, Wet Meadow, 

and Marsh macrogroups) is likely to remain static due to their hydrologic conditions. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

74 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Patos Island supports one known habitat area with wetland plants and seasonally ponded water 

(approximately 1 acre in size). However, this area does not support hydric soils (i.e., soils seasonally or 

permanently saturated by water), and thus does not meet the Clean Water Act definition of a wetland. 

The BLM has not identified any lotic (flowing) riparian systems within the Monument. Although several 

stream segments occur within Monument lands on Lopez Island, these segments are either inundated by 

ponded and wetland areas (Chadwick Marsh) or are no longer active (connection between Watmough Bay 

Wetland and Watmough Bay). Mesic (i.e., moderately moist) areas in forest and woodlands within the 

Monument may support some riparian species (e.g., red alder (Alnus rubra) and willow (Salix scoulerii)) 

and mesic microclimates, but do not have defined scour or flowing water associated with streams. There 

are no 303(d) water bodies within the Monument. 

There have been historic losses of wetlands in San Juan County associated with human development 

(landings, harbors, docks, and housing); these losses have not been accurately quantified, but have led to 

the development of land use ordinances protecting wetlands (Rozenbaum 2012). More recently, 

approximately 20 percent of the wetland resources in the San Juan Islands have been classified as 

potentially disturbed (based on data in WDOE 2011b). 

Effects of the Alternatives 

The alternatives would vary in their effects on the extent of each vegetation class and macrogroup in the 

Monument over the next 20 years. Under the No Action Alternative and Alternative A, these effects 

would be driven by the continued encroachment of forest vegetation in grasslands and shrublands coupled 

with minimal active management. Under alternatives B, C, and D, these effects would be driven by the 

implementation of projects over the life of the plan to meet each alternatives’ objectives (see Table 7). 

Table 7: Comparison of estimated acres of vegetation class after 20 years under each alternative 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

No Action 2016 Alternative Alternative Alternative 

Class Macrogroup Acres Alternative/ 

Alternative B C D 

(acres) A (acres) (acres) (acres) (acres) 

Southern Vancouverian 241 246 119 138 242 Dry Foothill Forest 

Wetland: Vancouverian Forest & 3 3 5 3 3 

woodland Flooded & Swamp Forest 

Tsuga heterophylla -

Picea sitchensis - Sequoia 603 615 298 345 603 

sempervirens Forest 

Southern Vancouverian 

Lowland Grassland & 126 109 520 487 126 Grassland Shrubland & Wetland: Vancouverian shrubland Lowland Wet Shrubland, 39 39 70 39 39 

Wet Meadow, and Marsh 

Unknown 9 9 9 9 9 –bare rock

23 No Action Alternative 

24 Under the No Action Alternative, the BLM would continue to provide custodial management of the 

25 Monument’s habitats and plant communities. Assuming continuation of current trends, this would mean 

26 approximately 20 acres of vegetation treatment per year to address hazard trees and non-ground 

27 disturbing invasive plant treatments. This analysis assumes that the BLM would continue not to remove 

28 encroaching forest vegetation in areas of the Monument classed as grasslands and shrublands. 

75 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 With continued custodial management, the extent of areas classed as grassland and shrublands would 

continue to shrink due to encroachment by forest species over 20 years (see Table 7). The grasslands and 

shrublands vegetation class would decrease by approximately 13 percent. The forest and woodlands 

vegetation class would increase by approximately 2 percent. 

Alternative A 

Under Alternative A, the BLM’s objective would be to allow natural succession to take place to the extent 

possible while maintaining the diversity of plant communities described in Proclamation 8947. The BLM 

projects that Alternative A’s thresholds for triggering management to maintain the extent of plant 

communities (see page 17) would not be crossed within the next 20 years. As a result, the BLM would be 

unlikely to remove encroaching vegetation and the estimated extent of plant communities and 

macrogroups within the Monument would be the same in Alternative A as in the No Action Alternative. 

Alternative B 

Under Alternative B, the BLM’s objective would be to enhance the area's ecological resilience and 

resistance, including by increasing the extent of the native plant communities (specifically grasslands and 

wetlands) that are relatively scarce within the San Juan Islands as a whole. To achieve this objective, the 

BLM —likely working with tribes and other partners—would undertake vegetation treatments to enhance the 

acreage of grasslands and wetlands to the extent possible given site conditions. As is the case in Alternative C, 

this would more closely approximate the plant communities that would have been maintained through 

management of the landscape using fire prior to 19th Century Euro-American settlement. 

Through active management of currently forested areas identified by BLM specialists as having the 

potential to be grasslands and shrublands and wetlands, the extent of plant communities within these 

classes would increase substantially over the life of the plan (see Table 7). Over 20 years, the extent of 

the grassland and shrubland vegetation class, which includes tree savanna, would increase by 

approximately 313 percent (from approximately 12 percent of the Monument to approximately 51 percent 

of the Monument). The extent of the forest and woodlands vegetation class would decrease by 51 percent 

(from 83 percent of the Monument to 41 percent of the Monument). The extent of wetlands would 

increase by 79 percent (from 4 percent of the Monument to 7 percent). 

Alternative C 

Under Alternative C, the BLM’s objective would be to manage vegetation within the Monument to 

approximate the extent and condition of plant communities existing prior to Euro-American settlement when 

Native American/Indigenous Peoples managed the landscape using fire. This would require the BLM—likely 

working with tribes and other partners—to undertake vegetation treatments to increase the extent of acres in 

the grassland and shrubland class, which includes tree savanna, to approximate what it might have been prior 

to Euro-American settlement. 

Through active management to restore grasslands and shrublands to their approximate pre-European 

settlement extent, the extent of plant communities within these classes would increase substantially over 

the life of the plan. Over 20 years, the extent of acres in the grassland and shrubland class, which 

includes tree savanna, would increase by approximately 287 percent (from approximately 12 percent of 

the Monument to approximately 48 percent of the Monument). The extent of the forest and woodlands 

class would decrease by approximately 48 percent (from approximately 83 percent of the Monument to 

approximately 47 percent of the Monument). The extent of wetlands would remain unchanged. 

Alternative D 

Under Alternative D, the BLM’s objective would be to maintain the approximate current (2016) extent of

vegetation classes within the Monument. This would require the BLM—working with tribes and other 

partners—to undertake vegetation treatments at the edges of grasslands and shrublands to prevent conversion 

to forest and woodlands. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

76 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Through active management to maintain grasslands and shrublands, the extent of plant communities 

within these classes would remain at their approximate 2016 extent instead of decreasing over the life of 

the plan as they would under the No Action Alternative (see Table 7). 

Conclusion 

The alternatives would vary in their effects on the extent of vegetation classes within the Monument. 

Acres in the grassland and shrubland vegetation class, which includes tree savanna, would increase 

substantially under alternatives B and C, and would continue to decline in extent under the No Action 

Alternative and Alterative A. Forest and woodlands would decrease substantially under alternatives B 

and C, and would continue to increase in extent under the No Action Alternative and Alternative A. 

Wetlands would remain static in size, except under Alternative B, under which they would increase in 

size. Under Alternative D, all vegetation classes would continue to occupy approximately the same 

percent of the Monument as under current conditions. 

Cumulative effects of the alternatives on plant communities in the San Juan 

Islands 

See cumulative effects under Habitat and Plants Issue 2 for a discussion on the effects of the alternatives 

on the cumulative extent and condition of plant communities in the San Juan Islands. 

Habitat and Plants Analytical Issue 2: How would each alternative affect the 

condition of each plant community? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Forest and Woodlands 

This sub-section addresses the Southern Vancouverian Dry Foothill Forest and Tsuga heterophylla -

Picea sitchensis - Sequoia sempervirens forest macrogroups in Table 6. The Vancouverian Flooded and 

Swamp Forest macrogroup is addressed under wetlands, below. 

Forests and woodlands within the Monument, as well as in the San Juan Islands in general, are shaped by 

the area’s varying precipitation levels, as well as by the level of disturbance (e.g., wildfire, disease, 

vegetation management). These factors influence both species composition and community structure 

(e.g., closed or open canopy, density of undergrowth). This sub-section describes the structure of the 

Monument’s forests and woodlands and how this has changed over time, the status of large and old trees 

within the Monument, and the species composition of the area’s moist and dry forests. 

Forests and woodlands within the Monument are shaped by the area’s precipitation levels (in addition to 

the soils and aspect of individual locations), which vary from a low of 17 inches on the southern end of 

Lopez Island to 29 inches on Patos Island. This change in precipitation is due to the rain shadow effect of 

the Olympic Mountains to the south. Most soils in the San Juan Islands are shallow, and droughty 

conditions are common in the summer. 

Plant Community Structure 

The lack of recent fire and other disturbance has caused open canopy communities, including tree 

savannas and woodlands, to convert to closed canopy forests over time due to increasing tree density 

(Kruckeberg 1991). Dunwiddie et al. (2011) estimated the historical tree density on Waldron Island was 

about 1/10 of the current density. The rate of encroachment, infill, and shrub expansion varied from 

island to island (Agee and Dunwiddie 1984, Avery 2004, Gray and Daniels 2006, Dunwiddie et al. 2011). 

Currently, according to BLM specialists, all oak habitat within the Monument is woodland rather than 

savanna 38 (i.e., the tree density is too high to be considered savanna). 

 

38 According to the BLM Forest Inventory System, savanna has less than 10 percent tree cover. Oak habitat with 

more than 10 percent tree cover is considered oak woodland. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

77 
Table 8: Current acres of succession classes within the Monument 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Forests and woodlands are often categorized into succession classes, which describe their percent cover, 

2 height, and species composition. The BLM identified succession classes within the Monument using the 

3 LANDFIRE succession classification (NatureServe 2016). Currently, nearly 90 percent of the 

4 Monument’s forests have a closed canopy (see Table 8). Based on the fire studies and historical 

5 descriptions referenced above, a higher percentage of forests and woodlands within the Monument, and 

6 within the San Juan Islands, would have historically been in either succession class A or C, which feature 

7 open canopies, or in succession class E. 

8 

Monument Forest 

Succession 

Class 

and Woodlands in Class Description Succession Class Canopy 

(Percent) 

Post-stand replacement community composed of 

A (Open 

Forest) 

herbs, shrubs, and young trees. Succession to class 

3% B after 20 years. For the Monument, most 

succession class A has developed from 

Single layer of 

trees in canopy 

<10 % tree cover 

encroachment of forest species into grasslands. 

B 

(Closed 

Forest) 

Closed-canopy young forest stands with trees 

averaging 10" in diameter and 65 feet in height. 52% Understory tends to be minimal because of low 

light levels. Succession to class E after 80 years. 

>35% tree 

canopy cover. 

One to two upper 

canopy layers 

C (Open 

Forest) 

Young forest stands opened up by mixed-severity 

fire or, on moist sites, by wind-throw or root-rot. 

8% Trees average 10-12" in diameter and 65-80 feet in 

height. Shrubs dominate the understory. 

Succession to class D or E after 80 years. 

<35% tree 

canopy cover. 

One upper 

canopy layer. 

D (Open 

Forest) 

Mature to old-growth forest stands opened up by 

mixed-severity fire, or on moist sites, opened up by 

wind-throw and root-rot. Largest trees are greater 

than 20" in diameter. Canopy opening may be 1% sufficient to permit shade-intolerant species or may 

only permit shade-tolerant species. This class has a 

diverse understory with essentially the same species 

as class E. Succession to class E after 50 yrs. 

> 35% tree 

canopy cover. 

One upper 

canopy layer and 

up to one to three 

size classes in 

this layer. 

E 

(Closed 

Forest) 

Mature to old-growth forest stands dominated by 

large individuals (>20" in diameter). Understories 

37% can be a mix of shade tolerant shrubs and herbs. 

Forest will maintain in class E until a stand 

replacement disturbance. 

> 35% tree 

canopy cover. 

Multiple upper 

canopy layers 

9 Source: Landfire 2016 

Large, Old Trees 

th In the 19 Century, the Federal government withdrew much of the land now included in the Monument

for lighthouse development, including Cattle Point, Iceberg Point, Kellett Bluff, Patos Island, Point

Colville, and Turn Point. Except for areas cleared for lighthouses, logging did not take place within these

much of these lighthouse reservations. Because of this, large and old trees occur on Patos Island, Iceberg

Point, and Point Colville. The BLM estimates the age of some of these trees at well over 300 years.

The large and old trees that occur within the Monument initially grew in more open conditions than 

currently exist. Frequent disturbances including fire, insects and disease, and weather events ensured 

adequate growing space for these trees. The relative absence of fire on the landscape over the last

10 

11 

12 

13 

14 

15 

16 

17 

18 

78 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 hundred years has allowed large numbers of new trees to become established. Competition from these 

new trees is causing stress in older stands and individual large and old trees. The increasing density of

trees, along with the stressed older trees, creates conditions that are susceptible to future severe fire 

(Brown et. al. 2004), insect and disease outbreaks, and susceptibility to weather/climate events. There is 

currently no management intervention to address this trend. 

Except at Point Colville, Iceberg Point, and Patos Island, stands of large and old trees are relatively scarce 

in the Monument. More common are individual trees and small stands that have old tree characteristics, 

including old crown and branch pattern characteristics, crown form and vigor, thick bark with wide plates 

and coloring indicative of old bark (relative to each species), sometimes (but not always) large size, and 

an age that is near the upper portion of the maximum biological age for that species or site (Van Pelt 

2007). Some individuals also have some form of internal decay or branch dieback (Van Pelt 2007). 

Dry Forest Species Composition 

Dry forests classified as North Pacific Maritime Dry-Mesic Douglas-fir-Western Hemlock Forest are the 

most extensive forest type in the Monument, occurring at Point Colville, Chadwick Hill, Iceberg Point, 

Kellett Bluff, and Turn Point. These forests include Douglas-fir (Pseudotsuga menziesii), grand fir (Abies 

grandis), Pacific madrone (Arbutus menziesii), lodgepole pine (also known as shore pine) (Pinus 

contorta), Garry oak (also known as Oregon white oak) (Quercus garryana), seaside juniper (Juniperus 

maritima), quaking aspen (Populus tremuloides), and other hardwoods. Dry forest sites are usually 

located on rocky, steep, south facing slopes. The understory is mostly grasses and forbs, though due to a 

lack of disturbance Douglas-fir are becoming a more prominent component of the understory. 

Several of the dry forest species and vegetative communities within the Monument are considered 

ecologically important, including Garry oak and seaside juniper. For example, the transition area between 

the grasslands and Douglas-fir forest on Lopez Island at Point Colville and Iceberg Point has been 

described as one of the finest examples of this type of habitat in the region (Dougherty 2004). 

Several BLM funded studies have found that there has been a departure from historic dry forest

conditions within the Monument (Dougherty 2004, Gray 2006, Spurbeck and Keenum 2003, Sherck

2013). These studies show that dry forests in the Monument have a history of frequent disturbance by

wildland fire that is similar to low elevation eastern Washington forests (Spurbeck and Keenum 2003). 

The fire return interval on the southern end of Lopez Island was found to be 11 to 14 years over a 340-

year-period, but the last recorded fire in this area was in 1916 (Spurbeck and Keenum 2003). 

The increasingly closed forest conditions are causing a decline in several dry forest species, including 

Garry oak, madrone, seaside juniper, and aspen. Garry oak occur in limited locations in the San Juan 

Islands; within the Monument, they are mostly found at Kellett Bluff (Henry Island) and a few other 

scattered locations. Sherck (2013) cited a number of sources indicating that mature oak trees initially 

grew in more open conditions. Pre-settlement oak habitat was characterized by relatively open canopies 

dominated by trees with full, mushroom-shaped crowns (Vesely and Tucker 2004). This translates to tree 

densities that vary with age but would eventually range from 25 to 50 trees per acre with a canopy closure 

of 25 to 50 percent. Currently, many of these areas have canopy cover of between 50 and 90 percent 

(Landfire 2016). Without management intervention, the decline of Garry oak would continue. Changing 

forest conditions threaten oak woodlands by throughout the Northwest (Livingston et al. 2016). 

Seaside juniper occurs in scattered locations throughout the Monument and has also declined due to 

changes in disturbance patterns in the San Juan Islands (MacDonald and Nakae 2015). Seaside juniper, 

which was identified as a species endemic to the Pacific Northwest in 2007 (MacDonald and Nakae 

2015), grows as single trees and in small groups in granitic or sandy soils. 

Aspen stands in the San Juan Islands were also once more abundant than today. Aspen occur as 

individuals and in small clumps; they grow best in deep, moist loamy soils in a range of precipitation 

zones (16 to 40 inches). Aspen stands often contain a mixture of age classes with a skirt or fairy ring of 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

79 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 regeneration around the edge of the stand (Shepperd et.al. 2001). This regeneration results from root 

sprouting that would occur from full sunlight reaching the ground and a lack of competing vegetation. 

Historically, fire, insects, and disease benefitted aspen by keeping encroaching vegetation from 

outcompeting aspen and by creating conditions that allowed aspen to regenerate by sprouting. The 

reduction of fire and other disturbances on the landscape has created conditions that are less favorable for 

aspen regeneration. 

The reduction in fire incidence in the San Juan Islands has also degraded conditions for Pacific madrone

by increasing competition for sunlight, water, and nutrients on many sites. Madrone dieback has been 

recently occurring on the San Juan Islands (Mehmel 2006). This dieback is a result of overhead shading 

from conifers and side-shading from conifers and other tree species. 

Moist Forest Species Composition 

Moist forests are extensive on Patos and Little Patos islands, which are the northern most locations in the 

Monument. On Patos and Little Patos islands, precipitation levels can reach 29 inches per year. The 

southern San Juan Islands receive less precipitation; in these areas, moist forest is usually restricted to 

draws, which are usually moister, productive, and protected from wind and salt spray (Gray and Daniels 

2006). Moist forest tree species include western red cedar (Thuja plicata), grand fir, western hemlock 

(Tsuga heterophylla), and Douglas-fir. 

The moist forests on Patos Island are considered of high ecological importance. The Western Red CedarGrand-Fir/Swordfern Forest association that occurs on Patos has been described as the best example of 

this closed forest type in Washington (Crawford and Chappell 2006). 

As with dry forest, current moist forest conditions in the San Juan Islands differ from historic conditions, 

which were characterized by more open conditions and uneven-aged patches of forest (Gray and Daniels 

2006). In addition, western hemlock, Sitka spruce, lodgepole pine, and grand fir, now a part of the moist 

forest species composition, may not have been present in the past (Gray and Daniels 2006). 

Grassland and Shrubland 

This sub-section addresses the Vancouverian Lowland Grassland and Shrubland macrogroup from Table 

6. The Vancouverian Lowland Wet Shrubland, Wet Meadow, and Marsh macrogroup is discussed under

wetlands, below. Vancouverian Lowland Grassland and Shrubland is made up of the North Pacific 

Herbaceous Bald and Bluff plant community, which is a dry to mesic (i.e., moderate moisture) grassland

and shrubland (Kittel 2010). This section will refer to this community as grassland and shrubland.

The grassland and shrubland communities consist of mostly herbaceous-dominated areas (balds) located 

primarily on shallow rocky soils (NatureServe 2015). Due to shallow soils, steep slopes, sunny aspect, 

and/or upper slope position, these sites are dry and marginal for tree establishment and growth except in 

favorable microsites. The vegetation is grassland with some dwarf-shrubs, which can occur as small 

patches but are usually in a matrix with the herbaceous vegetation. 

Rock outcrops are a typical small-scale feature within balds and are considered part of this system (Kittel 

2010). Sites with many favorable microsites can have a "savanna" type structure with a sparse tree layer 

of Douglas-fir or, less commonly, Garry oak or other species. The southern extent of the Monument has a 

relatively dry climate, always with a distinct dry summer season when these sites usually become 

droughty enough to limit tree growth and establishment (NatureServe 2015). 

The grasslands and shrublands in the San Juan Islands were once maintained by fires, both naturally

occurring and, primarily, set by native Coast Salish peoples (Kittel 2010). The presence of fire on the

landscape supported camas (Camassia spp.), an important food source for the Coast Salish inhabitants. 

Grasslands and shrublands have declined throughout the San Juan Islands and the broader ecoregion, 

primarily due to development and a decrease in fire frequency. Euro-American settlement brought

livestock grazing and more intensive cultivation, reduced the frequency of fire, and resulted in the 

introduction of numerous non-native plants. This resulted in fewer native forbs, including camas. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

80 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Because of this change in the fire regime, the extent of grasslands and shrublands has declined locally 

through tree invasion and growth. Areas formerly maintained as herbaceous by burning have filled in 

with trees. There is currently no active management to prevent this encroachment. 

Less than 3 percent of grasslands dominated by native species are extant, as measured using aerial

photographs, soil surveys, ground-truthing, and previous mapping efforts (Chappell et al 2000). The

North Pacific Herbaceous Bald and Bluff ecological system is considered vulnerable in the state and has a

short-term 30-50 percent decline in trend predicted, with a corresponding long-term trend of a 10-30 

percent decline (WNHP 2015).

Most of the grasslands and shrublands in the San Juan Islands, including within the Monument, are 

largely composed of non-native grasses, and support a mixture of native and non-native forbs. The 

presence or absence and relative dominance of groups such as non-native versus native grasses, forbs, and 

shrubs can be used to describe the habitat quality in grasslands and shrublands. Line-point data from 

herbaceous balds and bluff areas collected in 2014 indicate an average of 45 percent non-native cover 

(BLM 2014a). Vulpia bromoides was the most common non-native grass. 

Threats to Monument grasslands and shrublands include changes in the fire regime, climate change, and 

invasive species competition. Additional threats include overgrazing by species include native blacktailed deer (Odocoileus hemionus columbianus) and non-native European rabbits (Oryctolagus 

cuniculus). Fragmentation caused by excessive social trailing is also a threat to the integrity of remaining

grasslands. User created trails are noticeably present in the Monument grasslands and shrublands on the 

south end of Lopez Island. These systems tend to be very sensitive to disturbance and trampling. 

In a study funded by the BLM and Washington Native Plant Society, Rhoades (2009) describes nearly 

200 lichen species at Point Colville and Iceberg Point. Some of species are found in forested areas, while 

others grow on moss and rock in open areas and are vulnerable to foot traffic and weed encroachment. 

Rhoades found damage from foot travel of lichen heaths made up of fragile Cladonia species. This genus 

is especially vulnerable to breakage and can take decades to recolonize. 

Nearshore Habitat and Nearshore Marine Plant Communities 

Nearshore habitats include the littoral zone i.e., the area from the high water mark, which is rarely

inundated, to shoreline areas that are permanently submerged. The BLM’s jurisdiction, and the 

Monument designation, applies only above mean high tide. All Monument locations include shoreline 

and management can affect habitat below mean high tide, as well as the portions of the shoreline that lie 

above mean high tide. 

The BLM’s management of the Monument may affect nearshore habitats, including shoreline, high 

impact surf zones, kelp forest, and seagrass beds. There are six seagrass species in Washington State:

Zostera marina (eelgrass), Zostera japonica (non-native), Phyllospadix serrulatus, Phyllospadix scouleri, 

Phyllospadix torreyi, and Ruppia maritima. Eelgrass is by far the most abundant seagrass species in the 

greater Puget Sound. Eelgrass provides similar ecosystem services as other seagrass species (Christiaen 

et al 2017). Shoreline habitat comprises both sandy/gravelly (unconsolidated) shoreline and rocky

shoreline. The North Pacific Maritime Coastal Sand Dune and Strand ecological system is associated 

with sandy/gravelly shoreline and spits (NatureServe 2009). 

Much of the shoreline within the Puget Sound has been modified (historically and recently) for

agricultural, industrial, and residential uses. San Juan County has the lowest modification level in the 

Puget Sound region, with around 5 percent of its shorelines modified (Herrera 2011, Friends of the San 

Juans 2011). In addition to being less heavily developed than other parts of the Puget Sound region, 

many of the San Juan County shorelines are rocky, and so less vulnerable to erosion. Based on lack of

disturbance and minimal shoreline stabilization, shorelines in (above mean high tide) and adjacent to 

(below mean high tide) the Monument action area are assumed to be in good condition. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

81 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Native eelgrass (Zostera marina) covers an estimated 9 percent of Puget Sound below the mean lower 

low water mark, and is found along roughly 20 percent of San Juan County shoreline (SSPS 2007). 

Eelgrass occurs as patches or narrow bands near the shore, or as solid meadows in the subtidal zone. 

Eelgrass and other seagrasses provide physical structure and trophic support for the biological 

community and is nursery habitat for many sensitive species including salmon (Murphy et al. 2000, 

Mumford 2007). 

The condition (quality and extent) of seagrass beds can be reduced through introduction of toxicants, 

sediment delivery leading to mechanical abrasion, burying, turbidity (lack of light penetration), and 

mechanical loss during moorings (New South Wales Department of Primary Industry 2017). Seagrass 

conditions have remained stable or improved in the San Juan Islands generally, but eelgrass beds in bays 

such as Watmough Bay have seen substantial long-term declines (Christiaen et al. 2017). Seagrass beds 

are indicators of adequate water quality and absence of heavy disturbance or nuisance algae. Based on 

observed declines, the BLM assumes the quality of seagrass habitat in Watmough Bay is reduced from 

reference conditions (i.e., not high-quality), while seagrass communities in less enclosed inlets adjacent 

to the remainder of the Monument are in better condition. Sediment cycles in the Monument appear to 

be within historic ranges. No sediment plumes from Monument lands have been observed, and existing 

nearshore habitat does not show evidence of high sediment delivery such as silting-in of seagrass beds or 

forage fish spawning areas. However, water quality impacts from non-point source pollutants (roads, 

boats, etc.) appear to be high enough lead to seagrass bed declines in adjacent nearshore areas with less 

flushing (e.g., Watmough Bay). 

Watmough Bay includes the single most important forage fish spawning habitat area adjacent to the 

Monument (Friends of the San Juans 2007). Since this habitat type requires primarily substrate and wave 

disturbance and is not reliant on water quality (or lack of physical disturbance), it is assumed that forage 

fish spawning habitat areas adjacent to the Monument retain relatively stable and high-quality condition. 

Kelp forests in the San Juan Islands may include multiple species of algae, often dominated by bull kelp 

(Nereocystis luetkeana). Most kelp forests occur in the shallow subtidal zone from the mean lower low 

water mark to about 65 feet below this mark and are associated with high-energy environments 

(Mumford 2007). Floating kelp species occur along approximately 31 percent of San Juan County’s 

shoreline, while non-floating kelps occur along 63 percent (Mumford 2007). Kelp forests provide refuge 

habitat for a number of fish species (Mumford 2007). Through food web interactions, kelp forests are an 

important community for sea urchins, herring, crabs, mollusks, and a variety of marine mammals 

including sea otters and whales (Steneck et al. 2002, Mumford 2007, NOAA 2010). 

Kelp forests showed declines in recent state-wide surveys, including substantial declines in the Straits of Juan de Fuca (WDNR 2015c). Diverse factors influence kelp forest stability including kelp 

harvest, plant competition, storms, El Niño events, sedimentation, pollution, and grazing by 

fishes, sea urchins, and crustaceans (NOAA 2017). Non-point and point source pollution 

including sewage, industrial disposal, and runoff might contribute to this decline. High 

sedimentation from run-off may bury new plant shoots. Studies on microscopic stages of 

kelp suggest it is sensitive to poor water and sediment quality (NOAA 2017). Based on lack 

of point source pollution, limited non-point pollution, and mostly open marine systems, it is 

assumed that kelp forests adjacent to the Monument support moderately healthy 

conditions. 

 Threats facing the shorelines of San Juan Islands include climate change-induced sea level rise, geologic 

events, invasive species, human disturbance, contaminants, and marine debris. Impacts to nearshore 

habitats from current Monument management are limited to sediment deposition from trails, disturbance

 of nearshore vegetation from boat landing, and impacts to nearshore habitat function from shoreline 

stabilization. All shoreline stabilization within the Monument to date has been soft stabilization. 

82 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Wetlands 

This sub-section addresses the condition of the Vancouverian Flooded and Swamp Forest and the 

Vancouverian Lowland Wet Shrubland, Wet Meadow, and Marsh macrogroups described in Table 6. 

All freshwater wetlands within the Monument are found on Lopez Island. These wetlands have been 

described by Dunwiddie (2010) and Hedges and Camp (1996). The BLM has classified wetland 

conditions in the Monument using the proper functioning condition methodology (Prichard 1999). This 

qualitative classification (supported by quantitative measures and observations) includes three classes: 

proper functioning condition, functional-at risk, and nonfunctional. Systems in proper functioning 

condition have adequate vegetation, landform, and structure to dissipate energy, filter sediment, stabilize 

shorelines, and provide habitat for native riparian species. With the exception of the Point Colville 

wetland, all wetlands in the Monument are currently meeting proper functioning condition. The wetland 

at Point Colville is functional-at risk. To summarize, 40 acres of Monument wetlands are currently 

meeting proper functioning condition, 2 acres are functioning at risk, and 0 acres are nonfunctioning. 

Wetland functional condition as defined in Prichard 1999 includes three attributes: hydrology, vegetation, 

and erosion/deposition. Wetland hydrology includes consistent saturation with water quality and flow 

pattern sufficient to produce wetland conditions. Vegetation attributes include presence, diversity, and 

function (including stabilizing functions) of wetland plants. Erosion/deposition attributes include soils or 

bedrock restricting percolation and promoting saturation, without excessive erosion or deposition. 

The wetlands in the Monument currently have erosion/deposition patterns that promote stable wetlands, 

including basins that support saturated hydric soils with balanced erosion and deposition supporting stable 

banks. Vegetation attributes in most Monument wetlands include a diversity of stabilizing riparianwetland plants, with few non-native species that are also non-stabilizing or non-hydrophytic species. 

Invasive reed canary grass, which is stabilizing and hydrophytic, is co-dominant in some Monument 

wetlands. The wetlands that are co-dominated by invasive reed canary grass have a limited ability to 

provide high-quality freshwater habitat, though they do currently meet proper functioning condition. 

The Point Colville wetland is dominated by sedge (Carex obnupta) under a Sitka spruce (Picea 

sitchensis) overstory. This area has been called a bog, but does not meet bog definitions, as it is not 

overly acidic and does not support sphagnum moss. Comparisons with old aerial photos suggest that 

Point Colville wetland is filling in with trees (BLM 1990), primarily Sitka spruce, which is an upland 

species. This tree infilling has reduced cover by wetland plants and decreased presence of hydric soils, 

causing a decline in the wetland’s function over time. 

Effects of the Alternatives 

Forest and Woodlands 

The alternatives vary in how they would affect the structure and species composition of forests and 

woodlands and the condition of large and old trees. Specifically, they vary in the objectives and 

management direction that would drive vegetation treatments over the life of the plan and in the type and 

extent of recreational activities that would occur in existing forest and woodlands (Table 9). Figure 2 

compares the estimated annual forest and woodland treatment acres under each alternative. 

Vegetation treatments, which would vary by alternative in terms of both type and extent, would move the 

composition, structure, and function of forest vegetation toward each alternative’s desired conditions. 

Effectiveness of treatments would vary among alternatives due to differences in acres likely to be treated 

and types of treatments. Untreated areas that are currently departed from the normal historic conditions 

would be less resilient to insect, disease, and fire due to high stand densities, altered species composition 

and structure, and existing disease and insect outbreaks, and high levels of fuel loading. 

Camping in forests and woodlands can result in a reduction in understory cover and height at impacted 

sites (Cole and Monz 2003). Construction of new trails would result in removal of understory vegetation 

including, potentially, small trees. The effects of existing trails include the exposure of tree roots through 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

83 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 erosion and trampling of understory vegetation adjacent to the trail (Dale and Weaver 1974). Wilson and 

2 Seney (1994) and Marion (2006) found that equestrian use had the highest erosional and trail-widening 

3 impact on trails, followed by hiking, then mountain biking. Meadow and weedy plants are common at 

4 trailsides in forests, although, only a narrow (1-2 m) band of vegetation is affected. Plant responses at 

5 campgrounds and other high-use areas would be similar to those along trails (Dale and Weaver 1974). 

6 

0 

50 

100 

150 

200 

250 

Estimated average acres per year

Mechanical 

Herbicide 

Biological 

Prescribed Fire 

7 Figure 2: Estimated average acres of forest and woodland treatments per year 

8 Table 9: Recreational activities in forest and woodlands by alternative 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

Public motorized use (road miles) 0.9 0* 0.9 0.5* 0.9 

Hiking (trail miles) 

Equestrian (trail miles) 

Bicycling (trail miles) 

9.2 

9.2†

9.2†

0 

0 

0 

14 

0 

0 

7.7 

2 

0 

17.2 

6.7 

6.6 

Dispersed camping (acres) 421 0 0 0 468 

Dispersed camping w/permit (acres) 0 

13‡

0 600 

13‡

0 

13‡

0 

342** 

Designated site camping (acres) (in existing 0 (in existing (in existing (existing and 

sites) sites) sites) new sites) 

9 *The BLM would close all roads in forest and woodlands under Alternative A and 0.4 miles under 

Alternative C to public motorized use, but would maintain all existing roads for authorized and 

administrative purposes. 

†

Trails are currently open to all non-motorized uses. There is currently limited equestrian use at 

Chadwick Hill and Watmough Bay. There is no regular use of Monument trails by bicycles. 

‡

Forested portion of the developed west end of Patos Island; Patos Island has 7 existing sites. **Specific site locations for new designated campsites would be determined during plan implementation 

phase and involve a separate planning and NEPA compliance process. 

No Action Alterative 

Plant Community Structure 

Under the No Action Alternative, the BLM would continue to undertake very limited vegetation 

treatments in Monument land in the forest and woodland class. Over the next 20 years, the percent of 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

84 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Monument forests with a closed canopy would exceed 90 percent, further diverging from the area’s 

historic conditions. Less shade tolerant understory vegetation would decline under this alternative. 

Under this alternative, there would continue to be at least 9.2 miles of trail in the Monument’s forest and 

woodlands (see Table 9). If current recreation trends continue, the trail miles in more accessible forests 

and woodlands would expand. There would also continue to be 9 designated campsites at Patos Island, 

some of which occur in forested habitat. Understory vegetation would continue to be displaced and 

trampled in and around these campsites and trails. This impact would be limited to areas in and around 

campsites and trails, but could compound effects on less shade tolerant understory vegetation from 

increasing shading in these areas. Though visitors rarely participate in dispersed camping, the BLM 

would continue to allow this use on 421 acres of Monument land in the forest and woodland class. 

Large and Old Trees 

Under the No Action Alternative, it is likely that no vegetation treatments would occur in areas with large 

old trees over the next 20 years, with the exception of the occasional removal of hazard trees. These 

stands would remain overstocked, departed from historic conditions, and increasingly susceptible to 

insects, diseases, drought, climate change, and stand-replacing fires. See the affected environment section 

for further description of these conditions. 

Any beneficial impacts from the removal of hazard trees would likely be minor and short-term. These 

treatments would target trees that are posing threats to human health or safety or historic structures within 

the Monument. Beneficial impacts would result from the opening of the forest canopy and increased 

availability of water and nutrients to other trees near the removed hazard trees, but would not alter species 

or structural diversity outside of their immediate surroundings. 

Species Composition 

Under the No Action Alternative, the trends in species composition described in the affected environment 

would continue. This alternative would provide the least benefits to shade intolerant and moderately 

intolerant species, including Garry oak, seaside juniper, aspen, and Pacific madrone. Shade tolerant 

species such as western hemlock, Sitka spruce, Douglas-fir39, and grand fir would continue to expand, 

though increasingly dense conditions would make them susceptible to insects, diseases, drought, climate 

change, and stand-replacing fires. Several shade tolerant species may not have been present historically

making their expansion an increasing departure from historic conditions (Gray and Daniels 2006). 

Denser canopies would increase forest floor litter and humus, favoring less fire-adapted species. This 

addition of conifer litter would likely cause changes to soil properties, including nutrient cycling, 

microbial activity and moisture-holding capacity, which may influence the community of understory 

plants (Livingston et.al. 2016). 

Visitor and staff use would continue to create opportunities for invasive plant establishment on 3 feet on 

each side of 10.1 miles of roads and trail in forests (Dale and Weaver 1974). Invasive establishment 

related to vegetation treatments would continue to be minimal. 

Alternative A 

Under Alternative A, the BLM’s management of forests and woodlands would continue to be primarily

passive. Because the BLM estimates that it would only undertake vegetation treatments for invasive plant

species and hazard tree removal under this alternative (see Habitat and Plants Issue 3), the impacts to 

forests and woodlands would be similar to those from the No Action Alternative. The primary difference 

in effects to forests and woodlands would be from changes in recreation management. 

 

39 In wet draws where red cedar and hemlock are present, Douglas-fir is shade intolerant compared to the more 

shade tolerant cedar and hemlock; it is thus not found in the understory in such areas. In the drier portions of the 

Monument, Douglas-fir is found in the understory (Van Pelt, 2008) and behaves as a shade tolerant species. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

85 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under Alternative A, the BLM would prohibit recreational use within the Monument, though it would 

continue to facilitate public access for authorized educational, scientific, cultural, and spiritual uses. Over 

time, trail mileage and clearings for campsites within forests and woodlands would decrease. Understory 

vegetation would recover from the effects of trampling in and around campsites and trails, though this 

recovery would take several years (Cole and Monz 2003). 

Opportunities for invasive plant spread in forests would be reduced due to the decline in trail miles. 

Invasive establishment related to vegetation treatments would continue to be minimal. 

Alternative B 

Plant Community Structure 

Under Alternative B, the BLM would increase the extent of acres of the grassland and shrubland 

vegetation class, which includes tree savanna, and of wetlands within the Monument by expanding them 

into areas currently occupied by forest and woodland. Within lands that would remain in the forest and 

woodland class, the BLM would undertake treatments to enhance late-successional characteristics and to 

promote resistance and resilience from fire, drought, insect pests, disease, and climate change. 

In order to achieve objectives, the BLM estimates that it would use prescribed fire in existing woodland, 

such as at Kellett Bluff, and light thinning in much of the remaining forest and woodlands (See Habitat 

and Plants Issue 3). The BLM would use thinning in second growth forests to enhance late-successional 

characteristics by inducing fine-scale variation in homogeneous canopies (Aukema and Carey 2008). The 

use of thinning and fire would reduce the potential for stand replacement and crown fires (Peterson et. al. 

2004). Treatments would have some short-term negative effects, including potential increase in invasive 

plant species and a temporary reduction in understory cover (Aukema and Carey 2008). Over the life of 

the plan, treatments would result in less dense forests and more open canopies than under the No Action 

Alternative and alternatives A and D, though conditions would not be as open as under Alternative C. 

Under this alternative, trails crossing forest and woodland would increase to 14 miles (see Table 9). The 

nearly 5 miles of new trails in forest and woodland would require removal of understory vegetation, 

including small trees. There would also continue to be 9 designated campsites at Patos Island, some of 

which are in forested habitat. Designated site camping with a permit would be allowed on 600 acres that 

are currently in the forest and woodland class. These acres and miles would decline over the life of the 

plan as currently forested acres are converted to grassland and shrubland (see Habitat and Plants Issue 1). 

Understory vegetation would be displaced and trampled in and immediately around campsites and trails. 

The structure of the forest under this alternative would be closer to historic conditions and would be more 

resistant and resilient to effect from fire, disease, and other potential disturbances. 

Large and Old Trees 

Under Alternative B, the BLM would undertake treatments to remove younger trees that are creating 

overstocking stress on large and old trees that were established during more open conditions. In the longterm, large and old trees would recover physiologically and become more resilient and resistant to threats 

including high intensity wildfire, insect and disease attack, drought, and climate change. 

Species Composition 

Under Alternative B, treatments would reduce competition and increase sunlight reaching shade intolerant 

and moderately intolerant species, including Garry oak, seaside juniper, aspen, and Pacific madrone. 

Shade tolerant species such as western hemlock, Sitka spruce, Douglas-fir40 , and grand fir would continue 

to exist in the Monument, though would not continue to expand. Several of these shade tolerant species 

may not have been present historically (Gray and Daniels 2006). 

 

40In the Monument’s wet draws where red cedar and hemlock is present, Douglas-fir is intolerant of shade compared 

to the more shade tolerant cedar and hemlock; it is thus not found in the understory in such areas. In the drier 

portions of the Monument, Douglas-fir is found in the understory (Van Pelt, 2008) and behaves as a tolerant species. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

86 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Thinning in oak woodland, such as at Kellett Bluff, would allow oaks to recover their natural open 

growing crowns, potentially converting some areas to oak savanna. This would benefit the long-term 

sustainability of oak populations since most acorns are produced in the sunlit portions of the crown (Peter 

and Harrington, 2005). It would also decrease competition for water from encroaching conifers (Gould 

et.al. 2011). Treatments would increase resistance and resilience of Garry oaks suppressed by over-story 

shading and open up more former habitat for oak repopulation. 

The BLM would thin understories where they are currently dominated by a single species (e.g., 

rhododendron dominate the understory of forest on Patos Island), allowing for more diverse understories. 

Visitor and staff use would create opportunities for invasive plant establishment on 3 feet on each side of 

14.9 miles of roads and trail in forests (Dale and Weaver 1974). Opportunities for invasive plant 

establishment due to disturbance from vegetation treatments would increase substantially compared to the 

No Action Alternative; the BLM would minimize this impact through treating areas to control invasive 

plants, including with herbicides. 

Alternative C 

Plant Community Structure 

Under Alternative C, the BLM would approximate historic conditions by increasing acres in grassland 

and shrubland, which includes tree savanna, by expanding this class into areas currently occupied by 

forests and woodlands. In Monument lands that would remain forest and woodland, the BLM would 

undertake treatments to approximate the more open conditions that would have historically occurred 

through the use of fire as a management tool by Native American/Indigenous Peoples (Anonymous 1868, 

Agee and Dunwiddie 1984, Avery 2004, Gray and Daniels 2006, Dunwiddie et al. 2011). 

The BLM estimates that it would undertake similar treatments under Alternative C as under Alternative 

B, though these treatments would be repeated more times over the life of the plan. Due to the higher 

repetition rate, short-term negative effects would be greater than Alternative B. Over the life of the plan, 

treatments would result in the least dense forest conditions and most open canopies of any alternative. 

Under this alternative, trails in forest and woodlands would decrease to 7.7 miles (see Table 9). The 

miles of trail would further decline over the life of the plan as currently forested acres are converted to 

grassland and shrubland (see Habitat and Plants Issue 1). There would continue to be 9 designated 

campsites at Patos Island, some of which are in forested habitat. Understory vegetation would be 

displaced and trampled in and immediately around campsites and trails. Where trails were closed, 

understory vegetation would recover from the effects of trampling over the course of several years (Cole 

and Monz 2003). There would be no dispersed camping allowed under this alternative. 

Large and Old Trees and Species Composition 

Effects to large and old trees and in forest and woodland species composition would be similar under 

alternatives B and C except that there would be fewer opportunities for invasive plant spread from roads 

and trails under Alternative C. Visitor and staff use would create opportunities for invasive plant 

establishment on 3 feet on each side of 8.2 miles of roads and trail in forests (Dale and Weaver 1974). 

Opportunities for invasive plant establishment due to disturbance from vegetation treatments would be 

slightly greater under Alternative C than Alternative B due to the higher treatment repetition. 

Sub-Alternative C 

With two exceptions, impacts to forests and woodlands under Sub-Alternative C would be the same as 

under Alternative C. 

Without herbicide use, treatment of areas where the forest understory is dominated by a single species 

would be less effective. Without the use of herbicides to suppress currently dominating species (e.g., 

rhododendron in Patos Island forests), few other types of vegetation could become established. The 

prohibition on herbicide use would also make it more difficult for the BLM to minimize invasive plant 

species in areas disturbed through vegetation treatments and along trail and road sides. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

87 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The higher rate of treatment repetition that would be required to achieve objectives without the use of 

herbicides (see Habitat and Plants Issue 3) would create greater short-term negative effects to forest 

species composition and structure than under Alternative C. 

Alternative D 

Plant Community Structure 

Under the objectives for Alternative D, the BLM would maintain approximately the current forest and 

woodland conditions existing within the Monument. 

Under this alternative, trails in forest and woodlands would increase to 17.2 miles (see Table 9). The 8 

miles of new trails in forest and woodland would require removal of understory vegetation, including 

small trees. The BLM would also allow designated site camping at new and existing sites on 342 acres in 

forest and woodland, including at Iceberg Point, the east side of Patos Island, Point Colville, and Turn 

Point. Specific locations for new campsites would be determined during plan implementation and would 

involve a separate planning and NEPA compliance process prior to on-the-ground disturbance. Dispersed 

camping would be allowed on an additional 468 acres in the forest and woodlands class. Understory 

vegetation would be displaced and trampled in and immediately around campsites and trails. 

Large and Old Trees 

Under Alternative D, the BLM would undertake treatments in areas with large and old trees only to 

prevent an increase in overstocking compared to current conditions. Treatments to prevent further 

crowding would provide some long-term benefits to forest and woodlands compared to the No Action 

Alternative. Large and old trees would continue to be under competitive stress from smaller, younger

trees, but these conditions would not increase over the life of the plan. 

Species Composition 

Under Alternative D, shade intolerant and moderately intolerant species, such as Garry oak, seaside 

juniper, aspen, and Pacific madrone, would continue to be under-represented in the Monument’s forests 

and woodlands compared to historic conditions. Populations of shade tolerant species such as western 

hemlock, Sitka spruce, Douglas-fir, and grand fir would continue to be over-represented. Several of these 

species may not have been present historically (Gray and Daniels 2006). 

Visitor and staff use would create opportunities for invasive plant establishment on 3 feet on each side of 

18.1 miles of roads and trail in forests (Dale and Weaver 1974). Opportunities for invasive plant 

establishment due to disturbance from vegetation treatments would increase slightly compared to the No 

Action Alternative; the BLM would minimize the ability for such species to capitalize on these 

opportunities through treating areas to control invasive plants, including with herbicides. 

Conclusion 

Table 10 qualitatively summarizes the effects of the alternatives on the condition of forests and 

woodlands. It describes each alternative as causing an improvement, decline, or no change (+,-,=) in 

various components of forest and woodland conditions. 

Under the No Action Alternative and Alternative A, closed forests would continue to make up 

approximately 89 percent of Monument forest and woodland, with over 50 percent in mid aged closed 

forests that mostly developed after Euro-American settlement. These alternatives would result in a 

continued decline of open forest conditions and a continued increase in closed forests due to infilling of 

forested vegetation. Shade intolerant species would be negatively impacted from continued and 

increasing shading from taller coniferous species. Shade tolerant species would continue to increase. 

Large and old trees would come under increasing stress from the denser vegetation. Forest stands under 

these alternatives would continue to be less resistant and resilient to both natural and human disturbances. 

Under alternatives B and C, management actions would treat forests to create more open conditions. 

These treatments would be more intensive under Alternative C to approximate the more open conditions 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

88 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 that would have existed prior to Euro-American settlement. In addition, the BLM would convert 51 

2 percent and 47 percent of Monument forest acres to grasslands and shrublands under alternatives B and C 

3 respectively. Most of the treated and converted stands would originate from the class B (mid-aged, closed 

4 stands). Shade tolerant species would decline in extent, while shade intolerant species would increase in 

5 extent and improve in resistance and resilience to disturbances. Implementation of treatments to reduce 

6 competition stress would benefit large and old trees. 

7 Under Alternative D, the BLM would seek to maintain the forested vegetation in its current extent and 

8 condition. Open forest would continue to be only a small portion of the Monument (approximately 12 

9 percent). Shade tolerant species would continue to thrive and shade intolerant species would continue to 

10 decline. The BLM would maintain large and old trees through vegetation treatments. Resistance and 

11 resilience to disturbance would not improve and would remain low due to vegetation competition stress 

12 that a large portion of the forested area is experiencing in its present state. 

13 Table 10: Summary of the effects of the alternatives on forest and woodland conditions 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

Open Forest - - + + = 

Closed Forest + + - - = 

Shade tolerant species - - + + = 

Shade intolerant species + + - - -

Large and old trees - - + + = 

Resistance/resilience to disturbance - - + + -

14 Cumulative Effects of the Alternatives on Forests and Woodlands in the San 

Juan Islands 

The majority of forest vegetation within the San Juan Islands is managed by private land owners, the 

National Park Service, and the State of Washington. The Monument includes less than 2 percent of the 

Southern Vancouverian Dry Foothill Forest and Tsuga heterophylla - Picea sitchensis - Sequoia 

sempervirens forest macrogroups that occur in the San Juan Islands. 

While a variety of past management actions have affected forest and woodland habitat in the San Juan 

Islands, the primary agents driving current conditions were the end of fire as a management tool on the 

landscape and timber harvest after Euro-American settlement. These actions have altered the historic 

condition, extent, and distribution of forest and woodland habitat in the San Juan Islands. 

Other than hazard tree removal, there is currently limited active management of forest and woodland on 

public lands in the San Juan Islands. One exception is vegetation management the San Juan County Land 

Bank is undertaking to restore Garry oak woodland and savanna on approximately 25 acres on Orcas and 

San Juan islands (Habbeger 2017). There also remains some small-scale timber harvest occurring on 

private lands, including management intended to reduce the density of the forest canopy and enhance oak 

woodlands (Northwest Natural Resources Group 2017, Rainshadow Consulting 2017). 

Under all alternatives, the Monument would continue to contribute only a small percent of forest and 

woodland communities in the San Juan Islands. Under the No Action Alternative and alternatives A and 

D, it would continue to contribute less than 2 percent of the Southern Vancouverian Dry Foothill Forest 

and Tsuga heterophylla - Picea sitchensis - Sequoia sempervirens forest macrogroups in the San Juan 

Islands. Under these alternatives, it is likely Monument forests would return to something resembling 

historic conditions only through insect infestations, disease, and/or uncharacteristic stand-replacing fires. 

This could create risks for forests and woodlands on public and private lands adjacent to the Monument. 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

89 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under alternatives B and C, the BLM would reduce the acreage of forest habitat within the Monument 

would by approximately 50 percent. This would result in a decrease of less than 1 percent of the Southern 

Vancouverian Dry Foothill Forest and Tsuga heterophylla - Picea sitchensis - Sequoia sempervirens 

forest macrogroup acres in the San Juan Islands. Under alternatives B and C, the BLM would enhance 

woodland habitats and open forest conditions, which are declining in the San Juan Islands. These 

alternatives would have a beneficial impact on conditions of forests in the San Juan Islands in general, as 

it would reduce risks to adjacent plant communities and increase the relatively small extent of forests and 

woodlands in near historic conditions. 

Grasslands and Shrublands 

The alternatives vary in several ways that would affect Monument grassland and shrubland. Specifically, 

they vary in the objectives and management direction that would drive vegetation treatments and in the 

type and extent of recreational activities that would occur in grasslands and shrublands (Table 11). Figure 

3 compares the estimated annual grassland and shrubland treatment acres under each alternative. 

This sub-section also addresses herbaceous balds and bluffs (here rocky balds and bluffs) including 

exposed rocky areas with moss and lichen cover. Since rocky balds and bluffs often occur on the viewing 

edge of Monument locations, visitors are tempted to leave trails or are unable to discern trails and wander 

over the rocks. This has both short and long-term negative impacts and vegetation is slow to recover. 

See Habitat and Plants Issue 4 for impacts to specific special status plants. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

0 

200 

400 

600 

800 

1,000 

1,200 

Estimated average acres per year

Mechanical 

Herbicide 

Biological 

Prescribed Fire 

20 Figure 3: Estimated average treatment acres in grassland and shrubland per year 

21 Table 11: Recreational activities in grassland and shrubland by alternative 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

Public motorized use (road miles) 0 0 0 0 0 

Hiking (trail miles) 5.1 0 4.4 2.9 5.6 

Equestrian (trail miles) 5.1* 0 0 <0.1 1 

Bicycling (trail miles) 5.1* 0 0 0 1.1 

Dispersed camping (acres) 66 0 0 0 25 

Dispersed camping w/ permit (acres) 0 0 87 0 0 

90 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Designated site camping (acres) 

8 

(in existing 

sites) 

0 

8 

(in existing 

sites) 

8 

(in existing 

sites) 

93†

(existing and 

new sites) 

1 * Trails are currently open to all non-motorized uses. There is currently limited equestrian use at 

Chadwick Hill and Watmough Bay. There is no regular use of Monument trails by bicycles. 

† Specific locations for new designated campsites would be determined during plan implementation and 

involve a separate planning and NEPA compliance process prior to any on-the-ground disturbance. 

No Action Alternative 

Under the No Action Alternative, native forest species, along with native and introduced shrubs and forbs, 

would continue to encroach on Monument grasslands and shrublands. Vegetation treatments in grasslands 

and shrublands would continue to be minimal and limited to small-scale mechanical removal

(predominately clipping above ground growth) of invasive plants. Therefore, the number of plant groups 

(i.e., native bunchgrasses or flowering forbs), species within those groups, and the cover of those species

would stay the same or continue to decline slightly as non-native species continue to spread. The current

rate of decline is not known, but over the long-term there would be a neutral to minor negative effect. 

Short-term negative effects from limited vegetation treatments would be negligible. 

Under this alternative, there would continue to be at least 5.1 miles of trail crossing grasslands and 

shrublands (see Table 11). Trails would continue to be open to all non-motorized uses, though visitors 

currently use them almost exclusively for hiking. If current trends continue, trail miles in more accessible 

grasslands and shrublands, such as at Iceberg Point and Cattle Point, would increase over time. 

Use of these trails would continue to have direct negative short-term and long-term impacts on grasslands 

and shrubland plant associations through soil compaction, erosion via channeling of water, and widening 

of trails during wet periods. Wilson and Seney (1994) and Marion (2006) found that equestrian use had 

the highest erosional and trail-widening impact on trails, followed by hiking, then mountain biking. All 

of these impacts may limit or decrease the number of native plants able to inhabit areas adjacent to the 

trails and favor non-natives that are adapted to harsher conditions such as compacted soil. 

Camping in existing designated sites at Blind, Patos, and Posey islands would continue. These areas 

include approximately 8 acres of grassland and shrubland. Since these areas have already felt the impacts 

of camping, future effects would be negligible to grassland and shrubland quality. Dispersed camping 

would continue to be allowed in 66 acres of grassland, including at Cattle Point, Kellett Bluff, Turn Point, 

McConnell Rocks, and Lummi Rocks. If current recreation patterns continue, participation in this activity 

would remain relatively low. Effects of dispersed camping include negative short-term impacts such as 

crushing of vegetation from tents and hiking, which would result in damage and in some cases mortality. 

Rocky Balds and Bluffs 

Under the No Action Alternative, current impacts from recreational use in the rockiest areas of the 

herbaceous balds and bluffs would continue, including crushing and killing of lichens and mosses from 

off-trail travel over rocks. Visitors would continue to access these areas via the 5.1 miles of trail in 

grasslands and shrublands, as well as through overland hiking, which would continue to be allowed. 

Vegetation treatments in the rocky portions of the herbaceous balds and bluffs would continue to be 

minimal and limited to cutting invasive plants. Due to the minimal extent of these treatments, they would 

be unlikely to affect the diversity and cover of native plants. They may have short-term negative effects 

from crushing native plants when occurring off trails. Effects from this to the moss and lichen on the 

rocks would continue to be minimal. Shallow rooted non-native grasses growing between rocks and in 

rock crevices would continue to compete with native vegetation. This negative impact would continue 

due to the limited extent of invasive plant treatments to control non-native grasses. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

91 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative A 

Under Alternative A, the BLM’s management of grasslands and shrublands would be primarily passive. 

Encroachment by native forest species into Monument grasslands and shrublands would continue. Linepoint data from herbaceous balds and bluff areas indicate an average of 45 percent non-native cover 

(BLM 2014a). This suggests that early in the life of the plan Monument grasslands and shrublands would 

cross the Alternative A threshold for invasive plant management: “Control and contain invasive plant

species when an average of less than 50 percent cover by native vegetation remains in a vegetative 

community across the Monument.” Control of noxious weed species designated by Washington State for

mandatory eradication or control would continue to occur throughout the life of the plan. 

Due to Alternative A’s narrow vegetation objectives and prohibition on chemical treatments (e.g., 

herbicides) and prescribed fire, it is unlikely that the condition of the native plant community would 

greatly improve. Once grasslands and shrublands passed the invasive plant management threshold, the 

BLM would undertake invasive plant treatments (see Habitat and Plants Issue 3). Some seeding of native 

species would occur in conjunction with these treatments. Without the use of herbicides, treatment areas 

would not achieve high-quality standards (Denehey et al 2011, Stanley et al 2011a and 2011b, see 

assumptions in Appendix B). Clark and Wilson (2001) found that the number of inflorescences (flower 

heads) of velvetgrass (Holcus lanatus) and sweet vernalgrass (Anthoxanthum odoratum), both non-natives 

found in Monument grasslands, increased with hand removal and mowing. Competition with non-native 

plants would continue to cause short-term and long-term negative impacts to the diversity and cover of 

native plants. Short-term impacts due to the potential soil disturbance of manual treatments would be 

minor and negative. 

The BLM would not anticipate restoring native plant communities under this alternative except through 

seeding and planting after invasive plant species treatments. This would result in the diversity and cover 

of native plants continuing to decline, despite removal of non-native plants. The overall effect to 

grassland and shrubland plant associations from this alternative would be negative in the long-term. 

This alternative would close the Monument to recreational use, though the BLM would continue to 

facilitate access for authorized educational, scientific, cultural, and spiritual uses. The current negative 

impacts from recreation described under the No Action Alternative would not continue, though minor 

impacts from access for administrative and authorized uses would. Short-term negative impacts of trail 

use would be minimized under this alternative. The lack of herbicides under this alternative may make it 

difficult to entirely stop the spread of non-native plants along trails that are no longer in use. 

In summary, the condition of grasslands and shrublands would likely decline over time as a result of 

invasive plant treatment being undertaken in the absence of both herbicides and broader treatments to 

restore native plants. Direct impacts from trampling and crushing due to recreational use would heal over 

time, though closed trails could be invaded by invasive plant species. 

Rocky Balds and Bluffs 

Under Alternative A, the BLM would be unlikely to treat non-native plants that are not invasive, such as 

the shallow rooted non-native grasses that are currently in some rocky balds and bluffs. The probable 

targets (e.g., Canada thistle) for those treatments that would take place are typically found in the deeper 

soils of grasslands and forests. Therefore, it is unlikely that damage to vegetation, including moss and 

lichen, would occur from mechanical treatment in this alternative. However, non-native plants would 

continue to compete with in the rocky balds and bluffs. This would be a negative long-term impact. 

The closure to recreational uses have minor short-term positive impacts to rocky balds and bluffs. Moss 

and lichen on closed trails and at viewpoints would slowly recover, though would face competition from 

non-natives (see above). Major positive impacts would be long-term, as it would take years or decades 

for moss and lichens to regrow in places where they have been removed due to recreational use. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

92 
 

 

5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative B 

2 Under Alternative B, the BLM—likely working with tribes and other partners—would undertake 

3 extensive grasslands and shrubland restoration (see Habitat and Plants Issue 3 for estimated treatment 

4 types and acres). Treatments undertaken to maximize species richness, structural component diversity, 

and system resilience from fire, drought, insect pests, disease, and climate change, would have a major 

6 positive long-term effect on diversity and cover of native plants, though short-term negative effects would 

7 also occur. As described in the objectives for this alternative, treatments would be designed to maximize 

8 the species richness and structural diversity of native forbs, though not necessarily to eradicate shrubs. 

9 Like alternatives C and D, all tools would be considered in designing implementation-level vegetation 

treatments. Treatments would have some short-term negative effects on native plants in grasslands and 

11 shrublands, but also major positive short-term and long-term effects on the condition of these 

12 communities by giving managers a variety of tools for effective habitat improvement (Stanley 2011). Soil 

13 erosion would increase in the short-term after vegetation removal. Early seral native species may fare 

14 better in the short-term after vegetation treatments, but may slowly be replaced by late seral species. 

Under this alternative, the BLM would likely undertake prescribed burning to begin to reverse the effects 

16 of a lack of fire on the landscape and allow fire-tolerant species to increase in number and cover, while 

17 decreasing the cover of fire-intolerant species. Because fire-tolerant species include both native and non18 native plants (Stanley 2011), the BLM would likely undertake carefully timed herbicide use shortly post19 fire to target non-native plants while minimizing effects on slower germinating natives (Dennehy 2011). 

Mechanical and herbicide treatments to remove woody shrubs (e.g., rose and snowberry) and encroaching 

21 trees would allow for increased cover of desired grassland species, such as camas and native grasses. The 

22 long-term impacts of such treatments would be positive. In the short-term, there would be negative 

23 impacts from ground disturbance from mechanical removal, including a temporary increase in invasive 

24 plants. Dunwiddie (2002) found that out-planting of native seedlings was needed to outcompete nonnative species that established after tree and shrub removal on Yellow Island. Without aggressive native 

26 plant restoration, the negative impacts from invasive plants could be long-term. 

27 Efforts to restore native plants would improve diversity by increasing the number of growth form groups 

28 and members of each group. Species richness would increase and have a positive long-term effect on the 

29 condition of grassland and shrubland communities. Short-term effects from soil disturbance due to plug 

planting and raking in seed, if used, would be minor and negative due to the possibility of opening soil to 

31 invasion on non-desirable species. The BLM would minimize this effect by seeding native species in 

32 conjunction with invasive plant treatments. 

33 Herbicide application would result in some mortality of non-target plants, but this effect would be highly 

34 localized due to hand application methods (given the small size of Monument sites it is very unlikely that 

the BLM would undertake aerial herbicide application). This would be a short-term negative effect on 

36 group diversity and cover. Effects could further be minimized by the use of selective herbicides and 

37 careful phenological timing (Stanley 2011). 

38 While trail miles would increase overall under Alternative B, there would be a net decrease of trails in 

39 grasslands and shrublands from 5.1 miles to 4.4 miles (see Table 11). This would include closure of trails 

at Cattle Point (0.2 miles) and Iceberg Point (0.6 miles), in addition to several smaller closures of less 

41 than 0.1 miles (see Appendix H for travel and transportation planning maps). Trail closures would have 

42 short-term minor negative effects from potential invasion of non-native plants on the former trail, as well 

43 as short-term positive effects because soil compaction, erosion via channeling of water, and widening of 

44 trails during wet periods would no longer occur. There would also be long-term positive effects due to 

treatments to restore native plants and control invasive species. By removing trails, restoration efforts 

46 may be easier to implement because additional recreational disturbance and spread of weed propagules 

47 would cease to exist in these areas. The BLM would prohibit cross-country hiking under this alternative. 

93 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under Alternative B, camping would continue in existing designated sites and effects would be the same 

as the No Action Alternative. In addition, dispersed camping by permit would be allowed in 87 acres of 

grasslands and shrublands (see Table 11), including 50 acres that are not currently open to dispersed 

camping at Iceberg Point and Point Colville. Visitors would have to obtain permits for dispersed camping 

and the BLM would issue no more than one permit per location per night. Effects of dispersed camping 

include negative short-term impacts such as crushing of vegetation from tents and hiking, which would 

result in damage and in some cases mortality. Dispersed camping would also have a minor negative longterm effect to areas that are highly desirable camping locations due to level surfaces and favorable views. 

In summary, the number and diversity of plant groups within the Monument’s grasslands and shrublands 

would likely improve over the life of the plan. Impacts from trail use would decline due to the reduction 

of trail miles in grasslands and shrublands and the prohibition on cross-country hiking. Management of 

dispersed camping with a permit in easily accessible locations on Lopez Island would likely lead to a 

decline in grassland and shrubland condition in desirable camping locations over time. 

Rocky Balds and Bluffs 

Short-term negative impacts from treatments would primarily occur in grasslands—where the majority of 

target plant species occur—rather than on rocky balds and bluffs. Prescribed fire would be unlikely to 

reach into rocky areas, and would not be recommended for such areas because moss and lichen are killed 

by fire. Seeding of native species would occur in conjunction with invasive plant treatments. 

As described above, trail miles in grasslands and shrublands would decline slightly under Alternative B, 

leading to a slight decline in associated impacts to rocky balds and bluffs. While no off-trail hiking 

would be allowed under Alternative B, some impacts from off-trail travel would likely continue given that 

these areas often provide views and visitors are tempted to leave trails or unable to discern trails over the 

rocks. Travel over rocks can cause negative short and long-term impacts such as crushing and killing of 

lichens and mosses, as well as of plants that might be rooted in cracks and crevices. 

Impacts from dispersed camping with a permit on rocky balds and bluffs would be similar to those in 

grasslands and shrublands in general. The views from rocky balds and bluffs would attract campers, 

though their rocky nature would make them potentially less desirable as camping locations. 

Alternative C 

Under Alternative C, the BLM—likely working with tribes and other partners—would undertake 

extensive grasslands and shrubland restoration (see Habitat and Plants Issue 3 for estimated treatment 

types and acres). Vegetation treatments undertaken to achieve Alternative C’s objective to approximate 

historic conditions would have a major positive long-term effect on diversity and cover of native species, 

though some short-term negative impacts would occur. Treatments would include intensive restoration 

efforts to remove non-native plants and restore native plants, including culturally important species. 

Like alternatives B and D, all tools would be considered in designing implementation-level vegetation 

treatments. Impacts from vegetation treatments under Alternative C would be similar to Alternative B, 

though the magnitude of both short-term negative and long-term positive would be greater. Greater acres 

of treatment would be required to remove non-native plants and woody shrubs to an extent that would 

approximate historic conditions. 

Under Alternative C, trail miles in grasslands and shrublands would decrease from 5.1 miles to 2.9 miles 

(see Table 11). This would include closure of trails at Cattle Point (0.5 miles) and Iceberg Point (0.9 

miles), in addition to smaller closures at Blind Island, Indian Island, Patos Islands, and Point Colville (see 

Appendix H for travel and transportation planning maps). Trail closures would have short-term minor 

negative effects from potential non-native plant invasion on the former trail, as well as short-term positive 

effects because soil compaction, erosion via channeling of water, and widening of trails during wet 

periods would no longer occur. There would also be long-term positive effects due to treatments to 

restore native plants and control invasive species. By removing trails, restoration efforts may be easier to 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

94 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 implement because additional recreational disturbance and spread of weed propagules would cease to 

exist in these areas. The BLM would prohibit cross-country hiking under this alternative. 

Under Alternative C, camping would continue in existing designated sites and effects would be the same 

as the No Action Alternative. Dispersed camping would no longer be allowed in 66 acres of grassland 

and shrubland currently open to this use. This use occurs only occasionally within these areas, so positive 

effects from closing to this use would be minimal, though would prevent any future crushing of 

vegetation from tents and visitor use associated with camping. 

In summary, Alternative C’s combination of intensive restoration treatments and substantial trail closures 

would lead to the greatest improvement of native grassland and shrubland cover and diversity over the life 

of the plan. 

Rocky Balds and Bluffs 

Alternative C’s objective to approximate historic conditions would drive the greatest amount of change to 

vegetative on rocky balds and bluffs. Implementation-level treatments would likely be designed to 

remove non-native shallow rooted plants in the crevices and interspaces between rocks. The potential use 

of herbicides to undertake this task would cause short-term impacts to non-target species, including 

desirable natives such as moss and lichen. Correct plant identification and careful herbicide application 

would minimize this effect. The removal of non-native plants from rocky balds and bluffs would benefit 

native plants by reducing completion. Subsequent restoration of native species would result in higher 

cover of native plants and more species that would have been historically present. 

As described above, trail miles in grasslands and shrublands would decline under Alternative C, leading 

to a decline in associated impacts to rocky balds and bluffs. While no off-trail hiking would be allowed 

under Alternative C, some impacts from off-trail travel would likely continue given that these areas often 

provide views and visitors are tempted to leave trails or unable to discern trails over the rocks. Travel 

over rocks can cause negative short and long-term impacts such as crushing and killing of lichens and 

mosses, as well as of plants that might be rooted in cracks and crevices. 

Sub-Alternative C 

Impacts from to grasslands and shrublands from recreation under Sub-Alternative C would be the same as 

those for Alternative C. 

Under Sub-Alternative C, the BLM—likely working with tribes and other partners—would work to 

achieve the objectives of Alternative C without the use of chemical treatments (e.g., herbicides). To 

achieve the objectives without herbicides, the BLM would undertake a high frequency of vegetation 

treatments to remove invasive plant species and encroaching shrubs and trees (see Habitat and Plants 

Issue 3 for estimated treatment types and acres). Without the use of herbicides, treatment areas would be 

unlikely to achieve high-quality standards (Denehey et al 2011, Stanley et al 2011a and 2011b, see 

assumptions in Appendix B). Clark and Wilson (2001) found that the number of inflorescences (flower 

heads) of velvetgrass (Holcus lanatus) and sweet vernalgrass (Anthoxanthum odoratum), both non-natives 

found in Monument grasslands, increased with hand removal and mowing. 

The BLM would use prescribed fire and repeated mechanical treatments to improve the cover and 

diversity of native plants by removing non-native plants and encroaching shrubs and trees, followed by 

native plant restoration. However, without combining prescribed fire with the use of herbicides, control 

of non-natives may not be possible (Stanley 2011) and the BLM may not be able to achieve the objective 

of approximating historical diversity and cover conditions. This could be mitigated somewhat through 

aggressive mechanical/manual treatments carefully timed to target non-natives. There would likely 

continue to be short-term and long-term negative impacts to the diversity and cover of native plants due to 

competition with non-natives. Seeding of native species would occur in conjunction with invasive plant 

treatments to fill in areas where invasive plants are removed. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

95 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The high frequency of mechanical treatments under this alternative would result in a higher level of shortterm negative effects than would occur under Alternative C. This would lead to higher ground 

disturbance due to reentry, which could have a negative impact on the condition of the community. 

In summary, under Sub-Alternative C, vegetation treatments would increase the diversity and cover of 

native plants, but would be unlikely to achieve the objective of approximating historical conditions. 

Rocky Balds and Bluffs 

In the absence of herbicides, the BLM would likely undertake the removal of invasive plants from rocky 

balds and bluffs through hand-pulling and digging. Short-term negative effects would include a greater 

level of soil disturbance than in Alternative C. Increased levels of seeding and planting of native plants 

would be necessary to prevent more invasive plants from colonizing the disturbed areas. The removal of 

non-native plants from rocky balds and bluffs would benefit native plants by reducing completion. 

Subsequent restoration of native species would result in higher cover of native plants and more species 

that would have been historically present. 

Alternative D 

Under Alternative D, the BLM’s would be to maintain grassland and shrublands in approximately their

current conditions (see Habitat and Plants Issue 3 for estimated treatment types and acres). To meet this 

objective, the BLM would undertake treatments to control invasive plant species, restore native plant 

species subsequent to treatments, and remove additional encroaching shrubs and trees. 

Like alternatives B and C, the BLM would consider all tools in designing implementation-level 

vegetation treatments. Treatments would have some short-term negative effects on native species cover 

in grasslands and shrublands, but also minor positive short-term and long-term effects on the condition of 

these communities by giving managers a variety of tools for effective habitat improvement (Stanley 

2011). Negative effects could be minimized by the use of selective herbicides and careful phenological 

timing (Stanley 2011). Over time, treatments to retain current conditions would have a positive impact on 

native plant groups compared to the No Action Alternative as well as to Alternative A, though the longterm impacts would be less beneficial than under alternatives B and C. Grasslands and shrublands would 

remain substantially invaded by non-native plants and encroaching trees and shrubs. 

While Monument trail miles would increase substantially overall under Alternative D, in grasslands and 

shrublands there would be a relatively modest net increase from 5.1 to 5.6 trail miles (Table 11). This 

would include development of new trails in grasslands and shrublands at Blind Island (0.1 miles), Cattle 

Point (0.2 miles) Iceberg Point (0.2 miles), Kellett Bluff (0.1 miles), in addition to several new trail 

segments of less than 0.1 miles (see Appendix H for travel and transportation planning maps). Where the 

BLM developed new trails in grasslands and shrublands, habitat would be lost and adjacent habitat 

quality would decline. The new trail at the north end of Iceberg Point and the trail Kellett Bluff (which is 

part of a larger trail that goes mostly through forest and woodland) would be in herbaceous areas that do 

not have any current trails. These would result in mean loss and fragmentation of that habitat and would 

have short-term and long-term negative effects on this habitat. 

Trail closures would also occur in grasslands and shrublands at Cattle Point (0.4 miles). Trail closures 

would have short-term minor negative effects from potential invasion of non-native plants on the former 

trail, as well as short-term positive effects because soil compaction, erosion via channeling of water, and 

widening of trails during wet periods would no longer occur. There would also be long-term positive 

effects due to treatments to restore native plants and control invasive species in trail closure areas. 

All trails within grasslands and shrublands would be open to hiking. The BLM would continue to allow 

equestrian and bicycle use on respectively 1 mile and 1.1 miles of trail though grasslands and shrublands 

at Point Colville and Iceberg Point. These uses would be prohibited during the wet season. Impacts from 

equestrian use during the dry season would be similar to impacts from hiking, while use from bicycles 

would result in slightly less erosion to trails than either hiking or equestrian use due to the narrower 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

96 
 

 

 

 

 

 

 

5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 impact on the trail (Wilson and Seney 1994). Other researchers have found that equestrian use has much 

2 higher impacts to soil erosion and trail width than hikers and bicycles (Marion 2006). 

3 Under Alternative D, the BLM would also expand designated site camping for visitors arriving by non4 motorized boat to 93 acres of grassland and shrubland, including at Cattle Point and Iceberg Point. 

Specific locations for new designated campsites would be determined during plan implementation and 

6 would involve a separate planning and NEPA compliance process prior to any on-the-ground disturbance. 

7 Effects from designated site camping in existing sites would be the same as the No Action Alternative. 

8 Effects from new designated site camping would be trampling and crushing vegetation in and around 

9 campsites. This would result in direct mortality of individuals in concentrated areas. Additionally, social 

trails between campsites would be likely unless campsites are set up with an existing trail network. 

11 In addition, dispersed camping by permit would occur in 25 acres of the Monument’s grasslands and 

12 shrublands (Table 11), including at Kellett Bluff and Point Colville. Effects of dispersed camping include 

13 negative short-term impacts such as crushing of vegetation from tents and visitor use associated with 

14 camping, which would result in damage and in some cases mortality. Dispersed camping would also have 

a minor negative long-term effect to areas that are highly desirable camping locations due to level 

16 surfaces and favorable views. 

17 In summary, Alternative D would have an overall negative impact on the condition of grasslands and 

18 shrublands due to the increased recreational use and the modest vegetation restoration. 

19 Rocky Balds and Bluffs 

Under Alternative D, the BLM would be unlikely to treat non-native plants that are not invasive, such as 

21 the shallow rooted non-native grasses that are currently in some rocky balds and bluffs. The probable 

22 targets (e.g., Canada thistle) for treatments are typically found in the deeper soils of grasslands and 

23 forests. Therefore, it is unlikely that damage to vegetation, including moss and lichen, would occur from 

24 herbicides or mechanical treatment in this alternative. However, non-native plants would continue to 

compete with native plants in the rocky balds and bluffs. This would be a negative long-term impact. 

26 As described above, trail miles in grasslands and shrublands would increase under Alternative D, leading 

27 to a related increase in impacts to rocky balds and bluffs associated with trail use. The BLM would 

28 continue to allow off-trail hiking under Alternative D and impacts to rocky balds and bluffs would be 

29 likely given that these areas often provide views. Off-trail travel over rocks can cause crushing and 

killing of lichens and mosses. These impacts are negative in both the short-term and the long-term. 

31 The impact of new designated site camping on rocky balds and bluffs would depend on the eventual siting 

32 of the campsites. If sites were located on rocky balds and bluffs, it would have a major long-term effect 

33 on the resources found there, including the crushing of moss and lichen due to frequent use. 

34 Conclusion 

Table 12 qualitatively summarizes the effects of the alternatives on the condition of grassland and 

36 shrubland communities. It describes each alternative as causing an improvement, decline, or no change 

37 (+,-,=) in the condition of grassland and shrubland communities compared to current conditions. 

38 Alternative C would have the most substantial long-term positive impacts due to its intensive restoration 

39 approach and limited recreational uses. The No Action Alternative and alternatives A and D would all 

cause a decline in grasslands conditions over time due to a lack of restoration treatments (in No Action 

41 and A) and their relatively extensive recreational use (in No Action and Alternative D). Alternative B 

42 would have a moderate positive impact on conditions due to its intensive restoration efforts, but would 

43 also have negative impacts due to increased dispersed camping in grassland and shrubland. 

44 Table 12: Summary of effects of the alternatives on grassland and shrubland and rocky balds and 

bluffs 

97 
No Action 

Alternative Alternative A Alternative B 

Alternative 

C/Sub-C Alternative D 

Diversity and cover of 

native grassland species - - + + -

Rocky balds and bluffs - - + + -

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 

2 Cumulative effects of the alternatives on grasslands and shrublands in the San 

Juan Islands 

Throughout the Puget Lowland Ecoregion, which includes the San Juan Islands, both native and nonnative grasslands are at an estimated 9 percent of pre-Euro-American settlement levels (Chappell et al. 

2000). The Monument currently encompasses approximately 1 percent of the Southern Vancouverian 

Lowland Grassland and Shrubland occurring within the San Juan Islands. All grassland and shrubland in 

the San Juan Islands fall into this class. 

Outside of the Monument planning process, other projects have the potential to benefit native grassland 

communities in the San Juan Islands. On June 5, 2012, the National Park Service published a notice of 

intent to prepare a Prairie Stewardship Plan and Environmental Impact Statement for the San Juan Island 

National Historical Park (National Park Service 2012). This would include restoration occurring in close 

roximity to the Monument land at Cattle Point. The Nature Conservancy has ongoing restoration 

rojects on 11-acre Yellow Island, which has a small amount of grasslands. 

nder the No Action Alternative and Alternative A, there would be an estimated 17 acres of grasslands 

nd shrublands lost. This would decrease the total extent of this vegetation class in the San Juan Islands 

y 0.2 percent. The Monument would continue to include about 1 percent of grasslands and shrublands in 

he San Juan Islands. In addition, the condition of grasslands and shrublands would likely decline over 

ime under this alternative and would contribute to the overall regional decline of this habitat. 

nder Alternative B, there would be an estimated 394 acres of grasslands and shrublands gained, which 

ould increase grasslands and shrublands in the San Juan Islands by approximately 4 percent. The 

iversity and cover of the native plant community in Monument grasslands and shrublands would 

mprove over the life of the plan and provide some counter to the overall regional decline of this habitat. 

nder Alternative C, there would be an estimated 361 acres of grasslands and shrublands gained, which 

ould increase grasslands and shrublands in the San Juan Islands by approximately 3 percent. The 

iversity and cover of the native plant community in Monument grasslands and shrublands would 

mprove over the life of the plan, and would provide some counter to the overall regional decline of this 

abitat. Under Sub-Alternative C, there would be long-term improvement in the diversity and cover of 

he native plant communities. This would be after a longer period of short-term disturbance that would be 

ecessary to ensure invasive species removal without herbicides. 

nder Alternative D, the Monument would continue to encompass approximately 1 percent of the 

rassland and shrubland vegetation in the San Juan Islands. The current level of invasive plant cover in 

he Monument would remain. Given the increased trail mileage under this alternative, the dispersal of 

nvasive plant species throughout the San Juan Islands might increase due to more dispersed visitor traffic 

ith limited treatment of invasive plants. 

earshore Habitat and Nearshore Marine Plant Communities 

hile BLM administration, and so inclusion in the Monument, only applies above mean high tide, this 

ocument considers potential indirect effects on the condition of the nearshore marine environment

urrounding the Monument. The alternatives vary in several ways that would affect nearshore habitat. 

pecifically, they vary in the recreational uses, road and trail networks, shoreline stabilization techniques, 

nd projected extent of vegetation treatments that could influence sediment deposition in nearshore habits 

r, in the case of boat landing, cause direct impacts to these communities (Table 13). 

p

p

U

a

b

t

t

U

w

d

i

U

w

d

i

h

t

n

U

g

t

i

w

N

W

d

s

S

a

o

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

98 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The BLM assumes that an increase in vegetation treatments and/or road and trail miles in close proximity 

(200 feet) of nearshore habitats would lead to some increase in sediment deposition in these habitats. 

This sediment contribution distance is a conservative estimate based on forest floor travel from a culvert 

outlet (Dubé et al. 2004); sediment quantities would decrease exponentially after traveling from a source. 

It is not clear precisely how much of the sediment produced from trails would reach nearshore marine 

environments below mean high tide, due to abundant vegetation, duff, and porous surface soils between 

most trails and shorelines. Figure 4 compares the estimated annual treatment acres within 200 feet of the 

shoreline under each alternative. For effects from herbicide use, see Habitat and Plants Issue 6. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

0 

50 

100 

150 

200 

250 

300 

350 

400 

450 

Estimated average acres per year

Mechanical 

Herbicide 

Biological 

Prescribed Fire 

11 Figure 4: Estimated average treatment acres within 200 feet of shoreline per year 

12 Note: 27 percent of the Monument falls within 200 feet of the shoreline. The BLM assumed that 27 

13 percent of estimated treatment acres would occur within 200 feet of the shoreline. 

14 Table 13: Recreational activities that could affect nearshore habitat by alternatives 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

Shoreline open to recreational boat 

landing (miles) 21.2 0 16.4 17.8 21.2 

Roads open to public motorized 

access within 200 feet of nearshore 0.1 0* 0.1 0* 0* 

habitat (miles) 

Trails open to public access within 

200 feet of nearshore habitat (miles) 8.7 0 9.4 6.3 12.3 

15 *The BLM would close the 0.1 mile of existing road within 200 feet of the shoreline under alternatives A,

C, and D, but would maintain it under all alternatives for authorized and administrative purposes. 

No Action Alternative 

Under the No Action Alternative, vegetation treatments would continue to be limited to hazard tree 

removal and limited mechanical treatments of invasive species (approximately 20 acres per year). This 

level of treatment would continue to cause negligible sediment delivery to nearshore habitats. 

Under this alternative, 0.1 miles of Monument road at Turn Point (Stuart Island) would continue to be 

open to public motorized access within 200 feet of the shoreline; this road segment would likely continue 

16 

17 

18 

19 

20 

21 

22 

99 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 to be used almost exclusively for administrative purposes. There would also continue to be 8.7 miles of 

trails within 200 feet of the Monument shoreline (Table 13). All trails would continue to be open to all 

non-motorized uses, though hiking would likely continue to be the predominant mode of travel. These 

trails would continue to contribute approximately the current level of sediment to nearshore habitats. 

Under the No Action Alternative, recreational boat landings could continue on all 21.2 miles of 

Monument shoreline. The number of landings would vary depending on the accessibility of the area and 

the approachability of the site. The BLM has no jurisdiction over boat mooring below mean high tide; 

however, the Monument would likely continue to draw visitors to moor at nearby sites. At the points of 

impact, boat landings and temporary moorings would lead to site-scale physical removal of plants such as 

eelgrass and bull kelp and disturbance of forage fish spawning sites (NOAA 2012, Pentilla 2007). 

The BLM would continue to undertake shoreline stabilization as needed basis to protect cultural 

resources. While the BLM has only undertaken a limited amount (<0.1 mile of shoreline) of soft 

stabilization in the past, there are no existing plan decisions prohibiting hard shoreline stabilization. 

Impacts from soft stabilization projects would be relatively minor. Soft stabilization allows for the 

continued circulation of sediment, replaces unstable areas with native vegetation, and increases 

complexity through the placement of large logs. If applied, hard stabilization would lead to permanent 

removal of coastal strand and headland habitat in the stabilization footprint. Additionally, hard 

stabilization would lead to impacts associated with increased sediment delivery and reduced sediment 

detention (i.e., loss of accretion), reflected wave energy, and modified sand circulation/deposition 

(WDOE 2014). These indirect impacts would likely include increased disturbance and turbidity (i.e., 

cloudiness), which could lead to removal of adjacent nearshore habitat such as seagrass beds. 

In summary, under the No Action Alternative, many nearshore communities within close proximity to the 

Monument would continue to be of moderately high quality. However, continued low levels of 

disturbance from recreational boat landing, small non-point source water quality impacts, small amounts 

of sediment delivery from nearby roads and trails would affect some nearshore habitats, particularly those 

with limited flushing or high use such as Watmough Bay (Christiaen et al. 2017). 

Alternative A 

Similar to the No Action Alternative, under Alternative A, the BLM would undertake negligible 

vegetation treatments that would affect nearshore habitat. Thus, succession would be the primary driver 

of changes in vegetation conditions in Monument lands adjacent to nearshore habitats. Although 

numerous non-native plants are present areas adjacent to nearshore environments, the majority of these 

species (e.g., tall fescue) are fully capable of stabilizing soils, and their continued expansion would not 

lead to additional sediment deposition. Sediment delivery from vegetation treatments would be expected 

to remain close to historical conditions. 

Under Alternative A, no recreational use of the Monument would be allowed, though the BLM would 

continue to facilitate access for scientific, educational, cultural, and spiritual purposes. The BLM would 

close the 0.1 miles of road within 200 feet of the shoreline to public motorized access, though it would 

continue to maintain it for administrative use. The BLM would maintain trails as needed for authorized 

and administrative purposes; over time, the number of trail miles within 200 feet of nearshore habitats 

would decrease as trails returned to a natural state. Although some sources of sediment would remain, the 

vast majority of Monument trails would become vegetated quickly following restriction of access. Thus, 

Alternative A would produce less sediment delivery to nearshore habitats than the No Action Alternative. 

Under this alternative, no recreational boat landings would occur on Monument shorelines. The annual 

number of landings would be dramatically reduced to only those necessary for authorized and 

administrative uses. This would minimize physical disturbance (including mechanical removal of plants), 

and allow nearshore plant cover (e.g., eelgrass beds) to persist or increase in currently disturbed areas. 

Restriction of boat landings would reduce non-point source toxicant impacts associated with fuel leaks. It 

would also minimize direct impacts to nearshore habitat in Watmough Bay, which is the single most 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

100 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 important forage fish spawning habitat area adjacent to the Monument. Minimization of disturbance 

would increase the quality and productivity of the nearshore habitats adjacent to Monument shoreline. 

Nearshore habitat (particularly seagrass beds) decline in Watmough Bay appears to be due to water 

quality more than disturbance (Christiaen et al. 2017); thus, improvement would be expected to be minor. 

The BLM would only undertake soft stabilization to protect cultural resources under Alternative A. 

Impacts from soft stabilization projects would be the same as under the No Action Alternative. 

In summary, under Alternative A, nearshore communities within close proximity to the Monument would 

continue to be of moderately high quality and would undergo minor improvement based on a reduction in 

disturbance and sediment deposition related to recreational boat landing and erosion from trails. 

Alternative B 

Under Alternative B, the BLM—likely working with tribes and other partners—would undertake 

extensive vegetation treatments to enhance limited plant communities and increase species and structural 

diversity (see Figure 4). Treatment locations would be determined during implementation. 

Most areas treated would retain or quickly develop deep-rooted vegetation to prevent soil erosion. 

However, due to the estimated acres of treated area and removal of erosion-preventing plants, it is likely 

that increased sediment would reach nearshore habitat (WDOE 1993). Approximately 27 percent of the 

Monument lies within 200 feet of the shoreline, and ground disturbance would occur in much of this area 

during vegetation treatments. Alternative B would treat the largest extent (total acres), but Alternative C 

would involve more repeated treatments. Thus, Alternative B would deliver the second-most sediment 

associated with vegetation treatments to nearshore areas. Once new plant communities became 

established, sediment delivery would be reduced to approximately current levels. 

Under this alternative, 0.1 miles of Monument road at Turn Point would continue to be open for public 

motorized access within 200 feet of nearshore habitat, though, if current trends continue, it would be used 

almost exclusively for administrative access. There would be an increase of approximately 0.6 miles of 

trails within 200 feet of the Monument shoreline compared to existing trail conditions (see Table 13). 

These trails would be open only to hiking. This approximately 7 percent increase in trails within 200 feet 

of the Monument shoreline would minimally increase the contribution of sediment to nearshore habitats 

compared to current conditions. 

Under this alternative, the BLM would continue to allow recreational boat landings on 16.4 miles of 

Monument shoreline. This activity would be prohibited in all marine rocks and at Watmough Bay (see 

Appendix O for Category A Rocks, Category B Rocks, and Watmough Bay RMA frameworks). 

The prohibition on recreational boat landings at Watmough Bay would minimize direct impacts to the 

single most important forage fish spawning habitat area adjacent to the Monument. The closure of rocks 

would further limit impacts to rocky intertidal and littoral zone resources. Impacts to the 16.4 miles of 

Monument shoreline that remain open to recreational boat landings would be the same as under the No 

Action Alternative. Thus, under Alternative B disturbance to littoral zone resources would decline 

compared to current conditions; there would be more disturbance than would occur under Alternative A. 

Under Alternative B, the BLM could undertake hard shoreline stabilization, in addition to soft 

stabilization, as needed to protect cultural resources. Given the greater ecological impacts of hard 

stabilization, soft stabilization is likely to be used in most cases. The impacts of hard and soft 

stabilization are described under the No Action Alternative. 

In summary, under Alternative B, nearshore communities in close proximity to the Monument would 

experience increased sediment deposition from vegetation treatments and trails. Locations that are closed 

to recreational boat landing would be less disturbed than the current condition. The combination of 

increased sediment delivery, reduced physical disturbance, and reduced pollution and toxicant delivery in 

some nearshore areas (particularly Watmough Bay) would lead to a slight reduction in quality for most 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

101 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 nearshore habitat adjacent to the Monument, with habitat condition improvement in areas with restricted 

boat landings. Sediment impacts would be predicted to decrease over the life of the plan. 

Alternative C 

Under Alternative C, the BLM—likely working with tribes and other partners—would undertake 

extensive treatments to approximate historic vegetation conditions within the Monument (see Figure 4). 

Most areas treated would retain or quickly develop deep-rooted vegetation to prevent soil erosion. 

However, due to the estimated acres of treated area and removal of plants, it is likely that increased 

sediment would reach nearshore habitat. Approximately 27 percent of the Monument lies within 200 feet 

of the shoreline, and ground disturbance would occur in much of this area during vegetation treatments. 

Sediment delivery would likely be somewhat less than under Alternative B and Sub-Alternative C, but 

more than under the No Action Alternative and alternatives A and D. Once new plant communities 

became established, sediment delivery would be reduced to approximately current levels. 

The BLM would close the 0.1 miles of road within 200 feet of the shoreline to public motorized access, 

though it would continue to maintain this road segment for administrative use. Alternative C would result 

in a decrease of approximately 2.5 miles of trails within 200 feet of the Monument shoreline compared to 

existing trail conditions (Table 13). The BLM would continue to allow equestrian use on approximately 2 

miles of trail. This approximately 30 percent decrease in trail miles within 200 feet of the Monument 

shoreline would reduce the contribution of sediment to nearshore habitats compared to current conditions. 

Under this alternative, the BLM would continue to allow recreational boat landings on 17.8 miles of 

Monument shorelines. This activity would be prohibited on smaller and/or more sensitive rocks; 

motorized boat landings would be prohibited at Watmough Bay (see Appendix O for Category B Rocks 

and Watmough Bay RMA frameworks). 

The prohibition on motorized recreational boat landings at Watmough Bay would reduce the current level 

of direct impacts to the single most important forage fish spawning habitat area adjacent to the 

Monument; disturbance from non-motorized boats would continue. The closure of smaller and/or more 

sensitive rocks and rock grouping would limit impacts to rocky shoreline and littoral zone resources. 

Impacts to the remainder of the shoreline would be the same as under the No Action Alternative. Thus, 

under Alternative C, direct disturbance to littoral zone resources would decline compared to current 

conditions and Alternative D, but more disturbance would occur than under either Alternative A or 

Alternative B. 

The BLM would only undertake soft stabilization of the shoreline to protect cultural resources under 

Alternative C. Impacts from soft stabilization projects are described under the No Action Alternative. 

In summary, under Alternative C, nearshore communities in close proximity to the Monument would 

experience limited increased sediment deposition from vegetation treatments. Locations closed to 

recreational boat landing would fewer physical/ mechanical and water quality impacts than the current 

condition. As a whole, the condition of identified nearshore habitat adjacent to the Monument would be 

predicted to decline slightly in condition (quality), primarily through increased turbidity; this impact 

could be ameliorated by reduced water quality impacts associated with restrictions on boat landings. 

Sub-Alternative C 

The effects to nearshore habitats under Sub-Alternative C, would be similar to those under Alternative C. 

Under Sub-Alternative C, the acres of vegetation treatments would likely increase as the BLM attempted 

to achieve ambitious restoration objectives without the use of herbicide (see Figure 4). Treatment 

locations would be determined during implementation. 

Although total acres of vegetation treatment under Sub-Alternative C would be similar to Alternative C, 

Sub-Alternative C would produce the most sediment deposition from vegetation treatments of any 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

102 
5

10

15

20

25

30

35

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 alternative, due to intense mechanical treatments and multiple treatments required. Once new plant 

communities became established, sediment delivery would be reduced to approximately current levels. 

Alternative D 

Under Alternative D, the BLM would undertake relatively modest treatments to maintain approximate 

current conditions (see Figure 4). Treatment locations would be determined during implementation. 

Under this alternative, sediment deposition from vegetation treatments would increase slightly compared 

to current conditions, but would be substantially lower than under alternatives B and C. 

The BLM would close the 0.1 miles of road within 200 feet of the shoreline to public motorized access, 

though it would continue to maintain this road segment for administrative use. There would be an 

increase of approximately 3.5 miles of trails within 200 feet of Monument shoreline compared to existing 

trail conditions (see Table 13). The BLM would continue to allow equestrian and bicycle use on 6.7 

miles of trails. This 40 percent increase in trails within 200 feet of Monument shoreline would increase 

the contribution of sediment to nearshore habitats compared to current conditions. 

Impacts from recreational boat landings would increase slightly under this alternative. Recreational boat 

landings could continue on all 21.2 miles of Monument shoreline and the BLM would increase the 

amount of designated site camping for visitors arriving by non-motorized boat. As a result, as campsites 

are developed during plan implementation landings at these locations would likely increase. The impacts 

from recreational shoreline would be the same type as those described under the No Action Alternative, 

but the frequency of direct disturbance would increase with the rate of recreational boat landings. 

Under Alternative D, the BLM could undertake hard in addition to soft stabilization of shorelines, as 

needed to protect cultural resources outside of areas managed for their wilderness characteristics. Areas 

managed for their characteristics under Alternative D encompass 232 acres, including the east half of 

Patos Island and an array of rocks and islands. Given the greater ecological impacts of hard stabilization, 

soft stabilization is likely to be used in most cases even outside of areas with wilderness characteristics. 

Impacts from hard and soft stabilization are described under the No Action Alternative. 

In summary, given increased direct impacts from recreational boat landings and increased sediment 

deposition from trails, the condition of nearshore habitats, including density of key structural species 

(such as eelgrass) and structural components (such as sand expanses or vegetation for spawning), could be 

slightly reduced under Alternative D compared with other alternatives. 

Conclusion 

Table 14 qualitatively summarizes the effects of the alternatives on the condition of nearshore habitats. It 

describes each alternative as causing an improvement, decline, or no change (+,-,=) in the condition of 

nearshore habitats compared to current conditions. 

Alternative A would be most beneficial to nearshore habitats, as it would minimize sediment deposition, 

direct impacts from boat landings, and impacts from shoreline stabilization. Alternatives B, C, and D 

would likely cause a modest decline in nearshore habitat condition, due to increased sediment delivery. 

Under Alternative B, sediment deposition from both trails and vegetation treatments would increase and 

hard shoreline stabilization be allowed, though direct impacts from boat landings would decrease. Under 

Alternative D, sediment deposition from trails would increase as would direct impacts from boat landings. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

103 
1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 14: Summary of the effect of the alternatives on nearshore habitat 

Condition of nearshore habitat No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C /Sub- C 

Alternative 

D 

Impacts from sediment deposition = + - - -

Direct disturbance from 

recreational boat landing = + + + -

Potential disturbance from hard 

shoreline stabilization = + = + + 

2 The Cumulative Effect of the Alternatives on Nearshore Habitat in the San Juan 

Islands 

Much of the shoreline within the Puget Sound has been modified (historically and recently) for 

agricultural, industrial, and residential uses. San Juan County has the lowest modification level in the 

Puget Sound region, with around 5 percent of its shorelines modified (Herrera 2011, Friends of the San 

Juans 2011). Over 600 marine shoreline alterations are present in San Juan County (San Juan County 

2013); these modifications are part of the affected environment for the Monument and adjacent areas. 

Many relatively minor alterations to the shoreline are permitted each year; most shoreline developments 

are residential (Kuller personal communication 2017). The largest recent developments are ongoing 

projects to expand/upgrade existing marinas at Snug Harbor on San Juan Island and at the Rosario Resort 

on Orcas Island. San Juan County recently completed a feasibility study to relocate approximately 1 mile 

of the Mackaye Harbor Road, which runs along the shoreline on the south end of Lopez Island and 

provides the closest public road access to Monument land at Iceberg Point (San Juan County 2017a). 

While San Juan County has not yet determined a course of action for Mackaye Harbor Road, given the 

continuing coastal erosion and projected increases in sea level, some action to move the road is more 

likely than not. 

Given current recreation and visitation tends (see Recreation and Visitor Services Issue 1), the BLM 

assumes that recreation in the nearshore environment throughout the San Juan Islands would increase 

over the life of the plan. This would result in correlated indirect effects on nearshore habitat. 

The BLM predicts that the effects of the No Action Alternative, Alternative B, and Alternative D, 

combined with foreseeable shoreline alterations outside of the Monument and increased recreation, would 

lead to an overall decline in nearshore habitat conditions adjacent to the Monument. This negative effect 

would be associated with (in order of severity of impact): boat landings, hard shoreline stabilization, and 

indirect sediment effects. The BLM predicts that alternatives A and C would lead to overall improved 

nearshore habitat conditions adjacent to the Monument, considering both positive (restrictions on landings 

and hard shoreline stabilization) and negative (temporary increases in sediment) impacts. The BLM 

estimates that at most <1 percent of extent of nearshore habitat types would be removed (due primarily to 

hard shoreline stabilization), <5 percent of nearshore habitats would experience slightly reduced habitat 

function (due to increased boat landings and increased sediment delivery), leading to minor and mostly 

temporary changes in the function of nearshore plant communities adjacent to the Monument. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

104 
 

 

 

9

10

11

12

13

14

15

16

17

18

19

20

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Wetlands 

The alternatives vary in several ways that would affect wetland functional condition (e.g., the hydrologic, 

vegetation, and erosion/deposition attributes of wetlands, as well as to the achievement of their ecological 

potential). Wetland potential is defined as the highest ecological status a wetland area can attain, given 

no social/political constraints. Specifically, the alternatives vary in the objectives and management 

direction that would drive vegetation treatments and in the type and extent of recreational use that would 

occur near wetlands (Table 15). Figure 5 compares the estimated annual treatment acres in wetlands 

under each alternative. 

2 

3 

4 

5 

6 

7 

8 

0 

1 

2 

3 

4 

5 

6

Estimated average acres per year

Mechanical 

Herbicide 

Biological 

Prescribed Fire 

21 Figure 5: Estimated average acres of vegetation treatment in wetlands per year 

22 Table 15: Recreational activities within 25 feet and 150 feet41 of wetlands by alternative 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

Public Within 25 feet 0 0 0 0 0 

motorized use 

(road miles) Within 150 feet 0.1 0* 0.1 0.1 0.1 

Hiking Within 25 feet 0.3† 0 0.4 0.3 0.4 

(trail miles) Within 150 feet 0.9† 0 1.2 0.9 1.2 

Equestrian Within 25 feet 0.3† 0 0 0.1 0.3 

(trail miles) Within 150 feet 0.9† 0 0 0.5 1.1 

Bicycling Within 25 feet 0.3† 0 0 0 0.3 

(trail miles) Within 150 feet 0.9† 0 0 0 0.9 

23 

24 *The BLM would close all roads under Alternative A to public motorized use, but would maintain these 

25 roads, including 0.1 mile within 150 feet of wetland, for authorized and administrative purposes. 

41 Dube et al. (2004) conclude that sediment leaving a culvert or similar source and moving across 

vegetated areas (a situation conservatively comparable to the analysis area) move less than 150 feet in 

nearly all cases. The BLM specialist identified 25 feet as an appropriate buffer within to measure direct 

impacts to wetlands. See Appendix B for more information. 

105 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 † Trails are currently open to all non-motorized uses. There is currently limited equestrian use at 

Chadwick Hill and Watmough Bay. There is no regular use of Monument trails by bicycles. 

There may be some differences in sediment production between trail uses, with equestrian use appearing 

to produce the most sediment (Wilson and Seney 1994, Pickering et al. 2009). 

No Action Alternative 

Under the No Action Alternative, the BLM would continue to undertake negligible vegetation treatments 

that would affect wetlands. This analysis assumes that minimal wetland succession would occur in the 

Monument during the 20 years analyzed. Except at Point Colville, wetland vegetation attributes would 

continue to contribute to proper functioning condition over the next 20 years. The invasion of Sitka 

spruce into the Point Colville wetland would continue to contribute to that wetland functioning at risk. 

Non-native plant species would continue to represent a departure from site potential in all Monument 

wetlands. Contributions of non-point source pollution from upslope homes and agriculture would 

continue to represent a departure from site potential in some Monument wetlands. 

Under the No Action Alternative, 0.3 miles of Monument trail would be within 25 feet of a wetland; 0.1 

miles of road (at Watmough Bay) and 0.9 miles of trail would be within 150 feet of a wetland (see Table 

15). Trail miles could increase over time due to continued social trail expansion. The No Action 

Alternative includes the second-most use by equestrian and the highest potential bicycle use of trails, 

suggesting the No Action Alternative would deliver the second-highest sediment to Monument wetlands. 

Wetlands would continue to intercept sediments from trail-surface erosion and small amounts of toxicants 

from road and trail users—including, oils and gasoline from the Watmough Bay road and parking area 

and sunscreen, insect repellant, and other toxicants (Reidell 2006)—at approximately current rates. 

Sediment loads leaving trail surfaces would be approximately 1,500 pounds/ac./year (Reidell 2006), or 

approximately 750 pounds/year for all trails within proximity (150 feet) of wetlands in this alternative. 

Given that the depth of wetlands nearest to trails is over 3 feet and the fact that most trails are more than 

25 feet away, sediment delivery would continue to have a minor to negligible impact on wetland function. 

Sediment and toxicant introduction from road and trail use would have a very small indirect impact to 

wetland hydrology and erosion/deposition. This continued small contribution to sediment load would be 

unlikely to change soil saturation, water percolation, or wetland classification (e.g., emergent or open 

water status). Accumulation of sediment and toxicants would not affect wetland plant productivity or 

composition. Based on these factors, the BLM assumes that the continuation, or slight increase, of the 

level of recreational use near wetlands would not constrain wetland enlargement, impact wetland water 

quality enough to limit riparian-wetland plants, or impact flow patterns. Similarly, trail use adjacent to 

wetlands would continue to lead to negligible increases in chemicals and no impact on soil saturation in 

adjacent areas. Thus, wetland hydrology and erosion/deposition attributes would be similar to current 

conditions described above. 

In summary, under the No Action Alternative, all Monument wetlands that are currently in proper 

functioning condition would most likely continue in this status over the next 20 years (see affected 

environment section). The continued lack of vegetation management under this alternative would allow 

the tree invasion at Point Colville to continue, further reducing wetland vegetation diversity and cover by 

wetland plants, and perhaps reducing the amount of soil saturation in this wetland. This is unlikely to 

result in substantial additional departure from wetland potential over the next 20 years, due to the slow 

pace of invasion, and the possibility of natural disturbance (wind throw) mitigating this invasion. 

Movement towards potential is unlikely due to the continued presence of non-native species. 

Alternative A 

Similar to the No Action Alternative, under Alternative A, the BLM would continue to undertake 

negligible vegetation treatments that would affect wetlands and would not apply herbicide. Only 

succession would actively change vegetation components of properly functioning condition. Except at 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

106 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Point Colville, the vegetation attributes of the Monument’s wetlands would continue contributing to 

proper functioning condition over the life of the plan. The invasion of Sitka spruce into the Point Colville 

wetland would continue to contribute to that wetland functioning at risk. Non-native plant species would 

continue to represent a departure from site potential in all Monument wetlands. 

Under Alternative A, the BLM would not allow recreational use of the Monument, though it would 

facilitate access for authorized scientific, educational, cultural, and spiritual uses. The BLM would 

continue to maintain the 0.1 mile of road at Watmough Bay, which is within 150 feet of the Watmough 

marsh, for authorized and administrative purposes. The BLM would only maintain trails for regular 

authorized and administrative uses; as a result, the miles of trails within 25 and 150 feet of wetlands 

would decline over time as they return to a natural state due to lack of use. 

Since trail use and density would decrease from the current condition, the BLM assumes that trail use 

would not constrain wetland enlargement, impact water quality, or impact flow patterns under Alternative 

A. Decreasing road and trail use would reduce the amount of toxicants introduced into wetlands. Thus, 

wetland hydrology and erosion/deposition would be similar to or improved compared to current 

conditions. This could improve wetland composition by allowing plant richness to increase from low (but 

sufficient to dissipate energy and filter sediment) to conditions closer to historic reference conditions. 

In summary, under Alternative A, the wetlands currently achieving proper functioning condition would 

continue to do so and would come closer to achieving full potential due to the decline in trail density and 

use. The lack of vegetation management under this alternative would allow the tree invasion at Point 

Colville to continue, further reducing wetland vegetation diversity and perhaps reducing the amount of 

soil saturation in this wetland. This is unlikely to result in substantial additional departure from wetland 

potential over the life of the plan, due to the slow pace of invasion, and the possibility of natural 

disturbance (wind throw) mitigating this invasion. 

Alternative B 

Under Alternative B, the BLM—likely working with tribes and other partners—would undertake 

extensive work to enhance the condition and extent of wetlands (see Habitat and Plants Issue 3 for 

estimated treatment types and acres). Approximately 30 acres of the Monument that are currently 

classified as forest and woodland would be modified to support wetland characteristics, bringing the 

Monument’s total wetland acres to approximately 75. Treated acres would enlarge existing wetlands. 

Wetland creation would require excavation and planting, and loss of existing forest plant communities. 

Under this alternative, the BLM would treat current and new wetland acres to maintain or improve 

wetland function. To accomplish this objective, the BLM is likely to undertake treatments including 

herbicide application and planting of native wetland plugs. The BLM would also likely use mechanical 

treatments and, as useful, prescribed fire, to remove invading overstory trees that are reducing wetland 

function. Work to expand wetlands would have short-term negative impacts on existing wetland acres. 

Over the life of the plan, however, restoration work would improve wetland function and composition by 

improving vegetation age-class diversity and vigor and removing non-native and invading species. 

Newly created wetland acres would initially have reduced function compared to existing wetland acres. 

There would be potential short-term water quality impacts from work to establish wetlands, and it would 

take time for new wetland acres to develop an age-class distribution of wetland plants with root masses 

capable of withstanding disturbance. Within 2 years, planted wetland vegetation would grow and be 

predicted to have high vigor and the ability to dissipate energy and filter sediment (Prichard 1999, p. 7). 

Under Alternative B, there would be a 0.1-mile increase in trails within 25 feet of a wetland and a 0.3-

mile increase in trails within 150 feet of a wetland. There would continue to be 0.1 miles of road within 

150 of a wetland (see Table 15). The BLM would not allow off trail hiking, so proliferation of user 

created trails should be negligible. All trails would be open exclusively to hiking. Miles of trail within 

wetland buffer areas would increase somewhat as wetland acres expanded over the life of the plan. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

107 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The effect on wetland function from the 0.1 miles of road at Watmough Bay within 150 feet of a wetland 

would be the same as under the No Action Alternative. Impacts from trail use within 25 feet and 150 feet 

of a wetland would also be similar to the No Action Alternative (i.e., some deposition of sediment and 

toxicants in wetlands), but an additional 850 pounds/year of sediment would be associated with new trail 

area. This small increase in sediment would not be sufficient to change soil saturation, water percolation, 

or wetland classification (e.g., emergent or open water status) in existing or created wetland acres. 

Accumulation of sediment and toxicants would not affect wetland plant productivity or composition. 

Additional impacts from new trails would be slight and the BLM would not expect them to change the 

ratings of wetlands currently assessed as achieving proper functioning condition or as functioning at risk. 

In summary, under Alternative B, treatments to enhance vegetation age-class diversity and vigor and 

remove non-native and invading species would cause an increase in the acres of existing wetland meeting 

properly functioning condition and a decrease in acres classified as functioning at risk over the life of the 

plan (i.e., at Point Colville). Wetland acres at potential would increase over time, though roads and trails 

(both new and existing) would ultimately constrain the potential of some wetlands. 

Alternative C 

Under the objectives for Alternative C, the BLM—likely working with tribes and other partners—would 

undertake extensive work to improve the condition of wetlands within the Monument in an attempt to 

approximate historic conditions (see Habitat and Plants Issue 3 for estimated treatment types and acres). 

Unlike Alternative B, the BLM would not enhance the size of wetlands under this alterative. 

Under Alternative C, the BLM would use mechanical, manual, biological control, chemical, and fire 

treatment methods to approximate historic wetland conditions. This would include elimination of nonnative vegetation in wetlands and removing invading overstory trees that are reducing wetland function. 

Over the life of the plan, these treatments would increase native wetland plant composition, vigor, and 

age class distribution. These treatments would have negligible impact on wetland hydrology or 

erosion/deposition. Treatment types under Alternative C would be comparable to Alternative B, with the 

exception of excavation, which would not occur under Alternative C. 

Under Alternative C, trails throughout the Monument would decrease; trail miles within 25 feet of a 

wetland would increase very slightly (<0.1 mile) and trail miles within 150 feet of a wetland would 

decrease very slightly (<0.1 mile). The BLM would not allow off trail hiking, so proliferation of user 

created trails should be negligible. Because there would be effectively no change in trails, the impact to 

wetland function and composition would be the same as the No Action Alternative. 

Under Alternative C, 0.1 miles of trail within 25 feet of a wetland and 0.5 miles of trail within 150 feet of 

a wetland would continue to be open to equestrian use (see Table 15). Monument trails are currently 

open to all non-motorized uses; it is possible that explicit management of certain trails for equestrian use 

would increase participation in this activity. Equestrian trail use may produce more sediment than other 

trail uses (Pickering et al. 2009). The BLM would allow this use on a limited number of trails under 

Alternative C, but on fewer trails than under the No Action Alternative or Alternative D. 

In summary, under Alternative C, the BLM would expect all Monument wetlands (i.e., 42 acres) to 

achieve proper functioning condition over the life of the plan. Most of these wetlands would move closer 

to potential through treatments to approximate historic conditions. 

Sub-Alternative C 

The effects to wetland condition under Sub-Alternative C would be similar to those under Alternative C, 

but less positive. Sub-Alternative C would produce wetland conditions comparable to conditions in the 

affected environment, with approximately the current amount of wetland area achieving proper 

functioning conditions (i.e., 40 acres) and functioning at risk (i.e., 2 acres). However, few to none of the 

Monument’s wetlands would achieve potential under this alternative. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

108 
 

 

 

 

 

 

 

 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Mechanical removal of invading Sitka spruce at Point Colville would be effective, but any invading 

understory species would be difficult to control without herbicides. Although some invasive non-native 

wetland plants can be controlled through biological control—or, on small spatial scales, through 

mechanical control—without herbicide treatments it is likely that non-native species would continue to 

increase. While they have only small impact on wetland function, these non-native species represent a 

departure from site potential, as well as from historic conditions. 

Alternative D 

Under Alternative D, the BLM would undertake treatments to maintain wetlands in approximate current 

condition (see Habitat and Plants Issue 3 for estimated treatment types and acres). Unlike Alternative B, 

the BLM would not enhance the size of wetlands under this alterative. Since negligible succession would 

occur in wetlands over the life of the plan, management in these wetlands would include minor control 

efforts to maintain invading non-native and native species at their approximate 2016 levels. Some 

wetland treatments would likely be necessary to counteract impacts from the elevated level of recreation 

disturbance under Alternative D (see below). 

Roads and trail miles within 25 feet and 150 feet of a wetland would be approximately the same as under 

Alternative B. There would be a 0.1-mile increase in trails within 25 feet of a wetland and a 0.3-mile 

increase in trails within 150 feet of a wetland. There would continue to be 0.1 miles of road within 150 

feet of a wetland. The BLM would continue to allow off trail hiking under this alternative, so some 

proliferation of user created trails could continue. As described under Alternative B, trail use could lead 

to a slight increase in sediment and toxicant deposition in wetlands. 

Under Alternative D, 0.3 miles of trail within 25 feet of a wetland would continue to be open to 

equestrian and bicycle use. Within 150 feet of a wetland, 1.1 miles of trail would continue to be open to 

equestrian use and 0.9 miles of trail would continue to be open to bicycle use (see Table 15). Monument 

trails are currently open to all non-motorized uses; it is possible that explicit management of certain trails 

for equestrian use would increase participation in this activity. Of the action alternatives, Alternative D 

would have the highest number of trail miles open to equestrian use and would be predicted to produce 

the most sediment from trail use of any alternative (Wilson and Seney 1994, Pickering et al. 2009). 

In summary, under Alternative D there would continue to be approximately the current amount of wetland 

area achieving proper functioning conditions (i.e., 40 acres) and functioning at risk (i.e., 2 acres), due to 

management efforts to retain current conditions. The Monument’s wetlands would continue to not

achieve potential over the life of the plan due to the lack of management action to improve wetlands and 

the increase in trail disturbance. 

Conclusion 

Table 16 qualitatively summarizes the effects of the alternatives on wetlands. It describes each alternative 

as causing an improvement, decline, or no change (+,-,=) in wetland condition compared to current 

conditions. 

Alternative C would lead to all existing Monument wetlands achieving proper wetland function and at or 

approaching potential. Alternative B would increase the total number of wetland acres, and the total 

number of acres in proper functioning condition, though not all created wetland areas would be expected 

to be achieve proper functioning condition within the life of the plan. The No Action Alternative—by 

continuing negligible wetland treatments and current levels of recreation—would result in the least 

amount of wetland acres achieving proper functioning condition and approaching potential. 

Table 16: Summary of the effects of the alternatives on wetland condition 

109 

Impact to wetland No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C 

Alternative 

D 

Proper functioning condition = = + + = 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Movement towards potential = + + + = 

1 The Cumulative Effect of the Alternatives on Wetlands in the San Juan Islands 

Freshwater wetlands are relatively limited in the San Juan Islands. Approximately 20 percent of the 

wetland resources in the San Juan Islands have been classified as potentially disturbed (WDOE 2011b). 

The following actions would affect the size and condition of wetland habitat in the San Juan Islands: 

private filling of wetlands for development, private creation and enhancement of wetland areas for 

wetland mitigation, State and Federal wetland enhancement and creation (e.g., work at Odlin Park). 

In recent years, San Juan County and private landowners in the islands have undertaken wetland 

enhancement and creation on Lopez Island. Private landowners, working with Ducks Unlimited, intend 

to continue projects to enhance and create wetlands. Because of this, it is reasonably foreseeable that the 

total acreage of wetland in the San Juan Islands will increase over the life of the plan. 

Development of wetlands is regulated by the Clean Water Act and State regulations including the Joint 

Aquatic Resources Permit Application. The BLM does not know of any major new private development 

projects that would require wetland mitigation in the planning area. 

The Monument currently encompasses approximately 1 percent of the Vancouverian Flooded and Swamp 

Forest and approximately 6 percent of the Vancouverian Lowland Wet Shrubland, Wet Meadow, and 

Marsh in the San Juan Islands. This would remain unchanged except under Alternative B, where the 

Monument’s contribution to wetlands in the San Juan Islands would increase by 33 acres and would 

represent approximately 2 percent and approximately 10 percent of these wetland classes respectively. 

None of the alternatives would cause Monument wetlands to fall into a non-functioning condition; under 

alternatives A, B, and C, the condition of wetlands within the Monument would move closer to potential. 

Habitat and Plants Analytical Issue 3: How would the alternatives vary in the 

approximate extent and type of vegetation treatments the BLM would apply 

during their implementation? 

See Appendix B for analytical methods used in this analysis. See the Habitat and Plants Analytical Issue 

3 section in Appendix E for definitions of the types of treatments described in this section (i.e., 

mechanical, biological, prescribed fire, and herbicide). 

Affected Environment 

Vegetative treatments within the Monument are currently limited to hazard tree management and the 

limited treatment of invasive plant populations with hand tools. In total, the BLM undertakes 

approximately 20 acres of vegetation treatments per year. There is currently no prescribed fire, 

biological, or chemical (e.g., herbicide) treatments occurring within the Monument. 

Effects of the Alternatives 

The alternatives vary substantially in the vegetation treatments that would be necessary to meet their 

objectives for habitat and plant communities. The acres of treatments estimated here are not management 

direction. The actual locations, sizes, and management tools used would be determined during the 

implementation-level planning and NEPA compliance processes. 

The acres described below are conservative estimates (i.e., they are likely somewhat higher than the 

acreages of treatment that would take place). In many cases, the described treatments would take place 

on the same acres of land. For example, mechanical or manual treatments to remove woody shrubs and 

subsequent planting of native plants would be likely to take place in the same area. Similarly, the same 

acres could undergo mechanical or manual treatments before and after a prescribed fire. 

Under all alternatives, the BLM would plant and seed after treatments, as necessary. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

110 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 No Action Alternative 

2 Under the No Action Alternative, the BLM would continue its current custodial management approach 

3 with approximately 20 acres per year of hazard tree management and non-ground disturbing invasive 

4 plant treatment. If current trends continue, there would be no prescribed fire, biological, or herbicide use. 

5 Alternative A 

6 Table 17 provides an overview of the treatment acres and repetition rates the BLM estimates would be 

7 necessary to achieve the Alternative A vegetation objectives. The table is followed by a description of the 

8 types of treatments the BLM might undertake. See page 17 in Chapter 2 for Alternative A habitat and 

9 plants objectives. The BLM does not project that the plant communities would cross the Alternative A 

10 extent thresholds identified in Chapter 2 during the life of the plan (see Table 7 on page 75). Given that 

11 some plant communities within the Monument had 45 percent non-native cover in 2014 (BLM 2014a), 

12 the invasive plant threshold identified in Chapter 2 is likely to be crossed within the life of the plan. 

13 Table 17: Estimate of treatment acres under Alternative A 

Mechanical Treatment Biological Treatment 

Acres # of treatments over 20 

years 

Acres # of treatments over 20 

years 

Grassland & Shrubland 

Treatment to reduce/ 

control non-native plants 65 10 65 6 

Average Annual Acres 

over 20 years 33 20 

Total Acres 650 390 

14 Note: these acres are the BLM’s estimates of the extent and repetition of vegetation treatments that might

15 be necessary to achieve the alternative’s objectives. The actual extent, type, and timing of treatments 

would be determined during plan implementation through project-level planning and NEPA compliance. 

Forest and Woodland 

Other than for hazard trees, vegetation treatments in forest would be unlikely under Alternative A. 

Grassland and Shrubland 

In order to control invasive plants, treatments in grasslands under Alternative A could include cutting, 

grubbing, mowing, brushing, trimming, weed eating, hand pulling, pulling with tools, and clipping. The 

BLM would prohibit herbicides, so mechanical treatments would be relatively frequent, especially for 

rhizomatous species such as Canada thistle and blackberry. 

Biological treatments would use either livestock, such as goats, to target dense patches of invasive plants 

or APHIS approved biological agents, for species, such as Canada thistle, with approved agents. 

Wetland 

Vegetation treatments in wetlands are unlikely under Alternative A. 

Alternative B 

Table 18 provides an overview of the treatment acres and repetition rates the BLM estimates would be 

necessary to achieve the vegetation objectives for Alternative B. The table is followed by a description of 

the types of treatments that the BLM might undertake to achieve the objectives. 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

111 
 

 

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 18: Estimate of treatment acres under Alternative B 

Mechanical 

Treatment 

Herbicide 

Treatment 

Biological 

Treatment Prescribed Fire 

# of 

Acres treatments 

over 20 years 

# of 

treatments Acres over 20 

years 

# of 

treatments Acres 

over 20 

years 

# of 

treatments Acres over 20 

years 

Forest & woodland 

Treatment to maintain or 1.5 (repeated 

400 twice for half 63 3 

open canopy the acres) 

Treatment of forest 

understory 200 2 100 2 

Grassland & shrubland 

Treatment to reduce or 

eliminate woody shrubs 200 5 200 5 200 2 

Treatment to reduce 

encroaching trees 410 2 50 5 50 2 

Treatment to reduce/ 

control non-native plants 100 5 200 5 300 5 200 3 

Treatment to restore 

native plants 500 5 135 3 

Wetland 

Treatments to restore 

existing wetlands 3 2 5 3 1 3 

Planting to facilitate 

development of functional 2 2 

wetlands 

Treatment to expand 

wetlands 33 3 33 3 3 2 5 2 

Average Annual Acres 

over 20 years 296 128 75 85 

Total Acres 5,929 2,564 1,509 1,704 

2 Note: these acres are the BLM’s estimates of the extent and repetition of vegetation treatments that might

be necessary to achieve the alternative’s objectives. The actual extent, type, and timing of treatments 

would be determined during plan implementation through project-level planning and NEPA compliance. 

Forest and Woodland 

In order to enhance older forest characteristics and oak woodlands under Alternative B, as well as to 

enhance resistance to and resilience from fire and other disturbances, the BLM would undertake 

treatments affecting the forest canopy and understory. 

Treatments in forests and woodlands could include canopy and low thinning to reduce canopy cover, and 

lighter thinning (mostly low thinning) to maintain canopy cover, using feller bunchers, chainsaws, hand 

tools, and/or prescribed fire. Accessible areas would have cut materials removed to reduce fire danger. 

Treatments to thin understory trees and brush enhance older forest characteristics and tree woodlands 

including oak woodlands, could include cutting, mowing, chipping, pulling, clipping, herbicide 

application, and prescribed burning. Some woodland treatments would result in tree savannas. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

112 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Grassland and Shrubland 

In order to enhance the extent of grasslands and maximize native grassland species richness under 

Alternative B, the BLM would undertake a variety of treatments to remove trees, control invasive plant 

species, remove woody shrubs, and restore native plants. This alternative would not eradicate shrubs, but 

would remove them to the extent necessary to maximize species richness and structural diversity of forbs. 

Treatment of woody shrubs could include removal of both above and below ground structures of rose, 

snowberry, blackberry, and other shrubs using cutting tools as well as digging. Broadcast burning could 

be used to clear above ground biomass of woody shrubs; this would kill some species, but some may resprout. The BLM would likely use herbicides to kill below ground shrubs following above ground 

removal, especially in culturally sensitive areas where ground disturbance is not recommended. 

Treatments to remove trees and convert understory of current forest to grasslands and shrublands and tree 

savannas could involve mechanically cutting trees and removing stumps as well as non-grassland shrubs 

such as salal. The BLM would likely remove young trees that seed into grassland edges mechanically by 

cutting them with saws close to the soil surface. The BLM could apply herbicides to trees and nongrassland understory plants in areas identified for conversion to grassland. Prescribed fire could be used 

to remove residual forest species, control tree encroachment, and maintain grasslands once established. 

Treatments to control non-native plants could include mowing thick stands of non-natives or hand-cutting 

individual plants. The BLM would likely apply herbicide via backpack sprayers and would target 

noxious and invasive weeds. Prescribed fire in the form of broadcast burns could be applied to kill nonnative plants after grasslands are expanded. The disturbance created by the conversion of forest to 

grassland under this alternative would create opportunities for invasive plants, requiring relatively 

extensive and frequent treatments for invasive plants. Biological treatments using livestock, such as 

goats, could be used to target dense patches of invasive plants. APHIS approved biological agents could 

also be used to control species, such as Canada thistle, with approved agents. 

Treatment to restore native plants could include planting native grass and forb plugs in grasslands. Native 

seed could be broadcast and raked in or drill seeded to increase diversity. The BLM would also likely use 

prescribed fire to prepare a site for planting and maintaining grassland habitat. Planting and seed mixes 

would include culturally important plants as appropriate to the site. 

Wetland 

In order to enhance the extent of wetlands and maximize native hydrophytic (i.e., aquatic) plant species 

richness and wetland processes (e.g., anaerobic conditions) under Alternative B, the BLM would 

undertake a variety of treatments to expand wetland acres and restore existing wetlands. 

Treatments to restore existing wetlands could include mechanical removal of over-story trees invading 

wetlands using chainsaws. Hand application (wicking, wiping) of herbicide approved for aquatic uses by 

the EPA and the BLM could be used to control invading non-native species such as reed canary grass, 

yellow flag iris, Canada and Scotch thistle, and poison hemlock. APHIS approved biological agents 

could also be used to control species, such as Canada thistle, with approved agents. 

Mechanical actions could include removal of vegetation and excavation to allow for low-density planting 

of individual plugs (seedlings) in order to increase native wetland species richness in areas dominated by 

one or few species (e.g., Carex obnupta at the Point Colville wetland). Plantings could include native 

grown seedlings such as soft rush (Juncus effusus) or forbs (Angelica genuflexa, Stachys cooleyea). In 

general, seeding, as opposed to planting, is unlikely to be used in existing wetlands since competition 

with existing wetland species (mostly native) would be high and seed germination and survival low. 

Mechanical treatments to increase the total size of wetlands could include excavation of existing upland 

and forested areas. Excavation could remove soil to achieve elevations producing a range of conditions 

from lake with vegetated bottom to emergent wetland with hydric soils and hydrophytic plants but dry 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

113 
 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 conditions for much of the summer. Excavation could require medium tracked excavators and could 

2 focus on the upland perimeters of existing wetlands. 

3 The BLM could apply prescribed fire to control non-native rhizomatous species in newly-created 

4 wetlands. Hand application (wicking, wiping) of herbicide approved for aquatic uses by the EPA and the 

5 BLM could be used to minimize establishment of invasive plant species in newly-created wetlands. 

6 Alternative C 

7 Table 19 provides an overview of the treatment acres and repetition rates the BLM estimates would be 

8 necessary to achieve the vegetation objectives for Alternative C. The table is followed by a description of 

9 the types of treatments the BLM might undertake to achieve the objectives. 

10 Table 19: Estimate of treatment acres under Alternative C 

Mechanical 

Treatment 

Herbicide 

Treatment 

Biological 

Treatment Prescribed Fire 

Acres 

# of 

treatments 

over 20 

years 

Acres 

# of 

treatments 

over 20 

years 

Acres 

# of 

treatments 

over 20 

years 

Acres 

# of 

treatments 

over 20 

years 

Forest & woodland 

Treatment to maintain or 

open canopy 

400 2 63 3 

Treatment of forest 

understory 200 4 100 4 

Grassland & shrubland 

Treatment to reduce or 

eliminate woody shrubs 200 5 200 5 200 2 

Treatment to reduce 

encroaching trees 378 2 60 5 60 2 

Treatment to reduce/ 

control non-native plants 487 5 425 5 487 5 487 5 

Treatment to restore 

native plants 425 5 125 3 

Wetland 

Treatments to restore 

existing wetlands 3 4 3 4 3 4 

Planting to facilitate 

development of 

functional wetlands 

1 2 

Average Annual Acres 

over 20 years 397 192 122 176 

Total Acres 7,930 3,837 2,447 3,519 

11 Note: these acres are the BLM’s estimates of the extent and repetition of vegetation treatments that might

be necessary to achieve the alternative’s objectives. The actual extent, type, and timing of treatments 

would be determined during plan implementation through project-level planning and NEPA compliance. 

Forest and Woodland 

In order to approximate the less densely vegetated conditions that relatively frequent, low intensity fires 

would have historically produced, the BLM would undertake treatments affecting the forest canopy and 

understory. The types of treatments that would occur under Alternative C are the same as under 

Alternative B, though the extent and repetition is likely to be greater to achieve the objectives. 

12 

13 

14 

15 

16 

17 

18 

114 
 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Grassland and Shrubland 

2 In order to enhance the extent of grasslands and approximate the more open conditions and native species 

3 composition that would have occurred historically, the BLM would undertake a variety of treatments to 

4 remove trees, control invasive plant species, remove woody shrubs, and restore native plants. The types 

5 of treatments that would occur under Alternative C are the same as those that could occur under 

6 Alternative B, though the extent and repetition of treatments is likely to be greater in order to maximize 

7 the cover of native vegetation and enhance culturally important plant communities. 

8 Wetland 

9 In order to approximate historic wetland conditions, the BLM would undertake a variety of treatments to 

10 expand wetland acres and restore existing wetlands. This would include removing non-native wetland 

11 species, reestablishing or enhancing native wetland species, and removing native trees that are 

12 encroaching on existing wetlands. The types of treatments that would occur under Alternative C are the 

13 same as under Alternative B, except that there would be no expansion of wetlands under Alternative C. 

14 Sub-Alternative C 

15 Table 20 provides an overview of the treatment acres and repetition rates the BLM estimates would be 

16 necessary to achieve the vegetation objectives for Alternative C. Under Sub-Alternative C, the BLM 

17 would prohibit herbicide treatments. All other treatments types under this alternative would be the same 

18 as under Alternative C, except that the repetition rate of mechanical treatments would need to be much 

19 higher to achieve Alternative C’s ambitious objectives without the use of herbicides. 

20 Table 20: Estimate of treatment acres under Sub-Alternative C 

Mechanical Treatment Biological Treatment Prescribed Fire 

Acres # of treatments over 

20 years Acres # of treatments over 20 years Acres # of treatments over 20 years 

Forest & woodland 

Treatment to maintain or 

open canopy 

400 2 63 3 

Treatment of forest 

understory 200 20 

Grassland & shrubland 

Treatment to reduce or 

eliminate woody shrubs 200 20 200 2 

Treatment to reduce 

encroaching trees 378 20 60 2 

Treatment to reduce/ 

control non-native plants 487 20 487 5 487 5 

Treatment to restore 

native plants 425 5 125 3 

Wetland 

Treatments to restore 

existing wetlands 3 20 3 4 

Planting to facilitate 

development of functional 

wetlands 

1 2 

Average Annual Acres 

over 20 years 1,414 122 176 

Total Acres 28,287 2,447 3,519 

115 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Note: these acres are the BLM’s estimates of the extent and repetition of vegetation treatments that might

2 be necessary to achieve the alternative’s objectives. The actual extent, type, and timing of treatments 

3 would be determined during plan implementation through project-level planning and NEPA compliance. 

4 Alternative D 

5 Table 21 provides an overview of the treatment acres and repetition rates the BLM estimates would be 

6 necessary to achieve Alternative D vegetation objectives. The table is followed by a description of the 

7 types of treatments the BLM might undertake. The BLM would allow biological control under this 

8 alternative, but did not estimate that it would be necessary to achieve Alternative D objectives. 

9 Table 21: Estimate of treatment acres under Alternative D 

Mechanical TreatmentHerbicide Treatment Prescribed Fire 

# of treatments # of treatments # of treatments Acres over 20 years Acres Acres over 20 years over 20 years 

Forest & woodland 

Treatment to maintain or open 100 5 

canopy 

Grassland & shrubland 

Treatment to reduce or 25 5 25 5 25 2 eliminate woody shrubs 

Treatment to reduce 17 5 2 5 encroaching trees 

Treatment to reduce/control 5 10 65 5 

non-native plants 

Treatment to restore native 10 5 plants 

Average Annual Acres over 41 23 3 20 years 

Total Acres 810 460 50 

10 Note: these acres are the BLM’s estimates of the extent and repetition of vegetation treatments that might

be necessary to achieve the alternative’s objectives. The actual extent, type, and timing of treatments 

would be determined during plan implementation through project-level planning and NEPA compliance. 

Forest and Woodland 

In order to maintain current forest and woodland conditions under Alternative D, the BLM would 

undertake treatments affecting the forest canopy and understory. 

Where monitoring indicates that forest and woodland canopies are becoming more closed, the BLM could 

undertake light thinning (mostly low thinning) to maintain the current density of canopy cover using feller 

bunchers, chainsaws, hand tools, and/or prescribed fire. Accessible areas would have cut materials 

removed to reduce fire danger. 

Where monitoring indicates that forest and woodland understory is becoming denser or changing 

composition during the life of the plan, the BLM could undertake thinning of understory trees and brush, 

including by cutting, mowing, chipping, pulling, clipping, herbicide application, and prescribed burning. 

Grassland and Shrubland 

When monitoring indicates that encroachment by forest and shrub species is increasing in grassland and 

shrublands, that non-native plant cover is increasing, or that sensitive or culturally important plant 

populations are decreasing, the BLM would undertake a variety of treatments to remove trees, control 

invasive plant species, remove woody shrubs, and restore native plants. Treatment types would be similar 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

116 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

to those described under Alternative B, except that the BLM would not convert current forest and 

woodland acres to grasslands and shrublands. 

Wetland 

The BLM estimates that no treatments would be necessary to maintain wetlands in the approximate 

current conditions. If monitoring identifies changes to conditions, treatments similar to those described 

under Alternative B could be undertaken, except that no expansion of wetlands would occur. 

Habitat and Plants Analytical Issue 4: How would the alternatives affect 

special status plants and lichen and Washington Natural Heritage Program 

priority ecological communities? 

See Appendix B for analytical methods used in this analysis. 

Background 

Special Status Plants 

Special status plants are those included on the Oregon/Washington State Director’s Special Status Species 

List. This list includes three categories: 1) species listed or proposed for listing under the Endangered 

Species Act (ESA), 2) species designated as sensitive species by the BLM State Director, and 3) species 

designated as strategic by the BLM State Director. For more information on the special status species list

and the BLM’s general objectives for managing these species, see Appendix E. 

Washington Natural Heritage Program (WNHP) priority ecological communities 

In addition to special status plants, this document also considers priority ecological communities, which 

NatureServe and the WNHP have identified and ranked (WDNR 2007, 2011). The importance of the 

communities identified here is that they are, on a statewide or global scale, becoming more scarce or 

compromised. For more general information about WNHP priority communities see Appendix E. 

Affected Environment 

Special Status Plants and Lichen 

Proclamation 8947 referred to the federally threatened golden paintbrush (Castilleja levisecta), which is a 

regional endemic of open grasslands in the Puget Trough. There are no known occurrences of golden 

paintbrush within the Monument; however, six other special status plant or lichen species do occur within 

the Monument (see Table 22). Golden paintbrush is considered critically imperiled at both State and 

global levels, with a NatureServe rank of G1S1 (NatureServe 2015). A recovery plan for the golden 

paintbrush was published in 2000 (U.S. FWS 2000) with additional conservation measures added in 2010 

(U.S. FWS 2010b) . The recovery actions focus on the reintroduction of the species into likely historical

habitat. Through reintroductions in Oregon and Washington, there are now 40 known populations of

golden paintbrush (U.S. FWS 2015) .

Golden paintbrush has been documented at several sites in the San Juan Islands, but there are no known 

current populations within the Monument. In 2012, there was a small reintroduction program in the San 

Juan Islands, including a site at within the Monument at Iceberg Point, to determine survivability of

introduced plants. By 2015, the single reintroduction plot at Iceberg Point contained zero plants. Despite 

the results of the test plot, the Monument’s grasslands have the potential to support a population of the 

plant through reintroductions. Under current management, the grassland community that provides

potential habitat for golden paintbrush within the Monument would continue to decline due to 

encroachment by shrubs and forest species, and persistence of non-native species. 

Four of the six known or historically known (golden paintbrush) species of rare plants documented in the 

Monument occupy open grassland habitats (see Table 22). Bear’s-foot sanicle (Sanicula arctopoides) 

occupies coastal bluffs and grassy sand dunes and Niebla lichen (Niebla cephalota) is an epiphyte that 

lives on the lower branches of conifers, generally within sight of open water. Suspected (but not 

documented) special status plant species’ habitats are described in Table 23. 

117 
 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Single populations of slender crazyweed and white-topped aster—both Washington State sensitive 

2 species—have been documented at Iceberg Point. Signs of trampling are evident on the slender 

3 crazyweed and white-topped aster populations. The white-topped aster population is bisected by a trail, 

4 and some slender crazyweed individuals are impacted when visitors step off trail to reach overlooks. 

5 Slender crazyweed has a G5S2 NatureServe ranking, which is state imperiled yet globally secure. Within 

6 the San Juan Islands, slender crazyweed occurs only along the southern end of Lopez Island. Outside of 

7 the islands, slender crazyweed is also extant in Okanogan, Jefferson, and Clallam counties in Washington 

8 State. 

9 Limited populations of California buttercup (Ranunculus californicus var californicus) are known to 

10 occur within the Monument at Iceberg Point. An additional historical occurrence was recorded at Point 

11 Colville. Other occurrences of California buttercup have been mapped on non-Monument lands on Lopez 

12 and San Juan Island, but only about 5 recent sites are known throughout the San Juan Islands (Camp and 

13 Gamon 2010; WDNR 2015). California buttercup has a G5S1 ranking, which indicates it is critically 

14 imperiled in the state of Washington (S1) and secure globally (G5, NatureServe 2015). It is listed as 

15 threatened by Washington State (WDNR 2018). 

16 White-topped aster is a regional endemic and ranked as G3S3, which corresponds to vulnerable in 

17 Washington State and vulnerable with a moderate risk of extinction globally. The white-topped aster 

18 population at Iceberg Point is the only population documented in the San Juan Islands and is the 

19 northernmost population in Washington State. White-topped aster is otherwise restricted to the 

20 Willamette Valley and Puget Lowlands (Camp and Gamon 2010). This species is listed as threatened by 

21 the State of Oregon; a very small number of populations occur in the lowlands of the Willamette Valley. 

22 Conifer encroachment and competition by non-native shrubs and grasses is a substantial threat to this 

23 species (NatureServe 2015).

24 Niebla lichen is documented on Point Colville and mentioned in Rhoades (2009) as commonly found on 

25 Iceberg Point on shaded branches of Douglas-fir in transitional woods. This lichen was elevated in rank 

26 to being BLM sensitive in 2015 and is WNHP Sensitive. NatureServe ranked this lichen as G3G4S2, 

27 which is globally vulnerable and imperiled in the state. 

28 Bear’s-foot sanicle is documented on two of the Monument islands off of Orcas Island (WNHP 2018). 

29 This species has a ranking of G5S1, which is globally secure yet critically imperiled in Washington State. 

30 This BLM sensitive plant is maritime, found on coastal bluffs and grassy sand dunes near salt water from 

31 Vancouver Island, British Columbia (Canada), to Santa Barbara, California. It is often in association with 

32 red fescue, rose, and western buttercup. 

33 Table 22: Special status plants and lichen currently or historically within the Monument 

Species Name Federal

Status

State

Status

BLM 

Status

Associated Habitat within the 

Monument1

Bear’s-foot sanicle (Sanicula arctopoides) E Sen Coastal bluffs and grassy sand 

dunes near salt water

California buttercup (Ranunculus 

californicus var californicus) T Sen Open grasslands

Golden paintbrush (Castilleja levisecta) T T Open grasslands

Niebla lichen (Niebla cephalota) S Sen Epiphyte on lower conifer

branches

Slender crazyweed (Oxytropis campestris 

var gracilis) S Sen Open grasslands and rocks

White-topped aster (Sericocarpus rigidus) S Sen Open grasslands

118 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Sources: Bureau sensitive plants documentation source: GeoBOB and WNHP databases, BLM files. 

2 Sen=BLM sensitive, Str=BLM strategic, S=sensitive, T=threatened, E=endangered, X=believed to be 

3 extirpated in the state. 

4 1Habitat descriptions from Camp and Gamon 2010 except for Rhoades 2009 for Niebla cephalota 

5 Table 23 describes rare plant species that are known to occur in San Juan County but have not been 

6 documented in the Monument. The BLM considers these species to be suspected within the Monument—

7 a suspected species is one that is not documented on land administered by the BLM, but may occur

8 because the land is within the species' range and appropriate habitat is present or there are known 

9 occurrences of the species (historic or current) in the vicinity (BLM 2015a). 

10 Table 23: Special status plants and lichen in San Juan County not documented in the Monument 

Documented 

* Species Associated Habitat State/Federal 

status/Rank in the 

Monument? 

General 

location(s) †

seasonally wet areas in bogs, Adder’s-tongue fens, wet meadows, moist (Ophioglossum pusillum) woods, and other settings 

S/Sen/G5S2 No Orcas Island 

submerged on banks of lakes, Blunt-leaf pondweed sloughs, and slow-flowing (Potamogeton obtusifolius) streams in 1-4 m of water 

S/Str/G5S2 No Orcas and San 

Juan Island 

springs, bogs, wetlands, and Bog twayblade (Liparis wet sunny areas in Douglas- loeselii) fir forests 

E/Str/G5S1 No Orcas Island 

wet to moist vernal pools on Erect pygmy-weed coastal bluffs, seasonally wet (Crassula connata) cliffs, rock outcrops 

T/Str/G5S1 No San Juan and 

nearby island 

Few-flowered sedge (Carex wet acidic environments, 

pauciflora) bogs S/Sen/G5S2 No Orcas Island 

Nuttall’s quillwort (Isoetes seasonally wet ground and 

nuttallii) mud near vernal pools S/Sen/G4S2 No San Juan Island 

Rush aster lakesides, marshes, bogs, 

(Symphyotrichum boreale) and fens T/Str/G5S1 No Orcas Island 

salt spray zone, growing in Sharp-fruited peppergrass moist cracks and vernal (Lepidium oxycarpum) pools on bedrock 

E/Str/G4S1 No San Juan 

Island 

Siskiyou Mountain open woods and dry open ragwort (Packera places macounii) 

T/Sen/G5S1 No Orcas 

Island 

open grassland where wet to White meconella San Juan moist in spring and dry by (Meconella oregana) early summer 

E/Sen/G2G3S1 No Island 

11 Sources: Bureau sensitive plants documentation source: GeoBOB and WNHP databases 

Sen=BLM sensitive, Str=BLM strategic, S=State sensitive, T=State threatened, E=State endangered. 

LT=federally listed as threatened. *

Habitat descriptions are from Camp and Gamon 2010 except for Rhoades 2009 for Niebla cephalota and

Burke Herbarium 2016 for Siskiyou Mountain ragwort.

†

From known populations on public lands, per Washington Natural Heritage Program.

Detailed trend information is not available for the slender crazyweed (Oxytropis campestris var gracilis), 

California buttercup (Ranunculus californicus var californicus), bear’s-foot sanicle, Niebla lichen, or 

12 

13 

14 

15 

16 

17 

18 

119 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

white-topped aster (Sericocarpus rigidus), or for the locally important plants (see subsection below), but 

all are subject to the trends described in the following paragraph. 

In comparison to the conditions that existed prior to extensive Euro-American settlement, trends for many

special status plants in Washington State have been downward as a result of conversion of natural habitats 

to development and altered communities. Exotic invasive species have spread into much of the remaining

habitat, competing with native plants. Anticipated changes in temperature and precipitation patterns are 

also likely to affect special status species through alterations in competitive relationships, phenology, and 

fire frequency. In the San Juan Islands, species closest to the coastline, such as slender crazyweed, are 

threatened by rising sea levels and trampling by visitors walking the coastline. White-topped aster has the

potential to be impacted by conifer encroachment, invasive species, and trampling from recreational uses.

Priority Ecological Communities 

The WNHP has inventoried 15 ecological communities in the Monument (Table 24). Acres identified as 

part of these communities include both BLM-administered and non-BLM-administered lands. The 

WNHP inventoried the majority of these areas as part of a project to better understand the biodiversity 

importance of BLM-administered lands that were not currently in an ACEC (Crawford and Chappell 

2006). Therefore, the WNHP did not study Iceberg Point and Watmough Bay, which are included in 

ACECs, in that effort. Many of the polygons developed were part mosaics in a forested community; 

therefore, there is some overlap between the communities. The fifteen communities identified by the 

WNHP are spread between nine types, eight of which are forested and one of which is grass-dominated. 

The WDNR prioritized ecological communities for conservation in its 2018 Natural Heritage Plan 

(WDNR 2018). Some of the communities mapped in the Monument are not on the WNHP list of 

priorities. WNHP priority communities are described below. Definitions for the WNHP priorities can be 

found in the Habitat and Plants Issue 4 section of Appendix E. 

Patos Island’s community of western red cedar, grand fir, and swordfern is a WNHP identified priority 1 

ecological community and was ranked as “A” quality, the highest ranking in the program. NatureServe 

describes this community as critically imperiled due to its restricted range and notes the lack of good 

quality occurrences because of logging and fragmentation. Patos Island also encompasses a Priority 2 

community – Douglas-fir, western hemlock, and salal, a priority 3 community–Douglas-fir, salal, and 

oceanspray, and priority 1–Douglas-fir, grand fir, western red cedar, dwarf Oregon grape, and salal 

forest. In total, WNHP considers nearly all of the forested areas of Patos Island and Little Patos to have 

some conservation significance. 

Chadwick Hill on Lopez Island has a high-quality (AB WNHP rank) example of a Douglas-fir, pacific 

madrone, and American vetch forest, as well as a high-quality Douglas-fir, salal, and oceanspray forest. 

Another forested community, shore pine with Douglas-fir and salal, is ranked BC, or good-fair integrity. 

The North Pacific Herbaceous Bald and Bluff macrogroup at Lummi Rocks and Point Colville includes a 

red fescue – great camas – Oregon gumweed plant association rated by NatureServe as G1S1, which 

means it is critically imperiled both globally and in Washington State. The WNHP considers this 

community to be a priority 1 for conservation. This community also occurs at Iceberg Point, though the 

WNHP did not identify it, likely due to poor condition. Only ten occurrences of this grassland 

association are known in Washington with fair to good ecological integrity. 

Iceberg Point also has a priority 1 ecological community, the Douglas-fir–(grand fir, western red-cedar)/ 

dwarf Oregon-grape – salal community is present on the north half of Iceberg Point. The condition of 

this forest community, as mapped in 1987, was ‘BC’ or good-fair integrity. 

Carter Point, on the southern tip of Lummi Island, had several communities mapped of conservation 

importance. A priority 1, fair integrity forest of Douglas-fir, common snowberry, and oceanspray was 

found, as well as a priority 2, good integrity Douglas-fir, western hemlock, and salal forest. Lastly, the 

120 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

WNHP also documented good integrity communities of Douglas-fir, salal, oceanspray and Douglas-fir, 

pacific madrone, American purple vetch. 

President Channel, on the west side of Orcas Island, includes part of a WNHP identified fair to good 

integrity Douglas-fir, salal, oceanspray and Douglas-fir, Pacific madrone, American purple vetch 

community. This community spans the entire parcel. 

Regional threats to these forested communities include residential development in scenic coastal areas, as 

well as logging, fragmentation, biological resource use such as legal floral and mushroom harvest, and 

exotic species. Threats to the grassland communities include native tree encroachment due to the absence 

of fire, non-native species invasions, and human intrusions and disturbances such as trail proliferation and 

reduction in vegetation cover (WNHP 2015). 

The WNHP determines whether to include an ecosystem occurrence in their conservation system by 

combining the global and state status with the condition, or ecological integrity, of the ecosystem 

occurrence (Figure 6). Therefore, all occurrences of rare ecosystems become an “element occurrence”

tracked by the WNHP; occurrences of lower status and lower integrity are not tracked by the WNHP. 

15 

16 Figure 6: WNHP ecological integrity assessment rankings 

17 Source: WDNR, Natural Heritage Program website: http://www.dnr.wa.gov/NHPecosystems 

121 
 

 

 

 

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 24: Monument communities inventoried by Washington Natural Heritage Program 

Community Conservation 

Rank 

Condition 

Rank 

State 

Priority 

Location 

Name Acres Survey Date 

Recommendations/Notes 

(All recommendations/notes are from WNHP) 

Douglas-fir – western 

hemlock / salal G3S2 B 2 Carter Point 130* 2005 Mature (~125-year-old) and young forest with scattered old 

residuals. BLM land has never been logged. 

Douglas-fir - pacific 

madrone / American purple 

vetch 

G1G2QS1S2 B 2 Carter 

Point 65* 2005 

Mature (~125-year-old) post-fire forest and woodland with 

frequent old-growth residual Douglas-fir. Char on bark of old 

trees. Canopy is dominated by mix of Douglas-fir and madrone. 

Significant portions of area may have been savanna, maintained 

by fire. 

Douglas-fir / salal -

oceanspray 

G2G3S2 B 3 Carter 

Point 200* 2005 Mature (~125-year-old) and young forest with scattered old residuals. BLM land has never been logged. 

Douglas-fir / common 

snowberry - oceanspray 

G1S1 C 1 Carter 

Point 10* 2005 

Mature (~125-year-old) forest with scattered old residuals. 

Canopy is dominated completely by Douglas-fir. Some Acer 

glabrum is in subcanopy. Understory of dense tall shrubs: 

Holodiscus discolor and Symphoricarpos albus are major 

species. 

shore pine - Douglas-fir / 

salal G1G2S1 BC 1 Chadwick Hill 30 1994 

Mature (~115-year-old) post-fire lodgepole pine-dominated 

stands. Prescribed fire would be appropriate to regenerate PICO. 

In absence of fire, will probably succeed to PSME/GASHHODI. Research Natural Area (RNA) quality. 

Douglas-fir - pacific 

madrone / American purple 

vetch 

G1G2QS1S2 AB 2 Chadwick 

Hill 65 1994 

Decline of madrone could be a problem - widespread decline 

evident year of survey. Best known example, good condition, no 

past logging, extensive for this type. RNA quality. 

Douglas-fir / salal -

oceanspray 

G2G3S2 AB 3 Chadwick 

Hill 130 1994 

Mature (~110-130-year-old) Douglas-fir forest. Old-growth 

residuals with charred bark vary from absent to scattered to codominant. Keep trails to a minimum. RNA quality. 

Douglas-fir - (grand fir, 

western red-cedar) / dwarf 

Oregon -grape - salal forest 

G2S1 BC 1 Iceberg 

Point ~20 1987 

red fescue - great camas -

Oregon gumweed G1S1 B 1 Lummi Rocks 3 2005 

Good- to fair-condition patches of largely native grassdominated community. Occurs as patches in mosaic with 

substantial rock outcrops and—to lesser degree—shrublands. 

Douglas-fir - western 

hemlock / salal G3S2 B 2 Patos Island 70 2005 Old-growth forest. RNA quality. 

122 
 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Community Conservation 

Rank 

Condition 

Rank 

State 

Priority 

Location 

Name Acres Survey Date 

Recommendations/Notes 

(All recommendations/notes are from WNHP) 

Douglas-fir / salal -

oceanspray 

G2G3S2 C 3 Patos 

Island 4 2005 

Mature (~125-year-old) Douglas-fir post-fire stand with 

scattered old trees. Some smaller Arbutus in subcanopy. RNA 

quality. 

western red cedar - grand 

fir / swordfern G1G2S1 A 1 Patos Island 85 2005 

Old-growth and mature (~145-year-old) forest that has never 

been logged. Entire area appears to have burned since 

establishment of old-growth cohort, thought pockets in eastern 

third maybe not. Density of old trees that survived varies. RNA 

recommended. Best example of this type in the state. 

Douglas-fir - (grand fir, 

western red-cedar) / dwarf 

Oregon -grape - salal forest 

G2S1 BC 1 Patos 

Island 30 2005 

Mix of mature stands with scattered old trees and old-growth 

stands. All burned prior to establishment of mature cohort. 

RNA quality. 

red fescue - great camas -

Oregon gumweed G1S1 D 1 Point Colville 1997 Open rocky headland. 

Douglas-fir - grand fir / 

common snowberry / 

Alaska oniongrass forest 

G1S1 C 1 Point 

Colville 1994 

Southern half of Pt Colville was formerly Douglas-fir savanna 

that has been invaded during this century with dense canopy of 

PSME and grand fir. Scattered old PSME with charred bark. 

Douglas-fir – western redcedar – grand fir / Oregongrape – salal forest 

G2S1 C 1 Point 

Colville 1994 

Southern half of Pt Colville was formerly Douglas-fir savanna 

that has been invaded during this century with dense canopy of 

PSME and grand fir. Scattered old PSME with charred bark. 

Douglas-fir - western 

hemlock / salal -

oceanspray forest 

G3S2 C 2 Point 

Colville 1994 

Southern half of Pt Colville was formerly Douglas-fir savanna 

that has been invaded during this century with dense canopy of 

PSME and grand fir. Scattered old PSME with charred bark. 

Douglas-fir - pacific 

madrone / American purple 

vetch 

G1G2QS1S2 BC 2 President 

Channel 70* 1993 

Deserves some level of protection. Multi-cohort Douglas-firPacific madrone forest. Typical old Douglas-fir is about 285 

years old, 30" at diameter breast height. Smallish canopy-level 

fir is 95-100 years old. Charcoal abundant on tree bark, 

especially older trees. Majority of area unlogged. 

1 

2 

3 

Source: WNHP dataset 2018 

*Inventoried acres include both BLM-administered and non-BLM-administered lands. The BLM administers approximately 43 acres at Carter

Point and 32 at President Channel.

123 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Locally Significant Plants 

2 Local stakeholders requested that the BLM address several plants of importance to San Juan Islands 

3 residents in this planning effort (Table 25). Many on the list do not meet the BLM or Washington State 

4 criteria for special status plants. Those that do are addressed under special status plant species, above. 

5 Venus’ looking glass (Triodanis perfoliata) is considered globally and nationally secure (not rare, 

6 NatureServe 2015), and is currently not ranked by the WNHP. Showy Jacob’s ladder (Polemonium 

7 pulcherrimum) is considered globally secure and is not ranked nationally or by WNHP. Yampah 

8 (Perideridia gairdneri), or Indian carrot, is considered globally secure and is not ranked nationally or by 

9 WNHP. Harebell (Campanula rotundifolia) is considered globally secure and is not ranked nationally or 

10 by WNHP. Chick lupine (Lupinus microcarpus) is considered globally secure and is not ranked 

11 nationally or by WNHP. Brittle prickly pear (Opuntia fragilis) is considered globally, nationally, and 

12 state secure. Kinnikinnick (Arctostaphylos uva-ursi) is considered globally and nationally secure and is 

13 currently not ranked by WNHP. The BLM and WNHP do not track occurrences of the species referred to 

14 in this paragraph. Impacts to these plants of local importance would correspond with affects to the 

15 habitats and plant communities within which they live (see Habitat and Plants Issue 2, above). 

16 Table 25: Plants of local concern within the San Juan Islands* 

Species Name Habitat BLM Status

Sharp-fruit peppergrass (Lepidium oxycarpum) Salt Spray Zone Str

Nuttall’s quillwort (Isoetes nuttallii) Vernal pools Sen

Venus’ looking glass (Triodanis perfoliata) Open rocky none

Showy Jacob’s ladder (Polemonium pulcherrimum) Open rocky none

Yampah (Indian carrot) (Perideridia gairdneri) Open grassland none

Hare bell (Campanula rotundifolia) Open rocky none

Chick lupine (Lupinus microcarpus) Open grassland none

Brittle prickly pear (Opuntia fragilis) Open grassland none

Kinnikinnick (Arctostaphylos uva-ursi ) Open grassland, understory none

17 Sen=BLM sensitive, Str=BLM strategic 

18 * This is an abbreviated version of a table provided to the BLM in 2015 by the Kwiaht Center for the 

Historical Ecology of the Salish Sea. This table is made up of species identified by Kwiaht as of local 

importance but which either A) do not have special designation or protection per the BLM Special Status 

Species Program, or B) are species with special designation that have not been documented within the 

Monument. 

Effects of the Alternatives 

The alternatives vary in how they would affect special status plants and priority communities. The effects 

of the alternatives on the extent and condition of plant communities are addressed in Habitat and Plants 

Issues 1 and 2, above. 

Special Status Plants and Lichen 

Suspected plants will not be discussed in the effects analysis individually because they have not been 

documented within the Monument. However, the BLM assumes that potential habitat for these species 

would improve or decline in accordance with their associated plant communities (see Table 23). For 

example, alternatives that expand and improve grassland and shrubland would improve potential habitat 

for suspected species associated with grassland and shrubland. 

No Action Alternative 

Under the No Action Alternative, as under Alternative A, the extent of Monument land in the grassland 

and shrubland class would decrease by approximately 13 percent and Monument land in the forest and 

woodland class would increase by approximately 2 percent over the next 20 years (see Table 7 on page 

75). With limited vegetation treatments, the condition of communities in the grassland and shrubland 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

124 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 class would continue to decline due to encroachment by forest and shrub species and invasive plant 

species spread. Forest and woodlands would continue to have increasingly dense and closed conditions. 

The continuation of current trends would cause a long-term decrease in the habitat for the five special 

status plants currently or historically occupying open grassland or grassy habitats on the Monument (see 

Table 22). The white-topped aster occurrence at Iceberg Point would become more shaded by 

encroaching conifers. Encroachment of conifers is also a habitat threat for bear’s-foot sanicle (Camp and 

Gamon 2010). The continuing expansion of Douglas-fir under this alternative would increase habitat for 

the Niebla lichen. 

Travel and transportation impacts (primarily hiking) would also continue to have minor negative longterm impacts to rare plants in the No Action Alternative. Specifically, the effects of trampling would 

presumably continue at Iceberg Point on the slender crazyweed and white-topped aster populations (see 

affected environment). However, impacts to both of these BLM sensitive species would not cause either 

to become federally listed. 

Common to all Action Alternatives 

Under all action alternatives, the BLM would implement management direction for the conservation and 

recovery of special status plants. The BLM would conduct pre-disturbance surveys prior to management 

actions that might disturb sensitive plants in areas where suitable habitat for such plants is suspected. 

Where sensitive plants are found, projects would be modified to avoid or reduce impacts. By 

implementing this direction, impacts to special status plants from disturbance related to management 

actions—including restoration efforts and invasive species removal—would be minimized and long-term 

effects to those resources would be positive. 

During plan implementation, the BLM would install fencing as necessary to minimize trampling and 

herbivory of rare botanical resources. Long-term positive impacts to the size and vigor of special status 

plant populations could occur from these efforts. 

Under all action alternatives, the BLM would remove encroaching conifers and non-native vegetation 

where the agency determines that they are negatively effecting nearby BLM special status plants. The 

BLM would replace plants removed with non-competitive native plants. Because many special status 

plants known or suspected in the Monument do not tolerate shade, this effort would benefit those special 

status plants that are known to occur in areas with active conifer encroachment. Conifer removal could 

have minor negative impacts on the quantity of available habitat for Niebla lichen, which grows on 

shaded branches of Douglas-fir in transitional woods. However, current records for the lichen and the 

documented special status plants do not occur adjacent to one another, so direct impacts to the Niebla 

lichen are not anticipated. 

The BLM would also undertake implementation actions to install fencing and signs as necessary to 

minimize trampling and herbivory of rare botanical resources. These installations would both physically 

prevent visitor activities from damaging rare plants and would also educate visitors on the fragile nature 

of the plant communities. Long-term, positive impacts to the size and vigor of special status plant 

populations could occur from these efforts. 

Alternative A 

The changes to the extent of plant communities under Alternative A would be the same as under the No 

Action Alternative (see Table 7 on page 75). 

As described under Habitat and Plants Issue 2, the prohibition on herbicide use under Alternative A 

would make it unlikely that the BLM would be as successful as under alternatives B, C, and D in 

controlling invasive plants without ground disturbance. Without chemical treatments, invasive plant 

removal would be undertaken using methods more likely to cause ground disturbance. In the short-term, 

this would result in less beneficial impacts to the known rare plant populations that occupy Monument 

grasslands and shrublands, as well as to potential habitat for golden paintbrush. However, these effects 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

125 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 would be minor due to the small number of acres the BLM anticipates it would treat in order to meet the 

alternative’s objectives.

There would no longer be recreation impacts to special status plants under Alternative A. Long-term 

minor positive impacts would result for California buttercup, white-topped aster, and slender crazyweed, 

all of which experience some trampling from visitor traffic. 

Under Alternative A, there could be some short-term negative impacts to special status plants and their 

habitats from naturally caused wildfires that are not suppressed, though naturally ignited wildfires are rare 

in the San Juan Islands (see Table 61 on page 238). This would be from the direct burning of the plants 

or habitat. However, overall habitat could improve through wildland fire, and long-term effects would be 

positive by adding more potential rare plant habitat. 

Alternative B 

Under Alternative B, the extent of Monument land in the grassland and shrubland class, which would 

include tree savanna, would increase by approximately 313 percent and the forest and woodland class 

would decrease by approximately 50 percent over the life of the plan (see Table 7). The extent of 

wetlands would increase by approximately 79 percent. Under this alternative, the BLM would undertake 

vegetation treatments to control invasive plant species and maximize native grassland species richness. 

Through local seed collection and augmentation, the BLM would also work with partners to establish 

populations of rare botanical species native to the San Juan Islands. Introductions would include both 

those species historically occurring on the Monument as well as species with recovery plans calling for 

introduction into suitable habitat, such as golden paintbrush. 

This alternative’s vegetation approach would favor the expansion of habitat for white-topped aster, 

California buttercup, slender crazyweed, and bear’s-foot sanicle, and would provide additional suitable 

habitat for golden paintbrush. It would also provide additional suitable habitat for rare plants native to the 

San Juan Islands, but not documented in the Monument, some of which would benefit from the expanded 

wetland habitat (see Table 23). Habitat for Niebla lichen would decline under this alternative due to the 

reduction of acreage in forest and woodland and the removal of encroaching Douglas-fir from grasslands. 

Travel and transportation impacts would continue to have minor negative long-term impacts to California 

buttercup, slender crazyweed, and white-topped aster, though impacts would be reduced due to a 

requirement for visitors to remain on trails. However, impacts would not cause these species to become 

federally listed. 

Potential future coordination between the BLM and partner agencies to remove invasive animals from the 

landscape under this alternative would provide long-term positive impacts to rare plants and their habitats 

by reducing excessive levels of herbivory. This would also allow for more successful survival of 

augmentations of new rare plant populations. 

Alternative C 

Under Alternative C, the extent of Monument land in the grassland and shrubland class, which would 

include tree savanna, would increase by approximately 287 percent and the forest and woodland class 

would decrease by approximately 48 percent over the life of the plan (see Table 7 on page 75). Under 

this alternative, the BLM would undertake vegetation treatments to approximate the conditions that would 

have existed when Native American/Indigenous Peoples used fire as a management tool by; this would 

involve creating more open forest conditions and removing non-native plants and encroaching forest 

species and woody shrubs from grasslands. 

This alternative would favor the expansion of four of the five currently known rare plant species and 

would provide additional suitable habitat for golden paintbrush. Habitat for Niebla lichen would decline 

due to the reduction of acreage in the forest and woodland class and the removal of encroaching Douglasfir from existing grasslands. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

126 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Travel and transportation impacts would continue to have minor negative long-term impacts to slender 

crazyweed and California buttercup, though impacts would be reduced due to a requirement for visitors to 

remain on trails. Impacts to these BLM sensitive species would not cause them to become federally 

listed. Under this alternative, the trail bisecting the white-topped aster population would be rerouted to 

eliminate trampling and allow the plant to fill in the old footprint. This would have a minor long-term 

positive impact on this BLM sensitive plant. 

Potential future coordination between the BLM and partner agencies to remove invasive animals from the 

landscape under this alternative would provide long-term positive impacts to rare plants and their habitats 

by reducing excessive levels of herbivory. This would also allow for more successful survival of 

augmentations of new rare plant populations. 

Sub-Alternative C 

The effects of Sub-Alternative C on special status plant species would be similar to those in Alternative 

C. As described under Habitat and Plants Issue 2, without herbicides the BLM would be unlikely to be as 

successful as under alternatives B and C in controlling invasive plants and restoring native plant 

communities without extensive ground disturbance in grassland and shrubland. In the short-term, this 

would result in less beneficial impacts to rare plant populations that occupy Monument grasslands and 

shrublands, as well as to potential habitat for golden paintbrush. Effects on Niebla lichen would be the 

same as under Alternative C. 

Alternative D 

Under Alternative D, the BLM would maintain the current extent of Monument lands in the grassland and 

shrubland and forest and woodland classes. It would undertake treatments to ensure that invasive plants 

and encroaching forest species and woody shrubs do not further expand in grassland and shrubland. 

Suitable habitats for the five currently known rare plant populations and the historically present golden 

paintbrush would remain approximately unchanged under Alternative D. 

Travel and transportation impacts would continue to have minor negative long-term impacts to California 

buttercup, slender crazyweed, and white-topped aster; unlike under alternatives B and C, cross-country 

hiking would continue to be allowed under this alternative. Impacts to this BLM sensitive species would 

not cause them to become federally listed. 

Potential future coordination between the BLM and partner agencies to remove invasive animals from the 

landscape under this alternative would provide long-term positive impacts to rare plants and their habitats 

by reducing excessive levels of herbivory. This would also allow for more successful survival of 

augmentations of new rare plant populations. 

Priority Ecological Communities 

The fifteen communities identified by the WNHP are spread between nine types, eight of which are 

forested and one of which is grass-dominated. 

No Action Alternative and Alternative A 

Under the No Action Alternative and Alternative A, the extent of Monument land in grassland and 

shrubland would decrease by approximately 13 percent and forest and woodland would increase by 

approximately 2 percent over the next 20 years (see Table 7 on page 75). A more rapid decrease in 

grasslands has been documented at Point Colville, where the WNHP has identified a red fescue, great 

camas, and Oregon gumweed community that is in poor condition (Dougherty 2004). The BLM assumes 

that the Monument would lose more of this priority 1 community under the No Action Alternative and 

Alternative A. The increase in the forest and woodland are not likely to occur in any of the later seral 

communities prioritized by WNHP. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

127 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternatives B and C 

Under Alternative B, the extent of Monument land in the grassland and shrubland class, which includes 

tree savanna, would increase by approximately 313 percent and the forest and woodland class would 

decrease by approximately 50 percent over the life of the plan. Under Alternative C, the grassland and 

shrubland class, which would include tree savanna, would increase by approximately 287 percent and the 

forest and woodland class would decrease by approximately 48 percent over the life of the plan (see Table 

7 on page 75). 

Treatments to improve grassland and shrubland condition under both alternatives would likely improve 

the quality of existing red fescue, great camas, and Oregon gumweed communities at Point Colville and 

Lummi Rocks in the long-term. Iceberg Point also contains an herbaceous bald and bluff community that 

would benefit from these treatments. Short-term negative effects on native plants in the community may 

occur during restoration efforts, such as damage from digging or herbicide application; these effects 

would be minor. 

Under alternatives B and C, the BLM would not convert G1S1 forest associations to other plant 

community types. Generally, the BLM would maintain some acres of uncommon forest associations 

identified in the Monument. Extent of non-G1S1 forest associations would decline. 

By removing 50 percent and 58 percent of forests in the Monument respectively, alternatives B and C 

(including sub-C) would both have severe negative impacts where those conversions occur within priority 

ecological community areas. The locations of vegetation treatments would be determined during plan 

implementation. Part of the ranking system for priority communities takes into account the current 

conservation status. The WNHP assumed that the communities at Point Colville and Iceberg Point would 

not be altered due to the ACEC designation. Areas most vulnerable to impacts are Patos Island, Little 

Patos Island, Point Colville, Carter Point, Iceberg Point, and Chadwick Hill. Conversion of priority 

forests to grasslands and shrublands would mean complete loss of those systems in the conversion 

footprint. Alternatively, careful vegetative treatments in these identified priority forested areas, such as 

weed removal, could benefit these systems. Although these forested community types are considered by 

WNHP to be critically imperiled, the constituent species would remain present and common within the 

San Juan Islands, and would increase in density and structural diversity in all areas not treated. 

Alternative D 

Under Alternative D, the BLM would maintain the current extent of Monument land in the grassland and 

shrubland and forest and woodland classes. It would undertake treatments to ensure that invasive plants 

and encroaching forest species and woody shrubs do not further expand into grassland and shrubland. 

This would have a minor positive effect on existing priority ecological communities by removing 

invasive plants and improving quality. 

Conclusion 

Table 26 qualitatively summarizes the effects of the alternatives on priority ecological communities and 

habitat for special status plant species. It describes each alternative as causing an improvement, decline, 

or no change (+,-,=) to current conditions. 

Alternatives B, C, and Sub-Alternative C would most improve the extent and condition of habitat for the 

four documented and one historically present special status species associated with the grassland and 

shrubland. Under these alternatives, there would be a decline in the extent of habitat for Niebla lichen. 

Similarly, improvements to the condition of grassland and shrublands at Lummi Rocks and Point Colville 

would subsequently benefit the priority ecological community identified there. Through the reduction in 

the extent of forested areas under these alternatives, there may also be a reduction in the extent of priority 

ecological communities on the Monument, depending on the location of site specific work. 

The No Action Alternative and Alternative A would see a reduction of habitat acres and condition for the 

four documented and historically present special status species associated with the grassland and 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

128 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 shrubland vegetation class. There could be reduction in the extent of the priority ecological communities 

2 that occur in grassland and shrublands at Point Colville and Lummi Rocks. Under these alternatives, 

3 there would be an increase in the extent of habitat for Niebla lichen. There could also be an increase in 

4 forested areas adjacent to identified forest priority ecological communities. The extent and quality of the 

5 habitat for all special status plant species and priority ecological communities would remain static under 

6 Alternative D. 

7 Table 26: Summary of effects of the alternatives on general habitat for special status plant species 

8 and priority ecological communities 

No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C and SubC 

Alternative 

D 

Grassland & Shrubland (golden 

paintbrush, slender crazyweed, 

white-topped aster, bear’s-foot

sanicle)

- - + + = 

Forest & Woodland (Niebla 

lichen) + + - - = 

Non-forested WNHP priority 

ecological communities 

- - + + = 

Forested WNHP priority 

ecological communities 

+ + - - = 

9 Cumulative Effects on Special Status Plants and Lichen 

While detailed trends of the special status plant and lichen populations in the Monument are not known, 

the BLM assumes alternatives that favor associated habitat could contribute to an improvement in 

populations and alternatives that do not favor those habitats could contribute to a decline in species trend 

in the San Juan Islands. Effects of the alternatives to rare plant and lichen species are described in more 

detail above. 

Due to the singular occurrence of populations of slender crazyweed, white-topped aster, and the two 

occurrences of Niebla lichen and bear’s-foot sanicle, the BLM does not believe that any minor negative 

effects of this RMP would cumulatively cause any of these species to become federally listed. While the 

Monument’s white-topped aster population is the only documented occurrence in the San Juan Islands, 

the species is well represented in the region, including on Vancouver Island, Fidalgo Island, and in 

Thurston County (WA). Slender crazyweed occurs on U.S. FWS islands near Iceberg Point, as well as 

several inland Washington counties, mainland British Columbia, and Idaho, Montana, and Wyoming. 

Bear’s-foot sanicle occurs on several small islands in the San Juan archipelago, and along the coast of 

Washington, Oregon, and California. Niebla lichen occurs in several other areas in the archipelago 

including on National Park Service property. It is also found south of the Puget Sound in Washington, 

and along the west coast from Alaska to Mexico (Consortium of Pacific Northwest Herbaria accessed 

2018). 

Cumulative Effects on Priority Ecological Communities 

While the plant communities, including WNHP priority ecological communities, in the Monument are 

described in Proclamation 8947 as “dramatic and unusual” in their diversity, they are also found in many

other locations in the archipelago and on the main land. 

The decrease in grasslands and shrublands under the No Action Alternative and Alternative A would 

contribute to the decline of the north Pacific herbaceous bald and bluff ecological systems, including the 

red fescue, camas, and Oregon gumweed communities, which has experienced a 30-50 percent short-term 

and 10-30 percent long-term decline in extent (WNHP 2015). 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

129 
 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative B and C, including Sub-Alternative C, would greatly improve the regional herbaceous bald 

2 and bluff trend mentioned above. However, if forest conversion to grasslands occurs where priority 

3 ecological systems occur, this would decrease the extent of forested priority ecological communities. 

4 Two priority 1 ecological systems, Douglas-fir (grand fir, western red-cedar) / dwarf Oregon-grape-salal 

5 forest and western redcedar-grand fir/swordfern, found on Patos and Iceberg Point have a long-term trend 

6 of 10-30 percent loss in the region. Douglas-fir, western hemlock, and salal forests, found on Carter Point 

7 and Patos, have experienced a 30-50 percent short-term and long-term decrease in acreage trend where 

8 found (WNHP 2015). Several of the WNHP identified priority forests found on Patos, Carter Point, and 

9 Chadwick Hill fall under the north pacific dry Douglas-fir madrone forest description, which is 

10 experiencing a 30-50 percent short-term and 70-80 percent long-term decline in extent in the region. 

11 Habitat and Plants Analytical Issue 5: How would the alternatives affect 

12 invasive plant species presence and spread within the Monument and the San 

13 Juan Islands? 

14 See Appendix B for analytical methods used in this analysis. See the Habitat and Plants Issue 5 section in 

15 Appendix E for background on noxious weeds, invasive plants, and control methods. 

16 Affected Environment 

17 Proclamation 8947 references invasive species as a threat to the Monument’s fire-dependent grasslands. 

18 More broadly, invasive plants, and specifically noxious weeds, threaten Monument woodland, wetland, 

19 and small islands both directly, through competition with native plants, and indirectly, through disruption 

20 of ecosystem function. 

21 The Washington State Noxious Weed Control Board identified 148 species on their 2017 list; 36 were 

22 listed as Class A (i.e., eradication is required). The San Juan County Noxious Weed Control Board 

23 identified 63 of these species in the county. In 2017, the county added butterfly bush (Buddleja davidii) 

24 with control or eradication required and changed old man’s beard to control or eradicate. There are also 

25 nine unregulated plants of concern in the county. Inventories in 2010 and 2013 found 15 noxious weed 

26 species in the Monument with five of these in Class B and 10 in Class C (see Table 27). San Juan County 

27 requires control or containment of four of the Class B and two of the Class C weeds. Although neither 

28 the State nor the county can mandate control on Federal land, the BLM currently cooperates with the 

29 county in controlling the Class B and C weeds amenable to hand control methods. 

30 Table 27: Washington State noxious weeds documented within the Monument, based on the 2017 

31 State and County noxious weed lists 

Species Weed 

Class 

Control or 

Containment 

required 

Sites documented within the Monument (species 

may exist in additional locations) 

shiny geranium 

(Geranium lucidum) B Yes Posey Island 

herb Robert (Geranium 

robertianum) B No Posey Island, Broken Point Island 

Scotch broom (Cytisus 

scoparius) B Yes Blind Island (Blind Bay and East Sound) 

spurge laurel (Daphne 

laureola) B Yes Victim Island, Blind Island (East Sound), Twin Rocks 

tansy ragwort (Senecio 

jacobaea) B Yes Kellett Bluff, Patos Island, Parks Bay Island 

130 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Species Weed 

Class 

Control or Sites documented within the Monument (species Containment may exist in additional locations) required 

Cattle Point, Point Colville, Watmough Bay, Iceberg Point, 

Posey Island, Victim Island, Blind Island (Blind Bay), Oak 

bull thistle (Cirsium 

vulgare) C Island, Little Patos Island, Twin Rocks, Kanaka Bay No Islands, Carter Point, Parks Bay Island, Reads Bay Island, 

Stuart Island, Chadwick Hill, McConnell Rocks, 

Richardson Rocks, Patos Island, Victim Island 

Canada thistle (Cirsium 

arvense) C No Watmough Bay, Kanaka Bay Islands 

* hairy cat’s ear

(Hypochaeris radicata) C Iceberg Point, Lummi Rocks, Reeds Bay Island, Victim No Island, Parks Bay Island, Posey Island 

common groundsel 

(Senecio vulgaris) C No 

common St. Johnswort 

(Hypericum perforatum) C No Carter Point 

common tansy 

(Tanacetum vulgare) C Yes 

English ivy (Hedera 

helix) C Yes Blind Island, Broken Point Island, Indian Island 

evergreen blackberry 

(Rubus laciniatus) C No 

Himalayan blackberry 

(Rubus armeniacus) C 

Cattle Point, Watmough Bay, Posey Island, Blind Island, 

No Broken Point Island, Eliza Island, Freeman Island, Indian 

Island, Oak Island, Patos Island, Skull Island, Twin Rocks 

oxeye daisy 

(Leucanthemum vulgare) C No Iceberg Point 

reed canary grass 

(Phalaris arundinacea) C No Watmough Marsh, Chadwick Marsh 

1 * Hairy cat’s ear in the USDA Plants database, common cat’s ear on the State of Washington noxious 

weed list 

Source: BLM 2013 Inventory 

The Monument has a substantial population of invasive plant species that the State has not identified as 

noxious weeds. While invasive plants are found in nearly every vegetation type in the Monument, they 

are most common in open areas and dry forests (McNew 2014). The most common invasive grasses 

include soft brome (Bromus hordeaceus), common velvetgrass (Holcus lanatus), Kentucky bluegrass 

(Poa pratensis), orchardgrass (Dactylis glomerata), silver hairgrass (Aira caryophyllea), ripgut brome 

(Bromus diandrus ssp. rigidus), brome fescue (Vulpia bromoides), and colonial bentgrass (Agrostis 

capillaris). In addition to the noxious weeds hairy cat’s ear, Canada thistle, and bull thistle, the most 

common invasive forbs include sheep sorrel (Rumex acetosella), garden vetch (Vicia sativa), tiny vetch 

(Vicia hirsuta), and narrowleaf plantain (Plantago lanceolata). English holly (Ilex aquifolium), an 

invasive tree, has been found in forests on Iceberg Point, Point Colville, Stuart Island, and Patos Island 

(McNew 2014). These other non-native invasive species would be a lower priority for control treatments. 

Noxious weeds and non-native invasive plants (invasive plants), as well as opportunistic native plants, 

can alter the floristic structure and composition of communities and disrupt key ecosystem processes. At 

local scales, these species can displace desirable native plants, interfere with site recovery mechanisms, 

and result in permanent changes to ecological condition and function. The loss of desirable native plant 

diversity may lead to decline or loss of wildlife habitat and increase the risk of losing special status 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

131 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 species. Once established, these invasive species can cause substantial harm to environmental and 

economic values. Invasive plant populations not only affect the condition of Monument habitats, but can 

also spread to adjacent or nearby lands outside of the BLM’s administration. For example, the San Juan 

County Noxious Weed Control Board is concerned that spurge laurel on the Monument’s Victim Island 

could spread. Boaters visiting Posey Island could also easily spread shiny geranium to other islands. The 

Monument is also susceptible to the spread of invasive plant species from non-BLM administered lands.

Line-point data from herbaceous balds and bluff areas collected in 2014 indicate an average of 45 percent 

non-native cover (BLM 2014a). The Monument’s grasslands are largely composed of non-native grasses 

and support a mixture of native and non-native forbs. Invasive grasses dominate the grasslands and 

shrublands, with invasive forbs common and invasive woody shrubs, such as blackberry, expanding into

the grasslands and shrublands as well.

Mechanisms for introduction and dispersal of invasive plants include natural disturbances, animals, 

management activities, and public use. Vectors of spread include wind, water, vehicles, administrative 

and recreational equipment, wildlife, pets, livestock, and visitors and staff. Seeds and other propagules

can be dispersed after becoming attached to feathers, fur, mud on equipment and vehicles, boats, and the 

clothing and footwear. Livestock and wildlife can disperse seeds that pass through digestive systems 

intact and viable as well as on fur, hair, and feathers.

Climate change increases the uncertainty over the effectiveness of invasive plant treatments. Some native 

plants may no longer be able to persist in their current ranges, creating additional opportunities for

nonnative plants to invade. Increased global temperatures and altered patterns of precipitation and water

storage will affect soil moisture and temperature regimes and soil biota, affecting which species can 

establish and persist and where. The physiological tolerances of some invasive plant species may be 

within the projected variation in climate and will in some instances be more suited to changed conditions 

(e.g., Molina-Montenegro and Naya 2012). Some of the current invasive plants may die out in response 

to changes in climate patterns, while previously non-invasive plants may become invasive (see the 

climate change section).

Approaches to addressing invasive plant species vary within the San Juan Islands. San Juan County 

prohibits the use of all pesticides on county rights-of-way. San Juan County has focused eradication and 

removal efforts on the Class A weeds milk thistle (Silybum marianum), garlic mustard (Alliaria 

petiolata), eggleaf spurge (Euphorbia oblongata), slenderflower thistle (Carduus tenuiflorus), and 

common cordgrass (Spartina anglica); and Class B and C weeds tansy ragwort, common teasel (Dipsacus 

fullonum), poison hemlock (Conium maculatum), meadow knapweed (Centaurea x moncktonii), perennial 

sowthistle (Sonchus arvensis ssp. arvensis), Scotch broom, and hoary cress (Lepidum draba) (SJCNWCB 

2017). The National Park Service, the U.S. Fish and Wildlife Service, and Washington State Parks use an 

integrated pest management approach, which may include the use of herbicides. The BLM currently 

exclusively uses hand cutting in order to avoid intentional ground disturbance. 

Effects of the Alternatives 

The BLM does not know the rate of invasive plant spread in the San Juan Islands generally or the 

Monument specifically. The consensus among invasive plant ecologists and many managers is that, with 

few exceptions, well established invasive plants continue to spread at their full biological potential. 

However, that potential has never been quantified for any species and likely varies from species to 

species. Within the Monument, some populations, such as the invasive grasses at Cattle Point, may 

already fully occupy all available space while others, such as several species at Iceberg Point, continue to 

spread as disturbances create new potential growing sites. 

This analysis rates the risk of continued spread or new introductions based on expected land management 

activities over the life of the plan and the area or miles of trail open for certain types of recreational uses. 

It also assumes that the effectiveness of invasive plant treatments depends on the number of acres planned 

for treatment, treatment options, and frequency of treatments. In general, the larger the number of acres 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

132 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 planned for treatment, the wider range of treatment options available, and the more frequent the 

treatments, the greater the probability of success. The effects of the action alternatives are rated relative 

to No Action Alternative, i.e., are the risks associated with invasive plant spread higher or lower than 

under current management. Because the BLM does not have specific information about invasive plant 

populations or treatments on private lands, no assessment of the risk of new invasions onto the Monument 

from adjoining lands is possible. However, the BLM can estimate the risk of spread from Monument 

lands onto adjoining lands, assuming the invasive plant(s) are not already present. 

Common to All Alternatives, Including the No Action Alternative 

Visitor use levels are expected to increase due to the combination of population growth generally and the 

desire to visit the Monument specifically. Visitors would inadvertently carry invasive plant seeds and 

propagules on clothing, pets, and vehicles into the Monument. These introductions may either spread 

existing invasive plants from one part of the Monument to another or from elsewhere on the San Juan 

Islands into the Monument. In addition, introductions of invasive species new to the San Juan Islands 

would be likely. 

Gravity, wind, water, and wildlife are all effective vectors of nearly all invasive plant species. Since these 

vectors are beyond the control of the BLM, they would maintain a continued risk of the spread of invasive 

plant species within the Monument and between the Monument and adjoining lands. Introductions of 

new invasive species would likely come from humans. 

No Action Alternative 

Under this alternative, current custodial management would continue. Current management of invasive 

plants consists of cutting Himalayan blackberry, Scotch broom, sweetbriar rose (Rosa rubiginosa), 

Canada thistle, and bull thistle using hand tools and power tools (BLM 2014a). The BLM treats 

approximately 20 acres per year (this includes hazard tree removal). 

Increased visitor use would increase the risks of user developed trails, erosion, trampling, and 

compaction, creating sites suitable for the establishment or spread of invasive plants (Masters and Sheley 

2001). Cutting alone is usually ineffective at both reducing the invasive species and increasing native 

species (Dennehy et al. 2011, Kettenring and Adams 2011), particularly if done only once per year (Tarmi 

et al. 2011). Cutting alone can keep the invasive plants listed in OR 130-2014-CX-0001 from spreading 

by preventing seed dispersal, but only if cutting occurs before seed formation with no subsequent 

reflowering or if seedheads are collected and disposed of properly. Cutting alone would require repeated 

visits to cut resprouts and new germinants from soil stored seed, such as from Himalayan blackberry 

(Tirmenstein 1989), Canada thistle (Zouhar 2001), and Scotch broom (Zouhar 2005). Overall, under 

current management, invasive plants would continue to spread, the risk of new introductions would 

remain high, and the risk that invasive plants could spread from the Monument onto adjoining lands 

would remain high. 

Alternative A 

Under Alternative A, invasive plant management would consist of eradicating or controlling noxious 

weed species where control is required, and controlling other invasive plants when less than 50 percent of 

the native vegetation remains in a community type across the Monument. Control is required for shiny 

geranium, Scotch broom, spurge laurel, tansy ragwort, common tansy, and English ivy. Control measures 

would be limited to physical (manual and mechanical) methods and biological methods. The Monument 

would be closed to recreation use, while research, educational, cultural and spiritual activities would 

continue. 

Closing the Monument to visitation would reduce the risk of invasive plant spread from most human 

activity, although some risk would remain from administrative and authorized activities. Of the noxious 

weeds where control is required, animals can spread spurge laurel, common tansy and English ivy 

(Gucker 2009, Waggy 2010, Washington State Noxious Weed Control Board No date), water can spread 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

133 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Scotch broom and common tansy (Zouhar 2005, Gucker 2009), and wind can spread tansy ragwort and 

common tansy (King County Noxious Weed Control Program 2006, Jacobs 2009, King County Noxious 

Weed Control Program 2010). In addition, there are several other very invasive plants not classified as 

noxious weeds that would continue to spread through vegetative propagation and dispersal of seeds by 

explosive dehiscence, wind, water, and animals. 

Waiting until less than 50 percent of the native vegetation remains means infestations would likely be 

large relative to parcel size. Control or eradication efforts are most successful when invasive plant 

populations are small and localized. Control efforts taken once infestations are large are typically very 

expensive, require several treatments over a single growing season and/or over several years, and can 

often fail (Davies and Sheley 2007 and references therein). Alternative A would likely fail to control 

invasive plant spread adequately, leading to further losses in plant diversity and potentially threatening 

the persistence of rare, sensitive, and culturally important plant species. Invasive plants would continue 

to pose a threat of spreading from the Monument to adjoining lands. 

Alternatives B and C 

Alternative B emphasizes increasing ecological resistance and resilience by increasing the extent of native 

vegetation and decreasing the extent of invasive plant species. All potential control measures would be 

allowed, with early detection and rapid response to new infestations emphasized. Alternative B would 

slightly reduce the acres open to recreation use (including recreational boat landings) relative to current 

conditions, but would increase the miles of trails. Permits would be required to access 167 acres and pets 

would be prohibited. In addition, active vegetation management through cutting and burning in forests 

and woodlands would likely create conditions suitable for the spread of invasive plants. 

Alternative C emphasizes approximating vegetation conditions that would have occurred prior to EuroAmerican settlement by increasing the extent of grasslands and shrublands and controlling invasive 

plants. All control methods would be permitted, with early detection and rapid response to new 

infestations emphasized. The Monument would be open to recreation use generally with no permits 

required for access and the potential to construct additional visitor facilities. Leashed pets would be 

allowed. The area available for recreational use (including recreational boat landings) would be similar to 

that under Alternative B, but the miles of trails would be less than the current condition. 

Since all forms of invasive plant management are available under both alternatives, the BLM could fully 

apply integrated plant management practices and ecologically-based invasive plant management 

principles. Larger infestations of invasive plants are more effectively treated using combinations of 

methods such as mechanical treatment or prescribed fire followed by herbicides, targeted grazing 

followed by mechanical treatment or herbicides, or other combinations of methods. Effective control of 

many invasive plants often requires combinations of methods (U.S. FWS 2009). The risks of new 

introductions and spread of invasive plants would be higher in Alternative B than C given increased 

hiking opportunities. The level of active vegetation management would be very similar between the two 

alternatives. Access to the full suite of treatment options increases the probability that the BLM can 

effectively control many invasive plants; protect rare, sensitive, and culturally important plants; and 

reduce the risks of invasive plants spreading from the Monument to adjoining lands. In addition, the 

BLM would be more likely to catch new infestations while small and more easily controlled (Davies and 

Sheley 2007). 

Sub-Alternative C 

Sub-Alternative C would have the same objectives as Alternative C, but the BLM would prohibit the use 

of herbicides to control invasive plants. To make up for the lack of herbicides, the frequency of manual 

and mechanical treatments would increase from an estimated five treatments to 20 treatments over the 

expected life of the plan. The acres and trails available for recreational use would be the same as under 

Alternative C. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

134 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The repeated mechanical treatments would be accompanied by frequent ground disturbance. Further, it is 

2 not clear that applying manual and mechanical treatments alone would effectively reduce certain invasive 

3 plants, particularly large infestations (Davies and Sheley 2007, U.S. FWS 2009). Uncertainty would 

4 increase over whether the BLM would could effectively control all new infestations and prevent invasive 

5 plants from spreading onto adjoining lands from the Monument. This alternative carries an increased risk 

6 that rare, sensitive, and culturally important plant species would also be harmed by the frequency of 

7 treatments (U.S. FWS 2009). 

8 Alternative D 

9 Alternative D would maintain the current extent, structure, and species composition of the different plant 

10 communities. Invasive plant management would emphasize early detection and rapid response to new 

11 infestations and eradication or control of the noxious weed species where control is required, but the 

12 BLM would not place a particular emphasis on reducing invasive plant species from current populations. 

13 The BLM would allow all methods of invasive species control. This alternative would have the greatest 

14 number of trail miles open to hiking. 

15 Since the BLM would allow all methods of invasive species control, this alternative would likely lead to 

16 successful control of most noxious weed species, with the possible exception of large infestations. 

17 However, since attempting to maintain the status quo with invasive plants is rarely successful, the 

18 probability remains high that these species would continue to spread, posing continued threats to rare, 

19 sensitive, and culturally important plant species and higher risks of spread to adjoining lands. The 

20 number of available trail miles and the continued availability of off-trail hiking would increase the 

21 probability of additional spread and new introductions from hikers and their equipment and pets. 

22 Conclusion 

23 The No Action Alternative and alternatives A and D would likely prove ineffective at controlling the 

24 spread of invasive plants, although Alternative D would be more likely to successfully control noxious 

25 weed species where control is required. Sub-Alternative C would likely prove ineffective at controlling 

26 the spread of invasive plants generally, although control or eradication of new or small infestations of 

27 species would occur where control can be achieved without the use of herbicides. The high frequency of 

28 treatment would create the highest risk to rare, sensitive, and culturally important plants of all the 

29 alternatives. Alternatives B and C would have the highest probability of controlling the spread of 

30 invasive plants. Alternative C would have a slightly lower risk of new introductions and continued spread 

31 by visitors than Alternative B. 

32 Table 28: Summary of impacts from alternatives to risks of invasive plant spread 

No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C Sub-Alt C Alternative D 

Noxious Weeds 

Requiring High High Low-Mod Low-Mod High Low-Mod 

Risk of Control 

Continued All Other 

Spread Noxious Weeds High High Low-Mod Low-Mod High High 

Other Invasive 

Plants High High Low-Mod Low-Mod High High 

Effectiveness of Available 

Measures Low* Low Mod-High Mod-High Low-Mod Mod-High 

Risks to Native Plants High High Low-Mod Low-Mod High High 

Risks to Adjoining 

Properties High High Low-Mod Low-Mod High High 

Spread by Visitors High High Mod Low-Mod Low-Mod High 

135 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 *Assumes continuation of current management.

Cumulative effects of the alternatives on the presence and spread of invasive 

plants in the San Juan Islands 

Regardless of alternative selected, the number of vectors and resident and visitor population growth 

would ensure that invasive plants remain problematic on the islands generally and within the Monument. 

Only small, localized populations of invasive plants can be eradicated, but detecting small populations of 

invasive plants remains difficult (Emry et al. 2011, AHWGISCC 2014). Since eradication is possible 

only for small, localized populations and since control is not the same as eradication, invasive plants are 

highly likely to remain present both within the Monument and the San Juan Islands. Invasive plants are 

also likely to continue moving between adjoining lands and the Monument due to a number of vectors 

that no entity can control. 

Climate change brings additional uncertainty over time as it can affect the effectiveness of treatment 

regimens and how readily a site can be invaded by a particular species (AHWGISCC 2014). Changing 

climate can also increase an invasive species, decrease it, or cause a currently benign non-native species 

to become invasive (AHWGISCC 2014). While it is not possible to estimate which nonnative plants may 

increase, decrease, or become invasive, such changes are more likely to occur later in the expected life of 

the plan than earlier. In addition, some non-native plants may be more prone to rapid adaptation as a 

result of changing climate, particularly where introduced populations are very diverse genetically, 

indicating introductions from different parts of the invading species’ native range (Henery et al. 2010, 

Colautti and Barrett 2013). 

Habitat and Plants Analytical Issue 6: How would use of chemical 

treatments (e.g., herbicides) affect non-target resources including vegetation, 

human health and safety, water quality, wildlife, and soils? 

Affected Environment 

There are currently no chemical (e.g., herbicide) treatments occurring within the Monument. 

Chemical treatments on public lands within the San Juan Islands are limited. In general, public land 

managers in San Juan County use herbicides to treat weeds in situations where alternative means of 

control would not be effective. The use of herbicides is currently prohibited on county road rights-ofway, but herbicides are applied in a limited amount to control weeds on other county properties (San Juan 

County Noxious Weed Board 2017). Chemical treatments are also part of the integrated pest 

management approach taken by the National Park Service, U.S. Fish and Wildlife Service, and 

Washington State Parks within the San Juan Islands (NPS 2008, U.S. FWS 2010, Washington State Parks 

2000). 

Effects of the Alternatives 

The general impacts from herbicide use on human health and the environment are analyzed in the 2007 

EIS and the 2016 EIS. This document tiers to both of these EISs and examples of impacts applicable for 

Monument lands are summarized and incorporated by reference below. These documents are available 

online at: 

• Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States

Final Programmatic EIS (2007 EIS): eplanning.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=103592

• Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron on Bureau of Land

Management Lands in 17 Western States Final Programmatic EIS (2016 EIS): eplanning.blm.gov/eplfrontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=103601 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

136 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Whenever applying herbicides, the BLM would also undertake the standard operating procedures and 

mitigation measures identified in the 2007 and 2016 EISs. 

Appendix Q summarizes and contextualizes the potential for effects from herbicides described in the two 

vegetation treatment EISs. 

Each of the 21 currently approved herbicides42 listed in the 2007 EIS and 2016 EIS would be available for 

use within the Monument under the No Action Alternative and alternatives B, C, and D. The BLM would 

prohibit the use of herbicides under Alternative A and Sub-Alternative C. If the Approved RMP allows 

their use, specific herbicides chosen for future projects would be dependent on project-specific objectives 

and analysis. 

The BLM estimated the extent of herbicide treatments that would be necessary to meet the objectives of 

each alternative over the life of the plan (see Habitat and Plants Issue 3). Dependent upon site-specific 

conditions and weed densities, the BLM estimates that under Alternative B it would treat an average of 

128 acres annually, followed by an average of 192 acres under Alternative C, and an average of 23 acres 

under Alternative D. The BLM assumes that it would treat these same acreages multiple times over the 

life of the plan. If current trends continue, the BLM would not use herbicides under the No Action 

Alternative. They would be prohibited under Alternative A and Sub-Alternative C. 

Cumulative Effects of the Alternatives on Impacts from Herbicides on Non-Target 

Resources in the San Juan Islands 

As stated in the affected environment section above, herbicide use in the San Juan Islands is limited. 

However, other agencies and organizations, such as the National Park Service, State Parks, the Nature 

Conservancy, County Land Bank, and U.S. Fish and Wildlife Service, as well as private landowners have 

used and currently use herbicide to treat vegetation. The BLM expects that herbicide use on these lands 

will continue over the next 20 years. 

The BLM does not expect cumulative effects from herbicides under the No Action, Alternative A, or SubAlternative C because it would prohibit herbicide use in the Monument. Conversely, the beneficial 

impacts from treating non-native and invasive vegetation with herbicides described in sections above 

under alternatives B, C, and D would not occur under these alternatives either individually or 

cumulatively when considering past, present, and reasonably foreseeable herbicide use on non-BLMadministered lands. 

Under alternatives B, C, and D, cumulative effects on non-target resources would be similar. These 

effects would occur over the largest amount of acres under Alternative C (average 192 acres treated 

annually), followed by Alternative B (average 128 acres annually), and on the least amount of acres under 

Alternative D (average 23 acres annually). Considering the limited amount of acreage estimated for 

treatment in the Monument under these alternatives, the BLM’s herbicide use would not add substantially 

to the overall use of herbicides across the San Juan Islands. Moreover, the BLM’s potential use of

herbicide under these alternatives would be similar to that of other agencies and organizations on the 

islands in that it would be considered as an additional tool for vegetation management where deemed 

appropriate based on site conditions and the species requiring treatment. 

Lands and Realty 

Key Points 

 The designating proclamation prohibits the BLM from disposing of any Monument land except by 

exchanges that further the protective purposes of Proclamation 8947. 

 

42 2,4-D, bromacil, chlorsulfuron, clopyralid, dicamba, diuron, glyphosate, hexazinone, imazapyr, 

metsulfuron methyl, picloram, sulfometuron methyl, tebuthiuron, triclopyr, imazapic, diquat, 

diflufenzopyr (in formulation with dicamba), fluridone. aminopyralid, fluroxypyr, and rimsulfuron 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

137 
 

 

 

 

 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1  Rights-of-way for the Coast Guard to access aids-to-navigation would be unaffected by the range of

2 alternatives around rights-of-way avoidance or exclusion areas.

3 This section contains two analytical issues: 

4 1. How would the alternatives affect the availability of Monument lands for rights-of-way? (Page 138)

5 2. How would the alternatives affect the BLM’s ability to engage in land exchanges that further the

6 protective purposes of Proclamation 8947? (Page 140)

7 Lands and Realty Analytical Issue 1: How would the alternatives affect the 

8 availability of Monument lands for rights-of-way? 

9 See Appendix B for analytical methods used in this analysis. The Lands and Realty Issue 1 section of 

10 Appendix E provides background on rights-of-way including the definition of rights-of-way avoidance 

11 and exclusion areas. 

12 Affected Environment 

13 Proclamation 8947 designating the San Juan Islands National Monument provides that “nothing in this 

14 proclamation shall be deemed to limit the authority of the Secretary of Homeland Security to engage in 

15 search and rescue operations, or to use Patos Island Light Station, Turn Point Light Station, or other 

16 aids to navigation for navigational or national security purposes.” One implication of this language is

17 the necessity of maintaining existing, and potentially authorizing new, right-of-way authorizations to 

18 the Coast Guard, which is under the Department of Homeland Security, to operate and maintain aid to 

19 navigation equipment and associated facilities within and adjacent to the Monument. 

20 The 1990 ACEC decisions prohibit rights-of-way in these areas for additional roads, power lines, 

21 pipelines, or communication facilities. Outside of the ACECs, the BLM considers rights-of-way in the 

22 Monument on a case-by-case basis. There are no recorded applications for rights-of-way on Monument 

23 lands beyond the Coast Guard rights-of-way described below. 

24 There are currently five active rights-of-way within the Monument issued to the Coast Guard for road and 

25 utility access to lighthouse related structures and equipment. Two of the right-of-way reservations 

26 include visibility and noise protective areas and authorization to enforce these protective measures. The 

27 BLM is currently researching whether other rights-of-way may occur on lands it acquired from private 

28 ownership on Lopez Island in the 1990s. Decisions made through this planning effort would not affect 

29 existing rights-of-way. 

30 The visibility protective areas apply to land formerly withdrawn to the Coast Guard at Cattle Point and at 

31 Turn Point. This provision allows Coast Guard to limit the height of structures and prune and remove 

32 vegetation to prevent interference with unobstructed visibility at these facilities. The right-of-way at 

33 Cattle Point also includes a protective provision prohibiting human habitation and the construction of 

34 dwellings to minimize effects to the sound pressure levels of the fog signal. Any proposed action by the 

35 BLM that has the potential to interfere with visibility (at Cattle Point and Turn Point) or sound pressure 

36 levels (at Cattle Point) would need to be reviewed by the Coast Guard to assure the protective area is not 

37 adversely impacted. 

38 Table 29: Current known rights-of-way in the Monument*

BLM Case File 

Serial Number Location and Purpose for the Right-of-Way Issued/Expiration Date 

WAORE 0 016851 Cattle Point – Access Rd & Restrictive Interference 1965 / Perpetual 

WAORE 0 018465 Iceberg Point – Access Road 1968 / Perpetual 

WAOR 36694 Turn Point –Access Rd & Restrictive Interference 1984 / Perpetual 

WAOR 38385 Patos Island – Walkway & Landing Dock 1985 / Perpetual 

WAOR 67814 Cattle Point – Temporary Access Road to Lighthouse 2016 / 2019 

138 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 * The BLM is currently researching whether other rights-of-way may occur on lands it acquired from 

private ownership on Lopez Island in the 1990s. 

Effects of the Alternatives 

No Action Alternative 

Under the No Action Alternative, the BLM would continue to generally consider new requests for rightsof-way on a case-by-case basis. Except for rights-of-way for additional roads, power lines, pipelines, or 

communication facilities in areas covered under the 1990 ACEC decisions, the BLM could continue to 

allow rights-of-way it determines to be consistent with the protection and restoration of the Monument’s 

objects and values. If current trends in applications continue, the number of rights-of-way would remain 

static or increase only minimally. 

Alternative A 

Under Alternative A, the BLM would continue to consider new requests for rights-of-way on a case-bycase basis. The BLM could allow rights-of-way it determines to be consistent with the protection and 

restoration of the Monument's objects and values. If current trends in applications continue, the number 

of rights-of-way would remain static or increase only minimally. 

Alternatives B and D 

Under alternatives B and D, the BLM would designate the Monument as a right-of-way avoidance area. 

The BLM could grant rights-of-way that do not degrade Monument objects and values, in addition to 

those requested by the Coast Guard as necessary for the use and maintenance of aids to navigation for 

navigational or national security purposes. 

As specified under alternatives B and D, the BLM would not consider rights-of-way for wind and solar 

energy projects or communications towers, as, given the small size of Monument parcels, these types of 

projects would be very likely to negatively impact Monument objects and values. This clear prohibition 

would save time and energy for those considering submitted applications for rights-of-ways for these 

uses. 

Alternative C 

Under Alternative C, the BLM would designate the Monument as a right-of-way exclusion area, with an 

exception for rights-of-way to the Coast Guard as necessary for the use and maintenance of aids to 

navigation for navigational or national security purposes. In the event that an individual or entity does 

submit an application for a right-of-way over Monument land, the BLM would not consider this request 

unless it meets the exception described above. If current trends in applications continue, this restriction 

would have a minimal effect on potential right-of-way inquirers. The number of rights-of-way within the 

Monument would remain static or increase only minimally through requests from the Coast Guard. 

Conclusion 

Rights-of-way for Coast Guard aids-to-navigation access would be unaffected by the alternatives. 

Assuming limited demand for rights-of-way continues into the future, the effects on new rights-of-ways 

would be minimal under all alternatives. To the extent that rights-of-way are sought in the future, 

Alternative A would have the least effect on these requests, though the Monument Manager would still 

only issue a right-of-way where he or she determines that it is consistent with Proclamation 8947. 

Alternative B would have the greatest potential impact on new rights-of-way, by prohibiting them except 

to the Coast Guard as necessary for the use and maintenance of aids to navigation for navigational or 

national security purposes. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

139 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Lands and Realty Analytical Issue 2: How would the alternatives affect the 

BLM’s ability to engage in land exchanges that further the protective purposes of

Proclamation 8947? 

See Appendix B for analytical methods used in this analysis. The Lands and Realty Issue 2 section of 

Appendix E provides background on land tenure zones. 

Affected Environment 

Since no RMP currently covers these lands, there are no land tenure zones within the Monument. 

Proclamation 8947 prohibits any disposal of Monument lands except by exchanges that further the 

protective purposes of the proclamation. 

Effects of the Alternatives 

The alternatives differ in how the BLM would apply land tenure zones to the Monument. Land tenure 

zones would affect the BLM’s ability to engage in land exchanges that would further the protective 

purposes of the proclamation (e.g., by consolidating sensitive habitat). The alternatives have no effect on 

the BLM’s ability to acquire new lands through donation or purchase. 

No Action Alternative 

Under the No Action Alternative, there would continue to be no RMP decisions on land tenure. The 

BLM would continue to only consider land disposal through exchanges that further the proclamation’s

protective purposes. Exchanges would require additional planning and analysis. 

Alternative A 

Under Alternative A, the BLM would designate the whole of the Monument as land tenure zone 1 (i.e., all 

lands would be retained). This would ensure that all Monument lands would remain under BLM 

administration and continue to be managed consistent with the proclamation. It would preclude the BLM 

from undertaking exchanges that would further the protective purposes of the proclamation. 

Alternative B, C, and D 

Under alternatives B, C, and D, the BLM would designate Monument lands acquired using Land and 

Water Conservation Funds (currently, Watmough Bay, Chadwick Hill, and parts of Iceberg Point) as land 

tenure zone 1. This would ensure that these lands remain under BLM administration to be managed 

consistent with the proclamation and the purposes for which they were acquired. All other Monument 

lands would be land tenure zone 2 (i.e., retain unless exchanged to further the proclamation’s protective 

purposes). Any exchange of Monument land would require additional planning and analysis. 

Conclusion 

The BLM would continue to have the ability to engage in exchanges that further the protective purposes 

of the Monument under the No Action Alternative and for the majority of the Monument under 

alternatives B, C, and D. The BLM would not have the ability to engage in such exchanges under 

Alternative A. 

Paleontological Resources 

Key Points 

 There is one documented paleontological resource locality in the Monument. 

 Alternative C and Sub-Alternative C would have the greatest potential for disturbance to 

paleontological resources from vegetation treatments. 

 The No Action Alternative and alternatives B and D would have the greatest potential for disturbance 

to paleontological resources from recreation. 

This section contains one analytical issue: 

1. How would the alternatives affect paleontological resources within the Monument? (Page 141) 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

140 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Paleontological Resources Analytical Issue 1: How would the alternatives 

affect paleontological resources in the Monument? 

See Appendix B for analytical methods used in this analysis. See the Paleontological section of Appendix 

E for general background on paleontological resources. 

Affected Environment 

Proclamation 8947 refers to fossils that have been discovered throughout the San Juan Islands. One 

paleontological resource locality has been documented within the Monument. The locality, which 

currently appears to be in stable condition, includes remains of Serpula vermicularis, a calcareous tube 

worm, fan worm, or plume worm, often found in marine inter-tidal zones. 

While this is the only documented paleontological resource locality in the Monument, the Monument 

includes exposures of rock formations and groups in which fossils have been found in the surrounding 

area. Given that paleontological resources occur throughout the San Juan Islands additional 

paleontological resource localities likely occur within the Monument. Paleontological resources in 

exposures of the Nanaimo Group of rock from the Upper Cretaceous (100.5 to around 66 million years 

ago) have been found on Vancouver Island and Gulf Islands of Canada as well as in the San Juan Islands. 

Common paleontological resources from the shallow marine rocks found in the Cedar District Formation, 

a member of the Nanaimo Group, include ammonites, baculitids, bivalves, and other fossil remains. 

The first dinosaur fossil discovered in Washington State was found in rock from the Cedar District 

Formation in the San Juan Islands. The fossilized bone is one of the northernmost discoveries of 

theropod dinosaurs on the Pacific Coast (Peecook and Sidor 2015). In addition, paleontological remains 

of various plants and animals and their trackways occur within the Chuckanut Formation, a sedimentary 

unit that formed during the Eocene Epoch (54 to around 42 million years ago). Chuckanut and related 

geologic formations occur in western Washington including the San Juan Islands and British Columbia. 

Pleistocene (2.6 million years ago to around 11,700 years ago) age remains of extinct animals have also 

been identified in the San Juan Islands. Bones of the extinct species of bison (Bison antiquus), found on 

Orcas Island, appear to have been utilized by early inhabitants of the area near the end of the last Ice Age. 

Paleontological resource localities are nonrenewable resources. Natural processes including erosion, 

weathering, soil conditions, and animal activity can expose and adversely affect these resources, as can 

human activities, whether intentional or inadvertent. Recreational use of the area has increased over the 

last decade, increasing the possibility of finding paleontological resources but also increasing the risk of

unauthorized collection or vandalism in areas where paleontological resources are exposed. Actions that 

result in excavations, research studies, or other measures that require survey and inventory for 

paleontological resources would contribute information to the scientific record. 

Effects of the Alternatives 

The alternatives vary in their impact to paleontological resources. Management actions most likely to 

affect paleontological resources include those associated with shoreline stabilization, vegetation 

treatments, and recreation. The BLM can reduce effects to paleontological resources through systematic 

and thorough inventories. 

The integrity of paleontological resources can be assessed by the condition of the paleontological resource 

and its relationship with its stratigraphic context (e.g., the geological layer in which it is found). 

Disturbance can obscure the association between the paleontological resource and its place of geologic 

origin making it difficult to accurately identify or classify the species of individual specimens and the age 

of the fossil-bearing deposits. Actions that alter, degrade, or otherwise affect the integrity and condition 

of a paleontological resource or locality have a high potential to impact their value as a resource for 

science, education, and recreation. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

141 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Long-term adverse impacts to paleontological resources could include the damage, destruction, or 

complete loss of scientifically important paleontological resources. The greater the extent and depth of 

ground disturbing activities, the greater the potential for impacts to paleontological resources, particularly 

where the subsurface potential for fossil bearing sediments cannot be determined prior to the ground 

disturbance. Increased visitor access to sensitive paleontological resources and localities can lead to 

unauthorized collection, inadvertent damage, or vandalism. 

Impacts to paleontological resources exposed by natural erosion, particularly along the shorelines, can be 

exacerbated by surface disturbing activities. Such activities can lead to the discovery of fossils and fossil 

bearing rock formations. These activities can also lead to permanent damage or destruction of 

paleontological resources or to increased vulnerability to unauthorized collection. Measures to control 

ground disturbance, erosion, and loss of ground cover could reduce damage to or destruction of 

paleontological resources located on or near the ground surface. 

Under all alternatives, the BLM would identify paleontological resources through review of the Potential 

for Fossil Yield Classification (where available) and inventory prior to authorizing projects that could 

impact paleontological resources, such as campsite development, trail building, tree removal, and digging 

or pulling to remove invasive plants. The Potential Fossil Yield Classification system provides an 

estimate of the potential that important paleontological resources will be found and is used to assess 

possible resource impacts and management needs. 

Where important paleontological resources are identified, the BLM would modify projects to avoid or 

reduce impacts. Despite these precautions, recreation activities and vegetation treatments create the 

potential for disturbance and loss of paleontological resources. Where important scientifically important 

paleontological resources could not be avoided, the BLM would develop mitigations to address adverse 

impacts. Actions that include paleontological resources survey, inventory, and research studies would 

contribute information to the scientific record. 

Under all alternatives, the BLM would address potential impacts to paleontological resources through 

project design during implementation-level planning and NEPA compliance and Paleontological 

Resources Preservation Act review. The BLM would work with partners to avoid, minimize, or mitigate 

potential impacts and identify, evaluate, protect, stabilize, and repair scientifically important 

paleontological resources. 

Impacts from Shoreline Stabilization 

Shoreline stabilization measures would reduce or limit erosion from large storm events. Storms and 

associated tidal surges can modify spatial relationships of paleontological resources to their stratigraphic 

context and alter or destroy the physical characteristics of the paleontological resources themselves. This 

can make it difficult or impossible to accurately classify the species of individual specimens, or identify 

the age of the fossil-bearing deposits or better understand the paleo-environment from which the 

paleontological resource originated. Measures to stabilize shorelines could preserve the integrity of fossil 

deposits and prevent further damage or loss of opportunities for studying and learning about past 

environments. 

Where shoreline erosion threatens important paleontological resources, the BLM, in consultation with 

university and other scientific and community partners, would consider shoreline stabilization to protect 

these resources. It is not possible to predict the number or location of these projects. Impacts to 

paleontological resources from the range of alternatives for shoreline stabilization are summarized in the 

paleontological resources conclusion below. 

Impacts from Recreation 

Recreational use and access can impact paleontological resources through direct disturbance, soil 

compaction, altered surface water drainage, erosion, and access leading to unauthorized collection or 

vandalism. These effects can result in a loss of specimen integrity and scientific information and public 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

142 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 education potential. Surface-disturbing activities could directly impact any undiscovered paleontological 

resources by exposing or damaging buried material. This could result in inadvertent destruction or loss of 

scientific and educational values, including potential illicit collecting of newly exposed materials. 

Impacts from recreation on paleontological resources would be substantively the same as those described. 

In general, increases in acres open to camping and trail miles open to hiking, equestrian, or bicycling 

access would increase risk of exposure or damage to undocumented paleontological resources. Impacts to 

paleontological resources from the range of alternatives for recreation are summarized in the conclusion 

below. 

Roads and trails would not cross documented paleontological resource localities under any alternative. 

Under the No Action Alternative and alternatives B and C, the documented paleontological resource 

locality would continue to be within 164 feet43 of 0.02 miles of trail. Under Alternative A these 0.02 

miles of trail would be closed to recreational use and would likely return to a natural state over time. 

Under alternative D, there would be 0.08 miles of trail within 164 feet of the documented resource. The 

known locality would be in an RMA under alternatives B, C, and D. The area would be closed to 

camping under all alternatives. 

Impacts from Vegetative Treatments 

Vegetation management can include mechanical, biological, chemical treatment and prescribed fire. The 

treatment measures that the BLM would allow during plan implementation vary by alternative. While the 

BLM would identify paleontological resources prior to authorizing surface disturbing projects, vegetation 

treatments that include surface disturbance such as hand pulling, digging, surface scarring, or tree 

removal could directly impact undiscovered paleontological resources and human remains by exposing 

buried fossil material. Prescribed fire could impact paleontological resources through staining or spalling 

(i.e., chipping) of fossils from high temperature fires. Chemical herbicidal applications would have 

limited impacts to paleontological resources. 

Impacts to paleontological resources from the range of alternatives for vegetation management are 

summarized in the paleontological resources conclusion below. 

Conclusion for Paleontological Resources 

The alternatives would vary in their effects on paleontological resources within the Monument. 

Specifically, they would vary in terms of available stabilization tools and the potential for short-term and 

long-term effects from disturbance related to recreation and vegetation management. 

Stabilization of localities threatened by erosion and storm surges would likely be most effective under 

Alternative B and the No Action Alternative where the full range of shoreline stabilization measures 

would be available to protect paleontological resources in the Monument. Under alternatives A and C, 

and under Alternative D in areas with wilderness characteristics (232 acres), the BLM would not allow 

hard shoreline stabilization. Because soft stabilization measures are less effective than hardening in 

certain situations, the BLM assumes that some additional paleontological resources would be damaged, 

altered, or lost under alternatives that do not allow hard shoreline stabilization in some or all of the 

Monument. 

As described above, the BLM would use the Potential for Fossil Yield Classification and inventory prior 

to authorizing projects that can impact paleontological resources. Where important paleontological 

resources are identified, the BLM would modify the project to avoid, reduce, or mitigate impacts. 

Under the No Action Alternative and Alternative D, potential impacts from camping, off-trail hiking, and 

extensive trail use would occur, but there would be limited potential for disturbance of paleontological 

resources due to vegetation management. As a result, the No Action Alternative and Alternative D would 

 

43 Generally, 164 feet is the minimum distance the BLM uses for buffers to avoid potential impacts to a 

paleontological resource. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

143 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 both have an intermediate potential for disturbance to paleontological sites however, increases in 

designated camping, opening previously closed areas to camping, and increasing trail miles by 

approximately 50 percent would increase potential risks under Alternative D. Alternative C and SubAlternative C would have the greatest potential of any alternative for disturbance to paleontological 

resources from vegetation treatments, but more limited potential for disturbance from trail use and 

camping. Because of this mix of high potential for disturbance from vegetation treatments and a 

moderate potential for disturbance from recreation activities, these alternatives would have a higher 

potential for disturbance compared to the No Action Alternative and alternatives A, B, and D. 

Under Alternative A, the BLM would prohibit recreation in the Monument and undertake a very limited 

approach to vegetation management. Alternative A would produce the least potential for human caused 

damage, alteration, or loss of paleontological resources though some paleontological resources could be 

damaged or lost where soft shoreline stabilization measures are ineffective. In addition, there would be 

fewer opportunities for public education and enrichment about paleontological resources, though 

opportunities for scientific research would continue. This alternative would have the lowest potential of 

any alternative for disturbance to paleontological resources from the recreation activities and vegetation 

management. 

Under Alternative B, the BLM would undertake more extensive vegetation treatments than would occur 

under the No Action Alternative and alternatives A and D, though they would be less extensive than 

under Alternative C and Sub-Alternative C. Under this alternative, more than half of the Monument 

would be open to dispersed camping by permit and trail miles would increase by 27 percent. Because of 

the relatively high potential for disturbance from both recreation and vegetation management, the BLM 

believes this alternative would have a high potential for disturbance to paleontological resources. 

However, a full range of shoreline stabilization measures under this alternative would reduce potential 

impacts to paleontological resources. 

Under Alternative C, the BLM would undertake more extensive vegetation treatments than under the No 

Action Alternative and alternatives A, B, and D, though they would be less extensive than under SubAlternative C. Extensive vegetation treatments would contribute to adverse impacts to paleontological 

resources if the BLM does not effectively identify and avoid these resources prior to treatments. Potential 

impacts from recreation would be moderate under this alternative and it would be more likely reduce 

impacts from recreation to paleontological resources more than any alternative other than A. As under 

Alternative A, the BLM would prohibit hard shoreline stabilization. Measures to reduce long-term 

adverse impacts would occur where stabilization measures are ineffective for controlling erosion leading 

to damage or loss of important paleontological resources. 

Under Sub-Alternative C, the BLM would undertake more extensive vegetation treatments than would 

occur under the other alternatives. Without the use of herbicides, the BLM would likely need to increase 

the repetition of mechanical treatments to meet the vegetation objectives, which would contribute 

additional short-term and long-term negative impacts related to ground disturbance. Risk for impacts to 

paleontological resources from recreation would be the same as Alternative C but when combined with 

the risk from vegetation management, this alternative would have the greatest potential risk to 

paleontological resources. 

Under Alternative D, the BLM would maintain the approximate extent and condition of plant 

communities in the Monument as of 2016. The BLM would increase trail miles by approximately 50 

percent and most of the Monument would be open to camping. The BLM would allow hard shoreline 

stabilization except in areas with wilderness characteristics. Considering all factors, under Alternative D, 

there would be greater potential risk to paleontological resources than under the No Action Alternative 

and Alternative A, similarly risk as Alternative B, and less risk than under Alternative C and SubAlternative C. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

144 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Cumulative effects of alternatives on paleontological resources in the San Juan 

Islands 

The Monument’s contribution to the fossil record in the San Juan Islands is relatively small given that

only one paleontological resource locality has been recorded in the Monument. Fossil bearing geologic 

formations from the Upper Cretaceous, Eocene, Pleistocene and other time periods have been 

documented in the San Juan Islands. A number of the formations likely occur within the Monument and 

could include additional paleontological resources. The majority of the documented paleontological 

resources are outside of the Monument. 

Natural erosion and human development have impacted numerous fossil bearing formations in the San 

Juan Islands. San Juan County has the lowest shoreline modification level in the Puget Sound region, 

with around 5 percent of its shorelines modified (Herrera 2011, Friends of the San Juans 2011). Even 

with limited shoreline modification, development and some degree of shoreline simplification have 

altered the nearshore environment of all the major islands. Most Monument shorelines are relatively 

unaltered pocket beaches, feeder bluffs, and rocky headlands. 

While less altered than outside shorelines, developments have taken place on lands now included in the 

Monument. Developments constructed before BLM administration include lighthouses and associated 

aids to navigation facilities, recreation sites, and roads and trails, some of which receive ongoing 

maintenance and care. Filling and development occurred historically in and near the wetland at 

Watmough Bay and agricultural development occurred near Chadwick Hill and at Iceberg Point. Many of 

these developments have potentially obscured, damaged, altered, or destroyed paleontological resources. 

Reasonably foreseeable actions that would affect coastlines within the San Juan Islands over the next 20 

years include the rerouting of the road to Agate Beach on Lopez Island and the construction of docks and 

other small scale coastline developments within the San Juan Islands. The alternatives would differ in the 

extent to which they would contribute to the protection or disturbance of paleontological sites within the 

San Juan Islands. 

Because development and shoreline erosion is likely to continue, paleontological resources in the San 

Juan Islands will continue to be threatened, damaged, or lost. The overall number of paleontological 

resources in the San Juan Islands (documented and undocumented) will likely decline over time. While 

the total number of scientifically important paleontological resources is likely to decline, the number of 

documented localities are likely to increase through inventories and unintentional discoveries. 

The alternatives would differ in their effect on the Monument’s contribution to the total number of 

scientifically important paleontological resources and localities in the San Juan Islands. As described in 

the conclusion (above), they would differ both because of the tools available to protect paleontological 

resources and because of the magnitude of the potential for these resources to be disturbed or lost due to 

recreational activities and vegetation management. Under all alternatives, there would be some potential 

for disruption or loss of important paleontological resources due to shoreline erosion and storm surge, 

visitor use, and vegetation management. 

Considering all factors, the Monument’s contribution to paleontological sites in the San Juan Islands 

would be most likely to decline under Sub-Alternative C, followed by alternatives C, B, D, and the No 

Action Alternative. Alternative A would have the lowest likelihood that the Monument’s contribution to 

paleontological sites in the San Juan Islands would decline over the life of the plan. 

Recreation and Visitor Services 

Key Points 

 Because the Monument encompasses only 4 percent of the area’s public lands the alternatives would 

have a limited effect on recreational opportunities in the San Juan Islands as a whole, 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

145 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1  Because the Monument encompasses 53 percent of the public land on Lopez Island, the alternatives 

would have a substantial effect on the recreational opportunities available to its residents and visitors. 

 While the Monument encompasses only a small percent of the public land in the San Juan Islands, the 

BLM’s recreation decisions can affect the demand for recreational opportunities on non-Monument 

lands and on the management effectiveness of nearby land managers. 

Note: this section addresses impacts to travel within the Monument, since the great majority of travel is 

associated with recreation. 

This section contains three analytical issues: 

1. How would the alternatives’ approaches to recreation and transportation affect recreational

opportunities? How would the alternatives affect acres and trails open to potentially conflicting 

recreational uses and vegetation treatments that would disrupt recreational opportunities? (Page 146) 

2. How would the BLM’s designation of recreation opportunity spectrum classes across the alternatives

affect recreation settings in the Monument? (Page 183) 

3. How would the alternatives indirectly affect the management of human use activities on nearby nonBLM-administered lands in the San Juan Islands? (Page 187) 

Background 

When developing plans, the BLM designates areas that it intends to manage to support recreational 

opportunities as recreation management areas (RMAs). It identifies visitor activities, experiences, and 

benefits and allowed and prohibited uses to support those objectives. See Appendix O for RMA 

frameworks that lay out the alternative’s range of recreation objectives and use decisions for each RMA. 

For further background information on the BLM’s approach to recreation management see Appendix E. 

Recreation and Visitor Services Analytical Issue 1: How would the 

alternatives’ approaches to recreation and transportation affect recreational 

opportunities? How would the alternatives affect acres and trails open to 

potentially conflicting recreational uses and vegetation treatments that would 

disrupt recreational opportunities? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Proclamation 8947 does not identify recreation as an object or value for which the Monument was 

designated. Recreation is, however, a primary means by which the public can interact with and learn to 

appreciate the Monument’s ecological and cultural objects and values. Recreation also has the potential 

to degrade the values that attract visitors to the area. 

In the absence of a law, regulation, or supplementary rule, BLM-administered lands are generally open to 

recreational uses unless closed through a land use plan decision. See the No Action Alternative on page 8 

for an overview of current restrictions. For example, visitors may currently land boats on all Monument 

rocks and islands, but must not violate Federal, State, or local laws that protect marine mammals and 

migratory birds (e.g., the Marine Mammal Protection Act and the Migratory Bird Treaty Act). 

The exceptional maritime environment of the San Juan Islands provides outstanding and diverse

recreational opportunities. Recreation is vital to the San Juan Island’s economy and plays an important

role in the culture of the local communities. Visitors to the San Juan Islands predominately arrive via 

some type of watercraft, usually either by the Washington State Ferry, private or charter boat, or smaller

crafts such as canoes and kayaks. Visitors also arrive by private aircraft and smaller commercial aircraft. 

About 900,000 visitors utilized the Washington State Ferry system to reach the San Juan Islands in 2009 

(Compilation of San Juan Visitors Bureau Surveys, 2005−2009; San Juan Visitors Bureau 2010). 

Although it encompasses only a small percentage of the public land in the San Juan Islands (see Table 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

146 
 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 30), the Monument is an important recreational resource for both local residents and visitors. In 2014, the 

2 Monument had over 100,000 visitors. The BLM estimates these visits through an array of methods, 

3 including trail counters, volunteer monitors, partner monitoring, assessment of impacts in remote areas 

4 compared to areas with known visitation numbers, and BLM staff reporting. The difficulty of monitoring

5 use at some of the Monument’s more remote rocks and islands means that this is probably an 

6 underestimate of current usage. The great majority of this visitation takes place between May 15 and 

7 September 15. The shoulder seasons for visitor use are typically March 15 to May 14 and September 16 

8 to October 15. The off-season occurs between October 16 and March 14. In fair weather conditions, 

9 visitors can enjoy most of the Monument’s recreational opportunities during the shoulder and off seasons. 

10 Visitors currently engage in a variety of activities in the Monument, including hiking, kayaking, camping, 

11 photography, lighthouse appreciation, volunteer events, hunting, and wildflower and marine mammal 

12 viewing. Fishing is a popular activity in the San Juan Islands, but this use is currently very limited in the 

13 Monument. Almost half of visitors access the Monument via boat.

14 Developed and semi-developed recreation areas (e.g., sites with kiosks, toilets etc.) are scattered 

15 throughout the Monument, with most occurring at Patos Island, Blind and Posey Islands, Turn Point Light 

16 Station, and on the south end of Lopez Island. The BLM and its partners maintain and monitor these sites 

17 for recreation uses and benefits. See Table E-4 in the Recreation and Visitor Services Issue 1 section of 

18 Appendix E for information about recreational opportunities and facilities at prominent Monument sites. 

19 Recreation also occurs outside of these prominent areas; visitors may seek out these more remote sites 

20 due to their primitive nature and opportunities for solitude. 

21 In addition to providing traditional recreational opportunities, the lands on the south end of Lopez Island 

22 are also culturally important to members of the local community, as expressed in an array of feedback 

23 received by the BLM during the scoping period for this planning process. Residents expressed a sense of 

24 spiritual connection to these lands and described using them for celebrations, coming of age ceremonies, 

25 memorials, and visits of a contemplative nature (BLM 2015b,c). 

26 The following subsections offer an overview of recreational opportunities currently available in the 

27 Monument. In order to provide context for the BLM’s contribution to the broader availability of

28 recreational opportunities, each section also provides an overview of opportunities on non-Monument

29 lands in the San Juan Islands. Recreational opportunities are described in association with each ferry

30 served island and with areas only accessible by personal watercraft.

31 General Recreational Opportunities44

32 All 1,021 acres of Monument land are currently open to recreation (including recreational boat landing). 

33 The Monument encompasses 4 percent of the nearly 24,000 acres of land open to public recreational use 

34 in the San Juan Islands. As laid out in Table 30, Monument land encompasses 5 percent or less of the 

35 publically accessible land associated with each ferry-served islands, with the exception of Lopez Island. 

36 The Monument encompasses more than 50 percent of publically accessible land on Lopez Island. 

37 Table 30: Publically accessible lands in the San Juan Islands 

Monument land

(acres)

Land open to public recreation

in the San Juan Islands

(acres)

Percent of land open to 

public recreation in the 

Monument

San Juan Island* 23 6,442 <1% 

Orcas Island* 42 7,501 1% 

Lopez Island* 508 964 53% 

Shaw Island* 5 522 1% 

Lummi Island* 50 944 5% 

44The BLM and other public land managers that allow the public to use lands under their jurisdiction for outdoor 

recreation are not liable for unintentional injuries to such users (RCW 4.24.210). 

147 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Monument land

(acres)

Land open to public recreation

in the San Juan Islands

(acres)

Percent of land open to 

public recreation in the 

Monument

Non-ferry

Served Islands

and Rocks

393 7,508 5% 

Total 1,021 23,882 4% 

1 Source: BLM inventory data and personal communication between Nick Teague and non-BLM land 

managers in the San Juan Islands. 

* Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by

non-motorized boat (e.g., the Orcas Island acreage includes Indian Island)

The Monument currently has no formally designated trail 

network. Most existing trails are user created. Proclamation Appendix H: Draft

8947 states, “except for emergency, Federal Comprehensive Travel and law enforcement, 

or authorized administrative purposes, motorized vehicle use Transportation Plan includes

in the Monument shall be permitted only on designated roads, maps and site-specific information 

and non-motorized mechanized vehicle use in the Monument about roads and trails identified

shall be permitted only on designated roads and trails.” Thus, through the inventory. 

motorized vehicle use is currently restricted to roads and 

mechanized vehicle use (e.g., bicycle) is currently restricted to roads and trails. 

In 2015, the BLM worked with a local contractor to complete an inventory of all roads and trails in the 

Monument (inventory was initiated in 2012). The BLM added a small number of trail segments that 

were missing from the inventory during the preparation of this Draft RMP/EIS. The Monument currently 

has 14.9 miles of mostly user created trails. An additional 1.2 miles of user created trails occur on 

adjacent Coast Guard lands at Cattle Point and Iceberg 45 Point . 

While many receive regular use, these trails are generally primitive and unmarked. The trail surface is 

typically natural soil, though 0.4 miles are concrete, 0.3 miles are gravel, and less than 0.1 miles are 

wood. Most of these trails (13.4 miles including Coast Guard) are single track, with an average width of 

18 to 24 inches. Approximately 2.6 miles are double track, which are typically no wider than 48 inches 

but can be as wide as 72 inches or greater (i.e., older roadbeds). 

The BLM also administers a total of 1 mile of road at Point Colville, Turn Point, and Watmough Bay. 

The public routinely uses these roads to access the Monument. Landowners also use the road segment 

that crosses Point Colville to access private land. A small segment of the road at Turn Point 

(approximately 0.1 miles) is currently used only for administrative access. 

From the early 1990s through 2009, the BLM documented 6-8 miles of trails within what is now the 

Monument. The current inventory documents approximately twice that mileage of trails. The current 

inventory is more comprehensive than past efforts, which may account for some of this increase. There 

has also been an increase in user created trail miles in the more accessible Monument lands. As 

described below, recreation in the Monument has increased substantially over the past two decades (see 

Table 37). 

Specific Recreational opportunities46

 

Recreational Boating 

 

45 The BLM provides on the ground management support for these adjacent Coast Guard lands. While the BLM 

does not have decision-making authority over these lands, it will provide recommendations regarding the trail 

network to the Coast Guard based on this analysis. 46The BLM and other public land managers that allow the public to use lands under their jurisdiction for outdoor 

recreation are not liable for unintentional injuries to such users (RCW 4.24.210). 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

148 
 

 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Monument: While the designation extends only to mean high tide, recreational boating is a popular way

2 to experience the Monument. In some cases, recreational boaters also access the Monument by landing

3 on its shoreline. Currently, all 21.1 miles of Monument shoreline are technically open to recreational boat

4 landing; the frequency with which this takes place varies substantially depending on the accessibility of

5 the landing and the remoteness of the area. Safe landing would be difficult or impossible on some 

6 portions of the shoreline. BLM staff observations indicate that most boats that land on the Monument are 

7 non-motorized. 

8 San Juan Islands: Recreational boating—including sailing, motor boating, and paddling—is a popular

9 activity in the San Juan Islands for both visitors and residents. A 2009 study estimated that 25,000 

10 kayaking visitors travel annually to San Juan Island alone (San Juan County Economic Development

11 Council 2009). The National Park Service, Washington State Parks, WDNR, WDFW, San Juan 

12 Preservation Trust, and San Juan County all manage shoreline that is open to at least some types of

13 recreational boat landing. The majority of shoreline in the San Juan Islands is in private ownership (San 

14 Juan County 2016a). In a recent survey, San Juan County residents identified shoreline access as a key 

15 priority (San Juan County 2016a). 

16 Hiking47 

17 Monument: Hiking is a popular recreational activity in the Monument; there are approximately 14.9 

18 miles of undesignated, mostly user created trails. There are an additional 1.2 miles of on adjacent lands 

19 under Coast Guard jurisdiction at Cattle Point and Iceberg Point48 that an interconnected part of the trail

20 network. While there is no current prohibition against hiking cross-country, most visitors stay on trails. 

21 Most trails in the Monument and on adjacent Coast Guard lands are single track (13.4 miles). The other

22 2.6 miles are double track, allowing visitors to walk side by side. Hiking also takes place on the 

23 Monument’s 1 mile of roads (at Point Colville, Turn Point, and Watmough Bay). The majority of hiking

24 in the Monument takes place at relatively easily accessible lands on Lopez Island and San Juan Island. 

25 San Juan Islands: Hiking is a popular recreational activity across the San Juan Islands; there are an

26 estimated 198 miles of publically accessible hiking trails available on both ferry served islands and non27 ferry served islands. The trail network varies substantially between ferry-served islands, with Orcas and 

28 San Juan islands having substantially larger trail systems than Lopez, Lummi, and Shaw islands. Trails 

29 range from single track to double track and include both user created and professionally designed and 

30 constructed trails. Many are multi-use trails open to a variety of non-motorized uses. Individual trails 

31 may be closed to certain activities during specific dates and times. 

32 Table 31 displays the miles of trails available for hiking on publically accessible lands on both ferry

33 served islands and non-ferry served islands.

34 Table 31: Hiking opportunities in the San Juan Islands 

Monument Trails Used for Hiking

(trail miles)

Total Hiking Trails 

(trail miles)

San Juan

Island

1.2

Locations: Cattle Point 65

Orcas Island 

0.8

Locations: Freeman, Indian, Oak, Skull, 

Victim islands* 

53

Lopez Island 9.7 14

47 For the purposes of this document, “Hiking” encompasses all forms of pedestrian recreational travel, including,

but not limited to, walking for pleasure and exercise and trail running. 

48 The BLM provides on the ground management support for these adjacent Coast Guard lands. While the BLM 

does not have decision-making authority over these lands, it will provide recommendations regarding the trail 

network to the Coast Guard based on this analysis. 

149 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Locations: Cape Saint Mary, Chadwick Hill, 

Iceberg Point, Lopez Pass, Point Colville, and 

Watmough Bay

Shaw Island 0.4 3 Locations: Blind and Broken Point islands* 

Lummi Island 0.1 6 Locations: Carter Point and Lummi Rocks* 

Non-ferry

Served 

Islands

3.9 

Areas known to have trails: Eliza, Kellett

Bluff, McConnell Rocks, Patos, Posey, 

55

Islands known to have trails: Decatur, 

Vendovi, James, Clark, Doe, Jones, Turn, 

Reads Bay, Turn Point Matia, Henry, Waldron, Cypress, Stuart

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

Source: BLM inventory data and personal communication between Nick Teague and non-BLM land 

managers in the San Juan Islands. 

*These islands are near enough to the ferry served island to provide visitor and resident opportunities.

Equestrian Use 

Monument: Limited horseback riding currently takes place in the Monument. This activity has 

historically taken place on approximately 1 mile of lower elevation trails at Chadwick Hill and 

Watmough Bay. This majority of this trail mileage is 18 inches wide and made of natural soils. 

Equestrian use also occurs on the gravel trail from the parking area to Watmough Bay. 

San Juan Islands: In the San Juan Islands, horseback riding predominately takes place on private lands. 

However, there are an estimated 35 miles of publically accessible equestrian trails on ferry served 

islands. The great majority (88 percent) are on San Juan Island and Orcas Island. Trails range from 

single track to double track and include both user created and professionally designed and constructed 

trails. Many are multi-use trails open to a variety of non-motorized uses. Individual trails may be closed 

to certain activities during specific dates and times. Horseback riding also takes place on roads in the San 

Juan Islands. 

Table 32 displays the miles of trails for equestrian use on publically accessible lands on both ferry served 

islands and non-ferry served islands. 

Table 32: Equestrian opportunities in the San Juan Islands 

Monument Trails Regularly Used for Equestrian 

Access * (trail miles)

Total Equestrian Trails

(trail miles)

San Juan Island 0 18

Orcas Island 0 12

Lopez Island 1

Location: Chadwick Hill, Watmough Bay 4

Shaw Island 0 0

Lummi Island 0 0

Non-ferry Served 

Islands 0 0

19 Source: BLM inventory data and personal communication between Nick Teague and non-BLM land 

20 managers in the San Juan Islands. 

21 *All trails in the Monument are currently open to all non-motorized uses.

22 Bicycle Use 

23 Monument: Currently, members of the public are not regularly using any trails within the Monument for

24 bicycling, though trails within the Monument are open to all non-motorized uses. Proclamation 8947 

25 prohibits mechanized vehicle use (e.g., bicycles) off roads and trails. 

150 
 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 San Juan Islands: Bicycling is a popular recreational activity in the San Juan Islands; there are an 

2 estimated 58.6 miles of publically accessible bicycling trails. The great majority (92 percent) are on San 

3 Juan Island and Orcas Island. These trails range from single track to double track and include both user

4 created and professionally designed and constructed trails. Many are multi-use trails open to a variety of

5 non-motorized uses. Individual trails may be closed to certain activities during specific dates and times. 

6 Bicycling also takes place on roads in the San Juan Islands.

7 Table 33 displays the available miles of trails for bicycling on publically accessible lands on both ferry

8 served islands and non-ferry served islands.

9 Table 33: Bicycling trails in the San Juan Islands 

Monument Trails Regularly Used for

Bicycling* (trail miles)(trail miles)

Total Bicycling Trails

(trail miles)

San Juan Island 0 20

Orcas Island 0 34

Lopez Island 0 4.6

Shaw Island 0 0

Lummi Island 0 0

Non-ferry Served Islands 0 0

10 Source: BLM inventory data and personal communication between Nick Teague and non-BLM land 

11 managers in the San Juan Islands. 

12 *All trails in the Monument are currently open to all non-motorized uses.

13 Motorized Recreation/Access 

14 Monument: In the Monument, motorized access is limited to the 1 mile of existing roads at Point

15 Colville, Watmough Bay, and Turn Point. Public use of these roads is primarily to access the Monument

16 for recreational use. Land owners also use the road at Point Colville to access private land. Given the 

17 short distances of Monument roads, they do not provide an opportunity for scenic driving as an activity. 

18 Visitors to Point Colville and Watmough Bay on Lopez Island typically arrive by automobile and park at

19 the trailheads. The BLM-administered sections of road at Point Colville and Watmough Bay are 0.4 miles

20 and 0.1 miles respectively. The BLM is currently undertaking a survey process to determine whether a 

21 portion of the road to the Watmough Bay parking lot crosses private land; any decisions made through 

22 this planning effort would apply only the portion of the road crossing BLM-administered land. 

23 Visitors to Turn Point on Stuart Island, which is not served by the Washington State Ferry, typically arrive 

24 by hiking from the public boat landing. Occasionally visitors arrive by automobile or, more rarely, by all25 terrain vehicle. A county road transitions to 0.5 miles of graveled BLM road to provide access to the Turn 

26 Point Light Station. Approximately 0.1 miles of this road is currently used only for administrative access. 

27 San Juan Islands: In the San Juan Islands, visitors and residents travel by automobile on paved and 

28 unpaved county roads and by motorized watercraft. Scenic driving is a popular activity. There are no

29 public lands in the San Juan Islands that provide trail-based motorized recreational opportunities. Trail30 based motorized activities take place only on private lands. 

31 Camping 

32 Monument: Camping is a popular activity in three Monument locations: Patos, Blind, and Posey islands

33 (see Table 34). The BLM cooperatively manages these areas with Washington State Parks through a 

34 memorandum of understanding. 

35 Occasional dispersed camping (i.e., no campsite and limited or no facilities) also takes place. With the 

36 exception of areas included in the ACECs (Chadwick Hill, Iceberg Point, Point Colville, and Watmough 

37 Bay), the Monument is currently open to this use. The ACECs are currently closed to camping. 

151 
 

 

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 34: Designated site camping opportunities in the Monument 

Site Name Level of Development Campsites Reservation System 

Patos Island Low* 7 No 

Blind Island Low* 4 No 

Posey Island Low* 2 Yes 

2 *These camping areas all have composting or vault toilets, fire-rings, and picnic tables. None of them 

3 have electricity or fresh water. 

4 San Juan Islands: Camping is a popular activity in the San Juan Islands; there are an estimated 419 

5 public campsites available throughout the islands. These campsites range from primitive with no fresh 

6 water available to more developed areas with potable water, flushing toilets, and shelters with electricity. 

7 There is also camping available on private lands with a wide variety of amenities and fees. Outside of the 

8 Monument there are currently no dispersed camping opportunities on public lands in the San Juan Islands. 

9 Table 35 displays public campsites available on both ferry served islands and non-ferry served islands.

10 Table 35: Designated site camping opportunities in the San Juan Islands 

Designated Campsites 

in the Monument

(number of campsites)

Total Designated Campsites

(number of campsites)

San Juan 

Island 0

30

Locations: San Juan County Park, Griffin Bay Campground 

(DNR)

Orcas 

Island 0

156

Locations: Moran State Park, Obstruction Pass State Park, Point

Doughty Natural Resources Conservation Area (DNR)

Lopez

Island 0 77Locations: Odlin County Park, Spencer Spit State Park

Shaw

Island 

4

Locations: Blind Island* 

17

Locations: Blind Island (Monument), Shaw County Park

Lummi

Island 0

5

Locations: Lummi Island Natural Resources Conservation Area 

(DNR)

Non-ferry

Served 

Islands

9

Locations: Patos and 

Posey islands 

182

Locations: Clark Island Marine State Park, Cypress Island 

Natural Resources Conservation Area (DNR), Doe Island Marine 

State Park, James Island Marine State Park, Jones Island Marine 

State Park, Patos and Posey islands (Monument), Matia Island 

(U.S. FWS), Stuart Island State Park, Sucia Island Marine State 

Park, Turn Island (U.S. FWS)

11 Source: BLM inventory data and personal communication between Nick Teague and non-BLM land 

managers in the San Juan Islands. 

*

This island is near enough to Shaw Island to provide visitor and resident opportunities. 

Hunting Using Firearms 

Note: Based on public comments, the BLM has included firearms prohibitions in some Alternative C and 

Sub-Alternative C (see page 174). These prohibitions would affect hunting using firearms, but would not 

affect other forms of hunting (e.g., bow hunting). The prohibitions would also not affect hunting by 

Coast Salish tribal members. 

Hunting with rifles is prohibited in San Juan County. Legal firearms for hunting in San Juan County are 

center fired pistols and shotguns, which reduce the overall distance a projectile can travel as compared to 

12 

13 

14 

15 

16 

17 

18 

19 

20 

152 
 

 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 a rifle. By law, anyone born after 1972 is required to take and pass a hunter safety course. Hunters using

2 a firearm, though not bow hunters, are required to wear “safety orange.” Members of Tribes with off3 reservation hunting rights are not subject to State requirements regarding hunting. 

4 Monument: The BLM is aware of hunting occurring on approximately 590 acres of Monument land. 

5 The BLM and partners have observed hunting (with or without firearms) on Lopez Island at the 

6 contiguous Chadwick Hill, Point Colville, and Watmough Bay area and at Iceberg Point. Hunting has

7 also occasionally been observed at Cattle Point (San Juan Island) and Turn Point (Stuart Island). 

8 Residents of Lopez Island have raised safety concerns about conflicts between hunting using firearms and 

9 hiking and volunteer activities (BLM 2015b,c, BLM 2016a,b). The BLM has also received comments 

10 from members of the public and partner agencies asking that hunting opportunities be maintained (BLM 

11 2016a,b). The Monument is one of two areas of public land where hunting is allowed on Lopez Island. 

12 Based on informal conversations between hunters and BLM staff and volunteers, most hunters in the 

13 Monument are from off-island and live in the nearby region. Firearms used for hunting in the Monument

14 have traditionally been shotguns, though muzzleloaders have been used in recent years. Bow hunters also 

15 use Monument lands (a decision prohibit firearm discharge in a particular area would not affect bow

16 hunting). Hunting for deer is the primary activity, though there have been rare instances of waterfowl

17 hunting at Chadwick Marsh. Chadwick Marsh is the only publically accessible area for waterfowl

18 hunting on Lopez Island. 

19 DOI Secretarial Order 3356 calls for National Monument land use plans to “include or expand hunting, 

20 recreational shooting, and fishing opportunities to the extent practicable under the law.” Currently, the 

21 whole Monument is open to the discharge of firearms except developed recreation sites (e.g., 

22 campgrounds and picnic areas with facilities) as provided in current supplementary rules that apply to all

23 BLM-administered lands in Oregon and Washington (see Appendix I). 

24 The BLM is not aware of any use of firearms within the Monument for recreational target shooting or any

25 other non-hunting activity. 

26 San Juan Islands: In the San Juan Islands as a whole, hunting on publically accessible lands is 

27 extremely limited (see Table 36). However, the majority of Cypress Island (approximately 5,000 acres), 

28 which is managed by WDNR, is open for hunting; small sections of the island are closed to this activity. 

29 Hunting on private lands occurs with written permission from the landowner.

30 Table 36 displays the publically available acres open to hunting for both ferry served islands and non31 ferry served islands. 

32 Table 36: Hunting opportunities in the San Juan Islands* 

Known Hunting in the 

Monument (acres) Total Public Land Open to Hunting (acres)

San Juan Island 23

Locations: Cattle Point

23

Locations: Cattle Point

Orcas Island 0 Acres: 148

Location: Killebrew Lake (WDFW)

503 907

Lopez Island Locations: Chadwick Hill,

Iceberg Point, and Point

Locations: Monument lands and Lopez Hill (San Juan 

County Land Bank). Lopez Hill is only open during 1⁄2 of

Colville, Watmough Bay the regular deer hunting season.

Shaw Island 0 0

Lummi Island 0 0

Non-ferry

Served Islands

86

Locations: Turn Point 

5,186

Locations: Cypress Island (DNR), Turn Point

(Monument) 

153 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Source: BLM inventory data and personal communication between Nick Teague and non-BLM land 

managers in the San Juan Islands. 

*All 1,021 acres of the Monument are currently open to hunting; this table provides acres in the 

Monument where hunting currently takes place. Many of the Monument’s small rocks and islands would 

provide very limited hunting opportunities. 

Solitude and Quiet 

Monument: While the BLM does not currently explicitly manage any Monument lands for solitude and 

quiet (i.e., opportunities for visitors to have no or minimal interaction with other visitors or disturbance 

from non-natural noise), opportunities for these experiences exist throughout the area. The availability of

such opportunities are dependent on several factors, including the presence of overhead small planes and

jets and nearby motorized boats, vehicles, and people. The BLM has no jurisdiction over sources of

disturbance outside of the lands it administers (e.g., boats in the water or overhead planes and jets).

The impact of these factors varies substantially depending on the accessibility of the area and the time of

year or day. Visitors can most easily find experiences of quiet and solitude at locations only accessible 

via personal watercraft. Monument lands on ferry served islands, which are easily accessed by roads, 

typically offer these opportunities only on certain days and times. Even during the busiest time of year

for visitation, individuals can find solitude and quiet on more accessible Monument lands during the early 

morning and later afternoon and evening. Opportunities for solitude and quiet increase during the 

shoulder seasons. In the off season opportunities for solitude and quiet can frequently be found. 

San Juan Islands: The San Juan Islands offer opportunities to experience solitude and quiet in the natural

world. As with the Monument lands, these experiences are affected by factors including noise and visual

disturbance from overhead small planes and jets and nearby motorized boats, vehicles, and people. The 

effect of these influences vary substantially depending on the time of year or day. 

The San Juan Islands receive an estimated 750,000 to 1 million visitors each year (San Juan Islands

Scenic Byway: June 2012). Many arrive during the high-use season. Due to the relative remoteness of

much of the archipelago, solitude and quiet can be found at certain times and locations even during highuse periods. The off-season is optimal for experiences of solitude and quiet. Easily accessible areas 

typically offer fewer opportunities for solitude and quiet compared to more remote rocks and islands. 

A 2016 survey conducted by San Juan County found that 77 percent of residents felt that County-owned 

parks, trails, and natural areas are not at all or only slightly crowded. Residents of Lopez and Shaw 

islands expressed a slightly greater concern about crowding (San Juan County 2016a). A 2017 survey 

found that more than half of visitors to Watmough Bay described some degree of crowding, while nearly 

half of visitors at Iceberg Point and 10 percent of visitors at Cattle Point described some degree of 

crowding (Confluence Research and Consulting 2018). The 2017 survey took place between late May 

through Labor Day, which is the high visitation period (Confluence Research and Consulting 2018). 

Commercial, Competitive, and Organized Group Recreation Uses 

While most visitors to the Monument recreate individually or in small groups, others participate in 

organized events such as weddings or commercial recreation such as sea kayaking tours. The BLM 

requires that organized groups of ten or more individuals obtain permits to visit the lands included in the 

ACECs at the south end of Lopez (BLM 1990). Permits are also required for organized (without a 

defined group size threshold outside of ACECs), commercial, and competitive group activities at all 

locations in the Monument. On average, the BLM currently issues approximately 1-2 permits each year. 

Most are area or activity specific permits, such as for weddings.

For the past 20 years, the BLM’s Spokane District Office has been concerned about unpermitted 

commercial uses. The BLM believes that some outfitters—primarily sea kayaking guides and charter

boat operators— use the Monument without obtaining the appropriate authorization. The BLM has made

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

154 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 an effort bring unauthorized activities into compliance; however, the relative isolation of some Monument

lands and the limited staff and law enforcement presence has made enforcement and monitoring difficult. 

Other Recreational and Human Use Activities 

The primary, current recreational uses of the Monument are described above, as are those about which 

members of the public have expressed an interest. The BLM is aware that other recreational uses take 

place in the Monument occasionally or have taken place historically. These include, use of metal 

detectors, use of recreational drones, lighting of fireworks, geocaching, and gathering of natural materials 

by members of the public. The 1990 ACEC decisions require members of the public to obtain permits to 

collect vegetation (permits have rarely, if ever, been requested). Rock climbing has historically taken 

place at Watmough Bay, but this use has not been observed in the past several years. 

Trends in Recreation 

Overall trends show a substantial increase in visitor use at prominent sites in the Monument (see Table 

37), though improved data collection has also caused the overall visitation numbers to increase. At

Watmough Bay, for example, 5,000 visitors were reported in 2002 and over 17,000 visitors were reported 

in 2003. It is likely that this increase was influenced by changes in visitation estimate methods rather

than an actual dramatic change in visitation. 

San Juan County’s population is growing at a modest pace and the fastest-growing age group is 50 and 

older (San Juan County 2016). A 2016 survey of residents found that this demographic participates in 

relatively low-impact outdoor recreation such as hiking, walking, wildlife watching, and relaxing in 

nature (San Juan County 2016). This survey also found that 87 percent of respondents value parks, trails, 

and natural areas as critical to their quality of life. This survey found that 90 percent of respondents 

participating in hiking or walking on a frequent basis. 

San Juan County recognizes the priority placed by its residents on having well connected networks of 

trails (San Juan County 2016a). In the recent survey, over 77 percent of respondents selected trails in 

parks and natural areas as one of their top five priorities for recreational programs or services in the 

county. Respondents also identified shoreline access as a key priority (San Juan County 2016a). 

Throughout Washington State, recreation is expected to increase due to a combination of social and 

environmental conditions, overall population growth, and growing recreation on public lands. Demand 

for recreational opportunities has increased across the region. Eighty percent of state residents participate 

in nature related activities and 59 percent participate in wildlife viewing and photography (Ritchie et al. 

2013). Walking and hiking are the second highest ranked outdoor recreational activities; the most popular 

statewide activity is picnicking, barbequing, or cooking out (Ritchie et al. 2013). 

Recreation demand is also increasing nationally, as identified in the National Survey on Recreation and 

the Environment, which showed that between 2000 and 2007, the total number of people in the United 

States who participated in one or more outdoor activities grew by 4.4 percent (Cordell 2008). Prominent 

among the growing activities identified in the national survey were viewing and photographing natural 

scenery, flowers, trees, wildlife, birds, and fish. Based upon the documents referenced in this section, 

recreation demand is expected to continue to rise for the types of activities available in the Monument. 

The reliance of many visitors on the Washington State Ferry system to access the San Juan Islands may 

eventually provide a limit on the increasing number of visitors. According to the Washington State 

Department of Transportation Ferries Division Final Long-Range Plan, there are no plans to substantially 

increase the capacity of the ferries serving the San Juan Islands for the foreseeable future (WDOT 2009). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

155 
1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 37: Monument total recreation, including all recreation sites and dispersed uses, from 2001−2014

Monument

location

Visits

2014 2013 2012 2011 2010 2009 2008 2007 2006 2005 2004 2003 2002 2001

Blind Island 7,900 7,700 7,750 7,750 Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Cattle Point 12,200 10,100 9,950 9,900 Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Chadwick Hill 3,700 3,200 5,500 5,250 2,400 3,467 3,507 3,208 2,060 2,000 2,000 2,000 2,000 2,000

Iceberg Point 15,300 13,000 15,500 15,210 10,500 7,543 5,209 4,676 3,090 3,000 5,000 6,500 5,000 5,000

Indian Island 9,550 7,650 7,500 7,450 Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Kellett Bluff 320 250 250 250 Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Patos Islands 8,500 6,900 6,500 6,450 5,500 7,128 7,030 7,204 6,695 6,500 6,500 8,450 6,500 6,500

Point Colville 3,500 3,100 3,200 3,100 2,200 3,102 3,074 2,897 2,060 2,000 2,000 2,600 2,000 2,000

Posey Island Data 

NA 2,750 2,750 2,750 2,750 Data NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Turn Point 13,750 12,200 12,000 11,735 10,500 10,239 10,112 9,673 6,180 6,001 8,500 8,700 6,000 6,001

Watmough 

Bay 17,500 16,000 15,500 15,450 10,500 10,215 10,368 10,110 9,370 23,100 15,700 17,300 5,000 5,000

Other

Monument

Rocks and 

Islands

8,750 7,900 7,800 7,780 Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Data 

NA

Monument:

Total Visits 100,970 90,750 94,200 93,075 41,600 41,694 39,300 37,768 29,455 42,601 39,700 45,550 26,500 26,501

2 

156 
 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Effects of the Alternatives 

2 The alternatives would have varying impacts on the extent to which access and recreational opportunities 

3 are available in the Monument and, by extension, on the availability of recreational opportunities in the 

4 San Juan Islands as a whole. 

5 General Recreational Use 

6 The alternatives vary in the percent of the Monument that would be available for recreational use. Under 

7 all alternatives, the BLM would facilitate public access to Monument lands for scientific, educational, 

8 cultural, and spiritual purposes. The recreational closures in alternatives A, B, and C are intended to 

9 maximize protection to ecological and cultural resources; except under Alternative A, these closures 

10 encompass a small percentage of the Monument (Table 38). Alternatives B and C also include 

11 requirements for visitors to obtain permits to access certain areas of the Monument (see Table 39); these 

12 permits are intended to provide opportunities for visitors to experience solitude and quiet (see page 177). 

13 The road and trail network designated for public use would also vary by alternative. An overview of the 

14 travel network under each alternative is described in this subsection. The details of the travel 

15 management decisions (e.g., the location of each trail segment within each travel management area) are 

16 available in Appendix H: Draft Travel and Transportation Management Plan. The effects of travel 

17 management decisions on trail-based recreational activities (hiking, biking, and equestrian use) are 

18 described in specific sub-sections below. 

19 Table 38: Acres open to public recreational use by alternative 

No Action 

Alternative 

(Acres) 

Alternative A* 

(Acres) 

Alternative B 

(Acres) 

Alternative C 

(Acres) 

Alternative D 

(Acres) 

San Juan Island† 23 0 23 23 23 

Orcas Island† 42 0 42 42 42 

Lopez Island† 508 0 508 508 508 

Shaw Island† 5 0 5 5 5 

Lummi Island† 50 0 50 50 50 

Non- Ferry Served 

Islands and Rocks 393 0 382 386 393 

Total 1,021 0 1,011‡ 1,014‡ 1,021 

20 * Under Alternative A, the BLM would facilitate access for authorized scientific, educational scientific, 

21 cultural, and spiritual uses, but not for recreation. 

22 † Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

23 non-motorized boat (e.g., the Orcas Island acreage includes Indian Island) 

24 ‡Recreational use closures would apply to Category A and B rocks under Alternative B and Category C 

25 rocks under Alternative C. The BLM received comments specifically requesting that recreational use of 

26 rocks be restricted or prohibited. 

27 Table 39: Acres requiring written authorization for access by alternative 

No Action 

Alternative 

(Acres) 

Alternative A* 

(Acres) 

Alternative B* 

(Acres) 

Alternative C* 

(Acres) 

Alternative D 

(Acres) 

San Juan Island† 0 23 <1 0 0 

Orcas Island† 0 42 32 0 0 

Lopez Island† 0 508 2 0 0 

Shaw Island† 0 5 3 0 0 

Lummi Island† 0 50 50 0 0 

Non- Ferry Served 

Islands and Rocks 0 393 80 4 0 

Total 0 1,021 167 4 0 

157 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 * Under Alternative A, the BLM would facilitate access for authorized scientific, educational scientific, 

2 cultural, and spiritual uses. Under alternatives B and C, permits would be issued for recreational use, in 

3 addition to authorized scientific, educational scientific, cultural, and spiritual uses. 

4 †Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

5 non-motorized boat (e.g., the Orcas Island acreage includes Indian Island) 

6 Table 40: Miles of road open to public motorized access by alternative* 

No Action Alternative A Alternative B Alternative C Alternative D 

San Juan Island 

Alternative 

(Miles) 

0 

(Miles) 

0 

(Miles) 

0 

(Miles) 

0 

(Miles) 

0 

Orcas Island 0 0 0 0 0 

Lopez Island 

Shaw Island 

0.5 

0 

0 

0 

0.5 

0 

0.1 

0 

0.5 

0 

Lummi Island 0 0 0 0 0 

Non- Ferry Served 

Islands and Rocks 0.5 0 0.5 0.4 0.4 

Total 1 0 1 .0.6† 0.9 

7 * Under alternatives B, C, and D, all roads would remain open to hiking, biking, and equestrian uses, 

8 regardless of whether they are open to public motorized use. 

9 †Linear distances in this document are rounded to a 10th of a percent, which causes the occasional 

10 appearance of errors in totals. 

11 Table 41: Trail miles open to non-motorized uses under each alternative 

Public 

Mode of 

Travel 

No Action 

Alternative 

(trail miles) 

Alternative A 

(trail miles) 

Alternative B 

(trail miles) 

Alternative C 

(trail miles) 

Alternative D 

(trail miles) 

Hiking* 16 0 20 11.9 24.5 

Bicycling* 16 0 0 0 8.4†

Equestrian* 16 0 0 2.6† 8.4†

12 Note: these miles include trails under U.S. Coast Guard jurisdiction on Monument adjacent lands at Cattle 

Point and Iceberg Point.49 

*Under alternatives B, C, and D, existing Monument road would remain open to open to hiking, 

bicycling, and equestrian uses, regardless of whether it is open to public motorized use. 

† Trail miles open to bicycle and/or equestrian access are also open to hiking (e.g. the 11.9 miles of trail 

open to hiking under Alternative C include the 2.6 miles of trail open to equestrian use.) 

No Action Alternative 

Under the No Action Alternative, the whole of the Monument (1,021 acres) would continue to be open to 

the public for recreational purposes without a permit. The 1990 ACEC decisions that apply to Chadwick 

Hill, Iceberg Point, Point Colville, and Watmough Bay would continue to require members of the public 

to obtain permits for organized groups of 10 or more. 

Under the No Action Alternative, there would remain no travel network designated for public access in 

the Monument. The BLM would continue to maintain the 1 mile of road in the Monument under this 

alternative (see Table 40). If levels of recreational use continue or increase, the current network of 14.9 

miles of user created trails in the Monument and 1.2 miles of user created trails on adjacent Coast Guard

lands at Cattle Point and Iceberg Point49 would persist (see Table 43). Given proliferation of trails over 

the past decade, miles of user created trails at more accessible locations would increase over time. 

 

49 The BLM provides on the ground management support for these adjacent Coast Guard lands. While the BLM 

does not have decision-making authority over these lands, it will provide recommendations regarding the trail 

network to the Coast Guard based on this analysis. 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

158 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative A 

Under Alternative A, the BLM would facilitate public use of the Monument for authorized research, 

educational, cultural, and spiritual activities, but not for recreation. As a result, no acres of Monument 

land would be available for recreation. 

Under this alternative, there would remain no travel network designated for public access in the 

Monument. The BLM would close the 1 mile of road to public motorized use but would continue to 

maintain these existing road segments for authorized and administrative uses. It would also maintain 

trails as needed for routine and regular authorized and administrative uses (e.g., maintaining a trail for 

upkeep to the Coast Guard aide-to-navigation at Iceberg Point). Under this alternative, there would be no 

opportunity for visitors to use roads and trails to access the Monument for recreational purposes. The 

ability for visitors to use roads to access the Monument for authorized research, educational, cultural, and 

spiritual activities, as well as to access private property, would remain unchanged. The ability for visitors 

to use trails to access the Monument for authorized, but not routine, activities would decrease over time as 

trails reverted back to a natural state due to lack of use. 

Alternative B 

Under Alternative B, all but 10 acres of the Monument would remain open to recreational use and would 

be designated as RMAs. The BLM would prohibit recreational use of 10 acres categorized as Category A 

Rocks and Category B Rocks (see Appendix O for RMA frameworks). Monument land open to 

recreational use would decrease by approximately 1 percent. 

In order to provide opportunities for solitude and quiet, 167 acres of the Monument would be open for 

recreation by permit only. This would enable the BLM to limit visitation to these areas in order to 

minimize interaction between members of the public. The areas that would be open to recreation by 

permit only would be Broken Point Island, Cape Saint Mary, Carter Point, Fauntleroy Rock, Kellett Bluff, 

Little Patos Island, Lopez Pass, Lummi Rocks, McConnell Rocks, Mud Island, Oak Island, Park Bay 

Island, President Channel, Reads Bay Island, and Richardson Rocks. Monument acres available for 

recreational use without a permit would decrease by approximately 16 percent (special recreation permits 

for organized groups are addressed on page 178). 

Under Alternative B, the BLM would designate 1 mile of existing road for public motorized access at 

Point Colville, Turn Point, and Watmough Bay (see Table 40). This would maintain 100 percent of the 

current miles of road available for motorized visitor use in the Monument. 

Under Alternative B, the BLM would designate approximately 19.5 miles of trail exclusively for hiking. 

It would also recommend that the Coast Guard designate approximately 1 mile of trail for hiking on its 

Monument adjacent lands at Iceberg Point and Cattle Point. Trail access would increase by 27 percent. 

Alternative C 

Under Alternative C, all but 7 acres of the Monument would be open to recreational use. The BLM 

would prohibit recreation on Category B Rocks. This would decrease the Monument land open to 

recreation by less than 1 percent. The BLM would also require permits to access Category A rocks for 

recreational purposes. Monument acres available for recreational use without a permit would decrease by 

less than 1 percent (special recreation permits for organized groups are addressed on page 178). 

Under Alternative C, the BLM would designate 0.6 miles of existing road for public motorized access at 

Turn Point and Watmough Bay (see Table 40). The BLM would maintain an additional 0.4 miles of 

existing road for authorized and administrative motorized access, but would close these road segments to 

public motorized access (they would remain open to hiking, biking, and equestrian use). This would 

decrease the miles of road available for motorized visitor use in the Monument by 40 percent. Despite 

this substantial percent decrease, the closure would have a relatively minimal impact on the ability of 

visitors to access the Monument. Visitors to Point Colville would park at Watmough Bay and walk 0.3 

miles to the Point Colville trailhead. The small segment of road that would be closed at Turn Point 

(approximately 0.1 miles) is currently used only for administrative access. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

159 
 

 

 

 

 

 

 

 

 

 

5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under Alternative C, the BLM would designate approximately 11.3 miles of trail for public use (hiking 

2 and some equestrian use). Trail miles open to equestrian access are also open to hiking. It would also 

3 recommend that the Coast Guard designate approximately 0.7 mile of trail for hiking on Monument 

4 adjacent lands at Iceberg Point and Cattle Point. Trail access would decrease by 25 percent. 

Alternative D 

6 Under Alternative D, the entire Monument would remain open to recreational use without a permit and 

7 would be designated as a RMA (special recreation permits for organized groups are addressed on page 

8 178). 

9 Under Alternative D, the BLM would designate approximately 0.9 miles of existing road for public 

motorized use at Point Colville, Turn Point, and Watmough Bay (see Table 40). An additional 

11 approximately 0.1 miles of existing road would be maintained for authorized and administrative uses at 

12 Turn Point, but would be closed to public motorized use (it would remain open to hiking, biking, and 

13 equestrian use). Road available for visitors to access the Monument would decrease approximately 10 

14 percent. The small segment of road that would be closed is currently used only for administrative access. 

Under Alternative D, the BLM would designate approximately 23.4 miles of trail for public use (hiking 

16 and some equestrian and bicycling use). Trail miles open to equestrian or bicycling access are also open 

17 to hiking. It would also recommend that the Coast Guard designate approximately 1.15 mile of trail for 

18 public use (hiking and some equestrian and bicycling use) on its lands adjacent to the Monument at 

19 Iceberg Point and Cattle Point. Trail access would increase by 54 percent. 

Cumulative effects of the alternatives on access in the San Juan Islands 

21 The alternatives would vary in their incremental impact on the total supply of land open to the public for 

22 recreational use in the San Juan Islands, as well as the supply of opportunities easily available to residents 

23 and visitors on each island. 

24 In the San Juan Islands there are an array of governmental agencies and non-profit organizations that 

provide approximately 23,882 acres of public access for a variety of recreation activities. Under the No 

26 Action Alternative and alternatives B, C, and D, the Monument would continue to provide approximately 

27 4 percent of the overall acres available for recreational use in the San Juan Islands and 5 percent or less of 

28 public land easily accessible from most of the ferry served islands in the archipelago (see Table 30 on 

29 page 147). While this overall percent is small, the Monument accounts for more than half of the land 

open to the public for recreational use on Lopez Island. Other than the Monument planning process, there 

31 are no on-going efforts that would substantially change the availability of lands available for public 

32 recreational use within the San Juan Islands. 

33 Under Alternative A, the Monument would no longer contribute to the supply of lands available to the 

34 public for recreational use. This would cause a four percent reduction in the acres of publically accessible 

land in the San Juan Islands. This small reduction in the overall land available for public recreational use 

36 in San Juan Islands could slightly increase competition for areas that remain open to recreational use. 

37 Under this alternative, there would be a 53 percent reduction in the land available for public recreational 

38 use on Lopez Island. While this alternative would not markedly reduce the overall lands available in the 

39 San Juan Islands, it would have a substantial impact on the supply of lands easily accessible for recreation 

to residents and visitors on Lopez Island. 

41 Recreational Boat Landing 

42 The alternatives vary in the miles of shoreline that would be open to recreational boat landing under each 

43 alternative (note: this is a function of locations being open or closed to recreational use, there are no 

44 separate decisions about shoreline use). Under all alternatives, the shoreline would continue to be open 

for emergency boat landing and for authorized and administrative uses. Under all alternatives, safe 

46 landing would be difficult or impossible on some portions of the shoreline regardless of whether it is 

47 technically open to recreational boat landing. Since the BLM’s jurisdiction only extends to mean high 

48 tide, the alternatives do not otherwise address recreational boating. 

160 
 

 

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 42: Monument shoreline open to recreational boat landing 

No Action Alternative A Alternative B Alternative C Alternative D 

San Juan Island* 

Alternative 

(Miles) 

.5 

(Miles) 

0 

(Miles) 

.5 

(Miles) 

.5 

(Miles) 

.5 

Orcas Island* .3 0 .3 .3 .3 

Lopez Island* 

Shaw Island* 

3.9 

0 

0 

0 

3.7 

0 

3.9 

0 

3.9 

0 

Lummi Island* 1.1 0 1.1 1.1 1.1 

Non- Ferry 

Served Islands 15.3 0 10.7 11.9 15.3 

and Rocks 

Total 21.2 0 16.4 17.8 21.2 

2 *Miles for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

non-motorized boat (e.g., the Orcas Island miles includes Indian Island) 

No Action Alternative 

Under the No Action Alternative, all 21.2 miles of Monument shorelines would continue to be open to 

recreational boat landing. The opportunity for visitors to land recreational boats in areas that are safe and 

appropriate for their individual skill levels and watercraft type would remain unchanged. 

Given trends in visitation, recreational boating landings on Monument shorelines would increase over 

time, particularly during high visitation seasons. The number of landings would continue to vary by 

location depending on the ease of landing and the remoteness of the site. Landings and shoreline access 

would continue to be unrestricted, except for the requirement for special recreation permits for organized, 

commercial, and competitive activities. 

Alternative A 

Under Alternative A, the BLM would facilitate public use of the Monument for authorized research, 

educational, cultural, and spiritual activities, but not for recreation. As a result, 0 miles of Monument 

shoreline would be available to recreational boaters for landings. All 21.2 miles of the Monument 

shoreline would continue to be open to landings for authorized research, educational, cultural, and 

spiritual activities. Under this alternative, recreational boaters could continue to enjoy the Monument 

from the water, but there would be no opportunity to land on the Monument for recreational purposes. 

Alternative B 

Under Alternative B, 16.4 miles of Monument shoreline would remain open to recreational boat landing. 

Under this alternative, the BLM would prohibit recreational use, including boat landing, to Category A 

and Category B Rocks (see Appendix O for RMA frameworks). It would also prohibit recreational boat 

landing at Watmough Bay in order to reduce potential disruption to juvenile forage fish close to shore, 

though recreational use of the area would otherwise be permitted. Under this alternative, the Monument 

shoreline available for recreational boat landing would decrease by 20 percent. 

Shoreline associated with Category A and B rocks account for 4.6 miles of the 4.8 miles of shoreline that 

the BLM would close to recreational boat landing under this alternative. According to BLM personnel, 

these rocks currently receive relatively little visitation, so this prohibition would have a relatively minor 

impact on known recreational use. Non-motorized boats regularly land at Watmough Bay, particularly 

during the summer; small motorboats also occasionally land. The prohibition of recreational boat landing 

on 0.2 miles of shoreline on Watmough Bay would remove this recreational opportunity. If current 

visitation trends continue, recreational boating landings on Monument shorelines as a whole would 

increase over time, particularly during high visitation seasons (see affected environment, above). 

In addition to shoreline closed to recreational boat landing, the BLM would require permits for 

recreational boat landing on 7.1 miles of Monument shoreline. This shoreline is associated with the areas 

that the BLM is managing for quiet and solitude by requiring permits for recreational use (see the Access 

section above for a list of areas for which permits would be required under Alternative B). 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

161 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Alternative C 

Under Alternative C, 17.8 miles of Monument shoreline would remain open to recreational boat landing. 

Under this alternative, the BLM would prohibit recreational use, including boat landing, to Category B 

Rocks (see Appendix O for RMA frameworks). It would also prohibit recreational motorboat landing at 

Watmough Bay in order to reduce potential disruption to forage fish spawning habitat close to shore; nonmotorized recreational boat landings would continue. Under this alternative, the shoreline available for 

recreational boat landing would decrease by 16 percent. 

The shorelines closed to recreational boat landing would all be associated with Category B rocks, which 

are rocks identified by the BLM as having relatively little recreation potential and/or relatively sensitive 

resources. According to BLM personnel, these rocks currently receive relatively little visitation, so this 

prohibition would have a relatively minimal impact on known recreational use. Small motorboats 

occasionally land at Watmough Bay; this prohibition would remove this opportunity. If current visitation 

trends continue, recreational boating landings on Monument shorelines would increase over time, 

particularly during high visitation seasons (see affected environment description above). 

In addition to shoreline closed to recreational boat landing, the BLM would require permits for 

recreational boat landing on 1.2 miles of Monument shoreline. This shoreline is associated with Category 

A Rocks (this category includes seven rocks and groups of rocks that have some recreation potential: see 

Appendix O). These rocks are relatively small; the BLM would require permits under this alternative in 

order to control the number of visitors at these locations at a given time. Recreational boat landing 

without a permit would continue on 16.6 miles of Monument shoreline. 

Alternative D 

Under Alternative D, all 21.2 miles of Monument shoreline would remain open to recreational boat 

landing. If current recreational trends continue, boating landings on Monument shorelines would increase 

over time, particularly during high visitation seasons (see affected environment description above). 

Under Alternative D, the BLM would allow designated site camping for visitors arriving via nonmotorized boat on 436 acres of Monument land. As new campsites were developed during plan 

implementation, recreational boat landings would increase at these sites. 

Cumulative effects of the Monument’s contribution to recreational boat landing in 

the San Juan Islands 

The alternatives would vary in their incremental impact on the total supply of shoreline open for public 

recreational boat landing in the San Juan Islands. 

The National Park Service, Washington State Parks, WDNR, WDFW, San Juan Preservation Trust, and 

San Juan County all manage shoreline that is open to at least some types of recreational boat landing. 

The majority of shoreline in the San Juan Islands is privately owned (San Juan County 2010). Other than 

the Monument planning process, there are no on-going efforts that would substantially change the 

availability of shoreline open to public recreational boat landing within the San Juan Islands. 

Under the No Action Alternative and alternatives B, C, and D, the BLM would continue to provide a 

relatively small portion of the total shoreline available to the public for recreational boat landing in the 

San Juan Islands. Given the concern expressed by San Juan County residents around shoreline access, 

this contribution may be meaningful regardless of its size (San Juan County 2017). 

Under Alternative A, the Monument would no longer contribute to the supply of lands available to the 

public for recreational use. This reduction in the overall availability of shoreline for recreational boat 

landing could increase competition for areas that remain open to recreational use. It would also limit the 

ability of visitors and residents to participate in non-motorized boat activities in areas where Monument 

lands are typically used as destinations or rest stops where there are no easily accessible and or nearby 

alternatives (e.g., Patos Island). 

162 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Hiking 

2 The alternatives vary in the miles of trails that would be available for hiking in the Monument. Hiking 

3 (including walking) is currently one of the most popular activities within the more easily accessible 

4 Monument lands on Lopez and San Juan islands. 

5 The effects of designating trails for multiple uses on the potential for visitor conflict are described below 

6 (page 180). For maps and information on route segments at each location with the Monument, refer to 

7 Appendix H for the Draft Comprehensive Travel and Transportation Plan. 

8 Table 43: Monument trails open to hiking by alternative 

No Action Alternative A Alternative B Alternative C Alternative D 

Alternative 

(miles) 

(miles) (miles) (miles) (miles) 

* San Juan Island 1.2 0 0.9 0.4 0.9 

Orcas Island* 0.8 0 0.8 0.6 1.4 

Lopez Island* 

Shaw Island* 

9.7 

0.4 

0 

0 

12.4 

0.3 

7.3 

0.2 

14.1 

0.4 

Lummi Island* 0.1 0 0.1 0.1 0.7 

Non- Ferry 

Served Islands 3.9 0 5.4 3.4 7 

and Rocks 

Total 16 0 20 11.9 24.5 

9 Note: these miles include trails under Coast Guard jurisdiction on Monument adjacent lands at Cattle 

Point and Iceberg Point. 

*

Miles for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

non-motorized boat (e.g., the Orcas Island miles includes Indian Island) 

No Action Alternative 

Under the No Action Alternative, 14.9 miles of existing trails would continue to be available to visitors 

participating in hiking in the Monument. There would continue to be no requirement that visitors remain 

on trails, though ease of access would cause most hiking to continue to be on trail. Assuming current 

management continues, there would continue to be 1.2 miles of trail available for hiking on Coast Guard 

lands adjacent to the Monument at Cattle Point and Iceberg Point. 

Most trails would continue to be single track. There would continue to be 2.6 miles of double track tails 

at Cattle Point, Eliza Point, Iceberg Point, Patos Island, Turn Point, and Watmough Bay providing 

opportunities for visitors to hike next to their companions. This includes 0.6 miles of double track trail on 

adjacent Coast Guard lands at Cattle Point and Iceberg Point. 

Given the past increase of trails miles under the BLM’s custodial management approach, user created 

trails would continue to proliferate in the Monument under the No Action Alternative. If current 

recreation trends continue, participation in hiking in the Monument would increase over time, particularly 

during high visitation seasons at more accessible locations (see affected environment section above). 

Alternative A 

Under Alternative A, the BLM would facilitate public use of the Monument for authorized research, 

educational, cultural, and spiritual activities, but not for recreation. As a result, 0 miles of Monument 

trails would be available for recreational hiking. This would remove all currently available opportunities 

for this recreational activity in the Monument. Given that the adjacent Coast Guard lands at Cattle Point 

and Iceberg Point are accessible only through the Monument, the BLM would recommend that these trails 

also be closed. 

The removal of opportunities for this activity would have the greatest impact on residents and visitors to 

Lopez Island and San Juan Island, where the majority of hiking on Monument trails currently takes place. 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

163 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative B 

Under Alternative B, the BLM would designate 1,011 acres of the Monument as RMAs managed in part 

for hiking access (see Appendix O). To facilitate this use while providing additional opportunities for 

solitude and quiet, the BLM would designate 19 miles of trails in the Monument open exclusively to 

hiking. A small number of trails would be closed seasonally to avoid disturbance to nesting seabirds 

(0.04 miles of trail at Indian Island and 0.08 miles of trail at Skull Island)50 . The BLM would also 

recommend that the Coast Guard designate 0.9 miles of trail for hiking on its lands adjacent to the 

Monument at Iceberg Point and Cattle Point. Opportunities for hiking on trails within and immediately 

adjacent to the Monument would increase by 26 percent (3.9 miles). 

Under this alternative, the BLM would require visitors to remain on trails or on un-vegetated shorelines 

while hiking, except in locations that are open to recreation under this alternative but currently have no 

trails. Given that the majority of hiking is currently taking place on trail, this would have a limited impact 

on visitors partaking in this activity. Cross-country hiking would continue to be allowed at Fauntleroy 

Rock, Little Patos Island, Mud Island, Park Bay Island, President Channel, Richardson Rocks, and Twin 

Rocks (these are all low-visitation areas that would be open to recreation under this alternative and that 

currently have no trails). Under Alternative B, a permit is required to recreate at these areas. 

Under this alternative, the BLM would narrow, and recommend that the Coast Guard narrow, 1.1 miles of 

double track trail. This would decrease miles of trail on which visitors can hike next to their companions 

from 2.6 miles to 1.5 miles. 

Under Alternative B, 168 acres of the Monument would be open for recreation by permit only. These 

areas include 1.46 miles of trail at Broken Point Island, Cape Saint Mary, Carter Point, Kellett Bluff, 

Lopez Pass, Lummi Rocks, McConnell Rocks, Oak Island, and Reads Bay Island. Given the low 

visitation currently occurring at these locations—and the relatively small number of affected trail miles—

this permit requirement would have a minor impact on hiking in the Monument. Visitors who are 

interested in opportunities to hike on trails at these locations could request a permit from the BLM. 

If current recreation trends continue, participation in hiking in the Monument would increase over time, 

particularly during high visitation seasons at more accessible locations (see affected environment section 

above). The increased trail miles would potentially increase the dispersal of visitors engaging in hiking in 

the Monument. Under Alternative B, visitors would have an opportunity to hike on trail in areas currently 

unavailable for this activity, including on Kellett Bluff, the northeast section of Chadwick Hill, the north 

shore of Iceberg Point, the northeast side of Patos Island, and the northeast section of Point Colville. See 

Appendix H for maps with specific locations of these potential new trails. 

Alternative C 

Under Alternative C, the BLM would designate 1,014 acres of the Monument as RMAs managed in part 

for hiking access (see Appendix O). To facilitate this use while minimizing the footprint of trails in the 

Monument, it would designate 11.2 miles of trails in the Monument as open to hiking. The BLM would 

also recommend that the Coast Guard designate 0.7 miles of trail for hiking on its lands adjacent to the 

Monument at Iceberg Point and Cattle Point. Opportunities for hiking on trails within and immediately 

adjacent to the Monument would decrease by 25 percent (4.1 miles). The BLM would designate the 

majority of these trail miles exclusively for hiking; 2.6 miles would be designated for both hiking and 

equestrian use. 

Under this alternative, the BLM would require visitors to remain on trails or un-vegetated shorelines 

while hiking, except in areas that are open to recreation under this alternative and currently have no trails. 

Given that the majority of hiking is currently taking place on trail, this would have a limited impact on 

visitors partaking in this activity. Cross-country hiking would continue to be allowed at East Sound Blind 

Island South, Fauntleroy Rock, Kanaka Bay Islands, King Islands, Little Patos Island, Massacre Bay 

Rocks, Mud Island, Park Bay Island, President Channel, Richardson Rocks (both the larger formation and 

the small rocks), Twin Rocks, Trinka Rock, and Unnamed Rock (WNW Kanaka Bay Island) (these are all 

 

50The period of the seasonal closure would be based on BLM monitoring and could vary from year to year. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

164 
 

 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 low-visitation areas that would be open to recreation under this alternative and currently have no trails). 

2 Under Alternative C, a permit would be required to recreate at East Sound Blind Island South, Kanaka 

3 Bay Islands, King Islands, Massacre Bay Rocks, Richardson Rocks (two smaller rocks), Trinka Rock, and 

4 Unnamed Rock (WNW Kanaka Bay Island), which compose the potential Category A Rocks RMA (see 

5 Appendix O: RMA Frameworks). 

6 Under this alternative, the BLM would narrow, and recommend that the Coast Guard narrow, 1.5 miles of 

7 tail that would be designated under this alternative. This would decrease miles of trail on which visitors 

8 can walk next to their companions from 2.6 miles to 1.1 miles. 

9 If current recreation trends continue, participation in hiking in the Monument would increase over time, 

10 particularly during high visitation season at more accessible locations (see affected environment section 

11 above). The reduced trail miles under this alternative would concentrate visitors participating in hiking 

12 on the remaining trails. 

13 Alternative D 

14 Under Alternative D, the BLM would designate all 1,021 acres of the Monument as RMAs to be managed 

15 in part for hiking access (see Appendix O). To expand opportunities for this activity it would designate 

16 23.4 miles of trails in the Monument. The BLM would also recommend that the Coast Guard designate 

17 1.2 miles of trail for hiking on its lands adjacent to the Monument at Iceberg Point and Cattle Point. 

18 Opportunities for hiking on trails within and immediately adjacent to the Monument would increase by 53 

19 percent (8.5 miles). The BLM would designate the majority of these trail miles exclusively for hiking; 

20 8.4 miles would be designated for hiking and equestrian use and/or bicycle use. 

21 Visitors would continue to be allowed to hike cross-country under this alternative, though ease of access 

22 would cause most hiking to continue to be on trail. 

23 Under this alternative, the BLM would widen, and recommend that the Coast Guard widen, 0.2 miles of 

24 trail. This would increase the miles of trail on which visitors can hike next to their companions from 2.6 

25 to 2.8 miles. 

26 If current recreation trends continue, participation in hiking in the Monument would increase over time, 

27 particularly during high visitation season at more accessible locations (see affected environment section 

28 above). Visitors would have an opportunity to hike on trail in areas currently unavailable for this activity, 

29 including on Kellett Bluff, the northeast section of Chadwick Hill, the north shore of Iceberg Point, the 

30 east side of Patos Island, and the northeast section of Point Colville. Those seeking opportunities to hike 

31 in the absence of equestrian or bicycle use might shift their use to areas and trails where these activities 

32 are not allowed under this alternative. See Appendix H for maps with specific locations of these potential 

33 new trails. 

34 Cumulative effects on hiking opportunities in the San Juan Islands 

35 The alternatives would vary in their incremental impact on the total supply of opportunities for hiking on 

36 trails in the San Juan Islands, as well as the supply of opportunities easily available to residents and 

37 visitors on each island. Table 44 provides the percent increase or decrease in the total trail network in 

38 both the San Juan Islands as a whole and for each ferry-served island. 

39 Table 44: Percent change in San Juan Islands hiking trail miles 

Current Total Trail 

Miles (Monument and 

Non-Monument) 

Alternative A 

(percent 

change) 

Alternative B 

(percent 

change) 

Alternative C 

(percent 

change) 

Alternative D 

(percent 

change) 

San Juan 

Island* 65 -2% <-1% -1% 0% 

Orcas Island* 53 -1% <-1% 0% +1% 

Lopez Island* 14 -69% 19% -17% +31% 

Shaw Island* 3 -12% <-1% -5% +3% 

165 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Current Total Trail 

Miles (Monument and 

Non-Monument) 

Alternative A 

(percent 

change) 

Alternative B 

(percent 

change) 

Alternative C 

(percent 

change) 

Alternative D 

(percent 

change) 

Lummi 

Island* 6 -2% 0% <-1% +10% 

Non- Ferry 

Served Islands 

and Rocks 

55 -7% +3% -1% +6% 

Total 196 -8% +2% -2% +4% 

1 * Miles for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

non-motorized boat (e.g., the Orcas Island miles includes Indian Island) 

In the San Juan Islands there are an array of governmental agencies and non-profit organizations that 

provide approximately 196 miles of publically accessible trails for hiking. Under the No Action 

Alternative, the Monument, and the adjacent Coast Guard lands, would continue to provide approximately 

8 percent of the overall miles available for hiking in the San Juan Islands. The magnitude of this 

contribution varies substantially between islands (Table 44), with by far the most substantial contribution 

occurring on Lopez Island, where the Monument is a primary provider of trails for hiking. While new 

trails may be developed in the San Juan Islands over the life of the plan, the BLM does not have data to 

calculate how trail miles outside of the Monument would change. 

Alternatives A and C would both decrease the overall supply of trails on public lands in the San Juan 

Islands. Under Alternative A, the overall opportunities for hiking on trail on public lands in the San Juan 

Islands would decrease by 8 percent if no new trails are developed or closed outside of the Monument. 

For Shaw Island, the closure of 0.4 miles of trail on nearby Blind and Broken Point islands would cause a 

12 percent decrease in the overall trail miles available for hiking. On Lopez Island the supply of trails for 

hiking would decrease by 69 percent. Given the popularity of hiking as an activity in the San Juan 

County (San Juan County 2017), this would substantially impact visitors and residents seeking to 

participate in this activity on Lopez Island and increase demand for the approximately 4.3 miles of trail on 

Lopez Island not associated with the Monument. 

Under Alternative C, the overall opportunities for hiking on trail in the San Juan Islands would decrease 

by 2 percent if no new trails are developed or closed outside of the Monument. On Lopez Island, miles 

available for this activity would decrease by 17 percent. This would increase demand for the remaining 

trails both within and outside of the Monument. 

Alternatives B and D would both increase the overall supply of trails in the San Juan Islands. Under 

Alternative B, the overall opportunities for hiking on trail in the San Juan Islands would increase by 2 

percent. On Lopez Island, the trail miles would increase by 22 percent, providing increased opportunities 

for visitors to disperse across the trail system, particularly during higher visitation seasons. 

Under Alternative D, there would be a 4 percent increase in the overall supply of trails for hiking in the 

San Juan Islands if no new trails are developed or closed outside of the Monument. New trails at Carter 

Point (0.4 miles) and Lummi Rocks (0.2 miles) would increase the overall trail network for Lummi Island 

by 10 percent. On Lopez Island, the trail miles would increase by 31 percent, providing increased 

opportunities for visitors to disperse across the trail system, particularly during higher visitation seasons. 

Equestrian Use 

The alternatives vary in the number of RMAs that would be managed in part for equestrian use, as well as 

in the miles of trail that would be designated for this use. The BLM has received comments from 

members of the public requesting opportunities for this activity within Monument lands on the south end 

of Lopez Island; the BLM has also received comments from members of the public requesting that this 

use not be allowed (BLM 2015b,c, BLM 2016a,b). There is no current known equestrian use on 

Monument lands outside of Lopez Island. The BLM has not received comments requesting that trails be 

designated for this use in other parts of the Monument. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

166 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 All trails in the Monument are currently open to all non-motorized uses. Equestrian use is currently 

2 occurring on a small number of these trails (approximately 1 mile). 

3 The effects of designating trails for multiple uses on the potential for visitor conflict are described below 

4 (page 180). 

5 For maps and information on route segments at each location with the Monument, see Appendix H for the 

6 Draft Comprehensive Travel and Transportation Plan. 

7 Table 45: Monument trails open to equestrian use by alternative 

No Action Alternative A Alternative B Alternative C Alternative D 

Alternative (Miles) (Acres) (Acres) (Acres) 

(Miles)* 

San Juan Island 1.2 0 0 0 0 

Orcas Island 0.8 0 0 0 0 

Lopez Island 9.7 

(~1 mile currently 0 0 2.6 8.4 

used for equestrian) 

Shaw Island 0.3 0 0 0 0 

Lummi Island 0.1 0 0 0 0 

Non- Ferry Served 

Islands and Rocks 3.9 0 0 0 0 

Total 16 0 0 2.6 8.4 

8 Note: these trail totals include trails under Coast Guard jurisdiction on Monument adjacent lands at Cattle 

Point and Iceberg Point. 

*There are no current management decisions related to equestrian use so all trails are open to this use. 

There is currently limited equestrian use. Trails associated with Shaw Island, Lummi Island, Orcas 

Island, and non-ferry served islands and rocks would be challenging to access for equestrian use. 

No Action Alternative 

Under the No Action Alternative, there would continue to be a user created trail network open to all nonmotorized uses. Equestrian use would continue to be allowed throughout the Monument, though, given 

that many Monument locations are only accessible by personal boat, this activity would remain primarily 

confined to the areas in which it currently takes place. It is likely that the current regular equestrian use 

of some trails at Chadwick Hill and Watmough Bay would continue. 

Alternative A and Alternative B 

Under both Alternative A and Alternative B, the BLM would not designate any RMAs for equestrian use. 

As a result, it would not designate any trails for equestrian use under these alternatives (i.e., all trails 

would be closed to equestrian use). Under both alternatives, all opportunities for trail-based equestrian 

use would be removed from the Monument. Under Alternative B, the Monument’s existing 1 mile of

road at Point Colville, Turn Point, and Watmough Bay would remain open to equestrian use. 

The removal of opportunities for this activity would have the greatest impact on residents and visitors to 

Lopez Island currently engaging in this use on a small number of trails at Chadwick Hill and Watmough 

Bay. There is no current equestrian use, or known public interest in this use, on Monument lands outside 

of Lopez Island. As a result, this prohibition would have a nominal effect on opportunities for this 

activity in the Monument outside of Lopez Island. 

Alternative C 

Under Alternative C, the BLM would designate RMAs at Chadwick Hill and Watmough Bay to be 

managed in part for trail-based equestrian access. To facilitate this use, the BLM would designate a total 

of 2.6 miles of trails as open to equestrian travel. Except for a 0.2 mile gravel trail from the parking lot to 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

167 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

the beach at Watmough Bay, these trails would be closed to equestrian use during the wet season51 . The 

Monument’s existing 1 mile of road at Point Colville, Turn Point, and Watmough Bay would remain open 

to equestrian use. All other RMAs and trails would be closed to equestrian use. 

While all trails in the Monument are currently open to equestrian use, it is likely that designating a set of 

trails explicitly for this use would increase the perceived opportunities for this activity across the 

Monument. This use is currently undertaken primarily by residents of Lopez Island, so increasing nonresident visitation may not affect rates of participation in this activity. 

Alternative D 

Under Alternative D, the BLM would designate RMAs at Chadwick Hill, Iceberg Point, Point Colville, 

and Watmough Bay to be managed in part for trail-based equestrian access. To facilitate this use, the 

BLM would designate a total of 7.9 miles of trail as open to equestrian travel. It would also recommend 

that the Coast Guard designate 0.3 miles of trail for equestrian use on its lands adjacent to the Monument 

at Iceberg Point. 

Except for a 0.2 mile gravel trail from the parking lot to the bay at Watmough Beach, these trails would 

be closed to equestrian use during the wet season51 . The Monument’s existing 1 mile of road at Point

Colville, Turn Point, and Watmough Bay would remain open to equestrian use. All other RMAs and 

trails would be closed to equestrian use. 

While all trails in the Monument are currently open to equestrian use, it is likely that designating a set of 

trails explicitly for this use would increase the perceived opportunities for this activity across the 

Monument. This use is currently undertaken primarily by residents of Lopez Island. Given the 

challenges associated with transporting horses to the San Juan Islands, increases in non-resident visitation 

over time may not affect rates of participation in this activity. Under Alternative D, the development of 

new trails would create opportunities for equestrian use in areas currently unavailable for this activity, 

including the northeast section of Chadwick Hill, the north shore of Iceberg Point, and the northeast 

section of Point Colville. See Appendix H for maps with specific locations of these potential new trails. 

Cumulative effects on equestrian opportunities in the San Juan Islands 

The alternatives would vary in their incremental impact on the total supply of opportunities for trail-based 

equestrian use in the San Juan Islands, as well as the supply of opportunities easily available to residents 

and visitors on Lopez Island. 

In the San Juan Islands, there are an array of governmental agencies and one private organization that 

currently provide approximately 34 miles of publically accessible trails used for equestrian travel (see 

Table 32 on page 150). Orcas Island has 12 miles of publically accessible trails used for equestrian 

travel; these trails are located in Moran State Park and in the San Juan County Land Bank’s Turtleback

Mountain property. On San Juan Island, there are 18 miles of publically accessible trails that are used for 

equestrian travel. On Lopez Island—the only island on which there is currently known equestrian use in 

the Monument—there are 4 miles of publically accessible trails used for equestrian travel. Given the 

difficultly and cost associated with transporting horses between islands, participants in this activity 

primarily benefit from local opportunities rather than from opportunities throughout the San Juan Islands 

(e.g., a resident of Lopez Island is unlikely to make substantial use of equestrian trails on Orcas Island). 

While new trails may be developed in the San Juan Islands over the life of the plan, the BLM does not 

have data to calculate how trail miles outside of the Monument would change. 

Under the No Action Alternative, all trails within the Monument would continue to be open to, but not 

specifically managed for, equestrian travel. Assuming current trends continue, trail-based equestrian 

travel would continue to be limited to approximately 1 mile of Monument trail. Under the No Action 

Alternative, the BLM would continue to provide approximately 3 percent of the publically accessible 

trails used for equestrian travel throughout the San Juan Islands and approximately 25 percent of the trails 

 

51The period of the seasonal closure would be based on BLM monitoring and could vary from year to year; it is 

likely to be from approximately mid-October to mid-May. 

5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

168 
 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 available for this use on Lopez Island. The Monument would remain one of the primary providers of 

2 opportunities for this activity on Lopez Island. 

3 Under alternatives A and B, the Monument would not contribute to the supply of trail-based equestrian 

4 opportunities in the San Juan Islands. This would decrease the miles of trail currently used for this 

5 activity by approximately 3 percent in the San Juan Islands and by approximately 25 percent on Lopez 

6 Island. The removal of this opportunity from the Monument would have a limited impact on equestrians 

7 outside of Lopez Island. It would substantially impact visitors and residents seeking to participate in this 

8 activity on Lopez Island and increase demand for the approximately 3 miles of equestrian trails on Lopez 

9 Island not associated with the Monument. These alternatives would also preclude Monument trails not 

10 currently used for equestrian travel from absorbing any unmet demand for trails open to this activity. 

11 Under alternatives C and D, the miles of trails designated for equestrian use would increase both in the 

12 San Juan Islands as a whole and on Lopez Island. Because all user created trails in the Monument are 

13 currently open to equestrian use, the theoretical opportunities for this activity would decrease under these 

14 alternatives. The trails managed specifically for this use would increase. 

15 Under Alternative C, the supply of trails designated for equestrian use would increase by approximately 5 

16 percent in the San Juan Islands and approximately 60 percent on Lopez Island. Under Alternative D, the 

17 supply of trails designated for this purpose would increase by approximately 21 percent in the San Juan 

18 Islands in general and approximately 197 percent on Lopez Island. Under both alternatives, opportunities 

19 to engage in this use would technically decline due to the current undesignated status of the trail system. 

20 It is likely, however, that explicit management of trails for this purpose would increase use. 

21 Bicycle Use 

22 The alternatives vary in the number of RMAs that would be managed in part for bicycle use, as well as in 

23 the miles of trail that would be designated for this use. The BLM has received comments from members 

24 of the public requesting opportunities for this activity on Monument trails on the south end of Lopez 

25 Island and at Cattle Point (San Juan Island). The BLM has also received comments from members of the 

26 public requesting that this use not be allowed (BLM 2015b,c, BLM 2016a,b). 

27 All trails in the Monument are currently open to all non-motorized uses. The BLM is not aware of 

28 current, regular bicycle use at any Monument location. 

29 The effects of designating trails for multiple uses on the potential for visitor conflict are described below 

30 (page 180). 

31 For maps and information on route segments at each location with the Monument, see Appendix H for the 

32 Draft Comprehensive Travel and Transportation Plan. 

33 Table 46: Monument trails open to bicycle use by alternative 

Island No Action Alternative A Alternative B Alternative C Alternative D 

Alternative (Miles) (Acres) (Acres) (Acres) 

(Miles)* 

San Juan Island 1.2 0 0 0 0.2 

Orcas Island 0.8 0 0 0 0 

Lopez Island 9.7 0 0 0 8.2 

Shaw Island 0.3 0 0 0 0 

Lummi Island 0.1 0 0 0 0 

Non- Ferry Served 

Islands and Rocks 3.9 0 0 0 0 

Total 16 0 0 0 8.4 

34 Note: these trail totals include trails under Coast Guard jurisdiction on Monument adjacent lands at Cattle 

Point and Iceberg Point. 

*There are no current management decisions related to bicycle use so all trails are open to this use; there 

are no Monument trails regularly used for bicycle access. Trails associated with Shaw Island, Lummi 

Island, Orcas Island, and non-ferry served islands and rocks would be challenging to access by bicycle. 

35 

36 

37 

38 

169 
 

 

 

5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 No Action Alternative 

Under the No Action Alternative, there would continue to be a trail network open to all non-motorized 

uses. If current trends continue, bicycling would be only an occasional use of Monument trails. 

Alternatives A, B, and C 

Under alternatives A, B, and C, the BLM would not designate any RMAs for trail-based bicycle use (i.e., 

all trails would be closed to bicycle use). As a result, it would not designate any trails for bicycle use 

under these alternatives. Under alternatives B and C, the 1 mile of existing road in the Monument (at 

Point Colville, Turn Point, and Watmough Bay) would continue to be open to bicycle use. 

The BLM has received comments requesting that bicycle access be allowed in specific locations or 

generally throughout the Monument, suggesting that there is some demand for bicycle trails that is not 

currently being met (BLM 2016a,b). While Monument trails are not currently being regularly used for 

bicycle travel, these alternatives would remove the potential for this demand to be met in the Monument. 

Alternative D 

Under Alternative D, the BLM would designate RMAs at Cattle Point, Chadwick Hill, Iceberg Point, 

Point Colville, and Watmough Bay to be managed in part for trail-based bicycle access. To facilitate this 

use, the BLM would designate a total of 8 miles of trail as open to bicycle travel. It would also 

recommend that the Coast Guard designate 0.3 miles of trail for bicycle use on its lands adjacent to the 

Monument at Iceberg Point and <0.1 miles of trail for bicycle use on its lands adjacent to the Monument 

at Cattle Point. 

Except for a 0.2 mile gravel trail from the parking lot to the bay at Watmough Beach and a 0.2 mile trail 

from the road at Cattle Point, these trails would be closed to bicycle use during the wet season52. The 1 

mile of existing road in the Monument (at Point Colville, Turn Point, and Watmough Bay) would 

continue to be open to bicycle use. All other RMAs and trails would be closed to bicycle use. 

While all trails in the Monument are currently open to bicycle use, it is likely that designating a set of 

trails explicitly for this use would increase the perceived opportunities for this activity in the Monument. 

Under Alternative D, the development of new trails would create opportunities for bicycle use in areas 

currently unavailable for this activity, including the northeast section of Chadwick Hill, the north shore of 

Iceberg Point, and the northeast section of Point Colville. See Appendix H for maps with specific 

locations of these potential new trails. 

Cumulative effects on bicycling opportunities in the San Juan Islands 

The alternatives would vary in their incremental impact on the total supply of opportunities for trail-based 

bicycle use in the San Juan Islands, as well as the supply of opportunities easily available to residents and 

visitors on ferry-served islands. 

In the San Juan Islands there are an array of governmental agencies and private organizations that provide 

nearly 60 miles of publically accessible trails used for bicycle travel (see Table 33). Orcas Island has 34 

miles of trails open to this use, the majority of which are within Moran State Park. San Juan Island and 

Lopez Island respectively have 20 miles and 4.6 miles of publically accessible trails that are used for 

bicycle travel; the BLM is not aware of publically accessible trails on Lummi or Shaw islands that are 

open to this use. While new trails may be developed in the San Juan Islands over the life of the plan, the 

BLM does not have data to calculate how trail miles outside of the Monument would change. 

Under the No Action Alternative, all trails within the Monument would continue to be open to, but not 

specifically managed for, bicycle travel. Assuming current trends continue, trail-based bicycle use would 

continue to be limited in the Monument, though opportunities for this activity would continue. Under the 

No Action Alternative, the Monument would continue to negligibly contribute to the supply of the 

publically accessible trails used for bicycle travel throughout the San Juan Islands. The potential would 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

52The period of the seasonal closure would be based on BLM monitoring and could vary from year to year; it is 

likely to be from approximately mid-October to mid-May. 

170 
 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 remain for Monument trails in more accessible locations to absorb some demand for trail-based bicycling 

2 opportunities in the future. 

3 Under alternatives A, B, and C, the Monument would not contribute to the supply of trail-based bicycling 

4 opportunities in the San Juan Islands. While this would negligibly impact the supply of trails currently 

5 used for bicycle travel in the San Juan Islands, it would preclude any eventual use of these trails to absorb 

6 unmet demand for trails open to this activity. 

7 Under Alternative D, the miles of trails designated for bicycling use would increase both in the San Juan 

8 Islands as a whole and on Lopez and San Juan islands. Because all user created trails in the Monument 

9 are currently open to bicycle use, the theoretical opportunities for this activity would decrease under this 

10 alternative. The trails managed for this use throughout the San Juan Islands would increase by 14 

11 percent. The trails managed for this use on Lopez Island and San Juan Island would increase by 174 

12 percent and 1 percent respectively. This would substantially increase the trail miles managed for bicycle 

13 use available to residents and visitors on Lopez Island. The supply of trails managed for this use on 

14 Orcas, Shaw, and Lummi islands would remain unchanged. 

15 Camping 

16 The alternatives vary in Monument acres that would be open to different types of camping. The BLM has 

17 received comments from members of the public requesting that designated campsites be maintained or 

18 expanded and that camping generally be allowed where possible. The BLM has also received comments 

19 from members of the public requesting that camping be prohibited in specific areas or throughout the 

20 Monument (BLM 2015b,c, BLM 2016a,b). 

21 The alternatives consider three types of camping: designated site camping, dispersed camping without a 

22 permit, and dispersed camping with a permit (limit to one group per night per location, no more than five 

23 campers). Dispersed camping means that no sites are identified and limited or no facilities are provided. 

24 Table 47: Monument acres open to designated site camping by alternative 

No Action 

Alternative 

(Sites) 

Alternative A 

(Acres) 

Alternative B 

(Acres) 

Alternative C 

(Acres) 

Alternative D 

(Acres) 

San Juan Island* 0 0 0 0 † 23

Orcas Island* 0 0 0 0 †3

Lopez Island* 0 0 0 0 † 100

Shaw Island * 4 existing sites 

(Blind Island) 0 

‡2

(Blind Island) 

‡2

(Blind Island) 

†2

(Blind Island) 

Lummi Island* 0 0 0 0 †8

Non- Ferry 

Served Islands 

and Rocks 

9 existing sites 

(Posey and Patos 

islands) 

0 

‡ 212

(Posey and 

Patos islands) 

‡ 212

(Posey and 

Patos islands) 

† 300

Total NA 0 214 214 436 

25 *Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

26 non-motorized boat (e.g., the Shaw Island acreage includes Blind Island) 

†

27 The BLM would identify specific designated sites during plan implementation; disturbance would be 

28 likely to occur on a fraction of this acreage. 

29 

‡ Camping would be restricted to the existing designated campsites. 

171 
1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 48: Monument acres open to dispersed camping (no permit required) by alternative 

No Action 

Alternative 

(Acres) 

Alternative A 

(Acres) 

Alternative B 

(Acres) 

Alternative C 

(Acres) 

Alternative D 

(Acres) 

San Juan Island* 23 0 0 0 0 

Orcas Island* 42 0 0 0 33 

Lopez Island* 4 0 0 0 370 

Shaw Island* 5 0 0 0 3 

Lummi Island* 50 0 0 0 43 

Non- Ferry Served 

Islands and Rocks 392 0 0 0 86 

Total 516 0 0 0 535 

2 *Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

3 non-motorized boat (e.g., the Orcas Island acreage includes Oak Island) 

4 Table 49: Monument acres open to dispersed camping by permit only by alternative 

No Action 

Alternative 

(Acres) 

Alternative 

A 

(Acres) 

Alternative B 

(Acres) 

Alternative C 

(Acres) 

Alternative D 

(Acres) 

San Juan Island* 0 0 <1 0 0 

Orcas Island* 0 0 32 0 0 

Lopez Island* 0 0 470 0 0 

Shaw Island* 0 0 3 0 0 

Lummi Island* 0 0 50 0 0 

Non- Ferry Served 

Islands and Rocks 0 0 170 0 0 

Total 0 0 726 0 0 

5 *Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

6 non-motorized boat (e.g., the Orcas Island acreage includes Oak Island) 

7 Table 50: Monument acres closed to all camping 

No Action 

Alternative 

(Acres) 

Alternative A 

(Acres) 

Alternative B 

(Acres) 

Alternative C 

(Acres) 

Alternative D 

(Acres) 

San Juan Island* 0 23 23 23 0 

Orcas Island* 0 42 10 42 6 

Lopez Island* 503 508 37 508 37 

Shaw Island* 0 5 0 3 0 

Lummi Island* 0 50 0 50 0 

Non- Ferry Served 

Islands and Rocks* 0 392 9 173 6 

Total 503 1,021 78 799 49 

8 *Acres for ferry served islands include nearby, small islands that are easily accessible at low tide or by 

non-motorized boat (e.g., the Orcas Island acreage includes Indian Island) 

No Action Alternative 

Under the No Action Alternative, there would continue to be camping in designated sites at Blind, Patos, 

and Posey islands. Given current recreation trends, there would continue to be high levels of visitor 

participation in this activity during the summer. 

The majority of the Monument (516 acres) would continue to be open to the public for dispersed camping 

with no permit required. The 1990 ACEC decisions that apply to 503 acres on Lopez Island (Chadwick 

9 

10 

11 

12 

13 

14 

15 

172 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Hill, Iceberg Point, Point Colville, and Watmough Bay) would continue to prohibit overnight camping 

within these areas. 

While dispersed camping is currently available on all Monument lands outside of Lopez Island, this use 

occurs infrequently. This activity could become more popular in the future if demand for camping 

opportunities in the San Juan Islands is not met outside of the Monument. 

Alternative A 

Under Alternative A, the BLM would facilitate public use of the Monument for authorized research, 

educational, cultural, and spiritual activities, but not for recreation. As a result, there would be no 

recreational camping available, though overnight use could be allowed for authorized uses. 

The removal of opportunities for designated site camping in the Monument would substantially affect the 

many visitors who currently engage in this activity at Blind, Patos, and Posey islands. The prohibition on 

dispersed camping in the Monument would have a limited effect on current visitors given the very lowlevel of engagement in this activity. The BLM has received comments requesting additional camping 

opportunities within the Monument, however, suggesting that there is demand for camping not currently 

being met (BLM 2015b,c, BLM 2016a,b). This alternative would remove the potential for this demand to 

be met in the Monument. 

Alternative B 

Under Alternative B, as under all alternatives except for A, the BLM would continue to allow camping in 

designated sites at Blind, Patos, and Posey islands. Given current recreation trends, there would continue 

to be high levels of visitor participation in this activity during the summer. 

The BLM would also allow dispersed camping by permit on 726 acres of Monument land. Permits would 

be limited to one group per night per location with no more than five campers. This would provide 

opportunities for visitors seeking quiet and solitude through a primitive camping experience. The 

requirement of a permit would limit the number of visitors able to participate in this activity. 

Under this alternative, 78 acres of the Monument would be closed to all camping. This would include a 

continuation of the current camping prohibition at Watmough Bay, as well as a new prohibition on this 

activity at Freeman Island, Indian Island, Skull Island, Victim Island, and Category A and B Rocks. 

These closures would likely have a limited effect on visitors given the current very low-level of 

engagement in this activity in these areas and the continuation of camping opportunities at other locations. 

Alternative C 

Under Alternative C, as under all alternatives except for A, the BLM would continue to allow camping in 

designated sites at Blind, Patos, and Posey islands. Given current recreation trends, there would continue 

to be high levels of visitor participation in this activity during the summer. 

The remainder of the Monument (799 acres) would be closed to camping. This would include a 

continuation of the current camping prohibition at Chadwick Hill, Iceberg Point, Point Colville, and 

Watmough Bay, as well as a new prohibition on this activity on 302 Monument acres currently open to 

this use. Given the very low-level of engagement in this activity, the prohibition on dispersed camping in 

the Monument would have a limited effect on current visitors. The BLM has received comments 

requesting additional camping opportunities within the Monument, however, suggesting that there is 

demand for camping not currently being met (BLM 2015b,c, BLM 2016a,b). Alternative C would 

remove the potential for this demand to be met in the Monument. 

Alternative D 

Under Alternative D, as under all alternatives except for A, the BLM would continue to allow camping in 

designated sites at Blind, Patos, and Posey islands. This could include designating new sites in these 

locations. Given current recreation trends, there would continue to be high levels of visitor participation 

in this activity during the summer. 

Under this alternative, the BLM would also allow designated site camping on an additional 221 acres of 

Monument land. This would approximately double the current Monument acres open to designated site 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

173 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 camping. The BLM would determine specific locations for new designated sites during plan 

implementation; this would involve a separate project level planning and NEPA compliance process prior 

to any on-the-ground disturbance. Camping would only be allowed in these areas after the completion of 

the project level planning to designate sites. These sites would be developed in support of the Cascadia 

Marine Trail (see Special Designations) and would be open only to visitors arriving via non-motorized 

watercraft. Given the popularity of current designated site camping opportunities in the San Juan Islands, 

it is likely that visitor use of these sites would be high. 

The BLM would continue to allow dispersed camping on 166 acres of Monument land currently open to 

this use. It would also allow this activity on 370 acres of land currently closed to this use at Chadwick 

Hill and Point Colville. While dispersed camping is currently a very limited use of the Monument, this 

use could become more popular if demand for camping is not met through other opportunities. 

The remainder of the Monument (49 acres) would be closed to camping. This would include a 

continuation of the current camping prohibition at Watmough Bay, and a new prohibition on this activity 

at Indian Island, Twin Rocks, Victim Island, and Category B Rocks. This closure would likely have a 

limited effect on visitors given the current very low-level of participation in this activity and the 

availability under this alternative of camping opportunities in other parts of the Monument. 

Cumulative effects on designated site camping opportunities in the San Juan 

Islands 

The alternatives would vary in their incremental impact on the total supply of opportunities for camping 

in the San Juan Islands, as well as the supply of opportunities easily available to residents and visitors on 

each island. 

In the San Juan Islands, there are an array of governmental agencies that manage approximately 467 

designated campsites on public lands (see Table 35 on page 152). The ferry served islands cumulatively 

have 234 designated campsites on public lands, including 77 on Lopez Island, 5 on Lummi Island, 156 on 

Orcas Island, 17 on Shaw Island, and 30 on San Juan Island. Other than the Monument planning process, 

there are no on-going efforts that would substantially change the supply of camping opportunities within 

the San Juan Islands. 

Under the No Action Alternative and alternatives B and C, the Monument would continue to provide 

approximately 3 percent of the designated campsites available on public lands in the San Juan Islands. 

All of these campsites are only accessible via personal watercraft, though the four on Blind Island are 

close enough to Shaw for the BLM to consider them as contributing to the recreational opportunities 

available to that community. 

Under Alternative A, no designated site camping would be available within the Monument, reducing the 

overall supply of designated campsites on public land in the San Juan Islands by 3 percent. While this is 

a small percent of campsites, this closure would increase demand for other camping opportunities during 

high visitation periods. 

Under Alternative D, the acres available for designated site camping within the Monument would almost 

double. While the BLM would determine the number and location of sites after gathering input during 

plan implementation, the Monument’s contribution to the overall number of campsites in the San Juan 

Islands would increase over time under this alternative. 

Under the No Action Alternative and alternatives B and D, the BLM would continue to provide the only 

dispersed camping opportunities within the San Juan Islands. While dispersed camping is currently a 

very limited use of the Monument, this use could become more popular if demand for camping during 

high visitation periods is not met through other opportunities. Under alternatives A and C, the BLM 

would not allow dispersed camping in the Monument. This would remove the possibility that the 

Monument could absorb camping demand not met in the rest of the San Juan Islands. 

Hunting Using Firearms 

Note: Based on public comments, the BLM has included discharge of firearm prohibitions in the range of 

alternatives. These prohibitions would affect hunting using firearms, but would not affect other forms of 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

174 
 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 hunting (e.g., bow hunting); in other words, all 1,021 acres would remain open to hunting under all 

2 alternatives. These prohibitions would also not affect hunting with firearms by Coast Salish tribal 

3 members. 

4 The BLM does not regulate hunting per se; hunting in Washington State is regulated by WDFW. The 

5 BLM can restrict or prohibit the discharge of firearms within the Monument and is considering doing so 

6 within the range of alternatives. 

7 The BLM is not aware of firearms being discharged in the Monument for target shooting or other non8 hunting purposes, so potential closures would primarily affect opportunities for hunting with firearms. 

9 Non-firearm-based hunting would continue to be allowed under all alternatives to the extent consistent

10 with WDFW laws and regulations.

11 The BLM included the consideration of firearm prohibitions in Alternative C and Sub-Alternative C due 

12 to public comments requesting that hunting using firearms be restricted or eliminated either in specific 

13 locations or in the Monument as a whole. These requests were generally linked to safety concerns around 

14 conflicts between hunters and other visitors. The BLM has also received comments from members of the 

15 public and agency partners requesting that all hunting opportunities be retained. These comments 

16 describe variously a desire to preserve recreational opportunities and concerns about the deer population 

17 in the San Juan Islands. 

18 Secretarial Order 3356 calls for amending National Monument land use plans to “include or expand 

19 hunting, recreational shooting, and fishing opportunities to the extent practicable under the law.” The 

20 lack of plan-level prohibitions on firearm discharge under the No Action Alternative, Alternative B, and 

21 Alternative D would best meet the direction provided in Secretarial Order 3356. 

22 The effects of discharge of firearms prohibitions on the potential for visitor conflict are described below 

23 (page 180). 

24 Table 51: Firearm prohibitions by alternative* 

No Action 

Alternative 

(Acres)†

Alternative A Alternative B 

(Acres) (Acres) 

Alternative C 

(Acres) 

Alternative 

D 

(Acres) 

23 

San Juan Island 0 0 0 (partial closure‡) 0 

Sub-Alt C: 23 

Orcas Island 0 0 0 0 

Sub-Alt C: 42 0 

503 

Lopez Island 0 0 0 (partial closure‡) 0 

Sub-Alt C: 508 

Shaw Island 0 0 0 0 

Sub-Alt C: 5 0 

Lummi Island 0 0 0 0 

Sub-Alt C: 50 0 

Non-ferry Served 

Islands and Rocks 0 0 0 

86 

(partial closure‡) 

Sub-Alt C: 393 

0 

Total 0 0 0 612 

Sub-Alt C: 1021 0 

25 * All 1,021 acres of the Monument would be open to hunting under all alternatives. 

†

There are no current management decisions related to the discharge of firearms; all Monument lands are 

thus open to this use. Hunting with firearms is known to take place at least occasionally on 612 acres of 

Monument land. 

26 

27 

28 

175 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 ‡Firearm discharge would be prohibited in these areas except for one half of the firearm-based hunting 

season. The BLM would work with WDFW annually to establish the prohibition period. This is 

currently how the San Juan County Land Bank manages Lopez Hill, the only non-Monument public land 

currently open to hunting on Lopez Island. 

No Action Alternative, Alternative B, and Alternative D 

Under the No Action Alternative and alternatives B and D, there would continue to be no prohibition on 

the discharge of firearms in the Monument. BLM-administered lands on which firearm discharge is not 

prohibited would continue to be open to this use, though may be subject to temporary closures for 

emergencies and public health and safety concerns. 

Assuming continuation of current trends, hunting with firearms would continue at the contiguous 

Chadwick Hill, Point Colville, and Watmough Bay area (cumulatively approximately 406 acres) and 

Iceberg Point (approximately 97 acres). It would also likely occur occasionally at Cattle Point (23 acres)

and Turn Point (86 acres). Most of the Monument’s rocks and islands do not offer meaningful hunting

opportunities due to their small size and lack of target species. 

Alternative A 

Under Alternative A, there would continue to be no prohibition on the discharge of firearms within the 

Monument. The BLM would facilitate public use of the Monument for authorized research, educational, 

cultural, and spiritual purposes, but not for recreation. As a result, hunting opportunities in the 

Monument would be substantially reduced. The BLM could also work in partnership with WDFW to 

authorize hunting to reduce over-population of wildlife species that are damaging plant communities. 

This reduction in hunting opportunities would have the greatest effect on residents and visitors to Lopez 

Island, where most hunting within the Monument has been observed. 

Alternative C 

Under Alternative C, the BLM would prohibit firearm discharge in areas about which members of the 

public have specifically expressed concerns about hunting and/or the discharge of firearms, except for 

half of firearm-based deer hunting seasons to provide some opportunities for this activity. The BLM 

would work with WDFW on an annual basis to establish the period of time during which the prohibition 

would not apply. The San Juan County Land Bank currently takes a similar approach at Lopez Hill, 

which is the only non-Monument public land on Lopez Island that allows hunting. 

This prohibition would affect 612 acres of Monument land, reducing the acreage on which the discharge 

of firearms is allowed year round by 60 percent. Specifically, the prohibition would cover Chadwick Hill, 

Iceberg Point, Point Colville, and Watmough Bay on Lopez Island; Cattle Point on San Juan Island; and 

Turn Point on Stuart Island. This prohibition would have the greatest effect on residents and visitors on 

Lopez Island, where most hunting within the Monument has been observed. The partial prohibition could 

cause more hunters to visit the Monument during the shortened season for firearm-based hunting, 

potentially increasing crowding and visitor conflict during this part of the season. 

This prohibition would also remove opportunities for target shooting, though the BLM is not aware of any 

instances of this activity in the Monument. 

The firearm prohibition included in this alternative would not affect non-firearm-based hunting within the 

Monument (e.g., bow hunting), which would continue to be allowed. It would also not affect the 

discharge of firearms by Coast Salish tribal members for the purposes of hunting. 

Sub-Alternative C (same Recreation objectives and direction as Alternative C, except for direction 

around discharge of firearms) 

Under Sub-Alternative C, the BLM would prohibit firearm discharge on all 1,021 acres of Monument 

land to the discharge of firearms. This prohibition would remove opportunities for hunting using firearms 

entirely from the Monument. It would have the greatest effect on residents and visitors on Lopez Island, 

which is where most hunting within the Monument has been observed. This prohibition would also 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

176 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 remove opportunities for target shooting, though the BLM is not aware of any instances of this activity in 

the Monument. 

The firearm prohibition included in this alternative would not affect non-firearm-based hunting within the 

Monument (e.g., bow hunting), which would continue to be allowed. It would also not affect the 

discharge of firearms by Coast Salish tribal members for the purposes of hunting. 

Cumulative effects on opportunities for firearm-based hunting in the San Juan 

Islands 

The alternatives would vary in their incremental impact on the total supply of opportunities for hunting 

using firearms in the San Juan Islands, as well as the supply of opportunities easily available to residents 

and visitors on Lopez Island. 

In the San Juan Islands, hunting is allowed on approximately 6,600 acres of public land managed by the 

BLM, WDFW, WDNR, and the San Juan County Land Bank (see Table 36). The majority of this acreage 

is on Cypress Island (5,100 acres), which is a non-ferry served island managed by WDNR. Other than the 

Monument planning process, there are no on-going efforts that would substantially change the supply of 

publically available hunting opportunities within the San Juan Islands. 

Under the No Action Alternative and alternatives B and D, the BLM would continue to contribute 

approximately 16 percent of the public land on which hunting with the discharge of firearms is allowed in 

the San Juan Islands. This includes 52 percent of the public land available for hunting on Lopez Island; 

the non-Monument land open to this use on Lopez Island is closed to hunting for approximately half of 

hunting season. 

Under Alternative A and Sub-Alternative C, the contribution of the Monument to opportunities for the 

public to hunt with firearms in the San Juan Islands would be substantially reduced. Under Alternative A, 

the BLM would continue not to prohibit firearm discharge, but would only permit access for authorized 

scientific, educational, cultural, or spiritual purposes. Under Sub-Alternative C, the BLM would prohibit 

firearm discharge within the Monument. This would reduce the public land open to hunting with firearms 

in the San Juan Islands by 16 percent and on Lopez Island by 52 percent. This would increase demand 

for hunting with firearms at Lopez Hill, which would be the only remaining public land on Lopez Island 

open to this use. It may also increase demand for hunting with firearms at Cypress Island, though this 

area is much more difficult to access than Monument lands open to this use on Lopez Island and San Juan 

Island. 

This prohibition would also affect the opportunity for target shooting, though the BLM is not aware of 

any instances of this activity in the Monument. Outside of Monument lands, there are no public lands in 

the San Juan Islands on which target shooting is allowed. All current target shooting in the San Juan 

Islands occurs on private land. 

The firearm prohibition included in Alternative C and Sub-Alternative C, would not affect non-firearmbased hunting within the Monument (e.g., bow hunting) or hunting by Coast Salish tribal members. 

Solitude and Quiet 

The alternatives vary in the Monument acres the BLM would manage explicitly to provide opportunities 

for solitude and quiet (i.e., opportunities for visitors to have no or minimal interaction with other visitors 

or disturbance from non-natural noise). The BLM has received comments from members of the public 

expressing appreciation for experiences of solitude and quiet in the Monument and asking that these 

experiences be maintained. 

Under all alternatives, opportunities for solitude and quiet would continue to be available in the 

Monument. The availability of such opportunities would continue to be dependent on several factors, 

including the presence of overhead small planes and jets and nearby motorized boats, vehicles, and 

people. The impact of these factors varies substantially depending on the accessibility of the area and the 

time of year or day. The BLM has no jurisdiction over sources of disturbance outside of the lands it

administers (e.g., boats in the water around the Monument or overhead planes and jets).

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

177 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Experiences of quiet and solitude would continue to be most easy to find in Monument locations only 

accessible via personal watercraft. Monument lands on ferry served islands such as Lopez and San Juan 

Island, which are easily accessed by paved and gravel roads, would continue to offer these opportunities 

only on certain days and times. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue not to manage any Monument lands explicitly 

for providing solitude and quiet. As described above, these opportunities would continue to be available 

throughout the Monument on less popular days and times for visitation. 

Alternative A 

Under Alternative A, the BLM would facilitate public use of the Monument for authorized research, 

educational, cultural, and spiritual purposes, but not for recreation. While the BLM would not manage 

any parts of the Monument explicitly for solitude and quiet, the substantial reduction in public visitation 

would incidentally increase opportunities for those experiences to members of the public visiting for one 

of the authorized purposes identified above. Alternative A would substantially decrease the potential 

disruption from competing visitor groups for those accessing the Monument for research, educational, 

cultural, and spiritual purposes. 

Alternative B 

Under Alternative B, the BLM would manage 167 acres of the Monument explicitly for solitude and quiet 

by requiring permits to access these areas. The BLM would provide permits to these areas in a number 

that ensures a low level of contact between visitors. Permit numbers would be established during 

implementation. Permits would be required to access Broken Point Island, Carter Point (Lummi Island), 

Fauntleroy Rock, Kellett Bluff (Henry Island), Little Patos Island, Lopez Pass (Lopez Island), Lummi 

Rocks, McConnell Rocks, Mud Island, Oak Island, Park Bay Island, President Channel (Orcas Island), 

Reads Bay Island, and Richardson Rocks. Seven of these areas were found by the BLM to have 

outstanding opportunities for solitude through the wilderness characteristics inventory process (see page 

231 for more information). 

The BLM would designate the majority of the Monument (726 acres) for dispersed camping by permit 

only. The BLM would allow one group per location per night with no more than five campers. This 

would provide opportunities to experience solitude and quiet while camping. 

The BLM identified the second most extensive trail system under Alternative B with the intent of 

dispersing visitors across the Monument to enhance opportunities for solitude and quiet. Unlike 

Alternative D, which has the most extensive trail system, under Alternative B the BLM would limit trail 

access to hiking and would not provide additional facilities or designated site camping. 

Alternative C 

Under Alternative C, the BLM would continue not to manage any Monument lands explicitly for 

providing solitude and quiet. As described above, these opportunities would continue to be available 

throughout the Monument on certain days and times. 

Under this alternative, the BLM would also require a permit to access the seven rocks that encompass the 

Category A Rocks RMA. Through its wilderness characteristics inventory (see page 231 for more 

information), the BLM found that one of these rocks (East Sound Blind Island South) has outstanding 

opportunities for solitude. These rocks are larger and have more recreation potential than those included 

in Category B Rocks, which are closed to recreational use under this alternative. 

Alternative D 

Under the Alternative D, the BLM would continue not to manage any Monument lands explicitly for 

providing solitude and quiet. As described above, these opportunities would continue to be available 

throughout the Monument on certain days and times. 

Alternative D would have the most extensive trail network of any alternative, providing opportunities for 

users to disperse across the Monument. This may create additional opportunities for solitude and quiet, 

though increased designated site camping, access to some trails for equestrian and bicycle use, and the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

178 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 potential for the development of new facilities under this alternative may attract additional visitors and 

lessen these opportunities during high visitation periods. 

Commercial, Competitive, and Organized Group Activities 

The action alternatives vary in whether the BLM would issue competitive special recreation permits for 

Monument lands. 

Under the No Action Alternative, the BLM would continue to require organized groups of 10 or more to 

obtain special recreation permits within the areas included in the ACECs at the south end of Lopez Island 

(Chadwick Hill, Iceberg Point, Point Colville, and Watmough Bay). Permits would also continue to be 

required for organized (without a defined group size threshold outside of ACECs), commercial, and 

competitive group activities at all locations in the Monument. 

Under all action alternatives, as required by regulation, the BLM would continue to require organized and 

commercial groups to obtain special recreation permits. The BLM would consider applications and 

determine appropriate group size limits as applicable during plan implementation. 

Under alternatives A, B, and C, the BLM would not issue competitive special recreation permits because 

of the small size of the areas that compose the Monument and the potential for visitor conflict. Under 

Alternative D, the BLM would consider issuing such permits. 

Other Recreational and Human Use Activities 

The alternatives include decisions about activities that occur only occasionally within the Monument and 

that the BLM has not received comments from members of the public who would like to participate in 

these activities. The BLM anticipates that decisions on these activities would have a limited impact on 

the pertinent user group. Under the No Action Alternative, opportunities for these activities would 

continue, though the BLM assumes that participation would remain low. 

Under all action alternatives, the BLM would prohibit the use of fireworks and the take-off and landing of 

manned aircraft (except for administrative or emergency purposes) within the Monument due to concerns 

about visitor safety and to protect sensitive cultural and ecological resources. The BLM would also 

prohibit the recreational use of metal detectors and establishment of physical geocaches due to concerns 

about disturbance of sensitive cultural resources. 

The BLM would prohibit launching and landing of drones on Monument lands for recreational purposes 

under alternatives A and B. Under Alternative C, the BLM would only allow this use by permit. Under 

Alternative D, the BLM would continue to allow this use without a permit. Given the current limited 

participation in this activity, and the lack of public comments requesting access for this use, the BLM 

anticipates that the alternatives would have a minimal impact on recreational drone enthusiasts. 

The BLM would prohibit rock climbing at Watmough Bay under alternatives A and B. Under Alternative 

C, the BLM would only allow rock climbing at Watmough Bay without the use of permanent anchors. 

Under Alternative D, the BLM would continue to allow rock climbing at Watmough Bay without 

restriction. Given the current limited participation in this activity within the Monument, and the lack of 

public comments requesting access for this use, the BLM anticipates that the alternatives would have a 

minimal impact on rock climbers. 

Under the No Action Alternative, the 1990 ACEC decisions would continue to apply to Chadwick Hill, 

Iceberg Point, Point Colville, and Watmough Bay and would continue to require members of the public to 

obtain permits to collect vegetation. Under alternatives A, B, and D, the BLM would extend this 

management approach to the entire Monument. The BLM would prohibit all public collection of natural 

materials under Alternative C and would prohibit commercial collection of natural materials under 

alternatives A, B, and C. Under all, action alternatives, the BLM would restrict permit distribution as 

necessary to protect the Monument’s ecological values. Given the current limited participation in this 

activity within the Monument, and the lack of public comments requesting access for this use, the BLM 

anticipates that the alternatives would have a minimal impact on public collection of natural materials. 

Under all alternatives, the Monument would remain open to collection of natural materials by Coast 

Salish tribal members for spiritual or traditional uses. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

179 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Potential User Conflict 

The alternatives vary in their effect on potential conflict between visitor uses and the disruption of visitor 

uses by management activities. Specifically, they vary in the extent to which potentially conflicting 

activities would be allowed within the same location or trail and in the estimated extent of disruption to 

visitor use from vegetation management. 

Throughout the county, many public lands are managed for potentially conflicting multiple visitor uses 

(e.g., trails open to hikers, equestrians, and bicycles, public lands open to both hunting and hiking, etc.). 

While management for multiple visitor uses is common, it does affect the experience of those 

participating in the various recreational activity (e.g., the experience of using a multiple use trail system is 

different than using a trail exclusively designated for hiking or mountain biking etc.) (Carothers et al 

2001). Potential conflicts can be mitigated through measures such as directional trail signage and posted 

reminders about multiple recreational uses occurring during different times of year (e.g., reminding 

visitors that hunters may be present during hunting season). 

The alternatives would also vary in the potential for visitor uses to be temporarily disrupted due to 

vegetation treatments. Visitor use of specific areas would be disrupted during mobilization, operation, 

and recovery periods in areas under going vegetation treatments. Where vegetation treatment did not 

require disruption in access, it could still change the visitor experience near the treatment site. As 

possible, the BLM would undertake vegetation treatments during lower use periods of the year. Under all 

alternatives, the BLM could institute temporary closures following the appropriate decision making and 

NEPA conformance processes to protect ecological values, cultural values, or human health and safety. 

No Action Alternative 

Under the No Action Alternative, all 1,021 acres of Monument land would remain open to potentially 

conflicting recreational activities. This includes there continuing to be no plan-level prohibition on the 

discharge of firearms and the user created trail network being open to all non-motorized uses. If current 

trends continue non-hiking uses of trails would occur on approximately one mile of user created trail and 

discharge of firearms would occur regularly only during hunting season on Monument lands on the south 

end of Lopez Island. The BLM has heard from and documented visitors and volunteers who feel unsafe 

on Monument lands on which firearms are being discharged for the purposes of hunting. 

Under continued custodial management of the Monument, vegetation treatments would likely be minimal. 

Under the No Action Alternative, the BLM assumes that it would continue to undertake approximately 20 

acres of vegetation treatments per year and that these treatments would continue to minimally disrupt 

visitor uses. 

Alternative A 

Under Alternative A, the prohibition on recreational use would greatly reduce the potential for conflict 

between visitor uses. There would be minimal potential disruption from other visitor groups for those 

accessing the Monument for research, educational, cultural, and spiritual purposes. The BLM would 

continue not to prohibit firearm discharge, so all 1,021 acres of Monument land would remain open to this 

use. 

The relatively passive habitat management the BLM would undertake in Alternative A would create 

minimal disruptions to authorized human uses. Under this alternative, the BLM estimates that it would 

undertake approximately 1,040 acres of mechanical and biological vegetation treatment over the life of 

the plan (annual average of approximately 50 acres) (see Table 17 on page 111). This is more acreage of 

treatment than would occur under the No Action Alternative, but would continue to minimally disrupt 

visitor uses. 

Alternative B 

Under Alternative B, there would be some potential for conflict between visitor uses. The trail network 

would be open only to hiking, minimizing the potential for conflict between different modes of 

transportation on trails. The BLM would continue not to prohibit firearm discharge, so all 1,021 acres of 

Monument land would remain open to this use. The BLM has heard from visitors who feel unsafe on 

Monument lands on which firearms are being discharged for the purposes of hunting. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

180 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 While this alternative would result in a relatively low potential for visitor conflict, the relatively large 

amount of vegetation treatment would periodically disrupt visitor use. Under this alternative, the BLM 

estimates that it would undertake approximately 11,700 acres53 of mechanical, chemical, biological, and 

prescribed fire vegetation treatment over the life of the plan (annual average of approximately 585 acres) 

(see Table 18 on page 112). This level of treatment would periodically disrupt visitor uses, though, as 

possible, the BLM would undertake vegetation treatments during lower use periods of the year. 

Alternative C 

Under Alternative C, 2.6 miles of Monument trails would be open to both hiking and equestrian use and 

firearm discharge would be prohibited on 612 acres of Monument land except for half of hunting 

season 54 . There would be a higher potential for visitor conflict due to multiple uses on trails under 

Alternative C than alternatives A and B, but less than under Alternative D or the No Action Alternative. 

The partial discharge of firearms prohibition would reduce the potential for visitor conflict except for one 

half of the hunting season, during which hunting with the discharge of firearms could coincide with other 

visitor uses of the Monument. The partial prohibition could cause more hunters to visit the Monument 

during the shortened season for firearm-based hunting, potentially increasing visitor conflict during this 

part of the season. The BLM has heard from visitors who feel unsafe on Monument lands on which 

firearms are being discharged for the purposes of hunting. 

The firearm prohibition included in this alternative would not affect non-firearm-based hunting within the 

Monument (e.g., bow hunting) or hunting by Coast Salish tribal member. 

This alternative would also have the second greatest for potential disruption from vegetation treatments. 

Under this alternative, the BLM estimates that it would undertake approximately 17,733 acres55 of 

mechanical, chemical, biological, and prescribed fire vegetation treatment over the life of the plan (annual 

average of approximately 885 acres) (see Table 19 on page 114). This level of treatment would 

periodically disrupt visitor uses, though, as possible, the BLM would undertake vegetation treatments 

during lower use periods of the year. 

Sub-Alternative C 

The effects on the potential for conflict and disruption under sub-alternative C would be similar to under 

Alternative C. Under Sub-Alternative C, the BLM would prohibit firearm discharge on all 1,021 acres of 

the Monument throughout the year. This would reduce the potential for visitor conflict during hunting 

season. The BLM has heard from visitors who feel unsafe on Monument lands on which firearms are 

being discharged for the purposes of hunting. 

The firearm prohibition included in this alternative would not affect non-firearm-based hunting within the 

Monument (e.g., bow hunting) or hunting by Coast Salish tribal member. 

The prohibition on chemical treatments would require more repetition of mechanical treatment to achieve 

the alternative’s restoration objectives. Under this alternative, the BLM estimates that it would undertake 

approximately 35,600 acres 55of mechanical, biological, and prescribed fire vegetation treatment over the 

life of the plan (annual average of approximately 1,780 acres) (Table 20 on page 115). This level of 

treatment would periodically disrupt visitor uses, though, as possible, the BLM would undertake 

vegetation treatments during lower use periods of the year. 

Alternative D 

Under Alternative D, approximately one third of Monument and immediately adjacent Coast Guard trails 

would be open to multiple modes of travel. This would include 7.7 miles of Monument trails open to 

 

53 This includes the application of different types of treatments to overlapping acres—e.g., a particular treatment 

could include 200 acres of mechanical treatment and 200 acres of chemical treatment. 54 The BLM would work with WDFW to coordinate when the closure would not apply. A similar approach is 

currently implemented at Lopez Hill, which is managed by the San Juan County Land Bank. Lopez Hill is the only 

non-Monument public land on Lopez Island that allows hunting. 55 This includes the application of different types of treatments to overlapping acres—e.g., a particular treatment 

could include 200 acres of mechanical treatment and 200 acres of chemical treatment. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

181 
 

 

 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 hiking, equestrian use, and bicycling use; 0.7 miles open to hiking and equestrian travel only; and 0.7 

2 miles open to hiking and bicycling travel only. The remaining 15.4 miles would be open only to hiking. 

3 There would be a higher potential for visitor conflict due to multiple uses on trails under Alternative D 

4 than under alternatives A, B, and C, but less than under the No Action Alternative. The BLM would 

5 continue not to prohibit firearm discharge, so all 1,021 acres of Monument land would remain open to this 

6 use. The BLM has heard from visitors who feel unsafe on Monument lands on which firearms are being 

7 discharged for the purposes of hunting. 

8 This alternative would have slightly more potential for visitor use disruption from vegetation treatments 

9 than the No Action Alternative and Alternative A, but substantially less than under alternatives B, C, and 

10 Sub-C. Under this alternative, the BLM estimates that it would undertake approximately 1,300 acres55 of 

11 mechanical, chemical, biological, and prescribed fire vegetation treatment over the life of the plan (annual 

12 average of approximately 65 acres) (see Table 21 on page 116). This level of treatment would 

13 occasionally disrupt visitor uses, though, as possible, the BLM would undertake vegetation treatments 

14 during lower use periods of the year. 

15 Recreation and Visitor Services Issue 1 Conclusions 

16 Table 52 summarizes the effects of the alternatives on visitor opportunities and access. It describes each 

17 alternative as causing an increase, decrease, or no change (+,-,=) in each visitor opportunity compared to 

18 current conditions. 

19 The No Action Alternative and Alternative D generally provide the most opportunities for recreational 

20 activities within the Monument. By supporting a range of recreational activities they also, however, have 

21 the greatest potential for conflict between visitors. Alternative A provides the least public access and 

22 visitor use opportunities and has the least potential for visitor conflict. Alternative B focuses on hiking 

23 access and dispersed camping with management controls to maximize opportunities for solitude and quiet 

24 while participating in recreational activities. Alternative C provides some hiking and equestrian access 

25 and is the most restrictive alternative in relation to camping. 

26 The cumulative effects of the alternatives on the supply of various recreational opportunities in the San 

27 Juan Islands are described under the opportunities sub-sections above. 

28 Table 52: Summary of the effects of the alternatives on access and visitor opportunities 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

Access = - - - + 

Recreational boat landing = - - - = 

Hiking = - + - + 

Equestrian = - - + + 

Bicycling = - - - + 

Dispersed camping without 

= - - - - permit 

Dispersed camping w/ permit = - + = = 

Designated site camping = - = = + 

Hunting with firearms = - = - = 

Opportunities for quiet and 

solitude = + + = -

Minimizing potential for user 

conflict = + + = = 

Minimizing potential for 

disruption due to management = + - - = 

activities 

182 
 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Recreation and Visitor Services Analytical Issue 2: How would the BLM’s 

2 designation of recreation opportunity spectrum classes across the alternatives 

3 affect recreation settings in the Monument? 

4 See Appendix B for analytical methods used in this analysis. 

5 Affected Environment 

6 The BLM categorizes the type of setting that exists or is desired for a particular area using its recreation 

7 opportunity spectrum. The recreation opportunity spectrum is divided into six classes ranging from 

8 primitive to urban. Lands are categorized into these classes based on their recreation setting 

9 characteristics. See the Recreation and Visitor Services Issue 2 section in Appendix E for more 

10 background information on recreation setting characteristics. 

11 Using the process described in Appendix E, the BLM determined that nearly all lands in the Monument 

12 currently fall into either the primitive or back county recreation opportunity spectrum classes (Table 53). 

13 The BLM made this determination by identifying each area’s: a) physical setting in terms of its 

14 remoteness (i.e., how far it is from a road or bicycle trail) and level of development; b) social setting in 

15 terms of visitation levels; and, c) operational setting in terms of level of visitor controls. In general, 

16 Monument lands currently have both minimal visitor facilities and minimal visitor controls (restrictions). 

17 See the No Action Alternative on page 8 for an overview of current visitor controls. 

18 The majority of Monument lands on Lopez Island and San Juan Island, as well as Turn Point on Stuart 

19 Island, are within half a mile of a road. No other Monument lands are in close proximity to roads. Some 

20 Monument lands receive regular visitation, while those that are less accessible or less well known receive 

21 relatively little (see Table 37 on page 156). 

22 Currently 360 acres of Monument lands have visitor facilities and interpretive displays: Blind Island (2 

23 acres), Cattle Point (23 acres), Patos Island (211 acres), Posey Island (1 acre), Turn Point (86 acres), and 

24 Watmough Bay (37 acres). The remainder of the Monument does not have visitor facilities or interpretive 

25 signage. Visitors seeking an entirely undeveloped visitor experience can find it within the remaining 661 

26 acres of Monument land. 

27 The 19 percent of Monument land the BLM identified as primitive tends to be farther from roads, have 

28 less developed facilities, and lower visitation. The 81 percent of Monument land the BLM identified as 

29 back country tend to be closer to roads and/or have more developed visitor facilities (e.g., toilets and/or 

30 kiosks), and higher levels of visitation. The BLM identified both Posey and Blind islands as currently 

31 falling into the middle county class due to the combination of small size (less than 2 acres each) and 

32 relatively high visitation levels (see Table 37 on page 156), existing designated site camping, composting 

33 toilets, picnic tables, and informational signage. 

34 Recreational experiences are also shaped by the plant communities in which they take place. While all 

35 recreation opportunity spectrum classes can occur in any vegetation community (e.g., both forested and 

36 grassland communities can have primitive or back country classes depending on their proximity to roads, 

37 level of development, etc.), changes to the vegetation community do affect the user experiences. 

38 Currently, over 800 acres of the Monument are in the forest and woodlands vegetation class; just 126 

39 acres are non-wetland grassland and shrubland. 

40 Table 53: Monument acres currently within each inventoried recreation opportunity spectrum class 

Recreation Opportunity Monument Land Currently within Class 

Spectrum Class Acres Percent 

Primitive 193 19% 

Back Country 824 81% 

Middle Country 4 <1% 

Front Country 0 0 

Rural 0 0 

Urban 0 0 

183 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Effects of the Alternatives 

2 The alternatives would vary in their impact on the recreational setting characteristics of locations within 

3 the Monument. Specifically, they would vary in the acres of each setting characteristic classification the 

4 BLM would designate under each alternative and in how potential visitor facility development would 

5 affect the setting characteristics under each alternative. The recreation opportunity spectrum class the 

6 BLM would designate for RMAs under each alternative can be found in Appendix O: RMA Frameworks. 

7 Due to natural succession and the alternatives’ vegetation management objectives, the plant communities 

8 experienced by visitors would change somewhat under each alternative. While this would not change an 

9 area’s recreation opportunity spectrum class, it would change the experience of Monument visitors, e.g., 

10 even with the same level of remoteness, development, and visitor controls, the experience of hiking 

11 through a forest is different from the experience of hiking through a grassland. Under the No Action 

12 Alternative and Alternative A, visitors to the Monument would experience more forest and generally 

13 more densely vegetated communities over the next 20 years than they would under alternatives B and C. 

14 Under Alternative D, the BLM would manage vegetation to maintain approximately the current 

15 conditions. See Habitat and Plants Issues 1 and 2 for more details about how the alternatives would affect 

16 plant communities within the Monument. 

17 Table 54: Monument acres within each recreation opportunity spectrum class by alternative 

Recreation 

Opportunity 

Spectrum Class 

No Action 

Alternative 

(acres) 

Alternative A 

(acres) 

Alternative B 

(acres) 

Alternative C 

(acres) 

Alternative D 

(acres)* 

Primitive 193 197 59 10 6 

Back Country 824 824 958 1007 381 

Middle Country 4 0 4 4 633 

Front Country 0 0 0 0 0 

Rural 0 0 0 0 0 

Urban 0 0 0 0 0 

18 * Totals only 1,020 acres due to a rounding issue (i.e., the acres falling into two of the classes round down 

19 instead of up while under other alternatives the acres round up). 

20 Table 55: Percent of Monument acres shifting to more or less primitive classes by alternative 

No Action Alternative Alternative Alternative Alternative 

Alternative A B C D 

More primitive class 

(acres) (acres) (acres) (acres) (acres) 

0% <1% 0% 0% 0% 

Less primitive class 

No change 

0% 0% 13% 18% 80% 

100% 99% 87% 82% 20% 

21 

22 All alternatives would have at most a minor effect on the remoteness characteristic of each area’s physical

setting. This is because access to Monument lands is generally provided by non-BLM-administered roads 

or through personal watercraft. The proximity of Monument lands to roads would remain the same under 

all alternatives. Under Alternative D, land in the northwest corner of Chadwick Hill that is not within 1⁄2 

mile of a road would be within 1⁄2 mile of new trails designated for bicycle use. All other areas in which 

the BLM would designate new trails for bicycle use under Alternative D are already within 1⁄2 mile of a 

road or driveway; Alternative D would thus not change the remoteness of these areas. 

The alternatives vary in their effect on the naturalness/development characteristic of each area’s physical

setting. New recreational facilities and interpretive and educational signs would be prohibited under 

alternatives A and B, but would be allowed in most areas under alternatives C and D. Each area’s 

recreation opportunity spectrum class would influence the level of recreational development that would 

occur during plan implementation. For example, new educational signs and recreational facilities would 

be allowed at Cattle Point under both alternatives C and D, but the level of development would be lower 

under Alternative C in order to meet the designated back county setting class. The BLM has heard both 

from members of the public who would like to see the Monument managed in an as undeveloped a 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

184 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 manner as possible and from members of the public who would like to see additional signs and visitor 

facilities (BLM 2016a,b). 

The characteristics of an area’s social setting (i.e., visitor contacts, group size, and evidence of use) would 

likely parallel the changes in the physical recreation setting characteristics (e.g., areas with more 

developed facilities are likely to attract more visitors). One exception may be areas that emphasize 

hiking. Except for under Alternative A, RMAs such as Watmough Bay may see an increase in visitor 

contacts, group size, and evidence of use, regardless of the designated recreation opportunity spectrum 

class, due to the increasing recreation trends in the area (see page 155). 

The alternatives would also vary in their effect on management controls and visitor information. The 

alternatives vary in the extent to which the BLM would control visitor use by allowing or prohibiting 

various recreational activities (see Recreation and Visitor Services Issue 1). The alternatives would also 

vary in the extent to which signage would be present on the landscape, though in all cases signs needed to 

protect visitor safety and sensitive cultural and ecological values would be allowed. 

The alternatives would not affect front country, rural, and urban settings because these classes do not 

currently exist within the Monument and are not included under any of the alternatives. 

No Action Alternative 

Under the No Action Alternative, there would continue to be no management decisions related to 

recreation setting characteristics. It is likely that the majority of the Monument would retain either a back 

country or primitive setting, with limited visitor facilities (see Table 53). Blind and Posey islands—

which are respectively 2 and 1 acres, receive substantial visitation and have facilities including vault 

toilets, fire rings, and picnic tables—would likely retain their current middle county setting. 

The level of current visitor facilities within the Monument would likely remain unchanged, with 360 acres 

having some level of facilities and the remaining 661 having no visitor facilities or interpretive displays. 

Alternative A 

Under Alternative A, members of the public visiting the Monument—who would be restricted to those 

with authorization to access the Monument for scientific, educational, cultural, or spiritual purposes—

would experience the least developed landscape of any of the alternatives, as well as the lowest level of 

visitor contacts Under this alternative, the BLM would not develop additional visitor facilities or signage, 

with the exception of signs needed to protect public health and safety and ecological and cultural values. 

While these changes to characteristics would lead to more primitive physical and social settings, the 

substantial increase in visitor controls would lead to less primitive operational settings. 

Under this alternative, the BLM would designate 19 percent of the Monument (197 acres) as primitive 

and 81 percent (824 acres) as back country. The 4 acres of Monument lands with a middle country setting 

would shift to back country due to a substantial decrease in visitation and the likely removal of some 

existing visitor facilities (e.g., fire rings). Under this alternative, 99 percent of Monument lands would 

remain in their current recreation opportunity spectrum class (see Table 55). 

Alternative B 

Under Alternative B, the BLM would not develop additional visitor facilities or signage, with the 

exception of signs at trailheads and those needed to protect public health and safety and ecological and 

cultural values. Visitor controls would increase compared to the No Action Alternative, including 

limiting all trail use to hiking (i.e., closing all trails to equestrian and bicycle use) and allowing dispersed 

camping by permit only. Visitor contacts in most of the Monument would remain largely determined by 

the accessibility of the site and would continue to be affected by increasing trends in visitation. The BLM 

would manage 16 percent of the Monument to provide opportunities for quiet and solitude by limiting 

visitor numbers through a permit system. 

Under Alternative B, the BLM would designate 6 percent of the Monument (59 acres) as primitive, 94 

percent (958 acres) as back country, and 3 percent (4 acres) as middle country (see Table 54). Under this 

alternative, 87 percent of Monument lands would remain in their current recreation opportunity spectrum 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

185 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 classes; 13 percent would move from primitive to back country (see Table 55). This would result in a 

small impact on visitors seeking a primitive experience with minimal restrictions on their activities. 

Alternative C 

Under Alternative C, the BLM would allow the development of new visitor facilities and signage beyond 

trailheads on 99 percent of Monument lands. Such developments would not be allowed on Monument 

rocks (9 acres), which include all areas managed for their wilderness characteristics under this alternative. 

In areas designated as primitive and back country under this alternative, the BLM would allow a lower 

level of facility and signage development compared to areas with middle country designations. The 

design and location of facilities would be determined during plan implementation. 

Visitor controls would increase compared to the No Action Alternative, including limiting 95 percent of 

trails to hiking (i.e., closing them to equestrian and bicycle uses), prohibiting firearm discharge on 59 

percent of the Monument for most of the year, and allowing camping only in designated sites. Visitor 

contacts in the Monument would remain largely determined by the accessibility of the site and would 

continue to be affected by increasing trends in visitation. 

Under Alternative C, the BLM would designate less than 1 percent of the Monument (10 acres) as 

primitive, 99 percent (1,007 acres) as back country, and less than 1 percent (4 acres) as middle country 

(see Table 54). Under this alternative, 82 percent of Monument lands would remain in their current 

recreation opportunity spectrum classes; 18 percent would move from primitive to back country (see 

Table 55). As with Alternative B, there would be a small impact on visitors seeking a primitive 

experience with no developments and few restrictions on their activities. 

Alternative D 

Under Alternative D, the BLM would allow the development of new visitor facilities and signage beyond 

trailheads on 77 percent of the Monument. Such developments would not be allowed in areas managed 

for their wilderness characteristics or on Category B Rocks. In areas designated as middle country, the 

BLM would allow a higher level of facility and signage development compared to back country and 

primitive designations. Facility design and location would be determined during plan implementation. 

Visitor controls would increase compared to the No Action Alternative, but would be lower than under 

the other action alternatives. Visitor controls would include limiting 77 percent of trails to hiking and 

increasing areas where camping would only be allowed in designated sites. Visitor contacts in the 

Monument would remain largely determined by the accessibility of the site and would continue to be 

affected by increasing trends in visitation. 

Under Alternative D, the BLM would designate less than 1 percent of the Monument (6 acres) as 

primitive, 37 percent (381 acres) as back country, and 62 percent (633 acres) as middle country (see Table 

54). Under this alternative, 20 percent of Monument lands would remain in their current recreational 

opportunity spectrum class; 80 percent would move from either primitive to back country or from back 

country to middle country (see Table 55). There would be a moderate beneficial impact on visitors 

seeking a middle country setting and experience. There would be some displacement of visitors seeking a 

back country setting and experience. As with alternatives B and C, there would be a small impact on 

visitors seeking a primitive experience with no developments and few restrictions on their activities. 

Conclusion 

Under the No Action Alternative and alternatives A, B, and C, the great majority of Monument lands 

(between 100 percent and 82 percent) would remain in their current recreation opportunity spectrum 

classes (see Table 55). Under Alternative A, less than 1 percent of acres would shift to a more primitive 

class. Under alternatives B and C, 13 and 18 percent of acres respectively would shift from primitive to 

back country classes due to more restrictive operational settings in combination with limited changes to 

social and physical settings. 

The largest shift in recreation opportunity spectrum classes would occur under Alternative D. Under this 

alternative, 80 percent of the Monument would shift to a less primitive class compared to the current class 

(either from primitive to back country or from back country to middle country) (see Table 55). Under 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

186 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Alternative D, the BLM would designate the majority of the Monument as middle country. This 

alternative would increase opportunities and experiences for visitors who prefer a more developed setting. 

Under alternatives B, C, and D, there would be a decrease in Monument acres in the primitive class. This 

would decrease opportunities for individuals seeking limited visitor controls and entirely undeveloped 

recreational settings. Under all alternatives there would continue to be a mix of settings that provide a 

variety of visitor experiences. 

Cumulative effects on the Recreation Setting Characteristics 

Throughout the San Juan Islands, there are opportunities for visitors to experience a variety of recreation 

settings. Publically accessible lands include a wide-range of physical settings, including easily accessible 

areas with fully developed visitor facilities and remote and undeveloped areas accessible only by personal 

watercraft. Social settings also vary substantially by location and by season. More easily accessible 

public lands tend to attract more visitors and, at least during higher visitation seasons, are likely to have 

larger groups and more contacts between visitors. Even during higher visitation seasons, more remote 

areas are likely to have few visitor contacts and smaller group sizes. Operational settings in the San Juan 

Islands are generally characterized by visitor controls that are more restrictive than the visitor controls 

currently in place within the Monument (see Recreation and Visitor Services Issue 3 section in Appendix 

E). For example, outside of the Monument, dispersed camping is not allowed on any public lands within 

the San Juan Islands and hunting is allowed in only a small number of publically accessible areas. 

Under the No Action Alternative, the BLM would continue to provide some of the few publically 

accessible areas in the San Juan Islands with limited visitor controls. Under all action alternatives, 

opportunities for members of the public seeking primitive and unconstrained recreational experiences 

would be reduced. Opportunities for back country and middle country settings are readily available in the 

San Juan Islands; under all alternatives, the BLM would have a limited effect on the supply of these 

recreation settings. 

Recreation and Visitor Services Analytical Issue 3: How would the 

alternatives indirectly affect the management of human use activities on nearby 

non-BLM-administered lands in the San Juan Islands? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

The management of public lands and private lands with secured public access in the San Juan Islands 

varies substantially between management entities. Most, though not all, of the public lands in the San 

Juan Islands are managed at least in part for public access and enjoyment, though the types of uses 

allowed vary between areas and managers. Activities permitted or restricted by a land management 

agency can have indirect effects on the other land management agencies in the area. For example, 

decreasing camping opportunities in one area might increase demand for camping opportunities provided 

in a different area. Similarly, allowing a particular activity in one area may create challenges if an 

adjacent land manager prohibits the same activity. 

Non-BLM public land managers in the San Juan Islands generally have more restrictions on recreational 

use than those currently in place within the Monument. The Recreation and Visitor Services Issue 3 

section in Appendix E provides an overview of how public lands in close proximity to the Monument are 

managed. Specifically, these overviews describe each visitor management approach and the types of 

activities each entity allows. 

Effects of the Alternatives 

The alternatives would vary in how consistent or inconsistent the management of Monument lands is with 

the management of other public lands in the vicinity. The BLM has heard concerns from other land 

management agencies in the San Juan Islands about the potential for inconsistent management to cause 

visitor confusion and management challenges. 

5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

187 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under all action alternatives, the BLM would—for the first time—have management objectives and 

allowable and prohibited use decisions for all Monument lands. This would make it easier for the BLM 

to communicate clearly to the public about what uses are and are not allowed within the Monument as 

opposed to nearby non-BLM-administered public lands. 

No Action Alternative 

Under the No Action Alternative, the entire Monument would continue to be open to the public for 

recreational purposes and there would continue to be limited restrictions on recreational activities (see 

Recreation and Visitor Services Issue 1). The BLM would continue not to prohibit firearm discharge at 

the plan level on all Monument lands. The Monument would also continue to be open to cross-country 

hiking, all forms of non-motorized trail access (e.g., equestrian and bicycle use), the launching and 

landing of drones, and other non-camping recreational activities not otherwise prohibited in law or 

regulation. 

The BLM would continue to prohibit camping on land included in the ACECs at the south end of Lopez 

Island (Chadwick Hill, Iceberg Point, Point Colville, and Watmough Bay). Designated site camping 

managed in partnership with Washington State Parks would continue on Monument lands at Patos, Blind, 

and Posey islands. The remainder of the Monument would continue to be open to dispersed camping. 

Non-BLM public land managers in the San Juan Islands generally have more restrictions on recreational 

use than those currently in place within the Monument (see Appendix E). The BLM has heard 

anecdotally that members of the public sometimes confuse un-signed Monument lands with other public 

lands. A small number of visitors would access and recreate on other nearby public lands that they 

mistook of Monument lands. This would be particularly challenging in instances where visitors mistake 

U.S. Fish and Wildlife Service rocks and islands that are closed to public access for Monument rocks and 

islands, which would continue to be open to recreation with few restrictions. 

The continued availability of Monument lands for dispersed camping would perpetuate the potential for 

visitors to mistakenly camp on nearby public lands open only to day-use. Similarly, the continued 

availability of Monument lands for the discharge of firearms, equestrian and bicycle trail access, the 

launching and landing of drones, and other non-camping recreational activities not otherwise prohibited in 

law or regulation, could create management challenges for nearby public lands if these uses become 

popular. Under this alternative, the BLM would continue to lack clear management objectives and 

allowable and prohibited use decisions for the majority of Monument lands. This would continue to make 

it challenging to communicate clearly with the public about what uses are and are not allowed within the 

Monument as opposed to nearby non-BLM-administered public lands. 

Alternative A 

Under Alternative A, the BLM would facilitate public use of the Monument for authorized research, 

educational, cultural, and spiritual activities, but not for recreation. This would be a more restrictive 

management approach than is in place on the great majority of public lands in the San Juan Islands. 

Under this alternative, management of Monument rocks and islands would be similar to management of 

nearby U.S. Fish and Wildlife Service rocks and islands that are closed to public access. This would 

decrease the potential for visitors to mistakenly access closed areas of the National Wildlife Refuge. 

The prohibition on recreation on Monument lands could cause confusion among visitors to nearby public 

lands that do provide recreational opportunities. This issue is likely to be most pronounced at Cattle Point 

(San Juan Island), where non-BLM-administered public lands are adjacent or in very close proximity to 

the Monument and visitors currently move freely between jurisdictions. The prohibition on recreation 

would have a substantial effect on nearby land managers at Cattle Point, including the National Park 

Service, San Juan County Land Bank, and WDNR. This alternative would disrupt current and past 

collaborative efforts to provide beneficial recreational experiences, facilities, and information. The 

disruption of access connectivity at Cattle Point would cause confusion and frustration for members of the 

public. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

188 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 This alternative would also cause challenges for agencies that currently co-manage activities with the 

BLM. Washington State Parks, which currently manages camping within the Monument under a 

memorandum of understanding, would experience an economic revenue and recreational infrastructure 

investment loss due to the prohibition on camping at Blind, Posey, and Patos islands. 

Under this alternative, the prohibition on recreational use could cause confusion for visitors to nearby and 

adjacent publicly accessible lands, particularly at Cattle Point. As opposed to under the No Action 

Alternative, the RMP would provide clear management objectives and allowable and prohibited use 

decisions. This would make it easier for the BLM to mitigate this confusion by communicating clearly to 

the public about what uses are and are not allowed within the Monument. 

Alternative B 

Under Alternative B, all but 10 acres of the Monument would remain open to recreational use and would 

be designated as RMAs. The BLM would prohibit recreational use of 10 acres categorized as Category A 

Rocks and Category B Rocks. 

Under this alternative, management of Monument rocks would be similar to the management of nearby 

U.S. Fish and Wildlife Service rocks that are closed to public access. This would decrease the potential 

for visitors to mistakenly access these areas. Recreational use would still be allowed on Monument 

islands, continuing the potential for visitors to mistakenly access similar U.S. Fish and Wildlife Service 

islands on which recreation is prohibited. 

Within the Monument, 726 acres would be managed for dispersed camping with a permit. This could 

create the potential for visitors to mistakenly access nearby public lands on which camping is not allowed, 

though the requirement of a permit associated with a specific Monument location should minimize this 

confusion. 

Under Alternative B, the BLM’s prohibition of, drone operation and bicycle trail access on Monument 

lands could lessen the potential for visitor confusion compared to the No Action Alternative. These 

activities are currently prohibited on most public lands adjacent or in close proximity to the Monument. 

Alternatives B and C would have the recreation management approach most consistent with nearby nonMonument public lands, although discrepancies with some nearby management approaches would 

continue. As opposed to under the No Action Alternative, the RMP would provide clear management 

objectives and allowable and prohibited use decisions. This would make it easier for the BLM to mitigate 

this confusion by communicating clearly to the public about what uses are and are not allowed within the 

Monument. 

Alternative C 

Under Alternative C, all but 7 acres of the Monument would be open to recreational use. The BLM 

would prohibit recreation on Category B Rocks. 

Under this alternative, management of Category B Rocks would be similar to management of nearby U.S. 

Fish and Wildlife Service rocks that are closed to public access. This would decrease the potential for 

visitors to access these areas mistakenly. Recreational use would still be allowed on islands and Category 

A Rocks, continuing the potential for visitors to mistakenly access similar U.S. Fish and Wildlife Service 

islands and rocks on which recreation is prohibited. 

Under this alternative, the BLM would allow camping only in existing designated sites. This would 

minimize the potential for visitors to mistakenly camp on nearby public lands that are day-use only. The 

requirement on Monument lands for members of the public to obtain a permit to operate a drone, the 

designation of specified trails for equestrian access, and the prohibition of bicycle trail access, could 

lessen the potential for visitor confusion compared to the No Action Alternative. The BLM would 

prohibit firearm discharge on the majority of the Monument (612 acres) for approximately half of modern 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

189 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 firearm and muzzleloader deer hunting seasons.56 Since the majority of public land managers in the San 

Juan Islands do not allow the discharge of firearms (whether for hunting or other purposes), there would 

continue to be potential for confusion among visitors to nearby and adjacent lands. 

Alternatives B and C would have the recreation management approach most consistent with nearby nonMonument public land, although discrepancies with some nearby management approaches would 

continue. As opposed to under the No Action Alternative, the RMP would provide clear management 

objectives and allowable and prohibited use decisions. This would make it easier for the BLM to mitigate 

this confusion by communicating clearly to the public about what uses it would or would not allow within 

the Monument. 

Alternative D 

Under Alternative D, the entire Monument would remain open to the public for recreational purposes. 

Permits for recreational use would only be required for organized groups and for commercial or 

competitive recreational activities (as in all alternatives). 

The BLM would continue to allow recreational use on Monument islands and rocks, perpetuating the 

potential for visitors to mistakenly access similar U.S. Fish and Wildlife Service islands and rocks on 

which recreation is prohibited. 

The BLM would also continue not to prohibit dispersed camping, discharge of firearms, the launching 

and landing of drones, and leashed pets throughout all or some of the Monument (see Recreation and 

Visitor Services Issue 1). This would perpetuate the potential for confused visitors to participate in these 

activities on nearby public lands that do not allow them. The BLM would also allow equestrian and 

bicycle access on a limited number of designated trails. While the BLM would appropriately sign trails 

open to these uses, this could create confusion among visitors accessing nearby public lands that do not 

allow these uses. 

Under this alternative, the BLM’s approach to recreation management would be less restrictive than most

other nearby public land managers. As with the No Action Alternative, this would perpetuate the 

potential for visitors to mistakenly access nearby public lands for uses to which they are closed. As 

opposed to under the No Action Alternative, however, the RMP would provide clear management 

objectives and allowable and prohibited use decisions. This would make it easier for the BLM 

communicate clearly to the public about what uses it would and would not allow within the Monument. 

Conclusion 

The alternatives vary in the extent to which the visitor uses the BLM would allow or prohibit would be 

consistent with the visitor uses nearby public land managers allow or prohibit. Each nearby and adjacent 

public land manager has its own approach to managing public access (see Appendix E); because of this, 

aspects of the BLM’s management will be inconsistent with some recreation management approaches

regardless of the alternative. 

Under the No Action Alternative and Alternative D, the Monument would continue to be open to a variety 

of uses that some or most nearby public land managers prohibit (e.g., dispersed camping). Under 

Alternative A, the BLM would institute a substantially more restrictive approach to visitor management 

than is currently in place on the great majority of public lands in the San Juan Islands. Alternatives B and 

C would have the most consistent recreation management approach to nearby and adjacent Monument 

lands, although discrepancies with some nearby management approaches would continue. 

Under all action alternatives, as opposed to under the No Action Alternative, the RMP would provide 

clear management objectives and allowable and prohibited use decisions. This would make it easier to 

communicate clearly to the public about what uses it would and would not allow within the Monument. 

 

56 The BLM would work with DFW to coordinate when the closure would not apply. A similar approach is 

currently implemented at Lopez Hill, which is managed by the San Juan County Land Bank. Lopez Hill is the only 

non-Monument public land on Lopez Island that allows hunting. Hunting is allowed on Lopez Hill for one half of 

the hunting season: https://lopezhill.org/hunting-on-lopez-hill/ 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

190 
 

 

 

 

 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Scientific Research 

Key Points 

 All action alternatives would require that researchers obtain written approval from the Monument

Manager before conducting research in the Monument as a means to reduce conflict, redundancy, and

potential impacts to the Monument’s ecological and cultural values.

This section contains one analytical issue: 

1. How would the alternatives affect the use of the Monument for scientific research? (page 191)

Scientific Research Analytical Issue 1: How would the alternatives affect the 

use of the Monument for research? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Proclamation 8947 describes the Monument as “a refuge of scientific and historic treasures and a 

classroom for generations of Americans” and repeatedly refers to the scientific importance of, and 

scientific interest in, the Monument’s ecological and cultural values. 

Numerous research activities have taken place on BLM-administered lands in the San Juan Islands both 

prior to and since the Monument’s designation in 2013. Research within the Monument has included 

projects undertaken by citizen scientists, non-profit organizations, universities and university-affiliated 

researchers, and Tribal, Federal, State, and local agencies. External parties, rather than the BLM, have 

generally proposed and conducted research. Research topics have included plants and wildlife, cultural 

resources and cultural landscapes, maritime history, mollusks, fire history, wildland-urban interface, 

insects and pollinators, natural ambient sound, plastic and marine debris, and intertidal and nearshore 

habitats. The research sought by and shared with the BLM has helped the agency and its partners to 

better understand the Monument and the San Juan Islands as a whole. 

The BLM currently only requires authorization for research on the Monument where law or BLM policy 

requires a permit or other form of authorization. The BLM currently has a limited ability to monitor the 

impacts of research on the Monument or to reduce potential conflicts between research different projects 

or between research and other uses of the Monument. The lack of a general authorization requirement 

also limits the BLM’s ability to ensure that research is taking place consistent with Department of the 

Interior and BLM policies related to research and science (see below). 

Effects of the Alternatives 

No Action Alternative 

Under the No Action Alternative, scientific research would continue to take place within the Monument. 

Authorization from the Monument Manager would only be required where law or BLM policy requires a 

permit or other form of authorization. Under this alternative, research would continue at a similar rate as 

has occurred in the past. The BLM would continue to have a limited ability to monitor the impacts of this 

research on the Monument or to reduce potential conflicts between research different projects or between 

research and other uses of the Monument. 

Under this alternative, researchers would continue not to be required to provide the BLM with an 

electronic copy of all final reports and papers resulting from research conducted within the Monument. 

This would limit the BLM’s ability to apply research to Monument management and to share results, as 

appropriate, with the public. 

Alternatives A, B, C, and D 

Under the action alternatives, the BLM would continue to support and authorize scientific research within 

the Monument undertaken by citizen scientists, non-profit organizations, universities and universityaffiliated researchers, and Tribal, Federal, State, and local agencies. The BLM would require 

authorization from the Monument Manager for all research, including any collection of materials from the 

Monument for scientific purposes. This would ensure that research within the Monument complies with 

the Department of the Interior’s handbook on the Integrity of Scientific and Scholarly Activities (DOI

191 
 

5

10

15

20

25

30

35

40

45

 San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 2014), the Implementation Strategy for Advancing Science in the BLM (Kitchell et al. 2015) and the 

2 National Landscape Conservation System Science Strategy (BLM 2007a). Under all action alternatives, 

3 the BLM would develop a science plan for the Monument. 

4 This requirement for authorization would allow the BLM to monitor the impacts of research on the 

Monument and reduce potential conflicts between different research projects and between research and 

6 other uses of the Monument. The BLM could also prioritize research that would enhance the 

7 effectiveness of its management of the Monument’s cultural and ecological values. Under the action 

8 alternatives, the Monument Manager would only authorize destructive sampling (i.e., any procedure that 

9 causes permanent change to the sampled material) of Monument ecological and cultural values where: a) 

it is the only viable method for conducting the research, and b) the research is expected to answer critical 

11 questions that would benefit the long-term protection of the values. 

12 Under all action alternatives, researchers would also be required to provide the BLM with an electronic 

13 copy of all final reports and papers resulting from research conducted within the Monument. This would 

14 improve the BLM’s ability to apply research to Monument management and to share results, as 

appropriate, with the public. 

16 Under these alternatives, the number of research projects taking place within the Monument would 

17 decline. The need to obtain approval would deter some researchers. It is also likely that the BLM would 

18 not approve all projects in order to reduce conflicts and prioritize research to enhance understanding and 

19 protection of the Monument’s cultural and ecological values. In these cases, displaced researchers could 

find other opportunities across the San Juan Islands outside of the Monument. 

21 The authorization requirement would benefit researchers who obtained a permit by limiting conflict 

22 between different research projects. It would also benefit researchers interested in developing a better 

23 understanding of the Monument’s cultural and ecological values. This requirement would also benefit the 

24 BLM’s ability to effectively manage and limit impacts to the Monument’s cultural and ecological values. 

Conclusion 

As compared to the No Action Alternative, alternatives A, B, C and D would reduce conflict, 26 

redundancy, and potential impacts to the Monument’s ecological and cultural values. 27 Under these alternatives, the rate of research would decline compared to the No Action 

28 Alternative. 

29 Cumulative Effects of the Alternatives on Research in the San Juan Islands 

The No Action Alternative would have no impact on the current opportunities for research in the San Juan 

31 Islands. The action alternatives could slightly reduce the number of research projects undertaken in the 

32 San Juan Islands by requiring that researchers obtain authorization from the Monument Manager. The 

33 Monument includes approximately 4 percent of public lands in the San Juan Islands (See Table 30 on 

34 page 147), so this would have a very modest impact on scientific research in the area as a whole. 

Socioeconomics 

37 Key Points 

38  San Juan County has a strong tourism-based economy. The Monument’s main economic effect is in

39 attracting visitors. Visitors come to the San Juan Islands for a variety of reasons, including many

unrelated to the Monument. There is no reliable estimate of the Monument’s economic contribution.

41  The Monument provides non-market resources (benefits to wildlife and fisheries, air quality, cultural

42 resources, etc.). These are resources that the public values, but not bought or sold through markets.

43  Residents of the San Juan Islands have a high quality of life by a number of measures. They value

44 natural space, hiking trails, shoreline access, wildlife viewing, and land conservation and stewardship.

Residents are working to ensure that tourism is socially and environmentally sustainable.

 The main way that the BLM influences the quality of life for local communities is through provision

of recreational opportunities that provide a variety of experiences and benefits, and through

36 

46 

47 

192 
 

 

 

 

 

 

5

10

15

20

25

30

35

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 opportunities for shared stewardship of Monument lands and resources through volunteering and 

2 other forms of partnerships. 

3  The BLM did not identify any environmental justice populations living within the planning area, but 

4 regional Native American populations have a variety of strong ties to the islands that this document 

evaluates from an environmental justice perspective. 

6 This section contains three analytical issues: 

7 1. How would the alternatives affect economic activity in the planning area derived from BLM8 administered lands? (page 193) 

9 2. How would the alternatives affect the quality of life for local communities in the planning area? 

(page 197) 

11 3. Would the alternatives result in environmental justice impacts? (page 202) 

12 The great majority of the Monument lands are within San Juan County (see Table 2 on page 2) so this 

13 document uses the county as the socioeconomic planning area. San Juan County, which is surrounded by 

14 water, is composed of the San Juan Islands and encompasses about 180 square miles. Residents and 

visitors can access San Juan County, and the Monument, only by boat or air. For further background 

16 information, see the Socioeconomic section of Appendix E. 

17 Socioeconomic Analytical Issue 1: How would the alternatives affect 

18 economic activity in the planning area derived from BLM-administered lands? 

19 See Appendix B for analytical methods used in this analysis. 

Affected Environment 

21 The Monument has a very minor direct economic role in the county. The BLM makes payments in lieu of 

22 taxes to the county to compensate for tax revenues not received from Federal lands, as well as additional 

23 funds authorized by the Emergency Economic Stabilization Act of 2008 (Public Law 110-343). Due to 

24 the small amount of BLM-administered lands in the county, recent payments have totaled less than 

$1,000 annually, about 1/5 of the total payments received by the county from the Federal government. 

26 The BLM also makes a direct contribution through employment and by spending dollars on project27 related goods and services. In addition to two full-time employees currently living and working in the 

28 islands, seasonal staff work and live in the area. 

29 The Monument encompasses a small percentage of both the overall land (<1 percent), and the land 

available for public visitation (~4 percent) in the San Juan Islands. It represents a majority (53 percent) of 

31 the publically available land on Lopez Island (see Table 30 on page 147). 

32 Despite its relatively small size, the Monument is important to local communities and a draw for seasonal 

33 visitors to the islands. In 2014, the BLM and its partners counted over 100,000 visitors to the Monument. 

34 The Monument provides a variety of recreational opportunities to visitors and residents and is a primary 

provider of such opportunities on Lopez Island (see the Recreation section). These opportunities support 

36 the lifestyle beloved by the local residents and are a draw for visitors. The BLM assumes that these 

37 opportunities enhance the consumer surplus experienced by visitors to the San Juan Islands. 

193 
 

 

 

 

 

5

10

15

20

25

30

35

40

45

1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Most non-resident visitors to the Monument are likely to also visit non-Monument lands while in the San 

2 Juan Islands. The Monument does receive substantially 

3 more visitation during the summer, however, indicating that 

4 these lands play some role in the seasonal tourism 

economy. The National Park Service estimates that the San 

6 Juan Island National Historic Park’s 266,717 visits in 2011 

7 generated about $17 million in non-local visitor spending, 

8 creating 235 jobs, and nearly $6 million in income (Cui 

9 et.al. 2013). 

Through its management, the BLM also contributes to non11 market values including ecosystem services. Other Chapter 

12 3 sections describe contributions to air quality, habitat and 

13 plants, protection of historic and archaeological sites, and 

14 fish and wildlife. 

Effects of the Alternatives 

16 No Action Alternative 

What is consumer surplus? 

Consumer surplus is a measure of 

economic value. It describes the amount 

an individual would be willing to pay to 

participate in an activity or experience 

beyond the actual cost. For example, a 

visitor to the islands might pay for the 

ferry and lodging. If the individual has a 

wonderful experience in the islands, he 

or she might experience a high level of 

value compared to these costs, i.e., have 

a high level of consumer surplus. 

17 The No Action Alternative and Alternative D would provide the most opportunities for recreational 

18 activities within the Monument. Popular activities such as camping, hiking, and visiting Monument lands 

19 by boat would continue, as would other activities such as hunting with firearms and equestrian use. 

Although the BLM would continue not to manage any Monument lands explicitly for providing solitude 

21 and quiet, these opportunities would continue to be available throughout the Monument on less popular 

22 days and times for visitation. All trails in the Monument are currently open to all non-motorized uses. 

23 The BLM assumes that current trends in Monument visitation would continue, so there would be no 

24 change in current patterns of economic activity. As stated above, there are insufficient data to quantify 

the BLM’s contribution to overall economic activity associated with visitation to the San Juan Islands. 

26 By having very limited restrictions on recreational activities, this alternative may have the greatest 

27 potential for conflict between visitors, which could lower the consumer surplus experienced by 

28 Monument visitors. For example, the BLM has heard from visitors who feel unsafe due to firearm-based 

29 hunting on Monument lands. Without some restrictions on use, conflicts and crowding could increase at 

key times and places. This would lower the quality of some visitors’ experiences, thereby lowering the 

31 consumer surplus they associate with visiting the San Juan Islands. 

32 Alternative A 

33 Under this alternative, the BLM would prohibit recreational use on Monument lands, although it would 

34 authorize access for educational, scientific, cultural, and spiritual uses. Because the Monument 

encompasses only 4 percent of the publically available land in the San Juan Islands, this change would be 

36 unlikely to decrease current trends in visitation to the San Juan Islands in general. Thus, there would be 

37 no change in current patterns of overall economic activity. However, the effects of prohibiting recreation 

38 could decrease visitation levels to Lopez Island, where the Monument provides over half of the public 

39 lands, including Watmough Bay, the most heavily visited site in the Monument. Businesses that serve 

Lopez Island visitors could see a decrease in business, although the magnitude is difficult to estimate. 

41 Non-resident visitors who have developed strong attachments to Monument sites and opportunities 

42 through recreation would no longer be able to have these experiences and benefits unless they could 

43 obtain authorization for educational, scientific, cultural, and spiritual purposes. This could result in 

44 lowering San Juan Islands visitors’ consumer surplus. This alternative’s radical change from existing

conditions and the major departure from how the BLM manages all other national monuments under its 

46 administration would lead to public conflict and concern among visitors and residents alike (see 

47 Socioeconomic Issue 2). 

48 The consumer surplus for those participating in educational, scientific, cultural, and spiritual activities 

49 could increase under this alternative. The quality of these visitors’ experiences could increase because 

194 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 they would not have to compete with recreational visitors and would have greater opportunities for 

solitude, as well as encountering reduced environmental effects of human use. 

Management partners, including Federal, State, and local agencies and non-governmental organizations, 

could experience increased costs due to the displacement of Monument recreational visitors under this 

alternative. This visitor management approach could pose challenges to partnership that are crucial to 

effective management of the Monument. Washington State Parks, which currently manages camping in 

the Monument under a memorandum of understanding, would experience an economic revenue and 

infrastructure investment loss due to the prohibition on camping at Blind, Posey, and Patos islands. 

Alternative B 

Under Alternative B, all but 10 acres of the Monument would remain open to recreational use and would 

be designated as RMAs (Monument rocks would be closed to recreational use). The BLM would 

facilitate recreational hiking and manage for quiet and solitude by dispersing users on the increased 

number of trails and managing some areas, including recreational boat landing on some shorelines, for 

permit-only recreation. Existing designated site camping would continue; the BLM would allow 

dispersed camping on much of the Monument but would use permits to ensure solitude and quiet by 

allowing only one small group per site. The BLM would prohibit equestrian and bicycle access. 

As with other alternatives, the BLM would expect the current trends in visitation to the San Juan Islands 

in general and to Monument sites specifically to continue under this alternative. Therefore, the economic 

activity associated with the Monument would remain approximately the same as under the No Action 

Alternative. Some visitors’ consumer surplus could increase and some decrease, depending on the type of 

experience desired. 

The introduction of recreational permits for some areas and activities would be a change. Permit 

requirements would apply mainly to areas where use is currently low, so would not be expected to change 

use levels in the Monument. The consumer surplus for those participating in permitted uses could 

increase, because visitors would have greater opportunities for solitude and quiet. The requirement for 

permits for recreational boat landing in many less visited areas, coupled with the prohibition of 

recreational boat landing at Watmough Bay, would lower the consumer surplus for some visitors. Based 

on BLM and volunteer monitoring, approximately half of all visitors to the Monument arrive via boat. 

Alternative C 

All but 7 acres of the Monument would be open to recreational use and would be designated as RMAs. 

The BLM would close 3.6 miles of trail under this alternative, resulting in a 25 percent decrease in trail 

access compared to the existing network. The BLM would designate some trails for equestrian access, 

though fewer trails would be open to this activity than under the No Action Alternative or Alternative D. 

The BLM would manage fewer opportunities by permit than under Alternative B. While existing 

designated camping would continue, the BLM would close the remainder of the Monument to dispersed 

camping. Participation in dispersed camping is currently very low, so non-resident visitors may not be 

affected by this closure because the current popular designated site camping opportunities would remain. 

As with other alternatives, the BLM would expect current trends in visitation to continue. Therefore, the 

economic activity associated with the Monument would remain approximately the same as current levels, 

although the pattern of recreation use on BLM-managed lands would shift somewhat. Some visitors’

consumer surplus could increase and some decrease, depending on the type of experience desired. 

In keeping with this alternative’s restoration theme, the BLM would restore/rehabilitate historic structures 

to their historic appearance, and allow rebuilding of historically present, but currently absent structures. 

This would create additional opportunities for educating visitors about the area’s history. 

The BLM would close areas with known conflict associated with hunting to the discharge of firearms 

except for half of the hunting season, preserving some opportunity for recreational hunting using firearms 

not available in alternatives A or B. The partial closure would not affect non-firearm-based hunting (e.g., 

bow hunting) or hunting by Coast Salish tribal members. This partial closure would have the greatest 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

195 
5

10

15

20

25

30

35

40

45

50

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

effect on visitors to Lopez Island, where most hunting within the Monument occurs. The BLM does not 

have a reliable estimate of the magnitude of the effect this closure would have on local businesses. 

Sub-Alternative C 

The discharge of firearms closure under Sub-Alternative C would remove opportunities for hunting using 

firearms from the Monument, but would not affect opportunities for bow hunting or hunting by Coast 

Salish tribal members. This closure would have the greatest effect on visitors to Lopez Island, where the 

most hunting within the Monument occurs. The BLM does not have a reliable estimate of the magnitude 

of the effect this closure would have on local businesses. Other than this closure, the economic effect of 

Sub-Alternative C would be the same as under Alternative C. 

Alternative D 

Under this alternative, the BLM would manage for more recreational opportunities than any other 

alternative. The entire Monument would remain open to recreational use without a permit and would be 

designated as RMAs, with a range of expanded recreational opportunities including facilities and signage 

and a 54 percent increase in trail access. The BLM would allow equestrian and bicycle use on some 

trails, though fewer trails would be open to these uses than under the No Action Alternative. In areas 

designated as middle county under this alternative, the BLM would allow a higher level of facility and 

signage development compared to the back country designations in Alternative C. 

The new recreational opportunities could attract more visitors to the Monument, but the BLM assumes 

that, as a whole, visitation to the San Juan Islands would follow existing trends. Therefore, the economic 

activity associated with the Monument would remain the same as under the No Action Alternative. Some 

visitors’ consumer surplus could increase and some decrease, depending on the type of experience 

desired. 

The increases in trail miles and, over the life of the plan, of designated campsites and visitor facilities 

would increase the consumer surplus for visitors seeking these opportunities. Some visitors would also 

experience a decrease in consumer surplus from the potential conflict between recreational uses. There 

would be a higher potential for visitor conflict due to multiple uses on trails under Alternative D than 

under alternatives A, B, and C, but less than under the No Action Alternative. Under this alternative, the 

whole Monument would remain open to the discharge of firearms. The BLM has heard from visitors who 

feel unsafe due to firearm-based hunting on Monument lands. As use increases, without some of the 

restrictions found in other alternatives, conflicts and crowding could increase at key times and places. 

This could lower the quality of some visitors’ experiences and therefore their consumer surplus. 

Conclusion 

Regardless of the alternative selected, it is likely that BLM-related activities will continue to constitute a 

tiny percent of the local economy. The main economic effect of the alternatives would stem from how 

recreational use levels by non-resident visitors would change on both Monument lands and nonMonument lands. Although the Monument offers some unique recreational opportunities, it encompasses 

only 4 percent of the publically available land in the San Juan Islands. The BLM assumes that overall 

visitation levels to the San Juan Islands would remain about the same regardless of its approach to 

managing the Monument, leading to negligible changes in economic activity due to recreation. 

The exception to this general finding is the effect on economic activity on Lopez Island, where the 

Monument provides 53 percent of the public lands available, including Watmough Bay, the most heavily 

visited site in the Monument. Therefore, the alternatives have the potential to have a greater effect on 

economic activity specific to Lopez Island. 

Although the BLM assumes that overall levels of visitation to the San Juan Islands would follow existing 

trends under all alternatives, the alternatives would change the recreational opportunities available on the 

Monument and potentially the quality of visitors’ recreational experiences. This in turn could affect 

recreation visitors’ consumer surplus. Many of the repeat visitors returning to the islands have a strong 

sense of place, presumably for similar reasons as the people who live there; this group could be affected 

more than first-time or casual visitors. In addition, the alternatives would have distributive impacts based 

on peoples’ preferences for recreation. 

196 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Cumulative Effects on Economic Activity in the San Juan Islands 

In the San Juan Islands, there are an array of governmental agencies and non-profit organizations that 

provide approximately 23,882 acres of land available for a variety of recreation activities. The 

availability of publically accessible lands for outdoor recreation in a scenic setting is an important 

contributor to the attractiveness of the San Juan Islands as a tourism destination. Under all alternatives, 

non-BLM public and private recreation providers in the San Juan Islands would continue to conduct 

marketing efforts to attract visitors and the BLM expects existing trends in recreation to continue. 

The BLM’s small contribution to this economy would continue at its current rate under alternatives B, C, 

and D. Under alternative A, this small contribution would be withdrawn. Given the availability of other 

publically accessible lands in the San Juan Islands, this is would have a negligible impact on economic 

activity in San Juan County. However, because the Monument is a primary provider of publically 

accessible lands on Lopez Island this alternative would affect its desirability as a tourism destination. 

Socioeconomic Analytical Issue 2: How would the alternatives affect the 

quality of life for local communities in the planning area? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Residents of the San Juan Islands highly value open space, conservation of natural resources, recreational 

opportunities, and the atmosphere of island life (see Socioeconomics section in Appendix E). Monument 

lands and opportunities contribute to these values. While the Monument’s overall contribution to 

publically accessible land in the San Juan Islands is small (~4 percent), it represents the majority of public 

lands on Lopez Island (53 percent) (see Table 30 on page 147). 

Residents’ uses of the Monument—as well as of other areas in the San Juan Islands—encompass a variety 

of experiences and benefits. For example, the experience of enjoying natural landscapes can lead to 

onsite benefits such as greater environmental awareness and sensitivity and to offsite benefits such as 

increased community stewardship of natural resources (BLM 2014b). During project scoping and the 

2016 human use workshops, the BLM heard from local residents about the cultural importance to their 

community of the Monument lands on the south end of Lopez Island. In addition to comments describing 

the ongoing use of these lands by local residents for walking and other non-motorized forms of recreation, 

some commenters mentioned the use of the lands for community celebrations, overnight visioning 

retreats, naming ceremonies, and other cultural or spiritual purposes (BLM 2015b,c, BLM 2016a,b). 

As described in the San Juan County Vision Statement (see Socioeconomics section in Appendix E), 

residents value stewardship and self-sufficiency. There is a long history of local collaboration with the 

BLM in conservation and management activities. A volunteer monitoring program established after the 

designation of the ACECs provides the BLM with information about visitation and resource condition on 

Lopez Island. Very active partner groups maintain interpretive materials and displays at Turn Point Light 

Station and Patos Lighthouse, with volunteers providing onsite information. 

Partnerships are essential to the BLM’s management of the Monument, with partners assisting with work

including visitor management, monitoring, and historic structure restoration. The BLM works with 

diverse partners to provide educational and interpretive programs (See Education and Interpretation). It 

relies on a partnership with Washington State Parks to manage developed camping in the Monument. 

The BLM has worked in consultation with tribal partners to reduce risks of cultural resource damage and 

to develop a better understanding of culturally important plants and the area’s tribal heritage. Tribal

partners have reported to the BLM that collaborative stewardship projects provide a means of helping 

tribal members, particularly youth, to engage with lands in their traditional territories. 

In addition to providing opportunities for many types of recreation experiences and benefits, the 

Monument provides an opportunity for connection and engagement among residents, agencies non-profit 

organizations, and extremely dedicated volunteers. The Monument therefore contributes to community 

social cohesion, i.e., the extent to which a geographical place is a community in its shared values, 

cooperation, and interaction, and the extent to which people respond collectively to identify and reach 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

197 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 valued outcomes and to deal with collective economic, social, political, or environmental issues 

(Desjardin et al 2002). Volunteer organizations are a key component of social cohesion; volunteering is a 

way to meet people, develop relationships, and serve the community, often providing important service 

needs that could otherwise not be met (Desjardin et al 2002). 

The Monument has likely contributed to community social capital as well as generating its own social 

capital within the community. Social capital is an asset like human capital or financial capital that is 

available for use by people who possess it; it is developed through relationships and social networks that 

are often characterized by social norms and levels of trust and it facilitates collective action for mutual 

benefit (Putnam 2000). Social capital is especially important to island communities because they are 

typically smaller, more isolated, and self-sufficient, so things go more easily when people are able to 

work together to define and achieve common goals. 

Effects of the Alternatives 

No Action Alternative 

Residents would be able to continue to recreate on the entire Monument (subject to minimal current 

restrictions) without having to obtain a permit. Residents could continue to visit the Monument as they 

do currently, contributing to their lifestyle and the benefits gained from recreation experiences. 

By having few limitations on recreational activities, this alternative would also have the greatest potential 

for conflict between visitors, particularly if there is an increase in participation over time in activities that 

are currently available but have low participation rates, such as bicycle use and dispersed camping. 

Increasing visitation and diversifying uses with limited management could potentially diminish the 

quality of experiences available in the Monument. Members of the public who expected to see additional 

protections to Monument objects from recreational impacts, or restoration of plant communities, could be 

disappointed that Monument designation did not lead to those changes. Comments to the BLM suggest 

that residents highly value recreational opportunities, but want to see them managed to avoid crowding 

and protect ecological and cultural values (BLM 2016a,b). The BLM received a variety of comments 

requesting more restrictive recreational management than is currently in place. 

The BLM would continue to undertake very limited vegetation treatments in the Monument. As a result, 

residents and local organizations would have relatively little opportunity to participate in vegetation 

management activities as contractors, volunteers, or partners. On the other hand, recreation would not be 

as disrupted by vegetation management as under other alternatives. 

Alternative A 

Because the BLM would prohibit recreational use, local residents would no longer be able to recreate on 

Monument lands and would have to obtain authorization, through a process that would be determined 

during plan implementation, to visit for educational, research, cultural, or spiritual purposes. 

The primary outcome would be a decline in the quality of life for San Juan Islands residents, especially 

those living on Lopez Island, where the Monument provides a larger share of many recreational 

opportunities. These negative effects would be stronger among residents than visitors because many 

Lopez residents have come to depend on Monument recreational opportunities as part of their lifestyle, 

and have developed a strong sense of place for Monument sites. 

The requirement to obtain authorization for public access for one of the stated purposes would be a 

substantial impact to residents. One of the major sources of conflict regarding Federal recreation 

management occurs when a permit or other restricted entry system is enacted in a place where there has 

never been one (McCool 2001). The authorization system would facilitate research, cultural, educational, 

and spiritual purposes, though any authorization process could still create a barrier to use. The impact 

would depend to some extent on how easy or difficult it would be for residents to obtain access. 

Assuming the BLM approves some requests but denies others, this would create conflict among potential 

users and would increase tension between the community and the BLM. 

Residents who value resource protection over recreational public use, or who could continue to access the 

Monument for the educational or research related activities they value, may benefit from this alternative. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

198 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Residents who participate in citizen science and monitoring would be able to continue these activities, 

which are valued among some local residents. 

The lands on the south end of Lopez Island are culturally important to members of the local community, 

as expressed in an array of feedback received by the BLM during the scoping period for this planning 

process. This would make the problem discussed above—distinguishing between authorized uses and 

recreation—especially difficult for Lopez Island and other residents. There would be conflict over what 

constitutes an authorized purpose for a visit given the culture and values of San Juan Islands residents. 

The BLM estimates that meeting the vegetation objectives for this alternative would require a low level of 

vegetation management (an average of 52 acres per year). This would cause minimal disruption to 

authorized human uses and residents, but would also present less opportunity for local hires, volunteer 

involvement, and active partnerships with conservation organizations. The BLM would not allow the use 

of chemical treatments or prescribed fire; the BLM has received comments from local residents 

expressing concern over the application of chemicals and prescribed fire within the Monument. 

Alternative B 

Residents would continue to be able to access all but 10 acres of the Monument for recreational purposes. 

As under alternatives C and D, the recreational activities most residents are currently participating in 

would continue to be available. This alternative’s emphasis on hiking and quiet and solitude appears 

consistent with many San Juan Island residents’ values and preferences for recreation settings as 

expressed by some public comments (BLM 2016a,b). 

Lopez Island residents who currently use Monument trails for equestrian use would no longer have access 

to this opportunity under Alternative B. Given the limited availability of equestrian trails on Lopez 

Island, this could have an impact on these residents’ quality of life. Residents who have expressed a

desire to limit Monument trails to hiking would experience a decrease in potential conflict. As mentioned 

under Issue 1, recreation in certain locations would be available by permit only in order to provide 

opportunities for quiet and solitude. Recreational use in these areas is currently low use so residents may 

be able to obtain permits easily. Comments to the BLM suggest that many residents would support use 

limits in return for solitude experiences and protection of resources (BLM 2016a,b). Over time, the 

nature of the permit system, its rationale, whether it is perceived as fair, the ease of obtaining a permit, 

and other details would likely shape residents’ acceptance of the system.

As was described under Socioeconomic Issue 1, the prohibition of recreational boat landing at Watmough 

Bay would constitute a social impact to residents who land boats at that site. Residents who regularly 

take advantage of this opportunity may not have readily available substitute sites. 

The BLM estimates that it would require a relatively large amount of vegetation treatment to achieve 

Alternative B’s vegetation objectives (an average of 584 acres per year57). These treatments would

periodically disrupt human use and occasionally nearby residences. This level of management would also 

create opportunities for residents to work cooperatively with the BLM as volunteers, contractors, or 

partners. Members of the public would have the opportunity to comment on the design of treatments 

during plan implementation. 

The goal of enhancing the San Juan Islands’ ecological resistance and resilience by increasing the extent

of native plant communities—specifically grasslands and wetlands—that are relatively scarce within the 

San Juan Islands as a whole appears consistent with many residents’ values. However, this alternative 

would result in the second greatest change from existing conditions, so some residents would likely be 

uncomfortable with far less forest vegetation than they see at present in the Monument. 

Alternative C 

Residents would be able to continue to access all but 7 acres of the Monument for recreational purposes. 

As under alternatives B and D, the recreational activities most residents are currently participating in 

 

57 In many cases, the described treatments would take place on the same acres of land. For example, mechanical or 

manual treatments to remove woody shrubs and subsequent planting of native plants would be likely to take place in 

the same area. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

199 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 would continue to be available. The long-standing use of trails on Lopez Island for equestrian use by a 

small number of local residents would continue. Camping at existing designated sites would remain but 

the BLM would close the rest of the Monument to camping. Assuming that residents are less likely to 

camp, they could benefit from reduced impacts and fewer potentially conflicting uses. 

The BLM would close areas with known conflict around hunting to the discharge of firearms except for 

half of the hunting season, preserving some opportunity for recreational hunting using firearms not 

available in alternatives A or B. The partial closure would not affect non-firearm-based hunting (e.g., 

bow hunting) or hunting by Coast Salish tribal members. This partial closure would have the greatest 

effect on Lopez Island residents, where most hunting within the Monument occurs. Residents who 

reported conflict and safety issues associated with firearms would benefit from the removal of this 

potential conflict from their use of the Monument during approximately half of hunting season. 

This alternative would also have the second greatest for potential disruption from vegetation treatments 

(an average of 887 acres per year57). This level of treatment would periodically disrupt human use and 

occasionally nearby residences. It would provide many opportunities for residents and others to become 

involved in vegetation management activities, increasing their sense of stewardship and level of 

collaboration with the BLM. Members of the public would have the opportunity to comment on the 

design of treatments during plan implementation. 

The goal of approximating the extent and condition of plant communities that existed prior to European 

settlement could resonate with many residents, who would also likely agree with the goal of reducing the 

threat of high-severity wildland fire or other major disturbance events. However, this alternative, along 

with Sub-Alternative C, would result in the greatest change from existing conditions, so some residents 

would likely be uncomfortable with far less forest vegetation than they see at present in the Monument. 

Sub-Alternative C 

The discharge of firearms closure under Sub-Alternative C would remove opportunities for hunting using 

firearms entirely from the Monument. This closure would not affect non-firearm-based hunting (e.g., 

bow hunting) or hunting by Coast Salish tribal members. This closure would have the greatest effect on 

Lopez Island residents, where most hunting within the Monument occurs. Lopez Hill would be the only 

remaining public land on Lopez Island partially open to this use (Lopez Hill is open to hunting for 

approximately one half of regular deer hunting season). Residents who reported conflict and safety issues 

associated with firearms would benefit from the removal of this potential conflict. 

The other objectives and direction under Sub-Alternative C are the same as Alternative C except that no 

chemical vegetation treatments would be allowed, which residents opposed to this use would favor. The 

prohibition on chemical treatments would require more repetition of mechanical treatments to achieve the 

alternative’s restoration objectives. The BLM estimates that it would require the most acres of vegetation

treatment under this alternative (an average of 1,712 acres of treatment per year57). 

This alternative would cause the greatest disruption in human use from vegetation management though 

would also provide the greatest opportunities for residents and others to become involved in vegetation 

management activities, increasing their sense of stewardship and level of collaboration with the BLM. 

Members of the public would have the opportunity to comment on the timing, mechanism, and 

sequencing of treatments during plan implementation. The prohibition on herbicide use would also make 

it more difficult for the BLM to minimize invasive plant species occupying areas disturbed through 

vegetation treatments and along trail and roadsides. 

Alternative D 

Residents would continue to be able to access the entire Monument for recreational purposes without a 

permit. As under alternatives B and C, the recreational activities most residents are currently 

participating in would continue to be available. Residents of Lopez Island who currently participate in 

equestrian use on Monument trails, and those who are interested in using bicycles on Monument trails, 

would have the most trails explicitly designated for these uses under Alternative D (though this would 

still be a reduction in the total trail miles compared to those available under the No Action Alternative). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

200 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The recreation analysis noted that by allowing the most uses and opening up lands and opportunities for 

multiple forms of recreation, this alternative could result in higher levels of conflicts than the other action 

alternatives. Based on comments to the BLM, many residents could feel that this alternative does not 

restrict recreation use enough to protect the quality of the experience and the Monument’s ecological and 

cultural values (BLM 2016a,b). Therefore, this alternative could create more social conflict than 

alternatives that include stronger restrictions on recreational use, and result in recreation settings that are 

more developed and crowded than residents prefer. 

Monitoring could determine if this was becoming a problem and the BLM could undertake 

implementation-level actions to change trail designations or provide additional facilities as necessary in 

conformance with the Approved RMP. Assuming much monitoring would be citizen-based, this 

alternative would create additional opportunities for residents’ participation and stewardship.

The vegetation goal would be to maintain the approximate 2016 extent and condition of plant 

communities while minimizing wildfire risks to human health and safety, property, and infrastructure. 

Residents who favor the status quo and minimizing disturbances associated with vegetation treatment 

may favor this approach. The BLM estimates that it would require an annual average of approximately 

65 acres to accomplish this objective. This would be more vegetation treatments than the No Action 

Alternative and Alternative A. Compared with alternatives B and C, there would be fewer opportunities 

for residents to participate in vegetation management and associated stewardship activities, but this could 

be offset by the increased opportunities for recreation monitoring, interpretation, and visitor education. 

Conclusion 

The main way that the BLM influences the quality of life for residents is through provision of recreational 

opportunities. Another benefit is the opportunity to participate as volunteer monitors, citizen scientists, 

and similar roles that provide a sense of stewardship and collaboration. 

Many residents of local communities, particularly on Lopez Island, regularly use the Monument and the 

opportunities it provides. These opportunities contribute positively to residents’ quality of life, but the 

extent of this contribution relative to other public lands is not known. Alternatives that change these 

existing opportunities could affect the quality of life for residents who currently depend on them, as could 

alternatives that create or reduce social conflict, and how the alternatives align with residents’ values.

As was the case with Issue 1, these effects could be magnified for Lopez Island residents, due to the 

Monument including 53 percent of the public land on their home island. The importance of the 

Monument to Lopez residents is also reflected by the fact that the Lopez Island workshop garnered the 

vast majority (77 percent) of comments received by the BLM during its four 2016 human use workshops. 

Local residents are likely to favor, and view themselves as favorably affected by, alternatives that 

maintain the recreational opportunities that they value. This will vary among residents, but in general, 

many have expressed a desire to minimize crowding or impacts to ecological and cultural values. Thus 

alternatives A and D are the least likely to have positive effects on quality of life for many local residents. 

Alternatives B and C would maintain the activities most residents participate in while having more 

restrictions on recreation than Alternative D. All action alternatives would provide more opportunities for 

citizen engagement in vegetation management; alternatives B, C, and sub-C would have the most 

opportunities for engagement, but also the most potential for vegetation treatments to disrupt human uses. 

Cumulative Effects on Quality of Life for Local Communities 

As described under cumulative effects for Socioeconomic Issue 1, there are an array of governmental 

agencies and non-profit organizations that provide approximately 23,882 acres of land in the San Juan 

Islands for a variety of recreation activities. The availability of publically accessible lands for outdoor 

recreation in a scenic setting is an important contributor to the quality of life for residents. Under all 

alternatives, other public land managers in the San Juan Islands would continue to provide opportunities 

for residents to participate in outdoor recreation. 

The Monument would continue to contribute to the quality of life of local residents under all alternatives, 

although the overall availability of public land for resident recreation in the San Juan Islands would 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

201 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 decrease by 4 percent under Alternative A. Given the availability of other publically accessible lands in 

the San Juan Islands, this is would have a negligible impact on economic activity in San Juan County. 

The availability of non-Monument public lands would ameliorate the alternatives’ effects on quality of

life with the possible exception of Lopez, where the BLM decisions would have a larger effect due to the 

larger BLM share of public recreational opportunities. 

Socioeconomic Analytical Issue 3: Would the alternatives result in 

environmental justice impacts? 

See Appendix B for analytical methods used in this analysis. 

Background 

Environmental justice refers to the fair treatment and meaningful involvement of people of all races, 

cultures, and incomes with respect to the development, implementation, and enforcement of 

environmental laws, regulations, programs, and policies. Executive Order 12898 requires Federal 

agencies to “identify and address the disproportionately high and adverse human health or environmental

effects of its programs, policies, and activities on minority populations and low-income populations.”

According to the Council on Environmental Quality’s (CEQ) Environmental Justice Guidelines for NEPA

(1997), “Minority populations should be identified where either: (a) the minority population of the 

affected area exceeds 50 percent or (b) the minority population percentage of the affected area is 

meaningfully greater than the minority population percentage in the general population or other 

appropriate unit of geographic analysis.” Low-income populations are those whose residents live at or 

below the poverty level. 

Affected Environment 

Based on the race and ethnicity proportions of the San Juan County population described earlier in this 

section, and on the poverty rate compared to the statewide rate, the county population as a whole does not 

meet the threshold for either minority or low-income status. See the Socioeconomics section of Appendix 

E for information on San Juan County’s race and ethnicity demographics and poverty rate. 

However, lower-income individuals and families do live in San Juan County. For example, as of May 

2016, 43 percent of students in the San Juan Island School District received free or reduced-price meals, 

nearly the same as the statewide rate of 44 percent (Office of Superintendent of Public Instruction 2016). 

The Washington State Report Card also shows that there are minority students in the District; about 17 

percent of students were Hispanic/Latino, although the proportion of White, non-Hispanic students in the 

District (75 percent) was much higher than the statewide rate (56 percent). 

The long tradition of use and current interests in the San Juan Islands by Coast Salish tribes indicate that 

the BLM’s management affects Native American communities associated with the Monument (see the 

Tribal Interests section on page 215 of this chapter). Thus, the BLM is considering negative impacts to 

tribal interests to be an environmental justice issue. 

Effects of the Alternatives 

The main purpose of this environmental justice analysis is to describe whether impacts to tribal interests, 

specifically to the Native American/Coast Salish tribes with ties to Monument lands, would be 

disproportionately negative and adverse compared to impacts to non-tribal populations. A secondary 

purpose is to describe beneficial impacts to tribes. This section relies on the analyses of impacts 

presented in the Tribal Interests section, along with tribal comments received on preliminary drafts of this 

document, rather than conducting new or independent analyses. 

The Tribal Interests section assessed environmental consequences to tribal interests in two main ways. 

First, it assessed the impacts from recreation on cultural resources and traditional activities, including the 

exercise of treaty rights. Second, it assessed the positive and negative effects of vegetation management 

on tribal interests. The analysis found that recreational use can affect tribal interests and uses in several 

ways. Recreational use and access can affect the integrity of sites, locations, or resources identified as 

important to tribes. Recreational use can affect cultural sites through disturbance, soil compaction, 

altered surface water drainage, erosion, intrusions to the setting, and unauthorized collection or 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

202 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 vandalism. Actions that affect access or interfere with the exercise of traditional cultural uses and 

practices also can harm cultural resource values and treaty protected activities. Opening areas to new or 

increased access and use can increase risk to previously undisturbed and fragile resources from intentional 

or unintentional damage and loss. 

Vegetation management can have both positive and negative effects on tribal interests and uses. 

Disturbance from vegetation treatments can damage cultural resources. Vegetation treatments that 

change a cultural or natural setting, including visual and aural intrusions, or that concentrate activities in 

areas important for spiritual or other traditional practices can affect tribal interests. However, if 

vegetation treatments are not implemented, noxious weeds and invasive plants would continue to 

increase, forest health and wildlife habitats would continue to decline and encroachment of grasslands and 

shrublands would continue, contributing to long term impact on the historic setting, availability of plants 

for gathering, and other traditional uses and exercise of treaty rights. Alternatives having greater amounts 

of vegetation management also would create desired opportunities for the tribes to be involved in those 

activities. 

Effects Common to All Alternatives 

As described in the Tribal Interests section, the BLM would address potential impacts to tribal interests, 

including effects to cultural sites and traditional cultural practices, at the design or implementation phase 

of future projects through consultation with affected tribes along with National Historic Preservation Act 

Section 106 review. The BLM, in consultation with affected tribes and in consideration of tribal interests 

and treaty rights, would avoid, minimize, or mitigate potential impacts on historic properties. 

Consultation and identification of potential impacts to tribal interests prior to project implementation 

would reduce adverse impacts to tribal interests. 

Under all alternatives, the BLM would collaboratively engage with tribal government partners to facilitate 

traditional uses, develop opportunities for co-stewardship of plant communities and culturally important 

plants, engage tribal youth and elders, and maintain and improve access for exercise of treaty rights and 

traditional cultural practices. Through engagement with the tribes, the BLM would foster programs to 

enrich opportunities for tribal cultural, spiritual, and educational activities including projects to restore 

Salish place names within the Monument. 

Under all action alternatives, the BLM would prohibit several recreational activities that could disturb, 

damage, alter, or destroy important objects and values of cultural significance for which the Monument 

was designated. The BLM would undertake temporary closures as necessary to protect the Monument’s

ecological and cultural values, as well as sensitive tribal activities. Recreational use would vary by 

alternative but access for tribal use and exercise of treaty rights would be available under all alternatives. 

Opportunities for solitude and quiet would continue to be available in the Monument at certain times and 

seasons under all alternatives. 

No Action Alternative 

Under this alternative, the public would be able to continue to recreate on the entire Monument (subject to 

minimal current restrictions) without having to obtain a permit. The Tribal Interests analyses found that 

measures to reduce impacts to sites would continue but the potential for impacts from use and 

maintenance would grow if visitation continues to increase over time. Increased visitation could 

contribute to increased disturbance to cultural and natural resource sites and increased intrusion into 

locations for traditional and cultural practices. Use of trails would continue to have direct short-term and 

long-term impacts on cultural sites and other cultural properties crossed or accessed by trails, through soil 

compaction, erosion via channeling of water, and widening of trails during wet periods 

The No Action Alternative would have the least risk of any alternative for vegetation treatments to disturb 

cultural resources. Conditions for culturally important plants would continue to decline and there would 

continue to be few opportunities for tribes to work with the BLM on vegetation treatments. 

Alternative A 

This alternative would minimize impacts to cultural sites and traditional use from visitation to a greater 

extent than any other alternative. Opportunities for traditional and cultural practices requiring solitude 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

203 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 and quiet would increase and tribal enrichment programs and engagement would likely increase due to 

the reduction in potential conflicts from visitor uses under this alternative. Traditional uses of cultural 

properties would continue and potentially increase over the life of the plan. 

While slightly greater than the No Action Alternative, Alternative A would have a low risk for vegetation 

treatments to disturb cultural resources. Conditions for culturally important plants would continue to 

decline and there would continue to be few opportunities for tribes to work with the BLM on vegetation 

treatments. 

Alternative B 

Under Alternative B, all but 10 acres of the Monument would remain open to recreational use. The 

impacts from recreation described under the No Action Alternative would not continue at sites closed to 

recreation, though minor impacts from access for administrative and authorized uses would continue. To 

provide opportunities for solitude and quiet, 167 acres of the Monument would be open for recreation by 

permit only, which would reduce impacts by limiting the amount of recreation in those areas. 

Authorizing new trail routes would increase potential impacts to cultural sites and areas for traditional 

cultural uses. The BLM would consult with affected tribes and conduct cultural resource surveys of the 

proposed designated trail routes prior to implementation. Rerouting trails to avoid cultural sites and 

places important for traditional cultural practices would reduce potential impacts to tribal interests. 

Limiting access to designated trails except for authorized uses would reduce impacts to cultural sites and 

places important for traditional cultural practices outside of the designated trail routes. 

The magnitude and intensity of the vegetation control and restoration measures under Alternative B 

would create a relatively high potential for impacts to cultural resources from disturbance, chemical 

treatments, and fire. The potential for damage or destruction of archaeological or cultural sites and 

properties from vegetation treatments would be greater under this alternative than under the No Action 

Alternative, Alternative A, and Alternative D. Alternative B also would substantially increase the 

quantity and quality of grassland and shrubland plant communities within the Monument. This would 

increase opportunities for both collecting culturally-important grassland plants, such as camas, and for 

tribes to work with the BLM to implement vegetation treatments. 

Alternative C 

The BLM would expect this alternative to reduce impacts from recreation to cultural sites or places of 

importance for traditional cultural activities more than any alternative except A. Development of 

educational and interpretive signs and visitor facilities focusing on tribal history and enrichment (e.g., a 

longhouse) could benefit tribal interests by informing and enhancing the public’s understanding of the 

tribal heritage associated with the Monument. The BLM would close 3.6 miles of existing trail and 

would prohibit camping outside of existing designated campsites. Rerouting trails to avoid cultural sites 

and places important for traditional cultural practices would reduce potential impacts to tribal interests. 

Limiting hiking to designated trails except for authorized purposes would reduce the potential for impacts 

to cultural sites and places important for traditional cultural practices. 

Impacts from vegetation treatments under Alternative C would be similar to under Alternative B, though 

the magnitude of both negative and positive impacts would be greater. Alternative C, along with SubAlternative C, would go the furthest toward approximating pre-Euro-American settlement vegetation 

conditions and would provide the most opportunities for gathering of grassland plants. It would also 

provide many opportunities for tribes to work with the BLM to implement vegetation treatments. 

Sub-Alternative C 

Potential impacts to cultural sites from vegetation management would be highest under Sub-Alternative 

C. Without the use of herbicides, the BLM estimates that it would need to increase the repetition of

mechanical treatments to meet the vegetation objectives (see Table 20 on page 115). Along with

Alternative C, this alternative would go the furthest toward approximating pre-Euro-American settlement

vegetation conditions within the Monument and would provide the most opportunities for gathering of

grassland plants. It would also provide many opportunities for tribes to work with the BLM to implement

vegetation treatments.

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

204 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative D 

Opportunities for traditional and cultural practices requiring quiet and solitude likely would decrease 

under this alternative and conflicts with recreational activities would likely affect tribal enrichment 

programs and engagement. Opening areas currently closed to dispersed camping would increase the 

potential for long-term and direct impacts to cultural resources and places important for traditional 

cultural uses in these areas. However, development of educational and interpretive signs and visitor 

facilities focusing on tribal history and enrichment (e.g., a longhouse) could benefit tribal interests. 

While greater than the No Action Alternative and Alternative A, Alternative D would have a substantially 

lower risk for vegetation treatments to disturb cultural resources than alternatives B, C, and Sub-C. The 

condition of areas of traditional cultural importance for plant gathering and use would remain relatively 

unchanged though conditions in forests and woodlands would continue to be mostly closed and crowded. 

It would also create fewer opportunities for tribes to work with the BLM to implement vegetation 

treatments than under alternatives B, C, and sub-C. 

Conclusion 

Appendix D of the BLM’s Land Use Planning Handbook specifies that the BLM should assess 

environmental justice impacts in part through collaboration with affected populations. The avenue for 

that collaboration in this process is through government-to-government consultation and involvement of 

tribes as cooperating agencies. 

To date, the BLM has received formal, written comment assessing the alternatives from several Native 

American/Coast Salish tribes including the Tulalip Tribes of Washington (a Cooperating Agency for 

development of the RMP/EIS), the Swinomish Indian Tribal Community, and the Suquamish Tribe. 

Letters and comments received from tribes to date generally strongly support Alternative A, modified 

with Alternative C’s emphasis on restoring fire-dependent native grasslands. Some comments also make 

the point that recreation was not an object identified in Proclamation 8947 and describe a serious concern 

with current and increasing recreational pressures on sensitive spiritual and cultural sites, though tribal 

representatives have not identified specific sites. 

The BLM assumes that Alternative A would have beneficial effects on tribes as an environmental justice 

population, although its low level of vegetation management activities could be a concern. The No 

Action Alternative and Alternative D, which would accommodate the highest levels of recreational use, 

would constitute a negative effect on tribes as an environmental justice population. Alternatives B and C 

allow recreational use, but likely at lower levels and incorporating management actions that would 

minimize many of the associated negative effects. Alternatives B and C also provide the greatest 

opportunities for tribes to be involved in vegetation management activities, as well as creating 

environments conducive to many tribal uses. Therefore, the BLM assumes that these alternatives would 

not result in disproportionately negative effects to tribes. 

The issue for environmental justice is whether the negative impacts under the No Action Alternative and 

Alternative D would disproportionately affect tribes compared to other populations. The recreational 

analysis concluded that the No Action Alternative and Alternative D generally provide the most 

opportunities for recreational activities within the Monument, which would continue to be open to a 

variety of uses that nearby non-BLM land managers prohibit (e.g., dispersed camping). 

The recreational analysis also concluded that by supporting a wider range of recreational activities, the No 

Action Alternative and Alternative D would have the greatest potential for conflict between visitors. This 

is true for tribes as well as other populations. In addition to the potential levels of conflict shared with 

other Monument users, other experiences of tribes would be at increased risk due to their unique 

connection to these lands and resources described in the Tribal Interests section. That analysis found that 

the limited land available for the practice of traditional cultural activities within the San Juan Islands 

makes the availability of Monument lands particularly important to tribal interests. 

The No Action Alternative and Alternative D call for low levels of vegetation management, providing 

few opportunities for tribes to be involved in vegetation management activities, and not creating 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

205 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 environments conducive to many tribal uses. The Tribal Interests section concluded that the No Action 

Alternative and Alternative D would provide minimal benefits to plant communities important for many

traditional cultural practices. 

Therefore, the impacts to tribes under the No Action Alternative and Alternative D are considered 

disproportionately negative to tribes as an environmental justice population. 

Soils 

Key Point 

 The BLM should manage soils in all alternatives to maintain or achieve unimpaired function(s)

associated with their designated use(s).

 Under alternatives B and C, the magnitude and extent of short-term soil disturbances from vegetatio

management activities would be greater.

 Under alternatives B and D, more soils within the Monument may continue to have more limited

function due to the establishment and use of trails.

This section contains one analytical issue: 

1. How would the alternatives’ management of human uses and vegetation affect soil stability and

sediment-based water quality issues? (Page 206)

Soils Analytical Issue 1: How would the alternatives’ management of human 

uses and vegetation affect soil stability and sediment-based water quality 

issues? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

The great majority of the Monument is within San Juan County (see Table 2 on page 2). The BLM is 

using the U.S. Department of Agriculture’s Natural Resources Conservation Service’s (NRCS) soil data 

for San Juan County to describe soil types within the Monument. The San Juan Islands’ soils are 

primarily formed from glacial drift mixed with colluvium from metasedimentary bedrock, glacial drift, 

glacial drift over dense glaciomarine deposits. There are three dominant soil orders in the Monument;

Inceptisols comprise approximately 80 percent, while Mollisols and Alfisols comprise approximately 10

percent each. The soils in the San Juan Islands generally have a relatively warm soil temperature regim

and mixed (i.e., isotic) mineralogy. They are generally moist in the winter and dry in the summer with 

several smaller soil inclusions that are moist to wet for a majority of the year (NRCS 2016).58 For more 

information about soil orders within the Monument see the Soils section in Appendix E. 

Areas of highly erodible soils occur throughout the San Juan Islands. The NRCS categorizes soils by 

both their susceptibility to water erosion and their susceptibility to wind erosion. Areas with higher 

erosion potential ratings are more vulnerable to soil loss following vegetation removal or other ground 

disturbing activities unless mitigation measures are taken. 

The NRCS rates soils formed on steep slopes with grades of 30 percent or more and having textures of 

loam, silt loam, and some sands as having a high water erosion hazard rating (severe or very severe). 

Soils without exposure, those covered with vegetation, and non-erodible surfaces like rock, have lower 

water erosion hazard ratings. The NRCS rated approximately 67 percent of the Monument as having 

severe water erosion potential. It rated 25 percent of the Monument as having moderate water erosion 

potential (NRCS 2016). 

The NRCS categorizes soils into wind and hydrologic erodible groups, with the soils with the greatest 

susceptibility to wind erosion in Group 1, and the soils with the least susceptibility to wind erosion in 

Group 8. Wind erosion can result in the displacement or loss of topsoil, increased sediment deposition, 

and impacts to ambient air quality from elevated dust levels. Soils within the Monument range from 

 

58 The complete description of soils and conditions within the counties can be found at the Natural Resources 

Conservation Service’s Soil Survey Website: websoilsurvey.nrcs.usda.gov

2 

3 

4 

6 

7 

8 

9 

n

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

or

26 

27 

28 e 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

206 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Group 2 to Group 8, with most in Group 4 (NRCS 2016). Approximately 10 percent of the mapped lands 

are in Group 2 (NRCS 2016). 

Deep loamy soils are important features for wildlife, particularly for fossorial species (i.e., species that 

burrow) such as the Shaw Island Townsend’s vole. The majority of soils within the Monument are less 

than 36 inches in depth, which is relatively shallow compared to mainland soils described by the NRCS, 

which may exceed 60 inches in depth (NRCS 2016). Due to the soils’ glacial origin, there is a restrictive 

layer found at ten or fewer inches beneath the surface. The restrictive layer can impede movement of 

water, as well as some roots and animals, deeper into the soil. Some exposures of basalt have no 

overlying soil layer at all. These exposed basalt areas support a diversity of lichens, forbs, and mosses. 

Current impacts of human uses and Vegetation Management on Soils 

Visitation causes most current impacts to soils in the Monument, including where user created trails have 

worn very shallow soils (< 10.0 inches) down to bedrock. In a small number of cases associated with 

lighthouse properties, cement was historically used to surface trails (e.g., the “sidewalk” on Patos Island), 

which has provided exceptional hardening to the trail tread that protects the soils in that location. 

Trails with native surfaces on sandy (loamy) soil textures and on slopes greater than 30 percent are the

most vulnerable to chronic erosion. Approximately 20 percent of the existing 14.9 miles of trails in the 

Monument are in this category. Existing user created trails are distributed across the Monument with 

routes on headlands and small islands throughout the archipelago. Trail systems on the southern end of

Lopez Island constitute the majority of areas most prone to erosion. 

The BLM’s management of vegetation within the Monument is limited to the removal of hazard trees that 

pose a threat to safety or property and treatment of invasive plants through non-ground disturbing 

methods; these activities have very limited impacts on soils. Current weed control strategies have been to 

cut weeds before they go to seed, thus reducing the weed seed bank in the soil and minimizing soil 

disturbance at those sites. 

Soils within the Monument have substantial water holding capacity, because they are isotic and/or have 

substantial quantities of organic matter, which can hold approximately 80 percent of soil moisture. 

Where soil displacement has occurred, the soils and sediment generally remain on land rather than 

entering marine or freshwater aquatic environments. One exception to this is at Cattle Point on San Juan 

Island, where natural erosion of sandy soils has caused soil deposition in the surrounding coastal waters. 

Effects of the Alternatives 

Under all alternatives, the BLM would take mitigation measures to minimize soil loss on lands exposed 

through management actions (see Appendix F: best management practices). Regardless of mitigation 

measures, soil loss and compaction may occur through building, maintaining, and using trails, as well as 

through ground disturbance from vegetation management. See Appendix H for maps with specific 

locations of trails for each alternative.

Impacts from travel and transportation management on soils 

No Action Alternative 

Under the No Action Alternative, there would continue to be no travel network designated for public 

access in the Monument. The BLM would continue to maintain the current 0.9 miles of road in the 

Monument for authorized and administrative uses. The current network of 16 miles of primarily user 

created trail (including 0.6 miles on adjacent Coast Guard about which the BLM will provide 

recommendations) would also likely persist. Given recent trends (see Access and Visitor Use Issue 1), 

visitor use would likely increase and user created trails would continue to proliferate under the No Action 

Alternative. 

Additional user created trails would expose soils to more weather events and disturbance, which would 

lead to more erosion. A minimum of 7 acres (4 acres of road and 3 acres of trail), or 0.7 percent of the 

Monument would continue to be exposed to possible soil compaction and displacement from travel. All

trails would continue to be open to all non-motorized trail uses. Under the No Action Alternative, it

would be much more difficult to strategically manage these trail systems to mitigate soil loss and erosion. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

207 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Without management intervention, the transportation system under the No Action Alternative would have 

the greatest risk to soil function of any alternative.

Alternative A 

Under Alternative A, the BLM would continue to maintain 1 mile of road for authorized and 

administrative use at Point Colville, Watmough Bay, and Turn Point. This would result in the 

continuation of a total of 4 acres of potential soil disturbance from road use. Additionally, there would be 

no designated trails under Alternative A and the BLM would maintain trails only on an as needed basis 

for authorized and administrative purposes (e.g., to access areas for monitoring and maintenance 

activities). Assuming there would be no unauthorized use of undesignated routes, trail systems within the 

Monument would revegetate over time, thus reducing erosion across the Monument. Erosion of the most 

susceptible Monument soils would decrease dramatically compared with other alternatives. 

Alternative B 

Under Alternative B, the BLM would designate all existing roads (1 mile) for public motorized use. This 

would result in the continuation of a total of 4 acres of potential soil disturbance from road use. 

Additionally, the BLM would designate 20.3 miles of trail for hiking (including 0.9 miles the BLM would 

recommend for designation on adjacent Coast Guard land). This would include adding approximately 4 

miles to the existing network of trails, mainly on Chadwick Hill, Watmough Bay, Point Colville, Iceberg

Point, Kellett Bluff, and Patos Island. Soil function would be simplified within the footprint of the newly

developed trails, as the function would no longer support native plant communities and the biological

function and nutrient cycling capacity of the soils would be impaired on and adjacent to trail surfaces. 

In total, soil function on 9 acres, or 0.9 percent of the Monument, would be simplified and the soils would 

be more susceptible to displacement due to travel. A seasonal closure intended to minimize disturbance

to nesting seabirds would exist on 0.12 miles of trail, substantially reducing erosion potential for those

segments of trail.

Compared to the No Action Alternative it would be much easier to manage a designated transportation 

route and mitigate much of the erosion potential. 

Alternative C 

Under Alternative C, the BLM would designate 0.6 miles of existing road for public motorized use and 

maintain an additional 0.4 miles of existing road for authorized and administrative uses. This would 

result in the continuation of a total of 4 acres of potential soil disturbance from road use. In addition, the 

BLM would designate 12 miles of trail for hiking (including 0.7 miles the BLM would recommend for 

designation on adjacent Coast Guard land). Under Alternative C, the BLM would not develop new trail

segments (though it would reroute less than 0.1 miles of existing trail) and would eliminate 3.6 miles of

existing user-created trails. Equestrian use would continue to be allowed on 2.6 miles of these trails. 

Equestrian use would be limited to select trails on Chadwick Hill and Watmough Bay on Lopez Island 

that are low gradient and less susceptible to erosion. 

In total, soil function on 6 acres, or 0.6 percent of the Monument would be simplified and the soils would 

be more susceptible to displacement due to travel. A wet season closure would be implemented on 0.05

miles of trail for hiking use and 2.4 miles of trail for equestrian use, substantially reducing the potential

erosion on that mileage.

Compared to the No Action Alternative, it would be much easier to manage a designated transportation 

route and mitigate much of the erosion potential. 

Alternative D 

Under Alternative D, the BLM would designate 0.9 miles of existing road for public motorized use and 

maintain an additional 0.1 miles of existing road for authorized and administrative uses. This would 

result in the continuation of a total of 4 acres of potential soil disturbance from road use. In addition, 24.6 

miles of trail would be open to hiking and 8.4 miles would be open to equestrian use and bicycle use. 

This is the most extensive network of trails considered under any alternative. In addition to the trails 

designated in Alternative B, new trails would be designed on: Patos Island, Posey Island, Reeds Bay

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

208 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Island, Blind Island, Point Colville, Turn Point, President Channel, Victim’s Island, Cattle Point, Iceberg

Point, Chadwick Hill, Watmough Bay, Lummi Rocks, Carter Point, and Eliza Point. Except for a small

section of trail on Watmough Bay, these trails would not be on soils more prone to erosion. 

In total, soil function on 13 acres, or 1.3 percent of the Monument would be simplified and the soils 

would be more susceptible to displacement due to travel. Alternative D would have the largest designated 

transportation system of any action alternative and therefore would have the greatest potential to simplify

soil function and contribute to soil erosion of any alternative except the No Action Alternative. A wet

season closure would be implemented on 0.05 miles of trail for hiking use, 8 miles of trail for bicycle use, 

and 8.2 miles of trail for equestrian use, mitigating much of the potential for seasonal soil displacement. 

Compared to the No Action Alternative, it would be much easier to manage a designated transportation 

route and mitigate much of the erosion potential. 

Impacts from Vegetation Treatments on Soils 

The alternatives vary in the estimated extent of vegetation treatments needed to achieve objectives, as 

well as in the treatment types the BLM would allow. The BLM would determine the location, timing, and

type of treatments through additional project-level planning and NEPA compliance. Habitat and Plants 

Issue 6 discusses potential effects from herbicide treatments on soils. 

Descriptions of the potential impacts on soils from various vegetation treatments are summarized from the

Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic 

Environmental Report (BLM 2007b). Pages 4-11 through 4-18 of this document are summarized below 

and incorporated here by reference. 

Potential impacts on soils from vegetation treatments in general 

All vegetation treatments can potentially result in increased rates of erosion and reduced water 

infiltration, leading to reduced soil productivity. The risks of increased erosion within the Monument 

would depend on the type of treatment and the local site conditions. Increased erosion would potentially 

result in reduced soil quality and increased sedimentation in nearby bodies of water. Reestablishing 

vegetation on the site and maintaining organic matter at the soil surface (e.g., plant litter, forest duff, or 

mulch) would lower erosion rates. 

Vegetation removal would also contribute to a short-term reduction in water infiltration into soil. Soil 

compaction associated with some vegetation treatment methods could reduce infiltration and soil 

productivity by eliminating pore spaces used for water storage and air exchange. These effects would 

typically last until vegetation recovered at the treatment site. 

Potential impacts from mechanical and manual treatments 

Mechanical and manual treatments would affect soils by removing vegetation, by exposing or disturbing 

topsoil, and by compacting soils and affecting water infiltration. Because plant and litter cover protect the

soil, and roots hold the soil in place, removal of plant materials exposes soil, making them vulnerable to 

increased erosion and drying out. Laborers and equipment associated with treatments can cause soil 

disturbance and compaction at treatment sites. Mechanical and manual treatments can disturb soil, 

exposing soil organisms to desiccation and predation. 

Treatments involve pulling or cutting vegetation with non-motorized hand equipment or chainsaws, 

instead of heavier equipment, would have less direct effect on soil than treatments with heavier 

equipment. Limiting the number of people and the amount of time spent in each site would help 

minimize trampling for these treatments (Tu et al. 2001). 

Soil texture and morphology, site topography, and rainfall affect a soil’s response to mechanical and 

manual treatments. On sites that support coarse-textured soils with high infiltration rates, or clayey soils 

with low infiltration rates, some mechanical treatments could result in little change in infiltration rates. 

For most other soils, mechanical treatments that break up the soil surface and create furrows and ruts 

would increase water infiltration. Avoidance of mechanical treatments in windy areas with poorly 

structured soils would help to reduce loss of soil to wind erosion. Erosion can be prevalent on slopes 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

209 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 greater than 20 percent. In general, leaving vegetation residues on the soil surface, or mulching and 

spreading them after a mechanical or manual treatment, would help protect the soil surface. 

Potential impacts from prescribed fire 

Prescribed fire would primarily affect soils by consuming organic material including vegetative litter and 

cover and dead and down woody fuels. Depending upon the severity of the fire, changes would be 

beneficial or deleterious (Neary et al. 1999). Prescribed fire would help cycle soil nutrients and support 

the recovery of beneficial plant communities that improve soil function. Prescribed fire activities may 

also locally disturb soils by compaction, displacement, or causing an increase in water repellency from 

physical and chemical alterations (hydrophobicity). Compaction may occur from equipment operating in 

and around prescribed fire units. Displacement may occur from fireline construction or mop-up activities. 

Measurable physical and chemical soils alterations may occur in localized areas that experience more 

intense heat (170-200 °C) over longer durations. This could occur in larger piles or in larger 

concentrations of large diameter fuel (Debano 1981). Most of these undesirable effects would be 

mitigated through project design or occur in such small isolates that they would not adversely affect the 

overall function and integrity of soils at the treatment site. 

Potential impacts from biological treatments 

Biological treatments could involve containment by domestic animals (such as goats), insects, or 

pathogens. Biological control of vegetation using domestic animals would result in some effects to soil 

on public lands. The effects would be dependent on the type of animal used and the intensity and 

duration of the treatment in a particular area. 

The action of animal hooves would cause some disturbance, shearing, and compaction of soil, increasing 

its susceptibility to both water and wind erosion. Domestic animals could alter nutrient cycling processes 

in soil by depositing organic nitrogen in urine and feces. Following a planned vegetation management 

program can limit unintended effects by limiting the number and amount of time animals remain on any 

one site and using fencing and salt/nutrition blocks to restrict animals to treatment areas. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue its current very limited approach to vegetation 

treatments. Manual and mechanical treatments would continue to be limited to removal of hazard trees 

and non-ground disturbing treatment of invasive plants. Assuming current trends continue there would be 

no prescribed fire, biological, or herbicide treatments. Although localized effects to soil could occur, the 

effects of the current level of manual and mechanical treatments on soils are likely to be negligible due to

their very small size (approximately than 20 acres per year). This would result in the fewest direct effects 

to soils from vegetation treatments throughout the Monument. However, invasive plants would continue 

to propagate and replace native plant communities, increasing the long-term potential of impaired soil

function and simplification.

Alternative A 

Under Alternative A, the BLM would continue to undertake very limited vegetation treatments. The 

BLM estimates that approximately 650 acres of mechanical or manual treatment (i.e., an average of

approximately 35 acres per year) and 390 acres of biological treatments (i.e., an average of approximately

20 acres per year) would occur during the life of the plan. In some cases, these treatments would take 

place on the same acres (e.g., the BLM might follow up a biological treatment with a mechanical or

manual treatment in the same area). The BLM would prohibit prescribed fire and herbicide use under this 

alternative. Although localized effects to soils of the types described above could occur, the effects of

these treatments on soils are likely to be minimal and short-term due to their small size. This alternative 

would have the fewest direct effects to soils from vegetation treatments of any of the action alternatives. 

However, without the use prescribed fire and chemical treatments (e.g., herbicides) the success of

establishing native plant communities and restoring biological soil functions would be diminished.

Alternative B 

Under Alternative B, the BLM—likely working with tribes and other partners—would undertake 

extensive vegetation treatments in the Monument. The BLM estimates that approximately 5,930 acres of

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

210 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

mechanical or manual treatment (i.e., an average of approximately 300 acres per year) , and 1,500 acres of

biological treatments (i.e., an average of approximately 75 acres per year) , and 1,700 acres of prescribed 

fire (i.e., an average of approximately 85 acres per year) would occur during the life of the plan. In many

cases, multiple acres of treatment would take place on the same acres of land (e.g., the same acre could 

undergo mechanical or manual treatments before and after a prescribed fire) . 

Potential for direct effects to soils would be substantially more than under the No Action Alternative and 

alternatives A and D, but somewhat less than under Alternative C and Sub-Alternative C. The vegetation 

treatments proposed under Alternative B would establish a long-term trajectory that would have the 

potential to improve biological soil function and nutrient cycling through the establishment and 

maintenance of native plant communities on areas receiving treatments.

Alternative C 

Under Alternative C, the BLM—likely working with tribes and other partners—would undertake 

extensive vegetation treatments in the Monument. The BLM estimates that approximately 7,930 acres of

mechanical or manual treatment (i.e., an average of approximately 400 acres per year) , and 2,450 acres of

biological treatments (i.e., an average of approximately 120 acres per year) , and 3,520 acres of prescribed 

fire (i.e., an average of approximately 180 acres per year) would occur during the life of the plan. In 

many cases, multiple acres of treatment would take place on the same acres of land (e.g., the same acre 

could undergo mechanical or manual treatments before and after a prescribed fire) . 

Potential for the direct effects to soils would be substantially more than under the No Action Alternative 

and alternatives A and D, somewhat more than under Alternative B, and somewhat less than under SubAlternative C. The vegetation treatments proposed under Alternative C would establish a long-term

trajectory that would have the greatest potential to most reliably improve biological soil function and

nutrient cycling through the establishment and maintenance of native plant communities. 

Sub-Alternative C 

The BLM would prohibit chemical treatments (e.g., herbicides) under Sub-Alternative C. Because of this 

prohibition, the BLM estimates that it would need a high very high repetition rate of mechanical and 

manual treatments to achieve the Sub-Alternative C objectives. The BLM estimates that approximately

28,320 acres of mechanical or manual treatment (i.e., an average of approximately 1,415 acres per year) . 

In many cases, multiple acres of treatment would take place on the same acres of land (e.g., the BLM

might remove woody shrubs and apply native plant restoration in the same area) . This would result in the 

greatest potential impact to soils from vegetation treatments of any alternative. 

Alternative D 

Under Alternative D, the BLM would undertake vegetation treatments as needed to maintain 

approximately the current vegetation conditions in the Monument. The BLM estimates that

approximately 810 acres of mechanical or manual treatment (i.e., an average of approximately 40 acres

per year) and 50 acres of prescribed fire (i.e., an average of approximately 3 acres per year) would occur

during the life of the plan. While the BLM would allow biological treatments under this alternative, it

estimated that this treatment type would not be necessary for meeting the objectives of this alternative. In 

some cases, these treatments would take place on the same acres (e.g., the same acre could undergo 

mechanical or manual treatments before and after a prescribed fire) . 

Potential direct effects to soil function, described above, would be somewhat more than under the No 

Action Alternative and Alternative A, and substantially less than under alternatives B, C, and sub-C. 

Alternative D would achieve fewer long-term benefits, over a smaller area, for biological soil function 

and nutrients in comparison to alternatives B and C. 

Conclusion 

The BLM’s management of the Monument would have the fewest direct impacts to soil resources under

Alternative A, due to limitations on access and vegetation management. However, alternatives B and C 

are likely to have the greatest long-term benefits to soils resources by increasing soil biodiversity through 

more extensive vegetation management and a comprehensive invasive weed management strategy. 

211 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Cumulative Effects of the Alternatives on Soils 

Anticipated population growth and increases in tourism in San Juan County and Washington State are 

likely to drive additional land development and support the continued propagation of invasive plants that 

will simplify soil function and reduce soil biodiversity (U.S. Census Bureau, 2015; Decaëns et al, 2006). 

Cumulative effects to soil function from management or visitor use vary by alternative. Extensive 

vegetation management and subsequent maintenance under alternatives B and C have the highest 

potential of generating chemical, physical, and biological soil responses, which over time, have a greater 

potential to provide function and habitat that may be diminishing on other lands across the county and 

state. Alternatives with fewer options for vegetation management (No Action Alternative and alternatives 

A and Sub-C) or without ambitious vegetation restoration objectives (No Action Alternative and 

alternatives A and D) would have less potential for soils within the Monument to contribute to 

increasingly scarce ecosystem services. 

Continuation of all or parts of the existing trail system will contribute to the trend of soil simplification 

that is likely to occur across San Juan County with population and land use increases. Under the action 

alternatives, the designation and maintenance of trail systems may help to mitigate persistent impacts to 

soil resources that would otherwise receive less effective management under the No Action Alternative. 

Due to the small size of the Monument, the effects of all alternatives when combined with existing and 

anticipated effects to soils resources at a county-scale are very small and the ecological significance of 

those effects are most relevant at the site scale. 

Special Designations 

Key Points 

 The BLM designed the alternatives to meet the purpose and need of the planning effort to protect the

objects and values for which the Monument was designated, many of which overlap with the values

the BLM determined to meet the ACEC manual’s definition of relevance and importance.

 The existing ACEC would continue to apply to 503 acres on the south end of Lopez Island only under

the No Action Alternative.

 The No Action Alternative and alternatives B, C, and D all provide some level of support for the

Cascadia Marine Trail. 

 Under all alternatives, the Monument would provide at most a small percent of the designated

campsites associated with the Cascadia Marine Trail.

This section contains two analytical issues: 

1. How would the alternatives affect areas of critical environmental concern within the Monument?

(page 212)

2. How would the alternatives affect the extent and experience of using the Cascadia Marine Trail?

(page 213)

For information on the differences between congressionally or presidentially established special 

designations and ACEC criteria see the Special Designations section of Appendix E. 

Special Designations Analytical Issue 1: How would the alternatives affect 

areas of critical environmental concern within the Monument? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

There are two ACECs within the Monument. The Iceberg Point and Point Colville Areas of Critical

Environmental Concern Decision Record (BLM 1990) designated the BLM-administered lands at Iceberg 

Point and Point Colville as ACECs; the BLM later extended the decisions in this document to Watmough 

Bay and Chadwick Hill after the agency’s acquisition of these areas. The acreage managed under the 

1990 ACEC decisions now total approximately 503 acres. The BLM designated the current ACECs to 

preserve their “natural values.” Neither the decision document nor the analysis documents associated 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

212 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

with the ACECs discuss relevant and important values or provide details on the natural values for which 

the areas were designated (BLM 1988a, BLM 1990). 

Effects of the Alternatives 

No Action Alternative 

The 1990 ACEC decisions provided management direction that helped protect the BLM-administered 

lands on Lopez prior to the designation of the Monument in 2013. The designation of the Monument 

broadened and made permanent the protection of the area’s special objects and values. 

Under the No Action Alternative, the existing ACEC would continue to apply to 503 acres on the south 

end of Lopez Island (Iceberg Point, Point Colville, Chadwick Hill, and Watmough Bay). The 1990 

ACEC decisions would remain in place to protect these areas’ “natural values.” The content of those 

decisions can be found in Appendix D. 

Alternatives A, B, C, D 

Under these alternatives, the BLM would not designate any ACECs. The BLM planning team determined 

that the alternatives considered in the Draft RMP/EIS, which all meet the purpose and need for the 

planning effort, would protect the area’s relevant and important values (see Appendix C). Since the 

values do not require special management to protect them from the potential effects of actions permitted 

by the alternatives, the action alternatives do not include ACECs. The BLM designed the alternatives to 

meet the purpose and need of the planning effort to protect the objects and values for which the 

Monument was designated, many of which overlap with the area’s relevant and important values. 

Conclusion 

ACECs would occur within the Monument only under the No Action Alternative. However, relevant and 

important values would be protected under all alternatives (see Appendix C). 

Special Designations Analytical Issue 2: How would the alternatives affect 

the extent of the Cascadia Marine Trail? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

The Monument has two sites associated with the Cascadia Marine Trail: Blind Island and Posey Island, 

which have four and two campsites respectively. The BLM co-manages camping at these sites with 

Washington State Parks. Camping at these sites is open only to those who arrive by human or wind 

powered watercraft. The seven campsites located at Patos Island support the Cascadia Marine Trail by 

providing boat-accessible camping opportunities, but are not officially designated as part of the trail. 

The Secretary of the Interior designated the Cascadia Marine Trail as a National Recreation Trail in 1994; 

it was recognized as one of 16 national millennium trails in 1999. The trail encompasses a network of 

sites—which visitors can access by following an array of possible routes—extending from Olympia, 

Washington, up through Puget Sound and the San Juan Islands to the British Columbia border. It 

currently includes 66 associated campsites and 160 associated day use sites. An array of Tribal, Federal, 

State, and local agencies manage these sites. Washington State Parks, as the trail's lead agency, and the 

Washington Water Trails Association provide direction and/or assistance to the managing entities. 

Effects of the Alternatives 

No Action Alternative 

Under the No Action Alternative, there would continue to be camping in six designated sites at Blind and 

Posey Island along the Cascadia Marine Trail. The seven campsites as Patos Island would continue to 

support the Cascadia Marine Trail as a day-use area and by providing boat-accessible camping. Given 

current recreation trends, there would continue to be high levels of visitation and camping at these sites 

during the summer. 

Alternative A 

Under this alternative, the BLM would facilitate use of the Monument for authorized research, 

educational, cultural, and spiritual activities, but not for recreation. As a result, no acres of Monument 

5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

213 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 land would be available for recreation to support the Cascadia Marine Trail. This would remove the six 

designated sites at Blind and Posey Island along the Cascadia Marine Trail. This would also remove the 

seven campsites located at Patos Island that support the Cascadia Marine Trail. Under this alternative, 

there would be minor effect to visitors seeking a human powered watercraft designated camping 

experience as part of the Cascadia Marine Trail and would have a minor effect on other Cascadia Marine 

Trail designated campsites along the 160-mile water trail. 

Alternative B and C 

Under alternatives B and C, there would continue to be camping in six designated sites at Blind and Posey 

Island along the Cascadia Marine Trail. The seven campsites as Patos Island would continue to support 

the Cascadia Marine Trail as a day-use area and by providing boat-accessible camping. Under these 

alternatives, the BLM would not designate additional camping sites to support the Cascadia Marine Trail. 

Given current recreation trends, there would continue to be high levels of human powered watercraft 

visitors participating in this activity during the summer. 

Alternative D 

Under Alternative D, there would continue to be camping in six designated sites at Blind and Posey 

Island along the Cascadia Marine Trail. The seven campsites located at Patos Island would continue to 

support the Cascadia Marine Trail as day-use areas and provide camping opportunities although these 

sites are not officially designated Cascadia Marine Trail sites. 

Under this alternative, the BLM would allow designated site camping on an additional 221 acres of 

Monument land. This would approximately double the current Monument acres open to designated site 

camping. The BLM would determine specific locations for new designated sites during plan 

implementation; this would involve a separate project level planning and NEPA compliance process prior 

to any on-the-ground disturbance. The BLM would only allow camping in these areas after the 

completion of the project level planning to designate sites. These sites support the Cascadia Marine Trail 

and would be open only to visitors arriving via non-motorized watercraft. Given the popularity of current 

designated site camping opportunities in the San Juan Islands, it is likely that visitor use of these sites 

would be high. 

Conclusion 

The Monument would continue to provide 9 percent of the total number of designated campsites available 

to support the Cascadia Marine Trail in the No Action Alternative and alternatives B and C. Under 

Alternative A, the BLM would limit access to Monument lands and remove the existing opportunities 

supporting the Cascadia Marine Trail at Blind and Posey Islands and to a lesser degree at Patos Island. 

Under Alternative D, the BLM would develop new designated sites supporting the Cascadia Marine Trail 

over the life of the plan. Alternative D would provide the greatest contribution of any alternative to the 

Cascadia Marine Trail. Under all alternatives, Monument lands would continue to have an overall minor 

effect on other Cascadia Marine Trail designated campsites along the 160-mile water trail. 

Cumulative effects on designated site camping opportunities to support the 

Cascadia Marine Trail in the San Juan Islands 

The alternatives would vary in their incremental impact on the supply of camping opportunities 

supporting the Cascadia Marine Trail. Since the designation of the trail in 1994, 66 associated campsites 

and 160 associated day use sites have been added to the Cascadia Marine Trail. An array of entities 

manages these associated sites, including Tribal, Federal, State, and local agencies. The BLM is not 

aware that any public land managers in the San Juan Islands are currently planning any substantial 

expansions or reductions in camping opportunities. 

Under the No Action Alternative and alternatives B and C, the Monument would continue to provide 9 

percent of the total number of designated campsites associated with the Cascadia Marine Trail. 

Under Alternative A, the Monument would not provide camping or day use areas available for those 

exploring the Cascadia Marine Trail; this would represent a 9 percent decrease in campsites available 

along the trail. Given the high level of current participation in camping in these areas, this would likely 

create additional competition for remaining sites along the trail. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

214 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 

2 

3 

4 

Under Alternative D, the BLM’s contribution of designated campsites supporting the Cascadia Marine 

Trail would increase over the life of the plan. This would increase the trail’s capacity for visitors and 

potentially alleviate visitor pressure on existing sites. It could also allow trail visitors to access portions 

of the San Juan Islands that currently do not have safe and available camping. 

Tribal Interests 

Key Points 

 There are diverse tribal interests related to the Monument, including interests in the protection of

cultural sites, accessing the Monument for traditional cultural practices and the exercise of treaty

rights, and the availability of plants and wildlife for various tribal uses.

 Under all alternatives, the BLM would work with tribes to facilitate traditional activities and the

exercise of tribal treaty rights.

 Alternative A would have the least potential for disturbance and loss of cultural sites.

 Alternatives B, C, and Sub-Alternative C would most enhance habitat for culturally important plants

such as camas.

This section contains one analytical issue: 

1. How would the alternatives affect tribal interests and activities? (Page 215)

Background 

Proclamation 8947 describes the use of the San Juan Islands by native peoples dating back to the end of 

the last glacial period. Archaeological resources associated with this long-standing use of the land are an 

object of scientific or historic interest for which the Monument was designated, as are some of the 

vegetative communities, including fire-managed grasslands and areas (remnant cultural-historical 

“gardens”) of Great Camas. In addition, the proclamation states: “Nothing in this proclamation shall be 

deemed to enlarge or diminish the rights of any Indian tribe. The Secretary shall, in consultation with 

Native American tribes, ensure the protection of religious and cultural sites in the Monument and provide 

access to the sites by members of American Indian tribes for traditional cultural and customary uses, 

consistent with the American Indian Religious Freedom Act (42 USC 1996) and Executive Order 13007 

of May 24, 1996 (Indian Sacred Sites).” 

Native American/ Coast Salish Peoples have occupied the region for more than 10,000 years, utilizing

lands in the San Juan Islands for hunting, fishing, plant gathering, trade and exchange, and other cultural, 

social, and religious activities. Many of these activities occurred within the Monument. 

Tribal Interests Analytical Issue 1: How would the alternatives affect tribal 

interests and activities? 

See Appendix B for analytical methods used in this analysis. Impacts from shoreline stabilization on 

cultural sites are analyzed under Cultural Resources Issue 1. 

Affected Environment 

Habitat for fish, wildlife, and plants of traditional cultural value to the tribes occur on public lands and 

waters within the San Juan Islands, including within the Monument. Habitats supporting wildlife species 

that tribes traditionally hunted, gathered, or fished, and that support culturally important plants gathered 

for subsistence, medicinal, ceremonial practices, and other uses are available for access and use on public 

lands. The BLM is aware that marine shorelands and tidelands were important and extensively used by 

tribes for subsistence and cultural purposes. However, the specific locations of traditional use in the 

Monument are largely unknown to the BLM. Identification of traditional uses or properties of traditional 

cultural and religious importance is an ongoing process addressed during consultation between the BLM 

and tribes and is often specific to individual tribes or groups. 

Tribes have identified several locations that are culturally important for gathering of traditional resources, 

particularly plants, on lands in the Monument. However, the BLM may be unaware of many traditional 

resource procurement locations and their ongoing use. Traditional root gathering, a critical resource for 

ancestral peoples living near the Salish Sea, continues to be important to the tribes for its nutritional 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

215 
5

10

15

20

25

30

35

40

45

50

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

values and the added benefit of perpetuating tribal traditions. Root gathering locations, often passed 

down through families, continue to be used in many areas. Tribal members are no longer able to collect 

roots in traditional locations when access is restricted or prohibited or environmental changes, particularly 

those resulting from land use practices, alter the root grounds. In addition to plant gathering areas, tribes 

may consider many other sites culturally and traditionally important, including village sites, fishing 

stations, graves, prayer sites, pictographs, petroglyphs, talus/cache pits, rock cairns and alignments, and 

various other sites. 

Various roots, bulbs, berries, seeds, and nuts are important components of the traditional diet. In addition 

to fruits and berries, a variety of traditional roots and bulbs occur within the Monument. 

Habitats within and adjacent to the Monument support larger terrestrial species important to subsistence 

and traditions. These include deer and numerous smaller mammals, along with traditional marine 

subsistence resources, such as salmon, halibut, cod, shellfish, marine mammals, and birds. Access to 

Puget Sound through Monument lands is available for exercise of tribal fishing rights and interests, but

specific locations of ongoing traditional use for fishing related activities are, with few exceptions, 

unknown to the BLM. BLM management may indirectly affect nearshore habitat and wildlife below

mean high-tide, though they are outside of the BLM’s jurisdiction, which ends at mean high tide. 

Tribes have not formally identified to the BLM sacred sites or specific locations of ongoing ceremonial or

religious practices within the Monument. This might be due in part to the culturally sensitive nature of

the values at those locations or the practices or ceremonies conducted. The BLM is unaware of Coast

Salish sacred sites or locations of ceremonial or religious practices that may occur within the Monument.

Effects of the Alternatives 

The alternatives vary in their potential effect on the integrity of sites, locations, and resources identified as 

important to one or more tribe for cultural continuity, Indian trust assets, or as being integral to treatybased rights or responsibilities. They vary in the potential for vegetation management and recreational 

activities to disturb sites and activities of traditional importance. They also vary in the extent that they 

would benefit plants and wildlife associated with traditional subsistence use. Restrictions on the 

discharge of firearms would not apply to tribal members using firearms for the purposes of hunting. 

Management of wildlife species of concern (i.e., potentially harmful wildlife) could affect culturally 

important plants and animal species important for traditional uses (Arcese et al. 2014). The effects of the 

BLM potentially engaging with other agencies to manage wildlife species of concern are described under 

Wildlife Issue 4. 

Under all alternatives, the BLM would collaboratively engage with tribal government partners to facilitate 

traditional uses and the exercise of treaty rights, develop opportunities for co-stewardship of plant 

communities and culturally important plant species, engage tribal youth and elders, and maintain and 

improve access for exercise of treaty rights and traditional cultural practices. Through engagement with 

the tribes, BLM would foster programs to enrich opportunities for tribal cultural, spiritual, and 

educational activities including projects to restore Salish place names within the Monument. 

The effects of tools available to protect cultural sites from shoreline erosion are described under Cultural 

Resources Issue 1. 

Impacts from Recreation 

Objectives for recreation include protecting the Monument’s objects and values from damage, alteration,

or loss due to visitation. Under all action alternatives, several recreational activities that could disturb, 

damage, alter or destroy important objects and values of cultural importance for which the Monument 

was designated would be prohibited. The BLM would undertake temporary closures as necessary to 

protect the Monument’s ecological and cultural values, as well as sensitive tribal activities. Recreational 

use would vary by alternative but access for tribal use and exercise of treaty rights would continue under 

all alternatives. Opportunities for solitude and quiet would continue to be available at certain times and 

seasons in the Monument under all alternatives. 

Recreational use and access that affects the integrity of a site, location, or resource identified as important 

to one or more tribe for cultural continuity, an Indian trust asset, or as integral to a treaty-based right or 

216 
5

10

15

20

25

30

35

40

45

50

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

responsibility can impact tribal treaty rights and interests. Recreational use and access can impact cultural 

sites through disturbance, soil compaction, altered surface water drainage, erosion, intrusions to the 

setting, and access leading to unauthorized collection or vandalism. These effects can result in a loss of 

site integrity and associated cultural values. 

In addition to creating potential for the disturbance or destruction of cultural sites, recreational use can 

interfere directly with the exercise of treaty rights and traditional cultural uses and practices (e.g., hikers 

could inadvertently interfere with traditional ceremonies and the setting in which it takes place). 

Recreational activities can cause visual and aural intrusions to the cultural or natural setting in which 

spiritual or other traditional practices are taking place. Some visual and aural impacts could be reduced or 

prevented in instances where tribes request that the BLM undertake a temporary closure of an area for the 

duration of a traditional activity. The BLM would consult with tribes to identify activities that may affect 

suitability of an area for traditional activities and the exercise of tribal treaty rights. 

In addition to affecting the experience and setting for traditional practices, recreational use and access can 

also effect opportunities to exercise treaty-protected activities by disturbing cultural resource values and 

settings (e.g., trampling native plant communities or disturbing cultural resources). Repeated use in an 

area can compact soil, increase erosion, and introduce invasive species that alter cultural settings and 

important plant communities for traditional plant gathering. Even where land managers require visitors to 

remain on trails, repeated visits to locations can create new social trails, leading visitors to or across sites 

of traditional or cultural importance. Opening areas to new or increased access and use can increase risk 

to previously undisturbed and fragile resources from intentional or unintentional damage and loss. 

Camping could permanently impact traditional cultural values through direct disturbance of site structure, 

soil compaction, altered surface water drainage, erosion, creation of new routes, and visual and aural 

intrusions to the setting. Regulating or restricting camping and recreational use can reduce the potential 

for impacts to cultural sites by controlling the amount and location of activities in areas with sensitive 

resources. Restricting camping to designated sites would concentrate impacts to those locations and 

reduce the risk of disturbing traditional cultural resources and values located outside of designated 

campsites though impacts from camping would still occur. Prohibiting camping or restricting it to 

designated campsites and would reduce the risk of impacts to cultural resources and tribal interests from 

these activities, if access for cultural purposes including exercise of treaty rights can be maintained and 

cultural site protections are implemented and maintained. 

Under all alternatives, the BLM would address potential impacts to cultural resources and tribal interests 

at the design or implementation phase of future projects through consultation with affected tribes along 

with National Historic Preservation Act Section 106 review. Consultation with tribes regarding tribal 

interests and potential impacts from proposed projects would be complimentary to Section 106 review 

and compliance. The BLM, in consultation with affected tribes and in consideration of tribal interests and 

treaty rights, would avoid, minimize, or mitigate potential impacts on historic properties and other 

cultural resources. Consultation and identification of potential impacts to tribal interests prior to project 

implementation would reduce potential adverse impacts. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue to manage the Monument to support 

recreational activities and visitor needs. Approximately 14.9 miles of existing trails in the Monument 

would continue to be open to non-motorized travel. If current trends continue, visitors would use these 

trails almost exclusively for hiking, with a small amount of equestrian use on Lopez Island. Overland 

hiking would continue and trail miles in the Monument’s more accessible grasslands and shrublands, such 

as at Iceberg Point and Cattle Point, would likely increase over time. 

Use of the trails would continue to have direct short-term and long-term impacts on cultural sites and 

other cultural properties crossed or accessed by trails, through soil compaction, erosion via channeling of 

water, and widening of trails during wet periods. Currently, 76 percent (19 sites) of the Monument’s

recorded cultural sites are within 164 feet of roads and trails. Under this alternative, measures to reduce 

impacts to sites would continue but the potential for impacts would grow if visitation continues to 

217 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 increase over time. Increased visitation could contribute to increased disturbance to cultural and natural 

resource sites and increased intrusion into locations for traditional and cultural practices. 

Dispersed camping would continue within the Monument except where prohibited by the current ACEC 

decisions covering Chadwick Hill, Iceberg Point, Point Colville, and Watmough Bay. Twenty-two 

recorded cultural sites would continue to occur within areas open to camping. This alternative would 

include the potential for dispersed camping in 66 acres of grassland potentially associated with traditional 

plant gathering, including locations at Cattle Point, Kellett Bluff, Turn Point, McConnell Rocks, and 

Lummi Rocks. If current recreation patterns continue, participation in this activity would remain 

relatively low. Camping in existing designated sites would continue. Approximately half of the recorded 

cultural sites within the Monument occur in or near designated camping areas. 

Alternative A 

Under Alternative A, the BLM would facilitate use of the Monument for authorized research, and 

educational, cultural, and spiritual activities. The BLM would not designate any of the potential RMAs 

under Alternative A and would prohibit recreation on Monument lands. This alternative would minimize 

impacts to cultural sites and traditional use from visitor use to a greater extent than any other alternative. 

Traditional uses of cultural properties would continue and potentially increase over the life of the plan. 

The impacts from recreation described under the No Action Alternative would not continue under this 

alternative, though impacts from access for administrative and authorized uses would continue. Because 

there would be many fewer visitors on the Monument under this alternative, and the BLM would 

authorize uses, the BLM expects fewer and less severe impacts to cultural resources under this alternative. 

The BLM would continue to maintain roads and trails for authorized and administrative uses. Impacts 

from road and trail use and maintenance for authorized uses would continue but would be less than under 

all other alternatives. 

There would be fewer opportunities to inform, educate, and engage the visiting public about tribal 

heritage and the important natural and cultural values associated with the Monument. Opportunities for 

the exercise of treaty rights and traditional and cultural practices requiring solitude and quiet would 

increase and tribal enrichment programs and engagement would likely increase due to the reduction in 

potential conflicts from visitor uses under this alternative. 

Alternative B 

Under Alternative B, the BLM would designate all potential RMAs except Category A and B Rocks. All 

but 10 acres of the Monument would remain open to recreational use. The impacts from recreation 

described under the No Action Alternative would not continue at sites closed to recreational use, though 

minor impacts from administrative and authorized uses would continue. To provide opportunities for 

solitude and quiet, 168 acres of the Monument would be open for recreation by permit only, which would 

reduce impacts by controlling the amount of recreation allowed in those areas. As in alternatives C and 

D, all 25 recorded cultural sites would be within designated RMAs in this alternative. 

The BLM would designate 19.3 miles of trail for hiking under this alternative, a 27 percent increase 

compared to existing trail miles. This would include 5.2 miles of new trails in areas previously without 

trails increasing the potential for short-term and long-term direct and indirect impacts to cultural sites and 

areas of traditional cultural use. Authorizing new trail routes would increase potential impacts to cultural 

sites and areas for traditional cultural uses. The BLM would consult with affected tribes and conduct 

cultural resource surveys of the proposed designated trail routes prior to implementation. Rerouting trails 

to avoid cultural sites and places important for traditional cultural practices would reduce potential 

impacts to tribal interests. Limiting visitor use to designated trails except for authorized purposes would 

reduce impacts to cultural sites and places important for traditional cultural practices. 

Under this alternative, there would continue to be designated site camping in existing sites only. RMAs 

with designated sites would include 13 known cultural sites, approximately half of the recorded sites in 

the Monument. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

218 
5

10

15

20

25

30

35

40

45

50

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Approximately 726 acres would be open to dispersed camping with a permit, including the locations of 

nine recorded cultural sites. To provide opportunities for quiet and solitude when camping, permits 

would be limited to one group per night per location with no more than five campers. The BLM would 

reduce these impacts by not issuing permits for dispersed camping where adverse impacts to cultural and 

traditional sites would occur. When developing the permitting system during plan implementation, the 

BLM would consult with affected tribes and conducting cultural resource surveys of the areas proposed 

for dispersed camping and avoiding cultural sites and values that would be adversely affected would 

reduce potential impacts to tribal interests. 

The BLM would prohibit all camping on 78 acres of the Monument, including the locations of six cultural 

sites. This would prevent impacts from camping to 24 percent of sites, as well as to places within these 

RMAs important for traditional cultural activities or other tribal interests. 

Under this alternative, the BLM would allow educational and interpretive signs at trailheads and landing 

areas only. Compared to alternatives C and D, where the BLM could place educational and interpretive 

signage in locations throughout the Monument, there would be fewer opportunities to inform, educate, 

and engage the public about tribal heritage and the important natural and cultural values associated with 

the Monument. 

Alternative C 

Under Alternative C, the BLM would designate all potential RMAs except for Category B Rocks. All but 

7 acres of the Monument would remain open to recreational use. The number of known cultural sites 

located within RMAs would be similar to Alternative B. Category B Rocks reportedly receive minimal 

visitation so this closure would likely have minimal effect on cultural or natural resources for those areas. 

The BLM would also manage 3 acres of the Monument (Category A Rocks) as open for recreation by 

permit only, which would reduce potential impacts to cultural resources by controlling the amount of 

recreation allowed in those areas. As in alternatives B and D, all 25 recorded cultural sites would be 

within designated RMAs in this alternative. 

The BLM would designate 11.3 miles of trail in the Monument for hiking; 3.5 of these miles would also 

be open to equestrian use. The BLM would close 3.6 miles of existing trail. The number of recorded 

cultural sites near to or crossed by trails (19) would be similar to the No Action Alternative. Trail miles 

in this alternative would decrease by 25 percent from the current route network. The BLM would consult 

with affected tribes and conduct cultural resource surveys of the proposed designated trail routes prior to 

implementation. Rerouting trails to avoid cultural sites and places important for traditional cultural 

practices would reduce potential impacts to tribal interests. Limiting visitor use to designated trails 

except for authorized purposes would reduce the potential for impacts to cultural sites and places 

important for traditional cultural practices. With the exception of Alternative A, the BLM would expect 

this alternative to reduce more impacts from recreation to cultural sites or places of importance for 

traditional cultural activities than the other alternatives. 

Under this alternative, the BLM would allow camping only in existing designated sites only. RMAs with 

designated sites would include 13 known cultural sites, approximately half of the recorded sites in the 

Monument. Impacts to cultural sites and potentially places important for traditional cultural uses would 

continue to be concentrated at those locations. 

Under Alternative C, the BLM would close 799 acres within the Monument to camping. This would 

prevent impacts from camping to approximately half of the recorded cultural sites in the Monument, as 

well as to places within these RMAs important for traditional cultural activities or other tribal interests. 

Opportunities to inform, educate, and engage the public about tribal heritage and the important natural 

and cultural values associated with the Monument would be increased under this alternative and 

Alternative D, because educational and interpretive signage could be placed in locations throughout the 

Monument as necessary. The BLM could develop new visitor facilities through implementation-level 

planning and NEPA compliance. Development of educational and interpretive signs and visitor facilities 

focusing on tribal history and enrichment (e.g., a longhouse) could benefit tribal interests by informing 

and enhancing the public’s understanding of the tribal heritage associated with the Monument. 

219 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative D 

Under Alternative D, the BLM would designate all potential RMAs. All areas within the Monument 

would be open to recreational use without a permit except for organized and commercial and competitive 

groups. As in alternatives B and D, all 25 recorded cultural sites would be within designated RMAs in 

this alternative. Opportunities for traditional and cultural practices requiring quiet and solitude likely 

would decrease under this alternative and conflicts with recreational activities would likely affect tribal 

enrichment programs and engagement. 

The BLM would designate 23.4 miles of trail in the Monument for hiking; approximately 8 of these miles 

would be open to equestrian and bicycling use. Overall, trail miles in the Monument would increase by 

54 percent under this alternative. The BLM would close 0.5 miles of trail existing trail and would 

develop 8.8 miles of new trails; it would widen 0.2 miles of existing trail. Similar to Alternative B, roads 

and trails in Alternative D would cross 23 recorded cultural sites in the Monument. The BLM expects 

that development of approximately 8.8 miles of new trails to result in at least an 18 percent increase in the 

number of recorded sites crossed by trails within the Monument. The BLM would consult with affected 

tribes and conduct cultural resource surveys of the proposed designated trail routes prior to 

implementation. Rerouting trails to avoid cultural sites and places important for traditional cultural 

practices would reduce potential impacts to tribal interests. The acreage of recorded cultural sites crossed 

by roads and trails would be highest in this alternative; it would be slightly higher (3 percent) than 

Alternative B and approximately 30 percent higher than the No Action Alternative. 

As under all alternatives except for Alternative A, the BLM would continue to allow camping in 

designated sites at Blind, Patos, and Posey islands. Under this alternative, the BLM could develop new 

sites in these RMAs. The BLM would also designate an additional 221 acres of Monument land as open 

to designated site camping. In total, approximately 80 percent (20 sites) of all recorded cultural sites in 

the Monument would be in RMAs open to designated site camping. Authorizing new designated 

camping areas and visitor facilities would concentrate recreational activities in new locations and result in 

additional potential impacts to cultural sites and places important for traditional cultural uses. The BLM 

would identify specific locations for new designated sites and associated visitor facilities during plan 

implementation. The BLM would consult with affected tribes and conduct cultural resource surveys as 

part of the implementation-level planning process to identify new designated campsites. Locating 

campsites to avoid cultural sites and places important for traditional cultural practices would reduce 

potential impacts to tribal interests. 

The BLM would allow dispersed camping on 167 acres of Monument land currently open to this use and 

on 370 acres of land currently closed to this use at Chadwick Hill and Point Colville. Opening areas 

currently closed to dispersed camping would increase the potential for long-term and direct impacts to 

cultural resources and places important for traditional cultural uses in these areas. Under Alternative D, 

RMAs open to dispersed camping would include six recorded cultural sites. The BLM would close the 

remainder of the Monument (49 acres) to camping. This would prevent adverse impacts from camping to 

two recorded cultural sites, as well as to places within these RMAs that are important for traditional 

cultural activities or other tribal interests. 

Opportunities to inform, educate, and engage the public about tribal heritage and the important natural 

and cultural values associated with the Monument would be increased under this alternative and 

Alternative C, because educational and interpretive signage could be placed in locations throughout the 

Monument as necessary. The BLM could also develop new visitor facilities through implementationlevel planning and NEPA compliance. Developing educational and interpretive signs and visitor facilities 

focusing on tribal history and enrichment (e.g., a longhouse) could benefit tribal interests. 

Impacts from Vegetative Treatments 

Under all alternatives, the BLM would implement vegetation treatments to protect human health and 

safety (i.e., hazard tree removal) and to control invasive plant species designated by Washington State for 

mandatory eradication or control. Where vegetation projects require planting and seeding, culturally 

important plants, such as camas, would be used in culturally and environmentally appropriate settings. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

220 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Vegetation treatments that affect the integrity of a site, location, or resource identified as important to one 

or more tribes for cultural continuity, as an Indian trust asset, or as integral to a treaty-based right or 

responsibility can impact tribal treaty rights and interests. Trees, shrubs, and forbs and their fruit, seeds, 

nuts, and bulbs are traditionally used by tribes for food, shelter, transportation, clothing, basketry, and 

medicines. Under all alternatives, vegetation treatments could impact some plants of traditional use to 

tribes. 

Vegetation management can include mechanical, biological, chemical treatments and prescribed fire. 

While the BLM would undertake inventory prior to authorizing surface disturbing projects, vegetation 

treatments such as hand pulling, digging, surface scarring, tilling, or tree removal could directly impact 

undiscovered cultural resources and human remains by exposing buried material, causing surface erosion, 

and intruding into the cultural setting. Chemical treatments could leave residues on soils and plants 

within traditional plant collecting areas or potentially affect other cultural or archaeological materials. 

Prescribed fire could affect flammable cultural materials and artifacts, cause staining and spalling (i.e., 

fragmenting) of lithic artifacts or features such as pictographs, and distort site or artifact dating analyses. 

Any treatment that exposes cultural materials could increase potential unauthorized collection or 

vandalism of cultural resources. Opening areas to new and ground disturbing treatments can increase 

risks to previously undisturbed and fragile resources. 

Vegetation management could also affect access or interfere with the exercise of traditional cultural uses, 

negatively impacting cultural resource values and opportunities to exercise treaty protected activities. 

Vegetation treatments that alter or change a cultural or natural setting—including though temporary 

visual and aural intrusions—in areas important for spiritual or other traditional practices would impact 

tribal interests. Long-term or permanent impacts would occur when archaeological or other important 

cultural sites are substantially damaged or destroyed. 

Short-term impacts could result from treatments that temporarily block or impede access to or use of a 

traditional cultural property or other places important for traditional cultural practices. The various 

vegetation treatments would have variable durations and would temporarily limit access to the treatment 

areas during mobilization, operational and demobilizing periods for mechanical and fire treatments and 

during chemical herbicidal applications. Some chemical herbicidal applications may have short-term or 

long-term impacts to traditional plant gathering activities and uses. Some biological treatments would 

potentially have very short-term (i.e., duration of the project) impacts to access during the life of the 

projects. 

If vegetation treatments are not implemented, noxious weeds and other invasive plants would continue to 

increase, forest health and wildlife habitats would continue to decline, and encroachment of grasslands 

and shrublands would continue, contributing to negative long-term impacts on the historic setting, the 

availability of plants for gathering, and other traditional uses and exercise of treaty rights. Under taking 

vegetation treatments also creates opportunities for tribes to work with the BLM to manage traditional 

gathering areas. 

Under all alternatives, the BLM would address potential impacts to cultural resources and tribal interests 

at the design or implementation phase of future projects through consultation with affected tribes and 

National Historic Preservation Act Section 106 review. Consultation with tribes regarding tribal interests 

and potential impacts from proposed projects would be complimentary to Section 106 review and 

compliance. The BLM, in consultation with affected tribes and in consideration of tribal interests and 

rights, would avoid or minimize potential impacts to historic properties and other cultural resources and 

values important to tribal rights and interests. 

No Action Alternative 

Under the No Action Alternative, the BLM would continue custodial management of the BLM; the BLM 

assumes it would continue very limited vegetation treatments (approximately 400 acres over 20 years the 

Monument). Current trends in the plant communities would continue, including loss of native grassland 

and shrubland habitats, a decrease in species diversity, and an increase in invasive species. Loss of access 

to areas for traditional practices resulting from application of vegetation treatments would be minor. Over 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

51 time, cultural resource values associated with traditional plant gathering and use may be diminished due 

221 
5

10

15

20

25

30

35

40

45

50

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

to continued encroachment by invasive plants and forest species into grasslands and shrublands and 

decline in forest health. This alternative would have the least potential risk for vegetation treatments to 

disturb cultural resources. It would also have the fewest opportunities for tribes to work with the BLM to 

implement vegetation treatments. 

Alternative A 

Under Alternative A, the BLM’s management of vegetation would continue to be largely passive. 

Herbicides and prescribed fire would not be available for vegetation management. The BLM estimates 

that it would undertake approximately 650 acres of vegetation treatments over the life of the plan. Under 

this alternative, there would continue to be limited opportunities for tribes to work with the BLM to 

implement vegetation treatments, though such opportunities would be greater than under the No Action 

Alternative. 

Access to project areas would be temporarily limited during mobilization, operation, and demobilization 

periods for mechanical treatments. The 390 acres of biological treatments the BLM estimates that it 

would undertake to achieve habitat and plant communities objectives over the life of the plan could 

temporarily affect access during the life of the projects. 

Given that natural succession and other processes continue to the 50 percent threshold identified for 

vegetation treatments prior to treatment, the potential for direct impacts to cultural resources from 

vegetation treatments would be limited, though greater than under the No Action Alternative. 

Encroachment by native forest species into the grasslands and shrublands would continue and the 

condition of these communities would likely decline over time as a result of invasive plant treatment 

being undertaken in the absence of herbicides. This would result in a decline in the size and condition of 

grasslands and shrublands important for traditional plant gathering and other activities associated with 

traditional cultural practices (see Table 7 on page 75). The prohibition on recreation in the Monument, 

which would reduce though not eliminate visitor presence, could slow the introduction and spread of 

invasive plant species. 

Alternative B 

Under Alternative B, the BLM in consultation and collaboration with tribes and other partners would 

manage the Monument to enhance the San Juan Islands’ ecological resistance and resilience by 

increasing the extent of native plant communities—specifically grasslands and wetlands—that are 

relatively scarce within the San Juan Islands as a whole. The BLM would also undertake vegetation 

treatments in the Monument to increase native species richness and structural component diversity to the 

extent that doing so is not detrimental to site-scale resilience. To achieve these objectives, the BLM 

would undertake vegetation treatments to thin forests and woodlands, as well as extensive grassland 

restoration (see Table 18 on page 112). This alternative would provide many opportunities for tribes to 

work with the BLM to implement vegetation treatments. Like alternatives C and D, the BLM would 

consider all tools in designing implementation-level vegetation treatments. 

The magnitude and intensity of the vegetation control and restoration measures under Alternative B 

would create a relatively high potential for short-term and long-term impacts to cultural resources from 

disturbance, chemical treatments, and fire. Treatments would have the potential to inadvertently disturb 

or destroy artifacts and cultural features and their scientific context within archaeological sites located 

within the treatment area. Short-term impacts from vegetation treatments that temporarily block or 

impede access for traditional cultural practices or that would temporarily affect the historic or cultural 

setting would be more likely than under the No Action Alternative and alternatives A and D. The 

potential for long-term or permanent impacts from damage or destruction of archaeological or cultural 

sites and properties would be greater under this alternative than under the No Action Alternative, 

Alternative A, and Alternative D. 

Vegetation treatments implemented to enhance native species richness and structural component 

diversity would have a positive long-term effect on diversity and cover of functional/structural group 

species, though some short-term negative impacts would occur. Over time, treatments to enhance and 

expand grasslands and shrublands would increase opportunities for traditional cultural uses. 

222 
5

10

15

20

25

30

35

40

45

50

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative C 

Under Alternative C, the BLM in consultation and collaboration with tribes and other partners would 

manage the Monument to approximate the extent and condition of plant communities that existed prior to 

Euro-American settlement of the San Juan Islands (approximately 1860), when Native Americans used 

fire to manage landscapes. To achieve this objective, the BLM would undertake extensive grasslands and 

shrubland restoration within the Monument (see Table 19 on page 114). The BLM estimates this 

alternative would require the most acres of vegetation treatment over the life of the plan of any alternative 

other than Sub-Alternative C. This alternative would provide many opportunities for tribes to work with 

the BLM to implement vegetation treatments. As in alternatives B and D, the BLM would consider all 

tools in designing implementation-level vegetation treatments. 

Impacts from vegetation treatments under Alternative C would be similar to under Alternative B, though 

the magnitude of both negative and positive impacts would be greater. Short-term impacts from 

vegetation treatments that temporarily block or impede access for traditional cultural practices or that 

temporarily affect the historic or cultural setting would be more likely than under the No Action 

Alternative and alternatives A, B, and D. Short-term and long-term negative impacts related to ground 

disturbance, prescribed fire, and chemical use would be similar to but greater than those described under 

Alternative B. 

Vegetation treatments implemented to approximate historic conditions would have a major positive longterm effect on diversity and cover of functional/structural group species, though some short-term negative 

impacts would occur. Treatments would include intensive restoration efforts to remove non-native plants 

and restore native plants, including culturally important species. Over time, this would benefit cultural 

properties associated with traditional plant gathering and uses, increasing opportunities for these 

activities. 

Sub-Alternative C 

Under this alternative, the BLM in consultation and collaboration with tribes and other partners would 

work to achieve the objective for this alternative without herbicides and pesticides. Effects to cultural 

resources from vegetation treatments would be similar to, but greater in magnitude than, those under 

Alternative C. Without the use of herbicides, the BLM estimates that it would need to increase the 

repetition of mechanical treatments to meet the habitat and plant communities objectives (see Table 20 on 

page 115). Short-term and long-term negative impacts related to ground disturbance would be similar to 

but greater than those described under Alternative C. Positive long-term increases in opportunities for 

traditional plant gathering would be the same under this alternative as under Alternative C. 

Short-term impacts from vegetation treatments that temporarily block or impede access for traditional 

cultural practices or that would temporarily affect the historic or cultural setting would occur most 

frequently under this alternative. The prohibition on chemical treatments would reduce impacts to 

traditional plant gathering activities and uses associated with traditional cultural properties and other 

tribal interests. 

Alternative D 

Under Alternative D, the BLM would maintain the approximate extent and condition of plant 

communities that it documented in the Monument as of 2016. The BLM estimates that this would require 

more acres of vegetation treatment than would occur under the No Action Alternative and Alternative A 

and substantially fewer acres than would be required to meet objectives and management direction under 

alternatives B, C, and Sub-C. Under this alternative, there would be fewer opportunities for tribes to 

work with the BLM to implement vegetation treatments than under alternatives B, C, and Sub-C, but 

more than under the No Action Alternative and Alternative A. Like in alternatives C and B, the BLM 

would consider all tools in designing implementation-level vegetation treatments. 

Vegetation treatments would target the edges of grasslands and shrublands to prevent conversion to forest 

and woodlands; they would also target new or expanding invasive plant populations. Through active 

management, the extent of grassland and shrubland plant communities would remain at their approximate 

2016 extent instead of decreasing over the life of the plan as they would under the No Action Alternative 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

223 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 and Alternative A. The condition of areas of traditional cultural importance for plant gathering and use 

would remain relatively unchanged though conditions in forests and woodlands would continue to be 

mostly closed and crowded. The potential for direct impacts to cultural resources would be limited 

though greater than in the No Action Alternative or Alternative A. While vegetation management would 

limit encroachment of forest vegetation into grasslands and shrublands, the condition of cultural 

properties important for traditional plant gathering would not improve or expand as they would under 

alternatives B, C, and Sub-C. 

Summary Conclusion for Tribal Interests 

Under all alternatives, the BLM would collaboratively engage with tribal government partners to facilitate 

traditional uses, develop opportunities for co-stewardship of plant communities and culturally important 

plants, engage tribal youth and elders, and maintain and improve access for exercise of treaty rights and 

traditional cultural practices. Through engagement with the tribes, BLM would foster programs to enrich 

opportunities for tribal cultural, spiritual, and educational activities including projects to restore Salish 

place names within the Monument. 

Beyond these common to all approaches, the alternatives would vary in their effects on tribal interests 

within the Monument. Specifically, they would vary in terms of the potential for short-term and longterm effects from disturbance from recreation activities and vegetation management to cultural settings 

and traditional practices. They would also vary in the extent to which they would improve conditions for 

traditional cultural practices including plant gathering and hunting. 

Alternative A would have the least potential for impacts to cultural sites and settings from either 

recreational activities or vegetation treatments. Similarly, it would have the least potential for physical, 

visual, or aural conflict between vegetation management or visitor activities and traditional practices. 

Alternative C would have a substantially greater potential risk for impacts from recreation and vegetation 

treatments than Alternative A. It would provide relatively minimal recreational opportunities and so 

would have the second least potential for conflict between vegetation management or visitor activities and 

traditional practices. Alternatives B, Sub-C, and D would have the greatest potential for impacts to 

cultural sites and traditional cultural practices from recreation and vegetation management. Consulting 

with tribes and conducting cultural resources surveys prior to authorizing activities that may adversely 

affect cultural sites or places important for traditional cultural practices or exercise of treaty rights would 

reduce potential impacts to tribal interests. 

While alternatives B, C, and sub-C would have a greater potential for disturbance to cultural sites and 

settings due to vegetation treatments than the No Action Alternative and alternatives A and D, they would 

substantially increase the quantity and quality of grassland and shrubland plant communities within the 

Monument. This would increase opportunities for both collecting culturally-important grassland plants, 

such as camas, and for tribes to work with the BLM to implement vegetation treatments. Alternative C 

would go the furthest toward approximating pre-Euro-American settlement vegetation conditions within 

the Monument and would provide the most opportunities for gathering of grassland plants and costewardship opportunities with the BLM. The No Action Alternative and alternatives A and D would 

have lower potential for impacts from vegetation treatments but would have minimal benefits to plant 

communities important for many traditional cultural practices. 

In summary, different alternatives would most benefit different aspects of tribal interests. Among the 

alternatives, Alternative A would have the least potential for short-term and long-term impacts from 

vegetation management and recreational activities to cultural resources and settings. Alternative C, on the 

other hand, would most expand opportunities for cultural and traditional practices by improving the 

condition and extent of plant communities important for plant gathering and wildlife. 

Cumulative Effects on Tribal Interests in the San Juan Islands59

The Monument’s contribution to lands available for exercising Native American treaty rights and 

traditional cultural practices is relatively small, but important given the limited lands that are currently 

 

59 See Cultural Resources Issue 1 for analysis of the direct, indirect, and cumulative effects of shoreline stabilization 

on cultural sites and resources important to tribal interests. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

224 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

available for these activities in the San Juan Islands. The Monument includes approximately 4 percent of 

the public lands in the San Juan Islands and approximately 0.8 percent of the total land area in the San 

Juan Islands. Opportunities to access and exercise tribal rights and interests vary among the land 

managing jurisdictions. About 6 percent of the recorded cultural sites in the San Juan Islands are located 

in the Monument. Given that the great majority of the land in the archipelago is privately owned, the 

Monument can play an important role in providing opportunities for tribal members to access lands for 

traditional and spiritual practices. 

Healthy habitats for fish and wildlife and access to locations of traditional procurement activities are 

essential to the exercise of treaty rights and tribal interests. Opportunities to exercise treaty rights, as 

well as the availability of resources, have diminished in the San Juan Islands, as well as in the rest of 

region, since the signing and ratification of tribal treaties and agreements. Increased settlement and 

changes in land use practices, including agriculture, dams, irrigation, ranching, and resource extraction, 

continue to alter the landscape and natural habitats. Ongoing loss of habitat and fish, particularly salmon, 

are of particular concern (Treaty Indian Tribes in Western Washington 2011). Decreased availability of 

culturally and economically important resources such as native fish (including salmon and shellfish), 

game, and plant species and loss of access to areas of traditional use adversely affect the traditional 

socio-cultural activities and practices essential to the exercise of treaty rights and tribal interests. 

Grasslands in the Puget Lowland Ecoregion, which includes the San Juan Islands, have declined to an 

estimated 9 percent of pre-Euro-American settlement levels (Chappell et al. 2000). The Monument 

currently encompasses approximately 1 percent of the Southern Vancouverian Lowland Grassland and 

Shrubland occurring within the San Juan Islands; the great majority of lands in the San Juan Islands are 

in private ownership and are not available for the gathering of culturally important plants. Cumulative 

effects to grasslands, which have the potential for collection of culturally important plants, are discussed 

under Habitat and Plants Issue 2. 

Under alternatives B, C, and Sub-C, the BLM would substantially increase the quantity and quality of 

grassland and shrubland plant communities within the Monument. Under the No Action Alternative and 

Alternative A, the quality and quantity of these important communities would continue to decline in the 

Monument, decreasing the overall availability of opportunities for culturally important plant gathering in 

the San Juan Islands. Under these alternatives, the Monument would contribute to, rather than counter, 

the decline in grassland communities in the San Juan Islands. The limited land available for the practice 

of traditional cultural activities within the San Juan Islands makes the availability of these lands within 

the Monument particularly important to tribal interests. 

The alternatives would differ in their effect on the Monument’s contribution to the total cultural sites in 

the San Juan Islands. They would differ in accordance with the magnitude of the potential for these 

resources to be disturbed or lost due to recreation activities and vegetation management. Under all 

alternatives, there would be some potential for disruption or loss of cultural sites due to shoreline erosion 

and storm surge, visitor use, and vegetation management. Alternatives B, Sub-C, and D would have the 

greatest potential for a reduction in the Monument’s contribution to the total number of cultural sites in 

the San Juan Islands. 

Visual Resources 

Key Points 

 Under alternatives A and D, the BLM would manage all acres within the Monument at a VRM class

that is more restrictive or equivalent to the current VRI class.

 Under alternatives B and C, the BLM would manage most of the Monument at a VRM class that is

less restrictive than the current VRI class.

 Under all alternatives, the Monument’s overall visual value is expected to remain at VRI Class II

(high) even where a higher VRM class is designated and scenic quality would be at least temporarily

reduced due to vegetation treatments.

This section contains one analytical issue: 

41 

42 

43 

44 

46 

47 

48 

49 

225 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1. How would the BLM’s designation of visual resource management classes under each alternative

affect visual resources? For lands where the BLM would designate visual resource management class

as lower than the visual resource inventory class, how would vegetation treatments and potential

recreation developments affect the visual resources? (Page 226)

Visual Resources Analytical Issue 1: How would the BLM’s designation of 

visual resource management classes under each alternative affect visual 

resources? For lands where the BLM would designate visual resource 

management class as lower than the visual resource inventory class, how would 

vegetation treatments and potential recreation developments affect the visual 

resources? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

In 2010, the BLM completed a visual resources inventory for the Monument. After considering the 

factors described below, the BLM rated the whole of the Monument as having VRI Class II (high) visual 

resource values. Since there is no RMP for the Monument, there are no current VRM classes. 

In reaching the VRI determination, the BLM determines an area’s scenic quality (rated as A, B, or C) and 

the “distance zones” from which the areas in question are likely to be viewed from travel routes or 

observation points (e.g., are they typically viewed as foreground, middleground, or background?). The 

BLM considered the fact that most of the Monument is viewable from smaller private and commercial 

craft and that several Monument properties are viewable from the Washington State ferries serving the 

San Juan Islands. The Monument lands offer stunning vistas of wildflowers and lush vegetation, rocky 

bluffs, open prairie, tide-pools, rocky and sandy beaches, and barren rocks colored with brilliant displays 

of dust lichens and seaweeds, as well as several historic buildings. These qualities led the BLM to 

determine that the Monument has a scenic quality ranking of A and falls within the foregroundmiddleground distance zone. 

For the most part, Monument lands are relatively natural in appearance. The portions of the Monument 

that are not easily accessible by the public due to a lack of ferry service or legal access have generally 

retained a higher level of natural appearance. The degree of impacts from human use varies with the 

amount of use and the accessibility of the areas. 

The BLM determined that the Monument has a high sensitivity rating due to the type of users, amounts 

of use, public interest, adjacent land uses, and the fact that many residents and visitors consider 

Monument lands to be special areas. This rating is the highest level of sensitivity the BLM can identify 

during the inventory process. The type of users experiencing the Monument ranges from local residents 

to visitors coming from across the world. Many of the individuals who live in the San Juan Islands 

choose this area for the natural setting, remoteness, and predominantly undeveloped landscape. 

The BLM estimates that the Monument received over 100,000 visitors in 2014 (see Table 37 on page 

156), though the amount of use varies substantially by location and is difficult to ascertain with precision 

for remote and scattered rocks and islands. Well over a million people utilize the Washington State 

Ferry to access the San Juan Islands every year (Washington State Department of Transportation 2015). 

Numerous private vendors operate watercraft and flight services that allow residents and visitors to 

experience the area’s natural setting, remoteness, and predominantly undeveloped landscape. The public 

interest in the seascape and landscape of the San Juan Islands is high and prompted the 2008 designation 

of the San Juan Islands Scenic Byway, which includes the ferry route and designated roads on San Juan 

Island and Orcas Island. 

Although the BLM does not identify VRI or VRM classes for private lands, it does consider each 

location’s overall viewshed, including adjacent public and private lands, when undertaking the inventory. 

Thus, the BLM considered the sensitivity of the adjacent public and private lands during the inventory 

process. The majority of lands adjacent to the Monument are headlands, shorelines, rocks, and islands 

with undeveloped and natural settings. Some adjacent lands are under conservation easements held by a

5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

226 
 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 local land bank and or by non-profit land trusts. These conservation easements typically limit 

2 development. Even where no conservation easement exists, adjacent landowners often manage lands to 

3 retain the landscape’s naturalness and undisturbed setting. The San Juan County Shoreline Master Plan 

4 establishes coastal development setbacks to retain the area’s natural setting (San Juan County 2016b). 

5 The Monument also shares common borders, waterways, and or overall scenic foreground, middleground, 

6 and background vistas with numerous other protected public lands. These areas include preserves, natural 

7 resource conservation areas, wilderness areas, national historical parks, and Canadian national parks. 

8 Effects of the Alternatives 

9 The alternatives vary in the acres of Monument land the BLM would designate under the various VRM 

10 classes. They also vary in the likelihood that there would be long-term impacts to visual resources that 

11 would change scenic quality where the BLM would designate a lower VRM class. Under all alternatives, 

12 including the No Action Alternative, the overall visual value of Monument landscapes is expected to 

13 remain at VRI Class II (high)—even where repeated vegetation treatments may reduce scenic quality 

14 from A to B—because public sensitivity to visual change would remain high and all areas will remain 

15 within the foreground-middleground distance zone. 

16 The BLM would develop trails and shoreline stabilization projects in a manner that allows these projects 

17 to meet VRM II objectives. The BLM could use local materials and location-appropriate colors and sight 

18 lines to bring these projects into compliance with VRM II objectives. 

19 Table 56: Visual resource management designations by alternative (see Map 3 -Map 5, below) 

VRM Class No Action Alternative 

(acres) 

Alternative A 

(acres) 

Alternative B 

(acres)* 

Alternative C 

(acres)* 

Alternative D 

(acres) 

Class I 0 232 0 3 232 

Class II 0 789 28 28 789 

Class III 0 0 992 989 0 

Class IV 0 0 0 0 0 

Undesignated 1,021 0 0 0 0 

20 * Totals only 1,020 acres due to a rounding issue (i.e., the acres falling into two of the classes round down 

21 instead of up while under other alternatives the acres round up). 

22 Table 57: Percent of acres the BLM would manage at a visual resource management class that is 

23 more or less restrictive than the current visual resources inventory class 

No Action 

Alternative 

Alternative A 

(percent) 

Alternative B 

(percent) 

Alternative C 

(percent) 

Alternative D 

(percent) 

Percent acres less 

restrictive (more contrast 

allowed) VRM than VRI 

NA 0% 97% 97% 0% 

Percent acres more 

restrictive (less contrast 

allowed) VRM than VRI 

NA 23% 0% <1% 23% 

Percent acres equivalent 

VRM and VRI NA 77% 3% 3% 77% 

24 

25 

26 

27 

28 

29 

30 

31 

32 

No Action Alternative 

Under the No Action Alternative, there would continue to be no designated VRM classes in the 

Monument. Given that the BLM’s custodial management approach would continue under this alternative, 

it is unlikely that management activities would substantially affect visual resources outside of the duration 

of a project (e.g., visual resources would be temporarily affected by hazard tree removal, but there would 

be no change in the visual character of the area after the completion of the project). Increasing recreation 

under the minimal visitor use restrictions currently in place, could eventually affect visual resources, 

including through the continued proliferation of user created trails causing increasingly noticeable 

contrast in line, color, and texture. 

227 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative A (Map 3) 

Under Alternative A, the BLM would designate 232 acres of Monument lands as VRM Class I60 . The 

BLM would manage visual resources in this 23 percent of the Monument more restrictively than the 

existing VRI Class. The VRM Class I designation would require all projects in those areas to not be 

visible or attract attention; projects would have five years to come into compliance with this objective 

(e.g., a vegetation treatment could have short-term visual impacts as long as they became negligible 

within five years). 

Under this alternative, the BLM would designate 789 acres of Monument lands as VRM Class II. The 

BLM would manage visual resources in this 77 percent of the Monument at a VRM class that is 

equivalent to the current VRI class. The VRM Class II designation would allow projects to be visible but 

not attract attention; projects would have five years to come into compliance with this objective. 

Under this alternative, the Monument would retain A-quality scenery and high visual sensitivity, thus 

maintaining overall VRI Class II values. 

Alternative B (Map 4) 

Under Alternative B, the BLM would designate 28 acres of Monument lands as VRM Class II. The BLM 

would manage visual resources in this 3 percent of the Monument at a VRM class that is equivalent to the 

current VRI class. The VRM Class II designation would allow projects to be visible but not attract 

attention; projects would have five years to come into compliance with this objective (e.g., a vegetation 

treatment could have short-term visual impacts as long as they became negligible within five years). 

Under this alternative, the BLM would designate 992 acres of Monument lands as VRM Class III. The 

BLM would manage visual resources in this 97 percent of the Monument at a VRM class that is less 

restrictive than the current VRI class. The VRM Class III designation would allow projects to attract 

attention but not dominate the view. This would allow the BLM to repeat vegetation treatments within a 

five-year period as necessary to meet Alternative B’s vegetation objectives. The BLM assumes that the 

scenic quality in many of these areas would shift from A to B during the life of the plan, primarily due to 

changes in vegetation and color and cultural modification scores. However, the long-term (i.e., more than 

the life of the plan) visual impacts of vegetation treatments would become minimal once the repetition 

rate of treatments declined either due to new plan-level decisions or due to a reduction in need to repeat 

treatments to achieve objectives over time (e.g., once grassland species are fully established in formerly 

forested areas). The BLM would not allow new recreational developments under this alternative. 

Under this alternative, although scenic quality in some areas would drop from A to B, visual sensitivity 

levels would remain high and, with no change in distance zones, VRI would remain Class II. 

Alternative C (Map 5) 

Under Alternative C, the BLM would designate areas managed for their wilderness characteristics (3 

acres) as VRM Class I. The BLM would manage visual resources in this <1 percent of the Monument 

more restrictively than the existing VRI Class. The VRM Class I designation would require all projects 

in those areas to not be visible or attract attention; projects would have five years to come into compliance 

with this objective (e.g., a vegetation treatment could have short-term visual impacts as long as they 

became negligible within five years). 

Under this alternative, the BLM would designate 28 acres of Monument lands as VRM Class II. The 

BLM would manage visual resources in this 3 percent of the Monument at a VRM class that is equivalent 

to the current VRI class. The VRM Class II designation would allow projects to be visible but not attract 

attention; projects would have five years to come into compliance with this objective (e.g., a vegetation 

treatment could have short-term visual impacts as long as they became negligible within five years). 

The BLM would designate 989 acres of Monument lands as VRM Class III. The BLM would manage 

visual resources in this 97 percent of the Monument at a VRM class that is less restrictive than the current 

VRI class. The VRM Class III designation would allow projects to attract attention but not dominate the 

 

60 Managing VRI Class II lands at a VRM Class I does not indicate that there are existing visual disturbances that 

need to be removed. The VRM class restricts how the BLM implements projects going forward. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

228 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 view. This would allow the BLM to repeat vegetation treatments within a five-year period as necessary to 

meet Alternative B’s vegetation objectives. The BLM assumes that the scenic quality in many of these 

areas would shift from A to B during the life of the plan, due to changes in vegetation and color and 

cultural modification scores. However, the long-term (i.e., more than the life of the plan) visual impacts 

would be the same as described under Alternative B. 

The BLM would allow for the development of new recreation facilities under this alternative. It would 

minimize visual impacts from these developments through site selection and the use of local materials and 

location appropriate colors and sight lines. 

Under this alternative, although scenic quality in some areas would drop from A to B, visual sensitivity 

would remain high and, with no change in distance zones, VRI would remain Class II. 

Alternative D (Map 3) 

Under Alternative D, the BLM would designate areas managed for their wilderness characteristics (232 

acres) as VRM Class I. The BLM would manage visual resources in this 23 percent of the Monument 

more restrictively than the existing VRI Class. The VRM Class I designation would require all projects 

in those areas to not be visible or attract attention; projects would have five years to come into compliance 

with this objective (e.g., a vegetation treatment could have short-term visual impacts as long as they 

became negligible within five years). 

Under this alternative, the BLM would designate 789 acres of Monument lands as VRM Class II. The 

BLM would manage visual resources in this 77 percent of the Monument at a VRM class that is 

equivalent to the current VRI class. The VRM Class II designation would allow projects to be visible but 

not attract attention; projects would have five years to come into compliance with this objective (e.g., a 

vegetation treatment could have short-term visual impacts as long as they became negligible within five 

years). The BLM would allow for the development of new recreation facilities under this alternative. It 

would minimize visual impacts from these developments through site selection and the use of local 

materials and location appropriate colors and sight lines. 

Under this alternative, the Monument would retain A-quality scenery and high visual sensitivity, thus 

maintaining overall VRI Class II values. 

Conclusion 

Under alternatives A and D, the BLM would manage all acres within the Monument at a VRM class that 

is more restrictive or equivalent to the current VRI class. These alternatives would have a negligible to 

positive impact on visual resources. Under alternatives B and C, the BLM would manage most of the 

Monument at a VRM class that is less restrictive that the current VRI class. Over the life of the plan, 

vegetation management would create visual contrast that would not resolve within five years due to the 

frequency of treatment repetition required to meet these alternatives’ objectives. Once the repetition of

vegetation treatments declines, visual resources should return to their current VRI classes. 

Under all alternatives, the Monument’s overall visual value of the Monument landscapes is expected to 

remain at VRI Class II (high) 

Cumulative Effects of the Alternatives for Visual Resource Management 

As described in the affected environment section above, the San Juan Islands have high-quality and 

highly valued visual resources. Current management of these lands on both public and private lands is 

maintaining the high-quality of these visual resources. There are no reasonably foreseeable management 

changes that would substantially affect the visual resources of the San Juan Islands. 

Under all alternatives, the visual sensitivity of the San Juan Islands would remain high and, with no 

change in distance zones, overall VRI would remain Class II. Under alternatives B and C, vegetation 

management within the Monument would lead to a noticeable, but not dominant, change to the visual 

resources on approximately 0.3 percent of land in the San Juan Islands. Under all other alternatives, the 

Monument would continue to contribute to the highly valued scenic resources of the San Juan Islands. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

229 
1 

2 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Map 3: VRM Classes under alternatives A and D Map 4: VRM Classes under Alternative B 

230 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Map 5: VRM classes under Alternative C 

2 

3 

4 Wilderness Characteristics 

Key Points 

 Under alternatives A and D, the BLM would manage all areas found to possess wilderness

characteristics explicitly for these characteristics and would contribute to the total acreage and

number of rocks and islands managed for wilderness characteristics in the San Juan Islands.

 Under the No Action Alternative and Alternative B, the BLM would continue not to manage these

areas explicitly for these characteristics. 

This section contains one analytical issue: 

1. How would the alternatives affect wilderness characteristics within the Monument? (Page 232)

Background 

The BLM is mandated by law to maintain an up-to-date inventory of wilderness characteristics on the 

lands it administers that are not currently designated as wilderness areas or wilderness study areas. It 

must also analyze impacts to this resource when undertaking actions and consider whether to 

manage these areas for their wilderness characteristics in its management plans. See the Wilderness 

Characteristics section of Appendix E for more information on the BLM’s inventory process. 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

231 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Wilderness Characteristics Analytical Issue 1: How would the alternatives 

affect wilderness characteristics in the Monument? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Currently, there are 23 areas within the Monument (totaling approximately 232 acres) found by the BLM 

to have wilderness characteristics (see Map 6). Each area generally appears to have been affected by the 

forces of nature, with the imprint of man’s work substantially unnoticeable; has outstanding opportunities

for solitude; and may contain ecological, geological, or other features of scientific, educational, scenic, or 

historical value. There is no minimum size criterion for islands surrounded by water. See the Wilderness 

Characteristics section of Appendix E for additional information about the wilderness characeristics 

inventory. 

The areas within the Monument that have been determined to have wilderness characteristics are: Carter 

Point Rocks, Davis Bay Island and Rocks, Eastsound Blind Island South, John’s Island Rocks, Patos 

Island (east side only), Fauntleroy Rock, Freeman Island, Little Patos Island, Lummi Rocks, MacKaye 

Harbor Rocks, McConnell Rocks, Oak Island, Park Bay Island, Reads Bay Island, Reid Harbor Rock, 

Satellite Island Rocks, Skull Island, Twin Rocks, Victim Island, Unnamed Rocks (Cone Island), 

Unnamed Rocks (Iceberg Point Rocks), Unnamed Rocks (Shaw Island), Unnamed Rocks (South Lopez 

Island). The largest area identified as having wilderness characteristics is the east side of Patos Island, 

which encompasses 194 acres. Little Patos Island and Lummi Rocks are 14 and 8 acres respectively. 

Many of the smaller islands are less than 2 acres; many of the rocks and rock groupings are under an acre. 

Map 6: Areas with wilderness characteristics identified through BLM inventory 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

232 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Effects of the Alternatives 

2 The alternatives vary in the areas the BLM would manage for wilderness characteristics. They also vary 

3 in the likelihood that wilderness characteristics would continue to exist where not explicitly managing for. 

4 Table 58: Acres and areas managed for their wilderness characteristics 

No Action 

Alternative Alternative A Alternative B Alternative C Alternative D 

Acres managed for wilderness 

characteristics 0 232 0 3 232 

Individual rocks and islands 

managed for wilderness 

characteristics 

0 23 0 12 23 

5 No Action Alternative 

Under the No Action Alternative, there would continue to be no plan decisions related to wilderness 

characteristics. Assuming the continuation of the current low level of management activity and visitor 

facility development, wilderness characteristics would persist under this alternative. 

Alternatives A and Alternative D 

Under both alternatives A and D, the BLM would manage all 23 rocks and islands (encompassing 232 

acres) with wilderness characteristics for these characteristics (see Map 6). Under both alternatives, the 

BLM would not develop visitor facilities within these areas and would allow develop signs only as 

needed to protect values and human health and safety. It would also designate lands with wilderness 

characteristics as VRM Class 1, which would require any activity to create negligible visual contrast (see 

page 225 for more information). There would be modest to no vegetation treatments within areas with 

wilderness characteristics over the life of the plan under these alternatives. Under Alterantive D, the 

BLM would prohibit the use of hard stabilization in areas with wilderness characteristics (under 

Alterantive A, hard stabilization would not be allowed in the Monument). 

Alternative B 

Under Alternative B, the BLM would continue not to manage any areas with wilderness characteristics 

explicitly for these characteristics. Under this alternative, the BLM would undertake actions to protect or 

restore cultural and ecological values that would conflict with the protection of wilderness characteristics. 

The BLM would allow hard shoreline stabilization to protect cultural and paleontological resources where 

soft stabilization measures would be ineffective. While the BLM would minimize impacts from this 

action, hard stabilization measures could permanently disrupt the apparent naturalness of an area with 

wilderness characteristics. Under this alternative, there would also be a high repetition rate of vegetation 

treatments to achieve objectives over the life of the plan. While vegetation treatments would only 

temporarily disrupt apparent naturalness, the high repetition rate expected under this alternative would 

frequently disrupt this characteristic during the life of the plan in areas identified for restoration. 

While the BLM would not manage any areas for wilderness characteristics, it is likely that these 

characteristics would persist in at least some locations over the life of the plan. The BLM would only 

implement hard stabilization where soft stabilization measure would be ineffective. It is likely that the 

BLM would implement these measures in, at most, a small percent of the areas with wilderness 

characteristics. The effects on apparent naturalness from vegetation treatments would be negligible once 

the repetition rate of treatments declined, either due to new plan-level decisions or due to a reduction in 

need to repeat treatments to achieve objectives over time (e.g., once grassland species are fully 

established in formerly forested areas). 

Alternative C 

Under Alternative C, the BLM would manage rocks with wilderness characteristics explicitly for their 

wilderness characteristics. This would result in the BLM managing the following 12 rocks encompassing 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

233 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 3 acres for wilderness characteristics (see Map 7): Carter Point Rocks, Davis Bay Island and Rocks, 

Eastsound Blind Island South, John’s Island Rocks, MacKaye Harbor Rocks, McConnell Rocks, Reid 

Harbor Rock, Satellite Island Rocks, Unnamed Rocks (Cone Island), Unnamed Rocks (Iceberg Point 

Rocks), Unnamed Rocks (Shaw Island), Unnamed Rocks (South Lopez Island). The BLM would not 

develop visitor facilities in these areas and would designate them as VRM Class 1 (see page 225 for more 

information). Given their small size and limited vegetation, these areas would likely undergo modest to 

no vegetation treatments. 

Under this alternative, there could be a high repetition rate of vegetation treatments in the 229 acres not 

managed for their wilderness characteristics. As described under Alternative B, vegetation treatments 

would repeatedly disrupt apparent naturalness during the life of the plan, but the effects would be 

negligible once the repetition rate of treatments declined. 

Map 7: Areas managed for their wilderness characteristics under Alternative C 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 Conclusion 

13 Table 58 quantitatively compares the acres and number of areas the BLM would explicitly manage for 

14 wilderness characteristics across the alternatives. Table 59 qualitatively summarizes the effects of the 

15 alternatives on wilderness characteristics. It describes each alternative as causing an improvement, 

16 decline, or no change (+,-,=) in protection of wilderness characteristics compared to current conditions. 

17 Alternatives A and D are the most protective of wilderness characteristics; the BLM would manage all 

18 areas with wilderness characteristics explicitly for these characteristics. Under the No Action Alternative 

19 and Alternative B, the BLM would continue not to manage these areas explicitly for these characteristics. 

20 Under Alternative C, the BLM would manage all of the rocks, but none of the islands, that have 

21 wilderness characteristics for these characteristics. 

234 
1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 59: Summary of alternatives’ impacts on wilderness characteristics

No Action 

Alternative Alternative A Alternative B Alternative C Alternative D 

Acres managed for 

wilderness characteristics = + = + + 

Potential condition of 

wilderness characteristics 

outside of areas explicitly 

managed for them. 

= 

All 232 acres 

managed for 

wilderness 

characteristics 

- -

All 232 acres 

managed for 

wilderness 

characteristics 

2 Cumulative Effect of BLM Management on Wilderness Resources in the San Juan 

Islands 

While only Congress can designate wilderness, the alternatives would vary in their contribution to areas 

managed for their wilderness characteristics in the San Juan Islands. There is currently one wilderness 

area designated by the U.S. Congress in the San Juan Islands. No other areas are currently explicitly 

managed for wilderness characteristics, as defined by the Wilderness Act of 1964 (16 USC 1132). Other 

than the Monument planning process, there are no reasonably foreseeable changes to the amount of land 

managed explicitly for wilderness characteristics in the San Juan Islands. 

In 1976, the U.S. Congress designated the San Juan Wilderness, which includes 80 rocks and islands 

totaling 353 acres; these rocks and islands are also part of the San Juan Islands National Wildlife Refuge 

managed by the U.S. Fish and Wildlife Service. The U.S. Fish and Wildlife Service has closed the 

majority of the San Juan Wilderness to public access. As a result, access to outstanding opportunities for 

solitude and primitive and unconfined recreation are very limited in the San Juan Wilderness. 

Figure 7 demonstrates the Monument’s contribution to land managed for wilderness characteristics in the 

San Juan Islands under each alternative. Under the No Action Alternative and Alternative B, the San 

Juan Wilderness would continue to be the only land managed explicitly for wilderness characteristics in 

the San Juan Islands. Under alternatives A and D, the Monument would provide the largest contribution 

to the land managed for wilderness characteristics. Under these alternatives, there would be a total of 582 

acres in the San Juan Islands managed for wilderness characteristics. Under Alternative C, there would 

be a total of 356 acres in the San Juan Islands managed for wilderness characteristics. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 Figure 7: Acres managed for wilderness characteristics in the San Juan Islands by alternative 

235 
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Wildfire 

Key Points 

 The No Action Alternative and alternatives A and D would likely lead to higher fire risks, lower

protection or maintenance of fire-dependent Monument objects and values, and increased risks to

adjoining properties.

 Alternatives B and C would likely reduce fire risks, maintain or enhance fire-dependent Monument

objects and values, and reduce risks to adjoining properties.

 In general, the dispersed nature of Monument locations limits the effect of the alternatives on the

overall wildfire risk in the San Juan Islands.

This section contains one analytical issue: 

1. How would alternatives affect fire behavior and risks to Monument objects and values or adjoining

lands? (Page 236)

Wildfire Analytical Issue 1: How would alternatives affect fire behavior and 

risks to Monument objects and values or adjoining lands? 

Analysis of impacts from prescribed burning under the alternatives are found in the air quality, climate 

change, soils, vegetation, and wildlife sections of this chapter. See Appendix B for analytical methods 

used in this analysis. 

Affected Environment 

Monument lands are scattered throughout the San Juan Islands, so the BLM assumed that conditions 

within the Monument are essentially the same as throughout the undeveloped portions of the islands. 

Thus, the conditions described apply equally to the San Juan Islands as a whole and to the Monument. 

Numerous fire history studies and historical accounts indicate that grasslands and oak-Douglas-fir 

savannas and woodlands, with only small patches of forest, dominated the San Juan Islands prior to the 

20th century (Anonymous 1868, Agee and Dunwiddie 1984, Avery 2004, Gray and Daniels 2006, 

Dunwiddie et al. 2011). Given the lack of lightning-caused fires in the 20th century within the San Juan 

Islands, human ignitions were likely the dominant ignition source, which is consistent with historical 

accounts (e.g., Anonymous 1868, Avery 2004). Burning by Native Americans/Indigenous Peoples to 

maintain certain plants, such as camas, and plant communities, such as oak woodlands and savannas, is 

the likely reason for such conditions (Avery 2004, McDadi and Hebda 2008, Pellatt and Gedalof 2014). 

Further, pre-Euro-American settlement fire scarring occurred in late summer and fall (Sprenger and 

Dunwiddie 2011, Pellatt and Gedalof 2014), consistent with humans as the primary ignition source. 

However, extensive heart rot in most fire-scarred trees makes reconstructing historical fire frequencies 

difficult (e.g., Gray and Daniels 2006). 

Fire return intervals apparently varied somewhat between islands. Dunwiddie et al.(2011) found that 

prior to Euro-American settlement, fire return intervals on Waldron Island averaged 7 to 18 years between 

fires on individual trees; Peterson and Hammer (2001) found similar results at Mount Constitution on 

Orcas Island. Spurbeck and Keenam (2003) estimated a fire return interval of 11 to 15 years on 

Monument lands at Point Colville and Iceberg Point. In contrast, current mean fire return intervals 

exceed 100 years (Peterson and Hammer 2001, Dunwiddie et al. 2011). Based on the structure of old 

Douglas-fir and basal charcoal on the boles of many trees, most fires prior to Euro-American settlement 

were low to moderate intensity, serving to keep woodlands and savannas open and limiting tree and shrub 

encroachment (Agee and Dunwiddie 1984, Avery 2004, Gray and Daniels 2006, Dunwiddie et al. 2011). 

Land use changes beginning during the Euro-American settlement period have caused changes to the San 

Juan Islands landscape, including forests becoming denser, conifers encroaching into grasslands and oak 

savannas, and shrubs starting to dominate understories (Peterson and Hammer 2001, Avery 2004, 

McCune et al. 2013, Pellatt and Gedalof 2014). For example, Dunwiddie et al. (2011) estimated the 

236 
 

 

 

 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

historical tree density on Waldron Island was about 1/10 of the current density. The rate of 

encroachment, infill, and shrub expansion varied from island to island (Agee and Dunwiddie 1984, Avery 

2004, Gray and Daniels 2006, Dunwiddie et al. 2011). Early in the Euro-American settlement period, 

several invasive plant species, including annual grasses, established on the larger islands, likely as a result 

of introducing sheep, cattle, hogs, and horses to these islands (Avery 2004, McCune et al. 2013). In many 

parts of the San Juan Islands, the dominant fuelbed has shifted from a vertically separated, open-canopy 

woodland or savanna with a grass understory to relatively dense, multi-layered forest with abundant 

ladder fuels and an understory dominated by shrubs and downed wood (Agee and Dunwiddie 1984, Gray 

and Daniels 2006, Dunwiddie et al. 2011, Sprenger and Dunwiddie 2011). In areas that remain open with 

grassy understories, invasive grasses have often displaced native grasses (Avery 2004). 

Current longer fire return intervals facilitated these changes in fuelbed and vegetation composition and 

structure (Agee and Dunwiddie 1984, Peterson and Hammer 2001, MacDougall et al. 2004, Dunwiddie et 

al. 2011, McCune et al. 2013, Pellatt and Gedalof 2014), which affect potential fire behavior. When fires 

occur, low to moderate fire intensity remains likely on the drier, more open windward side of the San 

Juan Islands. However, where a conifer-shrub community has replaced woodland, savanna, and 

grasslands and where multiple forest layers have developed, moderate and high intensity fire is more 

likely when fires occur. 

Since the Monument does not have an RMP or fire management plan, the default response to all wildfires, 

regardless of origin, is suppression, consistent with Federal wildland fire policy (U.S. Department of the 

Interior et al. 2001). This response applies to all fires that ignite within the Monument and that threaten 

to burn into the Monument. Once the BLM completes an RMP for the Monument, the subsequent fire 

management plan must describe allowable wildfire responses that support the management goals and 

objectives of the RMP. In all wildfire responses, the protection of human life is the single overriding 

priority. After human life, response priorities are based on the values to be protected, such as, 

communities, infrastructure, property and improvements, and natural and cultural resources (BLM 2005). 

Historical fire regimes describe the role fire would play in a landscape in the absence of modern human 

intervention, but take into account Native American/Indigenous Peoples traditional practices. Fire 

regimes are classified based on the average number of years between fires (fire frequency) combined with 

the severity (amount of replacement) of the fire on dominant overstory species. For example, areas with 

frequent, relatively low intensity fires are classified as fire regime I, while areas with infrequent, high 

intensity fires are classified as fire regime V (Table 60). 

According to San Juan County’s community wildfire protection plan (San Juan County 2012) most of the 

San Juan Islands consists of fire regimes III and V, although a substantial area was rated as having 

indeterminate fire regime characteristics (Table 60). However, the descriptions of the historical 

vegetation structure, communities, past estimated fire return intervals, and probable fire behavior suggest 

that the islands may have historically supported a considerable area in fire regimes I and II and less area 

in fire regimes III and V (Agee and Dunwiddie 1984, Avery 2004, Gray and Daniels 2006, Dunwiddie et 

al. 2011). The most recent LANDFIRE regime classification for the San Juan Islands also indicates a 

predominance of fire regimes III and V (LANDFIRE 2015). The difference between the descriptions of 

the historical vegetation and the current vegetation indicates that the county classification and the 

LANDFIRE classification are more representative of current fire regimes than of historical fire regimes. 

Table 60: Natural fire regime in the San Juan Islands 

Fire Regime Frequency 

(years) Severity Number ofAcres

Percent of

Total

I 0−35 Low and Mixed 0 0

II 0−35 Replacement 0 0

III 35−200 Mixed and Low 46,355 41%

IV 35−200 Replacement 13,440 12%

237 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Fire Regime Frequency 

(years) Severity Number ofAcres

Percent of

Total

V 200+ Replacement and Mixed 30,242 27%

Water N/A Water 1,008 <1%

Barren N/A Barren 515 <1%

Indeterminate N/A Indeterminate fire regime 

characteristics* 20,873 19%

Total 112,433 100%

1 * Urban areas, agricultural areas, and other developed areas

2 Source: San Juan County, Washington Community Wildfire Protection Plan/Wildfire Risk Assessment

3 (San Juan County 2012)

4 The community wildfire protection plan rated 75 percent of San Juan Islands as moderately departed from 

5 historical conditions, 10 percent with low departure, and less than one percent with high departure (San 

6 Juan County 2012). The current vegetation descriptions suggest that more than one percent of the area 

7 could be classified as highly departed from historical conditions with uncharacteristic vegetation structure 

8 and species compositions now widespread (Agee and Dunwiddie 1984, Avery 2004, Gray and Daniels 

9 2006, Dunwiddie et al. 2011). 

10 Because the BLM has no fire organization present on the San Juan Islands, WDNR has provided fire 

11 protection within Monument boundaries. The standardized methods used to archive wildfire occurrence, 

12 size, and lands affected make it difficult to determine how many, if any, wildfires have burned on 

13 Monument lands since 1970. Based on data collected by the BLM and WDNR over 40+ years, 88 

14 percent of wildfires on State and Federal lands in the San Juan Islands are human caused, 10 percent have 

15 an unknown cause, and 2 percent are lightning-caused (San Juan County 2012) (Table 61). Between 1970 

16 and 2011, San Juan County averaged 13 fires per year, although the number of ignitions declined between 

17 1970 and 1990 and have since fluctuated around an average of six ignitions. Only 30 acres burn, on 

18 average, each year, although in 2003, 468 acres burned, primarily on National Park Service lands ( San 

19 Juan County 2012). Drought conditions appear to play a substantial role in the number of acres burned in 

20 any given year, particularly when coupled with high wind events (San Juan County 2012) 

21 Table 61: Fire ignitions and acres burned within San Juan County by source, 1970−2011

Cause # of Ignitions Percent Acres Burned Percent

Lightning 11 2% 27 5%

Human 435 88% 421 74%

Unknown 47 10% 122 21%

Total 493 100% 570 100%

22 Source: San Juan County, Washington Community Wildfire Protection Plan/Wildfire Risk Assessment

(San Juan County 2012)

Land management agencies refer to wildlands in close proximity to homes and structures as wildland 

urban interface; these areas are a higher priority for both fire suppression and fuels management. A 

recent mapping effort classified most of the privately-owned portions of San Juan County as wildlandurban intermix (≥6.18 houses per km2 and ≥50 percent cover of wildland vegetation) with the southern 

portion of San Juan Island and the areas of Lopez and Orcas Island with denser housing as wildland urban 

interface (≥6.18 houses per km2 and ≤50 percent cover of wildland vegetation) (Martinuzzi et al. 2015). 

The BLM often uses various vegetative management tools, such as thinning and prescribed fire, to bring a 

landscape into closer conformance with its historical fire regime, as well as to reduce wildfire threats to 

homes and property from increased fuel loading. Currently, the BLM is not conducting fuels treatments 

of any sort in the Monument. Within the San Juan Islands, the National Park Service and The Nature 

Conservancy use thinning and prescribed burning to restore various plant communities. Other 

landowners use prescribed burning to dispose of fuels created by land management activities. 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

238 
 

 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Grassland fuelbeds provide the highest surface fire (i.e., fire that spreads through ground level fuels) 

2 potential under severe burning conditions (Table 62). The drier forests, such as those dominated by 

3 Douglas-fir and grand fir, have the highest spread potential and crown fire (i.e., fire that spreads through 

4 the top layer of foliage and is typically the most intense type of fire) potential. Crowning occurs readily 

5 in those trees growing in the grassland, but since such trees are generally widely scattered, there is no 

6 crown fire spread potential. However, torching (i.e., crowning in a single tree or small group of trees) 

7 could loft embers into surrounding fuel types, allowing spot fires to start under dry conditions. While the 

8 crowning potential in all forest types on the San Juan Islands is only moderate at most, they all have a 

9 high potential to support the spread of a crown fire. All forest types also have high fuel loading, but fine 

10 fuel loading is light (Table 62). The light loading indicates that starting a fire in these fuelbeds is 

11 difficult, but the heavy loading in coarse wood and duff indicate that once a fire is established, 

12 suppression could be difficult, especially in the riparian forests. 

13 The rates of spread and surface fire flame lengths in Table 62 are what would occur under relatively 

14 severe burning conditions in summer. Under the milder conditions that are more typical of the San Juan 

15 Islands, rates of spread would be slower and flame lengths lower. Other factors affecting potential fire 

16 behavior are slope steepness and midflame windspeed. On gentler slopes or under lower windspeeds, 

17 expected rates of spread and flame lengths would be lower, whereas they would be higher on steeper 

18 slopes or under higher windspeeds. 

19 Table 62: Outputs of key potential fire behavior from FCCS 

Fuelbed Name FCCS ID FCCS 

Code 

Crown Fire 

Initiation 

Potential 

Crown Fire 

Spread 

Potential 

Surface Fire 

Rate of Spread 

Surface Fire 

Flame Length 

Dry Forest and 

Woodland 208u2 659 4 9 41 chains/hour 9 ft 

Moist Forest 2u3 339 3 8 16 chains/hour 5 ft 

Riparian Forest 2u4 439 3 9 15 chains/hour 6 ft 

Grassland 41u2 940 8 0 99 chains/hour 12 ft 

Willow Shrubland 331u1 402 0 0 14 chains/hour 4 ft 

20 Note: the marsh fuelbed resulted in no estimates of fire behavior potential. The FCCS code, Crown Fire 

Initiation Potential code, and Crown Fire Spread Potential code vary from 0 to 9 (Prichard et al. 2013). 

The surface fire rates of spread and flame lengths are based on very dry woody fuels, cured grasses, 15 

percent slope, and 10 mph midflame wind speed. 1 chain = 66 feet 

The FCCS code consists of three potentials: surface fire potential, crown fire potential, and available fuel 

potential. Higher numbers indicate greater risk. The surface fire potential (first number in the code) is 

comprised of codes concerning reaction intensity, rate of spread potential, and flame length potential. 

The crown fire potential (second number) consists of codes for crown fire initiation potential and crownto-crown spread potential, or transmissivity, and crown fire spreading potential. Crown fire spread cannot 

occur until the fire can initially spread into tree crowns and then spread from crown-to-crown. Thus, the 

BLM has focused on those two elements of the crown fire potential. 

The surface fire behavior affects how readily firefighters can successfully suppress a fire, although other 

factors can affect success rates beyond what the fire behavior estimates indicate. In addition, actual fire 

behavior can vary from predicted fire behavior by a factor of two, ranging from half as much to twice as 

much. As rules of thumb, predicted flame lengths of 4 feet represent the upper limits of direct attack of a 

fire using just hand tools and predicted flame lengths of 8 feet indicate a high probability of tree 

crowning. However, the spacing between trees also affects whether a fire can move from crown-to-crown 

and burning conditions, particularly windspeed and live foliar moisture, affect whether an active crown 

fire can develop. 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

239 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Current Risks to Monument Objects and Values 

Ecological Objects and Values 

The Monument’s ecological objects and values include its diverse plant communities and the native plants 

and wildlife species that occur within them. Some of these communities are fire dependent and 

threatened by the lack of wildfire and the possibility of uncharacteristically severe wildfire. Others are 

fire sensitive and threatened by degradation or loss of habitat or direct mortality from high intensity 

wildfire. For still others, little is known about potential responses to wildfire of differing intensities or 

severity, resulting in unknown risks. 

The ecological values at risk from lack of wildfire or potentially uncharacteristically severe fire include 

species that typically grow in warmer, drier habitats or somewhat moister habitats previously maintained 

by fire. These include species that occupy woodlands, savannas, or grasslands, including many culturally 

important plants. As discussed above, Native Americans/Indigenous Peoples created and maintained 

habitat for these species through land management practices, including the frequent use of fire. These 

fire-maintained settings also created habitat for certain wildlife species such as western bluebirds, deer, 

and other species that depend on open areas or open woodlands. Conifer encroachment and stand 

densification has occurred on most Monument lands, reducing the extent of grasslands and nearly 

eliminating savannas and woodlands except in areas with a high proportion of surface rock. 

Surface fuel build-up, primarily in the form of dead thatch in grasslands, increased woody fuels, and duff, 

increase the probability of uncharacteristically severe fire with respect to soil heating and seed banks as 

well as many culturally important forbs. Much of this severity would arise from long-term smoldering 

that creates lethal soil temperatures in the upper 1-2 inches of soil, killing seeds and killing or severely 

damaging meristems. 

Conifer encroachment and stand densification have increased canopy fuels, with a resulting increase in 

the risk of stand-replacing wildfire or larger stand-replacing patches than may have occurred historically. 

This change places both fire dependent and fire sensitive species at greater risk. For example, the 

apparent increased presence of fire sensitive conifers such as grand fir and western hemlock at the 

expense of fire-adapted species such as Douglas-fir and Garry oak, results in more continuous canopy 

cover in the uplands and much higher risk of active crown fire development. Old tree-dependent species 

are more likely to lose substantial amounts of habitat with the loss of more complex forest structure. 

Prior to fire exclusion, habitat for such fire sensitive species was likely restricted to northerly aspects and 

wetter areas that were somewhat protected from stand-replacing fire by the surrounding more open forests 

and woodlands that limited the potential for crown fire development. 

Little is known about the relationship of most forbs and some wildlife species to fire. For example, the 

island marble butterfly occupies grasslands in close proximity to the Monument and is dependent on a 

native mustard during the larval stage. While many members of the mustard family increase following 

fire, not all mustard species do and nothing is known about the fire ecology of the native mustard, tall 

pepperweed (Lepidium virginicum var. menziesii), that the island marble butterfly formerly depended 

upon. The butterfly also uses two non-native mustards (field mustard, or Brassica rapa, and tumble 

mustard, or Sisymbrium altissimum) (Lambert 2011) that can increase following disturbances that create 

bare soil. Tumble mustard also appears to persist in the seedbank for many decades (Howard 2003). 

Cultural Objects and Values 

The Monument’s cultural objects and values include both historic structures and archaeological sites (see 

the Cultural Resources section for detailed descriptions). The historic structures include Patos Island 

Lighthouse and Turn Point Light Station and its associated buildings. Archaeological values consist of 

buried artifacts dating from both before and after Euro-American settlement. These values include 

middens, burial sites, former village sites, and artifacts associated with the lighthouses. 

Patos Island Light is a wooden structure located at the northwestern tip of Patos Island in an open area 

dominated by surface rock, short grass, and patches of low shrubs. Dense forest lies approximately 0.1 

240 
5

10

15

20

25

30

35

40

45

1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

miles to the southeast. The lighthouse appears to be moderately well protected from wildfire by its 

setting. While embers from a crown fire might ignite the structure, it would require a rare southeasterly 

wind during an unusually hot and dry summer. 

Turn Point Light Station is a concrete structure located on the western tip of Stuart Island. The site 

includes numerous other wooden structures within a woodland setting that has a grass understory. Solar 

panels and a propane generator provide power to the site; these are in a more forested setting up the hill 

from the structures. Google Earth imagery of the site suggests that canopy cover of conifers has 

increased since 1998, likely due to continued tree growth. Canopy cover appears to be more continuous 

around the associated structures (e.g., the keeper’s quarters) than around the main lighthouse and fog 

building, although much of the area around the keeper’s quarters also has no trees overhanging the 

structure. All structures, with the exception of the concrete light, are vulnerable to spotting (i.e., the 

spread of fire by wind-carried embers) and crown fire under east wind conditions. Surface fires that start 

after grasses have cured in the fall may be able to ignite any structures that do not have a concrete, 

concrete block, or brick foundation or if the flame heights are greater than the height of a non-burnable 

foundation. However, locally-made brick, concrete block, and masonry surfaces are subject to spalling, 

cracking, breaking, chipping, and crater formation on the surface and lime-based mortar can calcinate and 

crumble if the fire is of high enough intensity (Ryan et al. 2012). 

Archaeological resources within the Monument have not been fully inventoried (see Cultural Resources 

section for more detail). Therefore, this section discusses the vulnerability of such resources to fire and 

fire suppression actions only by general category. The vulnerability of archaeological resources depends 

on the nature of the resource, its location (above or below the soil), and fire intensity or severity (Ryan et 

al. 2012). Artifacts buried in soil are generally protected from fire, with essentially no impact from even 

the highest severity fires if buried at least six inches deep in the soil unless they are located adjacent to a 

tree root or stump that burns out (Ryan et al. 2012). Artifacts containing or consisting of wood or other 

plant materials, leather, bone, rubber, or plastics can be completely consumed and lost if on the surface, 

and can be charred or otherwise damaged in higher severity fires that result in high surface soil 

temperatures when located in the upper 1 to 2 inches of soil. Stone artifacts on or just under the soil 

surface made of quartz, quartzite, mudstone, siltstone, sandstone, or slate can suffer from micro- or 

macrocracks, spalling, exfoliation, and discoloration in areas of high fuel loading (e.g., large logs, dense 

brush) that burned completely or nearly completely (Ryan et al. 2012). Shell middens are likely better 

protected from fire, in part due to the material and in part due to their typical shoreline location. 

In addition to damage from fires, archaeological resources can be at risk from fire suppression actions 

(Ryan et al. 2012). Artifacts located close to the surface can be unearthed during fireline construction or 

mop-up activities. Middens could be damaged or disrupted by heavy equipment or by aerial drops of 

retardant or water. 

Current Risks to Adjoining Properties 

The San Juan County community wildfire protection plan (CWPP) rated all lands with a relative threat 

level based on slope, aspect, gorse occurrence, precipitation, fuel models, expected rates of spread, 

expected fire intensity, population density, and critical infrastructure (San Juan County 2012). In 

addition, the CWPP indicates which communities are actively engaged in creating Firewise communities 

and structures (Table 63) (i.e., taking proactive steps to reduce their vulnerability to wildfire). 

In assessing how many structures could be at risk from a wildfire starting on Monument lands, the BLM 

used a combination of Google Earth and San Juan County tax records (available at 

https://sjcgis.org/PolarisJS/) to estimate the numbers and locations (with respect to Monument 

boundaries) of potentially affected structures. The BLM counted the number of visible structures or tax 

record structures within 1⁄4 mile of Monument boundaries as most spotting typically occurs within 1⁄4 mile 

of torching or crowning trees. The counts do not necessarily capture all outbuildings, however. 

241 
 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Lopez Island 

2 There were no Firewise communities on Lopez Island as of 2012. Individual landowners may be taking 

3 proactive actions to reduce fire risks without being part of a Firewise community. About eight structures 

4 are located within 1⁄4 mile of the Point Colville-Watmough Bay parcels, with half located to the west of 

5 Point Colville and half to the east. Additional structures are located to the west beyond 1⁄4 mile. Most are 

6 located within the trees with poor access for structure protection equipment. The level of recreation use at 

7 Watmough Bay creates a somewhat increased risk of ignitions. Steep slopes to the south of Watmough 

8 Marsh would promote torching and crowning, allowing for rapid spread uphill should a fire start in 

9 proximity to Watmough Marsh. Several structures are also located in proximity to Chadwick Hill, 

10 although many of the structures are likely better protected by the combination of plowed fields between 

11 the structures and the Monument, the general lack of ignitions, and the lower rate of recreation use. The 

12 structures that would be most vulnerable are those located within or on the edge of denser forest. 

13 Approximately 15 structures are located in proximity to Iceberg Point with about half located in the trees 

14 and half located adjacent to open areas or plowed fields. A fire starting within the grassland during high 

15 to severe burning conditions (hot, dry, and windy) would likely result in a crown fire once the fire reached 

16 the trees. The access into Iceberg Point would likely mean a frontal attack on the fire, with concurrent 

17 very high risks of entrapment and burn-over of the firefighters. These conditions place the structures 

18 located in the trees at much higher risk than those located adjacent to open areas and plowed/mown fields. 

19 San Juan Island 

20 Cattle Point is the only Monument location of appreciable size on San Juan Island. Cattle Point is 

21 predominantly grassland and very high rates of spread are possible from a fire originating in this area. At 

22 least two structures are located in adjacent dense trees, with a state-owned structure beyond in another 

23 grassland, and approximately 26 structures across the road in a subdivision. The Cattle Point community 

24 is an active Firewise community, reducing the potential risk, although is not clear if the two or more 

25 structures in the forested parcel to the east of Cattle Point are included in the Firewise community. 

26 Henry Island 

27 Kellett Bluff is located on the southern tip of Henry Island with dense forest to the north. No structures 

28 are located within 1⁄4 mile of the parcel, but at least eight vacation cabins are located just beyond that 

29 distance on Open Bay. Rapid fire spread by torching and spotting is likely under severe burning 

30 conditions with no apparent road access to the structures. There are no Firewise communities on Henry 

31 Island as of 2012. There are no fire stations on Henry Island, so response is via boat by San Juan Fire 

32 District #3 under contract with WDNR. 

33 Stuart Island 

34 Turn Point is located on the northwest tip of Stuart Island. At least two structures are located within 1⁄4 

35 mile of Monument land to the south-southeast and several additional structures are located about 1⁄2 mile 

36 to the east. The two closer structures are located within denser forest while the structures further away 

37 are located near or adjacent to openings and in more open forest. There are no fire stations on Stuart 

38 Island, so response is via boat by San Juan Fire District #3 under contract with WDNR. 

39 Table 63: Potential fire risks posed to structures on adjoining lands from a wildfire originating on 

40 Monument lands 

Monument 

Parcel 

Structures 

within 1⁄4 

mile 

CWPP 

Wildfire 

Threat Rating 

Firewise 

Community 

Primary Fire 

Behavior Concern 

Primary Fire Weather 

Concern* 

Turn Point 2 Low to 

Moderate No Crown fire, torching spotting 

Strong west or 

northwest winds 

Kellett Bluff 0 Low No Torching and spotting Strong south or 

southwest winds 

242 
 

 

 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Monument 

Parcel 

Structures 

within 1⁄4 

mile 

CWPP 

Wildfire 

Threat Rating 

Firewise 

Community 

Primary Fire 

Behavior Concern 

Primary Fire Weather 

Concern* 

Cattle Point ~30 Moderate Yes Rapid spread Strong south or 

southwest winds 

Iceberg Point ~15 Moderate to 

High No Rapid spread, crown fire, torching, spotting 

Strong south, southwest, 

or west winds 

Point ColvilleWatmough 

Bay 

8 Low to 

High No 

Crown fire, torching, 

spotting, rapid spread 

uphill from 

Watmough Marsh 

Strong west or 

southwest winds, 3 

structures vulnerable to 

east winds 

Chadwick Hill 24 Low to 

Moderate No Crown fire, torching, spotting 

Strong south or 

southwest winds 

1 * Assumes hot, dry, and windy conditions, focus is on wind direction

2 Note: The focus of this table is on the parcels large enough for a free-burning wildfire to develop.

3 Effects of the Alternatives 

4 No Action Alternative and Alternatives A and D 

5 Under the No Action Alternative, the BLM would continue to take a custodial approach to management 

6 and vegetative communities in the Monument would further depart from historical conditions. Douglas7 fir and other conifers would continue to expand into the remaining oak woodlands and grasslands, further 

8 reducing the remaining camas gardens. These changes in the plant communities and associated fuel beds 

9 would increase the likelihood that when wildfires do occur, both fire behavior and fire effects would be 

10 more likely to produce undesired effects, such as high levels of smoke, increased erosion risks, and loss of 

11 vegetation features discussed in Proclamation 8947. In addition, such fires could pose an increased threat 

12 to structures downwind of Monument lands on the lower southeast section of Lopez Island. Fires on 

13 other Monument lands would be unlikely to pose risk to privately owned structures. However, given the 

14 size and location of most parcels in the Monument, the BLM has very limited opportunity to influence 

15 fire risks to private lands. 

16 The expected effects of alternatives A and D would be similar to the No Action Alternative. Under 

17 Alternative A, the BLM would continue a passive management approach and would likely conduct 

18 vegetation treatments only to control invasive plants and remove hazard trees (see Table 17 on page 111). 

19 The treated areas would maintain the same expected fire behavior and risks as under current conditions, 

20 although the untreated areas would experience changes in fire risk similar to the No Action Alternative. 

21 Alternative D seeks to maintain current conditions, and therefore would maintain current risks and 

22 expected fire behavior. 

23 Alternatives B, C and Sub-C 

24 This section describes how treatment of moist forest, dry forest, and grasslands would alter potential 

25 crown fire risks and fire behavior under alternatives B, C, and sub-C using typical summer wildfire 

26 conditions for the western United States. Although alternatives B, C and sub-C have different objectives 

27 and management direction, their impacts on fuelbed composition and structure, and the resulting potential 

28 fire behavior and fire risks, are very similar (Table 64). The remaining three vegetation types (riparian 

29 forest, marsh, and willow shrubland) comprise only a minor portion of the Monument and would either be 

30 an unlikely target for treatment or treatments would not be expected to alter wildfire risks (e.g., treatments 

31 in wetlands would not alter wildfire risks). 

243 
1 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Table 64: Changes in potential key fire behavior for alternatives B, C and sub-C post-treatment 

Fuelbed Name FCCS Code 

Crown Fire 

Initiation 

Potential 

Crown Fire 

Spread 

Potential 

Surface Fire 

Rate of 

Spread 

Surface Fire 

Flame 

Length 

Dry Forest and 

Woodland 522 Decreased 50 percent Eliminated Decreased ~30 percent 

Decreased 

~30 percent 

Moist Forest 624 Unchanged Eliminated Increased 

~168 percent Doubled 

Grassland 900 Unchanged Unchanged Increased ~30 

percent Unchanged 

2 Sources: Fuel Characteristic Class System and Consume 3.0 

Dry Forests and Woodlands 

Following treatment, forest canopies would be more open, ladder fuels largely eliminated, dead, downed 

woody fuels decreased, and grass fuels increased. Torching (ignition of the crown of one tree or a small 

group of trees) would still be likely but active crown fire (fire spreading through the crowns of trees) 

would not. Where treatment increased the proportion of deciduous trees, such as oak, the probability of 

torching would decline further as deciduous trees usually cannot support crowning fire. Reductions in 

duff and dead, downed woody fuel would greatly reduce smoldering combustion and resulting heat pulses 

into the soil and create more rapid burn out times (time for all available fuel to finish burning). The 

expected flame length would still exceed that considered safe for direct attack at the head of the fire but 

the reduced risk of crown fire and conversion to a dominance of grass fuels would increase the 

effectiveness of suppression tactics, including the use of water, firefighting foam, and retardant. 

Conversion of the surface fuels to predominantly grasses with their rapid burnout times would also permit 

the use of additional tactics, such as inside-out attack, where terrain is favorable. Inside-out attack 

consists of driving an engine into the burned area and applying water, foam, or retardant to the rear of the 

flames. 

Moist Forests 

Following treatment, forest canopies would be more open, ladder fuels greatly reduced but not eliminated, 

dead-downed woody fuels and shrub fuels reduced, and grass fuels increased. The BLM expects that 

moist forests would remain conifer dominated. Treatment would result in little to no change in torching 

potential, but active crown fire potential would be greatly reduced or nearly eliminated. Less duff and 

reduced dead, downed woody fuels would reduce burnout times, although likely not to the degree as in 

dry forests and woodlands. Expected flame lengths would nearly double and would exceed that 

considered safe for direct attack at the head of the fire, although the reason for that change is not clear 

given the expected changes in the fuelbed. Clumps of shrubs are more likely to produce the predicted 

flame lengths than grassy areas. Taller shrubs and grasses in moist forest as compared to the dry forest 

could also be a factor in the predicted increased flame lengths. More open canopy and lighter surface 

fuels should increase suppression effectiveness, however, such as use of burning out and application of 

firefighting foam or retardant. The increase in the extent of grass fuels may allow for a wider array of 

tactics, such as inside out attack where terrain and fuel arrangement permit. 

Grasslands 

Following treatment, woody fuels such as trees and shrubs would be reduced or eliminated, thereby 

eliminating torching and active crown fire. Since this type would remain grass dominated, flame lengths 

and burnout times would remain unchanged. Surface fire rate-of-spread would likely increase as fire 

usually spreads faster in grass fuels than in shrub or downed woody fuels. Reducing or eliminating these 

elements in the grassland would also reduce or eliminate pockets where fire spread would be lower. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

244 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Risks to Monument Objects and Values 

The predicted changes in fire behavior would likely reduce risks to Monument ecological values and 

some cultural objects and values. The BLM expects that changes in the available fuel potential would 

cause a decrease in the extent of smoldering combustion and duration of residual burning, reducing heat 

pulses into the soil and limiting heat exposure aboveground. Reducing the heat pulse into the soil would 

help protect seedbanks and cultural artifacts buried in the top six inches of soil (Ryan et al. 2012, Chapter 

2). The expected changes in fire behavior would also better protect the large trees that create old growth 

character in forests and woodlands (Stephens et al. 2009, Johnson et al. 2011, Safford et al. 2012) 

The BLM estimates that it would undertake prescribed burning to achieve habitat and plant communities 

objectives under alternatives B and C. This would likely favor fire-adapted culturally important plant 

species, such as camas. Ethnographic accounts indicate that many coastal prairies and grasslands were 

burned annually or semi-annually (Boyd 1999, Beckwith 2004). Late summer and fall burning, both 

before the onset of fall rains and after berry harvesting, appears to have been the more common practice 

in the Puget Sound area (Boyd 1999, Beckwith 2004), such that plant response may depend more on 

season of burn than frequency of burn. 

However, confounding potential favorable responses of culturally important plant species are the potential 

responses of invasive plant species. Many invasive plants are also disturbance adapted and thus favored 

by fire (Zouhar et al. 2008). Since alternative sub-C would not allow the use of herbicides to control 

invasive plants, the combination of ineffective control and the likelihood of prescribed fire would be more 

likely to favor invasive plants, especially invasive grasses, over culturally important plants (see also 

discussion under Habitat and Plants Issue 2). This risk would be lower under alternatives B and C, where 

use of herbicides in combination with other treatment methods would be more likely to successfully 

control invasive plant species. 

All three alternatives would reduce the risk of ignition from crown fire and ember showers from shortrange spotting for most historic structures by roughly equal amounts. Historic structures would remain 

vulnerable to ember showers from longer range spotting if forests on adjoining lands remain untreated. 

However, increased flame lengths could increase threats to some historic structures, exposing some to 

direct flames that exceed the predicted flame lengths under current conditions. Whether this particular 

threat would occur depends on whether grasses actually increase, particularly in moist forest, and the 

types of grasses that come in. As the FCCS outputs indicate, flame length is, in part, a function of 

fuelbed height. Tall grasses, such as the non-native tall fescue, Kentucky bluegrass, or orchardgrass are 

also more likely to produce the higher flame lengths than the typically shorter native bunchgrasses. In 

addition, because grass production varies from year-to-year, the threat would be higher following a year 

with a wetter spring or summer than following a year with a drier spring or summer and may be highest in 

a year with a wetter winter and spring followed by a flash drought. 

The BLM cannot predict with any acceptable level of accuracy whether grasses would increase in moist 

forests and what species of grasses would be likely to appear, particularly where post-treatment seeding 

did not occur. Whether post-treatment seeding would occur and what species the BLM would plant 

depends on specific implementation-level project design and is outside the scope of this analysis. Species 

of grasses nearby can provide seed sources. Rhizomatous species can spread into the treated area via 

underground stems. In dry forests, one intent of treatment would be to approximate historical conditions 

(alternatives C and sub-C) or to create conditions more resistant to insects, disease, drought, and fire 

(Alternative B), which would include an increase in grasses. 

Risks to Adjoining Properties 

Thinning in both dry and moist forest would reduce risks to adjoining properties from fires originating on 

or crossing Monument parcels that are largely forested. The greater risk to adjoining properties would be 

from ember showers originating in crown fires (Manzello and Foote 2014 and references therein). 

Success rates at stopping fire spread in tree crowns are very low since the only suppression technique is to 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

245 
 

 

 

 

 

 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

moisten tree crowns with water or reduce flammability through application of retardant or firefighting 

foams (Alexander and Cruz 2011). However, it is nearly impossible to treat entire tree crowns adequately 

with water, retardant, or foam. Therefore, the preferred technique is to reduce ladder fuels to greatly 

reduce crown fire initiation and thin stands enough that spread from crown-to-crown (transmissivity) is 

very low (Alexander and Cruz 2011, Johnson et al. 2011, Contreras et al. 2012). These techniques 

typically cause the fire to “drop” to the surface where firefighters can safely apply a greater number of

suppression techniques with higher rates of success in stopping wildfires (Moghaddas and Craggs 2007, 

Stephens et al. 2009). The FCCS output indicates that crown fire initiation within treated Monument 

parcels would reduce crown fire initiation in dry forest and leave it unchanged in moist forest. In both 

forest types, crown fire initiation probability would be low to moderately low and consist more of 

torching trees. In both forest types, thinning would reduce the probability of crown fire transmissivity to 

zero, indicating that crown fires entering treated Monument parcels would drop to the surface. 

Although treated Monument parcels would be unlikely to be large enough to completely halt fire spread, 

they could reduce potential fire severity for a short distance downwind of the parcel under more severe 

burning conditions (Martinson et al. 2003, Moghaddas and Craggs 2007, Kennedy and Johnson 2014). 

This effect would be most likely if a stand-replacing wildfire were to burn into a treated Monument parcel 

when the fire was still small (Martinson et al. 2003). 

Rapid fire spread would remain a concern due to the increase in grass fuels that would occur under these 

alternatives. However, as discussed above, firefighters likely would also have more options in 

suppression tactics. Similarly, the area’s steep slopes indicate that the risk of rapid spread uphill out of 

the Watmough Marsh area would remain unchanged. 

Table 65: Changes in expected fire risks to adjoining structures under alternatives B, C and sub-C 

from fires originating within or burning through treated Monument parcels 

Monument 

Parcel 

Structures within 

1⁄4 mile Primary Fire Behavior Changes 

Turn Point 2 Reduced torching and spotting, no crown fire 

Kellett Bluff 0 Reduced torching and spotting 

Cattle Point ~30 No change from current condition 

Iceberg Point ~15 Continued rapid spread, reduced torching and spotting, no 

crown fire 

Point ColvilleWatmough Bay 8 Reduced torching and spotting, reduced crown fire risk, 

continued rapid spread uphill from Watmough Marsh 

Chadwick Hill 24 Reduced torching and spotting, no crown fire 

24 Conclusions 

The No Action Alternative and alternatives A and D would likely lead to higher fire risks, lower 

protection or maintenance of fire-dependent Monument objects and values, and increased risks to 

adjoining properties. Alternatives B and C would reduce fire risks, maintain or enhance fire-dependent 

Monument objects and values, and reduce risks to adjoining properties. Alternative sub-C would produce 

some reduction in fire risks, partially maintain or enhance fire-dependent Monument objects and values, 

and moderately reduce risks to adjoining properties, but the probable increase in invasive species would 

reduce the effectiveness of this alternative relative to alternatives B and C. 

Cumulative Effects on Fire Behavior in the San Juan Islands 

Most of the Monument parcels are too small to have a substantial effect on fire regimes, condition class, 

wildfire behavior, and risks of adverse impacts from wildfires on any particular island, with the possible 

exception of Patos Island. Since the BLM manages all of Patos Island, the agency could alter vegetation 

and fuel condition class, potential fire behavior, and potential fire effects under alternatives B, C, and subC, but likely would not have the same effect under the No Action Alternative or alternatives A and D. 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

246 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The location of most Monument lands on points and other edges of islands limits the ability of any single 

parcel or all the parcels collectively to substantially affect overall wildfire risks, regardless of which 

alternative the BLM selects. However, where parcels are located upwind of active Firewise communities, 

changes to potential fire behavior and fire risks on the parcel would likely enhance the effectiveness of 

hazardous fuel reduction treatments on those properties under alternatives B, C, and sub-C. 

Wildlife and Fish 

Key Points 

 Departure from historic disturbance patterns is changing the extent and condition of habitats within

the Monument.

 There are trade-offs between the alternatives for wildlife associated with different Monument

habitats. The No Action Alternative and Alternative A would be beneficial for wildlife that make use

of forests with closed canopies. Alternatives B and C would be beneficial for wildlife that make use

of grasslands and shrublands, more open woodlands, and wetlands. 

 Alternative D would have the most trails within 300 feet of formally identified marine mammal

haulouts and within 300 feet of the shoreline in general. This alternative would have the greatest

potential for disturbance to nearshore wildlife, including marine mammals and seabirds.

 Alternatives that would enhance the extent and condition of Monument grasslands and shrublands

would expand potential habitat for the island marble butterfly, though only Alternative B is likely to

expand potential larval habitat. 

 The No Action Alternative and Alterative D would allow the greatest amount of recreational use of

the Monument and have the greatest potential for disturbance to wildlife.

This section contains three analytical issues: 

1. How would changes in the quality and quantity of habitat and plant communities affect wildlife

species and fishes (including sensitive species) under each alternative? (page 249)

2. How would variations in human use/disturbance under each alternative affect wildlife species and

fishes (including special status species)? (page 265)

3. How would the alternatives address the primary threats to island marble butterflies identified in the

U.S. FWS’ 12 month finding for the species? (page 280)

4. How would variations in the control of wildlife of management concern (i.e., potentially harmful

wildlife) and opportunities for hunting using firearms impact wildlife habitat? (page 284)

Background 

As stated in Proclamation 8947, “the diversity of habitats in the San Juan Islands is critical to supporting

an equally varied collection of wildlife.” Thus, the BLM’s role in maintaining and/or improving habitat

for wildlife is a focus of this section. However, because the BLM manages only a fraction of the habitat 

in the San Juan Islands, and does not have direct jurisdiction over the wildlife species occurring in the 

Monument, this document emphasizes those species most likely to occur within the Monument’s 

boundaries and those that have a special status under law or policy. 

Federally Listed Species 

Thirteen federally listed species occur in the San Juan Islands. The majority of the listed species in the 

islands, including orcas and listed fish species, occur in the waters surrounding the islands and are not 

present in habitats directly managed by the BLM. It is possible that in the future the U.S. FWS or NOAA 

Fisheries could identify recovery actions for listed species pertaining to Monument lands. As described 

in Wildlife Issue 3, in April of 2018 the U.S. FWS published a proposed rule to list the island marble 

butterfly, which is currently a candidate species, as an endangered species and designate critical habitat 

under the Endangered Species Act of 1973 (ESA) (U.S. FWS 2018). Critical habitat would include the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

247 
 

 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Monument land at Cattle Point (approximately 23 acres). Table 66 provides the federally listed species in 

2 the San Juan Islands and their current regulatory status. 

3 Table 66: Listed threatened and endangered species in the San Juan Islands* 

Group Species Status Presence Habitat Association

Birds Marbled murrelet

(Brachyramphus marmoratus) FT D Marine/nearshore

Marine 

Mammal

Orca (Orcinus orca), Southern Resident 

Distinct Population Segment (DPS) FE D Marine

Insect Taylor’s checkerspot butterfly

(Euphydryas editha taylori) FE X Grasslands andshrublands

Fish Bocaccio (Sebastes paucispinis) FE D Nearshore (juv), deep 

water rocky (adult)

Fish Green sturgeon (Acipenser medirostris), 

Southern DPS FT D Nearshore marine, estuary, migratory marine

Fish Eulachon (Thaleichthys pacificus), Southern 

DPS FT D Marine areas deeper than20 m, estuarine

Fish Bull trout (Salvelinus confluentus), Puget 

Sound/Coastal DPS FT D Nearshore marine areas, migratory marine

Fish Chinook (Oncorhynchus tshawytscha), Puget 

Sound Evolutionarily Significant Unit (ESU) FT D Nearshore marine areas, migratory marine

Fish Chum (Oncorhynchus keta), Hood 

canal/Summer run ESU FT D Nearshore marine areas, migratory marine

Fish Steelhead (Oncorhynchus mykiss), Puget 

Sound DPS FT D Nearshore marine areas, migratory marine

Fish Yelloweye rockfish (S. ruberrimus) FT D Nearshore (juv), deep 

water rocky (adult)

4 D-Documented, FE-Federally Endangered, FT-Federally Threatened, X-Extirpated or historically present 

5 *These species are documented or suspected in the San Juan Islands as a whole, not necessarily on within 

6 the Monument. 

7 Bureau Sensitive Species 

8 In addition to the federally listed species described above, 10 Bureau sensitive species occur or are 

9 suspected to occur within the Monument. As described above, the BLM emphasizes managing habitats to 

10 promote conservation and avoid the need for listing pursuant to the ESA (BLM 2008c). 

11 Table 67: BLM sensitive species in the San Juan Islands* 

Group Species Federal

Status

State

Status Presence Habitat Association

Bald eagle (Haliaeetus 

leucocephalus) BS D Forest & woodlands/nearshore 

Common loon (Gavia immer) BS S D Wetlands/nearshore

Birds Gyrfalcon (Falco rusticolus) BS M D Grasslands & 

shrublands/wetlands

Harlequin duck (Histrionicus 

histrionicus) BS D Nearshore

Lewis’s woodpecker (Melanerpes 

lewis) BS Forest

248 
 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

Group Species Federal

Status

State

Status Presence Habitat Association

Peregrine falcon (Falco peregrines) BS D Grasslands & 

shrublands/nearshore 

Sandhill crane (Grus Canadensis) BS Grassland and riparian 

(winter visitor)

Short-eared owl (Aegolius acadicus) BS Suspected Grasslands & shrublands

Terrestrial

Mammals

Little brown myotis (bat) (Myotis

lucifugus) BS D Forest & woodland/wetlands

Shaw Island Townsend’s vole

(Microtus townsendii pugeti) BS M D Forest & woodland/grasslands & shrublands

Townsend’s big-eared bat

(Corynorhinus townsendii) BS C D

Forest &woodlands/

grasslands & shrublands/

wetlands

Invertebrate Island marble butterfly

(Euchloe ausonides insulanus) PE, BS C D Grasslands & shrublands

1 BS-Bureau Sensitive, C- State Candidate, D-Documented, E-State Endangered, FC-Federal Candidate, 

M-State Monitored, PE-Proposed Endangered S-Sensitive, X-Extirpated or historically present 

*These species are documented or suspected in the San Juan Islands as a whole, not necessarily within the 

Monument. 

Wildlife Analytical Issue 1: How would changes in the quality and quantity 

of habitat and plant communities affect wildlife species and fishes (including 

sensitive species) under each alternative? 

Affected Environment 

As described under Habitat and Plants Issues 1 and 2, the Monument is composed of various plant

community classes. Each of these plant communities supports an array of wildlife, generally referred to 

as a wildlife habitat association or guild (Johnson and O’Neil 2001). This section discusses the plant

communities identified on the Monument in the context of wildlife habitat. For the current condition and 

trend of each plant community, as well as for the analysis of how the alternatives would affect these 

communities, please refer back to the Habitat and Plants section. 

For a complete list of known wildlife species within the San Juan Islands and their habitat associations, 

please see Appendix V. 

Forest and Woodland Habitat Association 

At more than 800 acres, the forest and woodland habitat type encompasses the majority of the Monument. 

Monument forests and woodlands support a multitude of migratory and resident birds, small mammals, 

amphibians, and terrestrial mollusks. While some wildlife species occur in only a particular forest type, 

many others are generalists and can occur throughout the Monument’s forest and woodlands and/or

transition zones and adjacent habitat. 

Species that may use forests and woodlands within the Monument include, but are not limited to, olivesided flycatchers (Contopus cooperi), pileated woodpecker (Hylatomus pileatus), Townsend’s big-eared 

bat, bats in the genus Myotis, and Pacific tree frog (Pseudacris regilla). Species such as the bald eagle, 

pileated woodpecker, purple martin (Progne subis), little brown myotis, and Townsend’s big-eared bat 

use large diameter live trees and snags (i.e., standing, dead trees) for roosting, nesting, or foraging. 

Sharptail snakes may occur in the oak habitat that remains within Monument lands (mostly at Kellett 

Bluff on Henry Island), though the San Juan Islands are near the northern extent of its range. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

249 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 In the past, golden eagle use of the San Juan Islands was greater than today. The numbers of eagles 

documented on the islands has been declining since the 1970s (Milner 2017a). The last documented 

active golden eagle nest in the San Juan Islands was in the late 1990s (Milner 2017b). Today, golden 

eagles may occasionally use Monument habitats, though fewer than 20 sightings have been submitted to 

ebird for all of Lopez Island and San Juan Island (Sullivan et al. 2009). Because golden eagles rarely nest 

in trees, forest conditions are unlikely to affect this species, unless they affect prey species. 

Monument forests include some relatively undisturbed, older stands of trees that may have the potential to 

provide nesting habitat for marbled murrelet and purple martin. However, there are currently no known 

occurrences of marbled murrelet nesting within the Monument (WDFW 2015b), and the U.S. FWS did 

not include the San Juan Islands in its designation of critical habitat for the species (U.S. FWS 2011)., 

Purple martins will nest in a variety of natural cavities or artificial cavities (e.g. hollow pilings, nest

boxes, gourds), often selecting locations over water. Purple martins will forage over a variety of habitat

types, but often fly over small woodland openings, fields, ponds, and marshes (Wiggins 2005).

Townsend’s big-eared bat forages in a variety of dry and moist forest types ranging from riparianwetlands, lowland conifer-hardwoods, to mixed-highland conifer forests. In eastern Washington, they 

have also been found to use mature and young-aged forests less than recently pre-commercially thinned 

forests or clear-cuts (Woodruff and Fergusen 2005). Townsend’s big-eared bat also use a variety of 

roosts, including mines, abandoned buildings, attics, and hollow snags as roosts (WDFW 2005). Little 

brown myotis can take advantage of many different habitats, foraging and roosting in a variety of 

locations, including roosting under the loose bark of snags or dying trees (Randall et al. 2014). 

Grasslands and Shrublands Habitat Association 

Monument grassland and shrublands habitats support a variety of migratory and resident birds, small

mammals, amphibians, and terrestrial mollusks. 

The Monument’s grasslands have the potential to support the rare island marble butterfly, as described 

further in Wildlife Issue 3. Another species of interest found in this habitat is the Shaw Island 

Townsend’s vole, which is considered restricted to the San Juan Islands. While not found on all islands in 

the archipelago, it is abundant on the islands where it occurs. This subspecies is BLM sensitive; WDFW

identifies it as a “monitor” species. 

Other species that may use Monument grasslands and shrubland include, but are not limited to, northern

harrier (Circus cyaneus), American kestrel (Falco sparverius), savannah sparrow (Passerculus 

sandwichensis), short-eared owl, purple martin, and peregrine falcon. Ebird includes one record of

gyrfalcon, a BLM sensitive and State monitored species, on San Juan Island from October of 1990 

(Sullivan et al. 2009). If this species makes use of the Monument, it would only be for occasional hunting 

during the winter months (Booms et al. 2008). 

Peregrine falcon hunt within the Monument’s grasslands and shrublands and nest on rocky headlands at 

both Watmough Bay and Kellett Bluff. There are thirteen records of short-eared owls on San Juan Island 

in ebird (Sullivan et al. 2009). The short-eared owl is a specialist that requires open habitats such as 

wetlands or grasslands for nesting and hunting. 

Nearshore Habitat Association 

At the interface of the terrestrial and marine environment, nearshore habitat is important for a variety of

seabirds, marine mammals, fish, marine invertebrates, and other wildlife species. Marine mammals 

haulout on the Monument’s rocky shorelines and beaches. The exposed rocks, cliffs, and driftwood along

the shoreline provide nesting habitat for a variety of birds, including peregrine falcon and black

oystercatcher (Haematopus bachmani). While the BLM’s jurisdiction ends at mean high tide, the analysis 

considers the indirect impact of the draft alternatives on nearshore habitat and species below mean high 

tide as well as above. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

250 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Harbor seals are the most abundant marine mammal encountered in the area, but California and Stellar 

sea lions and elephant seals may also make use of Monument shoreline at times. The WDFW has 

identified many of the isolated rocks and islands as important marine mammal haulouts (Jefferies et al. 

2000); most of the Monument’s shorelines have the potential for use by pinnipeds.

Several groups of fishes use nearshore marine habitats in the San Juan Islands, including forage fish, 

salmonids, rockfish, and green sturgeon. Occurrence and life history of listed species are described in the 

Wildlife section of Appendix E. Forage fish that utilize nearshore environments in the San Juan Islands 

include Pacific herring (Clupea pallasii), surf smelt (Hypomesus pretiosus), and Pacific sand lance 

(Ammodytes hexapterus). Forage fishes are an important part of the marine food web as prey items for 

sensitive salmonids, foraging raptors (such as osprey (Pandion haliaetus)), and marine mammals. Other 

species using deeper habitats (e.g., ling cod, greenling, flounder, halibut) are not addressed here since 

they are unlikely to be affected by BLM management in that sediment delivery is unlikely to occur in 

these habitats due to distance and dispersal. 

Other species that use nearshore habitat near the Monument include, but are not limited to, pelagic

cormorant (Phalacrocorax pelagicus), double-crested cormorant (Phalacrocorax auritus), pigeon 

guillemot (Cepphus columba), glaucous-winged gull (Larus glaucescens), and osprey. While an 

inventory of nesting sites is not available, seabirds are known to nest along Monument shorelines. 

Wetlands Habitat Association 

The limited freshwater resources within the San Juan Islands make the Monument’s wetlands particularly

important habitats for wildlife that depend on them, especially amphibians and waterfowl. All wetlands 

within the Monument are found on Lopez Island. At approximately 30 acres, Chadwick Marsh is the 

largest of the Monument’s wetlands. The freshwater wetland behind Watmough Bay (Watmough Bay

wetland) is approximately 5 acres and the forested wetland at Point Colville is approximately 2 acres. 

Species that may use wetlands within the Monument include, but are not limited to, Pacific tree frog, 

roughskin newt (Taricha granulosa), long-toed salamander (Ambystoma macrodactylum), red-winged 

blackbird (Agelaius phoeniceus), northern pintail (Anas acuta), mallard (Anas platyrhynchos), trumpeter 

swan (Cygnus buccinators), and great blue heron (Ardea herodias). Species like the rough-skinned newt 

depend on these freshwater habitats and small changes to the suitability or size of the wetlands available 

could negatively affect these species. Other species, such as purple martins (Progne subis), common 

loons, black swifts (Cypseloides niger), and little brown myotis do not depend exclusively on wetlands, 

but opportunistically use them as a food sources, nesting areas, hiding cover, or as a water source. 

No fish species have been positively identified in Monument wetlands (and none are specifically analyzed 

in this EIS), though the Chadwick Hill wetland may provide habitat for fish species based on remains 

found nearby by a BLM partner. 

Effects of the Alternatives 

The effects of the alternatives on wildlife vary depending on how the quantity and quality of the 

associated habitat would change. More detailed analysis is provided for each habitat type below. Table 

68 and Table 69, below, summarize effects from changes in habitat to both general wildlife associations 

and to specific special status species. 

Forest and Woodland Habitat Association 

No Action Alternative 

Under the No Action Alternative, vegetation management would be limited to removal of hazard trees 

and minimal treatment of invasive plants. The BLM estimates that forests and woodlands would expand 

by an estimated 17 acres under this alternative (see Table 7 on page 75) and forest canopies would 

continue to close. Under these circumstances, wildlife that prefer more densely stocked, coniferous forest 

would benefit most. The No Action Alternative would negatively affect wildlife that prefer shade 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

251 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 intolerant tree species or open forest due to the continued increasing density of forest canopy cover and 

the encroachment of forest species in grasslands. 

The continuation of custodial management would have a minimal effect on bald eagle, pileated 

woodpecker, and Townsend’s big-eared bat. The BLM would continue to remove the large diameter trees 

used by these species for perching, nesting, or foraging only where they are hazardous to humans or 

structures; the availability of such trees would increase slightly over the life of the plan as dominant trees 

mature. Several of these species use snags for perching, nesting, and foraging (Bull and Jackson 2011, 

U.S. FWS 2007, Adams 2001). Continued custodial management would potentially result in greater snag 

resources due to the vulnerability of trees in densely stocked forests to insects and diseases. This could 

also improve forage for insectivores, including the pileated woodpecker and the brown creeper. 

Under the No Action Alternative, forest roosting conditions for Townsend’s big-eared bat, long-legged 

myotis, hoary bat, silver-haired bat, and little brown myotis would improve over the life of the plan. As 

trees mature, become susceptible to disease, and eventually die, roosting habitat would become more 

available for these species. In the No Action Alternative, the lack of fire or timber cutting would result in 

some decreases in foraging habitat for these bats species. Most of the bats on the Monument are able to 

fly and echolocate more effectively and efficiently in woodlands and forest stands that have older stand 

qualities, mainly low or moderate understory clutter, and/or some small openings within them (Brigham 

et al 1997, Loeb and O’Keefe 2006, Smith and Gehrt 2010). 

Continuation of current management would negatively affect species that prefer open forests and/or forest 

openings, such as merlin, short-eared owls, and olive-sided flycatcher (Warkentin et al. 2005, Altman and 

Sallabanks 2012). Increasing tree density over the life of the plan would degrade hunting habitat for 

merlin and flycatchers. Under this alternative, oak woodlands would continue to decline in the 

Monument, reducing the potential habitat for sharptail snakes (Contia tenuis) (Milner 2017a). 

Alternative A 

Under Alternative A, the BLM would allow current trends to continue until specified thresholds have 

passed. The BLM assumes that this would result in the continuation of limited vegetation management 

over the life of the plan. Impacts to wildlife from this limited approach would be very similar to under 

the No Action Alternative. As under the No Action Alternative, the BLM estimates that forests and 

woodlands would expand by 17 acres and forest canopies would continue to close. 

Alternative B 

Under Alternative B’s habitat and plant communities objectives, forests and woodlands within the 

Monument would decrease by approximately 50 percent. In order to meet this alternative’s objectives, 

the BLM estimates that it would undertake treatments primarily in what are now succession class B 

forests (i.e., relatively young forests with a closed canopy, see Table 8 on page 78) in order to expand 

grasslands and shrublands. In addition, the BLM estimates that it would conduct thinning to promote the 

growth of large old trees and oaks and other shade intolerant tree species that are currently in decline. 

The BLM assumes that it would use prescribed fire to promote the health of oak woodlands and 

potentially restore some woodland to oak savanna. 

Species such as the bald eagle, pileated woodpecker, hoary bat, little brown myotis, and Townsend’s bigeared bat, that use forest habitat for perching, nesting, roosting or foraging would generally be negatively 

affected by the decrease in this habitat type under Alternative B. For example, loss of forest habitat, 

particularly near shorelines, would reduce some perching sites near preferred bald eagle hunting areas 

though taller, older, over-story trees would generally be retained. Retention of older aged trees and some 

snags would provide roosting habitat and characteristics of a mature forest with available space for 

foraging (Loeb and O’Keefe 2006, Smith and Gehrt 2010). Over time, thinning and pruning treatments 

that support hardwood and large and old tree growth would improve potential nesting and roosting habitat 

in the remaining forests and woodlands. Use of prescribed fire may increase snag availability if some 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

252 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 mature trees are lost during implementation, benefiting species that make use of dead trees, such as bald 

eagles and most bats associated with the Monument. 

Potential hunting habitat for golden eagles would expand under Alternative B. This uncommon species 

could benefit from additional acres of open grasslands and shrublands where prey could be found, such as 

non-native rabbits and eastern red foxes (Vulpes vulpes fulvus), though foxes occur only on San Juan 

Island. 

Alternative C 

Under Alternative C, effects on species associated with forests and woodlands would be similar to under 

Alternative B. Under both alternatives, the BLM would substantially reduce the acreage of forest and 

woodland habitat within the Monument. However, the BLM would convert less forest acreage to 

grassland or shrubland under this alternative than under Alternative B. Those species that require forest 

would be negatively impacted by Alternative C, but not as much as under Alternative B. Species that 

utilize large diameter trees or snags may benefit from thinning in remaining forests and increased snag 

availability due to prescribed fire, but those benefits are unlikely to ameliorate the loss of forest habitat. 

Alternative D 

Under Alternative D, the BLM would maintain forested habitat at its current extent and condition in the 

Monument. Habitat for forest and woodland associated species would remain much as it is today and 

effects would be similar to those discussed under the No Action Alternative or Alternative A. Occasional 

treatments to maintain the current canopy cover would support a consistent stand density and understory, 

although the diameter of trees would gradually increase, benefitting species that utilize large diameter 

trees such as bald eagle and pileated woodpecker. 

Conclusion 

The No Action Alternative and Alternative A would result in continued canopy closure, which would 

benefit wildlife species that prefer denser forest conditions. Alternatives B and C would substantially 

reduce acres of forested habitat in the Monument, which would negatively affect species that depend on 

these habitats. Additionally, the BLM would treat remaining forest and woodlands to reduce tree density 

and to favor tree species that are currently declining in the San Juan Islands, such as oaks and other 

hardwoods. This would have a negative impact on species such as the pileated woodpecker, that prefer 

more closed canopy forest conditions with a high prevalence of diseased and infested trees. Thinning 

forests and creating forest openings would benefit species such as merlin, short-eared owls, and olivesided flycatcher. Under Alternative D, Monument forests would remain much as they are currently; the 

BLM would not expect substantial changes to forest wildlife populations within the Monument. 

Cumulative Effects of Changes to Habitat Quantity and Quality on Forest and 

Woodland Associated Species 

The majority of forest and woodland habitat available to wildlife within the San Juan Islands is managed 

by private landowners, the National Park Service, and the State of Washington. The Monument includes 

less than 2 percent of the Southern Vancouverian Dry Foothill Forest and Tsuga heterophylla - Picea 

sitchensis - Sequoia sempervirens Forest macrogroups that occur in the San Juan Islands. The BLM 

assumes that current management would continue on all non-Monument lands. 

While a variety of past management actions have affected forest and woodland habitat in the San Juan 

Islands, the primary agents were the end of fire as a management tool on the landscape and timber harvest 

after Euro-American settlement. These actions have altered the historic condition, extent, and distribution 

of forest and woodland habitat in the San Juan Islands. 

Other than hazard tree removal, there is currently limited active management of forest and woodland 

habitat occurring on public lands in the San Juan Islands. The San Juan County Land Bank is restoring 

Garry oak woodland on approximately 25 acres of land on Orcas and San Juan islands (Habbeger 2017). 

There remains some small-scale timber harvest occurring on private lands, including management 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

253 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 intended to reduce the density of the forest canopy and enhance oak woodlands (Northwest Natural 

Resources Group 2017, Rainshadow Consulting 2017). 

Reasonably foreseeable actions that are likely to affect forest and woodland habitats in the San Juan 

Islands over the life of the plan include continued forest succession leading to more densely stocked forest 

stands, continued harvest and removal of forests, wildfires, gradual loss of the hardwood component of 

forests, insect and disease influences on forest habitat, and loss of forest to agricultural and urban 

development. 

Under all alternatives, the Monument will continue to contribute only a small percent of the habitat 

available in the San Juan Islands for forest and woodland associated wildlife. Under the No Action 

Alternative and alternatives A and D, the Monument would continue to contribute less than 2 percent of 

the Southern Vancouverian Dry Foothill Forest and Tsuga heterophylla - Picea sitchensis - Sequoia 

sempervirens Forest macrogroups that occur in the San Juan Islands. 

Under alternatives B and C, the BLM would reduce the acreage of forest habitat within the Monument 

would by approximately 50 percent. This would result in a decrease of less than 1 percent of the Southern 

Vancouverian Dry Foothill Forest and Tsuga heterophylla - Picea sitchensis - Sequoia sempervirens 

Forest macrogroup acres in the San Juan Islands; would not be a substantial decrease relative to the 

amount of forest available to wildlife within the San Juan Islands. Under alternatives B and C, the BLM 

would enhance woodland habitats and open forest conditions, which are declining in the San Juan Islands. 

Because less than 2 percent of the forest habitat in the San Juan Islands would be managed under the 

Approved RMP, the BLM does not expect any of the alternatives to contribute to the need to list and 

BLM special status species or bring any currently listed species closer to extinction. 

Grasslands and Shrublands Habitat Association 

No Action Alternative 

Under the No Action Alternative, the BLM would continue to conduct minimal vegetation treatments in 

grassland and shrubland habitat. Invasive plant species and forest species would continue to expand and 

the extent of these habitats in the Monument would decrease by approximately 13 percent (17 acres) over 

the next 20 years. Some Bureau sensitive species, including the gyrfalcon, short-eared owl, little brown 

myotis, Shaw Island Townsend’s vole, and Townsend’s big-eared bat would lose open habitat or edge 

habitat for foraging and hunting in the continued absence disturbance such as fire or tree removal beyond 

small-scale managerial activities. 

Wildlife that hunt and forage in grasslands and shrublands, such as peregrine falcons, would experience a 

reduction in Monument habitat available for this activity. However, the continued expansion of invasive 

plants and forest species in these habitats would be unlikely to substantially change prey availability in 

the remaining Monument grassland and shrubland. Similarly, species that nest or burrow in grasslands 

and shrublands would experience a 13 percent decrease in Monument habitat available for these activities. 

Under the No Action Alternative, potential habitat for island marble butterfly within the Monument 

would decrease over the next 20 years. While this species does not currently occur within the Monument, 

this could affect the availability of habitat for future occupation (see Issue 3, below). 

Alternative A 

Under Alternative A, the BLM would allow current habitat and vegetation trends to continue until 

specified thresholds as passed. The BLM assumes that this would result in the continuation of limited 

vegetation management over the life of the plan. Because of this, effects to wildlife associated with 

grassland and shrubland from vegetation management under Alternative A would be very similar under 

the No Action Alternative. The BLM estimates that there would be a small increase in vegetation 

treatments to address invasive plants, but this is unlikely to affect habitat suitability for wildlife. Openspace habitat types would continue to decline in quantity and quality for associated BLM sensitive 

species, such as the short-eared owl, Townsend’s big-eared bat, and Shaw Island Townsend’s vole. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

254 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative B 

Under Alternative B, Monument grassland and shrubland habitat would increase by approximately 313 

percent (from 126 acres to 520 acres). Efforts to increase plant diversity would improve the overall 

suitability of grasslands and shrublands as potential habitat for species like the island marble butterfly. 

Species expected to benefit from maintaining and restoring open-spaces and edges associated with 

grassland and shrublands include Townsend’s long-eared bat, olive-sided flycatchers, short-eared owl, 

peregrine falcon, merlin, and golden eagle. Additionally, this alternative could create potential habitat for 

sharptail snakes through restoration and maintenance of oak habitats. Species that hunt and forage in 

grasslands and shrublands, such as peregrine falcons and golden eagles, may see modest increases in prey 

availability within the Monument. Under Alternative B, habitat for grassland and shrubland associated 

wildlife would increase by the greatest amount out of all of the alternatives. 

Alternative B would have a mixed impact on species that require both forests and open habitats, like the 

merlin. Forest nesting habitat would decrease, but the quantity and quality of hunting habitat would 

improve. 

Alternative C 

Under Alternative C, Monument grassland and shrubland habitat would increase substantially (from 126 

acres to 487 acres). Compared to Alternative B, the BLM estimates that it would undertake more 

intensive efforts to treat non-native vegetation and approximate native historic plant communities. 

Species that would benefit from these treatments would be the same as those described under Alternative 

B. Alternative C would also have the same effect as Alternative B on species that require both forests and 

open habitats. 

Alternative D 

Under Alternative D, the BLM would maintain the current acreage and condition of Monument 

grasslands and shrublands. This alternative would not increase the suitability or acreage of these habitats. 

There would be no loss in habitat or substantial changes in suitability and so the Monument would 

continue to provide the current level of support to grassland and shrubland associated wildlife. 

Conclusion 

Alternative B would be most beneficial to wildlife species associated with grasslands and shrublands 

because it would provide the greatest increase in acres of this habitat within the Monument. Alternative C 

would provide almost as large an increase as Alternative B (394 acres compared to 361 acres). Under 

both alternatives, the BLM would improve habitat condition by undertaking treatments to control invasive 

plant species and enhance the cover and diversity of native plant associations; the BLM would conduct 

more intensive restoration efforts under Alternative C. Overall, alternatives B and C would create more 

suitable habitat for species like the island marble butterfly, short-eared owl, Townsend’s long-eared bat, 

Shaw Island Townsend’s vole, and merlin. The No Action Alternative and alternatives A and D would 

not substantially affect grassland habitat, though some acreage of grassland would be lost to conifer and 

shrub encroachment under the No Action Alternative and Alternative A. 

Cumulative Effects of Changes to Habitat Quantity and Quality on Grassland 

and Shrubland Associated Species 

Throughout the Puget Lowland Ecoregion, which includes the San Juan Islands, both native and nonnative grassland habitat covers an estimated 9 percent of the pre-Euro-American settlement extent of

native grassland (Chappell et al. 2000). The Monument currently encompasses approximately 1.2 percent 

of the Southern Vancouverian Lowland Grassland and Shrubland occurring within the San Juan Islands. 

Outside of the Monument, ongoing projects have the potential to enhance grassland and shrubland habitat 

in the San Juan Islands. On June 5, 2012, the National Park Service published a notice of intent to

prepare a Prairie Stewardship Plan and Environmental Impact Statement for the San Juan Island National 

Historical Park (National Park Service 2012). This restoration effort would include prairie at the San 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

255 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Juan Island National Historical Park that is in close proximity to Monument land at Cattle Point. The 

Nature Conservancy has ongoing vegetation restoration projects on 11-acre Yellow Island, which has a 

small amount of grasslands. 

Reasonably foreseeable activities that could negatively impact grasslands in the San Juan Islands include 

continued tree and shrub encroachment, continued invasion and expansion of non-native plants, continued 

herbivory by deer and European rabbits, continued impacts from recreation (erosion, vegetation 

trampling, etc.), and development and conversion to agricultural uses. Due to lack of predation and 

hunting pressure, black-tailed deer populations within the San Juan Islands have expanded and are 

influencing vegetative cover and wildlife habitat. Arcese et al (2014) found that the cover, richness, and 

diversity of native and culturally important shrubs were 52–85 percent lower at sites in the Salish Sea 

region with abundant deer. 

Under the No Action Alternative and Alternative A, there would be an estimated 17 acres of grasslands 

and shrublands lost within the Monument. This would decrease the total acreage of this habitat in the San 

Juan Islands by 0.2 percent. Under alternatives B and C, grassland and shrubland habitat in the 

Monument would expand by 394 acres and 361 acres respectively. This would increase the total acreage 

of this habitat type in the San Juan Islands by approximately 3 percent. Under both alternatives B and C, 

the diversity and cover of the native plant community within the Monument’s grasslands and shrublands 

would improve over the life of the plan, and providing some counter to the overall regional decline of this 

habitat. Under Alternative D, the Monument’s contribution to the supply of grassland and shrubland 

habitat in the San Juan Islands would remain unchanged. 

Because less than 2 percent of the available San Juan Islands grassland and shrubland habitat would be 

affected, the BLM does not expect any of the alternatives to contribute to the need to list and BLM special 

status species or bring any currently listed species closer to extinction. 

Nearshore Wildlife Association 

No Action Alternative 

As described under Issue 2 of the Habitat and Plants Section, under the No Action Alternative the impact 

of the BLM’s management on nearshore habitat would remain relatively unchanged from existing

conditions. Vegetation treatments would continue to be limited to hazard tree removal and limited 

mechanical treatments of invasive species (approximately 20 acres per year). This level of treatment 

would continue to cause negligible sediment delivery to nearshore habitats. 

The minor amount of sediment delivery that may be occurring from the approximately 9 miles of 

Monument trail within 200 feet of shoreline could continue to cause some disruption of both juvenile 

salmonid (smolt) rearing, refuge, and feeding and juvenile stage rockfish refuge and forage. Sediment 

affects both water quality and the presence and availability of invertebrate prey for salmonids (50 CFR 

226.212), a visual predator. This sediment deposition would result in continued depression of the 

carrying capacity of fishes using nearshore habitats compared with historic habitat support, particularly 

for those species relying on seagrass beds, which are susceptible to loss or decline with sediment 

deposition and turbidity (WDNR 2015b). 

Under the No Action Alternative, the BLM would continue to allow recreational boat landing on all 21.2 

miles of Monument shoreline. Boat landings would continue to lead to a minor amount of removal of 

seagrass beds or kelp habitat and a corresponding reduction in juvenile salmonid and juvenile stage 

rockfish rearing, refuge, and feeding in impacted areas. 

Under the No Action Alternative, there would continue to be no plan-level decisions related to shoreline 

stabilization. While the BLM has only undertaken soft stabilization in the past, hard stabilization could 

be applied were it would more effectively protect at-risk cultural resources. Soft stabilization would have 

limited long-term impacts on nearshore wildlife. Hard stabilization would permanently remove any 

habitat within the stabilization footprint along and increase disturbance to nearby habitat through changes 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

256 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 in sediment delivery, sand and sediment re-distribution, and potential loss or damage of habitat elements 

such as eelgrass. This would lead to a decline in both the extent and quality of habitat for juvenile 

salmonid rearing, refuge, and feeding and juvenile stage rockfish refuge and forage. 

Non-aquatic wildlife that make use of the nearshore environment, such as bald eagle and common loon, 

would be largely unaffected by sediment from vegetation treatments. The continued increase in forest 

vegetation could improve perching and hunting habitat for bald eagles that use shoreline trees and rocks 

when looking for fish. 

The BLM would continue with custodial management of cultural resources, including undertaking sitespecific stabilization and rehabilitation projects as necessary to protect them. Hard shoreline stabilization 

would alter available beach foraging habitat for migratory birds and nearshore species such as black 

oystercatchers (Gianou 2014). As described above, hard shoreline stabilization would reduce spawning 

habitat for forage fish. This would negatively affect prey species for marbled murrelet, common loon, 

rhinoceros auklet (Cerorhinca monocerata), bald eagle, and marine mammals (Gianou 2014). 

In summary, under the No Action Alternative, nearshore habitat would continue to provide approximately 

the same level of refuge and forage for fish as under current conditions. The Monument would also 

continue to provide the current level of support to birds and marine mammals associated with nearshore 

habitat. 

Alternative A 

Under Alternative A, the BLM would take a relatively passive approach to vegetation management (Table 

17 on page 111). There would continue to be negligible sediment delivery to nearshore habitats from 

these limited vegetation treatments. 

Under Alternative A, the BLM would prohibit recreational use of the Monument, though it would 

continue to facilitate access for scientific, educational, cultural, and spiritual purposes. This would 

minimize impacts to nearshore habitats and wildlife from both removal of nearshore vegetation (e.g., 

eelgrass) through boat landing and sediment deposition from trails. Improvements in seagrass beds and 

kelp bed habitat due to reductions in disturbance and sediment deposition could increase juvenile 

salmonid rearing, refuge, and feeding and juvenile stage rockfish refuge and forage. 

The BLM would exclusively use soft stabilization methods to protect at-risk cultural resources under 

Alternative A. Impacts from soft stabilization would be the same as those described in the No Action 

Alternative; nearshore fish, birds, and marine mammals would not be subject to the greater decline in 

their habitat that would occur from hard stabilization methods. 

The improvement in fish carrying capacity would benefit wildlife that use the nearshore environment to 

hunt, including bald eagles, common loons, rhinoceros auklets, and harbor seals (Phoca vitulina). The 

continued increase in forest vegetation could also improve perching and hunting habitat for bald eagles 

that use shoreline trees and rocks when looking for fish. 

In summary, under Alternative A, impacts from boat landings and trails would decline and impacts from 

sediment delivery due to vegetation treatments would remain at the current level. This would lead to 

higher nearshore habitat quality, which the BLM predicts would increase the carrying capacity of both 

nearshore forage fishes (e.g., eulachon) and the fishes (such as sensitive salmonids), birds, and marine 

mammals eating forage fishes and nearshore aquatic invertebrates. 

Alternative B 

Under the objectives for Alternative B, the BLM would undertake extensive vegetation treatments to 

enhance limited plant communities and increase species and structural diversity within the Monument. 

Alternative B would produce the most sediment deposition from vegetation treatments of any alternative 

other than other than sub-Alternative C (see Habitat and Plants Issue 2). However, due to travel distance 

through vegetated conditions, the BLM predicts that this sediment increase would be within historic 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

257 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 ranges in sediment delivery, and would not be expected to change the extent or species composition of 

nearshore plant communities such as seagrass beds. 

Under Alternative B, there would be an approximately 7 percent increase in trails within 200 feet of the 

shoreline compared to the No Action Alternative. These trails would only be open to hiking and closed to 

equestrian and bicycle use. 

The BLM would prohibit recreational use, including recreational boat landing, on all marine rocks and 

rock groupings and at Watmough Bay (see Appendix O for Category A Rocks, Category B Rocks, and 

Watmough Bay RMA frameworks). Impacts from recreational boat landing, the BLM would continue to 

allow on 16.4 miles of Monument shoreline, would be more than under Alternative A but less than all 

other alternatives. The prohibition on recreational boat landings at Watmough Bay could increase fish 

abundance and/or production in the most important forage fish spawning habitat area adjacent to the 

Monument. 

Under Alternative B, the BLM could undertake hard shoreline stabilization, in addition to soft 

stabilization, as needed to protect cultural resources. Given the greater ecological impacts of hard 

stabilization, the BLM is likely to use soft stabilization in most cases. Where the BLM applied hard 

stabilization, it would lead to a decline in both the extent and quality of habitat for juvenile salmonid 

refuge and feeding, and juvenile-stage rockfish refuge and forage, as well as for nearshore birds and 

marine mammals. 

The decline in fish carrying capacity would negatively affect some wildlife that hunt in the nearshore 

environment, including bald eagles, common loons, rhinoceros auklets, and harbor seals. In addition to 

affecting prey species, hard shoreline stabilization would substantially alter beach foraging habitat for 

nearshore species and migratory birds such as black oystercatchers (Gianou 2014). If the BLM removed 

trees along Monument shoreline as part of grassland/shrubland restoration or forest health treatments, 

perching habitat for bald eagles that use shoreline trees when looking for fish could decrease as well. 

In summary, under Alternative B, sediment deposition from vegetation treatments and trails would 

increase. This could lead to: a) indirect effects on nearshore fishes through loss of seagrass beds or other 

seagrass habitats b) indirect effects on birds and marine mammals that feed on nearshore fishes, and c) 

direct impact to nearshore fish production, through turbidity and water quality impacts on fish foraging 

and invertebrate prey bases. The effect would likely be strongest on fishes using sand areas and seagrass 

beds. This could decrease the carrying capacity of nearshore fishes including both forage fishes (e.g., 

eulachon), and the fishes eating forage fishes and nearshore aquatic invertebrates, such as sensitive 

salmonids (see Table 66). Impacts to deeper marine species such as adult rock fishes or migrating 

salmonids would be less than to species in shallower habitat. In addition to increased negative impacts 

from increased sediment delivery, there would also be a positive effect from the decrease in boat landing 

in Watmough Bay and around marine rocks, which could lead to an increase in abundance and/or 

production in these specific locations. 

Alternative C 

Under the objectives for Alternative C, the BLM—likely working with tribes and other partners—would 

undertake extensive treatments to approximate historic vegetation conditions within the Monument (see 

Issue 3 for estimated treatment types and acres). Alternative C would contribute the second-most 

sediment of any alternative related to vegetation management (see Habitat and Plants Issue 2). 

Under Alternative C, there would be an approximately 28 percent decrease in Monument trails within 200 

feet of the shoreline compared to the No Action Alternative. The decline in trail miles would lead to less 

sediment deposition from trails than under the No Action Alternative and alternatives B and D, but more 

than under Alternative A. 

The BLM would prohibit recreational use, including recreational boat landings, on smaller and/or more 

sensitive rocks and rock groupings; motorized boat landings would be prohibited at Watmough Bay (see 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

258 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Appendix O for Category B Rocks and Watmough Bay RMA frameworks). Impacts from recreational 

boat landing, which the BLM would continue to allow on 17.8 miles of Monument shoreline, would be 

greater than under Alternative A and Alternative B, but less than under the No Action Alternative and 

Alternative D. The prohibition on motorized recreational boat landings at Watmough Bay could improve 

fish abundance and/or production in the most important forage fish spawning habitat area adjacent to the 

Monument. 

The BLM would exclusively use soft stabilization methods to protect at-risk cultural resources under 

Alternative C. Impacts from soft stabilization would be the same as those described in the No Action 

Alternative; nearshore fish, birds, and marine mammals would not be subject to the greater decline in 

their habitat that would occur from hard stabilization methods. 

The decline in fish carrying capacity would negatively affect some wildlife that hunt in the nearshore 

environment, including bald eagles, common loons, rhinoceros auklets, and harbor seals. If trees the 

BLM removes trees along Monument shoreline as part of grassland/shrubland restoration or forest health 

treatments, perching habitat for bald eagles that use shoreline trees when looking for fish could decrease 

as well. 

In summary, under Alternative C, there would likely be a net increase in sediment deposition given the 

increase in vegetation treatments, though less sediment deposition would occur than under Alternative B 

and Sub-Alternative C. Increased sediment deposition could affect fish abundance and/or production in 

adjacent nearshore environments. The effect would likely be strongest on fishes using sand areas and 

seagrass beds. This could somewhat decrease the carrying capacity of nearshore fishes including both 

forage fishes (e.g., eulachon), and the fishes eating forage fishes and nearshore aquatic invertebrates, such 

as sensitive salmonids (see Table 66). This would have a negative indirect effect on birds and marine 

mammals that feed on nearshore fishes. Impacts to deeper marine species such as adult rock fishes or 

migrating salmonids would be less than to species in shallower habitat. In addition to increased negative 

impacts from increased sediment delivery, there would also be a positive effect from the decrease in boat 

landing in Watmough Bay and around smaller/more sensitive marine rocks, which could lead to an 

increase in abundance and/or production in these specific locations. 

Sub-Alternative C 

The effects to nearshore fishes under Sub-Alternative C would be similar to those under Alternative C. 

Under Sub-Alternative C, the acres of vegetation treatments would likely increase as the BLM attempted 

to achieve ambitious restoration objectives without the use of herbicide (see Issue 3 for estimated 

treatment types and acres). Sub-Alternative C would produce the most sediment deposition from 

vegetation treatments of any alternative. 

This increased sediment deposition would amplify the impacts described under Alternative C and could 

further decrease the carrying capacity of nearshore fishes including both forage fishes (e.g., eulachon), 

and the fishes eating forage fishes and nearshore aquatic invertebrates, such as sensitive salmonids (see 

Table 66). The decline in fish carrying capacity would negatively affect some wildlife that hunt in the 

nearshore environment, including bald eagles, common loons, rhinoceros auklets, and harbor seals. 

Alternative D 

Under the objectives for Alternative D, the BLM would undertake relatively modest acres of treatments to 

maintain approximate current vegetation conditions (see Issue 3 for estimated treatment types and acres). 

This small estimated acreage of vegetation treatments would lead to slightly more sediment production 

than the No Action and Alternative A, but far less sediment production than alternatives B and C. The 

BLM predicts that this small amount of sediment would lead to no measurable change in nearshore 

habitat conditions and no change in fish use or abundance. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

259 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under Alternative D, there would be an approximately 38 percent increase in trails within 200 feet of the 

shoreline compared to the No Action Alternative. Alternative D would have the largest amount of trailrelated sediment production associated with any alternative. 

Impacts from recreational boat landings would increase slightly under this alternative. Recreational boat 

landings could continue on all 21.2 miles of Monument shoreline; the BLM would also increase acres of 

land open to designated site camping for visitors arriving by non-motorized boat. The development of 

new campsites during plan implementation would lead to the increase of landings at these locations. This 

could lead to an increase in the removal of seagrass or kelp habitat and a corresponding reduction in 

juvenile salmonid and juvenile stage rockfish rearing, refuge, and feeding in impacted areas. 

Under Alternative D, the BLM could undertake hard stabilization of shorelines, in addition to soft 

stabilization, as needed to protect cultural resources outside of areas managed for their wilderness 

characteristics. Areas managed for their characteristics under Alternative D encompass 232 acres, 

including the east half of Patos Island and an array of rocks and islands (see Wilderness Characteristics on 

page 231 for more information). Where the BLM applied hard stabilization, it would remove or degrade 

the extent and quality of habitat for juvenile salmonid refuge and feeding, and the extent and quality of 

juvenile stage rockfish refuge and forage habitat. Based on techniques that the BLM could apply, it is 

logical to assume that these impacts would be intermediate between the No Action Alternative and 

Alternative B and alternatives A and C. 

The decline in fish carrying capacity would negatively affect some wildlife that hunt in the nearshore 

environment, including bald eagles, common loons, rhinoceros auklets, and harbor seals. In addition to 

affecting prey species, hard shoreline stabilization would substantially alter available beach foraging 

habitat for nearshore species and migratory birds such as black oystercatchers (Gianou 2014). This 

alternative would maintain the current level of perching habitat for bald eagles that use shoreline trees and 

rocks when looking for fish. 

In summary, under Alternative D, there would likely be a net increase in sediment deposition given the 

increase in trail miles, though less sediment deposition would occur than under alternatives B, C, and 

Sub-C. Increased sediment deposition, could affect fish abundance and/or production in adjacent 

nearshore environments, through mechanisms detailed above. The effect would likely be strongest on 

fishes using sand areas and seagrass beds. This could somewhat decrease the carrying capacity of 

nearshore fishes including both forage fishes (e.g., eulachon), and the fishes eating forage fishes and 

nearshore aquatic invertebrates, such as sensitive salmonids (see Table 66). This would have a negative 

indirect effect on birds and marine mammals that feed on nearshore fishes. Impacts to deeper marine 

species such as adult rock fishes or migrating salmonids would be less than to species in shallower 

habitat. Over time, there would also be an increase in impacts from boating landing, which could lead to 

a decrease in fish abundance and/or production in affected locations. 

Conclusion 

The alternatives would vary in their effects on the quality and quantity of nearshore habitat. Alternative 

A would minimize impacts to wildlife associated with nearshore habitat by closing trails, prohibiting 

recreational boat landing, and using only soft shoreline stabilization techniques. Alternative B would 

have the largest potential impact the quality and quantity of nearshore habitat, by driving the greatest 

increase in sediment deposition from vegetation treatments and by allowing hard shoreline stabilization. 

Other alternatives would be intermediate in their effects. The BLM predicts that changes in extent or 

species composition of nearshore plant and wildlife communities due to sediment delivery changes would 

be small and within historic ranges. 

Cumulative Effects of the Changes to Habitat Quantity and Quality to NearshoreAssociated Species 

The Monument encompasses a small fraction of the total nearshore habitat in the San Juan Islands. 

Nearshore habitat in the San Juan Islands is predominantly in private ownership. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

260 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Reasonably foreseeable effects to nearshore habitat both near the Monument and within the San Juan 

Islands in general include shoreline erosion and modification due to rising sea levels and sediment 

delivery into shoreline habitats from shoreline development, vegetation management, and recreation. The 

alternatives would add incremental impacts to historic, current, and future impacts to nearshore wildlife in 

the San Juan Islands. They would add to impacts from the following actions outside of the Monument: 

shoreline stabilization, land clearing and other vegetation treatments, recreational and commercial fishing, 

and docks, marinas, and landings. 

The above actions are regulated by the ESA and State regulations including the Joint Aquatic Resources 

Permit Application. The majority of shoreline development and impact has occurred historically. Over 

600 marine shoreline alterations have been identified in San Juan County (San Juan County 2013); these 

modifications are part of the affected environment for the Monument and adjacent areas. San Juan 

County is currently in the early planning stages to relocate a road within 200 feet of the shoreline on the 

south end of Lopez Island. Other than this project, the BLM is not aware of specific additional largescale proposed shoreline alterations, although many minor alterations are permitted each year. 

Recreational use in the San Juan Islands has increased and is likely to continue to increase, with 

correlated indirect effects on nearshore habitat similar to those described above. The cumulative effect of 

other foreseeable shoreline alterations and increased recreation, added to the indirect effects on nearshore 

habitats described above, would lead to an overall decline in nearshore habitat conditions in areas 

adjacent to the Monument under the No Action Alternative, Alternative B, and Alternative D. These 

effects would be associated with (in order of severity of impact): boat landings, hard shoreline 

stabilization, and indirect sediment effects. The BLM predicts that alternatives A and C would lead to 

overall improved nearshore habitat conditions in areas adjacent to the Monument, considering both 

positive (restrictions on landings and hard shoreline stabilization) and negative (temporary increases in 

sediment delivery) impacts on the nearshore habitat condition. For the San Juan Islands as a whole, the 

effects from implementation of any of the alternatives would be relatively minor when the severity of 

impacts, the duration of impacts, and the amount of habitat impacted is considered. The BLM estimates 

that at most <1 percent of nearshore habitat types would be removed (due primarily to hard shoreline 

stabilization), <5 percent of nearshore habitats would experience slightly reduced habitat function (due to 

increased boat landings and sediment delivery increased over historic ranges), leading to minor and 

mostly temporary changes in wildlife and fish behavior in a small area adjacent to the Monument. 

Sensitive fisheries population levels are substantially below historic levels. Rockfish (Sebastes spp.) have 

substantially declined in abundance in the Puget Sound (Tonnes 2011). Following a decade of effort, 

many salmonid species, including some listed chinook and steelhead runs, are consistently below 

recovery goals and decreasing (Governor’s Salmon Recovery Office 2014). The BLM does not expect

the contribution of effects from these alternatives to change the cumulative negative trends in sensitive 

fish populations. However, no fishes would be made more sensitive solely through the incremental 

indirect impacts described for these alternatives. The incremental contribution of these alternatives would 

not by themselves contribute to trends for listing any fish under the ESA, and would not cause an increase 

in protection levels for sensitive fishes (i.e., changing from threatened to endangered). Because actions 

under the alternatives would affect only a small percent of the available San Juan Islands nearshore 

habitat, the BLM does not expect any of the alternatives to increase the need to federally protect 

nearshore non-fish wildlife species. 

Wetland Wildlife Association 

No Action Alternative 

Under the No Action Alternative, there would continue to be little to no active management of Monument 

wetlands. Conifer encroachment would continue to cause wetlands at Point Colville to function at risk; 

sediment deposition from trails would continue to have a small negative effect on all Monument wetland 

habitat. These small changes in habitat suitability within the Monument would likely have a nominal 

effect on species associated with wetlands. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

49 

261 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative A 

Under Alternative A, the effects to wildlife associated with wetlands would be similar under the No 

Action Alternative. Little to no vegetation management would occur in wetlands under this alternative 

and so changes to habitat would be minimal. Under Alternative A, the eventual revegetation of trails 

would reduce sediment delivery from trails; this could also increase nearby vegetation cover for wildlife 

accessing wetlands. This small change in habitat suitability within the Monument would likely have a 

nominal positive effect on species associated with wetlands. 

Alternative B 

Under Alternative B, Monument wetland acreage would increase by approximately 30 acres. This would 

increase the extent of habitat available within the Monument for wetland-dependent species by 

approximately 80 percent. The BLM would use a variety of methods would be used to wetland function 

and native species diversity under this alternative, including use of pesticides to control non-native plants. 

For those species that use productive wetlands for hunting or foraging, food availability would increase as 

wetland habitat expands. Insect populations would increase, providing a greater food source for 

insectivores such as purple martins, black swifts, common nighthawk (Chordeiles minor). While 

gyrfalcons are an unlikely visitor, increased habitat for waterfowl could expand hunting opportunities. 

Vegetation treatments to remove invasive plants would improve native plant diversity in wetlands. 

Treatments to remove encroaching conifers would improve hydrologic function for the Point Colville 

wetland, which is currently functioning at risk. Increased sediment deposition resulting from vegetation 

removal, prescribed fire, and earth moving would temporarily reduce water quality and negatively impact 

wetland associated species, such as the rough-skinned newt (Houlahan and Findlay 2003). 

Sediment delivery from trail use and vegetation treatments might also negatively affect aquatic insect 

populations in the short-term (Gleason et al. 2003), which would affect aerial insectivores like bats, 

swallows, common nighthawk, and purple martins. Overall, however, Alternative B would benefit 

wetland-dependent species and other wildlife that utilize wetlands during their life histories. 

Alternative C 

Wetland conditions would improve, but not expand, under Alternative C. The BLM would use a variety 

of methods to approximate historic condition, including use of pesticides to control non-native plants. 

Native plant diversity would increase and removal of encroaching trees would increase the function of the 

wetland functioning at risk at Point Colville. 

Increased plant diversity and improved wetlands function should result in increased insect diversity and 

abundance (Hornung and Foote 2006). This would foster similar benefits to wetland-associated species 

as Alternative B, but at a smaller scale the BLM would not create new wetland acres. Insectivores such 

as bats, swallows, common nighthawk, and purple martins would benefit from higher insect prey 

availability with improved wetland conditions (Hornung and Foote 2006). 

Sub-Alternative C 

This alternative would prohibit the use of chemical vegetation treatments in the Monument. This would 

both eliminate the potential for negative effects from chemicals on wetlands and limit the effectiveness of 

efforts to approximate historic conditions. Thus increased plant diversity and the subsequent increase in 

insect availability would not be fully realized as compared to Alternative C. However, native plant 

diversity would still improve due to the mechanical methods to reduce invasive plants and the removal of 

encroaching trees would benefit the wetland functioning at risk at Point Colville. 

Alternative D 

Under Alternative D, the BLM would maintain the current size and condition of Monument wetlands. 

Because there would be no loss in habitat or substantial changes in suitability, the Monument would 

continue to provide the current level of support to wildlife that depend on or utilize wetlands. Invasive 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

262 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 plant populations and encroaching conifers would be maintained at approximately their current levels 

rather than expanding as is likely to occur under the No Action Alternative and Alternative A. Wetlands 

plant diversity and insect diversity could increase under this alternative if invasive plants in wetlands are 

successfully treated and reduced, but changes in suitability would be minimal. 

Conclusion 

Alternative B would be most beneficial to wildlife associated with wetland habitats. While there would 

be some impact to existing wetlands resulting from the large amount of vegetation treatments proposed, 

wetland acreage within the Monument would increase substantially, providing suitable habitat for species 

such as purple martin and short-eared owl. Alternative C would also benefit wetland wildlife species 

because of the restoration work proposed for existing wetlands within the Monument. 

Alternative A would have a limited, positive impact on wetlands associated wildlife because of the 

closure of Monument lands to recreation. Less human access would reduce the likelihood of erosion, 

vegetation disturbance, and weed introduction into wetland environments. Under the No Action 

Alternative, wetland conditions would remain much as they are today. Under both the No Action 

Alternative and Alternative A, conifer encroachment would continue and the Point Colville wetland 

would continue to function at risk due to such encroachment. Lastly, Alternative D would have a minor 

negative impact on wetlands because of the expanded camping and trail-based opportunities that would 

occur under this alternative. Increased access would increase the likelihood of weed introduction, soil 

erosion, and vegetation impacts from hiking, equestrian use, bicycle use, and dispersed camping. 

Cumulative Effects of the Alternatives on Wetland Associated Species 

There have been historic losses of wetlands in San Juan County associated with human development 

(landings, harbors, docks, and housing); these losses have not been accurately quantified, but have led to 

the development of land use ordinances protecting wetlands (Rozenbaum 2012). More recently, 

approximately 20 percent of the wetland resources in the San Juan Island have been classified as 

potentially disturbed (based on data in WDOE 2011b). 

In recent years, San Juan County and private landowners have undertaken wetland enhancement and 

creation on Lopez Island. Private landowners, working with Ducks Unlimited, intend to continue projects 

to enhance and create wetlands. Because of this, it is reasonably foreseeable that the total acreage of 

wetland in the San Juan Islands will increase over the life of the plan. The following actions would also 

affect the size and condition of wetland habitat in the San Juan Islands: private filling of wetlands for 

development, private creation and enhancement of wetland areas for wetland mitigation, State and 

Federal wetland enhancement and creation (e.g., work at Odlin Park) 

Wetland development is regulated by the Clean Water Act and State regulations including the Joint 

Aquatic Resources Permit Application. The BLM does not know of any major new private development 

projects that would require wetland mitigation in the planning area. Other changes that are reasonably 

foreseeable for wetlands within the San Juan Islands include loss of wetlands through successional tree 

encroachment, climate change, and sedimentation contamination. 

The alternatives would have either no effect or a positive effect on the extent of wetlands within the San 

Juan Islands and would either maintain or improve the condition of wetlands within the Monument. 

Because of this, the BLM does not expect any of the alternatives to contribute to the need to list and BLM 

special status species or bring any currently listed species closer to extinction 

Summary Wildlife Issue 1 Conclusions 

Table 68 provides a summary of effects from changes under each alternative in habitat quantity and 

quality on associated wildlife species. Each alterative is described as causing an improvement, decline, or 

no change (+,-,=) in the wildlife associated with the habitat type. Table 69 summarizes how changes in 

vegetation under the alternatives would affect potential habitat for associated special status wildlife. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

263 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Table 68: Summary of effects of changes in habitat under each alternative on associated wildlife 

2 species 

Habitat Association No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative C 

and Sub-C 

Alternative 

D 

Grassland & shrubland associated 

Species - - + + =

Forest & woodland associated 

Species +/- +/- - - =

Wetland associated species - - + + =

Nearshore associated species 

(impacts from sediment) = + - - -

Nearshore associated species 

(impacts from shoreline 

stabilization) 

= + = + + 

Generalist species = = = = =

3 Table 69: Summary of the effects of changes in habitat under the alternatives on special status 

4 wildlife 

Species No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative C 

and Sub- C 

Alternative 

D 

American peregrine falcon 

(Falco peregrines) = = + + = 

Bald eagle 

(Haliaeetus leucocephalus) + + - - = 

Common loon 

(Gavia immer) = = +/- +/- = 

Gyrfalcon 

(Falco rusticolus) = = + + = 

Harlequin duck 

(Histrionicus histrionicus) = = - - = 

Island marble butterfly 

(Euchloe ausonides insulanus) - - ++ ++ = 

Lewis’s woodpecker (Melanerpes 

lewis) + + +/- +/- = 

Little brown myotis 

(Myotis lucifugus) +/- + +/- +/- = 

Sandhill crane

(Grus Canadensis) - - + + = 

Shaw Island Townsend’s vole

(Microtus townsendii pugeti) = = + + = 

Short-eared owl 

(Aegolius acadicus) - - ++ + = 

Townsend’s big-eared bat 

(Corynorhinus townsendii) +/- +/- +/- +/- = 

264 
Wildlife Analytical Issue 2: How would variations in human use/disturbance 

under each alternative affect wildlife species and fishes (including special status 

species)? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

Human uses and management activities currently cause some level of disturbance to wildlife across the 

Monument. Activities such as hiking, horseback riding, boat landing, and camping all currently occur 

within the Monument and have the potential to affect wildlife. Recreation and Visitor Services Issue 1 

provides estimates of current annual visitation at sites throughout the Monument (see Table 37 on page 

156). 

Increased tourism and shoreline development in the Salish Sea could increase the frequency of 

disturbance to wildlife. Marine mammals, eagles, and other favored species are often the target of 

ecotourists looking to either get close enough for a photo or simply see a specific species in their native 

habitat. This can be of concern when those actions disrupt natural behavior such as breeding or foraging, 

and negatively affect recruitment and survival within a population. 

Vegetation treatments have short-term disruptive effects on wildlife species near the treatment; this 

disruption varies depending on the type and intensity of the treatment. The BLM’s management of

vegetation within the Monument is currently limited to approximately 20 acres of manual and mechanical 

treatment per year. Given the small acreage involved, it is unlikely that vegetation treatment is having a 

substantial disruptive effect on wildlife. The effects section addresses how changes in the intensity and 

extent of vegetation treatments under each alternative could affect wildlife and alter disturbance levels. 

A variety of visitor activities currently occur in the Monument and are likely to cause some disturbance to 

wildlife. While the BLM does not have the information necessary to quantify the level of disturbance, it 

can quantify the extent of visitor opportunities that occur in vegetation classes within the Monument. The 

BLM quantified visitor opportunities within 300 feet61 of nearshore habitats and 25 and 150 feet62 of 

wetland habitats. 

Forest and Woodland Associated Species 

There are currently 9.2 miles of trail in Monument forest and woodland. While Monument trails are 

currently open to all non-motorized uses, equestrian use only occurs on approximately 1 mile of trail 

though forest and woodland. There is no regular use of Monument trails for bicycle access. Designated 

site camping is a popular activity in the Monument; this activity currently occurs within approximately 13 

acres of Monument forest and woodlands. Though this activity rarely occurs, 421 acres of Monument 

forest and woodland are currently open to dispersed camping. 

 

61 A minimum distance of 300 feet is considered to be the best all-around minimum distance within which 

marine mammals would have above average detection and attention directed to human presence and most 

human related activities (NOAA 2018 access). A general setback guideline of 164 feet (50 meters) has 

been recommended for seabirds (Chatwin et al 2013). See Appendix B for more information. 

62 Dube et al. (2004) conclude that sediment leaving a culvert or similar source and moving across 

vegetated areas (a situation conservatively comparable to the analysis area) move less than 150 feet in 

nearly all cases. The BLM specialist identified 25 feet as an appropriate buffer within to measure direct 

impacts to wetlands. See Appendix B for more information. 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

265 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Grasslands and Shrubland Associated Species 

There are currently 5.1 miles of trail in Monument grassland and shrubland. While Monument trails are 

currently open to all non-motorized uses, there is no regular use of trails through grasslands and 

shrublands for equestrian or bicycle access. Designated site camping is a popular activity in the 

Monument; this activity occurs within approximately 8 acres of Monument forest and woodlands. 

Though this activity rarely occurs, 66 acres of the Monument grassland and shrubland are currently open 

to dispersed camping. 

Nearshore Associated Species 

There are currently 3.9 miles of Monument trail that are within 300 feet of a marine mammal haulout and 

10.2 miles of trail that are within 300 feet of the shoreline. All 21.2 miles of shoreline Monument 

shoreline are open to recreational use. All designated site camping within the Monument occurs within 

300 feet of the shoreline. While visitors are prohibited from harassing marine mammals under the Marine 

Mammal Protection Act, it is likely that some level of disturbance to these species occurs due to 

Monument visitation given the proximity of trails and camping areas to the shoreline. 

Wetland Associated Species 

There are currently 0.3 miles of Monument trail that are within 25 feet of a wetland and 0.9 miles of 

Monument trail that are within 150 feet of a wetland. There are no wetlands in any areas currently open 

to dispersed or designated camping. 

Effects of the Alternatives 

The effects of disturbance to wildlife species associated with Monument habitats vary depending on the 

extent of vegetation treatment and the type and extent of recreation activities and vegetation treatments 

allowed under each alternative. This section provides overview discussions on the type of disturbance 

that vegetation treatments and recreational activities could cause. These two overview discussions are 

followed by sections that compare the alternatives’ effects on recreational opportunities and vegetation 

treatments within different Monument habitats. 

Overview of Disturbance from Vegetation Treatments 

Disturbance from vegetation treatments would vary depending on the type and extent of treatments the 

BLM would undertake to implement the alternative. Habitat and Plants Issue 3 provides estimates of the 

treatment acres that would be required during the life of the plan to accomplish each alternatives’

objectives. 

Vegetation management, regardless of which technique is used, can have direct effects on wildlife. 

Machinery use and operation, human voices and activities, vegetation trampling, and dust would occur 

during implementation of projects; all of these effects have the potential to displace wildlife, interrupt 

nesting, alter behavior, and influence animal fitness and reproductive success. The potential impacts from 

various types of vegetation treatments are summarized below. The estimated extent of treatments 

occurring in each habitat type under each alternative is addressed below. 

Biological Treatments: Biological treatments can include using domestic livestock (e.g., goats) to 

remove undesirable vegetation or using insects or pathogens to target invasive plants. Livestock can 

directly harm wildlife by trampling on animals or their nests (Paine et al 1996). Disturbance to wildlife 

from biological treatments using insects or pathogens would be minor. 

Mechanical Treatments: Mechanical vegetation removal can cause direct injury or mortality to animals 

during implementation. Snakes and amphibians may be unable to escape from machinery, falling 

vegetation, or trampling by equipment (Semlitsch et al. 2009). Treating vegetation during nesting can 

cause nestling mortality and reduced reproductive success (Saab at al 2011). 

Prescribed fire: Use of prescribed fire can cause injury or mortality to wildlife, especially depending on 

the time of year. Spring burns could cause nest failure and mortality of eggs or nestlings (Dechant et al. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

266 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 2002, Kruse and Piehl 1986). Fall and summer use of fire may directly cause injury or mortality to 

species unable to escape from fire effects, such as rodents, reptiles, and amphibians. 

Human activity during treatments: Much like recreational disturbance, human activity during 

implementation of treatments can cause a level of disturbance that would result in displacement of 

animals, reduced breeding success, and higher vulnerability to predation (Steidl and Powell 2006, Edge 

and Marcum 1985). 

Overview of Disturbance from Visitation 

In general, wildlife are sensitive to human disturbance, but responses vary greatly among guilds (seabirds, 

marine mammals, etc.) and depending on the intensity or duration of disturbance. Researchers have 

documented negative effects to all wildlife taxa from hiking, equestrian use, bicycling, and camping 

(Boyle and Samson 1985, Miller et al 1998, Miller et al 2001, and Larson et al. 2016). Human 

disturbance increases vigilance in almost all wildlife species and the costs of vigilance has been wellstudied (Cituti et al. 2012, Knight and Cole 1991). Any increase in human access to wildlife habitat can 

generally be described as having negative impacts on most wildlife species (Larson et al. 2016). The 

descriptions below offer an overview of disturbance to wildlife that can be cause by trail use, camping, 

pet access, and accessing the nearshore environment (e.g., boat landing and camping and hiking near the 

shoreline). 

Non-consumptive recreation such as photography, hiking, boating, kayaking, and wildlife watching 

would generate disturbance risks to reproducing birds and animals associated with shoreline and 

nearshore habitat. Impacts could include flushing of birds off nests; trampling of ground-built nests, 

eggs, or chicks; or agitating birds out of established territories or feeding sites into less disturbed areas 

(Boyle and Sanson 1985). Similar displacement and annoyance type impacts could occur to adult or 

newborn seals basking on shore, as well as small mammals like mink, or river otter, which use the 

shoreline for hunting and foraging. Encounters between humans and wildlife would be more likely and 

impactful when people explore cross-country (as is currently allowed within the Monument). The 

presence of trails and recreation associated with them can alter wildlife communities or habitat 

availability (Miller et al 1998, Velando and Munilla 2011). It is difficult to quantify biological responses, 

per species, in relation to various human-created disturbances associated with recreation or other 

activities. Numerous variables such as line-of-site, distance, topography, season, weather or even 

temporal scales associated with a stimulus type (continuous or single event) or animal response (shortterm alertness to long-term reproductive effects) complicate a site-specific analysis per species by 

disturbance type (Pater et al 2009). 

Trail Use 

Empirical studies have shown that disturbance and the associated increased levels of vigilance in deer and 

other ungulates can reduce reproductive success and impact populations (Phillips and Aldredge 2002, 

Yarmoloy et al. 1988). Some studies indicate that the disturbance effect is greatest in response to humans 

on foot as opposed to on bicycles or motor vehicles (Knight and Cole 1995). This may be due to the 

unpredictable nature of people on foot; people on foot are more likely to leave trails, approach wildlife, or 

linger in areas where wildlife are present than those traveling by other means (Audrey and Knight 2003). 

Another possible reason for this is that humans on foot appear more like a human to animals than those in 

a vehicle or on a bicycle (Richens and Lavigne 1978, Eckstein et al. 1979, MacArthur et al. 1982, Freddy 

et al. 1986, Papouchis et al. 2001, Audrey and Knight 2003). Equestrians and bicyclists often travel more 

miles on trails than hikers (Audrey and Knight 2003) and thus their area of disturbance is greater, though, 

as just described, these modes of travel may elicit a lesser response from wildlife than hiking. 

In response to increased disturbance, larger animals like deer often move to more secluded habitats when 

recreation levels are high (Knight and Cole 1991, Burgin and Hardiman 2012, Taylor and Knight 2003, 

Macarthur et al. 1982, Ciuti et al. 2012, Wisdome et al. 2004). During daylight hours, for example, deer 

may stay in areas of higher cover habitat farther from trails (Coppes et al. 2017). At night, use of habitat 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

267 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 adjacent to trails would likely increase. Some animals may choose to leave the area entirely for all or 

portions of the year when use is particularly high (summer and fall) (Ciuti et al. 2012). 

In response to trail users, smaller animals, like birds, may continue to use habitat adjacent to trails, but 

nesting success may decrease near trails if they are frequently disturbed. Miller et al (1998) studied 

responses of multiple species of birds to recreational activities including mountain biking. They found 

that the presence of trails and activity along them led to change in species composition in the two habitats 

studied. Generalist species such as American robins (Turdus migratorius) were found to be more 

common along recreational trails. In addition, nests for all species were less likely to occur and were 

more susceptible to predation in areas close to trails. Disturbance to nesting birds can also result in 

delayed or decreased food delivery and increased exposure of eggs and nestling to predators and harsh 

environmental conditions (Miller at al. 1998). Interruptions to nesting also increase the likelihood of nest 

parasitism by cowbirds (Miller at al. 1998, Airola 1986). 

Camping 

Camping has an array of effects on wildlife. The typically longer duration of human occupation 

associated with camping, as opposed to hiking, may cause some species to habituate to the proximity of 

humans (Knight and Cole 1991). In addition, camping areas tend to have a higher prevalence of food (for 

human consumption), than hiking trails, for example. This food can act as an attractant to wildlife 

causing changes in habitat use and the dynamic between predators and prey (Knight and col 1991, West et 

al. 2016, West and Peery 2017). Food provided (intentionally or not) by recreationists can attract 

predators like ravens, crows, skunks, and raccoons to recreation sites making small mammals, reptiles, 

amphibians, and birds more susceptible to predation (West et al. 2016, West and Peery 2017). 

Predictability of human behavior often mitigates some of the impacts of human disturbance on wildlife 

(Cuiti et al. 2012, Knight and Cole 1991). Thus, dispersed camping may cause a greater impact on 

wildlife than camping limited to designated sites. Dispersed camping allows for use patterns that are 

intermittent and unpredictable. For example, Cuiti et al. (2012) found that elk vigilance was highest 

during times of the year when recreation disturbance was lowest (winter) and on private lands where 

recreation use was low compared to nearby national parks. They also found that elk vigilance was lowest 

during the busiest times of year in national parks (summer). Habituation to user presence reduced the 

level of vigilance in elk in this study. Reduced vigilance reduces the behavioral costs of not pursuing 

other activities such as foraging. Users may also knowingly, or unknowingly, select sites that are situated 

within or in close proximity to high value habitat, such as fresh water sources, productive understory 

vegetation, or nesting trees for species like bald eagles. Designated campsites can be strategically placed 

and managed to avoid high disturbance to high value habitat or know areas with special status species. 

Steidl and Anthony (2000) found that breeding behavior of bald eagles changed when people were 

camping for 24 hours within 100 yards of an active nest. They found that the amount of time away from 

the nest increased by 27 percent and amount of prey consumed by nestlings decreased by 29 percent. 

Pets 

In addition to human disturbance, public lands users can have other unintended impacts on wildlife. 

Many hikers bring their dogs with them and do not always obey leash laws. Dogs may chase, harass, and, 

in some cases, kill wildlife. A study conducted by Length and Knight (2008) concluded that several 

wildlife species altered their utilization patterns in response to the presence of domestic dogs on and off 

nearby trails. Activity levels and the density of species were substantially higher near trails where 

domestic dogs were not allowed. 

Accessing Nearshore Habitat (Including Boating) 

While the BLM’s jurisdiction only extends to mean high tide, activities within the Monument, can affect

wildlife in shallow nearshore habitat as well as in nearshore habitat above mean high tide. Seabirds are 

very sensitive to disturbance during the nesting season and may abandon eggs or young if disturbed. 

Seabird colonies have failed simply from boaters anchoring too closely or humans walking through the 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

268 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 colony during breeding (U.S. FWS 2011). Human disturbance to nesting seabirds and shorebirds has 

been shown to reduce productivity and contribute to species decline (McGowen and Simons 2006, Carney 

and Sydeman 1999, Anderson and Keith 1980, Rhulen 2003). Disturbance to nests can cause adults to 

flush from the nest, leaving eggs vulnerable to predation or hatch failure (Garber 1972, Hunt 1972, Bart 

1977). Yasue 2005 found that flock size and prey density decreased on shorebird foraging sites relative to 

human presence. 

Seabirds restricted to using ocean or nearshore habitats, such as common loon, marbled murrelet, and 

rhinoceros auklet, may be less vulnerable to land based recreation; water based recreation has been shown 

to cause disturbance responses in these species (Acosta et al. 2008 and Bellefleur and Ronconi 2009). 

Birds that are approached by motorized or non-motorized boats often flush from their preferred resting or 

foraging habitat, resulting in increased energetic costs to nearshore birds. Evans (2009) found that 

common loons flushed 51 meters (167 feet) on average in response approach by 1-2 kayaks. 

Birds that nest on land can also experience distress and alarm from human presence, especially during the 

nesting season. Mindfully avoiding any active nests or birds displaying nesting or brooding behaviors 

(e.g. birds sitting or calling from a nest, circling or diving away intruders) can minimize disturbance to 

terrestrial wildlife. A general setback guideline of 164 feet (50 meters) has been recommended to avoid 

disturbance to nesting seabirds (Chatwin et al 2013). The U.S. FWS National Bald Eagle Management 

Guidelines (2007) recommend limiting motorized and non-motorized watercraft activity, and human entry 

activity within 330 feet of active nests, particularly where eagles are unaccustomed to nearby activity. 

Pinnipeds (seals, sea lions) are also highly vulnerable to human disturbance, but may react differently 

depending on their degree of previous experience, age, sex, location, and life cycle stage. Disturbance 

can vary from temporary alertness, interrupted nursing, or the separation of pups from mothers, leading to 

reduced fitness, decreased blubber production, and increased mortality. Adults also sometimes crush 

pups during post-disturbance stampeding into the water. Among the disturbances that affect pinnipeds, 

research has shown that approaching kayaks have a disproportional negative response, perhaps due to the 

kayak’s stealthy, low profile approach or tendency to approach closer to the shore (Henry and Hammill

2011, Suryan and Harvey 1999). Land-based recreation can also cause seals and sea lions to be more 

vigilant or to prematurely leave preferred haul out areas (Andersen et al. 2011, Andersen et al. 2014). 

Though these impacts have not been extensively documented or quantified, direct impacts to fish of boat 

landing in nearshore environments can include: a) disruption of salmonid juvenile rearing, refuge, 

feeding, and adult migration; b) disruption of juvenile stage rockfish use shallow surface waters, kelp, and 

eelgrass for refuge and forage; c) direct killing or injuring of species present in nearshore habitats 

(Whitfield and Becker 2014). Based on observation of direct impacts and discussion with professionals, 

this analysis assumes that these impacts to fishes would be rare and localized (Radmer 2017). 

Direct impacts to fishes using deeper marine habitats from the landing of boats on Monument land are 

very unlikely, due to lack of proximity. While the BLM does not have jurisdiction to allow or prohibit 

anchoring or mooring in the waters adjacent to the Monument, the continued availability of Monument 

shorelines for recreational use may influence the amount of nearby anchoring or mooring activity, which 

could indirectly affect fish species in deeper marine habitats. 

Effects Common to all Habitat Types 

As discussed in the Overview of Disturbance from Visitation section, above, leashed and unleashed pets 

can have negative impacts on wildlife (Miller et al 2001). Under the No Action Alternative, there would 

continue to be no prohibition of pets within the Monument. Under existing supplemental rules, visitors 

would continue to be required to leash pets in developed recreation sites (BLM 2005). Outside of those 

sites, pets could continue to be off leash. Alternatives A and B would prohibit pets within the Monument 

(except service animals). Alternatives C and D would prohibit pets off-leash within the Monument (i.e., 

leashed pets would continue to be allowed). Disturbances to wildlife from pets in all habitat associations 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

269 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 would be lowest under alternatives A and B. The likelihood of disturbance or harm to wildlife due to free 

roaming pets would be greatest under the No Action Alternative. 

Forest and Woodland Habitat Association 

The alternatives would vary in the extent to which vegetation treatments and recreational opportunities 

would create the potential for wildlife disturbance in forest and woodland habitats. See the Overview of 

Disturbance from Vegetation Treatments section for a description of the types of wildlife disturbance that 

could occur through implementation-level vegetation treatments. See the Overview of Disturbance from 

Vegetation Treatments section for a description of the types of disturbance that could occur through 

visitors participating in the opportunities provided under each alternative. 

No Action Alternative 

Under the No Action Alternative, there would continue to be very little vegetation management (~20 

acres per year) within the Monument. Human disturbance of wildlife would continue to be primarily 

limited to recreational use, administrative use, and other authorized uses such as scientific research and 

educational activities. 

Other than Alternative D, there would be the greatest level of recreational use of forested Monument 

lands under the No Action Alternative (see Table 9 on page 84). Under the No Action Alternative, all 

Monument trails would continue to be open to all non-motorized uses. Disturbance to wildlife under this 

alternative would continue at the current rate. High trail use in the spring and summer would continue to 

potentially disrupt nesting migratory birds. 

Under the No Action Alternative, recreational use would continue to affect other diurnal wildlife species. 

Smaller mammals, such as squirrels and voles, would continue to be flushed from cover more frequently 

than would be likely under alternatives A, B, and C and be more vulnerable to predation. Human 

disturbance would also continue to affect larger species, such as black-tailed deer. 

Under the No Action Alternative, the BLM would continue allow dispersed camping without a permit on 

421 acres of forested Monument land. While this use is currently very limited, the BLM would continue 

to have minimal control over the numbers of campers and the season and locations of this activity. There 

would be fewer acres open to dispersed camping under the No Action Alternative than Alternative B, but 

the continued lack of permit requirement under this alternative may allow for greater impacts. The 

impacts from camping in designated sites would be similar to alternatives B and C, but substantially less 

than under Alternative D. 

In summary, the No Action Alternative would have the second largest disturbance impact on wildlife in 

forested habitat due to recreational use of trails, roads, and dispersed camping. However, disturbance due 

to vegetation management projects would be minimal. The BLM assumes that vegetation treatments 

would continue to be limited to vegetation removal using hand tools. 

Alternative A 

Alternative A would cause the least disturbance to forest and woodland wildlife out of all of the 

alternatives. The BLM would prohibit recreational use of the Monument and would undertake minimal 

vegetation treatments. Thus, disturbance would be limited to that caused by administrative use and 

authorized uses such as scientific research. Impacts such as reduced nesting success, increased energetic 

costs, and increased predation rates, would all be lowest under Alternative A. 

Alternative B 

Under Alternative B, the BLM would designate 14 miles of hiking trails and allow dispersed camping on 

600 acres of forested Monument lands and at the existing designated campsites at Blind, Patos, and Posey 

islands. Disturbance to wildlife from human use would be substantially greater than under Alternative A, 

moderately greater than under Alternative C, and somewhat less than under the No Action Alternative and 

Alternative D. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

270 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 While the BLM would use a permit system to limit the number of visitors engaged in dispersed camping 

under this alternative, there could be substantial impacts to forest wildlife from this activity. This 

alternative would allow dispersed camping on more acres of Monument forests and woodlands than any 

other alternative. Under Alternative B, the BLM would use a permitting system to limit the size of 

groups participating in dispersed camping. 

Under Alternative B, the BLM would designate more trail miles in Monument forest and woodlands than 

would exist under the No Action Alternative and than it would designate under alternatives A and C. 

While trail use would be limited to hiking, there would likely be more disturbance from trail use under 

this alternative than under either the No Action Alternative or Alternative C. 

Based on the vegetation treatment acres estimated under Habitat and Plants Issue 3, disturbance to forest 

wildlife due to vegetation treatments would be less than under Alternative C and Sub-Alternative C, but 

substantially more than the No Action Alternative and alternatives A and D (see Table 18 on page 112). 

Vegetation treatments would include mechanical vegetation removal, planting and seeding, herbicide 

application, and prescribed fire use. All of these activities would disturb wildlife in forested habitats (see 

the Overview of Disturbance from Vegetation Treatments section, above, for more detail on the types of 

disturbance). 

Alternative C 

Alternative C would have substantially greater impacts to forest and woodland associated wildlife from 

recreation-related disturbance than Alternative A, but more moderate impacts than the No Action 

Alterative and alternatives B and D. The BLM would designate a smaller mileage of trail miles for hiking 

than under alternatives B and D. There would also likely be less trail use than under the No Action 

Alternative. Two miles of trail would be open to equestrian use, which may cause greater visitation, and 

thus disturbance, along those trail miles. 

Under Alternative C, impacts to wildlife from camping would be lower than under all alternatives other 

than Alternative A. The BLM would not allow dispersed camping in the Monument under this 

alternative. Impacts from designated camping would the same as under the No Action Alternative and 

Alternative B, but substantially less than under Alternative D. Of the alternatives that allow recreation, 

Alternative C would have the lowest recreation related disturbance to forest and woodland wildlife. 

Based on the vegetation treatment acres estimated under Habitat and Plants Issue 3, disturbance to forest 

wildlife due to vegetation management projects would be slightly higher under Alternative C than under 

Alternative B, but lower than under Sub-Alternative C (See Table 19 on page 114). Disturbance effects 

from vegetation treatments would be substantially higher than under the No Action Alternative and 

alternatives A and D. Vegetation treatments would include mechanical vegetation removal, planting and 

seeding, herbicide application, and prescribed fire use. All of these activities would disturb wildlife in 

grasslands and shrubland habitats (see the Overview of Disturbance from Vegetation Treatments section, 

above, for more detail on the types of disturbance). 

Sub-Alternative C 

The primary difference between this alternative and Alternative C is that there would be substantially 

greater disturbance to forest and woodland associated wildlife from mechanical vegetation treatments (see 

Table 20 on page 115). Due to the prohibition on herbicides under this alternative, the BLM estimates 

that it would need to repeat treatments at a very high rate in order to meet habitat and plant communities 

objectives. This would cause the greatest disturbance to wildlife in forest and woodlands from vegetation 

treatments of any alternative. 

Alternative D 

Alternative D would have the greatest potential for disturbance to forest and woodland wildlife of any of 

the alternatives. While the BLM would allow dispersed camping on fewer forest and woodland acres 

than under Alternative B, it would continue not to require a permit for this activity. Impacts from 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

271 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 designated camping would increase substantially from the current condition by the addition of 137 acres 

of forest and woodland open to this use. Compared to the No Action Alternative, an additional 47 acres 

of forest and woodland would be open to dispersed camping without a permit. 

Trail miles in Monument forest and woodlands would nearly double under this alternative compared with 

the current user created trail network that would persist under the No Action Alternative (from 9.2 miles 

to 17.2 miles). The BLM would allow equestrian and bicycle use on fewer trail miles than are currently 

open to these uses, but on more trail miles than alternatives A, B, and C. 

Under Alternative D, the BLM would be likely to implement more vegetation treatments in forest and 

woodlands than under the No Action Alternative or Alternative A, but substantially fewer than under all 

other alternatives (see Table 21 on page 116). Disturbance effects from treatments would be similar to \ 

the No Action Alternative and Alternative A. The BLM would allow all types of vegetation treatments 

under this alternative, but estimates that it would use a small acreage of mechanical treatments, 

herbicides, and prescribed fire to accomplish the Alternative D habitat and plant communities objectives. 

All of these activities would disturb wildlife in grasslands and shrubland habitats (see the Overview of 

Disturbance from Vegetation Treatments section, above, for more detail on the types of disturbance). 

Grasslands and Shrublands 

The alternatives would vary in the extent to which vegetation treatments and recreational opportunities 

would create the potential for wildlife disturbance in grassland and shrubland habitats. See the Overview 

of Disturbance from Vegetation Treatments section for a description of the types of wildlife disturbance 

that could occur through implementation-level vegetation treatments. See the Overview of Disturbance 

from Vegetation Treatments section for a description of the types of disturbance that could occur through 

visitors participating in the opportunities provided under each alternative. 

Disturbance from recreation may be more pronounced in open vegetation than in forested habitats. 

Compared to forests and wetlands, grasslands and shrublands offer less hiding cover and inaccessible 

habitat. In this setting, some wildlife species, such as black-tail deer and hawks can detect human activity 

from farther distances than they would be able to in forested habitat. Noise from human activity also 

travels farther, giving animals a greater advantage of seeing and responding to humans, but fewer places 

to hide in response. 

No Action Alternative 

The No Action Alternative would have a similar potential for disturbance from recreation to wildlife in 

grasslands and shrublands as Alternative D, and greater potential than under alternatives A, B, and C. 

Human activities like designated site camping, hiking, and equestrian use would continue under the No 

Action Alternative. Dispersed camping and bicycling trail use might remain at their current low level of 

participation but the BLM would continue to allow these activities and they could expand over time. 

Acres of Monument grasslands and shrublands open to dispersed camping without a permit would be 

greatest in the No Action Alternative, though 19 additional acres would be open to dispersed camping 

with a permit in grasslands and shrublands under Alternative B. Impacts from existing designated site 

camping in grasslands and shrublands would continue and would be the same as under alternatives B and 

C, though substantially less than under Alternative D. Under the No Action Alternative, there would 

continue to be 5.1 miles of trail in Monument grasslands and shrublands, though this mileage could 

expand over time through new user created trails. This would be higher than under alternatives B and C 

and slightly lower than under Alternative D. These trails would continue to be open to all non-motorized 

uses. 

There would continue to be little to no disturbance to wildlife in grasslands and shrublands from 

vegetation management projects under this alternative. The BLM assumes that vegetation treatments 

would continue to be limited to vegetation removal using hand tools. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

272 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative A 

Alternative A would cause the least disturbance to grassland and shrubland wildlife out of all of the 

alternatives. The BLM would prohibit recreational use of the Monument and would undertake minimal 

vegetation treatment. The BLM would prohibit prescribed fire and pesticide use under this alternative. 

Thus, disturbance would be limited to that caused by administrative use and authorized uses such as 

scientific research. Impacts such as reduced nesting success, increased energetic costs, and increased 

predation rates, would all be lowest under Alternative A. 

Alternative B 

Under Alternative B, the impact of recreation disturbance to wildlife in grasslands and shrublands would 

be less than under the No Action Alternative and Alternative D, but substantially greater than under 

Alternative A and somewhat greater than under Alternative C. Under Alternative B, the BLM would 

designate 4.4 miles of trails for hiking and 87 acres for dispersed camping by permit within existing 

Monument grasslands and shrublands. There would be no authorized equestrian or bicycle trail use under 

this alternative. This would imply greater disturbance from trail use in Monument grasslands and 

shrublands than under Alternative A and Alternative C and less disturbance in this habitat type than under 

the No Action Alternative and Alternative D. 

This alternative would include the greatest acreage of Monument grasslands and shrublands open to 

dispersed camping; the BLM would also continue to allow camping in designated sites as under the No 

Action Alternative and Alternative C. This is the only alternative that would require permits for dispersed 

camping. As discussed in the Overview of Disturbance from Visitation section, the intermittent use of 

areas for dispersed camping may have a disproportionately negative effect on some wildlife species 

(MacArthur et al. 1982, Schultz and Bailey 1978, Miller at al. 2001). The BLM would limit dispersed 

camping to one group per location per night with no more than five participants; it could further use the 

permitting system to limit the timing, location, and duration of the activity in order to reduce or 

redistribute these impacts. 

Based on the vegetation treatment acres estimated under Habitat and Plants Issue 3, disturbance to 

grasslands and shrubland wildlife due to vegetation treatments would likely be less than under Alternative 

C and Sub-Alternative C, but substantially more than the No Action Alternative and alternatives A and D 

(see Table 18 on page 112). Vegetation treatments would include mechanical vegetation removal, 

planting and seeding, herbicide application, and prescribed fire use. All of these activities would disturb 

wildlife in grasslands and shrubland habitats (see the Overview of Disturbance from Vegetation 

Treatments section, above, for more detail on the types of disturbance). 

Alternative C 

Other than Alternative A, Alternative C would have the least amount of disturbance to grassland and 

shrubland wildlife resulting from recreation. Trail miles within grasslands and shrubland would decrease 

to 2.9 miles; less than 0.1 miles of this trail would remain open for equestrian use. There would be no 

dispersed camping authorized on any acres of the Monument. Impacts from designated site camping 

would be the same as under the No Action Alternative and Alternative B, but substantially lower than 

under Alternative D. 

Disturbance to grassland and shrubland wildlife due to vegetation management projects would be slightly 

higher under Alternative C than under Alternative B, but lower than under Sub-Alternative C. 

Disturbance effects from vegetation treatments would be substantially higher than under the No Action 

Alternative and alternatives A and D. Vegetation treatments would include mechanical vegetation 

removal, planting and seeding, herbicide application, and prescribed fire use. All of these activities 

would disturb wildlife in grasslands and shrubland habitats (see the Overview of Disturbance from 

Vegetation Treatments section, above, for more detail on the types of disturbance). 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

273 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Sub-Alternative C 

The primary difference between this alternative and Alternative C is that there would be substantially 

greater disturbance to grassland and shrubland wildlife from mechanical vegetation treatments. Due to 

the prohibition on herbicides under this alternative, the BLM estimates that it would need to repeat 

treatments at a very high rate in order to meet habitat and plant communities objectives. This would 

cause the greatest disturbance to wildlife in grasslands and shrublands from vegetation treatments of any 

alternative. 

Alternative D 

Alternative D would have a similar potential for recreation-related disturbance to grassland and shrubland 

wildlife to the No Action Alternative, and a greater potential for such impacts compared to alternatives A, 

B, and C. Trail miles within grassland and shrubland would increase to 5.6 miles, a 0.5 mile more than 

currently exist. Approximately 1 mile of trail in grassland and shrubland would continue to be open to 

equestrian and bicycle use. Because all trails are currently open to all non-motorized uses, there would be 

fewer trail miles on which the BLM would allow these modes of transportation than there are currently. 

However, the designation of trails explicitly for these uses could increase participation in these activities 

in the Monument. 

Acres open to dispersed camping in Monument grasslands and shrublands would decrease by 41 acres 

under this alternative compared to the No Action Alternative. Potential disturbance to wildlife from 

designated site camping would increase substantially under this alternative as an additional 85 acres of 

grassland and shrubland would be open to this use. Designated site camping is more predictable than 

dispersed camping and it is likely that the latter form of camping could cause greater disturbance to 

wildlife in grasslands and shrublands. 

Under Alternative D, the BLM would be likely to implement more vegetation treatments in grasslands 

and shrublands than under the No Action Alternative or Alternative A, but substantially fewer than under 

all other alternatives. Disturbance effects from treatments would be similar to the No Action Alternative 

and Alternative A. The BLM would allow all types of vegetation treatments under this alternative, but 

estimates that it would use a small acreage of mechanical treatments, herbicides, and prescribed fire to 

accomplish the Alternative D habitat and plant communities objectives. All of these activities would 

disturb wildlife in grasslands and shrubland habitats. 

Nearshore Wildlife Association 

The alternatives would vary in the extent to which nearshore stabilization and recreational opportunities 

would create the potential for wildlife disturbance in nearshore habitats. Specifically, the BLM assumes 

that the more miles of shoreline are open to recreational boat landing the greater the potential for 

nearshore fish and wildlife disturbance; similarly the BLM assumes that the more trails within 300 feet of 

the shoreline the more potential for disturbance to marine mammals and sea birds (see Table 70). Human 

and wildlife interactions are generalized with a basic assumption that fewer human-wildlife interactions 

would result in fewer negative impacts to wildlife. See the Overview of Disturbance from Visitation 

section for a discussion of impacts from these recreational activities. 

Unlike other habitat types, the BLM is unlikely to implement vegetation treatments directly in nearshore 

habitats. Stabilizing shorelines, which the BLM would undertake only to protect vulnerable cultural or 

paleontological resources, would disturb some amounts of nearshore wildlife during construction. 

Impacts from shoreline stabilization could include disruption or killing of fishes through the placement of 

stabilization materials. While impacts from shoreline stabilization to nearshore habitat would be longterm, disruption or killing of fish would only occur during the initial installation. The potential for direct 

impacts to fishes from installation of bank stabilization would be associated primarily with the amount of 

materials used; the BLM assumes that hard and soft stabilization would have similar potential to disrupt 

or kill nearshore fishes. Because the BLM would implement hard stabilization only where soft 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

274 
Table 70: Nearshore recreation-related disturbance indicators by alternative 

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 stabilization would be ineffective, the BLM assumes that more stabilization, and thus more disruption to 

2 nearshore wildlife, would take place under alternatives where it allows both methods. 

3 

No Action 

Alternative 

Alternative 

A 

Alternative 

B 

Alternative 

C 

Alternative 

D 

Miles of trail within 300 feet 

of a marine mammal haulout 3.9 0 4.4 3.2 6.1 

Miles of trail within 300 feet 

of shoreline 10.2 0 11.0 7.3 14.3 

Miles of shoreline continuing 

to be open to recreational use 

21.2 0 17.3 18.5 21.2 

4 No Action Alternative 

Under the No Action Alternative, the BLM would continue to allow recreational boat landings on all 21.2 

miles of Monument shoreline (see Table 70). Boat landings would continue to lead to rare, localized 

disturbance and occasional killing of fish utilizing nearshore habitats adjacent to Monument. The most 

likely individuals to be impacted would be fishes and lifeforms tied to nearshore habitat: eulachon, 

juvenile salmonids, and juvenile rockfishes. 

Access to all Monument shoreline for recreational boat landing, would continue current disturbance levels 

of marine mammals and birds making use of nearshore habitat. Similarly, current potential for 

disturbance associated with designated site camping at Blind, Posey, and Patos Islands would continue. 

The BLM would also continue to allow dispersed camping on all Monument lands outside of the 503 

acres included in the ACECs on the south end of Lopez Islands. If current trends continue, participation 

in dispersed camping would remain low. Under this alternative there would continue to be 10.2 miles of 

trail within 300 feet of the shoreline and 4 miles of trail located within 300 feet of documented marine 

mammal haulouts (see Table 70). Hikers are not currently required to remain on trail, although the 

majority do. The No Action Alternative would have less potential for disturbance from visitors hiking 

and camping in the Monument than the Alternative D, but more than all other alternatives. 

There would continue to be the current level of disturbance to marine mammals and special status 

nearshore birds such as bald eagle, harlequin ducks, common loons, and rhinoceros auklet. Except for 

Alternative D, this alternative would have the greatest potential for disturbance to these species. 

The BLM would continue to undertake shoreline stabilization on an as-needed basis to protect cultural 

resources. While the BLM has only undertaken a limited amount (<0.1 mile of shoreline) of soft 

stabilization in the past, there are no existing plan decisions prohibiting the use of hard shoreline 

stabilization. Where new stabilization projects occurred, the placement of materials could cause the 

disturbance and killing of fishes in nearshore habitats. The most likely individuals to be impacted would 

be fishes and lifeforms tied to nearshore habitat: eulachon, juvenile salmonids, and juvenile rockfishes. 

Alternative A 

Under Alternative A, the BLM would prohibit recreational boat landings along all 21.2 miles of 

Monument shoreline (see Table 70). While boat landing would continue in emergencies as well as for 

authorized and administrative purposes, this would dramatically reduce the rate of boat landing on 

Monument shoreline. Alternative A would have the least disturbance or killing of fishes from boat 

landing of any alternative. It would also have the least disturbance to nearshore birds and marine 

mammals using nearshore habitat of any alternative. Foraging and resting habitat for nearshore birds and 

marine mammals would improve due to the decline in disturbance. 

Under this alternative, the BLM would only undertake soft stabilization to protect cultural resources. 

Where new stabilization projects occurred, the placement of materials could cause the disturbance and 

killing of fishes in nearshore habitats. The most likely individuals to be impacted would be fishes and 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

275 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 lifeforms tied to nearshore habitat: eulachon, juvenile salmonids, and juvenile rockfishes. Potential 

impacts from shoreline stabilization to fishes would be slightly less than under the No Action Alternative. 

Alternative B 

Under Alternative B, the BLM would continue to allow boat landings on 16.4 miles of Monument 

shoreline (see Table 70). The BLM would prohibit recreational use, including recreational boat landings, 

on all marine rocks and rock groupings and at Watmough Bay (see Appendix O for Category A Rocks, 

Category B Rocks, and Watmough Bay RMA frameworks). This would result in more boat-landing 

related disturbance or killing of fishes utilizing nearshore habitats than Alternative A, but less than other 

alternatives. Forage fishes would benefit from reduced impact in Watmough Bay, leading to improved 

salmonid foraging in nearshore areas. 

Prohibiting recreational boat landing on 4.8 miles of Monument shoreline would minimize risk of 

disturbance to nearshore birds and marine mammals in those areas. Approximately 11 miles of trail 

would be located within 300 feet of the shoreline (0.8 miles more than currently exist) and 4.4 miles of 

trail would be located within 300 feet of documented marine mammal haulouts (0.4 miles more than 

currently exist) (see Table 70). Hikers would be required to remain on trail. The current potential for 

disturbance associated with designated site camping at Blind, Posey, and Patos Islands would continue. 

Alternative B would also allow dispersed camping by permit on 37 acres that are within 300 feet of 

designated marine mammal haulouts. Alternative B would have less potential for disturbance from 

visitors hiking and camping in the Monument than the No Action Alternative and Alternative D, but more 

than alternatives A and C. 

Under this alternative, the BLM could undertake hard shoreline stabilization, in addition to soft 

stabilization, as needed to protect cultural resources. Where new stabilization projects occurred, the 

placement of materials could cause the disturbance and killing of fishes in nearshore habitats. The most 

likely individuals to be impacted would be fishes and lifeforms tied to nearshore habitat: eulachon, 

juvenile salmonids, and juvenile rockfishes. Potential impacts from shoreline stabilization to fishes 

would be the same as the No Action Alternative and slightly greater than under the other action 

alternatives because of the likelihood that more stabilization would take place over the life of the plan 

under alternatives that allow hard stabilization throughout the Monument. 

Alternative C 

Under Alternative C, the BLM would continue to allow recreational boat landings on 17.8 miles of 

Monument shoreline. The BLM would prohibit recreational use, including recreational boat landings, on 

smaller and/or more sensitive rocks and rock groupings; motorized boat landings would be prohibited at 

Watmough Bay (see Appendix O for Category B Rocks and Watmough Bay RMA frameworks). This 

would result in an intermediate level of disturbance or killing of fishes utilizing nearshore habitats. Fewer 

landings on smaller and/or more sensitive rocks could lead to reduced impact to fishes using deeper 

marine habitats, including rockfishes. 

Prohibiting recreational boat landing on 3.4 miles of Monument shoreline would minimize risk of 

disturbance to nearshore birds and marine mammals in those areas (see Table 70). Approximately 7.3 

miles of trail would be located within 300 feet of the shoreline (2.9 miles less than currently exist) and 3.2 

miles of trail would be located within 300 feet of documented marine mammal haulouts (0.8 miles less 

than currently exist) (see Table 70). Hikers would be required to remain on trail. The current potential 

for disturbance associated with designated site camping at Blind, Posey, and Patos Islands would 

continue. The BLM would prohibit camping on all other Monument lands. Alternative C would have 

less potential for disturbance from visitors hiking and camping in the Monument than the No Action 

Alternative and alternatives B and D, but more than Alternative A. 

Under this alternative, the BLM would only undertake soft stabilization to protect cultural or 

paleontological resources. Where new stabilization projects occurred, the placement of materials could 

cause the disturbance and killing of fishes in nearshore habitats. The most likely individuals to be 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

276 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 impacted would be fishes and lifeforms tied to nearshore habitat: eulachon, juvenile salmonids, and 

juvenile rockfishes. Potential impacts from shoreline stabilization to fishes would be slightly less than 

under the No Action Alternative and alternatives B and D. 

Alternative D 

Under Alternative D, the BLM would continue to allow recreational boat landings on all 21.2 miles of 

Monument shoreline; the BLM would also increase acres open to designated site camping for visitors 

arriving by non-motorized boat (see Table 70). The development of new campsites during plan 

implementation would lead to the increase of landings at these locations. This would lead to a slightly 

increased level of boat landing-related disturbance and occasional killing of fish compared to the No 

Action Alternative. 

Potential for disturbance to marine mammals and nearshore birds would occur on all miles of the 

Monument shoreline. Approximately 14.3 miles of trail would be located within 300 feet of the shoreline 

(4.1 miles more than currently exist) and 6.1 miles of trail would be located within 300 feet of 

documented marine mammal haulouts (2.1 miles more than currently exist) (see Table 70). The current 

potential for disturbance associated with designated site camping at Blind, Posey, and Patos Islands 

would continue. Designated site camping would be allowed on an additional 117 acres within 30 feet of a 

documented marine mammal haulout. The BLM would identify new designated sites through 

implementation-level planning and NEPA compliance; it would not allow camping in these areas until 

sites are designated and analyzed for potential impacts to wildlife. Implementation-level planning would 

provide design features on a site-specific basis to avoid or minimize negative impacts associated with 

camping. Alternative D would also allow dispersed camping on 19 acres that are within 300 feet of 

designated marine mammal haulouts. If necessary seasonal closures or restrictions may be undertaken if 

human presence is observed to have negative impacts to wildlife. Alternative D would have the greatest 

potential for disturbance to marine mammals and nearshore birds of any alternative. 

Under Alternative D, the BLM could undertake hard stabilization of shorelines, in addition to soft 

stabilization, as needed to protect cultural or paleontological resources outside of areas managed for their 

wilderness characteristics (see Wilderness Characteristics on page 231 for more information). Where new 

stabilization projects occurred, the placement of materials could cause the disturbance and killing of 

fishes in nearshore habitats. The most likely individuals to be impacted would be fishes and lifeforms 

tied to nearshore habitat: eulachon, juvenile salmonids, and juvenile rockfishes. Based on hard 

stabilization being allowed in only part of the Monument, the BLM assumes that these impacts would be 

less than under the No Action Alternative and Alternative B and more than under alternatives A and C. 

Wetland Habitat Association 

The alternatives would vary in the extent to which vegetation treatments and recreational opportunities 

would create the potential for wildlife disturbance in wetland habitats. See the Overview of Disturbance 

from Vegetation Treatments section for a description of the types of wildlife disturbance that could occur 

through implementation-level vegetation treatments. See the Overview of Disturbance from Vegetation 

Treatments section for a description of the types of disturbance that could occur through visitors 

participating in the opportunities provided under each alternative. 

Wetland habitat is typically inaccessible to most recreationists. Wet soils and dense vegetation make offtrail use around wetlands difficult, thus deterring or preventing entrance by humans into most wetlands. 

Disturbance by human activity would be primarily limited to the margins of wetland habitats. Waterfowl 

and other migratory bird species could be flushed by Monument visitors that approach on trails in close 

proximity to wetlands. This could interrupt nesting behaviors resulting in decreased reproductive success, 

increased likelihood of nest predation or parasitism. Deer and other mammals may limit their use of 

wetland habitat during the busiest portions of the recreation season. Displacement from preferred habitat 

may occur, or the time of use may change (Ciuti et al. 2012). Animals may use wetlands as a water 

source during evening or night hours in order to avoid detection by humans. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

277 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 No Action Alternative 

If current management of the Monument continues, the BLM would expect recreation levels near wetland 

habitat to continue. There would continue to be 0.3 miles within 25 feet of a wetland and 0.9 miles of 

trail within 150 feet of a wetland, though these trail miles could expand through continued proliferation of 

user created trails. 

All trail miles would continue to be open to all non-motorized uses, though non-hiking uses are likely to 

continue to be limited. The 0.1-mile road to the Watmough Bay trailhead, which is partially within 150 

feet of Watmough Marsh, would remain open to all non-motorized uses in addition to public motorized 

use. Most research indicates that disturbance response for many wildlife species is greatest when wildlife 

are exposed to humans walking versus a vehicle or boat (Rodgers and Smith 1995, Miller et al 2001). 

Under the No Action Alternative, there would continue to be little to no disturbance of wetland wildlife 

from vegetation treatments management within the Monument. 

Alternative A 

Disturbance to wetland wildlife would be lowest under Alternative A. There would be no recreation 

allowed within the Monument under this alternative. Thus, human disturbance to wetland species would 

be limited to administrative use by Monument staff and authorized use for scientific, educational, cultural, 

and spiritual reasons. 

As under the No Action Alternative, under Alternative A there would continue to be little to no 

disturbance of wetland wildlife from vegetation treatments management within the Monument. 

Alternative B 

Under Alternative B, the BLM would designate 0.4 miles of trail within 25 feet of a wetland and 1.2 

miles of trail within 150 feet of a wetland; this would be slightly higher than under the No Action 

Alternative and Alternative C and substantially higher than under Alternative A. They would be the same 

trails as those under Alternative D. 

Unlike Alternative D, these trails would only be open to hiking under Alternative B. The 0.1-mile road to 

the Watmough Bay trailhead, which is partially within 150 feet of Watmough Marsh, would remain open 

to all non-motorized uses in addition to public motorized use. 

Disturbance impacts to wetland wildlife from implementation of wetland restoration and expansion 

projects would be substantial under Alternative B. Human activity, machinery noise, and disturbance to 

areas that are typically undisturbed would displace some wildlife, forcing them find other freshwater 

resources, which are limited on Lopez Island (the only Monument lands with wetlands are on Lopez 

Island). These effects would be temporary, however, and the BLM would expect normal wildlife use to 

resume once project implementation and habitat recovery were complete. 

Alternative C 

Under Alternative C, the BLM would designate the existing 0.3 miles of trail within 25 feet of a wetland 

and 0.9 miles within 15 feet of a wetland. Unlike the No Action Alternative, visitors would be required to 

stay on trails except for authorized purposes. The effects of disturbance from trail use to wetland wildlife 

under Alternative C would be very similar to the No Action Alternative. There would be a slightly lower 

potential for disturbance to wildlife from trail use under this alternative compared to alternatives B and D. 

The BLM would continue to allow equestrian use on 0.1 miles of trail within 25 feet of a wetland and 0.5 

miles of trail within 150 feet of a wetland, in addition to continued equestrian and bicycle access on the 

0.1-mile road to the Watmough Bay trailhead. While equestrian use does not inherently indicate a greater 

potential for disturbance, the explicit designation of these trails for that use may attract additional visitors. 

The potential for disturbance would increase if trail use increased over the life of the plan. 

Under Alternative C, the BLM would manage existing wetlands to control invasive species and improve 

hydrology (e.g., by removing encroaching trees). While wetland projects would affect fewer acres than 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

278 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 under Alternative B, there would still be substantial disturbance to wetland wildlife during the restoration 

efforts proposed. These disturbance effects would be similar to those described in Alternative B. 

Alternative D 

Under Alternative D, the BLM would designate 0.4 miles and 1.2 miles of trail respectively within 25 and 

150 feet of wetlands. This would be slightly higher than under the No Action Alternative and Alternative 

C and substantially higher than under Alternative A. They would be the same trails as those under 

Alternative B. 

Unlike Alternative B, nearly all of these trails would be open to equestrian and bicycle use. The 0.1-mile 

road to the Watmough Bay trailhead, which is partially within 150 feet of Watmough Marsh, would also 

remain open to all non-motorized uses in addition to public motorized use. While equestrian and bicycle 

use do not inherently indicate a greater potential for disturbance to wetland wildlife, the explicit 

designation of these trails for these uses may attract additional visitors. The potential for disturbance 

would increase if trail use increased over the life of the plan. 

Under Alternative D, the BLM would manage wetlands only to maintain current conditions. This would 

require slightly greater disturbance from vegetation treatments than under the No Action Alternative and 

Alternative A, but much less disturbance than under alternatives B and C. 

Conclusion 

Table 71 summarizes the relative impacts of human disturbance under each alternative on the various 

wildlife habitat associations. Potential impacts to wildlife include avoidance, displacement, decreased 

reproductive success, and energetic costs. In general, Alternative A would result in the lowest human 

disturbance to wildlife. The BLM would prohibit recreational use and undertake minimal vegetation 

treatments. Total human presence within the Monument would be lowest under Alternative A. With its 

lack of vegetation treatments and prohibition on recreational use, Alternative A would have the least 

impacts on wildlife from disturbance. 

Conversely, Alternative D would increase some recreational opportunities compared to the No Action 

Alternative, which would result in more human disturbance in the Monument during high use seasons. 

There would be substantially more acres open to designated camping and a slightly higher acreage (535 

acres compared to 516 acres) open to dispersed camping compared to the No Action Alternative. 

However, under Alternative D, the BLM would not implement the extensive vegetation treatments 

proposed in alternatives B and C, which would minimize project related disturbance to wildlife. 

Under the No Action Alternative, disturbance from recreation and minimal vegetation treatments would 

continue at their current level. Acres available to dispersed camping would be similar to Alternative D 

but there would be far more areas open to designated camping under Alternative D. Under Alternative D, 

the level of disturbance to wildlife resulting from recreation would be the greatest of any alternative and 

would be least desirable in regards to wildlife exposure to disturbance. 

The likelihood of direct impact to individual fishes under any of the alternatives would not be high. It is 

possible that implementation of some alternatives could lead to a temporary change in fish behavior for 

individual fishes using nearshore habitats, and perhaps very minor loss of individual nearshore fishes. It 

is very unlikely that any of the alternatives would lead to measurable changes in population or run sizes in 

any fish species in or adjacent to the Monument at any spatial scale. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

279 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Table 71: Summary of effects from disturbance due to vegetation treatments and recreational 

2 activities to wildlife under each alternative 

Wildlife and 

Habitat Association

No Action

Alternative

Alternative 

A Alternative B Alternative C

Alternative 

D

Terrestrial

Moderate 

impacts to 

wildlife 

Least

impacts to 

wildlife 

Moderate 

impacts to 

wildlife 

Moderate 

impacts to 

wildlife 

Greatest

impacts to 

wildlife 

Nearshore 

Moderate 

impacts to 

nearshore 

wildlife

Least

impacts

Moderate 

impacts to 

nearshore 

wildlife

Low impacts 

to nearshore

wildlife

Most

impacts to 

nearshore 

wildlife 

3 Cumulative Effects of the Alternatives on Disturbance to Wildlife 

Recreational activities with the potential to disturb wildlife (e.g., kayaking, hiking, camping, etc.) take 

place throughout the San Juan Islands on both private and public lands and waters. The intensity of 

visitor use varies by season and the accessibility of a given area. The Monument encompasses only 4 

percent of the public land in the San Juan Islands; nearly 96 percent of the land accessed by visitors is 

outside of the Monument. All waters accessed by visitors for boating and other aquatic activities are 

outside of the Monument. Decisions made in this RMP are unlikely to have a notable effect on the level 

of outdoor recreation taking place in the San Juan Islands. 

Because the acres of habitat that would be disturbed from recreation or vegetation management are small 

compared to the habitat available to wildlife in the San Juan Islands, the BLM does not expect substantial 

contributions to cumulative impacts from disturbance on wildlife species from any of the alternatives. 

While Alternative D would increase some recreational opportunities and alternatives B and C would 

result in large amounts of disturbance due to vegetation treatments, none of the alternatives would result 

in the need to federally list any species that are currently candidates for listing or are State or BLM 

special status species. 

See Wildlife Issue 1 for more detailed analysis of the cumulative effects of the alternatives on wildlife in 

the San Juan Islands. 

Wildlife Analytical Issue 3: How would the alternatives address the primary 

threats to island marble butterflies identified in the U.S. FWS’ 12 month finding 

for the species? 

See Appendix B for analytical methods used in this analysis. 

Background 

The U.S. FWS (2016) has identified the following threats to the island marble butterfly throughout the 

entirety of its range: (1) Habitat loss attributable to plant succession and competition with invasive 

species, herbivory by deer and European rabbits, and storm surges; (2) direct predation by spiders and 

wasps, and incidental predation by deer; (3) small population size and vulnerability to stochastic events; 

and (4) the cumulative effects of small population size and restricted range combined with any other 

stressor that removes individuals from the population or decreases the island marble butterfly’s 

reproductive success. 

The U.S. FWS announced a proposed rule to list the island marble butterfly, which is currently a 

candidate species, as an endangered species and designate critical habitat under the ESA (U.S. FWS 

2018). Critical habitat would include the Monument land at Cattle Point (approximately 23 acres). 

Affected Environment 

The only known extant population of the rare island marble butterfly occurs primarily on National Park 

Service lands adjacent to Monument land at Cattle Point (San Juan Island) with some minor occurrences 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

280 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 documented on State, county, and private lands. The BLM has the potential to contribute to the recovery 

of this species by providing suitable habitat for its expansion and/or reintroduction. Expansion or 

reintroduction of the species onto Monument land would primarily address the threat of habitat loss by 

providing suitable habitat to aid in the recovery of the species. The BLM assumes that improvements in 

habitat quality and quantity, and the potential expansion of the population, would assist in reducing the 

cumulative effects of small population size. 

Grassland habitat is of particular importance for the island marble butterfly; the Habitat and Vegetative 

Communities section includes a description of the current condition and trends for grasslands and 

shrublands on the Monument. Before its rediscovery on San Juan Island in 1998, the island marble was 

thought extinct for 90 years. Since 1998, the island marble butterfly has been documented in a few 

locations on San Juan Island and nearby Lopez Island (Schultz et al 2011, U.S. FWS 2014, U.S FWS 

2018), but only one population remains today. This population is located adjacent to the Monument on 

land managed by the National Park Service. The majority of Monument land known to be suitable for the 

island marble butterfly is at Cattle Point on San Juan Island (though this habitat would currently be 

limited to patrolling, mate finding, and nectaring, unless host plants become established); however, 

suitable habitat may occur on other Monument lands on Lopez Island. The Monument land at Cattle 

Point encompasses approximately 23 acres. 

The life cycle of the island marble butterfly is closely associated with its host plants (tumble and field 

mustard and Puget Sound peppergrass). The host plant on which the butterfly lays its eggs provides food 

for larvae in their early stages of development. The butterfly’s lifecycle begins in early April shortly after

the emergence of leaves and flowering stalks on the host plants at which time adults begin to emerge from

pupae. Adults live for 6-9 days, during which they mate and lay eggs. Eggs hatch in May and by June

larvae start searching for pupation sites where they wait until the following spring to emerge as adults 

(Lambert 2005).

The larval form of the island marble butterfly currently uses three species of host plants in the wild. Of

these three host plants, only Puget Sound peppergrass (Lepidium virginicum menziesii) is native to the 

area. Records indicate that peppergrass was once present at Cattle Point (1974), but no recent surveys 

have documented its presence. The other two host plants (tumble mustard [Sisymbrium altissimum] and 

field mustard [Brassica campestris]) are non-native species (U.S. FWS 2016). Currently, there are no 

known parts of the Monument, at Cattle Point or elsewhere, with established host plant populations. They

are, however, likely present in the seed bank at Cattle Point. While the BLM generally works to control

or eliminate non-native species in native-dominated habitat, the dependence of the island marble on nonnative mustards will require the BLM to consider the impact of such control on the butterfly. As a BLM 

sensitive species, during implementation the BLM will design projects to maximize potential benefits to 

species to avoid the need to list the species. 

Effects of the Alternatives 

No Action Alternative and Alternative A 

Under these alternatives, potential future habitat for the island marble butterfly would continue to 

decrease within the Monument, primarily from encroachment from undesirable or invasive herbaceous 

species or trees, by an estimated 17 acres (see Table 7 on page 75). Because suitable habitat would 

decrease, these two alternatives would not address the island marble butterfly’s “small population size 

and vulnerability to stochastic events.” 

Under the No Action Alternative and Alternative A, the BLM estimates that Monument grasslands and 

shrublands would decrease by approximately 13.5 percent over the next 20 years due to continued 

encroachment by forest species. This would reduce the potential Monument habitat available for 

expansion of the island marble butterfly population. Under these alternatives, the BLM would not treat 

grasslands to prevent this decline in acreage due to succession. Forest species and woody shrubs would 

continue to invade remaining grassland habitat, reducing its suitability for the butterfly. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

48 

281 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Under both the continuation of the current custodial management approach and Alternative A’s 

minimalist approach to management, the BLM would be unlikely to work with other agencies to reduce 

or eliminate non-native wildlife species, such as European rabbits, that may reduce the suitability of 

potential butterfly habitat through herbivory. While the island marble butterfly is not currently found 

within the Monument, in the event that they do re-occupy Monument habitat over the next 20 years, it is 

unlikely that the BLM would use actively manage grasslands to address predation by wasps and spiders, 

or incidental predation by deer. 

These alternatives would be the least likely to meet the intent of the BLM’s special status species policy, 

in that they would be unlikely to support the avoidance of the listing, or the eventual delisting, of the 

island marble butterfly under the ESA. 

Alternative B 

Under Alternative B, potential habitat for island marble butterfly would increase substantially compared 

to current conditions (from 126 acres to 520 acres). Approximately 50 percent of the Monument would 

be categorized as grassland and shrubland under Alternative B’s objectives. Vegetation management

would strive to enhance existing grasslands and the overall effect would be to improve and expand 

suitable habitat for the butterfly. The BLM would likely work with agencies to augment, translocate, or 

reintroduce butterflies on Monument lands and could partner with other agencies to reduce populations of 

non-native wildlife that negatively affect the Monument’s ecological values, including potentially

European rabbits. 

Under Alternative B, habitat for the island marble butterfly would increase in acreage and in suitability. 

The BLM would work with the U.S. Fish and Wildlife Service on vegetation management projects to 

enhance habitat conditions for federally listed or candidate wildlife species that are primarily using nonnative host plants, such as the island marble butterfly. Under this alternative, the BLM could maintain or 

establish non-native host plants for the butterfly (this would not include noxious weed species designated 

by Washington State for mandatory eradication or control). The BLM could also work with other 

agencies to address increases in non-native wildlife populations if monitoring demonstrates that they are 

damaging the Monument’s ecological values, which could reduce herbivory of important habitat, as well

as incidental predation. 

This alternative would best meet the intent of the BLM’s special status species policy, in that it would be 

most likely to result in the species not being listed, or eventually being delisted, under the ESA. 

Alternative C 

The effects of Alternative C on island marble butterfly would be similar to under Alternative B, except 

that the BLM would not establish or enhance populations of non-native host plants. The total potential 

habitat for island marble butterfly would be slightly smaller under this alternative than Alternative B (487 

acres compared to 520 acres), but much larger than under the No Action Alternative (109 acres) and 

alternatives A (109 acres) and D (126 acres). However, potential habitat would not include habitat for 

larval island marble butterfly, unless non-native host species become established incidentally or through 

the re-introduction of native Puget Sound peppergrass. As a result, benefits to the butterfly would be low 

under this alternative. 

This alternative would restore native grassland habitat, which could provide the non-larval island marble 

butterflies some additional habitat suitable for patrolling, mate finding, and nectaring. However, habitat 

for the larval form, which is the primary limiting factor for the butterfly, may not increase or have limited 

suitability. Of three known larval stage host plants, two are non-native and thus would not be managed 

for in this alternative, though they would likely continue to persist in the seed bank in some locations. 

The lone native host plant, Puget Sound peppergrass, is believed to be extirpated from Cattle Point and 

surrounding islands. The extent to which Puget Sound peppergrass could be re-introduced is not known 

at this time. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

282 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 The partial closure of 612 acres of the Monument to the discharge of firearms under this alternative would 

reduce the number of deer removed from the landscape through hunting. Hunting with the discharge of 

firearms would continue to be allowed throughout the Monument for half of hunting season. As a result, 

the reduction in the number of deer removed would be less than under Sub-Alternative C. Any 

substantial increase in deer in or near butterfly habitat would potentially increase incidental predation of 

butterflies and decrease the quality of habitat available (U.S. FWS 2018). The BLM could work with 

other agencies to address increases in non-native wildlife populations if monitoring demonstrates that 

they are damaging the Monument’s ecological values, which could reduce herbivory of important habitat, 

as well as incidental predation. 

Sub-Alternative C 

The primary difference between Alternative C and Sub-Alternative C is the prohibition of firearms and 

pesticide use for control of encroaching forest species and woody shrubs in grasslands. The overall 

benefit to the island marble butterfly would be negligible under this alternative, even less than under 

Alternative C. This is because it is unlikely that the BLM would achieve historic conditions and 

successfully control invasive and unwanted plants without the application of herbicides. 

The closure of the Monument to the discharge of firearms under this alternative would reduce the number 

of deer removed from the landscape through hunting. Any substantial increase in deer in or near butterfly 

habitat would potentially increase incidental predation of butterflies and decrease the quality of habitat 

available (U.S. FWS 2018). 

Alternative D 

There would be no increase or decrease in Monument acres of potential island marble butterfly habitat 

under Alternative D. However, the suitability of existing acres for non-larval island marble butterflies for 

patrolling, mate finding, and nectaring could increase if non-native plants (other than those used by the 

butterfly) are treated. The BLM estimates that it would do less vegetation treatment for invasive plants 

under this alternative than alternatives B and C, but more than under the No Action Alternative and 

Alternative A. In addition, the BLM could work with other agencies to address increases in non-native 

wildlife populations if monitoring demonstrates that they are damaging the Monument’s ecological

values, which could reduce herbivory of important habitat, as well as incidental predation. 

This alternative would maintain the current condition of existing grasslands, which could provide the nonlarval island marble butterflies some habitat suitable for patrolling, mate finding, and nectaring. 

However, habitat for the larval form, which is the primary limiting factor for the butterfly, may not 

increase or have limited suitability. 

Conclusion 

Alternatives B would result in the greatest benefit to the island marble butterfly. Restoration effort within 

existing grasslands, coupled with work to establish host plants, would improve and increase suitable 

habitat for this species within the Monument. This alternative would best meet the intent of the BLM’s 

special status species policy, in that it would be the alternative most likely to result in the species not 

being listed, or eventually being delisted, under the ESA. 

Alternative C would expand and improve habitat for non-larval island marble butterflies, but would only 

support larval butterflies if non-native host plants are established incidentally or native pepper grass is 

reintroduced. The No Action Alternative and Alternative A would have the greatest negative impacts on 

potential habitat for the butterfly. Over the life of the plan, the BLM estimates that colonization of trees 

into existing grasslands would result in 17 fewer acres of potential habitat available to the island marble 

butterfly. Under Alternative D, the BLM would maintain the current condition and extent of grasslands 

and so the extent and suitability of potential island marble butterfly habitat would not change. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

283 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Cumulative Effects of the Changes to Habitat Quantity and Quality on the 

Primary Threats to Island Marble Butterfly 

Throughout the Puget Lowland Ecoregion, which includes the San Juan Islands, both native and nonnative grassland habitat covers an estimated 9 percent of the pre-Euro-American settlement extent of

native grassland (Chappell et al. 2000). The Monument currently includes only 1.3 percent of the 

grasslands and shrubland vegetation within the San Juan Islands. This analysis assumes that all grassland 

and shrubland plant communities within the San Juan Islands are potential habitat for the island marble 

butterfly. Under all alternatives, the Monument includes only a small percent of this potential habitat. 

However, the close proximity of existing island marble butterfly populations to Monument grassland at 

Cattle Point (approximately 23 acres) make it potentially important habitat for expanding the butterfly 

population. The protected status of the Monument and its administration by a Federal agency also make it 

important to the potential expansion of the island marble butterfly throughout the San Juan Islands. 

The contribution of the Monument to potential island marble butterfly habitat varies by alternative. 

Alternative B would result in the greatest benefit to the island marble butterfly. Restoration effort within 

existing grasslands, coupled with work to establish host plants, would improve and increase suitable 

habitat for this species within the Monument. This alternative would best meet the intent of the BLM’s 

special status species policy, in that it would be the alternative most likely to result in the species not 

being listed, or eventually being delisted, under the ESA. Under the No Action Alternative and 

Alternative A, the decreasing acreage of Monument grasslands and shrublands would cause the overall 

acreage of potential habitat in the San Juan Islands to decrease by less than 0.1 percent (a decrease of 17 

acres). Under alternatives B and C, the overall potential habitat in the San Juan Islands would increase by 

3.7 percent (an increase of 394 acres) and 3.4 percent (an increase of 361 acres) respectively, though, as 

noted above, only under Alternative B would the BLM establish populations of non-native host plants. 

There would be no change in the overall potential habitat in the San Juan Islands under Alternative D. 

On June 5, 2012, the National Park Service published a notice of intent to prepare a Prairie Stewardship 

Plan and Environmental Impact Statement for the San Juan Island National Historical Park (National Park 

Service 2012). This plan would address island marble butterfly habitat near Monument land at Cattle 

Point on San Juan Island. Island marble butterfly currently occupy this nearby National Park Service 

land. It is reasonably foreseeable that some form of restoration will be carried out on this nearby land 

over the next 20 years. Management of Monument land in the grassland and shrubland class would likely 

be most consistent with this restoration effort under alternatives B and C. The limited management of 

invasive plant species under the No Action Alternative and Alternative A may hinder the effectiveness of 

this restoration effort due to limited management of invasive plants and non-native wildlife populations. 

Wildlife Analytical Issue 4: How would variations in the control of wildlife 

of management concern (i.e., potentially harmful wildlife) and opportunities for 

hunting using firearms impact wildlife habitat? 

See Appendix B for analytical methods used in this analysis. 

Affected Environment 

There are native, introduced, and domesticated and/or feral wildlife species within the San Juan Islands 

that may pose a threat to the diversity of habitats and wildlife for which the Monument was partially 

designated. For example, due to lack of predation and hunting pressure, black-tailed deer populations 

within the San Juan Islands have expanded and are influencing vegetative cover and wildlife habitat. 

Arcese et al (2014) found that the cover, richness, and diversity of native and culturally important shrubs 

were 52–85 percent lower at sites in the Salish Sea region with abundant deer. Martin et al (2011) found 

that islands in the San Juan archipelago with no deer have the more abundant and diverse bird populations 

than those with high deer densities. Another study, undertaken on a Canadian island near the San Juan 

Islands, suggests that herbivore browsing can have a greater influence on grassland native plant species 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

47 

284 
1 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

46 

than competition from non-native plants (Gonzales and Arcese 2008). Similar issues may arise in the 

Monument with Canada goose, non-native European rabbits, or other species. While the BLM does not 

have jurisdictional authority to manage these species directly, the BLM could collaborate with the 

WDFW, U.S. FWS, or APHIS to aid in regional planning efforts for wildlife of management concern. 

There is currently no management of potentially harmful wildlife within the Monument. 

The WDFW and tribes manage hunting, which includes both bow and firearm seasons. While 

participation numbers are unknown, the BLM is aware that hunters participate in the hunting seasons on 

Monument land. The BLM is aware of hunting occurring on approximately 590 acres of Monument 

land. The BLM and partners have observed hunting (with or without firearms) on Lopez Island at the 

contiguous Chadwick Hill, Point Colville, and Watmough Bay and Iceberg Point. Hunting has also 

occasionally been observed on Cattle Point (on San Juan Island) and at Turn Point (on Stuart Island). 

Based on BLM and partner observations, hunting for deer is the primary hunting activity, though there 

have been rare instances of waterfowl hunting at Chadwick Marsh on Lopez Island. Other species that

could be harvested within the Monument include California quail, wild turkey, and ring-necked pheasant, 

all three of which are introduced species to the San Juan Islands. 

Residents of Lopez Island have raised safety concerns about conflicts between deer hunting using

firearms and visitors participating in hiking and volunteer activities (BLM 2015b,c, BLM 2016a,b). The 

BLM has also received comments from members of the public and partner agencies asking that hunting

opportunities be maintained (BLM 2015b,c, BLM 2016a,b). Monument lands are one of two areas where 

hunting is allowed on publically accessible lands on Lopez Island. 

Effects of the Alternatives 

No Action Alternative

Under the No Action Alternative, there would continue to be opportunities to hunt with a firearm on 

Monument lands outside of developed recreation areas (e.g., parking lots, areas with picnic tables and 

designated campsites, etc.). As under all alternatives, opportunities for non-firearm-based hunting (e.g., 

bow hunting) would also continue. It is not possible to predict what level of harvest might take place 

over the next 20 years, but overall trends in participation in hunting with a firearm in Washington State 

are declining (U.S. FWS and U.S. Census Bureau 2011). If hunting use on the Monument did not change 

from current levels, populations for black-tail deer would be unlikely to decrease substantially. 

Assuming continuation of current management, the BLM would not work directly with agencies to 

control or eradicate species that are adversely affecting Monument objects and values (e.g., wildlife overconsuming native plant communities). Potentially harmful impacts include herbivory by European 

rabbits degrading potential habitat for the island marble butterfly and predation by eastern red foxes 

(which occur only on San Juan Island) on native wildlife such as ground nesting birds and the Shaw 

Island Townsend’s vole. 

Alternative A 

Under Alternative A, all Monument acres would continue to be open to firearms discharge. However, 

since no recreation would be allowed under Alternative A, there would be limited access to Monument 

lands for hunting. The BLM assumes that this would cause a reduction in harvest levels for black-tail

deer populations. Assuming current deer harvest on the Monument is influencing the deer population, 

this reduction in harvest could lead to an increase in impacts from deer on habitat and wildlife both 

within the Monument and on nearby public and private land. 

Under Alternative A, as under the No Action Alternative, there would remain no direction for the BLM 

to work with agencies to control or eradicate species that are adversely affecting Monument objects and 

values. There would be no opportunity to address any adverse impacts from wildlife species identified

during plan implementation. See the No Action Alternative for examples of potential adverse impacts. 

5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

285 
5

10

15

20

25

30

35

40

45

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Alternative B 

Under Alternative B, the use of firearms for hunting would continue to be allowed across the Monument. 

As a result, in regards to impacts to habitat from changes to deer populations, Alternative B would have 

similar impacts to the No Action Alternative and Alternative D. 

Under Alternative B, the BLM would work with wildlife agencies to control or eradicate wildlife species 

that are affecting Monument objects and values. This may include coordinating with APHIS, WDFW, 

and/or other agencies to control or eradicate potentially harmful wildlife. 

This alternative would allow for implementation of measures to reduce the impacts of species such as 

European rabbits and eastern red foxes, both non-native game species, on wildlife and habitats within the 

Monument. Reductions in European rabbit would lesson herbivory on native grasses and forbs, which 

would benefit potential habitat for important native wildlife, including the island marble butterfly. 

Similarly, reducing introduced eastern red foxes would help restore a more historically natural predator to 

prey relationship on San Juan Island. Less predation by foxes would increase survival and reproduction 

of native prey species like the BLM sensitive Shaw Island Townsend’s vole, as well as reduce parent or

egg consumption of ground nesting or near-ground birds. Restoration of grasslands impacted by 

European rabbits would also make habitat more suitable for the Taylor’s checkerspot butterfly, and other

grassland wildlife like the short-eared owl, streaked horned lark, and Shaw Island Townsend’s vole.

Alternative C 

Under Alternative C, discharge of firearms would be allowed on portions of the Monument during 

approximately half of regular deer hunting seasons. This would allow for some continued harvest of 

game species, such as black tailed deer, using firearms. As under all alternatives, tribal hunting and nonfirearm-based hunting (e.g., bow hunting) would continue. Given that there would be restrictions that 

would affect hunting that do not currently exist, the BLM assumes there would be some reduction in the 

current rate of harvest under this alternative. Assuming that current harvest is having an effect on the 

black tail deer population, this would lead to a slight increase in local black-tailed deer numbers and a 

commensurate increase in impacts to habitat and wildlife. 

Under Alternative C, as under Alternative B and D, the BLM would work with wildlife agencies to 

control or eradicate wildlife species that are negatively affecting Monument objects and values. The 

effects would be the same as those described under Alternative B. 

Sub-Alternative C 

Under Sub-Alternative C, the Monument would be closed to discharge of firearms (it is otherwise 

identical to Alternative C for the purposes of this issue). As under all alternatives, tribal hunting and nonfirearm-based hunting (e.g., bow hunting) would continue. Prohibiting the use of firearms would reduce 

hunter harvest rates of black-tailed deer. Assuming that current harvest is having an effect on the black 

tail deer population, this would lead to a slight increase in local black-tailed deer numbers and a 

commensurate increase in impacts to habitat and wildlife. 

Alternative D 

In regards to hunting with firearms, Alternative D would have similar impacts to the No Action 

Alternative and Alternative B. All acreage would continue to be open to firearms discharge. 

Under Alternative D, as with Alternative B and C, the BLM would work with wildlife agencies to control 

or eradicate wildlife species that are negatively affecting Monument objects and values. The effects 

would be the same as those described under Alternative B. 

Conclusion 

Because of restrictions on access or discharge of firearms closures, alternatives A, C, and Sub-C would 

reduce the level of hunting within the Monument. This would reduce the rate of harvest of game animal 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

286 
5

10

15

20

25

30

35

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 populations and could result in an increase in local deer populations in and around Monument lands 

where hunting is currently taking place (see affected environment). 

Under the No Action Alternative, Alternative B, and Alternative D, which would not have firearms 

closures, the BLM assumes that current harvest rates would continue. Current harvest rates on Monument 

lands are unknown but are unlikely to be substantial enough to have population-level effects. However, 

local deer numbers could potentially decline if harvest levels were to increase. It is possible that local 

deer populations would be reduced enough to have indirect impacts on habitat by reducing herbivory. 

Lastly, alternatives B, C, and D would direct the BLM to work with wildlife agencies to control or 

eradicate wildlife species that are negatively affecting Monument objects and values. Under all 

alternatives, the specifics of any of projects to control species, including species addressed and modes of 

control, would be determined during implementation and would be subject to public comment and review. 

Native species, such as Columbia black-tail deer, in addition to non-native species, could be controlled 

under these alternatives if they are adversely affecting Monument objects and values. 

Cumulative Effects of the alternatives on control of wildlife of management 

concern and access to firearm-based hunting opportunities impact wildlife and 

wildlife habitat 

In the San Juan Islands as a whole, hunting on publically accessible lands is extremely limited (see Table 

36 on page 153). Publically accessible lands available to hunting in the San Juan Islands are described on 

page 177. On Lopez Island, there is one area of non-Monument public land that currently allows hunting. 

Under Alternative A and Sub-Alternative C, limitations on access and discharge of firearms within the 

Monument would reduce the level of harvest of deer from public lands compared to what is currently 

taking place. Given the scarcity of public lands open to hunting in the San Juan Islands, hunters using 

firearms would have few alternative locations to hunt without the permission of a private landowner. 

This could lead to an overall decline in deer harvest in the San Juan Islands. 

There is limited effort to control of wildlife that adversely affect natural resources on public lands in the 

San Juan Islands. The National Park Service is in the early stages of planning for prairie restoration near 

Monument land at Cattle Point (National Park Service 2012). While a draft plan has not been released, 

this effort will consider control of nonnative wildlife. If the National Park Service undertakes control, a 

coordinated approach on nearby public lands would be beneficial; this could occur under alternatives B, 

C, and D, but would not occur under Alternative A. Given that there has been no wildlife control within 

the Monument in the past, the BLM assumes it would not occur under the No Action Alternative. 

None of the alternatives would have direct impacts on special status or federally listed species because 

legal harvest of these species would not be allowed within the Monument regardless of which alternative 

is selected. As described above, deer harvest and control of certain wildlife could improve the condition 

of potential habitat for the island marble butterfly. This could lead to an increase in overall suitable 

habitat in the San Juan Islands. The BLM does not expect there would be a contribution to negative 

cumulative effects on special status wildlife from hunting or wildlife control. 

2 

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

287 
5

10

15

20

25

30

35

40

San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Chapter 4 – Consultation and Coordination 

Introduction Partnerships are an essential component to the successful management of the Monument. The 

Monument’s many locations are dispersed throughout the San Juan Islands and share boundaries with 

lands and waters managed by Federal, State, and local governments, in addition to private individuals and 

organizations. The San Juan Islands are part of the ancestral territories of the Coast Salish peoples. 

Active participation by tribal partners in Monument management honors their long-standing relationship 

with the landscape and helps the BLM more effectively manage sensitive values and relate the Coast 

Salish people’s history and culture to the wider public. 

This chapter describes public involvement and agency consultation and coordination for this Draft 

RMP/EIS. The list of the preparers of this RMP/EIS can be found in Appendix M. 

The NEPA and associated regulations and policies require the BLM to seek public involvement 

throughout the planning process to develop a reasonable range of alternatives and to prepare 

environmental documents that disclose the potential significant impacts. 

Public involvement and agency consultation and coordination were achieved through Federal Register 

notices, one-on-one and multi-agency meetings, public meetings and workshops, individual contacts, 

media releases, newsletters, and the San Juan Islands National Monument RMP website. The BLM also 

has the benefit of working with the Monument Advisory Committee. 

Public Involvement Public scoping for the RMP began with the publication of a Notice of Intent to Prepare a Resource 

Management Plan in the Federal Register on March 2, 2015. During scoping, the BLM widely 

distributed press releases and sent 191 hard copy letters and 102 emails to potentially interested parties 

announcing the initiation of the scoping process and describing how to participate. The BLM also held 

five public meetings, one at each of the following locations: Lopez Island, Friday Harbor (San Juan 

Island), Eastsound (Orcas Island), Anacortes (the city from which the ferry departs), and on the 

interisland ferry. The BLM received 88 comments during the scoping period. The scoping report 

summarizes these comments and provides the planning issues and revised planning criteria. 

During the winter and spring of 2016, the BLM solicited public comments on human use (i.e., recreation) 

management in the Monument. During this time, the BLM held four workshops, in addition to one 

Monument Advisory Committee meeting, at which members of the public were invited to use large-scale 

maps to provide information on recreational uses they would like to see facilitated, limited, or prohibited. 

They also provided feedback on trails they would like to see maintained, closed, or developed and the 

uses the BLM should allow on each trail. The BLM used the feedback from these meetings to develop 

the RMA Frameworks in Appendix O and the Draft Travel and Transportation Plan in Appendix H. The 

BLM received 554 comments from 91 individuals during this time. 

During the development of the Draft RMP/EIS, the BLM has sent 17 newsletters to the RMP interested 

parties email list, which includes over 350 subscribers. These newsletters provide updates on the 

planning effort, as well as other Monument-related news. 

The scoping report and the summary of input from the 2016 workshops are available on the RMP 

website: https://go.usa.gov/xRphc 

Monument Advisory Committee 

Proclamation 8947 required that the BLM “shall prepare and maintain a management plan for the 

monument and shall establish an advisory committee under the Federal Advisory Committee Act (5 USC 

App.) to provide information and advice regarding the development of such plan.” The Monument

3 

4 

6 

7 

8 

9 

11 

12 

13 

14 

16 

17 

18 

19 

21 

22 

23 

24 

26 

27 

28 

29 

31 

32 

33 

34 

36 

37 

38 

39 

41 

42 

43 

44 

2 

288 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 Advisory Committee is composed of twelve members: two representing recreation and tourism interests, 

two representing wildlife and ecological interests, two representing cultural and heritage interests, two 

representing the public-at-large, one representing tribal interests, one representing local government, one 

representing education and interpretation interests, and one representing private landowners. 

The Monument Advisor Committee has provided invaluable guidance to the BLM on the Monument’s 

values, the human uses of the Monument, and on how the BLM can best incorporate the public into the 

planning effort. The committee met with the BLM 11 times during the development of the Draft 

RMP/EIS. All committee meetings are open to the public and include a public comment period. The 

BLM will continue to meet with the committee throughout the planning process. 

Government-to-Government Relationships 

Federally recognized tribes have a unique relationship with the Federal government, because they are 

sovereign nations and retain inherent powers of self-government. The BLM consults with tribes on a 

government-to-government basis. Numerous laws, regulations, and policies describe the requirement of 

Federal agencies to notify and consult with Native American tribes and to consider their rights and 

interests when planning and implementing Federal undertakings. In recognition of its responsibility to 

federally recognized tribes, the BLM conducts government-to-government consultation with tribes to 

identify areas of mutual interest and concern and to consider the potential effects of Federal undertakings 

and actions on tribal rights and interests. 

The San Juan Islands are part of the ancestral territories of the Coast Salish peoples. The BLM invited 

potentially affected tribes—listed below—to participate in government-to-government consultation in the 

development of this RMP. Consulting tribes have provided invaluable information on the relationship of 

the Coast Salish peoples with the San Juan Islands and approaches to managing the Monument. 

Twelve federally recognized Native American tribes are known to have interests in the Monument:

Jamestown S'Klallam Tribe Skokomish Indian Tribe 

Lower Elwha Tribe Stillaguamish Tribe of Indians 

Lummi Nation Suquamish Tribe 

Nooksack Tribe Swinomish Indian Tribal Community 

Port Gamble S'Klallam Tribe Tulalip Tribes of Washington 

Samish Indian Nation Upper Skagit Tribe 

The BLM sent pre-scoping letters to potentially interested tribes to notify them of the planning effort. 

The BLM formally initiated government-to-government consultation via letters from the BLM 

Oregon/Washington State Director in April of 2015. The BLM has solicited input from tribal 

governments throughout the planning process. This included opportunities to review and provide 

comments on preliminary drafts of Chapter 2 and 3 of this document, as well as a pre-publication draft of 

the full Draft RMP/EIS. The BLM has met in person with representatives of individual tribes throughout 

the planning process. The BLM has also met with representatives of multiple tribes on two occasions to 

discuss the range of alternatives and the analysis. 

The BLM will continue government-to-government consultation with the federally recognized Coast 

Salish tribes throughout the planning process. The BLM continues to seek opportunities to deepen 

cooperative partnerships with tribes. 

Cooperating Agencies 

The FLPMA and NEPA provide direction regarding the coordination and cooperation of Federal agencies 

with other Federal agencies and Tribal, State, and local governments. Cooperating agency status provides 

a formal framework for governmental units (including Tribal, Federal, State, and local) to engage in 

active collaboration with a lead Federal agency to implement requirements of the NEPA. For this RMP, 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

289 
San Juan Islands National Monument Draft RMP/EIS: Chapter 3 

1 the BLM has worked with cooperators from many agencies. With all formal cooperators, the BLM has 

signed a memorandum of understanding, identifying the roles and responsibilities of the BLM and the 

cooperating agency in the planning process. 

Thirteen Tribal, Federal, State, and local governments/agencies have signed MOUs to participate in the 

development of the RMP/EIS as cooperating agencies: 

City of Anacortes Stillaguamish Tribe of Indians 

National Park Service, San Juan Town of Friday Harbor 

Island National Historical Park Tulalip Tribes of Washington 

Port Gamble S'Klallam Tribe U.S. Coast Guard 

Samish Indian Nation U.S. Fish and Wildlife Service 

San Juan County U.S. Navy, Naval Air Station 

Skokomish Indian Tribe Whidbey Island 

State of Washington 

The Jamestown S’Klallam Tribe, U.S. EPA, NOAA Fisheries, Skagit County, and Whatcom County

formally declined the BLM’s invitation to participate as cooperating agencies. 

The BLM invited agencies with jurisdiction by law and/or special expertise to participate as cooperating 

agencies in April of 2015. The BLM has solicited input from cooperating agencies throughout the 

planning process. This included opportunities to review and provide comments on preliminary drafts of 

Chapter 2 and 3 of this document, as well as a pre-publication draft of the full Draft RMP/EIS. The BLM 

has met with the cooperating agencies as a group on five occasions during the development of the Draft 

RMP/EIS, in addition to engaging with sub-sets of the cooperating agency group through calls focused on 

specific topics. The BLM will continue to engage with cooperating agencies throughout the planning 

process. 

Regulatory Agency Consultation In addition to the coordination and cooperating mentioned above, the BLM consults with specific 

agencies that have regulatory duties under the Endangered Species Act and the National Historic 

Preservation Act. These consultations can be formal or informal and are ongoing throughout the planning 

process. The BLM will complete consultation before issuing a Record of Decision. 

The BLM will consult with the U.S. FWS and NOAA Fisheries on the Proposed RMP under Section 7 

(a)(2) of the Endangered Species Act. As part of this consultation, the BLM will prepare biological 

assessments that describe the impacts of implementing the Proposed RMP. In these biological 

assessments, the BLM will describe the Proposed RMP, the geographic area it will address, and the way it 

would affect threatened, endangered, and proposed species and their designated and proposed critical 

habitats. The BLM will submit these biological assessments to the U.S. FWS and NOAA Fisheries. 

The U.S. FWS and NOAA Fisheries will issue biological opinions. These evaluate whether the proposed 

RMP would be likely to jeopardize the continued existence of any threatened, endangered, or proposed 

species or if it would adversely modify their critical habitats. 

The BLM notified the Washington SHPO in March of 2015 that the BLM was preparing an RMP for 

management of the Monument. The State of Washington signed on as a cooperating agency in January of 

2016 with the Deputy SHPO identified as an agency representative. The BLM has received input from 

SHPO at several stages of the planning process, including on the range of alternatives and the preliminary 

analysis of the effects of the alternatives. The BLM will solicit comments from the SHPO on the 

development of the Proposed RMP/Final EIS and will continue to consult about undertakings pursued in 

accordance with an approved RMP. 

2 

3 

4 

5 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

290 

United States Department of the Interior 

Bureau of Land Management - Spokane District Office 

1103 N. Fancher Road 

Spokane, WA 99212 

OFFICIAL BUSINESS 

PENALTY FOR PRIVATE USE, $300 

FIRST CLASS MAIL 

POSTAGE AND FEES PAID 

Bureau of Land Management 

Permit No. G-76 

Cll -' 0 ii 

+ 

r--

a, N