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San Juan Islands National Draft RMP/EIS: Appendix A 

1 Appendix A: Alternatives and Issues Considered but not 

2 Analyzed in Detail 

3 Alternatives Considered but not Analyzed in Detail 

4 A Draft RMP/EIS must rigorously explore and objectively evaluate all reasonable alternatives. The BLM 

may eliminate from detailed analysis alternatives that are not reasonable. As explained in the BLM 

6 NEPA Handbook (BLM 2008b, page 52), an alternative need not be analyzed in detail if: 

7  It does not meet the purpose and need (see page 4 for the purpose and need) 

8  It is technically or economically infeasible 

9  It is inconsistent with the basic policy objectives for the management of the area 

 Its implementation is remote or speculative, or 

11  It is substantially similar to an alternative being considered in detail 

12 The BLM considered the following alternatives but eliminated them from detailed analysis, as explained 

13 below. Requested implementation-level actions that could be undertaken under one or more alternatives 

14 (such as installing bike racks or dog-bag dispensers) are not addressed in this list. 

Allow Camping throughout the Monument 

16 The BLM considered including in the range of alternatives an approach where camping (either dispersed 

17 or designated site) would be allowed throughout the Monument. BLM specialists determined that in 

18 certain areas totaling 49 acres it would not be possible to manage for this use while protecting sensitive 

19 cultural resources. These areas are small and have a high density of sensitive resources that could be 

disturbed through camping. This alternative would not meet the purpose of protecting the cultural 

21 resources for which the Monument was designated. An alternative does not need to be analyzed in detail 

22 if it does not meet the purpose and need for the project. Under alternatives B and D, camping is allowed 

23 in the majority of the Monument but is prohibited in specific areas with sensitive values (see the 

24 recreation frameworks in Appendix O). 

Allow Recreation but do not Manage It 

26 The BLM considered allowing recreation to take place within the Monument without managing it (i.e., 

27 allowing recreation but not designating recreation management areas with allowable and prohibited 

28 recreation uses). Given that recreation is increasing and that recreational activities affect the objects and 

29 values for which the Monument was designated, the BLM determined that this approach is not a 

reasonable way of meeting the purpose and need. This approach would also not meet the purpose and 

31 need of addressing increases in human uses of the Monument. An alternative does not need to be 

32 analyzed in detail if it does not meet the purpose and need for the project. 

33 Combine the Visitor Use Approach from Alternative A with the 

34 Ambitious Restoration Objectives (such as in Alternative C) 

The BLM received requests to combine the visitor use approach from Alternative A (i.e., focus visitor use 

36 on scientific, educational, cultural, spiritual, and tribal treaty related uses and prohibit recreation) with 

37 ambitious landscape restoration objectives, such as the approach that is currently included in Alternative 

38 C. Because these elements are already analyzed in the range of alternatives—and could be selected for 

39 inclusion in the Proposed RMP—the BLM did not recombine them into a separate alternative for the 

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San Juan Islands National Draft RMP/EIS: Appendix A 

1 Draft RMP/EIS. An alternative does not need to be analyzed in detail if it is substantively similar to other 

2 alternatives. 

3 Designate Trails for Motorized Use 

4 The BLM received requests for off-road opportunities in the Monument in general and on Indian Island 

specifically. Proclamation 8947 states that: "Except for emergency, Federal law enforcement, or 

6 authorized administrative purposes, motorized vehicle use in the monument shall be permitted only on 

7 designated roads, and non-motorized mechanized vehicle use in the monument shall be permitted only on 

8 designated roads and trails." The proclamation thus excludes from the Monument motorized use on trails 

9 or in open areas. In order to be in conformance with the requirements of the proclamation, the RMP does 

not consider allowing motorized use except on designated roads. This alternative does not meet the 

11 purpose of developing management actions that respond to the requirements of Proclamation 8947. It is 

12 also inconsistent with the basic policy objectives for the management of the area in that it would allow a 

13 use explicitly prohibited in Proclamation 8947. An alternative does not need to be analyzed in detail if it 

14 does not meet the purpose and need for the project or if it is inconsistent with the basic policy objectives 

for the management of the area. 

16 Designate the Area as a National Conservation Area 

17 The BLM received a request to designate Bureau-administered lands in the San Juan Islands as a National 

18 Conservation Area. Such designations can only be made by the U.S. Congress and so are outside the 

19 scope of this planning effort. The designation of the Monument in 2013 also gave the area a status very 

similar to that of a National Conservation Area. In that this action is outside of the scope of BLM’s 

21 management, it does not meet the purpose of the RMP to provide goals, objectives, and management 

22 direction to guide the BLM’s management of the Monument. An alternative does not need to be analyzed 

23 in detail if it does not meet the purpose and need for the project. 

24 Prohibit all Vegetation Management within the Monument 

The BLM considered including an entirely passive approach to vegetation management within the range 

26 of alternatives. Given that forest species are encroaching on the area’s grasslands and wetlands, and that 

27 Proclamation 8947 describes the Monument’s grasslands and wetlands as objects for which it was

28 designated, the BLM determined that an entirely passive approach would not meet the purpose of 

29 protecting the Monument’s diversity of habitats. An alternative does not need to be analyzed in detail if it 

does not meet the purpose and need for the project. Alternative A explores allowing natural succession 

31 on the landscape until thresholds have been passed and management intervention is needed to protect the 

32 viability of grasslands and wetlands within the Monument. 

33 Prohibit Hunting on Monument Lands 

34 The BLM received requests to restrict or eliminate hunting either in specific locations or within the 

Monument in general. These requests were generally linked to safety concerns around conflicts between 

36 hunters and other visitors. The BLM does not regulate hunting. In Washington State, the Washington 

37 Department of Fish and Wildlife regulates hunting. The purpose of the planning effort is to make 

38 decisions about lands and activities that are, or will be, under BLM jurisdiction. The BLM only included 

39 decisions in the alternatives that it has the authority to make or that it is likely to have the authority to 

make in the near future (e.g., for lands that are currently being relinquished by the Coast Guard). The 

41 BLM can restrict or prohibit the discharge of firearms within the Monument and is considering doing so 

42 within the range of alternatives. In that this action is outside the scope of the BLM’s management, it does

43 not meet the purpose of the RMP to provide goals, objectives, and management direction to guide the 

44 BLM’s management of the Monument. An alternative does not need to be analyzed in detail if it does not 

meet the purpose and need for the project. 

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San Juan Islands National Draft RMP/EIS: Appendix A 

1 Prohibit or Restrict Marine Fishing and Interactions with Orcas 

2 in the Waters around the Monument 

3 The BLM received requests to restrict or prohibit fishing and interactions between humans and orcas in 

4 the waters surrounding the Monument. The BLM does not have jurisdiction over these activities or over 

the waters surrounding the Monument. The purpose of the planning effort is to make decisions about 

6 lands and activities that are, or will be, under BLM jurisdiction. The BLM only included decisions in the 

7 alternatives that it has the authority to make or that it is likely to have the authority to make in the near 

8 future (e.g., for lands that are currently being relinquished by the Coast Guard). In that this action is 

9 outside the scope of the BLM’s management, it does not meet the purpose of the RMP to provide goals, 

objectives, and management direction to guide the BLM’s management of the Monument. An alternative 

11 does not need to be analyzed in detail if it does not meet the purpose and need for the project. 

12 Prohibit or Restrict Non-BLM-Administered Activities that 

13 Affect the Monument’s Soundscape

14 The BLM received requests to restrict loud activities taking place outside of the Monument, such as Navy 

training flights and loud speakers on boats in the waters surrounding the Monument. The BLM does not 

16 have jurisdiction over these activities or over the waters surrounding the Monument. The purpose of the 

17 planning effort is to make decisions about lands and activities that are, or will be, under the BLM’s 

18 jurisdiction. The BLM only included decisions in the alternatives that it has the authority to make or that 

19 it is likely to have the authority to make in the near future (e.g., for lands that are currently being 

relinquished by the Coast Guard). In that this action is outside the scope of the BLM’s management, it

21 does not meet the purpose of the RMP to provide goals, objectives, and management direction to guide 

22 the BLM’s management of the Monument. An alternative does not need to be analyzed in detail if it does 

23 not meet the purpose and need for the project. 

24 Prohibit Shoreline Stabilization 

The BLM considered including a full prohibition on shoreline stabilization in one of its alternatives, but 

26 concluded it could not do this and meet the purpose and need of protecting cultural resources. Shoreline 

27 erosion is currently affecting cultural resources within the Monument. While stabilization will not always 

28 be the best tool to address this issue, BLM specialists determined that it would not be possible to protect 

29 cultural resources without having stabilization available as a tool. This alternative would not meet the 

purpose of protecting the cultural resources for which the Monument was designated. An alternative does 

31 not need to be analyzed in detail if it does not meet the purpose and need for the project. The alternatives 

32 vary in whether the BLM would allow hard shoreline stabilization protect cultural resources; soft 

33 stabilization is allowed under all alternatives. 

34 Provide Camping to Support the Cascadia Marine Trail at 

Watmough Bay 

36 The BLM received comments asking that it consider designated site camping to support the Cascadia 

37 Marine Trail at a variety of locations, including Watmough Bay. In general, these requests were 

38 incorporated into Alternative D. BLM specialists determined that it is not possible to manage designated39 site camping at Watmough Bay (37 acres) while protecting sensitive objects and values at this location. 

This alternative would not meet the purpose of protecting objects for which the Monument was 

41 designated. An alternative does not need to be analyzed in detail if it does not meet the purpose and need 

42 for the project. 

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San Juan Islands National Draft RMP/EIS: Appendix A 

1 Identify Eligible Wild and Scenic River Segments as Suitable 

2 for Designation under the Wild and Scenic Rivers of 1968 (16 

3 USC 1271 et seq.) 

4 The Monument does not include any eligible river segments. The BLM has not identified any lotic 

(flowing) riparian systems within the Monument. Although several stream segments occur within 

6 Monument lands on Lopez Island, these segments are either inundated by ponded and wetland areas 

7 (Chadwick Marsh) or are no longer active (connection between Watmough Bay Wetland and Watmough 

8 Bay). In that the Monument does not include this resource, identifying eligible wild and scenic river 

9 segments does not meet the purpose of the RMP to provide goals, objectives, and management direction 

to guide the BLM’s management of the Monument. An alternative does not need to be analyzed in detail 

11 if it does not meet the purpose and need for the project. 

12 Analytical Issues Considered but Not Analyzed in Detail 

13 Analytical Issues considered in detail address the potential for significant impacts on the human 

14 environment from the alternatives or impacts from the alternatives that are pertinent to the purpose and 

need for the RMP. In general, issues were considered but not analyzed in detail because the alternatives 

16 do not have the potential to significantly affect the identified resource or issue. 

17 How would cultural and recreational approaches in the 

18 alternatives affect the risk of exposure to hazardous materials? 

19 In 2013, the BLM completed a human health risk assessment to characterize the nature and magnitude of 

health risks to residents, workers, and recreational visitors from lead contamination in the soil at the Turn 

21 Point Light Station and Patos Island Lighthouse. Pending a soil removal action at the Turn Point 

22 Lighthouse, use of these sites is not expected to pose unacceptable risks to human health under all 

23 alternatives. While the volume of visitation might increase under some alternatives, it is not reasonably 

24 foreseeable that the frequency or duration of visitation by individuals would have a potentially significant 

effect on risk of exposure to hazardous materials or pose unacceptable risks to human health under any 

26 alternative. The BLM has thus not analyzed this analytical issue in detail. 

27 How would the alternatives affect dark night skies in the San 

28 Juan Islands? 

29 Under all alternatives, the BLM would minimize impacts on dark night skies from all lighting installed 

within the Monument (see page 29 for pertinent management direction). Any lighting installations that 

31 would be developed during plan implementation would be required to meet this management direction 

32 and would be subject to additional planning, analysis, and public involvement. Any impact to dark night 

33 skies from lighting developed during plan implementation would be considered at that time. The plan 

34 direction will prevent potentially significant impacts to dark night skies from actions taken under this 

RMP. Because there is no potential for the RMP to have a significant impact on this resource, the BLM 

36 did not analyze this issue in detail. 

37 How would the alternatives affect the risk of oil spills to the 

38 San Juan Islands? 

39 The BLM’s response to oil and other hazardous material spills is not dictated by decisions made in this 

RMP. Under all alternatives, the BLM will continue to follow the most current version of the BLM 

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San Juan Islands National Draft RMP/EIS: Appendix A 

1 Spokane District’s Environmental Contingency Plan for Emergency Preparedness and Response to Oil 

2 and Hazardous Material Incidents (current version: BLM 2016c) and the Northwest Area Contingency 

3 Plan (www.rrt10nwac.com/nwacp/). The BLM does not have jurisdiction over either refineries in the 

4 vicinity of the San Juan Islands or vessel traffic through the Salish Sea. Thus, this RMP will not make 

decisions pertaining to either refineries or vessel traffic. The BLM’s responsibility under NEPA is to 

6 analyze the potentially significant effects of actions taken under its purview. The RMP would not have a 

7 potentially significant effect on the risk of oil spills in the San Juan Islands and so the BLM did not 

8 analyze this issue in detail. 

9 How would the alternatives affect underwater noise from 

existing and proposed vessel traffic and overflight naval test 

11 flights? 

12 The BLM’s jurisdiction applies only to the lands and activities it administers. For the purposes of this 

13 planning effort, this jurisdiction includes the lands the BLM-administers in the San Juan Islands; this 

14 jurisdiction ends at mean high tide and does not include the air space over the Monument. Thus, this 

RMP will not make decisions pertaining to vessel traffic and naval flights in the planning area. The 

16 BLM’s responsibility under NEPA is to analyze the potentially significant effects of actions taken under 

17 its purview. The RMP would not have a potentially significant effect on underwater noise from existing 

18 or proposed vessel traffic or naval test flights and so the BLM did not analyze this issue in detail. 

19 How would the alternatives affect Wild and Scenic Rivers? 

There are no designated, eligible, or suitable Wild and Scenic River segments in the Monument. The 

21 BLM has not identified any lotic (flowing) riparian systems within the Monument. The RMP would not 

22 have a potentially significant effect on designated, eligible, or suitable Wild and Scenic River segments 

23 and so the BLM did not analyze this issue in detail. 

24 How would the alternatives affect source water protection 

areas? 

26 Washington State’s Source Water Assessment Program has not identified any surface water protection 

27 areas within the Monument (Washington Department of Health 2018). In addition, the Monument does 

28 not include any land within identified time of travel zones for either Group A (15 or more service 

29 connections or serves 25 or more people) or Group B (fewer than 15 service connections) public water 

systems (Washington Department of Health 2010, 2018). Time of travel zones indicate the length of time 

31 between the introduction of water at the zone boundary and its eventual arrival at the well (Washington 

32 Department of Health 2010). For Group A public water systems the time of travel zones extend out to ten 

33 years. Because actions considered in the alternatives would not take place within a surface water 

34 protection zone and are outside the time of travel zones identified by the Washington State, the RMP 

would not have a potentially significant effect on source water and the BLM did not analyze this issue in 

36 detail. 

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