The Bureau of Land Management (BLM) San Juan Islands National Monument is inviting public comment on a proposal to conduct a Field School on Iceberg Point. As part of the proposed field school activities, a Professor from Central Washington University, along with his assistants and approximately 25 students will be conducting cultural resources inventory.
During the field school, interested community members and others visitors to the area can visit the site and learn more.
The BLM has prepared a draft categorical exclusion that is available for comment. If you would like to learn more, visit the Iceberg Point Fieldschool NEPA Project page.
Kwiaht is a conservation research cooperative based on Lopez that has studied the Iceberg Point ecosystem for the past 12 years. This is our comment objecting to a Categorical Exclusion for the field school:Report
Comment on BLM draft "categorical exclusion" document
As a scientific organization that has studied and interpreted the Iceberg Point landscape for more than a decade, we must condemn the draft categorical exclusion for an Iceberg Point archaeological field school in the strongest terms. The draft NEPA document misstates the law, ignores the existing ACEC status and declared values of the property, and makes assertions of fact regarding the potential impacts on biological resources that are false and misleading. The categorical exclusion cannot lawfully be granted.
Applicable law can be found in 43 CFR 46.210(e), which restricts "categorical exclusion" to "non-destructive data collection, inventory, and monitoring activities" that do NOT meet any of the "extraordinary circumstances" described in 43 CFR 46.215, which include:
1. "significant impacts" to "unique geographic characteristics as historic or cultural resources" 46 CFR 215(b);
2. "significant impacts" to "national monuments" 46 CFR 215(b);
3. "highly controversial" or "highly uncertain and potentially significant environmental effects" 46 CFR 215(c) and (d);
4. "significant impacts on species listed, or proposed to be listed" or habitat identified as critical for their survival, 46 215(h);
5. violates any federal, state, or tribal "law or requirement imposed for the protection of the environment" 46 CFR 215(i); or
6. contributes to the introduction or spread of noxious weeds, 46 CFR 215(l).
Based upon the sampling design described in the draft exclusion document, we calculate that the proposed field school activity will dig approximately 1,000 shovel-test pits in the native wildflower meadows at Iceberg Point in July 2017. That represents approximately 3,000 square feet of meadow surface, and thousands of plants that will be excavated and sieved for artifacts; not to mention the trampling of wildflowers in meadows and lichens on rocky balds by 25 people working off-trail for three weeks. By no stretch of the imagination is this level of disturbance "non-destructive".
Furthermore, the proposed activity involves all six of the "extraordinary circumstances" set out in 46 CFR 215 and summarized above. In brief:
1. The Executive Order establishing the San Juan Islands National Monument in 2013 states that the Monument includes unique "cultural landscapes". This is a reference to reports and conference papers by R. Barsh, M. Murphy, and G. Brown presenting ethnographic, botanical, and geological evidence for pre-Contact camas gardens at Iceberg Point. BLM's draft NEPA document ignores this evidence as well as express terms of the 2013 Proclamation by President Obama.
2. Iceberg Point is indisputably a part of a National Monument. The only question that remains is whether the proposed activity would have a "significant" impact. Based upon the studies of pre-Contact agriculture at Iceberg Point, the plants and soils are the principal cultural "artifacts" in this landscape, and destroying 3,000 square feet of them is difficult to describe fairly as "insignificant". In particular, we note that CWU's research plan includes walking over all of Iceberg Point's rocky outcrops or "balds" in a search for "petroglyphs" that somehow thousands of visitors have overlooked; this activity will devastate the remaining reindeer moss (Cladina) blankets on these balds, which trail relocation sought to protect, and which will almost certainly never regrow.
3. Digging a thousand test pits into the shallow soils of a pre-Contact garden site is an example of poorly-designed, highly destructive and therefore controversial research. More could be learned about pre-Contact use of this site by studying the genotypes of camas and other traditional food plants growing on the site (using leaf samples), and by drilling 50-100 half-inch soil cores for confirmation that soils are not natural products but rather the artifacts of pre-Contact gardening practices. We proposed such studies, but BLM rejected them unacceptably "destructive" - although in fact they would have involve fewer than 2 square feet of soil disturbance.
4. BLM claims that there are no listed or candidate species at Iceberg Point. Ironic, in view of the fact that BLM and USFWS out-planted federally-listed Golden Paintbrush at the site a few years ago; and that USFWS recently added island Townsend's Voles (Microtus townsendii pugeti) to its ESA candidate list. These voles abound at Iceberg Point, where they burrow and feed in the wildflower meadows that the proposed activity will disturb. In addition, White Topped Aster, a federal Species of Concern, and several state-listed plant species (described below) are also found throughout the Iceberg Point landscape. For example, California Buttercup, state-listed and also on Canada's Red List, is uniquely found at Iceberg Point mixed with more common Western Buttercups: the largest occurrence in Washington State of this flower, and the only provenance of the Washington State Museum's herbarium collection of this species. It is impossible in midsummer to identify and avoid California Buttercups.
5. The proposed activity violates the ACEC management plan that BLM itself adopted for Iceberg Point in 1990, and which in 2015 BLM admitted is still in force unless and until it is superseded by a management plan for the National Monument as a whole. The ACEC plan prioritizes protection of the unique plant community at Iceberg Point, and states that there are no other cultural resources on the property. It is unlawful to violate the ACEC protection of native wildflower communities in order to attempt to prove"or disprove"the accuracy of BLM's 1990 assessment that other cultural resources (perhaps burial cairns, shell middens, lithic tool scatters) are absent. Nor is there any urgent need to determine whether there are artifacts beneath the Iceberg meadows: existing protection of the meadows protects whatever cultural resources might possibly be concealed beneath them. The existing ACEC plan does not accord education (this is, after all, a "field school") priority over protecting the meadows.
6. It will be impossible for the proposed activity to avoid spreading noxious weeds such as European thistles. A crew of more than 25 people, walking the entire landscape as part of a systematic survey, digging pits and moving soils, leaving bare earth patches (even temporarily), would do more to spread weed seeds and create places for them to colonize than the damage we find has already been done by 37 years of public use of the limited network of trails.
The arid wildflower meadows at Iceberg Point have been shrinking for years as weeds fill in any disturbed areas such as trail edges, and shrubs and trees spread southward from the already-wooded half of the landscape. We have documented these changes for over a decade, and recommended that BLM support hand-clearing of woody colonists, and fencing to reduce the impact of deer browsing on tender herbaceous plants. We have recommended against the use of herbicides, burning, or heavy machinery in the meadows, all of which would be likely to open up bare soil to wind-blown weed seeds, and import additional weed seeds on boots and tires, as can be observed in parts of the nearby National Park where these methods have been assayed over the years with little success.
Interior Department recognition of the importance of Iceberg Point's flower meadows can be found in the 1990 ACEC designation and plan; in the 2013 Executive Order establishing this National Monument; in the Cooperative Agreements that the Department has funded with Stetson University, Kwiaht, and others to map, study and interpret the native plant community there; and in the signage that BLM has installed at the public entrance to Iceberg Point. It may also be relevant that Washington State's Natural Heritage Program classifies this type of rocky coastal bald-and-bluff landscape as "critical habitat" for rare state-listed plants.
The only ground-disturbance that BLM has permitted at Iceberg Point since 2013 was an attempt by the U.S. Fish and Wildlife Service to re-introduce Golden Paintbrush, the only plant species in our region that has a recovery plan under the Endangered Species Act. Clearly, the Interior Department and USFWS considered this coastal wildflower meadow to be an important "value" that would continue to be protected from degradation or loss.
The last thing this fragile landscape needs is 25 people with shovels trampling meadows off-trail, creating a thousand patches of bare soil and spreading weeds. It is nonsensical for BLM to argue that CWU will be careful not to spread weeds. CWU would have needed to propagate thousands of native wildflowers from Iceberg genetic stock before July (which we gravely doubt they have done), and immediately in-fill with native plants wherever they dug, and water them (it will be mid-July), which we see no evidence they have the capacity or intention of doing.
BLM's claim that rare plants will be avoided is also nonsensical. Most species of concern occur scattered among Eurasian grasses and weeds rather than in discrete patches. In July, they are finished flowering and may (at best) be identifiable from their leaves; but the leaves of most species have already died back for the year; or (in the case of Iceberg Point's exceptional Yellow Chocolate Lilies and state-listed California Buttercup, for instance) they are only distinguishable from similar but more common plants when they bloom in the spring.
Paradoxically, CWU asserts that it can reduce weed-seed dispersal by situating its field facilities and test pits in spots where there are no weeds. This is absurd in the Iceberg context and demonstrates CWU's lack of experience with this landscape. Weeds and native plants are interspersed throughout the landscape. There are no weed-less patches except on some of the rocky outcrops where only lichens, stonecrops (Sedum spp) and some small native wildflowers such as Polemonium and Olsynium can survive. But these patches have barely a few millimeters of soil and if trampled or scraped, disappear irreplaceably. These are precisely the most special and sensitive places in the Iceberg landscape"for the protection of which several social trails were closed by BLM in 2015"and yet they are the only places that meet CWU's criteria for low impact siting of field facilities. Unless they plan to situate them in the parcel's dense forest, a feat that would require new roads and tree-cutting.
Among the plant species at Iceberg Point that will be impacted are Seriococarpus rigidus (federal Species of Concern and also state-listed), Oxytropis campestris gracilis (state-listed), Ranunculus californicus (state-listed), and Lupinus microcarpus (state-listed). Rare, fragile lichens at Iceberg Point have been documented in exquisite detail by the lichenologist Fred Rhoades and published by the Washington Native Plant Society.
Iceberg Point meadows are not only important for their regionally rare lichens and plants but also for being the sole, or principal occurrence of many wildflower species in San Juan County. Examples include Polemonium pulcherrimum (one of only two occurrences in San Juan County), Olsynium douglasii (one of few occurrences in SJC), and Sanicula bipinnifinata (main occurrence in San Juan County, red-listed in Canada). We are especially anxious to avoid loss of Perideridia gairdnerii ("Yampah" or "Indian carrots"), an ethnobotanically significant species with curious as-yet unstudied variation in leaf morphology that is only found in scattered patches in the San Juan Islands, the largest of which by far is found at Iceberg Point and is probably a cultural product.
With the exception of a few low-lying dimples that collect water and silt, Iceberg Point is characterized by the thin gravelly soils, shingle fields, and polished and striated outcrops typical of a relatively recently de-glaciated landscape. It is highly unlikely that artifacts will be found in thin gravelly soils, especially in view of the fact that Iceberg Point is one of the few coastal areas of Lopez Island where local people have NOT reported finding projectile points.
We note in closing that while Kwiaht has chiefly studied the vascular plant community and (insofar as possible without excavation) the soils and substrates at Iceberg Point, our team has been vigilant for lithics, fire-cracked rocks, cairns, calcined shells and shell midden over the course of thousands of hours of pedestrian surveys and monitoring, and we have been able to report only a single thin exposure of shell midden (approximately three linear feet) which has subsequently mostly eroded away; although we have located cairns, shell middens, and a pre-Contact defensive trench on neighboring properties. Kwiaht's ecologist has had more than two months of experience excavating Coast Salish sites with professional archaeologists, including the Watmough Bight site (45SJ280) in the San Juan Islands National Monument, and served as a Tribal CRM for several years before working for Kwiaht.
For the foregoing reasons, BLM's justification of a "categorical exclusion" in favor of the proposed CWU field school at Iceberg Point is neither scientifically sound nor consistent with the federal rules currently applicable to Iceberg Point ACEC. Significant, irreversible loss of protected species and habitats is inevitable, as a result of trampling, excavation, structures, importation of weeds and producing some 3,000 square feet of bare earth without the capacity or resources to re-plant immediately and avoid colonization throughout the landscape by weed seeds. Creating approximately 1,000 points for weedy colonization throughout this unique cultural landscape, in which wildflower communities have been shaped by pre-Contact gardening, would be a disaster biologically, and render the protections promised by ACEC and Monument status largely void.
Russel Barsh, Director
May 13, 2017