Inconsistencies in the Bureau of Land Management’s plan for the San Juan Islands National Monument did not go unnoticed by the state’s government. Gov. Jay Inslee responded to the BLM’s Proposed Resource Management Plan/Final Environmental Impact Statement via letter on Jan. 15.

“The San Juan Islands, and the monument therein, are a national treasure and this plan provides an important step in protecting them,” Inslee wrote. “Sites within the monument are priceless to the Tribes who have lived here for thousands of years and to all Washingtonians.”

Bureau of Land Management released its San Juan Islands National Monument Proposed Resource Management Plan and Final Environmental Impact Statement on Nov. 22, 2019, which included the small island off the shore of Eastsound as part of a 274-acre area that could potentially allow camping by permit in the future. The document is available online at https://go.usa.gov/xRphc where you’ll find appendices and a Frequently Asked Questions document.

The 317-page document, along with its 26 appendices, contains management options ranging from no action to a complete shutdown of public access to the entire monument. Also included in the plan are options regarding hiking, boating, hunting and more. Over the last five years, the BLM has worked with islanders to create the RMP/EIS document.

Inslee stated that the plan is “well-considered but is inconsistent” on five topics — dispersed camping; habitat protection; firearms discharge; cultural resources; and climate change.

“It is my hope that, with the proper planning, we can protect these natural and cultural resources for generations to come,” Inslee said.

Dispersed camping

In regards to dispersed camping, Inslee noted inconsistencies throughout the entirety of the camping segment of the document. Dispersed camping is camping anywhere in national lands outside of a designated campground, where there are no toilets, fire pits, trash receptacles or treated water. Currently, 304 acres of the monument is open to dispersed camping. The plan proposed five alternatives including anything from allowing no dispersed camping anywhere in the islands to opening 535 acres of the monument up to dispersed camping.

According to Inslee’s letter, the plan runs into conflict with several federal, state, local or tribal government policies, including the Marine Mammal Protection Act, Washington State Parks San Juan Marine State Park Management Plan, and San Juan County Code.

“While recreation is an important use of public lands, Proclamation 8947 does not identify recreation as an object or value for which the monument was designed,” Inslee said. “The large amount of land designated for Recreation Management areas, as opposed to other classifications, creates many inconsistencies with federal, state, and local government policies plans, and programs.”

Proclamation 8947 was the establishment of the San Juan Islands National Monument by President Barack Obama in 2013.

Because the concept of dispersed camping can cause an excess of human waste and destruction to the natural environment and directly contradicts many of the neighboring lands’ rules and regulations, Inslee proposed that the Bureau of Land Management eliminate dispersed camping in the monument.

Habitat protection

The management document divides the monument into 16 recreational management zones, including two named Category A and B Rocks comprised of a total of 10 acres.

In his letter, Inslee suggested removing both categories from the recreation management areas. He explained that allowing recreational watercraft to land at the rocks puts users at risk for harassment of protected species under the Marine Mammal Protection Act and the Washington Administrative Code. Allowing access could be confusing as there are rocks in the islands which require a 200-yard buffer because they’re part of the National Wildlife Refuge.

Inslee proposed adding language to the plan stating that the BLM will work with the Federal Aviation Administration and U.S. Navy to address the impacts of non-natural noise from planes, jets and drones. He also suggested the plan include requiring written permission for all drone-use in the monument.

Firearms discharge

The plan included a proposal for allowing target shooting within the confines of the monument; Inslee opposed this idea. He noted that there is a likelihood of increased poaching and negative impacts from unorganized target shooting if the practice is allowed in the islands. While he stated the state appreciates the allowance for hunting, Inslee proposed removing target shooting as an allowed use.

“Allowing a wide range of firearms to be discharged during hunting season where hunting implements are purposefully limited creates significant enforcement challenges,” Inslee wrote, adding that San Juan County limits hunting weaponry which limits what firearms could be used in target practice anyway. “… The remote nature of the monument makes firearms enforcement, which is the responsibility of the state and county, quite problematic.”

Cultural resources

The fourth inconsistency Inslee addressed in his letter to the Bureau was the handling of cultural resources. Inslee noted that the management plan is allowing recreational use in areas that have not been properly surveyed for cultural resources, assessed for risk for damage or disturbance nor has it been considered how damage to those resources could be in violation of tribal treaties.

In areas where lands have been properly surveyed, Inslee added, the Bureau lacks staff and resources to reasonably enforce user compliance. He said that the document offered no clear plan for how the department intended to enforce or administrate on the monument lands, and it puts cultural resources at risk.

Inslee proposed the Bureau complete a cultural resource inventory for the monument and that it revise the recreational management areas in accordance with its discoveries. Additionally, he suggested the BLM add an appendix with specific staff requirements to implement each alternative, as has been previously done for other monuments’ management plans.

Climate change

As a monument containing many small rocks and islands, climate change is likely to have a strong impact on the islands. Inslee said that designating dozens of these small islands and rocks as recreation management areas will increase the recreational use of these areas significantly and there hasn’t been an adequate analysis of the users’ safety in relation to sea-level rise.

“More storm swells and large waves that can sweep users away or create sudden drowning hazards are a safety issue to both dispersed camping users and to day users in the monument,” Inslee wrote. He added that it is evident to him the BLM did not consider this when it recommended allowing recreational activities on the small rocks and islands.

In 2019, Inslee explained, The Washington State Parks and Recreation Commission published the Washington State Parks Adaptation Plan to address climate change concerns, which included its three campsites located in the islands. State parks’ plan included incorporating sea-level rise projections into management processes; minimalizing coastal hazards by considering climate change projections when planning infrastructure; and increasing resilience of infrastructure design standards.

The monument’s plan does not address sea-level rise directly, Inslee said, noting that BLM and state parks have a long history of shared management responsibilities and a lack of a climate change plan can cause issues in the partnership into the foreseeable future.

Inslee reiterated his proposal to eliminate dispersed camping and added that the BLM should analyze sea level rise projections in relation to user safety on all the small islands and rocks within the monument and then use that data to adjust the recreation management areas.

“The Bureau is commended for its coordination with state agencies in the creation of this plan,” Inslee wrote. “We look forward to your response to these consistency concerns and to future collaboration in protecting and managing our critical public lands for generations to come.”