Islanders for the
San Juan Islands National Monument
Issues In The Proposed Resource ManagEment Plan (RMP)
We have been studying the Proposed RMP and have concerns that the community should be aware of and may deserve your action.
For example, the photo below, from the BLM Site Catalog, shows Leo Reef, a state listed marine mammal haulout visible from the ferry route. The Proposed RMP would allow public recreation and camping by permit on this reef.
Members of the Monument Advisory Committee and others hosted a Citizens Advisory Meeting in the Lopez Library on December 10. That meeting's minutes can be found here.
the last opportunity for public input before the plan is adopted
There is a "Protest Period" that extends to December 22, 2019. There is also a public comment period on the use of firearms that extends to January 21. In parallel, the Governor's office is conducting a "Consistency Review," with the same January 21 end date. Below you will find information on how to participate in each of these processes.
Why protests are important: Public input should be an integral part of BLM's development of the Resource Management Plan and adoption of the final plan. Throughout a substantial and critical part of this process, the Monument Advisory Committee (MAC) was not allowed to meet and give input to BLM. This happened even though the Proclamation establishing the San Juan Islands National Monument required BLM to consult with the MAC. The public was denied a critical way to present information to BLM. Your protest helps fill this gap, giving a clear narrative to BLM as to the desires of the public for how this monument will be managed for the next 10 to 15 years. Your participation through previous public comments, at BLM scoping meetings, and by giving public comment when the MAC was allowed to have meetings has been important. Your participation is again needed. Although the protest process requires several particular steps, having your voice heard is important to the management of the lands over the next decade.
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The Proposed Resource ManagEment Plan (RMP)
BLM's home page for the proposed RMP includes links to all the documents of the "Proposed Resource Management Plan (RMP)/Final Environmental Impact Statement (EIS)" as well as BLM's official information about filing a protest. We encourage you to read our material below, which includes links to their instructions.
The BLM also published a Frequently Asked Questions document which is worth reading to get an overview of some of the key issues addressed in the RMP.
The BLM published the Proposed RMP/Final EIS as 27 documents (26 of which are appendices, but are vital to understanding the impact of the proposal). For ease of navigation, we've combined those into a single large PDF (904 pages, 112mb), which we suggest you download: Full Proposed RMP/Final EIS with Appendices. To rapidly find something in that document, use the search tool by pressing CTRL+F (Windows) or CMD+F (Mac) and type your search term.
If for reference you would like to review the advice the Islanders prepared on the draft RMP/EIS which came out a year ago, you may find those guides here.
Important note: The BLM published an updated copy of Appendix R on November 27. They made changes on pages 701 and 703 affecting Trinka Rock and Posey Island recreation, partially clarifying contradictions in the original document. It seems clear that both will be open to recreation, with Posey Island continuing to allow designated site camping and Trinka Rock allowing dispersed camping by permit only. We have left our compiled version of the Full Proposed RMP/Final EIS with Appendices reflecting the original November 22 version, which matches the printed version that BLM has made available and gives an online version of what was originally published. We have updated our table of recreation by site to show dispersed camping on Trinka Rock as a Category A Rock. You can find the updated Appendix R on the BLM website.
THE PROTEST PERIOD
Protests can be filed, postmarked by December 21 or using the BLM's online system by end-of-day December 22, by any person who previously participated in the planning process and has an interest that may be adversely affected by the proposed plan. A protest may raise only those issues which were submitted for the record during the planning process. The protest includes a statement of the issue(s) being protested and why the decision in the Proposed RMP/Final EIS is believed to be wrong. An experienced professional tells us that "For the protest to be valid it’s critical to tie the agency’s action to the legal & policy requirements, and clearly articulate why / how they missed the mark. Unfortunately it is not uncommon for the BLM to dismiss the vast majority of protests received (i.e., not make the requested changes in the ROD [Record of Decision]), even if they are valid.... It’s discouraging to see protest points dismissed/denied, but protesting is necessary and worth doing for potential litigation."
Protests may not be submitted by email. Protests may be submitted electronically using the BLM's online system or via mail (postmarked by the close of the protest period). If you are submitting comments electronically, we suggest you compose them on your computer and save them on your computer before using copy/paste to place them in the BLM system or use BLM's tools to upload/attach your document(s). This allows you to keep a copy and avoid problems caused by BLM's system which deletes your work if you take more than 60 minutes to complete their process. BLM's ePlanning system form limits the number of characters, making it difficult to discuss more than one issue per form. You can file multiple forms to discuss multiple issues.
BLM has very specific instructions for filing a protest. We strongly recommend that anyone considering filing a protest review their page on Filing a Plan Protest, their Protest Regulations, and their Critical Items Checklist, each of which is less than one page. If you are serious about making an enforceable protest, you may want to take a look at this example of a BLM Protest Resolution Report.
CRITICAL ITEM CHECKLIST FOR FILING A PROTEST
The following items must be included to constitute a valid protest.
- Name of Resource Management Plan (RMP) or Amendment (RMPA) being protested
- Protester’s Name, Address, and Phone Number
- Your interest in filing this protest (how will you be adversely affected by the approval or amendment of this plan?)
- Issue or issues being protested
- Statement of the part or parts of the plan being protested (including Chapter, Section, Page, and/or Map)
- Attach copies of all documents addressing the issue(s) that were submitted during the planning process by the protesting party, OR an indication of the date the issue(s) were discussed for the record (including dates)
- A concise statement explaining why the State Director’s decision is believed to be wrong.
THE PUBLIC COMMENT PERIOD ON FIREARMS
In accordance with the John D. Dingell, Jr. Conservation, Management, and Recreation Act of 2019, the BLM is offering a 60-day public comment period on a proposed closure of the Monument to shooting outside of hunting seasons established by the Washington State Department of Fish and Wildlife. This restriction will not apply to the use of firearms by Coast Salish tribal members for the purposes of hunting. BLM considers both hunting and target shooting as shooting/discharge of firearms. BLM does not mention target shooting in its FAQ's but does discuss this in the proposed RMP.
If you choose to comment on the firearms elements of the Proposed RMP, we encourage you to also consider submitting a protest by December 22 on the same topic - these are reviewed by different portions of BLM.
As with the comment period last winter, it is important that your comment be substantive - that you explain why your recommendation is the right approach. You should read BLM's guidance on making substantive comments. You can submit comments before or by January 21, 2020, on this topic through the internet, email, or postal mail:
Regular Mail: Lopez Island BLM Office / PO Box 3 / Lopez, WA 98261
Hand Delivery at: Lopez Island BLM Office / 37 Washburn Place / Lopez Island, WA 98261
or Spokane District BLM Office / 1103 N Fancher Rd / Spokane Valley, WA 99212
THE GOVERNOR'S CONSISTENCY REVIEW
Washington's Governor has a specific 60-day opportunity to "ensure consistency with state and local plans, policies, and programs." The Governor's responses on consistency must be resolved before BLM can issue their Record of Decision on the plan.
Islanders for the San Juan Islands National Monument is in touch with the Governor's team. If you can identify any specific areas of inconsistency between the Proposed RMP and any state or local plan, policy, or program, please send an email to info@SanJuanIslandsNM.org and we'll pass those issues on to the Governor's team.
Islanders for the San Juan Islands National Monument is a group of local citizens who care deeply for these lands and work to ensure their care.
Our Monument protects precious sites in the San Juan Islands. These sites, managed by the Bureau of Land Management (BLM), include recreation areas beloved by locals and visitors, cultural sites used by local tribes for thousands of years, historic lighthouses, disappearing habitat, and much more.
More information about the monument can be found on BLM's official website for the monument.