Issues with Proposed RMP

This pages is an archived copy of guidance prepared for the protest period associated with the Proposed Final RMP/EIS that was released in late 2019. This protest period is long past, though this page may make it seem ongoing.

Each person or group will have their own set of issues with the Proposed RMP. Use this page as a sampling of topics to consider. If you consider a protest, be sure to follow the steps necessary to ensure your protest is valid and submitted properly.

We have compiled a detailed summary of RMP issues that goes into detail on the topics listed on this page. We encourage you to refer to it, as it gives a few of the specific references that may be helpful or necessary in creating a valid protest, as a simple statement of disagreement will not be accepted as a valid protest. The detailed summary provides more information here. If you find errors in that summary, please email

We encourage you to, as we did, read key sections of the Proposed RMP/Final EIS and search for specific topics by pressing CTRL+F (Windows) or CMD+F (Mac) and typing your search term. When searching by topic, it is easy to become confused as you must be certain to read the Proposed RMP sections and not references to that topic in various other alternatives as this protest period is focused on the Proposed RMP.

Public Access to Sensitive Sites like small rocks and Reefs

The Proposed RMP allows public access on 55 of the Monument's 65 sites, including many small rocks and reefs and 10 state-designated marine mammal haulouts. This is discussed in our detailed summary of RMP issues.

Dispersed Camping ON over 70% of monument sites

The Proposed RMP would allow dispersed camping by permit on all 55 sites that allow public access, except for the four former ACEC sites on South Lopez (Iceberg Point, Chadwick Hill, Point Colville, Watmough Bay), and the three State-Parks-Managed camping sites (Patos Island, Posey Island, Blind Island). Dispersed camping by permit would be allowed on all sites in the “Category A” and “Category B” (more sensitive) rock groups, including marine mammal haulouts, and including locations of 8 recorded cultural sites (p. 39). Other notable sites that the Proposed RMP would open to dispersed camping by permit include Cattle Point, Indian Island, Kellett Bluff, Skull Island, Victim Island, Cape St Mary, and Turn Point. This is discussed in our detailed summary of RMP issues.

Monument Advisory Committee (MAC) Engagement

Though the BLM is required by Presidential Proclamation (p. 507) and Federal Statute (43 CFR Chapter II, 1610.3-1) to consult the Monument Advisory Committee (MAC) in developing the plan, that has largely been blocked for nearly three years by BLM action (a moratorium on meetings for many months in 2017) and inaction (not making appointments to positions as MAC terms ended, leaving the MAC below the quorum needed to meet). The BLM created the Draft EIS and the preferred alternative, managed the public comment period, received the comments and prepared the Proposed RMP without MAC input. This is discussed in our detailed summary of RMP issues.

Hunting and Target Shooting Throughout the Monument

The Proposed RMP would allow use of firearms and bow hunting during state-designated hunting seasons except in the three designated campgrounds. This includes allowing target shooting during hunting seasons. While the state excludes high-powered rifles in hunting (p. 810), the Proposed RMP does not place such limits on target shooting. Target shooting is not allowed on any other public lands in San Juan County (p. 173). This is discussed in our detailed summary of RMP issues.

Protests can be made with regard to this topic, and you can also submit a comment during the separate public comment period on shooting. Protests must be filed by December 23, 2019 in accordance with these guidelines and to this address. If you are concerned with this topic, we suggest you both file a protest and submit a comment.

The separate comment period for shooting ends on January 21, 2020. You can submit comments 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

Contradictions In The RMP

This Proposed MP will guide Monument management for 15-20 years. But it contains contradictions and internal inconsistencies that make it hard to discern the BLM's intent and will hinder its use as a governing document. For example Posey Island and LIttle Patos Island are listed as both allowing and not allowing camping, depending on the page you read. Our detailed summary of RMP issues lists over 20 such issues in the document.

Wildfire Risk

BLM states that its policy, rather than planning decisions, dictates the majority of the BLM’s wildfire response process (p.23). But in the Proposed RMP there are planning decisions which impact wildfire risk and thus the wildfire response. BLM’s proposed plan does not ban open flames (except to restrict campfires to metal rings at campsites on Patos/Posey/Blind Islands) and allows camp stoves to be used with dispersed camping permits. Prescribed fire, target shooting, hard to access sites, and nearby homes are other subjects that make wildfire risk a key topic. This is discussed in our detailed summary of RMP issues.

Wilderness Characteristics

There are 23 sites judged to have “Wilderness Characteristics” but BLM proposes not to manage for those characteristics. They state that is because “these characteristics are likely to persist for the life of the plan without specific management direction” (p. 23). This seems an inadequate way of managing an important and vulnerable feature of the sites. The Proposed RMP does not consider various actions that could be taken to minimize impacts to wilderness characteristics. Managing for wilderness characteristics is consistent with nearby San Juan Islands National Wildlife Refuge sites and would help to prevent visitor confusion as to what regulations apply to nearly indistinguishable sites. This is discussed in our detailed summary of RMP issues.

Vegetation Management, Visual Resource Management, Group Size Limits, and More

If you have read this far down the page, you care about the management of these lands. Please read our detailed summary of RMP issues for more information on these topics and some other topics to consider.