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Comments on the Fish & Wildlife Service Comprehensive Conservation Plan

Comments from the Prince William Wildflower Society:

February 21, 2011 -- The Virginia Native Plant Society is a non-profit organization with nearly 2,000 members throughout Virginia. VNPS is dedicated to the conservation of Virginia's native plants and habitats so that future generations will be able to appreciate the Commonwealth's rich natural heritage of ecosystems and biodiversity.

On behalf of myself and the Prince William Wildflower Society (PWWS), our local chapter of the Virginia Native Plant Society, I would like to submit the following comments on the Mason Neck/Featherstone National Wildlife Refuge draft Comprehensive Conservation Plan (please note that I presented similar comments at the public hearing held on February 2, 2011 at the Potomac Branch Library in Dale City, Virginia):

I am writing to comment on the Featherstone Refuge Comprehensive Conservation Plan and to express strong support for the immediate opening of the Featherstone National Wildlife Refuge, a component of the Potomac River National Wildlife Refuge Complex. To this end, I support the preferred management Option B for both refuges covered under this CCP, which includes increasing resource management at both refuges and opening Featherstone refuge to the public.

On the issue of potential damage that could be caused by opening Featherstone NWR to the public, I would like to state that based on my 19 years of experience managing public lands in Northern Virginia that even though the refuge is officially closed, it is not really closed, and the people who are going there are making management decisions in the absence of guidance from staff. Since the site is active, it is better to open it to the public and guide the use of the site through appropriate location of trails and types of allowed activities.

The Potomac River NWR Complex staff are doing a very good job managing the three refuges under their care with severely limited resources. I support increasing the staffing for the Potomac River Refuge system from the current six staff to something closer to the sixteen staff that should be at this location based on US Fish and Wildlife Service policy.

I support permanent regular funding for the Potomac River NWR Complex that is not tied to "earmarked" funds. I generally support the future location of a refuge headquarters at Occoquan Bay National Wildlife Refuge, but urge two possible courses of action: 1) First explore consolidating the Mason Neck Elizabeth Hartwell Refuge with the adjacent Virginia Mason Neck State Park and using the state park existing facilities for the refuge headquarters, offices, etc.; and 2) if the headquarters is located at Occoquan Bay NWR, place it either just inside the front gate near the existing building or near the existing public parking lot, but do not destroy habitat on the ridge over Marumsco Creek to build a new facility.

I support the proposal to consolidate the Mason Neck refuge lands by purchasing/transferring the 789 acres in fee from Northern Virginia Regional Park Authority to the US Fish and Wildlife Service. This land is currently under a long-term lease agreement. I suggest exploring a no-payment transfer from NVRPA to USFWS based on the likelihood that the land was originally purchased through The Nature Conservancy with the use of federal funds, and that transfer of the land would fulfill the original intent of preservation.

I and the PWWS strongly urges that the CCP language by expanded to include formal vegetation survey be conducted immediately for both sites but especially for Featherstone NWR for which no plant data currently existing. PWWS is prepared to assist in this process, and has already applied for and obtained a USFWS permit for these surveys for 2011 from Potomac River Refuge System staff. These surveys are critical to better understand the resources on site, make decisions on how to manage them, and guide human activities to avoid impacting sensitive plants and ecosystems.The plant surveys will also supply much needed information on the presence and location of non-native invasive plant species which can harm native plants and greatly reduce the value of the habitat for animal species.

Based on participation of PWWS volunteers in the Featherstone NWR open house in June 2010, we discovered the presence at Featherstone of the Virginia state rare species rare river bulrush (Schoenoplectus fluviatilis,). The bulrush itself was an exciting discovery, but what it represents is the presence of a healthy wetland community type called high-marsh which is very rare in our region. Featherstone also contains other known unique plants including Virginia day flower (Commelina virginica) and pitch pine (Pinus rigida). Virginia dayflower is found in moist soils in forests that have not been highly disturbed. Pitch pine is a very unusual plant because it occurs in the mountains to the west, but was mostly found in forested wetlands called bogs in our region. The presence of pitch pine at Featherstone provides evidence of bogs that were once common in forests near the tidal Potomac River, but were largely wiped out from the 18th through the 20th centuries.

In conjunction with the vegetation inventories, PWWS strongly supports the inventory for and control of non-native invasive plant and other species (emerald ash borer, etc.) on both refuges. PWWS feels that we can assist with the non-native invasive plant inventory process in the course of conduct our vegetative surveys in cooperation with refuge staff.

I support the proposed control of resident Canada geese and urge the US Fish and Wildlife Service to use all available means for this effort over time.

I support management objective 3.1 (listed for Mason Neck Refuge), but urge the following three things: 1) More clearly state that the primary objective is to manage white-tailed deer populations in order to restore and maintain healthy native vegetative communities and the ecosystems they support; 2) Recreational hunting is a secondary but valid management objective for the refuges that helps staff achieve the natural resource management goals; and 3) I support the inclusion of archery but also encourage US Fish and Wildlife Service staff to utilize every means possible to lower the white-tailed deer population to sustainable levels in order to recover native vegetative communities.

The mission of the U.S. Fish and Wildlife Service is "working with others to conserve, protect, and enhance fish, wildlife, plants, and their habitats for the continuing benefit of the American people." I support the proposed management objectives 1.2, 1.3, 2.1 and 2.2 (listed for Mason Neck) which address management of plant communities to achieve primary wildlife management goals. However, I recommend language be added for both refuges addressed under this CCP that specifically calls for the inventory and management of vegetative communities since they form the backbone of the ecosystems and are the foundation for the wildlife species and communities that are priorities for management under this draft plan.

Thank you for the opportunity to comment.


Charles Smith
Prince William Wildflower Society