New concerns over the possible permitting of an oyster aquaculture farm within the Dungeness Spit Wildlife Refuge have been raised by the Department of the Interior, which manages the refuge. In a letter written to Steve Gray, the Clallam County Deputy Director and Planning Manager, Jennifer Brown-Scott, the Project Leader for the Department of the Interior,has raised significant questions about issues concerning the application.
Of concern to the Department are a number of issues relating to wildlife in the refuge.The applicants have asked for permission to place approx. 150,000 of “on bottom” oysters bags on the central west side of the bay, in approximately 34 acres of the tide flats 1141 acres of the the inner spit. This appears to be approx. 3.35% the inner bay area. The applicants propose to raise non-native oysters. To be clear, a significant amount of cultivated oysters in the Salish Sea are non-native, so this is not a surprise.
The area in question was farmed prior to the 1950s, by a series of private owners. In 1953 the first lease was granted and non-native species were introduced. The Jamestown S’Klallam bought the oyster operations in 1990, and continued harvesting oysters until the State closed down the waters due to deteriorating water quality in the bay. The Jamestown have continued leasing the site, 50 acres in size, where this current proposal is located. Since the middle of the last decade,efforts at improving the water quality of the bay continued, with the Jamestown in a lead role, helping to get scientific studies of the water flow and quality done on behalf of themselves and the county. Now the State has upgraded 688 acres to Approved status, allowing the Jamestown to apply for reopening the site to aquaculture. The presence of eelgrass beds in the location reduce it to 34 usable acres.
The Dungeness Bay Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson. The order directs the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” (Jamestown S’Klallam Tribe -Dungeness Bay Bathymetry, Circulation and Fecal Coliform Studies 2003)). The front page of the Refuge web site states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.”
Within the area of the Dungeness Spit Wildlife Refuge are federally listed species that are protected or have environmental listings of concern. They include but aren’t limited to: Bull Trout, Marbled Murrelet, Puget Sound Chinook and Hood Canal Summer Chum. Also within the area is significant state listed wildlife habitat. Of somewhat lesser concern is the impact on the public to the scenic beauty of the wildlife preserve, which is one of the main reasons most visitors go to the area in the first place.
As stated by the Department of Interior letter, “The shores and tidelands in this area provide some of the most important wildlife habitat and supports the highest density of waterfowl and shorebirds within the refuge….These shorelines also support one of the largest Brandt haul out sites in the state of Washington….Shorebird densities are highest within the action area and the adjacent lagoon on Graveyard Spit.”
“Human-caused wildlife disturbance and habitat loss are two of the most pervasive threats to shorebird and waterfowl use of the Salish Sea….very little information is available on entrapment resulting from aquaculture structures.”
The letter also referenced that, “In 2016, a die-off of approximately 1000 Rhinoceros Auklets on Protection Island coincided with a significant reduction in the abundance of sand lance in the Strait of Juan de Fuca.” This reporter, who has been covering the Straits since 2007, was unaware of the scope of the die off in 2016 at Protection Island though a well publicized die off due to starvation was happening from Alaska to California. The extent of the local impact was not widely known and even a search of Google cannot find a specific reference to those numbers referenced in the letter.
While the specific habitat of the Dungeness Spit was not identified as the sole source of the lack of sand lance, the implication that this area is sand lance breeding habitat means that converting its use to aquaculture could continue the downward spiral of shorebirds and their food sources.
Herring also spawn at the west end of Dungeness Harbor and the Department of Interior raised questions about protecting Strait of Juan de Fuca herring, which have been designated “critical” (as in critically low). Sand Lance and Surf Smelt spawning grounds are also found in the area of the application. These species have been identified as “Washington Species of Greatest Conservation Need within the State Wildlife Action Plan (WDFW 2015). A worry related to this is that these spawning fish will be competing with the oysters for plankton. A failure to find enough food could lead to a significant reduction in the survival rates. There is no know mitigation for this, other than limiting the size and scope of the project.
Additionally, Interior pointed out that a 1996 scientific study found that some shorebirds significantly avoided areas used for aquaculture in a California bay.
The area just to the east of the proposed site is the location of the highest infestation of European Green Crabs in the Salish Sea. Another concern is that the proposed oyster bags may provide habitat for green crabs, allowing them to be moved to other areas outside the Spit the bags are transported. The State still does not have a Green Crab management plan.
This shoreline has been designated “Natural” in the Critical Areas Ordinance, as far back as 1976. That designation limits activities to those that preserve the national features unchanged. One would assume that the tidelands are also part of that designation.
An issue not addressed in the application was whether or not mechanized methods such as mechanical leveling and harrowing would be used. The letter said that this was of great concern to the Dept of Interior and it could damage or kill benthic layer animals and vegetation. Placement of these 150,000 oyster bags may also change water flow and nearshore transport of sediment, with unknown consequences. It does not appear that the applicant is going to use these methods.
A further issue that has been the reason for the inner bay to be closed to aquaculture for over a decade is that of fecal coliform (FC) bacteria. While the applicants and the State have worked for decades to identify and remove sources of FC, and current counts allow for shellfish harvest to be done, it is important to note that the applicants themselves have noted in a 2003 report that “wild birds are the second most important source of FC on a year round basis. It is especially important in winter, when their load approaches 1/2 of the measured marine water input.” It would seem to the average person that putting aquaculture into a bird reserve is by it’s very nature going to create a tension between the animals that are present and creating the problem and the desire to harvest.
Studies done by the applicants in 2003 show also that tidal turnover is not ideal in the inner bay. Their finding that states that approximately 45% of the water that leaves the inner harbor returns to the inner harbor. The study states that this “slows the effective flushing of water from the Inner Bay and leads to water quality properties that differ greatly from those observed in the Strait of Juan de Fuca. It is unclear as to whether there has been a more recent study to understand if the effects of 15 years of work have improved on the findings of this earlier study.
The Salish Sea has been used for commercial aquaculture since the founding of the State, but in the last twenty years, with China becoming more middle class, along with a more sophisticated palate here in States, the demands for geoduck and other shellfish have exploded. Much of the lower reaches of the Sound have been converted into aquaculture. The shoreline public has been upset with much of this conversion, with lawsuits against aquaculture being rather routine. The State has never really asked the question of “how much is too much? When do we decide we have leased out enough shoreline to aquaculture?”
There is precedent for this question, in the permitting of bulkheads. At one point the State saw no problem with turning vast amounts of shoreline into concrete. As our understanding of the use of the shore for forage fish and beach creation, among other natural processes, we decided to limit bulkhead conversion and opt to look at natural ways to protect the shoreline from erosion. Some, such as a conversion to natural shoreline was done about 15 years ago just east of the mouth of the Dungeness River, in a subdivision along the shore.
NOAA and other government agencies have studied just enough of the issue to deem aquaculture ‘safe’ yet hold out no significant long term studies of the possible ill effects of the conversion to single species farming. The NOAA science and subsequent scientific studies by Sea Grant, were of limited time frame and called for further study, which does not appear to have been done. In fact, this very location offers a good example of the need to look at what the substrate is like, both at the site, which once was extensively farmed, and the surrounding bottom layers. It should be able to tell us how much recovery could be anticipated if the farm does go in and eventually is removed. It is interesting to note that eel grass is present around the site, but apparently not in the very location of the previous aquaculture operation.
It is certainly reasonable for the applicants to want to return to aquaculture in the Bay, however the scale is being significantly increased. Science has learned a lot about the environment since the time when the State allowed the use in this location. In many other locations we have decided that the trade off of commercial activity is outweighed by a newer appreciation of the value of the natural landscape for a variety of species. It is up to all of us to question our elected officials and bureaucrats, not the applicants, as to why they believe that this is in all our best interests, when we so clearly have set this aside this location for wildlife protection and enhancement.
- If you want to comment on this application, you have until April 27.
- Responses to those comments must be in by May 18.
- The last public hearing will be held June 7 at 1 PM.
Send comments to gballard@co.clallam.wa.us and be sure to ask for an email confirmation of having received your comment. If you don’t get one within 24 hours, call Greg Ballard at 360.565.2616 to ask if he received it.
A final note to consider is from the web site of the Dungeness National Refuge:
Recognizing the importance of the fertile habitats, President Woodrow Wilson established the Dungeness National Wildlife Refuge on January 20, 1915 as a refuge, preserve, and breeding ground for native birds. Today the graceful arch of Dungeness Spit continues to protect nutrient-rich tide-flats for migrating shorebirds in spring and fall; a quiet bay with calm waters for wintering waterfowl; an isolated beach for harbor seals and their pups; and abundant eelgrass beds for young salmon and steelhead nurseries.
Dungeness National Wildlife Refuge is open to the public year-round. Hiking, wildlife viewing, and photography are popular activities on the Refuge. Some portions are closed seasonally or permanently to protect sensitive species. To ensure that wildlife continue to have a peaceful place to rest and feed, certain recreational activities such as swimming, jogging, and other beach activities are allowed only in selected areas during certain times of the year. Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.