ACTION item: Stopping the industrialization of the Dungeness Wildlife Refuge

Time after time, citizens have had to sue the U.S. Fish and Wildlife Service (USFWS) for failing to protect the animals and their habitat as required by law, in areas that the nation has recognized as critical to preserve as habitat and for public recreation. Now USFWS is willing to allow, for private profit, the industrialization of refuge lands for shellfish operations. 

 

>>Tell the U.S. Fish and Wildlife Service and U.S. Secretary of Interior Deb Haaland that the Dungeness National Wildlife Refuge lease for industrial aquaculture must be rescinded.

 

In spite of demonstrated harm to birds, salmon, forage fish, and shellfish, and a recommendation by the National Marine Fisheries Service that “an alternative site be identified in a location that results in less potential impacts to wildlife that is more appropriate for aquaculture and meets the goals of the tribe,” USFWS approved a lease for an industrial oyster farm inside the Dungeness National Wildlife Refuge. This decision, which is in violation of the Clean Water Act and the Migratory Bird Treaty Act, must be reversed. 

 

In the words written of an October 2022 USFWS internal memorandum, “Forgoing a compatibility determination in order to facilitate incompatible commercial activities by any entity would be a subversion of the fundamental requirements in the [USFWS] Improvement Act.” 

 

We are targeting the most recent case of the USFWS’s permissiveness in one of the country’s most pristine nature lands, the Dungeness National Wildlife Refuge in the small rural town of Sequim Washington, just below the Olympic National Park. In this case, the shellfish corporation raises shellfish on other sites. They do not need to operate in a national refuge and deny wildlife their feeding and breeding grounds. 

 

The Dungeness National Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing 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.” The front page of the Refuge website 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.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture.  

 

Industrial shellfish aquaculture is known to reduce or eliminate eelgrass with the use of pesticides. Shellfish aquaculture also involves large-scale use of plastics—PVC tubes and plastic netting—that are hazardous to marine organisms and can trap and entangle wildlife. Commercial shellfish aquaculture is a major industry in Washington state that has significant impacts on the nearshore marine environments, which provide essential habitat for many species, including invertebrates, fish (including herring and salmon), and birds (migratory and shorebirds). 

 

Among the negative impacts of this project are: 50% reduction in bird primary feeding grounds; plastic oyster bags that exclude the probing shorebird flocks from feeding deeply into the substrate, entrap fish and birds, add macro- and micro-plastic bits to the sediment throughout the refuge, and shift the benthic community composition; diminishing of the ecological benefits provided by eelgrass to threatened fish and birds, such as nourishment and cover from predators; and increased algal blooms that will leave a graveyard of dead oysters. These detrimental effects to the Dungeness National Wildlife Refuge are NOT minimal. Decisionmakers should not place financial benefits to the corporation above the long-term and cumulative impacts to the refuge. Half of the world’s 10,000-odd bird species are in decline. One in eight faces the threat of extinction. 2.9 billion breeding adult birds have been lost from the United States and Canada in only 50 years. 

 

Let’s raise our national voice and try and stop this refuge destruction with public persuasion. This is a public space we pay to protect. For more information, check out the Daily News post from last August, “Groups Sue U.S. Interior Department to Protect the Dungeness National Wildlife Refuge from Industrial Aquaculture.” 

 

This action follows a lawsuit filed by three environmental organizations against the U.S. Department of Interior for failing to protect the Dungeness National Wildlife Refuge from industrial aquaculture. The groups, including Protect the Peninsula’s Future, Coalition to Protect Puget Sound Habitat, and Beyond Pesticides, filed their complaint in the U.S. Western District Court of Washington State. The complaint states that the U.S. Fish and Wildlife Service (USFWS), U.S. Department of Interior, must “take action that is required by the Refuge Improvement Act and conduct a compatibility determination and require a special use permit for a proposed industrial aquaculture use” that will abut and impact the Refuge. The plaintiffs are represented by the Seattle, WA law firm of Bricklin and Newman LLP. 

 

>>Tell the U.S. Fish and Wildlife Service and U.S. Secretary of Interior Deb Haaland that the Dungeness National Wildlife Refuge lease for industrial aquaculture must be rescinded.

 

We are focusing this Action against the U.S. Environmental Protection Agency and the U.S. Secretary of State.  

 

Thank you for your active participation and engagement!

 

Please take this ACTION and circulate it to your family, friends and colleagues.

https://secure.everyaction.com/WMJxQmNjDUqarx4FmLzUrA2

also, to support the lawsuit, you can send checks to:

Send a check to: PPF, POBox 421, Sequim WA 98382 or through PayPal: https://www.protectpeninsulasfuture.org/donate/

        PPF is a federal recognized 501c3 non-profit.

Jamestown S’Klallam proceeding with Dungeness Spit Aquaculture Permit

Clallam County Department of Community Development has published that the Jamestown S’Klallam have applied to restart their permit application for an aquaculture permit inside the Dungeness Spit Wildlife Refuge. This highly controversial application has drawn criticism from the Refuge manager, in a detailed response to the previous application. (See below) Critics of the application have stated that any non Tribal organization wishing to seek to establish this kind of operation within a refuge would run into serious opposition from conservation organizations, and likely Tribes as well,  but due to this being put forward by the Tribe, criticism has been muted.  It will  be interesting to see how this plays out. With shorebird populations in decline, especially those using Protection Island and feeding underwater in this very location, it’s hard to understand how this will be allowed.  Then there is the growing problems of ocean acidification and the European Green Crab invading not far to the west of this spot. Could the State perhaps offer a trade off of shoreline to protect the Refuge?

DCD have tentatively scheduled the Public Hearing before the Clallam County Hearing Examiner for this matter for Thursday November 21, 2019 at 1 p.m..

More can be found at

http://websrv2.clallam.net/tm_bin/tmw_cmd.pl?tmw_cmd=StatusViewCase&shl_caseno=SHR2017-00011&projectcasetag=Y

Also this web site has published the letter of concern from the Refuge Manager.

https://olyopen.com/2018/04/10/concerns-raised-over-dungeness-spit-oyster-farm-application/

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 Jamestown S’Klallam Tribe (JST) wants to proceed with the application after the Government to Government meeting with U.S. Fish & Wildlife (USFW). In a letter dated August 6, 2019

U.S.F.W rescinded their previous letter dated May 22, 2019 (See item B1.83 & B2.1 below for more information).

DCD will be providing notice and a SEPA threshold determination in the next couple of weeks.

We have tentatively scheduled the Public Hearing before the Clallam County Hearing Examiner for this matter for Thursday November 21, 2019 at 1 p.m..

 

 

Salmon Coalition celebrates decade-long project – PDN

While I miss the old 3 Crabs Restaurant, the recovery of the estuary of the Dungeness is far more important. In addition to NOSC, we should be aware that the Jamestown S’Klallam Tribe along with the Dungeness River Managment Team has been extremely important to project management and stakeholder buy in.

For a good overview of the restoration issues with the Dungeness River, you can also view the 15 minute film I made with the Jamestown S’Klallam, the DRMT and others back in 2013. It will give you a good overview of the entirety of the project, along with a number of the people responsible for it’s restoration.

The North Olympic Salmon Coalition honored 10 years of work and partnerships made along the way in its 3 Crabs nearshore and estuarine restoration project at a ribbon-cutting ceremony at the estuary off 3 Crabs Road earlier this month…. This restoration project is one of many NOSC has implemented in areas throughout the Olympic Peninsula. It was made possible by 29 stakeholders and supporters involved in the project. Erin Hawkins reports. (Peninsula Daily News)

Salmon Coalition celebrates decade-long project

Concerns raised over Dungeness Spit oyster farm application

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.

 

 

 

 

Seasonal hunt ends; after finding 96 green crabs, trapping to resume in April – Skagit Valley Herald/PDN

News from the invasive front.

The hunt in Dungeness for the invasive European green crab is over for the season. Resource managers report that since April, they’ve caught 96 green crabs on the Dungeness Spit and one in Sequim Bay. Lorenz Sollmann, deputy project leader at the Washington Maritime National Wildlife Refuge, said researchers opted to extend the search for green crab after finding a few more of the invasive species, but in their last few days of trapping Oct. 16-18, no green crabs were caught. Matthew Nash reports. (Peninsula Daily News) See also: Group finds more invasive green crabs over summerhttps://www.goskagit.com/news/group-finds-more-invasive-green-crabs-over-summer/article_ad3d3afd-aae4-5b3a-b052-2973bc14c945.html Kimberly Cauvel reports. (Skagit Valley Herald)

http://www.peninsuladailynews.com/news/seasonal-hunt-ends-after-finding-96-green-crabs-trapping-to-resume-in-april/

Invasive Green Crabs found in Dungeness Refuge

This just in. The finding of these crabs in Dungeness  changes everything. This is a very real threat to our marine life as well as our sewer system outfalls, among other things. Those of us in the Marine Resources Committees and the county people, have known that green crabs were found randomly in isolated numbers west along the Canadian coast, and there have been limited findings of them at a few places around the north Sound. With this discovery though it means there is no turning back and stopping them is going to be very problematic, if it’s even possible. One crab can eat up to 45 clams a day and they reproduce worse than bunny rabbits or rats.

According to the USDA:

Impact: Preys on bivalves and other crustaceans, such as soft-shell clams and scallops (Grosholz and Ruiz 2002)

Heads up that 12 European green crab have been caught so far since last week at the Dungeness National Wildlife Refuge. We have been working with USFWS and WA Sea Grant to support a limited rapid response and planning on setting up a stakeholder meeting in the next couple weeks to discuss implications and options. We’ve been in contact with Kelly Toy of Jamestown S’Klallam Tribe.

Allen Pleus
WDFW AIS and BW Unit Lead
(360) 902-2724 office
Allen.Pleus@dfw.wa.gov<mailto:Allen.Pleus@dfw.wa.gov>

Here is a fun short video about them.

Feasibility study addresses Dungeness/3 Crabs-area pollution – PDN

This actually seems to be a reasonable alternative. The recommendation is to enforce current laws, raise the local money to pay for regular inspection, which as I have heard, is not happening currently, and monitor to see whether the problems improve. Rushing to judgement on putting in a huge infrastructure project, even if it’s eventually found to be the right solution, seems premature. Let’s make sure the existing laws work, before abandoning them.

Clallam County should strengthen an existing program to operate and maintain individual on-site septic systems in the Dungeness/3 Crabs area, a new study concludes. Staying the course was one of four alternatives being considered in a feasibility study for wastewater management in an unincorporated area where failing septic systems were said to be polluting Dungeness Bay with fecal coliform and nitrogen. Damon McAlister, a senior engineer with Parametrix, and county Environmental Health Director Andy Brastad presented the final study to the Clallam County commissioners Tuesday. Rob Ollikainen reports.

Feasibility study addresses Dungeness/3 Crabs-area pollution http://peninsuladailynews.com/article/20130731/NEWS/307319994/feasibility-study-addresses-dungeness-3-crabs-area-pollution

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Dungeness and Three Crabs Septic issues plan put forward

Progress is being made on coming up with alternatives for fixing the ongoing coliform bacteria problems at Dungeness Bay. Given that this spectacular shellfish area is generally prohibited from being harvested due to the pollution, fixing this problem would not only bring scenic but economic benefits.

The latest on it at the PDN:

http://peninsuladailynews.com/article/20130211/news/302119993/officials-outline-dungeness-septic-options-costs

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