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Friends of Dungeness NWR Logo

Friends of Dungeness National Wildlife Refuge
715 Holgerson Rd., Sequim, WA 98382

Commercial Oyster Farm Proposed Within Refuge

Aquaculture Project Information
Read documents about the proposed oyster farm here.

The Clallam County Hearing Examiner issued his final decision of approval on the proposal on January 10, 2020. You can read the decision here.

August 2023 Update
Three environmental groups are suing US Department of the Interior for not protecting Dungeness National Wildlife Refuge from industrial aquaculture activity. Read more here.

December 2022 Update
US Fish and Wildlife Service has released a statement:
No further approvals are needed from the U.S. Fish and Wildlife Service for the Jamestown S’Klallam Tribe to resume aquaculture operation on the state leased portion of Dungeness National Wildlife Refuge. There are existing permits and leases with county, state and federal approvals that govern the project.

The U.S. Fish and Wildlife Service takes Tribal treaty rights and sovereignty seriously and is committed to continuing to work with Tribal partners.

January 2022 Update
Clallam County Department of Community Development (CCDCD) has obtained an independent third-party review to address the monitoring of shorebirds and waterfowl and the scientific approach that will be taken toward monitoring of impacts of the proposed Jamestown S’Klallam Tribe commercial oyster farm within the Dungeness National Wildlife Refuge (application NWS-2007-1213) in Sequim, Washington. The monitoring of impact will be an important process in the CCDCD decision to allow expansion of bagged oyster cultivation from the planned initial 5 acres in Phase 1 to the entire 50 acre site (80,000 bags planned).

See below for some concerns regarding the impact of the proposed commercial shellfish operation.

The independent review is available here on the CCDCD website.

Six key points of concern about the proposed monitoring plan:

1) Need for baseline as well as impact assessments
2) Decrease light disturbance at night
3) Special techniques needed to assess bird disturbance at night, when most work will be done during low tides in winter (infrared?)
4) Observer training validation
5) Valid data analysis
6) Interim analyses, not only at 1 year

September 2021 Update
In July 2021 Washington State Department of Natural Resources approved a land lease for the proposed oyster farm, within the Dungeness National Wildlife Refuge. Obtaining this lease was one of the final hurdles in the approval process.

While operations are expected to begin in October 2021, there are two issues remaining that will need to be resolved: access and monitoring.

When the Clallam County Hearing Examiner gave his approval, it was contingent upon establishing a monitoring plan to evaluate the farming impacts on wildlife. A plan is currently under development, but monitoring human impact on wildlife is very complex. Monitoring itself can cause a disturbance to wildlife.

Accessing the farm location will require approval. Located in an area of the Refuge that is closed to humans from October 1–May 14 means US Fish & Wildlife will need to determine if this economic use is compatible to permit entry to the closed area.

Refuge staff began conducting a determination of compatibility to decide if the aquaculture use is compatible with Refuge goals.

Concerns about the proposed oyster farm location
• The Refuge was established in 1915 by President Woodrow Wilson to protect wildlife. It was not established to conduct commercial aquaculture operations. If allowed, what precedent might this set for the future?

• The proposed location is regarded as a high use area for waterfowl and shorebirds, especially for winter foraging.

• The level of proposed activity in this location would likely present a significant disturbance to wildlife.

• The proposed location could negatively impact the view and experience of the 100,000 annual Refuge visitors with the visual pollution of up to 80,000 plastic mesh bags, and boats and workers in the area.

• Plastic debris from the mesh bags is a concern. Wildlife could potentially get trapped in the mesh or ingest the plastic debris as it breaks down.

• Bags anchored to the ground could prevent new growth of native eelgrass and may disrupt natural habitat on the seabed, reducing foraging areas. Areas near the proposed site have eelgrass, which provides habitat for forage fish and shellfish. The forage fish provide food for salmon, and they become food for Orca. Will the proposed location disrupt eelgrass growth and the food chain?

• Noise pollution from workers, boats, and equipment may scare wildlife, causing wildlife health issues, or abandonment of the site. Noise may also disturb Refuge visitors and neighbors on the bay.

Additional Information
Boat access to this area of the Refuge is not allowed from October 1 to May 14, a regulation that protects the vulnerable wildlife that use this Refuge in winter. Disturbance, including lights, noise, human presence, boats and substrate disturbance can be anticipated from a commercial shellfish aquaculture operation, and these activities are in conflict with the purpose of the Refuge.

Dungeness Bay has some of the largest eelgrass beds in the Northwest. The eelgrass and associated fauna support regionally significant populations of Brant, diving ducks, seabirds, loons, grebes, and other diving birds. This increasingly rare habitat of Dungeness Bay is especially important to Pacific Black Brant (Branta bernicla), a sea goose of the Pacific Flyway, which nests in the Arctic and uses Dungeness Bay for wintering and migration staging. The Pacific Flyway Management Plan for Brant protects critical habitat, including pursuing mitigation (avoidance, minimization, and compensatory mitigation) for loss or degradation of eelgrass beds, grit sites, and loafing sites. This international management plan for the pacific population of Brant includes Russia, Mexico, Japan, the US Fish and Wildlife Service, and the Canadian Wildlife Service.

The number of Brant in Dungeness Bay has been correlated to eelgrass area in a 7-year study (1986-1993) (Wilson and Atkinson, 1995). Eelgrass surveyed in 2018 in Dungeness Bay shows large eelgrass beds in the southwest corner contiguous to the proposed commercial aquaculture area. Eelgrass is also present in the 16 of the 50 acres of the area, so it would be expected to also find foraging Brant in these areas. Brant have not been found to avoid aquaculture plots, but are less common at low tides with exposed gear (Harvey, 2018). Brant forage and roost in Dungeness Bay, and also consume grit at shoreline to aid in digestion. An average of 1,500 Brant winter in Dungeness Bay from October to February, with 1,596 reported in winter 2018 (USFWS 2018), (Wilson and Atkinson, 1995). Numbers increase during March with annual peak during April migration of 4,000 (Wilson and Atkinson 1995). Eelgrass is the mainstay of their highly specialized diet (Ward et al, 2005). Due to their short necks and foraging style, eelgrass is not available to them during high tide, when they have been observed waiting over favored eel grass beds (Moore and Black, 2006).

Flushing behavior in Brant is associated with exposure to boats, noise and proximal human activity. Extensive research has been performed to study Brant response to disturbance in Humboldt Bay, a similar ecosystem to Dungeness Bay with eelgrass used by wintering and migrating Brant, with a National Wildlife Refuge protecting a significant portion of the bay. High levels of disturbance to Brant were noted from clamming activity (Henry, 1980). The majority of Brant disturbances were from boats: small boats under 23 feet (27%), people (22%), and large boats (21%) (Schmidt 1999).

Routine disturbance will force individuals to move their foraging efforts to more marginal feeding areas, e.g., less healthy eelgrass beds, areas where they may be more susceptible to predation, or in regions where water depth gives less time to feed in waters shallow enough for them to feed. The mosaic of habitat is critical in Dungeness Bay. How far will disturbed birds go and when (at what human activity threshold) will they simply leave for another area, one that is likely to be less optimal than Dungeness Bay? Disturbance and flushing behavior in Brant decrease their foraging, resting and gritting time. Reduced foraging time and increased flight time deplete energy reserves of Brant (Ward et al, 1994), especially in the spring when it impacts their migratory and breeding success (Henry, 1980, Lewis et al 2013, Ward et al 2005). Brant increase their eelgrass intake in spring to build up important energy reserves for migration and breeding success in the summer (Wilson and Atkinson, 1995). Longer migratory stopover duration and slower mass gain may occur with even relatively small levels (10%) of disturbance (Stillman, 2015).

Human activity may damage the habitat and disrupt the birds’ ability to survive in the area. Phase 1 of the Dungeness Bay commercial aquaculture project proposes to use boats with hydraulic lifts, for an estimated 2– 6 round trips per month (estimated at one per week), lasting up to 6 hours each. The boats will need to traverse Dungeness Bay from public dock sites to the aquaculture site. In Dungeness Bay, low tides consistent with aquaculture work occur at night in the winter, and lights will be needed both by the boats and the estimated 3–15 workers.

The proposed commercial cultivation methods include 29 acres of on-bottom oyster aquaculture in Phase 1, in addition to 5 acres of bagged oysters and beach harvest of mature oysters. The decision to limit the oyster aquaculture project initially to 5 acres of on-bottom bags was made due to likely negative environmental impact findings. From the Mitigated Determination of Non-Significance issued 10/31/19: “The proposal is located within the Dungeness National Wildlife Refuge, which is an important area utilized by migratory birds, waterfowl geese and shorebirds. The following impact could still result in a probable significant adverse impact if not mitigated 1) Potential impact to marine plants and animals from the operation 2) Potential impacts to the Dungeness National Wildlife Refuge. A Mitigation and Monitoring Plan (Exhibit 89 B1.8) was submitted by the proponents. The rationale for the plan states “the most pressing concerns are to Refuge wildlife, particularly migratory birds, and the surrounding habitat as follows: 1) Potential disturbance to the Brant foraging and lofting (sic) habitat 2) Potential disturbance to shorebirds – namely Dunlin 3) Potential impact to eelgrass habitat 4) Potential impact to forage fish spawning habitat 5) Plastic debris from farming activities.”

Careful scientific monitoring of the proposed 5 acre bagged oyster project would be necessary, since this method of aquaculture is new to the Dungeness Bay. Bagged oysters require human intervention to avoid sedimentation. They must be flipped routinely. This adds an element of human disturbance to the Refuge that was not seen in previous on-substrate oyster cultivation. The frequency of oyster bag flipping will depend on sedimentation rate, but with an eventual plan of 80,000 bags of oysters, this presence could be calamitous.

During spring migration alone, Warnock and Bishop (1998) estimate 15,000-20,000 shorebirds use the Dungeness National Wildlife Refuge. Dungeness Bay is recognized as an area of Western Hemisphere Shorebird Reserve Network site of Regional Importance by the North Pacific Coast Regional Shorebird Management Plan (Drut and Buchanan, 2000).

Dungeness Bay is so noteworthy that it has received the Audubon designation “Important Bird Area,” identified as being significant habitat for the conservation of bird populations. Located on the north shore of the Olympic Peninsula, this site includes intertidal and subtidal waters of Dungeness Bay, Dungeness Spit, the Dungeness River estuary, and adjacent wetlands. It comprises extensive sandflats and mudflats; some of the largest eelgrass beds in the Northwest; and a network of spits, sandbars, and small islands. Adjacent coastal wetlands contain fresh water and estuarine marshes and ponds maintained by a seasonally high-water table. Dungeness Spit and adjacent intertidal areas lie within the Dungeness National Wildlife Refuge. Dungeness Bay, one of the premier estuaries in the Pacific Northwest, is used by tens of thousands of shorebirds, gulls, and waterfowl during migration and winter. Its sandflats and mudflats provide extensive feeding areas for shorebirds. Over 40 species of shorebirds have been recorded in and around Dungeness Bay, and two nest there: Killdeer, and Black Oystercatcher. Some of the most abundant migrant shorebird species -- Black-bellied Plover, Dunlin, and Sanderling -- also remain in Dungeness Bay through the winter. Subtidal eelgrass beds and associated fauna support significant populations of Brant, diving ducks, seabirds, loons, grebes, and other diving birds.



Drut M and Buchanan JB. 2000. US Shorebird conservation plan: Northern Pacific Coast regional shorebird management plan. US Fish and Wildlife Service, Portland OR. 31 pages.

Harvey HT and Associates (HTHH). 2018. Draft black brant monitoring plan :baseline assessment annual report 2018. Prepared for the California Coastal Commission October 6, 2018.

Henry WG. 1980. Populations and Behavior of Black Brant at Humbolt Bay, California. Thesis, Humbolt State University, Arcata, California.

Lewis TL et al. Brant (Brants Bernicia), version 2.0 in The Birds Of North America (A.F. Poole, Editor) Cornell Lab of Ornithology, Ithaca NY, USA

Moore JE and Black JM. 2006. Slave to the tides: Spatiotemporal foraging dynamics of spring staging black brant. Condor 108:661-677.

Pacific Flyway Management Plan for the Pacific Population of Brant, updated October 11, 2019

Schmidt, PE. 1999. Population counts, time budgets, and disturbance factors of black brant at Humbolt Bay, California. Thesis. Humbolt State University, Arcata, California.

Stillman RA et al. 2015. Predicting effects of environmental change. On a migratory herbivore. Ecosphere 6(7):1-19.

USFWS Maritime National Wildlife Refuge Complex. 2018. Letter and attachments from Jennifer Brown-Scott to Steve Gray providing comments on SEP 2017-00027 dated April 4, 2018.

Ward DH et al. 1994. Response of staging brant to disturbance at the Izembek Lagoon, Alaska. Wildlife Society Bulletin 22:220-228.

Ward DH, et al. 2005. North American brant: Effects of changes in habitat and climate on population dynamics. Global Change Biology 11(6), 869-880.

Warnock ND and Bishop MA. 1998. Spring stopover ecology of migrant western sandpipers. Condor 100:456-467.

Wilson UW and Atkinson JR. 1995. Black brant and spring-staging use at two Washington coastal areas in relation to eelgrass abundance, Condor 97:91-98.