PPF Comments on USFWS Reversal on Dungeness Wildlife Refuge Oyster Farm Proposal

October 25, 2019
Robyn Thorson, Regional Director, USFWS, 911 NE 11^th AVE, Portland OR 97232-4181

RE: USFWS Dungeness Refuge
Robyn:
Protect the Peninsula’s Future is writing to express its deep displeasure over the August 6, 2019 communication to the USACE withdrawing the USFWS’s early comments, and essentially placing a gag order on USFWS’s efforts to protect the Dungeness Refuge from an industrial shellfish farm. This site is under USFWS jurisdiction for public trust purposes. For the many citizens that have worked to protect this site over the years, this action has tossed those years of work to the wind. We are deeply disappointed. Instead of protecting the Refuge by instituting the Precautionary Prinicple, the recommendation for the operation to proceed with monitoring is a green light to damage the Refuge

The fact that we do not have available site-specific research on aquaculture impacts to bird species at this site does not indicate there will be no damage. You could have instead asked the Tribe to justify, with hard data, that there has been no impacts by the shellfish industry at other sites. USFWS only need to look to USFWS Pacific Coast refuges in Willapa Bay and Grays Harbor where the information exists. This is well layed out in the 2018 book, Toxic Pearl.

Migrating birds need to be free of pesticides, plastics, human traffic, loss of eel grass, and diminished feeding and resting areas; all necessary to continue their migratory flight. It boggles the mind that USFWS participates in this decimation at other refuge sites, and will add the Dungeness Refuge to that list.

The Jamestown S’Klallam Tribe does not need this site to grow shellfish. It is industrializing other Clallam and Jefferson County sites.

We include, herein, the recent federal court decision denying the shellfish industry and the USACE their attempts to ignore the damages of this industry. The USACE admitted to potential impacts.

See: United States District Court Western District of Washington at Seattle, Case No. C16-0950RSL
https://documentcloud.adobe.com/link/track?uri=urn%3Aaaid%3Ascds%3AUS%3A4c98d5a3-d4f4-4e68-9aa2-9d595dbfb6f0

By USFWS’s action, it is ceding its responsibilities to the local district USACE, Ecology and Clallam County to protect the Refuge, shirking its responsibility and disserving the public’s trust. If, as USFWS says in the final paragraph, USFWS is committed to assisting with finding the least resource-disturbing approach to this potential use, then rescind the August letter and disapprove of that use.

Protect the Peninsula’s Future is a federally recognized nonprofit that formed nearly a half-century-ago to protect the natural resources on the North Olympic Peninsula.

Signed,
Steve Koehler, Protect the Peninsula’s Future President
Cc:     Pam Sanguinetti, USACE   Seattle WA
USFWS Office in D.C