Protect rare bald eagle feeding area & ecologically crucial tidelands in Washington state

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A coalition of concerned residents, naturalists and conservationists urge you to support the preservation of Dabob Bay in Washington state from the proposed development of an invasive aquaculture farm which could involve up to 20 acres of on-bottom flip bags involving up to 120,000 bags attached to lines and staked to the beach with thousands of helical screws, up to 5 acres of clams, covered with predator netting, and up to 20 acres of oysters, with netting covering up to 2 acres of oysters at any one time. The proposal also involves 1-2 boat trips per day during May-June (peak harvest months) when the eagle convocation is present. There have been documented cases of this type of netting impacting juvenile Eagles (among other marine life) in negative ways.

The DNR (Department of natural resources) in conjunction with property owners have worked in tandem with one another to expand and preserve the boundaries of the Dabob Bay Natural Area; which is a rare example of intact salt marsh and sand spit plant communities within one of Washington’s highest functioning coastal spit and tidal wetland systems. The natural area includes mature coastal forests, coastal streams, feeder bluffs, forage fish spawning areas, eelgrass beds, native Olympia oyster beds, nearshore tidelands and mudflats utilized by juvenile salmon and shorebirds, and open marine waters utilized by salmon, marine birds, harbor seals and orcas.  

There is surmountable evidence that development will impact this area in negative and potentially irreversible ways including impacting recognized endangered species and habitats including but not limited to: 

1. Bald eagle feeding grounds, which could be one of the largest seasonal concentration of eagles in Hood Canal, perhaps even the Pacific Northwest. The eagles gather at low tide in the proposed use area and construction of any kind would directly impact this phenomenon. 
2. Impacts to federally threatened summer chum and Chinook salmon. Dabob Bay is a documented habitat for juvenile Hood Canal summer chum salmon and Puget Sound Chinook salmon, both listed as Threatened under the federal Endangered Species Act.
3. Vulnerability of the structures and debris generation. The aquaculture site is vulnerable to winter storms due to the long fetch up Hood Canal and exposure. There is a high likelihood that aquaculture structures will be torn up by storms and generate a large amount of plastic debris drifting onto beaches of Dabob Bay and the larger Hood Canal. The likely increase in plastic waste on the beaches of the area has significant negative cosmetic and environmental impact. 
4. Impact to longshore drift processes and saltmarsh spits.  The largest feeder bluffs in Dabob Bay abuts the proposed aquaculture operation. These feeder bluffs supply sediment that is transported north along the beach in the long shore drift process to build and maintain Long Spit, part of the Dabob Bay Natural Area. Long Spit supports very high quality coastal saltmarsh plant communities, including two globally imperiled plant associations and protection of the coastal spits was the original impetus for establishing the Dabob Bay Natural Area. The proposed aquaculture installations may impact long shore sediment transport processes. 

While both parcels in question were previously leased to Western Oyster Company for aquaculture purposes, the lease was never executed and development never began, which has allowed this area to remain a haven for large numbers of marine life and develop the pristine water environment this area is known for. 

This proposed use of land seems to directly contradict the spirit of the DNR’s (along with property owners, the Nature Conservancy, and others) mission to protect and restore this area.  The information provided in the SEPA checklist and other application materials IS NOT SUFFICIENT to properly evaluate the potential environmental, community, and social impact of this proposal.  We strongly urge Jefferson County, the DNR, and the applicants of the ‘point no point shellfish farm’  to factor in what might be lost in exchange for allowing access and cultivation of this land in this way to anyone and request this land be placed in a permanent conservation trust to preserve this ecologically crucial environment forever. 



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