Don’t build aquaculture in the Dungeness National Wildlife Refuge

This is the letter I mailed today to Washington State Commissioner of Public Lands, Hilary Franz:

From: Michael Maddox
(previously of Poulsbo)

To: Hilary Franz, Commissioner
Office of the Commissioner of Public Lands
MS47001, Olympia, WA  98504-7001
360-902-1000 Email:

CC: Kristin Swenddal
Assistant Division Manager, Aquatics
Washington Department of Natural Resources
360-902-1124 or 360-790-8847 (cell)

Re: Proposal to build an aquaculture facility in the Dungeness National Wildlife Refuge

Dear Commissioner Franz,

The Dungeness National Wildlife Refuge makes a statement. It declares that we in the Salish Sea are working hard to steward Earth and to save species.

The two greatest challenges facing humanity are extinction of species and climate change, and climate change worsens the threat of extinction. Natural habitat is essential to maintaining ecosystems, and each community has its own area of responsibility for sustaining and or recreating natural habitat. Ours is the Salish Sea.

The Dungeness NWR was established to provide habitat for waterfowl and other creatures. Building a monoculture oyster farm on it would destroy the refuge when its existence as a refuge is more essential than ever to sustain species. Dungeness, and places like it, make the statement that we, the smart species, are also wise, and that in inheriting the Earth we also assume responsibility for caring for the Earth. The decisions we make now will determine whether our future is filled with variety-of-life . . . or not.

In our time, many wildlife are at great risk for extinction.

For example, the North American bird population has declined 30% since 1970 (source: Mya Thompson, Cornell Lab of Ornithology, e-announcement, 2 Nov 2019, POC, regarding a study published in the journal Science).

Climate change has markedly increased that risk. In his article “Birds Are Telling Us It’s Time to Take Action on Climate,” David Yarnold, CEO and President of Audubon, says that “Five years ago, [Audubon] published its first report on how North American birds would do during the climate crisis,” which is not well. He explains that the 2019 analysis by Audubon, which is based on even more data and more detailed data, “shows that 389 North American bird species—nearly two-thirds of those studied—are vulnerable to extinction due to climate change.” He then goes on to say that we need to do two things to save birds: (1) protect the places that birds need now and into the future and (2) address the root causes of climate change (pp.12−13).

Dungeness NWR is protecting a place that birds need now and into the future.

Dungeness, like its neighbor to the south, the Klamath Basin, is part of the Pacific Flyway, and they are essential to the success of birds that migrate up and down the coast. Because of heat-caused drought, the lakes in Klamath Basin (as are the farms and towns there) are drying up. An intact, ecosystem-strong Dungeness is needed for the flyway now more than ever. As John Muir said, all things are connected.

Is it possible to eradicate vast numbers of wildlife in a short time through unwise and profit-focused action, or to do so from inaction?

Yes. Buffalo, passenger pigeons, salmon, and the loss of other species on a large scale, bear witness that we can, within a short time, reverse the Genesis intention of ‘Let the waters teem with living creatures, and let birds fly above the earth across the vault of the sky.” (Genesis 1: 20).

Humans can wreak havoc on a biblical scale. In the book Theodore Roosevelt and Bison Restoration on the Great Plains by Keith Aune and Glenn Plumb, “The near extinction of bison by 1890 was the result of multiple factors, including disease, overhunting for commerce and conversion of habitat for agriculture. It seems unfathomable to us in contemporary times, and was initially inconceivable to people of the time, that in a mere forty years, 30 million to 60 million bison would be reduced to only 1,000 by 1889. How could that be? What magnitude of decimation could bring to an end more than twelve thousand years of evolutionary momentum?” (p. 27). The evil deed was done through slaughter, disease, and the substitution of monoculture crops for what had been a vast ocean of a mixed-grass prairie habitat.

And the passenger pigeons? They once numbered in the billions and used to darken the skies for three days at a time. But they were slaughtered, and their habitat was destroyed. Martha, the last passenger pigeon, died in 1914 at the Cincinnati Zoo.

What do bison have to do with the Dungeness NWR?

 The salvation of bison represents a change in mindset. Bison were saved from extinction (there are now 500,000 bison in North American) because we changed our way of thinking in the late 1800s from that of a nation committed to the unthinking use of natural resources for our personal benefit as part of Manifest Destiny (during which time we shoved Native Americans out of the way to get to those resources) to one that, after Americans saw the pictures of piles of dead buffalo on prairies (the prairies themselves were being transformed into farms) converted ourselves to a nation with a conservation mindset. Consequently, we established national refuges, parks, wildernesses, and forests. Later, this mindset and these actions spread around the world. The world’s thinking evolved. Dungeness is part of that learned-by-experience enlightenment. To turn back toward the extinction direction by industrializing the Dungeness refuge would be to darken our future when—in this extinction/climate change time—we desperately need hope. Mass extinction is not melodrama, unfortunately; it’s the real world we live in (see Rachel Nuwer, “Mass Extinctions Are Accelerating, Scientists Report,” Seattle Times, 1 Jun 2020,

What does mass depletion of salmon and extinction of southern resident Orcas mean for us who live in the Salish Sea?

 Others have their part of the world; we have the Salish Sea. Here, we work to conserve orcas, salmon, forage fish, eelgrass, waterfowl, and other species in this mountain- and forest-ringed ecosystem. The Dungeness refuge is part of that effort.

The challenge is tough: Waterfowl, Orcas, and salmon are declining. In the past, people said that there were so many so salmon that you could imagine walking on their backs to cross a river. Today, we can’t image that because salmon in such numbers no longer exist—in large part because the habitat for salmon and forage fish is fading too. As Lorraine Loomis, chairman of the Northwest Indian Fisheries Commission said in this 5 Apr. 2019 North Kitsap Herald article, “More hatchery fish needed,” (p. 5): “Indian and non-Indian salmon harvest has been reduced 80-90 percent in the past four decades. Still, salmon have continued to decline in most places. That’s because all salmon, whether born in a hatchery or not, depend on the same habitat to survive. Unfortunately, that habitat is disappearing faster than it can be restored.”

Billy Frank, Jr. (whose 6-foot poster I had the privilege of seeing at the Smithsonian National Museum of the American Indian in Washington, D.C.) said, “We are losing the battle for salmon recovery in western Washington because salmon habitat is being destroyed faster than it can be restored.” (Billy Frank, “We Need to Win the Battle for Salmon Recovery,”, 9 Feb. 2012, [Note: On 17 Aug. 2021, I could no longer access this link–MRM]

As our population increases, and as the natural shoreline disappears (and part of that disappearance is due to the metastasis of industrial aquaculture along the cleanest and most natural parts of our shoreline), then the creatures disappear too. Ours is a different world than when creatures and habitat were superabundant. For survival, we must think and act wisely.

Yes, Native Americans have treaties to hunt and fish in their usual and accustomed places.

These actions are their legal right as well as part of their cultural and spiritual heritage. And yes, many tribes, including those in the Salish Sea, have been at the forefront of advocating for the environment, and for that we’re grateful. But tribes, as with all peoples, comprise different people and different motivations—some good for the environment, and some bad.

Industrial aquaculture (which produces a luxury food item), casinos, and gas stations are neither cultural nor spiritual; rather, they are commercial means to make a buck. There is nothing wrong with making a buck, but the above means are not special nor are they sacrosanct. Industrial aquaculture is not the nineteenth century definition of hunting and fishing. It’s twenty-first century, technology-amplified exploitation of natural resources, and it deteriorates our environment. Mass production aquaculture, even when done by tribes, must be thrown into the common pot of society’s considerations.

Serious considerations for all people are extinction, climate change, and our future. Those with a treaty right to natural resources have a huge responsibility to protect those resources—and putting 40,000 to 80,000 plastic bags in the middle of a wildlife refuge, and then tearing up the substrate during planting and harvesting, is not responsible.

Dungeness as a refuge is hope that other species and we have a future.

 If we can’t save Dungeness from profit-driven destruction, in this enlightened, educated, conservation-motivated part of the world called the Pacific Northwest, then what hope for anyone is there? Though Dungeness is a small piece of the world, it’s our piece of the world, and how we treat it speaks volumes.

Someone once said, there are other times, but these are ours. We live in climate change/extinction times. We must think and act wisely to survive, and if we presume to assume the mantle of inheritors/stewards of this Earth, then we must work hard to save habitat for other species and for ourselves. We do that locally by working to conserve Dungeness NWR and the Salish Sea . . . or we don’t.

Do preserve the Dungeness National Wildlife Refuge. Please reject the application to build a mass production monoculture oyster farm in the Dungeness National Wildlife Refuge.


Michael Maddox
(Previously of Poulsbo; now trailer traveling around America. I’ll return to the Salish Sea this year.)

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