Artificial Reefs and the DNR

[Gooch]

Folks,

I know there has been a lot of previous discussion about why we don't have large artificial reefs (in the form of large ships, cleaned and placed carefully) here in Washington. People interested in looking at the past discussions can refer to those threads with a search if they want to see what has already been talked about. I will just say there are pros and cons on both sides of that discussion.

The main sticking point seems to be "permission" from the government entities that would allow that sort of activity. Mike Racine and others with WSA have worked hard to try to move in that direction for a long time but with no definitive answers yet.

Frustrated, I sent the Department of Natural Resources commissioner a letter that detailed why, in my humble opinion, this kind of activity could be good for the state in a lot of ways. I posted a copy of the letter I sent on a blog site I help write for; you can view it below if you like.

http://nwdivers.me/blog/?p=67

There was no response for a long time so I just figured it went into round file up there. But I was pleasantly pleased to see a letter from Mr. Peter Goldmark (DNR commish) in my mail box recently.

In a nutshell, this is what he said:

1: The DNR has created reefs (with mostly natural materials) in the past, primarily to help with sport fishing fish populations. In 2000, they reassessed how those reefs were doing and decided that there was really no empirical evidence that the reefs were helping populations and no "official" long term monitoring setup to show that the targeted fish populations (mostly rockfish in these cases) had been enhanced. So activity on reef-building was stopped.

2: The legislature in 2006 looked into the sinking of a ship for divers and authorized a USGS study for doing that.(That study is available online to read). The study recommended a larger, more comprehensive, and more expensive feasibility study be done. No further work was done due to the cost projected for the next study.

3: He allowed that some states do allow the sinking of ships but suggested that fully cleaning a ship of hazardous materials was difficult and expensive. In his writing, I felt like he was suggesting that fully cleaning a ship was really almost impossible and would almost inevitability lead to some kind of pollution; something that his very agency is tasked with preventing. He also pointed to their Derelict Vessel Removal Program that has been nationally recognized. I feel that is a good program as well but it didn't do a great job with the liberty ship that fell apart over the years and leaked oil a stones throw from where I'm writing this.

4: All of that said, he did say that his agency WILL consider artificial reef proposals that fill a habitat need for specific fish and has already been identified and prioritized by the appropriate agency. He stressed it must be a specific goal, such as sustaining targeted threatened or endangered species. He also stressed that artificial reef proposals need to be looked at the in the larger context of a protected harvest area to help.

The bottom line is this statement:

"Given the statutory direction above, artificial reef proposals will be considered when DNR finds that they will protect and enhance, not merely change, the aquatic habitat. Applications for dive parks will be evaluated using these same standards."

It seems to me that what he is wanting is very definitive proof that creating habitat for fish and other animals will have a positive effect on the populations and, in the earlier statements, he is looking for specific, needy, populations to be identified. He also is looking for some specific proofs that ships destined to be large artificial reefs can be cleaned to the point where they will offer no future concerns for pollution to the waters he is charged with protecting. There are already federal standards for cleaning ships for use in underwater reefs which I previously mentioned but he didn't talk about that.


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This is the full letter if anyone would like to read the details:

Dear Mr. Guthrie:



Thank you for your email regarding the creation of artificial reefs. The Washington State Department of Natural Resources (DNR) has participated in discussions regarding artificial reefs in Washington waters, but does not currently have an active program or partnership with other entities or agencies to install them.



At DNR we are aware artificial reefs have been installed for a variety of purposes, including fish habitat and recreation. In 1975, the Washington Department of Fish and Wildlife (WDFW) initiated a formal artificial reef program. Early artificial reefs were primarily constructed near public fishing piers and urban areas to enhance recreational fishing. More than 10 different artificial reefs were constructed using materials mainly of rock and concrete.



In 2000, WDFW Biologists reassessed their agency position and produced a memorandum describing key issues of concern. While artificial reefs are known to have population concentrations of a variety of fish and shellfish species, the ability of artificial reefs to produce fish had not been proven. Also of concern was that though the primary purpose of artificial reef construction had been to aid the recovery of rock fish populations, no long-term monitoring program had demonstrated targeted fish populations had been enhanced in any Puget Sound region.



As a result of the updated WDFW position, artificial reef construction in Washington generally ended in 2000. The 2006 Legislature reviewed the possibility of sinking ships to create dive opportunity and directed several state agencies (with WDFW as lead) to undertake a preliminary scoping study. The U.S. Geological Survey was contracted and produced a report titled “Sinking Ships for Divers Scoping Study.” This report detailed many concerns, recommended a process for conducting a full feasibility study, and described a significant cost associated with accomplishing that study. No further work was done subsequent to the release of that report to assess the feasibility of sinking ships in Washington.



While there are some states that commonly authorize the sinking of vessels, this practice poses significant environmental risks. It is very difficult to ensure that a vessel is completely cleaned of all hazardous materials, such as oils and paints, before sinking. The introduction of materials to the marine environment carries considerable risk as vessels can be sources of polychlorinated biphenols (PCBs), asbestos, heavy metals (such as lead), and petroleum products. This is one of the main reasons DNR manages the Derelict Vessel Removal Program (DVRP), a nationally recognized program responsible for the removal of hundreds of derelict and abandoned vessels from Washington’s waters.



In light of the scientific and economic studies that have been completed, DNR will consider artificial reef proposals that fill a habitat need that has been specifically and previously identified and prioritized by an appropriate agency. Habitat goals must be specific, such as sustaining a targeted threatened or endangered species, and not a generic addition to aquatic habitat. Research of artificial reefs indicates that reef designs favor specific species of fish and life stages. Therefore, artificial reefs should be designed and located in the context of a larger network of marine-protected areas so that species diversity is preserved or enhanced. Research also shows that artificial reef construction almost always increases fishing pressure. Planning for artificial reefs should be done in an inclusive forum to increase the long-term chances for success. Given the statutory direction above, artificial reef proposals will be considered when DNR finds that they will protect and enhance, not merely change, the aquatic habitat. Applications for dive parks will be evaluated using these same standards.



I appreciate your eagerness to see artificial reefs come to life in Washington. I have directed all DNR staff to operate under my three guiding principles – manage resources sustainably, use sound science, and make decisions in the best interest of the public with their knowledge. The position stated above incorporates all of these principles, and my staff would be happy to evaluate any proposal that can meet these criteria. If you have any additional questions, please contact Michal Rechner, Aquatic Resources Assistant Division Manager at 360-902-1075 or at michal.rechner@dnr.wa.gov.



Sincerely,



Peter Goldmark

Commissioner of Public Lands

Washington State Department of Natural Resources

360-920-1000

cpl@dnr.wa.gov

http://www.dnr.wa.gov



cc: Bridget Moran, Deputy Supervisor

Kristin Swenddal, Aquatic Resources Division Manager

#11-005

[CaptnJack]

"Given the statutory direction above, artificial reef proposals will be considered when DNR finds that they will protect and enhance, not merely change, the aquatic habitat. Applications for dive parks will be evaluated using these same standards."

This is the scientifically impossible standard to meet. You've got to prove any type of reef/structure isn't just taking fish away from other areas. (which is a topic of much dispute). So everywhere else has to stay the same (or improve) and on top of that your reef has to have even more fish. Good luck.

[Gooch]

Capt Jack wrote:

This is the scientifically impossible standard to meet. You've got to prove any type of reef/structure isn't just taking fish away from other areas. (which is a topic of much dispute). So everywhere else has to stay the same (or improve) and on top of that your reef has to have even more fish. Good luck.

I gotta agree. It is almost as good as saying "don't try it." A scientific study to show these things would be expensive and probably inconclusive anyway.

It is interesting- I did a bit of web searching and found this page that discusses artificial reefs in the Georgia Strait. It has some of the same arguments put forth by the commissioner and also has points that Capt Jack has raised in the past (i.e. monies spent trying to get an artificial reef sunk in the form of a ship could be better spent on other projects to improve fish habitat) http://www.georgiastrait.org/?q=node/604

I know from diving that when I go to places that are restricted or banned from harvesting and fishing, there is more life there; more diversity, more density, bigger animals-- it is just plain to see once you have dove in a few places where there are no restrictions. I think it would be a no-brainer that any attempt at placing a reef would be coupled with a "no take" zone as well.

I also get the impression he wants to apply the same rules as creating a reef for habitat improvement toward the creation of an underwater park or attraction. I can see where you would want to regulate what is put in the water for waste control but a park would be an attraction for divers and not specifically an attempt at habitat improvement for any particular species (humans?). It would be important that any attempt at a park should be far enough away from natural reefs so it won't draw life away from any natural structures.

[FlyinV]

Hopefully reef surveys for the artificial reef they put in at Salt Water State Park will start to show its improving the fish counts.

I wonder what reef.org has to prove/disprove if artificial reefs help fish?

[ArcticDiver]

I may have misinterpreted, but what the letter says to me is that he doesn't want the reefs but as a good politician he is couching his disapproval in a requirement that is expensive, time consuming and appears to be nearly impossible to meet. Thus, if it doesn't get done it isn't his fault. It is because the citizen failed. One possible way to test his actual intentions is to ask what study protocol will produce data that meet his requirements.

I was typing as the other two posts were being made. I'm too slow.

My emphasis is on getting him to specify a test/study protocol that would provide satisfactory decision data. Without that you could be chasing your tail for years. Plus, it will smoke out his actual intentions.

[lamont]

I may have misinterpreted, but what the letter says to me is that he doesn't want the reefs but as a good politician he is couching his disapproval in a requirement that is expensive, time consuming and appears to be nearly impossible to meet. Thus, if it doesn't get done it isn't his fault. It is because the citizen failed.

+1

reads to me like he's saying to piss off and go away, without actually saying that.

of course i'm a natural cynic with no political skills...

[airsix]

"Given the statutory direction above, artificial reef proposals will be considered when DNR finds that they will protect and enhance, not merely change, the aquatic habitat. Applications for dive parks will be evaluated using these same standards."

DNR's intended purpose is conservation of public resources. Denying any use which can not be determined to be an ecological enhancement is NOT conservation. The standard should be "use allowed unless determined harmful" rather than "use denied unless proven beneficial". I believe strongly in conservation and protection of natural resources, but I also believe in the concept of public trust, and that resources should be managed ultimately for the benefit of the trust beneficiary, who is the public. It seems clear to me that DNR has no interest in enhancing the public experience. I believe the only course of action that will get results will be to bring pressure to bear on DNR through other channels, or to deal only with other agencies such as the parks department.

[CaptnJack]

DNR's intended purpose is conservation of public resources. Denying any use which can not be determined to be an ecological enhancement is NOT conservation. The standard should be "use allowed unless determined harmful" rather than "use denied unless proven beneficial". I believe strongly in conservation and protection of natural resources, but I also believe in the concept of public trust, and that resources should be managed ultimately for the benefit of the trust beneficiary, who is the public. It seems clear to me that DNR has no interest in enhancing the public experience. I believe the only course of action that will get results will be to bring pressure to bear on DNR through other channels, or to deal only with other agencies such as the parks department.

Apparently you don't live on Maury Island. DNR did stop Glacier NW from reopening a giant gravel mine there. At the dive site; in a state aquatic preserve which coincides with some of the last South Sound herring spawning grounds. So should that use have been allowed unless "proven" harmful? By the time the harm has occured its too late to reverse it...

[dsteding]

Interesting response. On the permitting side of things (something I do professionally) if this ever gathers enough momentum, I'd be willing to offer help on the legal side of things pro bono if my workload permitted. Would be an interesting nut to crack.

But, ultimately, this is a political issue that needs to be resolved at high levels. I know the city council in Port Angeles has kicked the idea around a bit as an economic stimulus project.

[airsix]

Richard, I don't mean DNR should allow the public to run rampant. I just expect reasonable consideration of potential use. As far as mining in a marine protected area? I can't imagine any reasonable consideration concluding that would be a good idea.

I used the word 'determined' not 'proven'.

[Gooch]

Dsteding- I think your offer of help is great. I also agree that it is something that needs more political clout from the top, not the bottom. Even if you look at it as a purely economic gain, call it environmentally neutral, it is something worth considering. Mike Racine seemed to think that the scenario that it would happen under would be like this; a poor community comes together to want to start a ships-to-reefs type of project and pushes ahead with it. They point to the possible economic boons to be had and ask "why can't we?". They forge forward and tell the powers that be "the benefits are obvious. Unless you can give us a solid reason why we can't do this that makes sense, we're doing it."

He envisioned a place like Brinnon or Port Towsnend. The idea first ship would be a ferry- strong connection to Washington and relatively easy to clean for environmental purposes.

I think it would be key to get your political backing together from your region and try to push that agenda. History has shown that almost anything can be done once you get enough political figures that realize they have something to gain together.

[ArcticDiver]

The February 2011 issue of National Geographic has an article on artifical reefs that may be pertinent to this discussion. It seems there is a question of New Life vs. Moved Life and how that affects fish stocks. At this point I don't know enough to judge whether that is a valid concern, or just a tactic by obstructionists and those who just want to wield power for power's sake.

[Biodiversity_Guy]

There may be merit in framing sinking ships and other similar structures not as "artificial reefs", which does imply a "marine life enhancement" conservation benefit, but rather as an underwater attraction for promoting ecotourism.

This focuses the question more on the economics of how and where to put such a structure rather than having to first justify the project for marine life enhancement purposes.

[wallyc72]

Just don't do this.


[youtube]http://www.youtube.com/watch?v=fPNqCBWs ... re=related[/youtube]

[dsteding]

There may be merit in framing sinking ships and other similar structures not as "artificial reefs", which does imply a "marine life enhancement" conservation benefit, but rather as an underwater attraction for promoting ecotourism.

This focuses the question more on the economics of how and where to put such a structure rather than having to first justify the project for marine life enhancement purposes.

I've always thought that is the only way to get it done. Prove no negative impact, make an economic argument. The dnr position above pretty clearly links the old experience with reefs as fish enhancing structures with reeding a ship. The old experiences of dnr need to be disconnected from dnr's position on reeding a ship.

[CaptnJack]

There may be merit in framing sinking ships and other similar structures not as "artificial reefs", which does imply a "marine life enhancement" conservation benefit, but rather as an underwater attraction for promoting ecotourism.

This focuses the question more on the economics of how and where to put such a structure rather than having to first justify the project for marine life enhancement purposes.

I've always thought that is the only way to get it done. Prove no negative impact, make an economic argument. The dnr position above pretty clearly links the old experience with reefs as fish enhancing structures with reeding a ship. The old experiences of dnr need to be disconnected from dnr's position on reeding a ship.

Agree.
Its not like an oyster farm lease or marina lease (or timber sale) has to prove they have a net beneficial biological impact. None of them do from a biomass or biodiversity perspective. Those activities are targeting the economic development personality of DNR and if there's enough economic development the biologist personality is superseeded.

Ship = tourist attraction = money for charters and shops. The more out of state money the better.

[dsteding]

Agree.
Its not like an oyster farm lease or marina lease (or timber sale) has to prove they have a net beneficial biological impact. None of them do from a biomass or biodiversity perspective. Those activities are targeting the economic development personality of DNR and if there's enough economic development the biologist personality is superseeded.

Ship = tourist attraction = money for charters and shops. The more out of state money the better.

And, if you look at the statute governing leases of aquatic lands (essentially the roll that DNR would play in this process), there isn't anything that I can see which supports the "statutory directive" that Mr. Goldmark discusses above. I'm aware of the only allowed if there is a benefit standard elsewhere (California has such a test for discharges to enclosed bays and estuaries, for instance), but I am unaware of the source of this standard in Washington law. Would be a good question for Mr. Goldmark if there was a dialogue.

But, I don't think there really should be a dialogue at this point. If people are really serious about this, go about it the way Mike Racine and WSA have. Find an interested community, build support there, get political momentum. Work with congressional representatives to find money (too bad no more stimulus, it won't come from the state). Once you have the money and political momentum, then tackle the leasing/permitting issues. Not the other way around.

[BASSMAN]

How many decommissioned ferries or junk boats are just sitting on the water, rotting away and continuing to pollute our waters? If there was a volunteer program, with minimal funding, to clean and sink these eye sores, wouldn't that be a motivator?
Just my two cents

[gmdollar]

As someone who has followed this debate for years and seen absolutely no change I would suggest that DNR is never going to allow anyone to sink a ship in Washington waters. Their focus is entirely on supporting the consumption based community and they have no interest in protecting the environment except when it allows an increase in take for one of their constituencies. If we ever hope to see progress we need to forget about DNR and go to work on the legislature. If a local community or two decide that artificial reefs can make money for them they can be our natural allies but we need to go to the legislature and change the DNR.

DNR claims that one of their primary missions is to enhance and protect fisheries and therefore it has to be proven that an artificial reef will not only do no harm but must have a positive impact. I suggest that the only way around this mindset is direction from the legislature requiring DNR to permit artificial reefs unless harm can be demonstrated as long as certain requirements such as cleaning are met. They would also need to specify the standards to be met, perhaps referencing federal standards. Without such intervention from their real bosses (i.e. the legislature) nothing will ever change.

It has now been over 20 years since the Artificial Reef Society of British Columbia sank the Chaudiere. There has been no demonstrable damage done to the environment after 20 years and there are now a total of seven reefs available for study. However, in all this time the Washington DNR position has not changed at all.

Jerry