Appendices A-M

Chapter 5HumanEnvironment

Chapter 4BiologicalEnvironment

Chapter 3PhysicalEnvironment

Chapter 1Introduction andBackground Appendices

© Dow Lambert

Chapter 2ManagementDirection

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-1 

Appendix A. Appropriate Use Findings 

A.1 Introduction 

The Appropriate Refuge Uses Policy (603 FW 1 (2006)) outlines the process that the Service uses to 

determine when general public uses on refuges may be considered. Priority public uses previously 

defined as wildlife-dependent uses (hunting, fishing, wildlife observation and photography and 

environmental education and interpretation) under the National Wildlife Refuge System 

Improvement Act of 1997 are generally exempt from appropriate use review. Other exempt uses 

include situations where the Service does not have adequate jurisdiction to control the activity and 

refuge management activities. In essence, the appropriate use policy provides refuge managers with a 

consistent procedure to first screen and then document decisions concerning a non-priority public 

use. When a use is determined to be appropriate, a refuge manager must then decide if the use is 

compatible before allowing it on a refuge. For purposes of this CCP an “appropriate use” must meet 

at least one of the following three conditions. 

 The use is a wildlife-dependent recreational use as identified in the Refuge Improvement Act. 

 The use involves the take of fish and wildlife under state regulations. 

 The use has been found to be appropriate as specified in section 1.11 of the policy and 

documented on FWS Form 3-2319. 

During the CCP process, the refuge manager reviewed all existing and proposed refuge uses for 

Dungeness National Wildlife Refuge that is associated with the Preferred Alternative (Alternative B). 

Documentation of appropriateness findings for wildlife-dependent uses is not included in this 

Appendix because wildlife-dependent uses are appropriate by definition. They are, however, 

evaluated for compatibility in Appendix B, Compatibility Determination. All other refuge uses were 

evaluated using the criteria described in policy and listed on FWS Form 3-2319. The table below 

shows the uses evaluated and appropriateness findings made by the refuge manager. Additional 

documentation is included in this Appendix for each use identified in the table. 

Table A-1. Summary of Appropriate Use Findings 

Refuge Use Appropriate Page 

Research, Scientific Collecting, and Survey Activities Yes A-2 

Boating Yes A-5 

Horseback Riding Yes A-8 

Vehicle Access to New Dungeness Light Station Yes A-11 

Jogging/ Running Yes A-14 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-3 

Finding of Appropriateness of a Refuge Use 

Supplement to FWS Form 3-2319 

Research, Scientific Collecting, and Surveys 

Further Explanation of Answers Provided for the Decision Criteria: 

Project: Conducting research on refuge lands and waters 

Summary: The Refuge receives requests to conduct scientific research on refuge lands and waters. 

Research applicants must submit a proposal that would outline: (1) objectives of the study; (2) 

justification for the study; (3) detailed methodology and schedule; (4) potential impacts on refuge 

wildlife and/or habitat, including disturbance (short- and long-term), injury, or mortality; (5) 

personnel required; (6) costs to the Refuge, if any; and (7) end products expected (i.e., reports, 

publications). Research proposals would be reviewed by refuge staff, the Regional Office Branch of 

Refuge Biology, and others as appropriate prior to the Refuge issuing a special use permit (SUP). 

Projects will not be open-ended, and at a minimum, will be reviewed annually. 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

(a) Do we have jurisdiction over the use? 

Some or all of the proposed activities would take place within refuge boundaries. The Refuge has 

jurisdiction over those research projects that are sited within refuge boundaries. 

(b) Does the use comply with applicable laws and regulations (federal, state, tribal, and local)? 

Any proposed research activities would comply with all applicable laws and regulations and any 

restrictions or qualifications that are required to comply with laws and regulations would be specified 

in the SUP. 

(c) Is the use consistent with applicable executive orders and Department and Service policies? 

Through the review of individual projects, the Refuge would ensure that they are consistent with 

applicable policies, especially the Research on Service Lands Policy (803 FW 1). 

(d) Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. If necessary, stipulations to ensure public safety will be included in the project’s SUP. 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Research activities are approved in instances where they can provide meaningful data that may 

contribute to refuge management and public appreciation of natural resources. 

(f) Is the use manageable within available budget and staff? 

The Refuge receives fewer than two requests per year for this activity, and it is manageable with 

available budget and staff. 

(g) Will this be manageable in the future within existing resources? 

The proposed activity at current levels would be manageable in the future with the existing resources. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

A-4 Appendix A. Appropriate Use Findings 

(h) Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use is beneficial to the Refuge’s natural and cultural resources because the types of 

research projects approved are those that have the distinct likelihood of helping achieve refuge 

purposes by providing information useful for the management of trust resources and contributing to 

the public’s understanding and appreciation of natural and/or cultural resources. 

(i) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see Section 1.6D, 603 FW 1, for description) 

compatible, wildlife-dependent recreation into the future? 

The Refuge will ensure that the research activities do not impair existing or future wildlife-dependent 

recreational use of the Refuge during individual project review, prior to issuing the SUP for the 

project. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

A-6 Appendix A. Appropriate Use Findings 

Finding of Appropriateness of a Refuge Use 

Supplement to FWS Form 3-2319 

Boating (electric and wind driven; human powered; and motorized) 

Further Explanation of Answers Provided for the Decision Criteria: 

Project: Boating 

Summary: Boating occurs in refuge waters primarily in support of fishing and wildlife observation. 

Boats are allowed in refuge waters from May 15 to September 30. The remainder of the year these 

waters are closed to all use to protect migrating and wintering species of wildlife. Boaters must 

operate at a no wake speed and stay 100 yards below mean high tide line thus providing a buffer to 

wildlife using the shoreline. 

For the findings listed on FWS Form 3-2319, a justification has been provided below 

(a) Do we have jurisdiction over the use? 

An October 20, 1994 memorandum from the Assistant Solicitor, Branch of Fish and Wildlife to the 

Director, U.S. Fish and Wildlife Service (Service) concludes “... that the Service has statutory 

authority under the National Wildlife Refuge Administration Act (Administration Act) to regulate 

activities that occur on water bodies ‘within’ refuge units. The Service, in terms of its refuge 

administration regulations, has effectively defined this authority to apply to areas the United States 

holds in fee or to the extent of the interest held by the United States.” The Solicitor also noted that 

“... other legislative authorities allow the Service to regulate activities on waters that are not ‘within’ 

refuge units but those authorities can be exercised only by regulations that are issued to protect 

migratory birds, to protect refuges that were acquired pursuant to the Migratory Bird Conservation 

Act, or to protect species listed under the Endangered Species Act or protected by the Marine 

Mammal Protection Act.” 

Federal authority to regulate activities on state owned tidelands was reiterated in an August 7, 2003 

memorandum to Refuge Chief, Fish and Wildlife Service, Region 1 from the Office of the Solicitor, 

Pacific Northwest Region concerning airboat use at Willapa National Wildlife Refuge. 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Boating, in support of recreational fishing and wildlife observation, supports Goals 5 and 6 in the 

Dungeness NWR CCP. 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Boating was modified with the 1997 Environmental Assessment “Management of Public Use for 

Dungeness National Wildlife Refuge” (USFWS 1997). 

i) Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-7 

Boating on refuge waters takes place primarily in support of fishing, wildlife observation and as a 

means of access to the New Dungeness Light Station. The National Wildlife Refuge System 

Improvement Act of 1997 identifies wildlife observation, photography, hunting, fishing, and 

environmental education as priority public uses on national wildlife refuges. Boating on the Refuge 

enhances visitor opportunities to participate in a number of these activities. The Service strives to 

provide visitor uses supporting these activities when compatible with the purpose(s) and goals of the 

Refuge and the mission of the National Wildlife Refuge System (System). 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

Based upon the biological impacts presented in the CCP/Environmental Assessment, it is determined 

that providing boating opportunities at Dungeness NWR will not materially interfere with or detract 

from the purposes for which the Refuge was established. By limiting areas open to boats, limiting the 

seasons of use, and complying with stipulations identified in the Compatibility Determination, 

impacts affiliated with boat use can be lessened. Monitoring of this activity and its impacts will allow 

the refuge staff to modify programs if needed to ensure this use remains at an acceptable level. 

Literature Cited 

USFWS (U.S. Fish and Wildlife Service). 1997. Management of public use for Dungeness National 

Wildlife Refuge – final environmental assessment. U.S. Department of Interior, Fish and Wildlife 

Service. Sequim, WA. 53 pp. On file at the Washington Maritime National Wildlife Refuge Complex 

Headquarters. Sequim, Washington. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-9 

Finding of Appropriateness of a Refuge Use 

Supplement to FWS Form 3-2319 

Horseback Riding 

Further Explanation of Answers Provided for the Decision Criteria: 

Project: Horseback riding 

Summary: Horseback riding will be allowed on designated areas of Dungeness NWR year-round if 

a safe and legal alternate access can be obtained from the east or the west. The activity will be 

restricted to the beach west of where the main trail joins the beach (west beach, Zone 1, 

approximately 0.5 mile). If a safe and legal access route onto the Refuge is obtained from the east, 

then horseback use of the administrative road from the eastern Refuge boundary to where the main 

trail joins the beach will also be allowed. Horseback riding will be permitted daily October 1 through 

March 31 and weekdays April 1 through September 30, by reservation only through the Refuge 

Office. No horseback riding on Memorial Day, the Fourth of July, and Labor Day. Depending on 

demand, numbers may be limited to prevent overcrowding and ensure public safety. 

For the findings listed on FWS Form 3-2319, a justification has been provided below 

(d) Is the use consistent with public safety? 

A serious accident between an equestrian and a pedestrian on a shared section of the main trail in 

May 2012 resulted in the Refuge being closed to horseback use due to safety concerns. The Service 

has determined that if safe and legal alternative access becomes available from the east or the west 

then this activity could take place on the west beach (Zone 1). Measures to ensure public safety and 

reduce conflicts with other users are listed in the stipulations necessary to ensure compatibility 

(Appendix B). 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Horseback riding was modified with the 1997 Environmental Assessment “Management of Public 

Use for Dungeness National Wildlife Refuge” (USFWS 1997). A serious accident between an 

equestrian and a pedestrian on a shared section of the main trail in May 2012 has necessitated this 

further modification. The Service has determined that if safe and legal alternative access becomes 

available from the east or the west then this activity could take place on the west beach (Zone 1). 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s 

natural or cultural resources, or is the use beneficial to the refuge’s natural or cultural 

resources? 

Facilitating this use on the Refuge will increase visitor knowledge and appreciation of fish and 

wildlife resources. This enhanced understanding will foster increased public stewardship of natural 

resources and support for the Service's management actions in achieving the refuge purposes and the 

mission of the National Wildlife Refuge System. 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

A-10 Appendix A. Appropriate Use Findings 

This use conducted with stipulations to ensure compatibility can be accommodated while minimizing 

impacts on existing wildlife-dependent recreational uses. The Refuge will monitor this use and its 

impacts to other refuge users and may further modify stipulations necessary for compatibility if 

needed. 

Literature Cited 

USFWS (U.S. Fish and Wildlife Service). 1997. Management of public use for Dungeness National 

Wildlife Refuge – final environmental assessment. U.S. Department of Interior, Fish and Wildlife 

Service. Sequim, WA. 53 pp. On file at the Washington Maritime National Wildlife Refuge Complex 

Headquarters. Sequim, Washington. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

A-12 Appendix A. Appropriate Use Findings 

Finding of Appropriateness of a Refuge Use 

Supplement to FWS Form 3-2319 

Transport - Vehicle Access to New Dungeness Light Station 

Further Explanation of Answers Provided for the Decision Criteria 

Project: Vehicle Access to New Dungeness Light Station 

Summary: The U. S. Coast Guard (USCG) withdrew its last keeper from the automated New 

Dungeness Light Station in March of 1994. Before the Station was unmanned, the USCG accessed 

the Station by boat, helicopter, and vehicles driven on the beach. The New Dungeness Light Station 

Association (NDLSA) obtained a renewable license with the USCG to care for the Station in 1994 

and have accessed the Station via vehicle under a refuge Special Use Permit since that time. Vehicle 

use is restricted to volunteer Light Station keeper exchange and for maintenance purposes. Keepers 

are rotated in and out of the Light Station once a week coinciding with a low tide event either on a 

Friday or Saturday. During the summer months these exchanges occur during the day while during 

the winter they occur at night. Maintenance trips are less frequent but average a couple per month. It 

is the intent of the U. S. Fish and Wildlife Service to acquire the Light Station from the USCG when 

it is excessed and to enter into an agreement with the NDLSA similar to the one they have with the 

USCG. 

For the findings listed on FWS Form 3-2319, a justification has been provided below. 

(d) Is the use consistent with public safety? 

The NDLSA access the refuge beach via Anderson Road so there are no vehicles on refuge trails. 

Once on the beach (Strait of Juan de Fuca side) they travel no more than 10 to 15 miles per hour and 

have a low volume horn that they sound if nearing a visitor on the beach so as to not startle them. 

This mode of transport for keeper exchange and maintenance needs is far safer than using a boat due 

to the weather and sea conditions that can occur in the Strait of Juan de Fuca. 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

The Refuge has identified in the CCP the intent to acquire the Light Station property from the USCG 

when it is excessed and then to enter into an agreement with the NDLSA to care, maintain and 

interpret the facilities. 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

This activity has been ongoing since 1994 although neither a compatibility or an appropriateness 

determination were ever prepared. 

(i) Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

Allowing safe access to the NDLSA to care for, maintain, and interpret the New Dungeness Light 

Station will contribute to the public’s understanding and appreciation of this significant cultural 

resource. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-13 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

This use conducted with stipulations to ensure compatibility and under a guiding document (Special 

Use Permit or Memorandum of Agreement/Understanding) can be accommodated while minimizing 

impacts on existing wildlife-dependent recreational uses. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-15 

Finding of Appropriateness of a Refuge Use 

Supplement to FWS Form 3-2319 

Jogging/Running 

Further Explanation of Answers Provided for the Decision Criteria: 

Project: Jogging/running 

Summary: Jogging/running will be allowed only on the trail adjacent to the refuge parking lot 

(parking lot trail, approximately 0.2 mile) and along the west beach from the end of the upland 

forested trail to the western boundary of the Refuge (west beach, Zone 1, approximately 0.5 mile). 

For the findings listed on FWS Form 3-2319, a justification has been provided below: 

(e) Is the use consistent with the goals and objectives in an approved management plan or other 

document? 

The use is consistent within the stipulations identified in the Compatibility Determination (Appendix 

B), restricted to the parking lot trail and west beach. There is a potential for this activity to disturb 

wildlife, however these two areas receive very little use by wildlife and those that are present appear 

to be accustomed to a high degree of disturbance associated with the trailhead and parking lot. 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Jogging/running was restricted in the 1997 EA – “Management of Public Use for Dungeness 

National Wildlife Refuge” to the main and primitive (formerly equestrian) trail and on the beach in 

Zones 1 and 2, although some “illegal” use occurs in Zone 3 (USFWS 1997). Upon revisiting this use 

in compliance with the Appropriate Refuge Uses Policy that was not in effect when the EA was 

finalized, jogging/running will be allowed only on the trail adjacent to the refuge parking lot and 

along the west beach (Zone 1). 

(i) Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

Although jogging is not a wildlife-dependent use and is primarily athletic in nature, it is likely that 

some joggers observe and enjoy wildlife while on the Refuge. 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1 for description), 

compatible, wildlife-dependent recreation into the future? 

Compatible wildlife-dependent activities such as wildlife watching, photography, and environmental 

education may be negatively affected because of the expected responses by wildlife to the fast 

moving activity associated with jogging. When wildlife react by moving away from jogging activity 

or alter behavior by hiding they will be less likely to be observed (Bennett and Zuelke 1999). Further, 

user groups of shared-use paths often have conflicting needs. Moore (1994) concluded that trail 

conflicts can occur among different user groups, among users within the same user group, and as a 

result of factors not related to trail user activities at all. Conflict has been found to be related to 

activity style, focus of trip, expectations, attitudes toward and perceptions of the environment, level 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

A-16 Appendix A. Appropriate Use Findings 

of tolerance for others, and different norms held by different users. This loss of expectation of a 

quality wildlife-dependent experience could result in avoidance of some refuge trails by wildlife 

watchers and photographers who encounter joggers using the same trail. 

There is a potential to interfere with wildlife-dependent uses; however, the parking lot trail and west 

beach both receive very little use by wildlife and those that are present appear to be accustomed to a 

high degree of disturbance associated with the trailhead and parking lot. As a result, conflicts 

between joggers and wildlife-dependent public use are expected to be minimal because visitors do 

not necessarily expect to encounter wildlife in these areas. Measures to reduce potential conflicts 

between user groups would include limiting group size to 3 individuals on the parking lot trail, and 

providing information at the parking lots, refuge headquarters and in the refuge tear sheet that clearly 

indicates permitted uses of each area. 

 

Literature Cited 

Bennett, K.A. and E. Zuelke. 1999. The effects of recreation on birds: a literature review. Delaware 

Natural Heritage Program. Smyrna, DE. 

Moore, R.L. 1994. Conflicts on multiple-use trails: synthesis of the literature and state of the 

practice. Federal Highway Administration Report No. FHWA-PD-94-031. Report Date: August 

1994. Federal Highway Administration. Washington, D.C. 68 pp. 

USFWS (U.S. Fish and Wildlife Service). 1997. Management of public use for Dungeness National 

Wildlife Refuge – final environmental assessment. U.S. Department of Interior, Fish and Wildlife 

Service. Sequim, WA. 53 pp. On file at the Washington Maritime National Wildlife Refuge Complex 

Headquarters. Sequim, Washington. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-1 

Appendix B. Compatibility Determinations 

B.1 Introduction 

The compatibility determinations (CDs) developed during the comprehensive conservation plan 

(CCP) planning process evaluate uses projected to occur under Alternative B, the preferred 

alternative, in the Draft CCP/Environmental Assessment (EA) for the Dungeness National Wildlife 

Refuge (NWR or Refuge) (USFWS 2012a), which was carried forward as the management direction 

for the Refuge in this CCP. The evaluation of funds needed for management and implementation of 

each use is described in Appendix C, Implementation. Chapter 6 of the Draft CCP/EA also contained 

an analysis of the impacts of refuge uses to wildlife and habitats. That document is incorporated 

through reference into this set of CDs. 

B.1.1 Uses Evaluated At This Time 

The following section includes full CDs for all refuge uses that are required to be evaluated at this 

time. According to Service policy, compatibility determinations are to be completed for all uses 

proposed under a CCP that have been determined to be appropriate. Existing wildlife-dependent 

recreational uses must also be reevaluated and new CDs prepared during development of a CCP. 

According to the Service’s compatibility policy, uses other than wildlife-dependent recreational uses 

are not explicitly required to be reevaluated in concert with preparation of a CCP, unless conditions 

of the use have changed or unless significant new information relative to the use and its effects have 

become available or the existing CDs are more than 10 years old. However, the Service planning 

policy recommends preparing CDs for all individual uses, specific use programs, or groups of related 

uses associated with the proposed action. Accordingly, the following CDs are included in this 

document for public review. 

Table B-1. Summary of Compatibility Determinations 

Refuge Use Compatible Page 

Environmental Education, Wildlife Observation, Photography, 

Interpretation 

Yes B-4 

Research, scientific collecting, and surveys Yes B-11 

Recreational fishing Yes B-25 

Tribal fishery Yes B-31 

Boating Yes B-37 

Vehicle access to New Dungeness Light Station Yes B-43 

Horseback riding Yes B-48 

Jogging Yes B-55 

B.1.2 Compatibility–Legal and Historical Context 

Compatibility is a tool refuge managers use to ensure that recreational and other uses do not interfere 

with wildlife conservation, the primary focus of national wildlife refuges. Compatibility is not new to 

the Refuge System and dates back to 1918, as a concept. As policy, it has been used since 1962. The 

Refuge Recreation Act of 1962 directed the Secretary of the Interior to allow only those public uses 

of refuge lands that were “compatible with the primary purposes for which the area was established.” 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-2 Appendix B. Compatibility Determinations 

Legally, national wildlife refuges are closed to all public uses until officially opened through a 

compatibility determination. Regulations require that adequate funds be available for administration 

and protection of refuges before opening them to any public uses. However, wildlife-dependent 

recreational uses (hunting, fishing, wildlife observation and photography, environmental education, 

and interpretation) are to receive enhanced consideration and cannot be rejected simply for lack of 

funding resources unless the refuge has made a concerted effort to seek out funds from all potential 

partners. Once found compatible, wildlife-dependent recreational uses are deemed the priority public 

uses at the refuge. If a proposed use is found not compatible, the refuge manager is legally precluded 

from approving it. Economic uses that are conducted by or authorized by the refuge also require 

compatibility determinations. 

Under compatibility policy, uses are defined as recreational, economic/commercial, or management 

use of a refuge by the public or a non-Refuge System entity. Uses generally providing an economic 

return (even if conducted for the purposes of habitat management) are also subject to compatibility 

determinations. The Service does not prepare compatibility determinations for uses when the Service 

does not have jurisdiction. For example, the Service may have limited jurisdiction over refuge areas 

where property rights are vested by others; where legally binding agreements exist; or where there 

are treaty rights held by tribes. In addition, aircraft overflights, emergency actions, some activities on 

navigable waters, and activities by other Federal agencies on “overlay refuges” are exempt from the 

compatibility review process. 

New compatibility regulations, required by the National Wildlife Refuge System Improvement Act 

of 1997 (Improvement Act), were adopted by the Service in October, 2000 (http://refuges.fws.gov/ 

policymakers/nwrpolicies.html). The regulations require that a use must be compatible with both the 

mission of the System and the purposes of the individual refuge. This standard helps to ensure 

consistency in application across the Refuge System. The Act also requires that compatibility 

determinations be in writing and that the public have an opportunity to comment on most use 

evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of 

primary consideration. The Improvement Act defined a compatible use as one that “in the sound 

professional judgment of the Director, will not materially interfere with or detract from the 

fulfillment of the mission of the System or the purposes of the Refuge.” Sound professional judgment 

is defined under the Improvement Act as “a finding, determination, or decision, that is consistent 

with principles of sound fish and wildlife management and administration, available science and 

resources.” Compatibility for priority wildlife-dependent uses may depend on the level or extent of a 

use. 

Court interpretations of the compatibility standard have found that compatibility is a biological 

standard and cannot be used to balance or weigh economic, political, or recreational interests against 

the primary purpose of the refuge (Defenders of Wildlife v. Andrus [Ruby Lake Refuge]). 

The Service recognizes that compatibility determinations are complex. For this reason, refuge 

managers are required to consider “principles of sound fish and wildlife management” and “best 

available science” in making these determinations (House of Representatives Report 105-106). 

Evaluations of the existing uses on the Dungeness National Wildlife Refuge are based on the 

professional judgment of refuge and planning personnel including observations of refuge uses and 

reviews of appropriate scientific literature. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-3 

In July 2006, the Service published its Appropriate Refuge Uses Policy (603 FW 1). Under this 

policy, most proposed uses must also undergo a review prior to compatibility. Uses excepted from 

the policy include priority wildlife-dependent recreational uses, and uses under reserved rights – see 

policy for more detail. Appropriate use findings for Dungeness NWR are included in Appendix A. 

B.2 References 

Defenders of Wildlife v. Andrus (Ruby Lake Refuge I). 11 Envtl. Rptr. Case 2098 (D.D.C. 1978), p. 

873. 

House of Representatives Report 105-106 (on NWRSIA) - 

http://refuges.fws.gov/policyMakers/mandates/HR1420/part1.html 

Compatibility regulations, adopted by the Service in October, 2000: 

(http://Refuges.fws.gov/policymakers/nwrpolicies.html) 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-4 Appendix B. Compatibility Determinations 

Compatibility Determination 

Use: Environmental Education, Wildlife Observation, Photography, and Interpretation 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for- (1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-5 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use: 

In the National Wildlife Refuge System Improvement Act of 1997, the United States Congress 

declared wildlife observation and photography, and environmental education and interpretation as 

four of six priority wildlife-dependent public uses of the NWRS. These four uses are nonconsumptive, wildlife-dependent public uses with similar elements and are considered together in 

this compatibility determination (CD). 

Existing wildlife-dependent public uses include wildlife observation, photography, interpretation, 

and environmental education. Dungeness NWR is open to public use year-round during daylight 

hours. Existing public use facilities that are involved in these uses include an orientation kiosk with 

interpretive panels; an entrance fee kiosk; a 3,300 foot main hiking trail with interpretive panels; a 

1,800 foot primitive hiking (former equestrian) trail with associated entrance fee kiosk; two 

observation decks (upper and lower) at the confluence of the main and primitive trails; and a parking 

lot and public restroom leased from Clallam County. Visitors engage in wildlife observation and 

photography while walking the self-guided forest trails and open areas of Dungeness Spit 

(approximately 5 miles of beach), sitting on observation benches along the main trail and at the 

observation decks. “Dungeness Spit,” as it is known to the local public, provides an opportunity for 

the public to enjoy the marine portion of the Refuge. Visitors use select portions of the beach for 

walking, picnicking, and wading in the course of observing seabirds, shorebirds, bald eagles, and 

occasional marine mammals. By allowing visitors to access only certain areas of the beach and water 

and monitoring visitor behavior, adverse effects associated with refuge visitation can be minimized. 

Complex staff, the Friends of Dungeness NWR, and refuge volunteers provide environmental 

education programs on site to local schools on a request basis. Interpretation is provided of the 

wildlife resources and habitat via interpretation panels at the orientation kiosk, along the main trail, 

and during on-site events by refuge friends, volunteers, and staff. 

Availability of Resources: 

Base funding is available to cover staff costs and sufficient funds are available to manage the activity 

at current levels but not at the level described under the management direction of the CCP. The 

following funding/annual costs will be required to administer and manage wildlife observation, 

photography, interpretation, and environmental education activities as designed under the CCP. 

Category One-time Expenses Recurring Expenses 

Special equipment, facilities, or equipment(signs, 

brochures, EE material) $23,000 

Monitoring and Administration $15,000 

Maintenance $22,000 

Law Enforcement $18,000 

Totals $23,000 $55,000 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-6 Appendix B. Compatibility Determinations 

Anticipated Impacts of the Use(s): 

The presence of people observing or photographing wildlife at Dungeness NWR has the potential to 

cause disturbance to wildlife such as nesting and loafing species and harbor seal pups left on the 

beach. Human activities on the forest trails and on the beach may result in direct effects on wildlife 

through harassment, a form of disturbance that can cause physiological effects or varying levels of 

behavioral modification (Smith and Hunt 1995). Various studies have shown that the severity of the 

effects depends upon the distance to the disturbance and its duration, frequency, predictability, and 

visibility to wildlife (Knight and Cole 1995). The variables found to have the greatest influence on 

wildlife behavior are (a) the distance from the animal to the disturbance and (b) the duration of the 

disturbance. Animals also show greater flight response to humans moving unpredictably than to 

humans following a distinct path (Gabrielsen and Smith 1995). These wildlife disturbance 

considerations were folded into the design of the interpretive trail, which helps keep people on a path 

to reduce off-trail walking, and assists in keeping human activities away from bluff edges. 

Of the wildlife-dependent public uses evaluated, wildlife photographers tend to have the largest 

disturbance impacts (Klein 1993, Morton 1995, Dobb 1998). While wildlife observers frequently 

stop to casually view species, wildlife photographers are more likely to approach wildlife (Klein 

1993) to get that perfect photograph. Even slow approach by wildlife photographers tends to have 

behavioral consequences to wildlife species (Klein 1993). Other compounding factors include the 

potential for photographers to remain close to wildlife for extended periods of time in an attempt to 

habituate the wildlife subject to their presence (Dobb 1998) and the tendency of casual 

photographers, with low-power lenses, to get much closer to their subjects than other activities would 

require (Morton 1995), including wandering off trails. This usually results in increased disturbance to 

wildlife and habitat, including trampling of plants. The establishment of seasonal and permanent 

areas closed to the public on Dungeness and Graveyard spits and the requirement that visitors remain 

on forest trails restricts the general visitor and photographers’ accessibility to areas where their 

actions would cause wildlife disturbance or trample sensitive vegetation. 

Impacts from the wildlife-dependent public uses of wildlife observation and photography are 

contained effectively and mitigated within the overall design of the 1997 Environmental Assessment 

“Management of Public Use for Dungeness National Wildlife Refuge” (USFWS 1997) by providing 

clearly defined zones where and seasons when these activities can take place, and requiring that 

visitors restrict their use to those seasons and areas. This strategy will continue to be implemented 

under the CCP. The Complex is aware that some visitors disregard signs requiring visitors to stay 

within the designated public use areas (Area Closed signs). Such unauthorized use creates the 

potential for greater disturbance to wildlife. 

The other two wildlife-dependent public use programs – interpretation and environmental education 

– use the existing public facilities, including the kiosk area, trail, interpretive panels, and wildlife 

observation accommodations (upper and lower observation decks). Impacts from these uses will not 

be additive with regard to impacts from wildlife observation and photography. 

Public Review and Comment: 

This compatibility determination was submitted for 90-day public review and comment as an 

appendix to the Draft Comprehensive Conservation Plan and Environmental Assessment for 

Dungeness NWR. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-7 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

The requirements laid out in the preferred alternative of the Environmental Assessment – 

“Management of Public Use for Dungeness National Wildlife Refuge” (USFWS 1997) are adopted 

as stipulations to ensure compatibility and include: 

User stipulations: 

 Graveyard Spit and the tip of Dungeness Spit are closed to public access 

 In Zone 1 – Beach in front of bluffs - Hiking, wildlife observation, and wildlife photography 

permitted year-round 

 In Zone 2 – Base of Dungeness Spit out to 1⁄2 mile - Hiking, wildlife observation, wildlife 

photography and incidental beach uses (picnicking and wading) permitted on the Strait of 

Juan de Fuca side year-round and on the Dungeness Harbor side from May 15 to September 

30. From October 1 to May 14, the Harbor side of Zone 2 is closed to all access. 

 In Zone 3 – Strait side of Dungeness Spit from 1⁄2 mile to New Dungeness Light Station – 

Hiking, wildlife observation, and wildlife photography permitted on the Strait side yearround. 

 In Zone 4 – Dungeness Spit from lighthouse to end of spit, the Harbor and Bay sides of 

Dungeness Spit, and all of Graveyard Spit including a 100-yard buffer zone below the mean 

high tide line - closed to public access year-round. Where the refuge boundary does not 

accommodate a 100 yard buffer, the buffer is slightly narrower. Boats are permitted to land 

year-round between the hours of 9 AM and 5 PM, by reservation only through the Complex 

office (as deemed necessary by the Refuge) in the designated 100 yard zone of beach next to 

the light station compound on the Bay side of Dungeness Spit. Visitors are allowed to walk 

through Zone 4 in a designated area to get to and from the landing site to the lighthouse. 

 In Zone 5 – Refuge waters and tidelands on the Harbor and Bay sides of Dungeness and 

Graveyard spits outside of the 100 yard buffer zone - wildlife observation and photography 

by use of a boat permitted from May 15 through September 30. From October 1 to May 14 

this zone is closed to all public access. 

Management actions taken to reduce disturbance to harbor seals pupping in areas open to public use 

will include: 

 As soon as a new pup is found, the immediate area where the pup is located will be closed 

and marked with cones. 

 A volunteer will be stationed at the site whenever possible to prevent disturbance and to 

educate visitors. 

 Brochures, signs, and visitor contacts will be used to educate the public about unnecessary 

pup disturbance and human intervention. 

The response of wildlife to these modifications in public use activities will be monitored and 

evaluated to measure the effectiveness of the program in meeting refuge purposes. Based on 

monitoring data, public use regulations could become more restrictive in the future. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-8 Appendix B. Compatibility Determinations 

Justification: 

Wildlife observation, photography, and environmental education and interpretation are priority 

public uses of the NWRS. Providing opportunities for these activities will contribute toward fulfilling 

provisions of the National Wildlife Refuge System Administration Act, as amended in 1997, and one 

of the goals of Dungeness NWR. Wildlife observation, photography, and interpretation will provide 

an excellent forum for allowing public access and increasing understanding of refuge resources. The 

educational possibilities provided by these opportunities will outweigh any anticipated negative 

impacts associated with implementation of the program. The stipulations outlined above, as well as 

the best management practices identified, will minimize potential impacts relative to wildlife/human 

interactions. 

Although all of these activities can result in disturbance to wildlife, disturbance will be limited in 

time and space. There is more than an adequate amount of undisturbed habitat available to the 

majority of refuge wildlife for escape and cover. 

It is anticipated that wildlife populations will find sufficient food resources and resting places such 

that their abundance and use of the Refuge will not be measurably lessened from wildlife 

observation, photography, and environmental education and interpretation activities. The relatively 

limited number of individuals expected to be adversely affected due to allowing these uses will not 

cause wildlife populations to materially decline, the physiological condition and production of refuge 

wildlife species will not be impaired, their behavior and normal activity patterns will not be altered 

dramatically, and their overall welfare will not be negatively impacted. 

Thus, allowing interpretation, environmental education, wildlife observation, and photography to 

occur with stipulations outlined above will not materially detract or interfere with achieving 

Dungeness NWR purposes or the NWRS mission, and in some instances may benefit refuge 

purposes. For example, an educated public is one less likely to damage natural and cultural resources 

and is more likely to be supportive of funding for national wildlife refuges and other public land. 

Mandatory Re-Evaluation Date: 

 X Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-9 

References: 

Dobb, E. 1998. Reality check: the debate behind the lens. Audubon 100(1):44-51, 98-99. 

Gabrielsen, G.W. and E.N. Smith. 1995. Physiological responses of wildlife to disturbance. Pages 

95-107 in: R.L. Knight and K.J. Gutzwiller, eds. Wildlife and recreationists: coexistence through 

management and research. Washington, D.C.: Island Press. 

Klein, M.L. 1993. Waterbird behavioral responses to human disturbances. Wildlife Society Bulletin 

21:31-39. 

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 51-70 in: R.L. Knight 

and K.J. Gutzwiller, eds. Wildlife and recreationists: coexistence through management and research. 

Washington, D.C.: Island Press. 

Morton, J.M. 1995. Management of human disturbance and its effects on waterfowl. Pages F59- F86 

in: W.R. Whitman, T. Strange, L. Widjeskog, R. Whittemore, P. Kehoe, and L. Roberts, eds. 

Waterfowl habitat restoration, enhancement and management in the Atlantic flyway. 3rd edition. 

Dover, DE: Environmental Management Committee, Atlantic Flyway Council Technical Section, 

and the Delaware Division of Fish and Wildlife. 

Smith, L. and J.D. Hunt. 1995. Nature tourism: impacts and management. Pages 203-219 in: R.L. 

Knight and K.J. Gutzwiller, eds. Wildlife and recreationists: coexistence through management and 

research. Washington, D.C.: Island Press. 

USFWS. 1997. Management of public use for Dungeness National Wildlife Refuge – final 

environmental assessment. U.S. Department of Interior, Fish and Wildlife Service. Sequim, WA. 53 

pp. On file at the Washington Maritime National Wildlife Refuge Complex Headquarters. Sequim, 

Washington. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-11 

Compatibility Determination 

Use: Research, Scientific Collecting, and Surveys 

Research: Planned, organized, and systematic investigation of a scientific nature. 

Scientific collecting: Gathering of refuge natural resources or cultural artifacts for scientific 

purposes. 

Surveys: Scientific inventory or monitoring. 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for- (1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-12 Appendix B. Compatibility Determinations 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

National Wildlife Refuge System Mission: 

“The mission of the [National Wildlife Refuge] System is to administer a national network of 

lands and waters for the conservation, management, and where appropriate, restoration of the 

fish, wildlife, and plant resources and their habitats within the United States for the benefit of 

present and future generations of Americans.” (National Wildlife Refuge System 

Administration Act of 1966 (16 U.S.C. 668dd-668ee), as amended by the National Wildlife 

Refuge System Improvement Act of 1997 (Public Law 105-57). 

Description of Use(s): 

The refuge staff receives periodic requests from non-Service entities (e.g., universities, state or 

territorial agencies, other Federal agencies, nongovernmental organizations) to conduct research, 

scientific collecting, and surveys on refuge lands. These project requests can involve a wide range of 

natural and cultural resources as well as public-use management issues including basic 

absence/presence surveys, collection of new species for identification, habitat use and life-history 

requirements for specific species/species groups, practical methods for habitat restoration, extent and 

severity of environmental contaminants, techniques to control or eradicate pest species, effects of 

climate change on environmental conditions and associated habitat/wildlife response, identification 

and analyses of paleontological specimens, wilderness character, modeling of wildlife populations, 

bioprospecting, and assessing response of habitat/wildlife to disturbance from public uses. Projects 

may be species-specific, refuge-specific, or evaluate the relative contribution of the refuge lands to 

larger landscapes (e.g., ecoregion, region, flyway, national, international) issues and trends. 

The Service’s Research and Management Studies (4 RM 6) and Appropriate Refuge Uses (603 FW 

1.10D(4)) policies indicate priority for scientific investigatory studies that contribute to the 

enhancement, protection, use, preservation, and management of native wildlife populations and their 

habitat as well as their natural diversity. Projects that contribute to refuge-specific needs for resource 

and/or wilderness management goals and objectives, where applicable, will be given a higher priority 

over other requests. 

Availability of Resources: 

Refuge staff responsibilities for projects by non-Service entities will be primarily be limited to the 

following: review of proposals, prepare SUP(s) and other compliance documents (e.g., Section 7 of 

the Endangered Species Act of 1973, Section 106 of the National Historic Preservation Act), and 

monitor project implementation to ensure that impacts and conflicts remain within acceptable levels 

(compatibility) over time. Additional administrative support, logistical and operational support may 

also be provided depending on each specific request. Estimated costs for one-time (e.g., prepare 

SUP) and annually re-occurring tasks by refuge staff and other Service employees will be determined 

for each project. Sufficient funding in the general operating budget of the Refuge must be available 

to cover expenses for these projects. The terms and conditions for funding and staff support 

necessary to administer each project on the Refuge will be clearly stated in the SUP(s). 

The Refuge has the following staffing and funding to administratively support and monitor research 

that is currently taking place on refuge lands (see table below). Any substantial increase in the 

number of projects will create a need for additional resources to oversee the administration and 

monitoring of the investigators and their projects. Any substantial additional costs above those 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-13 

itemized below may result in finding a project not compatible unless expenses are offset by the 

investigator(s), sponsoring agency, or organization. 

Category and Itemization One-time ($) Annual ($/yr) 

Administration and management $1,000 

Maintenance $500 

Monitoring $1,750 

Special equipment, facilities, or improvement 

Totals $3,250 

Itemized costs in the previous table are current estimates calculated using 30% of the base cost for a 

GS-11 Refuge Biologist and a 3% cost of a GS-11 Refuge Manager. 

Anticipated Impacts of the Use(s): 

Use of the Refuge to conduct research, scientific collecting, and surveys will generally provide 

information that will benefit fish, wildlife, plants, and their habitats. Scientific findings gained 

through these projects provide important information regarding life-history needs of species and 

species groups as well as identify or refine management actions to achieve resource management 

objectives in refuge management plans (especially CCPs). Reducing uncertainty regarding wildlife 

and habitat responses to refuge management actions in order to achieve desired outcomes reflected in 

resource management objectives is essential for adaptive management in accordance with 522 DM 1. 

If project methods impact or conflict with refuge-specific resources, priority wildlife-dependent 

public uses, other high-priority research, wilderness, and refuge habitat and wildlife management 

programs, then it must be clearly demonstrated that its scientific findings will contribute to resource 

management and that the project cannot be conducted off refuge lands for the project to be 

compatible. The investigator(s) must identify methods/strategies in advance required to minimize or 

eliminate the potential impact(s) and conflict(s). If unacceptable impacts cannot be avoided, then the 

project will not be compatible. Projects that represent public or private economic use of the natural 

resources of any national wildlife refuge (e.g., bioprospecting), in accordance with 16 U.S.C. 715s, 

must contribute to the achievement of the national wildlife refuge purposes or the National Wildlife 

Refuge System mission to be compatible (50 C.F.R. 29.1). 

 

Impacts will be project- and site-specific, and they will vary depending upon nature and scope of the 

field work. Data collection techniques will generally have minimal animal mortality or disturbance, 

habitat destruction, no introduction of contaminants, or no introduction of non-indigenous species. In 

contrast, projects involving the collection of biotic samples (plants or animals) or requiring intensive 

ground-based data or sample collection will have short-term impacts. To reduce impacts, the 

minimum number of samples (e.g., water, soils, vegetative litter, plants, macroinvertebrates, 

vertebrates) will be collected for identification and/or experimentation and statistical analysis. Where 

possible, researchers will coordinate and share collections to reduce sampling needed for multiple 

projects. For example, if one investigator collects fish for a diet study and another research examines 

otoliths, then it may be possible to accomplish sampling for both projects with one collection effort. 

Investigator(s) obtaining required State or Territorial, and Federal collecting permits will also ensure 

minimal impacts to fish, wildlife, plants, and their habitats. If, even after incorporating the above 

strategies, projects would result in long-term or cumulative effects, projects would not be compatible. 

A Section 7 consultation under the Endangered Species Act (16 U.S.C. 1531-1544, 87 Stat. 884, as 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-14 Appendix B. Compatibility Determinations 

amended Public Law 93-205) will be required for activities that may affect a federally listed species 

and/or critical habitat. Only projects that have no effect or will result in not likely to adversely affect 

determinations will be considered compatible. 

Spread of invasive plants and/or pathogens is possible from ground disturbance and/or transportation 

of project equipment and personnel, but it will be minimized or eliminated by requiring proper 

cleaning of investigator equipment and clothing as well as quarantine methods, where necessary. If 

after all practical measures are taken and unacceptable spread of invasive species is anticipated to 

occur, then the project will be found not compatible without a restoration or mitigation plan. 

There also could be localized and temporary effects from vegetation trampling, collecting of soil and 

plant samples, or trapping and handling of wildlife. Impacts may also occur from infrastructure 

necessary to support a projects (e.g., permanent transects or plot markers, exclosure devices, 

monitoring equipment, solar panels to power unattended monitoring equipment). Some level of 

disturbance is expected with these projects, especially if investigator(s) enter areas closed to the 

public and collect samples or handle wildlife. However, wildlife disturbance (including altered 

behavior) will usually be localized and temporary in nature. Where long-term or cumulative 

unacceptable effects cannot be avoided, the project will not be found compatible. 

At least 6 months before initiation of field work (unless an exception is made by prior approval of the 

refuge manager), project investigator(s) must submit a detailed proposal using the format provided in 

Attachment 1. Project proposals will be reviewed by refuge staff and others, as needed, to assess the 

potential impacts (short-term, long-term, and cumulative) relative to benefits of the investigation to 

refuge management issues and understanding of natural systems. This assessment will form the 

primary basis for allowing or denying a specific project. Projects which result in unacceptable refuge 

impacts will not be found compatible. If allowed and found compatible after approval, all projects 

also will be assessed during implementation to ensure impacts and conflicts remain within acceptable 

levels. 

If the proposal is approved, then the refuge manager will issue a SUP(s) with required stipulations 

(terms and conditions) of the project to avoid and/or minimize potential impacts to refuge resources 

as well as conflicts with other public-use activities and refuge field management operations. After 

approval, projects also are monitored during implementation to ensure impacts and conflicts remain 

within acceptable levels based upon documented stipulations. 

The combination of stipulations identified above and conditions included in any SUP(s) will ensure 

that proposed projects contribute to the enhancement, protection, conservation, and management of 

native wildlife populations and their habitats on the Refuge. As a result, these projects will help 

fulfill refuge purpose(s); contribute to the Mission of the NWRS; and maintain the biological 

integrity, diversity, and environmental health of the Refuge. 

Projects which are not covered by the CCP (objectives under Goal 4 [Gather scientific information 

(surveys, research, and assessments) to support adaptive management decisions under objectives for 

Goals 1-3.]) will require additional NEPA documentation. 

Public Review and Comment: 

This compatibility determination was submitted for 90-day public review and comment as an 

appendix to the Draft Comprehensive Conservation Plan and Environmental Assessment for 

Dungeness NWR. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-15 

Determination: (check one below) 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Each project will require a SUP. Annual or other short-term SUPs are preferred; however, some 

permits will be a longer period, if needed, to allow completion of the project. All SUPs will have a 

definite termination date in accordance with 5 RM 17.11. Renewals will be subject to refuge manager 

review and approval based timely submission of and content in progress reports, compliance with 

SUP stipulations, and required permits. 

 Projects will adhere to scientifically defensible protocols for data collection, where available 

and applicable. 

 Investigators must possess appropriate and comply with conditions of State or Territorial and 

Federal permits for their projects. 

 If unacceptable impacts to natural resources or conflicts arise or are documented by the 

refuge staff, then the refuge manager can suspend, modify conditions of, or terminate an ongoing project already permitted by SUP(s) on the Refuge. 

 Progress reports are required at least annually for multiple-year projects. The minimum 

required elements for a progress report will be provided to investigator(s) (see Attachment 2). 

 Final reports are due one year after completion of the project unless negotiated otherwise 

with the refuge manager. 

 Continuation of existing projects will require approval by the Refuge Manager. 

 The refuge staff will be given the opportunity to review draft manuscript(s) from the project 

before being submitted to a scientific journal(s) for consideration of publication. 

 The refuge staff will be provided with copies (reprints) of all publications resulting from a 

refuge project. 

 The refuge staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the project. 

 Upon completion of the project or annually, all equipment and markers (unless required for 

long-term projects), must be removed and sites must restored to the refuge manager’s 

satisfaction. Conditions for clean-up and removal of equipment and physical markers will be 

stipulated in the SUP(s). 

 All samples collected on refuge lands are the property of the Service even while in the 

possession of the investigator(s). Any future work with previously collected samples not 

clearly identified in the project proposal will require submission of a subsequent proposal for 

review and approval. In addition, a new SUP will be required for additional project work. For 

samples or specimens to be stored at other facilities (e.g., museums), a memorandum of 

understand will be necessary (see Attachment 3). 

 Sampling equipment as well as investigator(s) clothing and vehicles (e.g., ATV, boats) will 

be thoroughly cleaned (free of dirt and plant material) before being allowed for use refuge 

lands to prevent the introduction and/or spread of pests. 

 The NWRS, specific refuge, names of refuge staff and other Service personnel that supported 

or contributed to the project will be appropriately cited and acknowledged in all written and 

oral presentations resulting from projects on refuge lands. 

 At any time, refuge staff may accompany investigator(s) in the field. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-16 Appendix B. Compatibility Determinations 

 Investigator(s) and support staff will follow all refuge-specific regulations that specify access 

and travel on the Refuge. 

Justification: 

Research, scientific collecting, and surveys on refuge lands are inherently valuable to the Service 

because they will expand scientific information available for resource management decisions. In 

addition, only projects which directly or indirectly contribute to the enhancement, protection, use, 

preservation, and management of refuge wildlife populations and their habitats generally will be 

authorized on refuge lands. In many cases, if it were not for the refuge staff providing access to 

refuge lands and waters along with some support, the project would never occur and less scientific 

information would be available to the Service to aid in managing and conserving the refuge 

resources. By allowing the use to occur under the stipulations described above, it is anticipated that 

wildlife species which could be disturbed during the use will find sufficient food resources and 

resting places so their abundance and use will not be measurably lessened on the Refuge. 

Additionally, it is anticipated that monitoring, as needed, will prevent unacceptable or irreversible 

impacts to fish, wildlife, plants, and their habitats. As a result, these projects will not materially 

interfere with or detract from fulfilling refuge purpose(s); contributing to the Mission of the NWRS; 

and maintaining the biological integrity, diversity, and environmental health of the Refuge. 

Mandatory Re-evaluation Date: (provide month and year for “allowed” uses only) 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

 X Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below)

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-18 Appendix B. Compatibility Determinations 

Attachment 1 

FORMAT FOR PROPOSALS TO CONDUCT RESEARCH OR LONG-TERM 

MONITORING ON NATIONAL WILDLIFE REFUGES 

A Special Use Permit (SUP) is required to conduct research and/or long-term monitoring on refuge 

lands. To receive a SUP, a detailed project proposal using the following format must be submitted to 

the refuge manager approximately 6 months prior to the start of the project. 

Title: 

Principal Investigator(s): 

Provide the name(s) and affiliation(s) of all principal investigator(s) that will be responsible for 

implementation of the research and/or long-term monitoring described in the proposal. In addition, 

provide a brief description or attach vitae of expertise for principal investigator(s) germane to work 

described in the proposal. 

Background and Justification: 

In a narrative format, describe the following as applicable: 

 The resource management issue (e.g., decline in Pisonia rainforest) and/or knowledge gap 

regarding ecological function that currently exists with any available background 

information. 

 Benefit of project findings (e.g., management implications) to resources associated with the 

Refuge. 

 Potential consequences if the conservation issue and/or knowledge gap regarding ecological 

function is not addressed. 

Objectives: 

Provide detailed objective(s) for the proposed project. 

Methods and Materials: 

Provide a detailed description of the methods and materials associated with field and laboratory 

work (if applicable) to be conducted for the project. Methods should include the following: 

 study area(s) 

 number of samples; 

 sampling dates and locations 

 sampling techniques 

 data analyses including statistical methods and significance levels. 

Previously published methods should be cited without explanation; whereas, new or modified 

techniques should be described in detail. Include number of personnel as well as all facilities and 

equipment (e.g., vehicles, boats, structures, markers) required to collect samples/data. Provide a 

clear description of the relationships among study objectives, field methods, and statistical analyses. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-19 

Permits: 

Identify all State or Territorial and Federal permits required if applicable. 

Potential Impacts to Refuge Resources: 

Describe potential impacts to threatened or endangered species as well as other refuge plants, 

wildlife, and fish species that could result from the implementation of project activities on the Refuge. 

Consider the cumulative impacts associated with this project. 

Animal Welfare Plan: 

If appropriate, attach a copy of the Institutional Animal Care and Use review and/or animal welfare 

plans that are required by the principle investigator’s affiliation. 

Partnerships and Funding Sources: 

List other participating institutions, agencies, organizations, or individuals as well as the nature and 

magnitude of their cooperative involvement (e.g., funding, equipment, personnel). 

Project Schedule: 

Provide estimated initiation and completion dates for field sampling, laboratory work, data analyses, 

and report/manuscript preparation. If the project is divided into phases to be accomplished 

separately provide separate initiation and completion dates for each phase. 

Reports and Raw Data: 

Establish a schedule for annual progress and final reports; include adequate time for peer review of 

the final report/manuscript. Draft reports/manuscripts should be submitted to the refuge manager for 

review prior to submission for consideration of publication. At the conclusion of a research study 

(manuscripts accepted for publication), an electronic copy of the data (e.g., GIS vegetation layers, 

animal species composition and numbers, genetics) should be provided to the refuge manager. For 

long-term monitoring projects, the Service also requires raw data for management and planning 

purposes for the Refuge. 

Publications: 

Describe the ultimate disposition of study results as publications in scientific journals, presentation 

at professional symposiums, or final reports. 

Disposition of Samples: 

If the project entails the collection of biotic and/or abiotic (e.g., sediment) samples, then describe 

their storage. Although the samples may be in the possession of scientists for the purposes of 

conducting the project in accordance with the SUP, the Service retains ownership of all samples 

collected on refuge lands. If the samples will be used for subsequent research activities that are not 

described within the original proposal, a new proposal must be submitted to the refuge manager to 

obtain a SUP before initiation of the follow-up project. After conclusion of the research activities, 

consult with the refuge manager regarding the final disposition of the samples. If specimens will be 

curated at a museum, then prepare a MOU using the format provided in Attachment 3. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-20 Appendix B. Compatibility Determinations 

Attachment 2 

ANNUAL PROGRESS REPORTS FOR REFUGE RESEARCH AND LONG-TERM 

MONITORING PROJECTS 

Study title: 

Fiscal year: 

Progress: 

In a narrative format, summarize the work that was completed on the study including the number and 

types of samples collected and/or data analyses. 

Important findings: 

In narrative format, generally describe any conclusions and/or management recommendations that 

may be drawn from the work completed to date. 

Describe problems encountered: 

In narrative format, describe any problems that were encountered during the year and their effects 

upon the study. 

Proposed resolution to problems: 

For each problem encountered, describe the actions that have been taken to remediate it. 

Preparer: 

Date prepared: 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-21 

Attachment 3 

MEMORANDUM OF UNDERSTANDING 

FOR CURATORIAL SERVICES 

BETWEEN THE 

(Name of the Federal agency) 

AND THE 

(Name of the Repository) 

This Memorandum of Understanding is entered into this (day) day of (month and year), between 

the United States of America, acting by and through the (name of the Federal agency), hereinafter 

called the Depositor, and the (name of the Repository), hereinafter called the Repository, in the 

State/Territory of (name of the State/Territory).

The Parties do witnesseth that

WHEREAS, the Depositor has the responsibility under Federal law to preserve for future use certain 

collections of paleontological specimens and/or biological samples as well as associated records, 

herein called the Collection, listed in Attachment A which is attached hereto and made a part hereof, 

and is desirous of obtaining curatorial services; and

WHEREAS, the Repository is desirous of obtaining, housing and maintaining the Collection, and 

recognizes the benefits which will accrue to it, the public and scientific interests by housing and 

maintaining the Collection for study and other educational purposes; and

WHEREAS, the Parties hereto recognize the Federal Government’s continued ownership and control 

over the Collection and any other U.S. Government-owned personal property, listed in Attachment B 

which is attached hereto and made a part hereof, provided to the Repository, and the Federal 

Government’s responsibility to ensure that the Collection is suitably managed and preserved for the 

public good; and

WHEREAS, the Parties hereto recognize the mutual benefits to be derived by having the Collection 

suitably housed and maintained by the Repository;

NOW THEREFORE, the Parties do mutually agree as follows:

1. The Repository shall:

a. Provide for the professional care and management of the Collection from the (names 

of the resources) sites, assigned (list site numbers) site numbers. The collections 

were recovered in connection with the (name of the Federal or federallyauthorized project) project, located in (name of the nearest city or town), (name 

of the county, if applicable) county, in the State/Territory of (name of the 

State/Territory)-

b. Assign as the Curator, the Collections Manager and the Conservator having 

responsibility for the work under this Memorandum, persons who are qualified 

museum professionals and whose expertise is appropriate to the nature and content of 

the Collection. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-22 Appendix B. Compatibility Determinations 

c. Begin all work on or about (month, date and year) and continue for a period of 

(number of years) years or until sooner terminated or revoked in accordance with 

the terms set forth herein. 

d. Provide and maintain a repository facility having requisite equipment, space and 

adequate safeguards for the physical security and controlled environment for the 

Collection and any other U.S. Government-owned personal property in the 

possession of the Repository. 

e. Not in any way adversely alter or deface any of the Collection except as may be 

absolutely necessary in the course of stabilization, conservation, scientific study, 

analysis and research. Any activity that will involve the intentional destruction of any 

of the Collection must be approved in advance and in writing by the Depositor. 

f. Annually inspect the facilities, the Collection and any other U.S. Government-owned 

personal property. Every (number of years) years inventory the Collection and any 

other U.S. Government-owned personal property. Perform only those conservation 

treatments as are absolutely necessary to ensure the physical stability and integrity of 

the Collection, and report the results of all inventories, inspections and treatments to 

the Depositor. 

g. Within five (5) days of discovery, report all instances of and circumstances 

surrounding loss of, deterioration and damage to, or destruction of the Collection and 

any other U.S. Government-owned personal property to the Depositor, and those 

actions taken to stabilize the Collection and to correct any deficiencies in the physical 

plant or operating procedures that may have contributed to the loss, deterioration, 

damage or destruction. Any actions that will involve the repair and restoration of any 

of the Collection and any other U.S. Government-owned personal property must be 

approved in advance and in writing by the Depositor. 

h. Review and approve or deny requests for access to or short-term loan of the 

Collection (or a part thereof) for scientific and educational uses. In addition, refer 

requests for consumptive uses of the Collection (or a part thereof) to the Depositor for 

approval or denial. 

i. Not mortgage, pledge, assign, repatriate, transfer, exchange, give, sublet, discard or 

part with possession of any of the Collection or any other U.S. Government-owned 

personal property in any manner to any third party either directly or indirectly 

without the prior written permission of the Depositor, and redirect any such request to 

the Depositor for response. In addition, not take any action whereby any of the 

Collection or any other U.S. Government-owned personal property shall or may be 

encumbered, seized, taken in execution, sold, attached, lost, stolen, destroyed or 

damaged. 

2. The Depositor shall: 

a. On or about (month, date and year), deliver or cause to be delivered to the Repository 

the Collection, as described in Attachment A, and any other U.S. Government-owned 

personal property, as described in Attachment B. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-23 

b. Assign as the Depositor’s Representative having full authority with regard to this 

Memorandum, a person who meets pertinent professional qualifications. 

c. Every (number of years) years, jointly with the Repository’s designated 

representative, have the Depositor’s Representative inspect and inventory the 

Collection and any other U.S. Government-owned personal property, and inspect the 

repository facility. 

d. Review and approve or deny requests for consumptively using the Collection (or a 

part thereof). 

3. Removal of all or any portion of the Collection from the premises of the Repository for 

scientific or educational purposes; any conditions for handling, packaging and transporting 

the Collection; and other conditions that may be specified by the Repository to prevent 

breakage, deterioration and contamination. 

4. The Collection or portions thereof may be exhibited, photographed or otherwise reproduced 

and studied in accordance with the terms and conditions stipulated in Attachment C to this 

Memorandum. All exhibits, reproductions and studies shall credit the Depositor, and read as 

follows: “Courtesy of the (name of the Federal agency).” The Repository agrees to provide 

the Depositor with copies of any resulting publications. 

5. The Repository shall maintain complete and accurate records of the Collection and any other 

U.S. Government-owned personal property, including information on the study, use, loan and 

location of said Collection which has been removed from the premises of the Repository. 

6. Upon execution by both parties, this Memorandum of Understanding shall be effective on 

this (day) day of (month and year), and shall remain in effect for (number of years) years, 

at which time it will be reviewed, revised, as necessary, and reaffirmed or terminated. This 

Memorandum may be revised or extended by mutual consent of both parties, or by issuance 

of a written amendment signed and dated by both parties. Either party may terminate this 

Memorandum by providing 90 days written notice. Upon termination, the Repository shall 

return such Collection and any other U.S. Government-owned personal property to the 

destination directed by the Depositor and in such manner to preclude breakage, loss, 

deterioration and contamination during handling, packaging and shipping, and in accordance 

with other conditions specified in writing by the Depositor. If the Repository terminates, or is 

in default of, this Memorandum, the Repository shall fund the packaging and transportation 

costs. If the Depositor terminates this Memorandum, the Depositor shall fund the packaging 

and transportation costs. 

7. Title to the Collection being cared for and maintained under this Memorandum lies with the 

Federal Government. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-24 Appendix B. Compatibility Determinations 

IN WITNESS WHEREOF, the Parties hereto have executed this Memorandum. 

Signed: (signature of the Federal Agency Official) Date: (date) 

Signed: (signature of the Repository Official) Date: (date) 

Attachment 3A: Inventory of the Collection 

Attachment 3B: Inventory of any other U.S. Government-owned Personal Property 

Attachment 3C: Terms and Conditions Required by the Depositor 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-25 

Compatibility Determination 

Use: Fishing, General and Other 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for- (1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-26 Appendix B. Compatibility Determinations 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use(s): 

Two types of fishing occur at Dungeness National Wildlife Refuge; fin fish (salmon species 

primarily) and shell fish (mollusks and Dungeness crab). The Refuge has jurisdiction over the land 

base including shorelines to mean high water and the second class tidelands under a perpetual 

easement from the State of Washington and the waters associated with those tidelands. Anglers 

accessing the fishing opportunities on the Refuge do so by fishing from the shoreline or from boats. 

Finfishing from the shoreline occurs on the Strait of Juan de Fuca side of Dungeness Spit from the 

western boundary east to the New Dungeness Light Station (Zones 1, 2 and 3) and from boats in 

refuge waters associated with the Refuge’s second class tidelands on the Dungeness Harbor and Bay 

sides of Dungeness Spit outside a 100 yard buffer zone below Mean High Tide (Zone 5). Shellfishing 

occurs on the Dungeness Harbor side from the base of Dungeness Spit out to 1⁄2 mile (Zone 2)—foot 

access only—and on the Refuge’s second-class tidelands and waters associated with these tidelands 

on the Dungeness Harbor and Bay sides of Dungeness Spit outside a 100 yard buffer zone below 

Mean High Tide (Zone 5) – boat access only. Public uses of Zones 2 and 5 are restricted to May 15 

to September 30. All fishing is conducted in accordance with State regulations. 

This compatibility determination (CD) reassesses and re-evaluates recreational fishing from all 

shorelines and Dungeness Harbor and Bay areas within the refuge boundary. Under this use fishing 

will be allowed consistent with State regulations. Specific species/numbers to be taken and open 

periods will be set by the Washington Department of Fish and Wildlife to match adjacent areas open 

to fishing, however seasonal closures of Refuge Zones 2 and 5 will continue. 

Recreational fishing (a wildlife-dependent activity) has been identified in the National Wildlife 

Refuge System Administration Act, as amended, as a priority public use, provided it is compatible 

with the purpose for which the Refuge was established. 

Availability of Resources 

The recreational fishing program will not require any new infrastructure or personnel. Administration 

of a fishing program will require coordination with the State of Washington and require monitoring 

and some law enforcement patrols; however refuge staff is in place and capable of conducting these 

additional duties. 

Category One Time Expenses Recurring Expenses 

Monitoring/Law Enforcement $4,000 

Signage/Brochures $3,000 $500 

Maintenance $1,500 

Totals $3,000 $6,000 

Anticipated Impacts of the Use(s): 

As a solitary and stationary activity, fishing tends to be less disturbing to wildlife than hunting or 

motorized boating (Tuite et al. 1983). It is well recognized that fishing can give many people a 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-27 

deeper appreciation of fish and wildlife and a better understanding of the importance of conserving 

habitat, which has ultimately contributed to the Refuge System mission. A goal of Dungeness 

National Wildlife Refuge is to provide opportunities for wildlife-dependent recreation. Fishing is one 

of the six priority public uses in the National Wildlife Refuge System. Of key concern, then, is to 

manage the activity to keep any potential adverse impacts within acceptable limits. 

Any angler activities on the Refuge are and will remain consistent with State guidelines. Related 

impacts for fish stocks associated with recreational fishing in the Strait of Juan de Fuca adjacent to 

the Refuge and Dungeness Harbor and Bay, are estimated annually and taken into consideration by 

the State of Washington in the development of annual fishing agreements and associated regulations. 

Because fishing regulations are established to provide a sustainable fish resource, impacts to fish 

populations from recreational fishing activity are expected to be minor. 

Additional disturbance will be caused to birds and other wildlife using the open waters and where 

fishing will occur. Fishing activities may influence the composition of bird communities, as well as 

abundance, and productivity of waterbirds (Bell and Austin 1985, Bouffard 1982, Cooke 1987, 

Edwards and Bell 1985, Tydeman 1977). Anglers often fish in shallow, sheltered bays and creeks 

that birds prefer, negatively impacting distribution and abundance of waterfowl, grebes, and coots 

(Cooke 1987). Increases in anglers and associated shoreline activity discouraged waterfowl using 

otherwise suitable habitat (Jahn and Hunt 1964). Anglers influenced the numbers, behavior, and 

diurnal distribution of avian scavengers present at sites in Washington, when compared to nonfishing days (Knight et al. 1991). Shoreline activities, such as human noise, can cause some birds to 

flush and go elsewhere. 

Boating associated with fishing can alter bird distribution, reduce use of particular habitats or entire 

areas by waterfowl and other water-birds, alter feeding behavior and nutritional status, and cause 

premature departure from areas (Knight and Cole 1995). Boating close to shore may disturb harbor 

seals hauled out on the beach. Impacts of motorized boating can occur even at low densities, given 

their noise, speed, and ability to cover extensive areas in a short amount of time. (See Boating 

Compatibility Determination.) 

Despite the potential impacts that fishing and supporting activities (boating) can have on wildlife, 

impacts to wildlife from allowing fishing are expected to be minor for the following reasons. The 100 

yard buffer from the mean high tide on the Harbor and Bay side of Dungeness and Graveyard spits 

coupled with the requirement for boats to have no wake will minimize disturbance to any nesting 

seabirds or shorebirds and resting or pupping harbor or elephant seals. The majority of waterfowl use 

on the Refuge occurs in the fall, winter and spring months, with some birds arriving as early as 

September and October. Because the majority of the fishing activity occurs in the summer and fall 

(through mid-October), disturbance to waterfowl species is reduced by annual closing refuge waters 

to all use from October 1 to May 14. 

Public Review and Comment: 

This compatibility determination was submitted for 90-day public review and comment as an 

appendix to the Draft Comprehensive Conservation Plan and Environmental Assessment for 

Dungeness NWR.

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-28 Appendix B. Compatibility Determinations 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

The requirements laid out in the preferred alternative of the 1997 Environmental Assessment – 

“Management of Public Use for Dungeness National Wildlife Refuge” (USFWS 1997) are adopted 

as stipulations to ensure compatibility and include: 

User stipulations: 

 Graveyard Spit and the tip of Dungeness Spit are closed to public access 

 In Zone 1 – Beach in front of bluffs –Fin fishing permitted year-round 

 In Zone 2 – Base of Dungeness Spit out to 1⁄2 mile – Fin fishing permitted on the Strait of 

Juan de Fuca side year-round. Fin fishing and shell fishing permitted on the Dungeness 

Harbor side from May 15 to September 30 – foot access only. From October 1 to May 14, the 

Harbor side of Zone 2 is closed to all access. 

 In Zone 3 – Strait side of Dungeness Spit from 1⁄2 mile to New Dungeness Light Station – Fin 

fishing permitted year-round. 

 In Zone 4 – Dungeness Spit from lighthouse to end of spit, the Harbor and Bay sides of 

Dungeness Spit, and all of Graveyard Spit including a 100-yard buffer zone below the mean 

high tide line - closed to public access year-round. Where the refuge boundary does not 

accommodate a 100 yard buffer, the buffer is slightly narrower. 

 In Zone 5 – Refuge waters and tidelands on the Harbor and Bay sides of Dungeness and 

Graveyard spits outside of the 100 yard buffer zone – fin fishing and shell fishing permitted 

from May 15 through September 30 – boat access only. From October 1 to May 14 this zone 

is closed to all public access. 

The response of wildlife to these modifications in public use activities will be monitored and 

evaluated to measure the effectiveness of the program in meeting refuge purposes. Based on 

monitoring data, public use regulations could become more restrictive in the future. 

Justification: 

Recreational fishing is one of the six priority public uses of the National Wildlife Refuge System. 

Providing a quality fishing program contributes to achieving one of the Refuge’s goals. Despite the 

potential impacts that fishing and supporting activities (boating) can have on wildlife, impacts to 

wildlife from allowing fishing are expected to be minor for the following reasons. The 100 yard 

buffer from the mean high tide on the Harbor and Bay side of Dungeness and Graveyard spits 

coupled with the requirement for boats to have no wake will minimize disturbance to any nesting 

seabirds or shorebirds and resting or pupping harbor or elephant seals. The majority of waterfowl use 

on the Refuge occurs in the fall, winter and spring months, with some birds arriving as early as 

September and October. Because the majority of the fishing activity occurs in the summer and fall 

(through mid-October), disturbance to waterfowl species is reduced by annual closing refuge waters 

to all use from October 1 to May 14. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-29 

Mandatory Re-Evaluation Date: 

 X Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

References: 

Bell, D.V. and L.W. Austin. 1985. The game-fishing season and its effects on overwintering 

wildfowl. Biological Conservation 33:65-80. 

Bouffard, S.H. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the Forty-Seventh North American Wildlife and Natural Resources Conference 

47:553-556. 

Cooke, A.S. 1987. Disturbance by anglers of birds at Grafam Water. ITE Symposium 19:15-22. 

Edwards, R.W. and D.V. Bell. 1985. Fishing in troubled waters. New Science 1446(7 March):19-21. 

Jahn, L.R. and R.A. Hunt. 1964. Duck and coot ecology and management in Wisconsin. Technical 

Bulletin No. 33. Wisconsin Conservation Department. Madison, WI. 212 pp. 

Knight, R.L. and D.N. Cole. 1995. Factors that influence wildlife responses to recreationists. Pages 

71-79 in: R.L. Knight and K.J. Gutzwiller, eds. Wildlife and recreationists: coexistence through 

management and research. Washington, D.C.: Island Press 

Knight, R.L., D.P. Anderson, and N.Y. Marr. 1991. Responses of an avian scavenging guild to 

anglers. Biological Conservation 56:195-205. 

Tuite, C.H., M. Owen, and D. Paynther. 1983. Interaction between wildfowl and recreation at 

Llangorse Lake and Talybont Reservoir, South Wales. Wildfowl 34:48-63. 

Tydeman, C.F. 1977. The importance of the close fishing season to breeding bird communities. 

Journal of Environmental Management 5:289-296. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-31 

Compatibility Determination 

Use: Fishing, Other, Tribal 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for-(1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-32 Appendix B. Compatibility Determinations 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use: 

The S’Klallam and Skokomish Tribes were signatories to the Point-No-Point Treaty with the U.S. 

Government in 1855. The S’Klallam tribe today consists of the Jamestown S’Klallam, Lower Elwha 

Klallam, and Port Gamble S’Klallam. In accordance with the Treaty, the Tribes retained the right to 

fish “at their usual and accustomed places.” The Tribes, in exercising their Treaty rights, fish in 

Dungeness Harbor and Bay by set nets or other traditional methods, or by modern or improved 

fishing techniques. The U.S. Fish and Wildlife Service recognizes that the Treaty fishing rights 

include access to National Wildlife Refuge System lands. This is a treaty right against land owned by 

the United States. Access to the Refuge is only open to Tribal members involved in fishing. In 1983, 

the USFWS and the three S’Klallam Tribes signed a Letter of Agreement for Management of the 

Tribal Fishery on Dungeness National Wildlife Refuge. The Letter of Agreement contained 8 

principles of agreement to promote mutual understanding and cooperation between the USFWS and 

the Tribes of the Point-No-Point Treaty and to provide for orderly conduct of the fishery on 

Dungeness NWR. These principles of agreement are reflected in the stipulations necessary to ensure 

compatibility. 

Availability of Resources: 

The recreational fishing program will not require any new infrastructure or personnel. Administration 

of the Tribal fishing program will require coordination with the Point-No-Point Treaty Tribes and 

require monitoring and some law enforcement patrols; however refuge staff is in place and capable of 

conducting these duties. 

Category One Time Expenses Recurring Expenses

Administration- Coordination 

with tribes 

 $1,500 

Monitoring/Law Enforcement $2,500 

Totals $4,000 

Anticipated Impacts of the Use(s): 

Any Tribal angler activities on the Refuge are and will remain consistent with Tribal guidelines. 

Related impacts for fish stocks associated with Tribal fishing in Dungeness Harbor and Bay are 

estimated annually and taken into consideration by the State of Washington and Tribes as comanagers of the fishery in the development of annual fishing agreements and associated regulations. 

Because fishing regulations are established to provide a sustainable fish resource, impacts to fish 

populations from Tribal fishing activity are expected to be minor. 

Additional disturbance will be caused to birds and other wildlife using the open waters and where 

fishing will occur. Fishing activities may influence the composition of bird communities, as well as 

abundance, and productivity of waterbirds (Bell and Austin 1985, Bouffard 1982, Cooke 1987, 

Edwards and Bell 1985, Tydeman 1977). Anglers often fish in shallow, sheltered bays and creeks 

that birds prefer, negatively impacting distribution and abundance of waterfowl, grebes, and coots 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-33 

(Cooke 1987). Increases in anglers and associated shoreline activity discouraged waterfowl using 

otherwise suitable habitat (Jahn and Hunt 1964). Anglers influenced the numbers, behavior, and 

diurnal distribution of avian scavengers present at sites in Washington, when compared to nonfishing days (Knight et al. 1991). Shoreline activities, such as human noise, can cause some birds to 

flush and go elsewhere. Tribal members currently may set fires for camping and curing fish and 

construct temporary shelters as has been done traditionally. These activities reduce drift wood habitat 

on the spit and may result in a wildfire. 

Boating associated with fishing can alter bird distribution, reduce use of particular habitats or entire 

areas by waterfowl and other water-birds, alter feeding behavior and nutritional status, and cause 

premature departure from areas (Knight and Cole 1995). Boating close to shore may disturb harbor 

seals hauled out on the beach. Impacts of motorized boating can occur even at low densities, given 

their noise, speed, and ability to cover extensive areas in a short amount of time. (See Boating 

Compatibility Determination.) 

There will be impacts to refuge resources from Tribal fishing. Under the 1983 Letter of Agreement 

for Management of the Tribal Fishery on Dungeness NWR, Tribal members are allowed access to 

refuge closed areas in exercising their Treaty Rights. Tribal members can camp, collect drift wood 

and build fires. These activities result in wildlife displacement, reduce drift wood habitat on the spit 

and may result in a wildfire. Boating in support of the Tribal fishery can take place in waters closed 

to public use after September 30th if the fishery continues beyond that date. Wildlife species using 

these closed areas can be disturbed. In addition avian and marine mammal species may become 

entangled in Tribal nets and be injured or die. 

Despite the potential impacts that Tribal fishing and supporting activities (boating) can have on 

wildlife, impacts to wildlife from allowing fishing are expected to be minor for the following 

reasons. In most years, relatively few individuals participate in this fishery. The use is limited in time 

usually beginning in mid- September and finishing in late October before we get large numbers of 

wintering birds and there is plenty of adjacent sanctuary for disturbed wildlife to escape to. An 

additional steelhead fishery occurs from December through February but has resulted in very limited 

participation and occurs mostly outside of refuge waters in the vicinity of Cline Spit. Tribal members 

must maintain visual contact with their nets and not leave them unattended which reduces the 

incidence of bycatch of avian and marine mammal species. Fires are not to be left unattended thus 

reducing the likelihood of a wildfire event. 

Public Review and Comment: 

This compatibility determination was submitted for 90-day public review and comment as an 

appendix to the Draft Comprehensive Conservation Plan and Environmental Assessment for 

Dungeness NWR. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-34 Appendix B. Compatibility Determinations 

Stipulations Necessary to Ensure Compatibility: 

The principles of agreement as laid out in the 1983 Letter of Agreement for Management of the 

Tribal Fishery on Dungeness National Wildlife Refuge are adopted as stipulations to ensure 

compatibility and include: 

1. During the prescribed fishing seasons, established by the Tribes and the Washington 

Department of Fish and Wildlife, the Tribes (Lower Elwha Klallam, Jamestown S’Klallam 

and Port Gamble S’Klallam) of the Point-No-Point Treaty (PNPT) may conduct their fishery 

in Dungeness Harbor and Bay in compliance with tribal and applicable state regulations 

2. Access by tribal members and fish buyers to the refuge areas, which are the usual and 

accustomed fishing grounds and stations of the Tribes (Lower Elwha Klallam, Jamestown 

S’Klallam and Port Gamble S’Klallam), is limited to boat and foot. 

3. Leaving equipment (boats, nets, etc.) on the refuge lands is discouraged. The owner assumes 

all risks associated with unattended equipment 

4. The Tribes (Lower Elwha Klallam, Jamestown S’Klallam and Port Gamble S’Klallam) of the 

PNPT may set fires for camping and curing fish and construct temporary shelters as has been 

done traditionally. Fires should not be left unattended. Camp sites should be totally removed 

and fire pits extinguished and covered with sand at the conclusion of the fishing season. 

5. The USFWS prohibits pets and littering while on refuge lands 

6. The Tribal Enforcement Division will be responsible for ensuring compliance with the above 

principles and with Tribal fishery regulations and will respond to complaints from USFWS 

personnel for reasons of non-compliance. 

7. The Tribes will notify the USFWS of opening and closing dates of the fishing seasons on 

Dungeness NWR. 

8. The USFWS agrees to discourage visitors to the Dungeness NWR from vandalizing fishing 

gear or otherwise disturbing Indian fishing activities on refuge lands. 

The Letter of Agreement is 29 years old and the Refuge will contact the Tribes concerning updating 

the document. In particular the Refuge will work to modify conditions 3 and 4. Should these two 

principles be changed then the CD (stipulations necessary to ensure compatibility) will be modified 

to reflect same. 

Justification: 

The USFWS recognizes the Point-No-Point Treaty Tribes retained the right to fish “at their usual and 

accustomed places” and that Dungeness NWR is one of those places. Although there may be some 

wildlife and habitat disturbance associated with this activity, the USFWS will continue to work with 

the Tribes to minimize these effects. Although Tribal fishing and associated boating can result in 

disturbance to wildlife, disturbance is expected to be intermittent and limited in time and space. 

There are more than adequate amounts of undisturbed habitat available to the majority of wildlife for 

escape and cover. 

It is anticipated that wildlife populations will find sufficient food resources and resting places such 

that their abundance and use of the Refuge will not be measurably lessened from Tribal fishing 

activities. The relatively limited number of individual animals and plants expected to be adversely 

affected due to fishing will not cause wildlife populations to materially decline, the physiological 

condition and production of affected species will not be impaired, their behavior and normal activity 

patterns will not be altered dramatically, and their overall welfare will not be negatively impacted. 

Thus, allowing Tribal fishing to occur with stipulations (1983 Letter of Agreement for Management 

of the Tribal Fishery on Dungeness National Wildlife Refuge) will not materially detract from or 

interfere with the purposes for which the Refuge was established or the Refuge System mission. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-35 

Mandatory Re-Evaluation Date: 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

 X Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

References: 

Bell, D.V. and L.W. Austin. 1985. The game-fishing season and its effects on overwintering 

wildfowl. Biological Conservation 33:65-80. 

Bouffard, S.H. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the Forty-Seventh North American Wildlife and Natural Resources Conference 

47:553-556. 

Cooke, A.S. 1987. Disturbance by anglers of birds at Grafam Water. ITE Symposium 19:15-22. 

Edwards, R.W. and D.V. Bell. 1985. Fishing in troubled waters. New Science 1446(7 March):19-21. 

Jahn, L.R. and R.A. Hunt. 1964. Duck and coot ecology and management in Wisconsin. Technical 

Bulletin No. 33. Wisconsin Conservation Department. Madison, WI. 212 pp. 

Knight, R.L. and D.N. Cole. 1995. Factors that influence wildlife responses to recreationists. Pages 

71-79 in: R.L. Knight and K.J. Gutzwiller, eds. Wildlife and recreationists: coexistence through 

management and research. Washington, D.C.: Island Press 

Knight, R.L., D.P. Anderson, and N.Y. Marr. 1991. Responses of an avian scavenging guild to 

anglers. Biological Conservation 56:195-205. 

Tydeman, C.F. 1977. The importance of the close fishing season to breeding bird communities. 

Journal of Environmental Management 5:289-296. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-37 

Compatibility Determination 

Use: Boating (Motorized and Non-motorized) 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for-(1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-38 Appendix B. Compatibility Determinations 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use: 

Boating use addressed in this compatibility determination is for motorized and non-motorized boats, 

including kayaks and canoes in refuge waters associated with the Refuge’s second class tidelands. 

Although boating is not a wildlife-dependent public use, it does facilitate other wildlife-dependent 

uses such as fishing, wildlife observation, and photography. Boating at Dungeness NWR primarily 

supports fishing (shell fish and fin fish), although wildlife observation and photography are also 

conducted from these platforms. Access to the New Dungeness Light Station via boat is permitted 

through a reservation system (See Environmental Education, Wildlife Observation, Photography, and 

Interpretation Compatibility Determination). Currently boating on refuge waters is limited to May 15 

through September 30. Personal watercrafts, wind surfing and para-surfing/sailing are not permitted 

on refuge waters. 

Availability of Resources: 

The following funding/annual cost will be required to administer and manage boating activities as 

described above: 

Category One Time Expense Recurring Expense 

Administration (Reservation system for 

lighthouse landings) 

$1,000 

Monitoring $4,000 

Signage/Outreach $3,500 $500 

Totals $3,500 $5,500 

The Refuge has sufficient staff and funding to allow the use. 

Anticipated Impacts of the Use(s): 

Dungeness NWR provides crucial foraging and resting habitat for wintering migratory birds, 

including waterfowl, shorebirds, seabirds, and other waterbirds. Recreational boating affects their use 

of refuge and other Dungeness Harbor and Bay waters. Boating activity, both motorized and nonmotorized, can alter distribution, reduce use of particular habitats or entire areas by waterfowl and 

other birds, alter feeding behavior and nutritional status, and cause premature departure from areas 

(Knight and Cole 1995). More sensitive species may find it difficult to secure adequate food or 

loafing sites as their preferred habitat becomes fragmented and recreation-related disturbances 

increase (Skagen et al. 1991, Pfister et al. 1992). During migration and wintering, Pacific brant can 

be considered obligate feeders on eelgrass. Because of this, the eelgrass beds associated with the 

Refuge’s second-class tidelands are important brant feeding areas. 

Another species that could be impacted is the harbor seal. Harbor seals haulout and bear their pups 

on Dungeness Harbor and Bay tideflats and beaches. Harbor seals are afforded protection under the 

Marine Mammal Protection Act of 1972. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-39 

Canoes and kayaks can cause significant disturbance effects based on their ability to penetrate into 

shallower areas (Speight 1973, Knight and Cole 1995). Canoes or slow-moving boats have been 

observed to disturb great blue herons (Vos et al. 1985). Huffman (1999) found that non-motorized 

boats within 30 meters (98 feet) of the shoreline in south San Diego Bay caused all wintering 

waterfowl to flush between the craft and shore. However, compared to motorboats, canoes and 

kayaks appear to have less disturbance effects on most wildlife species (Huffman 1999, DeLong 

2002). 

The overall effects to wildlife will not be significant because refuge waters are closed to all use 

during the migration and winter season and there is a requirement to maintain a closed area 100 yard 

buffer zone below the mean high tide line during periods when these waters are open to public use. 

Impacts from boating are contained effectively and mitigated within the overall design of the 1997 

Environmental Assessment “Management of Public Use for Dungeness National Wildlife Refuge” 

(USFWS 1997) by providing clearly defined zones where and seasons when these activities can take 

place, and requiring that visitors restrict their use to those seasons and areas. This strategy will 

continue to be implemented under the CCP. The Complex is aware that some visitors disregard signs 

requiring visitors to stay within the designated public use areas (Area Closed signs). Such 

unauthorized use creates the potential for greater disturbance to wildlife 

Public Review and Comment:

This compatibility determination was submitted for 90-day public review and comment as an 

appendix to the Draft Comprehensive Conservation Plan and Environmental Assessment for 

Dungeness NWR. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility:

The requirements laid out in the preferred alternative of the Environmental Assessment – 

“Management of Public Use for Dungeness National Wildlife Refuge” (USFWS 1997) are adopted 

as stipulations to ensure compatibility and include: 

 In Zone 4 – Dungeness Spit from lighthouse to end of spit, the Harbor and Bay sides of 

Dungeness Spit, and all of Graveyard Spit including a 100-yard buffer zone below the mean 

high tide line - closed to public access year-round. Where the refuge boundary does not 

accommodate a 100 yard buffer, the buffer is slightly narrower. 

 In Zone 5 – Refuge waters and tidelands on the Harbor and Bay sides of Dungeness Spit 

outside the 100 yard buffer – motorized and non-motorized boats (kayaks, small sailboats, 

canoes, rowboats, etc.) allowed access to the areas west and east of Graveyard Spit in Zone 5, 

from October 1 to May 14. 

 From October 1 to May 14 this zone is closed to all public access. 

 Zone 5 is a no wake zone for power boats. 

 Boats are permitted to land year-round between the hours of 9 AM and 5 PM, by reservation 

only through the Complex office (as deemed necessary by the Refuge), in the designated 100 

yard zone of beach next to the light station compound on the Bay side of Dungeness Spit. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-40 Appendix B. Compatibility Determinations 

Number of landings is limited to no more than 20 per day. Visitors are allowed to walk 

through Zone 4 in a designated area to get to and from the landing site to the lighthouse. 

The response of wildlife to these modifications in public use activities will be monitored and 

evaluated to measure the effectiveness of the program in meeting refuge purposes. Based on 

monitoring data, public use regulations could become more restrictive in the future. 

Justification: 

Boating itself is not considered wildlife-dependent recreation, but many wildlife-dependent 

recreational activities (fishing, waterfowl hunting, environmental education, interpretation, and 

wildlife observation/photography) are associated with boating. Providing opportunities for wildlifedependent priority public uses will contribute toward fulfilling provisions under the National 

Wildlife Refuge System Administration Act as amended in 1997. Although boating has a potential to 

impact wildlife, implementing the prescribed measures listed in the Stipulations section will 

minimize these impacts. It is anticipated that closing refuge waters to boating during the migration 

and winter time periods will provide secure feeding and resting places for brant, waterfowl and 

shorebirds. The 100 yard buffer on the Dungeness Harbor and Bay side of Dungeness and Graveyard 

spits will minimize the potential for disturbance to nesting black oystercatchers and harbor seals. 

Thus, it is anticipated that birds will find sufficient food resources and resting places such that their 

abundance and use of the Refuge will not be measurably lessened, the physiological condition and 

production of waterfowl and other waterbirds will not be impaired, their behavior and normal activity 

patterns will not be altered dramatically, and their overall status will not be impaired. Thus, allowing 

boating under the stipulations described above will not materially detract from or interfere with the 

purposes for which the Refuge was established or the Refuge System mission. The Refuge will also 

implement a monitoring program to help assess disturbance effects on wildlife and habitat. Improved 

outreach and educational information for refuge visitors involved in activities associated with boating 

will also help to reduce the impacts associated with boating activities. 

Mandatory Re-Evaluation Date: 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

 X Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

References: 

DeLong, A. 2002. Managing visitor use and disturbance of waterbirds. a literature review of impacts 

and mitigation measures. Appendix L in: Stillwater National Wildlife Refuge Complex final 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-41 

environmental impact statement for the comprehensive conservation plan and boundary revision, 

Volume 2. Department of the Interior, Fish and Wildlife Service, Region 1, Portland, OR. 114 pp. 

Huffman, K. 1999. San Diego South Bay survey report-effects of human activity and water craft on 

wintering birds in South San Diego Bay. USFWS. 45 pp. 

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 51-70 in: R.L. Knight 

and K.J. Gutzwiller, eds. Wildlife and recreationists: coexistence through management and research. 

Washington, D.C.: Island Press. 

Pfister, C., B.A. Harrington, and M. Lavine. 1992. The impact of human disturbance on shorebirds at 

a migration staging area. Biological Conservation 60:115-126. 

Skagen, S.K., R.L. Knight, and G.H. Orians. 1991. Human disturbances of an avian scavenging 

guild. Ecological Applications 1:215-225. 

Speight, M.C.D. 1973. Outdoor recreation and its ecological effects: a bibliography and review. 

Discussion Papers in Conservation 4. University College. London, United Kingdom. 35 pp. 

USFWS. 1997. Management of public use for Dungeness National Wildlife Refuge – final 

environmental assessment. U.S. Department of Interior, Fish and Wildlife Service. Sequim, WA. 53 

pp. On file at the Washington Maritime National Wildlife Refuge Complex Headquarters. Sequim, 

Washington. 

Vos, D.K., R.A. Ryder, and W.D. Graul. 1985. Response of breeding great blue herons to human 

disturbance in north central Colorado. Colonial Waterbirds 8:13-22. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-43 

Compatibility Determination 

Use: Transport - Vehicle Access to New Dungeness Light Station 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for-(1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-44 Appendix B. Compatibility Determinations 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use: 

The U.S. Coast Guard (USCG) withdrew its last keeper from the automated New Dungeness Light 

Station (Station) in March of 1994. It planned to board up the buildings and maintain the equipment 

with regular inspections, a move necessitated by budget reductions and made possible by automation. 

Other unattended light stations have experienced damage by vandals and general deterioration. The 

New Dungeness Light Station Association (NDLSA) organized in early 1994 with the mission of 

protecting and preserving the Station. With help from the U.S. Lighthouse Society it obtained a 

renewable license from the USCG to care for the Station 

Since September 3, 1994, NDLSA has continuously staffed the Station with volunteer keepers who 

serve in one-week shifts. Keepers, along with their supplies and personal effects, are taken to the 

Station in a NDLSA vehicle at low tide each week. In addition, vehicles are used to transport work 

parties when maintenance needs dictate, usually a couple of times a month. During the summer 

months these exchanges occur during the day while during the winter they occur at night. Volunteer 

keepers clean and repair buildings, maintain the grounds, and conduct tours for refuge visitors 

arriving by foot or by water in kayaks or small boats. Typically about 5,000 visitors sign the guest 

book at the Station every year. 

Vehicle access coincides with low tide events. Two vehicles make the trip to ensure that if one 

vehicle breaks down then the other can move people and equipment and the stranded vehicle to a safe 

area. NDLSA vehicle drivers undergo training and are instructed on what to do if approaching 

walking refuge visitors and the maximum speed allowed on the Refuge. 

Availability of Resources 

Administration of this use will not require any new infrastructure or personnel but will require 

coordination with the NDLSA and some increased monitoring by refuge staff. 

Category One Time Expenses Recurring Expenses

Administration - Coordination 

with NDLSA 

 $500 

Monitoring $1,200 

Totals $1,700 

Anticipated Impacts of the Use(s): 

The extent of impacts from vehicle use of the beach varies by season. During the daylight summer 

months, seal pups on the beach may be trampled and resting shorebirds and gulls displaced. 

Compatible wildlife-dependent activities such as wildlife watching, photography, and environmental 

education may be negatively affected because of the expected responses by wildlife to vehicles 

approaching or passing by. When wildlife react by moving away from or alter behavior by hiding, 

they are less likely to be observed (Bennett and Zuelke 1999). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-45 

User groups of shared-use paths often have conflicting needs. Moore (1994) concluded that trail 

conflicts can occur among different user groups, among users within the same user group, and as a 

result of factors not related to trail user activities at all. Conflict has been found to related to activity 

style, focus of trip, expectations, attitudes toward and perceptions of the environment, level of 

tolerance for others, and different norms held by different users. This loss of expectation of a quality 

wildlife-dependent experience could result in avoidance of refuge beach by wildlife watchers and 

photographers who encounter vehicles using the same beach. 

During the winter season when vehicle use on the beach occurs at night to coincide with winter low 

tide events, impacts to refuge wildlife resources will be minimized but will include resting shorebird 

and gull displacement. Impacts to marine mammals will be minimal and might affect molting 

elephant seals. Impacts to refuge visitors will be negligible as the Refuge is open only during 

daylight hours. 

 

Public Review and Comment: 

This compatibility determination was submitted for 90-day public review and comment as an 

appendix to the Draft Comprehensive Conservation Plan and Environmental Assessment for 

Dungeness NWR. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

 Levels of use and impacts associated with the use will be monitored to ensure that the use 

remained compatible. Monitoring will evaluate impacts of the use upon, among others, 

refuge management activities; fish, wildlife, plants, and their habitats; biological integrity, 

diversity, and environmental health; and wildlife-dependent public uses. If monitoring 

reveals that levels of use or associated impacts exceed those envisioned in the compatibility 

determination, the use might be re-evaluated and modified to ensure it remains compatible or 

terminated if found not compatible. 

 Vehicle speed while on the Refuge will not exceed 15 MPH 

 Vehicles will be equipped with “beepers” and give an audible warning before passing visitors 

on the beach 

 Vehicles will come to a complete stop when approaching children and wait until safe to pass. 

 The Refuge will contact NDLSA when seal pups or molting seals are on the beach to inform 

them of their presence and location. 

 Vehicle use is restricted to keeper exchange, major maintenance needs, and emergency 

evacuation of keepers or NDLSA work party members. 

 NDLSA drivers will receive training on safe operation of motor vehicles on the Refuge and 

on sandy, rocky surfaces. 

 Any accidental spillage of petroleum products (gas, oil) resulting from operation of vehicles 

by the NDLSA will be immediately reported to the refuge manager. Clean-up operations will 

be conducted immediately, or as soon as it can be safely accomplished, and be the 

responsibility of the NDLSA. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-46 Appendix B. Compatibility Determinations 

Justification: 

The New Dungeness Light Station is a cultural resource located at the northeast end of Dungeness 

Spit. The 35 acres presently owned by the USCG is an inholding on Dungeness NWR. The Refuge 

has identified in the Dungeness NWR CCP its intent to acquire the area when excessed by the USCG 

and to enter into a formal agreement with the New Dungeness Light Station Association to care, 

maintain, and interpret the Station. The safe movement of people and supplies necessary to maintain 

and interpret the Station is best accomplished by allowing vehicle access via the beach at low tides. 

Weather patterns in the Strait of Juan de Fuca often result in strong westerly winds and subsequent 

rough water making access by boat unpredictable and hazardous. As described above, disturbance 

and other impacts to wildlife and refuge visitors from allowing the use will be negligible. Thus 

allowing the NDLSA to use vehicles on the beach under a Special Use Permit or Memorandum of 

Understanding/Agreement and with stipulations as listed above will not materially interfere with or 

detract from the mission of the National Wildlife Refuge System or the purposes for which the 

Refuge was established. 

Mandatory Re-Evaluation Date: 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

 X Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

References: 

Bennett, K.A. and E. Zuelke. 1999. The effects of recreation on birds: a literature review. Delaware 

Natural Heritage Program. Smyrna, DE. 

Moore, R.L. 1994. Conflicts on multiple-use trails: synthesis of the literature and state of the 

practice. Federal Highway Administration Report No. FHWA-PD-94-031. Report Date: August 

1994. Federal Highway Administration. Washington, D.C. 68 pp. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-48 Appendix B. Compatibility Determinations 

Compatibility Determination 

Use: Horseback Riding 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for-(1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-49 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use: 

While not one of the six wildlife-dependent public uses listed or identified in the National Wildlife 

Refuge System Administration Act, as amended (1997), horseback riding on the Dungeness NWR 

can facilitate wildlife observation, but is not necessary to achieve it. The Service will allow 

horseback use on the beach west of the point where the main trail meets Dungeness Spit (Zone 1) if a 

safe and legal alternate access route can be obtained from the west or from the east. If an alternate 

route is obtained from the east then horseback use of the administrative road from the gate separating 

the Refuge from the private landowner to the east to the beach will also be allowed. 

Availability of Resources 

Costs to provide for horseback riding, including operation of a reservation system, signing, required 

trail maintenance, and monitoring will be moderate. If access from the east is obtained in the future 

then a new entrance/fee area will need to be developed including signage and a fee collection point. 

Monitoring costs will be covered with other public use activities. Base funding is available to cover 

staff costs. 

Category One Time Expenses Recurring Expenses

Administration and management (operation of 

reservation system) 

 $1,000 

Maintenance (trail and signs) $3,000 $1,000 

Monitoring $1,200 

Special equipment, facilities, or improvements 

(mounting blocks, signs, development of new 

access entry station if access is obtained from the 

east at a future date) 

$4,500 

Totals $7,500 $3,200 

Anticipated Impacts of the Use(s): 

Impacts related to horseback riding can range from exotic plant seed dispersal (Beck 1993, Hammitt 

and Cole 1987) in horse coats and manures, soil compaction and erosion (Bainbridge 1974, Hammitt 

and Cole 1987, Hendee et al. 1990), stream sedimentation (Wilson and Seney 1994), trail widening 

(Whittaker 1978), vegetation trampling (Nagy and Scotter 1974, Weaver and Dale 1978, Whittaker 

1978), aesthetic concerns relative to horse manure (Lee 1975), and direct wildlife disturbance (Owen 

1973), to direct and indirect conflicts with other recreationists. 

Impacts to Wildlife and Habitat: 

Possible biological impacts of horseback riding include disturbance to wildlife and habitat. Wildlife 

can be affected through the sight and sound of recreationists (Boyle and Samson 1985). Some of the 

effects of disturbance to wildlife from recreational activities include changes in foraging behavior; 

reduction of productivity; abandonment or alteration of breeding territories; alteration of animal 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-50 Appendix B. Compatibility Determinations 

distribution; alteration of flight behavior; energy depletion; and disruption of nest and brood rearing 

attentiveness (Klein 1989, Knight and Skagen 1988). 

Wildlife disturbance relative to horseback riding has been poorly studied, with most references using 

other activities such as hiking and cross-country skiing to infer horseback riding impacts. Only one 

study identified disturbance tolerance of waterfowl to horseback riders and found that horseback 

riders could approach geese up to a distance of 150 feet. This is compared to suggested hiking trail 

distances of 250 feet (Miller et al. 1998) and boat buffers ranging from 250 to 900 feet (depending on 

type of boat, whether motorized, and species impacted; Burger et al. 1999). The 150-foot approach 

distance offered by Owen (1973) is consistent with observations suggesting that horseback wildlife 

observers can approach wildlife at closer distances than through other forms of travel. However, any 

form of approach is expected to cause some disturbance, which will vary according to the species 

affected and the type, level, frequency, and duration of disturbance, as well as the habitat type and 

time of day or year that it occurs. 

In addition to direct impacts to wildlife, habitat can be affected through vegetation trampling, soil 

compaction and erosion (Cole 1983, Cole 1990). Impacts from vegetation trampling can lower 

species richness, decrease ground cover and density of plant species, increase species diversity 

through an increase in weedy annuals, and induce changes in species composition (Bonanno 1992, 

Bright 1986, Grabherr 1983). 

Exotic plant establishment is further facilitated by increased soil disturbance, as many exotic plants 

gain a competitive advantage in highly disturbed sites; hoof action tends to dig up and puncture the 

soil surface (McQuaid-Cook 1978). This can also increase the spread of previously established 

exotics by providing loose, disturbed soil for germination and spreading reproductive plant 

structures. 

Refuge-specific Impacts 

A primary concern in allowing any public use on Dungeness NWR is to maintain adverse impacts 

within acceptable limits. Potential impacts of horseback riding include conflicts between user groups, 

exotic plant establishment, and wildlife disturbance. Conflicts with non-equestrian users may occur 

as some users are not comfortable around horses and may even perceive them as dangerous. Noxious 

weeds could be spread into upland habitat from horse droppings. Horseback riding on Dungeness 

NWR has the potential of impacting marine mammal, shorebird, and other migratory bird 

populations feeding and resting on the beach during certain times of the year. The extent of impacts 

from horseback riding on the west beach (Zone 1) varies by season. During the summer months, seal 

pups on the beach and bluff nesting guillemots may be disturbed. Throughout the year, shorebirds 

and gulls may be disturbed and displaced. 

Due to the potential for horseback riding to adversely affect refuge resources and other refuge 

visitors, a variety of stipulations will be enacted to minimize impacts. The stipulations pertaining to 

timing, space, pace of use, and waste removal also will ensure proper control of the uses and provide 

management flexibility should detrimental impacts develop. Disturbances to wildlife and habitat will 

be minimized by limiting horseback riding to the beach west of Dungeness Spit (Zone 1). 

Overall, disturbances on the beach to the west of where the main trail meets the beach are expected to 

result in minor impacts to resident wildlife and other refuge users, due to the low volume and seasons 

of use. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-51 

Public Review and Comment: 

In the Draft Comprehensive Conservation Plan and Environmental Assessment for Dungeness NWR, 

the Service proposed to discontinue allowing horseback riding due to safety concerns. The Service 

received numerous comments and suggestions over the course of our 90-day public review and 

comment period in response to our proposal to discontinue horseback riding, the results of which are 

this revised proposal for horseback riding and compatibility determination. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

 Zone 1- (west beach) – Horseback riding will be permitted by reservation only through the 

Complex office and riders will be required to obtain an entrance permit. 

 Additional permits may be required in the future if the reservation system is not sufficient. 

 Depending on demand, the number of parties per day may be limited to prevent 

overcrowding and ensure public safety. 

 Party size will be limited to no more than 4 horses to reduce potential conflicts with 

pedestrians. 

 Horses must walk (no trotting, cantering or galloping) while on refuge areas open to horse 

use. 

 Pedestrians have the right of way. 

 If access is gained from the east, equestrians would be required to remove manure from the 

service road. 

 Horseback riding daily October 1 through March 31 and weekdays April 1 through 

September 30. No horseback riding on Memorial Day, the Fourth of July, or Labor Day. 

 The response of wildlife and visitors to this public use activity will be monitored and 

evaluated to measure the effectiveness of the program in meeting refuge purposes. If 

monitoring reveals that levels of use or associated impacts exceeds those envisioned in the 

compatibility determination, the use will be re-evaluated and modified to ensure it remains 

compatible or terminated if found not compatible. 

Justification: 

Facilitating this use on the Refuge will increase visitor knowledge and appreciation of fish and 

wildlife resources. This enhanced understanding will foster increased public stewardship of natural 

resources and support for the Service's management actions in achieving the refuge purposes and the 

mission of the National Wildlife Refuge System. 

Allowing use on only the west beach (Zone 1) should reduce conflicts between user groups as this 

area historically sees limited public use. Although horseback riding can result in disturbance to 

wildlife, disturbance is expected to be intermittent, short-term and limited in time and space. There is 

more than an adequate amount of undisturbed habitat available to the majority of wildlife for escape 

and cover. The relatively limited number of individuals expected to be adversely affected by 

horseback riding will not cause wildlife populations to materially decline, the physiological condition 

and production of wildlife species will not be impaired, their behavior and normal activity patterns 

will not be altered dramatically, and their overall welfare will not be negatively impacted. Thus, 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-52 Appendix B. Compatibility Determinations 

allowing horseback riding under the stipulations will not materially interfere with or detract from the 

mission of the National Wildlife Refuge System or the purposes for which the Refuge was 

established. 

Mandatory Re-Evaluation Date: 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

 X Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

References: 

Bainbridge, D.A. 1974. Trail management. Ecological Society of America Bulletin 55:8-10. 

Beck, K.G. 1993. How do weeds affect us all. Proceedings of the Eighth Grazing Lands Forum. 

Washington, District of Columbia. December 2, 1993, pages 5-13. 

Bonanno, S.E. 1992. Vegetation of a Lake Ontario dune barrier, Oswego and Jefferson Counties, 

New York, under high and low recreation pressure. Master's thesis. Syracuse State University, New 

York. 88 pages. 

Boyle S.A., and F.B. Samson. 1985. Effects of non-consumptive recreation on wildlife: A review. 

Wildlife Society Bulletin 13:110-116. 

Bright, J.A. 1986. Hiker impact on herbaceous vegetation along trails in evergreen woodland of 

central Texas. Biological Conservation 36:53-69. 

Burger, J., B. Harrington, J. Rodgers, and H. Smith. 1999. Minimum recommended set-back (RS) 

distances for various disturbances approaching directly towards waterbirds to prevent flushing. 

Cole, D.N. 1983. Campsite conditions in the Bob Marshall Wilderness, Montana. Research Paper 

INT-312. U.S. Department of Agriculture, Forest Service, Intermountain Forestry and Range 

Experimental Station. 18 pages. 

Cole, D.N. 1990. Ecological impacts of wilderness recreation and their management. Pages 425-466 

in Wilderness Management (J.C. Hendee, G.H. Stankey, and R.C. Lucas, editors). North American 

Press, Golden, Colorado. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-53 

Grabherr, G. 1983. Damage to vegetation by recreation in the Austrian and German Alps. Pages 74- 

91 in The Ecological Impacts of Outdoor Recreation on Mountain Areas in Europe and North 

America (N.G. Bayfield and G.C. Barrow, editors). Report 9. 203 pages. 

Hammitt, W.E., and D.N. Cole. 1987. Wildland Recreation: Ecology and Management. John Wiley 

and Sons, New York, New York. 341 pages. 

Hendee, J.C., G.H. Stankey, and R.C. Lucas. 1990. Wilderness Management. North American Press, 

Golden, Colorado. 

Klein, M.L. 1989. Effects of high levels of human visitation on foraging waterbirds at J.N. "Ding" 

Darling National Wildlife Refuge, Sanibel, Florida. Final Report to the U.S. Fish and Wildlife 

Service. 103 pages. 

Knight, R.L., and S.K. Skagen. 1988. Effects of recreational disturbance on birds ofprey: A review. 

Pages 355-359 in Proceedings ofthe Southwest Raptor Management Symposium Workshop. National 

Wildlife Federation, Washington, District of Columbia. 

Lee, R.G. 1975. The management of human components in the Yosemite National Park ecosystem. 

Yosemite National Park, California. 134 pages. 

McQuaid-Cook, J. 1978. Effects ofhikers and horses on mountain trails. Journal of Environmental 

Management 6:209-212. 

Miller, S.G., R.L. Knight, and C.K. Miller. 1998. Influence of recreational trails on breeding bird 

communities. Ecological Applications 8:162-169. 

Nagy, J.A.S., and G.W. Scotter. 1974. A quantitative assessment ofthe effects of human and horse 

trampling on natural areas, Waterton Lakes National Park. Canadian Wildlife Service, Edmonton, 

Alberta, Canada. 145 pages. 

Owen, M. 1973. The management of grassland areas for wintering geese. Wildfowl 24:123-130. 

U. S. Fish and Wildlife Service. 1997. Management of Public Use for Dungeness National Wildlife 

Refuge – Final Environmental Assessment. Sequim, WA. 53pp. 

Weaver, T., and D. Dale. 1978. Trampling effects of hikers, motorcycles, and horses in meadows and 

forests. Journal of Applied Ecology 15:451-457. 

Whittaker, P.L. 1978. Comparison of surface impact by hiking and horseback riding in the Great 

Smoky Mountain National Park. National Park Service Management Report 24. 

Wilson, J.P., and J.P. Seney. 1994. Erosional impact of hikers, horses, motorcycles, and off-road 

bicycles on mountain trails in Montana. Mountain Research and Development 14(1): 77-88. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-55 

Compatibility Determination 

Use: Jogging 

Refuge Name: Dungeness National Wildlife Refuge 

County and State: Clallam County, Washington 

Establishing and Acquisition Authorities: 

 Executive Order 2123, Dungeness Spit Reservation for Protection of Native Birds, signed 20 

January 1915 

 Tidelands of the second class were conveyed to the United State of America, U.S. Fish and 

Wildlife Service, from the State of Washington through a permanent easement on May 29, 

1943, (Deed No. 18251 App. No. 10585), under the authority described in Section 152, 

Chapter 255, State of Washington Laws of 1927. 

 Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) as amended 

 Refuge Recreation Act of 1962 as amended (16 U.S.C. 460k-460k-4) 

 Endangered Species Act of 1973 

Refuge Purpose(s): 

The purposes for the Dungeness NWR have been identified in historic legal documentation 

establishing and adding refuge lands. The Refuge was originally established to preserve important 

habitat for native birds with refuge purposes specified as follows: 

“...as a refuge, preserve, and breeding ground for native birds.” (Executive Order 2123 dated 

20 January 1915. 

“... suitable for-(1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” (16 U.S.C. 460k-1) 

“... the Secretary ... may accept and use ... real ... property. Such acceptance may be 

accomplished under the terms and conditions of restrictive covenants imposed by donors ...” 

16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended). 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. § 1534 (Endangered Species Act of 1973) 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. § 

742f(b)(1) (Fish and Wildlife Act of 1956) 

In accordance with 601 FW 1, all lands acquired since the original establishment of the Refuge retain 

these purposes. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-56 Appendix B. Compatibility Determinations 

National Wildlife Refuge System Mission: 

“The mission of the System is to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future 

generations of Americans.” (National Wildlife Refuge System Administration Act of 1966 as 

amended, 16 U.S.C. 668dd-668ee). 

Description of Use: 

While not one of the six wildlife-dependent public uses listed or identified in the National Wildlife 

Refuge System Administration Act, as amended (1997), jogging is an existing use on the Dungeness 

NWR. Jogging will be limited to the trail adjacent to the refuge parking lot (parking lot trail, 

approximately 0.2 mile) and along the west beach from the end of the upland forested trail to the 

western boundary of the Refuge (west beach, Zone 1, approximately 0.5 mile). The parking lot trail 

connects the bluff and horse trails within Dungeness County Park. Organized running groups and 

special events such as practice meets will be prohibited. Groups will be limited to 3 people or less on 

the parking lot trail due to the confined nature of the trail. Restrictions on this activity will be clearly 

posted at the refuge kiosk adjacent to the parking lot and in the refuge brochure and website. 

Jogging occurs year-round on the Refuge with the majority of use observed from spring through fall. 

Although jogging is primarily athletic in nature, it is likely that some joggers observe and enjoy 

wildlife while on the Refuge. Anecdotal evidence indicates that total use by joggers in appropriate 

areas is minor. However, refuge staff, volunteers and visitors have observed jogging in sections of 

the Refuge in which this use is not allowed due to disturbance of wildlife and conflicts with refuge 

visitors. 

Availability of Resources 

Costs to administer jogging, including signage, required trail maintenance, enforcement of 

regulations, and the monitoring of public use and biological impacts will be moderate. The direct 

costs for trail and sign maintenance associated with this activity will be minimal as costs will be 

covered along with other public use activities. Base funding is available to cover staff costs and 

sufficient funds and staff are available to manage the activity. 

Category One Time Expenses Recurring Expenses

Maintenance (trail and signs) $2,000 $750 

Monitoring $1,200 

Totals $2,000 $1,950 

Anticipated Impacts of the Use(s): 

Impacts to Wildlife (Disturbance): 

Immediate responses by wildlife to recreational activity can range from behavioral changes including 

nest abandonment or change in food habits, physiological changes such as elevated heart rates due to 

flight, or even death (Knight and Cole 1995). The long-term effects are more difficult to assess but 

may include altered behavior, vigor, productivity or death of individuals; altered population 

abundance, distribution, or demographics; and altered community species composition and 

interactions. Knight and Cole (1991) found that wildlife responses to human disturbance include 

avoidance, habituation, and attraction. The magnitude of the avoidance response may depend on a 

number of factors including the type, distance, movement pattern, speed, and duration of the 

disturbance, as well as the habitat type, time of day, time of year, weather; the animal’s access to food 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-57 

and cover, energy demands, and reproductive status (Knight and Cole 1991, Gabrielsen and Smith 

1995). 

Conflicts arise when migratory birds and humans are present in the same areas (Boyle and Samson 

1985). Response of birds to human activities includes departure from site (Owens 1977, Burger 1981, 

Korschgen et al. 1985, Henson and Grant 1991, Klein 1993, Taylor and Knight 2003), use of 

suboptimal habitat (Erwin 1980, Williams and Forbes 1980), altered behavior (Burger 1981, 

Korschgen et al. 1985, Morton et al. 1989, Ward and Stehn 1989, Havera et al. 1992, Klein 1993), 

and increase in energy expenditure (Morton et al. 1989, Belanger and Bedard 1990). 

The locations and timing of recreational activities impact species in different ways. Miller et al. 

(1998) found that nesting success was lower near recreational trails where human activity is 

common, than at greater distances from the trails. A number of species have shown greater reactions 

when pedestrian use occurred off trail (Miller et al. 1998, Taylor and Knight 2003). In regard to 

waterfowl, Klein (1989) found migratory dabbling ducks to be the most sensitive to disturbance, and 

migrant ducks to be more sensitive when they first arrived in the late fall, than later in winter. Burger 

(1981) found that migratory shorebirds showed the most sign of disturbance by flushing out of the 

area entirely, while resident gulls were least disturbed and were only temporarily displaced. For 

songbirds, Gutzwiller et al. (1997) found that singing behavior of some species was altered by low 

levels of human intrusion. 

Jogging can impact normal wildlife behavioral activities, including feeding, reproductive, and social 

behavior. Studies have shown that waterfowl and shorebirds are sensitive to jogging activity (Burger 

1981, Burger 1986). Rapid movement by joggers is more disturbing to wildlife, than slower moving 

hikers (Bennett and Zuelke 1999, Burger 1981). Movement away from or at an oblique angle to 

wildlife is less disturbing than a direct approach (Knight and Cole 1991). 

The impacts of jogging, as conducted on Dungeness NWR, have not been studied in detail. However, 

jogging can impact marine mammal, passerine, shorebird, waterfowl and other migratory bird 

populations feeding and resting on the beach, bluff, or near trails. The extent of impacts from jogging 

to refuge wildlife would vary by season. For example, during the summer months seal pups on the 

beach may be disturbed and resting shorebirds and gulls displaced. 

Potential Conflicts between User Groups: Moore (1994) concluded that trail conflicts can occur 

among different user groups, among users within the same user group, and as a result of factors not 

related to trail user activities at all. Conflict has been found to be related to activity style, focus of 

trip, expectations, attitudes toward and perceptions of the environment, level of tolerance for others, 

and different norms held by different users. Compatible wildlife-dependent activities such as wildlife 

watching, photography, and environmental education, may be negatively affected because of the 

expected responses by wildlife to joggers approaching or passing by. When wildlife react by moving 

away from or alter behavior by hiding, they are less likely to be observed (Bennett and Zuelke 1999). 

This loss of an anticipated quality wildlife-dependent experience could result in avoidance of the 

Refuge by wildlife watchers and photographers who encounter joggers using the same areas. 

Impacts of jogging have been reported from refuge staff, volunteers and visitors including wildlife 

disturbance on the forested trail and beach as well as conflicts between user groups. The number of 

encounters that create conflict is unknown. Measures to reduce potential conflicts between other user 

groups will include providing information at the refuge kiosk adjacent to the parking lots and in the 

refuge brochure and website that clearly indicates permitted uses and rules of conduct. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-58 Appendix B. Compatibility Determinations 

Overall Impact to Dungeness NWR: The studies cited above show that public use activities can and 

do disturb wildlife. Based on the circumstances described in the scientific literature as well as reports 

from staff, volunteers and visitors, similar effects are occurring on Dungeness NWR. A primary 

concern in allowing any public use on Dungeness NWR is to maintain adverse impacts within 

acceptable limits. Korschgen and Dahlgren (1992) and Fox and Madison (1997) state the importance 

of disturbance-free food reserves and areas as a management alternative to minimize human 

disturbances. The Refuge has several areas which are removed from human activity and support high 

use by aquatic birds and marine mammals including Graveyard Spit and the tip of Dungeness Spit. 

We will allow jogging only on the trail adjacent to the parking lot and the west beach since these 

areas receive less overall wildlife use compared with other sections of the Refuge and conflicts with 

other visitors, primarily engaged in wildlife-dependent activities, will be limited. Therefore, we 

anticipate the impacts on wildlife and wildlife-dependent public use from jogging in these areas to be 

minor. 

Jogging will not be allowed on the forested trails leading down to the beach because the higher speed 

of joggers, combined with short sight distances on confined wooded trails, creates unsafe conditions 

for both joggers and other refuge visitors (e.g., families with baby strollers, people with limited 

agility and mobility). Special running events and team training will not be allowed since group size 

has been found to increase wildlife response to disturbance (Geist et al. 2005, Yosef 2000) and group 

events can cause conflicts with other visitors on confined wooded trails. Restricting group size to a 

maximum of 3 and educating the public on the effects of recreation on wildlife and habitat will 

further reduce impacts to wildlife and reduce conflicts with other refuge visitors. 

Enforcement of regulations and imposed fines may also minimize visitor disturbance to wildlife 

(Knight and Gutzwiller 1995). If a pattern of violation is demonstrated which results in jogging 

becoming a non-compatible activity (i.e. wildlife disturbance or impacts on wildlife-dependent public 

use) this use will be reevaluated and may be eliminated. 

 

Public Review and Comment: 

In the Draft Comprehensive Conservation Plan and Environmental Assessment for Dungeness NWR, 

the Service proposed to discontinue allowing jogging on the Refuge due to wildlife disturbance 

concerns. The Service received numerous comments and suggestions over the course of our 90-day 

review and comment period in response to our proposal to discontinue jogging, the results of which 

are this revised proposal for jogging and compatibility determination. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

 Jogging will only be allowed on the trail adjacent to the parking lot and west beach (Zone 1). 

This activity will not be allowed on any other part of the Refuge. 

 Use is restricted to daylight hours only. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-59 

 Organized running groups and running events will be prohibited. Groups will be limited to 

three people or less along the parking lot trail. 

 Compliance, levels of use, and impacts associated with the use will be monitored to ensure 

that it remains compatible. Monitoring will evaluate impacts of the use upon fish, wildlife, 

plants, habitats, and wildlife-dependent public uses. 

 If monitoring reveals that levels of use or associated impacts exceed those envisioned in the 

compatibility determination, the use will be re-evaluated and modified to ensure it remains 

compatible or terminated if found not compatible. 

Justification: 

Although jogging is not a wildlife-dependent public use of the Refuge, as defined by statute (16 

U.S.C. 668dd et seq.), it is likely that some joggers observe and enjoy wildlife while on the Refuge. 

Occasional use of the west beach and parking lot trail is expected to have negligible impacts on 

wildlife or wildlife-dependent public uses. Potential for wildlife disturbance is minimal given the low 

level of use by wildlife and refuge visitors in these areas. In addition, conflicts between joggers and 

wildlife-dependent public uses are expected to be low due to the low use of the west beach and 

parking lot trail by wildlife and subsequent low expectations of visitors to encounter wildlife in these 

areas. 

It is anticipated that wildlife populations will find sufficient food resources and resting places such 

that their abundance and use of the Refuge will not be measurably lessened from allowing jogging on 

the west beach and parking lot trail. The relatively limited number of individuals expected to be 

adversely affected due to jogging will not cause wildlife populations to materially decline; the 

physiological condition and production of wildlife species will not be impaired; their behavior and 

normal activity patterns will not be altered dramatically; and their overall welfare will not be 

negatively impacted. Allowing jogging on specified areas of the Refuge where conflicts with other 

refuge visitors would be limited will allow joggers to experience the Refuge safely. Thus, allowing 

jogging to occur with stipulations will not materially detract or interfere with the purposes for which 

the Refuge was established or the Refuge System mission. 

Mandatory Re-Evaluation Date: 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

 X Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

B-60 Appendix B. Compatibility Determinations 

References: 

Belanger, L., and Bedard J. 1990. Energetic cost of man-induced disturbance to staging snow geese. 

Journal of Wildlife Management 54(1), 36-41. 

Bennett, K.A. and E. Zuelke. 1999. The effects of recreation on birds: a literature review. Delaware 

Natural Heritage Program. Smyrna, DE. 

Boyle, S.A. and Samson, F.B. 1985. Effects of non-consumptive recreation on wildlife: A review. 

Wildlife Society Bulletin 13 (2) 110-116. 

Burger, J. 1981. The effect of human activity on birds at a coastal bay. Conservation, 21, 231-241. 

Burger, J. 1986. The effect of human activity on shorebirds in two coastal bays I northeaster United 

States. Environmental Conservation 13: 123-130. 

Erwin, R.M. 1980. Breeding habitat use by colonially nesting waterbirds in two mid-Atlantic U.S. 

regions under different regimes of human disturbances. Biological Conservation, 18, 39-51. 

Fox, A.D., and Madsen, J. 1997. Behavioral and distributional effects of hunting disturbance on 

waterbirds in Europe: Implications for refuge design. Journal of Applied Ecology, 34 (1) 1-13. 

Gabrielson, G.W. and E.N. Smith 1995. Physiological responses of wildlife to disturbance. Pages 95-

107 in R. L. Knight and K. J. Gutzwiller, ed. Wildlife and Recreationists; coexistence through 

management and research. Island Press, Washington, D. C. 372 pp. 

Geist, C. Liao, J. Libby, S. Blumstein, D. T. 2005. Does intruder group size and orientation affect 

flight initiation distance in birds? Animal Biodiversity and Conservation 28.1 69-73. 

Gutzwiller, K., Wiedenmann, R.T., Clements, K.L., and Anderson., S. H. 1994. Effects of human 

intrusion on song occurrence and singing consistency in sub-alpine birds. Auk, 111, 28-37. 

Havera, S.P., Boens, L.R., Georgi, M.M. and Shealy, R.T. 1992a. Human disturbance of waterfowl 

on Keokuk Pool, Mississippi River. Wildl. Soc. Bull 20, 290-98. 

Henson, P., and Grant, T. A. 1991. The effects of human disturbance on trumpeter swan breeding 

behavior. Wildlife Society Bulletin, 19, 248-257. 

Klein, M.L. 1989. Effects of high levels of human visitation on foraging waterbirds at J.N. "Ding" 

Darling National Wildlife Refuge, Sanibel, Florida. Final Report to the U.S. Fish and Wildlife 

Service. 103 pages. 

Klein, M. L. 1993. Waterbird behavioral responses to human disturbances. Wildlife Society bulletin 

21, 31-39. 

Knight, R.L., Cole, D.N. 1991. Effects of recreational activity on wildlife in wildlands. Transcripts of 

the 56th North American Wildlife and Natural Resources Conference (238-246). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-61 

Knight, R.L., and Gutzwiller, K.J. eds. 1995. Wildlife and recreationalists: coexistence through 

management and research. Island Press, Washington, D.C. 372 pp. 

Korschgen, C. E., George, L.S. and Green, W.I. 1985 Disturbance of diving ducks by boaters on a 

migrational staging area. Wildl. Soc. Bull 13, 290-96. 

Korschgen, C. E., Dahlgren, R.B. 1992. Human disturbances of waterfowl: causes, effects, and 

management. 13.2.15. Waterfowl Management Handbook. Fish and Wildlife Leaflet 13. U.S. Fish 

and Wildlife Service. 

Miller, S.G. Knight R.L., Miller, C.K. 1998. Influence of recreational trails on breeding bird 

communities. Ecological Applications, 8(1) 162-169. 

Moore, R.L. 1994. Conflicts on multiple-use trails: synthesis of the literature and state of the 

practice. Federal Highway Administration Report No. FHWA-PD-94-031. Report Date: August 

1994. Federal Highway Administration. Washington, D.C. 68 pp. 

Morton, J.M. Fowler, A.C., Kirkpatrick, R.L. 1989. Time and energy budgets of American Black 

Ducks in winter. Journal of Wildlife Management, 53 (2) 401-410. 

Owens, N.W. 1977. Responses of wintering Brent Geese to human disturbance. Wildfowl, 28, 5-14. 

Taylor and Knight 2003. Wildlife responses to recreation and associated visitor perceptions. 

Ecological Applications, 13(4) 951-963. 

Ward, D. and R. Stehn. 1989. Response of brant and other geese to aircraft disturbances at Izembek 

Lagoon, Alaska. USFWS Alaska Fish and Wildlife Research Center, Anchorage. 241 pp. 

Williams, G. and Forbes, J.E. 1980. The habitat and dietary preferences of dark-bellied brent geese 

and widgeon in relation to agricultural management. Wildfowl 31: 151-157. 

Yosef, R. 2000. Individual distances among greater flamingos as indicators of tourism pressure. 

Waterbirds 23 (Special Publication 1), 26-31. 

 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-1 

Appendix C. Implementation 

C.1 Introduction 

Implementation of the comprehensive conservation plan (CCP) will require increased funding, which 

will be sought from a variety of sources including Congressional allocations and public and private 

partnerships and grants. There are no guarantees that additional federal funds will be made available 

to implement any of these projects. Other sources of funds will need to be obtained, both public and 

private. Activities and projects identified will be implemented as funds become available. 

The CCP identifies several projects to be implemented over the next fifteen years. Most of these 

projects are included in the Refuge Operational Needs System (RONS - new staff), or Service Asset 

Maintenance and Management System (SAMMS - deferred maintenance projects) which are used to 

request funding from Congress. Visitor Facility and Enhancement (VFE) projects considered for 

funding must be requested through the Branch of Visitor Services. Currently, a large backlog of 

maintenance needs exists for Dungeness NWR. In 2008, the deferred maintenance backlog for 

Dungeness NWR was $1,156,000, with more projects needing to be added. An attempt at reducing 

this backlog needs to be addressed and is included here in the analysis of funding needs. Prioritized 

staffing needs identified in the RONS will be necessary to implement the CCP to meet refuge goals 

and objectives and legal mandates. The SAMMS database documents and tracks repairs, 

replacements, and maintenance of facilities and equipment. Smaller projects will be implemented as 

funding allows, and funding will be sought for these projects through a variety of sources. 

Annual revenue sharing payments, associated with Dungeness NWR in Clallam County will 

continue. The total payment made in 2010 was $7,967 for 213 acres of refuge lands. In addition 

Dungeness NWR leases from Clallam County the public restroom and parking lots located adjacent 

to the main trail entrance for $1,800 a year. 

Monitoring activities will be conducted on a percentage of all new and existing projects and activities 

to document wildlife populations and changes across time, habitat conditions, and responses to 

management practices. Actual monitoring and evaluation procedures will be detailed in step-down 

management plans. General monitoring activities are discussed in Chapter 2 under Goal 4, which 

addresses the collection of scientific information (inventories, monitoring, feasibility studies, 

assessments, and research) to support adaptive management decisions on Dungeness NWR. 

C.2 Step-Down Plans 

The Comprehensive Conservation Plan is one of several necessary plans used by managers, 

biologists, and staff for refuge management. The CCP provides guidance in the form of goals, 

objectives, and strategies for several refuge program areas but may lack some of the specifics needed 

for implementation. Step-down management plans will be developed for individual program areas 

within approximately 5 years after CCP completion. All step-down plans require appropriate NEPA 

compliance and implementation may require additional county, state and federal permits. Projectspecific plans, with appropriate NEPA compliance, may be prepared outside of these step-down 

plans. Step-down plans for the Refuge follow in Table C-1. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

C-2 Appendix C. Implementation 

Table C-1. Dungeness NWR Step-down Management Plans 

Step-Down Management Plan Status (Date Completed and/or Date to be 

Prepared/Updated) 

Habitat Management Plan (HMP) CCP meets requirement for HMP 

Forest Management Plan Prepare by 2018 

Integrated Pest Management Plan Prepared concurrently with CCP, Appendix G 

Fire Management Plan Complex-wide plan in draft concurrent with CCP 

Visitor Services Plan Initiate planning after completion of CCP 

Inventory and Monitoring Plan Initiate planning after completion of CCP 

C.3 Costs to Implement CCP 

The following sections detail both one-time and recurring costs for various projects as described 

within the CCP. One-time costs reflect the initial costs associated with a project, whether it is 

purchase of equipment, contracting services, construction, a research project, or other activity. 

Recurring costs reflect the future operational and maintenance costs associated with the project. The 

following tables primarily document projects with a physically visible, trackable “on-the-ground” 

component, such as facilities, habitat restoration, research, and monitoring and surveys. The scope 

and costs for “administrative” activities such as the development and implementation of cooperative 

documents (e.g., memorandum of understanding, agreements), reporting, and establishment of 

partnerships are difficult to estimate in advance and thus are not accounted for in the tables below. 

C.3.1 One-time costs 

One-time costs are project costs that have a start-up cost associated with them, such as purchasing a 

new vehicle for wildlife and habitat monitoring, or designing, constructing and installing an 

interpretive sign. Some cost estimates are for projects that can be completed in three years or less. 

One-time costs can include the cost of temporary or term salary associated with a short-term project. 

Salary for existing and new positions, and operational costs, are reflected in operational (or 

recurring) costs. 

Funds for one-time costs will be sought through increases in refuge base funding, special project 

funds, and grants. Projects listed below in Table C-2 show one-time start-up and implementation 

costs, such as those associated with building and facility needs including removal of old buildings, 

replacement of buildings, public use facilities, road/trail improvements, and new signs. One-time 

costs are also associated with projects such as habitat restoration, invasive plant and animal control, 

and research. In many cases, new research projects, because of their relatively high initial 

establishment cost, are considered one-time projects and include costs of contracting services or 

hiring a temporary staff position for the short-term project. Some project costs are taken from RONS 

or SAMMS proposals; others are not yet in any project database and their costs have been estimated, 

particularly if the scope of the project is unknown at this time due to lack of baseline data. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-3 

Table C-2. One-Time Costs (in thousands) for Research and Assessments; Inventories, Surveys, 

and Monitoring, Habitat Management and Restoration, Facilities and Public Use-Related 

Actions 

Project Description Priority Type 

Current 

Management 

Future 

Management 

Potential Fund 

Source 

Research 

Study the value of salt 

marsh habitat in 

Graveyard Spit as a 

nursery area for crab and 

salmon 

Low Study 0 5 1260 funds, 

grants, 

partnerships 

Study driftwood 

recruitment and removal 

rates within the barrier 

beach and salt marsh 

habitats 

Low Study 0 10 1260 funds, 

grants 

Study climate change 

impacts to natural spit 

habitats 

High Study 0 200 1260 funds, 

grants 

Study microhabitat 

characteristics to track 

changes in distribution 

and diversity of plant 

species in the Graveyard 

RNA 

Medium Study 0 15 1260 funds, 

grants 

Study eelgrass 

distribution and density 

in Dungeness Harbor and 

Bay. 

High Study 0 35 1260 funds, 

grants, 

partnerships 

Study habitat quality 

(water quality, forage fish 

abundance and 

distribution and micro 

and macro invertebrate 

abundance and 

distribution of mud flat 

habitat. 

Medium Project 0 30 1260 funds, 

grants, 

partnerships 

Subtotal (thousands) 295 

Surveys and assessments 

Assess abundance and 

distribution of 

Lepidopterans on 

Dungeness and 

Graveyard spits 

High Project 0 8 ESA funds, 

grants 

Conduct forest 

assessment 

High Project 0 20 1260 funds 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

C-4 Appendix C. Implementation 

Project Description Priority Type 

Current 

Management 

Future 

Management 

Potential Fund 

Source 

Conduct road inventory 

and assessment (Dawley 

Unit) 

Low Project 0 5 1260 funds 

Conduct wetland 

inventory and 

hydrological assessment 

Medium Project 0 20 1260 funds 

Conduct baseline 

breeding bird survey of 

forest habitat 

Medium Survey 0 3 1260 funds, 

partnerships

Conduct baseline 

amphibian and bat 

surveys 

Medium Survey 0 7 1260 funds, 

partnerships

Conduct baseline aquatic 

species survey of refuge 

reach of Dean Creek 

Medium Survey 0 2 1260 funds, 

partnerships

Assess habitat suitability 

for anadromous and 

resident fish of refuge 

reach of Dean Creek 

Medium Project 0 2 1260 funds, 

partnerships

Subtotal (thousands) 0 67 

Habitat management and restoration 

Map bathymetry of 

impoundment (Dawley)

Medium Project 0 7 1260 funds

Develop step-down forest 

management plan 

High Project 0 33 

Remove small dump site 

(Dawley) 

Low Project 0 5 1260 funds

Slide stabilization on 

main forest road 

(Dawley) 

High Project 0 90 1260 funds 

Rehabilitate unneeded 

logging spur roads 

(Dawley) 

Low Project 0 22 1260 funds

Install new water control 

structure and water gauge 

at impoundment 

(Dawley) 

Medium Project 0 12 1260 funds

Remove USCG road 

access dike at base of 

Dungeness Spit if 

determined to be on 

refuge lands 

Medium Project 0 45 1260 funds

Rehabilitate road to 

beach house (Dawley) 

High Project 0 90 1260 funds

Subtotal (thousands) 0 304 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-5 

Project Description Priority Type 

Current 

Management 

Future 

Management 

Potential Fund 

Source 

Facilities 

Remove and replace 

caretaker cabin at 

Dungeness (Mellus 

cabin) 

High Project 0 350 1260 funds 

Deferred 

Maintenance 

(DM)

Replace caretaker cabin 

septic system and 

decommission old system 

High Project 0 18 1260 funds 

(DM)

Remove beach house 

(Dawley) and 

decommission septic 

system 

Medium Project 0 45 1260 funds 

(DM) 

Remove mobile home, 

associated shed and 

decommission septic 

system (Dawley) 

Medium Project 0 12 1260 funds 

(DM)

Remove rental house and 

decommission septic 

system (Dawley) 

Medium Project 0 32 1260 funds 

(DM)

Remove large wooden 

shed (Dawley) 

Low Project 0 8 1260 funds 

(DM)

Replace dock (Dawley) Low Project 0 85 1260 fund 

(DM)

Subtotal (thousands) 0 550 

Public Use 

Design, construct and 

install information and 

map panels at Cline Spit 

and Dungeness Landing 

High Project 0 12 8081 funds. 

Design, construct and 

install interpretive panels 

at New Dungeness Light 

Station 

Medium Project 0 15 8081 funds 

Design, construct and 

install climate change 

interpretive panel at main 

trail kiosk 

Medium Project 0 10 8081 funds

Develop cultural and 

environmental education 

materials for use on the 

Refuge and in the 

classroom 

Low Project 0 15 1260 funds, 

grants

Subtotal (thousands) 0 52 

Total of all one-time 

project costs 

 1,268 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

C-6 Appendix C. Implementation 

C.3.2 Annual Operational (Recurring) Costs 

Operational costs reflect refuge spending of base funds allocated each year. These are also known as 

recurring costs and are usually associated with day-to-day operations and projects that last longer 

than three years. Operational costs use base funding in Service fund code 1260. Table C-3 displays 

projected annual operating costs to implement strategies under the CCP. The CCP will require 

increased funding for new or expanded public uses and facilities, habitat management and restoration 

activities, and new monitoring needs. This table includes such things as salary and operational 

expenditures such as travel, training, supplies, utilities, and maintenance costs. Project costs listed in 

Table C-3 include administrative support for all programs and projects as well as permanent and 

seasonal staff needed year after year to accomplish each project; these staffing costs are not isolated 

in this table but are included as part of the entire project cost. 

Table C-3. Annual Operational (recurring) costs 

Activity Description 

Current 

Management 

Cost est. (K) 

Future 

Management 

Cost est. (K) 

Potential 

Fund Source 

Research: Facilitate and cooperate in specific 

research projects to benefit refuge resources 

7 15 1260, Special 

Projects, Grants 

Surveys and assessments: Aerial, boat-based 

and land survey and assessments; joint wildlife 

surveys with WDFW; continue GIS-based 

inventory and monitoring programs for plants 

and wildlife; derelict fishing gear surveys; 

creosote log deposition surveys; invasive 

species monitoring; monitor biodiversity trends; 

provide administrative and material support for 

all biological activities. 

25 35 1260 and 

special project 

funds 

Habitat management and restoration: 

Inventory, remove, prevent establishment of, 

and control invasive plants. Treat infestations 

with IPM; implement silvicultural practices 

outlined in step-down forest management plan. 

35 145 1260 and 

special project 

funds 

Facilities maintenance: Maintain and make 

minor repairs on refuge infrastructure and 

facilities, equipment, vehicles, boats and 

interpretive and regulatory signs. 

100 140 1260 

Public use opportunities and education: 

Provide funding for and manage a variety of 

both on-refuge and off-refuge interpretive and 

education programs; maintain interpretive 

panels located on and off the Refuge to offer 

interpretation through self-guided experience; 

conduct and manage volunteer program; patrol, 

enforce regulations and educate visitors to the 

sensitivity of wildlife resources, replace 

boundary and regulatory signage as needed. 

130 200 1260, 8081 

Total Recurring Costs 297 535 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-7 

C.3.3 Maintenance Costs 

The refuge maintenance program funding need over the next 15 years is defined as funds needed to 

repair or replace buildings, equipment, and facilities. Maintenance actions include preventative 

maintenance; cyclic maintenance; repairs; replacement of parts, components, or items of equipment; 

adjustments, lubrication, and cleaning (non-janitorial) of equipment; painting; resurfacing; 

rehabilitation; special safety inspections; and other actions to assure continuing service and to 

prevent breakdown. Maintenance costs include the maintenance “backlog” needs that have come due 

but are as yet unfunded, as well as the increased maintenance need associated with new facilities 

The facilities associated with Dungeness NWR that require maintenance include trails, kiosks, 

interpretive panels, regulatory signs, roads, parking lots, fencing, public restroom, caretaker cabin 

and administrative office, shop and garage buildings. Major equipment includes boats, vehicles, 

tractors, ATVs, and generators. Approximately 65% of operational (non-project) maintenance 

funding for the Washington Maritime NWR Complex is expended on Dungeness NWR including the 

Complex headquarters facilities (also see Table C-3); the other approximately 35% is used to 

maintain facilities, including buildings and equipment, which are located on, or support, the other 

three Complex Refuges and are not included in this Implementation Plan. 

C.3.4 Staffing 

Current (2012) staffing and future staffing to implement the programs detailed within the CCP are 

shown in Table C-4. Current positions serve all six refuges within the Washington Maritime NWR 

Complex; because there is no separate budget for the individual refuges, we have chosen to present 

the entire Complex staff in Table C-4. Approximately 55% Complex staff time is expended on 

Dungeness NWR; the other approximately 45% of staff time is expended on the other five refuges in 

the Complex. The new position (Environmental Education/Outreach Specialist) will work 70% of the 

time on Dungeness NWR and the rest of the time on the other refuges in the Complex. 

Table C-4. Current and Future Staffing 

Current Position Status GS & Grade 

Annual Salary* 

Cost (K) 

Annual Salary* 

(K) x 55% 

Project Leader PFT GS-0485-12 107.5 59.1 

Deputy Project Leader PFT GS-0485-11 91.1 50.1 

Wildlife Biologist PFT GS-0486-11 87.8 48.3 

Park Ranger PFT GS-025-09 78.3 43.1 

Maintenance Worker PFT WG-4749-08 81.7 44.5 

Office Automation Clerk PFT GS-0326-04 40.5 22.3 

Future Position 

Annual Salary 

(K) x 70% 

Environmental Education/Visitor 

Services Specialist 

PFT GS-1001-7/9 52.3 36.6 

Total current and future staffing costs 304 

* = salary and benefits 

PFT: Permanent Full Time 

GS: General Schedule Federal Employee 

WG: Wage Grade Federal Employee 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

C-8 Appendix C. Implementation 

C.3.5 Budget Summary 

Table C-5 summarizes the data from Tables C-2 and C-3 and displays the overall funding needed for 

the Washington Maritime National Wildlife Refuge Complex to implement the CCP for Dungeness 

NWR. 

Table C-5. Budget Summary (One-time projects and annual funding needs for Dungeness 

NWR as identified in the CCP) 

Budget Category Current Management Future Management 

One-time 

cost (K) 

Annual recurring 

cost (K) 

One-time 

cost (K) 

Annual recurring 

cost(K) 

Research - 7 295 15 

Surveys and assessments - 25 67 35 

Habitat management and 

restoration 

- 35 304 145 

Facilities and 

maintenance 

- 100 550 140 

Public use opportunities 

and education 

- 130 52 200 

Totals - 297 1,268 535 

C.4 Partnership Opportunities 

Partnerships are an important component of the implementation of this CCP and are reflected in the 

goals, objectives, and strategies identified in Chapter 2. The Refuge’s location (Olympic Peninsula) 

facilitates many opportunities for partnerships. Current and past partners include federal and state 

agencies, Tribes, non-governmental organizations, schools volunteers, and individuals. 

Coordinated partnerships efforts will focus on habitat restoration, land protection, environmental 

education, fish and wildlife monitoring, outreach, and quality wildlife-dependent recreation. Refuge 

Complex staff will work to strengthen existing partnerships and will actively look for new 

partnerships to assist in achieving the goals, objectives, and strategies in this CCP. 

Jamestown S’Klallam Tribe 

The Service has a close working relationship with the Tribe. The Tribe and the Service have 

collaborated on a number of projects including addressing water quality issues in Dungeness Harbor 

and Bay. The Service will partner with the Jamestown S’Klallam Tribe and other interested Tribes to 

deliver education and interpretation programs and materials that focus on the Refuge and area Native 

American culture. In addition, the Service will partner with interested Tribes for cultural resources 

inventory, evaluation, and project monitoring, consistent with the regulations of the National Historic 

Preservation Act. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-9 

U. S. Coast Guard (USCG)

The Service will coordinate with the USCG on transfer of the New Dungeness Light Station to the 

U.S. Fish and Wildlife Service. As part of that transfer the Service will work with the USCG on any 

unresolved contaminants issues concerning the lighthouse site. 

National Oceanic and Atmospheric Administration 

National Oceanic and Atmospheric Administration – Fisheries conducts research and monitors 

marine mammals in the Salish Sea. These activities are managed under a Special Use Permit when 

conducted on refuge lands and have involved Steller’s sea lions, elephant seals, and harbor seals 

National Park Service 

The Service will partner with Olympic National Park (ONP) on developing and presenting consistent 

and complementary interpretive material and programs on climate change to visitors and local 

community members. The Service will formalize an agreement with ONP for support on wildfires for 

initial attack resources. 

U.S. Forest Service 

Forest Service personnel from the Olympic National Forest Service staff participated in the 

preliminary CCP planning phase with several site visits to the forested habitat. The Service will 

consult with the Olympic National Forest as we develop the Forest Management Plan. 

Washington Department of Fish and Wildlife (WDFW) 

WDFW’s management responsibilities including lands and waters, fish and wildlife, threatened and 

endangered species and other programs, frequently overlap with USFWS resources and 

responsibilities. The WDFW and other state agencies are in a unique position to greatly assist the 

Service in protecting sensitive seabirds and pinnipeds from human disturbance in close proximity to 

the Complex Refuges. The Service and WDFW share mutual interests in species management, 

wildlife surveys, developing joint research projects, and education and outreach programs. The 

WDFW has been closely involved with the Service in waterfowl surveys, pinniped surveys, black 

oystercatcher and pigeon guillemot surveys, forage fish spawning beach surveys and review of 

Service’s projects in the marine environment. 

Washington Department of Ecology (WDOE) 

One of Washington Department of Ecology’s programs is spill prevention, preparedness, and 

response. This program focuses on prevention of oil spills to Washington State waters and land, as 

well as planning for an effective response to oil and hazardous substance spills whenever they occur. 

The Service will continue its partnership with WDOE in support and maintenance of a regional 

contingency plan that guides how spills are managed in the Northwest; and in the development and 

periodic review of Geographic Response Plans. 

Washington Department of Natural Resources (WDNR) 

Washington Department of Natural Resources has monitored eelgrass in the Salish Sea for a number 

of years using a variety of techniques including videography. The Service will partner with them for 

monitoring eelgrass beds in Dungeness Harbor and Bay. In addition, the Refuge will consult with 

them as we develop the Forest Management Plan. The Refuge uses WNDR’s Olympic Region as a 

dispatching resource for wildfires on the Refuge. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

C-10 Appendix C. Implementation 

Clallam County 

The Service will continue its cooperative relationship with Clallam County Parks on management of 

the Dungeness Recreation Area that lies immediately adjacent to Dungeness NWR and which refuge 

visitors must pass through to access the Refuge. The Service leases County property for parking lots 

and a public restroom at the refuge entrance. In addition, the Service will continue to work with 

Clallam County Department of Health and Human Services’ Division of Environmental Health on 

water quality issues in Dungeness Harbor and Bay. 

Clallam County Marine Resources Committee (MRC) 

The Service has partnered with the MRC for a number of years as the Refuge and its resources are 

important components of the marine ecosystem of the Strait of Juan de Fuca and the Salish Sea. 

Removal of derelict fishing gear (crab pots) and survey of eelgrass beds in Dungeness Harbor and 

Bay are projects the MRC has funded in the past and which the Service wishes to continue with the 

MRC partnership. 

University of Washington (UW) 

The Refuge participates in the UW’s Coastal Observation and Seabird Survey Team (COASST) 

program. A citizen science project, COASST monitors local marine resources and ecosystem health. 

In addition to providing beached bird data to the Refuge, these volunteers also act as an “early 

warning system” to alert the Refuge to any unusual or catastrophic marine events. 

Olympic Peninsula Audubon Society (OPAS) 

Olympic Peninsula Audubon Society has partnered with the Service on a number of important 

projects. Members of OPAS assist with the annual Christmas Bird Count and the Refuge’s 

participation in Cornell Lab of Ornithology Feeder Watch program. Breeding bird surveys have also 

been conducted by OPAS members. 

New Dungeness Light Station Association 

The New Dungeness Light Station is maintained and operated by the New Dungeness Light Station 

Association, a non-profit historical organization, under an agreement with the U.S. Coast Guard 

(USCG). The Association offers light house tours and interpretation every day of the year. In the 

event that the USCG declares the light station property excess to its needs, the Service will work with 

the USCG to bring the light station property into the Refuge System. Subsequently, the Service plans 

to enter into an agreement with the NDLSA to continue their management and maintenance of the 

light station facilities. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-1 

Appendix D. Wilderness Review 

D.1 Introduction 

D.1.1 Refuge Overview 

Dungeness National Wildlife Refuge (NWR or Refuge) consists of the Dungeness Unit, which 

includes the Graveyard Spit Research Natural Area (RNA), and the Dawley Unit. The Dungeness 

Unit was established to protect and preserve breeding grounds for native birds in 1915. Originally the 

Unit was part of a lighthouse reservation, on which the New Dungeness Light Station was built in 

1857. Dungeness Spit is the longest sand spit in North America. Extending five miles into the Strait 

of Juan de Fuca, it provides habitat for a great variety of migratory shorebirds, waterfowl, marine 

mammals, and marine life. The waters of Dungeness Bay, with its eelgrass beds, mudflats, and 

tidelands provide food, shelter, and breeding grounds to support a whole ecosystem teeming with 

life. Large numbers of brant, wigeon, pintail, mallard and bufflehead spend their winters here. Surf 

smelt, herring, Pacific sand lance and other species of marine fish breed and rear within the bay. 

Anadromous fish such as chinook, chum, pink, coho salmon and steelhead and cutthroat trout are 

dependent on nearshore habitats within Dungeness Bay and Harbor during the juvenile rearing 

period. The bay also serves as a vital nursery area for commercially important species such as marine 

invertebrates (e.g., Dungeness crab) which seek these areas for refugia. The rare northern elephant 

seal hauls out on the spit each year. Graveyard Spit supports some of the best remaining coastal 

strand habitat within the Salish Sea. Upland habitats at the base of Dungeness Spit include forests 

and sandy bluffs. 

The Dawley Unit, located along Sequim Bay, was established as a wildlife sanctuary in 1973. The 

residential area was heavily developed with the construction of aviaries, ponds, and gardens while 

the forested tract was altered by logging over the years. The forested area does have an established 

logging road system, but due to the topography, some areas were protected from further alterations 

and are considered good second growth forest habitat. 

D.1.2 Policy and Direction for Wilderness Reviews 

U.S. Fish and Wildlife Service policy (Part 602 FW 3.4 C. (1) (c)) requires that wilderness reviews 

be completed as part of the CCP process. This review includes the re-evaluation of refuge lands 

existing during the initial 10-year review period of the Wilderness Act of 1964, as amended (16 

U.S.C. 1131-1136), as well as new lands and waters added to the Refuge System since 1974. A 

preliminary inventory of the wilderness resources is to be conducted during pre-acquisition planning 

for new or expanded refuges (341 FW 2.4 B, “Land Acquisition Planning”). Refuge System policy 

on Wilderness Stewardship (610 FW 1-5) includes guidance for conducting wilderness reviews (610 

FW 4 – Wilderness Review and Evaluation). 

A wilderness review is the process of determining whether the Service should recommend Refuge 

System lands and waters to Congress for wilderness designation. The wilderness review process 

consists of three phases: wilderness inventory, wilderness study, and wilderness recommendation. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

D-2 Appendix D. Wilderness Review 

Wilderness Inventory 

The inventory is a broad look at a refuge to identify lands and waters that meet the minimum criteria 

for wilderness—size, naturalness, and outstanding opportunities for solitude or primitive and 

unconfined type of recreation. All areas meeting the criteria are preliminarily classified as 

Wilderness Study Areas (WSAs). If WSAs are identified, the review proceeds to the study phase. 

Wilderness Study 

During the study phase, WSAs are further analyzed: 

1. for all values of ecological, recreational, cultural, economic, symbolic 

2. for all resources, including wildlife, vegetation, water, minerals, soils 

3. for existing and proposed public uses 

4. for existing and proposed refuge management activities within the area, 

5. to assess the refuge’s ability to manage and maintain the wilderness character in perpetuity, 

given the current and proposed management activities. Factors for evaluation may include, 

but are not limited to, staffing and funding capabilities, increasing development and 

urbanization, public uses, and safety. 

We evaluate at least an “All Wilderness Alternative” and a “No Wilderness Alternative” for each 

WSA to compare the benefits and impacts of managing the area as wilderness as opposed to 

managing the area under an alternate set of goals, objectives, and strategies that do not involve 

wilderness designation. We may also develop “Partial Wilderness Alternatives” that evaluate the 

benefits and impacts of managing portions of a WSA as wilderness. 

In the alternatives, we evaluate: 

1. the benefits and impacts to wilderness values and other resources 

2. how each alternative would achieve the purposes of the Wilderness Act and the National 

Wilderness Preservation System 

3. how each alternative would affect achievement of refuge purpose(s) and the refuge’s 

contribution toward achieving the Refuge System mission 

4. how each alternative would affect maintaining and, where appropriate, restoring biological 

integrity, diversity, and environmental health at various landscape scales 

5. other legal and policy mandates 

6. whether a WSA can be effectively managed as wilderness by considering the effects of 

existing private rights, land status and service jurisdiction, refuge management activities and 

refuge uses, and the need for or possibility of eliminating Section 4(c) prohibited uses 

Wilderness Recommendation 

If the wilderness study demonstrates that a WSA meets the requirements for inclusion in the National 

Wilderness Preservation System, a wilderness study report should be written that presents the results 

of the wilderness review, accompanied by a Legislative Environmental Impact Statement (LEIS). 

The wilderness study report and LEIS that support wilderness designation are then transmitted 

through the Secretary of the Interior to the President of United States, and ultimately to the United 

States Congress for action. Refuge lands recommended for wilderness consideration by the 

wilderness study report will retain their WSA status and be managed as “... wilderness according to 

the management direction in the final CCP until Congress makes a decision on the area or we 

amended the CCP to modify or remove the wilderness recommendation” (610 FW 4.22B). When a 

WSA is revised or eliminated, or when there is a revision in “wilderness stewardship direction, we 

include appropriate interagency and tribal coordination, public involvement, and documentation of 

compliance with NEPA” (610 FW 3.13). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-3 

D.1.3 Criteria for Evaluating Lands for Possible Inclusion in the National 

Wilderness Preservation System 

The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136), provides the following description 

of wilderness: 

“A wilderness, in contrast with those areas where man and his own works dominate the landscape, is 

hereby recognized as an area where the earth and its community of life are untrammeled by man, 

where man himself is a visitor who does not remain. An area of wilderness is further defined to mean 

in this Act as an area of undeveloped Federal land retaining its primeval character and influence, 

without permanent improvements or human habitation, which is protected and managed so as to 

preserve its natural conditions...” 

The following criteria for identifying areas as wilderness are outlined in Section 2(c) of the Act and 

are further expanded upon in Refuge System policy (610 FW 4). The first three criteria are evaluated 

during the inventory phase; the fourth criterion is evaluated during the study phase. 

1. Generally appears to have been affected primarily by the forces of nature, with the imprint of 

man’s work substantially unnoticeable; 

2. Has outstanding opportunities for solitude or a primitive and unconfined type of recreation; 

3. Has at least five thousand acres of land or is of a sufficient size as to make practicable its 

preservation and use in an unimpaired condition; and 

4. May also contain ecological, geological, or other features of scientific, educational, scenic, or 

historic value. 

 

Criterion 3 is further defined in Section 3(c) of the Act as 1) a roadless area of 5,000 contiguous 

acres or more, or 2) a roadless island. Roadless is defined as the absence of improved roads suitable 

and maintained for public travel by means of 4-wheeled, motorized vehicles that are intended for 

highway use. 

D.1.4 Relationship to Previous Wilderness Reviews 

No previous wilderness reviews have been prepared for Dungeness NWR. 

D.2 Wilderness Inventory 

The following constitutes the inventory phase of the wilderness review for the Dungeness National 

Wildlife Refuge. 

D.2.1 Lands Considered Under This Wilderness Review 

All FWS-owned lands and waters (in fee title) within the Dungeness NWR boundary were 

considered during this wilderness review. 

D.2.2 Inventory Units 

The first step of a wilderness assessment is to divide a refuge or other management entity into 

preliminary wilderness evaluation units. The boundaries of these artificial units can follow the refuge 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

D-4 Appendix D. Wilderness Review 

boundary, but may not cross permanent roadways, private or other non-Federal lands, or non-Service 

owned waterways. These roads, non-Federal lands, or waterways can form the boundary for an 

individual evaluation unit. Other obvious incompatible wilderness uses or structures (such as refuge 

headquarters, residential areas, rights-of-way, and non-jurisdictional waters) may also be eliminated 

from any evaluation units at this time. Once boundaries have been established for each individual 

evaluation unit, the criteria in Section D.2.3 are applied to determine each unit’s suitability as 

potential wilderness and the need for further evaluation under the Wilderness Study. 

In determining units to be evaluated for wilderness character per this inventory, the Refuge was 

mapped using geographic information system (GIS) software. Using the major constraints set by the 

Wilderness Act, specifically land ownership/refuge boundary and permanent road systems, initial 

large evaluation units were developed by including all contiguous lands within those intractable 

confines. Through this process, four units were defined for evaluation: 

For the purposes of this wilderness review, the 392.3 acre Dungeness Unit is defined to include all 

refuge-owned forested lands at the base of Dungeness Spit and Dungeness and Graveyard spits. 

Tracts 10a and 12 are not contiguous with the remainder of the unit and thus are considered a 

separate unit (the 4.9 acre Mellus/Nature Conservancy Unit). The Dungeness Unit consists of coastal 

strand and spit, coastal lagoon, salt marsh, intertidal mudflat, and upland habitats. Upland habitats 

include second growth Douglas-fir/western hemlock/western red cedar forest, alder forest, and sandy 

bluffs. Dungeness Spit is 5.5 miles long and averages 300 feet wide (from mean low water); however 

the narrowest portion measures approximately 50 feet wide during high tide. Graveyard Spit is about 

1.4 miles long and averages 475 feet wide. Cumulatively, Dungeness and Graveyard spits consist of 

approximately fifteen miles of undeveloped sandy beach. Graveyard Spit was designated a Research 

Natural Area in 1990 because of its high quality low intertidal, high salinity sandy marsh; coastal spit 

with native vegetation; and high salinity coastal lagoon. Refuge visitor and administrative facilities 

are located on this unit. 

The forested 4.9 acre Mellus/Nature Conservancy (Tracts 10a and 12) Unit is located east of the 

base of Dungeness Spit and fronts Dungeness Bay and Harbor. There is private property separating 

this unit from the main Dungeness Unit. This unit provides a buffer for the Refuge and protects the 

viewshed to the east of the observation platforms along the main trail on the Dungeness Unit. 

The 14.7 acre Dawley North Unit is located along the southern part of Sequim Bay and north of 

Highway 101. The residential area was heavily developed with the construction of aviaries, ponds, 

and gardens. The Dawley North Unit structures and property are in caretaker status and the Service 

intends to work with other agencies or conservation organizations to pursue cooperative 

management. 

The 116.5 acre Dawley South Unit is located south of Highway 101. This unit is primarily forested 

with a ribbon of riparian forest along Dean Creek running through the southwest corner and a small 

1/5th acre impoundment located in the center of the unit. The forest has been altered by logging over 

the years and is now considered second growth. Consequently, an established logging road system 

still persists. State and private land border this unit. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-5 

D.2.3 Process of Analysis 

The following evaluation process was used in identifying the suitability of refuge units for wilderness 

designation: 

 Determination of refuge unit sizes. 

 Assessment of the units’ capacity to provide opportunities for solitude or primitive and 

unconfined recreation. 

 Assessment of “naturalness” of refuge units. 

General guidelines used for evaluating areas for wilderness potential during this wilderness inventory 

process include: 

1. The area should provide a variety of habitat types and associated abiotic features, as well as a 

nearly complete complement of native plants and wildlife indicative of those habitat types. 

Non-native and invasive species should comprise a negligible portion of the landscape. 

2. The area should be spatially complex (vertically and/or horizontally) and exhibit all levels of 

vegetation structure typical of the habitat type, have an interspersion of these habitats, and 

provide avenues for plant and wildlife dispersal. 

3. The area should retain the basic natural functions that define and shape the associated 

habitats, including but not limited to, flooding regimes, fire cycles, unaltered hydrology and 

flowage regimes, basic predator-prey relationships including herbivory patterns. 

4. Due to their size, islands may not meet the habitat guidelines in 1 and 2 above. Islands 

should, however, exhibit the natural cover type with which they evolved and they should 

continue to be shaped and modified by natural processes. Islands should be further analyzed 

during the study portion of the review if they provide habitat for a significant portion of a 

population, or key life cycle requirements for any resources of concern or listed species. 

5. Potential wilderness areas should be relatively free of permanent structures or man-made 

alterations. Areas may be elevated to the study phase if existing structures or alterations can 

be removed or remediated within a reasonable timeframe, and prior to wilderness 

recommendation to the Secretary of the Interior. 

Supplemental Values – The Wilderness Act states that an area of wilderness may contain ecological, 

geological, or other features of scientific, educational, scenic, or historical value. Supplemental 

values of the area are optional, but the degree to which their presence enhances the area’s suitability 

for wilderness designation should be considered. The evaluation should be based on an assessment of 

the estimated abundance or importance of each of the features. 

More detail on the factors considered and used for each assessment step follows. 

Unit Size: Roadless areas meet the size criteria if any one of the following standards applies: 

 An area with over 5,000 contiguous acres solely in Service ownership. 

 A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or an area that is markedly distinguished from the surrounding lands by 

topographical or ecological features. 

 An area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

D-6 Appendix D. Wilderness Review 

 An area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau of 

Land Management. 

Outstanding Solitude or Primitive or Unconfined Recreation: 

A designated wilderness area must provide outstanding opportunities for solitude or a primitive and 

unconfined type of recreation. Possession of only one of these outstanding opportunities is sufficient 

for an area to qualify as wilderness, and it is not necessary for one of these outstanding opportunities 

to be available on every acre. Furthermore, an area does not have to be open to public use and access 

to qualify under these criteria. 

Opportunities for solitude refer to the ability of a visitor to be alone and secluded from other visitors 

in the area. Primitive and unconfined recreation means non-motorized, dispersed outdoor recreation 

activities that are compatible and do not require developed facilities or mechanical transport. 

Primitive recreation activities may provide opportunities to experience challenge and risk, selfreliance, and adventure. 

Naturalness and Wildness: the area generally appears to have been affected primarily by the 

forces of nature, with the imprint of man’s work substantially unnoticeable. 

This criterion must be evaluated in the context of current natural conditions and societal values and 

expectations without compromising the original intent of the Wilderness Act. It is well recognized 

that there are few areas remaining on the planet that could be truly classified as primeval or pristine, 

with even fewer, if any, existing in the conterminous United States. Likewise, few areas exist that do 

not exhibit some impact from anthropogenic influences, be it noise, light, or air pollution; water 

quality or hydrological manipulations; past and current land management practices; roads or trails, 

suppression of wildfires; invasions by non-native species of plants and animals; or public uses. While 

allowing for the near-complete pervasiveness of modern society on the landscape, the spirit of the 

Wilderness Act is to protect lands that still retain the wilderness qualities of being: 1) natural, 2) 

untrammeled, 3) undeveloped. These three qualities are cornerstones of wilderness character. For 

areas proposed or designated as wilderness, wilderness character must be monitored to determine 

baseline conditions and thereafter be periodically monitored to assess the condition of these 

wilderness qualities. Proposed and designated wilderness areas by law and policy are required to 

maintain wilderness character through management and/or restoration in perpetuity. 

 

Defining the first two qualities (natural and untrammeled) requires knowledge and understanding of 

the ecological systems which are being evaluated as potential wilderness. Ecological systems are 

comprised of three primary attributes – composition, structure, and function. Composition is the 

components that make up an ecosystem, such as the habitat types, native species of plants and 

animals, and abiotic (physical and chemical) features. These contribute to the diversity of the area. 

Structure is the spatial arrangement of the components that contribute to the complexity of the area. 

Composition and structure are evaluated to determine the naturalness of the area. Function is the 

processes that result from the interaction of the various components both temporally and spatially, 

and the disturbance processes that shape the landscape. These processes include, but are not limited 

to, predator-prey relationships, insect and disease outbreaks, nutrient and water cycles, 

decomposition, fire, windstorms, flooding, and both general and cyclic weather patterns. Ecological 

functions are evaluated to determine the wildness or untrammeled quality of the area. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-7 

The third quality assessment is whether an area is undeveloped. Undeveloped refers to the absence of 

permanent structures such as roads, buildings, dams, fences, and other man-made alterations to the 

landscape. Exceptions can be made for historic structures or structures required for safety or health 

considerations, providing they are made of natural materials and relatively unobtrusive on the 

landscape. 

D.2.4 Summary of Inventory Results and Conclusion 

Table D-1 summarizes the above evaluation factors for each of the units that were delineated and 

evaluated as described in Sections D.1.1 and D.2.3. 

In this inventory, the 392.3 acre Dungeness Unit, 4.9 acre Mellus/Nature Conservancy (Tracts 10a 

and 12) Unit, 14.7 acre Dawley North Unit, and 116.5 acre Dawley South Unit did not meet the 

minimum wilderness criteria for size, outstanding opportunities for solitude and primitive/unconfined 

recreation, or naturalness. While the Refuge contains some excellent examples of coastal habitats, the 

small acreage, discontinuous refuge lands, and the presence of heavily used roads adjacent to the 

Refuge results in a determination that Dungeness National Wildlife Refuge does not satisfy minimum 

wilderness suitability criteria. 

Table D-1. Results of Wilderness Inventory for Dungeness NWR 

Refuge Unit Size Outstanding 

opportunities for solitude 

or primitive/unconfined 

recreation 

Naturalness Summary: Area will 

move forward for 

Wilderness Study 

Dungeness Unit No NE NE No 

Mellus/Nature 

Conservancy (Tracts 

10a and 12) Unit 

No NE NE No 

Dawley North Unit No NE NE No 

Dawley South Unit No NE NE No 

Notes: 

NE – Not evaluated (once any wilderness criteria was not met, further evaluation was not conducted.) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

D-8 Appendix D. Wilderness Review 

Document continues on next page. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-1 

Appendix E. Biological Resources of Concern 

E.1 Introduction 

Management direction of individual refuges is driven by refuge purposes and statutory mandates, 

coupled with species and habitat priorities. Management on a refuge should first and foremost 

address the individual refuge purposes. Additionally, management should address maintenance and, 

where appropriate, restoration of Biological Integrity, Diversity, and Environmental Health (BIDEH) 

as well as management for NWRS Resources of Concern. In this approach, each refuge contributes to 

the goals of the NWRS (601 FW 1) and achievement of the NWRS Mission. 

In concert with this approach, and as an initial step in planning, the planning team identified 

resources of concern for Dungeness National Wildlife Refuge (NWR or Refuge). As defined in the 

Policy on Habitat Management Plans (620 FW 1), resources of concern are: 

“all plant and/or animal species, species groups, or communities specifically identified in 

refuge purpose(s), System mission, or international, national, regional, State, or ecosystem 

conservation plans or acts. For example, waterfowl and shorebirds are a resource of concern 

on a refuge whose purpose is to protect ‘migrating waterfowl and shorebirds.’ Federal or 

State threatened and endangered species on that same refuge are also a resource of concern 

under terms of the respective endangered species acts (620 FW 1.4G).” 

To provide a framework for development of goals and objectives in the CCP, the planning team 

identified resources of concern, following the process outlined in the Service’s draft Identifying 

Refuge Resources of Concern and Management Priorities: A Handbook (USFWS 2009). 

E.2 Comprehensive Resources of Concern 

A comprehensive list of potential resources of concern was created early in the planning process. The 

team identified species, species groups, and communities of concern, based upon a review of the 

Refuge’s establishing history and purposes, a description of the key habitat types existing at the 

Refuge and a review of numerous conservation plans (see Section 1.7 of the CCP), many of which 

highlight priority species or habitats for conservation. The Comprehensive Resources of Concern list 

is contained in Table E-1. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-2 Appendix E. Biological Resources of Concern 

Table E-1. Dungeness National Wildlife Refuge Table of Comprehensive Resources of Concern 

Species/Habitat 

Refuge Purpose Species BIDEH Fed ESA Status 1State Status 2State Rank WNHP 3MMPA Species 4USFWS Bird of Management Concern or Bird of Conservation Concern 5Pacific Region Seabird Plan 6N Pacific Coast Shorebird Plan 7State Wildlife Action Plan Priorities8TNC WV/PT/GB EA 9PIF Species Assessment - BCR510Refuge Occurrence Ecological Significance 

SEABIRDS 

Double-crested 

Cormorant 

 S4S5B NC

R 

 X Year-round 

Pelagic 

Cormorant 

 S4B, 

S4N 

 BCR5 HC X Year-round 

Heermann’s 

Gull 

 S5N MC Migration & 

winter 

Western Gull S4B, 

S4N 

 LC Year-round 

Glaucouswinged/Western 

Gull 

 S5B, 

S5N, 

S4B, 

S4N 

 Year-round Close 

proximity to 

largest 

colony in 

Salish Sea 

Caspian Tern M S3B BCR5 MC Breeding First 

observed in 

2003, issues 

with avian & 

mammalian 

predation 

Marbled 

Murrelet 

 T T S3 BCR5 HC X X Adjacent to 

Dawley Unit, 

Breeding 

Pigeon 

Guillemot 

 S4B, 

S4N 

 MC X Breeding; 

foraging 

SHOREBIRDS 

Black-bellied 

Plover 

 S4N 3 X Migration, 

winter 

Snowy Plover T E S1 5 X Very limited 

observations 

Reports on 

Dungeness 

Spit in 1995, 

1996, 2012; 

nonbreeding 

Black 

Oystercatcher 

 M S4 N, R1, 

BCR5 

 4 X Year-round 

Whimbrel S3N N, R1, 

BCR5 

 4 Migration 

Sanderling S4N 3 X Migration, 

winter 

Western S4S5N 3 X Migration 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-3 

Species/Habitat 

Refuge Purpose Species BIDEH Fed ESA Status 1State Status 2State Rank WNHP 3MMPA Species 4USFWS Bird of Management Concern or Bird of Conservation Concern 5Pacific Region Seabird Plan 6N Pacific Coast Shorebird Plan 7State Wildlife Action Plan Priorities8TNC WV/PT/GB EA 9PIF Species Assessment - BCR510Refuge Occurrence Ecological Significance 

Sandpiper 

Least Sandpiper S4N 3 X Migration 

Dunlin X S4S5N 3 X Migration, 

winter 

WATERFOWL 

Brant S3N GBBDC X X Migration, 

winter 

Harlequin Duck S2B, 

S3N 

GBBDC X Migration, 

winter 

Mallard S5B, 

S5N 

GBBDC 

American 

Wigeon 

 S4B, 

S5N 

GBBDC X Migration, 

winter 

Northern 

Shoveler 

 S4B, 

S3N 

 Migration, 

winter 

Northern Pintail S3B, 

S4N 

GBBDC X Migration, 

winter 

Green-winged 

Teal 

 S4B, 

S3N 

 Migration, 

winter 

Greater Scaup S3N GBBDC X X Migration, 

winter 

Lesser Scaup S3N, 

S4B 

GBBDC X X Migration, 

winter 

Surf Scoter S3N X X Migration, 

winter 

White-winged 

Scoter 

 S3N X X Migration, 

winter 

 

Black Scoter S3N X X Migration, 

winter 

 

Common 

Goldeneye 

 S5N Migration, 

winter 

 

Barrow’s 

Goldeneye 

 S3B, 

S4N 

 Migration, 

winter 

 

OTHER WATERBIRDS 

Great Blue 

Heron 

 M S4S5B, 

S5N 

 X X Year-round Limited 

abundance 

RAPTORS 

Bald Eagle S S4B, 

S4N 

 N, R1, 

BCR5 

 X X 14 Year-round 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-4 Appendix E. Biological Resources of Concern 

Species/Habitat 

Refuge Purpose Species BIDEH Fed ESA Status 1State Status 2State Rank WNHP 3MMPA Species 4USFWS Bird of Management Concern or Bird of Conservation Concern 5Pacific Region Seabird Plan 6N Pacific Coast Shorebird Plan 7State Wildlife Action Plan Priorities8TNC WV/PT/GB EA 9PIF Species Assessment - BCR510Refuge Occurrence Ecological Significance 

Northern Harrier S3B, 

S3N 

 12 Year-round 

Sharp-shinned 

Hawk 

 S3S4B, 

S4N 

 14 Year-round 

Cooper’s Hawk S4B, 

S4N 

 15 Year-round 

Merlin S3B, 

S4N 

 13 Migration 

Peregrine Falcon S S2B, 

S3N 

 N, R1, 

BCR5 

 X X 13 Year-round 

LANDBIRDS 

Snowy Owl M S3N n/

a 

Irruptive 

winter visitor 

Band-tailed 

Pigeon 

 S

C 

 S4B X Year-round 

Short-eared Owl S2S3B, 

S3N 

 N, R1 X 12 Breeding 

Northern Sawwhet Owl  S4B, 

S4N 

 15 Migration, 

winter 

Rufous 

Hummingbird 

 S4B N, R1, 

BCR5 

 X 17 Year-round 

Belted 

Kingfisher 

 S5 14 Year-round 

Red-breasted 

Sapsucker 

 S4S5 X 18 Year-round 

Pileated 

Woodpecker 

 X S S4 12 Year-round 

Pacific-slope 

Flycatcher 

 S4S5B X 17 Breeding 

Hutton’s Vireo S5 16 Year-round 

Steller’s Jay S5 14 Year-round 

Northwestern 

Crow 

 S4? 17 Year-round 

Chestnut-backed 

Chickadee 

 S5 X 17 Year-round 

Bewick’s Wren S5 N 11 Year-round 

Golden-crowned 

Kinglet 

 S4S5B X 17 Year-round 

Varied Thrush S5B, 

S5N 

 15 Year-round 

Orange-crowned 

Warbler 

 S4B 14 Breeding, 

migration 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-5 

Species/Habitat 

Refuge Purpose Species BIDEH Fed ESA Status 1State Status 2State Rank WNHP 3MMPA Species 4USFWS Bird of Management Concern or Bird of Conservation Concern 5Pacific Region Seabird Plan 6N Pacific Coast Shorebird Plan 7State Wildlife Action Plan Priorities8TNC WV/PT/GB EA 9PIF Species Assessment - BCR510Refuge Occurrence Ecological Significance 

Townsend’s 

Warbler 

 S4N, 

S5B 

 16 Breeding, 

migration 

Spotted Towhee S5B, 

S5N 

 14 Year-round 

Bullock’s Oriole S4B 14 Migration 

Pine Siskin S4S5B 14 Year-round 

MARINE MAMMALS 

Pacific Harbor 

Seal 

 X M S4 X X Year-round pupping site 

Northern 

Elephant Seal 

 SNA X Haul-out rare 

OTHER SPECIES 

Pacific Sand 

Lance 

 X X Year-round, 

spawning 

key 

component 

of the marine 

food web 

Surf Smelt SNR X X Year-round, 

spawning 

key 

component 

of the marine 

food web 

Pacific Herring SNR X Year-round, 

spawning 

key 

component 

of the marine 

food web 

Puget Sound 

Chinook 

 T S

C 

SNR Year-round, 

Dungeness 

Unit 

Hood Canal 

Summer Chum 

 T S

C 

SNR varies, 

Dungeness 

Unit 

Keen’s Myotis C S1 X X potential at 

Dawley Unit 

Townsend’s 

Big-eared Bat 

 S

C 

C S2S3 X X potential at 

Dawley Unit 

Cope’s Giant 

Salamander 

 S3S4 X potential at 

Dawley Unit 

Olympic Torrent 

Salamander 

 S3 X potential at 

Dawley Unit 

Long-legged 

Myotis 

 S

C 

M S3S4 potential at 

Dawley Unit 

Long-eared 

Myotis 

 S

C 

M S4 potential at 

Dawley Unit 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-6 Appendix E. Biological Resources of Concern 

Species/Habitat 

Refuge Purpose Species BIDEH Fed ESA Status 1State Status 2State Rank WNHP 3MMPA Species 4USFWS Bird of Management Concern or Bird of Conservation Concern 5Pacific Region Seabird Plan 6N Pacific Coast Shorebird Plan 7State Wildlife Action Plan Priorities8TNC WV/PT/GB EA 9PIF Species Assessment - BCR510Refuge Occurrence Ecological Significance 

Western Toad S S3 X Dawley Unit T&E - 

forest/wetlan

ds 

Red-legged Frog S4 X Dawley Unit 

Sand-verbena 

Moth 

 C C S1? X Year-round 

Graveyard 

Spit 

10 sites 

globally, 1 

observation 

on Graveyard 

Spit 

NATIVE STRAND PLANTS 

Common 

Eelgrass 

X year-round 

American 

Dunegrass 

 X year-round 

Large-headed 

Sedge 

 X year-round 

ECOLOGICAL SYSTEMS 

Sandy Bluff X to the west of 

the base of 

Dungeness 

Spit 

Unarmored 

bluffs a key 

conservation 

issue in the 

Salish Sea 

Barrier Beach X Graveyard and 

Dungeness 

spits 

Dungeness 

Spit one of 

the longest 

natural sand 

spits in the 

world 

Barrier Lagoon 

and Mudflats 

 X Dungeness 

Harbor/ within 

Dungeness 

and Graveyard 

spits 

 

Eelgrass Beds X Dungeness 

Harbor and 

Bay 

Declining 

habitat type 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-7 

Species/Habitat 

Refuge Purpose Species BIDEH Fed ESA Status 1State Status 2State Rank WNHP 3MMPA Species 4USFWS Bird of Management Concern or Bird of Conservation Concern 5Pacific Region Seabird Plan 6N Pacific Coast Shorebird Plan 7State Wildlife Action Plan Priorities8TNC WV/PT/GB EA 9PIF Species Assessment - BCR510Refuge Occurrence Ecological Significance 

Salt Marsh X Within 

Graveyard 

Spit, small 

sections found 

within the 

Harbor at the 

base of 

Dungeness 

Spit 

Declining 

habitat type 

Mixed 

Coniferous 

Forests 

 X Dungeness 

and Dawley 

units 

Declining 

habitat type 

Seasonal 

Freshwater 

Wetlands 

 X Dungeness 

and Dawley 

units 

Declining 

habitat type 

Instream X Dawley Unit 

Managed 

Wetland 

 X Dawley Unit 

1 Status under the Endangered Species Act - E = Endangered; T = Threatened; C = Candidate 

2 State listing status - E = Endangered; T = Threatened; C = Candidate; S = Sensitive; M = Monitor; R1 = More data required to 

review status 

3 Washington Natural Heritage Program state rank - see http://www1.dnr.wa.gov/nhp/refdesk/lists/stat_rank.html for a 

description of ranks 

4 Species listed under the Marine Mammal Protection Act 

5 USFWS Bird of Management Concern (USFWS 2005a) and USFWS Birds of Conservation Concern (USFWS 2008) lists - N = 

National; R1 = Region 1; BCR5 = Bird Conservation Region 5; GBBDC - Game Bird Below Desired Condition 

6 Pacific Region Seabird Conservation Plan (USFWS 2005b) status - HC = High Concern; MC = Moderate Concern; NAR = Not 

at Risk 

7 Northern Pacific Coast Regional Shorebird Conservation Plan (Drut and Buchanan 2000) status - 4 = High Concern; 3 = 

Moderate Concern 

8 Washington Comprehensive Wildlife Conservation Plan priority species (WDFW 2005) 

9 The Nature Conservancy Willamette Valley Puget Trough Georgia Basin Ecoregional Assessment (Floberg et al. 2004) 

10 PIF Species Assessment Scores - Regionally Important Species (higher #s = higher conservation Concern) (PIF 2010) 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-8 Appendix E. Biological Resources of Concern 

E.3 Ecological System Descriptions 

Vegetation types and nomenclature in the following section are classified according to the 

International Terrestrial Ecological System Classification being developed by NatureServe and its 

natural heritage program members. Ecological systems are being described for the coterminous 

United States, southern Alaska, and adjacent portions of Mexico and Canada and are defined as 

follows: 

“Terrestrial ecological systems are specifically defined as a group of plant community types 

(associations) that tend to co-occur within landscapes with similar ecological processes, 

substrates, and/or environmental gradients. A given system will typically manifest itself in a 

landscape at intermediate geographic scales of tens to thousands of hectares and will persist 

for 50 or more years. This temporal scale allows typical successional dynamics to be 

integrated into the concept of each unit. With these temporal and spatial scales bounding the 

concept of ecological systems, we then integrate multiple ecological factors—or diagnostic 

classifiers—to define each classification unit. The multiple ecological factors are evaluated 

and combined in different ways to explain the spatial co-occurrence of plant associations.” 

(Comer et al. 2003) 

Thus, ecological systems link together recurring groupings of U.S. National Vegetation 

Classification (US-NVC) associations and alliances (Grossman et al. 1998, Anderson et al. 1998, 

Jennings et al. 2003) found in similar physical settings and influenced by similar dynamic processes 

such as fire or flooding. The nested US-NVC hierarchy groups associations into alliances based on 

common dominant or diagnostic species in the upper most canopy. By non-hierarchically grouping 

together associations and alliances using larger-scale environmental patterns and concepts, ecological 

systems form a “meso-scale” classification that lies between the finer-scale (floristic) classes and the 

generalized formation (physiognomic) levels of the US-NVC (Comer et al. 2003). As a “meso-scale” 

classification, ecological systems are more readily mapped, identifiable in the field, and practically 

understood as ecological units and wildlife habitats. Consequently, regional GAP analysis efforts 

have generally adopted them as target map units. Given their utility for standardized vegetation type 

mapping, ecological systems classification was performed for Dungeness National Wildlife Refuge. 

All ecological system descriptions based on NatureServe (2012) and available online at: 

http://www.natureserve.org/explorer/servlet/NatureServe?init=Ecol. 

E.3.1 Shoreline 

North Pacific Coastal Cliff and Bluff 

This ecological system includes unvegetated or sparsely vegetated rock cliffs and very steep bluffs of 

glacial deposits along the Pacific Ocean and associated marine and estuarine inlets. It is restricted to 

degrading slopes from southwestern British Columbia south into central Oregon. It is composed of 

barren and sparsely vegetated substrates, typically including exposed sediments, bedrock, and scree 

slopes. Exposure to waves, eroding and desiccating winds, slope failures and sheet erosion create 

gravelly to rocky substrates that are often unstable. There can be sparse cover of forbs, grasses, 

lichens and low shrubs. 

North Pacific Maritime Coastal Sand Dune and Strand 

This system includes beach strand (not the beach itself but sparsely or densely vegetated areas behind 

the beach), foredunes, sand spits, and active to stabile backdunes and sandsheets derived from quartz 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-9 

or gypsum sands. The mosaic of sparse to dense vegetation in dune systems is driven by sand 

deposition, erosion, and lateral movement. Disturbance processes include dune blowouts caused by 

wind and occasional wave overwash during storm tidal surges. Coastal dunes often front portions of 

inlets and tidal marshes. Dune vegetation typically includes herbaceous, succulent, shrub, and tree 

species with varying degrees of tolerance for salt spray, wind and sand abrasion, and substrate 

stability. Dune succession is highly variable, so species composition can vary significantly among 

occurrences. These dunes can be dominated by Leymus arenarius (= Elymus arenarius), Festuca 

rubra, Leymus mollis, or various forbs adapted to salty dry conditions. Gaultheria shallon and 

Vaccinium ovatum are major shrub species. Forested portions of dunes are included within this 

system and are characterized (at least in the south) by Pinus contorta var. contorta early in 

succession, Picea sitchensis somewhat later in the sere, and in some cases Tsuga heterophylla later 

still. Pseudotsuga menziesii sometimes codominates in Oregon. Disturbance processes include dune 

blowouts caused by wind and occasional wave overwash during storm tidal surges. Late-sere forests, 

dominating stabilized dune systems where active dune processes are nearly absent and that 

compositionally represent the adjacent matrix system, are excluded from this dune system. Interdunal 

wetlands occur commonly within the matrix of this system and sometimes are extensive in deflation 

plains or old dune troughs, but are considered part of various separate wetland ecological systems 

depending on their hydrology, and are not part of this upland system. 

E.3.2 Intertidal/Subtidal 

Temperate Pacific Intertidal Flat (Dungeness Unit) 

Tidal flats form a narrow band along oceanic inlets and are more extensive at the mouths of larger 

rivers. Algae are the dominant vegetation on mud or gravel flats where little vascular vegetation is 

present due to daily tidal flooding of salt or brackish water. Characteristic species include Vaucheria 

longicaulis and Enteromorpha spp. Vascular species are sparse, if present, and may include salttolerant species such as Eleocharis palustris, Salicornia spp., Plantago maritima, Glaux maritima, 

and other plants common to lower salt marshes; cover is less than 10%. The dominant processes are 

tectonic uplift or subsidence, isostatic rebound, and sediment deposition. 

North Pacific Maritime Eelgrass Bed (Dungeness Unit) 

Eelgrass beds are found within the subtidal and intertidal zones. Intertidal zones are found with clear 

water in bays, inlets and lagoons, typically dominated by macrophytic algae and marine aquatic 

angiosperms along the temperate Pacific Coast. Subtidal portions are never exposed while intertidal 

areas support species that can tolerate exposure to the air. Common substrates include marine silts, 

but may also include exposed bedrock and cobble, where many algal species become attached with 

holdfasts. Beds are dominated by Zostera marina. 

Transitional Vegetation Herbaceous-Woody Mix (Dungeness Unit) 

Transitional Vegetation Short Shrub (Dungeness and Dawley units) 

E.3.3 Forest 

North Pacific Lowland Riparian Forest and Shrubland (Dungeness and Dawley units) 

Lowland riparian systems are linear in character, occurring on floodplains or lower terraces of rivers 

and streams. Major broadleaf dominant species are Acer macrophyllum, Alnus rubra, Populus 

balsamifera ssp. trichocarpa, Salix sitchensis, Salix lucida ssp. lasiandra, Cornus sericea, and 

Fraxinus latifolia. Conifers tend to increase with succession in the absence of major disturbance. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-10 Appendix E. Biological Resources of Concern 

Conifer-dominated types are relatively uncommon and not well-described; Abies grandis, Picea 

sitchensis, and Thuja plicata are important. Riverine flooding and the succession that occurs after 

major flooding events are the major natural processes that drive this system. Very early-successional 

stages can be sparsely vegetated or dominated by herbaceous vegetation. 

North Pacific Maritime Dry-Mesic Douglas-Fir-Western Hemlock Forest (Dungeness and 

Dawley units) 

This ecological system occurs throughout low-elevation western Washington, except on extremely 

dry or moist to very wet sites. These forests occur on the drier to intermediate moisture habitats and 

microhabitats within the Western Hemlock Zone of the Pacific Northwest. Climate is relatively mild 

and moist to wet, however mean annual precipitation can be as low as 20 inches in the extreme 

rainshadow, falling predominantly as winter rain. Snowfall ranges from rare to regular, and summers 

are relatively dry. This is generally the most extensive forest in the lowlands on the west side of the 

Cascades and forms the matrix within which other systems occur as patches including North Pacific 

Maritime Mesic-Wet Douglas-fir-Western Hemlock Forest and North Pacific Dry Douglas-fir Forest 

and Woodland. 

Overstory canopy is dominated by Pseudotsuga menziesii, with Tsuga heterophylla generally present 

in the subcanopy or as a canopy dominant in old-growth stands. Abies grandis, Thuja plicata, and 

Acer macrophyllum codominants are also represented. In the driest climatic areas, Tsuga 

heterophylla may be absent, and Thuja plicata takes its place as a late-seral or subcanopy tree 

species. Gaultheria shallon, Mahonia nervosa, Rhododendron macrophyllum, Linnaea borealis, 

Achlys triphylla, and Vaccinium ovatum typify the poorly to well-developed shrub layer. Acer 

circinatum is a common codominant with one of more of these other species. The fern Polystichum 

munitum can be codominant with one or more of the evergreen shrubs on sites with intermediate 

moisture availability (mesic). Young stands may lack Tsuga heterophylla or Thuja plicata, especially 

in the Puget Lowland. Tsuga heterophylla is generally the dominant regenerating tree species. Other 

common associates include Acer macrophyllum, Abies grandis, and Pinus monticola. This is in 

contrast to North Pacific Maritime Mesic-Wet Douglas-fir-Western Hemlock Forest, which occurs 

on sites where soils remain moist to subirrigated for much of the year and fires were less frequent. 

Fire is (or was) the major natural disturbance. In the past (pre-1880), fires were high-severity or, less 

commonly, moderate-severity, with natural return intervals of 100 years or less in the driest areas, to 

a few hundred years in areas with more moderate to wet climates. This system was typified by a 

moderate-severity fire regime involving occasional stand-replacing fires and more frequent 

moderate-severity fires. This fire regime would create a complex mosaic of stand structures across 

the landscape. 

North Pacific Maritime Mesic-Wet Douglas-Fir-Western Hemlock Forest (Dungeness and 

Dawley units) 

This ecological system occurs throughout low-elevation western Washington, except on extremely 

dry sites and in the hypermaritime zone near the outer coast where it is rare. These forests occur on 

moist habitats and microhabitats, mainly lower slopes or valley landforms, within the Western 

Hemlock Zone of the Pacific Northwest. They differ from North Pacific Maritime Dry-Mesic 

Douglas-fir-Western Hemlock Forest primarily in having more hydrophilic undergrowth species, 

moist to subirrigated soils, high abundance of shade- and moisture-tolerant canopy trees, as well as 

higher stand productivity, due to higher soil moisture and lower fire frequency. Climate is relatively 

mild and moist to wet, however this system can be found in areas with mean annual precipitation as 

low as 20 inches in the extreme rainshadow (predominantly as winter rain). Snowfall ranges from 

rare to regular (but consistent winter snowpacks are absent or minimal), and summers are relatively 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-11 

dry. In some wetter climatic areas, it forms the matrix within which other systems occur as patches, 

especially riparian wetlands. In this area, it occurs as small to large patches within a matrix of North 

Pacific Maritime Dry-Mesic Douglas-fir-Western Hemlock Forest and North Pacific Dry Douglasfir-(Madrone) Forest and Woodland. 

Overstory canopy is dominated by Pseudotsuga menziesii, Tsuga heterophylla, and/or Thuja plicata, 

as well as Chamaecyparis lawsoniana in western Oregon, away from the coast. Pseudotsuga 

menziesii is usually at least present to more typically codominant or dominant. Acer macrophyllum

and Alnus rubra (the latter primarily where there has been historic logging disturbance) are 

commonly found as canopy or subcanopy codominants, especially at lower elevations. In a natural 

landscape, small patches can be dominated in the canopy by these broadleaf trees for several decades 

after a severe fire. Polystichum munitum, Oxalis oregana, Rubus spectabilis, and Oplopanax 

horridus typify the poorly to well-developed herb and shrub layers. Gaultheria shallon, Mahonia 

nervosa, Rhododendron macrophyllum, and Vaccinium ovatum are often present but are generally 

not as abundant as the aforementioned indicators; except where Chamaecyparis lawsoniana is a 

canopy codominant, they may be the dominant understory. Acer circinatum is a very common 

codominant as a tall shrub. Stands included are best represented on lower mountain slopes of the 

coastal ranges with high precipitation, long frost-free periods, and low fire frequencies. Young stands 

may lack Tsuga heterophylla or Thuja plicata, especially in the Puget Lowland. Tsuga heterophylla

is generally the dominant regenerating tree species. Other common associates include Abies grandis, 

which can be a codominant especially in the Willamette Valley - Puget Trough - Georgia Basin 

ecoregion. Soils are moist to somewhat wet but not saturated for much of the year and are welldrained to somewhat poorly drained. Typical soils for Polystichum sites would be deep, fine- to 

moderately coarse-textured, and for Oplopanax sites, soils typically have an impermeable layer at a 

moderate depth. Both types of soils are well-watered from upslope sources, seeps, or hyperheic 

sources. This is in contrast to North Pacific Maritime Dry-Mesic Douglas-fir-Western Hemlock 

Forest, which occurs on well-drained soils, south-facing slopes, and dry ridges and slopes where soils 

remain mesic to dry for much of the year. Fire is (or was) the major natural disturbance in all but the 

wettest climatic areas. In the past (pre-1880), fires were less commonly high-severity, typically 

mixed-severity or moderate-severity, with natural return intervals of a few hundred to several 

hundred years. This system was formerly supported by occasional, stand-replacing fires. More 

frequent moderate-severity fires would generally not burn these moister microsites. 

North Pacific Oak Woodland (Dungeness Unit) 

This system is associated with dry, predominantly low-elevation sites and/or sites that experienced 

frequent presettlement fires. In the Puget Lowland and Georgia Basin, this system is primarily found 

on dry sites, typically either shallow bedrock soils or deep gravelly glacial outwash soils. Even where 

more environmentally limited, the system is strongly associated with a pre-European settlement, lowseverity fire regime. Succession in the absence of fire tends to favor increased shrub dominance in 

the understory, increased tree density, and increased importance of conifers, with the end result being 

conversion to a conifer forest. The vegetation ranges from savanna and woodland to forest dominated 

by deciduous broadleaf trees, mostly Quercus garryana. Codominance by the evergreen conifer 

Pseudotsuga menziesii is common. This system is borderline between small patch and large patch in 

its dynamics. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-12 Appendix E. Biological Resources of Concern 

E.3.4 Wetlands 

North Pacific Hardwood-Conifer Swamp (Dungeness and Dawley units) 

Also known as Palustrine forested Wetland in the Cowardin classification system (Cowardin et al. 

1979), North Pacific Hardwood-Conifer Swamps mostly small-patch size, occurring sporadically in 

glacial depressions, in river valleys, around the edges of lakes and marshes, or on slopes with seeps 

that form subirrigated soils. This system is indicative of poorly drained, mucky areas, and areas are 

often a mosaic of moving water and stagnant water. Soils can be woody peat, muck, or mineral. 

Typical of extensive upland forests, this type can be dominated by any one or a number of conifer 

and hardwood species (Tsuga heterophylla, Picea sitchensis, Tsuga mertensiana, Chamaecyparis 

nootkatensis, Pinus contorta var. contorta, Alnus rubra, Fraxinus latifolia, Betula papyrifera) that 

are capable of growing on saturated or seasonally flooded soils. Overstory is often less than 50% 

cover, but shrub understory can have high cover. 

Temperate Pacific Tidal Salt and Brackish Marsh (Dungeness Unit) 

Also known as Estuarine Emergent Wetland in the Cowardin classification system (Cowardin et al. 

1979), intertidal salt and brackish marshes are primarily associated with estuaries or coastal lagoons. 

Salt marshes are limited to bays and behind sand spits or other locations protected from wave action. 

Typically these areas form with a mixture of inputs from freshwater sources into coastal saltwater, so 

they commonly co-occur with brackish marshes. This is a small-patch system, confined to specific 

environments defined by ranges of salinity, tidal inundation regime, and soil texture. Patches usually 

occur as zonal mosaics of multiple communities. They vary in location and abundance with daily and 

seasonal dynamics of freshwater input from inland balanced against evaporation and tidal flooding of 

saltwater. Summer-dry periods result in decreased freshwater inputs from inland. Hypersaline 

environments within salt marshes occur in “salt pans” where tidal water collects and evaporates. 

Characteristic plant species include Distichlis spicata, Monanthochloe littoralis, Limonium 

californicum, Jaumea carnosa, Salicornia spp., Suaeda spp., Batis maritima, and Triglochin spp. 

Low marshes are located in areas that flood every day and are dominated by a variety of low-growing 

forbs and low to medium-height graminoids, especially Salicornia virginica, Distichlis spicata, 

Schoenoplectus maritimus (= Scirpus maritimus), Schoenoplectus americanus (= Scirpus 

americanus), Carex lyngbyei, and Triglochin maritima. High marshes are located in areas that flood 

infrequently and are dominated by medium-tall graminoids and low forbs, especially Deschampsia 

caespitosa, Argentina egedii, Juncus balticus, and Symphyotrichum subspicatum (= Aster 

subspicatus). Transition zone (slightly brackish) marshes are often dominated by Typha spp. or 

Schoenoplectus acutus. The invasive weed Lepidium latifolium is a problem in many of these 

marshes. Rare plant species include Cordylanthus maritimus ssp. maritimus. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Resources of Concern E-13 

E.4 References 

Anderson, M., P. Bourgeron, M.T. Bryer, R. Crawford, L. Engelking, D. Faber-Langendoen, M. 

Gallyoun, K. Goodin, D.H. Grossman, S. Landaal, K. Metzler, K.D. Patterson, M. Pyne, M. Reid, L. 

Sneddon, and A.S. Weakley. 1998. International classification of ecological communities: terrestrial 

vegetation of the United States. Volume II. The National Vegetation Classification System: list of 

types. The Nature Conservancy. Arlington, VA. 502 pp. 

Comer, P., D. Faber-Langendoen, R. Evans, S. Gawler, C. Josse, G. Kittel, S. Menard, M. Pyne, M. 

Reid, K. Schulz, K. Snow, and J. Teague. 2003. Ecological systems of the United States: a working 

classification of U.S. terrestrial systems. NatureServe. Arlington, VA. 75 pp. 

Cowardin, L.M., V.Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of wetlands and 

deepwater habitats of the United States. U.S. Department of the Interior; Fish and Wildlife Service. 

Washington, D.C. 130 pp. 

Drut, M. and J.B. Buchanan. 2000. U.S. shorebird conservation plan: Northern Pacific Coast regional 

shorebird management plan. Portland, OR: Fish and Wildlife Service, U.S. Department of the 

Interior. 31 pp. 

Floberg, J., M. Goering, G. Wilhere, C. MacDonald, C. Chappell, C. Rumsey, Z. Ferdana, A. Holt, P. 

Skidmore, T. Horsman, E. Alverson, C. Tanner, M. Bryer, P. Iachetti, A. Harcombe, B. McDonald, 

T. Cook, M. Summers, and D. Rolph. 2004. Willamette Valley-Puget Trough-Georgia Basin 

ecoregional assessment, volume one: report. Prepared by The Nature Conservancy with support from 

the Nature Conservancy of Canada, Washington Department of Fish and Wildlife, Washington 

Department of Natural Resources (Natural Heritage and Nearshore Habitat programs), Oregon State 

Natural Heritage Information Center and the British Columbia Conservation Data Centre. 150 pp. 

Grossman, D.H., D. Faber-Langendoen, A.S. Weakley, M. Anderson, P. Bourgeron, R. Crawford, K. 

Goodin, S. Landaal, K. Metzler, K.D. Patterson, M. Pyne, M. Reid, and L. Sneddon. 1998. 

International classification of ecological communities: terrestrial vegetation of the United States. 

Volume I, the National Vegetation Classification System: development, status, and applications. The 

Nature Conservancy. Arlington, VA. 126 pp. 

Jennings, M., O. Loucks, D. Glenn-Lewin, R. Peet, D. Faber-Langendoen, D. Grossman, A. 

Damman, M. Barbour, R. Pfister, M. Walker, S. Talbot, J. Walker, G. Hartshorn, G. Waggoner, M. 

Abrams, A. Hill, D. Roberts, D. Tart, and M. Rejmanek. 2003. Guidelines for describing associations 

and alliances of the U.S. National Vegetation Classification. Version 3.0 November 2003. The 

Ecological Society of America, Vegetation Classification Panel. Washington, D.C. 100 pp. (+ 

appendices). 

NatureServe. 2012. International ecological classification standard: terrestrial ecological 

classifications. NatureServe Central Databases. Arlington, VA. Data current as of April 24, 2012. 

NAWMP (North American Waterfowl Management Plan) Plan Committee. 2004. North American 

waterfowl management plan 2004. strategic guidance: strengthening the biological foundation. 

Canadian Wildlife Service, U.S. Fish and Wildlife Service, Secretaria de Medio Ambiente y 

Recursos Naturales. 22 pp. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

E-14 Appendix E. Biological Resources of Concern 

PIF (Partners in Flight). 2010. Species assessment database. Available at: 

http://www.rmbo.org/pif/scores/scores.html. Accessed March 23, 2010. 

USFWS (U.S. Fish and Wildlife Service). 2005a. Birds of management concern - Region 1 & Region 

8 (CNO). U.S. Department of the Interior, Fish and Wildlife Service, Region 1. Portland, OR. 16 pp. 

USFWS. 2005b. Regional seabird conservation plan. U.S. Department of Interior, Fish and Wildlife 

Service, Pacific Region, Migratory Birds and Habitat Programs. Portland, OR. 261 pp. Available at: 

http://www.fws.gov/pacific/migratorybirds/PDF/Seabird Conservation Plan Complete.pdf. Accessed 

July 3, 2011. 

USFWS. 2008. Birds of conservation concern 2008. U.S. Department of Interior, Fish and Wildlife 

Service, Division of Migratory Bird Management. Arlington, VA. 85 pp. 

USFWS. 2009. Identifying refuge resources of concern and management priorities: a handbook. 

United States Department of the Interior, U.S. Fish and Wildlife Service, National Wildlife Refuge 

System. 67 pp. 

WDFW (Washington Department of Fish and Wildlife). 2005. Washington’s comprehensive wildlife 

conservation strategy. Washington Department of Fish and Wildlife. Olympia, WA. 723 pp. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Statement of Compliance F-1 

Appendix F. Statement of Compliance 

STATEMENT OF COMPLIANCE

for Implementation of the 

Dungeness National Wildlife Refuge, Clallam County, Washington

Comprehensive Conservation Plan 

The following executive orders and legislative acts were reviewed as they apply to implementation of 

the Dungeness National Wildlife Refuge Comprehensive Conservation Plan (CCP). 

National Environmental Policy Act (1969), as Amended (42 U.S.C. § 4321 et seq.) 

The planning process has been conducted in accordance with National Environmental Policy Act 

(NEPA) implementing procedures, with U.S. Department of the Interior and U.S. Fish and Wildlife 

Service (Service) procedures, and in coordination with the affected public. The requirements of 

NEPA (42 U.S. Code [U.S.C.] § 4321 et seq.) and its implementing regulations in 40 Code of Federal 

Regulations (CFR) 1500-1508 have been satisfied in the procedures used to reach decisions. These 

procedures included the development of a range of alternatives for the CCP; analysis of the likely 

effects of each alternative; and public involvement throughout the planning process. The start of the 

scoping period was announced through a Federal Register notice, news releases to local newspapers, 

the Service’s refuge planning website, and a planning update. The draft CCP/environmental 

assessment (EA) was released for a 30-day public comment period. The affected public was notified 

of the availability of the document through a Federal Register notice, news releases to local 

newspapers, the Service’s refuge planning website, and a planning update. Copies of the draft 

CCP/EA and/or planning updates were distributed to an extensive mailing list. Upon request, the 

public comment period was extended to 90 days. In addition, the Service participated in a variety of 

public outreach efforts throughout the planning process (see Appendix K). 

The CCP is programmatic in many respects and specific details of certain projects and actions cannot 

be determined until a later date depending on funding and implementation schedules. Certain projects 

or actions may require additional NEPA compliance. 

National Historic Preservation Act (1966), as Amended (16 U.S.C. § 470 et seq.) 

The management of the archaeological and cultural resources of the Refuge will comply with the 

regulations of Section 106 of the National Historic Preservation Act. Historic properties will be 

maintained and repaired as funding becomes available. Maintenance and improvement of historic 

resources will result in positive impacts to cultural resources; however, determining whether a 

particular action has the potential to affect cultural resources is an ongoing process that occurs as 

step-down and site-specific project plans are developed. Should additional historic properties be 

identified or acquired in the future, the Service will comply with the National Historic Preservation 

Act if any management actions have the potential to affect these properties. 

Executive Order 12372. Intergovernmental Review 

Coordination and consultation with affected Tribal, local and State governments, other Federal 

agencies, and the landowners has been completed through personal contact by refuge staff, refuge 

supervisors and/or inclusion of the appropriate entities on the CCP mailing list. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

F-2 Appendix F. Statement of Compliance 

Executive Order 13175. Consultation and Coordination with Indian Tribal Governments 

As required under the Secretary of the Interior Order 3206—American Indian Tribal Rights, Federal 

Tribal Responsibilities, and the Endangered Species Act—the Project Leader notified and consulted 

interested tribes. Refuge staff consulted with representatives of the Jamestown S’Klallam Indian 

Tribe during the planning process. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority and 

Low-Income Populations 

All Federal actions must address and identify, as appropriate, disproportionally high and adverse 

human health or environmental effects of its programs, policies, and activities on minority 

populations, low-income populations, and Indian Tribes in the United States. The CCP was evaluated 

and no adverse human health or environmental effects were identified for minority or low-income 

populations, Indian tribes, or anyone else. 

Wilderness Preservation Act of 1964 (16 U.S.C. § 1131 et seq.) 

The Service has evaluated the suitability of the Refuge for wilderness designation through the 

“Inventory” phase according to the guidelines of the Wilderness Review process as described in 610 

FW 4. In this inventory no areas on the Refuge were found to meet the minimum wilderness criteria 

for size, naturalness or outstanding opportunities for solitude and primitive/unconfined recreation 

(see Appendix D for additional details). 

Architectural Barriers Act of 1968, as Amended (42 U.S.C. § 4151 et seq.) 

The Architectural Barriers Act requires access to Federal facilities for people with disabilities. 

Access for persons with disabilities has been considered during the planning process and actions 

related to access are found in Chapter 2 of the CCP. 

National Wildlife Refuge System Administration Act of 1966, as Amended (16 U.S.C. § 668dd668ee) 

This Act requires the Service to develop and implement a CCP for each refuge. The CCP identifies 

and describes refuge purposes; the vision and goals for the Refuge; fish, wildlife, and plant 

populations and related habitats on the Refuge; archaeological and cultural values of the Refuge; 

issues that may affect populations and habitats of fish, wildlife, and plants; actions necessary to 

restore and improve biological diversity on the Refuge; and opportunities for wildlife-dependent 

recreation, as required by the Act. 

During the CCP process, the refuge manager evaluated all existing and proposed uses at the Refuge. 

Priority wildlife-dependent uses (hunting, fishing, wildlife observation and photography, 

environmental education and interpretation) are considered automatically appropriate under Service 

policy and thus exempt from appropriate uses review. Compatibility determinations have been 

prepared for all uses found appropriate (see Appendices A and B). 

Executive Order 13186. Responsibilities of Federal Agencies to Protect Migratory Birds 

This Order directs agencies to take certain actions to further implement the Migratory Bird Treaty 

Act. A provision of the Order directs Federal agencies to consider the impacts of their activities, 

especially in reference to birds on the Service’s list of Birds of Conservation Concern. It also directs 

agencies to incorporate conservation recommendations and objectives in the North American 

Waterbird Conservation Plan and bird conservation plans developed by Partners in Flight into agency 

planning as described in Chapter 1. The effects to refuge habitats used by migratory birds from 

Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

F-4 Appendix F. Statement of Compliance 

Document continues on next page. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-1 

Appendix G. Integrated Pest Management 

G.1 Background 

IPM is an interdisciplinary approach utilizing methods to prevent, eliminate, contain, and/or control 

pest species in concert with other management activities on refuge lands and waters to achieve 

wildlife and habitat management goals and objectives. IPM is also a scientifically based, adaptive 

management process where available scientific information and best professional judgment of the 

refuge staff as well as other resource experts will be used to identify and implement appropriate 

management strategies that can be modified and/or changed over time to ensure effective, sitespecific management of pest species to achieve desired outcomes. In accordance with 43 CFR 

46.145, adaptive management will be particularly relevant where long-term impacts may be 

uncertain and future monitoring will be needed to make adjustments in subsequent implementation 

decisions. After a tolerable pest population (threshold) is determined considering achievement of 

refuge resource objectives and the ecology of pest species, one or more methods, or combinations 

thereof, will be selected that are feasible, efficacious, and most protective of non-target resources, 

including native species (fish, wildlife, and plants), and Service personnel, Service authorized agents, 

volunteers, and the public. Staff time and available funding will be considered when determining 

feasibility/practicality of various treatments. 

IPM techniques to address pests are presented as CCP strategies (see Chapter 2 of this CCP) in an 

adaptive management context to achieve refuge resource objectives. In order to satisfy requirements 

for IPM planning as identified in the Director’s Memo (dated September 9, 2004) entitled Integrated 

Pest Management Plans and Pesticide Use Proposals: Updates, Guidance, and an Online Database, 

the following elements of an IPM program have been incorporated into this CCP: 

 Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to 

indicate the need for and successful implementation of IPM techniques; and 

 Monitoring before and/or after treatment to assess progress toward achieving objectives 

including pest thresholds. 

Where pesticides would be necessary to address pests, this Appendix provides a structured procedure 

to evaluate potential effects of proposed uses involving ground-based applications to refuge 

biological resources and environmental quality in accordance with effects analyses presented in 

Chapter 6 (Environmental Consequences) of the Dungeness National Wildlife Refuge Draft CCP/EA 

(USFWS 2012). Only pesticide uses that likely would cause minor, temporary, or localized effects to 

refuge biological resources and environmental quality with appropriate best management practices 

(BMPs), where necessary, would be allowed for use on the Refuge. 

This Appendix does not describe the more detailed process to evaluate potential effects associated 

with aerial applications of pesticides. However, the basic framework to assess potential effects to 

refuge biological resources and environmental quality from aerial application of pesticides would be 

similar to the process described in this Appendix for ground-based treatments of other pesticides. 

G.2 Pest Management Laws and Policies 

In accordance with Service policy 569 FW 1 (Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to ensure balanced 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-2 Appendix G. Integrated Pest Management 

wildlife and fish populations in support of refuge-specific wildlife and habitat management 

objectives. Pest control on federal (refuge) lands and waters also is authorized under the following 

legal mandates: 

 National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd668ee); 

 Plant Protection Act of 2000 (7 USC 7701 et seq.); 

 Noxious Weed Control and Eradication Act of 2004 (7 USC 7781-7786, Subtitle E); 

 Federal Insecticide, Fungicide, and Rodenticide Act of 1996 (7 USC 136-136y); 

 National Invasive Species Act of 1996 (16 USC 4701); 

 Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 USC 4701); 

 Food Quality Protection Act of 1996 (7 USC 136); 

 Executive Order 13148, Section 601(a); 

 Executive Order 13112; and 

 Animal Damage Control Act of 1931 (7 USC 426-426c, 46 Stat. 1468). 

Pests are defined as “...living organisms that may interfere with the site-specific purposes, 

operations, or management objectives or that jeopardize human health or safety” from Department 

policy 517 DM 1 (Integrated Pest Management Policy). Similarly, 569 FW 1 defines pests as 

“...invasive plants and introduced or native organisms that may interfere with achieving our 

management goals and objectives on or off our lands, or that jeopardize human health or safety.” 517 

DM 1 also defines an invasive species as “a species that is non-native to the ecosystem under 

consideration and whose introduction causes or is likely to cause economic or environmental harm or 

harm to human health.” Throughout the remainder of this CCP, the terms pest and invasive species 

are used interchangeably because both can prevent/impede achievement of refuge wildlife and 

habitat objectives and/or degrade environmental quality. 

In general, control of pests (vertebrate or invertebrate) on the Refuge would conserve and protect the 

nation’s fish, wildlife, and plant resources as well as maintain environmental quality. From 569 FW 

1, animal or plant species that are considered pests may be managed if the following criteria are met: 

 Threat to human health and wellbeing or private property, the acceptable level of damage by 

the pest has been exceeded, or State or local government has designated the pest as noxious; 

 Detrimental to resource objectives as specified in a refuge resource management plan (e.g., 

comprehensive conservation plan, habitat management plan), if available; and 

 Control would not conflict with attainment of resource objectives or the purposes for which 

the Refuge was established. 

The specific justifications for pest management activities on the Refuge are the following: 

 Protect human health and wellbeing; 

 Prevent substantial damage to important to refuge resources; 

 Protect newly introduced or re-establish native species; 

 Control non-native (exotic) species in order to support existence for populations of native 

species; 

 Prevent damage to private property; and 

 Provide the public with quality, compatible wildlife-dependent recreational opportunities. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-3 

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on the Refuge: 

 “We are prohibited by Executive Order, law, and policy from authorizing, funding, or 

carrying out actions that are likely to cause or promote the introduction or spread of invasive 

species in the United States or elsewhere.” 

 “Manage invasive species to improve or stabilize biotic communities to minimize 

unacceptable change to ecosystem structure and function and prevent new and expanded 

infestations of invasive species. Conduct refuge habitat management activities to prevent, 

control, or eradicate invasive species...” 

Animal species damaging/destroying federal property and/or detrimental to the management program 

of a refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control Operations). 

For example, the incidental removal of beaver damaging refuge infrastructure (e.g., clogging with 

subsequent damaging of water control structures) and/or negatively affecting habitats (e.g., removing 

woody species from existing or restored riparian) managed on refuge lands may be conducted 

without a pest control proposal. We recognize beavers are native species and most of their activities 

or refuge lands represent a natural process beneficial for maintaining wetland habitats. Exotic nutria, 

whose denning and burrowing activities in wetland dikes causes cave-ins and breaches, can be 

controlled using the most effective techniques considering site-specific factors without a pest control 

proposal. Along with the loss of quality wetland habitats associated with breaching of 

impoundments, the safety of refuge staff and public (e.g., auto tour routes) driving on structurally 

compromised levees and dikes can be threatened by sudden and unexpected cave-ins. 

Trespass and feral animals also may be controlled on refuge lands. Based upon 50 CFR 28.43 

(Destruction of Dogs and Cats), dogs and cats running at large on a national wildlife refuge and 

observed in the act of killing, injuring, harassing or molesting humans or wildlife may be disposed of 

in the interest of public safety and protection of the wildlife. Feral animals should be disposed by the 

most humane method(s) available and in accordance with relevant Service directives (including 

Executive Order 11643). Disposed wildlife specimens may be donated or loaned to public 

institutions. Donation or loans of resident wildlife species will only be made after securing State 

approval (50 CFR 30.11 [Donation and Loan of Wildlife Specimens]). Surplus wildlife specimens 

may be sold alive or butchered, dressed and processed subject to federal and state laws and 

regulations (50 CFR 30.12 [Sale of Wildlife Specimens]). 

G.3 Strategies 

To fully embrace IPM as identified in 569 FW 1, the following strategies, where applicable, would 

be carefully considered on the Refuge for each pest species. 

G.3.1 Prevention 

This would be the most effective and least expensive long-term management option for pests. It 

encompasses methods to prevent new introductions or the spread of the established pests to uninfested areas. It requires identifying potential routes of invasion to reduce the likelihood of 

infestation. Hazard Analysis and Critical Control Points (HACCP) planning can be used determine if 

current management activities on a refuge may introduce and/or spread invasive species in order to 

identify appropriate BMPs for prevention. See http://www.haccp-nrm.org/ for more information 

about HACCP planning. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-4 Appendix G. Integrated Pest Management 

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill; exclusion 

methods (e.g., barriers) and/or sanitation methods (e.g., wash stations) to prevent re-introductions by 

various mechanisms including vehicles, personnel, livestock, and horses. Because invasive species 

are frequently the first to establish newly disturbed sites, prevention would require a reporting 

mechanism for early detection of new pest occurrences with quick response to eliminate any new 

satellite pest populations. Prevention would require consideration of the scale and scope of land 

management activities that may promote pest establishment within un-infested areas or promote 

reproduction and spread of existing populations. Along with preventing initial introduction, 

prevention would involve halting the spread of existing infestations to new sites (Mullin et al. 2000). 

The primary reason for prevention would be to keep pest-free lands or waters from becoming 

infested. Executive Order 11312 emphasizes the priority for prevention with respect to managing 

pests. 

The following would be methods to prevent the introduction and/or spread of pests on refuge lands: 

 Before beginning ground-disturbing activities (e.g., disking, scraping), inventory and 

prioritize pest infestations in project operating areas and along access routes. Refuge staff 

would identify pest species on-site or within reasonably expected potential invasion vicinity. 

Where possible, the refuge staff would begin project activities in un-infested areas before 

working in pest-infested areas. 

 The refuge staff would locate and use pest-free project staging areas. They would avoid or 

minimize travel through pest-infested areas, or restrict to those periods when spread of seed 

or propagules of invasive plants would be least likely. 

 The refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. Where possible, the refuge staff would clean 

equipment before entering lands at on-refuge approved cleaning site(s). This practice does 

not pertain to vehicles traveling frequently in and out of the project area that will remain on 

roadways. Seeds and plant parts of pest plants would need to be collected, where practical. 

The refuge staff would remove mud, dirt, and plant parts from project equipment before 

moving it into a project area. 

 The refuge staff would clean all equipment, before leaving the project site, if operating in 

areas infested with pests. The refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned. 

 Refuge staff, their authorized agents, and refuge volunteers would, where possible, inspect, 

remove, and properly dispose of seed and parts of invasive plants found on their clothing and 

equipment. Proper disposal means bagging the seeds and plant parts and then properly 

discarding of them (e.g., incinerating). 

 The refuge staff would evaluate options, including closure, to restrict the traffic on sites with 

on-going restoration of desired vegetation. The refuge staff would revegetate disturbed soil 

(except travel ways on surfaced projects) to optimize plant establishment for each specific 

site. Revegetation may include topsoil replacement, planting, seeding, fertilization, liming, 

and weed-free mulching as necessary. The refuge staff would use native material, where 

appropriate and feasible. The refuge staff would use certified weed-free or weed-seed-free 

hay or straw where certified materials are reasonably available. 

 The refuge staff would provide information, training, and appropriate pest identification 

materials to permit holders and recreational visitors. The refuge staff would educate them 

about pest identification, biology, impacts, and effective prevention measures. 

 The refuge staff would require grazing permittees to utilize preventative measures for their 

livestock while on refuge lands. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-5 

 The refuge staff would inspect borrow material for invasive plants prior to use and transport 

onto and/or within refuge lands. 

 The refuge staff would consider invasive plants in planning for road maintenance activities. 

 The refuge staff would restrict off-road travel to designated routes. 

The following would be methods to prevent the introduction and/or spread of pests into refuge 

waters: 

 The refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment. Where possible, the refuge staff would remove any visible plants, animals, or 

mud before leaving any waters or boat launching facilities. Where possible, the refuge staff 

would drain water from motor, live well, bilge, and transom wells while on land before 

leaving the site. If possible, the refuge staff would wash and dry boats, downriggers, anchors, 

nets, floors of boats, propellers, axles, trailers, and other boating equipment to kill pests not 

visible at the boat launch. 

 Where feasible, the refuge staff would maintain a 100-foot buffer of aquatic pest-free 

clearance around boat launches and docks or quarantine areas when cleaning around culverts, 

canals, or irrigation sites. Where possible, the refuge staff would inspect and clean equipment 

before moving to new sites or one project area to another. 

These prevention methods to minimize/eliminate the introduction and/or spread of pests were taken 

verbatim or slightly modified from Appendix E of the U.S. Forest Service’s Preventing and 

Managing Invasive Plants Final Environmental Impact Statement (2005). 

G.3.2 Mechanical/Physical Methods 

These methods would remove and destroy, disrupt the growth of, or interfere with the reproduction 

of pest species. For plants species, these treatments can be accomplished by hand, hand tool 

(manual), or power tools (mechanical) and include pulling, grubbing, digging, tilling/disking, cutting, 

swathing, grinding, shearing, girdling, mowing, and mulching of the pest plants. 

For animal species, Service employees or their authorized agents could use mechanical/physical 

methods (including trapping) to control pests as a refuge management activity. Based upon 50 CFR 

31.2, trapping can be used on a refuge to reduce surplus wildlife populations for a “balanced 

conservation program” in accordance with federal or state laws and regulations. In some cases, nonlethally trapped animals would be relocated to off-refuge sites with prior approval from the state. 

 

Each of these tools would be efficacious to some degree and applicable to specific situations. In 

general, mechanical controls can effectively control annual and biennial pest plants. However, to 

control perennial plants, the root system has to be destroyed or it would resprout and continue to 

grow and develop. Mechanical controls are typically not capable of destroying a perennial plant’s 

root system. Although some mechanical tools (e.g., disking, plowing) may damage root systems, they 

may stimulate regrowth producing a denser plant population that may aid in the spread depending 

upon the target species (e.g., Canada thistle). In addition, steep terrain and soil conditions would be 

major factors that can limit the use of many mechanical control methods. 

Some mechanical control methods (e.g., mowing), which would be used in combination with 

herbicides, can be a very effective technique to control perennial species. For example, mowing 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-6 Appendix G. Integrated Pest Management 

perennial plants followed sequentially by treating the plant regrowth with a systemic herbicide often 

would improve the efficacy of the herbicide compared to herbicide treatment only. 

G.3.3 Cultural Methods 

These methods would involve manipulating habitat to increase pest mortality by reducing its 

suitability to the pest. Cultural methods would include water-level manipulation, mulching, winter 

cover crops, changing planting dates to minimize pest impact, prescribed burning (facilitate 

revegetation, increase herbicide efficacy, and remove litter to assist in emergence of desirable 

species), flaming with propane torches, trap crops, crop rotations that would include non-susceptible 

crops, moisture management, addition of beneficial insect habitat, reducing clutter, proper trash 

disposal, planting or seeding desirable species to shade or out-compete invasive plants, applying 

fertilizer to enhance desirable vegetation, prescriptive grazing, and other habitat alterations. 

G.3.4 Biological Control Agents 

Classical biological control would involve the deliberate introduction and management of natural 

enemies (parasites, predators, or pathogens) to reduce pest populations. Many of the most 

ecologically or economically damaging pest species in the United States originated in foreign 

countries. These newly introduced pests, which are free from natural enemies found in their country 

or region of origin, may have a competitive advantage over cultivated and native species. This 

competitive advantage often allows introduced species to flourish, and they may cause widespread 

economic damage to crops or out compete and displace native vegetation. Once the introduced pest 

species population reaches a certain level, traditional methods of pest management may be cost 

prohibitive or impractical. Biological controls typically are used when these pest populations have 

become so widespread that eradication or effective control would be difficult or no longer practical. 

Biological control has advantages as well as disadvantages. Benefits would include reducing 

pesticide usage, host specificity for target pests, long-term self-perpetuating control, low cost/acre, 

capacity for searching and locating hosts, synchronizing biological control agents to hosts’ life 

cycles, and the unlikelihood that hosts will develop resistance to agents. Disadvantages would 

include the following: limited availability of agents from their native lands, the dependence of 

control on target species density, slow rate at which control occurs, biotype matching, the difficulty 

and expense of conflicts over control of the target pest, and host specificity when host populations 

are low. 

A reduction in target species populations from biological controls is typically a slow process, and 

efficacy can be highly variable. It may not work well in a particular area although it does work well 

in other areas. Biological control agents would require specific environmental conditions to survive 

over time. Some of these conditions are understood; whereas, others are only partially understood or 

not at all. 

Biological control agents would not eradicate a target pest. When using biological control agents, 

residual levels of the target pest typically are expected; the agent population level or survival would 

be dependent upon the density of its host. After the pest population decreases, the population of the 

biological control agent would decrease correspondingly. This is a natural cycle. Some pest 

populations (e.g., invasive plants) would tend to persist for several years after a biological control 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-7 

agent becomes established due to seed reserves in the soil, inefficiencies in the agents search 

behavior, and the natural lag in population buildup of the agent. 

The full range of pest groups potentially found on refuge lands and waters would include diseases, 

invertebrates (insects, mollusks), vertebrates, and invasive plants (the most common group). Often it 

is assumed that biological control would address many if not most of these pest problems. There are 

several well-documented success stories of biological control of invasive weed species in the Pacific 

Northwest including Mediterranean sage, St. Johnswort (Klamath weed) and tansy ragwort. 

Emerging success stories include Dalmatian toadflax, diffuse knapweed, leafy spurge, purple 

loosestrife and yellow star thistle. However, historically, each new introduction of a biological 

control agent in the United States has only about a 30% success rate (Coombs et al. 2004). Refer to 

Coombs et al. (2004) for the status of biological control agents for invasive plants in the Pacific 

Northwest. 

Introduced species without desirable close relatives in the United States would generally be selected 

as biological controls. Natural enemies that are restricted to one or a few closely related plants in 

their country of origin are targeted as biological controls (Center et al. 1997, Hasan and Ayres 1990). 

The refuge staff would ensure introduced agents are approved by the applicable authorities. Except 

for a small number of formulated biological control products registered by USEPA under FIFRA, 

most biological control agents are regulated by the U.S. Department of Agriculture (USDA)-Animal 

Plant Health Inspection Service, Plant Protection and Quarantine (APHIS-PPQ). State departments of 

agriculture and, in some cases, county agricultural commissioners or weed districts, have additional 

approval authority. 

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrols agents from 

another state. Form 526 may be obtained by writing: 

USDA-APHIS-PPQ 

Biological Assessment and Taxonomic Support 

4700 River Road, Unit 113 

Riverdale, MD 20737 

Or through the internet at: 

http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html 

The Service strongly supports the development, and legal and responsible use of appropriate, safe, 

and effective biological control agents for nuisance and non-indigenous or pest species. 

State and county agriculture departments may also be sources for biological control agents or they 

may have information about where biological control agents may be obtained. Commercial sources 

should have an Application and Permit to Move Live Plant Pests and Noxious Weeds (USDA-PPQ 

Form 226 USDA-APHIS-PPQ, Biological Assessment and Taxonomic Support, 4700 River Road, 

Unit 113, Riverdale, MD 20737) to release specific biological control agents in a state and/or county. 

Furthermore, certification regarding the biological control agent’s identity (genus, specific epithet, 

sub-species and variety) and purity (e.g., parasite free, pathogen free, and biotic and abiotic 

contaminants) should be specified in purchase orders. 

Biological control agents are subject to 7 RM 8 (Exotic Species Introduction and Management). In 

addition, the refuge staff would follow the International Code of Best Practice for Classical 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-8 Appendix G. Integrated Pest Management 

Biological Control of Weeds (http://sric.ucdavis.edu/exotic/exotic.htm) as ratified by delegates to the 

X International Symposium on Biological Control of Weeds, Bozeman, MT, July 9, 1999. This code 

identifies the following: 

 Release only approved biological control agents, 

 Use the most effective agents, 

 Document releases, and 

 Monitor for impact to the target pest, non-target species, and the environment. 

Biological control agents formulated as pesticide products and registered by the USEPA (e.g., Bti) 

are also subject to PUP review and approval (see below). 

A record of all releases would be maintained with date(s), location(s), and environmental conditions 

of the release site(s); the identity, quantity, and condition of the biological control agents released; 

and other relevant data and comments such as weather conditions. Systematic monitoring to 

determine the establishment and effectiveness of the release is also recommended. 

NEPA documents regarding biological and other environmental effects of biological control agents 

prepared by another federal agency, where the scope is relevant to evaluation of releases on refuge 

lands, would be reviewed. Possible source agencies for such NEPA documents include the Bureau of 

Land Management, U.S. Forest Service, National Park Service, U.S. Department of AgricultureAnimal and Plant Health Inspection Service, and the military services. It might be appropriate to 

incorporate by reference parts or all of existing document(s) from the review. Incorporating by 

reference (43 CFR 46.135) is a technique used to avoid redundancies in analysis. It also can reduce 

the bulk of a Service NEPA document, which only must identify the documents that are incorporated 

by reference. In addition, relevant portions must be summarized in the Service NEPA document to 

the extent necessary to provide the decision maker and public with an understanding of relevance of 

the referenced material to the current analysis. 

G.3.5 Pesticides 

 

The selective use of pesticides would be based upon pest ecology (including mode of reproduction), 

the size and distribution of its populations, site-specific conditions (e.g., soils, topography), known 

efficacy under similar site conditions, and the capability to utilize best management practices (BMPs) 

to reduce/eliminate potential effects to non-target species, sensitive habitats, and potential to 

contaminate surface and groundwater. All pesticide usage (pesticide, target species, application rate, 

and method of application) would comply with the applicable federal (FIFRA) and state regulations 

pertaining to pesticide use, safety, storage, disposal, and reporting. Before pesticides can be used to 

eradicate, control, or contain pests on refuge lands and waters, pesticide use proposals (PUPs) would 

be prepared and approved in accordance with 569 FW 1. PUP records would provide a detailed, 

time-, site-, and target-specific description of the proposed use of pesticides on the Refuge. All PUPs 

would be created, approved or disapproved, and stored in the Pesticide Use Proposal System (PUPS), 

which is a centralized database only accessible on the Service’s intranet 

(https://systems.fws.gov/pups). Only Service employees would be authorized to access PUP records 

for a refuge in this database. 

Application equipment would be selected to provide site-specific delivery to target pests while 

minimizing/eliminating direct or indirect (e.g., drift) exposure to non-target areas and degradation of 

surface and groundwater quality. Where possible, target-specific equipment (e.g., backpack sprayer, 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-9 

wiper) would be used to treat target pests. Other target-specific equipment to apply pesticides would 

include soaked wicks or paint brushes for wiping vegetation and lances, hatchets, or syringes for 

direct injection into stems. Granular pesticides may be applied using seeders or other specialized 

dispensers. In contrast, aerial spraying (e.g., fixed wing or helicopter) would only be used where 

access is difficult (remoteness) and/or the size/distribution of infestations precludes practical use of 

ground-based methods. 

Because repeated use of one pesticide may allow resistant organisms to survive and reproduce, 

multiple pesticides with variable modes of action would be considered for treatments on refuge lands 

and waters. This is especially important if multiple applications within years and/or over a growing 

season likely would be necessary for habitat maintenance and restoration activities to achieve 

resource objectives. Integrated chemical and non-chemical controls also are highly effective, where 

practical, because pesticide-resistant organisms can be removed from the site. 

Cost may not be the primary factor in selecting a pesticide for use on a refuge. If the least expensive 

pesticide would potentially harm natural resources or people, then a different product would be 

selected, if available. The most efficacious pesticide available with the least potential to degrade 

environment quality (soils, surface water, and groundwater) as well as least potential effect to native 

species and communities of fish, wildlife, plants, and their habitats would be acceptable for use on 

refuge lands in the context of an IPM approach. 

G.3.6 Habitat Restoration/Maintenance 

Restoration and/or proper maintenance of refuge habitats associated with achieving wildlife and 

habitat objectives would be essential for long-term prevention, eradication, or control (at or below 

threshold levels) of pests. Promoting desirable plant communities through the manipulation of 

species composition, plant density, and growth rate is an essential component of invasive plant 

management (Masters et al. 1996, Masters and Shely 2001, Brooks et al. 2004). The following three 

components of succession could be manipulated through habitat maintenance and restoration: site 

availability, species availability, and species performance (Cox and Anderson 2004). Although a 

single method (e.g., herbicide treatment) may eliminate or suppress pest species in the short term, the 

resulting gaps and bare soil create niches that are conducive to further invasion by the species and/or 

other invasive plants. On degraded sites where desirable species are absent or in low abundance, 

revegetation with native/desirable grasses, forbs, and legumes may be necessary to direct and 

accelerate plant community recovery, and achieve site-specific objectives in a reasonable time frame. 

The selection of appropriate species for revegetation would be dependent on a number of factors 

including resource objectives and site-specific, abiotic factors (e.g., soil texture, precipitation/ 

temperature regimes, and shade conditions). Seed availability and cost, ease of establishment, seed 

production, and competitive ability also would be important considerations. 

G.4 Priorities for Treatments 

For many refuges, the magnitude (number, distribution, and sizes of infestations) of pest problems is 

too extensive and beyond the available capital resources to effectively address during any single field 

season. To manage pests in the Refuge, it would be essential to prioritize treatment of infestations. 

Highest priority treatments would be focused on early detection and rapid response to eliminate 

infestations of new pests, if possible. This would be especially important for aggressive pests 

potentially impacting species, species groups, communities, and/or habitats associated refuge 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-10 Appendix G. Integrated Pest Management 

purpose(s), NWRS resources of concern (federally listed species, migratory birds, selected marine 

mammals, and interjurisdictional fish), and native species for maintaining/restoring biological 

integrity, diversity, and environmental health. 

The next priority would be treating established pests that appear in one or more previously uninfested areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of 

invasive plants eventually would infest an area larger than the established, source population. They 

also found that control efforts focusing on the large, main infestation rather than the new, small 

satellites reduced the chances of overall success. The lowest priority would be treating large 

infestations (sometimes monotypic stands) of well-established pests. In this case, initial efforts would 

focus upon containment of the perimeter followed by work to control/eradicate the established 

infested area. If containment and/or control of a large infestation is not effective, then efforts would 

focus upon halting pest reproduction or managing source populations. Maxwell et al. (2009) found 

treating fewer populations that are sources represents an effective long-term strategy to reduce of 

total number of invasive populations and decreasing meta-population growth rates. 

Although state-listed noxious weeds would always be of high priority for management, other pest 

species known to cause substantial ecological impact would also be considered. For example, 

cheatgrass may not be listed by a state as noxious, but it can greatly alter fire regimes in shrub steppe 

habitats resulting in large monotypic stands that displace native bunch grasses, forbs, and shrubs. 

Pest control would likely require a multi-year commitment from the refuge staff. Essential to the 

long-term success of pest management would be pre- and post-treatment monitoring, assessment of 

the successes and failures of treatments, and development of new approaches when proposed 

methods do not achieve desired outcomes. 

G.5 Best Management Practices (BMPs) 

BMPs can minimize or eliminate possible effects associated with pesticide usage to non-target 

species and/or sensitive habitats as well as degradation of water quality from drift, surface runoff, or 

leaching. Based upon the Department of Interior Pesticide Use Policy (517 DM 1) and the Service 

Integrated Pest Management policy (569 FW 1), the use of applicable BMPs (where feasible) also 

would likely ensure that pesticide uses may not adversely affect federally listed species and/or their 

critical habitats through determinations made using the process described in 50 CFR part 402. 

The following are BMPs pertaining to mixing/handling and applying pesticides for all ground-based 

treatments of pesticides, which would be considered and utilized, where feasible, based upon targetand site-specific factors and time-specific environmental conditions. Although not listed below, the 

most important BMP to eliminate/reduce potential impacts to non-target resources would be an IPM 

approach to prevent, control, eradicate, and contain pests. 

G.5.1 Pesticide Handling and Mixing 

 As a precaution against spilling, spray tanks would not be left unattended during filling. 

 All pesticide containers would be triple rinsed and the rinsate would be used as water in the 

sprayer tank and applied to treatment areas. 

 All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be 

used as part of the make-up water in the sprayer tank and applied to treatment areas. 

 The refuge staff would triple rinse and recycle (where feasible) pesticide containers. 

 All unused pesticides would be properly discarded at a local “safe send” collection. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-11 

 Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in 

accordance with the label and in a manner safeguarding human health, fish, and wildlife and 

prevent soil and water contaminant. 

 The refuge staff would consider the water quality parameters (e.g., pH, hardness) that are 

important to ensure greatest efficacy where specified on the pesticide label. 

 All pesticide spills would be addressed immediately using procedures identified in the refuge 

spill response plan. 

G.5.2 Applying Pesticides 

 Pesticide treatments would only be conducted by or under the supervision of Service 

personnel and non-Service applicators with the appropriate state or BLM certification to 

safely and effectively conduct these activities on refuge lands and waters. 

 The refuge staff would comply with all federal, state, and local pesticide use laws and 

regulations as well as Departmental, Service, and NWRS pesticide-related policies. For 

example, the refuge staff would use application equipment and apply rates for the specific 

pest(s) identified on the pesticide label as required under FIFRA. 

 Before each treatment season and prior to mixing or applying any product for the first time 

each season, all applicators would review the labels, MSDSs, and Pesticide Use Proposal 

(PUPs) for each pesticide, determining the target pest, appropriate mix rate(s), PPE, and other 

requirements listed on the pesticide label. 

 A 1-foot no-spray buffer from the water’s edge would be used, where applicable and where it 

does not detrimentally influence effective control of pest species. 

 Use low-impact herbicide application techniques (e.g., spot treatment, cut stump, oil basal, 

Thinvert system applications) rather than broadcast foliar applications (e.g., boom sprayer, 

other larger tank wand applications), where practical. 

 Use low-volume rather than high-volume foliar applications where low-impact methods 

above are not feasible or practical, to maximize herbicide effectiveness and ensure correct 

and uniform application rates. 

 Applicators would use and adjust spray equipment to apply the coarsest droplet size spectrum 

with optimal coverage of the target species while reducing drift. 

 Applicators would use the largest droplet size that results in uniform coverage. 

 Applicators would use drift reduction technologies such as low-drift nozzles, where possible. 

 Where possible, spraying would occur during low (average<7 mph and preferably 3 to 5 

mph) and consistent direction wind conditions with moderate temperatures (typically <85°F). 

 Where possible, applicators would avoid spraying during inversion conditions (often 

associated with calm and very low wind conditions) that can cause large-scale herbicide drift 

to non-target areas. 

 Equipment would be calibrated regularly to ensure that the proper rate of pesticide is applied 

to the target area or species. 

 Spray applications would be made at the lowest height for uniform coverage of target pests to 

minimize/eliminate potential drift. 

 If windy conditions frequently occur during afternoons, spraying (especially boom 

treatments) would typically be conducted during early morning hours. 

 Spray applications would not be conducted on days with >30% forecast for rain within 6 

hours, except for pesticides that are rapidly rain fast (e.g., glyphosate in 1 hour) to 

minimize/eliminate potential runoff. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-12 Appendix G. Integrated Pest Management 

 Where possible, applicators would use drift retardant adjuvants during spray applications, 

especially adjacent to sensitive areas. 

 Where possible, applicators would use a non-toxic dye to aid in identifying target area treated 

as well as potential over spray or drift. A dye can also aid in detecting equipment leaks. If a 

leak is discovered, the application would be stopped until repairs can be made to the sprayer. 

 For pesticide uses associated with cropland and facilities management, buffers, as 

appropriate, would be used to protect sensitive habitats, especially wetlands and other aquatic 

habitats. 

 When drift cannot be sufficiently reduced through altering equipment set up and application 

techniques, buffer zones may be identified to protect sensitive areas downwind of 

applications. The refuge staff would only apply adjacent to sensitive areas when the wind is 

blowing the opposite direction. 

 Applicators would utilize scouting for early detection of pests to eliminate unnecessary 

pesticide applications. 

 The refuge staff would consider timing of application so native plants are protected (e.g., 

senescence) while effectively treating invasive plants. 

 Rinsate from cleaning spray equipment after application would be recaptured and reused or 

applied to an appropriate pest plant infestation. 

 Application equipment (e.g., sprayer, ATV, tractor) would be thoroughly cleaned and PPE 

would be removed/disposed of on-site by applicators after treatments to eliminate the 

potential spread of pests to un-infested areas. 

 Cleaning boots (or use rubber boots to aid in sanitation) and brush off clothing in a place 

where monitoring is feasible to control for new seed transportation. 

 

G.6 Safety 

G.6.1 Personal Protective Equipment 

All applicators would wear the specific personal protective equipment (PPE) identified on the 

pesticide label. The appropriate PPE would be worn at all times during handling, mixing, and 

applying. PPE can include the following: disposable (e.g., Tyvek) or laundered coveralls; gloves 

(latex, rubber, or nitrile); rubber boots; and/or an NIOSH-approved respirator. Because exposure to 

concentrated product is usually greatest during mixing, extra care should be taken while preparing 

pesticide solutions. Persons mixing these solutions can be best protected if they wear long gloves, an 

apron, footwear, and a face shield. 

Coveralls and other protective clothing used during an application would be laundered separately 

from other laundry items. Transporting, storing, handling, mixing and disposing of pesticide 

containers would be consistent with label requirements, USEPA and OSHA requirements, and 

Service policy. 

If a respirator is necessary for a pesticide use, then the following requirements would be met in 

accordance with Service safety policy: a written Respirator Program, fit testing, physical examination 

(including pulmonary function and blood work for contaminants), and proper storage of the 

respirator. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-13 

G.6.2 Notification 

The restricted entry interval (REI) is the time period required after the application at which point 

someone may safely enter a treated area without PPE. Refuge staff, authorized management agents of 

the Service, volunteers, and members of the public who could be in or near a pesticide treated area 

within the stated re-entry time period on the label would be notified about treatment areas. Posting 

would occur at any site where individuals might inadvertently become exposed to a pesticide during 

other activities on the Refuge. Where required by the label and/or state-specific regulations, sites 

would also be posted on its perimeter and at other likely locations of entry. The refuge staff would 

also notify appropriate private property owners of an intended application, including any private 

individuals who have requested notification. Special efforts would be made to contact nearby 

individuals who are beekeepers or who have expressed chemical sensitivities. 

G.6.3 Medical Surveillance 

Medical surveillance may be required for Service personnel and approved volunteers who mix, 

apply, and/or monitor use of pesticides (see 242 FW 7 [Pesticide Users] and 242 FW 4 [Medical 

Surveillance]). In accordance with 242 FW 7.12A, Service personnel would be medically monitoring 

if one or more of the following criteria is met: exposed or may be exposed to concentrations at or 

above the published permissible exposure limits or threshold limit values (see 242 FW 4); use 

pesticides in a manner considered “frequent pesticide use”; or use pesticides in a manner that requires 

a respirator (see 242 FW 14 for respirator use requirements). In 242 FW 7.7A, “Frequent Pesticide 

Use means when a person applying pesticide handles, mixes, or applies pesticides, with a Health 

Hazard rating of 3 or higher, for 8 or more hours in any week or 16 or more hours in any 30-day 

period.” Under some circumstances, individuals may be medically monitored who use pesticides 

infrequently (see Section G.7.7), experience an acute exposure (sudden, short-term), or use pesticides 

with a health hazard ranking of 1 or 2. This decision would consider the individual’s health and 

fitness level, the pesticide’s specific health risks, and the potential risks from other pesticide-related 

activities. Refuge cooperators (e.g., cooperative farmers) and other authorized agents (e.g., state and 

county employees) would be responsible for their own medical monitoring needs and costs. 

Standard examinations (at refuge expense) of appropriate refuge staff would be provided by the 

nearest certified occupational health and safety physician as determined by Federal Occupational 

Health. 

G.6.4 Certification and Supervision of Pesticide Applicators 

Appropriate refuge staff or approved volunteers handling, mixing, and/or applying or directly 

supervising others engaged in pesticide use activities would be trained and state or federally (BLM) 

licensed to apply pesticides to refuge lands or waters. In accordance with 242 FW 7.18A and 569 FW 

1.10B, certification is required to apply restricted use pesticides based upon USEPA regulations. For 

safety reasons, all individuals participating in pest management activities with general use pesticides 

also are encouraged to attend appropriate training or acquire pesticide applicator certification. The 

certification requirement would be for a commercial or private applicator depending upon the state. 

New staff unfamiliar with proper procedures for storing, mixing, handling, applying, and disposing 

of herbicides and containers would receive orientation and training before handling or using any 

products. Documentation of training would be kept in the files at the refuge office. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-14 Appendix G. Integrated Pest Management 

G.6.5 Record Keeping 

Labels and material safety data sheets 

Pesticide labels and material safety data sheets (MSDSs) would be maintained at the refuge shop and 

laminated copies in the mixing area. These documents also would be carried by field applicators, 

where possible. A written reference (e.g., note pad, chalk board, dry erase board) for each tank to be 

mixed would be kept in the mixing area for quick reference while mixing is in progress. In addition, 

approved PUPs stored in the PUPS database typically contain website links (URLs) to pesticide 

labels and MSDSs. 

Pesticide use proposals (PUPs) 

A PUP would be prepared for each proposed pesticide use associated with annual pest management 

on refuge lands and waters. A PUP would include specific information about the proposed pesticide 

use including the common and chemical names of the pesticide(s), target pest species, size and 

location of treatment site(s), application rate(s) and method(s), and federally listed species 

determinations, where applicable. 

In accordance with Service guidelines (Director’s memo [December 12, 2007]), refuge staff may 

receive up to five-year approvals for Washington Office and field reviewed proposed pesticide uses 

based upon meeting identified criteria including an approved IPM plan, where necessary (see 

http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan (requirements 

described herein) can be completed independently or in association with a CCP or a habitat 

management plan (HMP) if IPM strategies and potential environmental effects are adequately 

addressed within appropriate NEPA documentation. 

PUPs would be created, approved or disapproved, and stored as records in the Pesticide Use Proposal 

System (PUPS), which is centralized database on the Service’s intranet 

(https://systems.fws.gov/pups). Only Service employees can access PUP records in this database. 

Pesticide usage 

In accordance with 569 FW 1, the refuge Project Leader would be required to maintain records of all 

pesticides annually applied on lands or waters under refuge jurisdiction. This would encompass 

pesticides applied by other federal agencies, state and county governments, non-government 

applicators including cooperators and their pest management service providers with Service 

permission. For clarification, pesticide means all insecticides, insect and plant growth regulators, 

desiccants, herbicides, fungicides, rodenticides, acaricides, nematicides, fumigants, avicides, and 

piscicides. 

The following usage information can be reported for approved PUPs in the PUPS database: 

 Pesticide trade name(s) 

 Active ingredient(s) 

 Total acres treated 

 Total amount of pesticides used (lbs. or gallons) 

 Total amount of active ingredient(s) used (lbs.) 

 Target pest(s) 

 Efficacy (% control) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-15 

To determine whether treatments are efficacious (eradicating, controlling, or containing the target 

pest) and achieving resource objectives, habitat and/or wildlife response would be monitored both 

pre- and post-treatment, where possible. Considering available annual funding and staffing, 

appropriate monitoring data regarding characteristics (attributes) of pest infestations (e.g., area, 

perimeter, degree of infestation-density, % cover, density) as well as habitat and/or wildlife response 

to treatments may be collected and stored in a relational database (e.g., Refuge Habitat Management 

Database), preferably a geo-referenced data management system (e.g., Refuge Lands GIS) to 

facilitate data analyses and subsequent reporting. In accordance with adaptive management, data 

analysis and interpretation would allow treatments to be modified or changed over time, as 

necessary, to achieve resource objectives considering site-specific conditions in conjunction with 

habitat and/or wildlife responses. Monitoring could also identify short- and long-term impacts to 

natural resources and environmental quality associated with IPM treatments in accordance with 

adaptive management principles identified in 43 CFR 46.145. 

G.7 Evaluating Pesticide Use Proposals 

Pesticides would only be used on refuge lands for habitat management as well as croplands/facilities 

maintenance after approval of a PUP. In general, proposed pesticide uses on refuge lands would only 

be approved where there would likely be minor, temporary, or localized effects to fish and wildlife 

species as well as minimal potential to degrade environmental quality. Potential effects to listed and 

non-listed species would be evaluated with quantitative ecological risk assessments and other 

screening measures. Potential effects to environmental quality would be based upon pesticide 

characteristics of environmental fate (water solubility, soil mobility, soil persistence, and 

volatilization) and other quantitative screening tools. Ecological risk assessments as well as 

characteristics of environmental fate and potential to degrade environmental quality for pesticides 

would be documented in Chemical Profiles (see Section G.7.5). These profiles would include 

threshold values for quantitative measures of ecological risk assessments and screening tools for 

environmental fate that represent minimal potential effects to species and environmental quality. In 

general, only pesticide uses with appropriate BMPs (see Section G.4) for habitat management and 

cropland/facilities maintenance on refuge lands that would potentially have minor, temporary, or 

localized effects on refuge biological and environmental quality (threshold values not exceeded) 

would be approved. 

G.7.1 Overview of Ecological Risk Assessment 

An ecological risk assessment process would be used to evaluate potential adverse effects to 

biological resources as a result of a pesticide(s) proposed for use on refuge lands. It is an established 

quantitative and qualitative methodology for comparing and prioritizing risks of pesticides and 

conveying an estimate of the potential risk for an adverse effect. This quantitative methodology 

provides an efficient mechanism to integrate best available scientific information regarding hazard, 

patterns of use (exposure), and dose-response relationships in a manner that is useful for ecological 

risk decision-making. It would provide an effective way to evaluate potential effects where there is 

missing or unavailable scientific information (data gaps) to address reasonable, foreseeable adverse 

effects in the field as required under 40 CFR Part 1502.22. Protocols for ecological risk assessment 

of pesticide uses on the Refuge were developed through research and established by the U.S. 

Environmental Protection Agency (2004). Assumptions for these risk assessments are presented in 

Section G.7.2. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-16 Appendix G. Integrated Pest Management 

The toxicological data used in ecological risk assessments are typically results of standardized 

laboratory studies provided by pesticide registrants to the USEPA to meet regulatory requirements 

under FIFRA. These studies assess the acute (lethality) and chronic (reproductive) effects associated 

with short- and long-term exposure to pesticides on representative species of birds, mammals, 

freshwater fish, aquatic invertebrates, and terrestrial and aquatic plants. Other effects data publicly 

available would also be utilized for risk assessment protocols described herein. Toxicity endpoint and 

environmental fate data are available from a variety of resources. Some of the more useful resources 

can be found in Section G.7.5. 

Table G-1. Ecotoxicity tests used to evaluate potential effects to birds, fish, and mammals to 

establish toxicity endpoints for risk quotient calculations 

Species Group Exposure Measurement endpoint 

Bird 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)1

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)2

Mammal Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)3

1

Measurement endpoints typically include a variety of reproductive parameters (e.g., number of eggs, number of 

offspring, eggshell thickness, and number of cracked eggs). 2

Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time to hatch, growth, 

and time to swim-up. 

3

Measurement endpoints include maternal toxicity, teratogenic effects or developmental anomalies, evidence of 

mutagenicity or genotoxicity, and interference with cellular mechanisms such as DNA synthesis and DNA repair. 

G.7.2 Determining Ecological Risk to Fish and Wildlife 

The potential for pesticides used on the Refuge to cause direct adverse effects to fish and wildlife 

would be evaluated using USEPA’s Ecological Risk Assessment Process (USEPA 2004). This 

deterministic approach, which is based upon a two-phase process involving estimation of 

environmental concentrations and then characterization of risk, would be used for ecological risk 

assessments. This method integrates exposure estimates (estimated environmental concentration 

[EEC] and toxicological endpoints [e.g., LC50 and oral LD50]) to evaluate the potential for adverse 

effects to species groups (birds, mammals, and fish) representative of legal mandates for managing 

units of the NWRS. This integration is achieved through risk quotients (RQs) calculated by dividing 

the EEC by acute and chronic toxicity values selected from standardized toxicological endpoints or 

published effect (Table G-1). 

RQ = EEC/Toxicological Endpoint 

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by U.S. Environmental 

Protection Agency (1998 [Table G-2]). The LOC represents a quantitative threshold value for 

screening potential adverse effects to fish and wildlife resources associated with pesticide use. The 

following are four exposure-species group scenarios that would be used to characterize ecological 

risk to fish and wildlife on the Refuge: acute-listed species, acute-nonlisted species, chronic-listed 

species, and chronic-nonlisted species. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-17 

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from 

LC50 and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, 

chronic risks would indicate the potential for adverse effects associated with long-term dietary 

exposure to pesticides from a single application or multiple applications over time (within a season 

and over years). For characterization of chronic risks, the no observed concentration (NOAEC) or no 

observed effect concentration (NOEC) for reproduction would be used as toxicological endpoints for 

RQ calculations. Where available, the NOAEC would be preferred over a NOEC value. 

Listed species are those federally designated as threatened, endangered, or proposed in accordance 

with the Endangered Species Act of 1973 (16 USC 1531-1544, 87 Stat. 884, as amended-Public Law 

93-205). For listed species, potential adverse effects would be assessed at the individual level 

because loss of individuals from a population could detrimentally impact a species. In contrast, risks 

to nonlisted species would consider effects at the population level. A RQ<LOC would indicate the 

proposed pesticide use “may affect, not likely to adversely affect” individuals (listed species) and it 

would not pose an unacceptable risk for adverse effects to populations (non-listed species) for each 

taxonomic group (Table G-2). In contrast, an RQ>LOC would indicate a “may affect, likely to 

adversely affect” for listed species and it would also pose unacceptable ecological risk for adverse 

effects to nonlisted species. 

 

Table G-2. Presumption of unacceptable risk for birds, fish, and mammals (USEPA 1998) 

Risk Presumption Level of Concern 

Listed Species Non-listed Species 

Acute Birds 0.1 0.5 

Fish 0.05 0.5 

Mammals 0.1 0.5 

Chronic Birds 1.0 1.0 

Fish 1.0 1.0 

Mammals 1.0 1.0 

Environmental exposure 

Following release into the environment through application, pesticides would experience several 

different routes of environmental fate. Pesticides which would be sprayed can move through the air 

(e.g., particle or vapor drift) and may eventually end up in other parts of the environment such as 

non-target vegetation, soil, or water. Pesticides applied directly to the soil may be washed off the soil 

into nearby bodies of surface water (e.g., surface runoff) or may percolate through the soil to lower 

soil layers and groundwater (e.g., leaching) (Baker and Miller 1999, Pope et al. 1999, Butler et al. 

1998, Ramsay et al. 1995, EXTOXNET 1993). Pesticides which would be injected into the soil may 

also be subject to the latter two fates. The aforementioned possibilities are by no means complete, but 

it does indicate movement of pesticides in the environment is very complex with transfers occurring 

continually among different environmental compartments. In some cases, these exchanges occur not 

only between areas that are close together, but it also may involve transportation of pesticides over 

long distances (Barry 2004, Woods 2004). 

Terrestrial exposure 

The ECC for exposure to terrestrial wildlife would be quantified using an USEPA screening-level 

approach (USEPA 2004). This screening-level approach is not affected by product formulation 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-18 Appendix G. Integrated Pest Management 

because it evaluates pesticide active ingredient(s). This approach would vary depending upon the 

proposed pesticide application method: spray or granular. 

Terrestrial-spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (USEPA 

2004, USEPA 2012, Pfleeger et al. 1996) through the USEPA’s Terrestrial Residue Exposure model 

(T-REX) version 1.2.3 (USEPA 2005). To estimate the maximum (initial) pesticide residue on short 

grass (<20 cm tall) as a general food item category for terrestrial vertebrate species, T-REX input 

variables would include the following from the pesticide label: maximum pesticide application rate 

(pounds active ingredient [acid equivalent]/acre) and pesticide half-life (days) in soil. Although there 

are other food item categories (tall grasses; broadleaf plants and small insects; and fruits, pods, seeds 

and large insects), short grass was selected because it would yield maximum EECs (240 ppm per lb. 

ai/acre) for worst-case risk assessments. Short grass is not representative of forage for carnivorous 

species (e.g., raptors), but it would characterize the maximum potential exposure through the diet of 

avian and mammalian prey items. Consequently, this approach would provide a conservative 

screening tool for pesticides that do not biomagnify. 

For RQ calculations in T-REX, the model would require the weight of surrogate species and Mineau 

scaling factors (Mineau et al. 1996). Body weights of bobwhite quail and mallard are included in TREX by default, but body weights of other organisms (Table 3) would be entered manually. The 

Mineau scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide 

exposure than would be predicted only by body weight. Mineau scaling factors would be entered 

manually with values ranging from 1 to 1.55 that are unique to a particular pesticide or group of 

pesticides. If specific information to select a scaling factor is not available, then a value of 1.15 

would be used as a default. Alternatively, zero would be entered if it is known that body weight does 

not influence toxicity of pesticide(s) being assessed. The upper bound estimate output from the TREX Kanaga nomogram would be used as an EEC for calculation of RQs. This approach would yield 

a conservative estimate of ecological risk. 

Table G-3. Average body weight of selected terrestrial wildlife species frequently used in 

research to establish toxicological endpoints (Dunning 1984) 

Species Body Weight (kg) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Common grackle 0.114 

Japanese quail 0.178 

Bobwhite quail 0.178 

Rat 0.200 

Rock dove (aka pigeon) 0.542 

Mammal (1,000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-19 

Terrestrial – granular application 

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units which birds or mammals 

might ingest accidentally with food items or intentionally as in the case of some bird species actively 

seeking and picking up gravel or grit to aid digestion or seed as a food source. Granules may also be 

consumed by wildlife foraging on earthworms, slugs or other soft-bodied soil organisms to which the 

granules may adhere. 

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing 

the maximum milligrams of active ingredient (a.i.) exposed (e.g., EEC) on the surface of an area 

equal to 1 square foot by the appropriate LD50 value multiplied by the surrogate’s body weight 

(Table G-3). An adjustment to surface area calculations would be made for broadcast, banded, and 

in-furrow applications. An adjustment also would be made for applications with and without 

incorporation of the granules. Without incorporation, it would be assumed that 100% of the granules 

remain on the soil surface available to foraging birds and mammals. Press wheels push granules flat 

with the soil surface, but they are not incorporated into the soil. If granules are incorporated in the 

soil during band or T-band applications or after broadcast applications, it would be assumed only 

15% of the applied granules remain available to wildlife. It would be assumed that only 1% of the 

granules are available on the soil surface following in-furrow applications. 

EECs for pesticides applied in granular form and as seed treatments would be determined 

considering potential ingestion rates of avian or mammalian species (e.g., 10-30% body weight/day). 

This would provide an estimate of maximum exposure that may occur as a result of granule or seed 

treatment spills such as those that commonly occur at end rows during application and planting. The 

availability of granules and seed treatments to terrestrial vertebrates would also be considered by 

calculating the loading per unit area (LD50/ft2

) for comparison to USEPA Level of Concerns (USEPA 

1998). The T-REX version 1.2.3 (USEPA 2005) contains a submodel which automates Kanaga 

exposure calculations for granular pesticides and treated seed. 

The following formulas would be used to calculate EECs depending upon the type of granular 

pesticide application: 

 In-furrow applications assume a typical value of 1% granules, bait, or seed remain 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560 ft.

2

/acre)/(row 

spacing (ft.))] / (row spacing (ft.)} 

or 

mg a.i./ft

2 

= [(lbs product/1,000 ft. row)(% a.i.)(1,000 ft row)(453,580 mg/lb.)(1% exposed) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Incorporated banded treatments assume that 15% of granules, bait, and seeds are 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1,000 row ft.)(% a.i.)(453,580 mg/lb.)(1-% incorporated)] / (1,000 

ft.)(band width (ft.)) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-20 Appendix G. Integrated Pest Management 

 Broadcast treatment without incorporation assumes 100% of granules, bait, seeds are 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb.)] / (43,560 ft.

2

/acre) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

Where: 

 % of pesticide biologically available = 100% without species specific ingestion rates 

 Conversion for calculating mg a.i./ft.

2 

using ounces: 453,580 mg/lb. /16 = 28,349 mg/oz. 

The following equation would be used to calculate an RQ based on the EEC calculated by one of the 

above equations. The EEC would be divided by the surrogate LD50 toxicological endpoint multiplied 

by the body weight (Table G-3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, an RQ>LOC would be a presumption of unacceptable ecological 

risk. An RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or 

localized effects to species. 

Aquatic exposure 

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) 

would be evaluated separately for ground-based pesticide treatments of habitats managed for fish and 

wildlife compared with cropland/facilities maintenance. The primary exposure pathway for aquatic 

organisms from any ground-based treatments likely would be particle drift during the pesticide 

application. However, different exposure scenarios would be necessary as a result of contrasting 

application equipment and techniques as well as pesticides used to control pests on agricultural lands 

(especially those cultivated by cooperative farmers for economic return from crop yields) and 

facilities maintenance (e.g., roadsides, parking lots, trails) compared with other managed habitats on 

the Refuge. In addition, pesticide applications may be done <25 feet of the high water mark of 

aquatic habitats for habitat management treatments; whereas, no-spray buffers (≥25 feet) would be 

used for croplands/facilities maintenance treatments. 

Habitat treatments 

For the worst-case exposure scenario to non-target aquatic habitats, EECs (Table 4) would be would 

be derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, nontarget water body (1-foot depth) from a treatment <25 feet from the high water mark using the max 

application rate (acid basis [see above]). However, use of BMPs for applying pesticides (see Section 

G.4.2) would likely minimize/eliminate potential drift to non-target aquatic habitats during actual 

treatments. If there would be unacceptable (acute or chronic) risk to fish and wildlife with the 

simulated 100% overspray (RQ>LOC), then the proposed pesticide use may be disapproved or the 

PUP would be approved at a lower application rate to minimize/eliminate unacceptable risk to 

aquatic organisms (RQ=LOC). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-21 

Table G-4. Estimated Environmental Concentrations (ppb) of pesticides in aquatic habitats 

(1 foot depth) immediately after direct application (Urban and Cook 1986) 

Lbs/acre EEC (ppb) 

0.10 36.7 

0.20 73.5 

0.25 91.9 

0.30 110.2 

0.40 147.0 

0.50 183.7 

0.75 275.6 

1.00 367.5 

1.25 459.7 

1.50 551.6 

1.75 643.5 

2.00 735.7 

2.25 827.6 

2.50 919.4 

3.00 1,103.5 

4.00 1,471.4 

5.00 1,839 

6.00 2,207 

7.00 2,575 

8.00 2,943 

9.00 3,311 

10.00 3,678 

Cropland/facilities maintenance treatments 

Field drift studies conducted by the Spray Drift Task Force, which is a joint project of several 

agricultural chemical businesses, were used to develop a generic spray drift database. From this 

database, the AgDRIFT computer model was created to satisfy USEPA pesticide registration spray 

drift data requirements and as a scientific basis to evaluate off-target movement of pesticides from 

particle drift and assess potential effects of exposure to wildlife. Several versions of the computer 

model have been developed (i.e., v2.01 through v2.10). The Spray Drift Task Force AgDRIFT® 

model version 2.01 (SDTF 2003, AgDRIFT 2001) would be used to derive EECs resulting from drift 

of pesticides to refuge aquatic resources from ground-based pesticide applications >25 feet from the 

high water mark. The Spray Drift Task Force AgDRIFT model is publicly available at 

http://www.agdrift.com. At this website, click “AgDRIFT 2.0” and then click “Download Now” and 

follow the instructions to obtain the computer model. 

The AgDRIFT model is composed of submodels called tiers. Tier I Ground submodel would be used 

to assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with 

AgDRIFT using the following input variables: max application rate (acid basis [see above]), low 

boom (20 inches), fine to medium droplet size, EPA-defined wetland, and a ≥25-foot distance 

(buffer) from treated area to water. 

Use of information on effects of biological control agents, pesticides, degradates, and adjuvants 

NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another federal agency, where the scope would be 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-22 Appendix G. Integrated Pest Management 

relevant to evaluation of effects from pesticide uses on refuge lands, would be reviewed. Possible 

source agencies for such NEPA documents would include the Bureau of Land Management, U.S. 

Forest Service, National Park Service, U.S. Department of Agriculture-Animal and Plant Health 

Inspection Service, and the military services. It might be appropriate to incorporate by reference parts 

or all of existing document(s). Incorporating by reference (40 CFR 1502.21) is a technique used to 

avoid redundancies in analysis. It also would reduce the bulk of a Service NEPA document, which 

only would identify the documents that are incorporated by reference. In addition, relevant portions 

would be summarized in the Service NEPA document to the extent necessary to provide the decision 

maker and public with an understanding of relevance of the referenced material to the current 

analysis. 

In accordance with the requirements set forth in 43 CFR 46.135, the Service would specifically 

incorporate through reference ecological risk assessments prepared by the U.S. Forest Service 

(http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-InvPlantEIS.htm) and Bureau of Land Management (http://www.blm.gov/wo/st/en/prog/more/veg_eis.html). 

These risk assessments and associated documentation also are available in total with the 

administrative record for the Final Environmental Impact Statement entitled Pacific Northwest 

Region Invasive Plant Program – Preventing and Managing Invasive Plants (USFS 2005) and 

Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western 

States Programmatic EIS (PEIS) (BLM 2007). In accordance with 43 CFR 46.120(d), use of existing 

NEPA documents by supplementing, tiering to, incorporating by reference, or adopting previous 

NEPA environmental analyses would avoid redundancy and unnecessary paperwork. 

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, 

ecological risk assessments for the following herbicide and adjuvant uses prepared by the U.S. Forest 

Service would be incorporated by reference: 

 2,4-D 

 Chlorsulfuron 

 Clopyralid 

 Dicamba 

 Glyphosate 

 Imazapic 

 Imazapyr 

 Metsulfuron methyl 

 Picloram 

 Sethoxydim 

 Sulfometuron methyl 

 Triclopyr 

 Nonylphenol polyethylate (NPE) based surfactants 

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, 

ecological risk assessments for the following herbicide uses as well as evaluation of risks associated 

with pesticide degradates and adjuvants prepared by the Bureau of Land Management would be 

incorporated by reference: 

 Bromacil 

 Chlorsulfuron 

 Diflufenzopyr 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-23 

 Diquat 

 Diuron 

 Fluridone 

 Imazapic 

 Overdrive (diflufenzopyr and dicamba) 

 Sulfometuron methyl 

 Tebuthiuron 

 Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates, 

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals) 

Assumptions for ecological risk assessments 

There are a number of assumptions involved with the ecological risk assessment process for 

terrestrial and aquatic organisms associated with utilization of the U.S. Environmental Protection 

Agency’s (2004) process. These assumptions may be risk neutral or may lead to an over- or underestimation of risk from pesticide exposure depending upon site-specific conditions. The following 

describes these assumptions, their application to the conditions typically encountered, and whether or 

not they may lead to recommendations that are risk neutral, underestimate, or overestimate ecological 

risk from potential pesticide exposure. 

 Indirect effects would not be evaluated by ecological risk assessments. These effects include 

the mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or 

small mammals), reductions in the availability of prey items, and disturbance associated with 

pesticide application activities. 

 Exposure to a pesticide product can be assessed based upon the active ingredient. However, 

exposure to a chemical mixture (pesticide formulation) may result in effects that are similar 

or substantially different compared to only the active ingredient. Non-target organisms may 

be exposed directly to the pesticide formulation or only various constituents of the 

formulation as they dissipate and partition in the environment. If toxicological information 

for both the active ingredient and formulated product are available, then data representing the 

greatest potential toxicity would be selected for use in the risk assessment process (USEPA 

2004). As a result, this conservative approach may lead to an overestimation of risk 

characterization from pesticide exposure. 

 Because toxicity tests with listed or candidate species or closely related species are not 

available, data for surrogate species would be most often used for risk assessments. 

Specifically, bobwhite quail and mallard duck are the most frequently used surrogates for 

evaluating potential toxicity to federally listed avian species. Bluegill sunfish, rainbow trout, 

and fathead minnow are the most common surrogates for evaluating toxicity for freshwater 

fishes. However, sheep’s head minnow can be an appropriate surrogate marine species for 

coastal environments. Rats and mice are the most common surrogates for evaluating toxicity 

for mammals. Interspecies sensitivity is a major source of uncertainty in pesticide 

assessments. As a result of this uncertainty, data are selected for the most sensitive species 

tested within a taxonomic group (birds, fish, and mammals) given the quality of the data is 

acceptable. If additional toxicity data for more species of organisms in a particular group are 

available, the selected data would not be limited to the species previously listed as common 

surrogates. 

 The Kanaga nomogram outputs maximum EEC values that may be used to calculate an 

average daily concentration over a specified interval of time, which is referred to as a timeweighted-average (TWA). The maximum EEC would be selected as the exposure input for 

both acute and chronic risk assessments in the screening-level evaluations. The initial or 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-24 Appendix G. Integrated Pest Management 

maximum EEC derived from the Kanaga nomogram represents the maximum expected 

instantaneous or acute exposure to a pesticide. Acute toxicity endpoints are determined using 

a single exposure to a known pesticide concentration typically for 48 to 96 hours. This value 

is assumed to represent ecological risk from acute exposure to a pesticide. On the other hand, 

chronic risk to pesticide exposure is a function of pesticide concentration and duration of 

exposure to the pesticide. An organism’s response to chronic pesticide exposure may result 

from either the concentration of the pesticide, length of exposure, or some combination of 

both factors. Standardized tests for chronic toxicity typically involve exposing an organism to 

several different pesticide concentrations for a specified length of time (days, weeks, months, 

years or generations). For example, avian reproduction tests include a 10-week exposure 

phase. Because a single length of time is used in the test, time response data are usually not 

available for inclusion into risk assessments. Without time response data it is difficult to 

determine the concentration which elicited a toxicological response. 

 Using maximum EECs for chronic risk estimates may result in an overestimate of risk, 

particularly for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk 

estimates may underestimate risk if it is the concentration rather than the duration of 

exposure that is primarily responsible for the observed adverse effect. The maximum EEC 

would be used for chronic risk assessments although it may result in an overestimate of risk. 

TWAs may be used for chronic risk assessments, but they would be applied judiciously 

considering the potential for an underestimate or overestimate of risk. For example, the 

number of days exposure exceeds a Level of Concern may influence the suitability of a 

pesticide use. The greater the number of days the EEC exceeds the Level of Concern 

translates into greater the ecological risk. This is a qualitative assessment, and is subject to 

reviewer’s expertise in ecological risk assessment and tolerance for risk. 

 The length of time used to calculate the TWA can have a substantial effect on the exposure 

estimates and there is no standard method for determining the appropriate duration for this 

estimate. The T-REX model assumes a 21-week exposure period, which is equivalent to 

avian reproductive studies designed to establish a steady-state concentration for 

bioaccumulative compounds. However, this does not necessarily define the true exposure 

duration needed to elicit a toxicological response. Pesticides, which do not bioaccumulate, 

may achieve a steady-state concentration earlier than 21 weeks. The duration of time for 

calculating TWAs would require justification and it would not exceed the duration of 

exposure in the chronic toxicity test (approximately 70 days for the standard avian 

reproduction study). An alternative to using the duration of the chronic toxicity study is to 

base the TWA on the application interval. In this case, increasing the application interval 

would suppress both the estimated peak pesticide concentration and the TWA. Another 

alternative to using TWAs would be to consider the number of days that a chemical is 

predicted to exceed the LOC. 

 Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as bi-phasic. Field dissipation data would generally be the most 

pertinent for assessing exposure in terrestrial species that forage on vegetation. However, 

these data are often not available and it can be misleading particularly if the compound is 

prone to “wash-off.” Soil half-life is the most common degradation data available. 

Dissipation or degradation data that would reflect the environmental conditions typical of 

refuge lands would be utilized, if available. 

 For species found in the water column, it would be assumed that the greatest bioavailable 

fraction of the pesticide active ingredient in surface waters is freely dissolved in the water 

column. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-25 

 Actual habitat requirements of any particular terrestrial species are not considered, and it is 

assumed that species exclusively and permanently occupy the treated area, or adjacent areas 

receiving pesticide at rates commensurate with the treatment rate. This assumption would 

produce a maximum estimate of exposure for risk characterization. This assumption would 

likely lead to an overestimation of exposure for species that do not permanently and 

exclusively occupy the treated area (USEPA 2004). 

 Exposure through incidental ingestion of pesticide contaminated soil is not considered in the 

USEPA risk assessment protocols. Research suggests <15% of the diet can consist of 

incidentally ingested soil depending upon species and feeding strategy (Beyer et al. 1994). 

An assessment of pesticide concentrations in soil compared to food item categories in the 

Kanaga nomogram indicates incidental soil ingestion would not likely increase dietary 

exposure to pesticides. Inclusion of soil into the diet would effectively reduce the overall 

dietary concentration compared to the present assumption that the entire diet consists of a 

contaminated food source (Fletcher et al. 1994). An exception to this may be soil-applied 

pesticides in which exposure from incidental ingestion of soil may increase. Potential for 

pesticide exposure under this assumption may be underestimated for soil-applied pesticides 

and overestimated for foliar-applied pesticides. The concentration of a pesticide in soil would 

likely be less than predicted on food items. 

 Exposure through inhalation of pesticides is not considered in the USEPA risk assessment 

protocols. Such exposure may occur through three potential sources: spray material in droplet 

form at time of application, vapor phase with the pesticide volatilizing from treated surfaces, 

and airborne particulates (soil, vegetative matter, and pesticide dusts). The USEPA (1990) 

reported exposure from inhaling spray droplets at the time of application is not an appreciable 

route of exposure for birds. According to research on mallards and bobwhite quail, respirable 

particle size (particles reaching the lung) in birds is limited to maximum diameter of 2 to 5 

microns. The spray droplet spectra covering the majority of pesticide application scenarios 

indicate that less than 1% of the applied material is within the respirable particle size. This 

route of exposure is further limited because the permissible spray drop size distribution for 

ground pesticide applications is restricted to ASAE medium or coarser drop size distribution. 

 Inhalation of a pesticide in the vapor phase may be another source of exposure for some 

pesticides under certain conditions. This mechanism of exposure to pesticides occurs post 

application, and it would pertain to those pesticides with a high vapor pressure. The USEPA 

is currently evaluating protocols for modeling inhalation exposure from pesticides including 

near-field and near-ground air concentrations based upon equilibrium and kinetics-based 

models. Risk characterization for exposure with this mechanism is unavailable. 

 The effect from exposure to dusts contaminated with the pesticide cannot be assessed 

generically as partitioning issues related to application site soils and chemical properties of 

the applied pesticides render the exposure potential from this route highly situation specific. 

 Dermal exposure may occur through three potential sources: direct application of spray to 

terrestrial wildlife in the treated area or within the drift footprint, incidental contact with 

contaminated vegetation, or contact with contaminated water or soil. Interception of spray 

and incidental contact with treated substrates may pose risk to avian wildlife (Driver et al. 

1991). However, available research related to wildlife dermal contact with pesticides is 

extremely limited, except dermal toxicity values are common for some mammals used as 

human surrogates (rats and mice). The USEPA is currently evaluating protocols for modeling 

dermal exposure. Risk characterization may be underestimated for this route of exposure, 

particularly with high risk pesticides such as some organophosphates or carbamate 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-26 Appendix G. Integrated Pest Management 

insecticides. If protocols are established by the USEPA for assessing dermal exposure to 

pesticides, they would be considered for incorporation into pesticide assessment protocols. 

 Exposure to a pesticide may occur from consuming surface water, dew or other water on 

treated surfaces. Water soluble pesticides have the potential to dissolve in surface runoff and 

puddles in a treated area may contain pesticide residues. Similarly, pesticides with lower 

organic carbon partitioning characteristics and higher solubility in water have a greater 

potential to dissolve in dew and other water associated with plant surfaces. Estimating the 

extent to which such pesticide loadings to drinking water occurs is complex and would 

depend upon the partitioning characteristics of the active ingredient, soils types in the 

treatment area, and the meteorology of the treatment area. In addition, the use of various 

water sources by wildlife is highly species-specific. Currently, risk characterization for this 

exposure mechanism is not available. The USEPA is actively developing protocols to 

quantify drinking water exposures from puddles and dew. If and when protocols are formally 

established by the USEPA for assessing exposure to pesticides through drinking water, these 

protocols would be incorporated into pesticide risk assessment protocols. 

 Risk assessments are based upon the assumption that the entire treatment area would be 

subject to pesticide application at the rates specified on the label. In most cases, there is 

potential for uneven application of pesticides through such plausible incidents such as 

changes in calibration of application equipment, spillage, and localized releases at specific 

areas in or near the treated field that are associated with mixing and handling and application 

equipment as well as applicator skill. Inappropriate use of pesticides and the occurrence of 

spills represent a potential underestimate of risk. It is likely not an important factor for risk 

characterization. All pesticide applicators are required to be certified by the state in which 

they apply pesticides. Certification training includes the safe storage, transport, handling, and 

mixing of pesticides; equipment calibration; and proper application with annual continuing 

education. 

 The USEPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife 

dietary items. The USEPA (2004) “believes that these residue assumptions reflect a realistic 

upper-bound residue estimate, although the degree to which this assumption reflects a 

specific percentile estimate is difficult to quantify.” Fletcher’s (1994) research suggests that 

the pesticide active ingredient residue assumptions used by the USEPA represent a 95th 

percentile estimate. However, research conducted by Pfleeger et al. (1996) indicates USEPA 

residue assumptions for short grass was not exceeded. Baehr and Habig (2000) compared 

USEPA residue assumptions with distributions of measured pesticide residues for the 

USEPA’s UTAB database. Overall residue selection level tends to overestimate risk 

characterization. This is particularly evident when wildlife individuals are likely to have 

selected a variety of food items acquired from multiple locations. Some food items may be 

contaminated with pesticide residues whereas others are not contaminated. However, it is 

important to recognize differences in species feeding behavior. Some species may consume 

whole above-ground plant material, but others will preferentially select different plant 

structures. Also, species may preferentially select a food item although multiple food items 

may be present. Without species specific knowledge regarding foraging behavior 

characterizing ecological risk other than in general terms is not possible. 

 Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with 

LC50 or NOEC values expressed as concentrations of pesticides in laboratory feed. These 

comparisons assume that ingestion of food items in the field occurs at rates commensurate 

with those in the laboratory. Although the screening assessment process adjusts dry-weight 

estimates of food intake to reflect the increased mass in fresh-weight wildlife food intake 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-27 

estimates, it does not allow for gross energy and assimilative efficiency differences between 

wildlife food items and laboratory feed. Differences in assimilative efficiency between 

laboratory and wild diets suggest that current screening assessment methods are not 

accounting for a potentially important aspect of food requirements. 

 There are several other assumptions that can affect non-target species not considered in the 

risk assessment process. These include possible additive or synergistic effects from applying 

two or more pesticides or additives in a single application, co-location of pesticides in the 

environment, cumulative effects from pesticides with the same mode of action, effects of 

multiple stressors (e.g., combination of pesticide exposure, adverse abiotic and biotic factors) 

and behavioral changes induced by exposure to a pesticide. These factors may exist at some 

level contributing to adverse effects to non-target species, but they are usually characterized 

in the published literature in only a general manner limiting their value in the risk assessment 

process. 

 It is assumed that aquatic species exclusively and permanently occupy the water body being 

assessed. Actual habitat requirements of aquatic species are not considered. With the possible 

exception of scenarios where pesticides are directly applied to water, it is assumed that no 

habitat use considerations specific for any species would place the organisms in closer 

proximity to pesticide use sites. This assumption produces a maximum estimate of exposure 

or risk characterization. It would likely be realistic for many aquatic species that may be 

found in aquatic habitats within or in close proximity to treated terrestrial habitats. However, 

the spatial distribution of wildlife is usually not random because wildlife distributions are 

often related to habitat requirements of species. Clumped distributions of wildlife may result 

in an under- or over-estimation of risk depending upon where the initial pesticide 

concentration occurs relative to the species or species habitat. 

 For species found in the water column, it would be assumed that the greatest bioavailable 

fraction of the pesticide active ingredient in surface waters is freely dissolved in the water 

column. Additional chemical exposure from materials associated with suspended solids or 

food items is not considered because partitioning onto sediments likely is minimal. 

Adsorption and bioconcentration occurs at lower levels for many newer pesticides compared 

with older more persistent bioaccumulative compounds. Pesticides with RQs close to the 

listed species level of concern, the potential for additional exposure from these routes may be 

a limitation of risk assessments, where potential pesticide exposure or risk may be 

underestimated. 

 Mass transport losses of pesticide from a water body (except for losses by volatilization, 

degradation and sediment partitioning) would not be considered for ecological risk 

assessment. The water body would be assumed to capture all pesticide active ingredients 

entering as runoff, drift, and adsorbed to eroded soil particles. It would also be assumed that 

pesticide active ingredient is not lost from the water body by overtopping or flow-through, 

nor is concentration reduced by dilution. In total, these assumptions would lead to a near 

maximum possible water-borne concentration. However, this assumption would not account 

for the potential to concentrate pesticide through the evaporative loss. This limitation may 

have the greatest impact on water bodies with high surface-to-volume ratios such as 

ephemeral wetlands, where evaporative losses are accentuated and applied pesticides have 

low rates of degradation and volatilization. 

 For acute risk assessments, there would be no averaging time for exposure. An instantaneous 

peak concentration would be assumed, where instantaneous exposure is sufficient in duration 

to elicit acute effects comparable to those observed over more protracted exposure periods 

(typically 48 to 96 hours) tested in the laboratory. In the absence of data regarding time-to-
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-28 Appendix G. Integrated Pest Management 

toxic event, analyses and latent responses to instantaneous exposure, risk would likely be 

overestimated. 

 For chronic exposure risk assessments, the averaging times considered for exposure are 

commensurate with the duration of invertebrate life-cycle or fish-early life stage tests (e.g., 

21-28 days and 56-60 days, respectively). Response profiles (time to effect and latency of 

effect) to pesticides likely vary widely with mode of action and species and should be 

evaluated on a case-by-case basis as available data allow. Nevertheless, because the USEPA 

relies on chronic exposure toxicity endpoints based on a finding of no observed effect, the 

potential for any latent toxicity effects or averaging time assumptions to alter the results of an 

acceptable chronic risk assessment prediction is limited. The extent to which duration of 

exposure from water-borne concentrations overestimate or underestimate actual exposure 

depends on several factors. These include the following: localized meteorological conditions, 

runoff characteristics of the watershed (e.g., soils, topography), the hydrological 

characteristics of receiving waters, environmental fate of the pesticide active ingredient, and 

the method of pesticide application. It should also be understood that chronic effects studies 

are performed using a method that holds water concentration in a steady state. This method is 

not likely to reflect conditions associated with pesticide runoff. Pesticide concentrations in 

the field increase and decrease in surface water on a cycle influenced by rainfall, pesticide 

use patterns, and degradation rates. As a result of the dependency of this assumption on 

several undefined variables, risk associated with chronic exposure may in some situations 

underestimate risk and overestimate risk in others. 

 There are several other factors that can affect non-target species not considered in the risk 

assessment process. These would include the following: possible additive or synergistic 

effects from applying two or more pesticides or additives in a single application, co-location 

of pesticides in the environment, cumulative effects from pesticides with the same mode of 

action, effects of multiple stressors (e.g., combination of pesticide exposure, adverse abiotic 

[not pesticides] and biotic factors), and sub-lethal effects such as behavioral changes induced 

by exposure to a pesticide. These factors may exist at some level contributing to adverse 

effects to non-target species, but they are not routinely assessed by regulatory agencies. 

Therefore, information on the factors is not extensive limiting their value for the risk 

assessment process. As this type of information becomes available, it would be included, 

either quantitatively or qualitatively, in this risk assessment process. 

 USEPA is required by the Food Quality Protection Act to assess the cumulative risks of 

pesticides that share common mechanisms of toxicity, or act the same within an organism. 

Currently, USEPA has identified four groups of pesticides that have a common mechanism of 

toxicity requiring cumulative risk assessments. These four groups are: the organophosphate 

insecticides, N-methyl carbamate insecticides, triazine herbicides, and chloroacetanilide 

herbicides. 

G.7.3 Pesticide Mixtures and Degradates 

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert or other ingredients. The term active ingredient is defined by the FIFRA as 

preventing, destroying, repelling, or mitigating the effects of a pest, or it is a plant regulator, 

defoliant, desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must 

be identified by name(s) on the pesticide label along with its relative composition expressed in 

percentage(s) by weight. In contrast, inert ingredient(s) are not intended to affect a target pest. Their 

role in the pesticide formulation is to act as a solvent (keep the active ingredient is a liquid phase), an 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-29 

emulsifying or suspending agent (keep the active ingredient from separating out of solution), or a 

carrier (such as clay in which the active ingredient is impregnated on the clay particle in dry 

formulations). For example, if isopropyl alcohol would be used as a solvent in a pesticide 

formulation, then it would be considered an inert ingredient. FIFRA only requires that inert 

ingredients identified as hazardous and associated percent composition, and the total percentage of 

all inert ingredients must be declared on a product label. Inert ingredients that are not classified as 

hazardous are not required to be identified. 

The USEPA (September 1997) issued Pesticide Regulation Notice 97-6, which encouraged 

manufacturers, formulators, producers, and registrants of pesticide products to voluntarily substitute 

the term “other ingredients” for “inert ingredients” in the ingredient statement. This change 

recognized that all components in a pesticide formulation potentially could elicit or contribute to an 

adverse effect on non-target organisms and, therefore, are not necessarily inert. Whether referred to 

as “inerts” or “other ingredients,” these constituents within a pesticide product have the potential to 

affect species or environmental quality. The USEPA categorizes regulated inert ingredients into the 

following four lists (http://www.epa.gov/opprd001/inerts/index.html): 

 List 1 – Inert Ingredients of Toxicological Concern 

 List 2 – Potentially Toxic Inert Ingredients 

 List 3 – Inerts of Unknown Toxicity 

 List 4 – Inerts of Minimal Toxicity 

Several of the List 4 compounds are naturally-occurring earthen materials (e.g., clay materials, 

simple salts) that would not elicit toxicological response at applied concentrations. However, some of 

the inerts (particularly the List 3 compounds and unlisted compounds) may have moderate to high 

potential toxicity to aquatic species based on MSDSs or published data. 

Comprehensively assessing potential effects to non-target fish, wildlife, plants, and/or their habitats 

from pesticide use is a complex task. It would be preferable to assess the cumulative effects from 

exposure to the active ingredient, its degradates, and inert ingredients, as well as other active 

ingredients in the spray mixture. However, it would only be feasible to conduct deterministic risk 

assessments for each component in the spray mixture singly. Limited scientific information is 

available regarding ecological effects (additive or synergistic) from chemical mixtures that typically 

rely upon broadly encompassing assumptions. For example, the U.S. Forest Service (2005) found 

that mixtures of pesticides used in land (forest) management likely would not cause additive or 

synergistic effects to non-target species based upon a review of scientific literature regarding 

toxicological effects and interactions of agricultural chemicals (ATSDR 2004). Moreover, 

information on inert ingredients, adjuvants, and degradates is often limited by the availability of and 

access to reliable toxicological data for these constituents. 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

 TOMES (a proprietary toxicological database including USEPA’s IRIS, the Hazardous 

Substance Data Bank, the Registry of Toxic Effects of Chemical Substances [RTECS]). 

 USEPA’s ECOTOX database, which includes AQUIRE (a database containing scientific 

papers published on the toxic effects of chemicals to aquatic organisms). 

 TOXLINE (a literature searching tool). 

 Material Safety Data Sheets (MSDSs) from pesticide suppliers. 

 Other sources such as the Farm Chemicals Handbook. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-30 Appendix G. Integrated Pest Management 

Because there is a lack of specific inert toxicological data, inert(s) in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the 

pesticide spray mixture, and it would be assumed that negligible effects would be expected to result 

from inert ingredient(s). 

Although the potential effects of degradates should be considered when selecting a pesticide, it is 

beyond the scope of this assessment process to consider all possible breakdown chemicals of the 

various product formulations containing an active ingredient. Degradates may be more or less mobile 

and more or less hazardous in the environment than their parent pesticides (Battaglin et al. 2003). 

Differences in environmental behavior (e.g., mobility) and toxicity between parent pesticides and 

degradates would make assessing potential degradate effects extremely difficult. For example, a less 

toxic and more mobile, bioaccumulative, or persistent degradate may have potentially greater effects 

on species and/or degrade environmental quality. The lack of data on the toxicity of degradates for 

many pesticides would represent a source of uncertainty for assessing risk. 

A USEPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not possible to quantify the potential effects of 

these mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific 

information allowed a determination of whether the joint action of a mixture would be additive, 

synergistic, or antagonistic. Such information would not likely exist unless the mode of action would 

be common among the chemicals and receptors. Moreover, the composition of and exposure to 

mixtures would be highly site- and/or time-specific and, therefore, it would be nearly impossible to 

assess potential effects to species and environmental quality. 

To minimize or eliminate potential negative effects associated with applying two or more pesticides 

as a mixture, the use would be conducted in accordance with the labeling requirements. Labels for 

two or more pesticides applied as a mixture should be completely reviewed, where products with the 

least potential for negative effects would be selected for use on the Refuge. This is especially 

relevant when a mixture would be applied in a manner that may already have the potential for an 

effect(s) associated with an individual pesticide (e.g., runoff to ponds in sandy watersheds). Use of a 

tank mix under these conditions would increase the level of uncertainty in terms of risk to species or 

potential to degrade environmental quality. 

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial 

herbicides, adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally 

applies to surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, 

compatibility agents, stickers, and spreaders. Adjuvants are not under the same registration 

requirements as pesticides and the USEPA does not register or approve the labeling of spray 

adjuvants. Individual pesticide labels identify types of adjuvants approved for use with it. In general, 

adjuvants compose a relatively small portion of the volume of pesticides applied. Selection of 

adjuvants with limited toxicity and low volumes would be recommended to reduce the potential for 

the adjuvant to influence the toxicity of the pesticide. 

G.7.4 Determining Effects to Soil and Water Quality 

The approval process for pesticide uses would consider potential to degrade water quality on and off 

refuge lands. A pesticide can only affect water quality through movement away from the treatment 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-31 

site. After application, pesticide mobilization can be characterized by one or more of the following 

(Kerle et al. 1996): 

 Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area; 

 Attach to soil and move off-site through erosion from runoff or wind; 

 Dissolve in water that can be subjected to runoff or leaching. 

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the 

following: persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility. 

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50% of the 

deposited pesticide to degrade (completely or partially). Persistence in the soil can be categorized as 

the following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days (Kerle et al. 1996). Half-life data are usually available for aquatic and terrestrial environments. 

Another measure of pesticide persistence is dissipation time (DT50). It represents the time required 

for 50% of the deposited pesticide to degrade and move from a treated site; whereas, half-life 

describes the rate for degradation only. As for half-life, units of dissipation time are usually 

expressed in days. Field or foliar dissipation time is the preferred data for use to estimate pesticide 

concentrations in the environment. However, soil half-life is the most common persistence data cited 

in published literature. If field or foliar dissipation data are not available, soil half-life data may be 

used. The average or representative half-life value of most important degradation mechanism would 

be selected for quantitative analysis for both terrestrial and aquatic environments. 

Mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic 

matter, its solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to 

soil particles, relatively insoluble in water, and not environmentally persistent would be less likely to 

move across the soil surface into surface waters or to leach through the soil profile and contaminate 

groundwater. Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water 

soluble, and are persistent in the environment would have greater potential to move from the 

application site (off-site movement). 

The degree of pesticide adsorption to soil particles and organic matter (Kerle et al. 1996) is expressed 

as the soil adsorption coefficient (Koc). The soil adsorption coefficient is measured as micrograms of 

pesticide per gram of soil (μg/g) that can range from near zero to the thousands. Pesticides with 

higher Koc values are strongly sorbed to soil and, therefore, would be less subject to movement. 

Water solubility describes the amount of pesticide that would dissolve in a known quantity of water. 

The water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water 

(mg/L or parts per million [ppm]). Pesticide with solubility <0.1 ppm are virtually insoluble in water, 

100-1,000 ppm are moderately soluble, and >10,000 ppm highly soluble (USGS 2000). As pesticide 

solubility increases, there would be greater potential for off-site movement. 

The Groundwater Ubiquity Score (GUS) is a quantitative screening tool to estimate a pesticide’s 

potential to move in the environment. It utilizes soil persistence and adsorption coefficients in the 

following formula. 

GUS = log10 (t1⁄2) x [4 - log10 (Koc)] 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-32 Appendix G. Integrated Pest Management 

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a GUS 

<0.1 would considered to have an extremely low potential to move toward groundwater. Values of 

1.0-2.0 would be low, 2.0-3.0 would be moderate, 3.0-4.0 would be high, and >4.0 would have a very 

high potential to move toward groundwater. 

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it 

is usually measured as mg/L or ppm. Solubility is useful as a comparative measure because 

pesticides with higher values are more likely to move by runoff or leaching. GUS, water solubility, 

t1⁄2, and Koc values are available for selected pesticides from the OSU Extension Pesticide Properties 

Database at http://npic.orst.edu/ppdmove.htm. Many of the values in this database were derived from 

the SCS/ARS/CES Pesticide Properties Database for Environmental Decision Making (Wauchope et 

al. 1992). 

Soil properties influence the fate of pesticides in the environment. The following six properties are 

mostly likely to affect pesticide degradation and the potential for pesticides to move off-site by 

leaching (vertical movement through the soil) or runoff (lateral movement across the soil surface). 

 Permeability is the rate of water movement vertically through the soil. It is affected by soil 

texture and structure. Coarse textured soils (e.g., high sand content) have a larger pore size 

and they are generally more permeable than fine textured soils (i.e., high clay content). The 

more permeable soils would have a greater potential for pesticides to move vertically down 

through the soil profile. Soil permeability rates (inches/hour) are usually available in county 

soil survey reports. 

 Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay 

content with smaller the pore size would lower the likelihood and rate water that would move 

through the soil profile. Clay also serves to adsorb (bind) pesticides to soil particles. Soils 

with high clay content would adsorb more pesticide than soils with relatively low clay 

content. In contrast, sandy soils with coarser texture and lower water holding capacity would 

have a greater potential for water to leach through them. 

 Soil structure describes soil aggregation. Soils with a well-developed soil structure have 

looser, more aggregated, structure that would be less likely to be compacted. Both 

characteristics would allow for less restricted flow of water through the soil profile resulting 

in greater infiltration. 

 Organic matter would be the single most important factor affecting pesticide adsorption in 

soils. Many pesticides are adsorbed to organic matter which would reduce their rate of 

downward movement through the soil profile. Also, soils high in organic matter would tend 

to hold more water, which may make less water available for leaching. 

 Soil moisture affects how fast water would move through the soil. If soils are already wet or 

saturated before rainfall or irrigation, excess moisture would run off rather than infiltrate into 

the soil profile. Soil moisture also would influence microbial and chemical activity in soil, 

which affects pesticide degradation. 

 Soil pH would influence chemical reactions that occur in the soil which in turn determines 

whether or not a pesticide would degrade, rate of degradation, and, in some instances, which 

degradation products are produced. 

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination 

would be sandy soils with low organic matter. In contrast, the least vulnerable soils would be welldrained clayey soils with high organic matter. Consequently, pesticides with the lowest potential for 

movement in conjunction with appropriate best management practices (see below) would be used in 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-33 

an IPM framework to treat pests while minimizing effects to non-target biota and protecting 

environmental quality. 

Along with soil properties, the potential for a pesticide to affect water quality through runoff and 

leaching would consider site-specific environmental and abiotic conditions including rainfall, water 

table conditions, and topography (Huddleston 1996). 

 Water is necessary to separate pesticides from soil. This can occur in two basic ways. 

Pesticides that are soluble move easily with runoff water. Pesticide-laden soil particles can be 

dislodged and transported from the application site in runoff. The concentration of pesticides 

in the surface runoff would be greatest for the first runoff event following treatment. The 

rainfall intensity and route of water infiltration into soil, to a large extent, determine pesticide 

concentrations and losses in surface runoff. The timing of the rainfall after application also 

would have an effect. Rainfall interacts with pesticides at a shallow soil depth (1⁄4 to 1⁄2 inch), 

which is called the mixing zone (Baker and Miller 1999). The pesticide/water mixture in the 

mixing zone would tend to leach down into the soil or runoff depending upon how quickly 

the soil surface becomes saturated and how rapidly water can infiltrate into the soil. Leaching 

would decrease the amount of pesticide available near the soil surface (mixing zone) to 

runoff during the initial rainfall event following application and subsequent rainfall events. 

 Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper 

slopes would have greater potential for runoff following a rainfall event. In contrast, soils that 

are relatively flat would have little potential for runoff, except during intense rainfall events. 

In addition, soils in lower areas would be more susceptible to leaching as a result of receiving 

excessive water from surrounding higher elevations. 

 Depth to groundwater would be an important factor affecting the potential for pesticides to 

leach into groundwater. If the distance from the soil surface to the top of the water table is 

shallow, pesticides would have less distance to travel to reach groundwater. Shallower water 

tables that persist for longer periods would be more likely to experience groundwater 

contamination. Soil survey reports are available for individual counties. These reports 

provide data in tabular format regarding the water table depths and the months during which 

it persists. In some situations, a hard pan exists above the water table that would prevent 

pesticide contamination from leaching. 

G.7.5 Determining Effects to Air Quality 

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the 

atmosphere. The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure 

which would be affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. 

Vapor pressure is often expressed in mm Hg. To make these numbers easier to compare, vapor 

pressure may be expressed in exponent form (I x 10-7), where I represents a vapor pressure index. In 

general, pesticides with I<10 would have a low potential to volatilize; whereas, pesticides with 

I>1,000 would have a high potential to volatilize (OSU 1996). Vapor pressure values for pesticides 

are usually available in the pesticide product MSDS or the USDA Agricultural Research Service 

(ARS) pesticide database. 

G.7.6 Preparing a Chemical Profile 

The following instructions would be used by Service personnel to complete Chemical Profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-34 Appendix G. Integrated Pest Management 

imazapic) that would be contained in one or more trade name products that are registered and labeled 

with USEPA. All information fields under each category (e.g., Toxicological Endpoints, 

Environmental Fate) would be completed for a Chemical Profile. If no information is available for a 

specific field, then “No data are available in references” would be recorded in the profile. Available 

scientific information would be used to complete Chemical Profiles. Each entry of scientific 

information would be shown with applicable references. 

Completed Chemical Profiles would provide a structured decision-making process utilizing 

quantitative assessment/screening tools with threshold values (where appropriate) that would be used 

to evaluate potential biological and other environmental effects to refuge resources. For ecological 

risk assessments presented in these profiles, the “worst-case scenario” would be evaluated to 

determine whether a pesticide could be approved for use considering the maximum single application 

rate specified on pesticide labels for habitat management and croplands/facilities maintenance 

treatments pertaining to refuges. Where the “worst-case scenario” likely would only result in minor, 

temporary, and localized effects to listed and non-listed species with appropriate BMPs (see Section 

G.5), the proposed pesticide’s use in a PUP would have a scientific basis for approval under any 

application rate specified on the label that is at or below rates evaluated in a Chemical Profile. In 

some cases, the Chemical Profile would include a lower application rate than the maximum labeled 

rate in order to protect refuge resources. As necessary, Chemical Profiles would be periodically 

updated with new scientific information or as pesticides with the same active ingredient are proposed 

for use on the Refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and 

environmental effects) would be clearly identified for specific information presented in a completed 

Chemical Profile. Comparison with these threshold values provides an explicit scientific basis to 

approve or disapprove PUPs for habitat management and cropland/facilities maintenance on refuge 

lands. In general, PUPs would be approved for pesticides with Chemical Profiles where there would 

be no exceedances of threshold values. However, BMPs are identified for some screening tools that 

would minimize/eliminate potential effects (exceedance of the threshold value) as a basis for 

approving PUPs. 

Date: Service personnel would record the date when the Chemical Profile is completed or updated. 

Chemical Profiles (e.g., currently approved pesticide use patterns) would be periodically reviewed 

and updated, as necessary. The most recent review date would be recorded on a profile to document 

when it was last updated. 

Trade Name(s): Service personnel would accurately and completely record the trade name(s) from 

the pesticide label, which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, 

I, II or 64). The suffix often distinguishes a specific product among several pesticides with the same 

active ingredient. Service personnel would record a trade name for each pesticide product with the 

same active ingredient. 

Common chemical name(s): Service personnel would record the common name(s) listed on the 

pesticide label or material safety data sheet (MSDS) for an active ingredient. The common name of a 

pesticide is listed as the active ingredient on the title page of the product label immediately following 

the trade name, and the MSDS, Section 2: Composition/Information on Ingredients. A Chemical 

Profile is completed for each active ingredient. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-35 

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one 

of the following: herbicide, desiccant, fungicide, fumigant, growth regulator, insecticide, piscicide, or 

rodenticide. 

EPA Registration Number(s): This number (EPA Reg. No.) appears on the title page of the label 

and MSDS, Section 1: Chemical Product and Company Description. It is not the EPA Establishment 

Number that is usually located near it. Service personnel would record the EPA Reg. No. for each 

trade name product with an active ingredient based upon PUPs. 

Pesticide Class: Service personnel would list the general chemical class for the pesticide (active 

ingredient). For example, malathion is an organophosphate and carbaryl is a carbamate. 

CAS (Chemical Abstract Service) Number: This number is often located in the second section 

(Composition/Information on Ingredients) of the MSDS. The MSDS table listing components usually 

contains this number immediately prior to or following the % composition. 

Other Ingredients: From the most recent MSDS for the proposed pesticide product(s), Service 

personnel would include any chemicals in the pesticide formulation not listed as an active ingredient 

that are described as toxic or hazardous, or regulated under the Superfund Amendments and 

Reauthorization Act (SARA), Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), Toxic Substances Control Act (TSCA), Occupational Safety and Health 

Administration (OSHA), State Right-to-Know, or other listed authorities. These are usually found in 

MSDS sections titled “Hazardous Identifications,” “Exposure Control/Personal Protection,” and 

“Regulatory Information.” If concentrations of other ingredients are available for any compounds 

identified as toxic or hazardous, then Service personnel would record this information in the 

Chemical Profile by trade name. MSDS(s) may be obtained from the manufacturer, manufacturer’s 

website or from an on-line database maintained by Crop Data Management Systems, Inc. (see list 

below). 

G.7.7 Toxicological Endpoints 

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds, and 

fish. Data would be recorded for species available in the scientific literature. If no data are found for 

a particular taxonomic group, then “No data are available in references” would be recorded as the 

data entry. Throughout the Chemical Profile, references (including toxicological endpoint data) 

would be cited using parentheses (#) following the recorded data. 

Mammalian LD50: For test species in the scientific literature, Service personnel would record 

available data for oral lethal dose (LD50) in mg/kg-bw (body weight) or ppm-bw. Most common test 

species in scientific literature are the rat and mouse. The lowest LD50 value found for a rat would be 

used as a toxicological endpoint for dose-based RQ calculations to assess acute risk to mammals (see 

Table 1 in Section G.7.1). 

Mammalian LC50: For test species in the scientific literature, Service personnel would record 

available data for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most 

common test species in scientific literature are the rat and mouse. The lowest LC50 value found for a 

rat would be used as a toxicological endpoint for diet-based RQ calculations to assess acute risk (see 

Table G-1 in Section G.7.1). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-36 Appendix G. Integrated Pest Management 

Mammalian Reproduction: For test species listed in the scientific literature, Service personnel 

would record the test results (e.g., Lowest Observed Effect Concentration [LOEC], Lowest Observed 

Effect Level [LOEL], No Observed Adverse Effect Level [NOAEL], No Observed Adverse Effect 

Concentration [NOAEC]) in mg/kg-bw or mg/kg-diet for reproductive test procedure(s) (e.g., 

generational studies [preferred], fertility, new born weight). Most common test species available in 

scientific literature are rats and mice. The lowest NOEC, NOAEC, NOEL, or NOAEL test results 

found for a rat would be used as a toxicological endpoint for RQ calculations to assess chronic risk 

(see Table G-1 in Section G.7.1). 

Avian LD50: For test species available in the scientific literature, Service personnel would record 

values for oral lethal dose (LD50) in mg/kg-bw or ppm-bw. Most common test species available in 

scientific literature are the bobwhite quail and mallard. The lowest LD50 value found for an avian 

species would be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk 

(see Table G-1 in Section G.7.1). 

Avian LC50: For test species available in the scientific literature, Service personnel would record 

values for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most 

common test species available in scientific literature are the bobwhite quail and mallard. The lowest 

LC50 value found for an avian species would be used as a toxicological endpoint for dietary-based 

RQ calculations to assess acute risk (see Table G-1 in Section G.7.1). 

Avian Reproduction: For test species available in the scientific literature, Service personnel would 

record test results (e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for 

reproductive test procedure(s) (e.g., early life cycle, reproductive). Most common test species 

available in scientific literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, 

NOEL, or NOAEL test results found for an avian species would be used as a toxicological endpoint 

for RQ calculations to assess chronic risk (see Table G-1 in Section G.7.1). 

Fish LC50: For test freshwater or marine species listed in the scientific literature, Service personnel 

would record a LC50 in ppm or mg/L. Most common test species available in the scientific literature 

are the bluegill, rainbow trout, and fathead minnow (marine). Test results for many game species 

may also be available. The lowest LC50 value found for a freshwater fish species would be used as a 

toxicological endpoint for RQ calculations to assess acute risk (see Table G-1 in Section G.7.1). 

Fish Early Life Stage (ELS)/Life Cycle: For test freshwater or marine species available in the 

scientific literature, Service personnel would record test results (e.g., LOEC, NOAEL, NOAEC, 

LOAEC) in ppm for test procedure(s) (e.g., early life cycle, life cycle). Most common test species 

available in the scientific literature are bluegill, rainbow trout, and fathead minnow. Test results for 

other game species may also be available. The lowest test value found for a fish species (preferably 

freshwater) would be used as a toxicological endpoint for RQ calculations to assess chronic risk (see 

Table G-1 in Section G.7.1). 

Other: For test invertebrate as well as non-vascular and vascular plant species available in the 

scientific literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, 

or EC50 (environmental concentration) values in ppm or mg/L. Most common test invertebrate 

species available in scientific literature are the honey bee and the water flea (Daphnia magna). Green 

algae (Selenastrum capricornutum) and pondweed (Lemna minor) are frequently available test 

species for aquatic non-vascular and vascular plants, respectively. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-37 

G.7.8 Ecological Incident Reports 

After a site has been treated with pesticide(s), wildlife may be exposed to these chemical(s). When 

exposure is high relative to the toxicity of the pesticides, wildlife may be killed or visibly harmed 

(incapacitated). Such events are called ecological incidents. The USEPA maintains a database 

(Ecological Incident Information System) of ecological incidents. This database stores information 

extracted from incident reports submitted by various federal and state agencies and non-government 

organizations. Information included in an incident report is date and location of the incident, type and 

magnitude of effects observed in various species, use(s) of pesticides known or suspected of 

contributing to the incident, and results of any chemical residue and cholinesterase activity analyses 

conducted during the investigation. 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded. 

G.7.9 Environmental Fate 

Water Solubility: Service personnel would record values for water solubility (Sw), which describes 

the amount of pesticide that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). 

Pesticide Sw values would be categorized as one of the following: insoluble <0.1 ppm, moderately 

soluble = 100 to 1,000 ppm, highly soluble >10,000 ppm (USGS 2000). As pesticide Sw increases, 

there would be greater potential to degrade water quality through runoff and leaching. 

Sw would be used to evaluate potential for bioaccumulation in aquatic species [see Octanol-Water 

Partition Coefficient (Kow) below]. 

Soil Mobility: Service personnel would record available values for soil adsorption coefficient (Koc

[μg/g]). It provides a measure of a chemical’s mobility and leaching potential in soil. Koc values are 

directly proportional to organic content, clay content, and surface area of the soil. Koc data for a 

pesticide may be available for a variety of soil types (e.g., clay, loam, sand). 

Koc values would be used in evaluating the potential to degrade groundwater by leaching (see 

Potential to Move to Groundwater below). 

Soil Persistence: Service personnel would record values for soil half-life (t1⁄2), which represents the 

length of time (days) required for 50% of the deposited pesticide to degrade (completely or partially) 

in the soil. Based upon the t1⁄2 value, soil persistence would be categorized as one of the following: 

non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et 

al. 1996). 

Threshold for Approving PUPs: 

If soil t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-38 Appendix G. Integrated Pest Management 

Best Management Practices (BMPs) section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil t1⁄2 values would be used in evaluating the potential to degrade groundwater by 

leaching (see Potential to Move to Groundwater below). 

Soil Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade and move from a treated site; whereas, soil t1⁄2 describes the rate for degradation 

only. As for t1⁄2, units of dissipation time are usually expressed in days. Field dissipation time would 

be the preferred data for use to estimate pesticide concentrations in the environment because it is 

based upon field studies compared to soil t1⁄2, which is derived in a laboratory. However, soil t1⁄2 is 

the most common persistence data available in the published literature. If field dissipation data are 

not available, soil half-life data would be used in a Chemical Profile. The average or representative 

half-life value of most important degradation mechanism would be selected for quantitative analysis 

for both terrestrial and aquatic environments. 

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of 

the following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days. 

Threshold for Approving PUPs: 

If soil DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil DT50 values (preferred over soil t1⁄2) would be used in evaluating the potential 

to degrade groundwater by leaching (see Potential to Move to Groundwater below), if available. 

Aquatic Persistence: Service personnel would record values for aquatic t1⁄2, which represents the 

length of time required for 50% of the deposited pesticide to degrade (completely or partially) in 

water. Based upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: 

non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et 

al. 1996). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-39 

Threshold for Approving PUPs: 

If aquatic t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Aquatic Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade or move (dissipate); whereas, aquatic t1⁄2 describes the rate for degradation only. 

As for t1⁄2, units of dissipation time are usually expressed in days. Based upon the DT50 value, 

environmental persistence in aquatic habitats also would be categorized as one of the following: nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days. 

Threshold for Approving PUPs: 

If aquatic DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface runoff and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Potential to Move to Groundwater: Groundwater Ubiquity Score (GUS) = log10(soil t 1⁄2) x [4 – 

log10(Koc)]. If a DT50 value is available, it would be used rather than a t 1⁄2 value to calculate a GUS 

score. Based upon the GUS value, the potential to move toward groundwater would be recorded as 

one of the following categories: extremely low potential<1.0, low - 1.0 to 2.0, moderate - 2.0 to 3.0, 

high - 3.0 to 4.0, or very high>4.0. 

Threshold for Approving PUPs: 

If GUS ≤4.0, then a PUP would be approved without additional BMPs to protect water quality. 

If GUS >4.0, then a PUP would only be approved with additional BMPs specifically to protect water 

quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface runoff and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-40 Appendix G. Integrated Pest Management 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Volatilization: Pesticides may volatilize (evaporate) from soil and plant surfaces and move off-target 

into the atmosphere. The potential for a pesticide to volatilize is a function of its vapor pressure that 

is affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. Vapor 

pressure is often expressed in mm Hg. To make these values easier to compare, vapor pressure would 

be recorded by Service personnel in exponential form (I x 10-7), where I represents a vapor pressure 

index. In general, pesticides with I<10 would have low potential to volatilize; whereas, pesticides 

with I >1,000 would have a high potential to volatilize (OSU 1996). Vapor pressure values for 

pesticides are usually available in the pesticide product MSDS or the USDA Agricultural Research 

Service (ARS) pesticide database (see References). 

Threshold for Approving PUPs: 

If I ≤1,000, then a PUP would be approved without additional BMPs to minimize drift and protect 

air quality. 

If I >1,000, then a PUP would only be approved with additional BMPs specifically to minimize drift 

and protect air quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to reduce volatilization and potential to drift and 

degrade air quality: 

 Do not treat when wind velocities are <2 or >10 mph with existing or potential inversion 

conditions. 

 Apply the large-diameter droplets possible for spray treatments. 

 Avoid spraying when air temperatures >85o

F. 

 Use the lowest spray height possible above target canopy. 

 Where identified on the pesticide label, soil incorporate pesticide as soon as possible during 

or after application. 

 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because 

octanol is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow

would be used to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., 

fish). If Kow >1,000 or Sw<1 mg/L and soil t1⁄2>30 days, then there would be high potential for a 

pesticide to bioaccumulate in aquatic species such as fish (USGS 2000). 

Threshold for Approving PUPs: 

If there is not a high potential for a pesticide to bioaccumulate in aquatic species, then the PUP 

would be approved. 

If there is a high potential to bioaccumulate in aquatic species (Kow>1,000 or Sw<1 mg/L and soil 

t1⁄2>30 days), then the PUP would not approved, except under unusual circumstances where 

approval would only be granted by the Washington Office. 

Bioaccumulation/Bioconcentration: The physiological process where pesticide concentrations in 

tissue would increase in biota because they are taken and stored at a faster rate than they are 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-41 

metabolized or excreted. The potential for bioaccumulation would be evaluated through 

bioaccumulation factors (BAFs) or bioconcentration factors (BCFs). Based upon BAF or BCF 

values, the potential to bioaccumulate would be recorded as one of the following: low – 0 to 300, 

moderate – 300 to 1,000, or high >1,000 (Calabrese and Baldwin 1993). 

Threshold for Approving PUPs: 

If BAF or BCF≤1,000, then a PUP would be approved without additional BMPs. 

If BAF or BCF>1,000, then a PUP would not approved, except under unusual circumstances where 

approval would only be granted by the Washington Office. 

Worst-Case Ecological Risk Assessment 

Max Application Rates (acid equivalent): Service personnel would record the highest application rate 

of an active ingredient (ae basis) for habitat management and cropland/facilities maintenance 

treatments in this data field of a Chemical Profile. These rates can be found in Table CP.1 under the 

column heading “Max Product Rate – Single Application (lbs/acre – AI on acid equiv basis)”. This 

table would be prepared for a Chemical Profile from information specified in labels for trade name 

products identified in PUPs. If these data are not available in pesticide labels, then write “NS” for 

“not specified on label” in this table. 

EECs: An estimated environmental concentration (ECC) represents potential exposure to fish and 

wildlife (birds and mammals) from using a pesticide. EECs would be derived by Service personnel 

using an USEPA screening-level approach (USEPA 2004). For each max application rate [see 

description under Max Application Rates (acid equivalent)], Service personnel would record 2 

EEC values in a Chemical Profile; these would represent the worst-case terrestrial and aquatic 

exposures for habitat management and croplands/facilities maintenance treatments. For terrestrial and 

aquatic EEC calculations, see description for data entry under Presumption of Unacceptable 

Risk/Risk Quotients, which is the next field for a Chemical Profile. 

Presumption of Unacceptable Risk/Risk Quotients: Service personnel would calculate and record 

acute and chronic risk quotients (RQs) for birds, mammals, and fish using the provided tabular 

formats for habitat management and/or cropland/facilities maintenance treatments. RQs recorded in a 

Chemical Profile would represent the worst-case assessment for ecological risk. See Section G.7.2 

for discussion regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be 

based upon selected acute and chronic toxicological endpoints for fish and the EEC would be derived 

from Urban and Cook (1986) assuming 100% overspray to an entire 1-foot deep water body using 

the max application rate (ae basis [see above]). 

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints 

for fish and an EEC would be derived from the aquatic assessment in AgDRIFT® model version 

2.01 under Tier I ground-based application with the following input variables: max application rate 

(acid basis [see above]), low boom (20 inches), fine to medium/coarse droplet size, 20 swaths, EPAdefined wetland, and 25-foot distance (buffer) from treated area to water. 

See Section G.7.2 for more details regarding the calculation of EECs for aquatic habitats for habitat 

management and cropland/facilities maintenance treatments. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-42 Appendix G. Integrated Pest Management 

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service 

personnel based upon dietary exposure, where the “short grass” food item category would represent 

the worst-case scenario. For terrestrial spray applications associated with habitat management and 

cropland/facilities maintenance treatments, exposure (EECs and RQs) would be determined using the 

Kanaga nomogram method through the USEPA’s T-REX version 1.2.3. T-REX input variables 

would include the following: max application rate (acid basis [see above]) and pesticide half-life 

(days) in soil to estimate the initial, maximum pesticide residue concentration on general food items 

for terrestrial vertebrate species in short (<20 cm tall) grass. 

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see Section G.7.2 for the procedure that would be used to 

calculate RQs. 

All calculated RQs in both tables would be compared with Levels of Concern (LOCs) established by 

USEPA (see Table G-2 in Section G.7.2). If a calculated RQ exceeds an established LOC value (in 

brackets inside the table), then there would be a potential for an acute or chronic effect (unacceptable 

risk) to federally listed (T&E) species and nonlisted species. See Section G.7.2 for detailed 

descriptions of acute and chronic RQ calculations and comparison to LOCs to assess risk. 

Threshold for approving PUPs: 

If RQs≤LOCs, then a PUP would be approved without additional BMPs. 

If RQs>LOCs, then a PUP would only be approved with additional BMPs specifically to minimize 

exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs such as the 

following would be included in the Specific Best Management Practices (BMPs) section to reduce 

potential risk to non-listed or listed species: 

 Lower application rate and/or fewer number of applications so RQs≤LOCs 

 For aquatic assessments (fish) associated with cropland/facilities maintenance, increase the 

buffer distance beyond 25 feet so RQs≤LOCs. 

Justification for Use: Service personnel would describe the reason for using the pesticide based 

control of specific pests or groups of pests. In most cases, the pesticide label would provide the 

appropriate information regarding control of pests to describe in the section. 

Specific Best Management Practices (BMPs): Service personnel would record specific BMPs 

necessary to minimize or eliminate potential effects to non-target species and/or degradation of 

environmental quality from drift, surface runoff, or leaching. These BMPs would be based upon 

scientific information documented in previous data fields of a Chemical Profile. Where necessary 

and feasible, these specific practices would be included in PUPs as a basis for approval. 

If there are no specific BMPs that are appropriate, then Service personnel would describe why the 

potential effects to refuge resources and/or degradation of environmental quality is outweighed by 

the overall resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See 

Section G.4 of this document for a complete list of BMPs associated with mixing and applying 

pesticides appropriate for all PUPs with ground-based treatments that would be additive to any 

necessary, chemical-specific BMPs. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-43 

References: Service personnel would record scientific resources used to provide data/information for 

a chemical profile. Use the number sequence to uniquely reference data in a chemical profile. 

The following on-line data resources are readily available for toxicological endpoint and 

environmental fate data for pesticides: 

1. California Product/Label Database. Department of Pesticide Regulation, California 

Environmental Protection Agency. 

(http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods) 

2. ECOTOX database. Office of Pesticide Programs, U.S. Environmental Protection Agency, 

Washington, D.C. (http://cfpub.epa.gov/ecotox/) 

3. Extension Toxicology Network (EXTOXNET) Pesticide Information Profiles. Cooperative 

effort of University of California-Davis, Oregon State University, Michigan State University, 

Cornell University and University of Idaho through Oregon State University, Corvallis, 

Oregon. (http://extoxnet.orst.edu/pips/ghindex.html) 

4. FAO specifications and evaluations for plant protection products. Pesticide Management 

Unit, Plant Protection Services, Food and Agriculture Organization, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, 

Forest Health Protection, U.S. Department of Agriculture, U.S. Forest Service. 

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land 

Management, Department of Interior; Bonneville Power Administration, U.S. Department of 

Energy; and Forest Service, U.S. Department of Agriculture. (http://infoventures.com/ehlth/pesticide/pest-fac.html) 

8. Pesticide Fact Sheets. National Pesticide Information Center. 

(http://npic.orst.edu/npicfact.htm) 

9. Pesticide Fate Database. U.S. Environmental Protection Agency, Washington, D.C. 

(http://cfpub.epa.gov/pfate/home.cfm). 

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems, 

Inc. (CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained 

by agrichemical companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-44 Appendix G. Integrated Pest Management 

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment 

Canada, Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and 

Registration Fact Sheet. U.S. Environmental Protection Agency, Washington, D.C. 

(http://www.epa.gov/pestidides/factsheets/chemical_fs.htm) 

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The 

Invasive Species Initiative. The Nature Conservancy. 

(http://tnsweeds.ucdavis.edu/handbook.html) 

16. Wildlife Contaminants Online. U.S. Geological Survey, Department of Interior, Washington, 

D.C. (http://www.pwrc.usgs.gov/contaminants-online/) 

17. One-liner database. 2000. U.S. Environmental Protection Agency, Office of Pesticide 

Programs, Washington, D.C. 

Chemical Profile 

Date: 

Trade Name(s): Common Chemical 

Name(s): 

Pesticide Type: EPA Registration 

Number: 

Pesticide Class: CAS Number: 

Other Ingredients: 

Toxicological Endpoints 

Mammalian LD50: 

Mammalian LC50: 

Mammalian 

Reproduction: 

Avian LD50: 

Avian LC50: 

Avian Reproduction: 

Fish LC50: 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-45 

Fish ELS/Life Cycle: 

Other: 

Ecological Incident Reports 

Environmental Fate 

Water solubility (Sw): 

Soil Mobility (Koc): 

Soil Persistence (t1⁄2): 

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2): 

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score): 

Volatilization (mm Hg): 

Octanol-Water Partition Coefficient 

(Kow): 

Bioaccumulation/Bioconcentration: BAF: 

BCF: 

Worst Case Ecological Risk Assessment 

Max Application 

Rate 

(ai lbs/acre – ae 

basis) 

Habitat Management: 

Croplands/Facilities Maintenance: 

EECs Terrestrial (Habitat Management): 

Terrestrial (Croplands/Facilities Maintenance): 

Aquatic (Habitat Management): 

Aquatic (Croplands/Facilities Maintenance): 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-46 Appendix G. Integrated Pest Management 

Habitat Management Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) Species Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Cropland/Facilities Maintenance Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) Species Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Justification for Use: 

Specific Best 

Management Practices 

(BMPs): 

References: 

Table CP.1 Pesticide Name 

Trade 

Namea

Treatment 

Typeb

Max Product 

Rate – 

Single 

Application 

(lbs/acre or 

gal/acre) 

Max Product 

Rate -Single 

Application 

(lbs/acre - 

AI on acid 

equiv basis) 

Max 

Number of 

Applications 

Per Season 

Max Product 

Rate Per Season 

(lbs/acre/season 

or 

gal/acre/season) 

Minimum 

Time 

Between 

Applications 

(Days) 

 

a

From each label for a pesticide identified in pesticide use proposals (PUPs), Service personnel would record 

application information associated with possible/known uses on Service lands. 

b

Treatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is labeled for both 

types of treatments (uses), then record separate data for H and CF applications. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-47 

G.8 Specific Weed Control Plans 

G.8.1 Cheatgrass, Downy brome 

Priority: Medium: cheatgrass is widely distributed throughout the Protection Island, along roadways, 

and has invaded remnant native prairie and shrubland communities. Cheatgrass is prolific in dry 

upland habitat and competes with native plant species in especially disturbed soils such as those 

found in bluff and grassland habitat, both future restoration sites. It interferes with primary habitat 

management goals across the landscape, but the infestation is too large to eradicate with available 

technology. 

Description: Cheatgrass is a cool season annual grass that grows from 4 - 30 inches tall, reproducing 

by seed. Leaf sheaths and flat blades are covered with dense soft hairs. Mature cheatgrass seed heads 

are slender; 2 - 6 inches long and usually droop to one side. It easily competes with more desirable 

perennial grasses for moisture because of its fall, winter semi-dormant, and early spring growth habit. 

Seeds mature in mid to late June and plants dry and cure by the end of June, leading to hazardous fire 

conditions. 

Current Distribution on the Refuge: Cheatgrass is widely distributed throughout Protection Island, 

portions of Graveyard Spit and unknown on other refuge islands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites and other disturbed soil areas. 

Objectives: 

a. Monitor all newly seeded areas and other disturbed sites (e.g., remediation areas, wildfire 

areas, road cuts) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control cheatgrass to reduce competition with native plants germinating in the spring. Keep 

cheatgrass to less than 40% of the live vegetation ground cover and prevent it from spreading 

beyond its original infestation area. 

d. Maintain healthy stands of native perennial plants. 

Control Options: 

The chemical treatment of cheatgrass with an appropriate herbicide provides the most effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM), Clethodim (SelectTM) and imazapic 

(PlateauTM) are the herbicides used to control cheatgrass on the Refuge. The identified chemical 

control agents were selected on their versatility and selectivity in prairie restoration areas (PlateauTM 

and SelectTM) and complete control in areas requiring devegetation with minimal risk to groundwater 

contamination (RoundupTM). Glyphosate is soil binding, inexpensive, and a low threat to 

groundwater quality. Imazapic (PlateauTM) is used in dry upland sites with low leaching potential. 

This chemical can be broadcast in restoration areas where the establishment of native grasses and 

herbicide resistant native broadleafs are essential for restoration success. Clethodim (SelectTM) is 

considered as a selective herbicide for use in grasslands, restoration areas, fence lines and rights of 

way. Other agents indicated for cheatgrass control but not selected for use are quizalofop, fluazifopp-butyl, sethoxydim, sulfometuron methyl, and metribuzin. Clethodim is considered less toxic to 

avian and other wildlife species than other selective grass herbicides (quizalofop, fluazifop-p-butyl, 

sethoxydim, and metribuzin). Clethodim has a short half-life in soil and the EPA considers the 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-48 Appendix G. Integrated Pest Management 

chemical a low threat to groundwater quality. Other chemicals would be added as needed and be 

approved at the required level. All chemicals would be used in accordance with label 

recommendations. 

Mechanical control of cheatgrass also is conducted on the Refuge with mixed results. Mowing before 

seed ripening probably prevents some re-seeding, but oftentimes the plants produce new stems and 

seeds at the mowed height. Mowing after seed ripening kills adult plants, but dropped seeds are 

already viable. Repeated mowing during the growing season may be the most effective mechanical 

treatment, but is very labor-intensive and only practical on small infestations. Mowing is not possible 

in areas where cheatgrass starts seeding at height too low for the mower, steep slopes, and 

inaccessible islands. Prescribed burns in the spring or fall also help to control cheatgrass by 

stimulating native perennial grass growth or top killing seedlings. 

The cultural methods (e.g., cover crop) after plowing, discing, etc. often compete with the initial 

flush of cheatgrass growth and can help improve the control with herbicides before seeding with 

native perennial species. After restoration, the maintenance of healthy native plant communities and 

the minimization of disturbance help to prevent the spread of cheatgrass back into the area. 

Treatment Schedule: Cheatgrass should be sprayed in the fall or early spring when plants are less 

than 10 cm tall and actively growing, and non-target plants are dormant. 

G.8.2 Carduus nutans (musk thistle) 

Priority: Medium: musk thistle has a limited distribution throughout the Refuge along roadways, 

and has invaded remnant native prairie and shrubland communities. Musk thistle is prolific in dry 

upland habitat and competes with native plant species in disturbed soils such as those found in 

recently seeded habitat restoration sites. It interferes with primary habitat management goals across 

the landscape, and the infestation is not too large therefore this species is targeted for eradicate. 

Description: Musk thistle is a biennial which grows up to 6 feet tall. Leaves are dark green, deeply 

lobed, spiny, and extend onto the stem. Flowers are 11/2 to 3 inches in diameter and are usually deep 

rose, violet or purple. Musk thistle spreads rapidly to form dense stands that crowd out desirable 

plants. 

Current Distribution on the Refuge: Musk thistle is widely distributed throughout the refuge at 

low densities but can be especially prolific in disturbed soils. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor all newly seeded areas, roadways, and other disturbed sites (e.g., remediation areas, 

wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species if ground cover is needed. 

c. Control musk thistle to reduce competition with native plants germinating in the spring. Keep 

patches of musk thistle to less than one acre in area and less than 40% of live vegetation 

cover. 

d. Maintain healthy stands of native perennial plants. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-49 

Control Options: Mechanical control of musk thistle has been successful in preventing seed 

production and subsequent spread. Musk thistle is mowed at flowering in habitat restoration sites, 

along roadways, and in disturbed areas undergoing remediation. Dense stands are often mowed twice 

when new flowers appear. Repeated mowing during the growing season may be the most effective 

mechanical treatment, but is very labor-intensive. Small infestations of musk thistle rosettes also are 

removed by hand digging when labor is available. 

 

The biological control agent, Rhinocyllus conicus (seed head weevil) is established in Washington 

state, but has had limited effect on thistle control and a negative side effect of this bio-controls that it 

also attacks native thistle species. There are no known native thistle species occurring on any refuge 

unit. The larvae of this weevil eat the seeds in mature flower heads. This bio-control is probably 

effective in reducing musk thistle seed production by up to 50% based on casual observation. 

Infestations of individual plants or widely dispersed individuals would be examined for the presence 

of the Rhinocyllus conicus larvae and adults and left in place if infected. These infected plants can be 

used as nurseries for the insects with the harvested individuals relocated to larger thistle patches. 

The chemical treatment of musk thistle with an appropriate herbicide also provides effective control. 

Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM) glyphosate 

(RoundupTM, Roundup ProTM, RodeoTM), metsulfuron methyl (EscortTM) and imazapic (PlateauTM) 

are the herbicides that could be used to control small musk thistle infestations on the Refuge. 

Aminopyralid is very selective, provides longer control and can be used at lower rates. Glyphosate is 

soil binding, inexpensive, with low groundwater contamination potential. Imazapic is used in dry 

upland sites with low leaching potential. Metsulfuron is extremely effective on thistle and common 

mullein plants. Imazapic and metsulfuron can be broadcast in restoration areas where native grasses 

and resistant native broadleafs are essential for restoration success. Other chemicals would be added 

as needed and be approved at the required level. All chemicals would be used in accordance with 

label recommendations. 

The mechanical methods of plowing, discing, etc., often cause an initial flush of musk thistle rosettes 

that may be controlled with herbicides before seeding with native perennial species. After restoration, 

the maintenance of healthy native plant communities and the minimization of disturbance help to 

prevent the spread of musk thistle back into the area. 

Treatment Schedule: Musk thistle should be repeatedly mowed at flowering to prevent seed 

production and/or sprayed in the rosette stage in fall or late spring during bolting or when desirable 

non-target plants are dormant. Spraying in the early summer when the plants have bolted or rosettes 

in the fall are also effective control methods. Other options would be used according to the label 

recommendations. 

G.8.3 Diffuse knapweed 

Priority: High: The spread of diffuse knapweed is an increasing problem in many areas in 

Washington. It is considered one of the most important rangeland weeds in North America. The State 

of Washington considers this species one of the top ten priority weeds targeted for control, 

particularly for preventing new infestations. Diffuse knapweed infests disturbed areas where it forms 

dense colonies in pastures, croplands, waste places, and rights-of-way. It is a prolific seed producer, 

fast spreading, and highly agonistic with native plants often out competing them. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-50 Appendix G. Integrated Pest Management 

Description: Diffuse knapweed grows as an annual or short-lived perennial forb. The diffusely 

branched stems of mature plants are 1 to 2 feet tall, rough to the touch, and tipped with numerous 

slender, white to purplish flower heads. Prominent yellow bracts with comb-like margin projections 

subtend the flower. The leaves are pinnately divided near the plant’s base; the leaf margins appear 

entire towards the inflorescence. Flowering occurs from July through September. 

Current Distribution on the Refuge: No known infestations are present on any refuge lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of diffuse knapweed plants - targeting for elimination - to reduce competition 

with native plants and prevent establishment of knapweed and knapweed seed bank. Map and 

measure larger infestation patches using geographic information software and a global 

positioning system device. Treat patches to prevent increase in the infestation area. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Hand pulling or digging is a feasible control of small infestations and individual 

plants. The taproot would be removed to at least 2 inches below the ground surface. 

Insect species that target diffuse knapweed include the seedhead weevils (Larinus minutus), broadnosed seedhead weevil (Bangasternus fausti) are not well established, and seed head fly (Urophora 

affinis), seed head fly (Urophora quadrifasciata), and root boring/gall beetle (Sphenoptera 

jugoslavica) are available for mass collections. These insects reduce seed production which assists in 

slowing or eliminating spread. Biological agents would be an option in areas that are prohibited to 

other forms of control and pending the availability of the insect. Biological control of diffuse 

knapweed on the Refuge has not been attempted in the past. 

The chemical treatment of diffuse knapweed with an appropriate herbicide provides relatively 

effective control. Currently, aminopyralid (Milestone) glyphosate (RoundupTM, Roundup ProTM) and 

imazapic (PlateauTM) would be the herbicides used to control diffuse knapweed on the Refuge. 

Aminopyralid is very selective, provides longer control and can be used at lower rates. Glyphosate is 

soil binding, inexpensive, and a low threat to groundwater quality. Imazapic (PlateauTM) is used in 

dry upland sites and on soils with low leaching potential. This chemical can be broadcast in 

restoration areas where the establishment of native grasses and herbicide resistant native broadleafs 

are essential for restoration success. Other recommended chemical treatments for diffuse knapweed 

are picloram, clopyralid, dicamba, and 2,4-D. The Refuge avoids the use of restricted use pesticides 

like picloram. Clopyralid is not recommended for use on permeable soils due to potential 

groundwater contamination. Dicamba has low toxicity for wildlife but is not recommended for use 

near water. Aquatic formulations of glyphosate currently serve for weed control near water. Other 

chemicals would be added as needed and be approved at the required level. All chemicals would be 

used in accordance with label recommendations. 

Treatment Schedule: Hand removal would be conducted 2 to 3 times during the growing season, 

the first removal occurring early in the season (June) before bolt. Established areas too large to 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-51 

practically control by hand, or in areas prohibited to chemical control, would be mowed monthly to 

prevent floret emergence and seed production. 

The release of seed head weevils will occur as the leaves of the plants appear in June to the budding 

stage. Control is less effective if seeds have already formed. 

The application of aminopyralid, glyphosate or imazapic would occur once during the growing 

season (June - November). The most effective time of control is during the rosette or bolt stage 

before budding. Annual treatment is necessary as long as there is a viable seed source. 

G.8.4 Spotted knapweed 

Priority: High: The State of Washington considers this species one of the top ten priority weeds 

targeted for control. Spotted knapweed infests disturbed areas where it forms dense colonies in 

pastures, croplands, waste places, and rights-of-way. It is a prolific seed producer, fast spreading, and 

highly agonistic with native plants – often out-competing them. Populations enlarge by peripheral 

expansion of existing stands. Biodiversity, livestock and wildlife forage quality are reduced with 

infestations of spotted knapweed. 

Description: Spotted knapweed is a biennial or short-lived perennial forb with a deep taproot. Plants 

reach 1 to 3 feet with one or more branched stems. The basal leaves vary in morphology from entire 

to pinnate and elliptical to oblanceolate. The principal stem leaves are pinnately divided. Flowers are 

primarily light purple (rarely white). Involucral bracts are stiff with a finely branched, dark tip. 

Flowering occurs from June through September. 

Current Distribution on the Refuge: No known infestations are present on any refuge lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., restoration areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of spotted knapweed plants - targeting for elimination - to reduce 

competition with native plants and prevent establishment of knapweed and knapweed seed 

bank. Map and measure larger infestation patches using geographic information software and 

a global positioning system device. Treat patches to prevent increase in the infestation area. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Hand pulling or digging is a feasible control of small infestations and individual 

plants. The taproot would be removed to at least 2 inches below the ground surface. Entire plants 

would be removed from the site to limit the source of available seeds. 

Biological control of spotted knapweed is not effective in eliminating stands. Insect larvae are 

available that target flowers, roots, shoots, and leaves leading to reduced seed production. Two 

commonly used organisms that target spotted knapweed roots are the sulfur knapweed moth 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-52 Appendix G. Integrated Pest Management 

(Agapeta zoegana) and the knapweed weevil (Cyphocleonus achates). Biological control could be 

used in new and current infestations that cannot be controlled by hand or chemical treatment. 

The chemical treatment of spotted knapweed with an appropriate herbicide provides relatively 

effective control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM) and 

imazapic (PlateauTM) would be the herbicides used to control spotted knapweed on the Refuge. 

Aminopyralid is very selective, provides longer control and can be used at lower rates. Other 

recommended chemical treatments for diffuse knapweed are picloram, clopyralid, dicamba, and 2,4-

D. The Refuge avoids the use of restricted use pesticides like picloram. Clopyralid is not 

recommended for use on permeable soils due to potential groundwater contamination. Dicamba has 

low toxicity for wildlife but is not recommended for use near water. Aquatic formulations of 

glyphosate currently serve for weed control near water. Other chemicals would be added as needed 

and be approved at the required level. All chemicals would be used in accordance with label 

recommendations. 

Treatment Schedule: Hand removal would be conducted 2 to 3 times during the growing season, 

the first removal occurring early in the season (June) before bolt. Established areas too large to 

practically control by hand, or in areas prohibited to chemical control, would be mowed monthly to 

prevent floret emergence and seed production. 

Selected biological control insect(s) would be, if used, released during the optimal time for both 

insect and plant to provide the greatest effectiveness for controlling spotted knapweed. 

Aminoryralid, glyphosate, or imazapic would be applied once during the growing season (June - 

November). The most effective time of control is during the bolt to bud stage. Annual treatment is 

necessary as long as there is a viable seed source. 

 

G.8.5 Meadow Knapweed 

Priority: High: The State of Washington considers this species one of the top ten priority weeds 

targeted for control. Meadow knapweed invades open, disturbed areas. This species forms monotypic 

stands, suppressing the growth of other vegetation. Reproduction is primarily from seeds and crown. 

Description: Meadow knapweed is a perennial growing from a woody root crown, with 20 to 40 

inch tall upright stems. Its basal leaves can be up to six inches long and 1.25 inches wide, tapering at 

both ends. The stem leaves are lance-shaped, stalkless, and sometimes shallowly lobed, while the 

uppermost leaves are smaller and not lobed. The rose-purple to occasionally white flowers occur in 

solitary, oval, or almost globe-shaped flower heads at the ends of branches. The light to dark brown 

involucral bracts are roundish, with a torn, thin, papery margin, or a comb-like, fringed margin. More 

apparent on outer bracts, the fringes are about equal in width to the central body of the bract. 

Meadow knapweed flowers from July to September, producing ivory-white to light brown seeds that 

may or may not have a barely noticeable plume. However, because it is a hybrid, meadow knapweed 

traits are highly variable. 

Current Distribution on the Refuge: No known infestations are present on any refuge lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-53 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of Meadow knapweed plants - targeting for elimination - to reduce 

competition with native plants and prevent establishment of knapweed and knapweed 

seedbank. Map and measure larger infestation patches using geographic information software 

and a global positioning system device. Treat patches to prevent increase in the infestation 

area. 

d. Maintain healthy stands of native perennial plants 

Control Options: 

Removal of the above-ground tissue by mowing or hand-scything weakens the plant, reduces root 

growth, and prevents seed production, but would not eliminate the infestation. 

Biological control with the seed head gall fly, Urophora quadrifasciata, has had fair success on 

meadow knapweed. 

The reseeding of disturbed areas is effective in preventing the infestation of meadow knapweed. The 

chemical treatment of Meadow knapweed with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM) and imazapic 

(PlateauTM) would be the herbicides used to control Meadow knapweed on the Refuge. Aminopyralid 

is very selective, provides longer control and can be used at lower rates. Glyphosate is soil binding, 

inexpensive, with low groundwater contamination potential. Glyphosate is a nonspecific herbicide 

and the use of it should be accompanied by seeding, planting, or use in areas where native vegetation 

is prolific. Imazapic (PlateauTM) is used in dry upland sites and on soils with low leaching potential. 

This chemical can be broadcast in restoration areas where the establishment of native grasses and 

herbicide resistant native broadleafs are essential for restoration success. Other chemicals would be 

added as needed and be approved at the required level. All chemicals would be used in accordance 

with label recommendations. 

Treatment Schedule: Top growth would be removed before bolting during the growing season 

(June - mid-August) to weaken Russian knapweed plants. Plants that re-emerge (mid-August to 

September) are smaller and more vulnerable to further top removal and herbicide effect. 

Glyphosate would be applied once or twice during the growing season (June - November). Topgrowth of Russian knapweed can be controlled by applying herbicide during the bud stage. Root 

control is achieved by timing applications to the late bud and fall growth stage. Other listed chemical 

would be used according to the label recommendations. 

G.8.6 Bohemian knotweed 

Priority: High: The State of Washington considers this species one of the top ten priority weeds 

targeted for control. The most common invasive knotweeds in western Washington, this species is a 

hybrid between giant and Japanese knotweed and shares characters of both parent species. It was 

introduced as an ornamental in its own right but has become very widespread in our region, 

especially along rivers and roadways. This plant spreads mostly by stem and root fragments and is 

usually found in disturbed areas such as flood zones and roadsides. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-54 Appendix G. Integrated Pest Management 

Currently, most Bohemian knotweed plants are males and therefore lack seeds. Recent findings have 

found that seed-bearing hybrids have appeared, probably indicating a back-cross with giant or 

Japanese knotweed. The existence of seeding hybrids may allow this plant to spread even more 

rapidly in the future. 

Description: Plants are usually 6.5 to 10 feet tall. Stems are stout, cane-like, hollow between the 

nodes, somewhat reddish-brown and usually branched. The plants die back above ground at the end 

of the growing season. However, the dead reddish brown canes often persist throughout the winter. 

The stem nodes are swollen and surrounded by thin papery sheaths. Leaves can be either spade or 

heart-shaped, usually more heart-shaped lower down on the stems and more spade-shaped near the 

branch ends. This variability in leaf shape is one identifying character since the parent species 

generally have either heart-shaped or spade-shaped leaves. 

One key identifying feature is the hairs on the leaf undersides especially along the midvein. 

Bohemian knotweed has hairs that are short and broad-based (triangular-shaped), compared with 

long and wavy in giant knotweed and reduced to barely noticeable bumps in Japanese knotweed. 

The flowers are small, creamy white to greenish white, and grow in showy plume-like, branched 

clusters from leaf axils near the ends of the stems. Flower clusters are generally about the same 

length as the subtending leaf, unlike the shorter flower clusters found on giant knotweed and the 

longer clusters found on Japanese knotweed. Leaf and flower characters are most reliable when 

looking near the middle of a branch. The fruit is 3-sided, black and shiny. 

Current Distribution on the Refuge: Only known infestations are on the Dawley Unit. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of Bohemian knotweed plants - targeting for elimination - to reduce 

competition with native plants and prevent establishment of knotweed and knotweed 

seedbank. Map and measure larger infestation patches using geographic information software 

and a global positioning system device. Treat patches to prevent increase in the infestation 

area. 

d. Maintain healthy stands of native perennial plants 

Control Options: 

Knotweed is very difficult to eradicate once it has become established. It is, therefore, important to 

prevent new infestations and eradicate small patches before they spread. Mechanical and chemical 

control methods can be used on knotweed, often in conjunction with each other. If control is to be 

effective, the sites must be visited throughout several seasons to further control any new growth. 

Removal of the above-ground tissue by mowing or hand-scything weakens the plant, but because of 

the extensive root system this method is ineffective as a control method especially on larger 

infestation. 

The chemical treatment of Bohemian knotweed by injection with an appropriate herbicide provides 

relatively effective control. Currently, imazapyr (Arsenal), and glyphosate (RoundupTM, Roundup 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-55 

ProTM) would be the herbicides used to control Bohemian knotweed on the Refuge. Imazapyr is 

similar to glyphosate, has a very low toxicity to most animals, but does remain in the soil longer than 

glyphosate. Mixing two kinds of herbicides together often improves the effectiveness when 

compared with using each herbicide individually. By mixing the glyphosate and imazapyr together, 

we can reduce the total amount of herbicide used. Glyphosate is soil binding, inexpensive, with low 

groundwater contamination potential. Glyphosate is a nonspecific herbicide and the use of it should 

be accompanied by seeding, planting, or use in areas where native vegetation is lacking. Other 

chemicals would be added as needed and be approved at the required level. All chemicals would be 

used in accordance with label recommendations. 

Treatment Schedule: Injection of the herbicide is best done at the end of summer August/September 

during flowering but prior to seed set. 

G.8.7 Canada thistle 

Priority: Low to Medium: The priority for controlling this species is dependent upon location. The 

State of Washington considers this species widespread and detrimental to agriculture. Canada thistle 

can form monocultures, crowding out desirable species. Extensive horizontal roots give rise to 

shoots. This species infests roadsides, pastures, cropland, disturbed areas, and riparian areas. The 

dense growth pattern and spiny leaves of Canada thistle deters passage and consumption by wildlife. 

Description: Canada thistle is a colony-forming perennial forb. Stems reach 1 to 4 feet with 

branching tops. Flowers are purple with spineless bracts. The leaves are irregularly lobed and tipped 

with tiny spines. Flowering occurs July through August. 

Current Distribution on the Refuge: Canada thistle is widely distributed on the Protection Island, 

Dawley Unit, and patchy on Dungeness found in various soil types and vegetation communities. This 

species tends to invade re-seeded restoration areas. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Canada thistle control applied to keep infestations to less than 1 acre in area and weedy 

species comprising 40% or less of live vegetation cover. 

d. Maintain healthy stands of native perennial plants. 

Control Options: The nature of the Canada thistle infestations on the Refuge makes it impossible to 

control with simple hand methods. The removal of shoots by mowing is a viable option. The 

continued removal of above ground photosynthetic tissue has been shown to weaken plants and limit 

their spread through carbohydrate starvation. 

Biological control offers many insects and a few nematodes, and the American Goldfinch has been 

reported to feed on various parts of Canada thistle. Most of these do very little damage. Three insects 

from Europe have been studied for biological control: Altica carduorum Guer (flea beetle), a leaf 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-56 Appendix G. Integrated Pest Management 

feeder, has not established itself well. Adults of the beetle Ceutorhynchus litura F. eat young thistle 

shoots, but do little damage. The fly, Urophora cardui L. is the most promising biological control 

agent. Eggs are laid in the terminal buds and galls develop which divert nutrients and stress the plant. 

Many microorganisms have been found associated with Canada thistle, but no potential biocontrol 

agents are known. 

The chemical treatment of Canada thistle with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM, Rodeo®) and 

imazapic (Plateau ®) are the herbicides used to control Canada thistle on the Refuge. Aminopyralid 

is very selective, provides longer control, can be used at lower rates, and be applied near water. 

Glyphosate is soil binding, inexpensive, with low groundwater contamination potential. Glyphosate 

is a nonspecific herbicide and the use of it should be accompanied by seeding, planting, or use in 

areas where native vegetation is prolific. Imazapic (PlateauTM) is used in dry upland sites and on soils 

with low leaching potential. This chemical can be broadcast in restoration areas where the 

establishment of native grasses and herbicide resistant native broadleafs are essential for restoration 

success. Other herbicides that are shown to be effective on Canada thistle are picloram, clopyralid, 

and 2,4-D. The Refuge avoids the use of restricted use pesticides like picloram. Clopyralid is not 

recommended for use on leachable soils. 2,4-D would be used on the Refuge with its effectiveness 

monitored and the use expanded to possibly replace imazapic in some capacities. As with all 

herbicides, 2,4-D has been detected in groundwater although the sources of contamination are 

associated with inappropriate use and spillage. Other chemicals would be added as needed and be 

approved at the required level. All chemicals would be used in accordance with label 

recommendations. 

Treatment Schedule: Hand pulling or digging of plants in the rosette stage is effective for small 

infestations. Monthly mowing or scything of bolted plants in moist soil areas or areas with a high 

water table (riparian/wetlands) are effective in limiting spread. 

The stem-and-shoot gadfly would be released in June through July for new and existing invaded 

wetland areas where chemical and mechanical controls are not feasible. 

Chemical control would occur in spring and fall, 1-2 times per season (June-October), particularly in 

the fall when shoot to root translocation is highest. This species is sensitive to moisture content or 

drought stress. Application of pesticide should occur when moisture condition is higher. 

G.8.8 Bull thistle 

Priority: Low to Medium: The priority for controlling this species is dependent upon location. Bull 

thistle grows in moist to dry areas, particularly in loamy or clay soils. It is a rapidly proliferating 

transient species in disturbed, open sites. Native vegetation and wildlife habitat value are 

compromised by infestation. 

Description: Bull thistle is a biennial forb with a rosette forming the first year. A short tap root 

supports a 2 to 5 foot many-branched stem during the second year. The leaves are pinnately lobed, 

prickly, with a cottony underside. The involucre of the light purple flower is covered with long 

spines. Flowering occurs from July through September. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-57 

Current Distribution on the Refuge: Bull thistle has not produced major infestations on the 

Refuge. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control Bull thistle to reduce competition with native plants by preventing seed production 

and keeping infestations to less than 1 acre and less than 40% of live vegetation cover. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Small stands of Bull thistle would be mowed, scythed, or hand cut to remove the 

bolted but not flowered stem. Hand cutting would include removing the stem and root crown. 

The bull thistle seed head gall fly (Urophora stylata) is effective in reducing stand density. Control 

of seed production is effective where the population of gall flies is high. This control method is not 

recommended for small infestations. 

The chemical treatment of Bull thistle with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM, RodeoTM) 

and imazapic (PlateauTM) are the herbicides used to control Bull thistle on the Refuge. Aminopyralid 

is very selective, provides longer control, can be used at lower rates. Glyphosate is soil binding, 

inexpensive, and a low threat to groundwater quality. Imazapic (PlateauTM) is used in dry upland sites 

and on soils with low leaching potential. This chemical can be broadcast in restoration areas where 

the establishment of native grasses and herbicide resistant native broadleafs are essential for 

restoration success. Other chemicals would be added as needed and be approved at the required level. 

All chemicals would be used in accordance with label recommendations. 

Treatment Schedule: Mechanical and hand removal would occur during bolt but before flowering 

(late June - July). Late bolting plants need removal before flowering to prevent seed formation. 

Herbicides would be applied 1 -2 times during the growing season (April - November). Application 

would occur during the rosette stage or after mowing or scything. 

G.8.9 Field bindweed 

Priority: Low to Medium: Field bindweed is highly competitive species with prodigious powers of 

regeneration from roots and rhizomes. Bindweed can survive a wide range of environmental 

conditions, but disturbed soil is a necessity for invasion. Bindweed is a threat to the regeneration of 

native vegetation. 

Description: Field bindweed is perennial forb growing as a climbing and prostrate vine that forms 

dense mats. The taproot is deep, forming an extensive root system. The leaves are sagittate; flowers 

are bell-shaped and pink to white. Blooming occurs from June until frost. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-58 Appendix G. Integrated Pest Management 

Current Distribution on the Refuge: Bindweed is widely spread on Protection Island and unknown 

in other areas of the Refuge. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Control field bindweed to reduce competition with native plants by keeping any infestation at 

less than 40% of live vegetation cover. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Mechanical and hand methods of control are impractical and ineffective due to the 

species’ distribution and ability to regenerate from severed roots and rhizomes. 

The chemical treatment of field bindweed with an appropriate herbicide provides relatively effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM) and imazapic (PlateauTM) are the 

herbicides used to control field bindweed on the Refuge. Glyphosate is soil binding, inexpensive, and 

a low threat to groundwater quality. Imazapic (PlateauTM) is used in dry upland sites and on soils 

with low leaching potential. This chemical can be broadcast in restoration areas where the 

establishment of native grasses and herbicide resistant native broadleafs are essential for restoration 

success. Other herbicides indicated for field bindweed control are picloram, dicamba, and 2,4-D. The 

uses of restricted use pesticides like picloram are avoided at the Refuge. Dicamba has low wildlife 

toxicity but is not for use near water. Aquatic formulations of glyphosate and 2,4-D fill that niche. 

2,4-D would be used at the Refuge. Its effectiveness would be monitored and the herbicide would be 

considered as a replacement for imazapic in some situations. As with all herbicides, 2,4-D has been 

detected in groundwater although the sources of contamination are associated with inappropriate use 

and spillage. Other chemicals would be added as needed and be approved at the required level. All 

chemicals would be used in accordance with label recommendations. 

The field bindweed moth and the field bindweed mite have not been used to control field bindweed at 

the Refuge. These agents have not established well in the Pacific Northwest. 

Treatment Schedule: Herbicides would be applied one to two times during the growing season 

(June - November). The period of highest chemical effectiveness is in the early flowering stage. 

Invaded sites would be monitored to determine the local variation in conditions that lead to the 

plants’ flowering time. Multiple year applications may be necessary. 

The field bindweed moth and field bindweed mite would be released to heavily infested bindweed 

sites during the early growing season (June through August). The release of bioagents would be 

dependent on the insects’ availability. 

G.8.10 St. Johnswort 

Priority: Low to medium: St. Johnswort invades disturbed sites along roadsides, over-grazed 

pastures and range, and waste places. It prefers dry, sandy to gravelly soil. St. Johnswort forms a 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-59 

deep, laterally spreading root system that forms new plants vegetatively from root buds. Dense 

growth of these plants inhibits regeneration of native species. 

Description: St. Johnswort is a perennial shrub-like forb. The stems produce numerous branches and 

reach 1 to 3 feet high. Leaves are up to one inch long, opposite, entire, and contain numerous 

transparent dots. Flowers are yellow arranged in open, flat-topped cymes. 

Current Distribution on the Refuge: St. Johnswort has not been identified on any of the refuge 

lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of St. Johnswort plants - targeting for elimination - to reduce competition with 

native plants and stop the spread of infestations. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Small infestations of new plants can be pulled by hand or dug out. 

Glyphosate (Roundup® and Roundup Pro®) is effective in controlling St. Johnswort. Glyphosate is 

soil binding, inexpensive, and a low threat to groundwater quality. Other herbicides indicated for 

effective St. Johnswort control are picloram and 2,4-D. The use of restricted use pesticides such as 

picloram is avoided on the Refuge. 2,4-D is planned for use on the Refuge to control various 

broadleaf noxious weeds and its use for St Johnswort control could be considered in the future. As 

with all herbicides, 2,4-D has been detected in groundwater although the sources of contamination 

are associated with inappropriate use and spillage. Other chemicals would be added as needed and be 

approved at the required level. All chemicals would be used in accordance with label 

recommendations. 

Biological control of St. Johnswort with the Klamath weed beetle (Chrysolina quadrigemina) has 

been very effective in North America. Two foliage beetles, Chrysolina hyperici and C. quadrigemina

were released in California from 1945 to 1946, and established within two years. A root-boring 

beetle Agrilus hyperici and a leaf bud gall-forming midge Zeuxidiplosis giardi were released in 1950 

to help the Chrysolina spp. Recently released in the state and established is the moth Aplocera 

plagiata. Due to the success of these beetles in controlling St. Johnswort, their continued use for 

established and new infestations is the preferred method of control. 

Treatment Schedule: Removal and disposal of plants would be done in early spring (before flower 

formation). 

Spot spraying with glyphosate (Roundup® and Roundup Pro®) before flowering can be an effective 

control method if repeated applications are made. Bolting and flowering occur early and continue 

through late summer (June - September). Patches need to be monitored for newly sprouted plants 

throughout the summer. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-60 Appendix G. Integrated Pest Management 

The release of Klamath weed beetles would be made in July to new or non-beetle infested areas. 

Beetles (if available) established in an area on the Refuge would be harvested and used as colonizers. 

G.8.11 Dalmatian toadflax 

Priority: High: Dalmation toadflax is an aggressive, colony-forming invasive. This species is 

opportunistic in invading disturbed sites, but it can also press into established vegetation 

communities in good condition. Native communities and restored sites may be jeopardized by the 

creeping expansion of Dalmation toadflax adventitious root buds. Competition between natives and 

toadflax may make the community more vulnerable to other invasive species. Dalmation toadflax 

produces a toxic substance and is unpalatable to livestock and wildlife. 

Description: Dalmation toadflax is a perennial forb reaching up to 3 feet in height. Reproduction is 

by seed and underground root stalks. Leaves are alternate and variable in shape - ovate to lanceolate. 

Leaves and stems are robust, glaborous with whitish or bluish cast. Flowers grow at the axils of the 

upper leaves. The spurred-flower is yellow with an orange center. Flowers bloom late June through 

October. 

Current Distribution on the Refuge: Currently, no islands are known to have any infestation, but 

Dungeness Spit has a small patch located on Graveyard Spit. That site has been treated for several 

years by hand-pulling. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of Dalmation toadflax plants - targeting for elimination - to reduce competition 

with native plants. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Hand pulling individual plants before seed set decreases seed production. Scything 

or mowing of stands before seed set is also effective. These methods do not kill the plant, but over 

time with repeated pulling, the population would be reduced. 

The chemical treatment of Dalmation toadflax with an appropriate herbicide provides relatively 

effective control. Currently, glyphosate (RoundupTM, Roundup ProTM) and imazapic (PlateauTM) are 

the herbicides used to control Dalmation toadflax on the Refuge. Glyphosate is soil binding, 

inexpensive, and a low threat to groundwater quality. Glyphosate is appropriate for spot treatments, 

but its broad specificity precludes broadcast applications. Imazapic (PlateauTM) is used in dry upland 

sites and on soils with low leaching potential. This chemical can be broadcast in restoration areas 

where the establishment of native grasses and herbicide resistant native broadleafs are essential for 

restoration success. Other chemicals would be added as needed and be approved at the required level. 

All chemicals would be used in accordance with label recommendations. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-61 

Biological control using a defoliating moth is well-established in Washington and reportedly 

provides good control. 

Treatment Schedule: The removal of above ground portions of the plant before seed set would be 

done in April through July. The seeds are long-lived; annual removal of plants for up to ten years is 

necessary to deplete the seed bank. 

Applications of glyphosate and imazapic would be made one to two times per growing season (AprilNovember). Fall applications are particularly effective in decreasing the available stored 

carbohydrates in the roots. 

G.8.12 Yellow toadflax 

Priority: High: Yellow toadflax is an aggressive, colony-forming invasive. This species is 

opportunistic in invading disturbed sites, but it can also press into established vegetation 

communities in good condition. Native communities and restored sites may be jeopardized by the 

creeping expansion of yellow toadflax adventitious root buds. Competition between natives and 

toadflax may make the community more vulnerable to other invasive species. Yellow toadflax 

produces a toxic substance and is unpalatable to livestock and wildlife. 

Description: Yellow toadflax is a perennial forb, 1 to 2 feet, with pale green, alternate, linear leaves. 

The base of the branched stem is woody. Stems and leaves are pale green. Flowers are spurred and 

yellow with an orange center. 

Current Distribution on the Refuge: No known infestations exist on refuge lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of yellow toadflax plants - targeting for elimination - to reduce competition with 

native plants. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Hand pulling individual plants before seed set decreases seed production. Scything 

or mowing of stands before seed set is also effective. These methods do not kill the plant. 

The chemical treatment of yellow toadflax with an appropriate herbicide provides relatively effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM) and imazapic (PlateauTM) are the 

herbicides used to control yellow toadflax on the Refuge. Glyphosate is soil binding, inexpensive, 

and a low threat to groundwater quality. Glyphosate is appropriate for spot treatments, but its broad 

specificity precludes broadcast applications. Imazapic (PlateauTM) is used in dry upland sites and on 

soils with low leaching potential. This chemical can be broadcast in restoration areas where the 

establishment of native grasses and herbicide resistant native broadleafs are essential for restoration 

success. Other chemicals would be added as needed and be approved at the required level. All 

chemicals would be used in accordance with label recommendations. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-62 Appendix G. Integrated Pest Management 

Treatment Schedule: The removal of above ground portions of the plant before seed set would be 

done in April through July. The seeds are long-lived; annual removal of plants for up to ten years is 

necessary to deplete the seed bank. 

Applications of glyphosate and imazapic would be made one to two times per growing season (April 

- November). Fall applications are particularly effective in decreasing the available stored 

carbohydrates in the roots. 

G.8.13 Scotch thistle 

Priority: Low to Medium: Scotch thistle aggressively invades disturbed and moist areas. This thistle, 

due to its size and spinous leaves, presents a passage barrier. Infestation decreases the value and area 

of wildlife habitat. Scotch thistle seeds have a water-soluble germination inhibitor that facilitates its 

own propagation and expansion along irrigation canals and other wet areas. Scotch thistle reproduces 

by seed. 

Description: Scotch thistle is biennial forb that grows to 12 feet high. Leaves are large, green, and 

spiny. Fine hairs give the leaves a cottony appearance. First-year rosettes are 10 to 12 inches in 

diameter. Leaves of the mature plant may be two feet in length with a prominent white mid-rib. 

Flower heads are numerous and terminal. Flowers are 1 to 2 inches in diameter, pale purple to red in 

color. 

Current Distribution on the Refuge: No known infestations exist on refuge lands. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, other disturbed soil areas, and riparian and other moist areas. 

Objectives: 

a. Monitor known infestation sites, riparian and moist areas, newly seeded areas, roadways, and 

other disturbed sites (e.g., remediation areas, wildfire areas) depleted of native perennial 

plants. 

b. Seed disturbed sites with native species. 

c. Control Scotch thistle to reduce competition with native plants by keeping infestations to less 

than 1 acre and less than 40% of live vegetation cover. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Mechanical treatment would include hand pulling or cutting of individual plants 

and small stands. The taproot would be cut 1-2 inches below the ground surface. Scything and 

mowing would be options for larger stands. The removal of the top material before flower production 

decreases the number of seeds available for spreading and propagation. Preventing flowering by 

mechanical means in conjunction with herbicide application for root killing is most effective in 

eliminating and controlling Scotch thistle. 

The chemical treatment of Scotch thistle with an appropriate herbicide provides relatively effective 

control. Currently, aminopyralid (Milestone), glyphosate (RoundupTM, Roundup ProTM), imazapic 

(PlateauTM), and metsulfuron methyl (Escort®) are the herbicides used to control Scotch thistle on 

the Refuge. Aminopyralid is very selective, provides longer control and can be used at lower rates. 

Glyphosate is soil binding, inexpensive, and a low threat to groundwater quality. Glyphosate is 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-63 

appropriate for spot treatments, but its broad specificity precludes broadcast applications. Imazapic 

(PlateauTM) is used in dry upland sites and on soils with low leaching potential. This chemical can be 

broadcast in restoration areas where the establishment of native grasses and herbicide resistant native 

broadleafs are essential for restoration success. Metsulfuron methyl is very effective for thistle and 

mullein control and is the preferred treatment in restoration areas with a high infestation level. Other 

chemicals would be added as needed and be approved at the required level. All chemicals would be 

used in accordance with label recommendations. 

Treatment Schedule: Mechanical treatment would target plants before flowering (April to midJune). 

Herbicides would be applied before bolting in the spring (April to June), possibly in conjunction with 

mechanical control, or to rosettes in fall (September -November). 

G.8.14 Common cordgrass 

Priority: High: The State of Washington considers this species one of the top ten priority weeds 

targeted for control, particularly for preventing new infestations. Cordgrass is an aggressive species 

that regenerates from large rootstocks. Excessive proliferation of cordgrass can lower the 

groundwater level, reduce the amount of surface water, reduce habitat for wildlife dependent on open 

water, reduce bird use by as much as 50%, reduce and interfere with water flow through drainages. 

Description: Cordgrass is a perennial grass with stems reaching 7 feet. The stems have a waxy 

coating. Leaves are flat, 1/4 to 3/4 inch wide. The leaves lack auricles and have ligules that consist of 

a fringe of hairs. The leaf blades, which may be flat or inrolled, are 5 to 12 mm broad and may be 

persistent or falling. The flowers occur in numerous, erect, contracted panicles, which consist of 

closely overlapping spikelets in two rows on one side of the rachis. Reproduction is by seed, 

rhizomes, tillering, and rhizome fragments. The panicle is 3 to 8 inches long, initially compact but 

opening upon maturity. 

Current Distribution on the Refuge: The only known infestation of common cordgrass is on 

Graveyard Spit on Dungeness NWR. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants and 

established native communities in disturbed moist soil, riparian, and wetland environments. 

Objectives: 

a. Monitor known infestation sites - riparian, wetland, and moist areas for significant adverse 

effects on water flow and wildlife habitat. 

b. Seed disturbed sites with native species. 

c. Control common cordgrass to reduce competition with native plants and significantly altering 

the environment. Treatment applied to keep infestation to less than 40% of live vegetation 

cover and prevent infestations from increasing in area. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Mowing infestations can contain growth, limit seed set, and eventually kill the 

plants. To be effective, clones must be mowed repeatedly, beginning with initial spring green-up and 

continued until fall die-back. For clones under 10 feet in diameter, one to three mowings during the 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-64 Appendix G. Integrated Pest Management 

growing season may be effective. Larger clones need to be mowed nine to ten times over two seasons 

for eradication. In some cases, mowing would be required for a third or fourth year (Spartina Task 

Force 1994). 

Chemical control with glyphosate (Rodeo®) would be used on the Refuge for effective control of 

common cordgrass. Glyphosate is soil binding, inexpensive, a low threat to groundwater quality, and 

used to target numerous weed species. This chemical formulation is approved for aquatic application. 

All chemicals would be used in accordance with label recommendations. 

Treatment Schedule: Data from herbicide trials in Willapa Bay suggest chemical control is best 

performed when the plants carbohydrate stores are lowest. Treatment would be conducted 1 to 2 

times per season - once in the summer (June - August) and/or once in the spring (May) (Norman and 

Patten 1995). 

G.8.15 Himalayan blackberry and Evergreen blackberry 

Priority: High: Although widespread in Washington and control in not required, these species are 

highly invasive and difficult to control. Therefore it is important to protect wilderness areas as well 

as areas being restored to native vegetation. 

Description: A robust, thicket forming shrub with stout arching canes with large stiff thorns. They 

can grow up to 15 feet tall; canes to 40 feet long. They bloom in the spring and the flowers are small, 

white to pinkish with five petals and Himalayan blackberry leaves are palmately compound with 

large, rounded to oblong, toothed leaflets usually in groups of 5 on main stems, while Evergreen 

blackberry (also known as cut-leaf blackberry) has deeply incised leaflets. They can be distinguished 

from the native trailing blackberry (Rubus ursinus) by its tall, arching reddish-brown canes, much 

more robust plants, rounder leaflets (or deeply incised leaflets for evergreen blackberry), and larger 

fruits and flowers 

Current Distribution on the Refuge: Known infestations exist on the Dawley Unit and Protection 

Island. Currently, it is unknown distribution or densities of either of these species on any of the other 

refuge islands. 

Measurable Objectives and Goal: Prevent further spread into newly seeded native restoration sites, 

along other ditches or other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of blackberry plants - targeting for elimination - to reduce competition with 

native plants. 

d. Maintain healthy stands of native perennial plants. 

Control Options: Mechanical control includes hand pulling of small infestations, mowing or 

herbicide larger patches. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-65 

The chemical treatment of blackberries with an appropriate herbicide provides relatively effective 

control. Currently, glyphosate (RoundupTM, Roundup ProTM), would be used on the Refuge. 

Glyphosate is soil binding, inexpensive, and a low threat to groundwater quality. Glyphosate is 

appropriate for spot treatments. Metsulfuron methyl is very effective for thistle, mullein control and 

blackberry is the preferred treatment in restoration areas with a high infestation level. This chemical 

can be broadcast in restoration areas where the establishment of native grasses and herbicide resistant 

native broadleafs are essential for restoration success. Other chemicals would be added as needed and 

be approved at the required level. All chemicals would be used in accordance with label 

recommendations. 

Cultural control of blackberries is an important control method. The key to controlling spread is by 

decreasing seed production in established patches, and/or preventing the cane tips or nodes from 

touching the ground to produce “daughter” plants. Methods that assist in these control strategies are 

minimizing soil disturbance, maintaining healthy native vegetation, control seed formation with a 

combination of mechanical and chemical techniques. 

Treatment Schedule: The pulling can be done anytime. Mowing or cutting midsummer allow plant 

to grow back 18 inches then treat with herbicide is the preferred method. 

Chemical application would occur during the Fall (Sept Oct.). 

G.8.16 English Ivy 

Priority: Low: Although widespread in western Washington and control in not required, this specie 

is highly invasive but fortunately not too difficult to control. Therefore it is important to protect 

wilderness areas as well as areas being restored to native vegetation. 

Description: Evergreen vine that can trail along the ground or grow vertically up trees, fences, walls 

and hillsides. Most common type of growth lacks flowers and has dull green, lobed leaves with light 

veins that grow alternately along trailing or climbing stems. Leaf shape and size varies between 

varieties from deeply to shallowly lobed and from small, narrow leaves to large, broadly shaped 

leaves. Mature form of growth has shiny, unlobed leaves that grow in dense, whorl-like clusters and 

produce umbrella-like groups of small yellow-green flowers in the fall, followed by dark purpleblack berries in the late winter or early spring. 

Current Distribution on the Refuge: Only known infestations exist on Matia Island and the 

Dawley Unit. 

Measurable Objectives and Goal: Prevent further spread into newly seeded native restoration sites, 

along other ditches or other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., remediation areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat 100% of ivy plants - targeting for elimination - to reduce competition with native 

plants. 

d. Maintain healthy stands of native perennial plants. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-66 Appendix G. Integrated Pest Management 

Control Options: Mechanical control includes hand pulling and cutting of vines or herbicide larger 

patches. 

The chemical treatment of ivy with an appropriate herbicide provides relatively effective control. 

Currently, glyphosate (RoundupTM, Roundup ProTM), would be used on the Refuge. Glyphosate is 

soil binding, inexpensive, and a low threat to groundwater quality. Glyphosate is appropriate for spot 

treatments. Other chemicals would be added as needed and be approved at the required level. All 

chemicals would be used in accordance with label recommendations. 

Cultural control of ivy is an important control method. The key to controlling spread is by decreasing 

seed production in established patches, and/or preventing the vegetative spreading of the plants. 

Methods that assist in these control strategies are minimizing soil disturbance, maintaining healthy 

native vegetation, control seed formation with a combination of mechanical and chemical techniques. 

Treatment Schedule: The pulling can be done anytime. Mowing or cutting midsummer allow plant 

to grow back 18 inches then treat with herbicide is the preferred method. Cutting vines and treating 

stems with herbicide or foliar in spring are good alternatives. 

 

Chemical application would occur during the spring or fall. 

G.8.17 Scotch Broom 

Priority: High: The State of Washington considers this species as a Class B Noxious weed, and 

control is recommended. Scotch broom infests disturbed areas, along roadsides, pastures, and open 

areas where it forms dense colonies. It reproduces by seeds, which can remain viable for up to 60 

years. Populations enlarge by peripheral expansion of existing stands forming monocultures. 

Biodiversity, livestock and wildlife forage quality are reduced with infestations of scotch broom. 

Seed are toxic to livestock and horses. 

Description: Scotch broom is a perennial evergreen shrub with a deep taproot. Plants reach 3 to 10 

feet tall with many branched stems. There are relatively few leaves that are simple in the upper part 

of the plant and the lower parts are 3 leaflets and deciduous. Flowers are primarily yellow, but may 

be tinged with red or purple. They are an irregular shaped pea-like flower about 3⁄4 of an inch long. 

Flowering occurs from April to June. 

Current Distribution on the Refuge: Only known infestation is at the Dawley Unit of the Refuge 

Complex. 

Measurable Objectives and Goal: Prevent competition with newly seeded native plants in habitat 

restoration sites, along roadways, and other disturbed soil areas. 

Objectives: 

a. Monitor known infestation sites, newly seeded areas, roadways, and other disturbed sites 

(e.g., restoration areas, wildfire areas) depleted of native perennial plants. 

b. Seed disturbed sites with native species. 

c. Treat and control 100% of scotch broom plants - targeting for elimination - to reduce 

competition with native plants and prevent establishment of Scotch broom or its seed bank. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-67 

d. Map and measure larger infestation patches using geographic information software and a 

global positioning system device. Treat patches to prevent increase in the infestation area. 

e. Maintain healthy stands of native perennial plants. 

Control Options: Hand pulling or digging using a weed wrench is a feasible control of small 

infestations and individual plants. The taproot would be removed to at least 2 inches below the 

ground surface. Entire plants would be removed from the site to limit the source of available seeds or 

removed prior to seed set. 

Biological control of scotch broom is limited with a few domestic animals browsing the young stems. 

Two introduced insects; the twig-mining moth and the seed weevil eat only Scotch broom. They have 

been released in western Clallam County but their effectiveness in controlling Scotch broom has not 

yet been established. 

The chemical treatment of scotch broom with an appropriate herbicide provides relatively effective 

control. Currently, triclopyr (Garlon TM), or glyphosate (RoundupTM, Roundup ProTM) would be the 

herbicides used to control Scotch broom on the Refuge. 

Treatment Schedule: Hand removal would be conducted 2 to 3 times during the growing season, 

the first removal occurring early in the season (March) well before flowering. Established areas too 

large to practically control by hand, or in areas where injury to surrounding vegetation prohibits 

broad scale application with chemical control, a cut and stump treatment would be used. 

Selected biological control insect(s) would be, if used, released during the optimal time for both 

insect and plant to provide the greatest effectiveness for controlling Scotch broom. 

Triclopyr or glyphosate would be applied once before the flowering season (April-June). Annual 

treatment is necessary as long as there is a viable seed source. 

G.8.18 Other Future species 

Oxeye Daisy, Tansy Ragwort, and Spurge Laurel 

These are species currently not known to occur on the Refuge but do occur in surrounding areas. 

These include Purple Loosestrife, Russian knapweed, Garlic Mustard, Japanese Knotweed, and 

Lawnweed. Others may be added as information becomes available and new species are documented. 

Table G-5. Summary of invasive plant species and possible control methods to be used, 

Washington Maritime National Wildlife Refuge Complex 

Species Priority Mechanical Biological Chemical Cultural 

Blackberries Low-Medium X X 

Bull thistle Low-Medium X X 

Canada thistle Low-Medium X Stem-and-shoot gallfly 

(Urophora cardui) 

X 

Cheatgrass Medium X X X 

Dalmatian and 

yellow toadflax 

High X X 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-68 Appendix G. Integrated Pest Management 

Species Priority Mechanical Biological Chemical Cultural 

Diffuse, spotted, 

Russian, and 

meadow 

knapweed 

High X Broad-nosed seedhead 

weevil, 

Sulfur knapweed moth, 

Knapweed weevil, 

Knapweed flowerhead 

weevil 

X 

Field bindweed Low-Medium Field bindweed moth, 

Field bindweed mite 

X 

Scotch Broom High X X 

Leafy spurge High Brown-legged spurge flea 

beetle, Amber spurge flea 

beetle 

X 

Musk thistle Medium X Seed head weevil, Musk 

thistle weevil 

X 

Common 

cordgrass 

Medium-High X X 

Russian 

knapweed 

High X X 

Scotch thistle Medium-High X X 

St. Johnswort Medium-High Klamath weed beetle 

G.9 Non-native Mammal Control 

The animals referred to under this category are the non-native predators (rats, red fox, dogs, and cats) 

and the herbivore (European rabbit). All of these can be controlled using one or more methods. 

Currently, only rabbits are known to exist on a limited number of islands and in low numbers, but 

expanding. For initial population control traps would be the preferred method followed by shooting 

then poison bait. Any method used would be to eradicate the population in the quickest, most 

humane, and least impact to other potential non-target animals. 

G.10 References 

AgDrift. 2001. A user’s guide for AgDrift 2.04: a tiered approach for the assessment of spray drift of 

pesticides. Spray Drift Task Force. Macon, MO. 

ATSDR (Agency for Toxic Substances and Disease Registry) U.S. Department of Health and Human 

Services. 2004. Guidance manual for the assessment of joint toxic action of chemical mixtures. U.S. 

Department of Health and Human Services, Public Health Service, ATSDR, Division of Toxicology. 

62 pp. (+ appendices). 

Baehr, C.H. and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. Presentation at the American Society for Testing and Materials 

(ASTM) Tenth Symposium on Environmental Toxicology and Risk Assessment, April 2000, 

Toronto, Canada. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-69 

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication 

PM 1495. Iowa State University Extension. Ames, IA. 6 pp. 

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use patterns 

in the Sacramento Valley, CA. Proceedings of the International Conference on Pesticide Application 

for Drift Management. Waikoloa, HI. 15 pp. 

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and transformation 

products in surface waters of the midwestern United States. Journal of the American Water 

Resources Association (JAWRA) 39(4):743-756. 

Beyer, W.N., E.E. Connor, and S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

BLM (Bureau of Land Management). 2007. Vegetation treatments using herbicides on Bureau of 

Land Management Lands in 17 western states Programmatic EIS (PEIS). Bureau of Land 

Management. Washington, D.C. 539 pp. 

Brooks, M.L., C.M. D’Antonio, D.M. Richardson, J.B. Grace, J.E. Keeley, J.M. DiTomaso, R.J. 

Hobbs, M. Pellant, and D. Pyke. 2004. Effects of invasive alien plants on fire regimes. BioScience 

54:77-88. 

Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement to 

ground water. Extension Publication PI-2. University of Florida, Cooperative Extension Service. 

Gainesville, FL. 4 pp. 

Calabrese, E.J. and L.A. Baldwin. 1993. Performing ecological risk assessments. Chelsea, MI: Lewis 

Publishers. 

Center, T.D., J.H. Frank, and F.A. Dray, Jr. 1997. Biological control. Pages 245-263 in: D. 

Simberloff, D.C. Schmitz, and T.C. Brown, eds. Strangers in paradise: impact and management of 

nonindigenous species in Florida. Washington, D.C.: Island Press. 

Coombs, E.M., J.K. Clark, G.L. Piper, and A.F. Cofrancesco, Jr. 2004. Biological control of invasive 

plants in the United States. Corvallis, OR: Oregon State University Press. 

Cox, R.D. and V.J. Anderson. 2004. Increasing native diversity of cheatgrass-dominated rangeland 

through assisted succession. Journal of Range Management 57:203-210. 

Driver, C.J., M.W. Ligotke, P. Van Voris, B.D. McVeety, B.J. Greenspan, and D.B. Brown. 1991. 

Routes of uptake and their relative contribution to the toxicologic response of northern bobwhite 

(Colinus virginianus) to an organophosphate pesticide. Environmental Toxicology and Chemistry 

10:21-33. 

Dunning, J.B. 1984. Body weights of 686 species of North American birds. Western Bird Banding 

Association. Monograph No. 1. Cave Creek, AZ: Eldon Publishing. 

EXTOXNET. 1993. Movement of pesticides in the environment. Pesticide Information Project of 

Cooperative Extension Offices of Cornell University, Oregon State University, University of Idaho, 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-70 Appendix G. Integrated Pest Management 

University of California – Davis, and the Institute for Environmental Toxicology, Michigan State 

University. 4 pp. 

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA 

food-chain (Kanaga) nomogram, and instrument for estimating pesticide residue on plants. 

Environmental Toxicology and Chemistry 13:1381-1391. 

Hasan, S. and P.G. Ayres. 1990. The control of weeds through fungi: principles and prospects. 

Tansley Review 23:201-222. 

Huddleston, J.H. 1996. How soil properties affect groundwater vulnerability to pesticide 

contamination. EM 8559. Oregon State University Extension Service. Corvallis, OR. 4 pp. 

Kerle, E.A., J.J. Jenkins, and P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension Service. 

Corvallis, OR. 8 pp. 

Masters, R.A. and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Management 54:502-517. 

Masters, R.A., S.J. Nissen, R.E. Gaussoin, D.D. Beran, and R.N. Stougaard. 1996. Imidazolinone 

herbicides improve restoration of Great Plains grasslands. Weed Technology 10:392-403. 

Maxwell, B.D., E. Lehnhoff, and L.J. Rew. 2009. The rationale for monitoring invasive plant 

populations as a crucial step for management. Invasive Plant Science and Management 2:1-9 

Mineau, P., B.T. Collins, and A. Baril. 1996. On the use of scaling factors to improve interspecies 

extrapolation to acute toxicity in birds. Regulatory Toxicology and Pharmacology 24:24-29. 

Moody, M.E. and R.N. Mack. 1988. Controlling the spread of plant invasions: the importance of 

nascent foci. Journal of Applied Ecology 25:1009-1021. 

Morse, L.E., J.M. Randall, N. Benton, R. Hiebert, and S. Lu. 2004. An invasive species assessment 

protocol: evaluating non-native plants for their impact on biodiversity. Version 1. NatureServe, 

Arlington, VA. 40 pp. 

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. Invasive plant 

species. Council for Agricultural Science and Technology Issue Paper (13):1-18. 

Oregon State University. 1996. EXTOXNET-Extension Toxicology Network, Pesticide Information 

Profiles. Oregon State University. Corvallis, OR. 

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, and C. Wickliff. 1996. Field evaluation of the EPA 

(Kanaga) nomogram, a method for estimating wildlife exposure to pesticide residues on plants. 

Environmental Toxicology and Chemistry 15:535-543. 

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know. 

Extension Publication PAT 36. Iowa State University Extension, Ames, IA, and Iowa Department of 

Agriculture and Land Stewardship, Des Moines, IA. 6 pp. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management G-71 

Ramsay, C.A., G.C. Craig, and C.B. McConnell. 1995. Clean water for Washington—protecting 

groundwater from pesticide contamination. Extension Publication EB1644.Washington State 

University Extension. Pullman, WA. 12 pp. 

SDTF 2003 (Spray Drift Task Force 2003). 2003. A summary of chemigation application studies. 

Spray Drift Task Force. Macon, MO. 

Spartina Task Force. 1994. Spartina Management Program: Integrated Weed Management for Private 

Lands in Willapa Bay, Pacific County, Washington. Unpublished report prepared for the Noxious 

Weed Board and County Commissioners, Pacific County, Washington. 

Teske, M.E., S.L. Bird, D.M. Esterly, S.L. Ray, and S.G. Perry. 1997. A user’s guide for 

AgDRIFTTM 1.0: a tiered approach for the assessment of spray drift of pesticides. Technical Note 

No. 95-10. CDI. Princeton, NJ. 

Teske, M.E., S.L. Bird, D.M. Esterly, T.B. Curbishley, S.L. Ray, and S.G. Perry. 2002. AgDRIFT®: 

a model for estimating near-field spray drift from aerial applications. Environmental Toxicology and 

Chemistry 21: 659-671. 

Urban, D.J. and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. U.S. 

Environmental Protection Agency, Office of Pesticide Programs. Washington, D.C. 94 pp. 

USEPA (U.S. Environmental Protection Agency). 1990. Laboratory test methods of exposure to 

microbial pest control agents by the respiratory route to nontarget avian species. EPA/600/3-90/070. 

Environmental Research Laboratory. Corvallis, OR. 82 pp. 

USEPA. 1998. A comparative analysis of ecological risks from pesticides and their uses: 

background, methodology and case study. Environmental Fate and Effects Division, Office of 

Pesticide Programs, U.S. Environmental Protection Agency. Washington, D.C. 105 pp. 

USEPA. 2004. Overview of the ecological risk assessment process in the Office of Pesticide 

Programs, U.S. Environmental Protection Agency: endangered and threatened species effects 

determinations. Office of Pesticide Programs. Washington, D.C. 101 pp. 

USEPA. 2005. User’s guide TREX v1.2.3. Available at: 

http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

USEPA. 2012. Technical overview of ecological risk assessment risk characterization; approaches 

for evaluating exposure; granular, bait, and treated seed applications. Available at: 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. Accessed July 5, 2012. 

USFS (U.S. Forest Service). 2005. Pacific Northwest Region invasive plant program preventing and 

managing invasive plants final environmental impact statement. U.S. Forest Service. Portland, OR. 

359 pp. 

USFWS (U.S. Fish and Wildlife Service). 2012. Dungeness National Wildlife Refuge draft 

Comprehensive Conservation Plan and Environmental Assessment. U.S. Department of the Interior, 

Fish and Wildlife Service, Region 1, Portland, OR. 520 pp. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

G-72 Appendix G. Integrated Pest Management 

USGS (U.S. Geological Survey). 2000. Pesticides in stream sediment and aquatic biota—current 

understanding of distribution and major influences. USGS Fact Sheet 092-00. U.S. Geological 

Survey. Sacramento, CA. 4 pp. 

Washington State Noxious Weed Board. 2010. Common cordgrass (Spartina angilca). Available at: 

http://www.nwcb.wa.gov/detail.asp?weed=129. Accessed June 18, 2012. 

Washington State Noxious Weed Board. 2010. Dalmatian toadflax (Linaria dalmatica ssp. 

dalmatica). Available at: http://www.nwcb.wa.gov/detail.asp?weed=85. Accessed June 18, 2012. 

Washington State Noxious Weed Board. 2010. Oxeye daisy (Leucanthemum vulgare). Available at: 

http://www.nwcb.wa.gov/detail.asp?weed=84. Accessed June 18, 2012. 

Washington State Noxious Weed Board. 2010. Lawn burweed (Soliva sessilis). Available at: 

http://www.nwcb.wa.gov/detail.asp?weed=125. Accessed June 18, 2012. 

Wauchope, R.D., T.M. Buttler, A.G. Hornsby, P.M. Augustijn-Beckers, and J.P. Burt. 1992. 

The SCS/ARS/CES pesticide properties database for environmental decision making. Reviews of 

Environmental Contamination and Toxicology 123:1-155. 

Woods, N. 2004. Australian developments in spray drift management. Proceedings of the 

International Conference on Pesticide Application for Drift Management. Waikoloa, HI. 8 pp. 
Appendix H

Appen

Du

H. Sign Invent

ndix H.

ungeness Natio

tory and Maint

Sign In

onal Wildlife R

tenance Plan

nventory

Refuge Compre

 and M

hensive Conse

aintena

rvation Plan 

nce Plan 

H-1 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-2 Appendix H. Sign Inventory and Maintenance Plan 

H.1 General Information

Dungeness National Wildlife Refuge was set aside by Executive Order 2123 in 1915 as a refuge, 

preserve, and breeding ground for native birds. Located in the northwest corner of Washington State 

on the Strait of Juan de Fuca, the Refuge offers a diversity of habitats including sand beaches, 

protected bay waters, eelgrass beds, mudflats, and forested and grass uplands. Dungeness NWR 

consists of the Dungeness Unit, which includes the Graveyard Spit Research Natural Area (RNA), 

and the Dawley Unit. 

Originally the Dungeness Unit (including the Dungeness Spit) was part of a lighthouse reservation, 

on which the New Dungeness Light Station was built in 1857. Dungeness Spit is the longest natural 

sand spit in North America. Extending five and a half miles into the Strait of Juan de Fuca, it 

provides habitat for a great variety of migratory shorebirds, waterfowl, marine mammals, and other 

marine life within its protective reach. The tranquil waters of Dungeness Bay, with its eelgrass beds, 

mudflats, and tidelands provide food, shelter, and breeding grounds to support a whole ecosystem 

teeming with life. 

Large numbers of brant, wigeon, pintail, mallard, and bufflehead winter there. Dungeness crab, surf 

smelt, herring, and others breed within the bay and salmon frequent the waters surrounding the 

Refuge. Rare northern elephant seals haul out on the spit each year. Graveyard Spit supports some of 

the best remaining strand habitat within the Salish Sea. While Graveyard Spit is closed to the public, 

tidelands to the east and west are open seasonally. The Dungeness Spit is open to the public on the 

Strait side from the base of the spit to the lighthouse year-round and on the bay side for the first half 

mile seasonally. The west beach and forest trails are open to the public year-round. 

The Dawley Unit, located along Sequim Bay, was established as a wildlife sanctuary in 1973. The 

residential area was heavily developed with the construction of aviaries, ponds, and gardens while 

the forested tract was altered by logging over the years. The forested area does have an established 

logging road system, but due to the topography, some areas were protected from further alterations 

and are considered good second growth forest habitat. The entire unit is closed to the public. 

H.2 Purpose of this Plan

The general purpose of the sign inventory and maintenance plan is to identify and quantify the signs 

in use while documenting their condition and assessing and prioritizing repair and replacement 

needs. Furthermore, the plan seeks to accomplish four additional goals. First, refuge signs are 

intended to convey important general information to visitors such as where the Refuge is located and 

where they should and should not go or what they should not do with the overall goal of reducing 

impact to wildlife and their habitat. Second, refuge signs intend to facilitate a better understanding of 

the importance of the Refuge to wildlife while instilling in our visitors a sense of value for wildlife 

and habitat conservation. Signs should help to illuminate the Refuge’s unique history and how it is 

part of a larger cultural and natural perspective. Third, refuge signs intend to increase visitor safety 

and reduce injuries by providing important warnings. And finally, they are intended to accomplish 

these tasks with as little disruption to the aesthetic beauty of the Refuge as possible. 

 
Appendix H

H.3 U

The Daw

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H.4 S

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Figure H

Table HSign 

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1 Par

2 Ref

3 Ent

4 Blu

5 Ma

6 Ref

7 Tra

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9 Hea

10 Tra

11 Tra

12 Fee

13 Fee

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ehensive Conse

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as wildlife ha

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New 

/Reg New 

Poor 

New 

New 

New 

New 

New 

New 

New/

abitat, the Se

utilized on th

ungeness Un

It is estimate

rmation, and 

m. Due to the 

ngeness Unit 

here are 

roximately 1

amples of eac

”

dition Dat

d N/A

11/2

8/20

8/20

8/20

N/A

8/20

8/20

8/20

8/20

8/20

8/20

/Poor N/A

H-3 

ervice 

he 

nit is 

ed 

is 

0 

ch 

e 

A

2011 

011 

011 

011 

A

011 

011 

011 

011 

011 

011 

A
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-4 Appendix H. Sign Inventory and Maintenance Plan 

Sign Location Type Condition Date 

14 Restrooms w/ arrow (2) RR sidewalk & fence Info Good N/A 

15 Lighthouse Information Fence left of main trailhead Info Good N/A 

16 Parking Area Full Overflow lot entrance Info Poor N/A 

17 Distance to Spit 1 Near County Park kiosk Info Good N/A 

18 Distance to Spit 2 West end of parking lots Info Fair N/A 

19 Distance to Spit 3 Middle of parking lots Info Poor N/A 

20 Primitive Trail Fee Sign Primitive Trail Fee Station Info/Reg Fair N/A 

21 Primitive Arrow Symbol Base of spit @ bottom of 

main tr. 

Info Poor N/A 

22 Hiker w/ Arrow Base of spit @ bottom of 

main tr. 

Info Poor N/A 

23 No Jogging Past .5 mile Near 1⁄2 mile marker Info Poor N/A 

24 Hiker & Arrow Symbol Lighthouse access rd. Info Good N/A 

25 Map Panels 

(Porcelain on steel) 

a Primitive Trail Kiosk Info/Reg Fair N/A 

b Lighthouse boat landing 

area 

Info/Reg Poor N/A 

c County Park Kiosk Info/Reg Good N/A 

d Cline Spit (planned) Info/Reg -------- 

e Dungeness Landing 

(planned) 

Info/Reg -------- 

26 Fee Dollars at Work Entrance to upper overlook Info Fair N/A 

27 Harbor Overlook Entrance to upper overlook Info Poor N/A 

28 a Hiker Arrow Symbol Intersection of main & 

primitive trails 

Info Poor N/A 

b Primitive Arrow 

Symbol 

Intersection of main & 

primitive trails 

Info Poor N/A 

29 Amnesty Bucket Entrance to upper overlook Info New 11/2011 

30 Maintenance Area Mellus Cabin Gate Info Poor N/A 

31 Mile Markers a 1⁄2 Mile Info Poor N/A 

b 1 Mile Info Good N/A 

c 2 Mile Info Poor N/A 

d 3 Mile Info Good N/A 

e 4 Mile Info Good N/A 

Interpretive Signs 

34 Kiosk Interp. Panels (3) Kiosk Interp New 8/2011 

35 Main Trail Interp. (2) Lower main trail Interp New 8/2011 

36 Dungeness Spit Interp. Steep hill to beach Interp New 8/2011 

37 Spit Map Steep hill to beach Interp New 8/2011 

38 Plant Identification Main trail (series) Interp Good/Fair N/A 

39 Bird Pictorial Guide At entrance to upper viewing 

deck 

Interp New 11/2011 

Regulatory Signs 

40 Entrance Regulations Overflow parking entrance Reg Fair N/A 

41 Main Trail, symbols Main trailhead Reg Fair N/A 

42 Stop, Did You Pay Main trailhead Reg Poor N/A 

43 Stop, Did You Pay Primitive trailhead Reg Poor N/A 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-5 

Sign Location Type Condition Date 

44 No Pets Main trailhead Reg Fair N/A 

45 No RVs or Trailers Overflow lot entrance Reg Poor N/A 

46 Primitive Tr. symbols (6) Entrance to primitive trail Reg Good/Poor N/A 

47 No Horses on path Paver path to HQ @ 

overflow lot 

Reg Good N/A 

48 Caretaker Parking Overflow lot Reg Very good 2011 

49 Volunteer Parking Overflow lot Reg Very good 2011 

50 Disabled Parking Overflow lot Reg Very good N/A 

51 Disabled Parking (2) Main lot & restroom, 1st 

spaces 

Reg Poor N/A 

52 15 minute parking Restroom, 2nd space Reg Poor N/A 

53 Reserved Parking Restroom maintenance 

access 

Reg Poor N/A 

54 Main Tr. “Gate” barrier Main trailhead Reg Fair N/A 

55 Crosswalk Restroom crosswalk Reg Very good N/A 

56 Boating Regulations a Cline Spit Reg Poor N/A 

b Dungeness Landing Reg Poor N/A 

57 Boating Regs., Pylons Dungeness Harbor and Bay Reg Very good N/A 

58 Large Format Buffer Graveyard (3) Dungeness end 

(1) 

Reg Good N/A 

59 Boat Landing Zone Lighthouse boat landing area Reg Poor N/A 

60 Boat Visitors to LH Lighthouse boat landing area Reg Poor N/A 

61 Firearms Prohibited Headquarters doors, front & 

back 

Reg New N/A 

62 Area Closed Signs Various: bluffs, .5 mile, etc. Reg New/Poor N/A 

63 Refuge Boundary Boundaries; Dungeness/ 

Dawley 

Reg New/Poor N/A 

64 Unauthorized Entry Boundaries; Dungeness/ 

Dawley 

Reg New/Good N/A 

65 No Parking Refuge parking lots Reg Good/Fair N/A 

66 Bank Rest., Keep Off Lower main tr. @ lower 

overlook 

Reg Fair N/A 

67 No Climbing symbol Along lower main trail and 

bluffs 

Reg Fair/Poor N/A 

68 Sensitive wildlife habitat 5 mile closure, Strait side of 

spit 

Reg New/Good 4/2012 

69 Wildlife Sanctuary 

Closed 

a 5.5 mile, End of Spit Reg Fair N/A 

b South End of Graveyard 

Spit 

Reg Fair N/A 

c West side of Graveyard 

Spit 

Reg Fair N/A 

County Road Signs (Not Refuge Maintained) 

70 HWY 101 Highway 101 Info Good N/A 

71 Kitchen Dick Rd Kitchen Dick Rd @ 

Woodcock 

Info Good N/A 

72 Old Olympic Hwy Old Olympic Hwy @ Info Good N/A 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-6 Appendix H. Sign Inventory and Maintenance Plan 

Sign Location Type Condition Date 

Kitchen Dick Rd 

73 Lotzsgesell Rd Lotzsgesell Rd @ Park Entr. Info Good N/A 

74 Cays Rd Cays Rd @ Lotzsgesell Rd Info Good N/A 

75 Voice of America Rd Voice of Am. Rd @ Picnic 

area 

Info Good N/A 

76 West Anderson Rd West Anderson Rd, east of 

Cays Rd 

Info Good N/A 

77 Anderson and Cays NW Corner of Anderson & 

Cays 

Info Good N/A 

Sign Types: Info= Informational, Reg= Regulatory, Interp= Interpretive 

H.5 Sign Specification and Placement Criteria 

 

Signs will meet the specifications set forth in the USFWS Sign Manual. Signs posted in the Refuge 

will be constructed of high quality durable materials including steel, marine density overlay (MDO) 

3⁄4 inch plywood, poly metal, and plastic laminates and will have steel or wooden posts and supports. 

Large signs should be planted in cement. All mounting hardware should be corrosion-resistant 

stainless steel, such as Society of Automotive Engineers (SAE) grade 316, with locking nuts. The use 

of temporary and/or handmade signs is discouraged. 

Except as otherwise indicated, sign background color will be brown or white and lettering will be 

white, black, or, in the case of standard USFWS signs, dark blue. Text font will be Helvetica 

Medium. Reflective materials will be employed where vehicles (including boats) may encounter 

signs in dark conditions. 

Protected shoreline areas will utilize large format signs which can be read from the water at least 100 

yards offshore. These signs may also include the Service shield. Large format signs are at least 5 feet 

wide and 4 feet high. These signs should be well supported to protect against high winds common in 

the area. 

Standard USFWS closed area signs will be utilized to demarcate areas not open to the public as 

determined by the refuge manager. These signs will be posted on standard steel or wood posts. 

Standard USFWS refuge boundary signs should be posted along terrestrial boundary lines and 

sensitive habitat signs should be utilized as needed. See Figure H-1 for examples of standard Service 

signs. 

H.5.1 Large Special Purpose (Regulatory) Signs 

Due to the somewhat complicated nature of the Dungeness Unit, it is necessary to maintain a variety 

of large custom signs. In marine environments where wildlife disturbance is an issue, signs that can 

be read at distances up to 100 yards are necessary. The Refuge utilizes a variety of large format signs 

to inform visitors about refuge regulations including area closures. These signs are described below. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-7 

Sign Number(s): 40

Description: Visitor Information - Entrance 

Material: MDO plywood 

White and brown with white and brown lettering 

Text: Dungeness National Wildlife Refuge, Visitor Information 

 Dungeness Spit Trailhead 

 Entrance Fee Required 

 Refuge Closes at Sunset 

 Pets, Bicycles, Fires, and Camping Prohibited 

Dimensions: 66” X 48” 

Location: Voice of America Road at refuge overflow parking entrance 

 

Sign Number(s): 42 and 43

Description: Entrance fee stop sign 

Material: MDO plywood 

Reflective brown with white lettering and red “stop sign” symbol 

Text: Did You Pay Entrance Fee? 

Failure to comply with entrance fee requirement is a violation subject to penalties 

prescribed in 50 CFR 28.31 

Dimensions: 38” X 16” 

Location: Main and Primitive Trailheads 

Note: Need Replacements 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-8 Appendix H. Sign Inventory and Maintenance Plan 

Sign Number(s): 56a and 56b

Description: Boating Regulations 

Material: Metal 

White and brown with white and brown lettering 

Text: BOATING REGULATIONS 

Dungeness National Wildlife Refuge 

The following applies to boats visiting Dungeness Refuge 

 Refuge waters - identified by boundary signs on pilings in Dungeness Bay and 

harbor – are OPEN for boating from May 15 – September 30 (no wake zone) 

 Boat landings are allowed only in the marked area near the lighthouse. 

Reservations are required for boat landing. 

 Refuge waters are closed to jet skiing and windsurfing. 

 Contact (360) 457-8451 for reservations or more information 

Dimensions: 26” X 24” 

Location: Cline Spit and Dungeness Landing boat launches 

Note: Need Replacements 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-9 

Sign Number(s): 57a and 57b

Description: Tidelands seasonal closure 

Material: Heavy plastic on MDO plywood 

Reflective white or white and blue with black or white and blue lettering 

Text: WILDLIFE REFUGE AREA CLOSED 

EXCEPT MAY 15 – SEPT. 30 

BOATING (no wake zone) AND SHELLFISHING ALLOWED UP TO 100 YARD 

BUFFER FROM SHORE. SHORE AND UPLAND REMAIN CLOSED. 

Windsurfing & Jet Skis Not Allowed 

Dimensions: 24” X 42” 

Location: Refuge tidelands boundary pilings east and west of Graveyard Spit (Dungeness Bay 

and Harbor) 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-10 Appendix H. Sign Inventory and Maintenance Plan 

Sign Number(s): 59

Description: Lighthouse boat landing zone, reservation required 

Material: MDO plywood 

Reflective white or white and blue with black or white and blue lettering 

Text: BOAT LANDING ZONE, By Reservation Only, Between yellow posts 

For Information Contact Dungeness National Wildlife Refuge (360) 457-8451 

Dimensions: 60” X 42” 

Location: Lighthouse boat landing zone 

Note: Needs Replacement 

Sign Number(s): 60

Description: Lighthouse boat landing closed areas 

Material: MDO plywood 

Brown with white lettering and a red and yellow map 

Text: ATTENTION VISITORS, The tip of Dungeness Spit, including all beaches, 

tidelands, and uplands, is closed to public access to provide a sanctuary for wildlife. 

Dimensions: 44” X 20” 

Location: Lighthouse boat landing zone 

Note: Needs Replacement 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-11 

Sign Number(s): 69a, b, and c

Description: Wildlife sanctuary closures; end of Dungeness Spit, all of Graveyard Spit 

Material: MDO plywood 

White with black lettering 

Text: Wildlife Sanctuary Area Closed Refuge 

Boundary Posted on Pilings in Bay 

Dimensions: 66” X 48” 

Location: Tip of Dungeness Spit, Tip and West Side of Graveyard Spit (2) 

H.5.2 Posting Closed Areas on Dungeness Spit 

Bluffs: Some of the most hazardous areas in the Refuge are the 

west bluffs which are permanently closed to the public. Constantly 

eroding, the bluffs are known to shed large amounts of material 

without warning. At least one visitor has been seriously injured 

while trespassing in the closed area and attempting to climb the 

bluffs. Posting signs in this dynamic environment poses a constant 

challenge. Wave action at the base of the bluffs can quickly 

undermine sign posts on the beach resulting in regular loss of 

signs and posts. Refuge staff has experimented with different 

posting methods including posting signs directly on the bluffs but 

none have proven fully successful. 

Currently, the best approach is to continuously post signs on the 

beach approximately 10 feet away from the bluffs to create a 

safety buffer and allow for eroded material to collect. It is best to 

post in locations that present the most “inviting” avenues of access 

such as gullies and dirt piles. Signs should be posted 

approximately every 25 feet initially from the base of the Spit for the first hundred feet, 5 signs, and 

then every 75 to 100 feet thereafter to the western refuge boundary. Signs should be inspected daily 

and replaced as needed. 

Dungeness Spit: Although somewhat less dynamic than the west beach area, the “Spit” also presents 

a challenge for maintaining signs. Installing posts on the driftwood “spine” of the spit can be 

extremely difficult due to buried logs and rocks. Winter storms regularly dislodge and destroy signs 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-12 Appendix H. Sign Inventory and Maintenance Plan 

making it difficult to keep closed areas adequately posted. Signs along the entire “Spit” should be 

inspected monthly and replaced as needed. Each spring a team of staff and volunteers should conduct 

a comprehensive sign “replenishment” campaign. 

The first 1⁄2 mile of the Spit is closed seasonally from October 1 through May 14. While closed signs 

are removed during the open season, posts should left in place. In late September missing sign posts 

should be replaced in preparation for posting closure signs. Signs at the base of the spit should be 

placed no more than 25 feet apart on the service road and the first 150 feet of the spit. Additionally, a 

rope should span this area from post to post to provide a visual barrier and aid in enforcement. Signs 

after that should be posted every 75 to 100 feet to the 1⁄2 mile marker. Signs demarcating the 1⁄2 mile 

closure line on the inside of the spit should be no more than 25 feet apart extending from the 

driftwood spine into the harbor. These signs should be removed seasonally to reduce visitor 

confusion but the posts should be left in place. This area experiences a high level of trespass and 

should be well defined. 

The second 1⁄2 mile should be well posted with signs every 100 to 150 feet. After the first mile marker 

signs can be up to 200 feet apart except that they should be more numerous in the 4.5-5 mile section 

near the lighthouse where the spit is narrow and visitors are more tempted to cross over to the Bay 

side. Wash-over areas are often clear of driftwood and present inviting paths for trespassers. For that 

reason they are good places to post signs, however, they are also more likely places for signs to be 

lost to wave action. When posting in these areas signs should be placed on higher ground near the 

wash-over “path.” 

The Wildlife Sanctuary, 5 mile closure: Another area that experiences regular trespass is the 

“wildlife sanctuary” at the end of the “Spit.” At low tide beach walkers may inadvertently wander 

into this area. Because it is difficult to maintain signs on the beach, a clear line of signs should be 

visible on the upland area from the rip rap edge across the spit to the Bay. These signs, particularly 

the ones at the ends of the line, should be inspected weekly and replaced as needed. The inclusion of 

standard Service “Sensitive Wildlife Habitat” signs should help deter trespass. 

H.6 Sign Inspection and Maintenance 

 

The refuge caretaker in conjunction with staff will be responsible for routine inspections and 

maintenance of signs. A sign inspection form should be maintained for each non-standard sign. See 

Figure H-2. Inspection forms are not necessary for standard Service signs which should be visually 

inspected and replaced as needed. In addition, caretakers and staff will assess for sign damage as 

soon after high wind and water events as possible to insure signs have not been lost or damaged. Any 

sign damage that is not immediately remedied will be reported to the refuge manager or deputy 

manager. Materials necessary to repair signs will be stored in the maintenance building. These 

materials will include replacement USFWS shields, posts, cribbing, tools, and bolts. Due to their size 

and expense most large replacement signs will be stored at the Refuge Complex Headquarters at 715 

Holgerson Rd. in Sequim, Washington, or made to order as needed. A supply of standard Service 

signs will be maintained in the storage shed at the Caretaker’s cabin. A review of this sign plan will 

occur every 5 years unless conditions necessitate an earlier review. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-13 

Figure H-2. Sign Inspection Form. 

Washington Maritime NWRC 

Sign Inspection Checklist 

Name of Inspector: ________________________________________________ 

Refuge: ___________________ Unit: _________________ 

Date: ____/_____/______ Time: __________ 

Sign Inventory ID: 

Sign Location: ________________________ Description: ___________________________ 

Problem 

Substrate Face (overlay & lettering) Finish (Paint) Sign supports Hardware 

Comments 

Missing 

 

Blistering 

 

Corroded 

 

Cracking 

 

Dirty 

 

Damaged 

 

Decal faded/damaged 

 

Faded/readable 

 

Faded/unreadable 

 

Hanging or fallen 

 

Ply Separation 

 

Rotting 

 

Scratching or Tearing 

 

Unstable 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-14 Appendix H. Sign Inventory and Maintenance Plan 

Recommendations 

Clean 

 

Cut vegetation 

 

On-site repair 

 

Shop repair 

 

Remove 

 

Replace decal 

 

Replace sign 

 

Replace 

hardware/post(s) 

 

H.7 References 

U.S. Fish and Wildlife Service (USFWS). 1992. U.S. Fish and Wildlife Service sign manual, 

director’s memorandum signed by Acting Assistant Regional Director Carolyn Bohan, May 15, 

1992. U.S. Department of Interior, Fish and Wildlife Service, Region 1. Portland, OR. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-15 

Dungeness NWR Sign Reference Photos: Information (Sign #1 – 32) 

 1a. County Park Entrance (east side) 1b. County Park Entrance (west side) 

 2. Voice of America Rd 

 3a. Refuge Kiosk (front) 3b. Refuge Kiosk (back) 4. Bluff Trail 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-16 Appendix H. Sign Inventory and Maintenance Plan 

 5a. Main Trailhead 

 5b. Main Trailhead (Left) 5c. Main Trailhead (Right) 5d. Main Trailhead (Back) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-17 

 6a. Main Trailhead 6b. Primitive Trailhead 6c. Top of Hill to Spit 

 

 7. Kiosk 8. Fee Station 9a. Headquarters Entrance (left) 9b. Headquarters Entrance (right) 

 9c. HQ (left and right) 10. Kiosk 11. Main Parking Lot 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-18 Appendix H. Sign Inventory and Maintenance Plan 

 12. Fee Station 13a. Main Trail 13b. Primitive Trail 

 14a. Entrance Station Crosswalk 14b. Parking Lot Fence 

 15. Main Trailhead (Maintained by NDLSA) 16. Overflow Parking Lot Entrance 

 17. Near County Kiosk 18. West End of Parking Lot 19. Middle of Parking Lot 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-19 

 20a. Primitive Trail Fee Station 20b. Primitive Trail Fee Station 

 21. Spit Service Rd 22. Spit Service Rd 23. 1/2 Mile Marker 24. Lighthouse Service Rd 

 25a. Primitive Trailhead 25b. Lighthouse Landing Area 25c. County Park Kiosk 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-20 Appendix H. Sign Inventory and Maintenance Plan 

 26. Upper Overlook 27. Upper Overlook 28a and b. Main Trail Junction (Horseback 

 riding sign will be removed) 

 29. Caretaker’s Cabin 30. Caretaker’s Cabin Gate 

 31a. Spit 31b. Spit 31c. Spit 31d. Spit 31e. Spit 

 
Appendix H

Dungene

34a. Kios

 

 

35a. Low

Du

H. Sign Invent

ess NWR Sig

sk (left) 

 

wer Main Trai

ungeness Natio

tory and Maint

gn Reference

 

 34c. Kio

il (front) 

onal Wildlife R

tenance Plan

e Photos: Int

 

osk (right) 

 

Refuge Compre

terpretive (S

 34b. Kio

 35b. Low

ehensive Conse

Sign #34 – 3

osk (center) 

wer Main Tra

ervation Plan 

9) 

il (back) 

H-21 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-22 Appendix H. Sign Inventory and Maintenance Plan 

 36. Lower Main Trail, Hill 37. Lower Main Trail, Hill 

 38a. Main Trail 38b. Main Trail 38c. Main Trail 

 38d. Main Trail 38e. Main Trail 38f. Main Trail 

 38g. Main Trail 38h. Main Trail 38i. Main Trail 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-23 

 38j. Main Trail 38k. Main Trail 38l. Main Trail 

 38m. Main Trail 38n. Main Trail 38o. Main Trail 

 

 38p. Main Trail 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-24 Appendix H. Sign Inventory and Maintenance Plan 

39. Main Trail, Top of Hill 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-25 

Dungeness NWR Sign Reference Photos: Regulatory (Sign #40 – 69) 

 40. Voice of America Rd at Refuge Entrance 41. Main Trailhead 

 42. Main Trail 43. Primitive Trail 

 44. Main Trailhead 45. Overflow Parking Lot 46a. Primitive Trail Gate 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-26 Appendix H. Sign Inventory and Maintenance Plan 

46b 46c 

 47. Path to Headquarters 48. Overflow Lot 49. Overflow Lot 

 50. Overflow Lot 51. Main Parking Lot 52. Restroom Parking 53. Restroom 

 54a. Main Trail “Gate” (front) 54b. Main Trail “Gate” (back) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-27 

 55. Restroom Crosswalk 56a. Cline Spit 56b. Dungeness Landing 

 57a. Harbor/Bay Pilings 57b. Harbor/Bay Pilings 60. Lighthouse Boat Landing Area 

 61. Lighthouse Boat Landing Area 62. Headquarters Entrance 

62 – 65: Standard USFWS Signs (See Figure H-1, Standard Service Signs in use on Dungeness 

NWR) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-28 Appendix H. Sign Inventory and Maintenance Plan 

 66. Main Tr Hill 67. Bluffs 68. LH Beach 

69a, b, and c. Graveyard Spit and End of Dungeness Spit 

Dungeness NWR Sign Reference Photos: County (Sign #70 – 77) 

 70. Highway 101 71. Kitchen Dick Rd at Woodcock Rd 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Sign Inventory and Maintenance Plan H-29 

 72. Old Olympic Highway at Kitchen Dick Rd 73. Lotzsgesell Rd at County Park Entrance 

 74. Cays Rd 75. Voice of America Rd 

 76. East Anderson Dr at Cays Rd 77. West Anderson Dr and Cays Rd 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

H-30 Appendix H. Sign Inventory and Maintenance Plan 

Document continues on next page. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-1 

Appendix I. Acronyms, Glossary and Scientific Names 

I.1 Acronyms 

ABA Architectural Barriers Act 

ABC American Bird Conservancy 

ADA Americans with Disabilities Act 

ARPA Archaeological Resources Protection Act 

ATSDR Agency for Toxic Substances and Disease Registry 

Audubon National Audubon Society 

BBS Breeding Bird Survey 

BCC Birds of Conservation Concern 

BIDEH Biological Integrity, Diversity, and Environmental Health 

BLM Bureau of Land Management 

BMC Birds of Management Concern 

BMPs Best Management Practices 

BOR Bureau of Reclamation 

BP Before Present 

CCP Comprehensive Conservation Plan 

CD Compatibility Determination 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CIG Climate Impacts Group 

COASST Coastal Observation and Seabird Survey Team 

Complex Washington Maritime National Wildlife Refuge Complex 

COSEWIC Committee on the Status of Endangered Wildlife in Canada 

CWA Clean Water Act 

DAHP Washington State Department of Archaeology and Historic Preservation 

DAWACT Dungeness Area Watershed Analysis Cooperative Team 

DBH Diameter at Breast Height 

Director Director of the U.S. Fish and Wildlife Service 

DOE U.S. Department of Energy 

DRA Dungeness Recreation Area 

DWD Downed Woody Debris 

EA Environmental Assessment 

EDPU Elwha-Dungeness Planning Unit 

EE Environmental Education 

EIS Environmental Impact Statement 

ENSO El Niño/Southern Oscillation 

EO Executive Order 

ESA Endangered Species Act 

ESU Evolutionarily Significant Unit 

FIRFA Federal Insecticide, Fungicide, and Rodenticide Act 

FMP Fire Management Plan 

FR Federal Register 

FWA Fish and Wildlife Act of 1956 

FWS U.S. Fish and Wildlife Service (also, Service, USFWS) 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-2 Appendix I. Glossary and Scientific Names 

FY Fiscal Year 

GAO Government Accountability Office 

GHG Greenhouse Gases 

GIS Geographic Information System 

GPS Global Positioning System 

HMP Habitat Management Plan 

IAC Interagency Committee for Outdoor Recreation 

IBA Important Bird Areas 

IPCC Intergovernmental Panel on Climate Change 

IPM Integrated Pest Management 

LCC Land Conservation Cooperative 

LE Law Enforcement 

LWCF Land and Water Conservation Fund 

MHHW Mean Higher High Water 

MHW Mean High Water 

MLLW Mean Lower Low Water 

MLW Mean Low Water 

MOA Memorandum of Agreement 

MOU Memorandum of Understanding 

MSL Mean Sea Level 

MTL Mean Tide Level 

NAGPRA Native American Graves Repatriation Act 

NAS National Academy of Sciences 

NASA National Aeronautics and Space Administration 

NAVD88 North American Vertical Datum 1988 

NAWMP North American Waterfowl Management Plan 

NCDC National Climatic Data Center 

NDLSA New Dungeness Light Station Association 

NEPA National Environmental Policy Act 

NGO Non-governmental Organization 

NHPA National Historic Preservation Act 

NMFS National Marine Fisheries Service 

NOA Notice of Availability 

NOAA National Oceanic and Atmospheric Administration 

NOI Notice of Intent 

NRC Natural Resource Consultants 

NRHP National Register of Historic Places 

NSRE National Survey on Recreation and the Environment 

NWR National Wildlife Refuge 

NWRS National Wildlife Refuge System 

OCBP Ocean Carbon and Biogeochemistry Program 

OCNMS Olympic Coast National Marine Sanctuary 

OFM State of Washington’s Office of Financial Management 

OMB Office of Management and Budget 

ONF Olympic National Forest (also Olympic NF) 

ONP Olympic National Park (also Olympic NP) 

OPAS Olympic Peninsula Audubon Society 

PDO Pacific Decadal Oscillation 

PFT Permanent full time 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-3 

PIF Partners in Flight 

PLO Public Land Order 

PP Presidential Proclamation 

PRBO Point Reyes Bird Observatory 

PRPA Paleontological Resources Protection Act 

PSAT Puget Sound Action Team 

PSNERP Puget Sound Nearshore Ecosystem Restoration Project 

PSWQAT Puget Sound Water Quality Action Team) 

PTC Peninsula Trails Coalition 

PUP Pesticide Use Proposal 

R1 Region 1 of the FWS (WA, OR, HI, ID) 

RC&DC North Olympic Peninsula Resource Conservation & Development Council 

RCO Washington State Recreation and Conservation Office 

RNA Research Natural Area 

ROC Resource of Concern 

SAMMS Service Asset Management System 

SCORP Statewide Comprehensive Outdoor Recreation Plan 

SDTF 2003 Spray Drift Task Force 2003 

SHPO State Historic Preservation Office 

SLAMM Sea Level Affecting Marshes Model 

SO Secretarial Order 

SUP Special Use Permit 

T & E Threatened or Endangered Species 

TMDL Total Maximum Daily Load 

TNC The Nature Conservancy 

U.S.C. United States Code 

USC&GS U.S. Coastal and Geodetic Survey 

USCG U.S. Coast Guard 

USDA U.S. Department of Agriculture 

USDC U.S. Department of Commerce 

USDI U.S. Department of the Interior 

USEPA U.S. Environmental Protection Agency (also, EPA) 

USFS U.S. Forest Service 

USFWS U.S. Fish and Wildlife Service 

USGCRP U.S. Global Change Research Program 

USGS U.S. Geological Survey 

USHCN U.S. Historical Climatology Network 

WDEQ Washington Department of Environmental Quality 

WDFW Washington Department of Fish and Wildlife 

WDNR Washington Department of Natural Resources 

WDOE Washington Department of Energy 

WRCC Western Regional Climate Center 

WSDA Washington Department of Agriculture 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-4 Appendix I. Glossary and Scientific Names 

I.2 Glossary 

Adaptive Management. Refers to a process in which policy decisions are implemented within a 

framework of scientifically driven experiments to test predictions and assumptions inherent in a 

management plan. Analysis of results help managers determine whether current management should 

continue as is or whether it should be modified to achieve desired conditions. 

Alternative. 1. A reasonable way to fix the identified problem or satisfy the stated need (40 CFR 

1500.2). 2. Alternatives are different means of accomplishing refuge purposes and goals and 

contributing to the System mission (Service Manual 602 FW 1.6). 

Anadromous. A fish that hatches in freshwater, migrates to the ocean to live and grow, and returns 

to freshwater to spawn. 

BIDEH. Biological integrity, diversity and environmental health represented by native fish, wildlife, 

plants and their habitats as well as those ecological processes that support them. 

Biological Diversity. The variety of life and its processes, including the variety of living organisms, 

the genetic differences among them, and the communities and ecosystems in which they occur 

(Service Manual 052 FW 1.12B). The System’s focus is on indigenous species, biotic communities, 

and ecological processes. Also referred to as Biodiversity. 

Compatible Use. A proposed or existing wildlife-dependent recreational use or any other use of a 

national wildlife refuge that, based on sound professional judgment, will not materially interfere with 

or detract from the fulfillment of the National Wildlife Refuge System mission or the purposes of the 

national wildlife refuge (Service Manual 603 FW 2.6). A compatibility determination supports the 

selection of compatible uses and identifies stipulations or limits necessary to ensure compatibility. 

Comprehensive Conservation Plan (CCP). A document that describes the desired future conditions 

of a refuge or planning unit and provides long-range guidance and management direction to achieve 

the purposes of the refuge; helps fulfill the mission of the Refuge System; maintains and, where 

appropriate, restores the ecological integrity of each refuge and the Refuge System; and meets other 

mandates. (Service Manual 602 FW 1.6). 

Concern. See definition of issue. 

Cover Type. The type of vegetation in an area. Often referred to as percent cover or the % of ground 

covered by vegetation type (e.g. 20% shrub cover). 

Cultural Resources. The remains of sites, structures, or objects used by people in the past. 

Cultural Resource Inventory. A professionally conducted study designed to locate and evaluate 

evidence of cultural resources present within a defined geographic area. Inventories may involve 

various levels, including a background literature search, a comprehensive field examination to 

identify all exposed physical manifestations of cultural resources, or a sample inventory to project 

site distribution and density over a larger area. Evaluation of identified cultural resources to 

determine eligibility for the National Register follows the criteria found in 36 CFR 60.4 (Service 

Manual 614 FW 1.7). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-5 

Demography. The study of life-history parameters such as adult survival, fledgling success, and the 

number of broods raised per year. 

Disturbance. Significant alteration of wildlife behavior or habitat structure and composition. May be 

natural (e.g., fire) or human-caused events (e.g., aircraft over flight). 

Ecosystem. A dynamic and interrelating complex of plant and animal communities and their 

associated non-living environment. 

Ecosystem Management. Management of natural resources using system-wide concepts to ensure 

that all plants and animals in ecosystems are maintained at viable levels in native habitats and basic 

ecosystem processes are perpetuated indefinitely. 

Endangered Species (Federal). A plant or animal species listed under the Endangered Species Act 

that is in danger of extinction throughout all or a significant portion of its range. 

Endangered Species (State). A plant or animal species in danger of becoming extinct or extirpated 

in Washington within the near future if factors contributing to its decline continue. Populations of 

these species are at critically low levels or their habitats have been degraded or depleted to a 

significant degree. 

Environmental Assessment (EA). A concise public document, prepared in compliance with the 

National Environmental Policy Act, that briefly discusses the purpose and need for an action, 

alternatives to such action, and provides sufficient evidence and analysis of impacts to determine 

whether to prepare an environmental impact statement or finding of no significant impact (40 CFR 

1508.9). 

Finding of No Significant Impact (FONSI). A document prepared in compliance with the National 

Environmental Policy Act, supported by an environmental assessment, that briefly presents why a 

federal action will have no significant effect on the human environment and for which an 

environmental impact statement, therefore, will not be prepared (40 CFR 1508.13). 

Fire Regime. A natural fire regime is a general classification of the role fire would play across a 

landscape in the absence of modern human mechanical intervention, but including the influence of 

aboriginal burning. 

Focal Resources. Plant and animal species that are most representative of refuge purposes, BIDEH 

and other FWS and ecosystem priorities. Conservation and management of these species will guide 

refuge management in the future. See Priority Resources of Concern and Other Benefiting Species. 

Forb. A broad-leaved, herbaceous plant; for example, a columbine. 

Goal. A descriptive, open-ended, and often broad statement of desired future conditions that conveys 

a purpose, but does not define measurable units (Service Manual 602 FW 1.6). 

Habitat. Suite of existing environmental conditions required by an organism for survival and 

reproduction. The place where an organism typically lives. 

Habitat Type. See Vegetation Type. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-6 Appendix I. Glossary and Scientific Names 

Habitat Restoration. Management emphasis designed to move ecosystems to desired conditions and 

processes, and/or to healthy ecosystems. 

Invasive Species. A non-native species whose introduction causes or is likely to cause economic or 

environmental harm. Also referred to as exotic or non-native species. 

Inventory. A survey that documents the presence, relative abundance, status and/or distribution of 

abiotic resources, species, habitats, or ecological communities at a particular time. Often referred to 

as baseline inventory. 

Issue. Any unsettled matter that requires a management decision (e.g., a Service initiative, 

opportunity, resource management problem, a threat to the resources of the unit, conflict in uses, 

public concern, or the presence of an undesirable resource condition) (Service Manual 602 FW 1.6). 

Management Alternative. See Alternative. 

Migration. The seasonal movement from one area to another and back. 

Mission Statement. Succinct statement of a unit’s purpose and reason for being. 

Monitoring. A survey repeated through time to determine changes in the status and/or demographics 

of abiotic resources, wildlife or plants, habitat, or ecological communities. 

National Environmental Policy Act of 1969 (NEPA). Requires all agencies, including the Service, 

to examine the environmental impacts of their actions, incorporate environmental information, and 

use public participation in the planning and implementation of all actions. Federal agencies must 

integrate NEPA with other planning requirements, and prepare appropriate NEPA documents to 

facilitate better environmental decision making (40 CFR 1500). 

National Wildlife Refuge. A designated area of land, water, or an interest in land or water within the 

National Wildlife Refuge System. 

National Wildlife Refuge System. All lands, waters and interests therein administered by the 

Service as wildlife refuges, wildlife ranges, wildlife management areas, waterfowl production areas, 

and other areas for the protection and conservation of fish and wildlife, including those that are 

threatened with extinction. 

National Wildlife Refuge System Mission. The mission is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans. 

Native Species. Species that normally live and thrive in a particular ecosystem. 

Noxious species. Any plant or plant product that can directly or indirectly injure or cause damage to 

crops (including nursery stock or plant products), livestock, poultry, or other interests of agriculture, 

irrigation, navigation, the natural resources of the United States, the public health, or the 

environment. Control of these species is mandated by law. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-7 

Objective. An objective is a concise target statement of what will be achieved, how much will be 

achieved, when and where it will be achieved, and who is responsible for the work. Objectives are 

derived from goals and provide the basis for determining management strategies. Objectives should 

be attainable and time-specific and should be stated quantitatively to the extent possible. If objectives 

cannot be stated quantitatively, they may be stated qualitatively (Service Manual 602 FW 1.6). 

Obligate Species. Species that require a specific habitat type or plant species for their existence. 

Ocean Acidification. The ongoing decrease in the pH of the Earth’s oceans, caused by their uptake 

of anthropogenic carbon dioxide from the atmosphere. 

Other Benefiting Species. Native species, other than priority resources of concern and focal 

resources, that will benefit from management actions. 

Paleontology. The study of prehistoric life, including organisms’ evolution and interactions with 

each other and their environments. 

Passerine. See songbird 

Pinniped. A suborder of carnivores that are marine mammals, have flippers, and eat mostly fish and 

marine invertebrates (e.g., sea lions, seals). 

Plant Association. A classification of plant communities based on the similarity in dominance of all 

layers of vascular species in a climax community. 

Plant Community. An assemblage of plant species unique in its composition; occurs in particular 

locations under particular influences; a reflection or integration of the environmental influences on 

the site such as soils, temperature, elevation, solar radiation, slope, aspect, and rainfall; denotes a 

general kind of climax plant community (e.g., Sitka spruce). 

Preferred Alternative. This is the alternative determined (by the decision maker) to best: achieve a 

refuge’s purpose(s), vision, and goals; contributes to the Refuge System mission; addresses the 

significant issues; and is consistent with principles of sound fish and wildlife management. 

Priority Resources of Concern. Habitats that are most representative of refuge BIDEH, as well as 

other FWS and ecosystem priorities that were chosen as resources that will guide refuge management 

in the future. See Focal Resources. 

Priority Species. Fish and wildlife species that the Washington Department of Fish and Wildlife 

believe require protective measures and/or management guidelines to ensure their perpetuation. 

Priority species include the following: (1) state listed and candidate species; (2) species or groups of 

animals susceptible to significant population declines within a specific area or statewide by virtue of 

their inclination to aggregate (e.g., seabird colonies); and (3) species of recreational, commercial, 

and/or Tribal importance. 

Public. Individuals, organizations, and groups; officials of Federal, state, and local government 

agencies; Indian tribes; and foreign nations. It may include anyone outside the core planning team. It 

includes those who may or may not have indicated an interest in Service issues and those who do or 

do not realize that Service decisions may affect them. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-8 Appendix I. Glossary and Scientific Names 

Purpose(s) of the Refuge. The purpose of a refuge is specified in or derived from the law, 

proclamation, executive order, agreement, public land order, donation document, or administrative 

memorandum establishing, authorizing, or expanding a refuge, refuge unit, or refuge subunit (Service 

Manual 602 FW 1.6). 

Refuge Goal. See Goal. 

Refuge Purposes. See Purposes of the Refuge. 

Salish Sea. A single estuarine ecosystem that extends from the north end of the Strait of Georgia to 

the west end of the Strait of Juan de Fuca and south to the southern extent of Puget Sound. It 

encompasses the inland marine waters of Southern British Columbia, Canada and northern 

Washington, USA (Freelan 2009). 

Seabird. A group of birds that obtain at least some food from the ocean by traveling some distance 

over its surface. They also typically breed on islands and along coastal areas. Seabirds include: gulls, 

alcids, penguins, albatrosses, storm-petrels, and cormorants, among others. 

Songbirds. (Also Passerines) A category of birds that are medium to small, perching land birds. 

Most are territorial singers and migratory. 

Step-down Management Plans. Step-down management plans provide the details necessary to 

implement management strategies identified in the Comprehensive Conservation Plan (Service 

Manual 602 FW 1.6). 

Strategy. A specific action, tool, or technique or combination of actions, tools, and techniques used 

to meet unit objectives (Service Manual 602 FW 1.6). 

Succession. The observed process of change in the species structure of an ecological 

T-sheet. A historic type of topographic map produced by the U.S. Coast and Geodetic Survey. 

Threatened Species (Federal). Species listed under the Endangered Species Act that are likely to 

become endangered within the foreseeable future throughout all or a significant portion of their 

range. 

Threatened Species (State). A plant or animal species likely to become endangered in Washington 

within the near future if factors contributing to population decline or habitat degradation or loss 

continue. 

Tidelands. Submerged lands and beaches that are located between ordinary high tide and extreme 

low tide. 

Vegetation Type, Habitat Type, Forest Cover Type. A land classification system based upon the 

concept of distinct plant associations. 

Vision Statement. A concise statement of the desired future condition of the planning unit, based 

primarily upon the System mission, specific refuge purposes, and other relevant mandates (Service 

Manual 602 FW 1.6). 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-9 

I.3 Scientific Names 

The following tables contain the common and scientific names of plants and animals that are 

mentioned in this CCP. 

I-1. Common and Scientific Names of Plants Mentioned in this CCP 

Common Name Scientific Name 

American dunegrass Elymus mollis 

American glasswort Salicornia virginica 

Bigleaf maple Acer macrophyllum 

Black knotweed Polygonum paronychia

Bohemian knotweed Polygonum bohemicum

Bull thistle Cirsium vulgare 

Canada thistle Cirsium arvense 

Cattail Typha latifolia 

Caulerpa Caulerpa ssp. 

Cheatgrass Bromus tectorum

Common cordgrass Spartina angelica 

Common eelgrass Zostera marina 

Dalmatian toadflax Linaria dalmatica

Diffuse knapweed Centaurea diffusa 

Douglas-fir Pseudotsuga menziesii ssp. menziesii 

Dull Oregon grape Mahonia nervosa

Dwarf mistletoe Arceuthobium campylopodum

English holly Ilex aquifolium

English ivy Hedera helix 

Evergreen blackberry Rubus laciniatus 

False lily-of-the-valley Maianthemum dilatatum

Field bindweed Convolvulus arvensis 

Garlic mustard Alliaria petiolata 

Grand fir Abies grandis 

Herb Robert Geranium robertianum

Himalayan blackberry Rubus armeniacus 

Japanese eelgrass Zostera japonica 

Japanese knotweed Polygonum cuspidatum 

Large-headed sedge Carex macrocephala

Lawnweed Soliva sessilis 

Meadow knapweed Centaurea jacea x nigra 

Musk thistle Carduus nutans

Oceanspray Holodiscus discolor 

Oxeye daisy Leucanthemum vulgare

Pacific madrone Arbutus menziesii 

Pacific rhododendron Rhododendron macrophyllum

Poison hemlock Conium maculatum

Purple loosestrife Lythrum salicaria

Red alder Alnus rubra 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-10 Appendix I. Glossary and Scientific Names 

Common Name Scientific Name 

Red elderberry Sambucus racemosa ssp. pubens 

Red fescue Festuca rubra 

Russian knapweed Centaurea repens 

Salal Gaultheria shallon 

Salmonberry Rubus spectabilis 

Sargassum Sargassum ssp. 

Scotch broom Cytisus scoparius 

Scotch thistle Onopordum ancanthium 

Sea lettuce Ulva spp

Seashore saltgrass Distichlis spicata var. spicata 

Seaside plantain Plantago maritima ssp. juncoides 

Silver burweed Ambrosia chamissonis 

Slough sedge Carex obnupta 

Spotted knapweed Centaurea maculosa 

Spurge laurel Daphne laureola 

St. Johns wort Hypericum perforatum 

Sword fern Polystichum munitum 

Tansy Ragwort Senecio jacobea 

Western hemlock Tsuga heterophylla 

Western redcedar Thuja plicata 

Yellow sand-verbena Abronia latifolia

Yellow toadflax Linaria vulgaris 

I-2. Common and Scientific Names of Mammals Mentioned in this CCP 

Common Name Scientific Name 

American black bear Ursus americanus

Beaver Castor canadensis 

Black-tailed deer Odocoileus hemionus 

Bobcat Lynx rufus 

Domestic cat Felis catus 

Domestic dog Canis familiaris 

Elk Cervus elaphus

Keen’s myotis Myotis keenii 

Long-eared myotis Myotis evotis 

Long-legged myotis Myotis volans 

Northern elephant seal Mirounga angustirostris 

Nutria Myocastor coypus 

Pacific harbor seal Phoca vitulina 

Short-tailed weasel Mustela erminea

Silver-haired bat Lasionycteris noctivagans

Townsend’s big-eared bat Corynorhinus townsendii 

I-3. Common and Scientific Names of Birds Mentioned in this CCP 

Common Name Scientific Name 

American crow Corvus brachyrhynchos

American wigeon Anas americana
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-11 

Common Name Scientific Name 

Bald eagle Haliaeetus leucocephalus 

Band-tailed pigeon Patagioenas fasciata 

Barrow’s goldeneye Bucephala islandica

Belted kingfisher Megaceryle alcyon 

Bewick’s wren Thryomanes bewickii 

Black oystercatcher Haematopus bachmani 

Black scoter Melanitta nigra 

Black-bellied plover Pluvialis squatarola 

Brant Branta bernicla 

Bufflehead Bucephala albeola 

Bullock’s oriole Icterus bullockii 

Canada goose Branta Canadensis 

Caspian tern Hydroprogne caspia 

Chestnut-backed chickadee Poecile rufescens 

Common goldeneye Bucephala clangula 

Cooper’s hawk Accipiter cooperii 

Double-crested cormorant Phalacrocorax auritus 

Downy woodpecker Picoides pubescens 

Dunlin Calidris alpina 

Glaucous-winged gull Larus glaucescens 

Golden-crowned kinglet Regulus satrapa 

Great blue heron Ardea herodias 

Greater scaup Aythya marila 

Green-winged teal Anas carolinensis

Hairy woodpecker Picoides villosus 

Harlequin duck Histrionicus histrionicus 

Heermann’s gull Larus heermanni 

Hutton’s vireo Vireo huttoni 

Least sandpiper Calidris minutilla 

Lesser scaup Aythya affinis 

Mallard Anas platyrhynchos 

Marbled murrelet Brachyramphus marmoratus 

Merlin Falco columbarius 

Mew gull Larus canus 

Northern harrier Circus cyaneus 

Northern pintail Anas acuta 

Northern saw-whet owl Aegolius acadicus 

Northern shoveler Anas clypeata 

Northwestern crow Corvus caurinus 

Orange-crowned warbler Oreothlypis celata 

Pacific-slope flycatcher Empidonax difficilis 

Pelagic cormorant Phalacrocorax pelagicus 

Peregrine falcon Falco peregrinus 

Pigeon guillemot Cepphus columba 

Pileated woodpeckers Dryocopus pileatus 

Pine siskin Carduelis pinus 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-12 Appendix I. Glossary and Scientific Names 

Common Name Scientific Name 

Red-breasted sapsucker Sphyrapicus ruber 

Rufus hummingbird Selasphorus rufus 

Sanderling Calidris alba 

Sharp-shinned hawk Accipiter striatus 

Short-eared owl Asio flammeus 

Snowy owl Bubo scandiacus 

Spotted towhee Pipilo maculatus 

Steller’s jay Cyanocitta stelleri 

Surf scoter Melanitta perspicillata 

Townsend’s warbler Dendroica townsendi 

Varied thrush Ixoreus naevius 

Western gull Larus occidentalis 

Western sandpiper Calidris mauri 

Western snowy plover Charadrius alexandrinus nivosus 

Whimbrel Numenius phaeopus 

White-winged scoter Melanitta fusca 

Wood duck Aix sponsa 

I-4. Common and Scientific Names of Amphibians Mentioned in this CCP 

Common Name Scientific Name 

American bullfrog Rana catesbeiana

Cascades frog Rana cascadae 

Coastal tailed frog Ascaphus truei 

Cope’s giant salamander Dicamptodon copei 

Ensatina Ensatina eschscholtzii 

Long-toed salamander Ambystoma macrodactylum 

Northwestern salamander Ambystoma gracile 

Olympic torrent salamander Rhyacotriton olympicus 

Pacific chorus frog Pseudacris regilla 

Red-legged frog Rana aurora 

Rough-skinned newt Taricha granulosa

Western red-backed salamander Plethodon vehiculum 

Western toad Bufo boreas

I-5. Common and Scientific Names of Insects Mentioned in this CCP 

Common Name Scientific Name 

Amber spurge flea beetle Apthona flava 

Broad-nosed seed head weevil Bangasternus fausti 

Brown-legged spurge flea beetle Apthona lacertosa 

Bull thistle seed head gall fly Urophora stylata 

Carpenter ant Camponotus spp.

Field bindweed moth Tyta luctuosa 

Field bindweed mite Aceria malherbae 

Foliage beetle Chrysolina hyperici 

Klamath weed beetle Chrysolina quadrigemina 

Knapweed flower head weevil Larinus minutus 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Glossary and Scientific Names I-13 

Common Name Scientific Name 

Knapweed seed head fly Urophora affinis 

Knapweed seed head gall fly Urophora quadrifasciata 

Knapweed weevil Cyphocleonus achates 

Leaf bud gall-forming midge Zeuxidiplosis giardi 

Leaf-feeding flea beetle Altica carduorum Guer

Musk thistle seed head weevil Rhinocyllus conicus 

Musk thistle rosette weevil Trichosirocalus horridus 

Root-boring beetle Agrilus hyperici 

Root-boring/gall beetle Sphenoptera jugoslavica 

Sand-verbena moth Copablepharon fuscum 

Scotch broom seed weevil Apion fuscirostre

Stem-mining weevil Ceutorhynchus litura F

St. Johnswort inchworm Aplocera plagiata 

Sulphur knapweed moth Agapeta zoegana 

Taylor’s checkerspot Euphydryas editha taylori

Thistle gall fly Urophora cardui L

Toadflax defoliating moth Calophasia lunula

Twig-mining moth Leucoptera spartifoliella

I-6. Common and Scientific Names of Fish and Shellfish Mentioned in this CCP 

Common Name Scientific Name 

Bull trout Salvelinus confluentus

Coho salmon Oncorhynchus kisutch 

Chinook salmon Oncorhynchus tshawytscha 

Chum salmon Oncorhynchus keta 

Cutthroat trout Oncorhynchus clarkii 

Dungeness crab Metacarcinus magister 

European green crab Carcinus maenas 

Littleneck clam Protothaca staminea

Pacific herring Clupea pallasii 

Pacific sand lance Ammodytes hexapterus

Pink salmon Oncorhynchus gorbuscha

Steelhead trout Oncorhynchus mykiss 

Surf smelt Hypomesus pretiosus 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

I-14 Appendix I. Glossary and Scientific Names 

Document continues on next page. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. CCP Team Members J-1 

Appendix J. CCP Team Members 

The CCP was developed and prepared primarily by a core team comprised of refuge and regional 

office staff. There was some turnover of regional office staff core team members during the planning 

process. The core team sought technical expertise and review from other professionals both within 

and outside of the Fish and Wildlife Service throughout the CCP process. Extended team members 

provided critical input during wildlife and habitat review early in the process and continued to 

provide review and comment as the document evolved. The List of Preparers below includes the core 

team members as well as other persons responsible for writing specific portions of the plan. Many 

others provided assistance in developing and reviewing the CCP and associated products and in 

providing advice throughout the planning process. These people are captured in the List of Reviewers 

and Advisors. 

Table J-1. List of Preparers 

Name and Title

 

Organization CCP Contributions 

Kevin Ryan, 

Project Leader 

(Retired in 

12/2012) 

Washington Maritime 

National Wildlife 

Refuge Complex, 

USFWS 

Supervision; decision-making; responsible for overall 

coordination and development of the CCP; public 

involvement; writer/reviewer; research/ analysis: 

communication plan; appropriateness findings and 

compatibility determinations; compliance with 

NEPA, ESA, NHPA, etc.; Federal and State agency, 

and Tribal coordination. 

Lorenz Sollmann, 

Deputy Project 

Leader 

Acting Project 

Leader starting in 

1/2013. 

Washington Maritime 

National Wildlife 

Refuge Complex, 

USFWS 

Writer/reviewer: wildlife & habitat goals and 

objectives, affected environment and environmental 

consequences, contaminants, integrated pest 

management plan; research/analysis: invasive species, 

fire management, and habitats; public involvement: 

communication plan, wildlife & habitat review, and 

public meetings. 

Sue Thomas, 

Refuge Biologist 

Washington Maritime 

National Wildlife 

Refuge Complex, 

USFWS 

Writer/reviewer: wildlife & habitat goals and 

objectives, affected environment and environmental 

consequences; research/analysis: priority resources of 

concern, habitats, wildlife, biological integrity, 

diversity, and environmental health; public 

involvement: communication plan, wildlife & habitat 

review, and public meetings. 

Dave Falzetti, 

Refuge Law 

Enforcement 

Officer and Visitor 

Services Manager 

Washington Maritime 

National Wildlife 

Refuge Complex, 

USFWS 

Writer/reviewer: visitor services goals and objectives, 

refuge facilities, sign inventory and maintenance 

plans, regional recreation opportunities and forecasts, 

illegal uses, refuge visitation, and environmental 

consequences; public involvement: communication 

plan and public meetings. 

Sue Mayo, 

Administrative 

Assistant 

Washington Maritime 

National Wildlife 

Refuge Complex, 

USFWS 

Researcher/writer: refuge vision; list of common and 

scientific species names, abbreviations and glossary; 

public involvement: CCP mailing list and public 

meetings. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

J-2 Appendix J. CCP Team Members 

Name and Title

 

Organization CCP Contributions 

Jane Bardolf, 

Conservation 

Planner 

(formerly) Division 

of Planning, Visitor 

Services, and 

Transportation, 

Region 1, USFWS 

CCP Lead Planner (through 8/2011) responsible for 

regional office coordination, and process and policy 

guidance for development of the CCP; CCP schedule 

and status reports; team meeting facilitator; document 

layout, management, and review; planning record; 

public involvement: communications plan. 

Khemarith So, 

Geographer and 

Conservation 

Planner 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

CCP Lead Planner (starting 10/2011) responsible for 

regional office coordination, and process and policy 

guidance for development of the CCP; CCP schedule 

and status reports; team meeting facilitator; document 

layout, management, and review; planning record; 

public involvement: public meetings, scoping 

comments compilation, scoping report. Development 

of working, public involvement, and document maps; 

GIS data gathering and analysis; researcher/ writer: 

physical environment, climate change, environmental 

consequences, wilderness review. 

Virginia Parks, 

Archaeologist 

Division of Natural 

and Cultural 

Resources, Region 1, 

USFWS 

Researcher/writer: cultural resources objectives, 

affected environment, and environmental 

consequences. 

Erin Carver, 

Economist 

Division of 

Economics, 

Washington Office 

Researcher/writer: socioeconomics, environmental 

consequences. 

David Patte, 

Climate Change 

Coordinator 

Science Applications, 

Region 1, USFWS 

Researcher/writer/reviewer: climate change. 

Staci McCorkle, 

Natural Resources 

Scientist 

SWCA 

Environmental 

Consultants 

Writer/editor: wildlife & habitat and visitor services 

goals and objectives, refuge public uses. 

Nicole Garner, 

Writer/Editor 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

Technical edit review of CCP document and Federal 

Register Notices; design and edit of planning updates. 

Kay KierHaggenjos, 

Writer/Editor 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

Technical edit review of CCP document and Federal 

Register Notices; design and edit of planning updates. 

Lara Bjork, 

Technical Editor 

SWCA 

Environmental 

Consultants 

Technical edit review of CCP document. 

Pat Stark, 

Visual Information 

Specialist 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

CCP cover design and print management. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. CCP Team Members J-3 

Table J-2. List of Reviewers and Advisors 

Name and Title Organization CCP Contributions 

Robyn Thorson, 

Regional Director 

Region 1, USFWS Final decision-maker, CCP/EA and Federal 

Register notice approvals.

Robin West, 

Regional Chief of 

Refuges 

National Wildlife 

Refuges, Region 1, 

USFWS 

Major decisions on CCP direction, CCP/EA and 

Federal Register notice approvals. 

Ben Harrison, 

Assistant Regional 

Chief of Refuges 

National Wildlife 

Refuges, Region 1, 

USFWS 

CCP Advisor: policy, appropriateness findings, 

compatibility determinations, environmental 

consequences review.

Bob Flores, 

Refuge Supervisor 

National Wildlife 

Refuges, Region 1, 

USFWS 

Refuge workload assistance; reviewer; decisionmaker.

Bob Peyton, 

Assistant Refuge 

Supervisor 

National Wildlife 

Refuges, Region 1, 

USFWS 

Refuge workload assistance; reviewer; decisionmaker. 

Chuck Houghten, 

Division Chief of 

Planning, Visitor 

Services, and 

Transportation 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

CCP Advisor for planning policy and guidance; 

reviewer; coordination with other divisions and 

Washington Office.

Scott McCarthy, 

Branch Chief of 

Planning 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

CCP Advisor for planning policy and guidance; 

reviewer; planning workload priorities; 

coordination with other divisions. 

Mike Marxen, 

Branch Chief of 

Visitor Services and 

Communication 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

Visitor Services review and guidance design, 

public use goals and objectives; public 

involvement assistance.

Kevin O’Hara, 

Conservation Planning 

Division of Planning, 

Visitor Services, and 

Transportation, 

Region 1, USFWS 

Review of environmental effects analysis.

Joe Engler, 

Assistant Regional 

Refuge Biologist 

Division of Natural 

and Cultural 

Resources, Region 1, 

USFWS 

Development and review of biological goals 

and objectives and biological integrity, 

diversity, and environmental health analysis. 

Bridgette FlandersWanner, Assistant 

Regional Refuge 

Biologist 

Division of Natural 

and Cultural 

Resources, Region 1, 

USFWS 

Development and review of biological goals 

and objectives and biological integrity, 

diversity, and environmental health analysis. 

Brian Root, 

Zone Inventory and 

Monitoring Biologist 

Nisqually National 

Wildlife Refuge 

Complex, USFWS 

Wildlife and habitat review. 

Bill Ritchie, 

Refuge Biologist 

Willapa National 

Wildlife Refuge 

Complex, USFWS 

Habitat assessment of Dawley Unit for 

suitability for marbled murrelet. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

J-4 Appendix J. CCP Team Members 

Name and Title Organization CCP Contributions 

Cathy Sheppard, 

Division Chief, Realty 

and Refuge 

Information (retired) 

Division of Realty and 

Refuge Information, 

Region 1, USFWS 

Advice on realty issues; CCP review. 

Wayne Hill, 

Branch Chief, Realty 

Division of Realty and 

Refuge Information, 

Region 1, USFWS 

Advice on realty issues; CCP review. 

Joan Jewett, 

External Affairs 

External Affairs, 

Region 1, USFWS 

News release review and distribution. 

Greg Hagedorn, Fire 

Management Officer 

Region 1, USFWS Advice on fire management. 

Pat Gonzales-Rogers, 

Tribal Liaison 

External Affairs, 

Region 1, USFWS 

Identification of and coordination with Indian 

Tribes. 

Anita McMillan, 

Biologist 

WDFW WDFW contact for CCP coordination (local). 

Mick Cope, 

Regional Wildlife 

Program Manager 

WDFW WDFW contact for CCP coordination (Region 

6). 

Greg Schirato WDFW WDFW contact for CCP coordination and 

comment (Headquarters office). 

Don Kraege WDFW WDFW contact for CCP coordination and 

comment (Headquarters office). 

Shelly Ament, 

Wildlife Biologist 

WDFW WDFW contact for CCP coordination (local). 

Peter Dunwiddie, 

Botanist 

University of 

Washington 

Wildlife and habitat review. 

Susan Piper, 

Wildlife Supervisor 

Olympic National 

Forest, USFS 

Wildlife and habitat review. 

Chris Dowling, 

Silviculturalist 

Olympic National 

Forest, USFS 

Wildlife and habitat review. 

Curtis Tanner, 

Fish and Wildlife 

Biologist 

Western Washington 

Fish and Wildlife 

Office, USFWS 

Advice on wildlife and habitat. 

Scott Chitwood, 

Natural Resources 

Director 

Jamestown S’Klallam 

Tribe 

Tribal consultation. 

Ron Thom, 

Ecologist 

Battelle National 

Laboratory 

Advice on eelgrass. 

Roger Peters, 

Fisheries Biologist 

Western Washington 

Fisheries Office, 

USFWS 

Preliminary assessment of refuge reach of Dean 

Creek for salmonids. 

Brian Turner, 

District Manager 

WDNR Advice on forest management. 

Hugh Shipman, 

Coastal Geologist 

WDOE Advice on bluff and beach management. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Public Involvement K-1 

Appendix K. Public Involvement 

Public involvement was sought throughout the development of the CCP, starting in April 2011 with 

the preparation of a Communications Plan. Public involvement strategies included face-to-face 

meetings or phone conversations with community organizations, local, state and federal agencies, 

elected officials (or their aides), Tribal representatives, and local refuge users. For the broader public, 

the Refuge also held open houses and provided planning updates intended to inform, invite 

discussion and solicit feedback. The Refuge also maintains a website where CCP information can be 

found and where the public could print out comment forms or submit emails during the scoping 

phase, preliminary draft alternatives, or draft CCP/EA comment period. 

A mailing list of approximately 512 persons and organizations is maintained at the Refuge and was 

used to distribute planning updates and public meeting announcements. Below is a brief summary of 

the events, meetings, and outreach tools that were used in our public involvement efforts. 

Meetings with Elected Officials and/or their Aides: 

 December 12, 2011. Met with Judith Morris, legislative aide for Congressman Norm Dicks, 

6th District. 

 November 9, 2012. Met with Alex Fastle, legislative aide for Senator Patty Murray. 

 December 12, 2012. Met with State Representative Kevin Van De Wege, 24th Legislative 

District. 

Meetings with Federal Agency Representatives: 

 April 14, 2011. Met with William Ritchie, USFWS Wildlife Biologist, Willapa NWR to 

assess habitat suitability in the Dawley Unit for marbled murrelet. 

 July 18, 2011. Met with Roger Peters, USFWS Fisheries Biologist, Western Washington Fish 

and Wildlife Office to preliminary assess Dean Creek for salmonids and schedule formal 

assessment. 

 December 12, 2011. Met with Karen Gustin, Superintendent, Olympic National Park. 

Meetings with Tribal Representatives: 

 December 8, 2011. Met with Jamestown S’Klallam Tribe. 6 participants. 

Meetings/Contacts with State Agency Representatives: 

 May 10, 2011. CCP Coordination Meeting with Don Kraege and Greg Schirato, Washington 

Department of Fish and Wildlife. 

 November 9, 2011. Phone conversation with Brian Turner, Washington Department of 

Natural Resources. Discussed CCP and planning process with emphasis on Dawley Unit 

forest and adjacent WDNR forest habitats. 

 March 30, 2012. Personal communication with follow-up e-mail with Hugh Shipman, 

Coastal Geologist with Washington Department of Ecology. Sandy bluffs, barrier beach and 

inventory and monitoring goals and objectives were reviewed from a coastal geological 

perspective. January 24, 2012. E-mail from Anita McMillan, WDFW, regarding review of 

preliminary goals and objectives. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

K-2 Appendix K. Public Involvement 

Meetings with Multiple Agency Workgroups or Committees: 

 January 11, 2012. Made a public announcement at the Dungeness River Management Team 

monthly meeting about the upcoming public meeting on the draft alternatives. There were 33 

participants, including representatives from North Olympic Land Trust, Jamestown 

S’Klallam Tribe, Dungeness Beach Association, Clallam County, Sports Fisheries, Clallam 

Conservation District, Protect the Peninsula’s Future, City of Sequim, Riverside Property 

Owners, WDOE, USFS, Water Users Association, PUD#1, WDFW, StreamKeepers, OPAS, 

Clallam County Environmental Health, Olympic Park Associates, Sequim Gazette, 

Dungeness River Audubon Center staff, and people from general public. 

 January 25, 2012. Sent a follow-up email message to all on the Dungeness River 

Management Team general email list about the rescheduled public meeting for the draft 

alternatives. This was necessary as the original meeting had a very low turnout due to a snow 

storm. 

 March 1, 2012. Made an announcement to the Clean Water Working Group members 

concerning the draft CCP/EA and that the Refuge would appreciate if they could review this 

document when it comes out in the spring. There were 9 participants, including 

representatives from Clallam county, Jamestown S’Klallam Tribe, Clallam Conservation 

District, and private citizens. 

Meetings with Non-government Organizations: 

 October 31, 2011. Met with Olympic Peninsula Audubon Society. 9 participants. 

Notice to Refuge Volunteers: 

 April 8, 2011. New and returning Dungeness NWR Volunteers were given a presentation on 

the CCP process, alternatives being considered, and how they could get involved and offer 

input. 97 participants. 

 Prior to the public open houses, all refuge volunteers were provided with the Preliminary 

Draft Alternatives and invited to the public meetings. 130 people. 

Workshops / Field Review: 

 February 7-8, 2011. Wildlife and Habitat Management Field Review on the Refuge. 11 

participants, including representatives from the Washington Department of Fish and Wildlife, 

U.S. Forest Service, and University of Washington. 

Public Open Houses/Scoping Sessions: 

 January 19, 2012. Public Preliminary Draft Alternatives meetings at the Sequim Prairie 

Grange Hall, Sequim, WA. 

Purpose and format: To provide information on CCP process and preliminary draft 

alternatives. The public meeting was in an open-house format. At the open house, refuge staff 

explained the CCP process and progress to date; refuge purposes, and management; 

preliminary draft alternatives; and future opportunities for public input. The public was 

invited to submit comments either in writing or verbally. The attendees then had the 

opportunity to visit tables staffed by refuge staff and the lead planner. Each table had a scribe 

to record verbal comments. 

Attendance: A total of 5 private citizens and representatives from various organizations 

attended the open houses, providing comments on the issues and opportunities presented. 

 February 2, 2012. Public Preliminary Draft Alternatives meetings at the Dungeness 

Schoolhouse, Sequim, WA. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Public Involvement K-3 

Purpose and format: To provide information on CCP process and preliminary draft 

alternatives. The public meeting was in an open-house format. At the open house, refuge staff 

explained the CCP process and progress to date; refuge purposes, and management; 

preliminary draft alternatives; and future opportunities for public input. The public was 

invited to submit comments either in writing or verbally. The attendees then had the 

opportunity to visit tables staffed by refuge staff and the lead planner. Each table had a scribe 

to record verbal comments. 

Attendance: A total of 28 private citizens and representatives from various organizations 

attended the open houses, providing comments on the issues and opportunities presented. 

U.S. Fish and Wildlife Service Coordination: 

The core planning team coordinates frequently within the agency during the planning process. The 

core team also relies on specialists from various Service programs for their expertise. Additional 

coordination occurs with the Regional Office Management at key phases in the process including: 

R1, Pacific Regional Office Management Reviews 

 Preplanning Briefing meeting – April 14, 2011 

 Alternative Briefing meeting – November 1, 2011 

 Administrative Draft Briefing meeting – May 10, 2012 

Planning Updates: 

 October 2011. Hardcopies of Planning Update 1 mailed to approximately 320 persons, 

organizations, and officials on the mailing list and additional updates were hand delivered to 

R1 FWS staff. Throughout scoping, Planning Update 1 was provided to refuge office visitors 

and partners and mailed to interested parties. Planning Update 1 included background 

information on the Refuge, refuge purposes, preliminary issues, vision, goals, land status 

map, and a mail-in comment form with the following questions: 

o What do you see as the primary issues that need to be addressed in the 

Comprehensive Conservation Plan? 

o What are your thoughts on the visions and goals for Dungeness National Wildlife 

Refuge? 

o Do you have additional comments at this time? 

 January 2012. Hardcopies of Planning Update 2 mailed to approximately 350 persons, 

organizations, and officials on the mailing list and additional updates were hand delivered to 

R1 FWS staff. Planning Update 2 was also provided to refuge office visitors, partners, and 

attendees of the January 19, 2012 and February 2, 2012 public meetings. Planning Update 2 

included a summary of public scoping comments, a summary of Preliminary Draft 

Alternatives, information on the open house meetings, and contact information. 

 November 2012. Hardcopies of Planning Update 3 mailed to approximately 372 persons, 

organizations, and officials on the mailing list and additional updates were hand delivered to 

R1 FWS staff. Planning Update 3 was also made available at the refuge office for visitors and 

partners. This update announced the availability of draft CCP/EA for public review and 

comment, provided information on how and where to comment, and detailed the different 

draft management alternatives. 

 Planning Update 4, announcing the completion of the final CCP, will be released 

concurrently with this document. This planning update will summarize comments received 

on the draft CCP/EA, detail the Refuge’s management direction, and provide information on 

how and where to obtain copies of the final plan. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

K-4 Appendix K. Public Involvement 

Press Coverage: 

 Fall 2011. Refuge staff sent a news release to local media and made follow up contacts. 

Various notices of CCP scoping period were printed in the Peninsula Daily News, News 

Tribune, Bellingham Herald, and Port Angeles Daily News. 

 Winter 2012. Refuge staff sent a news release to local media and made follow up contacts. 

Various articles and notices of preliminary draft alternatives were printed in the Sequim 

Gazette. 

 November 28, 2012. Refuge staff sent a news release to local media announcing the 

availability of the draft CCP/EA for public review and comment. The news release resulted 

in articles in the following media. This list is not inclusive: 

o November 28, 2012 Sequim Gazette (No more running, riding near spit?) 

o November 30, 2012 Peninsula Daily News (Proposal would ban horses, jogging on 

Dungeness Spit) 

 December 7, 2012. Refuge staff sent a news release to local media announcing the extension 

of the draft CCP/EA public comment period to January 28, 2013. The news release resulted 

in articles in the following media. This list is not inclusive: 

o December 12, 2012 Sequim Gazette (Comment period extended for Dungeness 

Wildlife Refuge plan) 

 January 14, 2013. Refuge staff sent a news release to local media announcing the extension 

of the draft CCP/EA public comment period to February 28, 2013, providing a total of 90 

days for public review and comment. 

 Other press coverage related to the Dungeness NWR draft CCP/EA included the following: 

o December 25, 2012 Peninsula Daily News (Sequim lawmaker fights to keep horses in 

wildlife refuge) 

o December 26, 2012 Sequim Gazette (Van De Wege says state may reclaim spit) 

o January 2, 2013 The Port Townsend Leader (Van De Wege works for access to 

Dungeness Spit) 

o January 20, 2013 Peninsula Daily News (Lawmaker, Audubon forge proposed deal to 

keep some jogging, horses at Dungeness refuge) 

o January 27, 2013 Peninsula Daily News (Dungeness Spit deal sought) 

o February 8, 2013 Peninsula Daily News (Record number listens to phone-in town hall 

forum) 

Other Tools: 

 Website at http://www.fws.gov/pacific/planning/main/docs/WA/Dungeness/ featuring CCP 

information and scoping forms. 

Federal Register Notices: 

 October 4, 2011. Federal Register published Notice of Intent to prepare a comprehensive 

conservation plan and environmental assessment, and included background information on 

the Refuge and preliminary issues with request for scoping comments. 

 November 19, 2012. Federal Register published Notice of Availability of the Draft 

Comprehensive Conservation Plan and Environmental Assessment; and request for 

comments. 

 Federal Register Notice of Availability of the Final Comprehensive Conservation Plan and 

Finding of No Significant Impact for Environmental Assessment published concurrently with 

release of this document. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-1 

Appendix L. Public Comments and Service Responses 

L.1 Introduction 

The U.S. Fish and Wildlife Service (USFWS or Service) received comments from 183 entities during 

the 90-day public comment period held November 28, 2012 through February 28, 2013 for the 

Dungeness National Wildlife Refuge (NWR or Refuge) Draft Comprehensive Conservation Plan and 

Environmental Assessment (CCP/EA). All written comments were reviewed, analyzed, and 

addressed. A summary of the comments and our response is presented in this appendix. 

Each original piece of correspondence was identified with the commenter’s last name and first initial 

and a number. Note that for simplicity’s sake, we use the word “letter” to refer to any comment or 

reference document we received, whether by letter, phone call, or e-mail. Multiple correspondences 

from a commenter are counted as one comment letter. 

To help us analyze the comments, a number of themes and subthemes were identified within the 

letters, and similar comments were grouped together under a theme. Our responses apply to the 

comments grouped under a theme. Comments that fell outside the scope of the CCP were also 

considered and responded to as appropriate. 

L.2 Changes Made to the Final CCP 

The CCP planning team reviewed and evaluated all of the comments we received during the Draft 

CCP/EA comment period. In some cases, the management direction was either modified or clarified 

based on the comments. Table L-1 shows the major changes between the draft and final CCPs. For 

additional information, see Chapter 2 and Figure 2-1 in the CCP. 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

HABITAT MANAGEMENT 

Mixed-coniferous Forest 

Forest 

management 

within Dungeness 

Unit 

- Invasive species removal. 

- Use fire suppression techniques to prevent catastrophic 

wildfire. 

- Clear downed or overhanging branches across the public use 

trails that are hazards. 

- Enhance the effectiveness of the main trail firebreak by 

removing dead and downed materials within 10 feet of either 

side of the trail; keep live and large woody debris >21 inches 

DBH and snags. 

No change from draft plan. 

Forest 

management 

within Dawley 

Unit 

- Continue invasive species removal and fire suppression. 

- Conduct forest assessment. 

- Develop step-down forest management plan by 2018. 

- Use various techniques such as, but not limited to snag 

creation, thinning, and prescribed fire to enhance forest 

structure within core 40-acre area. 

- Remove small dump site. 

No change from draft plan. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-2 Appendix L. Public Comments and Service Responses 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

Roads within 

Dawley Unit 

- Conduct road inventory and condition assessment by 2016. 

- Maintain main road for regular vehicles up to turnaround (0.95 

mile), beyond that maintain for ATV only. 

- Slide stabilization, where needed. 

- Rehabilitate unneeded logging spur roads (0.58 mile) outside 

of 40-acre core area. 

No change from draft plan. 

Nearshore Habitats 

Multiple habitats - Rapid response in accordance with the Strait of Juan de Fuca 

Geographic Response Plan. 

- Collect and maintain information needed by the response team 

for resource protection. 

- Periodically review/update Geographic Response Plan. 

- Increase staff participation in deployment drills. 

- Work with partners (WA Dept. of Ecology, oil spill response 

groups) on validating deployment locations and techniques 

within Refuge lands. 

No change from draft plan. 

Oil spill and 

contaminants 

Sandy bluff 

habitat 

- Maintain public use closure. 

- Use IPM to control invasive species. 

- Coordinate with partners (e.g., State, County, and Tribes) to 

prevent or reduce shoreline armoring, especially to the west of 

Dungeness NWR. 

- Restrict further development within 150 feet of the bluff on 

Refuge lands. 

No change from draft plan. 

Barrier beach 

habitat 

- Seasonal public use closures. 

- Regular removal of marine debris. 

- Prohibition of driftwood collection 

- Fire suppression. 

- Rapid response in accordance with the Strait of Juan de Fuca 

Geographic Response Plan. 

- IPM for invasive species control. 

- Work with partners to remove marine debris and creosotecovered logs in adjacent marine areas, off-Refuge, and increase 

removal in closed areas. 

- Monitor environmental changes caused by climate change 

stressors (e.g., accelerated erosion due to sea level rise and/or 

increased frequency and severity of storm events, driftwood 

recruitment and retention). 

No change from draft plan. 

Mudflat and 

barrier lagoon 

- Monitor and if found, remove invasive species (e.g., Spartina) 

using IPM techniques. 

- Monitor for European green crab. 

- Seasonal public use closures. 

- Coordinate with partners (e.g., Clean Water Working Group) 

to monitor and address water quality issues within Dungeness 

Bay and Harbor. 

- Rapid response in accordance with the Strait of Juan de Fuca 

Geographic Response Plan. 

- Removal of marine debris. 

- Monitor environmental factors that are climate change related 

stressors (e.g., sedimentation, ocean acidification, salinity). 

- Remove abandoned USCG road access dike located at base of 

spit if determined to be on Refuge lands. 

No change from draft plan. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-3 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

Eelgrass Beds - Coordinate with partners (e.g., Clean Water Working Group) 

to monitor and address water quality issues within Dungeness 

Bay and Harbor. 

- Coordinate with oil spill response team. 

- Monitor for European green crab. 

- Monitor environmental factors that are known stressors. 

- Work with partners to determine adaptive management 

techniques to address stressors (e.g., climate change, 

sedimentation, excessive nutrients). 

No change from draft plan. 

Salt marsh - Monitor and if found, remove invasive species (e.g., Spartina) 

using IPM techniques. 

- Public use closure. 

- Fire suppression. 

- Rapid response in accordance with the Strait of Juan de Fuca 

Geographic Response Plan. 

- Removal of marine debris and creosote-covered logs. 

- Monitor environmental factors that are known stressors (e.g., 

sedimentation, ocean acidification, salinity, vegetation 

community, driftwood recruitment and removal). 

No change from draft plan. 

Freshwater Wetlands 

Seasonal 

freshwater 

wetlands on the 

Dawley and 

Dungeness units 

- Conduct wetland inventory and hydrological assessment by 

2015. 

- Conduct migratory bird, amphibian, and bat surveys. 

- Use IPM to control invasive species. 

Same as Draft CCP/EA but 

with the following 

clarification: Conduct 

amphibian and bat surveys. 

Instream and 

riparian habitat 

- Slope stabilization of main road. 

- Partner with upstream land owners to improve and protect 

water quality. 

- Conduct hydrological assessment by 2015. 

- Conduct survey and assess habitat suitability for anadromous 

and resident fish. 

- Use IPM to control invasive species. 

No change from draft plan. 

Freshwater 

impoundment on 

Dawley Unit 

- Maintain water delivery system to impoundment. 

- Maintain water level for use in fire suppression. 

- Clear woody vegetation from dike. 

- Conduct hydrological assessment of relationship between 

impoundment and domestic water source. 

- Map bathymetry of impoundment. 

- Conduct amphibian and bat surveys. 

- Install new water control structure and water gage. 

- Maintain minimum water levels and manage for optimum 

water levels/benthic layer characteristics for amphibians. 

- Manage vegetation and downed woody debris along waterline. 

- Use IPM to control invasive species (e.g., bullfrogs and 

nonnative fish). 

No change from draft plan. 

Monitoring and Research 

Status monitoring 

(Surveys) 

- Continue or expand bird counts (Christmas Bird Count, 

FeederWatch, Mid-winter Waterfowl Survey) and monitoring 

for invasive plants, European green crab, marine debris. 

- Conduct Breeding Bird Survey (BBS). 

- Determine frequency and monitor the distribution and 

densities of common eelgrass on the Refuge. 

Same as Draft CCP/EA with 

the following clarifications: 

- Continue or expand bird 

counts (Christmas Bird 

Count, Mid-winter 

Waterfowl Survey) and 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-4 Appendix L. Public Comments and Service Responses 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

monitoring for invasive 

plants, European green crab, 

marine debris. 

- Conduct breeding bird 

surveys. 

Research - Caspian tern colony productivity. 

- Sediment dynamics at the base of Dungeness Spit. 

- Large woody debris monitoring in the Elwha nearshore. 

- Assess the value of salt marsh habitat on Graveyard Spit as a 

nursery area for crab, salmon, etc. 

- Assess driftwood recruitment and removal rates within the 

barrier beach and salt marsh habitats. 

- Plot and monitor microhabitat characteristics (e.g., species, 

percent cover) to track changes in distribution and diversity of plant 

species in the Graveyard Spit RNA. 

- Assess climate change impacts on natural spit habitats such as 

Dungeness Spit. 

No change from draft plan. 

Effectiveness 

Monitoring 

- Monitor CCP and other step down plan objectives. No change from draft plan. 

Scientific 

Assessments 

- Conduct amphibian and bat surveys. 

- Follow-up assessment of the distribution and abundance of 

Lepidopterans on Graveyard and Dungeness spits. 

- Assess the number of breeding pairs of gull colony at the tip of 

Graveyard Spit. 

- Conduct survey and assess habitat suitability for anadromous 

and resident fish. 

- Conduct wetlands inventory (Dawley Unit) and hydrological 

assessment (Dawley and Dungeness units) by 2015. 

- Conduct road inventory and condition assessment (Dawley 

Unit) by 2016. 

No change from draft plan. 

PUBLIC USE 

Human-caused Wildlife Disturbance 

Aircraft 

disturbance 

- Federal Aviation Administration 2,000 foot Above Ground 

Level flight recommendation over national wildlife refuges. 

No change from draft plan. 

Refuge Foot Access – Open and Closed Areas 

Open areas: upland 

trails, strait-side of 

Dungeness Spit 

from west Refuge 

boundary to 

lighthouse (Zones 

1, 2, and 3). 

- Foot access only, sunrise to sunset. No change from draft plan. 

Seasonal open 

areas: uplands and 

tidelands in the 

first 1⁄2 mile of the 

Spit’s harbor side 

(Zone 2). 

- Foot access only May 15-September 30, sunrise to sunset. No change from draft plan. 

Temporary 

Closures 

- Close portions of high use areas when seal pups present. No change from draft plan. 

Closed areas: 

upland forest 

- Closed to public use. No change from draft plan. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-5 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

(except on 

established trails), 

bluffs, Graveyard 

Spit (Zone 4), end 

of Dungeness Spit 

(Zone 4), and bayand harbor- side of 

Dungeness Spit 

(Zone 4), and 

Dawley Unit 

Refuge Motorized and Nonmotorized Boat Access – Open and Closed Areas 

Boat access – 

landings 

- Allowed by advance reservation at designated lighthouse boat 

landing zone only. 

- Limited to 20 boat landings per day. 

- Boat landing limited to 9am-5pm. 

No change from draft plan. 

Boat access –

Refuge waters 

(tideland areas 

east and west of 

Graveyard Spit in 

Zone 5) 

- Open to boating May 15-September 30, sunrise to sunset. 

- No wake zone in all Refuge waters. 

- Boats must stay 100 yards from the mean high tide line. 

- Refuge waters closed to personal watercraft, windsurfing, and 

para-surfing/sailing. 

No change from draft plan. 

Boat buffers, nonRefuge waters - Boaters are encouraged to stay at least 100 yards from the 

mean high tide line. 

No change from draft plan. 

Visitor Orientation 

Staff and volunteer 

time devoted to 

making visitor 

contacts on the 

Refuge 

- Increase staff time to 520 hours per year and volunteer time to 

1,200 hours per year. 

No change from draft plan. 

Orientation 

materials 

- Tear sheet maps available at main and primitive trail 

entrances. Panel maps located at county park kiosk, entrance 

station, primitive trail entrance, base of main trail, and 

lighthouse boat landing area. 

- Add information and map panels at Cline Spit boat launch and 

Dungeness Landing boat launch 

- Develop trail etiquette materials including brochure and 

signage 

Same as Draft CCP/EA but 

with the following 

clarification: Tear sheet 

maps available at main trail 

entrance. Panel maps 

located at entrance station, 

base of main trail, and 

lighthouse boat landing area. 

Regulation Signs - Signs at closed areas (permanent): bluffs; bay-side of spit at 1⁄2 

mile to lighthouse; across end of spit at lighthouse; north side of 

trail adjacent to parking lot. 

- Signs at closed areas (seasonal): harbor-side of spit to 1⁄2 mile; 

boundary pilings in bay. 

- International symbol signage at: main and primitive trail 

entrance stations; bluffs 

- Additional signs at lighthouse, lighthouse boat landing area, 

and end of Dungeness Spit. 

No change from draft plan. 

Wildlife-dependent Uses 

Wildlife 

Observation and 

Photography 

- Unstructured opportunities to observe and photograph wildlife 

along approximately 1 mile of trails (including main, primitive 

and bluff trails) and on approximately 5.5 miles of beach (Zones 

1, 2, and 3). 

- Offer at least 5 guided wildlife walks and/or programs. 

No change from draft plan. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-6 Appendix L. Public Comments and Service Responses 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

Fishing - Permitted on Strait-side of spit and seasonally in boat access 

areas (Zones 1, 2, 3, and 5). 

- Install map/regulations panel at Cline Spit and Dungeness 

Landing. 

- Partner with WDFW to include Refuge-specific information in 

State sport fishing rules pamphlet. 

No change from draft plan. 

Shell-fishing - Permitted seasonally on Refuge tidelands in Dungeness 

Harbor and Bay up to 100 yards from the mean high tide line in 

zone 5 and in all foot access tideland areas (first 1⁄2 mile of Spit, 

zone 2). 

- Install map and regulations panel at Cline Spit and Dungeness 

Landing. 

- Partner with WDFW to include Refuge-specific information in 

State sport fishing rules pamphlet. 

No change from draft plan. 

Interpretation – 

biological 

- Maintain kiosk panel, trail panel, and overlook panels (6 

panels) and Refuge brochures. 

- Use volunteers and subject-matter experts for interpretive programs. 

- Present 1 interpretive program per year. 

- Provide 2 guided plant walks and/or programs annually. 

- Improve wildlife interpretive displays at lighthouse. 

- Incorporate Refuge-specific climate change information into at 

least 1 interpretive product. 

No change from draft plan. 

Interpretation – 

geological 

- Kiosk panel, trail panel, overlook panel (1 panel). 

- Use trained and expert volunteers to provide interpretive 

information. 

- Present 1 interpretive program per year. 

- Provide 1 guided geology program annually. 

No change from draft plan. 

Environmental 

Education 

- Continue to allow the Refuge to be used by others as an 

outdoor classroom. 

- Hire education specialist and offer programs to primary and 

secondary level school groups on and off the Refuge. 

- Increase partnerships. 

No change from draft plan. 

Other General Public Uses 

Beach use - Recreational beach use allowed from west Refuge boundary to 

the first 1⁄2 mile of the spit (Zone 1 and Strait-side of Zone 2). 

No change from draft plan. 

Horseback riding - Not appropriate, therefore not allowed. See Appendix A, 

Appropriate Use Findings. 

- Allowed on west beach 

(Zone 1) with stipulations, 

if an alternate access route 

is developed. 

- Daily, October 1-March 

31; and weekdays, April 1-

September 30. 

- No horseback riding on 

Memorial Day, the Fourth 

of July, and Labor Day. 

- Horses must walk (no 

trotting, cantering, or 

galloping). 

- Party size is limited to no 

more than 4 horses. 

- Pedestrians have right-ofway. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-7 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

Jogging - Not appropriate, therefore not allowed. See Appendix A, 

Appropriate Use Findings. 

- Allowed on west beach 

(Zone 1) and trail adjacent 

to the parking lot only. Not 

allowed on Dungeness Spit 

(Zones 2 and 3) and upland 

trails. 

- Monitor for repeated 

patterns of violations. If 

found, then will reevaluate 

compatibility. 

Cultural Resources Interpretation and Education 

Interpretation – 

New Dungeness 

Light Station and 

maritime history 

- Continue to partner with NDLSA to provide interpretation. 

- Continue to allow motorized access for keeper exchanges and 

facility maintenance. 

- Maintain human history panel in Refuge entrance kiosk. 

- Acquire New Dungeness Light Station properties when 

excessed by the U.S. Coast Guard and enter into formal 

agreement with NDLSA on management. 

Same as Draft CCP/EA but 

with the following 

clarification: 

- Continue to partner with 

USCG and NDLSA to 

provide interpretation. 

Interpretation – 

Native American 

history and 

culture 

- Maintain human history interpretive panel in Refuge entrance 

kiosk and displays in lighthouse. 

- Provide at least 1 interpretive product or program per year. 

- Partner with Tribe(s) to provide at least 1 Native American 

cultural program per year. 

No change from draft plan. 

Cultural Resources Protection,Preservation, and Evaluation 

Preservation - 

cultural resources 

- Identify archaeological sites that coincide with existing and 

planned roads, facilities, public use areas, and habitat projects. 

- Conduct systematic documentation and evaluation of historic 

buildings. 

- Evaluate threatened and impacted sites and structures for 

eligibility to the National Register of Historic Places. 

- Develop a GIS layer for cultural resources that can be used 

with other GIS layers for the Refuge, yet contains appropriate 

locks to protect sensitive information. 

- Develop partnerships with the Tribes for cultural resources 

inventory, evaluation, and project monitoring, consistent with 

the regulations of the National Historic Preservation Act. 

Same as Draft CCP/EA but 

also: 

- Continue to coordinate 

with USCG to allow Aids 

to Navigation maintenance 

personnel motorized access 

for lighthouse servicing 

and repair. 

Native American 

Graves Protection 

and Repatriation 

Act (NAGPRA) 

- Identify Native American Tribes, Groups, and direct lineal 

descendants that may be affiliated with Refuge lands. 

- Open consultation process with affiliated Tribes, Groups, and 

direct lineal descendants. 

- Develop procedures to follow for intentional and inadvertent 

discoveries. 

- Identify persons to contact for the purposes of NAGPRA 

compliance. 

No change from draft plan. 

Community Outreach 

Festivals and 

other public 

events 

- Attend at least 3 events per year. No change from draft plan. 

Community 

presentations 

- Deliver at least 5 presentations per year about the Service and 

Washington Maritime NWRC. 

No change from draft plan. 

Refuge website - Routinely upgrade and improve content. Add links to partners’ 

and other resources. 

No change from draft plan. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-8 Appendix L. Public Comments and Service Responses 

Table L-1. Summary of Changes to Management Direction between the Draft and Final CCPs 

Key Theme/issue Alternative B in Draft CCP Management Direction in 

Final CCP 

Media outreach - Increased coordination with media sources to improve the 

accuracy and content of Refuge-related articles. 

- Publish at least 2 local articles per year. 

- Target select media articles toward boating and aviation 

communities. 

No change from draft plan. 

Volunteer 

Program 

- Continue to work with Friends group. 

- Conduct 7 beach clean-ups per year. 

- Provide up to 4 full-time volunteer hosts. 

- Provide additional volunteer trainings. 

No change from draft plan. 

Illegal Uses 

Pets, bicycles, 

resource 

collecting, fires, 

discharging 

firearms, after 

hours trespass 

including 

camping, kite 

flying, ball 

playing, fireworks 

and Frisbees. 

- Maintain and increase law enforcement patrols. 

- Maintain regulation information panels and signage. 

- Continue to use staff, volunteers, and trail rovers to inform 

visitors. 

- Replace regulatory and guidance signage at lighthouse boat 

landing zone and end of Dungeness Spit. 

No change from draft plan. 

L.3 Summary of Comments Received and Service Responses 

Wildlife and Habitat Management 

1. Comment: Implement projects to maintain and/or restore the ecological integrity of the 

Refuge, through integrated management techniques guided by sound science such as those 

proposed for the forested habitats. 

Response: We appreciate the support for the proposed monitoring and management 

strategies. We agree that an integrated management approach is the most scientifically sound 

way to manage the Refuge, particularly in forested habitats. These habitats, on the edge of the 

nearshore environment, serve as a buffer from floodwaters, provide nutrient enrichment of 

aquatic environments in the outflow, and increase the biodiversity of the Refuge and 

nearshore environment as a whole.

2. Comment: Ban fire suppression techniques on the Refuge.

Response: The overall objectives for fire management on the Refuge Complex, as described 

in the Fire Management Plan completed in 2004 (USFWS 2004), are to promote a program 

that provides for firefighter and public safety, reduces the occurrence of human-caused fires, 

and ensures an appropriate suppression response capability to meet expected wildland fire 

complexity. Fire suppression techniques used on the Refuge are intended to prevent 

catastrophic wildfire and to promote the retention of driftwood and vegetation on the barrier 

beaches. Suppression tactics and strategies to be implemented are intended to minimize longterm impacts of suppression actions. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-9 

Within the Refuge’s forested habitats, the Service recognizes that historically natural 

disturbance regimes, including fire, wind throw, and flooding, helped to maintain a mosaic of 

mature to old-growth habitat with variable age classes of appropriately sized snags. Under the 

CCP, we will promote the development of old-growth forest characteristics. Strategies that 

could help return stands to historical densities and provide gaps in the canopy for accelerating 

the growth of the remaining trees include thinning and prescribed fire. A step-down forest 

management plan to be completed by 2018 will provide additional details on the use of 

silviculture practices. Fire suppression techniques will be used to prevent a stand replacement 

fire that would return the area to an early successional stage. 

Within the barrier beaches on Refuge lands, driftwood serves an important role in stabilizing 

the upper portion of the beach by holding sediments in place, particularly during storm events 

that coincide with high tides. Native strand plants act in the same manner as driftwood within 

the more protected strand portion of this habitat type. Fire suppression techniques are 

important for retaining these key structural components. 

3. Comment: The Refuge should not engage in invasive species removal.

Response: Throughout the CCP, the terms pest and invasive species are used interchangeably 

because both can prevent/impede achievement of Refuge wildlife and habitat objectives 

and/or degrade environmental quality. Service policy (569 FW 1) defines pests as “invasive 

plants and introduced or native organisms that may interfere with achieving our management 

goals and objectives on or off our lands, or that jeopardize human health or safety.” 

Department of the Interior policy (517 DM 1) defines an invasive species as “a species that is 

nonnative to the ecosystem under consideration and whose introduction causes or is likely to 

cause economic or environmental harm or harm to human health.” 

Introduced invasive plants (e.g., common cordgrass, Dalmatian toadflax, cheatgrass, etc.) are 

an issue within some of the nearshore habitats. Major invasive weeds that have invaded 

Refuge upland habitats include Bohemian knotweed, English holly, spurge laurel, Canada 

thistle, Scotch broom, and English ivy. More recently, Herb Robert has been found in several 

small patches of the Dawley Unit, along the upper most reaches of the main road (<1/4 acre). 

Many of these invasive plant species can directly out-compete native plant species by 

reducing light at the ground level and aggressively capturing water and nutrients. They also 

have the potential to affect food webs and alter ecosystem processes. Invasive marine 

invertebrates with high reproductive capacity and wide environmental tolerances are also 

threats to Refuge resources. For example, European green crabs prey on native Dungeness 

crabs, reduce populations of native clams, and outcompete native invertebrates for food 

resources where they have become established. 

The control of nonnative and invasive species on the Refuge is proactive and receives high 

management priority. The targets for control on the Refuge have primarily been plants (e.g. 

English ivy, English holly, and Dalmatian toadflax) although the Refuge’s integrated pest 

management (IPM) program also applies to animal species. 

Decisions to use particular tools and techniques, and the criteria for their use to control 

invasive species, are based on numerous factors and considerations (e.g., the particular 

species being targeted, associated natural history characteristics, proximity to sensitive 

resources and nontarget species, etc.). While the CCP provides overall direction and priority 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-10 Appendix L. Public Comments and Service Responses 

for the control of invasive species, naming specific treatments for the variety of possible 

problems would be premature. IPM is an interdisciplinary approach, utilizing various 

methods to prevent, eliminate, contain, and/or control pest species in concert with other 

management activities on Refuge lands and waters to achieve wildlife and habitat 

management goals and objectives. Considering refuge objectives and the ecology of pest 

species, once a pest species population reaches a threshold, one or more methods would be 

selected that are feasible, efficacious, and most protective of non-target resources, including 

native species (fish, wildlife, and plants), Service personnel, Service-authorized agents, 

volunteers, and the public.

4. Comment: Continue current inventory and monitoring programs. Data developed from these 

programs should be released or made accessible in a timely manner.

Response: The Service acknowledges the support for continuing current Refuge inventory 

and monitoring programs. We are committed to using sound science in decision-making and 

providing the public with information of the highest quality possible. Under Goal 4, we will 

emphasize continuing and expanding our efforts to conduct high-priority inventories, 

surveys, research, and assessments. Funding, staffing, and the Refuge Complex’s information 

needs priorities will dictate which surveys can be accomplished in any given year. Upon 

completion of survey efforts and data analysis, summary results will be available on the 

Refuge’s website, currently under development. Data collected by Refuge staff in support of 

larger projects (e.g., Christmas Bird Count and Birdathon) are sent immediately to compilers 

after the survey is completed. 

The Service is instituting data standards to improve the quality and compatibility of its data. 

This approach will increase opportunities to share data and reduce incidents of redundant 

data development. Federal agencies are required to publish guidelines for ensuring the 

quality, objectivity, utility, and integrity of the information we use and disseminate, and to 

provide mechanisms for allowing the public to seek correction of that information. In order to 

ensure the quality and credibility of the scientific information the Refuge uses to make 

decisions, the Service has implemented a formal “peer review” process for influential 

scientific documents following the Office of Management and Budget’s memorandum “Final 

Information Quality Bulletin for Peer Review” (available online at 

www.whitehouse.gov/sites/default/files/omb/memoranda/fy2005/m05-03.pdf). 

5. Comment: Provide access to the Dawley Unit and publicly accessible areas of Dungeness 

Spit for volunteer surveys of biological resources.

Response: The Refuge staff receives periodic requests from non-Service entities (e.g., 

universities, state or territorial agencies, other Federal agencies, nongovernmental 

organizations) to conduct research, scientific collecting, and surveys on Refuge lands. Access 

to the Refuge, including the Dawley Unit, for biological surveys is provided for under a 

special use permit if the use is appropriate and compatible. For more information on 

stipulations, see the appropriate use finding (Appendix A) and compatibility determination 

(Appendix B) for research, scientific collecting, and surveys. 

As discussed in Chapter 2, Objective 7.2, we will continue to engage Refuge volunteers in 

survey activities, including the Olympic Peninsula Audubon Society Christmas Bird Count 

and others, which occur in part on the Dawley Unit.
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-11 

General Public Use Management 

6. Comment: The Refuge should embrace a more user-friendly welcoming and multiple use 

philosophy.

Response: Dungeness NWR is managed as part of the National Wildlife Refuge System 

within a framework provided by legal and policy guidelines. The needs of wildlife and their 

habitats come first on Refuges, in contrast to other public lands that are managed for multiple 

uses. With few exceptions, lands and waters within the Refuge System are different from 

multiple-use public lands in that they are closed to all public access and use unless 

specifically and legally opened. No Refuge use may be allowed or continued unless it is 

determined to be appropriate and compatible. Generally, an appropriate use contributes to 

fulfilling the refuge’s purposes, the Refuge System mission, or goals and objectives described 

in a refuge management plan. A compatible use is a use that in the sound professional 

judgment of the refuge manager will not materially interfere with or detract from the 

fulfillment of the mission of the Refuge System or the purposes of the refuge. Further, each 

individual refuge must evaluate appropriateness and compatibility as it applies to their lands. 

For more information on appropriateness and compatibility, see Appendices A and B. For 

more information on the various Federal laws, executive orders, international treaties, Service 

policies, and refuge purposes that guide Dungeness NWR management, see Chapter 1. 

Public use activities determined to be appropriate and compatible on the Refuge include 

saltwater fishing, shell-fishing (clams and crabs), wildlife observation, wildlife photography, 

hiking, no-wake boating, jogging, horseback riding (should alternative access be obtained per 

compatibility determination), beach use (wading, picnicking, sunbathing, other recreational 

beach uses), environmental education, and environmental interpretation. In providing these 

public uses, the Refuge staff and volunteers strive to make visitors feel welcomed and 

oriented. The objectives and strategies under Goals 5 through 7, in particular, were developed 

to enhance the visitor experience. 

7. Comment: The Dawley Unit should be opened to wildlife observation.

Response: To protect wildlife resources, the Dawley Unit is closed to public uses. No public 

facilities exist or are planned. The Olympic Discovery Trail is adjacent to the northern 

portion of the unit. The southern forested portion has no trail connectivity and does not 

provide a unique visitor experience from other publicly accessible lands within the area. 

Wildlife Observation, Photography, Environmental Education, and 

Interpretation 

8. Comment: Expand and enrich wildlife observation, photography, environmental education, 

and interpretation programs. Increasing Refuge staff, including hiring an education and 

outreach coordinator and increasing volunteer time, should be a priority.

Response: The Service acknowledges the support for the Refuge’s proposed goals, 

objectives, and strategies to provide high quality wildlife observation, photography, 

environmental education, and interpretation opportunities. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-12 Appendix L. Public Comments and Service Responses 

Boat Landing Access 

9. Comment: Boat landing hours at the designated zone directly south of the New Dungeness 

Light Station should be available from sunrise to sunset.

Response: The designated boat landing area on the beach directly south of the New 

Dungeness Light Station is intended to facilitate visitation of the lighthouse; it is not intended 

to be an entry point to the Refuge. Areas adjacent to the landing are closed to reduce wildlife 

disturbance. The lighthouse is open to visitation from 9am to 5pm daily; consequently, boat 

landings at the designated landing area are limited to the same times. This restriction is not 

intended to apply to the U.S. Coast Guard (USCG) or others during emergencies or other 

coordinated activities. For more information see Chapter 2, Objective 5.2 and Chapter 5, 

Section 5.5.2.

10. Comment: Develop additional clarifications (e.g., maps, signs) regarding the regulations for 

boat landing access, including the reservation system.

Response: Strategies under Objectives 5.1, 5.2, and 5.3 include replacing existing signage at 

the Cline Spit and Dungeness Landing boat launches with new Refuge maps and regulations 

panels. New regulatory and guidance signage will be also installed at the lighthouse boat 

landing area. Additionally, under Objective 7.1, Refuge staff will specifically conduct 

outreach to the boating community in order to improve communication and promote 

understanding and awareness of Refuge resources and regulations. 

Vehicle Use 

11. Comment: Prohibit the use of vehicles on Dungeness Spit; it causes more wildlife 

disturbance than other public uses. 

Response: In comparison with other public uses, some research has suggested that certain 

wildlife species are less likely to be flushed or swim away from slow moving vehicles than 

from pedestrians (e.g., Klein 1993, Holmes et al. 1993, Pease et al. 2005). Nevertheless, the 

Service recognizes the potential for vehicle use on Dungeness Spit to disturb wildlife and 

wildlife-dependent recreation. 

At Dungeness NWR, the extent of impacts from vehicle use of the beach varies by season. 

During the daylight summer months, seal pups on the beach may be trampled, and resting 

shorebirds and gulls displaced. Compatible wildlife-dependent activities such as wildlife 

watching, photography, and environmental education may be negatively affected because of 

the expected responses by wildlife to vehicles approaching or passing by. When wildlife react 

by moving away from vehicles or alter behavior by hiding, they are less likely to be observed 

(Bennett and Zuelke 1999). During the winter season when vehicle use on the beach occurs at 

night to coincide with winter low tide events, impacts to Refuge wildlife resources will be 

minimized but will include resting shorebird and gull displacement. Impacts to marine 

mammals will be minimal and might affect molting elephant seals. Impacts to Refuge visitors 

will be negligible as the Refuge is open only during daylight hours. 

The use of vehicles is necessary, however, to accomplish management objectives, including 

but not limited to removing marine debris, maintenance of signage, inventory and 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-13 

monitoring, and emergency and law enforcement response. Often these activities require the 

use of a vehicle (e.g. removal of marine debris, emergency response) or are restricted to a 

particular tidal range (e.g. shorebird surveys) which necessitates use of a vehicle to complete 

the activity during daylight or working hours. Additionally, vehicles are used by the New 

Dungeness Light Station Association (NDLSA) to perform lighthouse keeper exchanges and 

to transport work parties when maintenance needs dictate. 

In order to reduce potential disturbances to wildlife or wildlife-dependent public use, the 

Service strives to minimize vehicle use on Dungeness Spit. The stipulations necessary to 

ensure the compatibility of allowing the NDLSA to use vehicles on the beach are also 

instituted as Refuge best management practices. Refuge staff members and NDLSA 

volunteers will adhere to practices, such as a speed limit, to minimize impacts to wildlife and 

Refuge visitors. Furthermore, for research, scientific collecting, and survey activities on the 

Refuge, vehicles will be thoroughly cleaned to prevent the introduction and spread of pests. 

See Appendix B for compatibility determinations for research, scientific collecting, surveys, 

and vehicle access to the New Dungeness Light Station. 

12. Comment: Consider boat access to provision the lighthouse, instead of driving a vehicle 

along the spit. 

Response: The safe movement of people and supplies necessary to maintain and interpret the 

New Dungeness Light Station is best accomplished by allowing vehicle access via the beach 

at low tides. Weather patterns in the Strait of Juan de Fuca often result in strong westerly 

winds, and rough water, making access by boat unpredictable and hazardous. Disturbance 

and other impacts to wildlife and Refuge visitors from allowing vehicle access will be 

negligible, with the stipulations identified in the Compatibility Determination in Appendix B. 

Horseback Riding 

13. Comment: The Service received comments in favor of no longer allowing horseback riding 

on the Refuge, and in favor of continuing horseback riding on the Refuge. Comments in 

favor of continuing to allow horseback riding follow. 

 The Service falsely concluded that horseback riding is an inappropriate use of the Refuge. 

 The CCP failed to identify and consider all reasonable alternatives, which is a violation 

of the National Environmental Policy Act. 

 The perceived safety risks created by potential user conflicts between horseback riders 

and pedestrians can be reduced to acceptable levels. 

Response: Horseback riding is not one of the six priority wildlife-dependent public uses 

identified in the National Wildlife Refuge System Administration Act as amended. In order 

for horseback riding to be allowed on the Refuge, it must first be determined to be 

appropriate in accordance with the Service’s Appropriate Refuge Uses Policy (603 FW 1) 

and then compatible per the Compatibility Policy (603 FW 2). In the Draft CCP/EA, the 

Service preliminarily determined that horseback riding was an inappropriate use of the 

Refuge and should not be allowed due to safety concerns and user conflicts. 

The Service is obligated to review serious incidents in the interest of providing safe Refuge 

access. In May 2012 a serious injury accident occurred involving a pedestrian and a horse 

and its rider on a section of steep trail—approximately 500 linear feet—leading to the Spit. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-14 Appendix L. Public Comments and Service Responses 

Investigators determined that there is an unacceptable level of risk involved in continuing to 

allow pedestrians and horseback riding on that steep section of trail in its current 

configuration. The situation is complicated by high and unpredictable levels of pedestrian 

use, and the absence of places for pedestrians to step off the trail when horses are 

encountered mid-trail. The average trail slope is approximately 8 percent, with a minimum 

trail slope of 5.4 percent and maximum of 10 percent. The average cross-slope (i.e., slope 

perpendicular to the trail) is approximately 3.5 percent with a minimum of 0.4 percent and a 

maximum of 5.9 percent. The trail width ranges from 8 feet to 10 feet. On one side of the 

trail, there is a steep drop-off down a bluff. On the other side, there is a steep incline. From 

May through September, the main trail receives approximately 50,000 visitors. It is not 

unusual to have 600 visitors per day during the summer, and more than 900 visitors on very 

busy days (USFWS 2012b). 

The National Environmental Policy Act (NEPA) directs the Service to analyze a range of 

reasonable alternatives. The Council for Environmental Quality (CEQ) has defined 

reasonable alternatives as those that are economically and technically feasible, and that show 

evidence of common sense. Alternatives that cannot resolve the need for action and fulfill the 

stated purpose in taking action to a large degree, are eliminated as unreasonable. 

Unreasonable alternatives may be those that are unreasonably expensive; that cannot be 

implemented for technical or logistic reasons; that do not meet mandates; or that are 

inconsistent with Refuge purposes or management objectives. 

The Service evaluated all of the comments and suggestions received on our proposal to 

discontinue horseback riding for feasibility and consistency with Refuge management 

objectives. This reevaluation resulted in the revision of the appropriate use finding, 

compatibility determination, and management direction for horseback riding. The Service has 

determined that horseback riding is an appropriate and compatible use of the Refuge, when 

conducted in certain locations and in accordance with specific stipulations. The locations 

follow; for additional information on the stipulations, see Appendix B. 

 The Service will allow horseback riding on the beach west of the point where the main 

trail meets Dungeness Spit (Zone 1), if a safe and legal alternate access route can be 

obtained from the west or from the east. 

 If an alternate access route is obtained from the east then horseback riding on the 

administrative road will be allowed, from the gate between Refuge lands and private 

lands to the beach. 

Under one possible scenario for implementing the stipulations, individuals or groups could 

work with private landowners and seek their own safe and legal access route to the Refuge. 

Alternatively, the Service would need to acquire additional Refuge lands through fee or 

easement acquisitions or cooperative agreements. Service policy for adding land to a refuge 

is to work with landowners within a refuge’s approved boundary who are willing participants 

in such acquisitions and agreements. The Service would work with partners to assess land 

conservation priorities within the area, and identify possible additions to the approved refuge 

boundary. 

The Service also reviewed the following suggestions submitted during the Draft CCP/EA 

comment period regarding changes to the trail or changes to the use of the trail. 

 Build a separate trail. 

 Install railings in various configurations. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-15 

 Require riders to dismount and walk horses. 

 Require self-registration. 

 Install traffic guides, signals, or sight mirrors. 

 Install signs and institute protocols. 

 Use volunteer flaggers. 

 Separate the hours of trail operation for pedestrians and equestrians. 

 Provide both pedestrian and equestrian uses in separate areas. 

The Service thoroughly evaluated each of the suggestions above. Modifications to the current 

trail (e.g., widening), or the construction of a bypass for the steep hill section, or the 

construction of a separate equestrian trail for beach access via refuge lands are considered 

impractical due to technical and logistical challenges. As such, the costs to construct and 

maintain such options would be prohibitive. The Service does not currently own other lands 

where a separate equestrian trail could be feasible. Installing railings would not adequately 

resolve safety issues associated with horse and pedestrians using the same trail or would 

prove impractical due to trail width limitations. Unsafe conditions persist whether riders 

dismount and walk horses or ride their horses when co-mingling with pedestrians. Regarding 

self-registration, should alternate access to the Refuge for horses be developed, the Service 

intends to streamline the reservation and permit process based on the specific access location 

and may install a horse-only fee station or require all riders to obtain a permit by phone or in 

person. Other suggestions would not achieve the desired result or ensure compliance, or 

would require substantial amounts of staff time to implement and thus would be infeasible to 

implement with the limited number of staff at the Refuge. Since each of the above 

suggestions was either not feasible to implement or would not achieve the desired result, 

none of the above suggestions were included as part of the program for allowing horseback 

riding on the Refuge. 

14. Comment: Horseback riding has no or very little impact to wildlife compared to impacts 

from other user groups. 

Response: Many public uses, including horseback riding, cause some disturbance to wildlife 

that varies by season. The 150 foot approach distance offered by Owen (1973) is consistent 

with observations suggesting that riders observing wildlife can approach wildlife at closer 

distances than through other forms of travel. However, any form of approach is expected to 

cause some disturbance, which will vary according to the species affected, the season and 

time of day, and the type, level, frequency and duration of the disturbance. The extent of 

impacts from horseback riding on the west beach (Zone 1) would vary by season. During the 

summer months seal pups on the beach and bluff-nesting guillemots may be disturbed, and 

resting shorebirds and gulls displaced. During the winter months gulls and shorebirds may be 

disturbed and displaced. However, overall, disturbances on the beach to the west of where the 

main trail meets the spit are expected to result in minor impacts to resident wildlife and other 

Refuge users, due to the low volume and seasons of use. More information on the potential 

impacts to wildlife from horseback riding is available in Appendix B. 

15. Comment: Horseback riding should be allowed to facilitate accessibility to the Refuge. 

Response: When necessary and when compatible with resource management objectives, we 

may make exceptions to general access restrictions for visitors with disabilities to facilitate 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-16 Appendix L. Public Comments and Service Responses 

their experience. However, public safety concerns along a 500-linear-foot section of trail to 

the beach preclude horseback access via this route. 

Jogging 

16. Comment: Comments regarding jogging and wildlife disturbance follow. 

 Jogging causes wildlife disturbance on the Refuge. 

 Jogging does not appear to be as much of a threat to wildlife compared to other public 

uses. 

 Disturbance to wildlife from jogging has not been observed by some visitors. 

Response: In general, responses by wildlife to recreational activity can range from 

behavioral changes including nest abandonment and food habits, physiological changes such 

as elevated heart rates due to flight, or even death (Knight and Cole 1995). The long-term 

effects are more difficult to assess but may include altered behavior, vigor, productivity, or 

death of individuals; altered population abundance, distribution, or demographics; and altered 

community species composition and interactions. Knight and Cole (1991) found that wildlife 

responses to human disturbance include avoidance, habituation, and attraction. The 

magnitude of the avoidance response may depend on a number of factors including the type, 

distance, movement pattern, speed, and duration of the disturbance, as well as the habitat 

type, time of day, time of year, and weather; the animal’s access to food and cover, energy 

demands, and reproductive status (Knight and Cole 1991, Gabrielsen and Smith 1995). For 

more information on the general impacts of recreation on wildlife see Appendix B. 

Jogging, more specifically, can impact normal wildlife behavioral activities, including 

feeding, reproducing, and social behaviors. Studies have shown that waterfowl and 

shorebirds are sensitive to jogging activity (Burger 1981, Burger 1986). Rapid movement by 

joggers is more disturbing to wildlife, than slower moving hikers (Bennett and Zuelke 1999, 

Burger 1981). Because wildlife use the same areas as joggers for feeding and resting, it is 

likely that joggers would be moving directly toward wildlife. This type of activity would 

cause an increase in disturbance since research has shown that a direct approach is more 

disturbing to wildlife than movement away from or at an oblique angle (Knight and Cole 

1991). 

Although the impacts of jogging, as conducted on Dungeness NWR, have not been studied in 

detail, impacts have been reported from Refuge staff, volunteers and visitors including 

wildlife disturbance on the forested trail and beach, and conflicts between user groups. 

Jogging can impact marine mammal, passerine, shorebird, waterfowl and other migratory 

bird populations feeding and resting on the beach, bluff, or near trails. The extent of impacts 

from jogging to Refuge wildlife would vary by season. For example, during the summer 

months seal pups on the beach may be disturbed and resting shorebirds and gulls displaced. 

17. Comment: We received comments regarding allowing or not allowing jogging on the 

Refuge. Comments supported Alternative A, the no action alternative, and Alternative B, as 

described in the Draft CCP/EA. Additionally, suggestions for modified jogging alternatives 

included but were not limited to the following. 

 Allow jogging along the trail parallel to the parking lot. 

 Close jogging on Dungeness Spit and on the upland trails, and continue to allow jogging 

along the west beach (Zone 1) below the bluffs. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-17 

 Continue to allow jogging on the upland trails. 

 Identify seasonal jogging closures or time restrictions. 

Response: The comments and suggestions received by the Service on the Draft CCP/EA 

related to discontinuing jogging resulted in a reevaluation and subsequent revision of the 

appropriate use finding, compatibility determination, and management direction for jogging. 

The studies cited for jogging (Appendix B) show that public use activities can and do disturb 

wildlife. Based on the circumstances described in the scientific literature as well as reports 

from staff, volunteers and visitors, similar effects are occurring on Dungeness NWR. A 

primary concern in allowing any public use on Dungeness NWR is to maintain adverse 

impacts within acceptable limits. Korschgen and Dahlgren (1992) and Fox and Madison 

(1997) state the importance of providing disturbance-free food reserves and areas, as a 

management alternative to minimize human disturbances. The Refuge has several areas 

which are removed from human activity and support high use by aquatic birds and marine 

mammals including Graveyard Spit and the tip of Dungeness Spit. 

Although jogging is not a wildlife-dependent use of the Refuge as defined by statute (16 

U.S.C. 668dd et seq.), it is likely that some joggers observe and enjoy wildlife while on the 

Refuge. Therefore, jogging will be allowed during daylight hours, on the trail adjacent to the 

parking lot and on the west beach only (Zone 1). These areas receive less overall wildlife use 

compared to other sections of the Refuge, and conflicts with other visitors, primarily engaged 

in wildlife-dependent activities, will be limited. Therefore, we anticipate the impacts on 

wildlife and wildlife-dependent public use from jogging in these areas to be minor. 

The west beach area is immediately adjacent to cliffs, bluffs, and open water, and receives 

less wildlife use compared to Dungeness Spit, in part, because the spit is adjacent to intertidal 

flats, eelgrass beds, salt marsh, and open water. The composition and spatial arrangement of 

habitats surrounding the spit make it more valuable to wildlife and more vulnerable to 

impacts from human disturbance. 

Jogging will not be allowed on the forested trails leading down to the beach because the 

higher speed of joggers, combined with short sight distances on confined wooded trails, 

creates unsafe conditions for both joggers and other Refuge visitors. Special running events 

and team training will not be allowed because group size increases wildlife response to 

disturbance (Geist et al. 2005, Yosef 2000), and group events can cause conflicts with other 

visitors on confined wooded trails. Restricting group size to a maximum of 3joggers and 

educating the public on the effects of recreation on wildlife and habitat, will further reduce 

impacts to wildlife and conflicts with other Refuge visitors. There are public lands nearby, 

including Clallam County’s Dungeness Recreation Area adjacent to the Refuge, that provides 

an extensive trail system appropriate for this activity. 

18. Comment: How will the Service define jogging and enforce restrictions on that activity? 

How is walking fast and running different from jogging? 

Response: In general, jogging is aerobic running and is defined as an activity designed to 

increase physical fitness. Typically, joggers run for an extended period and distance with 

their primary purpose being exercise. Jogging differs from walking or hiking in speed even 

when the intention is physical exercise. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-18 Appendix L. Public Comments and Service Responses 

The Service views the management direction for jogging described in this CCP as a relatively 

minor change to what is currently allowed on the Refuge and intends to gain voluntary 

compliance through public education. The Service does not intend to single out this activity 

for additional enforcement beyond current levels. We will work with the jogging community 

to achieve compliance. Nonetheless, engaging in the activity outside of the areas identified in 

the CCP and compatibility determination would be a violation of Refuge regulations as 

defined in Chapter 50 of the Code of Federal Regulations, Part 26, and would be considered a 

misdemeanor offense. Violators may be subject to revocation of their Refuge entry permit, or 

issuance of a warning notice or a federal notice of violation. 

Enforcement of regulations and imposed fines may minimize visitor disturbance to wildlife 

(Knight and Gutzwiller 1995). If a pattern of violation is demonstrated which results in 

jogging becoming a noncompatible activity (i.e. wildlife disturbance or impacts on wildlifedependent public use) it will be reevaluated and may be eliminated. 

Law Enforcement 

19. Comment: Violators, including joggers and bike riders, may not be aware that they are 

breaking the law. The Service should improve and add additional signage that includes 

information on the usage rules, explanations on why certain activities are not allowed, and 

penalties for noncompliance. 

Response: One of the primary goals of public education is the achievement of voluntary 

compliance with Refuge regulations which are designed to minimize wildlife disturbance and 

promote visitor safety. This goal will be achieved by utilizing a variety of techniques 

including but not limited to signage, publications, personal contact, education and 

interpretation presentations, internet based information sites, and media outlets. Strategies 

identified in Objective 5.3 utilize many of the above techniques and range from improved 

signage to increased volunteer and staff commitments to expanded outreach. The Service 

remains committed to continuously evaluating, replacing, and improving signage. For more 

information on the implementation of sign changes and improvements, see Appendix H, Sign 

Inventory and Maintenance Plan. 

The Service is careful not to overwhelm visitors with excessive regulatory signage; therefore, 

we utilize a variety of information tools including personal contact from staff and volunteers, 

a website, and publications. Despite these efforts, we are aware that some visitors will 

inadvertently or purposefully miss such information. It is incumbent upon Refuge users to 

obtain the required entrance permit and to comply with Refuge regulations. Failure to comply 

with Refuge regulations defined in Chapter 50 of the Code of Federal Regulations can subject 

violators to revocation of their Refuge entry permit and/or issuance of a warning notice or a 

federal notice of violation. Extreme violations can result in arrest and imprisonment. 

Volunteer Program 

20. Comment: Expand opportunities for citizen science volunteers to engage in Refuge 

programs and increase their value to the Refuge as identified in Alternative B.

Response: The Service recognizes the importance of working with volunteers to carry out 

some of the tasks associated with Refuge management (e.g., inventory and monitoring, 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-19 

invasive species control, and interpretation). The work of citizen scientists is particularly 

valued as evidenced by the many citizen science projects supported by Refuge staff 

including: Christmas Bird Count, Birdathon, COASST, Project FeederWatch, PTMSC 

Plastics Project, Purple Martin nest box project, amphibian surveys, pigeon guillemot burrow 

counts, and green crab surveys. Under Objective 7.2, the Service plans to continue to recruit, 

train, retain, and utilize volunteers for these and other projects. 

Outreach 

21. Comment: Outreach to local organizations and media should be a central part of the 

Refuge’s education and interpretation programs. 

Response: Much has been done in recent years to improve interpretive programs and signage 

on the Refuge; however, the Service recognizes that much more can be done to educate 

Refuge visitors and the public about the value of the National Wildlife Refuge System and 

the specific resources found on Dungeness Refuge. The strategies under Objective 7.1 are 

intended to guide increased media and local community outreach. 

22. Comment: In cooperation with partner agencies, the Refuge should create comprehensive 

maps showing recreational opportunities on all public lands in the vicinity of the Refuge. 

Response: The CCP includes comprehensive public use maps for Refuge lands (Figure 2-2); 

however, we agree that a comprehensive area map of recreational opportunities would be a 

valuable tool. We would offer our input to other agencies, organizations, or individuals if 

such an effort occurs, but a larger role is not feasible due to staffing and funding limitations. 

Staffing 

23. Comment: Additional permanent staffing for the Refuge is needed. 

Response: The Service appreciates the support for additional staffing (i.e., Environmental 

Education/Visitor Services Specialist) to implement the programs detailed within the CCP. 

Because Refuge staff and funding resources are limited, the Refuge will also partner with 

other organizations to enhance education and recreation opportunities. 

Dawley Unit Management 

24. Comment: In order to free up management capacity to focus on other efforts at the Refuge, 

the Dawley Unit should be transferred to another agency (e.g., Washington State Parks). 

Response: As referenced in Chapter 2, the Service plans to work with other agencies or 

conservation organizations to pursue cooperative management of the Dawley Unit. However, 

the ability of other agencies or conservation organizations to commit towards cooperative 

management is likely contingent upon budget availability. 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-20 Appendix L. Public Comments and Service Responses 

New Dungeness Light Station 

25. Comment: The Service should coordinate directly with the U.S. Coast Guard (USCG) 

regarding potential acquisition of the lighthouse property, the proposal to remove the road 

access dike at the base of Dungeness Spit, preservation of cultural resources, and signage. 

Response: The USCG District 13 has been on the Service’s CCP distribution list since the 

beginning of the CCP process. Additional USCG points of contact were added upon request. 

During implementation of the CCP, we will continue to coordinate with the USCG on issues 

of mutual interest including but not limited to those mentioned above. Further language and 

clarifications have been added to the CCP in Chapters 2 and 5, to reflect this intent. 

26. Comment: Figure 1-3 should show USCG withdrawal jurisdiction over the New Dungeness 

Light Station. The lighthouse property is not within the Service fee title area as the Service 

only has an overlapping withdrawal, not full administrative jurisdiction. 

Response: Figure 1-3 within the final CCP has been edited to include the USCG withdrawal 

jurisdiction over the New Dungeness Light Station. 

27. Comment: The Service should continue to allow the USCG motorized access to the 

lighthouse as appropriate (e.g., site cleanup, large-scale historic preservation, emergency, or 

aids to navigation servicing and repair projects). 

Response: The restrictions on boat landing access on the Refuge within Objective 5.2 are 

intended for the general public and do not apply to the USCG or others during emergencies 

or other coordinated activities. Further language and clarifications have been added to the 

CCP in Chapter 2, in order to reflect this intent. 

Planning Process 

28. Comment: The Service should extend the public comment period for the Draft CCP/EA. 

Response: Originally, the Service released the Draft CCP/EA for a 30-day public review and 

comment period starting on November 28, 2012 and ending December 27, 2012. On 

December 7, 2012, the Service announced an extension of the comment period to January 28, 

2013. On January 14, 2013, the Service extended comment period to February 28, 2013, 

providing a total of 90 days for public review and comment. 

29. Comment: The Service should hold public meetings on the Draft CCP/EA. 

Response: Public involvement has been encouraged throughout CCP development. Public 

involvement strategies included face-to-face meetings or phone conversations with 

community organizations; local, state, and federal agencies; elected officials or their aides; 

Tribal representatives; and local Refuge users. For the broader public, we held open houses 

and provided planning updates to inform, invite discussion, and solicit feedback. We held 

four public open house meetings in Sequim, Washington, on January 19 and February 2, 

2012, to inform the public about our preliminary draft alternatives, which included proposals 

to prohibit jogging, and stipulations for horseback riding on the Refuge. Following the 

release of the Draft CCP/EA, the public comment period was extended to 90 days to give the 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. Public Comments and Service Responses L-21 

public more opportunities to review and comment. Summaries of the events, meetings, and 

outreach tools used in our public involvement efforts are provided in Appendix K. 

Outside of the Scope of the CCP 

30. Comment: Many comments were submitted regarding camping, hunting, and other uses 

occurring on the adjacent Dungeness Recreation Area. 

Response: The 216-acre Dungeness Recreation Area (DRA), located to the south of the 

Refuge, is owned by Clallam County and managed by its Parks, Fair, and Facilities 

Department. Since the DRA is not part of Dungeness NWR, issues and concerns related to 

DRA management are outside of the scope of this CCP. The Service will continue to 

coordinate with Clallam County regarding the trailhead parking lot and public restroom lease 

as well as other areas of mutual interest such as invasive species management. 

The DRA and the Refuge have different purposes and mandates. Public uses and amenities 

offered at the DRA include: picnic sites, year-round camping, hiking, biking, horseback 

riding, and other recreation opportunities. Pets on leash are allowed in the park (Clallam 

County Parks 2012a). Hunting has been discontinued as of January 2013. 

 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

L-22 Appendix L. Public Comments and Service Responses 
Dungeness National Wildlife Refuge Comprehensive Conservation Plan 

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M-30 Appendix M. References Cited 

U.S. Department of the Interior

U.S. Fish & Wildlife Service

Dungeness National Wildlife Refuge

715 Holgerson Road

Sequim, WA 98382

Phone: 360/457 8451

Fax: 360/457 9778

http://www.fws.gov

National Wildlife Refuge System Information

1 800/344 WILD

October 2013

The mission of the U.S. Fish & Wildlife Service

is working with others to conserve, protect, and

enhance fish, wildlife, and plants and their habitats

for the continuing benefit of the American people.

Front Cover Photos

Dungeness Spit. ©Long B. Nguyen

Black oystercatcher. Dow Lambert/USFWS

Brant. ©Dow Lambert

Bufflehead. ©Dow Lambert