Shell Keys National Wildlife Refuge 

Comprehensive Conservation Plan 

U.S. Department of the Interior 

Fish and Wildlife Service 

Southeast Region 

October 2008 
Shell Keys National Wildlife Refuge 
COMPREHENSIVE CONSERVATION PLAN 

SHELL KEYS NATIONAL WILDLIFE REFUGE 

IBERIA PARISH, LOUISIANA 

U.S. Department of the Interior 

Fish and Wildlife Service 

Southeast Region 

Atlanta, Georgia 

September 2008 
Shell Keys National Wildlife Refuge 
Table of Contents i

TABLE OF CONTENTS 

COMPREHENSIVE CONSERVATION PLAN 

EXECUTIVE SUMMARY ....................................................................................................................... 1

I. BACKGROUND ................................................................................................................................. 3

Purpose And Need For The Plan .................................................................................................3

Fish and Wildlife Service .............................................................................................................. 3

National Wildlife Refuge System .................................................................................................. 4

Legal and Policy Context .............................................................................................................. 6

National and International Conservation Plans and Initiatives ..................................................... 7

Relationship To State Wildlife Agency .......................................................................................... 9

II. REFUGE OVERVIEW ...................................................................................................................... 11

Introduction ................................................................................................................................. 11

Shell Keys Refuge History and Purpose .................................................................................... 11

Special Designations .................................................................................................................. 13

Ecosystem Context ..................................................................................................................... 13

Overview ........................................................................................................................... 13

Lower Mississippi River Ecosystem (LMRE) ..................................................................... 15

Texas Gulf Coast Ecosystem (TGCE) .............................................................................. 15

Regional Conservation Plans and Initiatives .............................................................................. 15

Gulf Coast Joint Venture (Mississippi River Coastal Wetlands Initiative) ......................... 16

North American Waterbird Conservation Plan .................................................................. 16

United States Shorebird Conservation Plan ...................................................................... 16

Coastal Wetlands Planning, Protection and Restoration Act ............................................ 16

Coast 2050 - Towards a Sustainable Coastal Louisiana .................................................. 17

Louisiana Coastal Area Ecosystem Restoration Plan ....................................................... 17

Fisheries Vision for the Future .......................................................................................... 17

Louisiana Comprehensive Wildlife Conservation Strategy (Wildlife Action Plan) .................. 18

Ecological Threats and Problems ...............................................................................................18

Erosion and Contamination ............................................................................................... 19

Global Warming and Sea Level Rise ................................................................................ 19

Physical Resources .................................................................................................................... 20

Climate .............................................................................................................................. 20

Geology and Topography .................................................................................................. 20

Hydrology and Water Quality ............................................................................................ 21

Air Quality .......................................................................................................................... 21

Biological Resources .................................................................................................................. 21

Habitat ............................................................................................................................... 21

Wildlife ...............................................................................................................................22

Cultural Resources ..................................................................................................................... 22

Socioeconomic Environment ...................................................................................................... 22

Refuge Administration and Management ................................................................................... 23

Land Protection and Conservation .................................................................................... 23

Oil and Gas Activity ........................................................................................................... 24

Visitor Services ................................................................................................................. 26

Personnel, Operations, and Maintenance ......................................................................... 26
ii Shell Keys National Wildlife Refuge 

III. PLAN DEVELOPMENT .................................................................................................................. 27

Summary of Issues, Concerns, and Opportunities ..................................................................... 27

Fish and Wildlife Population Management ........................................................................ 27

Habitat Management ......................................................................................................... 27

Resource Protection .......................................................................................................... 28

Visitor Services ................................................................................................................. 28

Refuge Administration ....................................................................................................... 28

IV. MANAGEMENT DIRECTION ........................................................................................................ 29

Introduction ................................................................................................................................. 29

Alternatives For Managing Shell Keys NWR .............................................................................. 29

Vision for Shell Keys NWR ......................................................................................................... 29

Goals, Objectives, and Strategies for Shell Keys NWR ............................................................. 29

Fish and Wildlife Population Management ........................................................................ 30

Habitat Management ......................................................................................................... 31

Resource Protection .......................................................................................................... 32

Visitor Services ................................................................................................................. 32

Refuge Administration ....................................................................................................... 33

V. PLAN IMPLEMENTATION ............................................................................................................. 35

Introduction ................................................................................................................................. 35

Proposed Projects ...................................................................................................................... 35

Fish and Wildlife Population Management ........................................................................ 35

Habitat Management ......................................................................................................... 36

Resource Protection .......................................................................................................... 36

Visitor Services ................................................................................................................. 36

Funding and Personnel .............................................................................................................. 37

Partnership/Volunteer Opportunities .......................................................................................... 37

Step-Down Management Plans .................................................................................................. 37

Monitoring and Adaptive Management ....................................................................................... 38

Plan Review and Revision .......................................................................................................... 38

APPENDICES 

APPENDIX A. GLOSSARY ................................................................................................................. 39

APPENDIX B. REFERENCES AND LITERATURE CITATIONS ........................................................ 49

APPENDIX C. RELEVANT LEGAL MANDATES AND EXECUTIVE ORDERS ................................. 55

APPENDIX D. PUBLIC INVOLVEMENT ............................................................................................ 69

Summary Of Public Scoping Comments .................................................................................... 69

Summary Of Public Draft CCP Comments ................................................................................. 70

Draft CCP/EA Comments and Service Response ............................................................ 70

APPENDIX E. COMPATIBILITY DETERMINATIONS ........................................................................ 73

APPENDIX F. INTRA-SERVICE SECTION 7 BIOLOGICAL EVALUATIONS .................................... 79
Table of Contents iii

APPENDIX G. WILDERNESS REVIEW ............................................................................................. 83

APPENDIX H. REFUGE BIOTA ......................................................................................................... 85

APPENDIX I. LIST OF PREPARERS ................................................................................................. 87

APPENDIX J. FINDING OF NO SIGNIFICANT IMPACT..................................................................... 88
iv Shell Keys National Wildlife Refuge 

LIST OF FIGURES 

Figure 1. Location of Shell Keys National Wildlife Refuge and the Southwest Louisiana 

National Wildlife Refuge Complex ....................................................................................... 12

Figure 2. Lower Mississippi River Ecosystem and Shell Keys National Wildlife Refuge .................... 14

LIST OF TABLES 

Table 1. Population and industry statistics of Iberia Parish ................................................................ 23

Table 2. Summary of Projects ............................................................................................................. 37

Table 3. Shell Keys National Wildlife Refuge Step-down Management Plans ................................... 38
Comprehensive Conservation Plan 1

Executive Summary 

The Fish and Wildlife Service prepared this Comprehensive Conservation Plan to guide the 

management of Shell Keys National Wildlife Refuge (Shell Keys NWR) in Iberia Parish, Louisiana. 

The plan outlines programs and corresponding resource needs for the next 15 years, as mandated by 

the National Wildlife Refuge System Improvement Act of 1997. 

Public involvement in the development of the Comprehensive Conservation Plan and Environment 

Assessment for Shell Keys National Wildlife Refuge was sought throughout the planning process. 

The planning team held one public scoping meeting to solicit public reaction. Also, a 30 day public 

review and comment period of the draft comprehensive conservation plan and environmental 

assessment was provided. 

The Service developed and analyzed three alternatives. Alternative A represents the “status quo” 

alternative in which current habitat, wildlife, and public use management would continue with no 

changes. On an annual basis, monitoring and trip report status is conducted. Periodically during 

winter migratory bird surveys, fly-over surveys are conducted to determine if the island is emergent. 

A cooperative law enforcement agreement will remain in effect with the Louisiana Department of 

Wildlife and Fisheries (LDWF). 

Under Alternative B, nature would be allowed to take its course regarding the future of the islands 

with no restoration activities accomplished. If the islands fail to rebuild and continue to erode, areas 

available to birds may diminish. With the land area diminishing, the island will continue to not support 

colonial nesting birds. Working with LDWF, provide routine and additional patrols in coordination with 

Refuge law enforcement officers. Interpretation will concentrate on the history of the formation and 

subsequent changes and erosion of the shell key shoal/island and reef complex habitat through the 

Southwest Louisiana National Wildlife Refuge Complex (SW LA NWR Complex). Alternative B 

would open the refuge for public use by offering limited fishing and wildlife observation and 

photography. 

Alternative C, the Service’s proposed alternative for Shell Keys NWR, assesses the feasibility of 

implementing large-scale habitat restoration efforts in cooperation with partners. The Service would 

enter into a new cooperative agreement with LDWF Fur and Refuge Division focusing on natural 

resource monitoring and restoration as appropriate. Partners are necessary to supply expertise and 

funding for the daunting task of restoration. Feasibility studies would be performed to determine the 

costs associated with rebuilding and re-establishing the Shell Islands, or portions of the Islands. 

Restoration efforts would adapt to changing conditions as practices and techniques are assessed. The 

Refuge will be open to recreational fishing and wildlife observation and photography. Because the 

Refuge is remote and few guests actually visit the islands, outreach would center around providing 

information in combination with SW LA NWR Complex and on web pages. 

The Service selected Alternative C as its preferred alternative for implementation because these 

management actions provide balanced levels of compatible public use opportunities consistent with 

existing laws, Service policies, and sound biological principles. It provides the best mix of program 

elements to achieve desired long-term conditions. 

Under this alternative, all lands under the management and direction of the Refuge will be protected, 

managed, maintained, and enhanced to best achieve national, regional, ecosystem, and 

refuge-specific goals and objectives within anticipated funding and staffing levels. In addition, the 

action positively addresses significant issues and concerns expressed by the public. 
2 Shell Keys National Wildlife Refuge 
Comprehensive Conservation Plan 3

COMPREHENSIVE CONSERVATION PLAN 

I. Background 

This Comprehensive Conservation Plan (CCP) was prepared to guide the management actions and 

direction of Shell Keys National Wildlife Refuge (Shell Keys NWR), Iberia Parish, Louisiana. Fish and 

wildlife conservation will receive first priority in refuge management; wildlife-dependent recreation will 

be allowed and encouraged as long as it is compatible with, and does not detract from, the mission of 

the refuge or the purposes for which it was established. 

A planning team developed a range of alternatives that best met the goals and objectives of Shell 

Keys NWR and that could be implemented within the 15-year planning period. The draft of this plan 

was made available to state and federal government agencies, conservation partners, and the 

general public for review and comment. Comments from each entity were considered in the 

development of this final CCP. 

PURPOSE AND NEED FOR THE PLAN 

The purpose of this CCP is to identify the role that Shells Keys NWR will play in support of the 

National Wildlife Refuge System mission. It addresses key problems, issues and relevant mandates, 

and is consistent with sound principles of fish and wildlife management. 

Specifically, the plan is needed to: 

y Provide a clear statement of refuge management direction; 

y Provide refuge neighbors, visitors, and government officials with an understanding of Service 

management actions on and around the refuge; 

y Ensure that Service management actions, including land protection and recreation/education 

programs, are consistent with the mandates of the National Wildlife Refuge System; and 

y Provide a basis for the development of budget requests for operations, maintenance, and 

capital improvement needs. 

FISH AND WILDLIFE SERVICE 

The Fish and Wildlife Service (Service) traces its roots to 1871 and the establishment of the Commission 

of Fisheries involved with research and fish culture. The once independent commission was renamed the 

Bureau of Fisheries and placed under the Department of Commerce and Labor in 1903. 

The Service also traces its roots to 1886 and the establishment of a Division of Economic Ornithology 

and Mammalogy within the Department of Agriculture. Research on the relationship of birds and 

animals to agriculture shifted to delineation of the range of plants and animals, so the name was 

changed to the Division of the Biological Survey in 1896. 

The Department of Commerce, Bureau of Fisheries, was combined with the Department of 

Agriculture, Bureau of Biological Survey, on June 30, 1940, and transferred to the Department of the 

Interior as the Fish and Wildlife Service. The name was changed to the Bureau of Sport Fisheries 

and Wildlife in 1956, and finally to the Fish and Wildlife Service in 1974. 
4 Shell Keys National Wildlife Refuge 

The Fish and Wildlife Service, working with others, is responsible for conserving, protecting, and 

enhancing fish and wildlife and their habitats for the continuing benefit of the American people 

through federal programs relating to migratory birds, endangered species, interjurisdictional fish and 

marine mammals, and inland sport fisheries (142 DM 1.1). 

As part of its mission, the Service manages more than 540 national wildlife refuges covering over 

95 million acres. These areas comprise the National Wildlife Refuge System, the world’s largest 

collection of lands set aside specifically for fish and wildlife. The majority of these lands, 77 

million acres, is in Alaska. The remaining acres are spread across the other 49 states and 

several United States territories. In addition to refuges, the Service manages thousands of small 

wetlands, national fish hatcheries, 64 fishery resource offices, and 78 ecological services field 

stations. The Service enforces federal wildlife laws, administers the Endangered Species Act, 

manages migratory bird populations, restores nationally significant fisheries, conserves and 

restores wildlife habitat, and helps foreign governments with their conservation efforts. It also 

oversees the Federal Aid program that distributes hundreds of millions of dollars in excise taxes 

on fishing and hunting equipment to state fish and wildlife agencies. 

NATIONAL WILDLIFE REFUGE SYSTEM 

The mission of the National Wildlife Refuge System, as defined by the National Wildlife Refuge 

System Improvement Act of 1997 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.” 

The National Wildlife Refuge System Improvement Act of 1997 (Improvement Act) established, for the 

first time, a clear legislative mission of wildlife conservation for the National Wildlife Refuge System 

(Refuge System). Actions were initiated in 1997 to comply with the direction of this new legislation, 

including an effort to complete comprehensive conservation plans for all refuges. These plans, which 

are completed with full public involvement, help guide the future management of refuges by 

establishing natural resources and recreation/education programs. Consistent with the Improvement 

Act, approved CCPs will serve as the guidelines for refuge management for the next 15 years. The 

Improvement Act states that each refuge shall be managed to: 

y Fulfill the mission of the Refuge System; 

y Fulfill the individual purposes of each refuge; 

y Consider the needs of wildlife first; 

y Fulfill requirements of comprehensive conservation plans that are prepared for each unit of 

the refuge system; 

y Maintain the biological integrity, diversity, and environmental health of the Refuge System; and 

y Recognize that wildlife-dependent recreation activities, including hunting, fishing, wildlife 

observation, wildlife photography, and environmental education and interpretation, are 

legitimate and priority public uses; and allow refuge managers authority to determine 

compatible public uses. 

The following are just a few examples of your national network of conservation lands. Pelican Island 

NWR, the first refuge, was established in 1903 for the protection of colonial nesting birds in Florida, 

such as the snowy egret and the brown pelican. Western refuges were established for American bison 
Comprehensive Conservation Plan 5

(1906), elk (1912), prong-horned antelope (1931), and desert bighorn sheep (1936) after over-hunting, 

competition with cattle, and natural disasters decimated once-abundant herds. The drought conditions 

of the 1930s Dust Bowl severely depleted breeding populations of ducks and geese. Refuges 

established during the Great Depression focused on waterfowl production areas (i.e., protection of 

prairie wetlands in America’s heartland). The emphasis on waterfowl continues today but also includes 

protection of wintering habitat in response to a dramatic loss of bottomland hardwoods. By 1973, the 

Service had begun to focus on establishing refuges for endangered species. 

Approximately 38 million people visited national wildlife refuges in 2002, most to observe wildlife in 

their natural habitats. As the number of visitors grows, there are significant economic benefits to local 

communities. In 2001, 82 million people, 16 years and older, fished, hunted, or observed wildlife, 

generating $108 billion. In a study completed in 2002 on 15 refuges, visitation had grown 36 percent 

in seven years. At the same time, the number of jobs generated in surrounding communities grew to 

120 per refuge, up from 87 jobs in 1995, pouring more than $2.2 million into local economies. The 15 

refuges in the study were Chincoteague (Virginia); National Elk (Wyoming); Crab Orchard (Illinois); 

Eufaula (Alabama); Charles M. Russell (Montana); Umatilla (Oregon); Quivira (Kansas); 

Mattamuskeet (North Carolina); Upper Souris (North Dakota); San Francisco Bay (California); Laguna 

Atacosa (Texas); Horicon (Wisconsin); Las Vegas (Nevada); Tule Lake (California); and Tensas River 

(Louisiana) the same refuges identified for the 1995 study. Other findings also validate the belief that 

communities near refuges benefit economically. Expenditures on food, lodging, and transportation 

grew to $6.8 million per refuge, up 31 percent from $5.2 million in 1995. For each dollar spent on the 

Refuge System, surrounding communities benefited with $4.43 in recreation expenditures and $1.42 

in job-related income (Caudill and Laughland, unpubl. data). 

Volunteers continue to be a major contributor to the success of the Refuge System. In 2002, 

volunteers contributed more than 1.5 million hours on refuges nationwide, a service valued at more 

than $22 million. 

The wildlife and habitat vision for national wildlife refuges stresses that wildlife comes first; that 

ecosystems, biodiversity, and wilderness are vital concepts in refuge management; that refuges must 

be healthy and growth must be strategic; and that the Refuge System serves as a model for habitat 

management with broad participation from others. 

The Improvement Act stipulates that CCPs be prepared in consultation with adjoining federal, state, 

and private landowners and that the Service develop and implement a process to ensure an 

opportunity for active public involvement in the preparation and revision (every 15 years) of the plans. 

All lands of the Refuge System will be managed in accordance with an approved CCP that will guide 

management decisions and set forth strategies for achieving refuge unit purposes. The CCP will be 

consistent with sound resource management principles, practices, and legal mandates, including Service 

compatibility standards and other Service policies, guidelines, and planning documents (602 FW 1.1). 
6 Shell Keys National Wildlife Refuge 

LEGAL AND POLICY CONTEXT 

Legal Mandates, Administrative and Policy Guidelines, and Other Special Considerations 

Administration of national wildlife refuges is guided by the mission and goals of the Refuge System, 

congressional legislation, executive orders, and international treaties. Policies for management options of 

refuges are further refined by administrative guidelines established by the Secretary of the Interior and by 

policy guidelines established by the Director of the Fish and Wildlife Service. Select legal summaries of 

treaties and laws relevant to administration of the Refuge System and management of the Shell Keys 

NWR are provided in Appendix C. 

Treaties, laws, administrative guidelines, and policy guidelines assist the refuge manager in making 

decisions pertaining to soil, water, air, flora, fauna, and other natural resources; historical and cultural 

resources; research and recreation on refuge lands; and provide a framework for cooperation 

between Shell Keys NWR and other partners, such as the Louisiana Department of Wildlife and 

Fisheries (LDWF), Louisiana Department of Natural Resources (LDNR), U.S. Army Corps of 

Engineers (COE), and private landowners, etc. 

Lands within the Refuge System are closed to public use unless specifically and legally opened. No 

refuge use may be allowed unless it is determined to be compatible. 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. All programs 

and uses must be evaluated based on mandates set forth in the Improvement Act. Those mandates 

are to: 

y Contribute to ecosystem goals, as well as refuge purposes and goals; 

y Conserve, manage, and restore fish, wildlife, and plant resources and their habitats; 

y Monitor the trends of fish, wildlife, and plants; 

y Manage and ensure appropriate visitor uses as those uses benefit the conservation of fish 

and wildlife resources and contribute to the enjoyment of the public; and 

y Ensure that visitor activities are compatible with refuge purposes. 

The Improvement Act further identifies six priority wildlife-dependent recreational uses. These uses 

are: hunting, fishing, wildlife observation, wildlife photography, and environmental education and 

interpretation. As priority public uses of the Refuge System, they receive priority consideration over 

other public uses in planning and management. 

Biological Integrity, Diversity, and Environmental Health Policy 

The Improvement Act directs the Service to ensure that the biological integrity, diversity, and 

environmental health of the Refuge System are maintained for the benefit of present and future 

generations of Americans. The policy is an additional directive for refuge managers to follow while 

achieving refuge purpose(s) and the Refuge System mission. It provides for the consideration and 

protection of the broad spectrum of fish, wildlife, and habitat resources found on refuges and 

associated ecosystems. When evaluating the appropriate management direction for refuges, refuge 

managers will use sound professional judgment to determine their refuges’ contribution to biological 

integrity, diversity, and environmental health at multiple landscape scales. Sound professional 

judgment incorporates field experience, knowledge of refuge resources, and knowledge of the refuge 

role within an ecosystem, applicable laws, and best available science, including consultation with 

others both inside and outside the Service. 
Comprehensive Conservation Plan 7

The Coastal Barrier Resources Act of 1982 

The Coastal Barrier Resources Act of 1982 (CBRA) identifies undeveloped coastal barrier lands 

along the Atlantic and Gulf coasts and includes them in a coastal barrier resource system. Objectives 

of the CBRA are to restrict most federal expenditures that encourage development within the system 

to minimize loss of human life, reduce wasteful federal expenditures, and minimize damage to natural 

resources. Shell Keys NWR is located in Unit LA-05P under the CBRA and is classified as an 

“otherwise protected area.” 

The Energy Policy Act of 2005 

The Energy Policy Act of 2005 (Public Law 109-58) was signed into law by President Bush on 

August 8, 2005. Section 384 of the Energy Policy Act establishes the Coastal Impact Assistance 

Program (CIAP), which authorizes funds to be distributed to Outer Continental Shelf oil and gas 

producing states to mitigate the impacts of outer continental shelf oil and gas activities. States to 

share these funds are Alabama, Alaska, California, Louisiana, Mississippi, and Texas. (See further 

discussion below under conservation plans and initiatives.) 

NATIONAL AND INTERNATIONAL CONSERVATION PLANS AND INITIATIVES 

Multiple partnerships have been developed among government and private entities to address the 

environmental problems affecting regions. There is a large amount of conservation and protection 

information that defines the role of the refuge at the local, national, international, and ecosystem 

levels. Conservation initiatives include broad-scale planning and cooperation between affected 

parties to address declining trends of natural, physical, social, and economic environments. The 

conservation guidance described below, along with issues, problems and trends, was reviewed and 

integrated where appropriate into this CCP. 

This CCP supports, among others, the Partners-in-Flight Plan, the North American Waterfowl 

Management Plan, the Western Hemisphere Shorebird Reserve Network, and the National Wetlands 

Priority Conservation Plan. 

North American Bird Conservation Initiative. Started in 1999, the North American Bird 

Conservation Initiative (NABCI) is a coalition of government agencies, private organizations, 

academic institutions, and private industry leaders in the United States, Canada, and Mexico, working 

to ensure the long-term health of North America's native bird populations by fostering an integrated 

approach to bird conservation to benefit all birds in all habitats. The international and national bird 

initiatives include the North American Waterfowl Management Plan, Partners-in-Flight Plan, Waterbird 

Conservation for the Americas, and the U.S. Shorebird Conservation Plan. 

North American Waterfowl Management Plan. The North American Waterfowl Management Plan is 

an international action plan to conserve migratory birds throughout the continent. The plan's goal is to 

return waterfowl populations to their 1970s’ levels by conserving wetland and upland habitat. Canada 

and the United States signed the plan in 1986, in reaction to critically low numbers of waterfowl. Mexico 

joined in 1994, making it a truly continental effort. The plan is a partnership of federal, provincial/state 

and municipal governments, non-governmental organizations, private companies, and many 

individuals, all working towards achieving better wetland habitat for the benefit of migratory birds, other 

wetland-associated species, and people. Plan projects are international in scope, but implemented at 

regional levels. These projects contribute to the protection of habitat and wildlife species across the 

North American landscape. 
8 Shell Keys National Wildlife Refuge 

Partners-in-Flight Bird Conservation Plan. Managed as part of the Partners-in-Flight Plan, the 

Coastal Prairies physiographic area represents a scientifically based land bird conservation planning 

effort that ensures long-term maintenance of healthy populations of native land birds, primarily nongame land birds. Non-game land birds have been vastly under-represented in conservation efforts, 

and many are exhibiting significant declines. This plan is voluntary and non-regulatory, and focuses 

on relatively common species in areas where conservation actions can be most effective, rather than 

the frequent local emphasis on rare and peripheral populations. 

U.S. Shorebird Conservation Plan. The U.S. Shorebird Conservation Plan is a partnership effort 

throughout the United States to ensure that stable and self-sustaining populations of shorebird 

species are restored and protected. The plan was developed by a wide range of agencies, 

organizations, and shorebird experts for separate regions of the country, and identifies conservation 

goals, critical habitat conservation needs, key research needs, and proposed education and outreach 

programs to increase awareness of shorebirds and the threats they face. 

North American Waterbird Conservation Plan. This plan provides a framework for the 

conservation and management of 210 species of waterbirds in 29 nations. Threats to waterbird 

populations include destruction of inland and coastal wetlands, introduced predators and invasive 

species, pollutants, mortality from fisheries and industries, disturbance, and conflicts arising from 

abundant species. Particularly important habitats of the southeast region include pelagic areas, 

marshes, forested wetlands, and barrier and sea island complexes. Fifteen species of waterbirds are 

federally listed, including breeding populations of wood storks, Mississippi sandhill cranes, whooping 

cranes, interior least terns, and Gulf coast populations of brown pelicans. A key objective of this plan 

is the standardization of data collection efforts to better recommend effective conservation measures. 

Coastal Impact Assistance Program (CIAP). A federal law, signed in 2005, authorizes the 

Secretary of the Interior to distribute $250 million for each of the fiscal years 2007 through 2010 to oil 

and gas producing states (Alabama, Alaska, California, Louisiana, Mississippi, and Texas) and 

coastal political subdivisions to be used for one or more of the following purposes: 

y Projects and activities for the conservation, protection, or restoration of coastal areas, 

including wetlands. 

y Mitigation of damage to fish, wildlife, or natural resources. 

y Planning assistance and the administrative costs of complying with this section. 

y Implementation of a federally approved marine, coastal, or comprehensive conservation plan. 

y Mitigation of the impact of Outer Continental Shelf activities through funding or onshore 

infrastructure projects and public service needs 

In a Continuing Resolution dated February 16, 2007, Congress approved a 3 percent appropriation of 

the CIAP funds to be used by Minerals Management Service (MMS) to administer the CIAP program. 

MMS will lead the CIAP by establishing an environment that will enhance partner communications 

and an effective business relationship. Each eligible state will be allocated its share based on the 

state’s qualified Outer Continental Shelf revenue generated off of its coast in proportion to total 

revenue generated off the coasts of all eligible states. MMS will respond to recipients’ needs and 

provide advice through guidance, direction, training, and by ensuring that monitoring and evaluation 

are incorporated into a system of accountability designed to accomplish the results intended by the 

Energy Policy Act of 2005. 
Comprehensive Conservation Plan 9

RELATIONSHIP TO STATE WILDLIFE AGENCY 

A provision of the Improvement Act, and subsequent agency policy, is that the Service shall ensure 

timely and effective cooperation and collaboration with state fish and game agencies and tribal 

governments during the course of acquiring and managing refuges. State wildlife management areas 

and national wildlife refuges provide the foundation for the protection of species, and contribute to the 

overall health and sustainment of fish and wildlife populations in the State of Louisiana. 

 

In Louisiana, LDWF http://www.wlf.louisiana.gov) is vested with responsibility for conservation and 

management of wildlife in the state, including aquatic life, and is authorized to execute the laws 

enacted for the control and supervision of programs relating to the management, protection, 

conservation, and replenishment of wildlife, fish, and aquatic life, and the regulation of the shipping of 

wildlife fish, furs, and skins. The mission of the LDWF is to manage, conserve, and promote wise 

utilization of Louisiana’s renewable fish and wildlife resources and their supporting habitats through 

replenishment, protection, enhancement, research, development, and education for the social and 

economic benefit of current and future generations; to provide opportunities for knowledge of and use 

and enjoyment of these resources; and to promote a safe and healthy environment for the users of 

the resources. LDWF is divided into seven divisions for management of the state’s resources: 

Enforcement, Fur and Refuge, Inland Fisheries, Management and Finance, Marine Fisheries, Public 

Information, and Wildlife. 

The participation of the LDWF throughout this comprehensive conservation planning process has been 

valuable. LDWF personnel participated on the core planning team and are also active partners in annual 

hunt coordination, planning, and various wildlife and habitat surveys. A key part of the planning process is 

the integration of common objectives between the Service and the LDWF. Shell Keys NWR is located in 

close proximity to Marsh Island Wildlife Refuge, which is managed by the LDWF. 

 
10 Shell Keys National Wildlife Refuge 
Comprehensive Conservation Plan 11

II. Refuge Overview 

INTRODUCTION 

Shell Keys NWR is part of the Southwest Louisiana National Wildlife Refuge Complex, which also 

includes Cameron Prairie, Lacassine, and Sabine NWRs. Shell Keys NWR consists of an island off 

the Louisiana Gulf coast in southeast Louisiana (Iberia Parish) (Figure 1). Access is limited to boats 

that are able to venture offshore. 

SHELL KEYS REFUGE HISTORY AND PURPOSE 

Shell Keys was established by Executive Order (EO) on July 9, 1855, as a lighthouse reservation and 

subsequently as Shell Keys Reservation, and a breeding ground for native birds as established by 

EO 682 on August 17, 1907. On July 27, 1940, Presidential Proclamation Number 2416 changed the 

name from Shell Keys Reservation to Shell Keys NWR. It is noted that upon becoming a state, 

Louisiana was granted title to all lands lying below mean high tide. The United States retained title to 

the islands that form the Shell Keys. 

By the turn of the 20th century, the nation had witnessed the increasing devastation of wading bird 

populations by plume hunters in Florida, and severe reductions in the populations of other once 

abundant forms of wildlife, such as the passenger pigeon. Public support increased for more 

vigorous actions on the part of the Federal Government to reverse this downward slide. 

Such public concern, combined with the conservation-minded President Theodore Roosevelt, 

resulted in the initial federal land specifically set aside for a non-marketable form of wildlife (the brown 

pelican) when Pelican Island was proclaimed a Federal Bird Reservation in 1903 (USFWS 2007). 

Following the acquisition of Pelican Island, many other islands and parcels of land and water were 

quickly dedicated for the protection of various species of colonial nesting birds that were being 

destroyed for their plumes and other feathers. Such refuge areas included Breton, Louisiana (1904); 

Passage Key, Florida (1905); and Shell Keys, Louisiana (1907) (USFWS 2007). 

Congress established Shell Keys NWR on August 17, 1907, by EO 682, for the purpose “....as a 

reserve and breeding ground for native birds.” 

Shell Keys NWR is one of the oldest refuges in the Refuge System. Its boundary was and still is 

rather loosely described as "... a small group of unsurveyed islets located in the Gulf of Mexico about 

three and one-half miles south of Marsh Island, Louisiana, and approximately in latitude 29 degrees 

26 minutes north, longitude 91 degrees 51 minutes west from Greenwich...." The boundary of the 

refuge has been interpreted to be those areas in this vicinity that are above mean high tide. 

Reference is given to 77 acres, but in a memorandum dated July 24, 1956, the total acreage of lands 

lying above mean high water is stated at approximately 8.0 acres. 

It is noted that Shell Keys NWR is a small group of islands that are subject to shell deposits and 

erosion so the actual acreage above mean high water may, of course, be different at this time. How 

these islands change and move may affect ownership of that area lying above mean high water. 

Under certain circumstances, accreted areas above mean high water may belong to the State of 
12 Shell Keys National Wildlife Refuge 

Figure 1. Location of Shell Keys National Wildlife Refuge and the Southwest Louisiana 

National Wildlife Refuge Complex 
Comprehensive Conservation Plan 13

Louisiana. Shell Keys NWR is located within the Lower Mississippi River Ecosystem in the Gulf of 

Mexico. The refuge’s eight acres are located in the offshore waters to the west of the Atchafalaya 

River Delta and south of LDWF, Marsh Island Wildlife Refuge, Iberia Parish, Louisiana. 

For a number of years, there has been only one islet at this location. This islet is composed almost 

entirely of shell fragments. It is extremely dynamic and builds or recedes with passing storms. 

Vegetation is almost entirely lacking. 

Species known to nest here include royal terns, sandwich terns, black skimmers, and laughing gulls. 

In addition, the islet is used at various times as a loafing area by white pelicans, brown pelicans, and 

various other species of terns and gulls. Recent hurricanes and storms have eroded the island to 

such an extent that no known nesting has occurred since 1992. 

Public access to the refuge is restricted due to its remoteness and sole accessibility by boat. 

SPECIAL DESIGNATIONS 

The oyster reefs and shell water bottoms in the vicinity of Shell Keys NWR have been designated as 

essential fish habitat under provisions of the Magnuson-Stevens Fishery Conservation and 

Management Act (Magnuson-Stevens Act) for various life stages of red drum, brown shrimp, white 

shrimp, and Gulf stone crab. Any adverse impacts will be addressed in full detail if the study to 

determine what habitat restoration can be done is completed and the decision is made to implement 

any changes to the refuge. 

ECOSYSTEM CONTEXT 

OVERVIEW 

The Service is increasing its efforts to adopt collaborative resource partnerships with private 

landowners and local communities, as well as state and federal governments within ecosystems, to 

reduce the declining trend of fish and wildlife populations and biological diversity; establish 

conservation priorities; clarify goals; and solve common threats and problems associated with fish 

and wildlife resources. The synergy of all federal, state, tribal, and private organizations, working 

together, will ensure that the Service not only protects the more important areas, but also reduces 

redundancy and overlap. 

Shell Keys NWR is a member and participant of the Service’s Lower Mississippi River Ecosystem 

(LMRE) Team. This ecosystem (Figure 2) serves as the primary wintering habitat for mid-continental 

waterfowl populations, as well as breeding and migration habitat for migratory songbirds returning 

from Central and South America, and numerous resident wildlife species. 

Geographically, the refuge lies on the outer boundary of the ecosystem and has few opportunities to 

contribute to many of the goals and objectives of the LMRE. There are some common targets that 

are applicable to the refuge and to which they contribute. The refuge also could contribute to the 

objectives of the Service’s Texas Gulf Coast Ecosystem (TGCE). The TGCE is considered by many 

to be part of a larger ecological Gulf coast system that also includes portions of coastal Louisiana and 

Mexico. The TGCE Team has requested the participation of the Shell Keys NWR and other nearby 

southwest Louisiana refuges in its ecosystem team meetings. 
14 Shell Keys National Wildlife Refuge 

Figure 2. Lower Mississippi River Ecosystem and Shell Keys National Wildlife Refuge 
Comprehensive Conservation Plan 15

LOWER MISSISSIPPI RIVER ECOSYSTEM (LMRE) 

The LMRE includes the alluvial plain of the Mississippi River downstream of its confluence with the 

Ohio River and the delta plain and associated marshes and swamps created by the meanderings of 

the Mississippi River and its tributaries (FWS 2002). Louisiana has twelve water quality management 

basins delineated on the basis of natural drainage patterns of the state’s major river basins (Lester et 

al., 2005). Shell Keys NWR is located in or just outside the Teche/Vermillion Basin. 

The LMRE guides Service efforts to enhance, restore, and conserve the natural functional processes 

and habitat types of the LMRE, while maintaining the economic productivity and recreational 

opportunities. The ecosystem serves as primary wintering habitat for mid-continent waterfowl 

populations, as well as breeding and migrating habitat for migratory songbirds. The expansive flood 

plain forests of the past are now fragmented bottomland hardwood patches due to conversion from 

agriculture and flood control projects. 

The LMRE developed eight goals that this CCP will promote to ensure Shell Keys NWR continues its 

contribution to ecosystem conservation and integrity. 

y Conserve, enhance, protect, and monitor migratory bird populations and their habitats in the 

LMRE. 

y Protect, restore, and manage the wetlands of the LMRE. 

y Protect and/or restore imperiled habitats and viable populations of all threatened, endangered, 

and candidate species and species of concern in the LMRE. 

y Protect, restore, and manage the fisheries and other aquatic resources historically associated 

with the wetlands and waters of the LMRE. 

y Increase public awareness and support for LMRE resources and their management. 

y Enforce natural resource laws. 

y Protect, restore, and enhance water and air quality throughout the LMRE. 

TEXAS GULF COAST ECOSYSTEM (TGCE) 

The priorities identified by the TGCE Team, to which the refuge can contribute, include: 

y Encourage the Service’s Region 4 field stations with similar coastal resource objectives to 

participate in ecosystem team meetings. 

y Develop partnerships with other Service regions, Mexico, natural resource agencies, 

universities, and non-governmental organizations to plan and implement outreach programs. 

REGIONAL CONSERVATION PLANS AND INITIATIVES 

Conservation priorities for national wildlife refuges in the Lower Mississippi Valley focus on 

threatened and endangered species, trust species, and species of local concern. The goals and 

objectives in this CCP are stepped down from the following plans: 

y Gulf Coast Joint Venture 

y North American Waterbird Conservation Plan 

y United States Shorebird Conservation Plan 

y Coastal Wetlands Planning, Protection, and Restoration Act 

y Coast 2050 – Towards a Sustainable Coastal Louisiana 

y Louisiana Coastal Area Ecosystem Restoration Plan 
16 Shell Keys National Wildlife Refuge 

y Fisheries Vision for the Future 

y Louisiana Comprehensive Wildlife Conservation Strategy (Wildlife Action Plan) 

GULF COAST JOINT VENTURE (MISSISSIPPI RIVER COASTAL WETLANDS INITIATIVE) 

Regional partnerships or joint ventures composed of individuals; sportsmen’s groups; conservation 

organizations; and local, state, provincial, and federal governments were formed under the North 

American Waterfowl Management Plan. One such partnership—the Gulf Coast Joint Venture 

(GCJV)—was established to conserve priority waterfowl habitats along the western United States 

Gulf coast, one of the most important waterfowl areas in North America. The Gulf coast is the 

terminus of the Central and Mississippi Flyways and provides both wintering and migrating habitat for 

significant numbers of continental goose and duck populations. The GCJV’s greatest contribution to 

the North American Waterfowl Management Plan is to provide wintering grounds for waterfowl. A 

great diversity of birds, mammals, fish, shellfish, reptiles, and amphibians also rely on the wetlands of 

the Gulf coast for part of their life cycles. 

The GCJV is divided geographically into six initiative areas, one of which is the Mississippi River 

Coastal Wetland Initiative area. This area includes all or part of seventeen Louisiana parishes and is 

bounded on the east by the Louisiana state line and extends westward to Vermilion Bay. The 

northern boundary of the initiative area occurs at roughly the marsh-swamp interface. The area 

includes two major river deltas--the Mississippi and Atchafalaya. The goal of the initiative is to 

provide wintering and migrating habitat for significant numbers of dabbling ducks, diving ducks, and 

snow geese, as well as year-round habitat for mottled ducks. The Mississippi River Coastal Wetlands 

Initiative focuses on coastal marshes, forested wetlands, and sea grass beds of the Chandeleur 

Sound. Shell Keys NWR may contribute to some of the objectives of the Mississippi River Coastal 

Plain Initiative. 

NORTH AMERICAN WATERBIRD CONSERVATION PLAN 

The North American Waterbird Conservation Plan was developed under a partnership called the 

Waterbird Conservation for the Americas, which is a group of individuals and organizations having 

interest and responsibility for the conservation of waterbirds and their habitats in the Americas. Shell 

Keys NWR is located in the Southeast U.S. Regional Waterbird Conservation Planning Area. The 

refuge can contribute to a key objective of this region, which is to standardize data collection efforts 

and analysis procedures to allow better tracking of regional movements and the association of these 

movements with environmental or land use changes. 

UNITED STATES SHOREBIRD CONSERVATION PLAN 

The United States Shorebird Conservation Plan is a partnership involving organizations throughout 

the United States committed to the conservation of shorebirds. Shell Keys NWR is located within the 

Lower Mississippi, Western Gulf Coast Shorebird Planning Region. On a regional scale, the refuge 

can help ensure that adequate quantity and quality of habitat is identified and maintained to support 

the different shorebirds that breed in, winter in, and migrate through the area. 

COASTAL WETLANDS PLANNING, PROTECTION AND RESTORATION ACT 

In 1990, Congress passed the Coastal Wetlands Planning, Protection, and Restoration Act 

(CWPPRA) that generates $50 to $60 million annually for Louisiana coastal wetland restoration 

projects via an 85/15 federal/state cost-share, and which provided for the development of the 1993 

comprehensive Louisiana Coastal Wetlands Restoration Plan. Funding of proposed projects is 
Comprehensive Conservation Plan 17

determined by the Louisiana Coastal Wetlands Conservation and Restoration Task Force, which is 

composed of five federal agencies and the State of Louisiana. As mandated by CWPPRA, the task 

force developed a detailed Coastal Wetlands Restoration Plan in 1993 that describes the restoration 

actions and projects that should be implemented to address Louisiana’s coastal land loss crisis. A 

priority project list is developed and approved by the task force each year, outlining which projects will 

receive CWPPRA funding. 

COAST 2050 - TOWARDS A SUSTAINABLE COASTAL LOUISIANA 

Coast 2050, funded by CWPPRA, is a comprehensive, ecosystem-based plan developed by private 

citizens; local, state, and federal agencies; and the scientific community to address coastal wetland 

loss throughout southern Louisiana. This plan, which is recognized by the State of Louisiana, five 

federal agencies, and local coastal parish governments, serves as the joint coastal restoration plan 

for CWPPRA. Its overarching goal is to sustain a coastal ecosystem that supports and protects the 

environment, economy, and culture of southern Louisiana and that contributes greatly to the economy 

and well-being of the nation. The strategic objectives of Coast 2050 are to (1) sustain a coastal 

ecosystem with the essential functions and values of the natural ecosystem; (2) restore the 

ecosystem to the highest practicable acreage of productive and diverse wetlands; and (3) accomplish 

this restoration through an integrated program that has multiple use benefits (Louisiana Coastal 

Wetlands Conservation and Restoration Task Force and the Wetlands Conservation and Restoration 

Authority 1998). Shell Keys NWR is included in Region 3 - Terrebonne, Atchafalaya, and 

Teche/Vermilion of this plan. 

LOUISIANA COASTAL AREA ECOSYSTEM RESTORATION PLAN 

The Louisiana Coastal Area Ecosystem Restoration Plan evolved from the Coast 2050 Plan, with the 

overarching goal of reversing the current trend of degradation of the coastal ecosystem. This plan formed 

the basis for the Louisiana Coastal Area Ecosystem Restoration Study, which was designed to identify 

critical ecological needs, restoration efforts, scientific uncertainties to present a strategy for addressing the 

long-term needs of coastal Louisiana restoration, and to establish restoration priorities. 

Shell Keys NWR is located within Sub-province 3 for the Louisiana Coastal Area. The restoration plans 

identified in the Louisiana Coastal Area relate directly and indirectly to the refuge through long-term efforts 

to explore large-scale restoration projects that will influence the entire coastal zone of Louisiana. 

FISHERIES VISION FOR THE FUTURE 

In 2001, the Service worked with partners to refocus its Fisheries Program and to develop a vision. 

This vision of the Service and its Fisheries Program “is working with partners to restore and maintain 

fish and other aquatic resources at self-sustaining levels and to support Federal mitigation programs 

for the benefit of the American public.” To achieve the vision, the Fisheries program works with its 

partners to:

y protect the health of aquatic habitats, 

y restore fish and other aquatic resources, and 

y provide opportunities to enjoy the benefits of healthy aquatic resources. 

Together, the group developed a series of goals, objectives, and strategies to focus on key 

needs. Shell Keys NWR can contribute to the program’s recreational fishing goal to provide 

quality opportunities for responsible fishing and other related recreational enjoyment of aquatic 

resources on Service lands. 
18 Shell Keys National Wildlife Refuge 

LOUISIANA COMPREHENSIVE WILDLIFE CONSERVATION STRATEGY (WILDLIFE ACTION PLAN) 

The Louisiana Department of Wildlife and Fisheries Comprehensive Wildlife Conservation 

Strategy (CWCS) was defined in 2005 (Lester et al., 2005). Their mission statement follows: 

Louisiana Department of Wildlife and Fisheries’ mission is to manage, 

conserve, and promote wise utilization of Louisiana’s renewable fish and 

wildlife resources and their supporting habitats through replenishment, 

protection, enhancement, research, development, and education for the social 

and economic benefit of current and future generations; to provide 

opportunities for knowledge of and use and enjoyment of these resources; and 

to promote a safe and healthy environment for the users of the resources. 

The primary focus of the CWCS is species of conservation concern and the habitats they depend 

upon. Information relative to these species and those habitats found on Refuge System lands will be 

evaluated for opportunities to foster conservation efforts. 

In the Louisiana CWCS, Shell Keys NWR is located in the Gulf Coast Prairies and Marshes 

ecoregion. Shell Keys NWR is in the marine habitat outside the Vermillion/Cote 

Blanche/Atchafalaya Bay Complex Coastal Study Area, constituting one of seven coastal study 

areas seaward of the Gulf Intracoastal Waterway. Shell Keys NWR is one of numerous oyster 

reefs buffering Marsh Island Wildlife Refuge. Although no specific strategies for partnering with 

the Service are listed for the habitats on Shell Keys NWR, more general strategies on which the 

Service can partner with LDWF are: 

y partner to promote protection and support efforts for shoreline stabilization and habitat 

restoration of barrier islands; and 

y work with interested groups to promote appropriate use of dredge material and to develop 

improved management techniques for vegetated pioneer emerging delta habitat 

ECOLOGICAL THREATS AND PROBLEMS 

National wildlife refuges in the Mississippi Alluvial Valley (MAV) serve as part of the last safety net to 

support biological diversity—the greatest challenge facing the Service. According to the LMRE 

Team, the greatest threats to biological diversity within the MAV include: 

y The loss of sustainable communities, including the loss of 20 million acres of bottomland 

hardwood forests. 

y The loss of connectivity between bottomland hardwood forest sites (e.g., forest 

fragmentation). 

y The effects of agricultural and timber harvesting practices. 

y The simplification of the remaining wildlife habitats within the ecosystem and gene pools. 

y The effects of constructing navigation and water diversion projects. 

y The cumulative habitat effects of land and water resource development activities. 

Specific threats applicable to Shell Keys NWR include: 

y Problems associated with the Gulf of Mexico shipping operations, including soil erosion 

caused by wave action and contamination resulting from barge accidents. 

y Problems associated with sea level rise and climate change. 
Comprehensive Conservation Plan 19

EROSION AND CONTAMINATION 

Several major ecological threats that cause land loss and damage to Shell Keys NWR are tropical 

storms, subsidence and sea level rise, and oil and gas development. Shell Keys NWR is located in an 

area frequently in the path of tropical storms and hurricanes. Out of the 92 major hurricanes (category 

3 or higher) recorded making landfall between Texas and Maine from 1851 through 2004, 85 entered 

the Gulf of Mexico. Even storms coming onshore in states other than Louisiana can affect Shell Keys 

NWR, which is located off the mainland in the Gulf of Mexico. The shell/shell hash bottom habitat 

absorbs frequent storm surges. Although even tropical storms can cause impacts such as nest loss of 

ground nesting birds, much land loss has been caused by such notable hurricanes as the unnamed 

storm of 1947, Camille in 1969, Georges in 1998, Ivan in 2004, and Katrina and Rita in 2005. 

Active oil and gas development and exploration occur in areas adjacent to Shell Keys NWR. While 

impacts on the marine ecosystem are minimized and mitigated when possible, accidents near Shell 

Keys NWR occur that cause biological and ecological damage. Waterfowl and other water birds are 

susceptible to oiling and are especially vulnerable during nesting. Soils soak up oil and, depending 

on type, severity, and amount of oiling, have to be removed from the site. 

In the past there have been applications made for oil, gas, and mineral development and drilling but 

file documentation revealed that the islands were unsuitable for drilling and that it would destroy the 

area for the purpose for which it was established. A memorandum dated October 22, 1956, to the 

Service’s Regional Director stated "Although Shell Keys is listed in Appendix B of the revised leasing 

regulations, we believe that all operations should be denied on the basis that they would totally 

destroy the area for which it was established...." In a response to an application made in 1956, the 

Service’s Regional Director denied lease application citing that a "...so-called freeze order applicable 

to oil and gas leases on refuge lands still in effect...."

GLOBAL WARMING AND SEA LEVEL RISE 

The Service is mandated to address climate change in its management planning by the U.S. 

Department of Interior’s Secretarial Order 3226, issued on January 19, 2001. This order states that 

each bureau and office of the Department will consider and analyze potential climate change impacts 

when undertaking long-range planning exercises, when setting priorities for scientific research and 

investigations, when developing multi-year management plans, and/or when making major decisions 

regarding the potential utilization of resources under the Department’s purview. 

There is scientific consensus that suggests the earth is warming and that the primary cause of this 

warming is human-caused increases in greenhouse gas emissions. Since the beginning of the 

Industrial Revolution, average global temperatures have risen by one degree Fahrenheit, with the 

most accelerated warming occurring in the past two decades (Schlyer 2006). The complexity of 

effects that global warming will have on habitat and wildlife on national wildlife refuges is not known. 

Hand-in-hand with global warming is sea level rise. 

Coastal Louisiana has lost more than 1.2 million acres of land along its coast in the last 100 years and 

15,300 acres between 1990 and 2000, mostly due to the conversion of coastal wetlands to open water. 

Sea level is predicted to increase by 30 cm to 100 cm by 2100 based on the International Panel on 

Climate Change (IPCC) Special Report on Emissions Scenarios (SRES) (Meehl et al. 2007). Rising sea 

level may result in tidal marsh submergence (Moorhead and Brinson 1995). 
20 Shell Keys National Wildlife Refuge 

In an effort to address the potential effects of sea level rise on United States national wildlife refuges, 

the Fish and Wildlife Service contracted the application of the Sea-Level Affecting Marshes Model 

(SLAMM) for most Region 4 refuges. The SLAMM analysis for Shell Keys NWR assessed four 

different scenarios of sea level rise. Every scenario utilized predicted that by 2025 the southern 

portion of the refuge is predicted to disappear and a continued process of submergence is predicted 

for this site with complete loss by 2050 (Clough 2008). 

The SLAMM analysis further stated that “It is possible that Shell Keys NWR may reappear due to 

consolidation of submerged sediments and storm activities. The SLAMM model does not estimate 

such potential consolidation and reemergence of submerged lands. However, the results from this 

modeling indicate that permanent reemergence is unlikely due to the significant pressures of rising 

sea levels” (Clough 2008). 

 

PHYSICAL RESOURCES 

CLIMATE 

The climate in southwest Louisiana is relatively mild due to the subtropical influence of the Gulf of 

Mexico and cooler, drier air from the central plains. Summers tend to be hot and humid, and winters 

are mild. Average yearly precipitation is 66 inches. Louisiana is impacted by tropical weather 

disturbances with an average frequency of one tropical storm every 1.6 years, one hurricane every 

3.3 years, and a major hurricane every 14 years (Roth 1998). 

The Intergovernmental Panel on Climate Change recently concluded that warming of the climate is 

undeniable and could cause changes in our stewardship of land. Examples of potential changes are 

altered fire regimes, rain and snowfall patterns, access to water resources, hydrology in rivers and 

wetlands, frequency of extreme weather events, and rising sea levels at coastal refuges. 

GEOLOGY AND TOPOGRAPHY 

The Gulf of Mexico is a Mediterranean-type sea located at the southeastern corner of North America. 

The Gulf is bordered by the United States to the north (Florida, Alabama, Mississippi, Louisiana, 

Texas); five Mexican states to the west (Tamaulipas, Veracruz, Tabasco, Campeche, Yucatan); and 

the island of Cuba to the southeast. The Gulf measures approximately 1,600 kilometers from east to 

west, 900 kilometers from north to south, and has a surface area of 1.5 million square kilometers. 

The Gulf of Mexico basin is a relatively simple, roughly circular structural basin approximately 1,500 

km in diameter, filled in its deeper part with 10 to 15 km of sedimentary rocks that range in age from 

Late Triassic to Holocene (approximately 230 m.y. to present). The present Gulf of Mexico basin is 

believed to have had its origin in Late Triassic time as the result of rifting within the North American 

Plate at the time it began to crack and drift away from the African and South American plates. Rifting 

probably continued through Early and Middle Jurassic time with the formation of "stretched" or 

"transitional" continental crust throughout the central part of the basin. Intermittent advance of the 

sea into the continental area from the west during late Middle Jurassic time resulted in the formation 

of the extensive salt deposits known today in the Gulf of Mexico basin. It appears that the main 

drifting episode, during which the Yucatan block moved southward and separated from the North 

American Plate and true oceanic crust formed in the central part of the basin, took place during the 

early Late Jurassic, after the formation of the salt deposits (Gore 1992; Donnelly 1975; Martin 1975; 

Uchupi 1975; and Salvador 1991). 
Comprehensive Conservation Plan 21

Since Late Jurassic time, the basin has been a stable geologic province characterized by the 

persistent subsidence of its central part, probably due at first to thermal cooling and later to sediment 

loading as the basin filled with thick prograding clastic wedges along its northwestern and northern 

margins, particularly during the Cenozoic. To the east, the stable Florida platform was not covered by 

the sea until the latest Jurassic or the beginning of Cretaceous time. The Yucatan platform was 

emergent until the mid-Cretaceous. After both platforms were submerged, the formation of 

carbonates and evaporites has characterized the geologic history of these two stable areas. Most of 

the basin was rimmed during the Early Cretaceous by carbonate platforms, and its western flank was 

involved during the latest Cretaceous and early Tertiary in a compressive deformation episode, the 

Laramide Orogeny, which created the Sierra Madre Oriental of eastern Mexico. 

The northern Gulf of Mexico extends from Florida to the United States/Mexico border. North to south, 

the province extends from 200 miles inland of the present day shoreline to the Sigsbee escarpment. 

Sediments in the region are generally thick with the greatest sediment load provided by the 

Mississippi River. 

Shell Keys NWR is just outside the Teche/Vermillion Basin, in the Gulf of Mexico. Much of the basin 

is occupied by three large bays: East Cote Blanche, West Cote Blanche, and Vermilion. Marsh Island 

Wildlife Refuge is between the Gulf of Mexico and Vermillion Bay. Marsh Island Wildlife Refuge is an 

important hydrologic feature because it separates these bays from saltier water in the Gulf of Mexico. 

Shell Keys NWR and other live and relic oyster reefs southeast of Marsh Island buffer water 

exchange between the big bays and the Gulf of Mexico and contribute to stability of the coastlines. 

HYDROLOGY AND WATER QUALITY 

Shell Keys NWR is surrounded by shallow sea water. Pollutants in the water are a major problem in 

the Gulf coast region. The highest concentration of petrochemical companies in the nation is in the 

Gulf coast (Ning et. al, 1998). In addition to the chemicals released by the petrochemical companies, 

the Mississippi River carries the chemical pollutants of the central United States to the Gulf coast 

region (Ning et. al, 1998). Extraction, refining, and transport of oil and petro-chemicals all carry risks 

for the health of humans, wildlife, and ecosystems (Ning et. al, 1998). Extreme rains and flooding 

can enhance run-off of nutrients, pollutants, and micro-organics. Heavy rains and high nutrient levels 

can increase algal blooms and add to the "hypoxic zone" in the Gulf of Mexico, currently the size of 

New Jersey (Ning et. al, 1998). Salinity of water is also a problem in the Gulf coast region because it 

contributes to the loss of oysters (Ning et. al, 1998). Oysters have a positive effect on water quality 

by filtering water and removing pollutants. 

AIR QUALITY 

The growth of major cities and the effects of this growth on air quality is a major health concern in the 

Gulf coast region (Ning et. al, 1998). Large cities, such as Houston, Atlanta, and New Orleans, have 

major problems with air pollution, particularly tropospheric ozone (O3) (Ning et. al, 1998). Pollution 

stagnation, such as occurred in Baton Rouge in 1990 and 1995, is dangerous and may be 

exacerbated by increased temperatures (Ning et. al, 1998). 

BIOLOGICAL RESOURCES 

HABITAT 

Shell/Shell Hash Bottoms are estuarine water bottoms with significant coverage of mollusk shells. 

These bottoms may have potential for settlement of oysters, barnacles, or other invertebrate larvae 
22 Shell Keys National Wildlife Refuge 

that require hard substrates, and also serve as shelter for fish living in cryptic environments. These 

relatively hard substrates may reduce shoreline erosion along shallow, sloped shorelines, providing 

physical protection for adjacent marshlands. They also may cause changes in currents, creating 

environments that are beneficial for many species of fish and invertebrates. In the very low-salinity 

environments, relatively few species other that some small invertebrates are able to utilize the shell 

as a settlement substrate, but the other values of the habitat remain. 

Oysters provide the majority of the shell substrate in Louisiana, and are also a major fishery resource. 

Mussels, barnacles, worms, fishes, and a variety of other animals are either found in increasing 

abundance around oyster reefs, or are dependent upon these types of bottoms to survive. Other 

shell bottoms include Rangia clam and mixed shell hash. A number of bivalve mollusk species can 

co-exist in a single area, providing a variety of food sources and substrates to the animal 

communities. Shell and shell hash bottoms tend to be more resistant to erosion than mud bottoms, 

and relief to the bottom and modifying tidal currents, especially near passes. 

WILDLIFE 

In the past, Shell Keys NWR has supported large colonies of colonial nesting seabirds, although very 

limited. For a number of years, there has been only one islet at this location. This islet is composed 

almost entirely of shell fragments. It is extremely dynamic and builds or recedes with passing storms. 

Birds known to nest here include royal terns, sandwich terns, black skimmers, and laughing gulls. In 

addition, the islet is used at various times as a loafing area by white pelicans, brown pelicans, and various 

other species of terns and gulls. Recent hurricanes and storms have eroded the island to such an extent 

that no known nesting has occurred since 1992. On a recent survey of the island (May 2007), staff 

observed brown pelicans (30), Caspian terns (4), gull-billed tern (1), royal terns (6), ruddy turnstone (1), 

sandwich terns (12), sanderlings (6), and semi-plamated sandpipers (4). At the time, the tide was 2’ 7” 

above normal, exposing about 100 yards by 10 feet from 3-4 feet above the water. 

Gulf fisheries are some of the most productive in the world. In 2000, the commercial fish and shellfish 

harvest from the five U.S. Gulf states was estimated to be 1.7 billion pounds (approximately 772 

million kg), which represents almost 1/5 (19.4 percent) of the total domestic landings in the United 

States. In the same year, commercial catches in the Gulf represented approximately 25 percent of 

the total U.S. domestic commercial fishing revenue and were valued at over $900 million. The Gulf 

also supports a productive recreational fishery. Excluding Texas, U.S. Gulf states accounted for over 

40 percent (>104,000 lbs or >47,000 kg) of the U.S. recreational finfish harvest in 2000 (O'Bannon 

2001). As the refuge is located just south of the coastline, fishing is the only activity that can reliably 

occur on the refuge. Redfish, spotted seatrout, flounder, and other species feed on the baitfish 

sheltering in the shallow waters of the key. 

CULTURAL RESOURCES 

There are no known cultural resources on Shell Keys NWR. Geologically, Shell Keys NWR is 

relatively young and since formation, little-to-no human habitation has occurred. Infrastructure 

adjacent to the keys has been associated with the oil and gas industry. 

SOCIOECONOMIC ENVIRONMENT 

Shell Keys NWR is a remote island off the Louisiana coast and is considered part of Iberia Parish, 

Louisiana. Many of the land-based communities have rich historical backgrounds which began as 

large sugar cane plantations. Five percent of Iberia Parish residents report German ancestry and 

three percent report Irish. 
Comprehensive Conservation Plan 23

The parish seat is in the New Iberia metro area. The estimated population in 2004 was 74,449. This 

was an increase of 1.61 percent from the 2000 census. In 2002, the per capita personal income in 

Iberia Parish was $22,107. This was an increase of 17.6 percent from 1997. The 2002 figure was 72 

percent of the national per capita income, which was $30,906. 

Iberia Parish is one of about 3,141 counties and county equivalents in the United States. It has 575.1 

square miles in land area and a population density of 131.3 per-square-miles. In the last three 

decades of the 1900s, its population grew by 27.6 percent. On the 2000 census form, 98.8 percent of 

the population reported only one race, with 30.8 percent of these reporting African-American. The 

population of this parish is 1.5 percent Hispanic (of any race). The average household size is 2.82 

persons compared to an average family size of 3.28 persons. 

In 2006, manufacturing was the largest of 20 major sectors. It had an average wage per job of $46,858 

(Table 1). Per capita income grew by 26.5 percent between 1995 and 2005 (adjusted for inflation). 

Table 1. Population and industry statistics of Iberia Parish 

People and Income Overview

(By Place of Residence) Value Industry Overview (2006)(By Place of Work) Value

Population (2006) 75,509 Covered Employment 34,050 

Growth (%) since 1990 10.6% Average wage per job $39,154 

Households (2000) 25,381 Manufacturing - % all jobs in County 12.7% 

Labor Force (persons) (2006) 34,099 Average wage per job $46,858 

Unemployment Rate (2006) 3.3 Transportation and Warehousing - % all 

jobs in County 4.7% 

Per Capita Personal Income 

(2005) $26,378 Average wage per job $51,362 

Median Household Income (2004) $33,358 Health Care, Social Assistance - % all 

jobs in County 9.6% 

Poverty Rate (2004) 21.1 Average wage per job $26,821 

H.S. Diploma or More - % of 

Adults 25+ (2000) 66.9 Finance and Insurance - % all jobs in County 2.0% 

Bachelor's Degree or More - % of 

Adults 25+ (2000) 11.2 Average wage per job $36,884 

REFUGE ADMINISTRATION AND MANAGEMENT 

LAND PROTECTION AND CONSERVATION 

At present, no physical land protection measures other than refuge designation and law enforcement 

activities exist. 
24 Shell Keys National Wildlife Refuge 

OIL AND GAS ACTIVITY 

Shell Keys NWR does not hold the mineral rights for any of the acreage in its trust. Historically, no wells 

have been drilled on the refuge and currently no transmission or flow lines are present. However, as 

global and domestic demand increases for oil and gas, the refuge could potentially find itself with 

additional oil and gas related activities mainly in the form of a being in a proposed pipeline corridor or 

offshore drilling lease. 

As stated in previous comprehensive conservation plans (Cameron Prairie, Lacassine, and Sabine 

NWRs) recently completed, all refuges within the Southwest Louisiana National Wildlife Refuge 

Complex will manage future oil and gas development in accordance with the following: current Fish 

and Wildlife Service policy, which is derived from a July 17, 1986, Department of Interior Solicitor’s 

opinion and Louisiana State mineral rights law, which states that owners of sub-surface oil and gas 

mineral rights must be granted a reasonable and necessary means of extraction and production. 

In more explicit terms the Solicitor’s opinion states: 

The United States has a number of rights as a surface owner of refuge lands in Louisiana: 

1. It may request the mineral owner to alter its proposed operation to accommodate existing and 

planned uses of the refuge, provided that the burden on the mineral owner is not unreasonable. 

2. It may insist that the mineral owner use only the minimum amount of land that is required to carry 

out the operations. 

3. The necessary operations that are performed on the refuge must be carried out in a manner 

which is least injurious to refuge resources. 

4. Upon conclusion of each separable phase of operation the mineral owner must restore the 

surface to its original condition, insofar as is practicable. This will include filling pits no longer 

required, leveling land, cleaning up spilled oil and salt water, reseeding, and repair or replacement 

of damaged improvements. 

5. Access roads damaged by the mineral operator must be put in a condition for use by the United 

States, although they need not be completely regraded if damage is recurring and unavoidable. 

The United States may not: 

1. Charge a mineral operator for excavation of dirt on the lease where the dirt is required in order to 

carry out the operation. 

2. Charge for destruction of timber unless such right was reserved by the United States “grantor.”

 

3. Interfere with the reasonable and necessary operations of the mineral owner. 

Federally owned oil and gas rights on Refuge System lands embraced in the withdrawal of public 

domain and acquired lands of the United States are not available for leasing (43 CFR 3101.5-1) 

except where drainage occurs (43 CFR 3100.2). Shell Keys NWR falls under this closure. However, 

in the event circumstances ever change and some form of oil and gas development was to occur, a 
Comprehensive Conservation Plan 25

mutually agreed upon special use permit would be issued for all oil and gas operations to 

communicate Service expectations and environmental concerns to all operating companies. 

Transmission Pipeline Rights-of-Way 

Rights-of-way were inherited for transmission lines that traverse the refuge for the purpose of 

transporting oil, natural gas, synthetic liquid or gaseous fuels, or any refined petroleum based 

product. Transmission lines are usually large in diameter and transport product to or from large 

processing plants. These pipelines do not service mineral production from sub-surface minerals, but 

require a corridor of refuge land for transportation. In contrast, flow lines are usually the smallest in 

diameter and transport raw product from individual wells, from sub-surface mineral production, 

through the production separation process. Gathering lines, similar to flow lines, usually “gather” the 

production from multiple wells and transport it to production facilities. Permits for rights-of-way are 

not issued for flow lines and gathering lines. 

Existing oil and gas transmission lines and their associated rights-of-way on refuges in the Southwest 

Louisiana National Wildlife Refuge Complex that have been in place for decades have become 

manageable over the years. Their long-term effects on the environment, which have been identified 

as creating pathways for saltwater intrusion into freshwater marshes, are being indirectly addressed 

through numerous wetland management programs and laws such as the Louisiana Coastal Act, the 

Coastal Louisiana Wetlands Planning Protection and Restoration Act, the North American Wetlands 

Conservation Act, and many local government and private watershed initiatives such as the Cameron 

Creole Watershed Management Plan. These laws and initiatives have led to the development of 

significant wetland restoration projects which have mitigated the effects of some negative impacts 

associated with oil and gas transmission lines and associated rights-of-way. 

Future Management 

Existing oil and gas transmission lines on approved Fish and Wildlife Service rights-of-way currently within 

a national wildlife refuge will be managed as per Fish and Wildlife Service Policy 603 FW 2 in general, 

and explicitly under section 2.11D which states: 

Existing rights-of-way: We will not make a compatibility determination and will deny any request for 

maintenance of an existing right-of-way that will affect a unit of the Refuge System unless (1) the design 

adopts appropriate measures to avoid resource impacts and includes provisions to ensure no net loss of 

habitat quantity and quality; (2) restored or replacement areas identified in the design are afforded 

permanent protection as part of the national wildlife refuge or wetland management district affected by the 

maintenance; and (3) all restoration work is completed by the applicant prior to any title transfer or 

recording of the easement, if applicable. Maintenance of an existing right-of way includes minor 

expansion or minor realignment to meet safety standards. Examples of minor expansion or minor 

realignment include: expand the width of a road shoulder to reduce the angle of the slope; expand the 

area for viewing on-coming traffic at an intersection; and realigning a road to reduce the amount of curve. 

New construction for oil and gas transmission line rights-of-way will not be permitted because they can 

significantly contribute to further land loss on coastal Louisiana national wildlife refuges. Canals built for 

the construction and repair of oil and gas transmission lines allow saltwater to penetrate further inland, 

particularly during droughts and storms and can have severe effects on wetlands (Wang 1987). This is 

evident for the oil and gas transmission line rights-of-way which were established in accordance with 

federal and state transportation regulations already established on Sabine NWR. Oil and gas 

transmission lines constructed since the 1940s are still readily apparent. Compaction and displacement 

of hydric soils during oil and gas transmission lines repair or construction reduces water exchange and 

can result in increased waterlogging and plant mortality (Swenson and Turner 1987). Excavation 
26 Shell Keys National Wildlife Refuge 

necessary for oil and gas transmission line construction causes significant hydrological changes. 

Exposing hydric soil to oxygen changes the natural ecological processes, including chemical 

transformations, sediment transport, vegetation health, and migration of organisms. Furthermore, by 

altering salinity gradients and patterns of water flow, the natural process by which coastal marshes are 

replenished and protected cannot occur (U.S. Army Corps of Engineers 2004). 

Restoration of coastal marsh is a priority on national wildlife refuges in the Louisiana coastal zone. 

Approximately $24 million from CWPPRA has been dedicated to construct eight coastal restoration 

projects, and another $12 million is approved to construct two more projects within the Southwest 

Louisiana National Wildlife Refuge Complex. Extensive changes and alterations due to new pipeline 

rights-of-way could negatively affect restoration project predictability and life span. The stability 

created through these restoration projects could be jeopardized when major hydrologic changes 

occurred due to new pipeline construction. Therefore, managing existing pipelines and rights-of-way 

in accordance with current Service policy, and state and federal law is permissible under current 

conditions. Any expansion beyond the current conditions will be an inappropriate use considering the 

current status of Louisiana’s coastal wetlands and the Service’s role in managing and protecting this 

state’s coastal resources. 

VISITOR SERVICES 

Shell Keys NWR is accessible by boat only. The refuge is currently closed to all public use; however, 

occasional recreational fishing and wildlife observation is known to occur. 

Currently, no law enforcement position exists for Shell Keys NWR. The law enforcement staff from 

the Complex is available to patrol the refuge and partners with LDWF agents for coverage of each 

refuge in the Complex. Law enforcement issues involve oil and gas concerns, commercial fishing, 

and oyster shell dredging. 

PERSONNEL, OPERATIONS, AND MAINTENANCE 

Shell Keys NWR is part of the Southwest Louisiana National Wildlife Refuge Complex, which also 

includes the Cameron Prairie, Lacassine, and Sabine NWRs. Shell Keys NWR shares staff with 

Sabine NWR, which consists of three permanent employees, with occasional interns, volunteer 

workers, and term appointments supervised by the refuge manager. Positions include one refuge 

manager, one maintenance worker, and one refuge officer. A project leader stationed at the Complex 

headquarters at Cameron Prairie NWR supervises the refuge manager for Shell Keys/Sabine NWRs. 

Coordination/Cooperative Programs 

The refuge staff coordinates and cooperates extensively with state agencies, tribes, landowners, the 

public, conservation groups, oil and gas companies, and local agencies and organizations. Shell 

Keys NWR is a component of several important regional or ecosystem planning and management 

efforts, and works with all levels of government and non-governmental organizations and private 

citizens to accomplish goals and objectives specific to those efforts. 
Comprehensive Conservation Plan 27

III. Plan Development 

SUMMARY OF ISSUES, CONCERNS, AND OPPORTUNITIES 

The planning team identified a number of issues, concerns, and opportunities related to fish and 

wildlife protection, habitat restoration, recreation, and management of threatened and endangered 

species. Additionally, the planning team considered federal and state mandates, as well as 

applicable local ordinances, regulations, and plans. The team also directed the process of obtaining 

public input through a public scoping meeting and personal comments. All public and advisory team 

comments were considered; however, some issues important to the public fall outside the scope of 

the decisions to be made within this planning process. The team has considered all issues that arose 

through the planning process, and has developed a plan that attempts to balance the competing 

opinions regarding important issues. The team identified those issues that, in the team’s best 

professional judgment, are most significant to the refuge. A summary of the significant issues for 

Shell Keys NWR follows. 

FISH AND WILDLIFE POPULATION MANAGEMENT 

Historically, Shell Keys NWR has supported colonial nesting birds. Small nesting colonies of brown 

pelicans; laughing gulls; and royal, Caspian, and sandwich terns used the islands. It is possible that 

black skimmers and sooty, common, least, Forster’s, and gull-billed terns also used the island. 

Hurricanes and tropical storms have significantly eroded and submerged the island, leaving very little 

habitat above the waterline. It is doubtful the island will ever regain enough land above the waterline to 

provide safe nesting sites for significant numbers of birds. 

The eastern and Caribbean subspecies of the brown pelican remain endangered in California, 

Louisiana, Mississippi, Oregon, Puerto Rico, Texas, Virgin Islands, Washington, and Central 

and South America. The brown pelican was extirpated from Louisiana during the 1960s and 

later reintroduced at three sites, one of which was the north island of the Chandeleurs. The 

Louisiana population grew exponentially after the reintroductions. 

Small shorebirds have utilized the refuge as stop-over habitat. The federally listed piping plover is 

considered threatened throughout its wintering range along the south Atlantic and Gulf coasts, and 

Caribbean beaches and barrier islands. Other shorebirds of interest observed on Shell Keys NWR are 

semi-palmated sandpipers, ruddy turnstones, dowitchers, sanderlings, and other shorebird species. 

HABITAT MANAGEMENT 

Shell Keys NWR has the potential for being an important area for black skimmers, piping plovers, 

brown pelicans, and other bird species; however, it would have to be enhanced by adding more shell 

to a much higher level. 

Given the current circumstances, future habitat management depends on the amount and sources of 

sediment and funding available, and any new technologies which can be developed. A feasibility study 

would need to be conducted through partnerships with U.S. Geological Survey (USGS), LDWF, and 

others to determine restoration options and the sustainability of restoration efforts. 
28 Shell Keys National Wildlife Refuge 

RESOURCE PROTECTION 

Law enforcement is involved with every release or spill event involving oil and gas on the refuge. 

Officers work cooperatively with the state and other federal agencies to investigate each event to 

determine if charges should be filed. Other violations involve illegal fishing, oyster dredging, and 

oyster spreading. 

VISITOR SERVICES 

Due to the remoteness of the island, opportunities for public use are extremely limited. The refuge is 

currently closed to all public use; however, recreational fishing, bird watching, and photography have 

been observed. Since it is possible this use can occur on the refuge, given its compatibility, opening 

the refuge to these uses would be in the best interest of the Service. 

REFUGE ADMINISTRATION 

Presently, support from other staff of the Complex cover the administration of Shell Keys NWR. 

Funding is administered through the Complex as part of the headquarters. 

 

Wilderness Review 

Refuge planning policy requires a wilderness review as part of the comprehensive conservation 

planning process. The results of the wilderness review are included in Appendix H. 
Comprehensive Conservation Plan 29

IV. Management Direction 

INTRODUCTION 

The Service manages fish and wildlife habitats considering the needs of all resources in decisionmaking. But first and foremost, fish and wildlife conservation assumes priority in refuge management. 

A requirement of the Improvement Act is for the Service to maintain the ecological health, diversity, 

and integrity of refuges. Public uses are allowed if they are appropriate and compatible with wildlife 

and habitat conservation. The Service has identified six priority wildlife-dependent public uses. 

Hunting, fishing, wildlife observation, wildlife photography, and environmental education and 

interpretation are therefore emphasized in this CCP. 

Described below is the CCP for managing the refuge over the next 15 years. This management direction 

contains the goals, objectives, and strategies that will be used to achieve the vision of Shell Keys NWR. 

ALTERNATIVES FOR MANAGING SHELL KEYS NWR 

The following three alternatives for managing the refuge were considered, with Alternative C chosen 

as the preferred alternative. Each alternative was described in section B of the Draft CCP. 

A - No Action (Current Management) 

B - Custodial Cooperative Management 

C - Large-scale Habitat Restoration and Cooperative Management (Preferred) 

Implementing the preferred alternative will result in partnering with the LDWF, other conservation 

agencies, and large corporations to conduct a feasibility study based on dedicated dredging and 

exploring landscape scale efforts to restore the shell islands. Management will open the refuge to the 

public uses of fishing, wildlife observation, and wildlife photography. Public outreach will improve 

through the use of kiosks and a wayside exhibit, with updated brochures and maps, at the Complex 

headquarters. 

VISION FOR SHELL KEYS NWR 

Shell Keys NWR will provide dynamic shell island and reef complex habitat for the conservation and 

protection of colonial nesting seabirds and other wildlife in partnership with LDWF, other agencies, 

organizations, and individuals. Through the Complex visitor center, public use will emphasize fishing, 

wildlife observation, and wildlife photography; outreach will focus on interpretation and environmental 

education programs based on Shell Keys NWR’s unique natural resources. 

GOALS, OBJECTIVES, AND STRATEGIES FOR SHELL KEYS NWR 

The goals, objectives, and strategies presented for Shell Keys NWR are the Service’s response 

to the issues, concerns, and needs expressed by the planning team, the refuge staff and 

partners, and the public, and are presented in hierarchical format. Chapter V identifies the 

projects associated with the various strategies. 
30 Shell Keys National Wildlife Refuge 

These goals, objectives, and strategies reflect the Service’s commitment to achieve the mandates of 

the Improvement Act, the mission of the Refuge System, and the purposes and vision of Shell Keys 

NWR. With resources, as outlined in Chapter V, the Service intends to accomplish these goals, 

objectives, and strategies within the next 15 years. 

FISH AND WILDLIFE POPULATION MANAGEMENT 

Goal A. Through the use of partnerships, protect coastal fish and wildlife species, placing 

special emphasis on migratory birds, colonial nesting waterbirds, and threatened and 

endangered species. 

Discussion: Because of its location, Shell Keys NWR has historically served as habitat for many 

migratory bird species either for an entire season or for only a matter of hours or days. The island 

can give refuge to migratory birds on a regular basis or may serve as a haven to birds blown off 

course and not following normal migration patterns. 

Species that may use the refuge include brown pelicans; laughing gulls; black skimmers; and royal, 

Caspian, sandwich, sooty, common, least Forster’s, and gull-billed terns. It is unknown if the island 

will rebuild or be restored to the extent that nesting colonies can return. 

Threatened and endangered species that may utilize the refuge include the eastern brown 

pelican and the piping plover (wintering). 

Objective A-1. Develop a cooperative natural resource agreement with LDWF to monitor if colonial 

nesting seabirds, federally listed threatened and endangered species, and other species of federal 

responsibility are using the refuge. 

Discussion: Situated within close proximity to the Marsh Island Wildlife Refuge, developing a 

memorandum of understanding with LDWF would assist Shell Keys NWR in monitoring biological 

resources, managing natural resources, and addressing enforcement issues related to commercial 

and recreational fishing, and issues related to oil and gas. The most recent hurricanes, Lilli and Rita, 

severely impacted this area. The establishment of a cooperative agreement with LDWF relative to 

habitat restoration, biological monitoring, and natural resource management will benefit both 

agencies and the resources. 

Strategies:

y If any nesting occurs in response to habitat recovery and restoration, close island to public 

use. 

y Conduct annual bird surveys on the island in conjunction with LDWF, paying particular 

attention to brown pelican and piping plover use. 

y Monitor shorebird and other migratory bird populations during peak migration periods. 

y Develop and maintain a data base of survey information. 

y Determine the value of the essential fish habitat within the Shell Keys NWR boundary to 

species such as red drum, brown shrimp, white shrimp, and Gulf stone crab. 

Objective A-2. Working with academia, LDWF, and the National Marine Fisheries Service (NMFS), 

initiate study to determine the value of Shell Keys NWR to oyster resource and provide 

recommendations. 
Comprehensive Conservation Plan 31

Strategies: 

y Utilize grants and other funding sources to initiate oyster resource survey in partnership with 

others. 

y Determine feasibility of restoring island with oyster resource. 

y In the process of the feasibility study, consult with the National Marine Fisheries Service under 

provision of the Magnuson-Stevens Act, and other entities to ensure adverse impacts are 

avoided or mitigated. 

HABITAT MANAGEMENT 

Goal B. Through the use of partnerships, protect, conserve, and, if feasible, restore the physical 

and ecological functions of shell island and reef complex habitats for fish and wildlife resources. 

Discussion: The refuge is highly dynamic and constantly evolving. The most influential effect on 

the refuge is erosion, which results from strong storms and overwash. Over the years, hurricanes 

and severe storms have changed the face of the refuge in both dramatic and subtle ways. 

Severe storms in recent history have resulted in either moderate build-up or significant loss of the 

land existing above water. Usually, there is post-storm recovery to some extent. The 

Intergovernmental Panel on Climate Change recently concluded that warming of the climate is 

undeniable and could cause changes in our stewardship of land. Examples of potential changes 

are frequency of extreme weather events and rising sea levels at coastal refuges. At this point, it 

is difficult to set specific wildlife habitat goals. Refuge staff has learned from the past that smallscale restoration projects can no longer achieve lasting benefits. It will take working in 

partnership with others to achieve large-scale and costly restoration of the refuge. Information to 

be provided by USGS on sediment loss and the availability of suitable dredge material will be 

used to determine the feasibility of restoration options. 

Objective B-1. Shell Island Habitat: In partnership with LDWF, COE, USGS, and others, conduct a 

feasibility study to restore and/or enlarge the entire island to provide increased nesting habitat for 

colonial nesting birds based on historic information. 

 

Strategies: 

y Appropriately survey and mark the boundary with anchored ocean buoys. 

y Work with the state to establish a well-defined buffer zone approximately one-half mile 

around the island. 

y Enter into a contract with USGS or other appropriate contractor to determine the feasibility 

of protecting the shoreline and base substrate of the Shell Keys NWR. If it is determined 

that the project is feasible, move forward to seek funding for a beach nourishment and 

substrate replacement project to include anchoring buoy markers along the boundary of 

the island to aid in preventing oyster dredging ships from impacting the island. 

y Work with LDWF to determine if oyster seed ground areas within the boundary of Shell 

Keys NWR can be dissolved and that oyster leases not be renewed. 

y Develop and maintain partners such as LDWF, COE, USGS, TNC, Gulf of Mexico 

Foundation, Conoco Phillips, Shell Oil, and others to determine potential and value of 

restoration. 

y Seek funding and partners for dedicated dredge disposal projects to create three to five 

acres of restored shell habitat if the project is deemed feasible. 
32 Shell Keys National Wildlife Refuge 

y If restoration is feasible, and implementation is successful, proactively search for funding 

and partners for maintaining shell habitat. 

y If restoration is feasible, design restoration features that minimize impacts to the large 

oyster reef complex. Oysters tend to be more resistant to erosion and create relief which 

increases fish utilization. Designs should include access routes and containment dikes 

that avoid or minimize disturbances or impacts to the large oyster reef. 

y If restoration is feasible, consult with the National Marine Fisheries Service under 

provision of the Magnuson-Stevens Act and other entities to ensure adverse impacts are 

avoided or mitigated. 

y Participate in landscape-level coastal initiatives such as CWPPRA, LCA, CIAP, and Coast 

2050 as appropriate. 

RESOURCE PROTECTION 

Goal C. Through the use of partnerships, manage natural, cultural, and historical resources, 

and petroleum infrastructure and activities to protect habitat, and migratory and nesting birds. 

Objective C-1. Work with the LDWF and other partners to monitor oil and gas activity in the area. 

Discussion: Shell Keys NWR does not hold the mineral rights for any of the acreage in its trust. 

Historically, no wells have been drilled on the refuge and currently no transmission or flow lines are 

present. However, as global and domestic demand increases for oil and gas, the refuge could 

potentially find itself with additional oil and gas activities. 

Strategies: 

y All transmission and oil and gas activities will be managed in accordance with the policy 

described in Chapter II under the Refuge Administration and Management section. 

y Convey the Shell Keys NWR spill response protection strategy to the appropriate United 

States Coast Guard (USCG) Area Contingency Plan coordinators annually. 

y Coordinate with the One Gulf Plan for spill response priorities and refuge emergency spill 

response actions. 

Objective C-2. Work with State Historic Preservation Office to determine if any cultural or historic 

resources existed on the island.

VISITOR SERVICES 

Goal D. Provide, as appropriate, limited public wildlife-dependent recreational activities, such 

as fishing, wildlife observation, and wildlife photography.

Discussion: Recreational activities on Shell Keys NWR revolve around fishing, principally wade 

fishing in the shallow waters. Access is by boat. Disturbance to nesting colonies, if nesting were to 

resume, will be discouraged by posting the area as closed to prevent anglers and other visitors from 

walking among the nesting birds. Wildlife observation and photography are allowed but are not 

common because of the harshness of the environment, remoteness, insects, and rapidly changing 

weather patterns. The refuge does not offer transportation to the islands for any of the uses open to 

the public; visitors must rely on privately owned boats and charter fishing businesses. 
Comprehensive Conservation Plan 33

Objective D-1: Offer limited visitor services and programs of fishing, wildlife observation, and wildlife 

photography except in certain portions identified with “Area Closed” signs to protect bird nesting areas. 

Discussion: Opening opportunities for fishing, wildlife observation, and wildlife photography will allow 

the public to appreciate the value of the refuge as long as nesting areas are protected, should nesting 

resume. 

Strategies:

y Open limited fishing program; partner with LDWF for enforcement of regulations. 

y Explore possibilities of providing a tour of the islands for wildlife observation and interpretation 

as part of a Southwest Louisiana NWR Complex special event. 

y Develop a Visitor Services’ Plan as part of Southwest Louisiana NWR Complex Visitor Service 

Plan within six years of CCP implementation. 

y Evaluate access as appropriate. 

Objective D-2: Improve the quality and quantity of information about Shell Keys NWR offered 

to the public. 

Discussion: Shell Keys NWR is part of a unique and declining chain of barrier islands along the 

Louisiana coast. As stated in the Final CCP for Lacassine NWR, Cameron Prairie NWR’s Visitor 

Center will also serve as the Southwest Louisiana National Wildlife Refuge Complex Visitor Center, 

highlighting all refuges within the Complex. Through the use of this Visitor Center, Shell Keys NWR’s 

unique wildlife habitat and coastal protection stature will be portrayed. 

Strategies:

y Include information about Shell Keys NWR at wayside panels and kiosk at Southwest 

Louisiana NWR Complex Headquarters. 

y Improve and maintain current information on the web page and make it interactive so that 

information is two-way; include interpretive information. 

y Update the Shell Keys general refuge brochure as needed. 

y Include maps on kiosks; place fishing information and maps at local marinas; place small 

kiosk or panel at marina to include fish identification. 

y Include information on kiosks about the Refuge System, colonial nesting birds, and wading 

birds. 

y Communicate key issues and special events in news releases in local papers, partner with 

Iberia Parish on special events and festivals, and with the Southwest Louisiana NWR 

Complex headquarters’ special events. 

REFUGE ADMINISTRATION 

Goal E. Develop and maintain the Southwest Louisiana NWR Complex Headquarters to support, 

direct, and manage the needs, resources, and staff of Cameron Prairie, Lacassine, Sabine, and 

Shell Keys NWRs; Rockefeller State Refuge (administrative oversight); and the Cameron-Creole 

Watershed Project. Work with LDWF and other partners to protect Shell Keys NWR. 
34 Shell Keys National Wildlife Refuge 

Discussion: Shell Keys NWR is administered as one of four refuges under the Southwest Louisiana 

NWR Complex. Presently, two staff members share direct responsibility for Shell Keys NWR, with 

assistance from approximately 20 other staff members working on the Complex of refuges. Most 

personnel work out of the Complex headquarters. Law enforcement is an important tool for 

protection of the natural resources of the refuge. 

Objective E-1: Ensure employees with complex-wide responsibilities support the refuge. 

Strategies:

y Increase refuge officers’ presence at Shell Keys NWR. 

y Update Law Enforcement Plan by 2014. 

y Partner with LDWF to provide protection to resources and visitors. 

Objective E-2: Develop Memorandum of Understanding (MOU) with the LDWF to protect natural 

resources. 

Discussion: Given the close proximity to the LDWF Marsh Island Wildlife Refuge, and difficulty 

reaching Shell Keys NWR, co-management of the natural resources and law enforcement issues is 

most practical. 

Strategies: 

y Develop a MOU to manage natural resources of Shell Keys NWR in coordination and 

collaboration with LDWF. 

y Review Law Enforcement MOU and update as necessary. 
Comprehensive Conservation Plan 35

V. Plan Implementation 

INTRODUCTION 

Refuge lands are managed as defined under the Improvement Act. Congress has distinguished a 

clear legislative mission of wildlife conservation for all national wildlife refuges. National wildlife 

refuges, unlike other public lands, are specifically dedicated to the conservation of the Nation’s fish 

and wildlife resources and wildlife-dependent recreational uses. Priority projects emphasize the 

protection and enhancement of fish and wildlife species first and foremost, but considerable 

emphasis is placed on balancing the needs and demands for wildlife-dependent recreation and 

environmental education. 

To accomplish the purpose, vision, goals, and objectives contained in this CCP for Shell Keys NWR, 

this section identifies specific projects, funding and personnel needs, partnership opportunities, and 

required step-down management plans. 

This CCP focuses on the importance of funding the operations and maintenance needs of the refuge 

to ensure the refuge staff can achieve the goals and objectives identified and are crucial to fulfill the 

purpose for which the refuge was established. The refuge’s role in protecting and providing habitat 

for migratory waterfowl, birds, and endangered species is critical. Proposed priority public use 

programs will establish opportunities for wildlife-dependent recreation. 

PROPOSED PROJECTS 

Listed below are the proposed project summaries and their associated costs for fish and wildlife 

population management, habitat management, resource protection, visitor services, and refuge 

administration for the next 15 years. This proposed project list (Table 2.) reflects the priority needs 

identified by the public, planning team, and refuge staff based upon available information. These 

projects were generated for the purpose of achieving refuge-specific objectives and strategies. The 

primary linkages of these projects to those planning elements are identified in each summary. 

FISH AND WILDLIFE POPULATION MANAGEMENT 

Project 1. Work with LDWF to monitor species of concern, targeted species, and species of federal 

responsibility.

National wildlife refuges are mandated to manage for threatened and endangered species if they 

occur on the refuge. However, refuges are also responsible for management of other wildlife species 

if the action does not negatively impact the threatened or endangered species. Refuge management 

is geared toward managing the ecosystem as a whole. 

y Develop a wildlife inventory plan based on species selected as priority species. 

y Partner with local colleges or universities to conduct research concerning remaining available 

nesting habitat since Hurricane Rita. 

y Threatened and endangered species will be surveyed and monitored. Adaptive refuge 

management actions will reflect data collected. 
36 Shell Keys National Wildlife Refuge 

The initial cost for researchers and planning documents will be approximately $75,000. The annual 

survey cost for one biologist’s time is $5,000. (Linkages: Goal A, Objectives A-1-2; Goal E, 

Objectives E-1-2)

HABITAT MANAGEMENT 

Project 2. Conduct and coordinate a feasibility study to determine if island restoration is possible. 

Refuge staff will: 

y Determine a reasonable and feasible way to identify the boundary of the refuge with a 

triangulation of anchored navigational buoys placed in such a manner as to prevent the raking 

of the refuge by oyster boats. 

y Appropriately survey and mark the refuge boundary with ocean buoys. 

y Work with the Louisiana Governor’s office and LDWF to establish a well-defined buffer zone 

approximately one-half mile around island. 

y Develop a scope of work and contract with USGS and the University of New Orleans to 

determine current status of the island and the ability to rebuild with restoration. 

y Develop cost estimate of feasibility study in partnership with others. 

y Determine sources of dredge material. 

y If restoration is economically and environmentally feasible, determine cost estimates, timeline 

for completion, and implementation of each construction phase. 

y Consult with all necessary state and federal agencies regarding things such as threatened 

and endangered species, essential fish habitat, and mitigation measures. 

The initial and annual cost for evaluating the feasibility of large scale habitat restoration of the island 

is unknown due to project complexities. This cost will be assessed once the project is initiated. 

(Linkages: Goal B, Objectives B-1-2; Goal C, E):

 

RESOURCE PROTECTION 

Project 3. Administer oil and gas program with efforts guided to protect surface habitat and wildlife 

on the refuge. All activities relating to oil and gas near the refuge should be monitored. 

(Linkages: Goal C, Objective C-1, Goal E)

. 

y Issue special use permits and assess mitigation for impacts to the surface of the refuge if they 

cannot be avoided. 

y Response to all spill event and releases are conducted immediately after located; however, 

before work is performed the response/clean-up company must consult with the refuge 

manager to ensure methods are approved. 

y Provide guidance for wildlife-oriented protection methods, such as bird cannons, mylar 

steamers, and predator eyes, during spill events. 

y All transmission lines and oil and gas activities will be managed in accordance with the policy 

described in Chapter II. 

VISITOR SERVICES 

Project 4. Provide opportunities for recreational fishing, wildlife observation, and wildlife photography 

(Linkages: Goal D, Objectives D-1-2, Goal E). 
Comprehensive Conservation Plan 37

Fishing, wildlife observation, and wildlife photography opportunities on the refuge will be offered. Shell 

Keys NWR offers limited emergent shell habitat for fishing off of and for viewing sea birds. Access to the 

refuge is by boat only. Construct and place kiosks or other outreach materials at local marinas. 

FUNDING AND PERSONNEL 

Table 2. Summary of projects 

PROJECT 

NUMBER PROJECT TITLE FIRST YEAR COST * 

RECURRING 

ANNUAL COST 

1 Monitor and manage other trust 

resource populations 

$75,000 $5,000

2 Conduct and coordinate a feasibility 

study to determine if island 

restoration is possible 

Unknown Unknown

3 Administer oil and gas program $70,000 $70,000

4 Provide opportunities for recreational 

fishing, wildlife observation, and 

wildlife photography 

$15,000 $10,000

* Cost estimates are rough and undocumented; funding sources would be various and not all FWS funding. 

PARTNERSHIP/VOLUNTEER OPPORTUNITIES 

A key element of this CCP is to establish a cooperative agreement with LDWF, and partnerships 

with private organizations and other state and federal natural resource agencies. Partnerships 

are critically important to achieve refuge goals, leverage funds, minimize costs, reduce 

redundancy, and bridge relationships. In the immediate vicinity of the refuge, opportunities exist 

to establish and maintain partnerships with LDWF, Iberia Parish organizations, U.S. Customs, 

and the U.S. Coast Guard. 

STEP-DOWN MANAGEMENT PLANS 

A CCP is a strategic plan that guides the direction of the refuge. A step-down management plan 

provides more specific guidance on activities, such as habitat and visitor services’ management. 

Step-down plans (Table 3) are developed in accordance with the National Environmental Policy 

Act (NEPA), which requires the identification and evaluation of alternatives and public review and 

involvement prior to their implementation. 
38 Shell Keys National Wildlife Refuge 

Table 3. Shell Keys NWR step-down management plans 

Step-down Plans Completion Date

Visitor Use 2010 

Law Enforcement 2014 

Wildlife Inventory 2010 

Habitat Management 2015 

Sign 2020 

Fisheries Management 2020 

MONITORING AND ADAPTIVE MANAGEMENT 

Adaptive management is a flexible approach to long-term management of biotic resources that is directed 

over time by the results of ongoing monitoring activities and other information. More specifically, adaptive 

management is a process by which projects are implemented within a framework of scientifically driven 

experiments to test the predictions and assumptions outlined within a plan. 

To apply adaptive management, specific survey, inventory, and monitoring protocols will be adopted for the 

refuge. The habitat management strategies will be systematically evaluated to determine management 

effects on wildlife populations. This information will be used to refine approaches and determine how 

effectively the objectives are being accomplished. Evaluations will include ecosystem team and other 

appropriate partner participation. If monitoring and evaluation indicate undesirable effects for target and 

non-target species and/or communities, then alterations to the management projects will be made. 

Subsequently, the CCP will be revised. Specific monitoring and evaluation activities will be described in the 

step-down management plans. 

PLAN REVIEW AND REVISION 

The CCP will be reviewed annually in development of refuge annual work plans and budget. It will 

also be reviewed to determine the need for revision. A revision will occur if and when conditions 

change or significant information becomes available, such as a change in ecological conditions or a 

major refuge expansion. The CCP will be augmented by detailed step-down management plans to 

address the completion of specific strategies in support of goals and objectives. Revisions to the 

CCP and the step-down management plans will be subject to public review and NEPA compliance. 
Appendices 39

APPENDICES 

Appendix A. 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 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. 

Alluvial: Sediment transported and deposited in a delta or riverbed by flowing 

water. 

Alternative: (1) A reasonable way to fix the identified problem or satisfy the stated 

need (40 CFR 1500.2). (2) Alternatives are different sets of objectives 

and strategies or means of achieving refuge purposes and goals, 

helping fulfill the Refuge System mission, and resolving issues (Service 

Manual 602 FW 1.6B). 

Anadromous: Migratory fishes that spend most of their lives in the sea and migrate to 

fresh water to breed. 

Beneficial Dredging Using the spoil for restoring and building elevation from dredging that 

would take place regardless of the use of the spoil (see dedicated 

dredging). 

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). 

Focus is on indigenous species, biotic communities, and ecological 

processes. Also referred to as Biodiversity. 

Carrying Capacity: The maximum population of a species able to be supported by a habitat 

or area. 

Categorical Exclusion 

(CE,CX, CATEX, 

CATX): 

A category of actions that do not individually or cumulatively have a 

significant effect on the human environment and have been found to 

have no such effect in procedures adopted by a federal agency 

pursuant to the National Environmental Policy Act (40 CFR 1508.4). 

CFR: Code of Federal Regulations. 
40 Shell Keys National Wildlife Refuge 

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 purpose(s) of the 

national wildlife refuge (50 CFR 25.12 (a)). 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; helps 

achieve the goals of the National Wilderness Preservation System; and 

meets other mandates (Service Manual 602 FW 1.6 E). 

Concern: See Issue. 

Cover Type: The present vegetation of an area. 

Crevasse Relatively small opening or breach in levee or embankment. 

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 background 

literature search, comprehensive field examination to identify all 

exposed physical manifestations of cultural resources, or 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). 

Cultural Resource 

Overview: 

A comprehensive document prepared for a field office that discusses, 

among other things, its prehistory and cultural history, the nature and 

extent of known cultural resources, previous research, management 

objectives, resource management conflicts or issues, and a general 

statement on how program objectives should be met and conflicts 

resolved. An overview should reference or incorporate information from 

a field office’s background or literature search described in Section VIII 

of the Cultural Resource Management Handbook. 

(Service Manual 614 FW 1.7) 

Cultural Resources: The remains of sites, structures, or objects used by people in the past. 

Dedicated Dredging Dredging for the purpose of restoring and building elevation (see 

Beneficial Dredging). 
Appendices 41

Designated Wilderness 

Area:

An area designated by the United States Congress to be managed as 

part of the National Wilderness Preservation System (Draft Service 

Manual 610 FW 1.5). 

Disturbance: Significant alteration of habitat structure or composition. May be 

natural (e.g., fire) or human-caused events (e.g., aircraft overflight). 

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. 

Emergent Marsh Wetlands dominated by erect, rooted, herbaceous plants. 

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 

the state 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). 

Environmental Impact 

Statement (EIS): 

A detailed written statement required by Section 102(2)(C) of NEPA, 

analyzing the environmental impacts of a proposed action, adverse 

effects of the project that cannot be avoided, alternative courses of 

action, short-term uses of the environment versus the maintenance and 

enhancement of long-term productivity, and any irreversible and 

irretrievable commitment of resources (40 CFR 1508.11). 

Estuary: The wide lower course of a river into which the tides flow. The area 

where the tide meets a river current. 

Finding of No 

Significant Impact 

(FONSI): 

A document prepared in compliance with NEPA, 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). 
42 Shell Keys National Wildlife Refuge 

Goal: Descriptive, open-ended, and often broad statement of desired future 

conditions that conveys a purpose but does not define measurable units 

(Service Manual 620 FW 1.6J). 

Habitat: Suite of existing environmental conditions required by an organism for 

survival and reproduction. The place where an organism typically lives.

Habitat Restoration: Management emphasis designed to move ecosystems to desired 

conditions and processes, and/or to healthy ecosystems. 

Habitat Type: See Vegetation Type. 

Improvement Act: The National Wildlife Refuge System Improvement Act of 1997. 

Informed Consent: The grudging willingness of opponents to “go along” with a course of 

action that they actually oppose (Bleiker). 

Issue: Any unsettled matter that requires a management decision, such as an 

initiative, opportunity, resource management problem, threat to the 

resources of the unit, conflict in uses, public concern, or other presence 

of an undesirable resource condition (Service Manual 602 FW 1.6K). 

Management 

Alternative: 

See Alternative. 

Management Concern: See Issue. 

Management 

Opportunity: 

See Issue. 

Migration: The seasonal movement from one area to another and back. 

Mission Statement: Succinct statement of the unit’s purpose and reason for being. 

Monitoring: The process of collecting information to track changes of selected 

parameters over time. 

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). 
Appendices 43

National Wildlife 

Refuge System 

Improvement Act of 

1997 (Public Law 105-

57): 

Under the Improvement Act, the Service is required to develop 15-

year comprehensive conservation plans for all national wildlife 

refuges outside Alaska. The Act also describes the six public uses 

given priority status within the NWRS (i.e., hunting, fishing, wildlife 

observation, wildlife photography, and environmental education and 

interpretation). 

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. 

National Wildlife 

Refuge System: 

Various categories of areas administered by the Secretary of the 

Interior for the conservation of fish and wildlife, including species 

threatened with extinction; all lands, waters, and interests therein 

administered by the Secretary as wildlife refuges; areas for the 

protection and conservation of fish and wildlife that are threatened with 

extinction; wildlife ranges; games ranges; wildlife management areas; 

or waterfowl production areas. 

National Wildlife 

Refuge: 

A designated area of land, water, or an interest in land or water within 

the Refuge System. 

Native Species: Species that normally live and thrive in a particular ecosystem. 

Notice of Intent (NOI): A notice that a comprehensive conservation plan will be prepared and 

considered (40 CFR 1508.22). Published in the Federal Register. 

Noxious Weed: A plant species designated by Federal or State law as generally 

possessing one or more of the following characteristics: aggressive or 

difficult to manage; parasitic; a carrier or host of serious insect or 

disease; or non-native, new, or not common to the United States, 

according to the Federal Noxious Weed Act (PL 93-639). A noxious 

weed is one that causes disease or had adverse effects on man or his 

environment and therefore is detrimental to the agriculture and 

commerce of the Untied States and to the public health. 

Objective: A concise statement of what we want to achieve, how much we want to 

achieve, when and where we want to achieve it, and who is responsible 

for the work. Objectives derive from goals and provide the basis for 

determining strategies, monitoring refuge accomplishments, and 

evaluating the success of strategies. Making objectives attainable, 

time-specific, and measurable (Service Manual 602 FW 1.6N). 

Plant Association: A classification of plant communities based on the similarity in 

dominants of all layers of vascular species in a climax community. 
44 Shell Keys National Wildlife Refuge 

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. 

Preferred Alternative: This is the alternative determined [by the decision-maker] that best 

achieves the refuge purpose, vision, and goals; contributes to the 

Refuge System mission, addresses the significant issues; and is 

consistent with principles of sound fish and wildlife management. 

Prescribed Fire: The application of fire to wildland fuels to achieve identified land use 

objectives (Service Manual 621 FW 1.7). May be from natural ignition 

or intentional ignition. 

Priority Species: Fish and wildlife species that the Service believes 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 

recreation, commercial, and/or tribal importance. 

Public Involvement 

Plan: 

Broad long-term guidance for involving the public in the comprehensive 

planning process. 

Public Involvement: A process that offers impacted and interested individuals and 

organizations an opportunity to become informed about, and to express 

their opinions on Service actions and policies. In the process, these 

views are studied thoroughly and thoughtful consideration of public 

views is given in shaping decisions for refuge management. 

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. 

Purposes of the 

Refuge: 

“The purposes 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 sub-unit.” For refuges that encompass 

congressionally designated wilderness, the purposes of the Wilderness 

Act are additional purposes of the refuge (Service Manual 602 FW 106 S). 
Appendices 45

Recommended 

Wilderness: 

Areas studied and found suitable for wilderness designation by both the 

Director of the Fish and Wildlife Service and the Secretary of the 

Department of the Interior, and recommended for designation by the 

President to Congress. These areas await only legislative action by 

Congress in order to become part of the Wilderness System. Such 

areas are also referred to as “pending in Congress.” 

(Draft Service Manual 610 FW 1.5). 

Record of Decision 

(ROD): 

A concise public record of decision prepared by the federal agency, 

pursuant to NEPA, that contains a statement of the decision, 

identification of all alternatives considered, identification of the 

environmentally preferable alternative, a statement as to whether all 

practical means to avoid or minimize environmental harm from the 

alternative selected have been adopted (and if not, why they were not), 

and a summary of monitoring and enforcement where applicable for any 

mitigation (40 CFR 1505.2). 

Refuge Goal: See Goal. 

Refuge Purposes: See Purposes of the Refuge. 

Songbirds: 

(Also Passerines) 

A category of birds that is medium to small, perching landbirds. Most 

are territorial singers and migratory. 

Splay Splay in biological terms is a vegetated, emergent marsh that develops 

from sediments deposited in open water as a result of overflow of the 

natural banks or levees of a river or channel or as the result of a natural 

or created crevasse or sediment diversion. 

Step-down 

Management Plan: 

A plan that provides specific guidance on management subjects (e.g., 

habitat, public use, fire, safety) or groups of related subjects. It 

describes strategies and implementation schedules for meeting 

CCP goals and objectives (Service Manual 602 FW 1.6 U). 

Strategy: A specific action, tool, technique, or combination of actions, tools, and 

techniques used to meet unit objectives (Service Manual 602 FW 1.6 U). 

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 the state 

within the near future if factors contributing to population decline or 

habitat degradation or loss continue. 
46 Shell Keys National Wildlife Refuge 

Tiering: The coverage of general matters in broader environmental impact 

statements with subsequent narrower statements of environmental 

analysis, incorporating by reference, the general discussions and 

concentrating on specific issues (40 CFR 1508.28). 

U.S. Fish and Wildlife 

Service Mission: 

The mission of the U.S. Fish and Wildlife Service is working with others 

to conserve, protect, and enhance fish and wildlife and their habitats for 

the continuing benefit of the American people. 

Unit Objective: See Objective. 

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 what the planning unit should be, or what we 

hope to do, based primarily upon the Refuge System mission and 

specific refuge purposes, and other mandates. We will tie the vision 

statement for the refuge to the mission of the Refuge System; the 

purpose(s) of the refuge; the maintenance or restoration of the 

ecological integrity of each refuge and the Refuge System; and other 

mandates (Service Manual 602 FW 1.6 Z). 

Wilderness Study 

Areas: 

Lands and waters identified through inventory as meeting the definition 

of wilderness and undergoing evaluation for recommendation for 

inclusion in the Wilderness System. A study area must meet the 

following criteria: 

 Generally appears to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially unnoticeable; 

 Has outstanding opportunities for solitude or a primitive and 

unconfined type of recreation; 

 Has at least 5,000 contiguous roadless acres or is sufficient in size 

as to make practicable its preservation and use in an unimpaired 

condition (Draft Service Manual 610 FW 1.5). 

Wilderness: See Designated Wilderness. 

Wildfire: A free-burning fire requiring a suppression response; all fire other than 

prescribed fire that occurs on wildlands (Service Manual 621 FW 1.7). 

Wildland Fire: Every wildland fire is either a wildfire or a prescribed fire (Service 

Manual 621 FW 1.3). 
Appendices 47

ACRONYMS AND ABBREVIATIONS 

BCC Birds of Conservation Concern 

BRT Biological Review Team 

CBRA Coastal Barrier Resources Act of 1982 

CCP Comprehensive Conservation Plan 

CFR Code of Federal Regulations 

cfs cubic feet per second 

CIAP Coastal Impact Assistance Program 

CWCS Comprehensive Wildlife Conservation Strategy 

CWPPRA Coastal Wetland Planning, Protection, and Restoration Act 

COE US Army Corps of Engineers 

DOI Department of the Interior 

DU Ducks Unlimited 

EA Environmental Assessment 

EE Environmental Education 

EIS Environmental Impact Statement 

EO Executive Order 

EPA U.S. Environmental Protection Agency 

ESA Endangered Species Act 

FONSI Finding of No Significant Impact 

FR Federal Register 

FTE Full-time Equivalent 

FY Fiscal Year 

GIS Global Information System 

GIW Gulf Intracoastal Waterway 

GCJV Gulf Coast Joint Venture 

IPCC Intergovernmental Panel on Climate Change 

LCA Louisiana Coastal Area 

LDWF Louisiana Department of Wildlife and Fisheries 

LMRE Lower Mississippi River Ecosystem 

MMS Mineral Management Service 

MOU Memorandum of Understanding 

NABCI North American Bird Conservation Initiative 

NEPA National Environmental Policy Act 

NMFS National Marine Fisheries Society 

NRHP National Register of Historic Places 

NWR National Wildlife Refuge 

NWRS National Wildlife Refuge System 

PFT Permanent Full Time 

PUNA Public Use Natural Area 

RM Refuge Manual 

RNA Research Natural Area 

ROD Record of Decision 

RONS Refuge Operating Needs System 

RRP Refuge Roads Program 

Service U.S. Fish and Wildlife Service (also, FWS) 

TFT Temporary Full Time 

TGCE Texas Gulf Coast Ecosystem 

USC United States Code 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geologic Survey 
48 Shell Keys National Wildlife Refuge 
Appendices 49

Appendix B. References and Literature 

Citations 

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Bornhauser, M. 1958. Gulf Coast tectonics. Am. Assoc. Petroleum Geologists Bull. 42:339-370. 

Bryant, W.R., Antoine, J.W., Ewing, M. and Jones, B. 1968. Structure of Mexican continental shelf 

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Clough, Jonathon S. 2008. Application of the Sea-Level Affecting Marshes Model (SLAMM 5.0) to 

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Dupree, A. Hunter. 1957. Science in the Federal Government: A History of Policies and Activities 

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Elliott, L., and K. Mc Knight. 2000. U.S. Shorebird Conservation Plan, Lower Mississippi/Western 

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Ewing, J.I., Ewing, M. and Leyden, R. 1966. Seismic profiler survey of Blake Plateau. Am. Assoc. 

Petroleum Geologists Bull. 50:1948-1971. 
50 Shell Keys National Wildlife Refuge 

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Appendices 51

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SENER [Secretaria de Energia]. Sistema de Informacion Energetica: Informacion Estadistica. 

http://sie.energia.gob.mx/, accessed on July 25, 2006. 

Sheridan, R.E., Drake, C.L., Nafe, J.E. and Hennion, J. 1966. Seismic refraction study of continental 

margin east of Florida. Am. Assoc. Petroleum Geologists Bull. 50:1972-1991. 

Turner, R.E. 1999. Inputs and outputs of the Gulf of Mexico. Chapt. 4, In: Kumpf, H., Steidinger, K. 

and Sherman, K. (eds.) The Gulf of Mexico large marine ecosystem; assessment, 

sustainability and management. Blackwell Science, Inc. 704 pp. 

Uchupi, E. 1975. Physiography of the Gulf of Mexico and Caribbean Sea. In: Nairn, A.E.M. and 

Stehli, F.G. (eds.) The ocean basins and margins, vol. 3: The Gulf of Mexico and the 

Caribbean. Plenum Press, NY. 706 p. 

Uchupi, E. and Emery, K.O. 1968. Structure of continental margin off Gulf Coast of United States. 

Am. Assoc. Petroleum Geologists Bull. 52:1162-1193. 

U.S. Fish and Wildlife Service. 2004. A Blueprint for the Future of Migratory Birds. Migratory Bird 

Program Strategic Plan 2004-2014. U.S. Fish and Wildlife Service. 27 pp. 
Appendices 53

U.S. Fish and Wildlife Service (Content source); Cutler J. Cleveland (Topic Editor). 2007. "History of 

the U.S. Fish and Wildlife Service National Wildlife Refuge System." In: Encyclopedia of 

Earth. Eds. Cutler J. Cleveland (Washington, D.C.: Environmental Information Coalition, 

National Council for Science and the Environment). [First published August 30, 2006; Last 

revised January 31, 2007; Retrieved October 31, 2007]. 

<http://www.eoearth.org/article/History_of_the_U.S._Fish_and_Wildlife_Service_National_Wil

dlife_Refuge_System

Williams, S.J., S. Penland, and A.H. Sallenger, Jr., (eds.). 1992. Louisiana barrier island erosion 

study: atlas of shoreline changes in Louisiana from 1853 to 1989. USGS and LGS. 103 pp. 

Wilson, B.C., C.A. Manlove, and C.G. Esslinger. 2002. North American Waterfowl Management 

Plan, Gulf Coast Joint Venture: Mississippi River Coastal Wetlands Initiative. North American 

Waterfowl Management Plan, Albuquerque, NM. 28pp+appendix. 

Worzel, J.L., Leyden, R. and Ewing, M. 1968. Newly discovered diapirs in Gulf of Mexico. Am. Asso. 

Petroleum Geologists Bull. 52:1194-1203. 
54 Shell Keys National Wildlife Refuge 
Appendices 55

Appendix C. Relevant Legal Mandates and 

Executive Orders 

STATUE DESCRIPTION 

Administrative Procedures 

Act (1946) 

Outlines administrative procedures to be followed by federal 

agencies with respect to identification of information to be made 

public; publication of material in the Federal Register; maintenance 

of records; attendance and notification requirements for specific 

meetings and hearings; issuance of licenses; and review of agency 

actions. 

American Antiquities Act of 

1906 

Provides penalties for unauthorized collection, excavation, or 

destruction of historic or prehistoric ruins, monuments or objects of 

antiquity on lands owned or controlled by the United States. 

Authorizes the President to designate as national monuments 

objects or areas of historic or scientific interest on lands owned or 

controlled by the Unites States. 

American Indian Religious 

Freedom Act of 1978 

Protects the inherent right of Native Americans to believe, express, 

and exercise their traditional religions, including access to important 

sites, use and possession of sacred objects, and the freedom to 

worship through ceremonial and traditional rites. 

Americans With Disabilities 

Act of 1990 

Intended to prevent discrimination of and make American Society 

more accessible to people with disabilities. The Act requires 

reasonable accommodations to be made in employment, public 

services, public accommodations, and telecommunications for 

persons with disabilities. 

Anadromous Fish 

Conservation Act of 1965, 

as amended 

Authorizes the Secretaries of Interior and Commerce to enter into 

cooperative agreements with states and other non-federal interest 

for conservation, development, and enhancement of anadromous 

fish; and contribute up to 50 percent as the federal share of the cost 

of carrying out such agreements. Reclamation construction 

programs for water resource projects needed solely for such fish are 

also authorized. 

Archaeological Resources 

Protection Act of 1979, as 

amended. 

Strengthens and expands the protective provisions of the Antiquities 

Act of 1906 regarding archaeological resources. It also revised the 

permitting process for archaeological research. 
56 Shell Keys National Wildlife Refuge 

STATUE DESCRIPTION 

Architectural Barriers Act of 

1968 

Requires that buildings and facilities designed, constructed, or 

altered with federal funds, or leased by a federal agency, comply 

with standards for physical accessibility. 

Bald and Golden Eagle 

Protection Act of 1940, as 

amended 

Prohibits the possession, sale, or transport of any bald or golden 

eagle, alive or dead, or part, nest, or egg except as permitted by the 

Secretary of the Interior for scientific or exhibition purposes, or for 

the religious purposes of Indians. 

Bankhead-Jones Farm 

Tenant Act of 1937 

Directs the Secretary of Agriculture to develop a program of land 

conservation and utilization in order to correct maladjustments in 

land use and thus assist in such things as control of soil erosion, 

reforestation, preservation of natural resources, and protection of 

fish and wildlife. Some early refuges and hatcheries were 

established under authority of this Act. 

Cave Resources Protection 

Act of 1988 

Established requirements for the management and protection of 

caves and their resources on federal lands, including allowing the 

land managing agencies to withhold the location of caves from the 

public, and requiring permits for any removal or collecting activities 

in caves on federal lands. 

Clean Air Act of 1970 Regulates air emissions from area, stationary, and mobile sources. 

This Act and its amendments charge federal land managers with 

direct responsibility to protect the “air quality and related values” of 

land under their control. These values include fish, wildlife, and their 

habitats. 

Clean Water Act of 1974, as 

amended 

This Act and its amendments have as their objectives the restoration 

and maintenance of the chemical, physical, and biological integrity 

of the Nation’s waters. Section 401 of the Act requires that federally 

permitted activities comply with the Clean Water Act standards, 

state water quality laws, and any other appropriate state laws. 

Section 404 charges the COE with regulating discharge of dredge or 

fill materials into waters of the United States, including wetlands. 

Coastal Barrier Resources 

Act of 1982 (CBRA) 

Identifies undeveloped coastal barriers along the Atlantic and Gulf 

coasts and included them in the John H. Chafee Coastal Barrier 

Resources System (CBRS). The objectives of the Act are to 

minimize loss of human life, reduce wasteful federal expenditures, 

and minimize the damage to natural resources by restricting most 

federal expenditures that encourage development within the CBRS. 
Appendices 57

STATUE DESCRIPTION 

Coastal Barrier 

Improvement Act of 1990 

Reauthorized the CBRA, expanded the CBRS to include 

undeveloped coastal barriers along the Great Lakes and in the 

Caribbean, and established “Otherwise Protected Areas (OPAs).” 

The Service is responsible for maintaining official maps, consulting 

with federal agencies that propose spending federal funds within the 

CBRS and OPAs, and making recommendations to Congress about 

proposed boundary revisions. 

Coastal Wetlands Planning, 

Protection, and Restoration 

(1990) 

Authorizes the Director of the Fish and Wildlife Service to participate 

in the development of a Louisiana coastal wetlands restoration 

program, participate in the development and oversight of a coastal 

wetlands conservation program, and lead in the implementation and 

administration of a national coastal wetlands grant program. 

Coastal Zone Management 

Act of 1972, as amended 

Established a voluntary national program within the Department of 

Commerce to encourage coastal states to develop and implement 

coastal zone management plans and requires that “any Federal 

activity within or outside of the coastal zone that affects any land or 

water use or natural resource of the coastal zone” shall be 

“consistent to the maximum extent practicable with the enforceable 

policies” of a State’s coastal zone management plan. The law 

includes an Enhancement Grants Program for protecting, restoring 

or enhancing existing coastal wetlands or creating new coastal 

wetlands. It also established the National Estuarine Reserve 

Research System, guidelines for estuarine research, and financial 

assistance for land acquisition. 

Emergency Wetlands 

Resources Act of 1986 

Authorized the purchase of wetlands from Land and Water 

Conservation Fund moneys, removing a prior prohibition on such 

acquisitions. Requires the Secretary of the Interior to establish a 

National Wetlands Priority Conservation Plan, requires the states to 

include wetlands in their comprehensive outdoor recreation plans, 

and transfers to the Migratory Bird Conservation Fund amounts 

equal to import duties on arms and ammunition. It also established 

entrance fees at national wildlife refuges. 

Endangered Species Act of 

1973, as amended 

Provides for the conservation of threatened and endangered 

species of fish, wildlife, and plants by federal action and by 

encouraging the establishment of state programs. It provides for the 

determination and listing of threatened and endangered species and 

the designation of critical habitats. Section 7 requires refuge 

managers to perform internal consultation before initiating projects 

that affect or may affect endangered species. 
58 Shell Keys National Wildlife Refuge 

STATUE DESCRIPTION 

Energy Policy Act of 2005 Includes a section that establishes the Coastal Impact Assistance 

Program (CIAP), authorizing funds to outer continental shelf oil and 

gas producing states to mitigate the impact of oil and gas activities. 

Environmental Education 

Act of 1990 

Established the Office of Environmental Education within the 

Environmental Protection Agency to develop and administer a 

federal environmental education program in consultation with other 

federal natural resource management agencies, including the Fish 

and Wildlife Service. 

Estuary Protection Act of 

1968 

Authorized the Secretary of the Interior, in cooperation with other 

federal agencies and the states, to study and inventory estuaries of 

the United States, including land and water of the Great Lakes, and 

to determine whether such areas should be acquired for protection. 

The Secretary is also required to encourage state and local 

governments to consider the importance of estuaries in their 

planning activities that relate to federal natural resource grants. In 

approving any state grants for acquisition of estuaries, the Secretary 

is required to establish conditions to ensure their permanent 

protection. 

Estuaries and Clean Waters 

Act of 2000 

Creates a federal interagency council that includes the Director of 

the Fish and Wildlife Service, the Secretary of the Army for Civil 

Works, the Secretary of Agriculture, the Administrator of the 

Environmental Protection Agency, and the Administrator of the 

National Oceanic and Atmospheric Administration. The Council is 

charged with developing a national estuary habitat restoration 

strategy and providing grants to entities to restore and protect 

estuary habitat to promote the strategy. 

Food Security Act of 1985, 

as amended (Farm Bill) 

Contains several provisions that contribute to wetland conservation. 

The Swampbuster provisions state that farmers who convert 

wetlands for the purpose of planting after enactment of the law are 

ineligible for most farm program subsidies. The Act also established 

the Wetlands Reserve Program to restore and protect wetlands 

through easements and restoration of the functions and values of 

wetlands on such easement areas. 

Farmland Protection Policy 

Act of 1981, as amended 

Minimizes the extent to which federal programs contribute to the 

unnecessary conversion of farmland to nonagricultural uses. 

Federal programs include construction projects and the 

management of federal lands. 
Appendices 59

STATUE DESCRIPTION 

Federal Advisory Committee 

Act (1972), as amended 

Governs the establishment of and procedures for committees that 

provide advice to the federal government. Advisory committees 

may be established only if they will serve a necessary, nonduplicative function. Committees must be strictly advisory unless 

otherwise specified and meetings must be open to the public. 

Federal Coal Leasing 

Amendment Act of 1976 

Provided that nothing in the Mining Act, the Mineral Leasing Act, or 

the Mineral Leasing Act for Acquired Lands authorized mining coal 

on refuges. 

Federal-Aid Highways Act of 

1968 

Established requirements for approval of federal highways through 

wildlife refuges and other designated areas to preserve the natural 

beauty of such areas. The Secretary of Transportation is directed to 

consult with the Secretary of the Interior and other federal agencies 

before approving any program or project requiring the use of land 

under their jurisdiction. 

Federal Noxious Weed Act 

of 1990, as amended 

The Secretary of Agriculture was given the authority to designate 

plants as noxious weeds and to cooperate with other federal, state 

and local agencies; farmers associations; and private individuals in 

measures to control, eradicate, prevent, or retard the spread of such 

weeds. The Act requires each federal land-managing agency, 

including the Fish and Wildlife Service, to designate an office or 

person to coordinate a program to control such plants on the 

agency’s land, and implement cooperative agreements with the 

states, including integrated management systems to control 

undesirable plants. 

Fish and Wildlife Act of 1956 Established a comprehensive national fish, shellfish, and wildlife 

resources policy with emphasis on the commercial fishing industry, 

but also includes the inherent right of every citizen and resident to 

fish for pleasure, enjoyment, and betterment, and to maintain and 

increase public opportunities for recreational use of fish and wildlife 

resources. Among other things, it authorizes the Secretary of the 

Interior to take such steps as may be required for the development, 

advancement, management, conservation and protection of fish and 

wildlife resources including, but not limited to, research, 

development of existing facilities, and acquisition by purchase or 

exchange of land and water or interests therein. 

Fish and Wildlife 

Conservation Act of 1980, 

as amended 

Requires the Service to monitor non-gamebird species, identify 

species of management concern, and implement conservation 

measures to preclude the need for listing under the Endangered 

Species Act. 
60 Shell Keys National Wildlife Refuge 

STATUE DESCRIPTION 

Fish and Wildlife 

Coordination Act of 1958 

Promotes equal consideration and coordination of wildlife 

conservation with other water resource development programs by 

requiring consultation with the Fish and Wildlife Service and the 

state fish and wildlife agencies where the “waters of a stream or 

other body of water are proposed or authorized, permitted or 

licensed to be impounded, diverted...or otherwise controlled or 

modified” by any agency under federal permit or license. 

Improvement Act of 1978 Passed to improve the administration of fish and wildlife programs 

and amend several earlier laws, including the Refuge Recreation 

Act, the National Wildlife Refuge Administration Act, and the Fish 

and Wildlife Act of 1956. It authorizes the Secretary to accept gifts 

and bequests of real and personal property on behalf of the United 

States. It also authorizes the use of volunteers on Service projects 

and appropriations to carry out volunteer programs. 

Fish and Wildlife Programs 

Improvement and National 

Wildlife Refuge System 

Centennial Act of 2000 

Recognizes the vital importance of the Refuge System and the fact 

that the Refuge System would celebrate its centennial anniversary 

in the year 2003. Established the National Wildlife Refuge System 

Centennial Commission to prepare a plan to commemorate the 

100th anniversary of the Refuge System, coordinate activities to 

celebrate that event, and host a conference on the Refuge System. 

The commission is also responsible for developing a long-term plan 

to meet the priority operations; maintenance and construction needs 

for the Refuge System, and improve public use programs and 

facilities. 

Fishery (Magnuson) 

Conservation and 

Management Act of 1976 

Established Regional Fishery Management Councils comprised of 

federal and state officials including the Fish and Wildlife Service. It 

provides for regulation of foreign fishing and vessel fishing permits. 

Freedom of Information Act, 

1966 

Requires all federal agencies to make available to the public for 

inspection and copying administrative staff manuals and staff 

instructions; official, published and unpublished policy statements; 

final orders deciding case adjudication; and other documents. 

Special exemptions have been reserved for nine categories of 

privileged material. The Act requires the party seeking the 

information to pay reasonable search and duplication costs. 

Geothermal Steam Act of 

1970, as amended 

Authorizes and governs the lease of geothermal steam and related 

resources on public lands. Section 15c of the Act prohibits issuing 

geothermal leases on virtually all Service-administrative lands. 
Appendices 61

STATUE DESCRIPTION 

Lacey Act of 1900, as 

amended 

Originally designed to help states protect their native game animals 

and to safeguard U.S. crop production from harmful foreign species. 

This Act prohibits interstate and international transport and 

commerce of fish, wildlife, or plants taken in violation of domestic or 

foreign laws. It regulates the introduction to America of foreign 

species into new locations. 

Land and Water 

Conservation Fund Act of 

1948 

Provides funding through receipts from the sale of surplus federal 

land, appropriations from oil and gas receipts from the outer 

continental shelf, and other sources for land acquisition under 

several authorities. Appropriations from the fund may be used for 

matching grants to states for outdoor recreation projects and for 

land acquisition by various federal agencies including the Fish and 

Wildlife Service. 

Marine Mammal Protection 

Act of 1972, as amended 

The 1972 Marine Mammal Protection Act established a federal 

responsibility to conserve marine mammals with management 

vested in the Department of the Interior for sea otter, walrus, polar 

bear, dugong, and manatee. The Department of Commerce is 

responsible for cetaceans and pinnipeds, other than the walrus. 

With certain specified exceptions, the Act establishes a moratorium 

on the taking and importing of marine mammals, as well as products 

taken from them. 

Migratory Bird Conservation 

Act of 1929 

Established a Migratory Bird Conservation Commission to approve 

areas recommended by the Secretary of the Interior for acquisition 

with Migratory Bird Conservation Funds. The role of the 

Commission was expanded by the North American Wetland 

Conservation Act to include approving wetlands acquisition, 

restoration, and enhancement proposals recommended by the North 

American Wetlands Conservation Council. 

Migratory Bird Hunting and 

Conservation Stamp Act of 

1934 

Also commonly referred to as the Duck Stamp Act,” requires 

waterfowl hunters 16 years of age or older to possess a valid federal 

hunting stamp. Receipts from the sale of the stamp are deposited 

into the Migratory Bird Conservation Fund for the acquisition of 

migratory bird refuges. 

Migratory Bird Treaty Act of 

1918, as amended 

Implements various treaties and conventions between the U.S. and 

Canada, Japan, Mexico and the former Soviet Union for the 

protection of migratory birds. Except as allowed by special 

regulations, this Act makes it unlawful to pursue, hunt, kill, capture, 

possess, buy, sell, purchase, barter, export, or import any migratory 

bird, part, nest, egg, or product. 
62 Shell Keys National Wildlife Refuge 

STATUE DESCRIPTION 

Mineral Leasing Act for 

Acquired Lands (1947), as 

amended 

Authorizes and governs mineral leasing on acquired public lands. 

Minerals Leasing Act of 

1920, as amended 

Authorizes and governs leasing of public lands for development of 

deposits of coal, oil, gas and other hydrocarbons, sulphur, 

phosphate, potassium, and sodium. Section 185 of this title 

contains provisions relating to granting rights-of-way over federal 

lands for pipelines. 

Mining Act of 1872, as 

amended 

Authorizes and governs prospecting and mining for the so-called 

“hardrock” minerals (such as gold and silver) on public lands. 

National and Community 

Service Act of 1990 

Authorizes several programs to engage citizens of the U.S. in fulland/or part-time projects designed to combat illiteracy and poverty, 

provide job skills, enhance educational skills, and fulfill 

environmental needs. Among other things, this law established the 

American Conservation and Youth Service Corps to engage young 

adults in approved human and natural resource projects, which will 

benefit the public or are carried out on federal or tribal lands. 

National Environmental 

Policy Act of 1969 

Requires analysis, public comment, and reporting for environmental 

impacts of federal actions. It stipulates the factors to be considered 

in environmental impact statements, and requires that federal 

agencies employ an interdisciplinary approach in related decisionmaking and develop means to ensure that unqualified environmental 

values are given appropriate consideration, along with economic 

and technical considerations. 

National Historic 

Preservation Act of 1966, as 

amended 

Established a National Register of Historic Places and a program of 

matching grants for preservation of significant historical features. 

Federal agencies are directed to take into account the effects of 

their actions on items or sites listed or eligible for listing in the 

National Register. 

National Trails System Act 

(1968), as amended 

Established the National Trails System to protect the recreational, 

scenic, and historic values of some important trails. National 

Recreation Trails may be established by the Secretary of Interior or 

Agriculture on land wholly or partly within their jurisdiction, with the 

consent of the involved State(s), and other land managing agencies, 

if any. National scenic and national historic trails may only be 

designated by an Act of Congress. Several national trails cross 

units of the National Wildlife Refuge System. 
Appendices 63

STATUE DESCRIPTION 

National Wildlife Refuge 

System Administration Act 

of 1966 

Prior to 1966, there was no single federal law that governed the 

administration of the various wildlife refuges that had been 

established. This Act defines the National Wildlife Refuge System 

and authorizes the Secretary of the Interior to permit any use of an 

area provided such use is compatible with the major purposes(s) for 

which the area was established. 

National Wildlife Refuge 

System Improvement Act of 

1997 

This Act amends the National Wildlife Refuge System Administration 

Act of 1966. This Act defines the mission of the National Wildlife 

Refuge System, establishes the legitimacy and appropriateness of 

six priority “wildlife-dependent” public uses, establishes a formal 

process for determining “compatible uses” of Refuge System lands, 

identifies the Secretary of the Interior as responsible for managing 

and protecting the Refuge System, and requires the development of 

a comprehensive conservation plan for all refuges outside of Alaska. 

Native American Graves 

Protection and Repatriation 

Act of 1990 

Requires federal agencies and museums to inventory, determine 

ownership of, and repatriate certain cultural items and human 

remains under their control or possession. The Act also addresses 

the repatriation of cultural items inadvertently discovered by 

construction activities on lands managed by the agency. 

Neotropical Migratory Bird 

Conservation Act of 2000 

Establishes a matching grants program to fund projects that 

promote the conservation of neotropical migratory birds in the united 

States, Latin America, and the Caribbean. 

North American Wetlands 

Conservation Act of 1989 

Provides funding and administrative direction for implementation of 

the North American Waterfowl Management Plan and the Tripartite 

Agreement on wetlands between Canada, U.S., and Mexico. North 

American Wetlands Conservation Council is created to recommend 

projects to be funded under the Act to the Migratory Bird 

Conservation Commission. Available funds may be expended for 

up to 50 percent of the United States share cost of wetlands 

conservation projects in Canada, Mexico, or the United States (or 

100 percent of the cost of projects on federal lands). 

Refuge Recreation Act of 

1962, as amended 

Authorized the Secretary of the Interior to administer refuges, 

hatcheries, and other conservation areas for recreational use, when 

such uses do not interfere with the area’s primary purposes. It 

authorizes construction and maintenance of recreational facilities 

and the acquisition of land for incidental fish and wildlife-dependent 

recreational development or protection of natural resources. It also 

authorizes the charging of fees for public uses. 
64 Shell Keys National Wildlife Refuge 

STATUE DESCRIPTION 

Partnerships for Wildlife Act 

of 1992 

Established a Wildlife Conservation and Appreciation Fund to 

receive appropriated funds and donations from the National Fish 

and Wildlife Foundation and other private sources to assist the state 

fish and game agencies in carrying out their responsibilities for 

conservation of non-game species. The funding formula is no more 

that 1/3 federal funds, at least 1/3 foundation funds, and at least 1/3 

state funds. 

Refuge Revenue Sharing 

Act of 1935, as amended 

Provided for payments to counties in lieu of taxes from areas 

administered by the Fish and Wildlife Service. Counties are 

required to pass payments along to other units of local government 

within the county, which suffer losses in tax revenues due to the 

establishment of Service areas. 

Rehabilitation Act of 1973 Requires nondiscrimination in the employment practices of federal 

agencies of the executive branch and contractors. It also requires 

all federally assisted programs, services, and activities to be 

available to people with disabilities. 

Rivers and Harbors 

Appropriations Act of 1899, 

as amended 

Requires the authorization by the COE prior to any work in, on, over, 

or under navigable waters of the United States. The Fish and 

Wildlife Coordination Act provides authority for the Service to review 

and comment on the effects on fish and wildlife activities proposed 

to be undertaken or permitted by the COE. Service concerns 

include contaminated sediments associated with dredge or fill 

projects in navigable waters. 

Sikes Act (1960), as 

amended 

Provides for the cooperation by the Departments of Interior and 

Defense with state agencies in planning, development, and 

maintenance of fish and wildlife resources and outdoor recreation 

facilities on military reservations throughout the U.S. It requires the 

Secretary of each military department to use trained professionals to 

manage the wildlife and fishery resource under his jurisdiction, and 

requires federal and state fish and wildlife agencies be given priority 

in management of fish and wildlife activities on military reservations. 

Transfer of Certain Real 

Property for Wildlife 

Conservation Purposes Act 

of 1948 

Provides that upon determination by the Administrator of the 

General Services Administration, real property no longer needed by 

a Federal agency can be transferred, without reimbursement, to the 

Secretary of the Interior if the land has particular value for migratory 

birds, or to a state agency for other wildlife conservation purposes. 
Appendices 65

STATUE DESCRIPTION 

Transportation Equity Act for 

the 21st Century (1998) 

Established the Refuge Roads Program, requires transportation 

planning that includes public involvement, and provides funding for 

approved public use roads and trails and associated parking lots, 

comfort stations, and bicycle/pedestrian facilities. 

Uniform Relocation and 

Assistance and Real 

Property Acquisition Policies 

Act (1970), as amended 

Provides for uniform and equitable treatment of persons who sell 

their homes, businesses, or farms to the Service. The Act requires 

that any purchase offer be no less than the fair market value of the 

property. 

Water Resources Planning 

Act of 1965 

Established Water Resources Council to be composed of Cabinet 

representatives, including the Secretary of the Interior. The Council 

reviews river basin plans with respect to agricultural, urban, energy, 

industrial, recreational, and fish and wildlife needs. The Act also 

established a grant program to assist States in participating in the 

development of related comprehensive water and land use plans. 

Wild and Scenic Rivers Act 

of 1968, as amended 

Selects certain rivers of the nation possessing remarkable scenic, 

recreational, geologic, fish and wildlife, historic, cultural, or other 

similar values; preserves them in a free-flowing condition; and 

protects their local environments. 

Wilderness Act of 1964, as 

amended 

Directs the Secretary of the Interior to review every roadless area of 

5,000 acres or more and every roadless island regardless of size 

within the National Wildlife Refuge System and to recommend 

suitability of each such area. The Act permits certain activities 

within designated wilderness areas that do not alter natural 

processes. Wilderness values are preserved through a “minimum 

tool” management approach, which requires refuge managers to 

use the least intrusive methods, equipment and facilities necessary 

for administering the areas. 

Youth Conservation Corps 

Act of 1970 

Established a permanent Youth Conservation Corps (YCC) program 

within the Departments of Interior and Agriculture. Within the 

Service, YCC participants perform many tasks on refuges, fish 

hatcheries, and research stations. 
66 Shell Keys National Wildlife Refuge 

EXECUTIVE ORDERS DESCRIPTIONS 

EO 11593, Protection and Enhancement 

of the Cultural Environment (1971) 

States that if the Service proposes any development 

activities that may affect the archaeological or historic 

sites, the Service will consult with Federal and State 

Historic Preservation Officers to comply with Section 

106 of the National Historic Preservation Act of 1966, 

as amended. 

EO 11644, Use of Off-road Vehicles on 

Public Land (1972) 

Established policies and procedures to ensure that the 

use of off-road vehicles on public lands will be 

controlled and directed so as to protect the resources 

of those lands, to promote the safety of all users of 

those lands, and to minimize conflicts among the 

various uses of those lands. 

EO 11988, Floodplain Management 

(1977) 

Prevent federal agencies from contributing to the 

“adverse impacts associated with occupancy and 

modification of floodplains” and the “direct or indirect 

support of floodplain development.” In the course of 

fulfilling their respective authorities, federal agencies 

“shall take action to reduce the risk of flood loss, to 

minimize the impact of floods on human safety, health, 

and welfare, and to restore and preserve the natural 

and beneficial values served by floodplains. 

EO 11989 (1977), Amends Section 2 of 

EO 11644 

Directs agencies to close areas negatively impacted by 

off-road vehicles. 

EO 11990, Protection of Wetlands (1977) Directs federal agencies to provide leadership and take 

action to minimize the destruction, loss of degradation 

of wetlands, and to preserve and enhance the natural 

and beneficial values of wetlands. 

EO 12372, Intergovernmental Review of 

Federal Programs (1982) 

Seeks to foster intergovernmental partnerships by 

requiring federal agencies to use the state process to 

determine and address concerns of state and local 

elected officials with proposed federal assistance and 

development programs. 

EO 12898, Environmental Justice (1994) Requires federal agencies to identify and address 

disproportionately high and adverse effects of its 

programs, policies, and activities on minority and lowincome populations. 
Appendices 67

EXECUTIVE ORDERS DESCRIPTIONS 

EO 12906, Coordinating Geographical 

Data Acquisition and Access (1994), 

Amended by EO 13286 (2003). 

Amendment of EO’s and other actions in 

connection w/ transfer of certain functions 

to Secretary of DHS. 

Recommended that the executive branch develop, in 

cooperation with state, local, and tribal governments, 

and the private sector, a coordinated National Spatial 

Data Infrastructure to support public and private sector 

applications of geospatial data. Of particular 

importance to CCP planning is the National Vegetation 

Classification System (NVCS), which is the adopted 

standard for vegetation mapping. Using NVCS 

facilitates the compilation of regional and national 

summaries, which, in turn, can provide an ecosystem 

context for individual refuges. 

EO 12962, Recreational Fisheries (1995) Directs federal agencies to improve the quantity, 

function, sustainable productivity, and distribution of 

U.S. aquatic resources for increased recreational 

fishing opportunities in cooperation with states and 

Tribes. 

EO 13007, Native American Religious 

Practices (1996) 

Provides for access to, and ceremonial use of, Indian 

sacred sites on federal lands used by Indian religious 

practitioners and direction to avoid adversely affecting 

the physical integrity of such sites. 

EO 13061, Federal Support of 

Community Efforts Along American 

Heritage Rivers (1997) 

Established the American Heritage Rivers initiative for 

the purpose of natural resource and environmental 

protection, economic revitalization, and historic and 

cultural preservation. The Act directs federal agencies 

to preserve, protect, and restore rivers and their 

associated resources important to our history, culture, 

and natural heritage. 

EO 13084, Consultation and Coordination 

With Indian Tribal Governments (2000) 

Provides a mechanism for establishing regular and 

meaningful consultation and collaboration with tribal 

officials in the development of federal policies that 

have tribal implications. 

EO 13112, Invasive Species (1999) Directs federal agencies to prevent the introduction of 

invasive species, detect and respond rapidly to and 

control populations of such species in a cost effective 

and environmentally sound manner, accurately monitor 

invasive species, provide for restoration of native 

species and habitat conditions, conduct research to 

prevent introductions, to control invasive species, and 

to promote public education on invasive species and 

the means to address them. This EO replaces and 

rescinds EO 11987, Exotic Organisms (1977). 
68 Shell Keys National Wildlife Refuge 

EXECUTIVE ORDERS DESCRIPTIONS 

EO 13186, Responsibilities of Federal 

Agencies to Protect Migratory Birds. 

(2001) 

Instructs federal agencies to conserve migratory birds 

by several means, including the incorporation of 

strategies and recommendations found in Partners in 

Flight Bird Conservation plans, the North American 

Waterfowl Plan, the North American Waterbird 

Conservation Plan, and the United States Shorebird 

Conservation Plan, into agency management plans 

and guidance documents. 
Appendices 69

Appendix D. Public Involvement 

SUMMARY OF PUBLIC SCOPING COMMENTS 

Public involvement process: The notice of intent to prepare the draft comprehensive conservation plan 

was published in the Federal Register on June 27, 2007. The public was notified in the local newspapers 

and media of an open house meeting held on July 11, 2007, at the Central School in Lake Charles, 

Louisiana. Approximately 11 members of the public attended the open house and scoping meeting. In 

addition, information packets, including a letter of notice and invitation to attend, public input 

questionnaire, and mailing list request form were mailed to approximately 90 different federal, state, nongovernmental agencies, state and federal congressional offices, and private individuals. Seven 

individuals provided comments at the scoping meeting; no other comments were received. 

State involvement and date of initial contact: The Louisiana Department of Wildlife and Fisheries 

(LDWF) was contacted in May 2007, with an invite for state involvement in the comprehensive 

conservation planning process. We received word from LDWF of their agreement to participate. 

Major Issues Identified: 

y Internally: Major internal issues surrounding Shell Keys NWR include barrier island protection, 

global warming and sea level rise, adjacent oil well development, access to the refuge, 

management capabilities on the refuge, law enforcement issues regarding commercialized oyster 

shell dredging and regulating fishing or prohibited uses, partnerships with LDWF and Marsh Island 

Wildlife Refuge, and potential or lack of potential for boundary posting.

An important issue identified was increasing the potential for nesting and stop-over habitat for 

concentrations of shorebirds and colonial sea birds.

y State: The LDWF provided comments and a sincere willingness to participate in the Shell 

Keys NWR CCP. Comments included support for restoration by adding sand/shells to 

increase the elevation of Shell Keys NWR, interest in participating in cooperative management 

by staff from Marsh Island Wildlife Refuge, and continuing to restrict public access. LDWF 

believes restoration of Shell Keys NWR could be a great public relations opportunity in habitat 

and coastal restoration and could provide good shorebird/waterbird nesting habitat in 

southwest Louisiana.

y Tribes: Letters were provided to representatives of Tunica-Biloxi Indians of Louisiana, 

Coushatta Tribe of Louisiana, the Jena Band of Choctaw Indians of Louisiana, and the 

Chitimacha Tribe of Louisiana, requesting issues they would like to see addressed in the CCP 

and inviting them to participate in the process. No responses were received. 

y Partners: Included above under Internal and State headings.

y Public: After reviewing all comments received from scoping, the planning team identified 

the following significant issues: (1) hurricane coastal barrier island and shoreline 

protection; (2) fishing opportunities; (3) access to the refuge; (4) global warming and sea 

level rise effects; (5) mineral exploration; (6) oyster shell dredging; and (7) shorebird and 

colonial waterbird nesting habitat and refuge.
70 Shell Keys National Wildlife Refuge 

SUMMARY OF PUBLIC DRAFT CCP COMMENTS 

Public involvement in the development of the comprehensive conservation plan for Shell Keys NWR, 

Iberia Parish, Louisiana, was sought throughout the planning process. The issues and alternatives 

generated from the scoping meeting, coupled with the input of the planning team, are summarized in 

Chapter III of the CCP. 

Approximately 100 copies of the Draft CCP/EA were made available for public review, beginning 

June 13, 2008, and ending July 14, 2008. A news release was sent to 21 local area media outlets. 

Copies of the Draft CCP/EA were posted at refuge headquarters and area locations and over 100 

copies were distributed to local landowners; the public; and local, state, and federal agencies. Seven 

respondents consisting of the Service, the LDWF, and the National Oceanic and Atmospheric 

Administration submitted written comments by mail or email. Draft CCP comments and the Service 

response to those comments are summarized below. 

DRAFT CCP/EA COMMENTS AND SERVICE RESPONSE 

General 

Four respondents provided general editorial comments. 

Service Response: The Service will incorporate these changes where appropriate. 

One respondent believes specific projects need to be developed for implementing Objectives A-2, C2, D-2, E-1, and E-2. 

Service Response: The Service will ensure the addition of these objectives with associated funding 

are incorporated or added to Chapter V, Plan Implementation, of the CCP when appropriate. 

Fish and Wildlife Population Management 

One respondent states oyster reefs and shell water bottoms in the vicinity of Shell Keys NWR have 

been designated as essential fish habitat (EFH) under provisions of the Magnuson-Stevens Fishery 

Conservation and Management Act (Magnuson-Stevens Act) for various life stages of red drum, 

brown shrimp, white shrimp, and Gulf stone crab. The respondent further states that any actions 

proposed that could adversely impact such habitats must be coordinated with National Marine 

Fisheries Service (NMFS) under provisions of the Magnuson-Stevens Act. 

Service Response: The Service will ensure the inclusion of the EFH designation under the 

Magnuson-Stevens Act is cited throughout the CCP. The CCP only proposes to look into the 

feasibility of the large-scale habitat restoration and does not propose to implement this action 

until all biological, ecological, socio-economical, and economical impacts are thoroughly 

evaluated and determined to provide beneficial affects. Once an evaluation of how habitat 

restoration would occur, a simultaneous evaluation of impacts to EFH will be initiated in 

consultation with all appropriate partners and entities. 

One respondent recommends the Intra-Service Section 7 Endangered Species Consultation Form 

should more explicitly identify the management action, potential impacts, and mitigation 

measures from the CCP. 
Appendices 71

Service Response: The Service will ensure the impacts and mitigation measures from the CCP are 

included where appropriate; however, given the Section 7 Form is part and parcel of the CCP, only 

references to the action identified are needed. 

Habitat Management 

One respondent believes the Service should design restoration features that minimize impacts to the 

large oyster reef complex located at the refuge (e.g., access route and containment dikes) into the 

habitat feasibility study. 

Service Response: The Service agrees and references these specific design features in Goal B, 

Objective B-1. 

One respondent believes increasing the size of the island will provide benefits to waterbirds and 

possibly reduce erosion along the Marsh Island Wildlife Refuge Gulf of Mexico Shoreline. 

Service Response: The Service concurs and notes that the feasibility study will assess the 

impacts of increasing the size of the island in regards to benefits to fish and wildlife and 

erosion, among other impacts. 

Resource Protection 

One respondent believes the Service in direct coordination with LDWF should ensure that any oyster 

seed ground areas within the boundary of Shell Keys NWR be dissolved and that oyster leases (if 

any) not be renewed to decrease oyster dredging and spreading in the area. 

Service Response: The Services concurs and will work with LDWF to implement these changes. 

This information is added to the Resource Protection section of Chapter IV. 

Two respondents believe the Service needs to clarify information related to oil and gas activities in 

the area of Shell Keys NWR to respond to any potential oil and gas spills and placement and future 

management of transmission pipeline rights-of-way. One respondent further states that if oil and gas 

activities are to occur on the refuge, the Service should analyze potential impacts in the 

Environmental Assessment. 

Service Response: Currently, there is no oil and gas activity on the refuge. The Service has 

added clarifying language on how we would handle future requests, activities, and impacts to 

Chapters II and IV. 

One respondent requests the Service clarify how Objective C-2 will address and meet Goal C. 

Service Response: The Resource Protection goal was clarified to include language regarding cultural 

and historic resources as well as natural and petroleum resources. 
72 Shell Keys National Wildlife Refuge 
Appendices 73

Appendix E. Compatibility Determinations 

Shell Keys National Wildlife Refuge Compatibility Determination 

Uses: The following uses were considered for compatibility determination: 

(1) Recreational fishing of saltwater fish in accordance with the State of Louisiana regulations; and 

(2) Wildlife observation/photography. 

A description and the anticipated biological impacts for each use are addressed separately in this 

Compatibility Determination. 

Refuge Name: Shell Keys National Wildlife Refuge 

Date Established: August 17, 1907 

Establishing and Acquisition Authorities: Shell Keys National Wildlife Refuge was established by 

Executive Oder 682 for the purpose “....as a reserve and breeding ground for native birds.” 

Refuge Purpose: The refuge was established to provide sanctuary for nesting wading birds. 

National Wildlife Refuge System Mission: 

The mission of the Refuge System, as defined by the National Wildlife Refuge System Improvement 

Act of 1997, 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.

Other Applicable Laws, Regulations, and Policies: 

Antiquities Act of 1906 (34 Stat. 225) 

Migratory Bird Treaty Act of 1918 (15 U.S.C. 703-711; 40 Stat. 755) 

Migratory Bird Conservation Act of 1929 (16 U.S.C. 715r; 45 Stat. 1222) 

Migratory Bird Hunting Stamp Act of 1934 (16 U.S.C. 718-178h; 48 Stat. 451) 

Criminal Code Provisions of 1940 (18 U.S.C. 41) 

Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d; 54 Stat. 250) 

Refuge Trespass Act of June 25, 1948 (18 U.S.C. 41; 62 Stat. 686) 

Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j; 70 Stat.1119) 

Refuge Recreation Act of 1962 (16 U.S.C. 460k-460k-4; 76 Stat. 653) 

Wilderness Act (16 U.S.C. 1131; 78 Stat. 890) 

Land and Water Conservation Fund Act of 1965 

National Historic Preservation Act of 1966, as amended (16 U.S.C. 470, et seq.; 80 Stat. 915) 

National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd, 668ee; 80 Stat. 927) 

National Environmental Policy Act of 1969, NEPA (42 U.S.C. 4321, et seq; 83 Stat. 852) 

Use of Off-Road Vehicles on Public Lands (Executive Order 11644, as amended by 

Executive Order 10989) 
74 Shell Keys National Wildlife Refuge 

Endangered Species Act of 1973 (16 U.S.C. 1531 et seq; 87 Stat. 884) 

Refuge Revenue Sharing Act of 1935, as amended in 1978 (16 U.S.C. 715s; 92 Stat. 1319) 

National Wildlife Refuge Regulations for the Most Recent Fiscal Year 

(50 CFR Subchapter C; 43 CFR 3101.3-3) 

Emergency Wetlands Resources Act of 1986 (S.B. 740) 

North American Wetlands Conservation Act of 1990 

Food Security Act (Farm Bill) of 1990 as amended (HR 2100) 

The Property Clause of the U.S. Constitution Article IV 3, Clause 2 

The Commerce Clause of the U.S. Constitution Article 1, Section 8 

The National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57, USC668dd) 

Executive Order 12996, Management and General public Use of the National Wildlife Refuge 

System, March 25, 1996 

Title 50, Code of Federal Regulations, Parts 25-33 

Archaeological Resources Protection Act of 1979 

Native American Graves Protection and Repatriation Act of 1990 

Compatibility determinations for each description listed are considered separately. Although, for 

brevity, the preceding sections from “Uses” through “Other Applicable Laws, Regulations and 

Policies” are only written once within the CCP, they are part of each descriptive use and become part 

of that compatibility determination if considered outside of the CCP. 

(1) Description of Use: Recreational Fishing 

Recreational fishing, a wildlife-dependent activity, has been identified in the National Wildlife Refuge 

System Improvement Act of 1997 as a priority public use, provided it is compatible with the purpose 

for which the refuge was established. 

Recreational fishing of saltwater species will be open year-round on the refuge. Fishermen usually 

wade into the adjacent shallow areas. While fishing is a popular public use, fishing pressure should 

not be heavy due to access issues. 

All fishing will fall within the framework of the State of Louisiana open seasons and follow state 

regulations. Refuge-specific regulations will be reviewed annually and incorporated into the refuge 

brochure. Fishermen are not required to possess refuge permits while fishing on the refuge. The 

entire refuge is open to fishing during hours of daylight, with the exception of areas posted with “Area 

Closed” signs as designated in the refuge brochure. 

Recreational fishing is permitted with rod and reel or pole and line only. The use or possession of 

any other type of fishing gear is prohibited. No commercial fishing activities, including guiding or 

participating in a charter fishing trip, are permitted. 

Availability of Resources: Funding for recreational fishing is supported by annual operation and 

maintenance funds. Costs include permit printing, administration, and monitoring of the activity. 

Anticipated Impacts of the Use: While managed fishing opportunities result in impacts to individual 

fish, effects at the population level are usually negligible. The fish populations are capable of 

sustaining harvest because of the availability of abundant habitat in coastal Louisiana. Regulations 

for saltwater fishing are based on specific state-wide harvest objectives. State biologists set limits 

and harvest guidelines based on population survey and habitat condition data. Refuge fishing 

programs are always within these regulations. As currently proposed, the known and anticipated 

levels of disturbance of allowing fishing is considered minimal and well within the tolerance level of 
Appendices 75

known fish species and populations present on the refuge. All fishing activities will be conducted with 

the constraints of sound biological principles and refuge-specific regulations established to restrict 

illegal or questionable activities. Monitoring activities through fish wildlife inventories in partnerships 

with the state and assessments of public use levels and activities will be utilized, and public use 

programs will be adjusted as needed to limit disturbance. Implementation of an effective law 

enforcement program and development of site-specific refuge regulations that are reviewed annually 

should minimize most problems. 

Public Review and Comment: This compatibility determination was part of the Draft CCP/EA for Shell 

Keys NWR, which was announced in the Federal Register (73 FR 33848) on June 13, 2008, and made 

available for public comment until July 14, 2008. A news release was sent to 21 local area media outlets. 

Copies of the Draft CCP/EA were posted at refuge headquarters and area locations and over 100 copies 

were distributed to local landowners; the public; and local, state, and federal agencies. 

Determination (check one below):

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

y Access to areas of the refuge identified as “Area Closed” during nesting season for sea and 

shore birds will be instituted if nesting occurred. 

y Refuge fishing hours open 30 minutes before legal sunrise to 30 minutes after sunset for 

all public use on the refuge. 

y Trotlines, slat traps, nets, and jug fishing are prohibited. 

Justification: The National Wildlife Refuge System Improvement Act of 1997 identified 

recreational fishing as one of the priority public uses on national wildlife refuges, where 

compatible with refuge purposes. This use is legitimate and appropriate and is dependent upon 

healthy wildlife populations. Offering recreational fishing is in compliance with refuge goals, is a 

management objective for Shell Keys NWR, and furthers the goals and missions of the National 

Wildlife Refuge System. 

Mandatory 15-year Re-evaluation Date: 9/12/2023 

(2) Description of Use: Wildlife Observation and Photography 

Wildlife observation and photography have been identified in the National Wildlife Refuge System 

Improvement Act of 1997 as priority wildlife-dependent recreational uses provided they are 

compatible with the purpose for which the refuge was established. 

Though photography and observation have occurred on the refuge, these activities are not currently 

open. However, opportunities exist for visitors traveling to the refuge to participate in these activities. 
76 Shell Keys National Wildlife Refuge 

The general public may participate in wildlife observation and photography year-round from one-half 

hour before sunrise to one-half hour after sunset in the open areas of the refuge. Boating is the only 

available access for these activities due to location and area. 

Availability of Resources: Funding for wildlife observation and photography is supported by 

annual operation and maintenance funds. Costs include permit printing, administration, and 

monitoring of the activities. 

Anticipated Impacts of the Use: Wildlife observation and photography should not have any 

significant adverse biological impacts. As currently proposed, the known and anticipated levels of 

disturbance of allowing these activities are considered minimal and well within the tolerance level of 

known fish and wildlife species and populations present on the refuge. Implementation of an effective 

law enforcement program and development of site-specific refuge regulations that are reviewed 

annually should minimize most problems. 

Public Review and Comment: This compatibility determination was part of the Draft CCP/EA for Shell 

Keys NWR, which was announced in the Federal Register (73 FR 33848) on June 13, 2008, and made 

available for public comment until July 14, 2008. A news release was sent to 21 local area media outlets. 

Copies of the Draft CCP/EA were posted at refuge headquarters and area locations and over 100 copies 

were distributed to local landowners; the public; and local, state, and federal agencies. 

Determination (check one below):

 Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

y Access to areas of the refuge identified as “Area Closed” during nesting season for sea and 

 shore birds will be implemented if nesting occurs. 

y Refuge hours will open 30 minutes before legal sunrise to 30 minutes after sunset for all 

public use on the refuge. 

Justification: The National Wildlife Refuge System Improvement Act of 1997 identified wildlife 

observation and photography as two of the priority public uses on national wildlife refuges, where 

compatible with refuge purposes. This use is legitimate and appropriate and is dependent upon 

healthy wildlife populations. Offering wildlife observation and photography is in compliance with 

refuge goals, is a management objective for Shell Keys NWR, and furthers the goals and missions of 

the National Wildlife Refuge System. 

Mandatory 15-year Re-evaluation Date: 9/12/2023
Appendices 77

Approval of Compatibility Determinations 

The signature of approval is for all compatibility determinations considered within the Comprehensive 

Conservation Plan for Shell Keys National Wildlife Refuge. If one of the descriptive uses is 

considered for compatibility outside of the Comprehensive Conservation Plan, the approval signature 

becomes part of that determination. 

 
78 Shell Keys National Wildlife Refuge 
Appendices 79

Appendix F. Intra-Service Section 7 Biological 

Evaluations

Originating Person: Roy Walter 

Telephone Number: (337) 598.2216 

E-Mail: roy_walter@fws.gov 

Date: January 2, 2008 

PROJECT NAME: Shell Keys National Wildlife Refuge Comprehensive Conservation Plan 

I. Service Program: 

___ Ecological Services 

___ Federal Aid 

 ___ Clean Vessel Act 

___ Coastal Wetlands 

___ Endangered Species Section 6 

___ Partners for Fish and Wildlife 

___ Sport Fish Restoration 

___ Wildlife Restoration 

___ Fisheries 

 X Refuges/Wildlife

II. State/Agency: Louisiana, U.S. Fish and Wildlife Service

III. Station Name: Shell Keys National Wildlife Refuge 

IV. Description of Proposed Action 

The proposed action would result in the implementation of the preferred alternative developed 

during the preparation of the Comprehensive Conservation Plan (CCP) for Shell Keys 

National Wildlife Refuge, Iberia Parish, Louisiana. Upon approval of the CCP, the following 

uses on the refuge will be implemented for a period of fifteen years; recreational fishing, 

wildlife observation, and wildlife photography. 

The preferred alternative identified in the CCP is to continue providing sanctuary for sea birds, 

as well as wintering shore birds and waterfowl. This alternative supports the purpose for 

which the refuge was established. 

V. Pertinent Species and Habitat: 

Shell Keys National Wildlife Refuge is located within the Lower Mississippi River Ecosystem in the 

Gulf of Mexico, Louisiana. The eight-acre refuge is located in the offshore waters to the west of the 

Atchafalaya River Delta, and south of Marsh Island Wildlife Refuge, Iberia Parish, Louisiana. 
80 Shell Keys National Wildlife Refuge 

It is noted that Shell Keys National Wildlife Refuge is a small group of islands that are subject to shell 

deposits and erosion so the actual acreage above mean high water may, of course, be different at this 

time. How these islands change and move may affect ownership of that area lying above mean high 

water. Under certain circumstances, accreted areas above mean high water may belong to the State of 

Louisiana. 

For a number of years, there has been only one islet at this location. This islet is composed almost 

entirely of shell fragments. It is extremely dynamic and builds or recedes with passing storms. 

Vegetation is almost entirely lacking. 

Species known to nest here include royal terns, sandwich terns, black skimmers, and laughing gulls. 

In addition, the islet is used at various times as a loafing area by white pelicans, brown pelicans, and 

various other species of terns and gulls. Recent hurricanes and storms have eroded the island to 

such an extent that no nesting has occurred since 1992. 

Public access to the refuge is restricted due to its remoteness and only accessible by boat. 

The islands have been reshaped and continually decreasing in size due to impacts from tidal action, 

winds, and tropical storms. An endangered species occurring on the refuge is the brown pelican 

(Pelecanus occidentalis). A threatened species possibly occurring on the refuge is the piping plover 

(Chararadius melodus). 

 A. Include species/habitat occurrence map: See Figure 1 in CCP. 

B. Complete the following table: 

SPECIES/CRITICAL HABITAT STATUS1

Brown Pelican (Pelecanus occidentalis) Endangered

Piping Plover (Charadrius melodus) Threatened 

1

STATUS: E=endangered, T=threatened, PE=proposed endangered, PT=proposed threatened, CH=critical habitat, 

PCH=proposed critical habitat, C=candidate species, S/A=Similar Appearance 

VI. Location (attach map): 

A. Ecoregion Number and Name: 27, Lower Mississippi River 

B. County and State: Iberia Parish, Louisiana

C. Section, township, and range (or latitude and longitude: N 29 degrees 26 minutes 

W 91 degrees 51 minutes from Greenwich

D. Distance (miles) and direction to nearest town: Cypremort, LA, twenty miles north 

of the refuge 

E. Species/habitat occurrence: 
Appendices 81

Brown pelicans use the refuge for loafing, resting, and feeding around the islands throughout 

the year. 

Piping plovers have been observed occasionally during the winter. 

VII. Determination of Effects:

A. Explanation of effects of the action on species and critical habitats in item V. B: 

SPECIES/ 

CRITICAL HABITAT IMPACTS TO SPECIES/CRITICAL HABITAT

Brown Pelican If restoration of island habitat is feasible, positive population benefits will 

occur. Actions identified in CCP will further protect species.

Piping Plover If restoration of island habitat is feasible, positive stop-over habitat may 

increase. Actions identified in CCP will further protect species.

B. Explanation of actions to be implemented to reduce adverse effects:

SPECIES/ 

CRITICAL HABITAT ACTIONS TO MITIGATE/MINIMIZE IMPACTS

Brown Pelican Public access would be restricted during nesting season, increased law

enforcement and staff presence from cooperative agreement, oil and 

gas activity surrounding refuge would be closely monitored, and if 

habitat restoration is feasible, increased nesting and loafing habitat 

developed. 

Piping Plover Public access would be restricted during nesting season, increased law 

enforcement and staff presence from cooperative agreement, oil and 

gas activity surrounding refuge would be closely monitored, and if 

habitat restoration is feasible, increased nesting and loafing habitat 

developed. 

VIII. Effect Determination and Response Requested: 

SPECIES/CRITICAL HABITAT

DETERMINATION1

REQUESTED NE NA AA

Brown Pelican X Concurrence 

Piping Plover X Concurrence 

1

DETERMINATION/ RESPONSE REQUESTED: 

NE = no effect. This determination is appropriate when the proposed action will not directly, indirectly, or 

cumulatively impact, either positively or negatively, any listed, proposed, candidate species or 

designated/proposed critical habitat. Response Requested is optional but a “Concurrence” is recommended for a 

complete Administrative Record. 
82 Shell Keys National Wildlife Refuge 

NA = not likely to adversely affect. This determination is appropriate when the proposed action is not likely to 

adversely impact any listed, proposed, candidate species or designated/proposed critical habitat or there may be 

beneficial effects to these resources. Response Requested is a” Concurrence”. 

AA = likely to adversely affect. This determination is appropriate when the proposed action is likely to adversely 

impact any listed, proposed, candidate species or designated/proposed critical habitat. Response Requested for 

listed species is “Formal Consultation”. Response requested for proposed and candidate species is “Conference”. 
Appendices 83

Appendix G. Wilderness Review

The Wilderness Act of 1964 defines a wilderness area as an area of federal land that retains its 

primeval character and influence, without permanent improvements or human inhabitation, and is 

managed so as to preserve its natural conditions and which: 

1. generally appears to have been influenced primarily by the forces of nature, with the imprint of 

man’s work substantially unnoticeable; 

2. has outstanding opportunities for solitude or primitive and unconfined types of recreation; 

3. has at least 5,000 contiguous roadless acres or is of sufficient size to make practicable its 

preservation and use in an unimpeded condition; or is a roadless island, regardless of size; 

4. does not substantially exhibit the effects of logging, farming, grazing, or other extensive 

development or alteration of the landscape, or its wilderness character could be restored 

through appropriate management at the time of review; and 

5. may contain ecological, geological, or other features of scientific, educational, scenic, or 

historic value. 

The lands within Shell Keys National Wildlife Refuge were reviewed for their suitability in meeting the 

criteria for wilderness, as defined by the Wilderness Act of 1964. No lands in the refuge were found 

to meet these criteria primarily because of the size and often submerged nature of the island. 

Therefore, the suitability of Shell Keys National Wildlife Refuge lands for wilderness designation is not 

further analyzed in this CCP. 
84 Shell Keys National Wildlife Refuge 
Appendices 85

Appendix H. Refuge Biota 

Species of concern and/or significance for management purposes occurring on Shell Keys National 

Wildlife Refuge are listed below. 

Common Name Scientific Name

BIRDS 

Piping Plover Charadrius melodus

Eastern Brown Pelican Pelecanus occidentalis carolinensis

Laughing Gull Larus atricilla 

Royal Tern Sterna maxima 

Caspian Tern Sterna caspia 

Sandwich Tern Sterna sandvicensis 

Black Skimmer Rynchops niger

Sooty Tern Onychoprion fuscata 

Common Tern Sterna hirundo 

Least Tern Sternula antillarum 

Forster’s Tern Sterna forsteri

Gullbilled Tern Gelochelidon nilotica

Magnificent Frigate Bird Fregata magnificens 

Common Egret Casmerodius albus 

Reddish Egret Egretta rufescens 

Snowy Egret Egretta thula 

Clapper Rail Rallus longirostris 

White Ibis Eudocimus albus 

Louisiana or Tricolored Heron Egretta tricolor

Black-Crowned Night Heron Nycticorax nycticorax 

Little Blue Heron Egretta caerulea 

Herring Gull Larus argentatus 

Kelp Gull Larus dominicanus 

HABITAT COMMUNITIES 

Oyster shell 
86 Shell Keys National Wildlife Refuge 
Appendices 87

Appendix I. List of Preparers 

CORE PLANNING TEAM 

Don Voros, Refuge Project Leader, Fish and Wildlife Service, Southwest Louisiana National Wildlife 

Refuge Complex - Editor, provided overall guidance and oversight 

Terry Delaine, Refuge Manager, Fish and Wildlife Service, Southwest Louisiana National Wildlife 

Refuge Complex - Writer and Editor 

Tina Chouinard, Natural Resource Planner, Fish and Wildlife Service, North Louisiana National 

Wildlife Refuge Complex - Planning Team Leader, Writer and Editor 

Roy Walter, Supervisory Wildlife Biologist (former), Fish and Wildlife Service, Southwest Louisiana 

National Wildlife Refuge Complex - Writer and Editor 

Diane Borden-Billiot, Park Ranger, Southwest Louisiana National Wildlife Refuge Complex - 

Writer and Editor 

Billy Leonard, Oil and Gas Specialist/Wildlife Biologist, Southwest Louisiana National Wildlife 

Refuge Complex 

Cassidy Lejeune, Biologist, Louisiana Department of Wildlife and Fisheries, Fur and 

Refuge Division - Editor 

Michael Carloss, Supervisory Biologist, Louisiana Department of Wildlife and Fisheries, Fur and 

Refuge Division - Editor 

 
88 Shell Keys National Wildlife Refuge 

Appendix J. Finding of No Significant Impact 

Shell Keys National Wildlife Refuge Comprehensive Conservation Plan Iberia Parish, 

Louisiana 

Introduction 

The U.S. Fish and Wildlife Service (Service) proposes to protect and manage certain fish and wildlife 

resources in Iberia Parish, Louisiana, on the Shell Keys National Wildlife Refuge. An Environmental 

Assessment was prepared to inform the public of the possible environmental consequences of 

implementing the Comprehensive Conservation Plan for Shell Keys National Wildlife Refuge. A 

description of the alternatives, the rationale for selecting the proposed alternative, the environmental 

effects of the preferred alternative, the potential adverse effects of the action, and a declaration 

concerning the factors determining the significance of effects, in compliance with the National 

Environmental Policy Act of 1969, are outlined below. The supporting information can be found in the 

Environmental Assessment, which was Section B in the Draft Comprehensive Conservation Plan. 

Alternatives 

In developing the Comprehensive Conservation Plan for Shell Keys National Wildlife Refuge, the Fish 

and Wildlife Service evaluated three alternatives: 

Alternative A – No Action 

Alternative B – Custodial Cooperative Management 

Alternative C – Large-Scale Habitat Restoration and Cooperative Management Approach (Preferred 

Alternative) 

Alternative A: No Action (Current Management) 

This is the “status quo” alternative in which current habitat, wildlife, and public use management 

would continue with no changes. On an annual basis, monitoring and trip report status is conducted. 

Periodically during winter migratory bird surveys, fly-over surveys are conducted to determine if the 

island is emergent. A cooperative law enforcement agreement would remain in effect with the LDWF. 

Alternative B: Custodial Cooperative Management 

Under Alternative B, nature would be allowed to take its course regarding the future of the islands, 

with no restoration activities accomplished. If the islands fail to rebuild and continue to erode, areas 

available to birds may diminish. With the land area diminishing, the island would continue to not 

support colonial nesting birds. Working with LDWF, provide routine and additional patrols in 

coordination with refuge law enforcement officers. Interpretation will concentrate on the history of the 

formation and subsequent changes and erosion of the shell key shoal/island and reef complex habitat 

through the Southwest Louisiana National Wildlife Refuge Complex. Alternative B would open the 

refuge for public use by offering limited fishing and wildlife observation and photography. 

Alternative C: Large-Scale Habitat Restoration and Cooperative Management Approach 

(Preferred Alternative) 
Appendices 89

Alternative C, the Service’s preferred alternative for Shell Keys NWR, will explore the feasibility of 

implementing large-scale restoration efforts in cooperation with partners. The Service will enter into a 

new cooperative agreement with LDWF Fur and Refuge Division, focusing on natural resource 

monitoring and restoration as appropriate. Partners are necessary to supply expertise and funding for 

the daunting task of restoration. Feasibility studies will be performed to determine the costs associated 

with rebuilding and re-establishing the Shell Islands, or portions of the Islands. If the Service and 

Partners deem the feasibility study economically, ecologically, and biologically beneficial, further 

analysis of the environmental effects with appropriate state and federal agencies will occur. Restoration 

efforts will adapt to changing conditions as practices and techniques are assessed. The refuge will be 

open to recreational fishing and wildlife observation and photography. Because the refuge is remote 

and few guests actually visit the islands, outreach would center around providing information in 

combination with the Complex and on web pages. 

The Service adopted Alternative C, the “Preferred Action,” as the comprehensive conservation plan 

for guiding the direction of the refuge for the next 15 years. The overriding concern reflected in this 

CCP is that wildlife conservation assumes first priority in refuge management; wildlife-dependent 

recreational uses are allowed if they are appropriate and compatible with wildlife conservation. 

Wildlife-dependent recreational uses (fishing and wildlife observation and photography) will be 

emphasized and encouraged. 

Comparison of Alternatives 

Each of the three alternatives outlined above would pursue the refuge’s purpose, mission, vision, and 

management goals. However, each represents a different approach to doing so; while there are 

certainly overlaps between the three, each alternative has its own emphases and priorities, as well as 

tradeoffs toward land management, conservation, and public use. 

Each of the three would be consistent with the following: Partners-in-Flight Plan; North American 

Waterfowl Management Plan; Lower Mississippi Valley Joint Venture; Chenier Plain Initiative of the 

Gulf Coast Joint Venture; Endangered Species Act; National Wildlife Refuge System Improvement 

Act of 1997; Migratory Bird Conservation Act; and mission and goals of the National Wildlife Refuge 

System. Alternative C will achieve more in approaching the intent of these plans and statutes, but it 

will also cost more to implement than Alternatives A or B. Alternative B would be considered 

consistent with the intent of the above plans and statutes, but no active habitat restoration would be 

applied. Instead, the refuge and Complex staff in cooperation with the LDWF would serve as 

custodians of the refuge, observing and monitoring the natural forces and ecological succession that 

would shape its habitats and effectively determine their suitability for wildlife. 

Selection Rationale 

Alternative C is selected for implementation because it directs the development of programs to 

best achieve the refuge’s purposes, vision, and goals; fulfills the mission of the National Wildlife 

Refuge System; determines the feasibility to restore the refuge’s ecological integrity; addresses 

significant refuge issues and mandates; and is consistent with the principles of sound fish and 

wildlife management. 

Coastal Louisiana has lost more than 1.2 million acres of land along its coast in the last 100 

years and 15,300 acres between 1990 and 2000, mostly due to the conversion of coastal 

wetlands to open water. These habitat losses have led to commensurate impacts on wildlife 

populations, especially those species dependent on island habitat for nesting and loafing. 

Implementing the long-term management goals identified in this Comprehensive Conservation 

Plan will assess the feasibility of restoring shell island habitat to the refuge and improving areas 

available to avian wildlife. 
90 Shell Keys National Wildlife Refuge 

Environmental Effects 

Implementation of the Service’s management action is expected to result in environmental, social, 

and economic effects as outlined in the Comprehensive Conservation Plan. Potential habitat 

restoration, fish and wildlife management, resource protection, and visitor service activities on Shell 

Keys National Wildlife Refuge would result in increased protection for threatened and endangered 

species, enhanced wildlife populations, habitat restoration, and appropriate, compatible public use. 

This alternative will improve management of the refuge in all program areas. 

This alternative will not directly impact water quality, air quality, noise levels, or surrounding land 

uses. Any adjacent oil and gas exploration will be monitored and protective measures will be 

implemented to reduce these activities and any associated effects. 

Habitat and Wildlife 

This alternative (Alternative C) will strive to protect habitat for wildlife, including colonial and nesting 

migratory and resident birds and fish. The refuge hosts few threatened, endangered, or sensitive 

species and this alternative will not have adverse effects on these species. 

Alternative C will partner with other conservation agencies to assess the feasibility of and funding for 

restoring specific emergent shell habitat of the refuge. If large-scale habitat restoration is feasible, 

restoration would provide positive environmental effects, such as an increase in nesting habitat and 

buffering from storms. If colonies of terns, gulls, pelicans, and other seabirds return and successfully 

produce young, research can resume and increase in scope; predator control can be initiated to support 

nesting success. 

Cultural Resources 

The selected alternative will protect the refuge’s cultural resources in accordance with federal and 

state historic preservation legislation and regulations. No known cultural and historic resources exist 

on Shell Keys NWR. In most cases, new management actions will require review by the Service’s 

Regional Archaeologist in consultation with the State of Louisiana Historic Preservation Office, as 

mandated by Section 106 of the National Historic Preservation Act. Therefore, the determination of 

whether a particular action within the selected alternative has the potential to affect cultural resources is 

an on-going process that would occur during the planning stages of every project. 

Service ownership of land with known or potential archaeological or historical sites provides two 

major types of protection for these resources: protection from damage by federal activity and 

protection from vandalism or theft. The National Historic Preservation Act requires that any actions 

by a federal agency which may affect archaeological or historical resources be reviewed by the State 

Historic Preservation Office, and that the identified effects must be avoided or mitigated. The 

Service’s policy is to preserve these cultural, historic, and archaeological resources in the public trust, 

and avoid any adverse effects wherever possible. Development of off-refuge lands has the potential 

to destroy archaeological artifacts and other historical resources, thereby decreasing opportunities for 

cultural resource interpretation and research. 

Oil and Gas Activity 

The selected alternative offers protection for future oil and gas activities on the refuge. Currently, 

there are no oil and gas activities on the refuge. The refuge will be protected from any harmful 

effects caused by existing oil and gas activity in accordance with Fish and Wildlife Service Policy 603 

FW 2 in general, and explicitly under section 2.11D and state and federal laws. This alternative will 

treat requests for new oil and gas activity as an inappropriate use considering the current status of 

Louisiana’s coastal wetlands and the Fish and Wildlife Service’s role in managing and protecting this 

state’s coastal resources. 
Appendices 91

Public Use 

The selected alternative will open public use opportunities on the refuge. Fishing and wildlife 

observation and photography will all be accommodated and encouraged under Alternative C. 

Environmental education and interpretation would occur off refuge and in coordination with the 

Southwest Louisiana National Wildlife Refuge Complex. The alternative will involve preparation of a 

visitor services’ plan, which will include recommendations for environmental education, interpretation, 

and outreach, and should include recommendations for a safe, quality experience for all visitors. 

Limited fishing will be opened and accessible only by boat. Opportunities for wildlife observation and 

wildlife photography will be initiated. Similarly, environmental education and interpretation will be 

maintained at the refuge complex headquarters. 

Disturbance to wildlife is an unavoidable consequence of any public use program, regardless of the 

activity involved. While some activities, such as wildlife observation, may be less disturbing than 

others, all of the public use activities under the selected alternative will be planned to avoid 

unacceptable levels of impact. 

The known and anticipated levels of disturbance from the selected alternative are not considered to be 

significant. Nevertheless, the refuge will manage public use activities to reduce impacts. Providing 

access for recreational fishing opportunities allows the use of a renewable natural resource without 

adversely impacting other resources. General wildlife observation may result in minimal disturbance to 

wildlife. If the refuge determines that impacts from the expected visitor uses are above the levels that are 

anticipated, those uses will be discontinued, restricted, or rerouted to other less sensitive areas. 

Economics 

This alternative will offer some benefit to the local economy through visitation and use by local 

residents and nonresident visitors, as well as from purchases in the local economy by the refuge and 

its employees. Fishing, wildlife observation, and wildlife photography all contribute to local economic 

activity through purchases of food, lodging, gasoline, supplies, and from sales taxes. In addition, the 

Refuge Revenue Sharing Act requires the Service to make payments to local taxing authorities to 

offset the loss in tax revenue when private land is acquired for a refuge. These payments will 

continue. 

Potential Adverse Effects and Mitigation Measures 

Wildlife Disturbance 

Disturbance to wildlife at some level is an unavoidable consequence of any public use program, 

regardless of the activity involved. Obviously, some activities innately have the potential to be more 

disturbing than others. The management actions to be implemented have been carefully planned to 

avoid unacceptable levels of impact. 

As currently proposed, the known and anticipated levels of disturbance of the management action are 

considered minimal and well within the tolerance level of known wildlife species and populations 

present in the area. Implementation of the public use program will take place through carefully 

controlled time and space zoning and establishment of protection zones around key sites to avoid 

direct contact with sensitive areas, such as nesting bird habitat, etc. Monitoring activities through 

wildlife inventories and assessments of public use levels and activities will be utilized, and public use 

programs will be adjusted as needed to limit disturbance. 
92 Shell Keys National Wildlife Refuge 

User Group Conflicts 

As public use levels expand across time, some conflicts between user groups may occur. Programs 

will be adjusted, as needed, to eliminate or minimize these problems and provide quality wildlifedependent recreational opportunities. Experience has proven that time and space zonings, such as 

establishment of separate use areas, use periods, and restricting numbers of users, are effective 

tools in eliminating conflicts between user groups. 

Site Development 

Opening public use opportunities of fishing and wildlife observation and photography are not 

expected to have any adverse effects due to the remoteness and limited emergent land of the island. 

If the feasibility study results in large-scale habitat restoration, further analysis of the environmental 

effects and consultation with state and federal agencies will occur prior to project implementation. 

The management action is not expected to have significant adverse effects on wetlands and 

floodplains, pursuant to Executive Orders 11990 and 11988. 

Environmental Justice 

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations” was signed by President Clinton on February 11, 1994, to focus 

federal attention on the environmental and human health conditions of minority and low-income 

populations, with the goal of achieving environmental protection for all communities. The order 

directed federal agencies to develop environmental justice strategies to aid in identifying and 

addressing disproportionately high and adverse human health or environmental effects of their 

programs, policies, and activities on minority and low-income populations. The order was also 

intended to promote nondiscrimination in federal programs substantially affecting human health and 

the environment, and to provide minority and low-income communities with access to public 

information and opportunities for participation in matters relating to human health or the environment. 

The selected alternative will not disproportionately place any adverse environmental, economic, 

social, or health impacts on minority and low-income populations. Implementation of any action that 

includes public use and environmental education is anticipated to provide a benefit to the residents 

residing in the surrounding communities. 

Cumulative Impacts 

Cumulative impacts include impacts on the environment which result from incremental effects of 

proposed actions when added to other past, present, and reasonable foreseeable future actions. 

Cumulative impacts can result from individually minor, but collectively significant actions taking place 

over a period of time. 

Collectively implementing the goals, activities, and strategies as outlined in Alternative C or more 

explicitly, the Comprehensive Conservation Plan for Shell Keys National Wildlife Refuge would 

generally result in positive and beneficial impacts to habitat, wildlife, visitor programs, oil and gas 

activities, and general refuge administration. 
Appendices 93

Coordination 

The management action has been thoroughly coordinated with all interested and/or affected parties. 

Parties contacted include: 

All affected landowners; Congressional representatives; Governor of Louisiana; Louisiana 

Department of Wildlife and Fisheries; Louisiana State Historic Preservation Officer; Interested 

citizens; and Conservation organizations. 

Findings 

It is my determination that the management action does not constitute a major federal action 

significantly affecting the quality of the human environment under the meaning of Section 102(2)(c) of 

the National Environmental Policy Act of 1969 (as amended). As such, an environmental impact 

statement is not required. This determination is based on the following factors (40 C.F.R. 1508.27), 

as addressed in the Environmental Assessment for Shell Keys National Wildlife Refuge: 

1. Both beneficial and adverse effects have been considered and this action will not have a 

significant effect on the human environment. 

2. The actions will not have a significant effect on public health and safety. 

3. The project will not significantly affect any unique characteristics of the geographic area such as 

proximity to historical or cultural resources, wild and scenic rivers, or ecologically critical areas. 

4. The effects on the quality of the human environment are not likely to be highly controversial. 

5. The actions do not involve highly uncertain, unique, or unknown environmental risks to the human 

environment. 

6. The actions will not establish a precedent for future actions with significant effects nor do they 

represent a decision in principle about a future consideration. 

7. There will be no cumulatively significant impacts on the environment. Cumulative impacts have 

been analyzed with consideration of other similar activities on adjacent lands, in past action, and in 

foreseeable future actions. 

8. The actions will not significantly affect any site listed in, or eligible for listing in, the National 

Register of Historic Places, nor will they cause loss or destruction of significant scientific, cultural, or 

historic resources. 

9. The actions are not likely to adversely affect threatened or endangered species, or their habitats. 

10. The actions will not lead to a violation of federal, state, or local laws imposed for the protection of 

the environment. 
94 Shell Keys National Wildlife Refuge 

Supporting References 

U.S. Fish and Wildlife Service. 2008. Draft Comprehensive Conservation Plan and Environmental 

Assessment for Shell Keys National Wildlife Refuge, Iberia Parish, Louisiana. U.S. Department of the 

Interior, Fish and Wildlife Service, Southeast Region. 

Document Availability 

The Environmental Assessment was Section B of the Draft Comprehensive Conservation Plan for 

Shell Keys National Wildlife Refuge and was made available in June 2008. Copies of the 

Environmental Assessment are available by writing: Southwest Louisiana National Wildlife Refuge 

Complex, 1428 Highway 27, Bell City, LA 70630. 

_____________________________________ _____________________________ 

Sam D. Hamilton Date 

Regional Director