The public comment period on this issue ended Tuesday November, 21 2017. To view CCA Maryland’s official comments on this issue CLICK HERE
In 2015, Maryland Department of Natural Resources(DNR) made the decision to further their longstanding application to the US Army Corps of Engineers (USACOE) and Maryland Department of the Environment (MDE) for authorization to dredge fossil oyster shell from Man O War Shoal in the Upper Bay. The MDE has recommended approval of a Tidal Wetlands License by the State of Maryland Board of Public Works, which is one of the two required authorizations. The Board of Public Works, which is comprised of Governor Larry Hogan, Comptroller Peter Franchot, and Treasurer Nancy Kopp, is now accepting your input on this plan through November 21st, and we hope that you will take the time to reach out and let them know what you think.
For 46 years ending in 2006, Maryland allowed the dredging of fossil oyster shell from the Upper Bay. This program was called the repletion program, which mined fossil shell from areas where oyster populations weren’t as strong, and moved that shell to areas with higher spat yields so that young oysters would begin growing, and then move that same shell to public fishery areas where it would be harvested. Marketed in part as allowing for a sustainable oyster harvest, it was anything but. The action was started at a time when the Bay-wide oyster harvest was approximately 1.5 million bushels per year, and ended in a year where the harvest was approximately 26,000 bushels. While not solely attributable to the repletion program itself, this major decline in harvest can be seen as a proxy for the health of oyster populations in the state. Over the 46 year period it is estimated that 185-200 million bushels of shell were moved.
Now DNR and certain parts of the industry want to restart the repletion program by dredging fossil oyster shell from Man O’ War Shoal off the mouth of the Patapsco River in Baltimore County. The shell would be mechanically dredged from one of the few remaining large shell beds in the Upper Bay and is proposed to be used for undefined applications and proportions for the “restoration of native oyster populations and oyster fisheries”, which could include the traditional replenishment program for the public oyster fishery, use in sanctuaries, and in supporting aquaculture efforts.
Now is your chance to provide your thoughts to the Board of Public Works on the MDE recommendation for the approval of a Tidal Wetlands License that would allow for the dredging of fossil shell from Man O War Shoal. CCA Maryland has fought this issue for ten years and is doing so now, but we need your help. We oppose DNR’s plans and the application for the following reasons:
- Man O War is one of the last large living reefs in the Upper Bay and provides unique habitat and structure, hosting a variety of species that fish, crabs, and waterfowl all rely on for food and habitat. Also, the eastern 1/3rd of Man O War Shoal is an oyster sanctuary, and while oyster spawning success in the Upper Bay is severely limited, that does not mean that the shoal is not an important part of the regional ecosystem.
- DNR has no specific plan for the use of any shell dredged from the Shoal. It states that, “Ultimately, [DNR] will utilize comments from the public and the Oyster Advisory Commission to develop an allocation plan.” Without a clear, well-defined plan that includes sustainable funding sources, any proposed dredging of a such a unique habitat is an ill-advised and unacceptable use of a public resources.
- The proposed future use of any dredged fossil shell for an unsustainable “put and take” fishery does nothing for the long-term security of that industry. Once the proposed 5 million bushels of fossil shell have been dredged and allocated, the next question will be “where do we dredge shell from now?”
- The application from Maryland DNR includes the statement that once dredging occurs, they will need to “assess the ecological consequences of removing the shell from the shoal”. We should not risk the health of our natural resources unless we know the consequences ahead of time, or spend public dollars on an experiment with no known positive benefit.
- There is a very significant funding gap that would prevent the full execution of DNR’s proposal. This funding gap would most likely result in the misuse of any shell dredged from the Shoal. Without a commitment in funding that would help guarantee the wise use of shell from Man-O-War Shoal, the State cannot afford to gamble with its remaining historic oyster bars.
- The wild oyster population continues to decline and there are no controls in place to manage that harvest in a sustainable fashion, or control the shell loss which occurs because of harvest.
- The low profile shell reefs that would be built by fossil shell do not support the level of growth needed in the Chesapeake Bay to create a sustainable population or fishery.
You can share your thoughts about the application by contacting Bill Morgante, Wetlands Administrator for the Board of Public Works via email at email@example.com no later than 5pm on Tuesday, November 21st.
To find more information on DNR’s plans, the application itself, and other supporting materials, please visit the BPW’s website and click through the links found on the lower left corner of the page.