This 2-page letter is transcribed because file sizes were too large to reproduce it legibly as two images.
The ODFW's concerns are mostly about disturbance of wildlife by airboats as well as a potential conflict with other fish and wildlife recreationalists and potential habitat degradation.
[Added comments are within brackets.]
=============================== Transcription of 2-page letter
[State of Oregon logo.]
Department of Fish and Wildlife
Marine Resources Program
2040 SE Marine Science Drive
Newport, OR 97365
(541) 867-4741
FAX (541) 867-0311
June 20, 2003
Mr. Don Mann, Manager
Port of Newport
600 SE Bay Blvd.
Newport, OR 97365
Dear Mr. Mann:
Thank you for your inquiry concerning Oregon Department of Fish & Wildlife's opinion of a proposed airboat charter service on Yaquina Bay. This letter outlines some of our concerns regarding the operation of an airboat in bays or estuaries.
According to statements by the applicant in his letter to the Port of Newport, and to information provided by the Port regarding the applicants previous operation in the Willamette River basin, the intent is to provide access to "areas unattainable by any other means." The boat "will run over grass, mud, gravel and little or no water. It will go where other boats cannot go." By these descriptions it is clear the intent is for tour operations within the prime fish and wildlife feeding and resting habitats in the bay and river.
The most obvious wildlife species utilizing the mudflats, wetlands, and backwaters during the summer are wading birds (herons, egrets, rails, etc.), raptors (bald eagles, osprey, hawks, etc.), shorebirds (migratory and winter residents), and waterfowl (mallards, wood ducks, coots, teal, etc.). Marine and other mammals (seals and sea lions, otters, beaver, deer) are also present. Fisheries resources include juvenile salmonids and other marine species. An airboat operation conducted in the manner described would negatively, and in some cases severely, impact these species by several means. Noise disturbance would cause birds to take flight and expend energy doing so. Waterfowl such as resident geese and ducks may not be able to fly during early summer when adults molt and young have not yet acquired flight feathers. These waterfowl will not be able to escape from oncoming boats. Actual physical harm could occur to many wildlife species in shallow water, mudflats, gravel bars, or even deeper water from a high-speed airboat which is capable of quick stops without hard turns.
Damage to food resources such as benthic invertebrates, eelgrass beds, wetland marsh plants, and mudflats will have negative effects on the wildlife feeding upon them. Studies have documented damage to wetland and estuarine airboats in Alaska and Florida. Erosion of mudflats or deeper channels cut through mudflats by the bottom and wake of an airboat would change the microhabitat of mudflats, thereby altering wildlife use.
After consulting with Oregon State Police, the Department believes that the airboat tours as described by the applicant will violate ORS 498.006 "Chasing or harassing wildlife prohibited." The statute reads as follows: "Except as the State Fish and Wildlife Commission by rule may provide otherwise, no person shall chase, harass, molest, worry or disturb any wildlife except while engaged in lawfully angling for, hunting or trapping such wildlife."
Other agencies have concerns over the airboat operation. Roy Lowe, Refuge Manager for the U.S. Fish & Wildlife Service, stated that at low tide, waterfowl and shorebirds occupy the area close to the receding water line, where a shallow draft vessel such as an airboat would pass, and that the Fish & Wildlife Service would be strongly opposed to any such activity. Joe Koczur, Special Agent for the National Marine Fisheries Service Enforcement Office, said that harassment of any marine mammals would be prosecuted by his agency. The Environmental Protection Agency has ongoing research in the tideflats and shallow areas of the bay, and is concerned about potential damage to these sites.
Finally, an airboat tour business may easily come into conflict with other fish and wildlife recreationalists. Clam diggers, shrimp pumpers, anglers and bird watchers and others may well be negatively affected by an airboat that crosses mudflats, creates loud noises, travels at high speeds, etc. Sally's Bend is an especially important area for wading birds, waterfowl and wildlife viewing. An airboat passing through mudflats here would disturb wildlife and eliminate bird watching.
In conclusion, ODFW opposes the operation of an airboat charter service in the bay, due to the potential for disturbance of fish and wildlife, habitat degradation, and conflict with other recreational users of the natural resources of Yaquina Bay.
Again, thank you for your inquiry with ODFW on this important subject. Please don't hesitate to contact me at 867-0300, ext. 244, with any questions you may have.
Sincerely,
[signature]
Keith Matteson
Marine Fisheries Biologist
541-867-033 ext. 244
cc:
Patty Burke, Marine Program Manager, ODFW
Doug Cottam, Asst. Dist. Wildlife Biologist, ODFW
Roy Lowe, Refuge Manager, USFWS
Joe Koczur, Special Agent, NMFS
Walt Nelson, Branch Chief, EPA
Range Bayer, President, Yaquina Birders & Naturalists
Kathy Merrifield, OSU
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