Our mission is to protect the habitat of Puget Sound tidelands from the underregulated expansion of new and intensive shellfish aquaculture methods. These methods were never anticipated when the Shoreline Management Act was passed. They are transforming the natural tideland ecosystems in Puget Sound and are resulting in a fractured shoreline habitat. In South Puget Sound much of this has been done with few if any meaningful shoreline permits, limited public input, and with minimal peer-reviewed science. It is exactly what the Shoreline Management Act was intended to prevent.

Twitter: http://www.twitter.com/protectourshore
Facebook: https://www.facebook.com/ProtectOurShoreline
Older News: from 2006 to 8/20/10
(This blog evolved from: http://protectourshoreline.org/)

Thursday, November 20, 2014

Burley Lagoon: Demand Letters Sent to Pierce County and Washington State Attorney General From Coalition Attorney

If you ignore them they will not go away,
they will only become more focused.
 In the beginning:
"The purpose of this letter is to request that the Pierce County government [and Washington Attorney General] take action to strictly enforce current Pierce County regulations which prohibit any aquaculture activities on the shorelines of the State without a valid permit, and to impose the appropriate penalties that both State laws and Pierce County -regulations require, including prosecution of responsible Taylor Shellfish Company and/or its employees for a criminal misdemeanor pursuant to RCW 90.58.212." November 18, 2014 letter to Pierce County and Washington's Attorney General from Mr. Tienson

Demands for action will not go away
The Coalition to Protect Puget Sound Habitat, Friends of Burley Lagoon, and concerned individuals have had their attorney send letters to the Washington Attorney General Bob Ferguson, Pierce County Prosecuting Attorney Mark Lindquist, and Pierce County Executive Pat McCarthy  demanding action be taken against Taylor Shellfish's unauthorized and unpermitted activities which have been occurring in Burley Lagoon since April of 2012. The letters were written by attorney Thane Tienson, with the law firm of Landeye Bennett Blumstein in Portland, Oregon, and detail how Pierce County has turned a blind eye to citizens' complaints about Taylor Shellfish greatly expanding operations within Burley Lagoon. (attachments referenced in the letters above are found here; individual letters are found by clicking on links above)
You wouldn't question grandfather would you?
When Pierce County was asked to produce permits which allowed Taylor Shellfish to expand activities within Burley Lagoon, Pierce County responded: "There are no formal permits to produce as this has been a use that has been grandfathered." For reasons detailed in the demand letters, Mr. Tienson states: "Only the first portion of this statement from PALS is supported by the facts..." (no permits). All Pierce County has on record of something being "grandfathered" is a 1988 letter written to tideland owner Mr. Yamashita (Western Oyster Company) which described "floating oyster culture." However, the letter also states: "should Western Oyster wish to expand the operation in Burley Lagoon, Pierce County will require the obtaining of all shoreline permits and approvals."
Just because your car had a current license when you parked it in a garage 5 years ago doesn't mean it's current now.
In December of 2007 Western Oyster stopped reporting any shellfish harvests to Washington Department of Fish and Wildlife, something it had done on a regular monthly basis between 1986 and December of 2007, after which nothing harvested from Burley Lagoon was reported until 2012, then by Taylor Shellfish. Washington law is clear in requiring shellfish growers to report their harvests, including registered farm numbers, names of shellfish harvested, and the amounts harvested. Mr. Tienson also notes Washington and County regulations are clear in stating if a "nonconforming use activity ceases for more than one year, any restarting of that activity requires issuance of a new permit under any new rules that thereafter were adopted (WAC 173-27-080; PCC 20.72.060)." Western Oyster ceased reporting any harvests after 2007. Taylor Shellfish cannot, 5 years later, start up a nonconforming activity without permits.
He waved his arm and said this is what you are buying. Oops, he didn't own it to sell.
When Taylor Shellfish was found to be growing geoduck on state tidelands in Totten Inlet which it didn't own, they claimed the seller of the tidelands told them it was theirs to sell. This excuse was dismissed by the Attorney General. Likewise, Taylor Shellfish cannot now claim they were an "innocent purchaser" under PCC 18.140.023(D) when they began leasing tidelands in Burley Lagoon.
We're just making it disappear or look different, so we don't need a permit.
Part of Taylor Shellfish's unpermitted operations in Burley Lagoon included dismantling many of the >45,000 square feet of floats in Burley Lagoon and replacing a minor amount. Taylor Shellfish did not have the luxury of simply telling Pierce County it was "still within the footprint and use of the historical exemptions." As Mr. Tienson's letter shows with clarity, any exemption which may have existed ended long ago. Pierce County chose not to act, despite citizen complaints of unpermitted activities.
Pierce County's gumshoe investigation, without shoes (or gum?).
In June of 2014, Pierce County concluded its investigation of complaints from citizens about Taylor Shellfish's unpermitted activities in Burley Lagoon. At its foundation lay the belief that Taylor Shellfish was already authorized to be in the Lagoon. Had the investigator put on his shoes and taken a walk he would have discovered, for reasons detailed in Mr. Tienson's letter, that Taylor Shellfish had no authorization, permits, nor use rights of any nature to be operating as they were and still are.
In the end
In summation, Mr. Tienson ends with this closure:
"In sum, Taylor Shellfish has no authorization or valid permits of any sort which would authorize it to be in Burley Lagoon for any reason, let alone for a large industrial-scale commercial geoduck farm. Pierce County Code and Washington State laws demand that its unlawful operations and activities be halted immediately, that it be required to remove its equipment and materials and floats from the Lagoon, and allow the Lagoon to begin the slow process of recovering to its original condition. Costs for the Lagoon's recovery should be borne by Taylor Shellfish, as required by PCC 18.140.050(G).
"Finally, since Taylor Shellfish is in violation of several provisions of State and County law. We also request that any evaluation activity by PALS personnel on Taylor Shellfish's geoduck permit application that is currently under review be halted immediately."
It is called Puget Sound, not Taylor Shellfish Sound for a reason
Puget Sound is a treasure providing habitat for a diversity of species, some found only in the northwest. It was not meant to be a habitat for a few large companies to transform, used to create a treasure chest for themselves.


Wednesday, November 19, 2014

Non-native Pacific Oyster Hatcheries' New Problem - For Now

The progression of blame for
non-native Pacific oyster hatchery problems:
Vibrio Tubiashi>Ocean Acidification>Vibrio coralliilyticus>?
Old bacteria, newest blame
Vibrio coralliilyticus
(from 2003 study in Applied and
So many Vibrio to choose from
Shellfish hatcheries in the northwest trying to grow non-native Pacific oysters now have a new source of their trouble to point their fingers at: Vibrio coralliilyticus (Vc). In the years past, the bacterium Vibrio tubiashi (Vt) was believed to have been the source of hatchery die-offs, but Oregon State University now says there was a mis-identification. In a press release today, OSU states Vc is "the primary offender in bacterial attacks on Pacific Northwest oyster larvae."
Far more widespread and the primary offender
In announcing the mis-identification, OSU noted Vc is not only "...far more widespread than previously believed, but that it can infect a variety of fish, shellfish and oysters, including rainbow trout and larval brine shrimp. And it appears to be the primary offender in bacterial attacks on Pacific Northwest oyster larvae."
Sometimes a non-native species just
shouldn't be where we want it to be.
One piece of the puzzle about why non-native oyster hatcheries have a problem
Trying to grow the non-native Pacific oyster from Japan in the colder waters of Puget Sound has always been a challenge for the shellfish industry. Large sums of taxpayer money has been spent to overcome one perceived problem after another. Genetically modifying the species so they become sterile only adds a level of stress to a species out of its normal environ. OSU notes there are multiple problems in saying:
In what's now understood to be a problem with multiple causes, these pathogenic bacteria were involved in major crashes of oyster hatcheries, causing shortages in seed oysters for commercial producers. Dramatic losses were suffered in a Netarts Bay, Oregon, hatchery in 2005, and Washington hatcheries were also hard hit. Bacterial infection, water acidity, oxygen depletion and rising seawater temperatures are all believed to have been part of the problem.
Something to consider is the problem lies not with the waters of Puget Sound and the northwest, but instead it's in trying to force a non-native species into Puget Sound and other areas of the northwest. 

Monday, November 17, 2014

Tell Congress to Protect Our National Parks

2016 is the Centennial Celebration
of the National Parks System
Get involved in helping to ensure the National Park Service has the congressional support it needs. Click here to tell your Senators and Representatives you support the protection and funding of the National Parks for future generations. You can send the form letter as is, or better, add your own personal comments on why National Parks are important. Show your support by getting involved.

Monday, November 10, 2014

Drakes Bay Oyster: Black Helicopters Sighted About Point Reyes National Seashore

[Update 11/13: Portion of Hog Island lease in Tomales Bay closed by California Department of Health due to fecal coliform. (see Point Reyes Light article - requires subscription) Despite claims from Corey Goodman and Peter Prows of how well oysters filter water of fecal coliform, Tomales Bay tells another story. Hog Island Oyster has had a portion of its lease area closed to harvesting due to elevated levels of fecal coliform. This despite an abundance of oysters in Tomales Bay. Mr. Goodman and his sheep farm, along with other cattle ranchers along the shorelines of Tomales Bay, might consider where the pressure to clean up their discharges into the bay is going to be coming from. It will not be their bogey men written about in their October 6 article.] 

Peter Prows and Corey Goodman Claim Protect Our Shoreline
Part of Some Scheme to Eliminate Agriculture
on Point Reyes National Seashore

Flights of fantasy - no charge
In what borders on hyperbolic exclamations of paranoia, Peter Prows and Corey Goodman have claimed this blog site is somehow part of a scheme to eliminate cattle ranching on Point Reyes National Seashore. Quoting from an October 6 post in which it was suggested an opportunity exits to see how effective oysters are in clearing the water, when harvesting of planted oysters is completed at the end of the year, they instead use Glen Beck logic to make this site part of a "master plan" whose sole purpose is to eliminate ranching from Point Reyes Seashore. To be clear, this site is not part of a "plan" to end cattle ranching or sheep farming on Point Reyes or nearby.

They're coming after your minds.
Get your tinfoil hats out!

Control the press, you control their minds -  and willingness to speak of written memories?
Mr. Prows and Mr. Goodman have put in their minds, and now in printed words through the Point Reyes Light (which Mr. Goodman's Marin Media Institue purchased in 2010), a story of such fantasy it puts in question what legal or investing advice flows from the two authors. In their co-authored piece, retired (2003) superintendent of Channel Islands National Park Tim Setnicka and Santa Rosa Island are referred to. In a recent speech (which the PRL said "sometimes sounded like a conspiracy") Mr. Setnicka referred to a $28 million sale by Vail and Vickers Company of Santa Rosa Island which allowed occupancy for 25 years. In 2011, what had evolved into a private hunting reserve for wealthy clients, the lease came to an end and the National Park Service allowed Santa Rosa Island to become available to all citizens. Mr. Setnicka, Mr. Goodman, and Mr. Prows apparently feel the agreement signed between the Vail and Vickers Company, who chose to convert the island to a private hunting reserve in 1998, somehow makes clear ranching on Point Reyes National Seashore is doomed. Not clarified by Mr. Setnicka in his speech was while it may have taken him from 2003 until October of this year to "speak" of his "conspiracy" belief, he did write a 3 part series for the Sanata Barbara News-Press in 2006.

Nov. 11: Nita Vail to speak of the olden days.
 Nita Vail as a child on Santa Rosa Island

From the horse's mouth - November 11
Perhaps some clarity to just what went on with the Vail family's hunting reserve and the National Park Service, including what role Mr. Setnicka played while employed by the Park Service, will be heard on November 11 when Nita Vail, daughter of the family whose lease ended in 2011, speaks at West Marin School. Ms. Vail may also be willing to discuss who it is that invited her and Mr. Setnicka to speak and perhaps shed some light on the $28 million agreement signed over 25 years ago by the Vail and Vickers Company. She may also be willing to comment on testimony before Congress by Vail family member Tim Vail in 2007 which included:
 To ease in the transition,[to a National Park] part of the island’s sale included an important provision to allow the V&V [Vail and Vickers] cattle and wildlife operations to continue within the Park through the year 2011. Specifically the family was given a 25-year lease on a 7-acre parcel with right of use and occupancy. Separately, V&V was promised by the Park Service the cattle and wildlife operations were to continue for 25 years through the use of mutually agreed upon successive 5-year Special Use Permits.
Know your enemy - or who at least who it is
It is best for the Point Reyes Light to steer from the speculation and conspiracy theories submitted by others about who cattle ranchers and sheep farmers should fear. Were they to spend a small amount of time researching water quality, they would find it is the shellfish industry's concerns about clean water the cattle ranchers and sheep farmers should fear. It is not this site.

Saturday, November 8, 2014

Taylor Shellfish and Geoduck Farming, Welcome to Clallam County

"Don’t see major issues with proposal."
Greg Ballard, Senior Planner for Clallam County

 Taylor Shellfish proposes a 30 acre geoduck farm on Dungeness Farm's tideland parcel. The proposal is adjacent to the Dungeness Wildlife Refuge to the west and designated Wildlife Habitat Conservation Areas to the south. Taylor Shellfish apparently feels that expanding the wilderness area on the Olympic Peninsula is fine, as long as they are able to populate the tidelands with PVC.
[Note: This site is an avid supporter of wilderness, including the expansion of wilderness areas on the Olympic Peninsula. To not include the intertidal areas in the Wild Olympics proposal is short sighted. Bill Taylor fully supports the program "so that shellfish companies can continue to grow."]

The proposal describes how they would have a 14 year transformation of tidelands occurring. Up to 5 acres each year would be planted, meaning that after the 2nd year, at any one time, over 10 acres of PVC pipes and netting would cover areas in these tidelands. The parcel is leased through 2028, paying to Dungeness Farms 10% of the revenues and a small amount for acreage planted until harvest. The rest of the revenue generated for geoduck exported to China goes directly to Taylor Shellfish.
[Note: Seattle Shellfish has recently signed a lease which pays 30% to the tideland owner. The owners of Dungeness Farms may want to ask Taylor Shellfish about that.]
There is no description of when harvesting would occur or how much would occur, leaving only speculation to how much sediment would be disturbed. Also left to speculation is what number of wildlife which has become dependent on the Wildlife Refuge and Habitat Conservation areas will become ensnared in the "predator exclusion" netting.

Did any of the preceding help Clallam County
see any major issues?

The JARPA application and other documents submitted to the county may be found here:

Wednesday, November 5, 2014

Kitsap County: November 17, County to Discuss Department of Ecology's Conditionally Approved SMP update

Kitsap County will hold a meeting November 17 to discuss Ecology's conditionally approved Shoreline Master Program update. Both required and recommended changes will be available at the meeting, or are available on Ecology's web site. As a result of Taylor Shellfish's attorney, much of the regulatory oversight of aquaculture has been minimized.

Aquaculture gear provides "habitat"
so should not need a "burdensome" permit.
(p.3, 2012 letter)

Unlike aquaculture gear, Japanese eelgrass
is a "weed", not a food source for migratory birds,
habitat for other species, or something to sequester CO2.

 Date:  November 4, 2014
 Contact:  David Greetham, Planner Supervisor Kitsap County DCD  
  dgreetha@co.kitsap.wa.us or 360.337.5777
No:  2014-126 

 Kitsap County to Host Open House on Final Shoreline Master Program (SMP)
County to host an open house on Department of Ecology SMP conditional approval and Ecology’s required and recommended changes. 
(Port Orchard, WA)   The Kitsap County Shoreline Master Program (SMP) Update received conditional approval by the Department of Ecology on October 2, 2014. The Kitsap Board of County Commissioners wishes to provide the public an opportunity to view the required and recommended changes before they take final action to adopt the SMP.

Kitsap County will host an open house on Monday, November 17 from 5:00-6:00pm at the Silverdale Community Center, Evergreen Room.  Copies of the Department of Ecology Conditional Approval letter and display copies of the Kitsap SMP will be available at the open house. These documents can also be accessed via the Kitsap SMP website, www.kitsapshoreline.org.

The Board of County Commissioners is scheduled to hold a hearing on adopting the Ecology approval conditions on Monday, November 24th at their regular business meeting (5:30pm, Kitsap County Administration Building, Port Orchard).  

Thursday, October 30, 2014

Pierce County SMP Update: Final Council Hearing Delayed Until Early 2015, Geoduck Expansion Continues

Taylor Shellfish is "troubled." Kitsap County experiences
the geoduck industry's dislike of permits.

Pierce County SMP Update Council Hearing Put Off Until Early 2015
Pierce County has announced its final Council hearing on its updated Shoreline Master Program (SMP) will not occur until early 2015. Comments will continue to be accepted, as will public testimony at the final hearing (click here to comment). To see amendments proposed click here. To see the draft SMP, click here. To see Taylor Shellfish's 156 page document written by their attorney describing why they are "troubled" by the amendments, click here (10mb file).

Marine habitat or PVC?
Seattle Shellfish/Taylor Shellfish/Haley
Geoduck proposal

Older SMP Suits Industry Just Fine - Better than Almond Roca for Christmas 
In the interim the geoduck industry has continued to press for expansion in Pierce County under the old SMP. Most recently, a permit allowing 11 acres of intertidal habitat has been approved for Seattle Shellfish and Taylor Shellfish, the two largest geoduck operators in Washington. The joint project on tidelands owned by both, and by the Haley (Almond Roca) family, is a clear indication of the cooperation between the companies to ensure expansion occurs under the older, more lenient SMP, under terms they find acceptable. A delay of the more "troubling" updated SMP may be a Christmas gift the industry wants.

Kent Kingman's Unpermitted Shellfish Operation
(Mr. Kingman owns Minterbrook Oyster)
To be operated by Taylor Shellfish
So Good You Can't Have Just One - Taylor Shellfish, Picking up Pieces of the King
Among a myriad of other proposals in Pierce County, Taylor Shellfish has also proposed a 25 acre geoduck farm in Burley Lagoon, a small embayment located west of Gig Harbor. Taylor Shellfish has also been chosen to be the operator of Kent Kingman's unpermitted shellfish operation on tidelands he owns (Mr. Kingman is also the new owner of Minterbrook Oyster). The resolution of Mr. Kingman's various violations is currently being worked through by both Taylor Shellfish and Mr. Kingman  (click here to read Pierce County's June 3, 2014 letter to Taylor Shellfish requesting additional information and describing some of Mr. Kingman's violations). (See earlier post for additional details on Mr. Kingman's various shoreline violations.) Located ~2 miles south of the Haley operation, this too would fit well with Seattle Shellfish's hatchery and nursery facilities, ~2 miles to the west in Spencer Cove on Harstine Island.

Geoduck tubes and oyster tumblers.
Oops, did I need a permit?

A Philosophy Spreading into Kitsap County - "New Day Fisheries" (owned by Scott and Joni Kimmel)
Recently Kitsap County began to experience the philosophy of its being "easier to ask forgiveness than ask for permission" some industry members practice. Rather than apply for a permit, New Day Fisheries operators chose instead to simply install PVC tubes last summer into tidelands owned by the Baldwin family, and plant them with geoduck. When reported to the county, instead of being required to pull the unpermitted tubes, New Day Fisheries apparently said they were sorry, and that in addition to the 3,000 unpermitted PVC tubes they were also going to populate another 35,000 square feet with PVC tubes, and "oyster tumblers" on another 27,000 square feet of tidelands (see image above). Kitsap County told the Kimmels and the Baldwin family, the latter being the tideland owners, they do in fact need permits. That permit process has begun with an initial comment period on a SEPA decision of a mitigated determination of non-significance ending November 6, and a public hearing scheduled for January 8. The permit information may be found by clicking here. Unclear is how the lateral boundaries of the tideland parcel were determined. What is clear is the plasticizing of Puget Sound's tidelands is spreading north. Contact/permit information may be found here:

The application file may be examined at the Department of Community Development, 614 Division Street, Port Orchard, Washington, between the hours of 10:00 a.m. and 4:00 p.m. Monday through Thursday and Fridays 9:00 a.m. through 1:00 p.m., except holidays. The staff person assigned to this project is Lisa Lewis and may be contacted at (360) 337-5777. Lisa's email is: llewis@co.kitsap.wa.us
This is not in the "statewide interest"
and should be stopped.

"Statewide interest" or just in the interest of a few geoduck operators plasticizing Puget Sound's intertidal area?
Geoduck growers transforming Puget Sound's intertidal areas claim geoduck sold to China in order to satisfy their emotional belief of its bestowing virility, like shark fin soup or Black rhinoceros horns, is in the "statewide interest."  They claim their industry is a "preferred use" and as such should be allowed to use any methods with minimal regulatory oversight. Through well crafted public relations efforts and well paid attorneys they have to date succeeded in convincing agencies this is somehow good for Puget Sound. It is not.

Governor Inslee and Taylor Shellfish's Bill Dewey

Politics is messy, but it need not be gooey.
Governor Inslee has turned his eyes towards fundraising and sees a large pool of money available to support his campaign and those of others with help from the shellfish industry. Politics is messy, but it need not be gooey. Tell the governor geoduck farming is not in the statewide interest and populating Puget Sound's intertidal areas with PVC pipes is not a "preferred use" allowed under the Shoreline Management Act. Click here to contact the governor.

Wednesday, October 22, 2014

Taylor Shellfish/Seattle Shellfish Haley Geoduck Farm Permit Approved (was Ocean Acidification an issue to consider?)

Pierce County Hearing Examiner
Approves Haley Geoduck Farm Permit
Denies MDNS Appeal
Geoduck Farm on Haley Family
Tidelands in Case Inlet
On October 21, Pierce County's Deputy Hearing Examiner Edward McGuire issued a decision on the appeal of a Mitigated Determination of Non-significance (MDNS) and shoreline permit for a geoduck farm operated by the two largest geoduck growers, Taylor Shellfish and Seattle Shellfish, on tidelands owned by the Haley family and themselves.
MDNS Appeal: Industry Witnesses "More Persuasive"
In that decision Mr. McGuire found the challenges to the MDNS decision by the Coalition to Protect Puget Sound and neighbors were either "without merit", did not establish a "probable significant adverse impact", "failed to carry their burden of proof", and had witnesses who were "overshadowed by Applicant's witnesses pertaining to specific field experience, knowledge, and expertise in geoduck aquaculture; and were thus more persuasive." Despite Seattle Shellfish building a shellfish hatchery to the west on the shoreline of Harstine Island's Spencer Cove, operating a shellfish nursery over 100 yards long within Spencer Cove, and operating numerous geoduck farms in Spencer Cove, along with those in Case Inlet, the Hearing Examiner felt he was not presented with sufficient evidence to warrant requiring a cumulative impacts analysis.
Shoreline Permit: Approved with Conditions, Some added or Modified
Beginning on page 30 of the decision the Examiner lists the Conditions which are to be made part of the permit. Added is that a "status report" must be submitted every 2 years, listing all conditions of the permit and that an aquatic vegetation survey be completed "following issuance of the SDP", used to determine farm boundaries and to "reflect any changes between issuance of the SDP and planting." With conditions listed and as modified the Examiner believes the permit approval will meet all requirements.
Consumption of carbonate ions by CO2's
absorption impedes calcification.

Absorption of fewer carbonate ions by
increased high density shellfish farming
 will impede calcification in all species.
(image from NOAA)
Is what's good for the shellfish industry good for Puget Sound?
Ocean Acidification - Shellfish initiatives and CO2 absorption are bad for native species.
Not considered is what impact expansion of high density shellfish "farming" will have on chemical changes resulting from what is being promoted by the shellfish industry as a threat to its survival: Ocean Acidification. In the image provided by NOAA, it is seen that CO2 being absorbed by the marine waters is altering its chemical makeup, resulting in what Taylor Shellfish's Bill Dewey says are "fewer carbonic ions" required for shellfish. It is these carbonic ions which all species who require calcification to grow, whether it be shells or bones, are dependent on.
Pteropod shell dissolution
Shell dissolution on native pteropods
A study published August 27, 2014 by NOAA's Shalene Busch, shows pteropods native to Puget Sound, and an important link in the oceanic food chain:
"experiences shell dissolution and altered mortality rates when exposed to the high CO2, low aragonite saturation state (Va) conditions that occur in Puget Sound and the northeast Pacific Ocean." [click here for study]
Is what's good for the shellfish industry good for Puget Sound?  What will be the impact of the Washington and National Shellfish Initiatives on the native species of Puget Sound as those high density plantings "sop up" the fewer carbonic ions? There's something for Sea Grant, the University of Washington and Governor Inslee to ponder, along with other Hearing Examiners, the Shorelines Hearings Board, and judges.

Thursday, October 16, 2014

Sierra Club Calls on Governor Inslee to Roll Back the Shellfish Initiative

Click here to join with the Sierra Club to tell Governor Inslee the shellfish initiative's transformation of Puget Sound's intertidal habitat area is not in the statewide interest. Get involved.  The shellfish industry is.
Speak up to Protect Shorelines and Wildlife
from Unlimited Expansion of Industrial Aquaculture
PVC pipes for geoducks shipped to China.
Plasticizing Puget Sound's intertidal area 
is not in the "state wide interest."
Join with the Sierra Club in calling on Governor Inslee to roll back the shellfish initiative before it results in the transformation of the intertidal habitat area into one populated with PVC pipes, grow-out bags and other structures used in the industrial production of shellfish. The shellfish initiative is not healthy for this fragile habitat area, unique to Puget Sound, and upon which a diversity of species depend on for survival.

Grow-out bags for non-native oysters.
Grow-out bags leave nothing
but scoured sediments when removed.
Get involved. The shellfish industry is generating millions of dollars in profits from growing geoducks shipped to China. They are using those profits for their attorneys, lobbyists and public relations firms to craft an image which will result in a permanent transformation of a habitat area unique to Washington's Puget Sound. It is what the Shoreline Management Act was intended to protect and is not in the statewide interest.

Governor Inslee and Taylor Shellfish
lobbyist Bill Dewey.
The things that money can buy.
Plastic pollution - Over 40,000 PVC pipes per acre are stomped i

Plastic pollution - Over 40,000 PVC pipes per acre are stomped into the beach for geoduck planting.

Take Action


Wednesday, October 15, 2014

Willapa Bay: Ecology Announces Draft Pesticide Application Permit to Eliminate Native Shrimp

Comments accepted through December 8.
Documents are available by clicking here.
Comments may be emailed here: derek.rockett@ecy.wa.gov
(see below for mailing address for written comments)

Improving the "merroir" of Willapa Bay oysters.

Will the "chemical soup" have another ingredient added?
The Department of Ecology has announced a draft permit and EIS which would allow the application of the pesticide imidacloprid on the tidelands of Willapa Bay and Grays Harbor to eliminate that native burrowing shrimp, a food source of native Green Sturgeon, to help grow non-native Pacific oysters. It has been developed at the request of the shellfish industry and follows the first application of an herbicide to eliminate Japanese eelgrass, a sea grass which the shellfish industry claims makes growing non-native Manila clams difficult in Willapa Bay. Both follow Washington's Attorney General office describing Willapa Bay as a "chemical soup."

WSR 14-20-123
[Filed October 1, 2014, 11:42 a.m.]

Announcing a Draft Individual Permit for Burrowing Shrimp Management on Commercial Oyster and Clam Beds in Willapa Bay and Grays Harbor for Review and Comment

Proposed Permit: The Washington state department of ecology (ecology) is proposing a new individual permit to regulate the use of imidacloprid for management of burrowing shrimp on commercial oyster and clam beds in Willapa bay and Grays Harbor, a surface water of Washington state. Permit development was requested by the Willapa/Grays Harbor Oyster Growers Association (WGHOGA) to control burrowing shrimp on commercial oyster and clam beds in Willapa Bay and Grays Harbor to aid in the cultivation and harvest of oysters and clams.

Washington's water quality statutes and regulations do not allow the discharge of pollutants to waters of the state without permit coverage. Imidacloprid, the pesticide proposed for management of burrowing shrimp is a potential pollutant, and therefore requires a discharge permit before application to surface waters.

The applicant has applied for a sediment impact zone (SIZ) as the proposed discharge will likely impact sediment quality on sediments where the pesticide is applied. A SIZ allows for sediments and sediment dwelling organisms in the treatment areas to be temporarily impacted. A sediment monitoring program will be established to ensure that recovery or recolonization of treatment areas occurs. The applicant requests approval for a SIZ that covers an area of one thousand five hundred acres annually in Willapa Bay and five hundred acres annually in Grays Harbor throughout the term of the permit. If granted by ecology, the SIZ will be incorporated into the discharge permit as a permit condition.

As part of the environmental review necessary under the State Environmental Policy Act, ecology has determined that this proposal is likely to have significant adverse impacts on the environment. A draft environmental impact statement (DEIS) has been prepared. The DEIS, discharge permit and SIZ will be available for review and comment for forty-five days beginning on October 24, through December 8, 2014.

Purpose of the Permit: This permit would allow the management of burrowing shrimp on commercial oyster and clam beds in Willapa Bay and Grays Harbor, using the pesticide imidacloprid. WGHOGA must apply for coverage under this permit prior to implementing burrowing shrimp control activities using imidacloprid.

Copies of the Draft Permit: You may download copies of the draft permit, fact sheet, DEIS, and SIZ application beginning October 24, 2014, from the following web site

The public review period for these documents ends on December 8, 2014.

Ecology Contact: Derek Rockett, Washington State Department of Ecology, P.O. Box 47775, Olympia, WA 98504-7775, phone (360) 407-6697, e-mail derek.rockett@ecy.wa.gov.

Open House, Workshop, and Public Hearing: Ecology will hold one combined open house, workshop, and public hearing on the draft individual permit, DEIS, and SIZ application. The purpose of the workshop is to explain the individual permit, and answer questions in order to facilitate meaningful testimony during the hearing. The purpose of the hearing is to provide an opportunity for people to give formal oral testimony and comment on the proposed permit, DEIS, and SIZ application. Written comments will receive the same consideration as oral testimony. The open house, workshop, and public hearing will begin at 10 a.m. and conclude when public testimony is complete.

Open House, Workshop, and Public Hearing: On December 2, 2014, at 10 a.m., Willapa Harbor Community Center, 916 West First Street, South Bend, WA 98586.

Submitting Written Comments: Ecology will accept written comments on the draft permit, fact sheet, environmental impact analysis, and SIZ application until 5 p.m. (or postmark if mailed), December 8, 2014. Ecology prefers comments be submitted by e-mail. E-mailed comments must contain the commenter's name and postal address. Comments should reference specific permit text when possible.

Submit comments by e-mail to derek.rockett@ecy.wa.gov.

Submit written comments to Derek Rockett, Washington State Department of Ecology, P.O. Box 47775, Olympia, WA 98504-7775.

Ecology must receive e-mail comments by 5 p.m., December 8, 2014. Written comments must be postmarked no later than December 8, 2014.

Issuing the Permit: The final permit will be issued after ecology receives and considers all public comments. If public comments cause a substantial change in the permit conditions from the original draft permit, another public notice of draft and comment period may ensue. Ecology expects to issue the general permit in the spring of 2015.