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, April 16, 2015

Burley Lagoon: Taylor Shellfish Agrees - Not All Farms are Equal, will Perform an EIS

"every farm is different" Taylor Shellfish, April 13, 2015
What took you so long?
 
Trust us, one PVC tube is the same as the next, and the next, and the next ...
For years Taylor Shellfish and others have tried to place all geoduck farms into the same frame, using past separate permit approvals, Shorelines Hearings Board decisions and court decisions to support their applications, implying they are all the same. In permit hearings and court cases they have claimed studies which have looked at discrete farm operations clearly show all farms, no matter the size, no matter the location, have no impact. This despite one of their most widely used studies stating the following qualification after peer review and publication this year:
"...it is cautioned that projection of the current study results to larger temporal or spatial scales may be inappropriate in the absence of additional studies. The sites for the current study were relatively isolated from other geoduck aquaculture plots, and were being used for aquaculture of geoducks for the first time. The data may not provide a sufficient basis for unequivocal extrapolation to cases when a given plot is exposed to a long series of successive geoduck aquaculture cycles. Likewise, it may not be appropriate to extend the findings of the current study to cases when a number of separate plots are adjacent to one another and encompass significantly larger surface areas than any single plot. Resolution of the questions of larger spatial and temporal scales will be a major challenge for geoduck farmers as they continue production on existing plots and expand into new areas, and will be an important research goal in the interests of informed management policies by natural resource agencies." (ECOLOGICAL EFFECTS OF THE HARVEST PHASE OF GEODUCK (PANOPEA GENEROSA GOULD, 1850) AQUACULTURE ON INFAUNAL COMMUNITIES IN SOUTHERN PUGET SOUND, WASHINGTON, Glen Van Blaricom et al, Journal of Shellfish Research, March 2015)
 
 
After quoting the above study untold times, without noting the qualifications, Taylor Shellfish has finally conceded that, in fact, geoduck farms are not all equal. In an April 13, 2015 letter to Pierce County, their attorney Billy Plauche with Plauche and Carr has said Taylor Shellfish will perform an Environmental Impact Statement (EIS) for its proposed 25 acre geoduck farm in Burley Lagoon. It is not the only one which should be required to have an EIS.
 
Get involved. The people concerned about Burley Lagoon did.
 
  
 

Monday, April 13, 2015

Ban on Imidacloprid Use Grows - Except at DOE: Apply it on more acres, apply it more often.

Where have all the flowers gone?
Shellfish growers don't care.
Maybe they will if you stop
buying oysters from
Willapa Bay.

Bans continue to grow, except in Willapa Bay
The number of agencies and retailers who are implementing a ban on the use of the pesticide imidacloprid continues to grow. Most recently, Lowe's has agreed to stop selling neonicotinoid pesticides, of which imidacloprid is one. April 1, the City of Portland issued an immediate ban on its use. The Oregon Legislature currently has two bills before it which would eliminate its use. The US Fish and Wildlife agency  has banned their use on wildlife refuges across the United States. The European Commission, in 2013, banned the use of imidacloprid. April 8 the NY Times reportedEuropean Academies Science Advisory Council report stated imidacloprid:
“has severe effects on a range of organisms that provide ecosystem services like pollination and natural pest control, as well as on biodiversity,”

DOE - Spray it on more acres with more intensity
The Department of Ecology's viewpoint? In their recently released Final Environmental Impact Statement (FEIS) they have simply agreed with the shellfish growers in Willapa Bay who want to use it on more acres and in increasing intensity.
there would likely be a larger number of imidacloprid application events each year over a longer authorized application period (p.2-58, FEIS)
Growers have requested larger annual treatment acreage under the imidacloprid permit (2,000 acres) compared to the carbaryl permit (800 acres). It is possible that over the five-year term of the permit, the total acreage to be treated within Willapa Bay could range from 1,500 to 7,500 acres, and in Grays Harbor could range from 500 to 2,500 acres. (p. 1-6, FEIS)

Get involved. The shellfish industry is and agencies are not willing to stand up to them. You can start by not buying oysters harvested from Willapa Bay. You can also sign the petition created by Willapa Bay's Westport Salmon Tales.





Friday, April 10, 2015

Imidicloprid Spraying in Willapa Bay: Department of Ecology Releases Final EIS

[Update 4/10: A petition on Change.org has been created by Westport Salmon Tales which asks DOE to deny any permit applications for the use if imidacloprid in Willapa Bay. Get involved and sign the petition.] 
"[imidacloprid] has severe effects
on a range of organisms
that provide ecosystem services"
 
Preferred alternative for Willapa Bay:
Spray 7,000 acres with imidacloprid.
Final EIS, April 9 (20mb file)
 
Just another native species
the shellfish industry wants eliminated
through chemical application
to Willapa Bay's shellfish beds.

 
The Department of Ecology has released its final Environmental Impact Statement with spraying the pesticided Imidicloprid on up to 7,000 acres over 5 years to control burrowing shrimp as the preferred alternative. The FEIS can be found here (20mb file):
 
This follows by one day the article in the New York Times which describes the growing concerns over the use of neonicotinoids, which imidacloprid is one of. In the article, they remind us that Europe has banned the use of this pesticide and discuss the European Academies Science Advisory Council's study, noting:
A growing body of evidence shows that the widespread use of the pesticides “has severe effects on a range of organisms that provide ecosystem services like pollination and natural pest control, as well as on biodiversity,” the report’s authors said.
Get involved. The shellfish industry is and no state agencies are willing to stand up to the industry.

Elected officials: http://app.leg.wa.gov/DistrictFinder/
Tell Costco to stop buying oysters from Willapa Bay (email button on lower left of their Customer Service site)
Don't buy oysters from Willapa Bay.



 
 
 

Wednesday, April 8, 2015

Aquatic Reserves are Not Reserved for Taylor Shellfish - Get Out, Then Get Involved

Tell Pierce County and Elected Officials
Aquatic Reserves Were Not Reserved
To Be Commercialized by the Shellfish Industry
 
Washington's Aquatic Reserves
Dabob Bay: Withdrawn. Guess why.
 
The door to your tidelands is to the left
Taylor Shellfish owns 11,000 acres of tidelands. Yet, when Pierce County proposed to limit new permits for aquaculture in the Nisqually Reach Aquatic Reserve to the restoration of native Olympia oysters, what did they do? They told Daniel Hull, Executive Director of the Nisqually Reach Nature Center, to tell Pierce County that he would not support the amendment. In a follow-up email he said Taylor Shellfish would withdraw from the aquatic reserves program if the amendment was included in their Shoreline Master Program update. The proposal to create a reserve in Dabob Bay was withdrawn due in large part to pressure from the shellfish industry. Get out, get involved, and tell your elected officials Puget Sound is not for the profits of the few.
 
Pierce County Contacts (click here, or...)
Tell them you support their amendment to limit aquaculture to the restoration of native Olympia oysters in the Nisqually Reach Aquatic Reserve.
dyoung2@co.pierce.wa.us (Derek Young)
mkruger@co.pierce.wa.us (Mike Krueger)
 
Find your Washington elected official
Tell them Aquatic Reserves were not reserved to be commercialized by the shellfish industry.
 
See what the shellfish industry wants for itself
The daylight minus tides of Puget Sound continue with April's beginning to expose the lower intertidal tidelands, unique to Puget Sound. Within this habitat area a diversity of species unique to this environment exist, able to withstand exposure to air and submersion in water. Get out and see what the Shoreline Management Act was intended to protect and in part why aquatic reserves were created. Then get involved in helping to ensure this critical marine habitat is not converted for the profits of the few.

 
Updated 4/8 to clarify sequence of events.

Thursday, April 2, 2015

Superior Court will Decide the Detienne/Chelsea Subtidal Geoduck Farm Permit Tomorrow

[Update 4/3: The Superior Court has ruled in favor of the Shorelines Hearings Board decision to deny the permit. Details will be provided when available.]

What: Superior Court will decide whether the Shorelines Hearings Board decision to deny the permit for the Detienne/Chelsea subtidal geoduck farm will stand or be reversed.
When: 1:30
Where: Thurston County Superior Court  
2000 Lakeridge Drive 
Building 2 
Olympia 98502  
Why it's important: The Shorelines Hearings Board reversed Pierce County's approval of this permit saying its uniqueness should have resulted in Pierce County having denied the permit. It is the first subtidal geoduck farm in Puget Sound, within one of the only remaining eelgrass beds in south Puget Sound. 
SHB Decision: "the Permit is therefore DENIED." You may read the SHB decision here.
 
Permit denied by the SHB,
reversing Pierce County's decision.
 
 
To recap (from Friends of Burley Lagoon):   Pierce County originally  granted a Permit, with conditions,  for the geoduck farm in Wauna.  Citizens there, with the Coalition, appealed the County's decision to the Shoreline Hearings Board.   After a six- day hearing, the SHB denied the permit.   Pierce County (via Deputy Prosector advisor Jill Guernsey) appealed the SHB decision initially on a procedural matter, DeTienne/Chelsea Farms cited other issues.   The issues were heard by a single Judge of Thurston County Superior Court.  The Judge denied Pierce County's procedural portion;  the other issues will be decided at tomorrow's hearing before the same Judge.
 
Politics Pays: Jill Guernsey, Deputy Prosecuting Attorney 
gets some money from Plauche and Carr - after she appeals.
 
Ms. Guernsey runs for Mayor of Gig Harbor - unopposed - and wins
Entwined within the story is another of shellfish politics. In February of 2013, Pierce County, through their attorney Jill Guernsey, decided to appeal the SHB reversal of their granting the permit (see Ms Guernsey/Pierce County Petition for Review here, which was denied). In March of 2013, a $500 donation to Ms. Gurensey's campaign  from the law firm representing Chelsea and Detienne, Plauche and Carr, was recorded as having been made (see Plauche Carr Petition for Review here). In April of 2013, Ms. Guernsey formally kicked off her Gig Harbor mayoral campaign. She
 
Does a job depend on political donations?
Dennis Hamberg, Director of Pierce County
Planning and Land Services helps out too.
 
 

Sunday, March 29, 2015

Reminder: Zangle Cove Geoduck Farm Comments Due April 1

Not all tidelands are equal.
 
See Public Notice of application here:
Send comments to: Tony Kantas at kantast@co.thurston.wa.us
(see Public Notice for additional contact information)
 
Intensive commercial development
should not be permitted in residential areas
on tidelands NOT purchased for aquaculture.
 
Zangle Cove, Thurston County
A residential community with tidelands
shared by everyone for generations.
 
If you order today I'll include shipping and handling.
Mr. and Mrs. Sohn have created a LLC ("Pacific Northwest Aquaculture", formed in December of 2013) through which they have submitted a permit application for a geoduck farm in Zangle Cove. Their consultant, ACERA, who bills themselves as a firm providing services for a "competitive quote"  with a "current special offer" of $200 off their already low price, details in the application what the Sohn's intend to do. Who will be doing it is not explained, something of importance as the Sohn's have no apparent experience in aquaculture, let alone geoduck operations.
 
Whose tidelands are they and where are they located?
 
Are those stakes out there a mistake?
In mid-2014 stakes appeared in the middle of Zangle Cove, the result of a survey. Residents immediately began questioning why the stakes were placed where they were and for what reason. Explanations from the surveyor fell flat and it quickly became apparent the survey being done was not based on accurate information. As seen in the notes on the "Tideland Survey Plan View" above, the plan submitted is based on a "we think it's ours" assumption. Surveys are not supposed to be "it's close enough for government work." Project plans submitted on questionable data should be rejected.
 
 
That BE looks familiar.
ACERA was recently noted for its involvement with an unpermitted geoduck farm near Poulsbo. There, Scott Kimmel with New Day Fisheries "didn't know" he was supposed to get permits He has since withdrawn his attempt to obtain an after-the-fact permit, using ACERA. In south Puget Sound, ACERA was used in the Wheeler geoduck permitting process. The amount of cut-and-paste from the Wheeler Biological Evaluation to the Sohn's Biological Evaluation  should make regulators look closely at what is being provided.
 
"There is currently no commercial aquaculture,
but Zangle Cove was a historic shellfish farming area for oysters."
ACERA, page 9
Application to purchase the Sohn tidelands
from the state says that's not why they were purchased.
(click to enlarge)
 
Not all tidelands are equal - "Not suitable for the cultivation of oysters."
Of particular focus for regulators is just why these tidelands in Zangle Cove were purchased in the first place and what they have been used for since. The shellfish industry would have all believe that the only reason tidelands were purchased in Puget Sound was for aquaculture. This is far from the truth. In fact, it can be safely said that the majority of tidelands were not purchased for aquaculture. Especially the type of aquaculture being proposed by the Sohn's and described by ACERA. There is no commercial "historic shellfish farming" which has occurred in this residential cove of the type being proposed. These tidelands in Zangle Cove were purchased for the benefit of upland owners to ensure access to water at low tide. It clearly states on the application to purchase the tidelands they "are NOT suitable for the cultivation of oysters" which clearly proves they were not purchased for aquaculture then, nor were they ever intended to be.
 
Get involved: The shellfish industry is and they will say anything to obtain access to tidelands for commercial shellfish production.

 


 
 

 

 

Thursday, March 26, 2015

APHETI Provides an Update on Taylor Shellfish's 58 Raft Mussel Farm Proposal

Background (update follows): For almost 20 years APHETI has been opposed to a proposal by Taylor Shellfish to expand their mussel growing operations in south Puget Sound's Totten Inlet. Able to get Taylor Shellfish to reduce their original proposal by almost half the number of rafts, down to 58, APHETI was also able to force the permit to include monitoring of Totten Inlet's waters and sediments, to be managed by the Department of Natural Resources (Thurston County did not feel it had the expertise to design and implement a monitoring plan). Totten Inlet's waters are categorized as "extraordinary" by the Department of Ecology, leaving little room for man made impacts to its dissolved oxygen levels, one of the most critical parameters to measure. The mussel shell falloff onto the sediments below the rafts, especially during "harvest" when lines of mussels are pulled up will also be measured, of special concern as there are recovering subtidal geoduck tracts nearby. Finally, the non-native invasive tunicate, didemnum vexillum, which uses the surface area of the mussels and "predator netting" to grow on, which then becomes dislodged during harvest events, spreading throughout the water column of south Puget Sound, is of concern. It is assumed DNR will create and oversee a robust monitoring plan, and not allow the revenues received from leasing this area to Taylor Shellfish to diminish the oversight required. Too much is at stake.

Update from APHETI:

Greetings, APHETI members-  

Our last communication to you was almost one year ago. Since then APHETI has continued to address the concerns of Taylor's proposed expansion of mussel raft aquaculture in Totten Inlet. The attached APHETI newsletter will detail APHETI's efforts and next steps. As always, Thank you for your support. Please feel welcome to contact us with any questions you may have. 

APHETI Board of Directors


Association for the Protection of Hammersley, Eld, & Totten Inlets
-APHETI-
PO Box 11523, Olympia WA 98508-1523
(360) 866-8245                                                         www.apheti.com
 
March 25, 2015
 
Re:  Update / Pending expansion of Taylor mussel raft aquaculture in Totten Inlet
 
Greetings APHETI Members and Supporters - 
 
Our last letter reported that Taylor had appealed the environmental monitoring requirements required by the State Shoreline Hearings Board (SHB) and that the Judge sent the monitoring issue back to the SHB for Thurston Co. and Taylor to argue in support of or in opposition to the monitoring conditions – or Taylor and Thurston Co./APHETI could choose to negotiate a mutually agreed upon outcome to the monitoring issue.
 
All parties agreed to negotiate, Thurston Co./APHETI arguing for strong environmental monitoring and Taylor arguing for something much weaker.  The following outcome has only now been agreed to by all parties: 
 
Taylor's Thurston Co. permit, when issued, will include all environmental monitoring elements as required by Thurston Co. Hearing Examiner Tomas R. Bjorjen; all Thurston Co. Resource Stewardship Department recommended conditions; all mitigation measures from the Final Environmental Impact Statement (FEIS); and a formal environmental monitoring plan approved by the Washington State Dept. of Natural Resources (DNR) including all conservation measures as required by the DNR Aquatic Lands Habitat Conservation Plan as mandated by the US Dept of Ecology.
 
Next Steps: 
With your generous support over the last 19 years, APHETI has produced hundreds of hours of scientific study and litigation in opposition to Taylor's proposed expansion of mussel raft aquaculture in Totten Inlet.  All possible scientific and legal challenges to Taylor's proposal have now been exercised with the Court’s final decision in place requiring Thurston Co. to issue Taylor a permit to proceed if all permit requirements are met. 
 
APHETI 's efforts will now be directed (1) toward assuring all public rules for granting a mussel raft permit to Taylor are complied with and (2) providing input to the elements of a strong environmental monitoring plan as a part of that permit.  To start, Thurston Co. will not issue a permit until Taylor has a lease from the Washington State Dept of Natural Resources (DNR). 
 
DNR lease discussions will not begin until Taylor has a permit from the US Army Corps of Engineers requiring independent study by the Corps, US Dept of Ecology, US Fish & Wildlife, and National Marine Fisheries Service.  A Corps permit will likely take considerable time, require public input and include its own monitoring requirements.  Presently, DNR has not received any indication that Taylor has yet applied for a Corps permit.
 
DNR has committed to keep APHETI informed of all aspects of DNR lease negotiations with Taylor including an invitation to review and provide input to the environmental monitoring plan for Taylor's operations.  Follow us at www.apheti.com for links to DNR  and Thurston Co. publications regarding the permitting process.
 
APHETI's financial resources are presently sufficient to support our near term custodial activities.  However, your sustaining contributions are always welcomed and put to good use.  If a major need may arise, we will let you know what it is and what may be needed to support that action.   Please send your e-mail address to apheti@gmail.com for future updates via e-mail or contact APHETI, PO Box 11523 Olympia WA 98508-1523, or telephone (360) 866-8245 for any questions.  
 
Best Regards! /            APHETI Board of Directors    

Tuesday, March 24, 2015

Drakes Bay Oyster Cleanup Progresses

Drakes Estero
 
The Press Democrat writes on March 23 about the ongoing cleanup of Drakes Bay Oyster Company's operation left behind for taxpayers to pay for. When completed the question of how significant a commercial shellfish operation is to a marine ecosystem, positive or negative, can be answered.
 
You clean it up. I'm going to go start a restaurant.
Thank you Mr. Lunny.
 
 


Monday, March 23, 2015

Paralytic Shellfish Poison Toxins in Geoduck Causing Canadian Geoduck Industry Concerns


Hong Kong Ban Impacts 70% of BC Geoduck Market

Turns out there's more to it.
A "buried treasure" turns out not be pure gold
Geoduck harvesters in British Columbia are beginning to worry about a ban which Hong Kong has placed on geoduck harvested from the Canadian province. When testing by Canada showed levels of PSP toxins higher than levels accepted by China, overseas labs confirmed some geoduck harvested from the same area in BC did have elevated levels of PSP toxins. In turn, Hong Kong banned the import of all geoduck from BC. The response by growers in BC was described in the article this way:
Particularly galling to BC harvesters is the fact that other exporters have stepped into the gap, including Washington state – whose waters border BC – and Mexico, which Austin said did not even test its clams for PSP toxin prior to export.
Offer: $500,000= 5% ownership + 50% of royalties
Agreement: $500,000=5% ownership+interest+100% of royalties


YouTube from Dragon's Den, 2012
Reality: Investing is a risky business.

And I just invested based on past projections
It is reported that harvest boats are no longer leaving the dock and shipments to date are 180,000 kg below last year at this time. James Austin, with the Underwater Harvesters Association, was reported to have described it this way:
Austin said the Hong Kong ban had had a huge impact; the BC harvest is down about 180,000kg compared to this time last year. Boats are lying idle and divers who gather the wild delicacy from the seabed are taking time off work.
Testing? Sure, we do that.
Of concern to the Chinese was the geoduck were allowed to be harvested and shipped to Hong Kong before testing found the elevated levels of PSP toxins. As Washington's oyster growers have found, reacting to illnesses is not in the best interest of the consumers. As Washington's geoduck harvesters found, China also had concerns about arsenic in geoduck from Washington, made extreme when they discovered Washington did not even test for it. This resulted in a five month ban of geoduck from Washington, beginning in December 2013. Testing has since shown only a few areas have geoduck with arsenic levels of concern, and those areas are now closed.
Now we will do even more testing.
In the case of vibriosis contracted from oysters harvested in Washington, it took people becoming ill from the naturally occurring bacterium Vibrio parahaemolyticus before harvesting would be banned. The lag time created from becoming ill, seeing the doctor and in some case becoming hospitalized, and records of illnesses being reported back to the Department of Health, stretched reaction out for weeks. In the interim, hundreds of dozens of oysters could have been harvested and shipped around the United States and to China, resulting in unnecessary illnesses.

Not all testing programs are the same. 
Washington's Department of Health does have a proactive system in place to test for PSP toxins. When elevated levels are found either in geoduck or in an indicator species, such as mussels, harvesting is halted. At the time of the BC shipment three geoduck tracts had been closed due to elevated levels of PSP toxins. DOH is currently in the process of implementing a proactive system to prevent vibriosis (caused by Vp in oysters), relying heavily on growers to monitor water temperature. Training has begun. 


 A new use for tulip bulb harvesters.
Will it remove PVC pipes too?
What will we do with the tulip bulb harvesting machines if the tulip bulb market collapses?
What matters in the case of Hong Kong's reaction is the significance of having one primary market for this product. Despite claims of a domestic market, the reality is the huge majority (reported to be 90%) are exported to Asia, most to China. If this market collapses, whether it be from the rising dollar making this clam too expensive, illnesses contracted because poaching allowed untested geoduck to be exported, or China simply waking up to the modern world and realizing geoduck will not bestow any male virility qualities to its consumers, Puget Sound's intertidal area will be left with PVC tubes and nets nobody can afford to remove. It is a market waiting to collapse.

Saturday, March 21, 2015

Washington's Mason County Oysters Cause Norovirus-like Illnesses for a Second Time in 3 Months


Oysters Harvested from Hood Canal
Cause Norovirus-like Illnesses
 
One more "wee beastie" to worry about.

A second outbreak from norovirus carried by Mason County oysters?
Oysters harvested from in Washington's Mason County have again caused what the Department of Health describes as "norovirus-like illnesses." DOH has not yet said whether the oysters have tested positive for norovirus, nor whether the source is the harvest site in Hood Canal or at another point along the distribution chain, only describing the illnesses as being "norovirus-like." For now, DOH has closed the area in Hood Canal to commercial and recreational harvest while they research the cause.

Commercial and Recreational Harvesting Closed
on Hood Canal, near Lilliwaup

Are they "vibriosis-like" or "norovirus-like" symptoms?
Like vibriosis, caused by the naturally occurring bacterium vibrio parahaemolyticus, symptoms from infection of the unnatural norovirus (aka Norwalk virus) are described in a similar way by DOH. Those are described on the website of the Department of Health as:
Norovirus: The most common symptoms are watery diarrhea, explosive projectile vomiting (that shoots out), and stomach pain.
Vibriosis: Symptoms include diarrhea, abdominal cramps, nausea, vomiting, headache, fever, and chills. The illness is usually mild or moderate and runs its course in 2 to 3 days. In severe cases, hospitalization may be required.  
Norovirus illnesses appeared to have been dropping
Until December's outbreak, norovirus had not been as big of a problem for Washington's shellfish growers. Based on a report from the Center for Science in the Public Interest on norovirus caused by oysters harvested from Washington between 1993 to 2009, since 2007 it has been rare (0 reported in 2007, 2008 and 2009). DOH did report December 2011 illnesses in their March 2012 newsletter but the number was not noted and, until December of 2014, there do not appear to have been any other reported norovirus illnesses traced to Washington.

Until December of 2014
In early December a similar outbreak of illnesses from Washington oysters was confirmed to be norovirus. It is currently believed a leaking septic system was the source, although that could not be confirmed. That harvest area, also in Mason County, was in Hammersley Inlet and like Hood Canal's, was closed.

Will a new plan be needed to address norovirus?
The norovirus-like illness from oysters harvested from Mason County's waters comes at an awkward time as the Department of Health is just now implementing a new training program of 10 classes to try and be proactive in preventing vibriosis, something neither the growers nor DOH had been able to do under the old system. Growers will now be required to monitor water temperatures and, if the water temperature reaches a certain level, will voluntarily cease harvesting. In the past, DOH waited until a certain number of illnesses were traced to a growing area, then retroactively closed the area. Whether relying on the shellfish industry to control vibriosis through the new system will be successful remains to be seen, as does how DOH address the possible growing problem with norovirus in oysters harvested from Washington.