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 and with limited public input. It is exactly what the Shoreline Management Act was intended to prevent.

Get involved and contact your elected officials to let them you do not support aquaculture's industrial transformation of Puget Sound's tidelands.

Governor Inslee: https://fortress.wa.gov/es/governor/
Legislative and Congressional contacts:

Additional information
Twitter: http://www.twitter.com/protectourshore
Facebook: https://www.facebook.com/ProtectOurShoreline

Wednesday, April 27, 2016

Comment on Corps of Engineers Permitting Update

RGP or NWP - Both regulatory frames around the shellfish industry which they will try to break
On April 25 the Coastal Watershed Institute released an opinion on the Corps of Engineers' April 20 meeting at which the COE discussed their regulatory oversight of aquaculture (see below). Those regulations developed occur within either the framework of the Regional General Permit (RGP) or the Nationwide Permit process. RGP is more focused on regional issues and able to change more quickly (becoming more or less restrictive as impacts are discovered) whereas the NWP is more nationally focused, with regional conditions, but also set in place for 5 year periods. The former fits into Governor Inslee's misguided Shellfish Initiative.
[Note: The Nationwide Permit update process will be starting soon, as the current 2012 NWP's will be replaced in 2017.]

Taking an RPG to the time it takes 
A great number of concerns expressed by growers focused on the industry's dislike of how much time permitting of shellfish farms takes. Similar frustrations were expressed at an April 18 meeting of state agencies, where Governor Inslee pressed his Washington Shellfish Initiative and wanting to "streamline" the permitting process so expansion of the industry could occur on their schedule (for a summary of what was proposed to benefit the shellfish industry, see here). Some spoke of the "burden" it placed on small growers. Others spoke of multiple agencies (WDFW, NFMS) which had to be consulted and the time it added to the process. One speaker, a past employee of Seattle Shellfish, expressed concerns about time and a program he was involved with which would enable disabled veterans to become shellfish farmers.
[Note: The Pacific Coast Shellfish Growers Association had previously announced this program, but asked for members to provide sites already "permitted for shellfish farming." Whether any permitted sites were provided by PCSGA members is not known. Whether disabled veterans would prefer access to a natural shoreline over one populated with PVC pipes and netting is also unknown.]
Slippery regulations on eel grass
Also at the COE meeting there was concern expressed by an industry representative over comments about the regulation of activities in or near eelgrass. As noted in an earlier post, the shellfish industry successfully lobbied representatives in D.C. to get the Corps to drop protections of eelgrass in "fallow" shellfish beds. Reaction by tribal members, individuals and NGO's was sharp in opposing this action (see Coalition to Protect Puget Sound Habitat letter here). Concerns expressed at the meeting by the industry may be related to the developing science on the importance of eel grass in sequestering CO2, in addition to the well established science of the critical habitat it provides. Concerns which all should have is the slippery slope which the industry has put everyone on, where the economic benefit of a few override the long term benefits of the many by dropping protection of the critical habitat created by eel grass.

"iron fisted, misdirected support of the aquaculture industry"
As seen below, the Coastal Watershed Institute is clear about how it feels on the shellfish industry's growing regulatory influence. Speaking directly to Governor Inslee's "Shellfish Initiative", CWI notes the risk to the "wild and intact nearshore ecosystems" which "streamlined permitting" for industrial aquaculture brings with it. Also noted in their email is the success which political lobbying in Washington DC brought - the removal of eel grass protections. This is an industry well financed by geoduck grown and sold to China (netting over $1 million/acre to growers, with tideland owners simply being taken advantage of through lease terms benefiting no one but the growers). It is highly motivated. And, it does not like being regulated. Get involved.

Subject: CWI position on CoE Shellfish Aquaculture Permitting following
Informational Meeting April 20 (UNCLASSIFIED)

We attended the  20 April 2016 CoE informational meeting on  future federal
permitting of shellfish aquaculture in Washington state. The agenda is
attached, and the link to meeting presentation materials is below. We'll
have more to say when the draft biological opinions are published. Until
then, a few thoughts to consider as we wait...

One of the main decision points before the CoE is to decide the type of
permit they will develop for the future. They may pursue another national
permit, or alternatively, develop a regional aquaculture permit for
Washington state. The later would dovetail with seamlessly  Governor's state
'Shellfish Initiative', which  in our firm and clear opinion has been iron
fisted, misdirected support of the aquaculture industry, and that we feel is
in direct opposition to, and  displacement of, our wild and intact nearshore

The Washington state Department of Agriculture may well  be proposed as the
regional lead for the state in this regional construct. Remember that the
Department of Agriculture recently listed eelgrass, Zostera japonica, as a
nuisance species, opening the way to eelgrass irradiation by the shellfish
industry. WDFW should be a leader in this dialog-but WDFW (inexplicably)
has no permit authority over shellfish practices.

We just celebrated Earth Day. Many citizens spent the day participating in
beach clean ups around the state. They are the most recent witness to the
fact  that the majority of marine plastic debris of not only global, but
also our local shorelines, is from aquaculture. Bottom line:  exclusion
nets, tubes, spraying, and extensive monotypic cultures of non-native
species, and  mechanical disruption of shorelines for large scale and
industrial aquaculture are contra indicated with nearshore systems so
important for our northwest systems.

We were relieved to see military veterans were a profile at the meeting.
Our staff can speak from very personal experience-our wild, natural
nearshore ecosystems provide invaluable refuge/respite for healing veterans
and their families.  They must be protected.

Another point made at the meeting was that Washington state is one of the
largest shellfish industry producers in the nation-as reflected by the
number of permits along our shoreline.

The truth is that the  shellfish industry is extremely lucrative  in
Washington state (geoduck farms are reported to net over $1,000,000 an
acre), and politically extremely powerful. One recent and clear
illustration:  the startling letters from state and federal *elected*
politicians to the CoE Seattle branch chief that were specifically directed
to CoE protection of eelgrass. These letters , overnight, resulted in the
removal of  permit provisions that would have protected over 10,000 acres of
existing eelgrass in Puget Sound.

Based on what we observed at the 20 April  meeting- and in recent management
and political actions by state and federal agencies (and elected
officials)-,it's clear that our nearshore resources management actions are
being decided  as never before by industrial aquaculture, and the economic
heart that is at their core. The federal resource agencies and the CoE have
before them the opportunity and responsibility to preserve the intact
shorelines and ecosystems of our region. But to do so will require these
agencies to challenge the political forces that are becoming ever more
dominant in our ecosystem resource management. We strongly encourage them to
buck up,  chose  the right side of the ecosystem (as challenging as doing so
may be), and  be leaders for the resources (they are specifically charged
with protecting) and that we know they have the capacity to be.

Monday, April 18, 2016

Friday, May 13: Salmon Farming - Net Loss and Risks to Puget Sound

“The conditions of traditional salmon farms 
can only be compared to a floating pig farm”
The more you know
the better you do.

Frankenstein of Fish (movie not yet rated)
What better date than Friday the 13th of May to show a film on the risks to Puget Sound which net pen salmon farming brings. The film will be shown Friday the 13th of May at 7pm, at the Angus Dei Luther Church (10511 Peacock Hill Ave NW Gig Harbor). It is free to the public, and anyone who is concerned over the political pressures being put on agencies by large and well financed corporations to green light these operations, and what they bring with them, should attend. If you're not too afraid of getting out on Friday the 13th, you will find it to be time well spent. And, it's free.

Grade School Lessons from Lesions
discussing risks of net pen farming
in open waters)

A better world through antibiotics, pesticides and genetically engineered salmon - or is it?
Industrial production of any species, like an elementary school, is a breeding ground for bacteria. Once one child gets sick, almost everyone gets sick. The response? In the past, a prescription of antibiotics was given and all was well. But now, bacteria resistant to most antibiotics is posing a threat. In the marine environment, concentrated populations - whether salmon or shellfish - begin to present the same opportunity for bacteria to spread. One fish gets sick in the pen, they all get sick. The response? Antibiotics thrown into the water with the feed. The result? Bacteria becoming resistant to not only antibiotics applied, but also bacteria which the natural defense systems of wild and native species are unable to fight off, resulting in issues such as the lesion seen above. Pesticides are used to fight off sea lice, which become pervasive in the closed environment net pens create and then spread to the native species in waters these farms are located in.

No, that's not the kind of shot
the shellfish industry is now talking about.
Has your oyster been immunized?

It's just a phage we're going through and no, we don't know what the next problem will be, but $500,000 will help with the old one.
Salmon "farmers" are not the only ones interested in controlling the environment. Shellfish farmers are also an industrial group which uses the marine habitat having problems they feel should be dealt with through modern medicine. In the case of oysters, Food Safety News recently wrote about a number of vibrio bacteria threatening the economic health of the industry and the health of those who consume oysters. In 2008, Vibrio tubiashii was blamed for the deaths of oyster larvae in hatcheries. The cause of death then evolved into ocean acidification being the problem. After hundreds of thousands were spent on monitoring and filtering equipment for the industry, Vt is again being described as the problem larvae are having. The USDA has awarded $500,000 to commercialize of a "cocktail" of bacteriophages to deal with Vt., this following a $99,000 award in 2013.  Vibrio parahaemolyticus and Vibrio vulnificus, both present threats to human health if contracted and are both naturally occurring bacteria. The former is pervasive in Puget Sound during warmer summer months and the latter having been found present in recent years. Vv is prevalent in the warmer Gulf waters during the summer and causes death in ~50% of those who contract it and is expected to become a growing problem as the waters of Puget Sound continue to become warmer. Both Vp and Vv forms of bacteria are contracted primarily from consuming raw oysters.

No, that's not a hot dog
you want to eat.
"Fear can drive people away from a product"
No kidding.

Oysters dipped in a bacteriophage soup
As noted in Food Safety News, $500,000 is now available to see if "bacteriophages" are able to be commercialized to control Vt, and perhaps other forms of bacteria causing the shellfish industry economic hardships. How those will be administered is still unknown, but in Seafood Safety News, Bill Dewey, with Taylor Shellfish, suggested a "live seawater oyster-holding system with the phages in it" as one possibility. Whether there would be a risk of the concentrated phages being discharged into the waters of Puget Sound, and what risk to native species there may be, was not discussed.

Better fish through
genetic manipulation.
The Frankenstein of fish.

Big fish cause big problems which Puget Sound cannot afford.
Friday the 13th of May you are invited to see a film on net pen salmon farming and all it brings with it. Whether it be sea lice having to be dealt with through the application of pesticides or bacterial infections dealt with through the application of antibiotics or possibly bacteriophages, the waters and habitat of Puget Sound with its native species are far more important than the profits of a few.

Saturday, April 16, 2016

DOE Passes on Considering Current Research on PVC/Plastic Degradation In Marine Environment

*Note: April 18 the Washington Shellfish Initiative Advisory Group
 will meet 9:30am to 12:00pm
John L. O’Brien Building
Room B15/18, 504 15th Ave SE, Olympia,
See Draft Agenda for that meeting by clicking here
Streamlined permitting report will be discussed,
including Burley Lagoon's 25 acre geoduck farm.

Degradation of thought process
Political pressures have pushed the Department of Ecology (DOE) to develop Shoreline Master Program guidelines in the form of their SMP Handbook. In part, these guidelines are in place to help the shellfish industry expand operations in Washington's Puget Sound and Willapa Bay, part of Governor Inslee's "Washington Shellfish Initiative" through "streamlined permitting." In that process, DOE discussed whether research on the degradation of plastics and PVC in the marine environment, more current than 2010, should be considered. It was a thought well worth considering. As recently as July 19, 2015, a peer reviewed study on the degradation of PVC and plastics in the marine environment noted:
"...more studies of reaction pathways and potential degradation products of plastic polymers under conditions that more closely approximate the marine environment are needed. These experiments would also help to make quantitative extrapolations about degradation rates in the marine environment possible." (see Pathways for degradation of plastic polymers floating in the marine environment, published in Environmental Science: Processes & Impacts, 2015)

As seen in this email, DOE felt differently, most likely due to political pressures to complete and implement the SMP handbook.

(email is part of a FOI request found here which has links to
a 2010 report and 2014 PVC question/answer paper)

It's not habitat. It's pollution...
...and the shellfish industry's farms are a point source,
and they want to expand, which Governor Inslee
is happy to promote.

What you don't know won't matter until it matters. And then it may be too late.
In a paper titled Environmental Risk of Polymers and their Degradation Products, dated May of 2013, the author points out studies performed in laboratories do not replicate the real world. He writes:
"...there is limited information on the degradation of PBMs [polymer based materials, including PVC] under environmentally relevant conditions, where a number of degradation mechanisms occur at once; and the potential for PBMs to form other chemical compounds during the degradation process and the effects these formed compounds may have on organisms has received little attention."
Good for a few...
...not for Puget Sound.

At what point is enough too much?
In the video clip above, one farm less than 10 acres in size is seen. This is only a precursor to what the shellfish industry wants and what Puget Sound will get if Governor Inslee's "Washington Shellfish Intiative" is allowed to move forward as the industry wants. It is an industry motivated by money, hidden behind the pretext of being "advocates for clean water." Clean water means little if the marine habitat is transformed to PVC forests and nets.

Get involved
Attend the April 18 meeting noted above and point out there is more to Puget Sound's unique habitat than feeding the elite of China.

Sunday, April 10, 2016

April 20: Army Corps of Engineers to Present Status of Aquaculture Permitting in Seattle

COE presentation, April 20, Seattle WA - open to the public.

Notification to the COE by April 14 is required if you intend to be there in person. If you wish to listen via the internet an email/phone call is also required. A question and answer period will occur at the end of the presentation.
Contact: Patricia Graesser
email: patricia.c.graesser@usace.army.mil
phone: 206-764-3760

Get involved: Become aware of COE aquaculture oversight.
The Army Corps of Engineers has released an announcement about a presentation on the current and future oversight of shellfish aquaculture, nationally and more importantly, in the northwest. For almost ten years now the COE in Seattle has helped control the desired expansion of the shellfish industry in Puget Sound. Requirements in 2007 to supply accurate information were found to not have been met with all applications having been rejected and new ones required.  

Politics pays if you pay lobbyists to complain of oversight.
Political pressures in Washington DC to slacken oversight from the COE have been intense, with recent results being the removal of eelgrass protections when an area having lied "fallow" is considered for production. Current pressures for the COE to require a cumulative impacts analysis have not been met with success. Despite ongoing expansion resulting in small, discrete farms becoming far larger point sources of PVC and plastic pollution of Puget Sound, the shellfish industry continues to see nothing wrong and presses forward through politically driven programs such as the Washington Shellfish Initiative proposal to minimize oversight through "streamlining" the permitting process.
[Note: A separate meeting April 18 will be held by Washington State on their permitting process. The Washington Shellfish Initiative Advisory Group meeting will be held April 18, 2016, 9:30am to 12:00pm John L. O’Brien Building, Room B15/18, 504 15th Ave SE, Olympia, WA 98501. See Draft Agenda for that meeting by clicking here.]
<<Army Corps of Engineers' Press Release>>
The Seattle District, U.S. Army Corps of Engineers, is holding an informational meeting April 20 to update those involved with shellfish aquaculture about ongoing and upcoming permitting program activities in Washington State. Federal, Tribal, state and municipal officials along with growers and interested groups are invited to get an update from the District’s Regulatory Branch with an opportunity to ask questions following the presentation.
The information meeting will be held at 1 p.m. at the U.S. Army Corps of Engineers, Seattle District Office, at the Federal Center South, 4735 E. Marginal Way South, Seattle, Washington (a map is attached).
The preliminary agenda is as follows:
•       1:00 p.m.               Welcome By Col. John Buck, District Commander, Seattle District, U.S. Army Corps of Engineers
•       1:05 p.m.               Brief overview of the Corps aquaculture regulatory program
•       1:15 p.m.                Update on ongoing activities:
•       Status of the programmatic Endangered Species Act consultation for shellfish activities in Washington
•       Regional General Permit for shellfish activities or 2017 Nationwide Permit 48 for commercial shellfish activities
Upcoming milestones and opportunities for involvement
•       1:45 p.m.               Questions & Answers
•       2:45 p.m.               Closing Remarks
The building is a secure facility.  If you plan to attend, you must RSVP to enable us to provide names to security officers before the event. Please arrive 15 minutes early to allow time to pass through security.  In addition you will need to have valid photo ID and go through a metal detector to enter the building.
If you plan to attend in person, please call Patricia Graesser, Public Affairs Chief, by April 14 at (206) 764-3760 or e-mail her at: patricia.c.graesser@usace.army.mil   If you can’t attend in person and wish to join on to a web meeting and audio conference call, please contact Ms. Graesser for the sign on information.
We look forward to seeing you there.
Michelle Walker
Seattle District, U.S. Army Corps of Engineers
Regulatory Branch Chief

Thursday, March 31, 2016

Taylor Shellfish Proposes to More than Double Stratford/Meyer Geoduck Farm, Known Since 2013

Shorelines Hearings Board Needs to Ask the Right Questions
Who's Testimony is Really Reliable?

(One of 3 leases executed in April of 2013)

Background - Not Disclosed
In April of 2013, Taylor Shellfish executed 3 separate leases with private tideland owners in Pierce County which would more than double in size their Stratford-Meyer geoduck farm. The farm is located to the south of the recently approved "Haley/Seattle Shellfish/Taylor Shellfish" geoduck farm and north of Herron Island along the shoreline of Case Inlet. (The original farm has operated since the mid-2000's.)

Background - An appeal of Haley/Seattle Shellfish/Taylor Shellfish decisions and belief a cumulative impacts analysis should be required.
One year later, in May of 2014, the Coalition to Protect Puget Sound Habitat appealed a permit approved by Pierce County and an associated mitigated determination of non-significance (MDNS) decision. In the initial hearing before the Hearing Examiner, affidavits were submitted to Pierce County by representatives of Taylor Shellfish and Seattle Shellfish stating no additional farms "abutting the Haley Farm" were proposed. Pierce County's staff noted "no applications for nearby farms were pending before the County." No mention of plans for the Stratford-Meyer farm to more than double in size was made, a plan known in April of 2013 if not sooner. In October of 2014 the Hearing Examiner denied the appeal of the MDNS and approved the permit. The appeal to the Shorelines Hearings Board was denied and the permit, with conditions, was approved in May of 2015.

Why an analysis was not required.
The SHB noted "Pierce County has no pending aquaculture applications between the county line to the north and Herron island to the south." Taylor Shellfish's Diane Cooper submitted an email from the Corps stating it only had "...2 pending applications in all of Pierce County for geoduck farms." (They were not for the 3 leases signed in 2013). Disclosure of the 3 executed leases for tidelands north of Herron Island, south of the "Haley" farm, was not made.

Was Pierce County's testimony really that reliable?
In its decision, the SHB found Pierce County's "testimony" to be the "most reliable" which lead it to believe there was no need for a Cumulative Impacts Analysis and the Coalition had "...failed to prove that there will be adverse impacts from the Haley farm, along with other existing aquaculture and reasonably foreseeable aquaculture in the vicinity of the Haley Farm." (p. 32 SHB decision) 

Current permit application (at least what's known) March 23, Pierce County announced Taylor Shellfish intended to more than double in size its Haley/Stratford geoduck farm, using leases it had executed in 2013. It will accept comments through April 19, by 5PM (See permit application announcement here)

True, but not the complete story. What else is there?

 "Additionally, the Applicant provided affidavits by Cooper and Gibbons, speaking on behalf of Taylor and Seattle Shellfish, respectively, indicating “No plans to operate any additional shellfish aquaculture farms abutting the Haley Farm.” Further, the MDNS and staff report considered aquaculture activities adjacent to or abutting the proposed site, noting that no aquaculture activity occurs within 4,300 feet of the Haley site and no applications for nearby farms were pending before the County."
Size is a relative term - and like geoducks, it just keeps getting larger and larger, overwhelming south Puget Sound.
In the October 2014 decision, the Hearing Examiner noted the Haley/Seattle Shellfish/Taylor Shellfish geoduck farm was "in proportion" to the area proposed. Currently, Taylor Shellfish is also proposing an additional 25 acre geoduck operation in nearby Burley Lagoon, also in Pierce County. More importantly, the University of Washington recently released a study stating a mere increase of ~3 acres to ~7 acres of geoduck farming in the Central Basin of Puget Sound would cause significant adverse impacts. The UW wrote, "Gear...Impacts Ecosystem If Farming Increases." If only 7 acres in the Central Basin causes impacts, what will the current proposals in south Puget Sound do?
"The scale of aquaculture operations shall be in proportion with the surface area and configuration of the affected water body. The proposed site is not within a constricted waterway, but along the shore of Case Inlet. Case Inlet is long and wide and the proposed farm, even at 11 acres, is within an appropriate scale for such a water body, even considering other aquacultural activity in Case Inlet." (p. 28, Hearings Examiner Decision, October 2014)
Get involved. Pierce County is accepting comments now.

Wednesday, March 30, 2016

Reminder: DOE's Hearing on Pierce County's Shoreline Master Program Update Tonight, March 30

Get involved.

Open house and public hearing :

Attend Ecology’s open house and public hearing to learn more about Pierce County’s shoreline program and provide written comments. You may also provide verbal testimony during the public hearing.
Date: Wednesday, March 30, 2016
Time Open House starts at 5:00 p.m.
Public Hearing starts at 6:30 p.m.
Location Pacific Lutheran University
Chris Knutzen Hall
12180 Park Avenue South
Tacoma, Washington 98447

Monday, March 28, 2016

March 30, 5PM: Pierce County Shoreline Master Program Meeting

The Department of Ecology will hold a public hearing on Pierce County's Shoreline Master Program update. DOE has told Friends of Burley Lagoon testimony and comments will be accepted, and questions may be asked during the public hearing, but those questions will not be answered. Comments will be accepted through April 29 at 5PM. (See DOE's Pierce County SMP update page by clicking here.)

Open house and public hearing

Attend Ecology’s open house and public hearing to learn more about Pierce County’s shoreline program and provide written comments. You may also provide verbal testimony during the public hearing.
Date: Wednesday, March 30, 2016
Time Open House starts at 5:00 p.m.
Public Hearing starts at 6:30 p.m.
Location Pacific Lutheran University
Chris Knutzen Hall
12180 Park Avenue South
Tacoma, Washington 98447
Pacific Lutheran University is located seven miles south of downtown Tacoma Washington, at the intersection of Garfield Street S. and Park Avenue S.
From Interstate 5
• Take exit 127 off Interstate 5 and head east on Highway 512
• Continue on 512 for approximately two miles to Pacific Avenue S. (Parkland-Spanaway exit)
• Turn right (south) on Pacific Avenue S.
• Turn right on 121st

Sunday, March 13, 2016

Mason County and Pierce County Shoreline Master Program Comment Periods

Two county Shoreline Master Program updates, in different stages, have agencies involved asking for public comments. Mason County is asking for comments on the SEPA determination, and the Department of Ecology is asking for comments in Pierce County's update they are reviewing.

Mason County: Comments accepted through March 31
email: rebeccah@co.mason.wa.us or
Mason County Community Services Department ATTN: Rebecca Hersha
615 W Alder St.
Shelton, WA 98584

The Planning Commission has completed their draft which will be submitted to the Commissioners in the near future. The county is asking for comments through March 31 has issued a SEPA Determination on "Non-Significance" (DNS) for the update which includes the SEPA environmental checklist. Supporting documents, including the final draft (with changes noted) and cumulative impacts analysis, are found on the county's SMP update page. After comments have been received and changes made the SMP update will move to the Commissioners for further comments and possible changes, then to the Department of Ecology for their review. Examples of comments may be found in the "comment matrix", with those focused on aquaculture beginning on page 55.

Pierce County: Department of Ecology Review
Comments accepted March 15, 2016 to April 29, 2016
email: Kim.VanZwalenburg@ecy.wa.gov (reference Pierce County SMP update)
Washington Department of Ecology
Shorelands and Environmental Assistance Program
Southwest Regional Office
PO Box 47775
Olympia, Washington 98504-7775
Attn: Kim Van Zwalenburg
Public meeting at 5:00 p.m. on March 30, 2016 at Pacific Lutheran University
Chris Knutzen Hall
12180 Park Avenue South
Tacoma, Washington 98447
Pierce County's SMP update has moved past the commissioners and is now in the Department of Ecology's hands. DOE's responsibility is to ensure the update submitted meets with the intended goals of the Shoreline Management Act, administered by DOE. All related documents are available on DOE's Pierce County SMP update site. Included is the proposed update which includes the proposed regulations and appendices, including requirement for aquaculture permitting (Appendix C on page 92) and how tideland boundaries are determined (Appendix I, page 108).

Wednesday, February 24, 2016

Cocaine, Prozac and other Drugs Found in Juvenile Salmon from Puget Sound, Plastic from Geoduck Farms found at Tolmie State Park

"Highest levels reported in the country."
(from Seattle Times)

I need a pill to deal with the depression this brings on.
Adding further strength to the question of how healthy Puget Sound's waters and species harvested from them truly are, the Seattle Times writes on a paper published in Science Direct by James Meador and others with NOAA. The paper discusses the variety of chemicals found both near sewage treatment outfalls and, to their surprise, near south Puget Sound's Nisqually Delta, an area supposed to have been used as a control site, "...our clean reference area." The Seattle Times reported they included Prozac and Cocaine. The Science Direct abstract describes them as "...pharmaceuticals, personal care products (PPCPs), and several industrial compounds."

Source of chemicals unknown.

Better living through chemistry in the northwest.
Equally if not more surprising than chemicals being found in the Nisqually Delta area was that the levels found "... in many cases were higher than in many of the 50 largest wastewater-treatment plants around the nation." Whether the rains of winter bring on the use of more pharmaceutical drugs by residents in the northwest was not explored. Also not studied were levels found in algae, which drifts with the current and which the juvenile salmon and other species consume or filter, nor levels in predators which consume the salmon.

At least something is known of
where pollution in Puget Sound comes from.

Better profits from geoduck grown with plastic cups. And, you just leave them to drift away. Unless somebody complains.
Meanwhile, a short distance from Nisqually Delta, one source of pollution was determined. In a letter written to The Olympian, the writer complained about plastics from a nearby geoduck farm washing up on the shores of Tolmie State Park. In the letter, the author writes that a "...biologist was dissecting several common murre which had washed up on the beach last fall, emaciated and unhealthy. He showed us small pieces of plastic that had been digested and filled their stomachs, inhibiting absorption of nutrients and blocking their ability to survive due to starvation." While the plastic found on Tolmie State Park was not tied to that Murre, its being found so far away at Tolmie State makes the point of geoduck farms clearly continuing to be a "point source" of pollution in Puget Sound all the stronger. 

Just because you can't see it 
doesn't mean it's not there.
Decades later - 
it still takes a letter to the editor
to motivate a geoduck operator.

Was that a bribe or just an offer of employment?
After the letter in The Olympian was published, it was reported a geoduck operator phoned the author and offered to pay for the plastics found. [It should be noted there were no identifying marks on the plastic reportedly found, so who to call was left a mystery.] What the offer was for the pollution found was not reported, nor was it reported whether additional funds would flow for further cleaning of the beach by the author, nor whether silence in the future was requested for the offer. It was reported that after a long period of accumulation, and publication of a letter to the editor, the operator was finally motivated to clean up the pollution. What remains, unseen, still drifting in the waters and along the shorelines, is left unknown.

Read more here: http://www.theolympian.com/opinion/letters-to-the-editor/article59292003.html#storylink=cpy

Tuesday, February 16, 2016

WDFW Investigation Reveals Contaminants Filtered and Retained by Shellfish in Puget Sound

What is filtered and retained by
Puget Sound's filter feeders?
"long-banned pesticides, flame retardants, toxic metals
 and other human-caused contaminants
are creeping into all parts of Puget Sound."
"one oyster, one mussel, one bite of fish at a time"
Washington's Department of Fish and Wildlife's (WDFW) continues to expand awareness of pollutants in Puget Sound's waters in an expanded program with results first published in the 2011/2012 Mussel Watch Phase 1". As it was noted in the 2012 Quality Assurance Plan:
"... expanded spatial distribution and additional mussel monitoring sites are needed to address regional questions regarding the fate, transport, and effects of chemical contaminants in the Puget Sound’s nearshore urbanized waters." 
(sample locations from 
2/19/2013 progress report)

Did I want to know that?
Building on the 2010/2011 Mussel Watch program, the implementation of the expanded program was designed to create a "...more regionally-focused, nearshore contaminant status and trends monitoring program in Puget Sound." While current results will not be known until 2017, program implementation results from 2012 were reported by WDFW in 2013. In that "Field Summary and Progress Report", four highly carcinogenic compounds (PAHs, PCBs, PBDEs, and DDTs) were found in mussels tested. As would be expected, the highest levels were found in the most urbanized areas (Elliott Bay, Salmon Bay, Commencement Bay, and Sinclair Inlet near Bremerton). However, as the Puget Soundkeeper noted in November:
"All four carcinogens were found in every mussel sample, regardless of location."

 ""I don't eat shellfish anymore," [Maradel Gale said.
"Not since I've been doing this."

There's more carried by the tides throughout the Puget Sound basin than algae and bacteria.
While current agency programs attempt to limit illnesses contracted from naturally occurring bacteria (e.g., various strains of vibrio) and naturally occurring toxic algae (e.g., diatoms producing domoic acid), there has not been a long term program tracking industrial pollutants in the nearshore environment where shellfish are harvested from and eaten. Chemicals entering Puget Sound's waters, through urban runoff and industrial activities, both current or past, exist throughout the basin being filtered and retained by shellfish. And as was noted in the Kitsap Sun article:
[Agencies] don't routinely test for metals, petroleum hydrocarbons and other substances that cause problems slowly, accumulating in the body in low dosages. 

Meanwhile, down on the farm the Department Of Ecology, EPA moves to impose water quality rules DOE cannot
Tribal rights include “..not only a right to take those fish, but necessarily include an attendant right to not be exposed to unacceptable health risks by consuming those fish.” (from EPA's 9/14/2015 proposed rule, part III. Necessity Determination for Washington)
At the same time as WDFW is reporting carcinogens in mussels tested throughout Puget Sound, the Department of Ecology is in a tug-of-war with the Environmental Protection Agency over what the average amount of seafood consumed is and what should be tested. After years of being unable to determine what the average amount of seafood consumed per day should be and what should be tested, the EPA told the Department of Ecology it had waited long enough and was now developing rules which DOE was unable or unwilling to, publishing in the Federal Register, September 4, 2015, the proposed rules. As far back as 2013 the EPA was telling DOE it was concerned about its lack of progress, writing in a letter dated June 21, 2013:
"The best available science includes evidence of consumption rates well above 6.5 grams per day among high fish consumers and shows that the human health criteria currently currently in effect for Clean Water Act purposes in Washington are not sufficiently protective."
Father knows best. He just can't make up his mind.
In a letter from tribal members to the EPA regarding DOE's lack of motivation, they wrote as recently as December 23, 2015, to encourage the EPA to do what DOE was unable or unwilling to, saying:
"The state of Washington has avoided, deferred, and delayed adoption of revised water quality standards that would safeguard public health for high fish consuming groups including tribes. The state has attempted to trade off a more protective fish consumption rate [175 g/day] for a less protective standard [6.5 g/day]  for cancer risk. EPA has given the state multiple opportunities to develop and adopt revised human health criteria. We have no confidence that the state of Washington will adopt more protective water quality standards in the next 12 months, if at all, and urge you to promulgate the EPA’s proposed rule without further delay."
Trust us - we know better than the EPA what's good for the state. Did Flint, Michigan?
"Ecology is in the best position to develop human health criteria (HHC) for the state of Washington." DOE to EPA, December 2015
It was not until February 3 DOE agreed fish consumption rate assumptions were too low and called for comments on new water quality standards. However, they noted they did not agree with EPA on standards for industrial pollutants or time frames to control discharges, stating on their website calling for comments:
"EPA's draft rule [being imposed on the state due to inaction] contains stringent limits for PCBs and arsenic, and adds a new limit for methyl mercury that will be difficult for Washington dischargers to meet. Our new draft rule would maintain the current standards, as proposed in our initial rule, for PCBs. Criteria for mercury would remain under federal regulation. Arsenic would align with the federal Safe Drinking Water Act standard." [fish consumption rates were raised to 175 g/day]
Do you really want to know?

In the end shellfish are only as safe to eat as the regulations you make controlling what flows into the water and they filter out of it.
Puget Sound's waters are a state-wide treasure. Seafood taken from Puget Sound, whether shellfish or fish, should be safe to eat in both the short and long term, and consumption rates safety is based off of should be realistic. The EPA has told Washington their regulations are weak. Results from the Mussel Watch program confirm mussels - and all other filter feeders - retain what is being discharged into those waters. Those chemicals are not being adequately monitored in seafood consumed and DOE has agreed their assumed consumption levels are far below what it should be, but does not want to implement new regulations any time soon. Until the state finds the political will to act, Ms. Gale's advice on not eating shellfish harvested from Puget Sound is something for everyone to consider.