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.

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Friday, August 17, 2012

DNR Retains SEPA Decision for Taylor Shellfish Harvesting of Geoduck on State Tidelands Trespassed On

In this SEPA decision we see what we want to see (or in the case of salmon during dive harvesting, not much).

What does dive harvesting look like?
or click on arrow below for the full 25 minutes
(also note the discarded geoduck tubes)
Selective science? In the case of DNR's Supplemental Environmental Impact Statement (SEIS) on deeper subtidal harvesting, as it applies to intertidal dive harvesting, we read what we want to read.[click here for complete SEIS]
Part of this study looked at a "liberal" 10,000 geoduck-per-acre tract being harvested versus the typical 60,000+ geoduck per acre in a commercial farm. Hardly the same.
Yet, the SEIS clearly states sediment plumes do not "settle out quickly" as DNR and NMFS authors state in the SEPA documents. In fact, dive harvesting of geoduck clearly shows a far greater impact to the water column and sediments than was considered by DNR and NMFS.
After 20 minutes at 1.0 m/sec current speed, the [sediment] clouds with up to 10 mg/l of TSS were 170 m [>500'] down current from the diver. (page 33, SEIS) (Note: A 10 mg/l increase in TSS increased turbidity 6 NTU units. WAC 173-201A-210(1)(e) does not allow an increase of over 5 NTU.) There is no indication any consideration was given to the unique location of this farm and currents.
The shoreward boundary [of -18 feet] protects shallow water geoducks, minimizes impacts on nearby shoreline residents, and helps protect eelgrass beds and other sensitive nearshore habitats. (page 10, SEIS) Nothing indicates consideration was given to the species within the sediments between where the geoduck were planted and the -18 foot depth. Further, if DNR is concerned about impacts to shoreline residents, why not restrict dive harvesting to daylight hours only? 
Most of this material -- the coarser sediments -- settles immediately to the bottom and forms a berm round the harvest hole, while the fine material (particle size less than 63 microns) settles much more slowly and remains in the water for longer periods. (page 31, SEIS) Statements that sediments "settle out quickly" are simply not scientifically based.
Look a little deeper.
The Department of Natural Resources has retained its SEPA mitigated determination of non-significance (MDNS) decision which will allow Taylor Shellfish to dive harvest up to 70% of the geoduck planted on state owned tidelands. One commenter noted DNR's Environmental Impact Statement (EIS) and Supplemental Environmental Impact Statement (SEIS) on subtidal dive harvesting limited harvest activity to no shallower than 18 feet below mean low lower water (MLLW). DNR responded the EIS and SEIS were not intended to be used for intertidal (shallow) dive harvesting, despite the papers clearly noting impacts to the water column and shallow area from dive harvesting. DNR went on to respond the 18' depth limit was primarily to address shoreline resident concerns about "noise and commotion from harvest activities" and to avoid "eelgrass and herring spawning areas". It responded further by referencing National Marine Fisheries Service (NMFS) and Fish and Wildlife Service (FWS) letters. Neither reference any studies looking at dive harvesting of an intertidal commercial farm which has over 60,000 geoduck per acre, because none exist. Instead they rely on inferences from observations of harvesting activities performed out of water at small farms, in some cases at midnight, and low density wild harvesting to reach the conclusion there is no impact. NMFS states sediment disturbance is no different than naturally occurring wave action, seeming to overlook the fact that 3' of sediments are liquefied and geoduck planted in densities of up to 3 per square foot are being extracted. Waves and currents both have an immediate and ongoing effect on sediments which are carried far further than those disturbed by "dry" harvesting. The stratified sediment composition which had formed over millennium from waves and current is turned upside down in harvesting.
Southern Resident Orca, August 2011
(At the mouth of Hammersley Inlet
which passed directly by Taylor's farm
in Pickering Passage.)
In response to concerns of Southern Resident Orca which frequent the area, NMFS states the vessels used are "slow moving" and pose no risk. In fact, the vessels used by the shellfish industry are some of the largest and fastest vessels on Puget Sound. The fact that geoduck need to be moved directly from harvesting to the airport for delivery in China the next day has to make one wonder what era of shellfish harvesting NMFS was thinking about. It's not grandfather Taylor's oyster farm anymore.    
This is slow moving?
Commissioner Goldmark and the Aquatic Division of DNR have tried to do their best in protecting the intertidal shoreline habitat for future generations. They have tried to rely on science to base decisions on. But pressures are building to convert what few remaining public tidelands there are into industrial shellfish farms for the benefit of a few corporate owners who will become very rich while Washington State's citizens loose access to the few public tidelands which remain. Taylor Shellfish should never have been allowed to plant where they did. Taylor Shellfish trespassed and as part of the settlement agreement they are allowed to harvest their geoduck, at great profit (~$2 million). What should not be allowed now is for this SEPA decision to be used as the basis for future decisions.
The area where Taylor Shellfish
planted geoduck without a lease agreement.

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