[click here for complete information]
Ecology prefers to have comments submitted by email to: EelgrassComments@ecy.wa.gov; or,
You may submit comments to:
Washington State Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
Is this non-native Manila clam more important
than the habitat functions of Japanese eelgrass?
than the habitat functions of Japanese eelgrass?
Introduced into Washington's waters by the shellfish industry in the early 1900's, Japanese eelgrass has become an established species supporting a diversity of life. Migratory waterfowl use it as a source of energy as they pass by. Forage fish use it for protection and Herring for spawning. Sediments are stabilized through its root system. CO2 and nitrogen are removed from the waters and sediments, helping to lessen ocean acidification.
[click here for a 12mb file on eelgrass meadows by USFWS]
For years these critical habitat functions were recognized by the Washington Department Fish and Wildlife. It was listed on their Priority Habitat Species list. WDFW Hydraulic Code Rules still do not distinguish different species of eelgrass, noting: "WAC 220-110-250(3) "The following vegetation is found in many saltwater areas and serves essential functions in the developmental life history of fish or shellfish:
(a) Eelgrass (Zostera spp [spp is used to denote multiple species, not single species]); " [click here for WAC 220-110-250, Saltwater habitats of special concern]
The Department of Ecology's Shoreline Master Program Updates guidance manual notes: "The SMP Guidelines currently do not distinguish between protection requirements for native (Zostera marina) and non-native (Zostera japonica) eelgrass. Eelgrass is considered a critical saltwater habitat in the SMP Guidelines per WAC 173-26-221(2)(c)(iii) and requires "a higher level of protection due to the important ecological functions they provide." WAC 173-26-241(3)(b)(i)(C) states that aquaculture should not be permitted where it would adversely impact eelgrass." (page 10) [click here for manual]
Shellfish Politics: Minimize Public Involvement
Despite the critical habitat functions being recognized and codified in Washington law, Bill Dewey with Taylor Shellfish was able to convince the Director of Washington Department of Fish and Wildlife that because Japanese eelgrass was "non-native" it should be removed from their Priority Habitat List. So doing opened the door for the Noxious Weed Board to list it as a "Class C" Noxious Weed.
The importance of this to the shellfish industry is found in the Noxious Weed Board minutes from November 2, 2011: "...the growers explained that there will be a lot of scrutiny when they use chemical or mechanical measures to control Japanese eelgrass...they can point to the listing to support the concern that a noxious weed is having ecological/economic impacts." [click here for minutes] (Note: Pacific County recently requested the Noxious Weed Board to expand application to all tidelands, in part to help "shellfish gardens", a term promoted by the shellfish industry for non-commercial shellfish planting.)
In executing the strategy above, the shellfish industry was able to minimize public hearings before the legislature, something required to change the various WAC's which do not distinguish between Japonica and Marina, considering all eelgrass to be important. Below is an internal WDFW email detailing the strategy, noting "much discussion with industry leader Bill Dewey." His concern? "Industry opinion" wanted to avoid a "...public rule making process that would target industry as promoting reduced protection of eelgrass in the state."
The Current Proposal: Imazamox for Everyone (almost)
After the shellfish industry was able to convince WDFW to remove Japonica from its Priority Habitat Species list and the Noxious Weed Board to list it as a Class C weed on commercial shellfish farms, their focus turned onto the Department of Ecology. The shellfish industry provided DOE with stories of "small manila clams." They provided a "white paper," commissioned by the Pacific Shellfish Growers Association, describing an "invasion." With "support" provided by the Noxious Weed Board's action, the shellfish industry was able to convince DOE to issue a permit proposal which would have allowed for the application of the herbicide imazamox onto Japanese eelgrass wherever there was a "commercial shellfish farm", a term as yet undefined,
Agencies and the public all expressed concerns, some questioning whether growing a non-native manila clam was so important it should allow for a non-discriminate* herbicide to be applied. (* Imazamox will kill any aquatic vegetation it comes in contact with.) As a direct result of these comments DOE scaled back its permit to allow for application only on commercial shellfish farms in Willapa Bay and that an Environmental Impact Statement be created.
November 2, comments are due on whether this is something to consider, and if so, what the limitations should be.
Non-native Species and Self Induced Problems
One of the significant questions for agencies to consider is the role the shellfish industry has played in transforming Willapa Bay into what we see today. Their direct actions created self induced problems: over harvesting lead to non-native oysters being introduced and with them Spartina and Japanese eelgrass. With over harvesting, the structured reefs of native Olympia oysters were eliminated. The shells which oysters used to set on disappeared, followed by the expansion of the Ghost shrimp population, causing softer sediments. The shellfish industry initiated spraying of chemicals throughout Willapa Bay to get rid of Spartina and Ghost shrimp. Elimination of Ghost shrimp caused sediments to firm, which also created a habitat for Japanese eelgrass to expand into. Now they wish to spray Japanese eelgrass because they claim the non-native manila clams are not growing as large as they used to. All of this, where for the first time in 8 years a natural set of oysters has occurred. What will the addition of imazamox and hundreds of acres of Japanese eelgrass it has killed do to the water chemistry?
At some point agencies will be asked how much they are going to allow the shellfish industry to transform Washington's marine habitat for their economic benefit. If non-native Japanese eelgrass is going to be eliminated, why not non-native Pacific oysters and Manila clams? Both of those non-native species have taken over the habitat of native Olympia oysters and Little neck clams. Is it unreasonable to consider a permit for the erradication of those non-native species?
Get involved. The shellfish industry is. Comments are due November 2 by 5PM.