When is enough too much?
Current mussel farm in Totten Inlet
An audio recording of Taylor Shellfish's appeal on November 14 of their mussel farm permit being denied before the Thurston County Commissioners is available. [click here] Included is APHETI's attorney, David Mann with Gendler Mann, testifying why cumulative impacts should be considered and why the Hearing Examiner's denial of the permit was correct. A decision by the commissioners will be made by November 27.
Presented at the hearing was why cumulative impacts should, or should not, be considered under both the Shoreline Management Act and Thurston County's Shoreline Master Program. As noted in earlier posts, the legal interpretation of the SMA and counties SMP's allows for discretion in determining whether cumulative impacts should be considered. In the case of Taylor's proposed mussel farm, there is no question that cumulative impacts should be closely analyzed.
Structures for oysters
In the case of aquaculture, it is not "aquaculture" itself which is in question. What is in question are the current methods and intensity. While some forms of "aquaculture" may be considered a "preferred use" of the shorelines, it does not mean any and all methods should be permitted to operate at any time of the day. It most certainly does not mean cumulative impacts should be ignored.
Sunday morning, 7AM
Taylor's geoduck farm in Hammersley Inlet
Taylor would have us believe the intensity of today's operations have not changed from when the SMA and Thurston County's SMP were created, in 1971 and 1990, respectively. And, if they have, "filtering" provided by shellfish more than makes up for any fragmentation of habitat which may have occurred, is occurring, and will occur.
Oyster bags in Totten Inlet
In fact, "aquaculture" has changed dramatically in that time and there is intense pressure for it to be allowed to expand, with little oversight. Cumulative impacts to the aquatic habitat have taken place and will take place.
One of many "barges" used
to transport geoduck
In the case of Taylor's mussel rafts, the shellfish "production" found under one 30' X 34' raft is equivalent to what used to be produced on one acre of tidelands (25,000 pounds). In the case of geoduck, over 120,000 pounds are produced on one acre, where they never used to grow in that density, through the use of PVC pipes, rebar and netting. Currently, grow-out bags and "cages" for both oyster and clam have increased the density of shellfish produced. Willapa Bay has had native ghost shrimp eradicated through chemical application and now a permit for the application of the herbicide imazamox to eradicate eelgrass is being considered. In short, there has been a dramatic change in production methods and intensity which has occurred. Put together, the cumulative impact is beyond significant.
PVC pipes for geoduck farm
You cannot argue that because "aquaculture" was once considered a "preferred use" and is "water dependent" that it means "anything goes." In fact, Thurston County's current Shoreline Master Program is clear in its intent to protect water quality and aquatic habitat, not just for "aquaculture" and not just from upland development. Its primary goal is clearly defined in Section V's Regional Criteria, Part B:
Protection of water quality and aquatic habitat is recognized as a primary goal. All applications for development of shorelines and use of public waters shall be closely analyzed for their effect on the aquatic environment. Of particular concern will be the preservation of the larger ecological system when a change is proposed to a lesser part of the system, like a marshland or tideland.
The Shoreline Management Act was passed and approved by voters to prevent the fragmentation of shoreline habitat from piecemeal development. Corporate shellfish companies and current methods have become that process which is fragmenting the shoreline habitat and what needs to have far greater regulatory oversight applied. Thurston County should be where that process begins and where an analysis of cumulative effects begins.
If you want to help ensure cumulative impacts from corporate shellfish methods are analyzed, contact APHETI (Association to Protect Hammersly, Eld and Totten Inlets).
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