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:

Tuesday, May 28, 2013

First Subtidal Geoduck Farm Approved by Pierce County Hearing Examiner

Why doesn't DNR require replanting geoduck
after wild populations are "clear cut" from
state owned subtidal tidelands?
[click here for wild harvest numbers]

A permit for the first shallow subtidal geoduck farm has been approved by the Pierce County hearing examiner. It opens an area of Puget Sound to commercial geoduck "farming" which the Department of Natural Resources (DNR) had excluded from activity for decades to help protect a nearshore area where beds of native eelgrass are found (the nearshore area between extreme low and -18 feet). It also puts in question why DNR is not requiring the areas they do allow harvesting in (-18 to -70 feet) to be replanted. Annually, over 4 million pounds of wild geoduck are harvested from these subtidal areas. Why aren't they replanted like the state's forest lands are after they are harvested?

Regarding this specific permit approval, an environmental impact statement (EIS) which the state has been operating under for over 10 years has been nullified. Protections for this nearshore area have been minimized if not eliminated. As noted in DNR's Habitat Conservation Plan:
"Eelgrass is light limited and in Puget Sound rarely occurs deeper than –18 feet MLLW." The importance in protecting eelgrass is "...because of the role of eelgrass as the basic energy source for a variety of food web interactions, and because of the other functions it provides, the covered species use, or benefit in some manner from eelgrass." It notes further, "The shoreward boundary [of -18 feet] acts to protect geoducks closer to shore, eelgrass beds, and other nearshore habitats and their inhabitants (e.g., juvenile fish)."  
The Habitat Conservation plan also notes: "Nearshore buffers – DNR will protect nearshore habitats from geoduck harvest activities by locating the closest shoreward harvest boundary at or deeper than the –18 foot MLLW water depth contour. This protects nearshore habitats where younger juvenile salmonids and forage species are generally found and where forage fish species spawn. It also prevents disturbance of migrating adult salmonids.
"Eelgrass buffers – DNR will avoid and protect eelgrass by establishing a 2-foot vertical or 180-foot horizontal (on very gradual slopes) buffer between geoduck tracts adjacent to eelgrass beds and the deepest occurrence of eelgrass.
"This will protect habitat used by the covered fish species for refuge, and will protect habitat used for spawning and refuge by forage fish species important as prey to the covered species."

At the hearing the attorney representing the applicant simply stated this concern was "overly broad" and "a relic of a DNR EIS", the only environmental impact statement ever done regarding geoduck farming's impacts. In the Final Environmental Impact Statement (FEIS) it notes:
"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."

In that FEIS, Dr. Charles Simenstad with the University of Washington School of Aquatic Fisheries and Sciences, when asked about the impact on salmon from harvesting stated "The exclusionary principle of not allowing leasing/harvesting in water shallower than -18 ft. MLLW or 200 ft (sic yds) distance from shore (MHW); 2 ft. vertically from elevation of lower eelgrass margin, and within any regions of documented herring or forage fish spawning should under most conditions remove the influences of harvest-induced sediment plumes from migrating salmon. As the available information indicates that sediment plumes do not enter the nearshore zone, impacts to juvenile salmon habitat and prey resource should also be protected from impact by these policies if effectively regulated."
When John Lentz (owner of Chelsea Sea Farms) was questioned by the applicant's attorney whether he was aware of this restriction in the EIS, his off-the-cuff response was "they did it in the office." It seems the importance of an EIS is based on whether it supports your viewpoint or not.

Permit approval for this farm expands the area of impacts from geoduck farming exponentially. Tube placement will no longer be limited to the intertidal area, that area uncovered when the tide falls. Harvesting will no longer be prevented in depths between extreme low and -18 feet. Now these tubes and harvesting activity have been allowed to expand into an area previous protected by DNR, based on the only environmental impact statement focused on geoduck farming.

Most ironic in this approval is the question of why DNR is not requiring the state owned subtidal areas which are commercially harvested of "wild" geoduck to be replanted after they are "clear cut." Annually over 4 million pounds of wild geoduck are harvested, leaving the state's subtidal tidelands harvested empty. John Lentz, a past harvester of state tidelands, stated clearly that subtidal planting is not a problem. If subtidal planting is not a problem, why isn't DNR doing it?

What to do:
If you want to become involved in helping to ensure the rapid expansion of shellfish farming will not occur without a complete review of impacts to Puget Sound's diversity of life through an Environmental Impact Statement there are organizations who will accept your help and donations. These include:

Case Inlet Shoreline Association, a non-profit 501(c)3 organization
Focused on commercial geoduck operations in south Puget Sound
http://www.caseinlet.org/ - contact info@caseinlet.org

APHETI, a non-profit 501(c)3 organization
Focused on expansion of mussel farming in south Puget Sound
http://www.apheti.com/index.htm - contact apheti@gmail.com

Coalition to Protect Puget Sound Habitat
Representing most organizations concerned about expanding aquaculture

Tell the state you want DNR to replant state tidelands which are "clear cut".
You may also contact your government officials and tell them it is time for an Environmental Impact Statement to be done to ensure Puget Sound's diversity of life is not put at risk through expansion of commercial shellfish operations.
Contact your state legislative representative
Contact Governor Inslee

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