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:

Thursday, June 6, 2013

Taylor Shellfish/Haley Geoduck Farm: Pierce County Expresses Concerns Over Size of Operation, Helping Reinforce the Need for an EIS/Cumlative Impacts Analysis

"The Haley project is much larger than the previous two farms and I’m not sure whether the conclusions of the various studies and pieces of literature referenced in the BE can be applied without some additional discussion." Pierce County Memo Dated 5/15/13

"Evidence is increasing that the most devastating environmental effects may result not from the direct effects of a particular action, but from the combination of individually minor effects of multiple actions over time." (Chapter 1, Introduction to Cumulative Effects Analysis, Council on Environmental Quality)

Pierce County Expresses Concerns on Taylor Shellfish/Haley Geoduck Farm
Pierce County has expressed concerns over the size of the Taylor Shellfish/Haley Geoduck farm, questioning whether literature referenced in Environ's* Biological Evaluation is applicable to a farm of this size. They have asked for additional information to be submitted.
(*Environ Principal Greg Reub and past Principal Jeff Fisher, now with NOAA's National Marine Fisheries Service, are registered owners of companies involved in geoduck farming.)

Haley/Seattle Shellfish/Taylor Shellfish
Parcels on Case Inlet

Overview of area
(Spencer Cove is directly below
the arrow, west of the Haley Farm)
As noted in comments submitted on many permit applications there should be a focus on the number and size of expanding operations as well as the infrastructure supporting that expansion. While generally focused on geoduck farming, the proposed expansion of other shellfish operations with non-native/genetically modified Pacific oysters, invasive Manila clams and rafts of non-native Gallow mussels adds to the problem. The time for an Environmental Impact Statement where a complete Cumulative Impacts Analysis addresses the growing impacts from aquaculture in Puget Sound is now, not after the fact. The Shoreline Management Act's defining Puget Sound's habitat as "among the most valuable and fragile of its natural resources" clearly supports this position (RCW 90.58.020).

Cumulative Impacts Analysis
The need for a cumulative impacts analysis is found in Consideration of Cumulative Impacts in EPA Review of NEPA Documents. It begins with: "The combined, incremental effects of human activity, referred to as cumulative impacts, pose a serious threat to the environment." The combination of activities which are occurring in size, time, and location which are associated with the "Haley Farm" helps to establish why it is needed.

In the EPA document, it notes:
CEQ's [Council on Environmental Quality] regulations (CEQ, 1987) explicitly state that cumulative impacts must be evaluated along with the direct effects and indirect effects of each alternative. By mandating the consideration of cumulative impacts, the regulations ensure that the range of actions that is considered in NEPA documents includes not only the project proposal but also all actions that could contribute to cumulative impacts.
In the case of the "Haley Farm" multiple levels of expanding activities are found. At the farm level, as Pierce County notes, it is larger than any previously proposed, and contrary to statements from the shellfish industry that there are only a few tidelands where geoduck may be planted, there are still vast areas of flat and sandy beaches which have never been developed in south Puget Sound.

Subtidal Nearshore Farm is Permitted

Detienne Farm, the first subtidal farm
to receive a permit for planting and harvesting.

Adding to the growing intertidal developments are the nearshore subtidal regions which have only recently been proposed as areas to plant. Recently the "Detienne Farm" permit was approved by the Pierce County Hearing Examiner which included over 4 acres of subtidal area, with one of the few native eelgrass beds in south Puget Sound splitting the proposed intertidal and subtidal operation (see Detienne Farm post for an overview). On Harstine Island, across from the "Haley Farm" is a vast subtidal area, a large portion owned by Seattle Shellfish, which has not yet been commercially planted. Pierce County's permitting of the Detienne Farm establishes a precedent for others to follow.

Spencer Cove's privately owned
subtidal area, directly west of
the "Haley Farm"

Expanding Shellfish Hatchery and Nursery on Spencer Cove
In addition to the exponential increase in acres which the Detienne Farm's approval has now added to impacting Puget Sound's "most valuable and fragile" area is the infrastructure necessary for this to occur. In the case of the Haley Farm, one of its parcels is jointly owned by the Taylor Shellfish family and Seattle Shellfish, tying the two more tightly together. Seattle Shellfish has a large geoduck and nursery operation in Spencer Cove, directly west of the proposed Haley Farm. Uplands adjacent to the state owned lagoon seen in the picture below are under consideration for an industrial  hatchery. PVC pipe is currently "bagged" and loaded onto barges from the site.

In February Seattle Shellfish met with Mason County to discuss placing an upland shellfish nursery to support its growing operation, a follow-up on a 2010 meeting. Recently installed were "nursery rafts" in which geoduck seed from hatcheries elsewhere are grown out to a larger size which allows for a higher survival rate in the upper intertidal areas, further expanding tidelands impacted. The proposed hatchery facility will provide additional seed, currently a constraint to expansion onto undeveloped tidelands, both intertidal and subtidal. Impacts to county infrastructure include heavy truck use of what has been described by a County Commissioner as a "failing bridge" which is the only access to Harstine Island, as well as its roads. The hatchery facility will add to the impact and county maintenance expense.

Expanding Shellfish Nurseries in Marinas
In addition to the facilities owned by Seattle Shellfish and expanding developments on currently undeveloped tidelands is the recent permit application by Chelsea Farms, operator of the subtidal Detienne farm, for a commercial nursery at the only public marina in Oakland Bay. In their permit application it was noted how allowing for the commercial expansion of nurseries could potentially increase seed availability 10 fold. Following the permit request the City of Shelton submitted an amendment to the already drafted Shoreline Master Program to allow up to 10 of the boathouses to be converted from public use to commercial shellfish nurseries. Other conversions are proposed throughout Puget Sound. The loss of slips to moor boats provides minimal public benefit.

Conversion of a public marina
to commercial shellfish nurseries.

Funding for Expanding Shellfish Operations
With the expansion of shellfish operations also comes expenditures of state revenues, county revenues, and private landowners to help support the industry. In order for shellfish to grow there is a need for clean water. Water quality testing throughout Puget Sound is paid for by the Department of Health. County personnel inspect suspected upland areas where problems may exist. Farms pay for fencing to keep cattle out of streams and private land owners in Thurston County are required to pay an annual fee if they own a septic system. While all help to ensure state waters are kept clean, the financial benefactor is the shellfish industry who pays minimal taxes, property or otherwise, and whose jobs created are filled for the most part by underpaid migrant workers.

Small Studies Cannot be used to determine Large Impacts
Pierce County is correct in having a concern of using isolated studies of small farm activities to determine whether new applications for larger farms should be approved or not. While one cottage on a shoreline may have minimal impact, it does not mean a 5 story condominium will have minimal impact nor that a 100 room hotel will have a minimal impact. Each level brings with it a set of incrementally larger actions with both direct and indirect impacts. That is the stage where the shellfish industry is now, whose incremental impacts have not, as a whole, been considered.

Pacific Seafood Processing 
Facility in Warrenton Burns Down

Coast Seafood was recently acquired
by Pacific Seafood which includes a
50% ownership of Penn Cove Shellfish.

Industrial Level of Activity Requires an EIS
The shellfish industry is no longer a group of small families operating on discrete tideland parcels. The industry is becoming controlled by a few large corporations. As seen in the Coast acquisition, consolidation of operations and ownership is occurring, creating a level of industrial activity which small studies of family owned farms cannot replicate.

Let your political representatives know it is time to ensure the state's "most valuable and fragile" natural resource is protected through requiring an Environmental Impact Statement which has an inclusive Cumulative Impacts Analysis.

Governor Inslee: https://fortress.wa.gov/es/governor/
State Legislator: http://app.leg.wa.gov/DistrictFinder/
Senators: http://www.senate.gov/general/contact_information/senators_cfm.cfm?State=WA
Representatives: http://www.house.gov/representatives/find/#listrep

Read more on Cumulative Impacts Analysis:
EPA's Consideration of Cumulative Impacts in EPA Review of NEPA Documents
Council on Environmental Quality's Considering Cumulative EffectsUnder the National Environmental Policy Act
"Evidence is increasing that the most devastating environmental effects may result not from the direct effects of a particular action, but from the combination of individually minor effects of multiple actions over time." (Chapter 1, Introduction to Cumulative Effects Analysis)

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