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, July 2, 2013

Taylor Shellfish Mussel Farm Update: APHETI to Appeal Shorelines Hearings Board Decision

Decision to Reverse Thurston County's Denial of
Taylor Shellfish's Permit Application for
58 Raft Mussel Farm in Totten Inlet
(see APHETI announcement
at the end of this posting)
You can help support APHETI's appeal to Superior Court by donating to:
APHETI (as a registered 501(c)3 organization donations are tax deductible)
PO Box 11423
Olympia, WA 98508-1523
Phone: 360-866-0218
Web Site: www.apheti.com
Buying up Puget Sound's
Natural Ecosystem
One Tideland Acre at a Time
Shellfish Industry's Vision for South Puget Sound
In January of 2012 the Senate Environment Committee heard what the vision for south Puget Sound was, clearly articulated by Jim Gibbons with Seattle Shellfish. In that testimony he told them that compared to south Puget Sound's production of 20 million pounds of commercial shellfish, Spain produced, in the same area of south Puget Sound, over 600 million pounds. His excitement over the amount of nitrogen removed was difficult for him to contain.
"Imagine the Nitrogen Removed"
Is this what Puget Sound needs?
(shellfish farming in France)
More than Nitrogen is Removed
However, as Thurston County's hearing examiner clearly recognized in the denial of Taylor's permit, the problem with "the vision" described by Mr. Gibbons - reflected in part in the mussel farm proposal - is commercial shellfish operations bring with them more than removal of a miniscule amount of nitrogen (estimated at ~1% of the total weight harvested). That nitrogen is removed as shellfish filter and feed on plankton needed by native species in Puget Sound, ejecting feces and pseudo-feces in a concentrated area which are consumed by bacteria, further lowering levels of dissolved oxygen in the area. To the point of why the permit was denied, you can no longer look at a single event (one mussel farm) within a larger system and ignore everything else which is occurring. Specific to shellfish, as anyone who is aware of the impact which nitrogen has on a body of water knows, none of the fresh water systems now safe and healthy were made so by shellfish. It was through controlling the inputs into those systems. In Puget Sound, it is the political pressures from the shellfish industry regulating what goes into Puget Sound which helps makes the waters healthy, not shellfish. 
CO2 in a Bottle -> CO2 in the Ocean ->
Lower pH (acidification) -> Shellfish Industry Crisis
(from Shallin Busch at The Evergreen State College)
Ocean Acidification, the Shellfish Industry, and Beyond
As is currently being heard throughout the country, but especially in Washington state, there is a crisis in the shellfish industry, caused by what is commonly referred to as "ocean acidification." From the breakdown of CO2 in the Pacific Ocean comes the lowering of pH levels ("acidification"), which in turn breaks down the element needed for calcification - carbonate ions. This reduction has resulted in hatcheries having had a near collapse in their oyster seed production as larvae become stressed, unable to produce shell. As more energy is used to create shell, they become more vulnerable to other external stressors, such as Vibrio tubiashii. Through "buffering" and choosing when to draw in water, production has risen, but the drop in carbonate ions remains, made less so by intensive shellfish farming.
These ions are needed by all species - whether native shellfish or any other species which require calcification. Through harvesting the shellfish grown, in many cases non-native species, those limited ions used to create shells are removed from the system and do not return, removing any "buffering" which occurs in a natural system.
Washington will Lead - Where?
In response to the shellfish industry's crisis created from CO2 emissions the Washington Shellfish Initiative was created, wrapped within the belief that by so doing will show the nation "Washington will lead" in addressing excessive CO2 emissions. [Skipped over is how allowing coal terminals to export hundreds of millions of tons of coal to Asia affects the perception of just what "leadership" there really is.] In that leadership role is a proposal to "streamline" permitting in order to facilitate the expansion Mr. Gibbons and others in the shellfish industry desire.
Cumulative Impacts Cannot be Ignored
To date, industry attorneys have successfully argued that current regulations cannot look beyond the myopic vision of "one farm at a time." Thurston County's denial of Taylor's permit was the first significant acknowledgement that in fact cumulative impacts have to be considered. While Taylor argues that over $1 million in studies have been done, in part funded by taxpayer dollars, having a big report does not mean it is correct and that cumulative impacts should be ignored. For this reason and others, APHETI has chosen to appeal the SHB decision. Further, it disagrees strongly with Taylor Shellfish now attempting to create their own monitoring plan through the SHB instead of Thurston County as the added condition required. More importantly, if additional monitoring is in fact needed, then it should be designed around existing operations. It is why the permit was denied in the first place.
The Shoreline Management Act
The Shoreline Management Act defines its shorelines as "the most valuable and fragile of its natural resources" and is in place "to prevent the inherent harm in an uncoordinated and piecemeal development of the state's shorelines." (RCW 90.58.020)  It is not in place to promote an industry's expansion and use of any methods it chooses simply because in 1971 it was considered one of the uses of Washington's "most valuable" resources. Shellfish farming is no longer Grandpa Taylor's oyster farm.
Association for the Protection of
Hammersley, Eld, & Totten Inlets
PO BOX 11523
Olympia WA 98508-1523    
Phone: (360) - 866 - 0218
Email: apheti@gmail.com     
June 28, 2013

RE:  State Shoreline Hearings Board (SHB) decision

Greetings APHETI Members and Supporters -

The SHB met on April 22, 2013 to hear Taylor's appeal to overturn Thurston County's denial of Taylor's application to expand aquaculture of non-native mussels in Totten Inlet.  The basis of the denial was that Taylor's Environmental Impact Statement (EIS) lacked sufficient study on cumulative impacts.   

The SHB issued its decision on June 17, 2013 – overturning Thurston County's denial of Taylor's permit application – see APHETI's website www.apheti.com.  This is disappointing but not surprising.  The SHB has a historical bias of siding with the commercial aquaculture industry.  We have learned the future Puget Sound wide plan of the aquaculture industry is to use suspension aquaculture (rafts) to grow not only mussels but all other forms of shellfish - clams, oysters, scallops, sea urchins, etc.

The bottom line – unless each one of us does all we can to stop this NOW, Taylor has a green light to put 58 more mussel rafts in Totten Inlet – AND – open the door for the aquaculture industry to put more rafts not only in Totten Inlet but throughout all of South Puget Sound!  Hundreds of raft type aquaculture operations could easily develop in Eld, Budd, and Henderson Inlets and the Nisqually Reach areas of Thurston County and Hammersley, Carr, and Case Inlets in Mason and Pierce Counties.  

APHETI attorney, David Mann, says this of the SHB decision - 
I continue to believe the SHB got it wrong on Benthic impacts, dissolved oxygen, Gallo mussels and cumulative impacts. The only way they could get to their answer was to ignore entirely our legal arguments, our cross examination, and the multiple holes in the analysis.” 
“Frankly I believe all of the issues the Examiner raised and we defended before the SHB are worthy of appeal. It will be an uphill fight, but it is by no means a slam-dunk against us.” 

APHETI intends to appeal the SHB decision to Superior Court.  This will require substantial financial resources.  Your help is needed.  Previously, we asked for your financial contribution to support this coming appeal and some have responded most generously – THANK YOU!  Additional resources are needed though.  If you have not yet considered making a contribution please do so now for without your support APHETI's appeal may not be possible.  

APHETI is an IRS registered non-profit charitable organization.  Contributions may be tax deductible and all are acknowledged in writing.  The identity of all donors is kept strictly confidential.  Please use the enclosed pre-addressed envelope to mail your contribution to APHETI or use APHETI, PO Box 11523, Olympia, WA 98508-1523 if you are receiving this communication via e-mail.  

As always, please feel welcome to contact APHETI (360/ 866-0218) with any questions you may have.  We again, Thank You! for your continued support.  
APHETI Board of Directors

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