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:

Friday, September 13, 2013

Drakes Estero Seal Count 38% Below Peak Count: Drakes Bay Oyster Company Implies "Great News"

Update 9/14: Playing with numbers and graphs. Graph of 1998 - 2013 seal counts with notes added.

Regressive Correlations Between
Commercial Operations and Wildlife in Wilderness Areas
"This is Public Relations?"

The 2013 maximum molt count of Harbor Seals in Drakes Estero just released indicates a level almost 40% below its peak count in 2003. In 2002 the Johnson Oyster Company reported its lowest planting in history and near record low harvest of 78,064 pounds. The following year, 2003, the peak molt count of seals was ~1,800. In 2004 Drakes Bay Oyster Company began operations. Except for two years (2006 and 2008) the seal count fell steadily to a low of ~550 in 2011, from where it climbed to ~700 in 2012. The 2013 annual count showed a peak of 1,122 seals. Why?

Positive Correlation Between
California Coastal Commission Actions
and Rising Harbor Seal Counts?

California Coastal Commission Actions Precede Rise in Drakes Estero Seal Count
In 2007 the first cease and desist order was issued, after which seal counts rose, then dropped to a low in 2011.

In November of 2011 a "letter of concern" was mailed to Drakes Bay Oyster Company telling them of compliance issues, including protection of Harbor seals, followed by a rise in the seal count of 2012.

In February of 2013, the California Coastal Commission issued a second Cease and Desist Order to Drakes Bay Oyster Company which included Section 5.2, further addressing Harbor seal protection (see below). In July, Peter Prows, attorney for Drakes Bay Oyster Company stated in the July 18th MarinIJ:
Peter Prows, ... said the oyster operation is already complying with the commission's order. "We want to comply and have been complying," Prows said, noting the oyster company has developed several plans to address the commission's concerns. "We are happy to keep working with the commission."
Positive Correlation?
Clearly there is a positive correlation between complying with the California Coastal Commission's Cease and Desist Order addressing Harbor Seal Protection Measures, and an increased seal count. Merely complying, however, is not enough to bring the seal count back to its historic peak which occurred at a time when harvest levels and planting levels were at  or near their historic lows (2002/2003). It is simply one more example of why commercial operations are not compatible with wilderness. Public relations firms, their clients and supporters touting a number almost 40% below the peak seal count (1,800 vs. 1,100) as a great example of compatibility do their profession and themselves a disservice.

Or we see what we want to see?
As Corey Goodman knows so well, statistics is a funny class of math. Depending on data points and variables chosen, you can prove just about anything. Does the above mean that every time the California Coastal Commission acts against Drakes Bay Oyster Company a rise in the seal count will result? You decide.
Interim Use Provision from February 2013 Cease and Desist Order:
5.2 Harbor Seal Protection Measures.

(A) Permanent Closure. Respondents’ personnel, boats, equipment and structures shall not enter harbor seal protection areas identified in Attachment 4.
(B) Seasonal Closure. Respondents’ personnel, boats, structures and their equipment not enter the Lateral Channel, as defined in Section 3.7, above, during the Harbor Seal Breeding Season, as

defined in Section 4.9, above.
(C) Haul-Out Buffers. Respondents shall maintain a distance of a minimum of 100 meters from any hauled out harbor seals.
(1) Should the Executive Director determine that operations are causing flushing or disruption of behavioral patterns of seals, the Executive Director may increase this minimum approach-distance to not more than 200 meters by providing written notice to Respondents.

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