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.

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Monday, April 21, 2014

Pierce County Issues Mitigated Determination of Non-Significance for Seattle Shellfish/Taylor Shellfish Geoduck Farm

[Update 4/23: Ms. Meaders no longer works for Environ. She is currently employed by Confluence Environmental Company.]
>11 Acre "Haley" Geoduck Farm
SEPA Determination is Issued
Comments Due April 29th
Staff Contact: Ty Booth - tbooth@co.pierce.wa.us Phone - 253-798-3727
Director: Dennis Hanberg - dhanber@co.pierce.wa.us
(If affirmed or modified: Appeal Date - May 13th)
Location of proposed farm
"Mitigated" Determination of Non-Significance issued (MDNS)

Pierce County's planning department has issued a MDNS for an 11 acre geoduck farm proposed by a partnership between Seattle Shellfish and Taylor Shellfish. This partnership of the two largest intertidal geoduck farmers leaves little doubt of whether the current industry is controlled by a few companies. The minimal conditions contained within the SEPA determination leave little doubt of their influence.
>11 Acres of netting and tubes
Let industry set the conditions and manage oversight
The first "condition" contained in the SEPA determination allows the industry to determine its own oversight based on whatever they determine is the "most current version" of their own "Environmental Codes of Practice." Nothing in the conditions requires anything currently contained in their ECOP to be a condition of the permit. Should the industry decide they have "practices" which are too restrictive they may simply re-draft their ECOPs. 
Predator netting over tubes.
MDNS would allow up to 11 acres.
After tube removal netting is replaced.
Predator netting may remain for as long as industry wants, covering as much as industry wants
Condition 5 notes netting may remain in place for as long as geoduck are "vulnerable." Nothing requires netting to be removed at any time nor is there any limit to how many contiguous acres may be covered at any one time. In an October 1, 2013 letter to Ms. Meaders, then with Environ the Pierce County biologist expressed concerns about the fact that 11 acres will be covered by canopy netting. In the letter it is noted:
The Haley project is not proposing individual nets and considerably more than one acre will be netted at any one time. As such, based on the information available to us we can’t agree with the BE that the potential for the impacts discussed are insignificant. Please address this concern in a revised BE or stand-alone letter. [It is unknown what, if anything, was submitted to Pierce County to address this concern. Nothing in the SEPA determination requires limited planting.] 
Cumulative impacts, local: Proposed DNR leases and subtidal geoduck
The MDNS does not mention DNR has proposed leasing intertidal areas to the south nor does it fully consider the subtidal geoduck tract adjacent to the proposed farm. While only probabilities, activities in all areas create a far larger action area where harvesting may occur simultaneously. [For an idea of what dive harvesting and subtidal harvesting activities result in, see this Youtube video.] Nothing in the conditions limits when harvesting activities may occur, creating the possibility of a large simultaneous harvesting event which has never been considered nor its impacts studied.

Seattle Shellfish proposed hatchery on
Harstine Island, west of proposed farm.

Cumulative impacts, Mason County proposals
Adding to the cumulative impacts and not considered is the recent permit application from Seattle Shellfish in Mason County for their new upland shellfish hatchery and recent 19 acre lease of tidelands from Mason County. The hatchery, located directly west from the proposed farm is intended to increase the amount of seed available to the geoduck industry, and perhaps give Seattle Shellfish the opportunity to become less dependent on other seed suppliers (although partnering with Taylor Shellfish puts this in question). The recent 19 acre parcel between McMicken Island State Park and Harstine Island leased by Seattle Shellfish, is south west only 3 miles. Currently geoduck farming in Mason County is basically unregulated by the County, its being considered "aquaculture."

Fishtrap Loop in Thurston County
Taylor Shellfish Leases and Surveys
for future geoduck farms.

Cumulative impacts, Thurston County proposals
To the south in Thurston County, Taylor Shellfish has been active in permit applications for new geoduck farms and in surveying and leasing activities for future permit applications. Fishtrap Loop has seen a number of leases signed and surveys plotting out tidelands to plant. The Lockhart parcel to the east was recently approved, along with the Thiesen parcel (applied for by Arcadia Point Seafoods).
Sand Dollars - Just another "pest" 

Freedom to plant wherever needed without worry of native species
Also contained in the October 1 letter to Environ were concerns Pierce County's biologist had about moving native species, some considered little more than "pests" by the industry. [click here for a current industry "pest" document] Specifically mentioned in the letter were tube worms and sand dollars. In spite of the biologist stating his "expectation" would be no planting in areas of native species which could not be moved, there is nothing to prevent it nor anything on how species should be moved and/or replanted.

From our review of the site, and from previous projects, it appears unlikely that there will be any need to move things around, but with that said, if there is some area of sand dollars or tube worms or some other natural feature that can’t be planted around or relocated, the expectation is that you will simply not plant that area.

"Financial guarantees" are only good
if you're still in business.
Financial guarantees should the market collapse 
A minor plus in the MDNS is the requirement for a "financial guarantee" of $1/tube should the geoduck market collapse and industry participants find it is not financially worth their while to remove the tubes and netting. Unfortunately, a "financial guarantee" will mean little if a company has gone bankrupt.
Comments on cumulative impacts are important
As anyone involved in the oversight of the geoduck industry has seen, a favorite tactic of the shellfish attorneys at permit hearings is to state "a SEPA determination was made and was not appealed." It is a critical step in assuring Puget Sound's shorelines are protected as the Shoreline Management Act intended. Waiting to rely on the Shorelines Hearings Board to determine whether additional conditions should be required is a risk which in the past has, for the most part, resulted in decisions in favor of this growing and invasive industry. Commenting on weaknesses in a SEPA determination helps ensure adequate protections are in place.


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