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:

Wednesday, April 27, 2016

Comment on Corps of Engineers Permitting Update

RGP or NWP - Both regulatory frames around the shellfish industry which they will try to break
On April 25 the Coastal Watershed Institute released an opinion on the Corps of Engineers' April 20 meeting at which the COE discussed their regulatory oversight of aquaculture (see below). Those regulations developed occur within either the framework of the Regional General Permit (RGP) or the Nationwide Permit process. RGP is more focused on regional issues and able to change more quickly (becoming more or less restrictive as impacts are discovered) whereas the NWP is more nationally focused, with regional conditions, but also set in place for 5 year periods. The former fits into Governor Inslee's misguided Shellfish Initiative.
[Note: The Nationwide Permit update process will be starting soon, as the current 2012 NWP's will be replaced in 2017.]

Taking an RPG to the time it takes 
A great number of concerns expressed by growers focused on the industry's dislike of how much time permitting of shellfish farms takes. Similar frustrations were expressed at an April 18 meeting of state agencies, where Governor Inslee pressed his Washington Shellfish Initiative and wanting to "streamline" the permitting process so expansion of the industry could occur on their schedule (for a summary of what was proposed to benefit the shellfish industry, see here). Some spoke of the "burden" it placed on small growers. Others spoke of multiple agencies (WDFW, NFMS) which had to be consulted and the time it added to the process. One speaker, a past employee of Seattle Shellfish, expressed concerns about time and a program he was involved with which would enable disabled veterans to become shellfish farmers.
[Note: The Pacific Coast Shellfish Growers Association had previously announced this program, but asked for members to provide sites already "permitted for shellfish farming." Whether any permitted sites were provided by PCSGA members is not known. Whether disabled veterans would prefer access to a natural shoreline over one populated with PVC pipes and netting is also unknown.]
Slippery regulations on eel grass
Also at the COE meeting there was concern expressed by an industry representative over comments about the regulation of activities in or near eelgrass. As noted in an earlier post, the shellfish industry successfully lobbied representatives in D.C. to get the Corps to drop protections of eelgrass in "fallow" shellfish beds. Reaction by tribal members, individuals and NGO's was sharp in opposing this action (see Coalition to Protect Puget Sound Habitat letter here). Concerns expressed at the meeting by the industry may be related to the developing science on the importance of eel grass in sequestering CO2, in addition to the well established science of the critical habitat it provides. Concerns which all should have is the slippery slope which the industry has put everyone on, where the economic benefit of a few override the long term benefits of the many by dropping protection of the critical habitat created by eel grass.

"iron fisted, misdirected support of the aquaculture industry"
As seen below, the Coastal Watershed Institute is clear about how it feels on the shellfish industry's growing regulatory influence. Speaking directly to Governor Inslee's "Shellfish Initiative", CWI notes the risk to the "wild and intact nearshore ecosystems" which "streamlined permitting" for industrial aquaculture brings with it. Also noted in their email is the success which political lobbying in Washington DC brought - the removal of eel grass protections. This is an industry well financed by geoduck grown and sold to China (netting over $1 million/acre to growers, with tideland owners simply being taken advantage of through lease terms benefiting no one but the growers). It is highly motivated. And, it does not like being regulated. Get involved.

Subject: CWI position on CoE Shellfish Aquaculture Permitting following
Informational Meeting April 20 (UNCLASSIFIED)

We attended the  20 April 2016 CoE informational meeting on  future federal
permitting of shellfish aquaculture in Washington state. The agenda is
attached, and the link to meeting presentation materials is below. We'll
have more to say when the draft biological opinions are published. Until
then, a few thoughts to consider as we wait...

One of the main decision points before the CoE is to decide the type of
permit they will develop for the future. They may pursue another national
permit, or alternatively, develop a regional aquaculture permit for
Washington state. The later would dovetail with seamlessly  Governor's state
'Shellfish Initiative', which  in our firm and clear opinion has been iron
fisted, misdirected support of the aquaculture industry, and that we feel is
in direct opposition to, and  displacement of, our wild and intact nearshore

The Washington state Department of Agriculture may well  be proposed as the
regional lead for the state in this regional construct. Remember that the
Department of Agriculture recently listed eelgrass, Zostera japonica, as a
nuisance species, opening the way to eelgrass irradiation by the shellfish
industry. WDFW should be a leader in this dialog-but WDFW (inexplicably)
has no permit authority over shellfish practices.

We just celebrated Earth Day. Many citizens spent the day participating in
beach clean ups around the state. They are the most recent witness to the
fact  that the majority of marine plastic debris of not only global, but
also our local shorelines, is from aquaculture. Bottom line:  exclusion
nets, tubes, spraying, and extensive monotypic cultures of non-native
species, and  mechanical disruption of shorelines for large scale and
industrial aquaculture are contra indicated with nearshore systems so
important for our northwest systems.

We were relieved to see military veterans were a profile at the meeting.
Our staff can speak from very personal experience-our wild, natural
nearshore ecosystems provide invaluable refuge/respite for healing veterans
and their families.  They must be protected.

Another point made at the meeting was that Washington state is one of the
largest shellfish industry producers in the nation-as reflected by the
number of permits along our shoreline.

The truth is that the  shellfish industry is extremely lucrative  in
Washington state (geoduck farms are reported to net over $1,000,000 an
acre), and politically extremely powerful. One recent and clear
illustration:  the startling letters from state and federal *elected*
politicians to the CoE Seattle branch chief that were specifically directed
to CoE protection of eelgrass. These letters , overnight, resulted in the
removal of  permit provisions that would have protected over 10,000 acres of
existing eelgrass in Puget Sound.

Based on what we observed at the 20 April  meeting- and in recent management
and political actions by state and federal agencies (and elected
officials)-,it's clear that our nearshore resources management actions are
being decided  as never before by industrial aquaculture, and the economic
heart that is at their core. The federal resource agencies and the CoE have
before them the opportunity and responsibility to preserve the intact
shorelines and ecosystems of our region. But to do so will require these
agencies to challenge the political forces that are becoming ever more
dominant in our ecosystem resource management. We strongly encourage them to
buck up,  chose  the right side of the ecosystem (as challenging as doing so
may be), and  be leaders for the resources (they are specifically charged
with protecting) and that we know they have the capacity to be.

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