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: https://fortress.wa.gov/es/governor/
Legislative and Congressional contacts:
http://app.leg.wa.gov/DistrictFinder/

Additional information
Twitter: http://www.twitter.com/protectourshore
Facebook: https://www.facebook.com/ProtectOurShoreline



Saturday, August 20, 2016

Willapa Bay - Critical Habitat for Endangered Green Sturgeon: Study supports longline oyster growing method and retaining all of Willapa Bay as critical habitat

Willapa Bay: Critical Habitat for Green Sturgeon
Burrowing Shrimp: Critical food source

Kim Patten, WSU with longlines


Get involved. The Department of Commerce through NOAA/NMFS are performing a "regulatory review" of listings, one of which includes listing Willapa Bay and Grays Harbor as critical habitat for the endangered southern Green Sturgeon. Comments must be submitted by September 6 and must be done in writing or through the Federal e-Rulemaking Portal. 
Comment here by September 6: 
http://www.regulations.gov/comment?D=NOAA-NMFS-2016-0099-0001
(or CLICK HERE)

Read Pubic Notice here: 
http://www.regulations.gov/document?D=NOAA-NMFS-2016-0099-0001
(or CLICK HERE)

Tell NMFS and NOAA you support Willapa Bay and Grays Harbor being retained, with no exclusions, as critical habitat for the Green Sturgeon. Shellfish growers do have alternative methods of growing oysters and do not need to spray pesticides onto shellfish beds to kill a primary food source for this endangered species.

Willapa Bay: Critical Habitat for Green Sturgeon, a
threatened/endangered species under the 
United States Endangered Species Act.

Change is hard - stop living in your father's shadow and make a difference.
A study by Kim Patten with Washington State University has shown strong support for the use of the longline ("off bottom") method to grow oysters in beds which have burrowing shrimp in Willapa Bay. Willapa Bay was listed in 2009 as critical habitat for the endangered southern distinct population (SDP) of the Green Sturgeon, once far more abundant. Unlike salmon who pass through this important estuary on their way to the open ocean, the Green Sturgeon relies "...heavily on estuarine habitats over their lifespans." (from 2009 listing) Included is reliance on burrowing shrimp as a food source.

Damien Schiff
Tried to get the southern resident Orca
de-listed as an endangered species.
PLF - a danger to the 
endangered species act

2009 Habitat Listing Challenged by Pacific Legal Foundation
Earlier this year the Pacific Legal Foundation (PLF) asked the Supreme Court to review whether regulators had the discretion to determine whether to not exclude areas from being considered critical habitat. The court ruled those decisions are not subject to judicial review. It is unlikely the Supreme Court will consider Mr. Damien's case during the Long Conference, scheduled for September 26. (see here for PLF's response brief)

Not to Exclude is still discretionary.
While not involved in the lawsuit, in comments to NMFS on the then proposed 2009 decision, shellfish growers in Willapa Bay did ask for shellfish beds to be excluded from being considered critical habitat during the comment period. In response to that request, the National Marine Fisheries Services responded:
"Telemetry data show that tagged green sturgeon disperse widely throughout these estuaries, most likely for foraging. In addition, anecdotal accounts have noted observations of sturgeon in intertidal aquaculture beds in the past, likely when populations of sturgeon were more abundant in these estuaries."
 Sturgeons like long lines and shrimp beds.

Can oyster growers, an endangered species, and that species' food source co-exist?
According to Mr. Patten's recently published study, yes. His study finds an abundance of "foraging pits" in areas using longlines to grow oysters with burrowing shrimp >10/square meter. In fact, it was only in areas with no shellfish activity the forage pits were in greater density. Further, in a study published in 2007, it noted that "... these large predators [Green Sturgeon] may have performed an important top down control function on shrimp populations in the past when they were more abundant."

Bad conclusion to a good study - there is not a "surplus of foraging habitat". There are lower numbers of Green Sturgeon. It's why they're endangered.
As highlighted in the comments quoted above, sturgeon used to be more abundant. So much so one of the studies believes Green Sturgeon may have both played an important role in controlling shrimp populations and, contrary to Mr. Patten's observations, included shellfish beds in their foraging (something which would seem to support the grower's statement that shellfish beds improve the habitat). One of the stressors which reduced their population has been the past use of the pesticide Carbaryl by shellfish growers. Loss of spawning habitat and over-fishing no doubt also played roles as well. But the important point is the population of Green Sturgeon is not what is was. That is why there appears to be a "surplus of foraging habitat" and, more importantly, why they are considered endangered.


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