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



Tuesday, April 25, 2017

Norovirus: Shelton-Mason Journal Reports Illnesses from Puget Sound Oysters Grow to Over 100

Number ill from Puget Sound oysters swells to over 100.
Anthony's Homeport in Olympia stops selling oysters.

Norovirus
 Just a little has a big impact.

Illnesses from Puget Sound oysters grows
The April 20th edition of the Shelton-Mason Journal reports that registered cases of illnesses in King County caused by consumption of raw oysters contaminated by Norovirus have grown to over 100.* It notes DOH saying the majority were harvested from tidelands in south Puget Sound. It has resulted in the recall of oysters from over a dozen companies having operations in Hammersley Inlet. The Journal also reported Anthony's Homeport Restaurant in Olympia saying they will "indefinitely" stop selling oysters due to health concerns.
* In the article it notes: "Health care providers are not required to report norovirus to the Department of Health ... there could be more than the originally reported 100 cases."
Closure map courtesy of iFIBER One News.
(See DOH interactive map for more)

Hammersley Inlet shellfish companies recalling oysters
Companies involved in the recall include: Arcadia Sellfish, Squaxin Island Tribe, Clearwater Shellfish, Russ Shellfish, Schreiber Shellfish, Sea Fresh Farms, Hernandez Shellfish, Taylor Shellfish, Montanos Shellfish Company, National Fish and Oyster Company, Navy Yard Oyster Company, Padden Seafood and Rivera's Shellfish.

Willapa Bay Shigoku oysters also recalled

Willapa Bay's Shigoku oysters also recalled
In addition to Hammersley Inlet, King County's April 14 update also noted Shigoku oysters harvested from Willapa Bay were contaminated with Norovirus and linked to reported illnesses from consumption of those oysters. Testing by the FDA's Pacific Region Laboratory NW confirmed the presence of Norovirus in Shikogu oysters from the Willapa Bay area. As a result of those illnesses and testing, DOH initiated a recall of oysters harvested from that area in Willapa Bay on April 13 and closed the area to commercial harvest.*
*Unlike Hammersley Inlet, the Willapa Bay area closed was recently declared safe by DOH and re-opened.
City of Shelton's wastewater treatment facility
Ultraviolet treatment a good idea?

Where to look, what not to do
To date there has been no report of finding the source of Norovirus in Hammersley Inlet. It had been hoped that norovirus from Hammersley Inlet's shellfish in 2015 had resulted in the source being found. Given the size of the current area closed, it would seem logical to assume the City of Shelton's Sewage Treatment facility at the end of Hammersley Inlet would be where to look. Especially given the recent upgrade which eliminated chlorine treatment, replacing it with ultraviolet disinfection. DOH notes Norovirus "...is not particularly susceptible to either cold temperatures or ultraviolet radiation." (DOH in 2013) Until the source is discovered, DOH does not recommend consuming raw oysters.

Friday, April 21, 2017

Reminder: May 21 - Industrial Aquaculture's Impact on Puget Sound Ecosystems

(Reposted from April 2)

The Association of Bainbridge Communities'
Annual Environmental Conference
(Note: The conference is free. However, due
to space limitations, registration is required.)

When: May 21, 12:30 pm to 5:30 pm
Where: 4450 Blakely Ave NE, Bainbridge Island, WA 98110
Registration: [click here] (Note: Space is limited so registration is required).

This may be good for a few corporations
and the very well off consumers in China,
but not for Puget Sound. Find out why.

The Association of Bainbridge Communities' annual Environmental Conference will cover the impacts to Puget Sound from industrial aquaculture. From the announcement:
"Speakers for this regional conference will cover ecosystem impacts, science and policy of aquaculture, legal aspects of the industry, food safety and health issues, problems with Atlantic salmon netpens, and experiences of neighbors living with this industry on their shorelines."
Agenda:
12:30 pm - Registration/Exhibits at IslandWood Welcome Center
1:00 pm - Introduction to Conference
1:10 pm - Overview of Impacts of Industrial Aquaculture
1:30 pm - Dispelling the Myths of Aquaculture
2:05 pm - Legal Aspects including Shellfish Initiative
2:35 pm - Regulatory Gaps in Permitting
3:00 pm - BREAK to visit exhibits
3:20 pm - Specific Aquaculture Topics: Atlantic Salmon Feedlots and Spraying and Health Issues
4:20 pm - Panel of Puget Sound Homeowners impacted by Industrial Aquaculture
5:20 pm - Next Steps: getting involved
5:30 pm - Adjournment

Wednesday, April 12, 2017

Threat to Humboldt Bay Eelgrass: Corps of Engineers Accepts Comments Through April 20



Comments due April 20 (see below for details)
[Thank you to Richard James and The Coastodian for this reminder.]

Get involved: Humboldt Bay's eelgrass beds are irreplaceable and the species dependent on them do not have an alternative location. A permit for Coast Seafood's proposed expansion into this critical marine habitat should not be approved by the Corps of Engineers. You can make a difference, but you have to engage.
[Note: A separate permit approved by the Humboldt Bay Harbor District is being challenged in court by the California Audubon and the California Waterfowl Association, represented by attorneys from Earthjustice. See April 3 post for details, or click here for case information.]


Above and below,
Humboldt Bay is critical 
marine habitat.
for more information.)

Send comments to L. Kasey Sirkin of the Army Corps at: l.k.sirkin@usace.army.mil
Important:  All comments should reference the PN file number and be submitted by the Response Required Date on the PN. Public Notice # is 2002-26912N. [Note: Comments should be directed to environmental impacts from expanded oyster cultivation in eelgrass.]

See Public Notice 2002-26912N here [Note: The comment period has been extended to April 20]:
http://www.spn.usace.army.mil/Portals/68/docs/regulatory/publicnotices/2017/SPN-2002-269120.pdf
See project description here:
http://www.spn.usace.army.mil/Missions/Regulatory/Public-Notices/Article/1104259/2002-26912n-coast-seafoods-company-humboldt-bay-shellfish-aquaculture-permit-re/

Coast Seafood's existing
and proposed expansion
into Humboldt Bay eelgrass beds.
A bad idea.

Richard James of The Coastodian reminds people who wish to stop the expansion by Coast Seafoods into the critical eelgrass beds of Humbold Bay the Corps of Engineers will accept comments through April 20. [click here to read Mr. James' post]

Comment letter from California Audubon/EarthJustice/Oceana - September 16, 2016:
http://coastodian.org/wp-content/uploads/2017/04/Audubon-EJ-Oceana-Coast-RDEIR-comments_9-16-16.pdf
the Project and its impacts remain enormous. The Project encompasses 622 acres of eelgrass and other sensitive tideland habitats, in addition to Coast‘s existing 300 acre footprint of operations, much of which also occupies eelgrass habitat. 
the best available information indicates that the proposed Project would result in a loss of eelgrass density on the order of 89-92 percent in the existing footprint (2.5-ft longline spacing) and of 45-67 percent in the expansion areas (10- ft. longline spacing).
analysis of the Project‘s effects on eelgrass is fundamentally flawed, and the conclusions based on that analysis are wrong

Comment letter from the National Marine Fisheries Services:
http://coastodian.org/wp-content/uploads/2017/04/20160912_Cmmt-Ltr_Coast-Seafoods_RDEIR.pdf
the analysis does not consider the current operations despite ongoing impacts to eelgrass from existing culture. [current operations cover 290+ acres]
does not adequately address effects to federally listed species (green sturgeon, Chinook salmon, coho salmon, and steelhead) and their designated critical habitat and does not incorporate information provided by NMFS
Comment letter from the Corps:
http://coastodian.org/wp-content/uploads/2017/04/ACOE_coast-letter_final.pdf
the Corps cannot agree with the determination that aquaculture longline operations set apart at 10-ft spacing will have a neutral/beneficial effect on eelgrass habitat.
it appears that many of the proposed conservation and mitigation measures do not address the potential impacts that they are intended to be addressing.

Friday, April 7, 2017

Norovirus in Shellfish from Puget Sound and British Columbia - A Wintertime Problem for Shellfish

It's no longer summer time oysters 
industry and consumers 
need to worry about.

A business model is becoming ill.
The recent outbreak of illnesses traced to Norovirus contracted from the consumption of raw oysters harvested from Puget Sound and British Columbia is presenting new and major problems for the northwest shellfish industry. It has created a year-round safety question about oysters and shellfish safety harvested from the northwest, put in question the export market, seen how the east coast shellfish growers are stepping in with safe native shellfish, and created increased risk to a business model.

Summertime Vibriosis from Puget Sound oysters
In the past, the naturally occurring bacterium Vibrio parahaemolyticus increased dramatically during the warm summer months and resulted in the contraction of vibriosis from raw oysters harvested from Puget Sound. Over the past decade, immense effort has gone into attempts to control the outbreaks. While somewhat successful, vibriosis is still being contracted from Puget Sound oysters harvested in the summer months. To make matters more of a challenge, warming temperatures increase the probability of the more virulent bacterium Vibrio vulnificus, currently found in Gulf Coast grown oysters, becoming established in Puget Sound (DOH reported it 2013 Vv having been found in Washington grown shellfish - click here for paper).

Wintertime Norovirus in Puget Sound and British Columbia oysters, and nobody knows why
A March 31 press release from King County has said the outbreak of illnesses contracted by hundreds from eating raw oysters has nothing to do with their failed treatment plant. They point out the oysters contaminated with norovirus have come from growing areas as far south as Olympia, WA, to British Columbia in the north and that illnesses began far before, stating in the press release:
"The implicated oysters [for illnesses contracted in King County] come from all over the Puget Sound – from down near Olympia to all the way up in Bellingham/Samish Bay." 

A March 22 article in The Globe and Mail quotes the BC Shellfish Growers Association as saying, "...the longer the outbreak continues the more devastating it is for the industry." The article goes on further to note BCSGA executive director Darlene Winterburn:
She said the cause of the norovirus has yet to be determined and government officials and scientists are examining a range of possibilities, including a sewage leak or perhaps an unusually cold winter that also meant less sunlight, which affected the oysters’ ability to filter toxins.
More than oysters at risk - geoduck from Hammersley Inlet 
It is not only contaminated oysters shellfish growers are concerned about. China consumes almost 90 percent of the geoduck clams harvested in these same waters. Like oysters, they too filter the water and retain whatever may happen to be in that water. In south Puget Sound, Hammersley Inlet contains one of Taylor Shellfish's largest geoduck operations. Beginning in mid-March, shellfish growing areas of Hammersley Inlet began to be closed by the Department of Health, who expanded those areas closed in the first week of April, moving west towards Taylor's geoduck operation. Of concern to growers is China and Hong Kong do not hesitate banning imports of tainted shellfish, as noted in August of 2015 when this occurred:
Hong Kong has decided to ban the import and sale of all raw oysters from British Columbia, Canada, after the province announced that a batch had been contaminated with bacteria.
Opportunities seen by East Coast Shellfish Growers: Restaurants in Vancouver "...carrying east coast oysters not subject to the same contamination scare." (Vancouver Sun, March 22)
Unlike the tainted shellfish found in the northwest waters, the East Coast shellfish growers believe their product to be a safe alternative with restaurants in Vancouver already describing their east coast oysters as being "..not subject to the same contamination scare." CBCNews noted on April 5, as a result of the norovirus illnesses from British Columbia (and presumably Puget Sound), the northeast shellfish operators in the Maritimes (Canada's eastern provinces) were  "...struggling to keep up with demand." An interview with one of the northeast growers speaks about the BC growers problem and the difference between the native oysters they provide versus the non-native Pacific Oysters grown in BC.

Expansion at risk of becoming ill?
Unable to determine the source of the Norovirus which has tainted oysters from the northwest has put in question the expansion so desired by this industry. Financing is at risk when over 300 people become ill from oysters over a large geographic area and nobody knows what the source is. Should China ban shellfish from the northwest because of bacteria or virus, as they have done before, a revenue stream will come to a halt. That increased risk is an illness the industry should be concerned about.

Monday, April 3, 2017

NGO's Sue over Coast Seafood's Plans to Expand into Humboldt Bay Eelgrass Beds

Aquaculture and Eelgrass Are not Compatible
Picture from 2015 clearly shows eelgrass beds stopping
where oyster cultivation begins.

Attorneys for Earthjustice have filed a Writ of Mandate for the California Audubon and California Waterfowl Association in order to stop Coast Seafood's (Pacific Seafood Group) planned expansion into Humboldt Bay eelgrass beds. Filed by Earthjustice against the Humboldt Bay Harbor District, in the California Superior Court in Humboldt County, the papers claim the environmental impact studies used to base the decision off of are flawed (see Final EIR here). Trent Orr, staff attorney with Earthjustice states:
“In its environmental review and approval of the Coast Seafoods expansion, the Humboldt Bay Harbor District ignored solid scientific data and extensive comments from biologists on the severe impacts this proposal would have on Humboldt Bay’s eelgrass beds and the birds, fish, and other wildlife whose survival depends upon them”
 In describing the critical significance of Humboldt Bay and its eelgrass beds to species dependent on that marine habitat, the California Audubon notes:
[Humboldt Bay is] second only to San Francisco Bay in its importance to shorebirds, Humboldt Bay is one of the most important migratory stopovers along the United States Pacific Coast. It is a globally Important Bird Area and a Western Hemisphere Shorebird Reserve Network site of international significance. It boasts the highest shorebird species diversity on the West Coast, with 46 shorebird species regularly using the bay. It provides habitat to significant portions of the populations of Black Brant, Western Sandpipers, Least Sandpipers, Marbled Godwit, and Dunlin, among many others.
The bay is so rich in bird life because of its unusually varied intertidal zone and rich subtidal habitat, which is home to approximately 50% of California’s remaining eelgrass. Eelgrass is particularly important as habitat for producing forage fish and crustaceans and to provide food for migratory and breeding birds.
In the papers filed with the Superior court Earthjustice attorneys write:
"...the FEIR fails to fully inform the public and decision-makers of the Project’s significant environmental impacts and fails to analyze and mitigate these impacts as the California Environmental Quality Act (CEQA) requires. Petitioners therefore seek relief from this Court to void the Harbor District’s certification of the FEIR and approval of the Project. "
The papers go on to describe the impacts the proposed expansion would have and how the analysis was deeply flawed. Points discussed in detail include:
Impacts from Increased Disturbance Associated with Aquaculture Operations; Interference with Various Species’ Feeding and Movement Associated with Aquaculture Gear in Eelgrass and Mudflat Habitats; Broader Environmental Context of Project Impacts;  Impacts to Recreational Uses; The Project Approval Process; a Failure to Analyze Cumulative Impacts; and, Failure to Consider Reasonable Range of Alternatives
Get involved. Coast Seafoods is only one of the west coast shellfish companies who sees critical tideland habitat, including eelgrass beds, as little more than a template for corporate profits. Whether Puget Sound, Willapa Bay, Humboldt Bay or Drakes Estero, expansion into these critical areas is not speculative. It is real. There is money and motivation behind this industry to forever change a critical marine ecosystem which a diversity of species have depended on for existence. There is no other place to go. When it is gone, they will be gone. Forever.

CONTACTS
Trent Orr, Earthjustice, (415) 217-2000
Garrison Frost, Audubon California, (415) 644-4604
Mark Hennelly, California Waterfowl, (916) 648-1406, ext 105

Sunday, April 2, 2017

Changing the Nature of Puget Sound: the impacts from industrial aquaculture

When: May 21, 12:30 pm to 5:30 pm
Where: 4450 Blakely Ave NE, Bainbridge Island, WA 98110
Registration: [click here] (Note: Space is limited so registration is required).

This may be good for a few corporations
and the very well off consumers in China,
but not for Puget Sound. Find out why.

The Association of Bainbridge Communities' annual Environmental Conference will cover the impacts to Puget Sound from industrial aquaculture. From the announcement:
"Speakers for this regional conference will cover ecosystem impacts, science and policy of aquaculture, legal aspects of the industry, food safety and health issues, problems with Atlantic salmon netpens, and experiences of neighbors living with this industry on their shorelines."
Agenda:
12:30 pm - Registration/Exhibits at IslandWood Welcome Center
1:00 pm - Introduction to Conference
1:10 pm - Overview of Impacts of Industrial Aquaculture
1:30 pm - Dispelling the Myths of Aquaculture
2:05 pm - Legal Aspects including Shellfish Initiative
2:35 pm - Regulatory Gaps in Permitting
3:00 pm - BREAK to visit exhibits
3:20 pm - Specific Aquaculture Topics: Atlantic Salmon Feedlots and Spraying and Health Issues
4:20 pm - Panel of Puget Sound Homeowners impacted by Industrial Aquaculture
5:20 pm - Next Steps: getting involved
5:30 pm - Adjournment

Wednesday, March 29, 2017

Norovirus Update: Outbreak News Reports over 300 Ill, King County Reports Washington Oysters Also Contaminated

Update: Widespread Norovirus contamination of oysters 
harvested throughout British Columbia and Washington.

Outbreak News reports  today that the Public Health Agency in Canada has reported over 321 illnesses traced to eating raw oysters contaminated with Norovirus which were harvested in waters of British Columbia. This total does not appear to include those who became ill in November who attended a festival on Vancouver Island. The 321 reported illnesses are all in Canada.

In addition, KING5 News reports that the Seattle King County Public Health Department has also reported an outbreak of illnesses traced to oysters harvested from Washington's Puget Sound, a body of water to the south of British Columbia, and consumed primarily in restaurants in Seattle. The Health Department noted the oysters were harvested from "different bays and beds across the state." KING5 noted a specific portion of Samish Bay was implicated in a large number of the illnesses, which Washington's Department of Health has now closed.

Speculation that the outbreak is related to the West Seattle sewage treatment plant problems is logical, but the outbreaks began before the failure so it is unlikely there is a relationship. Why the outbreak is so widespread is unknown. How the Department of Health will address the apparently growing problem is unknown.

Sunday, March 26, 2017

30 Million Gallons of Untreated Sewage Flow into Puget Sound

It's not raw sewage - it's only half raw.
Will the Trump administration care?

February 9th the West Point Treatment Plant in Seattle suffered a massive equipment failure. Since then Puget Sound's waters received 30 million gallons of untreated sewage. Currently, while repairs take place, the sewage flowing into Puget Sound from the plant being partially treated. Over 6 weeks later, the cause of the original flooding which crippled the treatment facility, is still unknown. It is hoped the repairs, currently estimated at $25 million, will be completed by the end of April. While clearly in violation of the Clean Water Act, it is not known whether action under the Trump administration will be taken.

Read more in the March 26 Tacoma News Tribune.

Wednesday, March 22, 2017

Ongoing Illness from British Columbia Oysters Puts Shellfish Safety in Question

Four months later, over 300 illnesses reported,
the source is not clear - beyond raw oysters.

What's in your filter feeder?
(Jean-Pierre Muller/AFP/Getty Images)

Headline March 22: B.C. shellfish industry reels as norovirus sickens hundreds, forces closures
(CTV News)
Headline January 13: BCCDC (British Columbia Center for Disease Control) advises consumers to properly cook oysters following outbreak (BCCDC)
Headline February 2: British Columbia oysters may be making Ontarians ill, health official warns (CTV News)
Headline November 25: Health officials investigate reports of illness after Tofino, B.C. food festival (CBC News)

18 Viral Particles and You're Ill
(Photo, CDC)

"Quickly" and "devastating" are apparently relative terms
Between November 25 and March 22, over 300 people having consumed raw oysters from British Columbia have become ill. Most are believed to be from reactions to Norovirus. While likely filtered from the coastal waters of the northwest, what its source is remains unknown.

Today, March 22, the shellfish industry has said it is "stunned" and they need to "find the cause quickly" as the alternative "could be devastating". It is unclear what "quickly" is defined as, given the outbreak has been ongoing over four months. It is also unclear what they define "devastating" as, given the number of people who have become ill and their inability to discover the source after four months.

As an article noted, the Executive Director of the shellfish growers association says, "...the far reach of the outbreak, which has been reported from oyster farms along much of the coast of Vancouver Island, is especially troubling."

In the mean time, the BCCDC recommends not consuming raw (uncooked) oysters harvested from British Columbia.

Monday, March 20, 2017

The Miami Herald Writes on Trump's Budget and the Risks to Puget Sound - Will Trump Care about Washington?

Research Supporting Geoduck Operations at Risk
But there's much more at risk.

The Miami Herald writes on the risk to Puget Sound should the budget proposed by the Trump administration gain traction and become reality. Included would be de-funding Sea Grant and cutting $28 million from the EPA currently being used to support Puget Sound cleanup. While unrealistic to believe the deep funding cuts proposed  would be accepted by officials elected to Washington DC, there is no love lost by the Trump administration for the state of Washington, a state who President Trump lost to Hillary Clinton by a wide margin.

Oh yes it can happen here, and it is.

Making a list and Washington's on it.
As a result of President Trump's Executive Order 13768, the US Immigration and Customs Enforcement (ICE) now publishes a "list" of "non-Federal jurisdictions that release aliens from their custody" in which numerous Washington counties are listed as not supporting ICE policies. Washington's Attorney General having filed and won a court case against President Trump's immigration policy has no doubt been added to the list. Washington's Representative Kilmer's (D) being upset at apparent ties between Russia and Trump surrogates a today's hearing will no doubt be added, as will Governor Inslee's resistance to Trump policies. Don't believe these things will not be used by a dangerous man and his surrogates against Washington, whether in the form of funding removed for the support of sanctuary cities or funding for protection and restoration of Puget Sound. It can happen here.

Get involved - it takes more than marching on a weekend to protect what you care about. 
Slate recently wrote on Samatha Bee's Full Frontal who berated liberals for being good at protesting but horrible at voting (see youtube clip on "the resistance" here). She noted only 12% of the voters turned out for the recent Los Angeles' mayoral election. In Louisiana a run-off for a Senate seat was won by a Republican, where only 29% of registered voters turned out. As the Slate article notes:
"...this apathy for current elections does not bode well for Democrats hoping to put the U.S. back on the right track in 2018 and 2020."
If you care about Puget Sound and the funding which supports its health, get involved. The Miami Herald notes Tod Meyers with the Washington Policy Center as saying, it's disingenuous for local leaders to protest proposed cuts for Puget Sound when they have not prioritized spending for salmon recovery and Puget Sound, going on to quote him as saying:
"It's ironic to criticize people in Washington D.C. for not treasuring what is in our own backyard when we won't prioritize what's in our own backyard"
Don't complain. Get involved.



Friday, March 17, 2017

Clarification/Correction to March 15 Post on Funding

Clarification and correction to the post questioning whether funding cuts to support NOAA and other agencies was necessarily a bad thing.

Clarification
Direct reference to studies created by Jeff Fisher, operator of a geoduck farm under the name of "Fisherport", continued as recently as January 6, 2017, in a letter penned by Pacific Coast Shellfish Growers Association attorneys to the Corps of Engineers. That letter was in response to the Seattle District's proposed General Conditions to the 2017 Nationwide Permit and an attempt to lessen regulatory oversight by the Corps. Reference to Dr. Fisher was made in order to support PCSGA's position that aquaculture in Puget Sound had "...minimal adverse to beneficial impacts..."

In addition to Dr. Fisher's studies, the PCSGA attorney's letter from January, 2017, also referenced the involvement of National Marine Fisheries Services in the programmatic consultation between NMFS and the Corps of Engineers in which NFMS issued a Programmatic Biological Opinion (PBO) on the Corps' oversight, dated September 2, 2016. As noted in the NFMS letter, that consultation between NMFS and the Corps began in 2007, noting that consultation process resulted in:
"...a final Biological Opinion in November 2014. That opinion required NWP-specific consultations before the COE could issue an individual NWP. The Services are addressing [in their September letter] that requirement for the 2012 NWP 48 with this [September 2, 2016] PBO." (p. 2 of September 2, 2016 opinion)
Correction
After extensive NMFS involvement providing consultation to the Corps' Seattle District, Jeff Fisher has left NMFS and in 2016 began work at the Marine Institute.

Thursday, March 16, 2017

Focus on Local Control: The Community Environmental Legal Defense Fund

[Update 3/17: Additional contact information -Lynn Lloyd, and phone - 253-561-3409
or, email at - lloydlynn52@gmail.com]

Learn how to get involved from The Community Environmetnal Legal Defense Fund.
Contact: Kai Huschke at  kai@celdf.org

The Community Environmental Legal Defense Fund has announced two events, one free one for a fee, on how to become involved at the local level to protect our environment from being seen as little more than a template to generate profits from. Given the current administration, it is critical that efforts to protect our natural systems be focused on the local level. 

April 6 - Free
April 7, 8 - $65

On April 6, at 6PM, CELDF's Kai Huschke will present a documentary at The Blend Wine Shop on elevating community and nature's rights over corporate rights. The efforts of CELDF are focused on the local level of ensuring the protection of the natural environment.

Blend Wine Shop
8914 Key Peninsula Highway North
Lakebay, WA 98349


On April 7, from 6pm to 9pm and then April 8, from 9am to 5pm, the Community Environmental Legal Defense Fund will present a seminar on how to protect, at the local level, the natural environment which the current administration has cast aside. The location is to be determined, based on those attending. Please contact Kai Huschke at: kai@celdf.org


Wednesday, March 15, 2017

Sea Grant Funding Threatened by Trump Administration: A bad thing?

[March 17 - Clarification and correction:

Clarification
Direct reference to studies created by Jeff Fisher, operator of a geoduck farm under the name of "Fisherport", continued as recently as January 6, 2017, in a letter penned by Pacific Coast Shellfish Growers Association attorneys to the Corps of Engineers. That letter was in response to the Seattle District's proposed General Conditions to the 2017 Nationwide Permit and an attempt to lessen regulatory oversight by the Corps. Reference to Dr. Fisher was made in order to support PCSGA's position that aquaculture in Puget Sound had "...minimal adverse to beneficial impacts..."

In addition to Dr. Fisher's studies, the PCSGA attorney's letter from January, 2017, also referenced the involvement of National Marine Fisheries Services in the programmatic consultation between NMFS and the Corps of Engineers in which NFMS issued a Programmatic Biological Opinion (PBO) on the Corps' oversight, dated September 2, 2016. As noted in the NFMS letter, that consultation between NMFS and the Corps began in 2007, noting that consultation process resulted in:
"...a final Biological Opinion in November 2014. That opinion required NWP-specific consultations before the COE could issue an individual NWP. The Services are addressing [in their September letter] that requirement for the 2012 NWP 48 with this [September 2, 2016] PBO." (p. 2 of September 2, 2016 opinion)
Correction
After extensive NMFS involvement providing consultation to the Corps' Seattle District, Jeff Fisher has left NMFS and in 2016 began work at the Marine Institute.]

Is the threat of de-funding Sea Grant and its associated research used to support the expansion of shellfish aquaculture in Puget Sound necessarily a bad thing? Consider just a few of the authors and research reports funded in whole or in part by taxpayer dollars to support expansion of the industry:

1. Jeff Fisher and Gregory Reub - Current or past principals with Environ, both significant providers of research funded in part or whole by Sea Grant to look at the impacts from geoduck operations in Puget Sound. Papers created and authored by each found little in the way of adverse impacts. These papers continue to be referenced directly or indirectly in permit hearings as proof of minimal impacts from expanding geoduck operations in Puget Sound.
Not disclosed: Both Mr. Fisher and Mr Reub, at the time of their involvement, each operated geoduck farms whose profitability would be directly impacted by favorable reports. Mr. Fisher is now with the National Marine Fisheries Services (NMFS) which provides opinions on the impacts of current and future shellfish operations to the Army Corps, and continues to operate his geoduck operation on Totten Inlet and has purchased tidelands adjacent to those his operation is on. Mr. Reub continues work for Environ and continues his geoduck operation. He has purchased the tidelands originally leased, put them into and out of a self-directed IRA, and has proposed to expand onto nearby tideland parcels.
2. The University of Washington, through funding contracts with Sea Grant, created a study using a model to determine how much commercial geoduck operations could expand in the Central Basin of Puget Sound before adverse impacts would begin to be felt by native species. Despite knowledge the kilograms harvested was likely not accurate, and choosing to ignore far higher harvesting levels from other years, they chose to publish the paper.
At issue with the paper is the generally accepted fact that harvest records reported to the Department of Fish and Wildlife are under reported (i.e., lower than reality), despite a law requiring accuracy of production from the growers. More significant, the paper stated there were 10,546 kg (23,250 pounds) harvested in 2012. WDFW records show nothing harvested in 2012, but instead that amount was harvested in 2011. More important than an incorrect year is that in addition, WDFW records show in 2008 there were 47,343 kg (104,374 pounds); in 2009 there were 19,050 kg (42,000 pounds); and in 2014 there were 5,436 kg (11,985 pounds). [2008 - 104, 374 pounds; 2009 - 42,000 pounds; 2011 - 23,250 pounds; and 2014 - 11,985 pounds] Further, when the paper was referenced in a recent permit hearing as evidence for impacts to consider, a memo was created by an industry environmental firm framing the paper as being little more than a model and something not to be relied on by agencies.
If this is the type of research taxpayers' dollars pay for through Sea Grant should citizens be upset it is being de-funded? Puget Sound is a critical resource and funding for its protection is important. It may be time another source be found. Perhaps taxing those who profit from its protection - in this case the shellfish industry and those leasing their tidelands to those corporations - should be considered.

* After leaving his position at Environ, Mr. Fisher moved to NOAA's NMFS where he was branch manager for the Lower Columbia River and Washington Coast, an area encompassing Puget Sound

Friday, March 3, 2017

Coalition Submits Comment to Ecology on Net Pen Salmon Farming

Net pen salmon farming in Puget Sound 
is not a good idea.

The Coalition to Protect Puget Sound Habitat has submitted comments to the Department of Ecology on their proposed "Managing Sustainable Commercial Net-Pen Aquaculture in Washington Straits and Estuaries". In those comments the Coalition presents evidence on the significant adverse impacts to the marine habitat and native salmon which net-pen aquaculture in other parts of the world have created.

Feed lots of concentrated animals create vectors 
for parasites and disease to take hold.

Pesticides in marine ecosystems do not remain in one place.
Included in the comments is the recently published paper showing pesticides used to treat salmon infested with sea lice spread throughout the marine eco-system and impact species far beyond those the industry seeks to treat. That paper on farms in Scotland noted, "...between 2006 and 2016 levels of anti-sea lice pesticides found in sediment 100 metres away from salmon cages exceeded environmental quality standards in 45 sea lochs and inshore waters." Anyone consuming shellfish filtering waters where these net pens are proposed should take note, as should shellfish growers. (See paper here: https://theferret.scot/45-lochs-polluted-fish-farm-pesticides/)

From waters near Olympia the sea lice 
have no problem living.

Puget Sound is not so different that sea lice won't be a problem.
In the comments the Coalition has also challenged Ecology to produce peer reviewed papers showing that the salinity of Puget Sound is so different from British Columbia and other parts of the world that sea lice will not be a problem. Anyone catching cutthroat in south Puget Sound has experienced the sight of these unwanted parasites clinging to these fish. Anyone looking at the Department of Health water monitoring reports can see the salinity levels are more than adequate to support sea lice populations, as they exist now and the dramatic increase which will occur with these vectors which net pens create.

Lesions are not pretty on any fish, nor healthy.

One thing leads to another.
Parasitic sea lice are not the only problem these concentrated feel lot operations create. A recent study published in the scientific journal Plos One on net pen salmon "...showed evidence of HSMI histopathological lesions over an 11-month timespan, with the prevalence of lesions peaking at 80– 100% in sampled fish." The cause of the lesions were traced to three sources: Piscine orthoreovirus (PRV), and parasites Paranucleospora theridion and Kudoa thyrsites. But the paper notes, importantly, that the virus "... PRV alone was statistically correlated with the occurrence and severity of histopathological lesions in the heart."

Land based salmon farming in Norway
to produce 20,000 tons.
Ecology should not be beholden to the industry
who claim it is more expensive.

Alternatives cost more to operate - but what are the native species in Puget Sound worth?
When sea lice create stress on the salmon it creates an opportunity for the virus to overwhelm the immune system of the salmon, resulting in lesions, poor health, and death. Of more importance, it will not be limited to net pen salmon. The marine ecosystem is fluid and dynamic. Hoping to be able to contain the disease is a false hope. The true alternative to net pen farming are land based operations where the populations are isolated from native species. As the Coalition comments note, Ecology did not appear to consider this alternative, discussed in depth at a 2014 summit held in Canada. There, attendees heard clear and concise methods presented on land based operations.

Get involved. Aquaculture is receiving your tax dollars to promote industry's expansion at the expense of Puget Sound's ecosystem and its native species.
NOAA is proposing millions of dollars be spent in order to overcome "...major constraints, barriers, or hurdles limiting United States aquaculture production." As noted:
NOAA Sea Grant expects to have available a total of $10,000,000-$12,000,000 across fiscal years 2017, 2018, and 2019 for a national initiative to increase aquaculture production in the short-term (2-4 years). 

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

Call:
Sen. Patty Murray: (202) 224-2621
Sen. Maria Cantwell: (202) 224-3441

Monday, February 6, 2017

Willapa Bay Herbicides: Ecology Extends Comment Period for Application of Imazamox by Shellfish Growers

Get involved. If you don't the shellfish industry's "alternative facts" generated by their paid contract scientists will continue to guide agency decision making on the expansion, and impacts from, aquaculture in Washington's marine waters. Tell the Department of Ecology to stop allowing herbicides and pesticides to be applied in Willapa Bay.

Comment period extended to: March 7, 5PM
Comment form: http://www.ecy.wa.gov/programs/wq/pesticides/eelgrass.html
or, Mail to: Nathan Lubliner, DOE
PO Box 47696
Olympia, WA 98504-7696

We don't like your study's conclusion, so we'll find our own. They appreciate our money.
"If a reduction in shoots translates to death of the affected plants [native eelgrass], it may be premature to conclude little if any impact on native eelgrass outside of the 10m buffer." Impacts of Imazamox on Native Eelgrass, Grue and Conquest, with the University of Washington (Conclusion, p. 12)

Comments already submitted by the Coalition to Protect Puget Sound Habitat have stated the initial study performed by University of Washington scientists Christian Grue and Loveday Conquest on application of Imazamox to beds owned by Taylor Shellfish showed native eel grass outside of the buffers was being negatively impacted by Imazamox . They suggested in the conclusion of their study to monitor the same site in the future and would do so as part of their contract (Contract Number 14-1358). However, in the Coalition's comments, it is stated Taylor Shellfish prevented the University of Washington scientists from returning to their tidelands for follow-up studies. (Grue and Conquest "were barred from re-entry into the test site in 2015 by the grower,Taylor Shellfish, to do their follow up results." Coalition comments, page 3.) 

You'll like her conclusions much better.
Instead of allowing Grue and Conquest back, the Coalition's comments state that Confluence Environmental was chosen as the firm who Taylor would allow back for follow-up studies. Confluence is considered the "go to" biological firm for hire used by the shellfish industry when they need support at hearings for permits or legislative support. They are paid well to support what the industry wants. The independent scientists from the University of Washington were apparently told they had fulfilled the terms of the contract and that despite their offer to follow-up for no charge, Confluence would be paid to do that. 
[Note: Not mentioned was that it was Confluence who provided what was considered inappropriate data, by someone considered not to be knowledgeable on eel grass, at the Detienne geoduck operation permit hearing. The Court of Appeals Washington State decision agreed that permit should be denied, despite what Confluence tried to get people to believe. Attempts by shellfish attorneys to block that decision from being published were denied.]
Should conflicts of interest matter? Disclosure of conflicts should be out front if your study - or opinion - is used to support something you may profit from.
In addition to Confluence, DOE has provided another follow-up study provided by Kim Patten with Washington State University. Mr. Patten has, over the years, provided numerous opinions, some called studies, which support whatever it is the shellfish industry wishes to have supported, including the ongoing application of herbicides and pesticides in Willapa Bay. According to the Coalition's comments, Mr. Patten has neglected to mention his ownership of tidelands in Willapa Bay, stating further, he also has a clam farm on those tidelands. [Note: It could not be confirmed there was an active clam farm operation on Mr. Patten's tidelands.]

Contrary to what DOE says, agencies did not agree the study showed no harm from Imazamox, let alone that it was adequately designed.
Further discussed in the Coalition's comments was that initially, DOE claimed that agencies had supported the buffer, stating so both in the December 7, 2016 announcement, as well as at the first public meeting held January 24, 2017. When challenged, that comment was withdrawn. In fact, the Department of Natural Resources wrote in June of 2016 that WDNR "...remains concerned about impacts to native vegetation when lmazamox is sprayed to manage Z. japonica." 

Saturday, January 28, 2017

Illnesses from Raw Oysters Consumed at Taylor Shellfish's Queen Anne "Oyster Bar" Reported by King County

Illnesses traced to raw oysters
consumed at Queen Anne location.

King County Public Health has reported illnesses traced to raw oysters consumed at Taylor Shellfish's Queen Anne, Seattle, location. The "norovirus-like symptoms" were reported to King County Public Health on January 9th and traced back to raw oysters consumed on January 4th. An investigation of the restaurant on the 11th eventually confirmed the raw oysters consumed there as the source. The press release notifying the public was dated January 27th.

Many bacterium and virus may cause "norovirus-like" symptoms, some more so than others. Consumers whose immune systems are suppressed should be especially aware of the risks inherent in consuming raw seafood. Warming water temperatures, some believe tied to man-caused global warming, will increase the likelihood of  different Vibrio strains and blooms in Puget Sound which oysters' natural filtering retain during the summer months.


Thursday, January 19, 2017

Monterey Bay Aquarium Drops Commercially Farmed Geoduck from Green "Best Choice" Category

Commercial Geoduck 
from Washington
Loses Certification

Commercially Farmed Geoduck From Washington Lose Monterey Bay Aquarium's Seafood Watch "Best Choice" Certification
Monterey Bay Aquarium's Seafood Watch has dropped commercially farmed geoduck from their green "Best Choice" category due to a "...heavy reliance on plastic tubing to protect growing geoduck clams, and a better understanding of the ecosystem impacts of this practice is needed." It was a move long in coming and a welcomed recognition that this form of aquaculture is, in fact, transformative to the tidelands of Puget Sound in which it is taking place. (Note: Taylor still notes geoduck as being a "Best Choice" on their website.)

Is "Farmed Responsibly" the same?
From one to the next.
Without Monterey Bay Aquarium's certification showing that commercially farmed geoduck grown in Washington's Puget Sound is a sustainable "Best Choice", Taylor Shellfish has now sought, and achieved, a certification of "farmed responsibly" from another body, the Aquaculture Stewardship Council (ASC). As with all standards bodies and their associated certifications, differences exist, and the two certifications are not equivalent.


Benchmarking ASC versus Monterey Bay Aquarium's Seafood Watch
In a 2012 evaluation of other certification bodies, ASC Bivalve (clam) standards did not meet the green, "Best Choice" level of Monterey Bay Aquarium's Seafood Choice. Below is the result from Monterey Bay's "Eco-certification Benchmarking Project" (page 7) which compared other certification bodies to Monterey Bay's Seafood Watch.
[Note: The ASC 'Bivalve Standard' used for certification was 'Version 1, dated January of 2012'. This was a certification standard which Bill Dewey, with Taylor Shellfish, played a direct role in developing.]
ASC versus Monetery Bay Aquarium's Seafood Watch (click to enlarge)

In addition to ASC, the other certification body which Taylor Shellfish also used, the Food Alliance, while higher than ASC, was still not able to achieve the "Best Choice" level of certification.

Food Alliance versus Monterey Bay Aquarium's Seafood Watch


Does it really matter? It should.
When testimony is given to Hearing Examiners about certifications to support permit applications, it should matter. At Tuesday's hearing for a geoduck farm permit in Puget Sound's Zangle Cove, Diane Cooper with Taylor Shellfish testified that all of their farms had been certified as being "sustainable" by ASC. Initially, Ms. Cooper was confused about what ASC stood for, telling the examiner it stood for "Aquaculture Sustainability Certification". She later corrected the description of what ASC actually stood for (Aquaculture Stewardship Council), but not that ASC only certified farms as being "responsible", not sustainable (from ASC's website: "ASC aims to be the world's leading certification and labelling programme [sic] for responsibly farmed seafood.")
(Hear Ms. Cooper discuss what she thought ASC stood for, here, at 20:28)

Moving aquaculture towards truly sustainable practices is a goal which all should support. Why a company moves from one certification body to another is something which should be looked at closely, whether you are a consumer or an agency listening to testimony. In this case, that Monterey Bay Aquarium's Seafood Watch has dropped commercially farmed geoduck from Washington from their green, "Best Choice" certification category, should not be masked by achieving certification from another body.

Monday, January 16, 2017

Reminder: January 17 - Hearing on Zangle Cove Geoduck Operation in Zangle Cove

Zangle Cove Hearing Continued to Tuesday, January 17, 2017 at 10 a.m.
Thurston County Courthouse 
Building One, Room 152

Who is that "recreating" over my geoduck farm
and why are they "recreating" there?
Diane Cooper of Taylor Shellfish:
Clear evidence you can "recreate" over a geoduck farm.
(Exhibit submitted by shellfish attorneys in hearing.)

Better bring lunch and dinner to eat. 
The appeal of Thurston County's "Mitigated Determinatin of Non-significance" (MDNS) for a geoduck operation in the ecologically sensitive Zangle Cove, whose tidelands were not sold as being suitable for aquaculture, and the associated Shoreline Substantial Development Permit, continues January 17. Based on an email from the Hearing Examiner, it may be a marathon, stretching into the night, noting parties should "... arrange to be available into the evening as late as necessary." Bring food for the body.

Mental food for thought from a recently published court decision the shellfish industry attempted to prevent being published.
Appeals Court of Washington:
The SHB [Shorelines Hearings Board] concluded the permit did not appropriately balance statewide interests and was inconsistent with RCW 90.58.020

The SMA [Shoreline Management Act] is liberally construed "to give full effect to the objectives and purposes for which it was enacted." RCW 90.58.900. The essential purpose of the SMA is to protect the shorelines of the state because they are "among the most valuable and fragile of its natural resources." RCW90.58.020. Permitted shoreline uses must be designed and conducted in a manner that minimizes damage to the ecology, damage to the environment, and interference with the public's use of Washington's water. RCW 90.58.020.

Shorelines Hearings Board: There is more to the Shoreline Management Act than aquaculture.
" particular consideration must be given to balancing the interests of aquaculture as one statewide interest, with other statewide interests like the shoreline's ecological values and the public's recreational use"

Friday, January 13, 2017

DOE on Net Pen Fish Farming in Washington: After 30 years it's time we re-visited it.

Comment period extended to March 4
Email Cedar Bouta with DOE at: cedar.bouta@ecy.wa.gov
See: http://www.ecy.wa.gov/programs/sea/aquaculture/recommendations.html

Should permit decisions on salmon net pen
farming be based on guidance from a 30 year old plan?

A 30 year management plan on salmon net pen farming is finally going to be updated - after most counties on Puget Sound have been told their Shoreline Master Programs must accommodate net pen aquaculture. Is this really guidance or accommodation of an industry's desire to exploit Puget Sound's critical marine habitat for their benefit?

Yes, a lot can happen in 30 years.
Genetic modification is only one thing.

Have another meeting, write another email, give me some new guidance. Or not.
DOE notes they hope to have a new plan by 2019. A date after which which permits have been issued under the 30 year old management plan DOE used to tell counties this activity was in the state wide interest and must be allowed. This is the same DOE who decided not to discuss PVC tubes in their SMP Handbook, Chapter 16, with Ms. Bouta writing in an email dated June 17, 2015, to DOE's Perry Lund, "...I'm hesitant to include guidance on PVC tubes in the Aquaculture SMP Handbook chapter...". After whatever meetings took place, it was decided to leave mention of PVC tubes out of the chapter on Aquaculture, presented by DOE to counties to use in their program planning process.

Puget Sound's low salinity
keeps Sea Lice from being a problem.
(DOE's Lori Levander in 2013)
Near Olympia, about as far south as you can get,
Sea Lice have no problem surviving.

Net Pen science likely discovers risks to wild salmon and marine habitat over 30 years time. But let's wait until the SMP updates are completed and we've told counties these pens are in the "statewide interest" so should be permitted.
Ecology is replacing the state’s 30-year old management recommendations for commercial marine finfish aquaculture (net pens). Why the Department of Ecology decided to wait until most of the counties impacted by what an updated plan would reveal isn't made clear. Unfortunately, as noted above, by the time a new "plan" is created, new operations will have been permitted and will likely never go away.
Politics at its best: Industry and DOE 
hand in hand, testifying before the House
on why net pen farming is good for you (2013)
Net pen farming is good for you
if you're a fish grower, questionable by others.
(CLICK HERE for testimony which begins at 22:50
through 1:01:43, then begins again at 1:04:39 to 1:59:00)

Is it any wonder people question who the Department of Ecology is really working for?
After allowing Whatcom County to ban salmon net pens in their Shoreline Master Program update, then telling Jefferson County "oops, we made a mistake" and Jefferson County could not ban them in their SMP update, then telling Island County they would be able to ban them due to a "...lack of evidence that net pens are an immediately foreseeable use", and having told other counties in the process of updating their Shoreline Master Programs net pen farming is in "the statewide interest" and should be allowed, Washington's Department of Ecology has now decided their 30 year old management plan should be updated with current science. Science which may have been found to be very useful in determining whether, in fact, net pen farming is really something in the statewide interest, or instead, in the interest of a few large corporations seeking to exploit Puget Sound's critical marine habitat. Orchestrated testimony before a House committee by net pen industry representatives with DOE on net pen farming clearly puts in question who is pulling what strings.

Get involved. As seen in the 2013 testimony, industry is and they are very motivated.
At the very least you may send comment to DOE on what a new and updated plan should include. Better is to tell DOE and your elected officials they have so badly managed their net pen guidance that no permitting in any counties should be allowed until the new plan is developed.

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

Tuesday, January 10, 2017

Washington Court of Appeals Agrees to Publish Decision Supporting Permit Denial of Geoduck Operation

The Coalition to Protect Puget Sound Habitat has released a statement about the Washington Court of Appeals agreeing to publish their decision which affirmed a Shorelines Hearings Board permit denial for a geoduck operation in Pierce County. Despite immense sums of money having been spent by the shellfish industry for attorneys, expert witnesses, and even political donations in support of a Pierce County attorney running for mayor of Gig Harbor, and a final attempt by the industry to claim the decision had little in the way of public interest, the panel of judges agreed to publish their ruling.
Read decision in support of denying permit here:
https://app.box.com/s/rgjvffsgdrklchytus6uwy7chmtljv56
Read decision agreeing to publish here:
https://app.box.com/s/ww0vd3g2r648hjugljqg3v8xk7mgsc50

Dear Interested Parties,
The Coalition to Protect Puget Sound Habitat is pleased to announce that the Washington State Court of Appeals has granted our motion to publish the Detienne Shoreline Hearings Board win that will serve to protect our marine critical habitat, eelgrass, forage fish, the public's right for safe recreation/windsurfing and the need for cumulative impacts analysis..

The Washington State Court of Appeals, Division 1 decision affirmed the Shorelines Hearings Board (SHB) decision to deny the 5 acre geoduck aquaculture permit in Henderson Bay/Pierce County.  The Court of Appeals stated: 

1.  "We conclude the SHB did not err in concluding the Coalition met its burden of proving the permit buffers did not adequately protect eelgrass from adverse impacts in violation of the SMA (Shoreline Management Act) and Pierce County SMP (Shoreline Master Program).".. The Coalition relied on the FSEIS buffer to argue the buffers approved by the Hearing Examiner were inadequate. The FSEIS identifies the need for a "2-foot vertical buffer or a minimum of 180-foot horizontal buffer" between eelgrass and geoduck harvest areas to protect eelgrass."

"The SHB found that while Meaders (industry expert) "is knowledgeable of the geoduck industry and science underlying aspects of industry practices," she was not "a credible expert in all aspects of study related to the nearshore environment to which she claimed expertise."

2. "Evidence presented at the hearing showed there are potential adverse impacts to critical habitat."

3.  "Because the consideration of a cumulative impact analysis prior to approval of the permit is consistent with the purpose of the SMA and clearly furthers the goal of the SMA to prevent "uncoordinated and piecemeal development,"the SHB did not err in concluding consideration should be given to preparing a cumulative impacts analysis."

4.  "De Tienne contends the SHB decision is not timely..... Because de Tienne stipulated to consolidation of the petition he filed on June 28, 2013 and there is no dispute the SHB extended the time period for good cause for an additional 30 days, the SHB complied with the time limits of the statute."


If you have any questions, please feel free to contact us.

Sincerely,
Laura Hendricks
Director, Coalition To Protect Puget Sound/Habitat
(253) 509-4987