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.