Ecology Issues New 401 Certification

Kilisut Harbor Geoduck Farm

Approved by Ecology

Kilisut Harbor

(From Google Maps)

The Department of Ecology has issued its first Section 401 Water Quality Certification for a new geoduck  farm in Puget Sound, operated by the Jamestown S'Klallam tribe. 

(see: http://www.ecy.wa.gov/programs/sea/fed-permit/pdf/200900900_WQC.pdf)

Proposed is a 1.5 acre farm on what is known as Beach 2 on the northeast shore of Naval Magazine Indian Island.  The farm will be planted annually in 12,000 square foot sections, resulting in farming impacts occurring each year over the typical 5 year cycle. 

Since 1939 this island has been used as a Naval weapons station.  In part, runoff from these storage areas has resulted in Beach 2 being closed to shellfish harvesting, with it only recently having been opened (storage bunkers adjacent to this location are seen in the photo above).  Whether these historical contaminants still exist in sediments from which the geoduck are harvested is unknown, but past studies indicate constricted estuaries with historical pollution have contaminants still contained in the deeper sediments.

Kilisut Harbor is also one of the critical habitat areas for the Cherry Point Herring population, currently in decline.  Significant areas of Eel Grass are used for spawning by this population.  As noted in the certification, beds of Eel Grass are adjacent to the proposed farm.  Impacts to these beds from farm activities are currently unknown.

Will sediments disturbed impact this habitat?  Are contaminants still held within the sediments which will be released upon harvesting?  Constricted outlets at both the south and north ends of Kilisut Harbor make flushing of the harbor less than ideal and whatever is disturbed will remain for an unknown period of time.

WAC  173-201A-400(4) states:  No mixing zone shall be granted unless the supporting information clearly indicates the mixing zone would not have a reasonable potential to cause a loss of sensitive or important habitat, substantially interfere with the existing or characteristic uses of the water body, result in damage to the ecosystem, or adversely affect public health as determined by the department.

Has Ecology's allowing a "mixing zone" of 150' met the above?  The proposed Eel Grass study which is part of the 401 Certification clearly indicates impacts from geoduck farming on beds of Eel Grass are unknown.  Are deeper sediments still contaminated, increasing the risk again of exposure to arsenic and BEHP which had kept this beach closed in the past?  Samples of the upper 10cm are not adequate to answer this question. 

WDFW has clearly established Kilisut Harbor as a priority habitat area.  Species of forage fish and critical habitat are well documented.

The Jamestown S'Klallam Tribe notes the following on its web site:
We, the Port Gamble S’Klallam and the Jamestown S’Klallam Tribes, of the Point No Point Treaty Area, recognize the responsibility and need to protect and advance the treaty reserved hunting, fishing and gathering rights of our Tribes.

Contained within the responsibility of protecting reserved hunting, fishing and gathering rights is consideration of whether an intertidal geoduck farm in this critical habitat area meets this stated goal for everyone and everything.