New Burley Lagoon Area Geoduck Operations

A new geoduck farm near the mouth of Burley Lagoon is being proposed.
http://www.nws.usace.army.mil/PublicMenu/documents/REG/NWS-2009-1530-PN.pdf
Comments are due November 16.

Unique to this proposal and what should be of concern to everyone is the expansion from intertidal farming into the nearshore subtidal area, to a depth of 38'.   Nothing like this has been proposed nor been considered by any agency other than DNR who does not allow "harvesting" of subtidal depths between the lowest tide and a depth of 18 feet. 

As proposed the farm will be planted in five annual rotations, the effect of which will be continual impacts to the area from PVC tube insertion/removal; net placement, cleaning and removal; and, sediment plumes from dive harvesting (subtidally) and "dry" harvesting (areas exposed at low tide).

Eel grass beds contained within these tidelands provide critical habitat for Pacific Herring; Steelhead; Cutthroat; and, Chinook.  As seen in Ecology's condition for the Jamestown S'Klallam geoduck farm, impacts to eel grass beds from farm activities are unknown.  Common sense dictates dive harvesting and other activities will spread a plume of sediment far wider than the proposed 10' buffer.  As clearly stated in the July 17, 2009 letter from Pierce County to Mr. DeTienne:

"The range of buffers referenced in literature varies from 10 feet (the standard buffer required in Hydraulic Project Approvals and the distance referenced in the recent U.S. Fish and Wildlife Service and National Marine Fisheries Service biological opinions) to 180 feet (referenced in the 2001 State Final Environmental Impact Statement which pertains to subtidal harvest)."
(It should be noted that an Environmental Impact Statement is far more rigorous than a "biological opinion," which is just that - an opinion.  It is the EIS which requires the 180' buffer.)
The critical habitat provided by Burley Lagoon and the nearshore area at its mouth is already at risk.  Whether from past and current upland activities or proposed future activities related to the expansion of geoduck farming, the specific and cumulative adverse impacts to this critical area - and to Puget Sound in general - need to be fully considered before any expansion of geoduck farming is permitted.