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:

Tuesday, December 18, 2012

Shellfish Politics: Japanese Eelgrass Now a Weed in all Washington Waters

"If any other agriculture industry experienced a 40% decline, there would be a state of emergency and something would be done about it" (Pacific County comment in support of proposal)

"It's the end of the world!"

Pacific County's Willapa Bay growers were most vocal, portraying a Mayan "end of the world apocalypse" if classification of Japanese eelgrass as a weed remained only on commercial shellfish beds. But reality, as in all frenzies, is quite different. WDFW harvest records for Willapa Bay show something quite far from the end of the world:

2006: 964,638 pounds of Manila clams harvested
2011: 1,166,665 pounds of Manila clams harvested

2006: 1,373,105 oysters harvested
2011: 1,955,131 oyster harvested

Agency Oppostion Ignored
Despite comments from state agencies opposing expansion of Japanese eelgrass being classified a Class C noxious weed, and even the Noxious Weed Board's own advisory committee suggesting it not be adopted, Japanese eelgrass has now been declared a "Class C Noxious Weed" in all of Washington's marine waters. Despite clear evidence showing it has become a naturalized part of the ecosystem relied on by migratory birds as a food source and fish for habitat, the Noxious Weed Board instead relied on the shellfish industry's unfounded complaints that limiting control to only shellfish beds would be a disaster of epic proportions.

Agency Comments
WDFW: The Washington Department of Fish and Wildlife (WDFW) is strongly opposed to this proposal...
DNR: DNR does not support the WSNWCB expanding the listing of Z. japonica as a Class C noxious weed
Noxious Weed Control Board Advisory Committee: WSNWCB's advisory committee has recommended that this proposal not be adopted at this time
Department of Ecology's Permit for Control: At this time, the Department of Ecology’s (ECY) draft NPDES permit process for Japanese eelgrass is exploring the option of allowing the use of the herbicide ClearCast (imazamox) on commercial clam beds in Willapa Bay only. [from the decision paper]
Shellfish logic on ecosystem integrity -  

From the Pacific Coast Shellfish Growers Association"Those growers believe very strongly that if this invasive weed is not controlled everywhere in Willapa Harbor that the entire Harbor's ecosystem will be permanently damaged, "The native shellfish which were brought to near extinction by over harvesting and whose habitat is now taken over by non-native Pacific oysters and non-native Manila clams would have a different view. As would the native Ghost shrimp being eradicated by the shellfish grower's chemical spraying.

From Grays Harbor Oyster Growers Association
"The entire food web of the estuary is being negatively impacted, and the few species that could be utilizing japonica have a multitude of other food and cover options readily available." Based on what? The shellfish industry has cleared the natural oyster reefs which used to exist and provide structure for other food sources to grow in. Ghost shrimp, as noted above, which did survive are eradicated through chemical spraying. Even the Noxious Weed Board noted: Although active research is ongoing and the net ecological impact of Japanese eelgrass is still unclear, the shellfish industry has indicated that this nonnative, invasive species is negatively impacting shellfish production and causing economic loss as well as causing some ecological harm.

Northern Oyster
"we have developed a vast amount of experience in dealing with invasive species" It was the introduction of the non-native and invasive Pacific oyster and non-native Manila clams in Point Reyes Shoreline Wilderness EIS which, in part, caused the National Park System to allow a commercial shellfish farm's lease to expire, so a natural ecosystem could be restored. In Willapa Bay, these native species are Olympia oysters and Littleneck clams. 
Willapa-Grays Harbor Oyster Association and Integrity
Controlling Japanese eelgrass will allow the shellfish industry to "protect the integrity of Willapa Bay." Integrity is something everyone should think about. It's difficult to attain but easy to lose.

Wednesday, December 12, 2012

Geoduck Farm Hearing in Thurston County, December 17

December 17, Monday, 1PM
Room 152, Thurston County Courthouse Complex
Building #1 - Administration
2000 Lakeridge Drive SW, Olympia
verbal and written testimony will be accepted at the hearing.
[Click here for county information **VERY LARGE FILE**]

Location of Xia farm on Wheeler Parcel
9330 Maple Beach Lane NW
With adjacent existing farm to the south

A fourth Shoreline Substantial Development Permit for a new geoduck farm in Thurston County has been requested and a hearing scheduled. Adjacent to an existing geoduck farm in Eld Inlet this will be the fourth addition to the numerous existing geoduck farms already existing in Thurston County.
Existing Geoduck Farms Placed
Before Shoreline Permits were Required

How many geoduck farms are there in Thurston County?
Based on the staff report, the answer to this question is unknown. On page two of the staff report, it notes: "...immediately South is a commercial Geoduck plantation of approximately 1.75 acres. Based on aerial photos it appears that this adjacent Geoduck plantation was installed sometime between 2008 and 2009. No Shoreline Permit or exemption was issued for this adjacent Geoduck Plantation." (To be clear, in 2007 Taylor Shellfish reported to the Army Corps this adjacent parcel  -12903240500 - to be growing geoduck, manila and littlneck clams and, pacific and kumamoto oysters. It did not state how long this farm had been growing these shellfish.)

Geoduck farms in North Henderson Inlet
Existing and Proposed

Why should the county, and taxpaying citizens, care how many farms exist?
Beyond cumulative impacts of numerous adjacent farms operating on separate schedules and grow-out cycles, Thurston County is the only county known to be making an attempt to determine the fair market value of tidelands converted to shellfish farms, especially geoduck farms. In order to do so they need to know whether a farm is in place and what it is growing, in part why the SSDP is so important.
Geoduck Farms near Nisqually Delta
(click to enlarge)

What is the value of a tideland parcel converted to a geoduck farm?
To put the importance into perspective, the entire Wheeler parcel (12903240200) is currently assessed at $82,100, resulting in property taxes of $880 [click here for tax information]. Tidelands make up ~$1,600 of that value [click here for valuation report]. If the .92 acre farm is planted as described, in 5 years the operator (based on today's price) will generate over $1 million with $100,000 or more going to the Wheelers, or $20,000 per year in lease revenues. Once permitted, a farm will be able to operate for numerous cycles, meaning a $1,600 tideland parcel generates ~$20,000/year to the owner, over $180,000 per year in net profits to the operator.

Why do shellfish operators prefer leasing to ownership?
Beyond the reality that tideland owners do not realize the true value of their property, it is because the current leases are written such that the owner is responsible for property taxes, not the operator. When the counties, lead by Thurston County, realize the fair market value of a tideland parcel permitted and converted to geoduck farming exceeds $100,000/acre it will be the owner who has to pay the tax increase. Not the operator.

Get involved. The shellfish industry has pushed to have Japanese eelgrass in all Willapa Bay declared a "noxious weed." Puget Sound's tideland conversion is next and it is coming faster that you know.
Beyond money, it will be the future generations who pay for the conversion in habitat which has occurred when endless cycles of planting and harvesting occur.


Saturday, December 8, 2012

Subtidal Planting Of Geoduck in Pierce County and the Public Process (or lack thereof)

With minimal Public Notice from Pierce County, on November 21 a "mitigated determination of non-significance" (MDNS) SEPA decision was issued, opening the door for the development of the first subtidal "geoduck farm" adjacent to Burley Lagoon. Comments were due December 5. An appeal is due December 19. [click here for documents, then click on "Documents" Tab] (Note: While the SEPA decision was signed and issued November 21, the web site notes it having been added the day before, November 20.)

Subtidal Geoduck Farm
Adjacent to Burley Lagoon

As noted, the decision was apparently issued with minimal public notice. This is an option which Pierce County has. However, Pierce County also had the option to notify a far broader base of the public, but chose not to. Instead, the needs of Mr. Detienne, a resident of California, were focused on.

The public has expressed an intense interest in the Shoreline Master Program's update and expansion of geoduck farming in Burley Lagoon where Taylor Shellfish proposes "only" a 30 acre development. It would seem the County would want to have the local residents involved in this decision through a broad Public Notice process. They could have but chose not to.

The attorney representing California's Mr. Detienne was certainly involved in the process, as seen in this portion of an email from Pierce County's Senior Planner, Ty Booth, to Mr. Plauche, attorney for California's Mr. Detienne:

I will not have this issued until we hear back from your team. Note, I am happy [to] discuss or meet regarding these issues. I have discussed the issue extensively with Adonais Clark…but he will not receive a copy of this until tomorrow (as I need to get to my meeting). I am also providing a draft to Dave Risvold to review. Finally, I will be recommending approval of this proposal to the KPAC and Examiner.

Was the SEPA decision "clearly erroneous"? It clearly sets a precedent for the development of "shorelines of statewide significance" (the subtidal area). It clearly sets a precedent in allowing development with subtidal native eelgrass in it. It clearly sets a precedent in allowing development in an area where bulkheads and a roadway already impact the nearshore environment. Perhaps most important, it clearly sets a precedent on how Pierce County views the involvement of local citizens in their permitting process.

Wednesday, December 5, 2012

Washington and Ocean Acidification: She said What?

"What do you think Governor?"

Country representatives meeting in Qatar over the past two weeks on climate change must now be asking, "She said what?" about Governor Gregoire's answer to why, if Washington was so concerned about CO2 emissions and ocean acidification, they were considering the exporting of hundreds of tons of coal to Asia. [click here for article]. An opportunity to lead the nation, if not the world, in addressing CO2 emissions and climate change fell below flat.

It's more than shellfish.

After the praising of how great the leadership was of all involved on the "Blue Ribbon Panel on Ocean Acidification" finished, questions were taken. The first one, like many which followed, was directed at the Governor, asking for her opinion on the exporting of coal to southeast Asia through Washington ports. A reasonable question given that the scientists on the panel were clear about the cause of ocean acidification being CO2 emissions and that burning coal is the primary source.
It's more than "coal jobs."

Unlike the past and current Governors of Oregon who openly oppose the export of coal, Governor Gregoire did not want to "invite litigation" or "invite problems" by expressing an opinion [read article here]. Does she really think being "silent" is going to mean no lawsuits will be filed? Governor Romney discovered what not taking a firm position on controversial issues results in.

This is not leadership and not what is needed at a national level. It makes people look at Washington and ask, "What are they thinking?" It's embarrassing to everyone.

Sunday, December 2, 2012

Drakes Bay Oyster Company: Castles Made of Sand

"Castles made of sand ..."

Shellfish growers from the East Coast Shellfish Growers Association and Pacific Coast Shellfish Growers Association lobbying groups are upset about Secretary Salazar's decision to allow a lease for a commercial shellfish farm in the Point Reyes wilderness area to expire. They claim "accepted environmental science" shows commercial shellfish farms, as operated today, benefit the environment and they are "going to sue." More importantly, they are at the same time lobbying for Governor Gregoire to replace Secretary Salazar. Unlike the Governor, Secretary Salazar placed the definition of "Wilderness" above the commercial needs of the shellfish industry.

Look a Little Deeper

Why are they bringing "forces to bear?" It is not over concern of the Lunny family who purchased the farm, knowing its lease was set to expire in 2012. The Lunny family is very well off and will continue to be well off from the profits made while operating the shellfish farm and from their upland dairy/cattle farm operated nearby. Nor are they concerned about their employees. Workers will be displaced, but if we are to believe Taylor Shellfish and the PCSGA, their skills are in high demand and will be easily absorbed by the shellfish industry. They lobbied in Washington D.C. this February for immigration reform, distributing an "issues paper" stating: "In a healthy economy, the domestic workforce does not provide sufficient numbers of qualified workers for the shellfish industry."

Why are they so upset they are going to spend the money to sue? It is because they are worried the Environmental Impact Statement (EIS), which clearly shows adverse impacts from current methods used in commercial shellfish farming, establishes a precedent which will be used to regulate the industry and constrict the growth and tideland development they have lobbied so hard for.

Existing and Proposed Geoduck Farms in Henderson Inlet
From a November 26 permit hearing, courtesy of Sierra Club

Commercial shellfish farms, as operated today, are transforming the aquatic habitat of all areas they operate in, and even those far from where they are located. Gone are the days when Justin Taylor, as a boy, used to spread shell on the tidelands for oyster clusters grow on, to be harvested three years later. Now, genetically modified non-native Pacific oysters are "hatched" in a waterside factory and placed into growout bags, smothering and scouring the tidelands they are placed on. Other growers tie "oyster cages" together with floats which rise off of and fall back onto the tidelands with each cycle of the tides, scouring the sediments. A natural habitat is completely altered.

Grow Out Bags

Shellfish growers justify this by saying bags create "structure" and oysters provide "filtering". Were oysters left in place, and natural reefs allowed to develop as they had in the past, this may have merit. But they are not. Every two years, or sooner, this "structure" and any filtering provided are removed, leaving in its place scoured tidelands, soon covered by new growout bags and oysters hatched from as far away as Hawaii. This is not "wilderness" nor is it even natural. Nor is it the only impact from commercial shellfish operations which is occurring.
Penn Cove Processing Barge
In addition to the adverse tideland impacts the shellfish industry is so concerned about are the in water facilities which exist. Totten Inlet and Penn Cove are two areas where large mussel farms are operated. In Penn Cove, an in-water processing facility is used to clean and process mussels harvested from the near 50 rafts located in Penn Cove.

A recent permit for 58 mussel rafts in Thurston County was denied due to the EIS not adequately considering cumulative impacts. Among other things, dissolved oxygen levels below the rafts were significantly decreased. Shells dropping off from mussel die-off smothered the sediments below the rafts. Deposition of feces and pseudo-feces concentrated nutrients below the rafts. Spreading of non-native Gallo mussels into habitat of native mussels was occurring. All were issues not adequately addressed in the EIS and, in part, why the Hearing Examiner denied the permit.

CO2 and Ocean Acidification

Most recently, the Blue Ribbon Panel on Ocean Acidification described how CO2 is lowering the pH level in ocean waters and lessening the molecules necessary for calcification, resulting in hatcheries being unable to produce adequate amounts of seed. It also results in native species having fewer molecules to use for calcifying. The recommendation? Expand shellfish farming. The problem? The increase in densities of shellfish grown will use up even more of the diminished supply of molecules necessary for life by native species.

Their recommendation on limiting the primary source of CO2 exported to China, coal? "We are silent on that issue." Involvement of the farming/dairy/cattle industries on recommendations? Nothing because, as Bill Dewey reported to the PCSGA in January: "Ocean Acidification – Sustainable Fisheries Partnership will help identify participants for the Governor’s Blue Ribbon Panel." (January 2012 minutes of PCSGA meeting.) It seems Mr. Warren forgot to include them when he helped create the panel, even knowing they would be one of the primary targets of recommended actions.

Castles built of sand slip into the sea. The shellfish industry is finding their own "scientific" foundation slipping into the sea.

Get involved. Let President Obama and your congressional representatives know Governor Gregoire is not the best choice to replace Secretary Salazar, should he decide to leave.

Thursday, November 29, 2012

Drakes Bay Oyster Company Lease will Not be Renewed

Secretary of the Interior Ken Salazar has agreed that the Drakes Bay Oyster Company commercial shellfish farm is not compatible with Drakes Estero wilderness designation. As such the lease will expire November 30. Despite the immense resources of the Pacific Coast Shellfish Growers Association and the East Coast Shellfish Growers Association, it was clearly demonstrated that commercial shellfish aquaculture has significant adverse impacts.
[click here for article]

Drakes Estero

Tuesday, November 27, 2012

Why Does Drakes Estero Matter to the East Coast Shellfish Growers Association?

And why should you care?
Drakes Estero, Part of
Point Reyes National Seashore

Recently the East Coast Shellfish Growers Association (ECSGA) Director Bob Rheault sent out an email to members describing the National Park Services as being on a "crusade" to eliminate a commercial shellfish operation and having "fabricated evidence and harassed good, hard-working people in their effort to eliminate 60 jobs and half of California's oyster production."

"used against our industry for decades to come."
His real concern wasn't about jobs or the operation. It was about the EIS showing the very real adverse impacts the shellfish operation was having, and would continue to have, on the wilderness shoreline area of Drakes Estero. More important to Mr. Rheault was that information would be "used against our industry for decades to come."  [click here for the EIS]

Invasive Tunicates on Drakes Bay Oysters

Wilderness and the Lunny Family
When the Lunny family purchased the commercial operation they made a tactical business decision which included trying to convince the National Park Service they should renew a lease which they knew expired in 2012. They were aware the National Park Service did not consider the commercial shellfish operation fitting within the definition of "wilderness" and operations would cease.

Debris from the Commercial Operation

Established by Congress in 1964, the National Wilderness Preservation System was created to ensure some areas would be preserved and protected in their natural condition for the permanent good of the people. These areas would be designated wilderness areas, further defined as "an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation which is protected and managed so as to preserve its natural conditions." In 1976 it was decided that an area on Point Reyes, making up over 33,000 acres, would be designated "wilderness" or "potential wilderness", including Drakes Estero. Part of that decision included "efforts to steadily continue to remove all obstacles to the eventual conversion of these lands and waters to wilderness status." A major obstacle in achieving this goal was the shellfish operation whose lease expired in 2012.

Drakes Bay Oyster Company

In business there is risk. Sometimes it is out of our control. Sometimes it is within our control. When the Lunny Family purchased the commercial shellfish operation they were fully aware of the risk, including the fact that the lease expired in 2012. Their hope was they would be able to muster allies, including members of the shellfish industry, to help convince the Federal Government that somehow their commercial operation did, in fact, fit the definition of "wilderness." It does not.

Why the Shellfish Industry Cares so Much
As part of the decision process which the National Park Service used, an Environmental Impact Statement was required. In that EIS the NPS analyzed the various alternatives and what impacts those alternatives contained. Included in that analysis were impacts from the non-native Pacific Oyster and Manila Clam encroaching into native species' habitat; spreading of the non-native tunicate Didemnum vexillum from the shellfish farm operation; noise; visual; and erosion/accretion from the various structures used by the operation. The EIS was clear in its conclusions about the continued operation:
  • It would result in long-term unavoidable adverse impacts on eelgrass, wetlands, wildlife and wildlife habitat (benthic fauna, fish, and birds) due to continued disturbance of sediments in Drakes Estero by another 10 years of DBOC (Drakes Bay Oyster Company)  motorboat use.
  • Long-term unavoidable adverse impacts to the benthic fauna would result from the continued cultivation of nonnative species (Pacific oysters and Manila clams...) in Drakes Estero. [adverse impacts included were the establishment of nonnative breeding populations; substrate for the establishment and spread of the nonnative invasive tunicate Didemnum vexillum; and, adverse impacts on eelgrass]
  • Noise would disrupt the bilogical activity of birds, such as foraging and resting behavior, potentially leading to a reduction in fitness and reproductive success. 
  • The NPS would be unable to create the congressionally designated wilderness area.

Why does it matter to Puget Sound?
NOAA and Governor Gregoire, through lobbying from the shellfish industry at a national and state level, have created the National and State Shellfish Initiatives. Through these programs, immense pressure is being put on agencies to allow for the significant expansion of the shellfish industry along the shorelines and in the waters of Puget Sound. Primary species supported by the programs include the nonnative Pacific oysters and Manila clams, noted in the EIS as having a long-term and significant adverse impact, as well as the nonnative Gallo mussel. In addition, geoduck are being planted in densities and in areas they do not naturally grow, higher in the tidelands, through the use of PVC structures and "nurseries."

"The Wild Olympics are our common ground.
But the tidelands are mine."
At the same time, there is a major effort being put forth to create a "Wild Olympics" which would expand the wilderness on the Olympic Peninsula. Not yet included in that effort is the recognition that tidelands play as important a role, if not more so, than the rivers and forests being proposed for inclusion. Instead, these tidelands are being looked at as "shellfish factories" which the proposed wilderness areas will protect. In that function they are being smothered with grow-out bags; filled with PVC pipes, placed every square foot; and covered with netting. All altering the habitat supporting native species.

The nearshore environment is being impacted by far more than upland development. It is now the shellfish industry which is being brought under scrutiny, as it should be. The tone and attitude are reflected in the following email sent to the East Coast Shellfish Growers Association. Will this attitude and tone be what guides the decision on Drakes Estero and the future of Puget Sound's tidelands?

(From Bob Rheault, Executive Director of the East Coast Shellfish Growers Association to its members)

for the past five years I have periodically shared with you the tawdry details of the crusade by the National Park service to eliminate the oyster farm in Drakes Estero outside San Francisco. The NPS has falsified data, hidden exculpatory evidence, fabricated evidence and harassed good, hard-working people in their effort to eliminate 60 jobs and half of California's oyster production.

In what should beheld up as a sterling example of sustainable food production in harmony with nature, we see instead a farm being vilified by misguided government scientists and administrators.

What is worse is that the shoddy, misleading "science" being used to vilify these good people will be used against our industry for decades to come. We must stand up and defend these guys. We have evidence of fraud, data manipulation, incompetence, violations of national scientific integrity policies. Yet the NPS refuses to pull any of their discredited publications down.

Monday, November 26, 2012

What causes shellfish beds to close? What happens when they open?

In Saturday's Kitsap Sun is an article about the Puget Sound Partnership, now in its 5th year, measuring the health of Puget Sound and improvements with various indicators [click here for article]. Well known in developing any strategy to address an issue is that measurable points have to be pre-determined in order to show strategies implemented are successful in their implementation. One of the primary indicators now being used is to restore 10,800 acres to "harvestable" condition by 2020 [click here for "indicators"]. A recent report shows 1,384 acres have been opened to shellfish farming.

Shellfish beds are closed for long periods by the Department of Health for one primary reason: measurement of fecal coliform above a certain level over a period of time. Immense resources are expended by the Department of Health each month to obtain water samples from Puget Sound which are, in turn, analyzed. If elevated levels are found over a period of time there begins a determination of what the source is. Typically the "low hanging fruit" is assumed to be defective septic systems, dairy or cattle farms.  Other sources include seals, Orca, and waterfowl. The percentage of each is an ongoing challenge to determine.

Farmland adjacent to Samish Bay

For years closures have been addressed in a number of ways. If failing septic systems are suspected, counties are asked to send out inspectors to individual parcels for testing. Counties are also able to create, in some cases mandated, "shellfish protection districts" such as Oakland Bay, Burley Lagoon and Henderson Inlet [click here for information on how shellfish districts are created]. Waste water treatment plants can be upgraded. Dairy and cattle farms divert waste from streams. In Thurston County, residents along part of Henderson Inlet will be assessed a fee if they own a septic system. All incrementally help to improve levels of fecal coliform.

What Else Causes Closure?
Closure is not only tied to fecal coliform. Shellfish being "filter feeders" graze on whatever is floating by in the water. Important to shellfish consumption is the naturally occurring bacteria Vibrio parahaemolyticus (Vp), a bacteria which lies dormant in sediments until warmer summer months trigger a bloom. In addition to bacteria, phytoplankton also create unsafe shellfish. Diseases contracted toxins created by phytoplankton include Diarrhetic Shellfish Poisoning (DSP) and Paralytic Shellfish Poisoning (PSP).
Vibrio Parahaemolyticus

In the case of Vp, there is an annual outbreak every summer which each year causes illness from oyster consumption. Washington and Texas lead the nation in illness from Vibrio. Last summer, Samish Bay, Hood Canal, Totten Inlet, Hammersley Inlet, and Oakland Bay were all closed due to Vp.
Life Cycle of Alexandrium Bacteria

DSP in Puget Sound had not been been considered a problem until last year and is now of such concern the Department of Health recently purchased a $350,000 testing unit which allows faster detection and closure of shellfish beds. The increase in concern is also due, in part, to new studies suggesting that exposure to low levels of DSP may increase the risk of cancer.

Last summer, a family was hospitalized after contracting PSP from shellfish harvested from Discovery Bay. The Public Health Officer commented, "It's noteworthy in terms of the severity of the symptoms." Recent testing found unsafe levels of PSP toxin in geoduck from intertidal areas of Discovery Bay and subtidal tracts, resulting in their closure to commercial harvesting.

What does it mean?
One result of Puget Sound's water being safe to grow shellfish is the safe consumption of shellfish growing naturally on the tidelands as they have for millennium. Another is to profit from growing shellfish on the tidelands. Profits from the latter have driven many efforts to achieve a more healthy Puget Sound. However, it is also the latter which has transitioned from a historical role of being a benign "preferred use" of the tidelands as the Shoreline Management Act envisioned. To many, as the Shoreline Master Programs are being updated, it is becoming clear the fragmentation and piecemeal development of the shorelines should now be focused on the shellfish industry.

Being a "preferred use" no longer means having a free hand to use whatever structures and methods there are at hand to convert tidelands to a shellfish farm. Reopening shellfish beds which have been closed should not mean a wholesale conversion to monolithic populations which would not survive without the current structures used in shellfish farming. Restoration of natural shellfish beds is important. It is why the measurements of what makes up the "Human Qualities of Life" are so critical to develop, now.


Tuesday, November 20, 2012

Thurston County on Diminished Property Values from Geoduck Farms

"Affected property owners may request a change in valuation for property tax purposes."
Thurston County's Resource Stewardship Council, in recommending approval of three geoduck farm permits in Henderson Inlet, states to property owners impacted by these geoduck farms, that reducing the value in their property is how to achieve the "balance" between geoduck farming and its impact on adjacent property values. For full staff reports on the Arcadia Point Seafood and Taylor Shellfish permits, click here (Note: Files are each ~35mb in size.)
To get a sense of what impact this reduction in property values will have on Thurston County's property taxes collected, and budget, see below. At the end is an example of "representation without taxation" where an existing geoduck farm and upland property are valued at $85,000 (taxes = $1,150) and adjacent properties are valued between $581,000 to $893,000 (taxes = $5,620 and $5,440, respectively). Another geoduck farm is proposed on the Wheeler owned property, adjacent to the existing geoduck farm.

There was no analysis of what this recommendation will result in. It presents another clear example of why a cumulative impacts analysis should be required before these permits are issued.
Existing Geoduck Farms
in Thurston County
(As reported by shellfish growers in 2006)
Nisqually Reach
(existing geoduck farms)
Henderson Inlet
(existing and currently proposed geoduck farms)
Totten Inlet, Carlyon Beach Area
Eld Inlet
(existing geoduck farms, south of proposed "Xia" geoduck farm)
Values of existing geoduck farm
and adjacent properties
(Note: Wheeler property/proposed Xia geoduck farm 
is valued at $82,000.  Taxes collected = $446)

Monday, November 19, 2012

Thurston County Commissioners Affirm Mussel Farm Permit Denial

"...the law requires an adequate analysis of cumulative impacts before a SSDP permit may be issued in this case."

Thurston County Commissioners have affirmed the Hearing Examiner's denial of Taylor Shellfish's Shoreline Substantial Development Permit application for a 58 raft mussel farm in Totten Inlet. They agreed that denial based on an inadequate analysis of cumulative impacts was correct[click here for decision].

It quotes from a recent Shoreline Hearing Board decision:
"...consideration of potential cumulative effects and precedential effects is warranted in any case where there is proof of impacts that risk harm to habitat." Coalition to Protect Puget Sound Habitat v. Pierce Co. and Longbranch Shellfish, LLC, SHB No. 11-019-2012

Cancel or Appeal?
Taylor Shellfish may appeal the decision to the Shoreline Hearing Board or they may simply cancel the permit application and wait for Mason County to update its Shoreline Master Program. Based on current policy in Mason County and industry's heavy involvement in their SMP update process, Taylor's 58 rafts will most likely be allowed on the Mason County side of Totten Inlet, with little to no permitting requirements.

Become Engaged
The public cannot appreciate the amount of money Taylor Shellfish, the Pacific Coast Shellfish Growers Association, and other "benefactors" put into minimizing regulatory oversight. The public cannot appreciate how much taxpayer money is spent to support the industry, whether it be the Department of Health's monthly monitoring of waters or funding for hatcheries.  The dairy, agriculture, and timber industries all incur expenses to help the shellfish industry, and pay a far greater percentage in taxes.

All the while, owners of Taylor Shellfish and Arcadia Point Seafood, among others, generate over $1 million/acre in profits from geoducks. That money in turn pays for attorneys, "scientists", and lobbyists to ensure they are able to continue generating wealth for themselves at the expense of Puget Sound's tidelands and waters, and at the expense of taxpayers.

Modern shellfish aquaculture is transforming Puget Sound's habitat. Once converted, that habitat does not recover. The public needs to become engaged in the current Shoreline Master Program updates.

Thursday, November 15, 2012

Taylor Mussel Farm Permit Appeal: Audio Recording of Appeal is Available

When is enough too much?
Current mussel farm in Totten Inlet

An audio recording of Taylor Shellfish's appeal on November 14 of their mussel farm permit being denied before the Thurston County Commissioners is available. [click here] Included is APHETI's attorney, David Mann with Gendler Mann, testifying why cumulative impacts should be considered and why the Hearing Examiner's denial of the permit was correct. A decision by the commissioners will be made by November 27.

Presented at the hearing was why cumulative impacts should, or should not, be considered under both the Shoreline Management Act and Thurston County's Shoreline Master Program. As noted in earlier posts, the legal interpretation of the SMA and counties SMP's allows for discretion in determining whether cumulative impacts should be considered. In the case of Taylor's proposed mussel farm, there is no question that cumulative impacts should be closely analyzed.

Structures for oysters

In the case of aquaculture, it is not "aquaculture" itself which is in question. What is in question are the current methods and intensity. While some forms of "aquaculture" may be considered a "preferred use" of the shorelines, it does not mean any and all methods should be permitted to operate at any time of the day. It most certainly does not mean cumulative impacts should be ignored.

Sunday morning, 7AM
Taylor's geoduck farm in Hammersley Inlet

Taylor would have us believe the intensity of today's operations have not changed from when the SMA and Thurston County's SMP were created, in 1971 and 1990, respectively. And, if they have, "filtering" provided by shellfish more than makes up for any fragmentation of habitat which may have occurred, is occurring, and will occur.

Oyster bags in Totten Inlet

In fact, "aquaculture" has changed dramatically in that time and there is intense pressure for it to be allowed to expand, with little oversight. Cumulative impacts to the aquatic habitat have taken place and will take place.

One of many "barges" used
to transport geoduck

In the case of Taylor's mussel rafts, the shellfish "production" found under one 30' X 34' raft is equivalent to what used to be produced on one acre of tidelands (25,000 pounds). In the case of geoduck, over 120,000 pounds are produced on one acre, where they never used to grow in that density, through the use of PVC pipes, rebar and netting. Currently, grow-out bags and "cages" for both oyster and clam have increased the density of shellfish produced. Willapa Bay has had native ghost shrimp eradicated through chemical application and now a permit for the application of the herbicide imazamox to eradicate eelgrass is being considered. In short, there has been a dramatic change in production methods and intensity which has occurred. Put together, the cumulative impact is beyond significant.

PVC pipes for geoduck farm

You cannot argue that because "aquaculture" was once considered a "preferred use" and is "water dependent" that it means "anything goes." In fact, Thurston County's current Shoreline Master Program is clear in its intent to protect water quality and aquatic habitat, not just for "aquaculture" and not just from upland development. Its primary goal is clearly defined in Section V's Regional Criteria, Part B:

Protection of water quality and aquatic habitat is recognized as a primary goal. All applications for development of shorelines and use of public waters shall be closely analyzed for their effect on the aquatic environment. Of particular concern will be the preservation of the larger ecological system when a change is proposed to a lesser part of the system, like a marshland or tideland.

The Shoreline Management Act was passed and approved by voters to prevent the fragmentation of shoreline habitat from piecemeal development. Corporate shellfish companies and current methods have become that process which is fragmenting the shoreline habitat and what needs to have far greater regulatory oversight applied. Thurston County should be where that process begins and where an analysis of cumulative effects begins.

If you want to help ensure cumulative impacts from corporate shellfish methods are analyzed, contact APHETI  (Association to Protect Hammersly, Eld and Totten Inlets).

Wednesday, November 14, 2012

Thurston County Geoduck Farms, Permit Hearing November 26

Shoreline Substantial Development Permit Hearing for 3 proposed geoduck farms 
November 26, 10AM
Expo Center, Thurston County Fairgrounds
3054 Carpenter Road
Comments by email: peterscs@co.thurston.wa.us by 4PM, November 23
Additional permit information: [click here] (Note: Complete permit documentation will not be put up until ~ 1 week prior to the decision.)

Existing and proposed geoduck farms
Henderson Inlet
(click on photo to enlarge)
Almost 3 years ago Taylor Shellfish and Arcadia Point Seafood were told by Thurston County their proposed geoduck farms would require a Shoreline Substantial Development Permit. Taylor and Arcadia, instead of applying, chose to pay for appealing all the way through Superior Court. Their decision was based primarily on an opinion by Attorney General McKenna which said their PVC pipes, netting and rebar necessary for a geoduck farm was not a "structure." In October of 2011, the Superior Court agreed with the Hearing Examiner who said Attorney General McKenna's opinion was legally flawed and they would need to apply for a permit.
[click here for flawed AG Opinion]
[click here for Superior Court decision]

On November 26 the Thurston County Hearing Examiner will listen to testimony on whether the three geoduck farms (Thiesen, McClure, and Lockhart) meet the requirements of Thurston County's current Shoreline Master Program. As seen in the recent permit decision for Taylor's mussel farm in Totten Inlet, the Examiner has the discretion to determine whether cumulative impacts have been adequately addressed. If not, the Examiner can ask for additional information, including an Environmental Impact Statement, to determine whether granting a permit for these three farms is warranted.
Totten Inlet

An individual farm may be inconsequential. But when seven adjacent commercial developments are being operated a far more significant fragmentation of shoreline habitat and use occurs. When seven adjacent operations are taking place, run by separate companies with different planting rotations, a far more continuous pattern of disruption will occur, day and night. When seven adjacent farms are allowed to be permitted there is little to prevent future applicants from pointing to those approved permits in support of theirs.
Wilson Point, Harstine Island

Cumulative impacts from corporate shellfish farming do matter, they are occurring, and they are growing. Nothing in the SEPA approval for these farms considered adjacent farms being operated simultaneously. While the hearing has combined 3 of the 5 proposed farms, there is nothing to indicate simultaneous operation of seven adjacent farms has been considered. The Examiner has the discretion to look at the broader picture and determine whether greater analysis of cumulative impacts is required. It should be.

Monday, November 12, 2012

Taylor Shellfish Mussel Farm Appeal, Nov 14

November 14, at 4PM
Thurston County Courthouse
Building One, Room 280
Before Thurston County Commissioners

Taylor Shellfish will appeal the mussel farm permit denial before the Thurston County Commissioners Wednesday, November 14. When Taylor Shellfish was asked to provide additional information to the Hearing Examiner, Mr. Thomas Bjorgen, to address cumulative impacts, Taylor instead asked Mr. Bjorgen to deny the permit, which he did. [click here for mussel farm documents]

Now, Taylor has appealed the denial they requested to the County Commissioners. It will be a public hearing, but no new evidence nor public testimony will be allowed. At the hearing the County Commissioners will be asked to consider the legal arguments supporting Taylor's position, the Hearing Examiner, and APHETI (Association for the Protection of Hammersely, Eld and Totten Inlets). APHETI's attorney will testify in support of the decision to deny the permit.

Taylor's primary concern, and why they asked the Examiner to deny the permit, is their fear of what an analysis of cumulative impacts from expanding commercial shellfish operations will show. They should be concerned.

Sunday, November 11, 2012

Blue Ribbon Panel on Ocean Acidification: Facing Godzilla or Swatting Flies?

"The panel itself is silent on that question."
Brad Warren, panel member,
when asked about coal exports to China. 
"It's big! It's terrifying!"
Brad Warren* on Ocean Acidification
*Brad Warren is with Sustainable Fisheries Partnership
who, with Bill Dewey of Taylor Shellfish, helped to
create the "Blue Ribbon Panel" on Ocean Acidification.
On November 27, Governor Gregoire's Blue Ribbon Panel on Ocean Acidification (OA) will release recommendations on what Washington should do about OA. OA was brought to the Governor's awareness by the shellfish industry's Bill Dewey with Taylor Shellfish, and Brad Warren with Sustainable Fisheries Partnership. Taylor Shellfish had been experiencing hatchery failures in producing the non-native/genetically modified triploid Pacific oyster. Brad Warren had been trying since the mid-2000's to make people aware of CO2's link to OA and, initially, its impact on the salmon industry. Oyster hatchery failures is now the conduit being used by Mr. Warren to build awareness of CO2 emissions and OA. [click here for one of Mr. Warren's first presentations].

What will the perception of the public be when the panel releases its recommendations? A truly meaningful "attack" on Godzilla or something far less? [click here]

At a meeting on OA in 2011, Norm Sims called for "actionable advice" agencies could take. Three weeks later, Mr. Dewey and Mr. Warren were able to convince Governor Gregoire OA should be made part of her "Shellfish Initiative." [hear Mr. Warren's presentation on meeting with Bill Dewey]. The "Blue Ribbon Panel" on Ocean Acidification was created and made part of the Washington Shellfish Initiative, announced in December of 2011. Its task: to create "actionable advice" on which government agencies could act to address OA, tied directly CO2 emissions, and in turn climate change. [read Charter here]

Hurricane Sandy, October 29

November 27 those recommendations will be issued. At hand is the opportunity for the panel to present actions which are truly meaningful, locally, nationally and internationally. Many people are watching. Ocean Acidification and its cause - elevated levels of CO2 emissions - is real. Tied directly to it is climate change, its effect most recently seen on the east coast.

Whether those recommendations will in fact face up to "Godzilla" or simply be perceived as swatting at flies already being dealt with remains to be seen. Will calling for further "actions" to reduce local inputs of nitrogen be more effective than those already in place? Will calling for preservation of aquatic vegetation while spraying Willapa Bay to eradicate eelgrass be taken seriously?  How does dramatically expanding shellfish grown in Puget Sound help when calcifying agents, already diminished by CO2, will be used up by them at the expense of other species? Is calling for a tax on miles driven to reduce CO2 more effective than telling China Washington will not allow hundreds of tons of coal to be exported until they limit their emissions?

The panel and incoming Governor Inslee have an opportunity to make a meaningful difference on CO2 emissions, climate change and Ocean Acidification. They risk being perceived as simply a tool to further the gains of others. When asked about their stance on coal exports to China at the Northwest Straits annual meeting, their answer: "The panel itself is silent on that question."  [hear the response to this first, difficult to hear question, here]

Norma Smith, Representative for the 10th District and also a panel member was not silent and said: "This is a global issue and we have to engage with our Pacific Rim neighbors because the problem is upwelling."

Saturday, November 3, 2012

Mason County Shoreline Master Program: Only to Protect Local Shellfish Jobs?

Next meeting: November 14, 2012; 9:00 AM to12:00 PM; Public Works Building - 100 W Public Works Drive; Discussion Item: Draft SMP
Contact: LaJane Schopfer  lajanes@co.mason.wa.us,  360-427-9670 X408
600Hp engine exhaust discharged
directly into the waters of Puget Sound
with wakes eroding the shoreline.

Is the purpose of Mason County's Shoreline Master Program (SMP) update to "keep waters clean and healthy" in order to "protect local shellfish industry related jobs"? According to a recent post card from Washington State University Extension on the SMP update, mailed to over 10,000 shoreline residents, it would seem that way.

Nowhere in the mailing is the Shoreline Management Act's (SMA) goal of preventing the "uncoordinated and piecemeal development of the state's shorelines" to be found. Nowhere is the inclusive "fostering all reasonable and appropriate uses" found. Instead we are led to believe its primary purpose is to protect the shellfish industry, contrary to the legislative findings of the SMA, RCW 90.58.020 (see below).

Harstine Island Geoduck Farm

Mason County's promotion of the Shoreline Master Program as clearly favoring the shellfish industry is no better example of how adept the corporate shellfish industry is in using the political process for its own gain. Immense profits generated from geoduck farming create funds to pay for attorneys, "government outreach" employees, and public relation firms. They in turn craft shoreline regulations through local political influence allowing tideland structures for "aquaculture" to be placed in the tidelands with little to no regulatory oversight, yet severely restrict other reasonable development of any other shoreline use, recreational or otherwise. They are relentless in their push back on any oversight (e.g., Kitsap County has just received a third "re-write" of their SMP update from attorneys representing the shellfish industry).

"You can only see the tubes 20% of the time."

What gain is found in preserving the nearshore environment when the adjacent tidelands are being smothered with nets, grow-out bags and PVC tubes? What gain is there in restricting recreational floats and docks when mussel rafts, geoduck nurseries and oyster rafts are allowed to proliferate? Are a few shellfish industry related jobs worth an unregulated transformation of the entire intertidal ecosystem where native species are displaced by non-native species, or are eradicated with chemical sprays? Should the aquaculture industry be prioritized over all other uses of the shoreline? Mason County has been convinced it should be and will allow it to be so unless the public engages in the process.

The Shoreline Management Act RCW 90.58.020

The legislature finds that the shorelines of the state are among the most valuable and fragile of its natural resources and that there is great concern throughout the state relating to their utilization, protection, restoration, and preservation. In addition it finds that ever increasing pressures of additional uses are being placed on the shorelines necessitating increased coordination in the management and development of the shorelines of the state. The legislature further finds that much of the shorelines of the state and the uplands adjacent thereto are in private ownership; that unrestricted construction on the privately owned or publicly owned shorelines of the state is not in the best public interest; and therefore, coordinated planning is necessary in order to protect the public interest associated with the shorelines of the state while, at the same time, recognizing and protecting private property rights consistent with the public interest. There is, therefor, a clear and urgent demand for a planned, rational, and concerted effort, jointly performed by federal, state, and local governments, to prevent the inherent harm in an uncoordinated and piecemeal development of the state's shorelines.

It is the policy of the state to provide for the management of the shorelines of the state by planning for and fostering all reasonable and appropriate uses. This policy is designed to insure the development of these shorelines in a manner which, while allowing for limited reduction of rights of the public in the navigable waters, will promote and enhance the public interest. This policy contemplates protecting against adverse effects to the public health, the land and its vegetation and wildlife, and the waters of the state and their aquatic life, while protecting generally public rights of navigation and corollary rights incidental thereto.

The legislature declares that the interest of all of the people shall be paramount in the management of shorelines of statewide significance. The department, in adopting guidelines for shorelines of statewide significance, and local government, in developing master programs for shorelines of statewide significance, shall give preference to uses in the following order of preference which:

(1) Recognize and protect the statewide interest over local interest;

(2) Preserve the natural character of the shoreline;

(3) Result in long term over short term benefit;

(4) Protect the resources and ecology of the shoreline;

(5) Increase public access to publicly owned areas of the shorelines;

(6) Increase recreational opportunities for the public in the shoreline;

(7) Provide for any other element as defined in RCW
90.58.100 deemed appropriate or necessary.

In the implementation of this policy the public's opportunity to enjoy the physical and aesthetic qualities of natural shorelines of the state shall be preserved to the greatest extent feasible consistent with the overall best interest of the state and the people generally. To this end uses shall be preferred which are consistent with control of pollution and prevention of damage to the natural environment, or are unique to or dependent upon use of the state's shoreline. Alterations of the natural condition of the shorelines of the state, in those limited instances when authorized, shall be given priority for single-family residences and their appurtenant structures, ports, shoreline recreational uses including but not limited to parks, marinas, piers, and other improvements facilitating public access to shorelines of the state, industrial and commercial developments which are particularly dependent on their location on or use of the shorelines of the state and other development that will provide an opportunity for substantial numbers of the people to enjoy the shorelines of the state. Alterations of the natural condition of the shorelines and shorelands of the state shall be recognized by the department. Shorelines and shorelands of the state shall be appropriately classified and these classifications shall be revised when circumstances warrant regardless of whether the change in circumstances occurs through man-made causes or natural causes. Any areas resulting from alterations of the natural condition of the shorelines and shorelands of the state no longer meeting the definition of "shorelines of the state" shall not be subject to the provisions of chapter
90.58 RCW.

Permitted uses in the shorelines of the state shall be designed and conducted in a manner to minimize, insofar as practical, any resultant damage to the ecology and environment of the shoreline area and any interference with the public's use of the water.

Wednesday, October 31, 2012

Spraying Imazamox on Japanese Eelgrass, EIS/Permit Comments Due Nov 2

Comments on the Department of Ecology's proposal to issue a permit to allow spraying imazamox onto Japanese eelgrass in Willapa Bay are due November 2 by 5PM.
[click here for complete information]

Ecology prefers to have comments submitted by email to: EelgrassComments@ecy.wa.gov; or,     
You may submit comments to:    
Kathy Hamel
Washington State Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600

Is this non-native Manila clam more important
than the habitat functions of Japanese eelgrass?


Introduced into Washington's waters by the shellfish industry in the early 1900's, Japanese eelgrass has become an established species supporting a diversity of life. Migratory waterfowl use it as a source of energy as they pass by. Forage fish use it for protection and Herring for spawning. Sediments are stabilized through its root system. CO2 and nitrogen are removed from the waters and sediments, helping to lessen ocean acidification.
[click here for a 12mb file on eelgrass meadows by USFWS]

For years these critical habitat functions were recognized by the Washington Department Fish and Wildlife. It was listed on their Priority Habitat Species list. WDFW Hydraulic Code Rules still do not distinguish different species of eelgrass, noting:  "WAC 220-110-250(3) "The following vegetation is found in many saltwater areas and serves essential functions in the developmental life history of fish or shellfish:
      (a) Eelgrass (Zostera spp [
spp is used to denote multiple species, not single species]); " [
click here for WAC 220-110-250, Saltwater habitats of special concern]

The Department of Ecology's Shoreline Master Program Updates guidance manual notes: "The SMP Guidelines currently do not distinguish between protection requirements for native (Zostera marina) and non-native (Zostera japonica) eelgrass. Eelgrass is considered a critical saltwater habitat in the SMP Guidelines per WAC 173-26-221(2)(c)(iii) and requires "a higher level of protection due to the important ecological functions they provide." WAC 173-26-241(3)(b)(i)(C) states that aquaculture should not be permitted where it would adversely impact eelgrass." (page 10) [click here for manual]

Shellfish Politics: Minimize Public Involvement

Despite the critical habitat functions being recognized and codified in Washington law, Bill Dewey with Taylor Shellfish was able to convince the Director of Washington Department of Fish and Wildlife that because Japanese eelgrass was "non-native" it should be removed from their Priority Habitat List. So doing opened the door for the Noxious Weed Board to list it as a "Class C" Noxious Weed.

The importance of this to the shellfish industry is found in the Noxious Weed Board minutes from November 2, 2011: "...the growers explained that there will be a lot of scrutiny when they use chemical or mechanical measures to control Japanese eelgrass...they can point to the listing to support the concern that a noxious weed is having ecological/economic impacts." [click here for minutes] (Note: Pacific County recently requested the Noxious Weed Board to expand application to all tidelands, in part to help "shellfish gardens", a term promoted by the shellfish industry for non-commercial shellfish planting.)

In executing the strategy above, the shellfish industry was able to minimize public hearings before the legislature, something required to change the various WAC's which do not distinguish between Japonica and Marina, considering all eelgrass to be important. Below is an internal WDFW email detailing the strategy, noting "much discussion with industry leader Bill Dewey." His concern? "Industry opinion" wanted to avoid a "...public rule making process that would target industry as promoting reduced protection of eelgrass in the state."

The Current Proposal: Imazamox for Everyone (almost)

After the shellfish industry was able to convince WDFW to remove Japonica from its Priority Habitat Species list and the Noxious Weed Board to list it as a Class C weed on commercial shellfish farms, their focus turned onto the Department of Ecology. The shellfish industry provided DOE with stories of "small manila clams." They provided a "white paper," commissioned by the Pacific Shellfish Growers Association, describing an "invasion." With "support" provided by the Noxious Weed Board's action, the shellfish industry was able to convince DOE to issue a permit proposal which would have allowed for the application of the herbicide imazamox onto Japanese eelgrass wherever there was a "commercial shellfish farm", a term as yet undefined,

Agencies and the public all expressed concerns, some questioning whether growing a non-native manila clam was so important it should allow for a non-discriminate* herbicide to be applied. (* Imazamox will kill any aquatic vegetation it comes in contact with.) As a direct result of these comments DOE scaled back its permit to allow for application only on commercial shellfish farms in Willapa Bay and that an Environmental Impact Statement be created.

November 2, comments are due on whether this is something to consider, and if so, what the limitations should be.

Non-native Species and Self Induced Problems

One of the significant questions for agencies to consider is the role the shellfish industry has played in transforming Willapa Bay into what we see today. Their direct actions created self induced problems: over harvesting lead to non-native oysters being introduced and with them Spartina and Japanese eelgrass. With over harvesting, the structured reefs of native Olympia oysters were eliminated. The shells which oysters used to set on disappeared, followed by the expansion of the Ghost shrimp population, causing softer sediments. The shellfish industry initiated spraying of chemicals throughout Willapa Bay to get rid of Spartina and Ghost shrimp. Elimination of Ghost shrimp caused sediments to firm, which also created a habitat for Japanese eelgrass to expand into. Now they wish to spray Japanese eelgrass because they claim the non-native manila clams are not growing as large as they used to. All of this, where for the first time in 8 years a natural set of oysters has occurred. What will the addition of imazamox and hundreds of acres of Japanese eelgrass it has killed do to the water chemistry?

At some point agencies will be asked how much they are going to allow the shellfish industry to transform Washington's marine habitat for their economic benefit. If non-native Japanese eelgrass is going to be eliminated, why not non-native Pacific oysters and Manila clams? Both of those non-native species have taken over the habitat of native Olympia oysters and Little neck clams. Is it unreasonable to consider a permit for the erradication of those non-native species?

Get involved. The shellfish industry is. Comments are due November 2 by 5PM.