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.