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

Email: Kathy.Hamel@ecy.wa.gov

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

Background

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.



Oct 31: Mason County SMP Update on In Water Structures

October 31, 2012
9:00 AM to12:00 PM Public Works Building
100 W Public Works Drive
Discussion Item: Boating Facilities, In-water structures, Habitat Restoration, Beach Access Structures; Chapter 15

October 31 Mason County will hold Citizens Advisory Committee meeting to discuss the updated Shoreline Master Program. Items to be discussed will include in-water structures. Regulating structures used for aquaculture (netting, pvc piping, grow-out bags, mussel rafts, etc.), docks, stairs or floats will be discussed. Whether developments related to aquaculture will receive the same scrutiny as other shoreline activities is to be discussed.

• The shellfish industry notes "shellfish filter the water." Not noted is before they reach a size where filtering becomes meaningful they are harvested.
• The shellfish industry notes "structure" is created when items are placed into the tidelands. Not noted is the "structure" is destroyed each grow-out cycle when they are removed.
• The shellfish industry notes "shellfish need clean water to grow." Not noted is it is not shellfish which make the water clean, it is controlling what enters the water (e.g., Lake Washington is not clean because of shellfish).
• The shellfish industry notes "nitrogen from lawns causes algae blooms." Not noted is Lake Washington's shoreline is far more developed than Mason County's yet the water in Lake Washington is not impacted from fertilized gardens and lawns.
• The shellfish industry notes "aquaculture is a preferred use." Not noted is being a "preferred use" is not an open door to place whatever they want in the tidelands.

Oyster Cages

 

Grow-out Bags

 

PVC Pipes for geoduck

 

County Shoreline Master Programs are meant to balance uses of Puget Sound's shoreline at the local level. The shellfish industry believes it should be allowed to place structures and perform activities of any type, at any time, and in any place they wish. As Diane Cooper with Taylor Shellfish notes, there are  times when corporate shellfish aquaculture is not compatible with shoreline development.

 

 



Taylor Mussel Farm: Are Future Projects Contemplated?

Taylor Shellfish has submitted its response to the Thurston County Commissioners on why the Hearing Examiner's denial of a shoreline permit for their 58 raft mussel farm should be reversed. [read appeal papers here] (Note: It was Taylor Shellfish themselves who asked for this denial.) Their defence rests within a cloud of supposition, believing there are no future projects being contemplated. With the help of Governor Gregoire, they have shot themselves in the foot.

Symptomatic of "Romnesia" they have forgotten a key piece of evidence they submitted and fought to keep as part of the record at the hearing in support of this permit being granted: the Washington Shellfish Initiative. Its importance was reiterated in their initial appeal where they also pointed to the Shoreline Hearings Board's accepting it as fact and of significance.

That initiative is clear in its contemplation of future projects. As Taylor's appeal states, the initiative calls for "Expanding, promoting and improving shellfish aquaculture in Washington." They go further to note the Shoreline Hearings Board accepting it as evidence and belief in its importance, quoting them as saying aquaculture's importance is "emphasized by the Washington Shellfish Initiative..."

Taylor's Current Mussel Farm

Yield: ~800,000 pounds per year.

Jim Gibbons/Paul Taylor: Spain grows 600 million

pounds in an area the size of south Puget Sound.

Further evidence of "contemplation" focused specifically on mussel farms is found in testimony before the Senate Environment Committee by Jim Gibbons, owner of Seattle Shellfish. In that testimony he brings up a conversation he and Paul Taylor (co-owner of Taylor Shellfish) had while "on a ski lift." In that testimony Mr. Gibbons points out how Spain is growing over 600 million pounds of mussels in an area the size of south Puget Sound where "only" 20 million pounds of shellfish are grown. Taylor's proposal of 58 rafts would yield 1 million pounds. Contemplation of further projects is clearly established.
[click here for Seattle Shellfish testimony before the Senate Environment Committee]

Why is contemplation important? As Taylor's attorney notes, appellate and Shoreline Board cases note "important factors to consider in deciding whether to exercise the discretionary authority to evaluate cumulative impacts for a SDP application include, among other things, whether...similar projects in the area are pending or contemplated and whether such projects would be approved under applicable criteria."

The Washington Shellfish Initiative was created by the Governor to aid in the expansion of the shellfish industry. Part of that initiative is streamlining permits for additional projects. Mason County has already stated its intention to streamline mussel raft permits as part of its updated SMP. Evidence submitted in support of this mussel farm is being used to support current streamlining efforts. To believe projects similar to this are not being "contemplated" is naive. The Hearing Examiner was correct in denying this permit because cumulative impacts were not adequately analyzed, something the Commissioners will agree with.

What can you do if you care? Help support APHETI in their fight to help ensure Puget Sound's development considers cumulative impacts from shellfish aquaculture. [click here for APHETI's web site]

Burley Lagoon Kicked Down the Road by the City of Gig Harbor

The City of Gig Harbor has decided inclusion of Burley Lagoon in their Shoreline Master Program (SMP) would be politically problematic. Instead, they will let Pierce County's SMP control its development.

Plans to annex Burley Lagoon allowed for its inclusion within the Urban Growth Area, and with it, the opportunity for true local involvement in shaping Burley Lagoon's future through the SMP update process. It is unlikely Pierce County will be as responsive to citizens' concerns. The "dilution of influence" a small community has within a larger one is well known. More important is the amount of time and money Taylor Shellfish has devoted to crafting Pierce County's updated SMP to favor their transformative shoreline developments, including geoduck farming.

The new Burley Lagoon

[click here for 30mb file of written public comments to the City of Gig Harbor, none in favor of expanding aquaculture activities in Burley Lagoon] Note: On page 231 is a comment by Gary Ritchie, Ph.D., on a presentation by a Dr. VanBlaricom on geoduck farming's impact on the benthic community, in part relied on by Pierce County. He notes: "I contend that Dr. VanBlaricom found no significant harvesting effects because his experimental design simply lacked the statistical power needed to find any effects among all of the natural variation in his study populations. Hence the study was fatally flawed and, consequently, his conclusion was not supported by the study results."

DNR Aquatic Lands: Active Managment or Extraction of Value

Through our sustainable management of resources entrusted to our care, future generations will have ample opportunities to enjoy and benefit from Washington’s rich natural heritage. We will also ensure that revenues for our trusts will be stable or growing and that associated industries will thrive for generations to come. (From Department of Natural Resources website)

The Department of Natural Resources (DNR) is responsible for managing state owned lands and resources in Washington for the benefit of current and future generations. Included are upland acres with timber, and aquatic tideland (primarily subtidal) acres with geoduck. From timberland, trees are harvested and replanted with seedlings. From subtidal aquatic beds geoduck are extracted but are not replanted.

As Trustee, DNR has a responsibility to both current and future generations in its management of lands. In the case of subtidal aquatic bedlands, management of an area should not stop after geoduck are extracted, but should, as with harvested timberland, require replanting. Instead, DNR relies on the natural recruitment of geoduck from whatever population may remain after harvesting, whether within the tract harvested or nearby. This is short sighted management.

Imagine the same philosophy applied to timberlands. Harvesters arrive and cut stands of timber leaving pockets of trees to seed the harvested lands. While over time the area would reseed and a new forest would grow, that growth would only happen where seedlings from the remaining trees  land and take hold. While reforestation would occur, it would do so over a period extended by decades beyond a forest replanted with seedlings already established and planted at the optimal time of year for survival.

In the case of geoduck, it is estimated a harvested subtidal tract will take 40 years to repopulate in densities high enough to warrant reharvesting. Compare this to a crop cycle of 5 to 7 years currently taking place with commercial intertidal harvesting by private companies, in areas geoduck do not naturally grow.

Subtidal planting is happening now. In Alaska the first commercial harvests of subtidally planted geoduck are occurring. In Canada large sums of money are being drawn in from investors to further develop subtidal planting. Studies on impacts from harvesting subtidal plots up to 6,000 square meters (1.5 acres) in size have taken place there. In Puget Sound, divers from Spencer Cove report successful subtidal planting as high as 4 geoduck per square foot. Seattle Shellfish has leased subtidal tidelands from Manke Timber for the "cultivation and harvest of geoduck clams."

Numbers below compare a replanted subtidal density of 2 per square foot, harvested every 10 years (growth subtidally is slower), versus current management practices resulting in natural densities at .5 per square foot (a generous assumption*) harvested every 40 years. (*From Goodwin/Pease: "The average density of these young [geoduck] clams was 0.78/square meter in unfished areas and 0.54/square meter in fished [harvested] areas. The results indicated that fishing [geoduck harvesting] had an adverse effect on recruitment.")

Actively Managed: Harvesting Every 10 years
1 acre  = ~44,000 square feet
Planted (survival of 2/square foot) = 88,000 geoduck per acre
Harvested (2 pounds ea.) = 176,000 pounds of geoduck every 10 years

Unmanaged: Harvesting Every 40 years
1 acre = 44,000 square feet
Natural reseeding .5/square foot (most likely less) = 22,000 geoduck per acre
Harvested (2 pounds ea.) = 44,000 pounds of geoduck every 40 years

Over 40 years
Managed: 704,000 pounds of geoduck (4 separate harvests)
Unmanaged: 44,000 pounds of geoduck (1 harvest)

While there is an added expense of seedlings, planting, and having to use divers for harvesting (something intertidal growers do at high tide now), there are also economic upsides. Facilities to grow seed will need to be used. Divers to plant and harvest would need to be hired. Those divers would need commercial diving equipment. And, of course, there is the immense increase in revenues DNR would generate for the tribes and Washington from an acre of subtidal tidelands replanted after harvest.

Perhaps most significant of all is the current private commercial methods have transformed intertidal tidelands into geoduck farms, with both habitat functions and species diversity impacted.

Were DNR to actively manage its subtidal aquatic beds as well as it does its timberland, financial returns for the tribes and state would be greatly increased. Intertidal impacts would be lessened, if not eliminated. It requires effort and forward thinking. As Trustee of state lands, however, DNR has a fiduciary responsibility to manage them for the benefit of both current generations, and "...for generations to come."

Mason County Draft Shoreline Master Program Presented

Mason County SMP OPEN HOUSE – October 24, 2012; 3:00 PM to 7:00 PM; Public Works Building - 100 W Public Works Drive, Sheton, WA
[For a flyer click here]

October 24 Mason County will present its draft of their new Shoreline Master Program (SMP) to the public. Will Mason County begin to focus on the shellfish industry's growing impacts as other counties have? Thurston County recently denied a permit for Taylor Shellfish's proposed 58 raft mussel farm in Totten Inlet over concerns of the overall impact aquaculture was having in Totten Inlet. On the other hand, in a recent press release, it was noted Mason County's new SMP would "streamline" mussel and oyster raft permits.

Existing Mussel Rafts in Totten Inlet

on Mason County Side

The shellfish industry has been active for years in helping to craft the counties SMP updates, for their benefit. Financed through immense profits generated from geoduck farming and little in the way of taxes the industry has hired attorneys, public relations firms, and scientists to create a picture of positive "ecoengineering benefits" provided by aquaculture. Govenor Gregoir and NOAA's Shellfish Initiatives are pressuring counties to allow increased expansion through "streamlined permitting." All while cumulative impacts from additional farms and expansion of existing farms continue to grow.

Fudge Point, Harstene Island

in Mason County 

Puget Sound's intertidal tidelands are unique to the world, where species have evolved over thousands of years, able to survive both in and out of water. In Willapa Bay native Ghost shrimp are considered a "pest" by corporate shellfish farmers resulting in their eradication through spraying of Carbaryl in the marine waters. In Puget Sound, where the shellfish industry has introduced non-native Pacific oysters and non-native Manila clams, native Sea Stars; Goldeneye and Scoter diving ducks; Starry Flounder; Sand Dollars; Shiner Perch; Moon Snails are all considered to be "pests" which they would like to eliminate. [click here for more industry pests]

Mason County's tidelands are a treasure for current and future generations. Their value reaches far beyond that derived from oysters grown in plastic grow-out bags and geoducks grown in PVC pipes.

Just because you can't see it

doesn't mean it's not there. Get involved.



NOAA is Duped in Huge Geoengineering Experiment to Reduce CO2 in Ocean

Phytoplankton Bloom in August of 2012

West of Haida Gwaii (Queen Charlotte Islands)



Circled area in the middle may be the bloom

created from dumping over 100 tons of dust/iron. 

In the boiling concern of rising CO2 levels in the Pacific Ocean, NOAA has found itself involved in the middle of what some may consider a multi-million dollar deception. A NOAA spokesman claims they had no idea the 20 monitoring buoys they provided were being used to support geoengineering experiment not approved by anyone. Over 100 tonnes of "finely ground dust" containing iron was dumped into the waters of the Pacific Ocean. Having taken place off the coast of the Haida Gwaii (Queen Charlotte Islands), it is claimed to have resulted in a phytoplankton bloom over 10,000 square kilometers in size (see picture above). [click here for story]

Haida Village Circa 1876



Ancient Haida First Nation Totem Poles Today





The Haida Salmon Restoration Corporation was created by the Haida First Nation to help restore salmon runs on the Haida Gwaii where Haida ancestors lived for over 9,000 years. There, remains of their past culture are still seen on the island shorelines of Haida Gwaii, placed before their population was decimated by smallpox, reduced almost 95% by the late 1800's.

Russ George with Planktos, Inc



Haida First Nation members were approached by Russ George, a USA entrepeneur who proposed "fertilizing" the Pacific Ocean with 100 tonnes of iron dust to help stimulate a phytoplankton bloom. As phytoplankton absorb CO2, this bloom would result in "carbon credits" and also help provide a food source, krill, for salmon. The former would be sold and the latter provide sustenance for the Haida, both helping to offset the multimillion dollar cost. A Canadian credit union was approached who agreed to loan over $2 million to support the plan. [click here to hear an audio report from CBC]

Bill Dewey, Govenor Gregoire, NOAA Director Lubchenco



In Washington, NOAA and the Governor are rushing towards solutions which address CO2, ocean acidification and its impact on the shellfish industry. What happened in Canada should serve as a cautionary lesson. On one level, Mr. George made an exponential leap in faith on "ocean fertilization" which had been discredited over 3 years ago, being called ineffective. [read Nature's "Ocean Fertilization: Time to Move On" here] On another level, charlatans have existed for centuries, aware of monetary opportunities and very persuasive in extracting money from your pocket, especially effective when an urgency to act is included.

When state legislators are told "you have to act now" by the outgoing Governor they should be cautious and ask questions. [read Croscutt article here on legislation being introduced]  Perhaps asking NOAA if they have any extra buoys in order to establish baseline monitoring information would be a good place to start.

 

NOAA Ocean-monitoring Buoy

off of La Push.

Invasive Tunicate Spreading in Point Reyes Shellfish Farm

Didemnum vexillum ("marine vomit") smothering oysters

in Point Reyes shellfish farm

[click here for the Marin Indepent Journal article]

 

The non-native invasive tunicate, Didemnum vexillum (Dv) is spreading within the commercial oyster farm located in the Point Reyes National Seashore, part of the Drakes Estero area. Dv is considered the most invasive of the tunicate family and is found in Totten Inlet within Taylor Shellfish's existing mussel farm in Gallagher Cove. It spreads when colonies are broken off, in this case during oyster harvesting or, in the case of Totten Inlet, when mussels are harvested.

Invasive Tunicate Dv from

Taylor's Gallagher Cove Mussel Farm



(photo courtesy of Woods Hole Science Center)

[cick here for additional photos from Taylor's Gallagher Cove mussel farm]

 

Dv is a "colonial" tunicate which can spread when portions are dislodged. Those parts float free in the current and are able to re-attach for up to 4 weeks, more than ample time to leave Totten Inlet and enter the waters of south Puget Sound. 

 

A recent peer-reviewed study published in "Bilogical Invasions" has shown that anthropogenic activities, including commercial shellfish farming, can be a threat to increasing the spread of this invasive tunicate, noting: " D. vexillum can inflict ecological and economic damage through biofouling and habitat modification. Natural and anthropogenic processes that fragment colonies of D. vexillum may be accelerating the spread of this invader. Reattachment success and fragment viability were confirmed in the laboratory after four weeks of suspension in experimental aquaria." [click here for abstract]

 

The spread of the invasive Dv tunicate in the Point Reyes National Seashore is most likely tied directly to the operation of the shellfish farm. According to Ted Grosholz, a University of California at Davis marine ecologist who conducted the estero survey, the oyster farm structures provide a base for "fouling species" like D. vexillum. As seen in the picture above, the harvested oysters also provide a suitable substrate.

 

Dislodging colonies during harvesting allows them to drift within the National Seashore area and reattach when suitable substrate is found, including " establishing new colonies on the various structures used in shellfish farming or the planted shellfish.

.

Taylor Shellfish's proposed 58 raft facility will have over 40,000 lines of mussels on which Dv will be able to establish itself, as it did in Gallagher Cove. Each time these mussels are harvested, established colonies will have portions break loose which will be allowed to float free within the waters of Totten Inlet, flowing into south Puget Sound on the outgoing tides.

 

Cumulative impacts are real, in part why the permit for Taylor's proposed mussel farm was denied. Thurston County Commissioners will hear Taylor's appeal to this permit denial November 14.

 

 

 

 

Cumulative Impacts? Thurston County Issues SEPA Decision on Taylor/Arcadia Geoduck Farms

Thurston County has issued Mitigated Determination of Non-Significance SEPA decisions for 3 geoduck farms, 2 operated by Arcadia Point Seafood and one by Taylor Shellfish. All are on located on the west side of Henderson Inlet.

These geoduck farms were first proposed in 2010. In early 2011 Thurston County told Taylor and Arcadia they would need to apply for Shoreline Development Permits. Taylor and Arcadia appealed that decision. After large legal expenses funded by current geoduck operations, and long delays in the permitting process which they complained about, they were told by the Superior Court they needed to apply for a permit.

A recent Hearing Examiner decision told Taylor Shellfish they needed to consider cumulative impacts of existing shellfish operations for another Thurston County aquaculture project. Thurston County's planning department has felt that advice does not apply to these projects.

Taylor Shellfish and Arcadia Point Seafoods will still need to apply for a Shoreline Permit.

Willapa Bay Experiences a Commercial Natural Oyster Set

The oysters are back. For the first time in 8 years there has been a natural set of oysters on a commercial scale in Willapa Bay. [read article here] Whether a result of water conditions or natural adaptation or a combination is unclear. What is clear is that sometimes nature has a way of taking care of problems without our help. Hopefully next year will be even better.

Kistap County Shoreline Master Program and Science

A consortium of groups*, with support from People for Puget Sound staff, is sponsoring the "Sound Shoreline Science Forum" this Saturday, October 13th. Running from 9:30 to 2PM, there will be presentations on near shore wildlife, its needs, and the Kitsap County Shoreline Master Program (SMP).

Regristration starts at 9AM and will be at the Klahowya Secondary School, 7607 Northwest Newberry Hill Road, Silverdale. Lunch is available as an option. You may register in advance here:
http://shorelineforum.brownpapertickets.com/
Program information is here: 
http://pugetsound.org/education/sound-shoreline-science-forum

* Groups sponsoring the forum include:  Futurewise, Kitsap County Conservation Voters, League of Women Voters, Port Gamble S’Klallam Tribe, Suquamish Tribe, Washington Sea Grant, and West Sound Conservation Council

Is Japanese Eelgrass now a Noxious Weed in ALL of Willapa Bay?

Why would the Washington State Noxious Weed Control Board (WSNWCB) consider such a proposal? The Environmental Impact Statement addressing the application of Imazamox on commercial farms in Willapa Bay has not even gone through the scoping process  nor has a General Permit for its application been approved. [click here for Imazamox EIS Scoping and Discharge Permit information]

PUBLIC NOTICE: A hearing will be held in Yakima on November 6 from 1 to 3 PM to consider expanding the definition of Japanese eelgrass as a Class C noxious weed beyond commercial shellfish farms in Willapa Bay. Comments will be accepted by email to noxiousweeds@agr.wa.gov by 5PM November 5; mail to WSNWCB, PO Box 42560, Olympia, WA 98504-2560; or, in person.

 

The Pacific County Noxious Weed Board (PCNWB) is not satisfied with a measured and balanced approach on how to deal with Japanese eelgrass. It has told WSNWCB they now want Japanese eelgrass in all of Willapa Bay to be declared a noxious weed. This is another step to the eradication of Japanese eelgrass through the application of the herbicide Imazamox in all of Willapa Bay and elsewhere. The process should be stopped here and the EIS initiated by the Depatment of Ecology completed before any further actions are taken by WSNWCB. [click here for DOE EIS information]

 

"Therefore we do not at this time support development of a NPDES and State Waste Discharge General Permit addressing the application of imazamox on commercial shellfish beds." US Fish and Wildlife letter to the Department of Ecology, March 7, 2012 [click here for copy of letter]

 

"We encourage the DOE to adopt a precautionary approach to aquatic herbicide application to control Japanese eelgrass..." WDFW letter to DOE, March 7, 2012 [click here for copy of letter]

 

"...DNR does not support issuance of a NPDES permit to allow imazamox to be broadly used to control Zostera japonica [Japanese eelgrass] on aquaculture farms at this time." DNR letter to DOE, March 9, 2012  [click here for copy of letter]

 

Look a little deeper and you'll what

they don't want you to see.

"...the seagrass system has not only scientific value, but an enormous economic value as well. This aspect appears not to be well understood by the general public..." The Ecology of Eelgrass Meadows in the Pacific Northwest: A Community Profile, US Fish and Wildlife Service, 1984 ("USFWS Community Profile")

 

Pacific County Noxious Weed Board and the shellfish industry believe the only economic values to consider are shellfish related. Any other species dependent on Japanese eelgrass are of secondary importance. They see no risk from "collateral damage."
 

Willapa Bay Wildlife Refuge

Migratory Birds

(photo by "wildbio")

"...Zostera japonica [Japanese eelgrass], [is] a favorite foodplant of black brant [geese] and other waterfowl" USFWS Community Profile

"Conflicting uses of the eelgrass habitat, such as oyster culture, ...need suitable management." USFWS Community Profile

"There are, at present, no known undesirable effects of eelgrass in the Pacific Northwest region" USFWS Community Profile

 

Importance of eelgrass

(including Japanese eelgrass)

in the food web.

(click to enlarge)

 

Eelgrass' location is in the lower right-hand corner.

 

"There was some discussion at the November 2 [2011] WSNWCB meeting, including over the value of adding a species to the Class C noxious weed list when there were no county weed boards intending to mandate control at that time." Concise Explanatory Statement, Noxious Weed Board December 2, 2011 [Detailing why the decision to lists Japanese eelgrass was made, including comments for and against the proposal.]



Why did the Washington State Noxious Weed Control Board open the door for Imazamox to be applied on such an expansive area of Willapa Bay (all commercial shellfish farms)?

Shellfish corporations/lobbyists are implementing a strategy which consisted of first having Japanese eelgrass removed from Fish and Wildlife's Priority Habitat Species list; then declared a noxious weed by the WSNWCB; followed by getting the Department of Ecology to approve application of the herbicide Imazamox.  In support, they provided a "White Paper" written by Jeff Fisher (formally with Environ, now a Branch Chief with NOAA's National Marine Fisheries covering Mason and Pacific Counties), who is also a shellfish farmer.

Because of citizen involvement the proposal to apply Imazamox was scaled back from all of Washington's marine waters to its application only on commercial shellfish farms in Willapa Bay. Corporate shellfish farmers will continue to press agencies for what they need to increase profits. If you care, get involved.

(email exchanges with WDFW and Bill Dewey, Taylor Shellfish)

 

 

Taylor Shellfish Appeals Mussel Farm Permit Denial to Thurston County Commissioners

Taylor Shellfish has appealed the permit denial it asked for. The appeal will be heard by Thurston County Commissioners November 14 at 4 PM.
[read appeal here - 12mb file]

Taylor's attorney incorrectly claims the examiner places too much emphasis on "Regional Criteria B" of Thurston County's Shoreline Master Program, which reads:

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.

[Shoreline Master Program is here]

Taylor's attorney also misinterprets the intent of the Shoreline Management Act whose opening paragraph reads:
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.
[read RCW 90.58.020 here]

Taylor's attorney believing the examiner disregarded the information supplied is unfounded. In fact, that information was reviewed in detail and was found to be lacking. When offered the opportunity to provide additional information Taylor's attorney instead advised Taylor Shellfish to tell the examiner to deny the permit, which they did. The examiner complied with their request.

Cumulative Impacts from Shellfish Farming Continue to Grow: What Ocean Acidification Means

Concerns over cumulative impacts from corporate shellfish farming continue to grow. Most recently the "Blue Ribbon Panel" on ocean acidification has spent a great deal of time analyzing how CO2 absorption in marine waters lowers pH levels ("acidification"). In turn, the entire food web is impacted, beginning at the fundamental level of phytoplankton upwards. Unlike other species of oyster, the Pacific oyster is apparently hyper-sensitive to these changes, to the point hatcheries are being shut down and natural "sets" are not occurring. But Puget Sound species are far more diverse than the non-native Pacific oyster.

Look a little deeper

than where the shellfish industry

wants you to.



At the core of ocean acidification is a reduction in "carbonate ions for calcifying biota" which 30% of Puget Sound's species are dependent on. This reduction, in turn, results in these species becoming physiologically stressed due to an increase in energy spent as they move through their life stages. Planktotrophic larvae are especially sensitive, becoming "energetically disadvantaged as they attempt metamorphosis, thereby suffering reduced survivorship and fitness." (Miller) [further details are included in Miller's study here and in Shalin Busch's presentation to the "Blue Ribbon Panel"]

From Shallin Busch Presentation - March 30, 2012                    

Why does this matter? The shellfish industry is pressing to greatly increase production in the tidelands and waters of Puget Sound. Densities far beyond those found in the natural environment are proposed. Geoduck are planted up to 3 per square foot in upper intertidal areas where they do not naturally occur. Mussel rafts grow larger, non-native mussels in densities of 25,000 pounds in a 1,020 square foot area which, per Bill Dewey with Taylor Shellfish, would require 1 acre, or 42,000 square feet of tidelands (a permit denied for 58 of these rafts in Totten Inlet is currently being appealed [click here for 12mb appeal]). Jim Gibbons with Seattle Shellfish has pointed out south Puget Sound is "only" harvesting an estimated 20 million pounds of shellfish in an area where Spain is harvesting 600 million pounds of mussels [click here for short video of Spain's mussel farms, preceded by short advertisement]. All these shellfish require diminishing calcifying agents to grow their shells.

If what has been presented to the "Blue Ribbon Panel" on ocean acidification is in fact true - that CO2 is causing a decrease in the ions needed for species to use for calcification - what will happen to those species if densities of shellfish increase to levels corporations want? This critical building block needed at the most fundamental levels of the food chain will not be there at the levels needed, having been instead used up by shellfish. As noted in the study by Miller [click here] there are oysters far less impacted by ocean acidification than the Pacific oyster.

Cumulative impacts from corporate shellfish farming do exist, they are increasing, and Taylor Shellfish with others are more than willing to spend immense sums of money to fight any consideration of cumulative impacts in permitting decisions.

Before agencies rush to satisfy the needs of a few corporate shellfish companies they should consider listening to the voices of what the shellfish industry would like to consider just a few "NIMBY's" (Not In My Back Yard). The continued increase in calls about aquaculture's tideland habitat transformation seen on Eld Inlet, Totten Inlet, Oakland Bay, Pickering Passage, Case Inlet, the Nisqually Reach, Henderson Bay and Burley Lagoon are from more than "just a few NIMBY's". They are eyewitnesses to an unsustainable transformation and can see down the road to what's coming.