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:

Friday, November 29, 2013

New Geoducks at Risk With Deep Minus Tides and Arctic Air Mass Next Week

Late night deep minus tides (down to -3.5 on Tuesday night) and an arctic air mass which is forecast to move into Washington state at the same time will put those geoduck planted this summer and fall, and other shellfish, at risk next week. With temperatures projected to fall into the teens at night during the same period, shellfish exposed to freezing air temperatures may have their gills permanently damaged or die outright. Those planted in the higher elevations are especially at risk due to the length of time they are exposed to the below freezing temperatures (e.g., during a -3.5 cycle, those planted at a +2 tidal elevation are exposed to freezing temperatures for almost 5 hours). 
December 2013 Tide Table

Tides and forecast temperatures

Monday, Dec 2: Tide -3.1, Temperature 27 degrees
Tuesday, Dec 3: Tide -3.5, Temperature 20 degrees
Wednesday, Dec 4: Tide -3.4, Temperature 18 degrees
Thursday, Dec 5: Tide -3.4, Temperature 23 degrees
Friday, Dec 6: Tide -2.9, Temperature 23 degrees
Saturday, Dec 7: Tide -1.8, Temperature 23 degrees

Tuesday, November 26, 2013

Seattle Shellfish Shellfish Hatchery Hearing Postponed, Tideland Ownership Unclear

Mason County has postponed the hearing on a Shoreline Substantial Development Permit for a shellfish hatchery on Harstine Island. The Mason County Journal reports it may be held in mid-January.
Mason County's contact is Grace Miller at gbm@co.mason.wa.us or 360-427-9670 X360. Permit # is SHR2013-00013
Northeast Harstine Island's lagoon
at the south end of Spencer Cove.
Proposed hatchery within the circle.
(click to enlarge)
Tideland ownership within lagoon in question
Located at the south end of Spencer Cove, the proposed facility is adjacent to a lagoon whose tidelands do not appear to have been sold by Washington. In a 2011 letter from DNR to Seattle Shellfish they noted the state had "never sold the tidleands" (see below). This issue is still unresolved as deeds from the state do not reference any tidelands having been sold.
From DNR to Seattle Shellfish
dated April 15, 2011.

Current use of tidelands
Seattle Shellfish has continued to use the tidelands still apparently owned by Washington and managed by DNR. Information submitted to Mason County by Confluence Environmental Company in August of this year notes it is being used for growing manila clams, oyster culture, and accessing company vessels.
From Confluence Environmental Company
report dated August 30, 2013. 
(Note: Confluence incorrectly refers to the tidal
lagoon as being Spencer Cove. Spencer Cove
is the larger body of water to the north, which
the smaller lagoon is part of, on the south.)
An expanding convenience - and value - for Seattle Shellfish 
For Seattle Shellfish, the convenience of being able to use these tidelands to support its geoduck operations cannot be understated. Upland bags of PVC pipe are staged then loaded onto barges within the lagoon where they are then transported to nearby areas of Spencer Cove. There they are inserted into the tidelands, planted with geoduck, and covered with nets (see picture below). With the proposed upland hatchery supplying seed for Seattle Shellfish's geoduck nursery adjacent to the lagoon its convenience - and value - will only increase with time.
Spencer Cove Geoduck Farm
(click to enlarge)

Monday, November 25, 2013

California Democratic Party Environmental Caucus Votes for Wilderness in Drakes Estero

From the Environmental Action Committee of West Marin:

Wilderness for future generations
is more important.

In Key Votes, California Democratic Party’s Environmental Caucus
Rejects Drakes Bay Oyster Company
Three Times
Caucus Votes Overwhelmingly Support Drakes Estero Wilderness by 3 to 1 Margin
Point Reyes, Calif. –  In a major win for supporters of Wilderness, the California Democratic Party’s Environmental Caucus overwhelmingly passed a resolution supporting protection of the Drakes Estero Marine Wilderness area in Point Reyes National Seashore on Saturday.
“Thankfully the Environmental Caucus agreed that a deal is a deal, and that the Interior Department’s decision to let the 40-year lease expire was good government in action. Like the millions of us that cherish our national parks and wilderness areas, they supported returning this ecologically rich estuary to all American to enjoy as long ago planned,” said Amy Trainer, executive director of the Environmental Action Committee of West Marin. “This company continues to flout the California Coastal Act, refusing to comply with the second cease and desist order against it, and it is fundamentally incompatible with a national park wilderness area,” said Trainer.
The 26-8 vote supporting Drakes Estero came at the annual meeting of the California Democratic Party’s Executive Board in Milbrae. It comes in the wake of the Sonoma County Democratic Central Committee’s approval of the pro-wilderness resolution in early October in an 18-5 vote.
“North Bay democrats clearly see the DBOC campaign aligned with the Koch brothers agenda, and we were proud to support protecting America's best idea, our national parks, from exploitation," said former Sebastopol mayor Lynn Hamilton. "I'm grateful to the Environmental Caucus for making the right decision,” said Hamilton.
On Saturday, the Environmental Caucus also twice rejected a resolution to support the ongoing operation of the Drakes Bay Oyster Company by 24-8 votes.
Amy Trainer and Lynn Hamilton spoke at the Caucus on behalf of the national coalition supporting the protection Drake Estero.
The Drakes Bay Oyster Company was denied for the second time a preliminary injunction to keep operating by the 9th Circuit Court of Appeals on September 3rd.  Refusing to take no for an answer, the Company petitioned for an en banc rehearing before the 9th Circuit Court of Appeals in mid-October, and the Department of Justice has been requested to file a response brief to it by December 2nd.  The Company was removed from the Monterey Bay Aquarium’s Seafood Watch Partner list almost 4 years ago and is being supported by the Koch brothers funded Pacific Legal Foundation and is working with the Tea Party in its quest to privatize Drakes Estero Wilderness. 
Amy Trainer
Executive Director

Environmental Action Committee of West Marin
Box 609 Point Reyes, CA 94956
(415) 663-9312 office
(415) 306-6052 cell

Protecting West Marin Since 1971!

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Those who contemplate the beauty of the Earth
find reserves of strength that will endure
as long as life lasts.  ~ Rachel Carson

Friday, November 22, 2013

Friends of Baynes Sound, BC: Aquaculture Impacts - A Lot To Be Lost

It's not just Puget Sound, Willapa Bay, or Drakes Estero.
There's a lot to be lost everywhere from modern aquaculture.
Friends of Baynes Sound has produced a video showing the growing impacts and habitat transformation occurring from modern aquaculture practices.

Wednesday, November 20, 2013

9th Circuit Court of Appeals Asks DOI/NPS to Respond to Drakes Bay Oyster Company's En Banc Hearing Petition

The 9th Circuit Court of Appeals has asked the United States government through the Department of the Interior (DOI) and National Park Service (NPS) whether the denial of an appeal by Drakes Bay Oyster Company (DBOC) for an injunction should be reheard en banc. DBOC's attorneys filed a petition for a rehearing en banc in October. The DOI/NPS have until December 2 to respond.

Intentions of some don't change a clearly written law
At the crux of the issue is whether Congress "intended" to "force" the Secretary of the Interior to issue a special use permit to Drakes Bay Oyster Company or if they intended to simply give the Secretary the discretion to issue a permit, or not issue a permit. Two federal courts have ruled that it is clear that when Congress changed the language from "shall issue" to "may issue" its intention was plainly memorialized. The Secretary was not required to issue a new permit and Congress gave the Secretary absolutely no direction about how to make this discretionary decision. As trustee of America's public lands, if the Secretary felt the benefits to all Americans which flow from the Wilderness Act were more important than a single family's continued commercial operation in a national park wilderness area then he could say no or let the permit expire on its own terms.

Wilderness Act or a commercial operation
Then Interior Secretary Salazar determined that the public policies underlying the 1976 Point Reyes Wilderness Act, which designated Drakes Estero as a wilderness area, and the 1964 Wilderness Act were appropriate to guide his decision. As such, Salazar concluded that the promise of wilderness in Drakes Estero was the appropriate future of this ecological rich estuary. He also concluded that the private commercial operation, which prohibited full wilderness protections, was slated to terminate for 40 years on November 30, 2012, and which in its entirety spans hundreds of acres within the Phillip Burton Wilderness, should end. Pressure-treated wood racks being used in the marine environment to grow non-native oysters would be slated to be removed, allowing the area to revert to wilderness for the nation to enjoy. It is the equivalent of allowing a wilderness area which at one time had been logged to revert to forestland and wilderness.

The Public Trust and leases contingent on ...
DBOC advocates argue that California, in retaining the Constitutional "right to fish" intended for the private commercial aquaculture operations to continue. However, all relevant state agencies have concluded that the public's "right to fish" pertains to public trust resources like salmon or rockfish and not to privately cultivated aquaculture. Otherwise, the public could buy a fishing license and go harvest their own oysters in Drakes Estero! Additionally, the Department of Fish & Wildlife's Office of Legal Counsel concluded in 2007 that primary management authority over Drakes Estero lies with the National Park Service, not the State. In 2004, a clause was added to the state's lease containing the contingency that it was only good as long as "a concurrent federal Reservation of Use and Occupancy for fee land in the Point Reyes National Seashore." When Secretary Salazar declined to issue a new permit this necessary federal authority requirement went away. This all clearly points to what California's intention was - that when the upland federal Reservation of Use and Occupancy ended so too would the state lease, allowing reversion to wilderness. When then Secretary Salazar chose not to issue a new permit after the RUO ended so ended the lease from California.

Economics of thousands of tideland acres leased but not used
Others feel removal of Drakes Bay Oyster Company's would have severe economic impacts on the state of California's shellfish industry. There's no merit to these claims. California is part of the West Coast shellfish market, and because it imports so many oysters and clams from Washington, it cannot be viewed in a vacuum. Restoring the marine wilderness area at Drakes Estero is good public policy. The supply from DBOC will be more than covered by the significant oyster-production expansion occurring in Humboldt Bay, California's largest oyster producer.

Drakes Estero is not Chesapeake Bay
Finally, concerns expressed over environmental issues from removing the non-native oysters are unfounded. Drakes Estero is not San Francisco Bay nor is it Chesapeake Bay. Drakes Estero experiences two full tidal cycles per day which keeps the waters clean. More importantly, figures of how much water is "cleared" or "filtered" mean little when the oysters reaching any meaningful size are removed, and along with them any benefit they may provide. What matters to the health of bodies of water is controlling upland sources of pollution. When that is controlled then healthy shellfish may be grown. It does not go the other way.

Drakes Estero is our only opportunity for a marine wilderness on the West Coast. American taxpayers bought and paid for the land upon which Drakes Bay Oyster Company continues to operate - at considerable profit - without paying for any rent for almost one year. The DOI/NPS should emphatically tell the 9th Circuit Court of Appeals that the issues have been resolved, to look beyond the feckless allegations, and return Drakes Estero to all Americans.

[Update 11/21: The date on which the contingency clause was added to the state's lease was 2004, not 2009.]

Ocean Acidification - It's not complicated. Or is it?

The University of Washington's Ph.D. professor Cliff Mass has questioned whether modern civilization's increasing production of CO2 is the primary cause of ocean acidification and of shellfish hatchery failures. He questions if instead those failures may be more closely tied to an attempt at raising non-native oysters in waters colder and at times more "acidic" than where the shellfish are from. He has written a second perspective to the Seattle Times articles. In his second piece he writes:
"The ST suggested that mankind’s emission of CO2 was having profound effects today on shellfish in Northwest waters.   I argued that the ST story was exaggerating the current impacts of CO2 increases and neglected a key point: that the short periods of lowered ph (a measure of acid/base ) were predominantly caused by natural variability.  The truth is that mankind's CO2 emission is actually a very minor player in the current problems at local oyster larvae hatcheries."
Billions lost millions still harvested
Within the shellfish industry there is a belief that the cause of shellfish hatchery failures and the loss of "billions of oysters"* is directly related to increasing levels of CO2 being absorbed by the ocean's waters which in turn are causing a shift in the chemical makeup of those waters. It is believed that the increasing CO2 concentration in seawater decreases carbonate ions. This decrease in carbonate ions affects the saturation state for calcium carbonate, which makes it harder for shelled organisms to grow and maintain shells. As noted, Professor Mass believes the anthropogenic source is a small percentage of the cause.
*As a side note, according to production reports from the Washington Department of Fish and Wildlife, between 2008 and 2012 the pounds of oysters harvested in Washington state have remained relatively steady. From WDFW: 2008-9.7 million pounds; 2009-8.8 million pounds; 2010-9.1 million pounds; 2011-9.3 million pounds; and, 2012-9.4 million pounds. As it takes ~2 years for an oyster to reach maturity, the 2008 numbers include seed produced in 2006.
A complicated web and a chemical soup
It is important to understand that while the shellfish industry may be having problems "hatching" non-native shellfish using Puget Sound's colder waters, where native Olympia oysters and Geoduck appear to have no problems, there may be multiple causes for whatever problems they face, including genetically modifying oysters so they are sterile. The spraying of Willapa Bay tidelands to eliminate species of shrimp considered to be a "pest" by the industry is another example of a self-induced problem. Eliminating these shrimp causes sediments to firm and in turn creates a habitat suitable for Japanese eelgrass to grow in which the shellfish industry now wants to spray with Imazamox. It is little wonder the office of the Attorney General referred to Willapa Bay as a "chemical soup."

Crying wolf is counterproductive
Professor Mass summarizes his position in the following words:
The truth is that anthropogenic increases in CO2 are only having subtle impacts on our regional weather today, the big changes and impacts will occur decades into the future. Both global warming and ocean acidification are very serious issues and by the end of the century their impacts will be substantial.   But exaggerating and hyping the effects today are unacceptable.  Citizens and policy makers deserve the facts, not exaggerations designed to elicit the proper response.  Crying wolf in the end is counterproductive and undermines the credibility of science to promote the proper actions is unacceptable.

Saturday, November 16, 2013

Dive Harvesting of Nearshore Geoduck Farms in Spencer Cove

What has been presented
While one diver working over 2 days harvesting 1,500 geoduck may have some impacts, the industry has moved far beyond that level and agencies have simply accepted small scale studies of small farms and single divers. The Shorelines Hearings Board should consider the reality of what is happening in south Puget Sound. In the pictures below, a farm area of ~500,000 geoduck is seen.

Spencer Cove, Harstine Island
Tideland habitat populated with PVC
covered with netting on various "cycles"...
(~25% of Spencer Cove below)
Note: Estimated ~10 acres planted
in this photo alone.
(click to enlarge)
...followed by ongoing
harvesting by divers...
2 dive barges, 4 divers
(click to enlarge)
...which may, if planted on a
"rotation" be ongoing for years...
Dive barge with two divers.
(click to enlarge)
...or if multiple diver sets are used, create an
intense pulse lasting for months.
(Note: The above is only representative.)
(click to enlarge)
Currently the only observations of sediment plumes submitted by the industry are based on single divers harvesting low density  planting over a one or two day period. There have been no studies on the scale and density of harvesting which is now occurring in areas such as Spencer Cove and elsewhere in Puget Sound. In the first picture above, over 10 acres are populated with ~500,000 geoduck. At the Detienne Shorelines Hearings Board hearing a study was presented which looked at dive harvesting 1,500 geoduck to prove "no impact". Is it really comparable?
Is it truly possible to determine the impacts of
what's below by studying the output of a single chimney?

Friday, November 15, 2013

Drakes Bay Oyster Company: Signs of Support Grow in Size

Is Marin County fearful of political backlash if signs are regulated?
Much has been written on the precedent which would be set in allowing Drakes Bay Oyster Company to remain in a wilderness area. Using it as an example of how expansive commercial operations can be allowed to exist within lands regulated under the Wilderness Act would put all wilderness areas at risk.
On a small, local scale, one can see throughout Marin County one of the spinoffs support for this belief is having. While billboards and political banners are strictly regulated by the county there is an apparent eye turned the other way if the signs are supporting Drakes Bay Oyster Farm. A new scale of sign has been reached on the Point Reyes Petaluma Road at Rich's Readimix. At issue is whether the county's inaction will result in other companies pointing to this and other signs in support of their wishing to place billboard size signs throughout the county.

~13' X 6'
Advertising or Political?
Regulated or Not?
Rich's Readimix on the
Point Reyes Petaluma Road 

Monday, November 11, 2013

Nov. 12, 13, 14: Shorelines Hearings Board to Hear Appeal of Detienne Subtidal Geoduck Farm Permit

Date:  November 12, 13 and 14
Time:  9AM to 5PM
What: Appeal of Pierce County's issuance of a permit to Chelsea Farms and Mr. Detienne for the first commercial subtidal geoduck farm. Case #: 13-016c
Location:  1111 Israel Road SW, Suite 301
                 Tumwater, WA
From Friends of Burley Lagoon:
This week, the Shorelines Hearings Board accepts testimony from citizens opposed to Pierce County';s conditional approval  for Darrell DeTienne and Chelsea Farms'  5 acre geoduck farm around the corner on Henderson Bay at Wauna.  The Hearings begin at 9:00am and end at 5:00pm.  Some of our neighbors will testify on Wednesday morning but we ask anyone who can go Tues. Wed., etc to appear as audience support for the Coalition...look for people wearing "Seahugger" T-Shirts.
 Burley Lagoon residents have a stake in the outcome of the hearing; some will testify about the potential danger to uses of the Lagoon, salmon runs and wildlife generally.  Photos will show the disaster that occurred when the previous Wauna geoduck farm (Washington Shellfish) was shut down and tides filled the Lagoon sediments with plastic tubes and other major debris. In addition to the impact on eelgrass beds at the Wauna site, these proposals do not exist in isolation from other areas, especially when annual King tides come with a destructive force that makes containment of "farms" highly questionable.
Directions: I-5 South --Exit #101 Tumwater Blvd.
                  At stop light, turn left onto Tumwater Blvd.
                  At first stop light, turn left onto Linderson Way.
                  At first stop light turn left onto Israel Rd.
                  At first left into parking lot.
Background photos:

Thursday, November 7, 2013

Shorelines Hearings Board Affirms Shoreline Permits for Taylor/Arcadia/Xia Geoduck Farms

"On balance, it is a very close call whether a
cumulative impacts analysis is warranted prior to approval
of these four SSDP's" Shorelines Hearings Board
After consideration of testimony and evidence the Shorelines Hearings Board (SHB) felt there was not quite enough evidence to require four geoduck farms in Thurston County to perform a cumulative impacts analysis before approval. The SHB felt the County had also reached the same conclusion through a condition which required review of the permits prior to replanting to consider whether a cumulative impacts analysis should, at that point, be required.
Note: The four geoduck farms are 2 proposed by Arcadia Point Seafoods, 1 proposed by Taylor Shellfish, and 1 proposed by the Xia family. All are in Thurston County, all are in areas which have existing farms adjacent to them or near by.
New Project Proposals Adding Pressure
Presumably, when the next permits considered by the Shorelines Hearings Board come up, new information on the plans for geoduck farm expansion will be given additional weight. Since these permit applications the Port Gamble S'Klallam tribe is now exploring expansion of subtidal planting on over 1,000 acres of subtidal tidelands. Seattle Shellfish is in the process of permitting a shellfish hatchery which would greatly expand the amount of seed for planting. Permit approvals for grow-out facilities at marinas also add capacity, with Chelsea Farms noting in their application: "if a hatchery could produce 70 million 6mm oysters a season, by outsourcing the nursery phase to growers that same hatchery could produce 700 million 2mm oysters." * Taylor Shellfish's proposal for 58 rafts growing up to 1 million pounds of mussels at the mouth of Totten Inlet only adds further to the impacts.
 *Note: Using Chelsea Farms' numbers, put another way, at 250 oysters per grow-out bag, the number of grow-out bags used would increase from 280,000 to 2.8 million.
"For the third time in the last two years the Coalition to Protect Puget Sound Habitat ("Coalition") has appealed a county approval of a geoduck project to the Shoreline[s] Hearings Baord ("Board")."
So begins the shellfish industry's pre-hearing brief for Chelsea Farms proposed subtidal farm on the Detienne tideland parcel.* Their frustration is palatable and understandable. At risk are future revenues worth millions of dollars. Also at risk is the expansion of an industry whose methods transform tideland habitats, those very same habitats which the Shoreline Management Act was to protect and prevent the fragmentation of. At some point the industry will be called on to perform an analysis which considers whether, on a cumulative level, their activities should no longer be considered a "preferred use."
*Note: The SHB hearing for the Detienne permit will be held November 12 - 15.

Drakes Estero - The Next Puget Sound?
Those concerned about what is happening in Drakes Estero should take note. In 2006 the Pacific Shellfish Growers Association engaged their Washington D.C. lobbyist David Weiman to help fight the conversion of Drakes Estero to the Wilderness Area as Congress had intended. Since that time they have been heavily involved in the campaign to support Drakes Bay Oyster Company, legally and politically. Most recently they file an amicus brief in support of an en banc hearing request before the 9th Circuit Court of Appeals.

Save our Shellfish - Expand Production in Drakes Estero
"State law requires holders of leases for shellfish cultivation to increase production annually." So states Save Our Shellfish, an ardent supporter of Drakes Bay Oyster Company. If industry succeeds in preventing the creation of the wilderness area congress intended the next step is clearly stated on the "Save our Shellfish" web site: expand production.

Monday, November 4, 2013

Seattle Shellfish Geoduck Hatchery: Permit Hearing December 10, 1PM

Update 11/7: Comments on the SEPA determination being a Mitigated Determination of Non-Significance (MDNS) are due by the end of today.

Shoreline Permit Hearing in Mason County
(Note: The SEPA determination has already been made.)

Date:  December 10
Time: 1PM
Location: Commissioner's Chambers of Building I, 411 North Fifth ST, Shelton
RE: Mason County Shoreline Permit SHR2013-00013, Seattle Shellfish Hatchery Facility
Description: Construction of two single story hatchery buildings, an algae growing area ( greenhouse), a seawater intake and return system, driveway and parking improvements and stormwater conveyances.

Proposed Location of Hatchery Facility

(click to enlarge)

Mason County will hold a hearing on Seattle Shellfish's proposal to install a new hatchery facility on their upland property located adjacent to Spencer Cove on Harstine Island. The hatchery is to address a seed shortage in general but more specifically to allow Seattle Shellfish to break from being dependent on Taylor Shellfish and the Lummi Tribe for their geoduck seed.

Tideland Ownership
There is a question of whether the tidelands within the lagoon which the proposal is adjacent to were ever transferred by the state into private ownership. While private transactions indicated ownership, there do not appear to be any deeds from the state. The original survey which the state based ownership and sales off of did not include the lagoon area. The surveyor only traced the outer shoreline along the spit, across the entrance, then northward along Spencer Cove, leaving the lagoon separated. As noted, tideland deeds from the state do not indicate they were ever transferred into private ownership.

Plate from 1880 of Spencer Cove and the Lagoon 
State surveyors did not include the lagoon.
Tidelands waterward of the blue line were sold.

 Current Use of Lagoon and Tidelands
Currently the lagoon is used by Seattle Shellfish for staging their barges onto which PVC pipes and other materials are loaded from the upland area. On occasion the barges use the tidelands to rest on when the tide is out (see picture above). How the Department of Natural Resources will resolve this legal issue is unknown.

Current Use of Lagoon's Tidelands
(hatchery proposal is upland
from the access road)
(click to enlarge)

Sunday, November 3, 2013

Tribal Entities Pressing for Subtidal Geoduck Re-Planting and Survey

[Update November 4: Information on the subtidal acreage (over 1,000 acres) in Hood Canal which the Port Gable S'Klallam Tribe has asked to be surveyed for the current population has been added. In addition, wording to clarify the subtidal area to "enhance" (replant) is that which has been harvested of wild geoduck, an area -18 to -70 feet deep.]

Port Gamble S'Klallam Tribal Request for Proposal (RFP) on Subtidal Geoduck Re-Planting
The Port Gamble S'Klallam Tribe (one of the four Klallam tribes) has requested proposals to study subtidal re-planting of geoduck after wild harvesting. Initially the RFP will be focused on literature, current methods employed, and how to improve the economic return from subtidal enhancement (planting). Proposals were due November 1.

RFP for Subtidal Survey of Over 1,000 Acres in Hood Canal
In addition to the re-planting project, the Port Gamble S'Klallam Tribe is also asking that over 1,000 subtidal acres in Hood Canal be surveyed to determine the current population of tracts, some of which have been harvested. The 22 separate tracts range in size from 6 acres to 294 acres. The subtidal acreage in the main body of Puget Sound, both harvested and not, is far greater.
Natural Recruitment After Wild Harvesting of Subtidal Tracts A Concern
In the Request for Proposal (RFP) a clear concern about the time it takes for a "harvested" subtidal tract to naturally replenish the population is noted. Concerns of over-harvesting is implicit.
"Current levels of subtidal harvest of wild geoduck populations may exceed the low natural recruitment rates of natural stocks."
Natural Recruitment Takes Time - A Long Time, if at All
Current estimates for a subtidal tract to naturally repopulate and reach maturity, in a density justifying harvesting, range from 40 up to 100 years. The range is dependent on how far away the remaining seed source is (i.e., mature geoduck not harvested), the topography and sediments of the bottom, and poaching. In a Seattle Times article published last year, Washington Department of Fish and Wildlife's (WDFW) Bob Sizemore, commenting on populations not being what they expected when surveying tracts previously harvested, was quoted as saying: "Poaching is very clearly a part of it — and in fact could be a very large part of it,".
Commercial Operations and Inventory Turns
Commercial intertidal areas (those tidelands exposed when the daily tides go out) using PVC pipe and "nursery seed" typically take 4 to 6 years to reach "market maturity" due to the size planted, warmer temperatures, and plankton typically being more plentiful in the nearshore area. Current subtidal planting occurring takes in the range of 7 to 8 years. (Note: Geoduck are considered "marketable" when they are 1.5 to 2 pounds per geoduck.) Assuming natural recruitment takes 40 years, subtidal planting of tracts whose wild geoduck have been harvested could increase "inventory turns" (and revenues received) by 5 fold. In addition, increased density through managed planting would further increase returns to the state and possibly the tribal entities.

Subtidal Tracts Managed by the State - Or Not
Virtually all of the subtidal lands of Puget Sound (those never exposed at low tide) are owned by  Washington state and managed by the Department of Natural Resources (DNR) and WDFW. The tribes, through treaty rights, participate in 50% of the revenues generated from geoduck harvesting. A small percentage of subtidal lands is privately held with industry divers stating planting densities of up to 4 per square foot are being achieved on some of these private subtidal lands. Unlike state and privately owned forest land which is required to be replanted after harvesting the subtidal tracts are simply stripped of the wild geoduck (estimated at over 4 million pounds per year) and left to recruit naturally.

Subtidal Geoduck Planting Expanding
John Lentz with Chelsea Farms is currently attempting to obtain a permit to grow geoduck on a subtidal plot near Burley Lagoon, and according to sources in Alaska, is currently participating in subtidal farming there. Taylor Shellfish has stated their desire to plant up to 30 acres within Burley Lagoon, a portion being subtidal. As noted above, divers in the industry have stated subtidal planting on privately owned subtidal tracts in Washington is already occurring with densities of up to 4 per square foot being achieved.

Is Seed Limitation a Problem?
Currently the availability of "seed" limits the amount of planting which occurs in Puget Sound. It is also a limiting factor in Alaska. But the expansion of hatchery and nursery facilities is occurring. As an example, Seattle Shellfish has discussed a hatchery facility on its Harstine Island property adjacent to Spencer Cover where its floating nursery facility already exists. Nursery facilities for oysters in marinas are currently being permitted which, when used for geoduck, would increase the supply. Within DNR seedling facilities for reforestation are managed by the state. Geoduck seed should be no different.

Lummi and Port Gamble S'Kallam Tribal Partnerships
More focused on tribal needs is the fact that the Lummi Tribe is currently one of the largest suppliers of geoduck seed to the industry. The Lummi could easily decide to provide seed to their tribal partners. Alternatively, the "technology" currently used by the Lummi Tribe (a converted fish hatchery, easily replicated) could easily be shared with the other tribal entities in Washington (e.g., the Squaxin, Nisqually, and Puyallup tribes). So doing would greatly enhance the subtidal management and planting, resulting in larger returns more quickly to the tribal members.  Were DNR and WDFW to agree that replanting the harvested subtidal tracts is, in fact, a viable means of "managing" state resources, both entities would benefit, including taxpayers.

It's Where they Grow Naturally and Where they are Being Removed From - And Is Vast
In the subtidal area between -18 and -70 feet, as noted earlier, over 4 million pounds of wild geoduck are being harvested subtidally each year. In Hood Canal alone, the Port Gamble S'Klallam tribe is asking over 1,000 acres be surveyed. It is where they grow naturally and where vast tracts are being left empty after harvest. Intertidal planting is occurring at elevations geoduck never grew naturally (up to +3.5 feet) displacing native species which use that habitat. To not replenish geoduck in lands under state management is an oversight. The Port Gamble S'Klallam tribe's press to make this happen should be a welcome step. It would also eliminate virtually all of the current anxiety over intertidal planting.