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, February 28, 2014

Massive Oyster and Scallop Die-off in Canada: Cause is Unclear

The Globe and Mail has reported a "massive" die-off of Pacific oysters and Scallops in Canada has occurred. Growers and scientists are unclear what the cause may be. Some feel a combination of high commercial densities and a lower than normal algae bloom has stressed the shellfish, making them more susceptible to disease. Some feel ocean acidification is the problem. As with most things it is likely a combination of events which will ultimately be found to be the cause. Whatever those may be it is there should be concern about the larger integrity of the ecosystem of the Salish Sea, made up of waters extending from Puget Sound north to Vancouver Island.

From the article:
Over the past two years, Mr. Perreault’s oyster farm on B.C.’s south coast has experienced 80 to 90 per cent mortality of young shellfish – the normal attrition rate is 50 per cent – and last year, nearby Pendrell Sound had a massive die-off of wild oysters.
“It was in the billions,” he said of the Pacific oysters that died only a few months after they hatched.
“It’s hard to say without having somebody there monitoring what’s going on. It could be food related. Maybe there were too many oysters and there was not enough food and they just starved – or something else [is happening] in the water like the acidity level,” he said. “To be frank, we don’t know a lot about it and that’s what’s scary.”

Wednesday, February 26, 2014

Pierce County Appeals Shorelines Hearings Board Reversal of Detienne Geoduck Farm

Location of proposed Detienne
subtidal geoduck farm.
SHB reverses/denies Pierce County permit approval.

Petition for Review filed by Pierce County
Pierce County has filed a Petition for Review of the Shorelines Hearings Board (SHB) reversal and denial of the county's permit approval for a subtidal geoduck farm.

What Pierce County does not question about the SHB decision
Filed with the Superior Court in Pierce County, the Petition does not question the need for a cumulative impacts analysis. The Petition does not question that eelgrass buffers were found to be inadequate in protecting this valuable habitat. The Petition does not question that the farm's lack of eelgrass habitat protection means it is not in the state-wide interest.

What Pierce County claims
The Petition relies instead on Pierce County simply claiming that because it could not find the Coalition for the Protection of Puget Sound Habitat's Petition for Review mailed to the County Auditor it was not served (despite a second copy having been mailed to the Prosecuting Attorney).
Note: Perhaps indicative of a deeper organizational problem, Pierce County also claimed to have emailed notice of a mitigated determination of non-significance (MDNS) to a large number of citizens. When questioned, Pierce County admitted it had in fact not done so. When the email was finally sent the public comment period had closed.
The SHB states otherwise
The SHB found the "...June 26 Declaration [of Service] to be conclusive evidence that the Coalition effected service on the County Auditor." The SHB cites from Leen v. Demopolis and states firmly, "...the burden is upon the person attacking the service to show by clear and convincing proof that the service was improper." The SHB goes further and notes that the Auditor's Office being unable to "...locate a copy of the petition is not dispositive of whether the Coalition mailed it." It concludes that "...the Coalition timely completed service on the County Auditor..." and denied the County's Motion to dismiss the case.

This is not in the state wide interest.

Expanding Aquaculture Requires Cumulative Impacts Analysis
Current methods used for growing shellfish on and in the tidelands of Puget Sound are far different now than when the Shoreline Management Act was passed in the early 1970's. Use of PVC pipes, plastic grow-out bags, nets and water jets for harvesting are transforming large and contiguous tideland areas. The ability of Puget Sound's shoreline habitat to support a large and diverse population of marine species is being converted into one with unnaturally high densities of shellfish. Harvesting these high density mono-lithic populations serves only to limit further the tideland's ability to support the diversity which has existed for generations, and puts at risk what future generations will experience.

NOAA: Plastic grow-out bags provide habitat.
Get involved in Pierce County shoreline politics - the shellfish industry is
Attend Pierce County's upcoming Shoreline Management Program meetings and tell them it is time to protect Puget Sound's habitat and not bend to the shellfish industry's needs.
Monday, March 3, 2014 – 1:30 p.m.
County-City Building, Room 1045, 930 Tacoma Ave. S, Tacoma, WA 98402
Thursday, March 6, 2014 – 5:30 p.m.
North Lake Tapps Middle School, 20029 12th Street East, Lake Tapps, WA 98391
Thursday, March 20, 2014 – 5:30 p.m.
Pacific Lutheran University, Scandinavian Cultural Center, 12180 Park Avenue South,
Tacoma Ave. S, Tacoma, WA 98402
Thursday, April 3, 2014 – 5:30 p.m.
Peninsula High School – Auditorium, 14105 Purdy Drive NW, Gig Harbor, WA 98332
Monday, April 7, 2014 – 1:30 p.m.
County-City Building, Room 1045, 930 Tacoma Ave. S, Tacoma, WA 98402

Tuesday, April 22, 2014
– 3:00 p.m.
Pierce County Council – Final Hearing
County-City Building, Room 1045, 930 Tacoma Ave. S, Tacoma, WA 98402

For Schedule information and updates, visit www.piercecountywa.gov/council
For questions, call Mike Kruger, Council Senior Legislative Analyst (253) 798-6067
or Jenifer Schultz, Committee Clerk at (253) 798-6696 or (800) 992-2456

Tuesday, February 25, 2014

Hood Canal Oil Spill - What may have been discharged into Hood Canal

What comes along with that oyster
from Hood Canal?

What Ohio Class Submarines contain their Waste Oil Containment Tanks
While waiting for additional information to be provided from agencies responsible for safe shellfish and Puget Sound's water quality, some may be interested in reading about what is contained in submarine bilge "water" and how it is handled. In "Submarine Bilgewater: Nature of Discharge" the Environmental Protection Agency describes the risk from what is contained in Ohio Class submarines' Waste Oil Containment Tanks (WOTC) this way:
Therefore, submarine bilgewater, uncontrolled, has the potential to cause an adverse
environmental effect.
Which tank was being pumped?
Detailed in the report mentioned above is how bilge "water" in the Ohio class submarines is dealt with. Of importance, it notes the oil and water are separated with the oil being retained until the submarines reach a land based facility. The "water" may be retained or discharged into the water, depending on location. The oil, however, is retained.
The upper, oil phase from the Waste Oil Collection Tank is discharged only to authorized shore facilities.
Was it oil or was it water or was it both?
What has not been made public by the agencies involved is what was being pumped when the failure resulting in the estimated 2,000 gallon discharge occurred. From the photos taken by the Department of Ecology is seems clear it was not simply dirty bilge water.
A sheen stretching 10 miles

What the discharge may have contained
Below is a table taken from the EPA report which indicates what have entered into Hood Canal and in turn may have been filtered by oysters along the shorelines of Hood Canal. How the Department of Health and the Department of Ecology are determining what may have been - or continues to be - filtered by shellfish in Hood Canal remains to be seen.

Discharged into Hood Canal
(click table to enlarge)

Monday, February 17, 2014

Final Pierce County Shoreline Master Program Meeting Schedule and Locations

NOAA and the shellfish industry are trying
to convince Pierce County politicians that this
is good for the intertidal tidelands of Puget Sound.
Plastic grow-out bags smother and scour the tidelands they
are placed on. "Habitat" created is destroyed at each harvest cycle.
This is not sustainable.

Meeting schedule is announced
Pierce County has announced its final schedule and the locations of Shoreline Management Program (SMP) meetings before presenting the final recommendations for the update to the Pierce County Council. That final hearing on April 22 will be preceded by 5 public meetings. Those meeting will be the last chance for the public to help direct how the intertidal habitat of Pierce County will be developed. How that tideland habitat will be protected for future generations is dependent on who has the largest influence on the political process in Pierce County. The Friends of Burley Lagoon and the Coalition to Protect Puget Sound Habitat strongly encourage anyone concerned to become involved.

Public Meeting Notice
2014 Shoreline Management Program

Pierce County Community Development Committee
Councilmember Rick Talbert, Chair

Monday, March 3, 2014 – 1:30 p.m.
County-City Building, Room 1045, 930 Tacoma Ave. S, Tacoma, WA 98402
Thursday, March 6, 2014 – 5:30 p.m.
North Lake Tapps Middle School, 20029 12th Street East, Lake Tapps, WA 98391
Thursday, March 20, 2014 – 5:30 p.m.
Pacific Lutheran University, Scandinavian Cultural Center, 12180 Park Avenue South,
Tacoma Ave. S, Tacoma, WA 98402
Thursday, April 3, 2014 – 5:30 p.m.
Peninsula High School – Auditorium, 14105 Purdy Drive NW, Gig Harbor, WA 98332
Monday, April 7, 2014 – 1:30 p.m.
County-City Building, Room 1045, 930 Tacoma Ave. S, Tacoma, WA 98402

Tuesday, April 22, 2014
– 3:00 p.m.
Pierce County Council – Final Hearing
County-City Building, Room 1045, 930 Tacoma Ave. S, Tacoma, WA 98402

For Schedule information and updates, visit www.piercecountywa.gov/council
For questions, call Mike Kruger, Council Senior Legislative Analyst (253) 798-6067
or Jenifer Schultz, Committee Clerk at (253) 798-6696 or (800) 992-2456

Beginning March 3, 2014, the Pierce County Council and its Community Development Committee will hold public meetings to take testimony on proposed amendments to the County's Shoreline Master Program and Development Regulations. Amendments to the County's Shoreline Master Program are mandated by the Washington State Legislature, through the Department of Ecology. A Pierce County Shoreline Citizen's Advisory Committee began working to establish a draft proposal in 2008. The proposal was considered by the Pierce County Planning Commission and forwarded to the County Council in October 2012. In 2013, a subcommittee of the Council's Community Development Committee recommended the Planning Commission consider additional changes suggested by the Washington State Department of Ecology. The Planning and Land Services Department has conducted an analysis and review of the initiated amendments and presented their findings before the Planning Commission. In October 2013, the Planning Commission forwarded their final recommendations that will be considered in the public hearings noted in the meeting schedule above.

Ordinance No. 2013-45
An Ordinance of the Pierce County Council Relating to the Pierce County Shoreline Master Program; Amending Chapter 1.22 of the Pierce County Code (PCC), "Pierce County Hearing Examiner Code"; Title 18 PCC, "Development Regulations – General Provisions"; Title 18A PCC, "Development Regulations – Zoning"; Title 18E PCC, "Development Regulations – Critical Areas"; Title 18H PCC, "Development Regulations – Forest Practices"; Title 18J PCC, "Development Regulations – Design Standards and Guidelines"; Adopting a New Title 18S PCC, "Development Regulations – Shorelines"; Repealing Title 20 PCC, "Shoreline Management Use Regulations" and the Shoreline Master Program for Pierce County as Originally Adopted on March 4, 1974; Adopting Findings of Fact; and Setting an Effective Date.

Shoreline Master Program Background: Pierce County has been regulating development along rivers, lakes and marine waters for over 40 years. The existing Pierce County Shoreline Master Program and Shoreline Development Regulations were adopted in the early 1970's following a referendum by the people of Washington State. The State law implemented by relying on existing regulations and local government is referred to as the "Shoreline Management Act of 1971" and is codified in Chapter 90.58, Revised Code of Washington. Implementing Rules are located in Chapter 173-26 and Chapter 173-27, Washington Administrative Code. In 2003, the Washington State Legislature amended State Law and established a schedule for all Counties and Cities to update their Master Programs. The Washington State Department of Ecology is responsible for administering shoreline management at the State level in partnership with local government. Ecology's web site for shoreline management is located at: www.ecy.wa.govlprograms/sea/shorelines.

The existing County Shoreline Master Program and Shoreline Development Regulations are codified in Pierce County Code - Title 20 and can be viewed online at: www.piercecountywa.gov/council.

Shoreline Master Program Components: Pierce County is obligated to manage shoreline development within 200 feet of all marine waters, rivers and streams with a mean annual flow of 20 cubic feet per second, lakes larger than 20 acres, wetlands associated with these waters as well as floodways and contiguous floodplain areas within 200 feet of the floodway.

State law includes a requirement that development result in "no net loss of shoreline ecological function." The law also includes criteria for shoreline vegetation conservation. Pierce County has proposed to comply with the law by establishing a shoreline buffer. These new buffer standards will not apply retroactively. For example, legally existing residential development is defined as a "conforming use" and will not be subject to new shoreline buffer requirements. Existing lawns, gardens and established landscaping may also be maintained within shoreline buffer areas.

All future development and redevelopment within shoreline jurisdiction will need to comply with the County's updated Shoreline Master Program. Typical examples of development that will be reviewed for compliance with the updated shoreline regulations include: residential development and associated accessory uses, docks, piers and floats, bulkheads and retaining walls, boat launching ramps, recreational development, marinas and aquaculture uses.

Property owners that have questions about the proposed changes to the shoreline regulations may contact Debby Hyde, with Planning and Land Services Department at dhyde@co.pierce.wa.us for a site specific analysis.

How to testify: You are encouraged to attend the public hearings and present comments regarding these proposed amendments. Please limit your testimony to 3 minutes. You cannot "give" your 3 minutes to someone else. If you have written materials to submit please provide 10 copies to the Clerk recording the meeting. All submitted materials become part of the official record and cannot be returned. Written comments can be provided at any time up to final adoption.

Web Page: www.piercecountywa.gov/council. Click on "Legislation" and then "Search all Legislation" and type in the key word "2013-45". The web page will provide access to the Ordinance and the Council's schedule for meetings on this Proposal. While the Council intends to adhere to the schedule provided in this notice, changes may occur. Use the web page or call the contact numbers above to obtain the latest information about meeting schedules.

Or follow this link: http://councilonline.co.pierce.wa.us/councilonline/proposal/proposal.htm?proposal_num=2013-45

Saturday, February 15, 2014

Hood Canal Naval Oil Spill: Department of Health Waits for Department of Ecology Test Results

[Update 2/20: The Department of Health continues to maintain a harvest advisory for the area 2 miles south of the naval facility north to the Hood Canal bridge. In addition, they continue the emergency closure of the intertidal and subtidal area along the eastern shoreline adjacent to the naval facility. As of 2/20 the Department of Ecology (DOE) has not publically released results of its water samples.]
Harvest Advisory/Closure as of 2/18 
(From DOH website 2/20)
USS Ohio Nuclear Submarine
Returning for Servicing 
to Naval Base Kitsap-Bangor
Passing Through the Hood Canal Bridge
On February 11 an estimated 2,000 gallons of "oily bilge water" from a naval ship was discharged into Hood Canal while being serviced at Naval Base Kitsap-Bangor. Presumably it was one of the Ohio-class "Trident" nuclear submarines. The naval facility is located on the Kitsap Peninsula on the shoreline of Puget Sound's Hood Canal and services the entire Pacific Fleet of the Ohio-class nuclear submarines. Initially the Navy estimated the spill to be only 150 gallons, an amount disputed a short time later by the Department Ecology who estimated the spill to be close to 2,000 gallons. The next day the Navy agreed that the spill was more likely to be 2,000 gallons. Whether more could have been done had the Navy been aware the spill was more than ten times larger is not known.
Bangor Naval Base - Service for
Ohio-class ("Trident")
Nuclear Submarine Fleet
Agency Response
The Department of Health (DOH) has stated they are awaiting test results from the Department of Ecology (DOE), expected Tuesday morning, before deciding what more to do. Until then they are advising commercial shellfish harvesters with beds from 2 miles south of Bangor to the Hood Canal bridge - a distance of 12 miles - to also wait for the results before harvesting shellfish. DOH closed the intertidal and subtidal areas at the base "...along the eastern shoreline of Hood Canal within the Hood Canal 2 Shellfish Growing Area." (see below for complete email sent to shellfish growers Friday, February 14th). It was not clear whether the Department of Health was separately testing water quality and shellfish tissue. Clean up is apparently being left in the hands of naval personnel. Whether China will take an interest in how shellfish safety is being attended to is unknown.
Oil 10 miles north of Bangor
at the Hood Canal Bridge
(courtesy of the Department of Ecology)
February 14 email from DOH to commercial growers:
In-field evaluations from our partner agencies have not identified any
significant intertidal impacts from this spill.  The Department of
Ecology has collected a sample of the spilled material and is analyzing
it in their laboratory.  We hope to have results by Tuesday morning.
Oil booms remain in place around the spill site and the Navy is
continuing to try to collect the remaining oil in this area.  The
majority of recoverable product has been collected.
We will continue to keep the shellfish harvest advisory in place until
we can evaluate the results from the samples collected by the Department
of Ecology. This advisory covers the area two miles south of the Navy
base north to the Hood Canal Bridge.  In addition to this advisory we
are closing the intertidal shoreline and subtidal areas at the Bangor
Navy Base, along the eastern shoreline of Hood Canal within the Hood
Canal 2 Shellfish Growing Area, to commercial shellfish harvest.

We will continue to keep you informed.

Friday, February 14, 2014

Reminder: Comments on Application of Imidacloprid in Willapa Bay and Grays Harbor Due February 15 by 5PM

Comments on EIS Scoping Due February 15 by 5PM
To Department of Ecology
Email Address:  derek.rocket@ecy.wa.gov
Click here for comments sent in by The Xerces Society, also endorsed by the following groups:
American Bird Conservancy
Beyond Pesticides
Beyond Toxics
The Center for Food Safety
The Endocrine Disruption Exchange
Haereticus Environmental Laboratory
The Institute for Fisheries Resources
The Northwest Center for Alternatives to Pesticides
The Pacific Coast Federation of Fishermen’s Associations
Pesticide Action Network North America
Robert Michael Pyle (individual)
Xerces Press Release:
Xerces and partners comment on proposed insecticide use in Willapa Bay and Grays Harbor
The Xerces Society and partners provide comprehensive comments on the proposed use of insecticides to control native burrowing shrimp in Willapa Bay and Grays Harbor
The comments are in response to the Washington State Department of Ecology’s proposal to develop an Environmental Impact Statement for use of the toxic neonicotinoid imidacloprid for the control of two species of native burrowing shrimp, Neotrypaea californiensis and Upogebia pugettensis, on commercial shellfish beds in Willapa Bay and Grays Harbor.
There is substantial information that the application of imidacloprid has great potential to damage the rich marine ecosystems of Willapa Bay and Grays Harbor. The pesticide is water soluble, long-lived, and highly toxic to aquatic invertebrates, such as insects and shrimp and other crustaceans. Imidacloprid can kill large portions of invertebrate populations and consequently harm fish—including salmon and steelhead listed under the Endangered Species Act—birds, and other organisms that rely on them for sustenance. An initial evaluation of this proposed use of imidacloprid found unacceptable risk to Dungeness crabs.
Birds depend heavily on the aquatic systems at the center of the food web. The expected reduction in invertebrate prey as a result of imidacloprid applications could reduce the health and fitness of birds, especially breeding and migrating birds and young hatchlings. There are also issues with compliance with the Migratory Bird Treaty Act and the Endangered Species Act.
For the full comments click here.
For additional information contact Aimee Code at aimee@xerces.org or 541-232-9767.
To read the Washington State Department of Ecology’s proposal, click here.
These comments are a collaborative effort of the American Bird Conservancy, Beyond Pesticides, Beyond Toxics, the Center for Food Safety, the Endocrine Disruption Exchange, Haereticus Environmental Laboratory, Institute for Fisheries Resources, the Northwest Center for Alternatives to Pesticides, Pacific Coast Federation of Fishermen’s Associations, Pesticide Action Network North America, the Xerces Society for Invertebrate Conservation, and Robert Michael Pyle.

Thursday, February 13, 2014

Drakes Bay Oyster Company Sued by California River Watch for Violations of Clean Water Act

Drakes Bay Oyster Company's refusal to cease operations in the wilderness area which Drakes Estero is part of has resulted in another lawsuit being added to those it has already caused. Added to their legally flawed request for consideration of an appeal before the Supreme Court, and their logically fractured suit against the California Coastal Commission, DBOC now finds itself being sued by the California River Watch for their ongoing violations of the Clean Water Act (see below for press release).
Structures of pressure treated wood
should not be allowed in a wilderness area.
Despite a well polished public relations campaign to support one family's continued commercial operation in a wilderness area, the fact is the Lunny family purchased an operation with a lease they knew would end in 2012 and which, under the Wilderness Act, they clearly knew would not be renewed. Pressure treated wood structures, plastic grow-out bags and the use of motor boats are not compatible with the Philip Burton Wilderness Act, created in 1976 by Congress under the Wilderness Act. No matter how hard you wave your arms the legal arguments to support the commercial operation will not fly.
Peter Prows, PR Attorney for DBOC
"The plan is for the ranchers to be next."
Pacific Legal Foundation Video
Attempts to claim this is the first step in part of a "grand plan" to eliminate ranching on Point Reyes, then Marin County, followed by Sonoma County only show how desperate the DBOC legal team is to gain traction. Peter Prows, public relations attorney for DBOC, continues to repeat the unfounded belief that this is part of some "plan" to remove cattle ranching from Point Reyes. Unlike the industrial shellfish operation in the marine wilderness, Congress specifically wrote into law cattle ranching as an exemption. Attempts to re-write the law are made with an pen lacking ink.
It is time for Drakes Bay Oyster Company to cease operating and allow for completion of the only marine wilderness area on the west coast.
Press release:
Drakes Bay Oyster Co. Sued by California River Watch for Violations of Clean Water Act
California River Watch, a Sebastopol-based organization devoted to protecting Northern California's water quality, filed a lawsuit against the Drakes Bay Oyster Company on February 7th, saying the commercial shellfish business operating in the Point Reyes National Seashore is polluting the national park waters and ocean with waste water, plastic, and invasive species and has failed to obtain the required pollution discharge permits for over seven years.  "Drakes Bay Oyster Company, which has been repeatedly cited by state agencies for its pollution, failure to obtain permits, and violations of environmental protection laws, is at it again," said Larry Hanson of California River Watch. "The Drakes Bay Oyster Company’s lack of respect for the federal Clean Water Act fouls our national park waters and degrades one of the most ecologically important wilderness areas established in the United States."  Read the River Watch lawsuit.

Wednesday, February 12, 2014

Oil Spill Response and Preparedness: Is it Real or Public Relations?

Public Meeting February 22, 2014: Oil Spill Response and Preparedness
(click here for details)

Are agencies really ready?
We'll find out.

Are you really ready to respond?
Agencies involved in the recent Community Engagement in Oil Spill Response and Readiness workshops held for the benefit of the public have been given the golden opportunity to show they are, in fact, "ready to respond."

Here we come, ready or not.

Oil and coal exports on ships add risk to Puget Sound's waters
As recently as January 24, and upcoming on February 22, workshops to help assuage public concerns over increased tanker traffic resulting from the Trans Mountain pipeline proposal by Kinder Morgan Canada have been held. They continue to be held. It has been estimated tanker traffic through Haro Straits and the Straits of Juan de Fuca will increase from 5 a month to 34 a month. With the addition of coal exports to Asia it has been estimated that an additional 487 ships annually to handle the coal would be added to ship traffic.

Is 2,000 gallons a "significant" spill?
At this point agencies' executing on a plan has been described in the Kitsap Sun this way:
The Kitsap Sun received mixed reports about whether a unified command would be implemented to develop a coordinated response to the spill. That level of coordination, which would include the Navy, Coast Guard and Ecology, is normally implemented for a significant oil spill.
Redfield-Wilder of Ecology said she was hearing that such a command would be established Wednesday morning, but Coast Guard spokesman Jordan Akiyama said his superiors told him that the Navy will remain in charge until further notice.

Tuesday, February 11, 2014

Naval Oil Spill in Hood Canal Spreads From Bangor to Hood Canal Bridge

[Update 2/20: The Department of Health continues to maintain a harvest advisory for the area 2 miles south of the naval facility north to the Hood Canal bridge. In addition, they continue the emergency closure of the intertidal and subtidal area along the eastern shoreline adjacent to the naval facility. As of 2/20 the Department of Ecology (DOE) has not publically released results of its water samples.]
Harvest Advisory/Closure as of 2/18
(From DOH website 2/20)

[Update 2/13: Inside Bainbridge's Julie Hall provides a detailed update on the estimated 2,000 gallon spill of oily bilge water into Hood Canal. She notes that a hotline has been established for citizens to report wildlife and/or beach damage: 1-800-22BiRDS.]

[Update 2/12: The Navy has acknowledged it underestimated the gallons of oily bilge water spilled into Hood Canal. Initially it had reported only 150 gallons were spilled but KOMO news has now reported they agree with DOH and DOE estimates of 2,000 gallons. Now is when we see whether the Community Engagement in Oil Spill Response and Readiness workshops recently held translate into meaningful action.]
The goal of the workshop is to “educate the general public and local officials about oil spills in the marine environment, who is engaged in Incident Command, how incident response decisions are made and how members of the public can become involved in spill response.” (Peninsula Daily News, January 24, 2014 on the upcoming workshop to be held.)

Oil Slick in Hood Canal
Photo: Department of Ecology

The Department of Health has reported that an oil spill into Hood Canal from an operation at the Bangor Naval Base has occurred. It is unclear how much entered the waters, with DOH reporting up to 2,000 gallons may have been spilled and KOMO news reporting 150 gallons. Oil has been seen as far north as the Hood Canal bridge, a distance of over 10 miles, with the Department of Ecology reporting oil in the Port Ludlow area, an distance of over 16 miles from Bangor.  DOH has advised shellfish operators to cease harvesting in the area. In addition to a number of shellfish beds, Taylor Shellfish's primary hatchery is also nearby.

Sunday, February 9, 2014

February 15: EIS Scoping Comments on Imidacloprid Application in Willapa Bay Due

Comments due by 5PM, February 15
Mail to: Derek Rockett, Permit Writer
Department of Ecology
Southwest Regional Office,
P.O. Box 47775, Olympia, WA 98504-7775
(must be postmarked no later than 5PM, February 15)
Phone: (360) 407-6697 for additional information
Should imidacloprid be added to Willapa Bay,
waters the Attorney General has already 
described as a "chemical soup"*?

EIS scoping comments due February 15, 5PM
The Department of Ecology  (DOE) has reminded people the scoping comments on the Environmental Impact Statement (EIS) addressing the application of the pesticide imidacloprid to control native burrowing shrimp in Willapa Bay and Grays Harbor are due February 15. The announcement may be found here. More detailed information on the proposal is found here.

Through the scoping process interested parties help define the issues the EIS will address, identify alternatives, and provide better focus to the EIS. When complete DOE will use the information within the EIS to determine whether a national pollutant discharge elimination system (NPDES) permit should be issued, or not.

EPA: Good for the environment,
Shellfish growers: It's a "pest".
EPA: "Burrowing shrimp have important impact on Pacific Northwest estuaries" 
February 3 the Western Ecology Division (WED) of the EPA, in collaboration with Oregon State University, released a preliminary statement on the importance of burrowing shrimp. In their release they note:
Research by a WED scientist in collaboration with Oregon State University colleagues has confirmed the importance of burrowing shrimp to the environment of Pacific Northwest estuaries where intertidal mudflats harbor dense populations of the shrimp. The shrimp construct burrows, which they use for refuge, feeding and mating, that extend as much as a meter below the sediment surface, and they constantly rework the sediments in between.
Preliminary issues
DOE has determined sediment quality, air quality, water quality, plants, animals, and human health are some of the preliminary issues to be addressed. Additional areas of concern will be considered, perhaps the most important being whether a native species (burrowing shrimp) should be given priority over growing non-native shellfish such as Pacific oysters and Manila clams.

Alternatives discussion
A discussion of alternatives could include:
1. No action - which means no permit is issued.
2. Mechanical control of burrowing shrimp only.
3. Alternative chemical control of burrowing shrimp only.
4. Other production methods.
5. An integrated pest management plan which may include both chemical and mechanical control methods.

One thing leads to another.
Spraying carbaryl on Spartina
in Willapa Bay.

Willapa Bay: A new ingredient to the "chemical soup" or a return to its natural state?
At issue with the question of whether imidacloprid should be sprayed onto the tideflats and waters of Willapa Bay is whether it is time to question what the long term impacts of chemicals on Willapa Bay's habitat is having. It is generally accepted that one of the prime reasons Japanese eelgrass has expanded in Willapa Bay is because eliminating the native burrowing shrimp left sediments firmer. It was this firm sediment which Japanese eelgrass found suitable for expansion into.

Something to question is whether allowing the native burrowing shrimp to return may be an effective means of controlling what the shellfish growers also consider a "pest", Japanese eelgrass, or if  further elimination of the burrowing shrimp will lead to further expansion of Japanese eelgrass, leading in turn to calls by the shellfish industry for expanded spraying of imazamox, adding further to the "chemical soup" of Willapa Bay.


Geoduck Exports to Vietnam Skyrocket: Smart Marketing or a Back Door to China?

The Seattle Times has reported that geoduck exports to Vietnam have skyrocketed from 16,371 pounds in December, 2012 to 117,983 pounds in December of 2013, the month China banned importing of geoduck from Puget Sound due to elevated levels of arsenic. Department of Health testing confirmed the skin did have levels of arsenic above what China considers safe and China confirmed its citizens do consume the skin. The Chinese have since requested additional information on shellfish safety programs, leaving the ban in place.

Vietnam and Hong Kong: Smart marketing or a back door to China?
When China announced the ban  on Puget Sound's geoduck December 5 the amount imported  dropped from 385,802 pounds in December 2012 to 282,216 pounds in December of 2013 (January's export data will not be released until March 7). The Associated Press reported that the Suquamish Tribe has now brought back all of its divers with their product now being shipped to Hong Kong. Robin Jordan, marketing expert for the Suquamish Tribe owned Port Madison Enterprises, is reported to have responded "Where they go after that is uncertain."