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:

Saturday, August 20, 2016

Willapa Bay - Critical Habitat for Endangered Green Sturgeon: Study supports longline oyster growing method and retaining all of Willapa Bay as critical habitat

Willapa Bay: Critical Habitat for Green Sturgeon
Burrowing Shrimp: Critical food source

Kim Patten, WSU with longlines

Get involved. The Department of Commerce through NOAA/NMFS are performing a "regulatory review" of listings, one of which includes listing Willapa Bay and Grays Harbor as critical habitat for the endangered southern Green Sturgeon. Comments must be submitted by September 6 and must be done in writing or through the Federal e-Rulemaking Portal. 
Comment here by September 6: 

Read Pubic Notice here: 

Tell NMFS and NOAA you support Willapa Bay and Grays Harbor being retained, with no exclusions, as critical habitat for the Green Sturgeon. Shellfish growers do have alternative methods of growing oysters and do not need to spray pesticides onto shellfish beds to kill a primary food source for this endangered species.

Willapa Bay: Critical Habitat for Green Sturgeon, a
threatened/endangered species under the 
United States Endangered Species Act.

Change is hard - stop living in your father's shadow and make a difference.
A study by Kim Patten with Washington State University has shown strong support for the use of the longline ("off bottom") method to grow oysters in beds which have burrowing shrimp in Willapa Bay. Willapa Bay was listed in 2009 as critical habitat for the endangered southern distinct population (SDP) of the Green Sturgeon, once far more abundant. Unlike salmon who pass through this important estuary on their way to the open ocean, the Green Sturgeon relies "...heavily on estuarine habitats over their lifespans." (from 2009 listing) Included is reliance on burrowing shrimp as a food source.

Damien Schiff
Tried to get the southern resident Orca
de-listed as an endangered species.
PLF - a danger to the 
endangered species act

2009 Habitat Listing Challenged by Pacific Legal Foundation
Earlier this year the Pacific Legal Foundation (PLF) asked the Supreme Court to review whether regulators had the discretion to determine whether to not exclude areas from being considered critical habitat. The court ruled those decisions are not subject to judicial review. It is unlikely the Supreme Court will consider Mr. Damien's case during the Long Conference, scheduled for September 26. (see here for PLF's response brief)

Not to Exclude is still discretionary.
While not involved in the lawsuit, in comments to NMFS on the then proposed 2009 decision, shellfish growers in Willapa Bay did ask for shellfish beds to be excluded from being considered critical habitat during the comment period. In response to that request, the National Marine Fisheries Services responded:
"Telemetry data show that tagged green sturgeon disperse widely throughout these estuaries, most likely for foraging. In addition, anecdotal accounts have noted observations of sturgeon in intertidal aquaculture beds in the past, likely when populations of sturgeon were more abundant in these estuaries."
 Sturgeons like long lines and shrimp beds.

Can oyster growers, an endangered species, and that species' food source co-exist?
According to Mr. Patten's recently published study, yes. His study finds an abundance of "foraging pits" in areas using longlines to grow oysters with burrowing shrimp >10/square meter. In fact, it was only in areas with no shellfish activity the forage pits were in greater density. Further, in a study published in 2007, it noted that "... these large predators [Green Sturgeon] may have performed an important top down control function on shrimp populations in the past when they were more abundant."

Bad conclusion to a good study - there is not a "surplus of foraging habitat". There are lower numbers of Green Sturgeon. It's why they're endangered.
As highlighted in the comments quoted above, sturgeon used to be more abundant. So much so one of the studies believes Green Sturgeon may have both played an important role in controlling shrimp populations and, contrary to Mr. Patten's observations, included shellfish beds in their foraging (something which would seem to support the grower's statement that shellfish beds improve the habitat). One of the stressors which reduced their population has been the past use of the pesticide Carbaryl by shellfish growers. Loss of spawning habitat and over-fishing no doubt also played roles as well. But the important point is the population of Green Sturgeon is not what is was. That is why there appears to be a "surplus of foraging habitat" and, more importantly, why they are considered endangered.

Sunday, August 14, 2016

Imidacloprid in Willapa Bay: Public Relations Effort to Spray Pesticides in Willapa Bay Begins

"Abandon ship!"
Did you have that boat inspected
before you bought it?

Easier to give up than change.
The Chinook Observer has published an article on why Goose Point Oyster (owned by the Nisbet family) is in desperate need to spray imidacloprid onto one of its Willapa Bay oyster beds. With a picture of their farm manager seeming to sink into a pool of quicksand, Dave Nisbet tells a story of why they are abandoning a parcel near the mouth of the Cedar River, done in by a 2" shrimp. Tidelands which were part of a $1.9 million transaction in 2015 which, had they been inspected, may have shown them to be incompatible with Goose Point's growing technique. And perhaps why tidelands at the mouth of a river with clear cut logging within its watershed may not have the firmest sediments.

Good shrimp, bad shrimp
Good duck, bad duck
Geoduck farming's "happy side": ecosystem services?

"Psst - I think we're giving a mixed message here."
Ironically, the Pacific Shellfish Grower's Association chose to show a diver harvesting geoduck feeding one of the dreaded shrimp to a Scoter, declaring the picture of what they consider to be two of their "pests" the winner of June's ecosystem system photo contest. The winged "pest" is kept off of shellfish beds - and away from the burrowing shrimp - by nets and hazing. Shellfish growers propose to rid the burrowing shrip - the clawed pest - by spraying the pesticide imidacloprid onto the oyster beds, hoping a permit application from the Willapa Grays Harbor Oyster Growers Association (WGHOGA) will be approved by the Department of Ecology. Editorials claim it doesn't kill the shrimp, it just "only makes them susceptible to suffocation." Kind of like propofol and benzodiazepine made Michael Jackson only go into a really really really deep sleep. (See a copy of what the shellfish industry considers to be "pests" by clicking here.)
Good eelgrass, bad eelgrass
It's a weed. No, it's a support.

Irony becomes steely
In the Chinook article, the irony continues to grow as the article points out that on the eastern side of the parcel eelgrass provides "...a support system of roots under the surface that allows oysters to sit above the mud during high tide." This would be eelgrass which WGHOGA, in some cases, is currently spraying with the herbicide imazamox. To be fair, it is not clear whether the eelgrass referred to is the native or non-native. But it is clear Goose Point's Mr. Nisbet speaks highly of the "economic services" it provides to his ability to grow oysters. Not mentioned were the other species which benefit from its ecosystem services.

"Get out of my way
and let me do what I want,
how I want, when I want."

Trust us, we're oyster growers and Willapa Bay is not what you think. We aren't either.
In a follow-up Chinook Observer editorial titled "Get out of the way and let oyster growers survive", the public relations push evolves further. In the editorial, Governor Inlsee is described as throwing oyster growers "under the bus in order to notch a symbolic win for environmental purity." Those who believe Washington shellfish can be - in fact should be - grown in unpolluted waters are "urban activists" standing in the way of oyster growers wanting to spray herbicides and pesticides into marine waters for their beneifit. How do they see themselves when they complain of urban runoff and sediments from logging operations running into Willapa Bay? Are "rural activists" pursuing clean and healthy waters so they may profit less pure than urban activists?

Dredging for ecosystem services

(screen shots from 
"Oyster Dredging" in Willapa Bay)

Dreading ecosystem services in Willapa Bay
In the final piece of irony, the public relations editorial printed in the Chinook Observer speaks highly of the habitat services provided by oyster beds: "...more crab, more fish, more birds." Unfortunately, not described is the devastation those oyster growers bring to those oyster beds and habitat at harvest time. In the images above it is clear that not only is eelgrass being ripped from the tidelands of Willapa Bay, but that whatever "habitat" those oyster beds provided is destroyed when harvesting takes place. It's the kind of ironic story which happens when people who sit in urban offices direct how a public relations campaign in a rural area should unfold - it folds up on itself.

Get involved - tell the Governor and your elected officials it is time to stop spraying chemicals into Willapa Bay and oyster growers to move into the future.

Governor Inslee: https://fortress.wa.gov/es/governor/
Legislative and Congressional contacts:

Wednesday, August 3, 2016

Hood Canal Experiences Bloom of Coccolithophores - If they can do it why can't I?

Coccolithophore - Emiliania huxleyi 
The great calcifiers.

The Lake Louise of Puget Sound
Satellite images from last week caught what a few may have seen while driving along Hood Canal - an immense bloom of phytoplankton, believed to be Coccolithophore. While generally known for turning vast areas of the oceans a milky white, they may also at times cause the waters to be turquoise in color, similar to the color of Lake Louise in Banff National Park, Alberta, Canada. They are made up largely of calcium carbonate shields.

Non-native Pacific Oysters:
Not so great calcifiers.

You're getting warmer
As the Coccolithophores are made up largely of calcium carbonate it is unclear why Taylor Shellfish and Coast Seafoods are having such difficulty growing non-native Pacific oysters in their hatcheries. Seen in the picture above is the concentration of the phytoplankton, located in Dabob Bay. It is the same area where non-native Pacific oyster larvae die-offs in hatcheries have caused large amounts of taxpayer dollars to be spent in an attempt to understand why. Currently, a low pH level believed to be caused by CO2 altering the chemistry of the water is believed to be the cause. A recent paper in Ocean Acidification discussed the possibility that global warming helped Coccolithophores adapt relatively quickly to the changes in chemistry brought about by lower levels of pH.

Why oh why can't I?
Native Olympia oyster on the left,
non-native Pacific oyster on the right.

Sometimes bigger isn't better.
In addition to discovering the currently accepted cause of this hatchery failure, taxpayer funding has also discovered the smaller, and native Olympia oyster appears to fare much better in this lower pH environment. Added to that list of native species which appear to be able to adapt to this environment is the Coccoliothophore phytoplankton currently thriving in Hood Canal. In the case of the shellfish industry, the non-native Pacific oyster is the oyster of choice, as it grows faster and larger than the native Olympia oyster which was over-harvested to near extinction. It may be, in the end, that being bigger isn't always better.

The big picture.

Get a larger perspective on things.
Seen in the satellite image above, taken in late July, the area of Hood Canal affected by the bloom is clearly seen. What the long term implications of the bloom are remain to be seen, except that things change, sometimes faster than we know.

Monday, August 1, 2016

Reminder: Comments on Nationwide Permits on Aquaculture Due August 1

[Update: The Coalition to Protect Puget Sound Habitat and Friends of Burley Lagoon have submitted comments which may be viewed here:

Lobbying Pays

Reminder: Comments on proposed Nationwide Permits for 2017 are due today. Changes to Nationwide Permit 48 which permits aquaculture activities (or not) are briefly discussed below. It is apparent the lobbyists have been active.
email: NWP2017@usace.army.mil
Include " COE–2015–0017" in the subject line.
Complete agency notice and reasoning is here:
[Note 1: Nationwide Permit 48 regulating aquaculture and proposed changes and reasoning is found on page 35202. A summary follows the end of this post.]
[Note 2: The Seattle District will add additional conditions in the near future, providing an additional opportunity to provide comments.]
"Hey now, just because this baby hasn't been 
driven in 20 years and it's over 30 years old
doesn't mean it's not as good as new. Right?"

The new new (or, what lobbying can buy you)
Proposed: "We are proposing to define a 'new commercial shellfish aquaculture operation’ as an operation in a project area where commercial shellfish aquaculture activities have not been conducted during the past 100 years."
Should an area in which some undefined form of "commercial aquaculture " occurred over the past 100 years be automatically approved? The shellfish industry has been lobbying intensely in Washington DC to lessen Army Corps oversight and to "..to further streamline the authorization process." Included is anything giving an operator a "...legally-binding agreement which establishes an enforceable property interest for an operator." [What does that mean? Does a 1901 tideland deed from the state of Washington create an enforceable property interest which can be passed on to an operator by a new owner?]
As noted, one of the results is to change the definition of what a "new commercial operation" is, pushing the "bar of activity" back 100 years. Is it realistic to say that because great-grandpa threw some shells on tidelands in 1930, but then stopped in 1950 when he died, that a geoduck farm proposed today by a new owner who holds a deed to the tidelands is not a "new commercial operation"?
As an added bonus, is this: " The presence of submerged aquatic vegetation should not prevent the use of NWP 48 to authorize commercial shellfish aquaculture..." Eelgrass? Not so important now. IF there is any questions on impact, PCN's "...should be EXPEDITIOUSLY reviewed by the district engineer." (Put another way, "Hurry up and approve it because I want to start dredging in eelgrass for oysters.")
As noted, the Washington shellfish industry has been busy lobbying in Washington DC and the results are apparent. Below is a brief summary of proposed changes. Details are at the link above.
Get involved. The shellfish industry is.
Summary of proposed changes to Nationwide Permit 48 (aquaculture):
Project areas include lands where
other legally binding agreements
establish enforceable property
interests. Define “new commercial
shellfish aquaculture operation”
as operating in an area where
such activities have not occurred
during the past 100 years.
Remove the PCN threshold for
dredge harvesting, tilling, or
harrowing in areas inhabited by
submerged aquatic vegetation.
Does not authorize activities that
directly affect more than 1/2-acre
of submerged aquatic vegetation
beds in an area that has not been
used for commercial shellfish
aquaculture during the past 100
years. PCN must include all
species that are planned to be
cultivated during the period the
NWP is in effect. PCN must
specify whether suspended
cultivation techniques will be used
and indicate the general water
depths in the project area.