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:

Monday, February 26, 2018

Highest Astronomical Tide Line? Pacific County Shoreline Master Program Update Questioned

60 days to appeal Pacific County's SMP update, starting from January 17.

HATs off to the County Commissioners
January 17 Pacific County's SMP update was accepted. Some are now wondering how it was that one area of Pacific County's shoreline is defined as being at the "Highest Astronomical Tide" (HAT) line, and other areas are the Ordinary High Water, typically defined as the average of the highest of the high tides. Two Districts, those represented by Commissioners Ayers and Rogers, do not have that definition (HAT) adapted.

Shifting lines in the sand, shifting times.
The difference can, in some cases, be very significant, impacting where buffer lines are set and developments occur. Using the Department of Ecology's definition, the line is towards the water, in essence providing upland owners a larger parcel and buffers beginning further towards the water. In the case of the HAT, that line is where the highest tide of the year (or perhaps decade, or maybe within the National Tidal Datum Epoch period - an 18 year period of time) is. How one determines that is a surveyor's dream, as they will have to spend hours researching the topography of the land and the cycles of the moon/sun to determine just where that line is. Or wait all year for the highest tide (assuming it is an annual event they are talking about).

Making waves in a storm.
To compound the problem, there is an issue over whether the line being pushed even higher by waves needs to be considered. If one is able to determine the HAT line, what happens if there is a storm which shows the water is actually rising higher? And what if there happens to be a low pressure event offshore which coincides with the HAT, in turn, pushing that line even higher?

Get involved. The seemingly arbitrary adoption of shorelines in two districts being defined as the Highest Astronomical Tide is going to cause Pacific County and property owners challenges as they move forward.

(SMP change from Dan Driscoll, Oysterville Seafarms at 360-244-0736)

Saturday, February 24, 2018

Cooke Aquaculture's Omega Protein Complains of Chesapeake Bay Forage Fish Catch Limits

Chesapeake Bay's Threat to Menhaden Forage Fish 
Just got Even Bigger
Thanks to Cooke Aquaculture

Cooke's Omega wants more and suggest Virginia just not adapt new catch limits to go "out of compliance" to help it.
Cooke Aquaculture's Omega Protein - the largest harvester of forage fish in Chesapeake Bay - now wants more, claiming they got "a raw deal" when the new catch limits were recently put in place. Cooke is now suggesting Virginia go out of compliance with the regulations set in place to get a "fair hearing". leaving one more odd milestone in this Canadian based company's legacy. (see news report here)

We need Omega 3 in Puget Sound
for our nonnative Atlantic salmon.

Omega 3 Menhaden obtain from filtering plankton/algae in Cheapeake Bay is needed elsewhere, and Cooke wants more.
Cooke Aquaculture uses forage fish, in part, to feed its worldwide farmed salmon operations which include, in part, those in Puget Sound, growing nonnative Atlantic salmon. The forage fish are needed in order to create the Omega 3 fatty acids farmed salmon are advertised as providing. Not advertised is the huge volume of forage fish, the base of the food chain relied on by other species. Equally important, perhaps more so, is this particular forage fish - Menhaden - are also filter the largest volume of plankton from Chesapeake Bay.

A pig farm is cleaner than a fish farm.
These salmon farm operations exist in the public's open waters. Unlike a pig or chicken farm, where waste is contained and recycled, all waste from a salmon farm simply drifts in the marine ecosystem, wherever the tides may carry it. Whether excess food not consumed or the feces discharged by the fish, the amounts are in the tons. At a recent Senate hearing, it was estimated that one net pen discharged the same amount of waste as a city of 60,000. In the case of Puget Sound, an estimated 250,000 "pigs" escaped into the marine ecosystem when Cooke Aquaculture's negligence led to the collapse of one pen.

Is it any wonder people are upset with Cooke Aquaculture? Tell your elected official these nonnative Atlantic salmon need to go.
Legislative and Congressional contacts:

Friday, February 2, 2018

Willapa Bay and Imidacloprid: EPA Risk Assessment Released December 22, After DOE Closes Public Comments

Willapa Bay is Too Important
Don't allow another problem like the escape 
of Atlantic salmon to occur. It can be stopped now.
This is a public body of water 
for all of the public to enjoy.

You can't have a food chain without a foundation.
After public comments closed on November 1, of  2017, the EPA released its preliminary risk assessment on imidacloprid on December 22. Shellfish growers in Willapa Bay wish to apply imidacloprid directly to the waters and shellfish beds of Willapa Bay. In the EPA's assessment, a clear risk to aquatic organisms was shown, due to imidacloprid's persistence and how it spread throughout the aquatic ecosystem once it entered. Those aquatic organisms make up the very base of the food chain which species build on, causing a cascading effect on the aquatic food web. [Click here to see EPA's risk assessment, dated December 22.]

Critical points made in the report released December 22, after DOE closed the comment period on November 1.
1. "...aquatic invertebrates in particular are highly sensitive to imidacloprid exposure." (p. 7)
2. "...the potential exists for indirect risks to fish and aquatic-phase amphibians through reduction in their invertebrate prey base." (p. 8)
3. "Chronic risks were also identified for saltwater invertebrates from all foliar spray and combination application method scenarios modeled." (p. 8) [Note: The assessment did not look at the direct application of imidacloprid to the aquatic ecosystem proposed by the shellfish industry.]
4. "The vast majority of use scenarios modeled with soil applications also indicated chronic risk concerns with freshwater and saltwater invertebrates" (p. 8) [Note: Same as above - direct application to the marine environment was not looked at.]
5. "...concentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates...' (p. 9) [Note: There has been no testing on widespread application to aquatic environments such as that proposed by shellfish growers, only small sample areas.]
6. "the risk findings summarized in this assessment are in general agreement with recent findings published by Canada’s Pest Management Regulatory Agency and the European Food Safety Authority." (p. 10) [Note: Preceding this comment in the report was mortality of crayfish due to a "run off event". Again, this was not a direct application to the aquatic ecosystem as proposed by the shellfish growers in Willapa Bay.] 
7. "...environmental fate properties of imidacloprid suggest high mobility and solubility" (p. 11)
8. "Aquatic invertebrates, specifically aquatic insects, have been shown to be among the most sensitive taxa to acute and chronic exposures of imidacloprid" (p.11)
9. "...new aquatic toxicity data has been generated for imidacloprid since the Agency conducted its most recent ecological risk assessments..." (p. 12) [Some from Willapa Bay, some generated from a scientists found in violation of state ethics laws for not disclosing, in part, his ownership of shellfish beds and a contractual relationship with one of the largest shellfish growers who would benefit if  studies of herbicide application showed positive results. Click here to read agreed to stipulation.

Get involved
Willapa Bay is a public body of water within which a diverse set of aquatic species exist. The Department of Ecology's denial or approval of this permit is dependent on having a clear picture of what the short term and long term impacts of this proposal will be. As noted in the EPA assessment, aquatic invertebrates are "highly sensitive" to imidacloprid. These make up the very base of the food chain upon which a larger population depends on.  The assessment showed there was "high mobility and solubility" in the marine environment, meaning it very likely when applied this pesticide would spread and kill an unknown number of non-target species. 

Shellfish Growers Have Alternatives to Pesticides in Public Waters
Washington's marine ecosystems are too important to simply brush aside the very real adverse and significant impacts which come along with aquaculture, which in this case is the proposal to apply a pesticide to Willapa Bay's public waters. There are funding opportunities to develop alternative growing methods (already used by some growers) which the National Marine Fisheries Services pointed out in their November 1 public comment letter, which opposed approval of this permit. Those funding sources include NMFS' Saltonstal-Kennedy Grant Program; NOAA Sea Grant's Marine Aquaculture Grant Program; NOAA Small Business innovation Research Program; and, NMFS' Finance Program. 

Tell your elected officials you are opposed to the application of pesticides in Willapa Bay. The shellfish industry has both alternative methods and funding to develop those methods available.

Elected representatives: