Dungeness National Wildlife Refuge: Permit Decision Delayed Until January 10

Voluminous Amount of Information, A Simple Reality
Clallam County has announced a delay until January 10 on the decision on whether a permit should be approved which would allow up to 80,000 plastic grow out on the tidelands within the boundaries of the Dungeness National Wildlife Refuge. The Hearing Examiner was flooded with information on why non-native Pacific oysters grown in grow out bags should not be allowed within the Wildlife Refuge, and more supporting why the industry thinks it's a good idea.

Native Olympia Oyster vs

nonnative Pacific oyster

Native Avian Species Using the Wildlife Refuge

Native Species have No Where Else to Go
At the core, the question before the Hearing Examiner is whether a small shellfish operation which was abandoned in the mid-2000's due to water quality issues should now be allowed to return in an intensity never seen in any Wildlife Refuge, nor for that matter anywhere in Washington State. 80,000 plastic bags layering over the tidelands is disruptive and belong somewhere else. Also weighing on the decision is the precedent it would set, being used by other commercial shellfish operators as an example of why other Wildlife Refuges should have commercial shellfish operations allowed.

Not conjecture, but reality.
Attorneys for the industry would argue the issue of precedence is merely conjecture. But one only need look at the precedent argument used by those same attorneys to justify expansion of new geoduck farms, pointing to other permits having been issued, establishing a clear reliance on the use of past permit decisions as a precedent for future permit decisions. It is the industry's legal reality they live in and for that reason alone the permit should be denied.

Enjoy the Holidays

Cooke Aquaculture and Football Shaped Rainbow Trout: Are they really "native steelhead"?

Comments due by November 22

Our Sound Our Salmon provides a how and why to submit comments here

Fool me once, shame on you.

Fool me twice, shame on me.

Above - 2017

Below - 2019

Genetically altered sterile rainbow trout are not native.

Our Sound Our Salmon is encouraging citizens to take advantage of the extended comment period on whether Cooke Aquaculture should be allowed to grow genetically altered rainbow trout in Puget Sound. Cooke intends to brand these rainbow trout raised in Puget Sound as "steelhead".*

*Steelhead are rainbow trout which have out-migrated from fresh water into salt water, then returned to their native streams to spawn. In the case of Cooke's fish, they are genetically modified to become sterile, will be fed pellets enriched with Omega 3, obtained from harvested forage fish, and fed supplements such as astaxanthin to turn the flesh pink. Whether raising a rainbow trout this way qualifies it as a "steelhead" is questionable, at best.

What altered genetics gets you:

Fish "shaped like footballs, with smaller heads"

(Seattle Times article)

"They're steelhead"

Maybe, but that's not native.

By altering the genetics of rainbow, most of the female fish will be sterile (Cooke cannot guarantee all will be), unable to develop gonads. Because of this, energy continues to be focused on growth as the fish age and continue to be fed. Documents submitted by Cooke, as reported in the Seattle Times,  describe the fish as "..often shaped like footballs, with smaller heads and stout bodies" (see image above, provided by WDFW). Economically, these genetically altered fish create more "meat on the bone." But they are not native.

These cows on the Serengeti 

can spread into native habitat.

Old science, new science, the reality is

farmed fish spread when they escape.

(WDFW estimated in a worse case scenario 

up to 1,000,000 genetically altered rainbow

may escape from Cooke Aquaculture's pens)

But "science" said they wouldn't travel far if they escaped.

One of the most significant lessons learned from Cooke Aquaculture's alleged negligence in 2017 which allowed over 250,000 farmed salmon to escape was they do not simply sit by the pen. As seen in the map above, created by WDFW from reported catches of Cooke's escaped salmon, they spread not only throughout the Salsish Sea, they also migrated up rivers use by native and endangered salmon for spawning. Despite documents submitted which try to show escapes would not travel far, not know where to go or what to do, the facts provided by WDFW clearly showed they do spread and do know how to find rivers with spawning habitat. There is no reason to believe these "steelhead" would not follow the same behavior as their closely related Atlantic salmon did. A fact based on reality, not a model created from behavior of fish somewhere else in the world. 

Cooke Aquaculture needs to move

into the future and stop polluting

public and tribal waters.

You can grow smolt here, 

you can grow steelhead here. 

And you have an additional 300 acres

less than 5 miles away to the west.

There is a better way to do things, creating jobs and infusing capital. You have the money and the land.

Of most significance to anyone concerned about the risks these genetically altered rainbow trout pose to Puget Sound, whether it be nutrients discharged from the pens or habitat and spawning grounds, is that Washington's Department of Fish and Wildlife did not consider the alternative of upland/contained operations. These facilities are being built throughout the world. Atlantic Sapphire has a facility in Florida which when complete will grow an estimated 50% of the USA demand for farmed salmon. Nordic Aquafarms has 2 projects, one in Maine and another in California. Whole Oceans has a project in Maine. And around the world facilities are being built, close to population centers. Water is filtered and treated. Risks from disease and sea lice are eliminated. Cooke could be a shining example of the future if they wanted to be. Or were forced to be. Or they could return to Canada.

Get involved. Cooke is. 

Canadian owned Cooke Aquaculture and operators before them have dominated the political process in Washington State. Cooke's alleged negligence in 2017 which led to the collapse of the Cypress Island net pen and subsequent release of over 250,000 nonnative Atlantic salmon motivated the public and legislators to ban these operations in Puget Sound. Cook's current attempt to claim these genetically altered rainbow are "native steelhead" is not what the public intended when legislation was passed in 2018. Cooke and their lobbyists are now heavily involved in convincing regulators and legislators that in fact, this is what the public intended.

Educate yourself on Our Sound Our Salmon's website, then submit meaningful comments. If you don't you'll end up with what somebody else wants.

Geoduck Market Experiences a Collapse: Washington considers it a junk clam for a reason.

The Junk Bond of Clams

They taste like they look. Unless you're Chinese.

Like the collapse of the junk bond market

so too is the market for geoduck collapsing.

(Picture from the Seattle Times)

Most Washington citizens have considered the geoduck clam to be little more than a junk clam. Beyond its size, there was little it had to offer. It was difficult to dig, difficult to cook, and difficult to chew. It had no intrinsic economic value beyond its odd shape.

The junk clam becomes a phallic symbol

with marketers in WA convincing Chinese men...

(From BBC)

I've got the cure for what ails you.
Then somebody discovered a weak point in the Chinese culture, men specifically, convincing  them a  Puget Sound clam was the cure. The junk clam became the item in China which would solve whatever it was Chinese men felt they were lacking. With a wink and a nod, and disbelief to  Washington State citizens, a market exploded in China and the junk clam experienced a demand never dreamed of. Like shark fins, Manta Ray gills, Black Bear gall bladders, a superstition was born. An extraction business in Washington's tidelands exploded. Geoduck over 130 years old (believed to be the longest living species) began to be clear cut from subtidal lands and commercial farms with PVC tubing appeared  in the intertidal areas. 

You too can become rich. 

We'll keep 85% of the revenue

and farm whenever we think it's best,

however much we think we should.

Your tidelands? No, you can't use them now.

That's fair, isn't it?

A fungus spreads in Washington's tidelands.

With the demand for geoduck came the demand for tidelands which never naturally supported the densities planted, let alone the plastic tubes and netting required for this mono-culture to take hold. Like the carpet baggers of the south, growers knocked on doors, left fliers and called tideland owners who were unaware of the value they had in those tidelands. Worse was the control they were giving away. Not known was when their lease was signed, the percentage of revenues paid was nothing more than an amount agreed on among a few growers as "fair"  (as low as 10%, predominantly 15%, maybe higher if someone signed a decades long lease). It is an oligopoly in the classic meaning of the word. Their properties became encumbered for decades, with the commercial operations in some cases reducing the value of their neighbors' property.   

"Don't I have some say

in when you harvest these clams?"

Didn't read the fine print in the lease.

If you don't know the value of what you have...

Of significance today, given up by tideland owners in their leases to these few growers was control over when their tidelands would be harvested, as well as use of them. Today, as written about in the Seattle Times, as a result of a tariff war between China and the USA, and changing "tastes", the geoduck market has collapsed. The "wild" geoduck are now fetching $6/pound versus $16/pound in the first quarter of 2016, a drop of over 60%. Cultured prices, depending on who you listen to at what point in time, have dropped from 25% to 45% from their peak.

Like a bank, geoduck growers are insulated

when a market collapses.

 "Why were geoduck on my tidelands harvested

at the low point of the market?" Good question, 

but a little late to ask.

A tariff war is never good, especially when product is available from other countries. 

In any business there is risk which, in theory, is taken on by the producers, or in this case, those leasing tidelands to grow geoduck or those bidding on wild geoduck. In the case of wild geoduck, Washington's Department of Natural Resources provided "financial relief" to the bidders when tariffs initially caused prices to drop. Those leasing tidelands weren't so fortunate. Instead, they found growers who had leased their tidelands were harvesting at the lowest price in recent history, and they had no say in whether they should wait for higher prices to arrive. That control they gave away, along with encumbering the title of their property for decades. Meanwhile, Canada, Mexico and New Zealand benefited from the battle between China and the USA, selling their geoduck, tariff free.

Think politics doesn't matter?

It will when it comes to tariffs.

He who put tariffs on

can take tariffs off and claim

a "great deal" has been made,

whether real or not.

Your geoduck are gone, but mine are just waiting for prices to rise.

Anyone who believes the current tariffs between the United States and China will remain in place as the election approaches is naive. Too much is at stake during election cycles, and this is no different. Between now and election time, there will be a "great deal" made between the US and China, and with it the removal of tariffs. And when those tariffs are gone, geoduck prices will once again rise to levels significantly higher than today. But those who leased their tidelands will have nothing to sell, having had them harvested by growers who, because prices were low, paid even less to those whose tidelands were leased (lower revenue times X% means less paid out to the lessor). On the other hand, geoduck growing on tidelands owned by the growers, tidelands purchased with the immense profits generated in years past, simply waited for higher prices to return, and can now begin harvesting.* A "great deal".

*Seattle Shellfish, Arcadia Point Seafood and Taylor Shellfish, directly or indirectly,  separately or together, have purchased large tracts of tidelands over the past decade in South Puget Sound, on which they have planted large tracts of geoduck. Examples include tideland parcels purchased in Spencer Cove on Harstine Island; Totten Inlet's Totten Shores; and Fudge Point on Harstine Island. Even well paid "scientists", involved in creating studies, purchased tidelands along the shoreline of Totten Inlet. All tidelands growing geoduck which don't have to be harvested at low prices because all have leased tidelands which have geoduck which can be harvested, and from which a lower rent will be paid. 

Banks don't lose and tideland owners likely aren't too happy. But business is tough.
The two markets - wild and cultivated - have experienced a significant loss in revenue and with it planning. Bank loans made based on prices now driven down by the current tariffs are in question. The Seattle Times article mentions salmon restoration projects being impacted because DNR's revenues are expected to be lower, leading to less in the Aquatic Lands Enhancement Account (ALEA).* (The Times notes $28 million from geoduck auction, of which the LEAP legislative document shows $6.6 million being allocated to ALEA.) And tideland owners wonder whether that lease they signed and encumbered their property with for, in some cases decades, was such a good deal after all. But that's business.

*A portion of revenues received by DNR from aquatic leases and wild geoduck harvest are allocated to the Aquatic Lands Enhancement Account (ALEA) which was intended to enhance public access to aquatic lands and for "restoring shorelines for salmon habitat." The LEAP document for 2019 shows projects in the ALEA account totaling $6.6 million. The Seattle Times notes revenues from geoduck auctions for wild geoduck totaling $28 million. It's not known where the $21.2 million difference was allocated to.

Business is tough. Products whose price is artificially inflated are laden with risk. Risk which has now come home to roost in the geoduck market.

US District Court Rules Against US Army Corps' Shellfish Permits: Impact analysis and environmental assessment were inadequate.

Decision will have impact 

on current proposals.

US District Court rules that Nationwide 48 permits for aquaculture issued by the US Army Corps were based on an inadequate "...impact analysis and environmental assessment".
Read complete decision here: https://app.box.com/s/dwftuu3wnam6bxfv32qlq5e03wo5t0hr

(Read original case filed by Coalition here:
http://coalitiontoprotectpugetsoundhabitat.org/…/complaint-…
(Read Center for Food Safety filing here:
http://www.centerforfoodsafety.org/…/2017-8-10-complaint_fi…)
(Read Swinomish Tribe complaint, also considered, here:
https://olyopen.files.wordpress.com/…/swinomish-lawsuit-aga…)

Clalllam County permitting decision just lost

a significant leg: US District Court rules

the Corps' analysis was inadequate.

This does not belong in the

Dungeness National Wildlife Refuge.

(Click here for proposal and to comment)

(Comments due by Nov 21)

"The Corps’ issuance of a nationwide permit, at least with respect to activities in the waters of the State of Washington, was arbitrary and capricious and not in accordance with NEPA or the CWA. Pursuant to 5 U.S.C. § 706(2), the Court holds unlawful and sets aside NWP 48 insofar as it authorizes activities in Washington."

One small farm lead to another, and another,

and another, and another....

Which all added together make a difference.

And the Corps didn't consider that.

Never give up

For over a decade the Coalition to Protect Puget Sound Habitat, driven by Laura Hendricks, has been saying there was never an adequate cumulative impacts analysis done in order to determine whether small discrete projects, taken as a whole, had a significant and adverse impact on Puget Sound's critical marine habitat. Today the US District Court agreed.

PVC tubes and netting are transforming

Puget Sound's critical marine habitat.

Zangle Cove is only one area

where expansion is occurring.

Native aquatic vegetation is displaced by shellfish farms.

Shellfish farming impacts eelgrass, a critical habitat.

Agreeing with the Coalition and Center For Food Safety, as well as considering a case brought the Swinomish Indian Tribal Community over concerns about impacts to eelgrass, the decision still to be made will be whether to vacate all of the Nationwide 48 permits issued, or to consider what the Swinomish may suggest. The tribe has until November 15 to file papers. Also being allowed to file papers on alternatives to cancelling all Nationwide 48 permits issued will be the intervenors, Taylor Shellfish and the Pacific Coast Shellfish Growers Association, and defendant, the Corps of Engineers.

Net pen fish farming is only one

of the many forms aquaculture takes.

Its impacts are additive to the 

marine ecosystem.

Tell WDFW their analysis of Cooke Aquaculture's proposal

to grow steelhead in Puget Sound was inadequate

and an Environmental Impact Statement 

analyzing ALL alternatives, including upland/contained systems

needs to be performed.

(Click here for proposal)

Email here: SEPAdesk2@dfw.wa.gov

Comments due by Oct 22

Get involved. Marine ecosystems are being impacted by many shapes and in many ways.

Get involved and make a difference in helping to protect the critical marine habitat as The Coalition to Protect Puget Sound Habitat, Center for Food Safety, and the Swinomish Tribe did.
See Coalition web site here:
http://coalitiontoprotectpugetsoundhabitat.org/?p=841
See Center for Food Safety site here:
https://www.centerforfoodsafety.org/…/center-for-food-safet…
See Swinomish site here:
http://www.swinomish-nsn.gov/

1.8 Million Farmed Salmon Die from Warming Waters - Puget Sound Does not Need Steelhead Farming by Cooke Aquaculture

Tell WDFW an EIS is required.

Comments: SEPAdesk2@dfw.wa.gov (By Oct 22)

Documents: https://wdfw.wa.gov/licenses/environmental/sepa/open-comments

Governor Inslee: https://www.governor.wa.gov/contact/contact/send-gov-inslee-e-message

WDFW did not consider the alternative of 

an upland and contained operation

on property Cooke Aquaculture owns

nor impacts from climate change.

Riverence grows "steelhead"* in fresh water.

Cooke Aquaculture can as well.

They don't need Puget Sound to discharge 

untreated plumes of waste into. 

Read about Riverence steelhead here:

https://riverence.com/fish.html

"We feed them a steelhead diet that is rich in Astaxanthin, 

which is the micronutrient that gives ocean-run steelhead their rich red flesh color, 

without requiring the ocean."

Cooke Aquaculture's Scatter Creek Hatchery

5 miles from Cooke's 300+ acres.

Upland and contained, where the first phase

of  genetically altered "steelhead" grow-out occurs.

Climate change is real and Puget Sound's waters are warming

Puget Sound's waters are warming and Canadian owned Cooke Aquaculture wants to extend use of its open net pens by converting to genetically altered sterile female rainbow trout they want to call "steelhead". Cooke Aquaculture owns 360+ acres in rural Rochester they could convert to upland/contained facilities. Puget Sound does not need the risk seen below, and upland/contained facilities was not an alternative considered by WDFW.

See WDFW public notice here: https://wdfw.wa.gov/news/wdfw-seeks-sepa-public-comment-cooke-aquaculture-farming-rainbow-troutsteelhead
See article on tribal involvement here: https://www.peninsuladailynews.com/news/tribe-in-partnership-with-cooke-aquaculture-eyeing-steelhead-fish-farm-in-port-angeles-harbor/
See article on state leases here: https://crosscut.com/2019/08/still-recovering-escaped-atlantic-salmon-cooke-aquaculture-now-wants-farm-steelhead

"It's natural"

Really? No - it's not.

Vessels pump up, then out, salmon remnants 

from the salmon die-off. Workers scoop

the visible pieces up. 

Open net pens are additive point sources of pollution
In Canada there is an environmental disaster unfolding with up to 1.8 million farmed salmon having died due to warm waters in late August and early September. Open net pens operated by Mowi experienced waters warm enough and oxygen levels low enough that salmon contained within the nets perished. The cleanup has begun with whatever may have been left alive being transported to a processing plant, with the smell being described as being so bad "you could taste it". The operator simply said "it's natural" and nature will clean it all up.
(Read about the cleanup here: https://www.theglobeandmail.com/canada/article-newfoundlanders-raise-a-stink-after-18-million-dead-farmed-salmon-are/)

"Salmon Butter" coats the shorelines

Cat food or salmon butter?

Others disagree with the simplistic perception that this is simply "natural" and should be ignored. In an interview with Biologist Dr Ian Jones, he compared it to the equivalence of an oil spill. Beyond the smell, he describes the impacts from the pink affluent and fish oil as being similar to a crude oil spill. Workers who are attempting to clean up the dead salmon describe the discharge of rotting salmon as "salmon butter". Whatever may be alive, or useable, is transported to a processing plant in Burgeo, NL where the Mayor has described the stench as "This stuff smelled so bad you could almost taste it." (See article here: https://www.cbc.ca/news/canada/newfoundland-labrador/mark-lane-burgeo-mayor-aquaculture-1.5313010)

"Under their breath, the cleanup crews call it salmon butter: the pink, coagulated sludge that has taken over a remote stretch of Newfoundland’s south shore." (From https://www.theglobeandmail.com/canada/article-newfoundlanders-raise-a-stink-after-18-million-dead-farmed-salmon-are/)

You can't regulate from behind a desk.

Get out.

Regulatory oversight - or lack thereof
Agency oversight has been called into question as the person in charge has yet to visit the area. This despite the event having been reported to the public in September, and its having begun in late August and early September.

"Nope, it doesn't look very pretty at all, I can tell you that," says Gerry Byrne, who has not visited the site himself. From: https://www.cbc.ca/news/canada/newfoundland-labrador/gerry-byrne-salmon-dieoff-reaction-1.5314433

Cooke's collapsed net pen in Puget Sound

Does Cooke really need another nightmare?

Does Puget Sound?

Cooke Aquaculture has already had one public relations disaster. Do they need another? Does Puget Sound?
Canadian owned Cooke Aquaculture does not need Puget Sound to grow "steelhead", whether genetically altered or not. As noted above, Riverence has been very successful in marketing "steelhead" grown in fresh water, fed a diet which rainbow trout might eat in the ocean. Consumers seem happy to accept that as "good enough". Cooke owns over 300 acres in a rural area where incentives to create a new and modern "steelhead" farm could motivate Cooke to reconsider this plan. And avoid a second public relations disaster.

Get involved - If you're not you'll be stuck with what you get.
Washington State does not need this. The impacts from it are additive, and only increase the stressors experienced. Cooke has the property, the technology exists, and the public accepts that "steelhead" do not need to be grown in salt water.

*Steelhead and Rainbow trout are genetically identical (unless altered to become sterile females, as Cooke proposes) with the only difference being Steelhead are Rainbow which migrate to the ocean and return to fresh water to spawn.

Burley Lagoon clam die-off: Just move along. We have this all under control. Really?

There are lots more bad clams out there 

in Burley Lagoon, so have it.

It's foggy out there.
After residents along the shoreline of Burley Lagoon and nearby areas pointed out to Taylor Shellfish, Pierce County, the Department of Health, the Washington Department of Fish and Wildlife and Sea Grant, directly or indirectly, that there had been a large clam die off on the tidelands of the enclosed estuary, there is no more clarity on the cause than before.

Death of a clam is "not an anomalous event." What about the death of thousands?
What is clear is this was a significant event. As in Rocky Bay, Burley Lagoon too was a commercially planted tideland with high densities of nonnative Manila clams planted. In both cases "crops" of clams died, surfaced and began to rot. Pierce County noted that "die offs are not anomalous events" and they will happen again. If they will happen again, and the result is a "stench so bad it almost knocked me over" (Rocky Bay resident), shouldn't there be some sort of urgency to determine exactly what caused these massive die offs in south Puget Sound, Discovery Bay, and now Burley Lagoon? Spread over a period of months?

Toxic Bloom: We have samples, but we need more testing, so we'll just keep harvesting oysters.
When contacted, Taylor Shellfish claimed there was a "toxic algae bloom." There was a vagueness to what that toxic bloom was, with words to the effect that more testing needed to be done. The Department of Health was unaware of any such bloom and was unsure of the exact cause. Temperatures weren't abnormally high and Taylor had apparently said nothing to them. Or any of the other agencies.

Their experts are on it.
Tacoma-Pierce County Health Department responded that WDFW and the DOH had their experts looking at it, and based on conversations with them, there was no problem. Except that a large area of commercially planted nonnative clams had surfaced, died, and begun to rot. For unknown reasons. With waters of Burley Lagoon spreading that rot and oysters filtering that rot.

Crabs and birds will get through the predator nets and "clean it up". On their schedule.
WDFW said the crabs and birds would clean up the mess, even with predator nets in place. Predator nets in place to keep crabs and birds off of the tidelands. There was little concern over whether those species would be impacted by whatever toxins may have killed the clams. Rotting on the tidelands, dead from an unknown cause. In an estuary with low flushing.

DOH: Oysters filtering waters with rotting clams and unknown toxin is not a problem.
The DOH, like the others, was unsure of the cause but felt it may have been related to the large die off in Rocky Bay and an area near Vaughn. This was a die off which had occurred in June, almost 3 months ago, and was apparently now repeating itself. With thousands of clams rotting in Burley Lagoon and oysters doing what they do best - filtering that water. And being harvested for consumption.

Sea Grant: We need more grant money. 
Sea Grant and their marine scientists who have helped support the expansion of aquaculture in south Puget Sound are still unsure of what the cause of the Rocky Bay event was, and are now requesting additional funds for further studies. While waiting for an answer from these experts, another massive die off has occurred in Burley Lagoon. Another die off which has resulted in a similar "stench which almost knocked me over" (a Rocky Bay resident). Another die off whose cause is unknown and which will not be cleaned up by anyone.

NAMBI: Not against my business or industry.
Shoreline residents whose properties  are the most heavily regulated in the state through the Shoreline Management Act and now Pierce County's updated Shoreline Master Program expect to see similar attention on developments in the tidelands. And actions when those industrial level developments create industrial level impacts. Instead, what they hear is Taylor Shellfish testifying before the Pierce County Council during the SMP update hearing that not enough was being done for them. A hearing at which numerous amendments to address their prior concerns were adopted. After they appealed the original proposal to the Growth Management Hearings Board, which found in their favor. Still, they want more.

It's aquaculture. Our commercial activities are more important than you.
Now, residents who own shoreline property, property which is heavily regulated and restricted, look at the tidelands which once grew shellfish in reasonable numbers. Without a past in which die offs were not a regular event and which did not impact the public's use of waters and shoreline. Without predator nets and without PVC tubes. Without a "stench which almost knocked me over."

Get involved. If Pierce County believes the state law needs to change in order to de-prioritize aquaculture, they will do it. You should to. Because the stench will only get worse.

Taylor Shellfish Says Clam Die-off in Burley Lagoon from Toxic Algae

"Based on recent water samples, 

there is a toxic algae bloom in Burley Lagoon."

Taylor Shellfish, September 15

Testing and reporting to...?

After weeks of complaints over a putrid smell in Burley Lagoon and large areas of dead clams rising found on the surface of sediments, an email was sent to Taylor Shellfish asking if perhaps the cause may be that Burley Lagoon's carrying capacity has been exceeded. In response, Taylor Shellfish stated water samples had shown there was a toxic algae bloom occurring in Burley Lagoon. It did not appear from the email any residents had been notified of the toxic algae.

"The stench of dead clams 

nearly knocked him over," he said.

In July.

Burley Lagoon? No, Rocky Bay. 

The stench of dead clams.

Toxic algae blooms have impacted high density clam plantings by Taylor Shellfish elsewhere in Puget Sound this year. In July, residents near Rocky Bay also complained of a similar "stench". In the case of Rocky Bay, it was found large areas with clams planted in high densities by Taylor Shellfish had also risen to the surface and died. The Key Peninsula News wrote about the event August 1. 

(Read article here: https://keypennews.com/rocky-bay-algae-bloom-suspected-in-clam-die-off

This looks and smells very familiar.

This canary flew around for a long time.

In the September 15 email, Taylor noted the toxic algae is a "canary" of some sort, indicating something. That sampling shows the algae is still present months later, and shellfish planted in high densities in the tidelands of Puget Sound are still dying, should motivate health officials to do something more than they are. Before shellfish with toxins make their way from tidelands to the public. 

Burley Lagoon Residents Complain of Putrid Smell, Clams Die Off: A "Preferred Use" of the tidelands?

"Particularly pungent smells 

may come from the beach when a common type of seaweed 

known as sea lettuce decays 

in an environment with low dissolved oxygen."

(Department of Ecology, "Focus on Saltwater Beach Odors")

Promoting and enhancing the public interest or industrial scale aquaculture?
After weeks of residents along the shoreline of Burley Lagoon complaining about a putrid smell so strong it has prevented many from enjoying the air outside of their homes, it appears there has been a clam die off to go along with it. To hear Taylor Shellfish discuss their "rights" under the Shoreline Management Act, the state and counties are to do nothing but promote and enhance aquaculture, prioritizing it over all other water dependent uses, believing it is in the statewide interest to do so. Even if it means what Burley Lagoon is experiencing.

Dead Clams in Burley Lagoon

Clean net placed too late?

The smell of politics.
Pierce County responded sources of the smell could be "Ulva" (aka Sea Lettuce, a native vegetative seaweed) so thick it smells of rotten eggs as it decays. Another source mentioned could be leaking septic fields. Not mentioned is that it could also be the carrying capacity of Burley Lagoon has been exceeded by Taylor Shellfish's intensive and industrial level of planting of clams and oysters, resulting in shellfish rotting as they die off, unable to survive due to the density of planting. Or it could be a combination of these or other things. Whatever it is, the stench is overwhelming and impacts enjoyment and use of the shoreline, whether a resident or a member of the public trying to enjoy the aquatic environment in Pierce County.

Maybe the nets just need 

a "good industrial scraping".

(Samish Bay, WA)

Do structures in the tidelands need bigger machines on the tidelands?

Long time residents of Burley Lagoon have stated they do not recall a stench so intense in all of their years living there, some for decades. What they also do not recall are the number of "predator nets"  which Taylor Shellfish uses to keep native species from feeding off of the sediments, or the expansive area covered. Nor do they recall the intensity of planting which is occurring, whether it be clams or nonnative Pacific oysters. As seen in the Samish Bay photo above, in order to deal with the heavy growth on their predator nets, Taylor partnered with New Holland and implemented the use of a tractor and a "street sweeper" to clear the nets there of Sea Lettuce so thick it prevents clams below from surviving. Algae which apparently exists in higher densities due to this artificial structure which has been placed over the tidelands of Burley Lagoon and on oysters planted in high densities.

It's not rocket science. It's "Ecosystem Services".

Oysters poop, seaweed grows, clams die. Ecosystem services at work.

As noted in an August 2017 "Ecosystem Services" winning picture, one source of the problem is directly related to oyster feces, their pseudo feces, associated ammonia, and shell surface area provided by high density planting of oysters. Oysters poop and provide "fertilizer". On the surface of those shells macro algae attaches and thrives on the "nutrients" expelled by the nonnative Pacific oysters. That growth is so intense oyster growth slows and clams rise to the surface. Summertime low tides and summertime heat promote decay and death. Smells emanate. Because of aquaculture. It's not rocket science. Calling it "ecosystem services" deflects attention from dealing with the problem created.

This is not "enhancing" the public interest

and is exactly what the Shoreline Management Act

was designed to prevent from happening

to Puget Sound tidelands.

(Read RCW 98.58.020 to see

intended preferences of the SMA)

"promote and enhance the public interest" - not industrial aquaculture

The Shoreline Management Act was created in response to industrial levels of activities impacting the shorelines of Puget Sound. It was not created to promote the industrial level of activities the shellfish industry has since evolved into. Activities and impacts which lower the statewide ability to enjoy the shorelines of Washington State. The Pierce County Council, in reluctantly passing their updated Shoreline Master Program, listened to Taylor Shellfish complain, even after additional changes were made to accommodate their industry, that more needs to be done in order for their industry to profit from tidelands and public waters. 

(Read August 28 letter from attorneys for Taylor Shellfish and the Foss family's North Bay Partners here: https://app.box.com/s/na0wpgwm4mjp7b41toj1iaf533iecij2)

Yes - Washington needs to change its laws.

"Maddening": Banning plastic straws and promoting PVC tubes in Puget Sound.

Most of what is noted in the Taylor/North Bay letter was addressed by Pierce County, yet still, Diane Cooper rose to state before the public and the council, not enough had been done for them. In response, most council members agreed, the state needs to change the law if, in fact, that is what Taylor Shellfish and others are relying on to promote their industry over other water dependent uses. [Read what the legislators who passed the SMA intended, here:

 https://app.leg.wa.gov/RCW/default.aspx?cite=90.58.020, where it states counties, in developing their Shoreline Master Programs:

"shall give preference to uses in the following order of preference which:
(1) Recognize and protect the statewide interest over local interest;
(2) Preserve the natural character of the shoreline;
(3) Result in long term over short term benefit;
(4) Protect the resources and ecology of the shoreline;
(5) Increase public access to publicly owned areas of the shorelines;
(6) Increase recreational opportunities for the public in the shoreline;
(7) Provide for any other element as defined in RCW 90.58.100 deemed appropriate or necessary."]

Get involved.
Use of structures and methods which create an environment from which odors emanate that are so strong as to prevent the public's enjoyment of the tidelands and shorelines is only one example showing how this industry is out of control. Pierce County agrees that laws promoting this need to change and will become active in the state to change this lopsided interpretation of a law intended benefit all in the state, not just a few corporations.

Pierce County Shoreline Master Program Update: Taylor Shellfish Still Not Happy

Pierce County Shoreline Master Program Update:

Council members approve amendment the Growth Management Hearings Board requested (4 yes, 2 no). Taylor Shellfish still complains they are too restrictive. Majority of council members say the state needs to act in order to protect Puget Sound's tidelands and estuaries from impacts aquaculture creates with 2 voting "No" and with others saying they are only voting "Yes" because the state law is forcing them to.

Video link is on the right side of this link:

https://online.co.pierce.wa.us/cfapps/council/iview/councilMeeting.cfm?meeting_dt=Sep%2010%202019%20%203:00PM

Taylor Shellfish's Diane Cooper complains not enough has been done:

(1:33:30 - states the update is still too restrictive, referring to Taylor's August 28 letter outlining what more they want to have changed)

(1:52:20 - believes because impacts have been occurring historically they should be allowed to continue; believes science created for the industry supports 40,000 PVC pipes/acre are just fine)

Council members comment, most saying state laws which promote 40,000+ PVC pipes/acre in Puget Sound need to be changed.

1:36:44 - Derek Young spoke passionately for most about how he is only voting "yes" because state law is forcing him to, believing estuaries and tidelands are being adversely impacted by aquaculture. That the state is speaking of banning plastic bags and straws, while allowing PVC and grow-out bags for aquaculture is "maddening."

1:41:46 - Council Member McCune has seen impacts to estuaries and habitat, and how that impacts fish populations, and agrees with Council Member Young.

1:43:51 - Council Woman Ladenburg agrees with both previous speakers and that geoduck "farming" is not justifiable. Impacts are harmful, shorelines are pristine, and this is harmful, leaving for future generations a problem. She voted "No".

1:46:10 - Councilman Morell expresses concerns about further appeals and lawsuits from the shellfish industry. [Given Taylor's testimony, this appears possible.] He voted "No".

Get involved. The shellfish industry views Puget Sound's tideland areas as little more than a template for profits. Their use of plastics and means of harvesting does impact the intertidal area. And they want more.