Burley Lagoon Geoduck Farm: Gig Harbor Advisory Commission (PAC) votes to DENY Taylor Shellfish permit for a geoduck farm in Burley Lagoon.

(Summary of meeting follows)

Burley Lagoon in Pierce County

Example of what a geoduck farm looks like.

.

Taylor Shellfish has proposed up to 25 acres be converted.

May 24: At a meeting held May 24, after hearing testimony from Pierce County and Taylor Shellfish representatives, Gig Harbor votes against Taylor Shellfish's proposal for conversion of tidelands to a  geoduck farm. While only advisory, the decision reflects strong local opposition to the proposal. 

(A recording of the meeting may be found here - scroll to "Agendas and Documents", then click on "5 24 23 PAC Recording - Audio": https://www.piercecountywa.gov/5934/Gig-Harbor-Peninsula-Advisory-Commission)

Highlights:

Question - Was all 300 acres farmed? Taylor Shellfish claims all 300 acres have historically been farmed. Some question whether that is the case, or if the acreage actually farmed is less. Taylor claims the geoduck farm would represent "only" 8% of the Lagoon. If fewer than 300 acres was actually used, the percentage of tidelands impacted would grow dramatically.

Question - How long will harvesting take place? Taylor Shellfish noted harvesting would occur during low tides in the summer and dive harvesting would occur during winter.

Sediment disturbed during dive harvesting.

Question: How will this farm uphold the values reflected in the community plan? (focus on how the farm would uphold these values) The County responded there are subjective opinions but felt the EIS addressed these concerns, pointing out the EIS is being appealed.

Question: If, after 5 years, it was found that goals were not being met, what recourse is there? The County stated the Hearing Examiner might require the county to monitor complaints. While revocation of a permit is possible, it is a "heavy lift" and staff does not have a boat to run out on. Not liking how it looked sounded unrealistic to address.

Question: If the 25 acres is approved, what is the process should Taylor wish to expand to 50 acres? The County said Taylor has told them 25 acres is all they want. But, a permit revision for expansion is available, or possibly a new permit would be required. (It was noted past regulations are not what future regulations may be. There was no clear answer.)

Question: Isn't this just farmland? If so, aren't they also under the same sort of restrictions as upland farms (e.g., wetland setbacks)? The County said tidelands are different as the public use of waters is also involved, bringing up why it's so difficult to install a dock, touching on issues of the "Public Trust".

Question: Aren't tidelands taxed far less than upland parcels are? The County "did not know" (For readers unaware, tidelands are taxed at a fraction of upland parcels.)

Opinion: Farming is good, all farming creates monocultures, in short, a farm is a farm is a farm. Except this is taking place in a marine environment. The County responded that if an existing upland farm wanted to expand they too may be subject to new regulations.

Question: Has the County acted on citizen complaints about debris and operational hours? The County said Taylor has been responsive to complaints about noise and debris. No attempt at setting up mediation has occurred, but it may be worth considering. The County expects complaints to continue.

Statement: The County said limit hours of operation has been attempted in the past but shellfish companies do not like those restrictions. It's possible the Examiner may put something in place.

Question: Logging and forestry are restricted, isn't aquaculture? The County said not really because this area is an existing farm and much of it was established when there was no noise requirement. While there is a noise pollution ordinance, it is enforced by the Health Department and they do not have the staff. Theoretically, it's possible, but, there is a question of whether only the new 25 acres would be impacted.

Question to Taylor: How long has Taylor actively farmed the area? Taylor responded they begun leasing tidelands in 2012 and actively farmed since 2014.

Question to Taylor: Why change to geoduck now? The owner asked Taylor to change. Taylor's attorney's "recollection" is markets change and product demand changes, creating a need for "diversification" of the "portfolio", including the risk of disease. (Taylor's attorney again pointed out 25 acres is "only" 8% of the area.)

Question to Taylor: Aren't there other areas Taylor can use? Taylor's attorney responded yes, although the attempt to do so was simply a scattering of seed in the water, both within and outside of the Lagoon.

Question to Taylor: If scattering is successful, why the need for PVC tubes and netting? Predation is too high and survival too low without PVC tubes and netting.

Question: Have all of Taylor's permit applications been approved? The County responded yes, pointing out his is the possibly the largest of all applications. (One in a subtidal area, the "Detienne" farm, was ultimately denied.

Comment: The County noted other agencies are involved in permitting.

Question: Is this site typical in proximity to residential surroundings? The County responded that most are on exposed tidelands, but not similar to a lagoon such as Burley Lagoon. "This one is different." In part it was why an Environmental Impact Statement was required.

Question: Are aware if any areas where upland owners are compensated?  The County noted again that Burley Lagoon is different in that there is a high density of development and use, again pointing out his was why an EIS was required.

Question: Did past applications have existing farms? The County responded that most did not.

Question: What is the County's take on the reduction in property values as farming increases? The County has said no reduction in property values has occurred, that they know of. The County could not say clearly what they would need in order to be convinced property values do become lower, although independent appraisers might be helpful. Taylor's attorney had recollections of the Haley farm testimony being experts having differing opinions and the examiner not acting on it.

Question: How would the County address a "taking" if property values decreased? It was no known, but the EIS did attempt to address probable significant adverse issues, and property values was not one of the issues. The questioner responded that many of the community members, who she spoke for, does have concerns.

Question: What was the County's involvement in the creation of an EIS? The County provided issues, responses were made, more issues were brought up, more information was provided, in short, that the County was involved from the beginning.

Question: Because of the involvement, does the County agree there is no net loss from whatever base line is established? The County agreed, pointing out, no net loss is not the same as no impact, and why mitigation may be required.

Question: Did the County have any input into who the consultant creating the EIS was? The County discussed the amount of time Dave and Ty have spent on previous permitting questions. Many of those past actions have presented consultants who were involved in the EIS's creation, but the County did not chose them. The County pointed out the applicants do chose the consultants and every EIS has had complaints about bias.

Question: With the change in tideland use, is there any mitigation in place to offset the changes which will occur? The County said there were things required, but visual issues were important, but they were unclear about what requirements there may be to minimize the visual impact, pointing out the subjectivity of it. 

Opinion: Many people don't find PVC pipes in the tidelands very appealing.

Question: What is the grandfathered use of tidelands in the past? The County was not clear, but that there were many letters describing exactly what was taking place, disagreeing with the statements of past use. The question of expansion/intensification was addressed years ago, but there was no clear answer beyond having to go re read the letters again.

Question: If shellfish were being grown in the past, where is the line between one shellfish species and another? The County responded the means and methods used to grow geoduck are very different than how clams/oysters are grown and harvested.

Opinion: Silt and sediment and water create a large disturbance within Burley Lagoon. The County determined only a "moderate" impact would occur, and why in part, an appeal of the EIS has occurred.

Dive harvesting disturbs large volumes of sediment.

Final comments: It's a farm; it does not fit within the community plan; nets are a navigational hazard; it's unique but geoduck are grown differently and property rights of upland property owners are as important as tideland owners; there won't be less geoduck for sale at Safeway if this does not go in; hours of operation should be put in place; it's an estuary with two important creeks; selling farm products to China make money; residential and aquaculture have competing interests; we're not taking aquaculture away from Taylor as they may continue to grow oysters and clams as they have; products sold overseas may benefit a few economically, but not the general population; environmental protection and sustainable practices are important to the advisory commission; changing the nature of the Lagoon and what the Lagoon has become is an important aspect; is selling natural resources overseas what the US really wants

Motion to DENY approval the permit as requested: Motion carried (i.e., DENIAL of approval).  

 

How Many Geoduck Are Being Grown on My Tidelands? (An old post - but still popular)

Trust - but verify.

[Originally posted in 2013 this still generates

a large number of views. For those who have

leased out tidelands to geoduck growers

consider spending some time on your tidelands

during the current and upcoming

minus tides of June. It's your money.]

Why you should have remembered your math.

(well, maybe not this one)

A large percentage of intertidal geoduck farms are on tidelands leased by private tideland owners to  a few shellfish companies. These owners are approached by company representatives with promises of a large check at harvest time. The amount ranges from 10% to 15% of the gross revenues, determined by the pounds of geoduck harvested and the current "market" price. With planting densities of three per square foot, a 60' X 100' tideland parcel could result in a check of up to $50,000 every 4 to 5 years. (After expenses the shellfish grower could easily net over $200,000 in profit.)

However, some tideland owners are finding that the check received is far less than what they had expected. There are a number of variables which weren't made quite clear enough at the signing of the contract, in some cases lasting for over 15 years. One of the most important is that you should be aware of what you have.

How many geoduck are there?

 

For example, as in timber harvesting there are a variety of log types and densities, some worth more than others. Not all geoduck harvested are considered "#1" grade which receive the higher prices which have ranged up to $14/pound, sometimes far higher (the Seattle Times reported last year prices up to $24/pound) . A short dark "neck" or a discolored shell will quickly drop the price Chinese are willing to pay. But an important variable is how many pounds of geoduck are harvested.

Not all geoduck are created equally.

Variables impacting density range from the survival of the seed planted to poaching. Whatever the case, a prudent tideland owner should be aware of what is planted and growing on their tideland parcel. This coming weekend presents a prime opportunity for those tideland owners who have leased their tidelands to a grower to inspect their "crop" and set their expectations.

(it's not rocket science)

[total square feet planted]*[average/square foot]*[1.5 pounds]*[$/pound]*[15%]

 

While digging a geoduck for sampling would most likely not be allowed by the grower (they'll claim ownership), sampling the area to determine the density of geoduck currently growing is a wise step all tideland lessors should take and an easy process.

1. Determine the total area in square feet where geoduck have been planted. This area should be easy to find from permit applications submitted by the grower. If you don't have it you may ask the grower for it or simply measure the area. A 60' X 100' area would equal 6,000 square feet.
2. Using a yard stick, lay out a number of 3' X 3' squares (each being 9 square feet) in different areas for sampling and count the number of "show"(siphons) which are within each square. If survival is high, you may have up to 27 geoduck within that square. If survival is low, or poaching is occurring, it may be much less.
3. When you have determined what the average number of geoduck per square foot is, then it is simply a matter of multiplying that number times the number of square feet the grower has planted on your tidelands.
4. After you had determined the number of geoduck growing, multiply that number times 1.5 or 2.0 (the latter if your harvest time is longer than 5 years) to determine the number of pounds.
5. Call your grower or Taylor Shellfish and ask them what the landed price for geoduck is then multiply that times the number of pounds growing, then that number times your lease %.

Using the 60' X 100' example above:
[60*100=6,000 square feet]
3X3 areas showed an average of 27 geoduck growing in each area, or 3 geoduck per square foot.
[27/9=3]
Total number growing is 18,000.
[6,000*3=18,000 geoduck]
Harvest time at 4th year should result in a 1.5 pound geoduck, or 27,000 pounds.
[1.5*18,000=27,000 pounds]
Landed price is $14*, or a gross amount of $378,000, of which the owner gets 15%, or $56,700.
[27,000*14=$378,000*15%=$56,700]

*6/2/2018: Best to assume the price received now is far higher than it was in 2013. Using a more realistic $20 per pound - 27,000*$20=$540,000*.15=$81,000.

July Starts with Minus Tides for July 4th

Low tide at

McMicken Island Marine State Park

A "tombolo" connects the state park

to Harstine Island at low tide.

Daylight mid-day minus tides start the month of July. Get out and see what's exposed when the waters of Puget Sound recede to one of their lowest levels. Temperatures are forecast to be in their 70's on the 4th when the lowest tide at McMicken Island Marine State Park will be -3.1, just after noon, at 12:15PM.

tide table from -

http://www.dairiki.org/tides/monthly.php/mcmk/2016-07

McMicken Island Marine State Park in

South Puget Sound

 At low tide a sand bar is exposed which connects

McMicken Island to Harstine Island.

McMicken Island Marine State Park

(note submerged "tombolo" connection

McMicken Island to Harstine Island)

You don't know what a treasure Puget Sound is if you don't get out. It's worth protecting because once it's gone you can't get it back.

Key Penninsula Advisory Commission Votes Against Taylor Shellfish Proposal of 3 New Geoduck Farms

May 18, the Key Peninsula Advisory Commission (KPAC) voted against recommending approval of 3 new geoduck farms proposed by Taylor Shellfish on south Puget Sound's Case Inlet. Taylor Shellfish found strong opposition from citizens opposed to the continued expansion of this form of aquaculuture, along with pointed questions from KPAC members asking at what point too many is too much. In the end, KPAC voted not to recommend approval.

This is not how Puget Sound

should be viewed.

Lots of little problems add up to big ones.
Puget Sound is not made up of discrete fish bowls. Yet, that is exactly how the shellfish industry wants regulatory agencies to view it. Studies looking at individual farms are brought out over and over to support expansion, one farm at a time, ignoring the dynamic and cohesive ecosystem of south Puget Sound. Calls for cumulative impacts are met by shellfish attorneys claiming agencies may only look at each farm individually. It ignores the contiguous and continuous ongoing impacts, cycle after cycle, this growing industry is creating, fracturing the cohesiveness which exists within the intertidal area of south Puget Sound. A cohesiveness the Shoreline Management Act was intended to protect.

This fish bowl is already cracked. Should we be forced to buy another?

Existing farms where these 3 new farms are proposed already have problems. Sediment deposition has buried nets and "flow through mesh tubes" which create an entire set of impacts not considered. As seen in the first picture below, removing nets buried in sediments is not as simple as pulling them out. "Flow through" mesh tubes, intended to replace PVC tubes, are buried and disappearing from sight. When they have to be removed, what will be their impact on the area? Contiguous upland parcels have apparent permit violations. Should new permits be granted while possible violations are being investigated? Some at Pierce County believe they are separate, so don't matter. They do matter.

Digging for geoduck? No, nets

which shifting sediments have buried.

How many tidal cycles to fill this hole?

 Flow through mesh tubes

buried in the sands of time.

Out of site out of mind?

The "Shellfish Initiative" is not the Shoreline Management Act, passed by the legislature and approved by the people. It is nothing more than a strategic marketing plan.

A strategic marketing plan is not a mandate to be forced onto agencies in support of expansion. Yet that is exactly what the shellfish industry presents it as. Unlike the Shoreline Management Act which was passed by the legislature and approved overwhelmingly by Washington's citizens, the "initiative" was dreamed up by the industry and its attorneys as a means to promote its expansion (see Shellfish Politics, Shellfish Initiatives, and the Shoreline Management Act  from 2013 for a history of the National and State initiatives). To believe it should force agencies to approve new projects shows a lack of insight by regulatory agencies.

Get involved. Industry is and they are not giving agencies the entire picture of what they want.

These three farms proposed were known of in 2013 when leases with the property owners were signed. Yet throughout recent permit hearings they were not disclosed. What else is not being told by the industry? Get involved. 

WDFW Maps Show Declining Densities and Negative Recovery of State Geoduck Tracts Adjacent to Commercial Farms

“If you cut down a forest, it takes a very long time 

to come back. So you need to be very careful with the harvest rate.”

Bob Sizemore, WDFW

WDFW Map showing plots sampled which have

declining densities and negative recovery

adjacent to commercial intertidal farms.

In "The Poaching of Puget Sound" from OPB's KCTS 9, Robert Sizemore with the Washington Department of Fish and Wildlife notes concerns over declining densities of wild geoduck in subtidal, publicly owned tracts, previously harvested. Provided by WDFW is a map showing the few plots sampled and those which have "declining densities" and "negative recovery" (tracts in red above). On Harstine Island, where some of the most intensive intertidal geoduck farming is occurring on private tidelands, those wild, subtidal state owned tracts co-managed by WDFW and DNR immediately adjacent to the commercial farms are not recovering as expected. In fact, they are declining in density.

Spencer Cove, Northeast Harstine Island

Intertidal farms/dive harvesting

are circled in red. The inset shows where

Washington's subtidal tract is located.

Wilson Point, Southeast Harstine Island

Private intertidal farms are circled in red. The

inset map shows DNR's subtidal geoduck tract

which is declining in density.

If all those geoduck are spawning why are they declining?

WDFW and DNR should both be concerned over how they are managing these public assets. Is it simple coincidence that some of the largest private farms are immediately adjacent to the tracts not recovering? Unlikely. Adding to why WDFW - and DNR - should be concerned is a recent study published shows the farmed geoduck in these commercial farms reach maturity and begin to spawn at 2 to 3 years of age. Why, if the high density geoduck on intertidal farms (40,000+ per acre) are spawning for a period of 3 to 5 years are subtidal tracts adjacent to them not recovering faster than normal? (see here for study: https://app.box.com/s/8glqtmh1v3vmbynwnzaga8spw7cn0ymc)

Is there a fox in the hen house?

Is poaching by those operating the farms adjacent to the state owned tracts occurring? Or is the commercial farming on private tidelands causing die-offs on subtidal tracts from sediment disruption or plastic pollution or a genetic problem? The answer needs to be found before the wild geoduck reach the same fate as the native Olympia oyster, now near extinction from overzealous shellfish farmers who simply sought a profit at the public's expense.

There's more to managing wild geoduck than

just counting how many are harvested.

As Mr. Sizemore with WDFW is quoted as saying, “If you cut down a forest, it takes a very long time to come back. So you need to be very careful with the harvest rate.” It's why DNR requires replanting of forestland after harvesting. As Commissioner Goldmark begins his campaigning on how he is managing state resources he may want to consider why DNR does not manage its subtidal tidelands like it does its forest land and require replanting of state owned subtidal tracts after geoduck ahve been harvested.

Full Moon May 14 Brings Deep Minus Tides in South Puget Sound

Full Moon Rises May 14

Lowest Tides Friday and Saturday

 

Tide Table for Olympia

 

Get out and see what's there.

 

Tideland owners - have you been poached?

A special note to tideland owners who have leased and converted their tidelands to geoduck growers: Do you know how many geoducks are on your tidelands? Do you know where your tideland parcel actually starts and ends? Minus tides present an opportunity for you to become educated. Be sure when harvest time comes and reports are received, you'll know if you've been poached. Divide the planted plot on your tidelands, which should be clearly known, into 3'X3' squares and count the number of geoduck "shows" in each square. You don't need to measure the entire plot, although that would be ideal, only a number of samples. Multiply the average number in the sample squares by the number of squares in your tideland area planted and you'll know what you should expect at harvest time.



Mason County to Geoduck Farmers: No Permits Nor Exemptions Needed

Is a tideland re-appraisal being considered?

 

While Mason County works on updating its Shoreline Master Program it has decided the current SMP does not require permits.

Mason County has sent letters to a number of geoduck farmers notifying them neither permits nor exemptions are needed for proposed geoduck farms. Whether the Department of Ecology or the Army Corps will authorize activity is unknown. What is known is the supply of geoduck to a limited market continues to increase, putting the pricing structure at further risk of collapse.

Examples of what has been noted as being sent:

February 6, for tidelands owned by the McDermid family: Letter sent to Taylor Shellfish. Planning Dept has determined shoreline permit is not required for proposed geoduck aquaculture.

April 24, for adjacent tidelands owned by the Yates and Millers: Authorization Letter issued for geoduck farm because it does not require a shoreline permit or a shoreline exemption. Project Name: Trident (Yates/Miller) Geoduck Farm. Parcel Numbers: 12131-22-00020 (Yates) and 12131-22-70010 (Miller). Letter sent 4/24/14. Copies sent to both parcel files.

April 24, for adjacent tidelands owned by the Butlers and Crosby's: Authorization Letter issued for geoduck farm because it does not require a shoreline permit or shoreline exemption. Project Name: Trident (Butler/Crosby) Geoduck Farm. PN 22127-23-00060 (Butler), 22127-23-00000 (Butler), 22127-23-00030 (Crosby). Letter sent 4/24/14. Copies sent to all 3 parcel files.

April 23, for adjacent tidelands owned by the Colello and Justis families: Letter of Approval sent on 4/23/14 approving proposal without need for exemption or shoreline permit. Copies sent to each parcel file: 22021-50-00036 (Colello) and 22021-50-00915 (Justis). This was indicated as "Site 1" by consultant.

April 24, for tidelands owned by the Vanderberg family: Letter of Approval sent on 4/24/14 approving proposal without need for exemption or shoreline permit. Copy sent to parcel file PN 22021-50-90031. This was indicated as "Site 3" by consultant within BE.

Thurston County Geoduck Farms, Permit Hearing November 26

Shoreline Substantial Development Permit Hearing for 3 proposed geoduck farms 

November 26, 10AM

Expo Center, Thurston County Fairgrounds

3054 Carpenter Road

Lacey

Comments by email: peterscs@co.thurston.wa.us by 4PM, November 23

Additional permit information: [click here] (Note: Complete permit documentation will not be put up until ~ 1 week prior to the decision.)

 



Existing and proposed geoduck farms

Henderson Inlet

(click on photo to enlarge)

 

Almost 3 years ago Taylor Shellfish and Arcadia Point Seafood were told by Thurston County their proposed geoduck farms would require a Shoreline Substantial Development Permit. Taylor and Arcadia, instead of applying, chose to pay for appealing all the way through Superior Court. Their decision was based primarily on an opinion by Attorney General McKenna which said their PVC pipes, netting and rebar necessary for a geoduck farm was not a "structure." In October of 2011, the Superior Court agreed with the Hearing Examiner who said Attorney General McKenna's opinion was legally flawed and they would need to apply for a permit.
[click here for flawed AG Opinion]
[click here for Superior Court decision]

On November 26 the Thurston County Hearing Examiner will listen to testimony on whether the three geoduck farms (Thiesen, McClure, and Lockhart) meet the requirements of Thurston County's current Shoreline Master Program. As seen in the recent permit decision for Taylor's mussel farm in Totten Inlet, the Examiner has the discretion to determine whether cumulative impacts have been adequately addressed. If not, the Examiner can ask for additional information, including an Environmental Impact Statement, to determine whether granting a permit for these three farms is warranted.

Totten Inlet

An individual farm may be inconsequential. But when seven adjacent commercial developments are being operated a far more significant fragmentation of shoreline habitat and use occurs. When seven adjacent operations are taking place, run by separate companies with different planting rotations, a far more continuous pattern of disruption will occur, day and night. When seven adjacent farms are allowed to be permitted there is little to prevent future applicants from pointing to those approved permits in support of theirs.

 

Wilson Point, Harstine Island

Cumulative impacts from corporate shellfish farming do matter, they are occurring, and they are growing. Nothing in the SEPA approval for these farms considered adjacent farms being operated simultaneously. While the hearing has combined 3 of the 5 proposed farms, there is nothing to indicate simultaneous operation of seven adjacent farms has been considered. The Examiner has the discretion to look at the broader picture and determine whether greater analysis of cumulative impacts is required. It should be.

DNR Aquatic Lands: Active Managment or Extraction of Value

Through our sustainable management of resources entrusted to our care, future generations will have ample opportunities to enjoy and benefit from Washington’s rich natural heritage. We will also ensure that revenues for our trusts will be stable or growing and that associated industries will thrive for generations to come. (From Department of Natural Resources website)

The Department of Natural Resources (DNR) is responsible for managing state owned lands and resources in Washington for the benefit of current and future generations. Included are upland acres with timber, and aquatic tideland (primarily subtidal) acres with geoduck. From timberland, trees are harvested and replanted with seedlings. From subtidal aquatic beds geoduck are extracted but are not replanted.

As Trustee, DNR has a responsibility to both current and future generations in its management of lands. In the case of subtidal aquatic bedlands, management of an area should not stop after geoduck are extracted, but should, as with harvested timberland, require replanting. Instead, DNR relies on the natural recruitment of geoduck from whatever population may remain after harvesting, whether within the tract harvested or nearby. This is short sighted management.

Imagine the same philosophy applied to timberlands. Harvesters arrive and cut stands of timber leaving pockets of trees to seed the harvested lands. While over time the area would reseed and a new forest would grow, that growth would only happen where seedlings from the remaining trees  land and take hold. While reforestation would occur, it would do so over a period extended by decades beyond a forest replanted with seedlings already established and planted at the optimal time of year for survival.

In the case of geoduck, it is estimated a harvested subtidal tract will take 40 years to repopulate in densities high enough to warrant reharvesting. Compare this to a crop cycle of 5 to 7 years currently taking place with commercial intertidal harvesting by private companies, in areas geoduck do not naturally grow.

Subtidal planting is happening now. In Alaska the first commercial harvests of subtidally planted geoduck are occurring. In Canada large sums of money are being drawn in from investors to further develop subtidal planting. Studies on impacts from harvesting subtidal plots up to 6,000 square meters (1.5 acres) in size have taken place there. In Puget Sound, divers from Spencer Cove report successful subtidal planting as high as 4 geoduck per square foot. Seattle Shellfish has leased subtidal tidelands from Manke Timber for the "cultivation and harvest of geoduck clams."

Numbers below compare a replanted subtidal density of 2 per square foot, harvested every 10 years (growth subtidally is slower), versus current management practices resulting in natural densities at .5 per square foot (a generous assumption*) harvested every 40 years. (*From Goodwin/Pease: "The average density of these young [geoduck] clams was 0.78/square meter in unfished areas and 0.54/square meter in fished [harvested] areas. The results indicated that fishing [geoduck harvesting] had an adverse effect on recruitment.")

Actively Managed: Harvesting Every 10 years
1 acre  = ~44,000 square feet
Planted (survival of 2/square foot) = 88,000 geoduck per acre
Harvested (2 pounds ea.) = 176,000 pounds of geoduck every 10 years

Unmanaged: Harvesting Every 40 years
1 acre = 44,000 square feet
Natural reseeding .5/square foot (most likely less) = 22,000 geoduck per acre
Harvested (2 pounds ea.) = 44,000 pounds of geoduck every 40 years

Over 40 years
Managed: 704,000 pounds of geoduck (4 separate harvests)
Unmanaged: 44,000 pounds of geoduck (1 harvest)

While there is an added expense of seedlings, planting, and having to use divers for harvesting (something intertidal growers do at high tide now), there are also economic upsides. Facilities to grow seed will need to be used. Divers to plant and harvest would need to be hired. Those divers would need commercial diving equipment. And, of course, there is the immense increase in revenues DNR would generate for the tribes and Washington from an acre of subtidal tidelands replanted after harvest.

Perhaps most significant of all is the current private commercial methods have transformed intertidal tidelands into geoduck farms, with both habitat functions and species diversity impacted.

Were DNR to actively manage its subtidal aquatic beds as well as it does its timberland, financial returns for the tribes and state would be greatly increased. Intertidal impacts would be lessened, if not eliminated. It requires effort and forward thinking. As Trustee of state lands, however, DNR has a fiduciary responsibility to manage them for the benefit of both current generations, and "...for generations to come."