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).  

 

 

Pierce County has released the Final Environmental Impact Statement (FEIS) on a proposed 25 acre geoduck farm in Burley Lagoon. There will be no public comments accepted. A 14 day period for an official appeal is currently in place.
The FEIS, supporting documents and timelines are available on-line, here:
https://www.piercecountywa.gov/burleylagoon

Al Bergstein writes on the recent presentation by the Center for Food Safety's attorney Kristina Sinclair. Ms Sinclair discusses the ongoing lawsuit against the Army Corps' permitting of shellfish farms in Puget Sound. 

Mr Bergstein's piece:  https://olyopen.com/2022/11/18/what-you-should-know-about-industrial-raised-shellfish-aquaculture-an-overview/

Ms Sinclair's slide presentation: https://olyopen.com/wp-content/uploads/2022/11/2022-11-17-Industrial-Shellfish-Slides.pdf

Contact Center for Food Safety here:

Pacific Northwest Office
2009 NE Alberta St, Suite 207
Portland, OR 97211
phone (971) 271-7372

(From Protect the Peninsula)

What You Should Know About

Insudstrial Raised Shellfish

Join Protect the Peninsula’s Future for its 49th Year Celebration (Virtual)

Thursday, November 17, 7:00 PM      

 RSVP to PPF@olympus.net to receive the Zoom connection*

Our featured speaker this year is Kristina Sinclair,

Associate Attorney at the Center for Food Safety

 

*Space is limited to 100.

Kristian Sinclair, Associate Attorney

Center for Food Safety

Kristina Sinclair is an Associate Attorney at the Center for Food Safety (CFS), where she focuses on environmental cases challenging industrial agriculture, including commercial shellfish.

Kristina earned her J.D. from the University of California, Berkeley, School of Law. While in law school, Kristina was an Articles Editor for the California Law Review. She also participated in the Environmental Law Clinic, served on the steering committee for Students for Economic and Environmental Justice, and worked as a teaching assistant for Appellate Advocacy. Upon graduation, she received recognition for her pro bono work and a Certificate of Specialization in Environmental Law.

Since joining CFS, Kristina has been working on a lawsuit challenging highly disruptive industrial shellfish operations in Washington. In this case, CFS and Coalition to Protect Puget Sound allege that the U.S. Army Corps (USACE) failed to properly consider the potential risks before reissuing the nationwide permit for commercial shellfish activities in January 2021, in violation of the Clean Water Act, National Environmental Policy Act, and Endangered Species Act. In addition, USACE has authorized over 400 commercial shellfish operations without any public notice or environment review. Consequently, these operations have significant adverse, effects on Washington's local environment and wildlife. 

 

 In this webinar, Kristina will provide an overview of USACE's shellfish permitting requirements, as well as the ongoing litigation challenging USACE's unlawful shellfish permitting actions. She will also share some insights from this legal work and potential opportunities for future advocacy. 

Background on USACE's Permitting Requirements
History of USACE's Unlawful Permitting Actions in Washington
Previous Case
Current Case

Future Opportunities

Tell DNR and USFWS It's a Wildlife Refuge

(See some of the many species here)

Get involved and make a difference for today and tomorrow, to help preserve one of the few National Wildlife Refuges supporting the great migrations of sea birds. An industrial shellfish farm does not belong in the Dungeness National Wildlife Refuge. 

Plastic Grow Out Bags Do Not Belong in a Wildlife Refuge

Beyond Pesticides has written a piece on why plastic grow out bags do not belong in a Wildlife Refuge, which includes a link for comments. 

As they note so well: 

The Dungeness Bay Wildlife Refuge was created by Executive Order in 1915 by Woodrow Wilson, directing the area to be set aside as a “refuge, preserve and breeding ground for native birds and prohibits any disturbance of the birds within the reserve.” The Refuge provides habitat, a preserve and breeding grounds for more than 250 species of birds and 41 species of land animals. 

The front page of the Refuge website states: “Pets, bicycles, kite flying, Frisbees, ball-playing, camping, and fires are not permitted on the Refuge as they are a disturbance for the many migrating birds and other wildlife taking solitude on the Refuge.” With this level of concern, it is counterintuitive to allow destructive industrial aquaculture. 

Beyond Pesticides Article

Submit Comments Here

An Industrial Shellfish Farm in the Dungeness National Wildlife Reserve is Not in the Public Interest

Make a difference in life. 

Help keep the Reserve intact.

Comments due by May 30.

Abandoned in 2005 - It should remain so.

Commercializing a Wildlife Refuge is NOT in the public interest, only in the interest of a few who stand to profit greatly from this rare public resource. Those few who profit will do so at the expense of fragmenting an intact ecosystem which is one of the few remaining on the West Cost used by migrating and resident water fowl. Shellfish farms can go elsewhere. Wildlife cannot. 

See Friends of Dungeness National Wildlife Reserve here: http://www.fodnwr.org/dungeness_oyster_farm.html

They have nowhere else to go. Shellfish farms do.

80,000 plastic bags do not belong in a Wildlife Refuge.

Putting a commercial shellfish operation, starting with 20,000 plastic bags and potentially growing to 80,000 bags, should not be permitted. It is not in the public interest. It is an unheralded expansion of intensity of an operation which was abandoned in 2005. There are alternative tidelands outside of the Wildlife Reserve available. 

See application here: http://www.protectpeninsulasfuture.org/wp-content/uploads/2020/04/NWS-2007-1213-PN.pdf

See Protect the Peninsula's Future "alert":  http://www.protectpeninsulasfuture.org/dungeness-refuge-alert/

See Protect the Peninsula's Future "how to comment section"  here: http://www.protectpeninsulasfuture.org/how-to-comment/

Get Involved.

Make a difference in life. Be able to say, "I helped to ensure the diversity of wild life will be here for future generations."

Comments to the Army Corps of Engineers due by May 30th: 

email pamela.sanguinetti@usace.army.mil    Reference Case #: 2007-1213.

Comments to the Department of Ecology:

email ecyrepermits@ecy.wa.gov Reference Case #: 2007-1213

(click to enlarge)

(click to enlarge)

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/

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.

Pierce County Shoreline Master Program Update: Final Decision by Council

Public testimony regarding Pierce County's SMP Update will be taken at the meeting or online. 

(See here: 

https://online.co.pierce.wa.us/cfapps/council/iview/proposal.cfm?proposal_num=2019-59)

SMP Update vote by Pierce County Council

September 10, 3PM

930 Tacoma Avenue South, Room 1045
Tacoma, WA 98402

(See meeting information here: 

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

After an appeal to the Growth Management Hearings Board by the shellfish industry's Taylor Shellfish, Seattle Shellfish, and, the Foss family's North Bay Partners (who leases tidelands to Taylor Shellfish) a decision by the Growth Management Hearings Board found Pierce County's updated Shoreline Master Program (SMP) to be too restrictive. As a result, a number of sections and amendments were dropped, some changed, others left as is. Generally, oversight of aquaculture has been made far more favorable to the industry. On the other hand, the GMHB did clarify that aquaculture does not have a priority over any other water dependent uses.
(See decision here: http://www.gmhb.wa.gov/Global/RenderPDF?source=casedocument&id=6516)
(See decision on a request for reconsideration here: http://www.gmhb.wa.gov/Global/RenderPDF?source=casedocument&id=6553)

After a public hearing was held August 19 by the Community Development Committee, and testimony heard, they recommended a "Do Pass".

(See information on that meeting here:

https://online.co.pierce.wa.us/cfapps/council/iview/committeeMeeting.cfm?id=3596)

Generally, oversight of aquaculture has been made far more favorable to the industry and state wide interests (however that is defined) were prioritized over the local interest. On the other hand, the GMHB did clarify that aquaculture does not have a priority over any other water dependent uses. 

Many people  devoted a great deal of time and effort in trying to ensure the marine habitat of Pierce County is preserved as best as possible. The aquaculture industry, and tideland owners who benefit financially from developments in their tidelands, devoted a great deal of money to ensuring their needs were met. Tomorrow, the Council will decide if they will accept what the GMHB has told them to.

Other legal efforts continue, some at a state level, others at the national level, with the goal being to preserve and protect the critical marine habitat unique to Puget Sound.

Friends of Dungeness Wildlife Refuge and Commercial Aquaculture

Friends of Dungeness Wildlife Refuge

on the proposed commercial shellfish operation

within the Dungeness National Wildlife Refuge

The Dungeness National Wildlife Refuge

Commercial Oyster Farm Proposed Within Refuge

The Jamestown S’Klallam Tribe has done many positive things for our community. They have worked with Friends and the Refuge for environmental restoration and other beneficial projects. We support their commercial aquaculture efforts. However, we do object to the proposed location within a closed area of the Refuge that is heavily used by wildlife.

Our concerns about the proposed oyster farm location: 
• The Refuge was established in 1915 by President Woodrow Wilson to protect wildlife. It was not established to conduct commercial aquaculture operations with non-native species. If allowed, what precedent might this set for the future?

• The proposed location is a high use area for waterfowl and shorebirds, especially for winter foraging. The area also has eelgrass, which provides habitat for forage fish and shellfish.

• The level of proposed activity in this location would present a great disturbance to wildlife.

• The proposed location could negatively impact the view and experience of the 100,000 annual Refuge visitors with the visual pollution of up to 80,000 plastic mesh bags, and boats and workers in the area.

• Plastic debris from the mesh bags is a concern. Wildlife could potentially get trapped in the mesh or ingest the plastic debris as it breaks down.

• Bags anchored to the ground could prevent native eelgrass from growing and may disrupt natural habitat on the seabed, reducing foraging areas.

• Noise pollution from workers, boats, and equipment may scare wildlife, causing health issues, or abandonment of the site. Noise may also disturb Refuge visitors and neighbors on the bay.

You may submit comments to Clallam County. Click here to submit or read the Documents about the proposed oyster farm.

Click on the link above, then find several detailed documents regarding the proposal, exhibits, and public comments. On the top right of the page you will find links to submit a comment by email or fill out a an online form. Update – The scheduled April 4, 2019 public hearing has been postponed. The Tribe is seeking government to government negotiations regarding the proposed location. Public input is still being received by the County.

The Great Migration of PVC to Puget Sound Tidelands Begins

Daylight minus tides arrive in April

and with them comes 

the 'Great Migration of PVC' to south Puget Sound

Minus tides bring much to light.

Like the great migrations of swallows returning to Capistrano or salmon returning to spawn in the gravel beds they were created in, so too do the tons of PVC pipe and mesh tubing used by the shellfish industry return to south Puget Sound when the daylight minus tides arrive in Spring. 8" PVC tubes placed one per square foot are used to grow geoduck for the elite in China, the only ones who can afford the $100/pound price. At the expense of Puget Sound's lowest and most unique intertidal area.

In Governor Inslee's "Green State"

plastic straws and plastic bags are banned. 

PVC pipes and HDPE bags in Puget Sound?

"It's habitat." 

So is an oil drilling platform.

That doesn't mean it belongs in Puget Sound.

Loose PVC tubes in South Puget Sound.

Comment from shellfish employee: 

"Geoduck push them out, 

and unless there is a major wind event, they'll stay put."

Except they don't, with wave energy and tidal currents

moving the tubes throughout the marine habitat area.

Not to mention what a mess it is.

Get involved and make a difference in life today and for the future. Help support those trying to preserve and restore Washington's critical marine habitat, an area unique to Puget Sound and which the shellfish industry sees as little more than a template to generate profits from. Whether protecting the waters from from pesticide application in Willapa Bay or excessive permitting for shellfish operations, these groups are making a difference. 

Coalition to Protect Puget Sound Habitat: http://coalitiontoprotectpugetsoundhabitat.org/

Center for Biological Diversity: https://www.biologicaldiversity.org/about/

Center for Food Safety: https://www.centerforfoodsafety.org/about-us

And tell Governor Inslee that if he's going to run for the presidential office as a "green politician" he should consider what's going on in Puget Sound under his leadership as Governor.

Oyster Industry, Politics and Pesticides

Read it and weep.

This is not a good idea.

(Purchase "Toxic Pearl" at Orca Books)

Who needs science when you can spend the money on politicians instead?
The Seattle Times writes on the current push by politicians who feel the oyster industry should be free to spray pesticides on oyster beds and the marine waters of WA so they won't have to spend money on improved growing techniques. Or on science which shows this ill thought idea is somehow in the statewide interest.
Read the article here: https://www.seattletimes.com/seattle-news/environment/politics-has-science-on-the-run-and-not-just-in-the-other-washington/

Like a bad oyster,

this just makes you sick.

Ad nauseam: It makes you feel worse than a bad oyster because it just keeps coming and coming.  
Unlike what the recent lawsuits filed against Pierce County by Taylor Shellfish and the Foss family claim, ad nauseam, the Shoreline Management Act is not in place to "plan for, foster, and give preference to aquaculture." It is in place to protect the critical marine ecosystems from industries who have become blinded by profits and feel their developments and actions within this ecosystem should be allowed to grow, unfettered, free from oversight.
Read Taylor lawsuit against Pierce County's Shoreline Master Program here:
 https://app.box.com/s/mjxvavgay49rqcs3fwvvw09utjjegu28
Read the Foss family's companion lawsuit here:
https://app.box.com/s/aaiclnj3ovyq9h5n5ix4mhi90wcdpgsa

"Shazam! I've created something from nothing!"

It doesn't matter how many times you say it. It's not there.
Nowhere in the Shoreline Management Act does it say aquaculture is supposed to be fostered and given preference over everything else as these suits, and the Department of Ecology seems to believe. The priority of the SMA is to protect this unique and fragile ecosystem from fragmentation.

The Shoreline Management Act is not subservient to NOAA policies created to do nothing more than promote aquaculture, many times based on dubious - at best - "science".

The Departement of Ecology's "handbook" on aquaculture painfully tries to outline the "legal" framework for why aquaculture should be placed on a pedestal, tripping over NOAA and national policies. The reality is the Shoreline Management Act was passed before NOAA's Coastal Zone Management Act. It was passed before the National Shellfish Initiative was created. It was passed before Washington's shellfish initiative was created. The SMA was voted on, and approved, by the citizens of WA.  Most importantly, both the National and State initiatives are nothing more than marketing documents created by lobbyists for the industry and politicians beholden to those lobbyists. They were not voted on - and overwhelmingly approved - by citizens.

Get involved. There are 3 bills politicians are trying to pass which would allow the application of Imidacloprid, a non-discriminate neurotoxic pesciticide (it doesn't care if you're a shrimp or a crab or any other crustacean) on oyster beds and Washington's marine waters. Tell your representative(s) and Governor Inslee the Shoreline Management Act is not meant to allow a wave of the wand to allow pesticides in Washington's marine waters. 

House Bills 1611 and 1037
https://app.leg.wa.gov/pbc/bill//1611
https://app.leg.wa.gov/pbc/bill//1037

Senate Bill 5626
https://app.leg.wa.gov/pbc/bill//5626

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