Thurston County is Targeted By Geoduck Farmers

Better Duck if you live in Thurston County 
The latest county to be targeted for expansion by geoduck farmers is Thurston County. Located in south Puget Sound, Thurston County has seen a number of proposed or actual applications for geoduck farms in the south Puget Sound area. The most recent is an expansion of operations by Greg Reub, currently employed by Eco Analysts, Inc. Previous employment history of Mr. Reub included Environ (now part of Ramboll), a firm who performed numerous studies on geoduck aquaculture, intended to show impacts were not significant. Studies still quoted today and studies which Mr. Reub benefits from directly. [A public hearing on Mr. Reub's proposal will be held September 26. To be put onto the notification list, contact Leah Davis at davisle@co.thurston.wa.us]

(In addition to Mr. Reub, Dr. Fisher and Marlene Meaders were also past employees of Environ, the latter two co-authoring numerous papers on geoduck farming and the application of the herbicide imazamox in Willapa Bay. Dr. Fisher, as with Mr. Reub, benefits directly from positive outcomes of papers he authored on geoduck farming as he too operates a geoduck farm, close to that currently operated by Mr. Reub and close to where Mr. Reub proposes to expand his operations. Dr. Fisher, after leaving Environ, worked for the National Marine Fisheries Services - NMFS - who provided Biological Opinions to the Army Corps on their proposed Nationwide Permits covering aquaculture.)

An existing navigational hazard,

with another proposed.

Showing some mussel
In addition to Mr. Reub's proposed expansion, Chelsea Sea Farms is also proposing a 10 acre operation in Gallagher Cove near where Taylor Shellfish is planning on placing 58 rafts in Totten Inlet. At appeals and hearings for the Taylor Shellfish proposal there was no mention of any geoduck operation so close and what the cumulative impacts may be from the two operations may be, not to mention Mr. Reub's proposed expansion just north. The common refrain from attorneys at the hearings and appeals was that any expansion of aquaculture was simply "conjecture" and should not be considered. Therefor, Thurston County did not consider any of it and simply relied on an overwhelmed staff and papers, including those authored by Dr. Fisher and Mr. Reub.

One word - plastics
The Graduate could not have had a more applicable scene when Dustin Hoffman was told by Mr. McQuire what to do with his life after graduation: "I just want to say one word to you. Just one word....Plastics. There's a great future in plastics." Who would have thought plastics covering Puget Sound's intertidal tidelands would have been the future that unfolded.

Get involved. You will make a difference for the future generations.
The shellfish industry has been for years. Lobbying, free shellfish fests, donations to non-profits, and authors of papers who have clear conflicts of interest have all resulted in an impending expansion throughout Puget Sound and Willapa Bay. You can help by donating to the following:

Consumers for Food Safety [click here]
Tell your elected officials enough is enough.
Governor Inslee: https://fortress.wa.gov/es/governor/
Legislative and Congressional contacts:
http://app.leg.wa.gov/DistrictFinder/
Thurston County Commissioners
http://www.co.thurston.wa.us/cm/email/email.asp?mod=1

Aquaculture's Impacts: Center for Food Safety Sues Army Corps Over Lack of Regulatory Oversight

What could go wrong? The more the better.

Good for the profits of a few,

bad for all who care about 

Washington's marine habitat.

The Center for Food Safety filed a lawsuit August 10 against the Corps of Engineers' decision to issue 2017 Nationwide Permit 48 covering aquaculture activities, asking the courts to:

 (1) declare the Corps’ decision to adopt 2017 NWP 48 in Washington State is unlawful under the CWA, NEPA, and arbitrary and capricious, in violation of the APA; (2) set aside or vacate the Corps’ March 17, 2017 decision to adopt 2017 NWP 48 in Washington (effective March 19, 2017); (3) declare that the Corps, prior to adopting any new NWP for commercial shellfish aquaculture, must comply with NEPA, including the preparation of an EIS, and the CWA, including the requirement that any general permit not cause more than minimal adverse individual or cumulative impacts to Washington’s aquatic environment. 

Read US News article here:
https://www.usnews.com/news/best-states/washington/articles/2017-08-11/lawsuit-targets-federal-oversight-of-shellfish-farming
Read article in The Olympian here:
http://www.theolympian.com/news/business/article166729272.html

Good old boys, slapping the backs

of politicians, paying a dollar here and there,

with a free oyster or two. It goes a long way.

(2016 lobbying visit by shellfish growers in DC)

In the papers filed, the Center pointed out one of the most glaring assumption swallowed by the Corps at the behest of the shellfish industry, defining a "new" operation:

The revised definition of “new” makes all operations “existing” so long as any commercial shellfish aquaculture took place in the area in the last 100 years. This would allow an operation in 2018 to be considered “existing” and thus avoid restrictions on “new” operations if, for example, oyster culture was conducted in 1919, with nothing in between.

Individual discrete parcels are becoming

one large area with multiple harvesting

cycles impacting the marine habitat

on an ongoing basis. 

Cumulative impacts matter.

Kao Torgeson Roosa - Pierce County, Public Hearing September 27, 9AM (Confirm with Ty Booth at ty.booth@co.pierce.wa.us or 253-798-3727)
Cumulative impacts matter and isolated events do not represent impacts adjacent operations create or vastly increasing operations creates. Throughout Puget Sound alone, what had been individual parcels are now becoming one large contiguous operation. These operations operate on multiple cycles creating an ongoing impact to the marine habitat on a scale not studied. One example is in Pierce County where two previously separate parcels operated. Now before the County is a permit request which would result in one large contiguous parcel. In Burley Lagoon, Taylor Shellfish is proposing a 25 acre operation. Thurston County has a 10 acre operation proposed by Chelsea Sea Farms and numerous smaller parcels. As noted in the papers filed, cumulative effects is defined as:

the changes in an aquatic ecosystem that are attributable to the collective effect of a number of individual discharges of dredged or fill material. Although the impact of a particular discharge may constitute a minor change in itself, the cumulative effect of numerous such piecemeal changes can result in a major impairment of the water resources and interfere with the productivity and water quality of existing aquatic ecosystems. 

Get involved and help support Center for Food Safety's efforts.
The papers filed go in to great detail about the current and future adverse impacts which will result directly from the Corps's issuing the 2017 Nationwide Permit 48 covering aquaculture. While lobbying over the past 3 years was effective in minimizing regulatory oversight of the shellfish industry by the Corps, that does not mean it should be accepted. You can help ensure the future of Washington's marine habitat will be protected by helping.
Read the Center's release here: 
http://www.centerforfoodsafety.org/press-releases/5039/center-for-food-safety-sues-trump-administration-to-protect-washingtons-coastal-waters#
Donate to the Center for Food Safety here:
https://secure.actblue.com/contribute/page/supportcfs
Read the suit filed here:
http://www.centerforfoodsafety.org/files/2017-8-10-complaint_final_95352.pdf

September 13, 1PM: Army Corps' Update on Regulatory Oversight

Update September 13: In January, Bill Dewey with Taylor Shellfish and Vicki Wilson inserted an absurd definition of what an "existing" aquaculture activity is into the proposed SMP update for Mason County. They defined an existing activity as being any tidelands sold in Washington under the 1895 Bush and Callow Act. Even if nothing was planted over 120 years ago. Politics pays and profits flow.

Paving a Fallow Brick Road 

With PVC and Plastic

Contact, by Monday afternoon, for Web and/or audio participation on September 13

Patricia Graesser, Public Affairs Chief

phone: (206) 764-3760
e-mail: patricia.c.graesser@usace.army.mil

Where are we and how did we get down this road?

September 13 the Army Corps of Engineers will hold a meeting to discuss their current situation as it relates to regulating the shellfish industry in Washington. A similar meeting was held on April 20 (click here for a pdf overview of that meeting).

The preliminary agenda is as follows:

1:00 p.m. Welcome By Col. John Buck, District Commander, Seattle District, U.S. Army Corps of Engineers
1:05 p.m. Brief overview of the Corps aquaculture regulatory program
1:15 p.m. Update on ongoing activities:
Status of the programmatic Endangered Species Act consultation for shellfish activities in Washington
Permit tools for 2017
Upcoming milestones and opportunities for involvement

• 1:45 p.m. Questions & Answers
• 2:45 p.m. Closing Remarks

Politics pays - and when you have lots of money it helps move the process in your direction

Related to the ongoing Army Corps' oversight of this industry which wishes to greatly expand its footprint in Puget Sound and elsewhere are Biological Opinions released by the US Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS). In 2015 the Corps asked each to provide their opinions on information provided to them by the Corps, in turn largely provided by the shellfish industry, on whether acres of aquaculture proposed and anticipated would have an impact on Puget Sound's habitat and species of concern.

Zangle Cove: Fallow or never planted?

Not "historically used for aquaculture" as claimed

in a permit application for a new geoduck farm.

Fallow me down the golden brick road

A summary document explaining the past history, which in part exemplifies the challenges with gathering information from the shellfish industry, may be found by clicking here. One of the primary issues relates back to 2007 permits which included ‘areas that are periodically allowed to lie fallow as part of normal operations’ in the public notice. This gaping door left open, by not defining what "fallow" means, was taken full advantage of by the industry, claiming huge numbers of acres not planted currently were simply lying fallow, implying they had been used at some undefined time in the past. Current proposals for the Nationwide permits call for defining "fallow" as tidelands not having been planted for as long as 100 years. As seen below, this has led the Corps to believe over 14,000 acres not planted were not done so simply because they were "fallow".

Put on the BiOp focals to review the opinions

Currently, "fallow" areas are included in the information presented to FWS and NMFS, asking them to rely on that information and to issue opinions on what the Corps should do. Those Biological Opinions are located here:

Click here for NMFS Biological Opinion

Click here for FWS Bilogical Opinion

You're going to need these to get through those opinions.

Read along with me and get involved

Currently the Corps is in the process of reviewing the opinions submitted by FWS and NMFS. As it is unknown at this time whether any changes or refusals to accept what each say it is best not to comment. But what is clear is the Corps and services have been put under immense political pressure to help promote this industry. Good intentions can get lost when politics get involved. Hoping for the best when industry is driving a process will not result in the best interests of the public. Get involved. The shellfish industry is and what they want is not good for Puget Sound and species dependent on the integrity of its habitat.

Reminder: Comments on Nationwide Permits on Aquaculture Due August 1

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

Coalition comments - https://app.box.com/s/b0hcwigv1ksuomjqgajtrwwt6b3sub4h

Burley comments - : https://app.box.com/s/ilx2d4esaxjztucxksz1rmmj3cyn2d81]

Lobbying Pays

Reminder: Comments on proposed Nationwide Permits for 2017 are due today. Changes to Nationwide Permit 48 which permits aquaculture activities (or not) are briefly discussed below. It is apparent the lobbyists have been active.

email: NWP2017@usace.army.mil
Include " COE–2015–0017" in the subject line.
Complete agency notice and reasoning is here:
http://www.usace.army.mil/…/nwp2017_proposed_fedreg_01june2…

[Note 1: Nationwide Permit 48 regulating aquaculture and proposed changes and reasoning is found on page 35202. A summary follows the end of this post.]

[Note 2: The Seattle District will add additional conditions in the near future, providing an additional opportunity to provide comments.]

"Hey now, just because this baby hasn't been 

driven in 20 years and it's over 30 years old

doesn't mean it's not as good as new. Right?"

The new new (or, what lobbying can buy you)

Proposed: "We are proposing to define a 'new commercial shellfish aquaculture operation’ as an operation in a project area where commercial shellfish aquaculture activities have not been conducted during the past 100 years."

Should an area in which some undefined form of "commercial aquaculture " occurred over the past 100 years be automatically approved? The shellfish industry has been lobbying intensely in Washington DC to lessen Army Corps oversight and to "..to further streamline the authorization process." Included is anything giving an operator a "...legally-binding agreement which establishes an enforceable property interest for an operator." [What does that mean? Does a 1901 tideland deed from the state of Washington create an enforceable property interest which can be passed on to an operator by a new owner?]

As noted, one of the results is to change the definition of what a "new commercial operation" is, pushing the "bar of activity" back 100 years. Is it realistic to say that because great-grandpa threw some shells on tidelands in 1930, but then stopped in 1950 when he died, that a geoduck farm proposed today by a new owner who holds a deed to the tidelands is not a "new commercial operation"?

As an added bonus, is this: " The presence of submerged aquatic vegetation should not prevent the use of NWP 48 to authorize commercial shellfish aquaculture..." Eelgrass? Not so important now. IF there is any questions on impact, PCN's "...should be EXPEDITIOUSLY reviewed by the district engineer." (Put another way, "Hurry up and approve it because I want to start dredging in eelgrass for oysters.")

As noted, the Washington shellfish industry has been busy lobbying in Washington DC and the results are apparent. Below is a brief summary of proposed changes. Details are at the link above.

Get involved. The shellfish industry is.

Summary of proposed changes to Nationwide Permit 48 (aquaculture):
Project areas include lands where
other legally binding agreements
establish enforceable property
interests. Define “new commercial
shellfish aquaculture operation”
as operating in an area where
such activities have not occurred
during the past 100 years.
Remove the PCN threshold for
dredge harvesting, tilling, or
harrowing in areas inhabited by
submerged aquatic vegetation.
Does not authorize activities that
directly affect more than 1/2-acre
of submerged aquatic vegetation
beds in an area that has not been
used for commercial shellfish
aquaculture during the past 100
years. PCN must include all
species that are planned to be
cultivated during the period the
NWP is in effect. PCN must
specify whether suspended
cultivation techniques will be used
and indicate the general water
depths in the project area.

Lummi Tribe Objects to Coal Trains, Causing Corps to Reject Cherry Point Proposal

The Seattle PI writes on the Lummi Tribe forcing the Army Corps to reject the proposed Cherry Point coal terminal. To date the tribe has not objected to the ever expanding PVC and mesh tubes interfering with tribal fishing rights along the shorelines of Puget Sound.

Early Lummi Tribe

Geoduck Seed Hatchery

Look beyond the low tide line for alternatives.
Too bad the Lummi tribe doesn't sell their geoduck seed for replanting subtidal areas harvested by tribal members instead of for intertidal farms which require PVC and mesh tubes. Then, the Lummi may also have asserted their tribal fishing rights - and those of other tribes dependent on those rights - and objected to the current plans for increasing geoduck farm structures in the intertidal areas of Puget Sound which interfere with tribal fishing rights. That may have also caused the Corps to bring permitting of geoduck farms to a halt.

No Tribal Fishing

Allowed on this Beach

No fishing allowed. This beach is for geoducks sold to China, not tribal members to fish from.
PVC pipes and netting interfere with tribal fishing from the shoreline, and as more permits are approved for geoduck farms, less shoreline will be available for all tribes to exercise their tribal fishing rights. Requiring the state to replant subtidal areas stripped of geoduck - and providing an income stream for tribal members - has yet to be implemented.

Small steps.
Small steps taken sometimes get far distances. Were the Lummi and other northwest tribes to see the alternatives available to them they may one day also object to the ever expanding PVC and mesh tubes in the intertidal area which, step by step, are extinguishing their tribal rights to fish from the shores of Puget Sound.

Puget Sound Shellfish Growers Lobby to Remove Eelgrass Protection

"Jump!" "Yes sir! How high?"

Puget Sound Shellfish Growers to lobbyist - We will pay you well to convince Washington's legislative representatives to tell the Army Corps to eliminate this protection for eelgrass:

For continuing activities in ‘fallow’ areas, those activities shall not occur within 16 horizontal feet of native eelgrass (Zostera marina). If eelgrass is present in the vicinity of a fallow acreage proposed for shellfish activities, the eelgrass shall be delineated and a map or sketch prepared and submitted to the Corps. Surveys to determine presence and location of eelgrass shall be done during times of peak above-ground biomass: June – August. The following information must be included to scale: parcel boundaries, eelgrass locations and on-site dimensions, shellfish activity locations and dimensions.

Washington environmental groups, including the League of Women Voters, band together and ask representatives (see complete letter here):

Specifically, we are asking you to immediately retract your request to remove Condition 7 from the Programmatic Biological Assessment (PBA) for aquaculture permitting currently being developed by the Army Corps of Engineers.



Eelgrass - a critical habitat to everyone.

Except the shellfish industry.

Money solves everyone's political problem.
The shellfish industry of Washington has successfully enlisted Washington DC lobbyists to convince legislative representatives that protection of eelgrass should not be a priority. Using their own definition of what a "fallow" tideland area is, and creating a false description of what "Condition 7" would actually do, the Seattle Division of the Corps was forced to remove the protection to eelgrass which the above paragraph would have provided.

Eelgrass can grow here?

Voters solve problems with representatives beholden to lobbyists.
In the letter to the Corps the Washington delegation claims falsely that aquaculture has "... successfully co-existed with eelgrass for over one hundred years." This is patently untrue. Anyone who has witnessed acres of plastic grow-out bags on the tideland sediments has seen the complete lack of aquatic vegetation which exists. Anything which may have grown on the bags is either washed off or removed during harvest. Any eelgrass, or other aquatic vegetation, which may have existed is simply scoured away. Areas under longline/raft facilities are shaded, preventing growth, and when coupled with shells which drop off, are simply a dead zone beneath them. A recent permit for a subtidal geoduck farm adjacent to eelgrass beds in south Puget Sound was rejected due to its impact on eelgrass.

Our well being is more important than critical marine habitat.
In the letter from the congressional delegates to the Corps the Puget Sound shellfish growers are clear in what they care about - their profitability and ability to make more money at the expense of Puget Sound's critical marine habitat. The letter states:

"We are concerned that if Condition #7 were to go into effect, current shellfish operations would be adversely impacted and the continued growth of the shellfish industry - and the thousands of jobs it supports - could be negatively impacted."

You don't always get what you want.
Sometimes in business there are things more important than the profits a company makes. Whatever the false narrative created by the shellfish lobbyists, the reality is eelgrass is a critical marine habitat. It does not co-exist with the industrial level of shellfish production which now exits and which is proposed. It is why docks are heavily regulated. It is why bulkheads are heavily regulated. It is why any overwater structure is heavily regulated. It is why shellfish aquaculture needs to be brought under control. It has certainly played a role in Washington's history. But it is not "vital" nor is it the only reason tidelands were sold.

Get involved. Puget Sound is not a factory for producing shellfish.
The following groups have demanded eelgrass protection be put back in place. You can as well.
League of Women Voters of Washington; Sound Action; Washington State Chapter of the Sierra Club; Friends of the San Juans; Coastal Watershed Institute; Black Hills Audubon Society; Audubon Washington; Tahoma Audubon Society; Orca Network; Resources for Sustainable Communities; Wild Fish Conservancy; and, Seattle Audubon Society.

Legislators who sent the letter and should be contacted were:
(additional contact information may be found here: https://www.usa.gov/elected-officials)
 Senator Patty Murray 154 Russell Senate Office Building Washington, D.C. 20510
Senator Maria Cantwell 11 Hart Senate Office Building Washington, D.C. 20510
Representative Suzan Delbene 18 Cannon House Office Building Washington, D.C. 20515
Representative Rick Larsen 113 Rayburn House Office Building Washington, D.C. 20515
Representative Jaime Herrera Beutler 130 Longworth House Office Building Washington, D.C. 20515
Representative Dan Newhouse 641 Longworth House Office Building Washington, D.C. 20515
Representative Cathy McMorris Rogers 203 Cannon House Office Building Washington, D.C. 20515
Representative Derek Kilmer 1520 Longworth House Office Building Washington, D.C. 20515
Representative Jim McDermott 1035 Longworth House Office Building Washington, D.C 20515
Representative Dave Reichert 1127 Longworth House Office Building Washington, D.C. 20515-4708
Representative Adam Smith 2264 Rayburn House Office Building Washington, D.C. 20515
Representative Denny Heck 425 Cannon House Office Building Washington, DC 20515

Lower Dungeness River: Army Corps Releases Environmental Assessment for River Restoration for Comment

Why bother with restoring the Dungeness River
if you are only going to be putting
millions of PVC tubes and "predator" netting

in the intertidal marine habitat you are trying to improve?
[Note: This site supports this restoration proposal and
the Wild Olympics campaign, but it does not
support Taylor Shellfish's geoduck farm.]

Is this the balance the SMA is intended to ensure?

(click to enlarge)
 

DPR/EA Released for Comments (email: melissa.l.leslie@usace.army.mil)
The Army Corps of Engineers has released a draft Integrated Detailed Project Report and Environmental Assessment (DPR/EA) (6Mb file) for the Lower Dungeness River Ecosystem Restoration Project near Sequim. This restoration project would remove an existing Corps levee and reconnect the river to an historic floodplain and re-establish historic side channel and back channel habitat "critical for fish spawning, rearing, and refuge." Comments will be accepted until February 18. (Information on how to comment may be found by clicking here.)

Area of restoration preferred.

(click to enlarge)

Restoration of one habitat should not mean another is transformed into PVC and netting - for years on end. Recent tideland leases extend into 2050, encumbering tidelands for decades.
At the same time this project and other tribal and taxpayer funded restoration projects - which reach into the multiple millions of dollars - is occurring, Taylor Shellfish is proposing to place millions of PVC tubes, covered with netting in the delta area created by this river to grow geoduck for Chinese consumption. The ongoing cycle destroys/transforms marine habitat multiple times.

 Habitat Transformation Stage 1: >38,000 PVC/acre

are inserted and covered with "predator" netting.

Habitat Transformation Stage 2: After ~2 years, mussels

barnacles and aquatic vegetation has taken hold 

on the thousands of PVC tubes and "predator" netting. 

They are removed, leaving the monolithic population 

of geoduck in its place, sometimes covered

for another year with "predator" netting.

Habitat Transformation Stage 3: Harvest

Sediments to 3' in depth are liquefied

to remove the geoduck, leaving 

a barren moonscape in its path.

Months later, the PVC and "predator" netting return,

to begin the habitat transformation cycles again.

 

Restoration and protection of the Olympic Peninsula's watersheds and resources does not end at the high tide line.

Taylor Shellfish and Clallam County planners believing there is nothing wrong in spending multiple millions of dollars to restore the lower Dungeness River so millions of PVC pipes and netting may cover an area in the intertidal tidelands stretches reason. Taylor Shellfish supporting the expansion of wilderness areas and wild/scenic rivers through the Wild Olympics campaign "...so that shellfish companies can continue to grow..." (Bill Taylor on why he supports the Wild Olympics) should not be used as a veil to hide the reality of how geoduck farming is transforming the intertidal habitat areas of Puget Sound.

 

Joan Thomas, 1931-2011

Helped negotiate and pass the SMA.

"I do not read the original intent or the original guidelines

[of the SMA] to promote the [shellfish] industry

as we know it today." Joan Thomas, 1991

 

The Shoreline Management Act and shellfish aquaculture are no longer in-synch.

When the Shoreline Management Act was passed aquaculture was perceived as benign. In 1991 one of its original authors, Joan Thomas, recognized the transformation which had occurred in the industry. It has continued to evolve into the very thing which the SMA is in place to protect part of Puget Sound from: the fragmentation and fracturing of the intertidal area. Studies to date have looked at small and discrete farms which in no way compare to the current proposals nor methods used. That Taylor Shellfish sees nothing wrong with an operation of this type, of this size, and in this location only shows what it has evolved into.

National Marine Fisheries Service: Cumulative Impacts Not Considered by Nationwide Permits

Cumulative impacts: The impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such other actions. (40 CFR 1508.7).

(click here to read the Bilogical Opinion)

A Biological Opinion written by National Marine Fisheries Service (NMFS) has told the Army Corps their 2012 Nationwide Permits are not able to determine whether cumulative impacts  are adversely impacting the environment.  NMFS has told the Army Corps they will now need to take specific steps with NFMS's Regional or Branch Office to ensure cumulative impacts are in fact considered (beginning on page 225).

NMFS's Northwest Regional Office, including the Southwest Washington Habitat Branch covering Mason, Thurston, Pacific, Pierce and Grays Harbor Counties, are now responsible for overseeing the Army Corps' implementation of Nationwide Permit 48 which covers existing shellfish farms as well as proposed new farms or expansion of existing farms.  They will be responsible for determining whether, in fact, cumulative impacts from shellfish farming can be determined and whether they are occurring.

Will the "Shellfish Initiative" and "streamlined permitting" being promoted by NOAA, the department overseeing NMFS, allow for objective oversight?  As it relates to Puget Sound and aquaculture, it borders on the fox guarding the hen house.  Especially in light of the recent lobbying by the shellfish industry to minimize the Army Corps' oversight of their activities.

(Shellfish industry lobbying paper on

minimizing Army Corps' oversight)

(Click to enlarge)