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

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

The Junk Bond of Clams

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

Like the collapse of the junk bond market

so too is the market for geoduck collapsing.

(Picture from the Seattle Times)

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

The junk clam becomes a phallic symbol

with marketers in WA convincing Chinese men...

(From BBC)

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

You too can become rich. 

We'll keep 85% of the revenue

and farm whenever we think it's best,

however much we think we should.

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

That's fair, isn't it?

A fungus spreads in Washington's tidelands.

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

"Don't I have some say

in when you harvest these clams?"

Didn't read the fine print in the lease.

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

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

Like a bank, geoduck growers are insulated

when a market collapses.

 "Why were geoduck on my tidelands harvested

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

but a little late to ask.

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

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

Think politics doesn't matter?

It will when it comes to tariffs.

He who put tariffs on

can take tariffs off and claim

a "great deal" has been made,

whether real or not.

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

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

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

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

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

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

Tribal Entities Pressing for Subtidal Geoduck Re-Planting and Survey

[Update November 4: Information on the subtidal acreage (over 1,000 acres) in Hood Canal which the Port Gable S'Klallam Tribe has asked to be surveyed for the current population has been added. In addition, wording to clarify the subtidal area to "enhance" (replant) is that which has been harvested of wild geoduck, an area -18 to -70 feet deep.]

Port Gamble S'Klallam Tribal Request for Proposal (RFP) on Subtidal Geoduck Re-Planting

The Port Gamble S'Klallam Tribe (one of the four Klallam tribes) has requested proposals to study subtidal re-planting of geoduck after wild harvesting. Initially the RFP will be focused on literature, current methods employed, and how to improve the economic return from subtidal enhancement (planting). Proposals were due November 1.

RFP for Subtidal Survey of Over 1,000 Acres in Hood Canal
In addition to the re-planting project, the Port Gamble S'Klallam Tribe is also asking that over 1,000 subtidal acres in Hood Canal be surveyed to determine the current population of tracts, some of which have been harvested. The 22 separate tracts range in size from 6 acres to 294 acres. The subtidal acreage in the main body of Puget Sound, both harvested and not, is far greater.

 

Natural Recruitment After Wild Harvesting of Subtidal Tracts A Concern

In the Request for Proposal (RFP) a clear concern about the time it takes for a "harvested" subtidal tract to naturally replenish the population is noted. Concerns of over-harvesting is implicit.

"Current levels of subtidal harvest of wild geoduck populations may exceed the low natural recruitment rates of natural stocks."

Natural Recruitment Takes Time - A Long Time, if at All

Current estimates for a subtidal tract to naturally repopulate and reach maturity, in a density justifying harvesting, range from 40 up to 100 years. The range is dependent on how far away the remaining seed source is (i.e., mature geoduck not harvested), the topography and sediments of the bottom, and poaching. In a Seattle Times article published last year, Washington Department of Fish and Wildlife's (WDFW) Bob Sizemore, commenting on populations not being what they expected when surveying tracts previously harvested, was quoted as saying: "Poaching is very clearly a part of it — and in fact could be a very large part of it,".

 

Commercial Operations and Inventory Turns

Commercial intertidal areas (those tidelands exposed when the daily tides go out) using PVC pipe and "nursery seed" typically take 4 to 6 years to reach "market maturity" due to the size planted, warmer temperatures, and plankton typically being more plentiful in the nearshore area. Current subtidal planting occurring takes in the range of 7 to 8 years. (Note: Geoduck are considered "marketable" when they are 1.5 to 2 pounds per geoduck.) Assuming natural recruitment takes 40 years, subtidal planting of tracts whose wild geoduck have been harvested could increase "inventory turns" (and revenues received) by 5 fold. In addition, increased density through managed planting would further increase returns to the state and possibly the tribal entities.

Subtidal Tracts Managed by the State - Or Not
Virtually all of the subtidal lands of Puget Sound (those never exposed at low tide) are owned by  Washington state and managed by the Department of Natural Resources (DNR) and WDFW. The tribes, through treaty rights, participate in 50% of the revenues generated from geoduck harvesting. A small percentage of subtidal lands is privately held with industry divers stating planting densities of up to 4 per square foot are being achieved on some of these private subtidal lands. Unlike state and privately owned forest land which is required to be replanted after harvesting the subtidal tracts are simply stripped of the wild geoduck (estimated at over 4 million pounds per year) and left to recruit naturally.

Subtidal Geoduck Planting Expanding
John Lentz with Chelsea Farms is currently attempting to obtain a permit to grow geoduck on a subtidal plot near Burley Lagoon, and according to sources in Alaska, is currently participating in subtidal farming there. Taylor Shellfish has stated their desire to plant up to 30 acres within Burley Lagoon, a portion being subtidal. As noted above, divers in the industry have stated subtidal planting on privately owned subtidal tracts in Washington is already occurring with densities of up to 4 per square foot being achieved.

Is Seed Limitation a Problem?
Currently the availability of "seed" limits the amount of planting which occurs in Puget Sound. It is also a limiting factor in Alaska. But the expansion of hatchery and nursery facilities is occurring. As an example, Seattle Shellfish has discussed a hatchery facility on its Harstine Island property adjacent to Spencer Cover where its floating nursery facility already exists. Nursery facilities for oysters in marinas are currently being permitted which, when used for geoduck, would increase the supply. Within DNR seedling facilities for reforestation are managed by the state. Geoduck seed should be no different.

Lummi and Port Gamble S'Kallam Tribal Partnerships
More focused on tribal needs is the fact that the Lummi Tribe is currently one of the largest suppliers of geoduck seed to the industry. The Lummi could easily decide to provide seed to their tribal partners. Alternatively, the "technology" currently used by the Lummi Tribe (a converted fish hatchery, easily replicated) could easily be shared with the other tribal entities in Washington (e.g., the Squaxin, Nisqually, and Puyallup tribes). So doing would greatly enhance the subtidal management and planting, resulting in larger returns more quickly to the tribal members.  Were DNR and WDFW to agree that replanting the harvested subtidal tracts is, in fact, a viable means of "managing" state resources, both entities would benefit, including taxpayers.

It's Where they Grow Naturally and Where they are Being Removed From - And Is Vast
In the subtidal area between -18 and -70 feet, as noted earlier, over 4 million pounds of wild geoduck are being harvested subtidally each year. In Hood Canal alone, the Port Gamble S'Klallam tribe is asking over 1,000 acres be surveyed. It is where they grow naturally and where vast tracts are being left empty after harvest. Intertidal planting is occurring at elevations geoduck never grew naturally (up to +3.5 feet) displacing native species which use that habitat. To not replenish geoduck in lands under state management is an oversight. The Port Gamble S'Klallam tribe's press to make this happen should be a welcome step. It would also eliminate virtually all of the current anxiety over intertidal planting.

Washington Department of Natural Resources to Consider Leasing Public Inetertidal Tidelands to Geoduck Growers

The Washington Department of Natural Resources has announced it is considering leasing some of the few remaining public tidelands to a select group of geoduck growers. Included from the 2006 lease proposals are Seattle Shellfish (Taylor Bay), Arcadia Point Seafood (Dikenson Point), Taylor Shellfish (as subcontractor to Case Cove for Herron Lake bid), Allen Shellfish (Wilson Point, Hartstine Island), and Discovery Bay Shellfish (North Navy). Leasing of these tidelands was first proposed in 2006 by then Commissioner of Public Lands Sutherland. The project has been on hold until now.

Strip mining or managing tidelands?
What people should ask the Department is why are they leasing the few remaining intertidal public tidelands instead of replanting the subtidal tracts being clearcut by dive harvesters. Instead of replanting subtidal areas, a process already taking place in Alaska and Canada, they simply wait for natural seeding to take place, a process estimated to take up to 40 years. In Alaska and Canada, subtidal planting matures in 7 to 8 years. A current proposal for a private subtidal farm estimates 5 to 7 years for maturity.

Why are geoduck different than timber?
Is this managing state tidelands or simply bending to the political pressures put forth by the geoduck growers who have found leasing of private tidelands played out? The Department has a far different management philosophy when managing its timberlands. After clear cutting, timberland is required to be replanted so a new stand of timber is ready for harvesting in 40 years instead of waiting for natural seeding to take place, a process which can take up to 100 years and results in stands that are far more difficult to manage.

Is "science" really science?
In 2007 Sea Grant began studies of geoduck harvesting. Part of that process was to include peer review of studies to determine impacts. To date there has been no peer review of the significant "studies" relied on. In fact, at a recent Shorelines Hearings Board hearing a scientist pointed out how weak the sample sets from which conclusions were being drawn were. So weak that were it a Master's Thesis it would have likely been rejected.

You should first replant what you've harvested. It's resource management.
The public shorelines of Puget Sound are a treasure which was recognized when the Shoreline Management Act was passed. Bending to the political  pressures of lobbyists and public relations firms is why it was created in the first place. It should not be allowed to be bent to those same pressure now. If the Department wants to consider leasing tidelands for geoducks they should first be replanting those subtidal tracts they are clear cutting.

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."