Taylor Shellfish Mussel Raft Permit Decision: Cumulative Impacts Not Adequately Considered

Thurston County's Hearing Examiner has issued a decision on Taylor Shellfish's proposed 58 raft mussel farm: cumulative impacts were not adequately considered. Taylor Shellfish has been given a choice on how to deal with this deficiency.

"First, it [Taylor Shellfish] may inform the Hearing Examiner that it wishes to challenge the determination that the present analysis of cumulative impacts is deficient and the requirement to perform an additional cumulative analysis. In that case, I will issue a supplemental decision denying the application on that basis, and the Applicant may appeal. Alternatively, the Applicant may inform the Examiner that it wishes to carry out the analysis of cumulative effects required by this decision. In that case, the Examiner and the parties will confer about the timing and nature of that analysis."

(click here for complete decision: http://www.co.thurston.wa.us/permitting/devactivity/totten/hearing/961372.decision.taylor.pdf)

As noted in this blog and by others for many years, one shellfish farm may appear to be benign. When considered as a whole, however, Puget Sound's long term health is at risk from the cumulative impacts from the growth of industrial shellfish farming. Cumulative impacts do matter and they are significant. Thanks to APHETI this reality is now being forced to be considered by agencies.
(Note: To be added to APHETI's email list, you may email them at: APHETI@gmail.com.)
Current examples of cumulative effects:

New Geoduck Nursery in Spencer Cove

NE Harstene Island, ~300' in Length

(click to enlarge)

(needed for "increased geoduck seed demand")

Corporate Shellfish Barge

3 ea. 200 hp Outboard Motors

(click to enlarge)

(growing production is resulting in growing demand

for increased transportation)

Area of Low Dissolved Oxygen

In Totten Inlet Near

Taylor Shellfish's Processing Plant

Which Discharges ~150,000 Gallons of

Waste Water Each Day

(increased production at Taylor plant will result

in more waste water being discharged)

Farms Continue to Loose PVC Tubes in 2012

After Email to County in 2010

(click to enlarge)

(The old "Brass Foundry" on Highway 101 near Shelton 

is now being used as a storage area for PVC pipes.)

Cumulative impacts from corporate shellfish farming's developments in Puget Sound's tidelands and waters are real and they are impacting Puget Sound. The Shoreline Management Act was created to prevent the piecemeal development of Puget Sound's shoreline. Its intent is beyond question. This decision will help ensure that intent is met and corporate profits will not become the overarching philosophy.

Taylor Shellfish Mussel Farm Permit Decision Postponed to July 19

The permit decision for the proposed 58 raft mussel farm operated by Taylor Shellfish has been pushed out to July 19. Maintaining Totten Inlet's water quality is of critical importance. Maintaining the quality of life enjoyed by Washington's citizens who experience Totten Inlet is of equal importance.

While the shellfish industry may be important to some, this does not trump the Shoreline Management Act's focus to prevent the fragmentation of Puget Sound's tidelands and waters by corporate interests' developments.

For those who wish to have emails from APHETI (Association for the Protection of Hammersley, Eld and Totten Inlet) on the status of this permit you may send an email to APHETI@gmail.com and ask to be added to their email list.

Post Hearing Briefs for Taylor Shellfish Mussel Farm in Totten Inlet are Submitted

The post-hearing briefs on Taylor Shellfish's proposed 58 raft mussel farm in Totten Inlet have been submitted to the Thurston County Hearing Examiner.  The permit decision will rest on whether Taylor Shellfish has satisfied its "burden of proof" requirement and proven the most pristine estuary in South Puget Sound, with waters categorized as "extraordinary", will not be degraded with the addition of 58 more rafts growing non-native mussels.  Among other things, their testifying that dissolved oxygen levels within, below and around current mussel farms - and by extension the proposed farm - fall to hypoxic levels is a self-inflicted "burden" they did not overcome.

APHETI Post Hearing Brief:  (click here)
Taylor Shellfish Post Hearing Brief:  (click here)

One of Two Existing Taylor Mussel Farms in Totten Inlet

Which Causes Dissolved Oxygen Levels to Reach Hypoxic Levels 

(click to enlarge)

"There isn't any place I'm aware of that the tunicates are causing harm on the shellfish farms,"

Why would Taylor Shellfish state "There isn't any place I'm aware of that the tunicates are causing harm on the shellfish farms,"
http://www.cbsnews.com/8301-501363_162-57331539/environmental-programs-fall-victim-to-budget-cuts
"When Washington's Legislature trimmed $30 million, or 27 percent, from the state Department of Fish and Wildlife's budget, three employees who had been diving in the Puget Sound to hunt down invasive sea squirts lost their jobs.
The gelatinous invaders, known as tunicates, form a goopy mat on the sea floor, raising fears that they will hurt the shellfish industry, as they have in eastern Canada.
"We are basically addressing tunicates on an emergency basis only," said Allen Pleus, Washington state's aquatic invasive species coordinator..."There isn't any place I'm aware of that the tunicates are causing harm on the shellfish farms," said Bill Dewey, of Taylor Shellfish Farms in Shelton, Wash."
Images from Woodshole seem to clearly show non-native invasive Tunicates causing harm at Taylor Shellfish's mussel rafts in Totten Inlet:
http://woodshole.er.usgs.gov/project-pages/stellwagen/didemnum/images/pdf/wash4b.pdf
The British Columbia Shellfish Growers Association says this on their Aquatic Invasive Species page:
"On Canada’s East coast, invasive tunicates have resulted in significant grow-out, harvesting and processing challenges for the mussel farming industry."
"Tunicates can out compete and suffocate filter feeding bivalves such as mussels and oysters."

Taylor Shellfish has a great deal to loose if their mussel farm is found to be a vector for non-native invasive tunicates.  Taylor Shellfish has a great deal to loose if these tunicates smother their cultured mussels (which the Woodshole images seem to show clearly happening).  Taylor Shellfish has a great deal to loose if what they believe isn't currently causing harm begins to smother oysters which other growers in Totten Inlet and south Puget Sound are culturing.

Sometimes it is better to react to a problem before it becomes an ecological disaster.  Washington State should reconsider its budget cut which eliminated the Washington Department of Fish and Wildlife's program to control invasive tunicates.  Taylor Shellfish should reconsider their statement, for the good of everyone, and work towards helping reinstate funding for WDFW to control this very real threat to Puget Sound's ecosystem.