Drakes Bay Oyster Company Sued by California River Watch for Violations of Clean Water Act

Drakes Bay Oyster Company's refusal to cease operations in the wilderness area which Drakes Estero is part of has resulted in another lawsuit being added to those it has already caused. Added to their legally flawed request for consideration of an appeal before the Supreme Court, and their logically fractured suit against the California Coastal Commission, DBOC now finds itself being sued by the California River Watch for their ongoing violations of the Clean Water Act (see below for press release).

 

Structures of pressure treated wood

should not be allowed in a wilderness area.

 

 

Despite a well polished public relations campaign to support one family's continued commercial operation in a wilderness area, the fact is the Lunny family purchased an operation with a lease they knew would end in 2012 and which, under the Wilderness Act, they clearly knew would not be renewed. Pressure treated wood structures, plastic grow-out bags and the use of motor boats are not compatible with the Philip Burton Wilderness Act, created in 1976 by Congress under the Wilderness Act. No matter how hard you wave your arms the legal arguments to support the commercial operation will not fly.

 

Peter Prows, PR Attorney for DBOC

"The plan is for the ranchers to be next."

Pacific Legal Foundation Video

 

Attempts to claim this is the first step in part of a "grand plan" to eliminate ranching on Point Reyes, then Marin County, followed by Sonoma County only show how desperate the DBOC legal team is to gain traction. Peter Prows, public relations attorney for DBOC, continues to repeat the unfounded belief that this is part of some "plan" to remove cattle ranching from Point Reyes. Unlike the industrial shellfish operation in the marine wilderness, Congress specifically wrote into law cattle ranching as an exemption. Attempts to re-write the law are made with an pen lacking ink.

 

It is time for Drakes Bay Oyster Company to cease operating and allow for completion of the only marine wilderness area on the west coast.

 

Press release:

 

Drakes Bay Oyster Co. Sued by California River Watch for Violations of Clean Water Act

California River Watch, a Sebastopol-based organization devoted to protecting Northern California's water quality, filed a lawsuit against the Drakes Bay Oyster Company on February 7^th, saying the commercial shellfish business operating in the Point Reyes National Seashore is polluting the national park waters and ocean with waste water, plastic, and invasive species and has failed to obtain the required pollution discharge permits for over seven years.  "Drakes Bay Oyster Company, which has been repeatedly cited by state agencies for its pollution, failure to obtain permits, and violations of environmental protection laws, is at it again," said Larry Hanson of California River Watch. "The Drakes Bay Oyster Company’s lack of respect for the federal Clean Water Act fouls our national park waters and degrades one of the most ecologically important wilderness areas established in the United States."  Read the River Watch lawsuit.

Drakes Bay Oyster Company - Jim Linford and Legislative Intent

Supreme Court Justice Scalia: “The manner in which the law ‘could have been written,’ has no bearing; what matters is the law the Legislature did enact. We cannot rewrite that to reflect our perception of legislative purpose.” Shady Grove Orthopedic Associates v. Allstate Insurance Company, No. 08-1008, slip op. at 9 (March 31, 2010)

The Perception
Jim Linford, semi-retire appellate attorney, writes in the October 10 online issue of the Marin Independent Journal about his perception of what the Court of Appeals for the 9th Circuit judges agreed on in their 2-1 ruling against Drakes Bay Oyster Company's continued commercial operation within Drakes Estero, part of the Phillip Burton Wilderness. In his opinion piece he writes on his belief that all judges agreed on what the "intent" of Congress was decades ago when the Phillip Burton Wilderness was created. In support of this belief he lifts part of one sentence from the decision and includes it in his writing:

The dissent fully develops this understanding of the original congressional intent, and the majority acknowledges "the accuracy of the dissent's recitation of the legislative history of the 1976 Act." [The Point Reyes National Seashore]

Marin County Fog
In resolving the issue of whether the Secretary of the Interior had the discretion to issue or not issue a special use permit, selectively pulling pieces of relevant documents (in this case the Court's decision) fogs the reality of the decision. Mr Linford neglects to point out that the decision also contained this paragraph written by the majority, specifically focused on the relevance of the minority's idea of what may have been the "intent" of Congress:

The dissent’s reliance on decades-old legislative pronouncements about the Johnson oyster farm for the proposition that Section 124 was intended to foreclose the Secretary from considering his department’s own policies with regard to Drakes Bay stretches even the most liberal use of legislative history to the breaking point. “[U]nenacted approvals, beliefs, and desires are not laws.” Puerto Rico Dep’t of Consumer Affairs v. Isla Petroleum Corp., 485 U.S. 495, 501 (1988). (emphasis added)

As they note, whatever the perceived "intent" of Congress one may have, and whether it was accurately recited or not, it is irrelevant to whether the Secretary had the discretion to issue a permit. The majority writes clearly and forcibly:

Regardless of the accuracy of the dissent’s recitation of the legislative history of the 1976 Act, the dissent’s citation to congressional statements in support of designating Drakes Estero as wilderness in 1976 do not reliably reflect that the Congress that enacted Section 124 was of the dissent’s view that Drakes Bay’s operations were “not an ‘obstacle’ to converting Drakes Estero to wilderness status.”

Planting Ideas in the Record Does Not Grow a Law
Relying on snippets pulled from letters submitted or read into the record during the creation of a bill is a far cry from what is actually written, voted on and signed by the President. As United States Supreme Court Justice Antonin Scalia has noted, "legislative intent" is often created by proponents of a bill to persuade a court to interpret the statute in a way that they were not able to persuade the legislative body to adopt when passing the bill. He believed it was "...legal fiction that committee reports reflect congressional intent."  Milavetz, Gallop & Milavetz v. United States (08-1119. He wrote further:

"...it is utterly impossible to discern what the Members of Congress intended except to the extent that intent is manifested in the only remnant of 'history' that bears the unanimous endorsement of the majority in each House: the text of the enrolled bill that became law." Graham County Soil, No. 08-304, slip op. at 12. (emphasis added)

The Wilderness Act as Law is Clear

Finally, Mr Linfield's attempt to redefine the "intent" of the Wilderness Act as being lands set aside to be viewed from "...behind a brass railing and a thick glass window..." only helps the thrust of public relations firms and lobbyists to create a corporate definition of "wilderness" far different than the law written, passed and signed into law.

Drakes Bay Oyster Company: NPS Commerce Policies Do Not Apply to Wilderness Areas

Commerce Policies on National Parks

Do Not Apply to Wilderness Areas

On 9/27, Corey Goodman's The Point Reyes Light newspaper published a piece authored by the paper's co-owner, Mark Dowie, titled "Commerce is a central purpose in parks." In Mr Dowie's piece he writes on "...business operations in America's 388 national parks, many of them chains with multiple outlets scattered about park lands." He notes "...many produce carbon footprints far larger than that of an oyster farm."

A National Park is not Wilderness (see here for a brief article)
Mr Dowie confuses national parks with lands set aside by the Wilderness Act. Further, he misses the spatial and temporal impact which Drakes Bay Oyster Company has on Drakes Estero, now part of the Phillip Burton Wilderness, created in 1976. DBOC is not a concession stand selling "souvenir teddy bears" in a national park. Its activities are impacting over 150 acres within a wilderness area, protected by the Wilderness Act, for everyone to experience. Not one to profit from.

Part of the Phillip Burton Wilderness 

impacted spatially by DBOC.

Structures of racks and bags.

 

Would this even be allowed 

under NPS commerce policies?

 DBOC Operation

A Compelling Story, But it Misses The Point
In Mr Dowie's piece he creates a compelling story about national parks having "...cruise lines, hotels, bath houses, marinas, outfitters, parking facilities, service stations and - perhaps the most ecologically destructive of them all - golf courses." Alarmingly, he notes that due to human activities, "Grizzly bear deaths from vehicle collisions in Yellowstone National Park alone have doubled since 2000."*

*While Mr Dowie fails to point to what this number is, information on Grizzly deaths in the Greater Yellowstone Ecosystem is available from the USGS (this area is larger than the park).  In 2010, out of 50 deaths, 2 were "road kill." In 2011, of 44 deaths, 2 were "road kill." In 2012, of 56 deaths, 2 were related to vehicle strikes. To date, in 2013, out of 21 deaths, 2 were related to vehicles. How many cows or Tule Elk have been killed by cars on Point Reyes is unknown, and how many more may be killed by cars if DBOC ceases operation is anyone's guess.  



 Wilderness Areas Are Unique
Mr Dowie correctly writes, "It has become quite difficult for humans or wildlife to find true peace or a semblance of wilderness in an American national park." Mr Dowie, however, incorrectly links policy statements on commerce which apply to national parks to how lands set aside under the Wilderness Act are to be managed. Mr Dowie's attempt to reframe the picture to one of Drakes Estero being only part a National Park is regrettable.

Drakes Estero and Congressman Huffman: Finally, a Breath of Honesty

In today's Marin Independent Journal, Congressman Jared Huffman brought a breath of fresh honest air to the debate over Drakes Bay Oyster Company's attempt to continue its commercial operation in Drakes Estero. A better example of what the word "integrity" embodies cannot be found elsewhere and is a clear indicator of why Marin County and others he represents should continue to support him.

Congressman Huffman (D, CA)

After having been mischaracterized and mis-quoted by Dr. Corey Goodman, Congressman Huffman felt it was time to speak out. In the Op-Ed he states clearly and with conviction:

Corey Goodman's misleading partial quote is another red flag in a debate where civility and truth have been casualties to strong opinions.

For too long people have allowed this process to be subverted by lobbyists and attorneys who represent industries whose agenda is not wanting to help the Lunny family continue their operation. Attempts by public relations firms to frame the issue as one of "government overreach" or of its being part of a subversive "Agenda 21" would be laughable were it not for the attempts to damage people's integrity which has come with it, intentional or not.

Attorneys' attempts to parse words and pretend the Point Reyes National Seashore was intended to include a commercial operation in perpetuity, covering over 1,000 acres, is great for billing hours. Creating the image of them being no different than a mother coming to the rescue of her injured child is something only a lobbyist could create. In reality, the amount of money spent in legal fees could have easily provided college educations for all of the employees' children or easily paid for relocation of the facilities and a new beginning.

Wanting to prevent the dismantling of the Wilderness Act which will protect Drakes Estero for the future of everyone, not one industry, requires focus and a strength of conviction few have. Standing in the face of a wind generated by political forces whose goal has little, if anything, to do with helping Drakes Bay Oyster Company's employees is a challenge few are willing or able to do. But a few have and those few will have Congressman Huffman to thank for the calm which integrity brings with it.

It is time for everyone in Marin County to take a deep breath of this fresh air.

Drakes Estero Wilderness: A Contract is not a Scientific Study

A Contract is Not Made of Straw

The Point Reyes Light newspaper, owned by Marin Media Institute which Dr. Corey Goodman co-founded, has published another Op-Ed piece which he authored. In that piece he attempts, once again, to breath life into his straw man  concerns over "perfect science" and claims Representative Huffman's reasons for not supporting a poorly written resolution passed by the Sonoma City Council are "mistakes." In Dr. Goodman's attempt to bait Representative Huffman into engaging him over something which is a side show he has created and tries to breath life into over and over, he wades further into the swamp where integrity is easily lost.

 

At issue with the Drakes Bay Oyster Company is not whether the science is perfect or not. It is a black and white contract which Drakes Bay Oyster Company entered into. They believed they could overcome the Wilderness Act and continue their commercial operation in Drakes Estero, thereby preventing the completion of the only shoreline wilderness on the West Coast. It was a false belief and a gamble which they lost. It was a contract they signed and need to honor.

 

Dr. Goodman, as Chairman of Labrys Biologics, Second Genome, Oligasis, Ossianix, Limerick BioPharma, Executive Chairman of Solstice Biologics, and Partner in VenBio, along with his past experience knows anyone's "science" can be easily pulled apart. No doubt many of his studies did not stand up to the scrutiny of peer review. You do the best with what you have. 

 

But in his various roles of the companies listed, Dr. Goodman also knows the value of a contract. After it is written and agreed to, signed and dated, it is not something which is as gooey as a conclusion based on imprecise data. It is sacrosanct and is one of the primary foundations for successful businesses, such as those Dr. Goodman has started and which he seeks capital for.

 

Dr. Goodman no doubt believes the conclusions drawn should be questioned. What nobody has justification in believing is that an agreement created 40 years ago is something which should simply be cast aside. It is time for Drakes Bay Oyster Company to realize the steps taken are creating a template for the dismantling of the Wilderness Act. As Dr. Goodman knows from past business failures, sometimes a business needs to close so you can move on to more successful things.

Thurston County Withdraws/Re-issues SEPA Determination for NW Shellfish/Staley Geoduck Farm

Comments due June 25, appeal date is July 2.
Email comments to Scott McCormick at mccorms@co.thurston.wa.us.
Reference project 2012103227

Thurston County has withdrawn and re-issued its SEPA determination of "Mitigated Determination of Non-Significance" (MDNS) on the proposed geoduck farm located on the William and Marie Staley tideland parcel, operated by Northwest Shellfish. The changes did not benefit the near shore environmental impact, individually or cumulatively, nor did they address the lack of information provided.

Picture submitted with application which

cuts off the tideland area where existing

shellfish operations are located.

2009 satellite view from the same

Thurston County Geodata web site.

(click to enlarge)

 

Location of existing farms to the north.



 

It appears the changes are the result of operator/owner comments wanting to weaken the conditions, not any concerns over the continued expansion of geoduck farming and cumulative impacts. As noted in an earlier piece on this site the proposal neglected to mention shellfish operations on adjacent parcels and larger operations to the north. Could Thurston County truly consider whether this met the requirements of SEPA which require accurate information to be submitted? Will it meet the requirements of the Shoreline Management Act and their own Shoreline Master Program requirements when the development permit is applied for?

 

Rather than addressing the lack of accurate information having been provided, instead, the following changes were made:

 

Condition 3, which required a recorded document which would allow access to the site for research was changed to simply allowing the owner/applicant to "consider" requests and to grant such requests if they do not disrupt farming activities.

Condition 8, which required all tubes and netting to be removed from the site within 2 years, was extended to allow for them to remain for 2.5 years.

The shellfish industry is actively involved in continuing to weaken the regulatory oversight of their activities and expansion. The Shoreline Management Act continues to be weakened by their political involvement in the local creation of county Shoreline Master Programs and in the SEPA process. Most recently the Pacific Coast Shellfish Growers Association has become involved in weakening the Wilderness Act's ability to protect wilderness areas from commercial development through preventing Drakes Estero from becoming wilderness. Are they really the canary in the coal mine or have they have become the strip miners of Puget Sound's tidelands?

Drakes Bay Oyster Company's Knot to Oil Gets Tighter

 "he urged a House subcommittee to open up part of

Alaska's Arctic National Wildlife Refuge (ANWR) for oil drilling."

[click here]

 

Representative "Doc" Hastings

Republican, WA

The knot tying Drakes Bay Oyster Company to oil drilling in wilderness areas was pulled tighter today, this time by Washington state Representative "Doc" Hastings (R - Wa). As a strong proponent for opening wilderness areas to drilling and mineral extraction it is no surprise. Ironically, Representative Hastings was also strongly opposed to the proposed federal protection of the San Juan Islands in Puget Sound, within his own home state, recently put in place.

Who needs wilderness?
"There is a small but active element in the Republican element in the house that does not support wilderness," Spitzer of the Wilderness Society said. He holds Doc Hastings, the chair of the Natural Resources Committee, most accountable. [click here for article]

We hear what we want to hear.

You only hear yourself if your ears are plugged.
Continuing to ignore the fact that Congress intended for this final commercial operation in Drakes Estero to end in 2012, he continues with ongoing complaints about how irrelevant studies were implemented and interpreted. He writes that in 2009 Congress "authorized" Secretary Salazar to extend for another 10 years the farms authorization and special use permit but ignores the fact that the original 2009 rider was changed from "requiring" the extension to merely giving him the option. We hear what we want to hear. [click here for letter from Hastings]

Oops, I did it again!

Shell Oil drilling platform, grounded.



It's just about an oyster farm.
This issue is far beyond an oyster farm. Any doubts were dispelled when the conservative "Cause of Action," with clear ties to the conservative Koch Brothers, stepped in to provide legal support for the Lunny family. It was made more clear when Senator Vitter attached a rider to his energy bill which would have both required continued operation of the commercial farm and also removed the wilderness designation from Drakes Estero. [click here for article] The oil industry is clear in its wishing to dismantle the protections which the Wilderness Act brings to a small area for current and future generations. They see in the Lunny family's complaints about "big government" a window of opportunity to exploit an opportunity and have drawn in as pawns that family and well intentioned chefs. [click here for Huffington Post article] The objective in the gambit is to open the door for redefining what "wilderness" is and creating a "new environmentalism," a direct outfall of the "personification" of corporations.

Oyster racks in Drakes Estero.

"Wilderness" through corporate eyes.

Riding on the coat tails.
Riding on the coat tails of the oil industry is the shellfish industry who sees a golden opportunity to exploit one of the few remaining bodies of water available for industrial shellfish operations. Drakes Estero, with its clear waters and protected embayment, and minimal payments to the state, offers an economic opportunity for them to exploit further. Despite Tomales Bay and Humboldt Bay offering ample opportunities for reasonable development outside of this wilderness area, they have poured resources into fighting this through lobbyists and attorneys. Is it any wonder the largest shellfish company, Taylor Shellfish, is also located in Washington state which Representative Doc Hastings is from?

Bill Taylor, Taylor Shellfish

Wilderness in the forests is great,

not so in the tidelands.

Wilderness is good - just not on tidelands the shellfish industry uses.
Most ironic in all of what is unfolding in Drakes Estero is the support for expanding wilderness areas on the Olympic Peninsula. The Wild Olympics campaign is endorsed by Bill Taylor, owner of Taylor Shellfish. [click here for endorsement] Where is his support for the only designated shoreline wilderness area on the entire west coast? Clouded in the conversion of tidelands for shellfish production.

Geoduck shellfish farm in Puget Sound.

Coming to Drakes Estero?

The shellfish industry: canary in a coal mine or strip miners of the tidelands?
Doc Hastings may have found a new political donor.

 





Drakes Bay Oyster Company and Senator Vitter: Part 2

Senator Vitter (R - La)

"I expect clear and complete answers ..."

Factual questions would help.

Senator Vitter (R - La) continues to help clarify what is behind the energy to force the Department of the Interior's National Park Service to renew the Drakes Bay Oyster Company's lease. It is not a love for raw oysters or their perceived effect.

In a letter dated March 18, sent to Ms. Sally Jewell, Interior Secretary Designate, Senator Vitter (a minority member of the US Senate Committee on Environment and Public Works) lists 19 questions he would like "thorough" and "clear and complete answers" to. [click here for letter] What standard he bases "clear and complete answers" on is unknown.

The first 6 questions are focused directly on how to expand or speed up permitting for oil, natural gas and coal. The next 7 meander around the protection of species by the Federal Government, state's rights and individual property rights impacted by that protection. Two more focus on hydraulic fracturing, another on Carbon tax, another implies "gas prices doubled" due to President Obama, and another asks clarification on her role as a board member with the National Parks Conservation Association.

Mixed in with all is a question about Drakes Bay Oyster Company's lease expiration which nobody could, or should, give a "clear and complete" response to as it ignores the fundamental issue: the lease has expired and the commercial operation must cease. Implied is a "vicious campaign" is underway to shut down a commercial operation. Ignored is the fact that Congress (who Senator Vitter is a member of) passed the Point Reyes Wilderness Act in 1976 with the only commercial operation to cease in 2012 [click here for Public Law 94-544]. Ignored is the current owner (who purchased the farm in 2005) having been told multiple times the lease would not be renewed. Ignored is the current owner having been found by the California Coastal Commission to be operating in violation of a cease and desist order from 2007 [click here for article]. Ignored is Congress (which Senator Vitter is a member of) gave the Secretary Salazar the discretion to let the lease expire in 2012, not the requirement to renew it as Senator Feinstein originally asked for [read analysis here].

While the shellfish industry is clearly concerned about Drakes Estero reverting to wilderness, it is becoming clear through the help of Senator Vitter how much the energy industry is involved. Everyone should be concerned about the precedent which allowing a commercial operation to continue in a designated wilderness area would have. It is a direct attack on the Wilderness Act. Contact your representative and tell them it is time for Drakes Estero to become the wilderness Congress intended in 1976.

Find your Representative here:  [click here]
Find your Senator here: [click here]

Drakes Bay Oyster Tied Directly to the Expansion of Oil Drilling in Wilderness

Senator David Vitter

(R - La)

Doing a Vitter
If there was any question of whether the immense sum of money being spent in support for the renewal of Drakes Bay Oyster Company's lease was tied directly to expanding oil drilling in designated wilderness areas, it has been extinguished. Senator Vitter (R - La) has added to his "Energy Production and Project Delivery Act of 2013" (the Bill) a requirement that the Department of the Interior extend the lease for the Lunny family's commercial operation in a designated wilderness area for 10 years, with an additional 10 year extension after that. Adding insult to injury, it would also prevent Drakes Estero from becoming the wilderness shoreline area Congress intended when the Point Reyes Wilderness Act was passed in 1976.

 Section 310 of the Bill reads:
(1) the Secretary of the Interior, acting through the Director of the National Park Service, shall--
(A) reinstate, for a period of not less than 10 years, the reservation of use and occupancy and special use permits to conduct commercial operations within Point Reyes National Seashore in the State of California held by Drakes Bay Oyster Company, which expired on November 30, 2012, subject to the terms and conditions contained in those permits, as in effect on November 29, 2012; and
(B) on receipt of a request from Drakes Bay Oyster Company (or a successor in interest), renew those reinstated permits for an additional 10-year period; and
(2) Drakes Estero in the State of California shall not be converted to a designated wilderness.

Drakes Estero: Public Lands and Entitlements

"The ability to use public land for private profit

is a privilege, not an entitlement."

Drakes Estero National Seashore 

 

In all of the articles written on Drakes Bay Oyster Company's (DBOC) press to continue using Point Reyes National Seashore for their commercial shellfish operation, no better sentence encapsulates DBOC's reasoning behind why a nonconforming commercial operation in Drakes Estero should continue. It brings forward the primary issue faced at the court hearing on January 25: Should a nonconforming commercial operation on public lands, purchased with full and clear knowledge the use had an explicit end date for an explicit reason, be allowed to challenge the terms of that agreement and prevent the creation of the only marine wilderness area on the West Coast of the United States? [see the Wilderness Act here]

 

Arguments about the science behind the Environmental Impact Study provide a convenient smoke screen to hide the fundamental question at hand: Is the Lunny family owned DBOC entitled to continue using areas of Drakes Estero for a commercial shellfish operation at the expense of its diminished value as a wilderness area for all the public to enjoy?

 

it is hereby declared to be the policy of the Congress

 to secure for the American people

of present and future generations

 the benefits of an enduring

 resource of wilderness.

The Wilderness Act

 

This is not about the Lunny family, nor is it about shellfish farming or displaced employees. It is not an attempt remove all public lands from commercial use. At the foundation of this case is whether a nonconforming use by corporations, owned by a family or publicly traded, is entitled to continue on public lands designated by Congress to become wilderness after a specific date. Relying on a legislative rider to extend the agreement will set a precedent for other legislatures to create their own riders to extend agreements for other nonconforming commercial operations in other designated wilderness areas, ad infinitum.

In this case, that the nonconforming commercial operation was to end in November of 2012 was clear in the agreement between DBOC and the National Parks Service, signed in 2005. That Drakes Estero was designated to become wilderness was known for decades. That the commercial shellfish operation was considered "nonconforming" was clear. That the commercial shellfish operation was given a more than reasonable amount of time, 40 years (November 2012), to end their operation was accepted as reasonable by the Johnson family's Johnson Oyster Company (JOC), who chose to cease operations earlier, in 2003.

For DBOC to arrive in 2004, purchase the assets and take over the agreement, and now claim their attorneys said it could be extended is nothing more than bad business and bad legal advice. Lobbying to have Senator Feinstein add a rider giving the Secretary of the Interior discretion - not the requirement - to extend the agreement is only an example of corporate lobbying efforts. DBOC's continuing to place shellfish in the designated wilderness area and now claim they will have to be "destroyed" is nothing more than a reflection of their belief in the entitlement they have to continue profiting from the only nonconforming commercial operation preventing the creation of the only National Seashore wilderness area on the West Coast outside of Alaska. An operation they knew full well was intended to end in November of 2012.

It is time for DBOC to cease operations, remove the structures and nonnative shellfish, and allow the Point Reyes National Seashore to become the wilderness Congress intended 40 years ago, for the benefit of present and future generations of all Americans. To do otherwise strikes at the integrity of the Wilderness Act, clearly why Cause of Action has chosen to become involved.

For further detailed legal analysis of this issue see the following:
1. "Will the Wilderness Act Be Diluted in Drakes Estero?"
2. "Congressionally Designated Potential Wilderness Areas"
3. "Contextualizing Secretary Salazar’s Recent Decision on Oyster Farming at Point Reyes"4. "Passions Run High in Bivalve Battle"