Preparing a Beach for a Geoduck Farm: Coming to a Tideland Near You

The following images show how to prepare a beach for a geoduck "farm." Revenues generated are more than adequate to help pay attorneys and scientists to help craft regulations which will allow for the expansion of this shoreline development. Unfortunately, those responsible for protecting the intertidal ecosystem either believe them or are intimidated by them. [hear Seattle Shellfish owner Jim Gibbons tell state legislators about hiring attorneys and public relations firms when considering whether to sue the state]

 

Step 1: Clear the beach of any aquatic vegetation and "pests".
[click here for previous post on what the shellfish
industry considers to be "pests"]

(photo courtesy of CISA)

 

Step 2: Be sure those "pests" don't come back.

In the case of a Moon Snail, rebar is an effective deterrent.

(photo courtesy of CISA)

Step 3: Survey the beach just to be sure nothing is missed

(e.g., Sand Dollars or Rock Crab).

(photo courtesy of CISA)

Step 4: Begin placing the "structure" scientists say
is so useful for Puget Sound's sea life. If a few become loose,
just know "Best Management Practices" tried to contain them.

(photo courtesy of CISA)

 

If you care about Puget Sound's intertidal shoreline area get involved in the public process. The shellfish industry is and has been, most recently in "streamlining" the federal and state permit process without public input and in crafting updated county regulations. What you see is what they want. [click here for Pierce County Shoreline Master Program update and September 25 meeting]

Penn Cove Avoids Biotoxin Closure, Department of Health Warns of Warm Temperatures and Vibrio

September 7, 2012, Department of Health closes the following area to recreational and sport shellfish digging due to biotoxins in shellfish:
In Island County, all of Saratoga Passage to include east Whidbey Island from Strawberry Point south to Possession Point including Crescent Harbor, Oak Harbor and Holmes Harbor and west Camano Island from Brown Point south to Camano Head. Penn Cove is not included in the closure.
[click here for additional information on recreational closures]
Note: Commercial closures are listed separately.
[Click here for commercial closure information. Registration may be necessary.]

Area closed to recreational harvesting September 7 

due to elevated levels of biotoxins in shellfish.

 
Note: After additional research, the Department of Health found one of the illnesses attributed to a Samish Bay oyster was "guilt by association." Samish Bay oysters were only "on hand" in the restaurant where the raw oysters causing illness were consumed. Taylor Shellfish and Chuckanut Shellfish, among others, are now able to harvest oysters again. However, noted by the Department of Health: "Two cautionary notes: (1) It will take only one more illness to reclose Samish Bay; and (2) Unusually hot weather is expected over the next week, so caution should be exercised in the harvest and handling of oysters intended for raw consumption."

Eelgrass and Ocean Acidification: Actions Based on Science or Corporate Profits?

"...the more man interferes with nature the greater become the problems he creates." (Maurice Yonge, Oysters, 1960 p. 189).

From a September 5, 2012 email from the Depatment of Ecology: "Ecology is in the process of developing a permit to allow treatment of Japanese eelgrass on commercial clam beds in Willapa Bay. The applicants [shellfish companies] have asked to treat [eradicate] the Japanese eelgrass [in Willapa Bay] with the aquatic herbicide imazamox."

For six months the Department of Ecology has been hosting the "Blue Ribbon Panel" on Ocean Acidification. Increased CO2 levels in marine waters has resulted in increased acidity (lower pH). Impacted hardest has been Willapa Bay where oysters have been unable to "set" (grow) naturally and caused a shellfish hatchery to move its facilities to Hawaii [read Seattle Times article here]. High levels of CO2 have been directly linked to the lower pH levels, in turn linked directly to why larvae are unable to survive in Willapa Bay.

On June 20, of the 10 recommendations on adapting to Ocean Acidification, four were specifically related to eelgrass and aquatic vegetation:

Encourage shellfish/seagrass [eelgrass] co-cultivation

Investigate and develop seaweed farming

Restore eelgrass and kelp beds

Promote community-based programs to mitigate nutrient inputs (using shellfish and seaweeds)
[See "Initial Recommendations for Managing and Adapting to the Impacts of OA here]

Notes from that presentation on Ecology's website include: "... conservation of existing eelgrass beds may be more feasible and less expensive than cultivation of new beds." [see page 6 from summary notes here]

July 20 the ability of eelgrass to absorb CO2 was stressed again, noting eelgrass "sucking up all that CO2."

August 8, "Workgroup 3: Adaptation and Remediation" of the committee produced its final four recommendations. Eelgrass or use of aquatic vegetation to lower CO2? It has apparently been absorbed by the shellfish industry, respired as how to "fund my hatcheries and industry."

Action 2.1 Continue water quality monitoring at six existing shellfish hatcheries and rearing areas.

Action 2.2 Investigate efficacy of water treatment strategies and/or hatchery design to protect larvae from corrosive seawater.

Action 2.3 Investigate potential to breed and/or select OA-tolerant strains of shellfish and other vulnerable marine species.

Action 3.1 Prioritize investment in adaptation & remediation actions that provide future shellfish habitat capable of enduring a full suite of anticipated environmental changes.

[see Priority Action Recommendations here] 
Panel members are right to question whether too much money and time is being spent on hatcheries. Concerns noted the process was spending too much time focusing on how to get shellfish to survive in a hatchery so they can survive in the water instead of putting energy into how to get the water clean so they can grow naturally.  

When the preservation and expansion of eelgrass beds are dropped by the Blue Ribbon Panel and the Department of Ecology wants to eradicate beds in Willapa Bay where ocean acidification has had the largest impact, a very real risk of a perception that science has taken a back seat to corporate profits rises. Is that what the scientists and panel members want to be remembered for?

Pickering Passage Closed to Commercial Harvesting of Oysters

Pickering Passage has been closed to commercial harvesting of oysters due to illnesses traced directly to oysters harvested from this growing area. This is now the 9th commercial growing area which has been closed because of illness caused by oysters harvested from Puget Sound. These illnesses continue a known and growing problem.

Laboratory-Confirmed cases of Vibriosis

(Note: CDC estimates for every laboratory

confirmed case >40 are not reported to CDC.)

 

The annual outbreak of vibriois caused by oysters harvested from Puget Sound is an ongoing annual problem. When the FDA attempted to deal with lowering numbers through press releases the Pacific Coast Shellfish Growers Association reacted with complaints of "economic harm" (see Issue Paper below). Currently the "Blue Ribbon Panel" on Ocean Acidification is recommending actions specifically for the benefit of the shellfish industry with estimated costs at over $4 million (Note: A number of actions' estimates were not available, only noting they were "dependent on scale.") Decisions on the allocation of taxpayer dollars for the shellfish industry might consider the fact that warming temperatures will bring with it an increase in the naturally occurring Vibrio parahaemolyticus and most likely its more deadly cousin Vibrio vulnificus (currently found in Gulf State oysters which kills 50% of those who contract it). Allocating a portion of those taxpayer dollars to prevent outbreaks might be something for the "Public Outreach" committee and panel to consider.

 

 

PCSGA Issue Paper on FDA Press Releases

(click to enlarge)



Ilnesses from Samish Bay Oysters Halts Harvesting

The Department of Health has closed Samish Bay to commercial harvesting of shellfish due to vibriosis contracted by people who consumed oysters harvested from the area. It will remain closed until October 1. Last year outbreaks of vibriosis and resulting closures of commercial harvesting areas, including Samish Bay, caused China to recall all oysters harvested from Washington state [read here].

Taylor Shellfish's processing plant in Samish Bay.

(from Google Earth, 8/25/11)

Unlike fecal coliform, Vibrio parahaemolyticus (Vp) is a naturally occurring bacteria in Puget Sound. Unlike fecal coliform, every summer Vp numbers increase in the water column. Oysters and other shellfish then filter Vp from the water. If the shellfish are undercooked or eaten raw, it may cause vibriosis. In addition to Samish Bay, Vp has already caused Oakland Bay, Totten Inlet, Dabob Bay, and areas in Hood Canal.

Whether the apparent increase in outbreaks and significant closures are the result of an increase in Vp, additional monitoring, the increase of triploid (genetically modified) oysters which are more "edible" during summer, or a combination is not known.

For a report from August 23 listing all areas closed and why, see the Olympic Penninsula Environmental News here. It does not include the most recent Samish Bay closure but does include areas closed for other reasons (e.g., biotoxins).

Department of Health contacts for various closures follow.  

Closure Explanations and Program Contacts: 

  BIOTOXIN - Biotoxin sample results exceed DOH closure standards

       Contact Frank Cox 360-236-3309 or Jerry Borchert 360-236-3328

  WWTP - A Wastewater Treatment Plant Malfunction

       Contact Mark Toy  360-236-3321

  HAZMAT - Hazardous Materials Substance Spill

       Contact Mark Toy  360-236-3321

  RAIN - The Conditionally Approved growing area is closed due to pollution associated with rainfall

       Contact Scott Berbells 360-236-3324

  MARINA - Seasonal Use Marina Closure

       Contact Mark Toy 360-236-3321

  FLOODING - Growing area is closed due to contamination from river flooding

       Contact Scott Berbells 360-236-3324

  EMERGENCY - Other public health emergency

       Contact Office Mainline 360-236-3330

  VIBRIO - A closure due to the naturally occurring pathogenic marine bacteria "Vibrio parahaemolyticus"

       Contact Richard Lillie 360-236-3313

  NO PSP SAMPLE / NO HARVEST - Geoduck tracts.  Must sample for PSP prior to harvest

       Contact Frank Cox 360-236-3309 or Jerry Borchert 360-236-3328

Taylor Shellfish Asks for Mussel Farm Permit Denial

Taylor Shellfish's attorney  has advised them to ask their permit application for a new mussel farm in Totten Inlet be denied so they may appeal that decision to the Shoreline Hearings Board. Has corporate shellfish aquaculture become the industry fragmenting the shorelines which Shoreline Management Act was passed to control?

Taylor Shellfish's current mussel farm in Totten Inlet.

Oyster bags in Totten Inlet

Taylor Shellfish has asked the Thurston County Hearing Examiner to deny their Substantial Shoreline Development Permit. Rather than supply the examiner with additional information addressing questions about about cumulative impacts shellfish farming is having in Totten Inlet, Taylor Shellfish will instead appeal the denial they are asking for to the Shoreline Hearings Board.
[see Hearing Examiner's options presented to Taylor Shellfish here]

 

After the Hearing Examiner issues his decision, "requests for reconsideration" will be allowed to be submitted within a 10 day period. Was the impact on shoreline residents and wildlife near the "assembly and maintenance" area of the rafts at the "Old Plant" adequately addressed? Will "retaining nets" ensure all the plastic discs which come loose are kept on site? After any "requests for reconsideration" have been addressed the question of whether Taylor Shellfish should be allowed to install 58 mussel rafts at the mouth of Totten Inlet will move to the Shoreline Hearing Board.

When is enough too much?

 

For over 14 years now APHETI (the Association for the Protection of Hammersley, Eld and Totten Inlets) has questioned whether a permit for the installation of a mussel farm of the size and density proposed is correct. As a direct result of their efforts and others (e.g., Case Inlet Shoreline Association "CISA") it is now being asked whether corporate shellfish farming in south Puget Sound has reached a point where the Shoreline Management Act's (SMA) original assumptions of shellfish aquaculture no longer apply.

If you wish to receive email updates from APHETI you may send an email to: APHETI@gmail.com If you wish to help ensure the Shoreline Management Act is applied as intended, both APHETI and CISA are 501(c)3 non-profit organizations. 

Hood Canal Oysters Recalled

An outbreak of vibriosis has initiated a recall of oysters harvested after August 16 from Hood Canal's Area 5 (just north of the southern "Great Bend"). Vibriosis, caused by the naturally occurring bacteria Vibrio parahaemolyticus (Vp) is an annual problem during the summer months for Washington's shellfish growers, moreso for those who become ill. Unlike most who contract vibriosis, reported cases are not getting better.

(from "Shellfish Safety", Department of Health)

(Note: The above numbers do not

include unreported cases, only those

confirmed by laboratory testing.)

Last year China banned the import of oysters from Washington State due to a similar outbreak and recall. Taylor Shellfish spokesman Bill Dewey responded: “This has wreaked havoc on our export business,” he said (Puget Sound Business Journal, 9/30/2011). Those who got ill were not interviewed for their response to what havoc, economic or otherwise, vibriosis caused in their lives.

In response to the FDA issuing a recall of the contaminated oysters last year, the shellfish industry sent a delegation of representatives, attorneys and lobbyists to Washington D.C. with this message for Congressman: "Despite seemingly adequate efforts by firms and SSCAs [State Shellfish Control Authorities], the FDA has unilaterally decided to elevate recalls and issue press releases which have unnecessarily alarmed consumers and had significant economic consequences on shellfish growers and distributors." (From the Pacific Shellfish Grower's Association's "FDA's Communications practices Hurth Shellfish Producers" handout dated February 2012.) It is unclear what "adequate efforts" industry lobbyists were referring to. What is clear is vibriosis is not under control.

As Governor Gregoire presses forward to expand the shellfish industry she should consider what she is leaving as her legacy. Scientists on her "Blue Ribbon Panel" have questioned whether the shellfish industry's expansion is something which should be promoted. Washington State's shellfish are causing increasing numbers of Vibriosis and other diseases. Warming temperatures can be expected to increase these numbers. She might consider listening to what her appointed scientists are saying. 


 
 

DNR Retains SEPA Decision for Taylor Shellfish Harvesting of Geoduck on State Tidelands Trespassed On

In this SEPA decision we see what we want to see (or in the case of salmon during dive harvesting, not much).

What does dive harvesting look like?

[click here for short version of intertidal dive harvesting]

or click on arrow below for the full 25 minutes

(also note the discarded geoduck tubes)

Selective science? In the case of DNR's Supplemental Environmental Impact Statement (SEIS) on deeper subtidal harvesting, as it applies to intertidal dive harvesting, we read what we want to read.[click here for complete SEIS]

Part of this study looked at a "liberal" 10,000 geoduck-per-acre tract being harvested versus the typical 60,000+ geoduck per acre in a commercial farm. Hardly the same.

Yet, the SEIS clearly states sediment plumes do not "settle out quickly" as DNR and NMFS authors state in the SEPA documents. In fact, dive harvesting of geoduck clearly shows a far greater impact to the water column and sediments than was considered by DNR and NMFS.

After 20 minutes at 1.0 m/sec current speed, the [sediment] clouds with up to 10 mg/l of TSS were 170 m [>500'] down current from the diver. (page 33, SEIS) (Note: A 10 mg/l increase in TSS increased turbidity 6 NTU units. WAC 173-201A-210(1)(e) does not allow an increase of over 5 NTU.) There is no indication any consideration was given to the unique location of this farm and currents.

The shoreward boundary [of -18 feet] protects shallow water geoducks, minimizes impacts on nearby shoreline residents, and helps protect eelgrass beds and other sensitive nearshore habitats. (page 10, SEIS) Nothing indicates consideration was given to the species within the sediments between where the geoduck were planted and the -18 foot depth. Further, if DNR is concerned about impacts to shoreline residents, why not restrict dive harvesting to daylight hours only? 

Most of this material -- the coarser sediments -- settles immediately to the bottom and forms a berm round the harvest hole, while the fine material (particle size less than 63 microns) settles much more slowly and remains in the water for longer periods. (page 31, SEIS) Statements that sediments "settle out quickly" are simply not scientifically based.

Look a little deeper.

The Department of Natural Resources has retained its SEPA mitigated determination of non-significance (MDNS) decision which will allow Taylor Shellfish to dive harvest up to 70% of the geoduck planted on state owned tidelands. One commenter noted DNR's Environmental Impact Statement (EIS) and Supplemental Environmental Impact Statement (SEIS) on subtidal dive harvesting limited harvest activity to no shallower than 18 feet below mean low lower water (MLLW). DNR responded the EIS and SEIS were not intended to be used for intertidal (shallow) dive harvesting, despite the papers clearly noting impacts to the water column and shallow area from dive harvesting. DNR went on to respond the 18' depth limit was primarily to address shoreline resident concerns about "noise and commotion from harvest activities" and to avoid "eelgrass and herring spawning areas". It responded further by referencing National Marine Fisheries Service (NMFS) and Fish and Wildlife Service (FWS) letters. Neither reference any studies looking at dive harvesting of an intertidal commercial farm which has over 60,000 geoduck per acre, because none exist. Instead they rely on inferences from observations of harvesting activities performed out of water at small farms, in some cases at midnight, and low density wild harvesting to reach the conclusion there is no impact. NMFS states sediment disturbance is no different than naturally occurring wave action, seeming to overlook the fact that 3' of sediments are liquefied and geoduck planted in densities of up to 3 per square foot are being extracted. Waves and currents both have an immediate and ongoing effect on sediments which are carried far further than those disturbed by "dry" harvesting. The stratified sediment composition which had formed over millennium from waves and current is turned upside down in harvesting.

   

Southern Resident Orca, August 2011

(At the mouth of Hammersley Inlet

which passed directly by Taylor's farm

in Pickering Passage.)

In response to concerns of Southern Resident Orca which frequent the area, NMFS states the vessels used are "slow moving" and pose no risk. In fact, the vessels used by the shellfish industry are some of the largest and fastest vessels on Puget Sound. The fact that geoduck need to be moved directly from harvesting to the airport for delivery in China the next day has to make one wonder what era of shellfish harvesting NMFS was thinking about. It's not grandfather Taylor's oyster farm anymore.    

This is slow moving?

Commissioner Goldmark and the Aquatic Division of DNR have tried to do their best in protecting the intertidal shoreline habitat for future generations. They have tried to rely on science to base decisions on. But pressures are building to convert what few remaining public tidelands there are into industrial shellfish farms for the benefit of a few corporate owners who will become very rich while Washington State's citizens loose access to the few public tidelands which remain. Taylor Shellfish should never have been allowed to plant where they did. Taylor Shellfish trespassed and as part of the settlement agreement they are allowed to harvest their geoduck, at great profit (~$2 million). What should not be allowed now is for this SEPA decision to be used as the basis for future decisions.

The area where Taylor Shellfish

planted geoduck without a lease agreement.

Vibrio Testing Closes Oakland Bay to Commercial Oyster Harvesting, Drakes Bay Oysters Recalled

The Department of Health has told shellfish farmers in Oakland Bay (Shelton) to stop harvesting oysters due to the naturally occurring bacteria Vibrio parahaemolyticus (Vp). A pilot program's testing for tlh (an indicator of how much Vp is present) resulted in 9,300 MPN/gram (most probable number), far above the action number of 100 MPN/gram.

Vibrio parahaemolyticus

Vp is present in Puget Sound waters year round, but warm summer months, salinity and turbidity all increase its numbers within the water column dramatically. Oysters, being filter feeders, accumulate this bacteria which is then consumed by humans, causing vibriosis [read here about Vp]. During the winter months it is found concentrated in the sediments and may be introduced into the water column through sediment disturbance.

As of yet no recalls of oysters harvested from Oakland Bay, Totten Inlet, and, Hood Canal area #8 have been issued. Illnesses traced back to oysters harvested, or testing from these areas, have indicated elevated levels of Vp to be present. The coming warm days are expected to increase the risk further.

Drakes Bay Oyster Company

Issues Recall for Infected Oysters

In the past, "after-the-fact" recalls were initiated only after an indeterminate number of people became sick.  In California, after illnesses of vibriosis were reported, the source was tracked back to oysters harvested by Drakes Bay Oyster Company between July 17 and August 8.  [read here for Drakes Bay Oyster Company recall] Washington's Department of Health is trying to be more pro-active by requiring harvesting to stop, before infected oysters enter the food stream.

Until prevented from entering into the food stream perhaps legislators and the FDA should simply require post harvest processing of oysters harvested where Vp is known to occur. The expense to the state from testing would be lessened and the economic hardships brought on by illnesses contracted from infected oysters would be minimized.

Vibriosis Closes Totten Inlet Oyster Harvesting - More in the Future?

From the Department of Health: Totten Inlet growing area is now closed for oyster harvest effective immediately. This reduction will remain in effect until September 30, 2012. In addition to Totten Inlet, Dabob Bay and Hood Canal area number 8 have also been closed to commercial harvesting

Vibriosis is caused by the naturally occurring bacteria named Vibrio parahaemolyticus (Vp). Oysters filter and retain this bacteria. When these oysters are consumed raw or undercooked Vibriosis is contracted.  A separate species of Vibrio, Vibrio vulnificus (Vv), is found in oysters harvested in the gulf states during the summer. The disease contracted by Vv is fatal in 50% of the cases. While not yet present in Puget Sound's cooler waters, the general warming trend is expected to result in both Vibrio species to become present.

"It's not going real well."

Bill Dewey, Taylor Shellfish

Last fall, Bill Dewey of Taylor Shellfish was asked by Food Safety News how well the industry was doing at minimizing illnesses caused by the more virulent Vv.  "It's not going real well," he told Food Safety News. "Some states are really struggling with it, both from an enforcement standpoint as well as an industry implementation standpoint," said Dewey, whose own state deals with other species of Vibrio bacteria -- Vibrio parahaemolyticus -- which are generally less deadly than Vibrio vulnificus but can also cause gastroenteritis.
Challenges include keeping trucks chilled in hot summer months and finding adequate space to store and chill oysters, among others, he explained.
(click here for full article)

For over 10 years the shellfish industry has been unsuccessful at controlling the outbreaks from the deadlier species of Vv, of which 1/2 die. Only California, which banned Gulf state oysters which have not been processed was successful in eliminating the disease (read more on Vv here). Oysters from Washington State continue to infect people with Vp. Last fall China recalled all oysters harvested from Washington and refused shipments due to Vp concerns (click here).


As the Governor and others press for a significant expansion of the shellfish industry it may be wise to consider whether they are truly prepared for what an expanded industry will bring with it. The "Blue Ribbon Panel" on Ocean Acidification has clearly established that tied to CO2 emissions are rising temperatures. For over 10 years the shellfish industry has been trying to stop Vv in oysters from infecting people. As Mr. Dewey says, "It's not going real well."