HomeMy WebLinkAbout059 Taylor Shelfish - response to reopening record
March 20, 2026
To: Office of Jefferson County Hearings Examiner
From: Erin Ewald, Dir. of Regulatory Affairs, Taylor Shellfish
Thank you for the opportunity to submit comments on the proposed project SSDP 2024-0006.
Both Gordon King, Director of Mussel Farming at Taylor Shellfish, and I testified in support of
Rock Island Shellfish at the Jefferson County hearing on August 19, 2025. As parties of record,
we are submitting these combined comments.
Taylor Shellfish Farms is based in Shelton, but has been growing mussels, clams, oysters and
geoduck over almost 400 acres in Jefferson County for several decades. Taylor Shellfish has
farmed shellfish in Washington State for over 100 years and worked with and alongside many
other growers since that time. Based on our experience and commitment to support fellow
growers, we strongly support Rock Island Shellfish’s permit application for oyster cultivation.
Aquaculture is expressly recognized as a preferred use of Washington State tidelands under the
Shoreline Management Act and Jefferson County Shoreline Master Program. Shellfish farms
produce sustainably grown, locally sourced protein for human consumption while delivering
measurable environmental benefits. Farmed shellfish provide ecosystem services to the
environment contributing to habitat complexity and improved water quality through the uptake
of nutrients caused by anthropogenic sources. Well managed, shellfish farms align economic
productivity with ecological stewardship.
As described, this project will operate under the conditions of a comprehensive 20-year
Programmatic Consultation which was prepared by U.S. Fish and Wildlife and National Marine
Fisheries Service. That consultation rigorously evaluated aquaculture activities, identified
potential impacts to species and habitats, and established conservation measures to avoid and
minimize risk. Building on that framework, Rock Island Shellfish also prepared a site-specific
habitat management plan tailored to this location, further refining best practices and mitigation
measures. Together, these layers of review provide robust, science-based assurances that the
project will be responsibly managed.
Rock Island Shellfish assumed stewardship after a failed operation vacated the property. Since
then, they have invested substantial time and resources to not only restore order and functionality
of the tidelands parcel to enable future productive oyster cultivation, but they have also made
efforts to improve the associated uplands by removing invasive weeds and accumulated debris.
These efforts enhance both the environmental function and aesthetics of the parcel. They also
demonstrate commitment, not only to business success, but to long-term land stewardship.
We would like to emphasize that upland activities should not be part of the Shoreline
Development Permit governing installation and management of the oyster farm. Upland
compliance matters are appropriately addressed through the County’s established enforcement
mechanisms, which are already in motion between the property owner and Jefferson County
staff, and which Rock Island Shellfish has already committed to completing. It should be allowed
to do so through that separate, established process. Many working tidelands throughout Puget
Sound remain connected to their associated uplands. Shellfish farms may have upland activities,
managed separately for storage, seed setting or access in support of tideland operations.
Developed uplands may also be managed for entirely different purposes, including residential or
commercial development with no relation to the tidelands. Because tidelands and uplands are
governed by distinct regulatory frameworks, they are often permitted and managed separately.
Linking upland permitting requirements, including financial assurances, to approval of a
tideland’s aquaculture permit would create an unnecessary and problematic precedent. We
strongly oppose such a linkage and urge the Examiner to evaluate the oyster farm application on
its own legal and factual merits.
Finally, aquaculture is inherently seasonal and biologically driven. Oyster seed is planted when
the seed is available and when environmental conditions, such as nutrient levels and water
temperatures, support growth. Farmers must also time operations to avoid predators and meet
market windows. Extended or uncertain permitting delays can cause growers to miss entire
production cycles, resulting in significant economic loss. The cumulative cost of permitting and
prolonged review can be substantial, especially to small and mid-sized growers.
For all the reasons expressed, legal consistency, environmental stewardship, sound science and
economic practicality, we respectfully encourage the Examiner to review the record and issue a
timely decision in favor of the project.