HomeMy WebLinkAbout007 Comment LetterDonna Frostholm
From: Marilyn Showalter <marilyn.showalter@gmail.com>
Sent: Tuesday, June 4, 2019 4:09 PM
To: Patty Charnas; Donna Frostholm
Cc: Philip Hunsucker
Subject: Missing Subjects in Application MLA 19-00036
Attachments: Ltr to county June 4 2019.docx
Hello, Patty and Donna,
Attached is a letter regarding three topics that need to be addressed in MLA 19-00036 (BDN-Smersh application).
Thank you --Marilyn
Marilyn Showalter
1596 Shine Rd
Port Ludlow, WA 98365
(360) 259-1700 (cell)
mariiyn.showalter@gmall.com
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MLA 19-00036, June 4, 2019
MARILYN SHOWALTER
1596 SHINE ROAD
PORT LUDLOW, WA 98365 rnari#yn.sliowalter@gmail.com
360-259-1700 (cell)
June 4, 2019
Patty Charnas, Director
Donna Frostholm, Associate Planner
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
Sent by Email
Dear Mses. Charnas and Frostholm:
Re: Missing Subjects in (Incomplete) Application MLA 19-00036
0 E.
F- 4 2019
I'm writing regarding some significant holes in the not -yet -complete application by BDN for a
geoduck farm on Shine Road, MLA19-00036 BDN. These are areas that are not addressed, or
just barely mentioned, but should be included before the application is deemed complete. (This
letter does not address many other concerns that are reserved for comment, if and when the
application is complete.)
1) The Application Should Address Parcel No. 970200001
The application does not mention this parcel. It is owned by Mr. Smersh but is not contiguous
with Parcel #721031007 (the waterfront/tidelands parcel containing Mr. Smersh's
residence). Rather, it is further east along Shine Road and across the street.
For more than two years, this property has been used to store tens of thousands of PVC tubes,
i.e., it is already in use for commercial geoduck operations, a use that does not comply, absent a
permit, with its zoning (rural residential). The application mentions removing tubes "off site"
from the tidelands, but does not mention where the tubes are going.
(Note: The county was made aware of this unpermitted use of the parcel by email, March 8,
2017, from Marilyn Showalter to Patty Charnas, with follow-up email correspondence including
David Greetham.)
The county should require the application to state whether Parcel No. 970200001 has been
used to store geoduck tubes, whether it is being used to store geoduck tubes, and whether
and how it plans to use the parcel for any part of the geoduck operation, including tube
storage, net storage, or parking.
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MLA 19-00036, June 4, 2019
Questions include:
a) Who owns Parcel #970200001?
b) How is this parcel zoned? What are the distances of the property from Bones Creek and
the high tide line of Squamish Harbor?
c) Have PVC tubes or netting been stored on this property? How many? Who owned
them? When were they placed on the property? Where were they transported from? How,
if at all, has leaching been controlled?
d) Are PVC tubes or netting currently being stored on this property? How many? Who
owns them? How will leaching be controlled?
e) What are'the plans for any PVC tubes or netting now being stored on the property?
f) Will this parcel be used for parking or PVC or other equipment storage, with respect to
geoduck farming anywhere in Squamish Harbor or elsewhere?
g) Was the road/driveway from Shine Road to this parcel graded or graveled in the last five
years? If so, was a permit obtained? Who conducted the work? How much vegetation
was removed in the process, and where?
2) The Application Should Address Bones Creek
The application barely mentions an "unnamed creek" that runs through Mr. Smersh's residential
property and into its tidelands. This is "Bones Creek," aka "East Squamish Creek," which Mr.
Smersh should know, since he and it were the subject of a complaint to the County by the
biologist for the Point No Point Treaty Council, and consequent stop -work order. Mr. Smersh
actually moved the creek and apparently constructed an elevated fish -blocking culvert when he
was building his house, and in handwritten notes explained that he brought in 180 yards of fill,
with plans for 15 yards of topsoil. (County records for parcel #720131007, 1993).
Records from the Washington Department of Transportation show that Bones Creek may be
home to Chum salmon, Coho salmon, Steelhead, Summer Run Cutthroat, and Rainbow Trout.
Moreover, State Route 104, which crosses over the creek upstream, has been extensively and
expensively retrofitted with a large new culvert, to accommodate fish (and wildlife) passage.
lett s://www.wsdot.wa. ov/data/toolsl eo ortal/9*conft =fsh- assa e -barriers WDFW Id
992196.
The County should ask for a full explanation of the creek, its history, its fish, its buffers,
and its mouth, and how five acres of PVC tubes will affect the flow of the creek and the way
fish will approach the creek and linger in the estuary. Questions include:
h) Where was the creek located before Mr. Smersh built his house?
i) How was it moved? What permits were required? What permits were granted?
j) When did the current grading and gravelling of the road/drive from Shine Road to Parcel
#9270200001 occur? What permits were required or granted?
k) What is the distance from the western edge of this drive to Bones Creek, as it runs from
Shine Road north to Parcel #9270200001?
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MLA 19-00036, June 4, 2019
1) How wide is the road/drive? What vegetation removed in the process of grading and
graveling it?
m) What fish have historically or recently used this stream? How will the PVC tubes and the
geoducks affect the fish in the way they approach the creek, linger around its mouth, and
eat tidal flora and fauna
3) The Application Should Address PVC Tubing in the Sand and Water
Plastics pollution, including microplastics, is a worldwide plague, with nearly daily news articles
about its hazards to human and animal health.
https://www.nationalgeographic. com/magazine/2018/06/plastic-planet-waste-pollution-trash-
crisis/
Closer to home—much closer—plastics have been acknowledged as a hazard to the foodchain.
A May 20, 2019 article in the Peninsula Daily News ("Teens clean plastic from shores of
Tarboo-Dabob Bay") quotes Jude Rubin, from Port Townsend's Northwest Watershed Institute:
"It is important to remove plastic refuse before it kills marine life and gets broken into micro -
particles and becomes part of the marine food chain."
htt s://www. eiiinsuladaiI tiews.com/news/teens-clean- lastic-from-shores-of-tarboo-dabob-
bay/
"So when you eat clams and oysters, you're eating plastics as well."
https://www. npr.org/sections/thesalt/2017/09/ 19/551261222/guess-whats-showing-up-in-our-
shellfish-one-word-plastics
Most ocean plastics pollution is unintentional. In the case of geoduck farming, however,
including this application, the insertion of plastic into the sand and water is deliberate. The
applicant plans to insert approximately 80 tons of PVC tubing in a five -acre bed, one tube per
square foot, ground by the sand and leaching into the water for up to two years out of every five
to seven years. That is about 40 miles of tubing.
http://www.caseinlet.org/uploads/The Use of PVC Plastics for Aquaculture in Pu et Sound.
pddf
In addition, the applicant plans to put netting over the tubes secured by a perimeter of rebar (of
unstated gauge and total length). And all of this equipment is cumulative to the acreage that
BDN is already farming in Squamish Harbor.
In 2017, the farming methods for geoducks prompted the Monterey Bay Aquarium's "Seafood
Watch," which rates the environmental impact of seafood around the world, to downgrade the
environmental standing of geoduck as food. "Any sort of plastic in the environment is not the
best choice," said Ryan Bigelow, a Seafood Watch program manager. "Plastics tend to break
down, and that works its way into fish and shellfish. Eventually, all that ends up back in us."
https://www.kitsapsun.com/stor/news/local/2017/02/05/farmed- eoducks-sustainabilit -ratin -
takes-hit/97410252/
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MLA 19-00036, June 4, 2019
From the Seafood Watch report:
Microplastics are believed to disrupt sediment physical and chemical processes, such as
nutrient cycling (Cluzard et al. 2014), and their entry into marine food webs through
ingestion is increasingly demonstrated (Cole et al. 2011) (Cluzard et al. 2014). The
trophic transfer of microplastics in marine organisms is concerning for all organisms,
including humans. For example, one study estimated that European shellfish consumers
were ingesting an average of 11,000 microplastics annually through the consumption of
blue mussels and Pacific oysters, which had filtered microplastics from sea water; data
from another study resulted in an estimate of about 1,700 microplastics present in an
average restaurant serving of farmed mussels (as reviewed in Cluzard et al. 2014).
Because microplastics have also been shown to attract and accumulate toxic chemicals in
the marine environment, to transfer toxins through ingestion (Cole et al. 2011), and to
penetrate cellular membranes (Teuton 2009), the concern related to eating microplastics
is apparent, even if the health effects are not well understood.
https://www.seafoodwatch.org/-
/m/sf-%v/pdf/reports/g/mba seafoodwatch farmedgeoduckreport.pdf, p. 36
As the report also points out, once consumers start to worry about contaminants in their food,
they stop buying the food. This reaction occurred when oyster beds were to be sprayed with
neurotoxins in Willapa Bay. https://www.seattletiiiies.coinllife/food-drink/plan-to-put-
iieurotoxin-oii-o ster-beds-distresses-restaurants/ And it occurred when China discovered too
much arsenic in some of Puget Sound's subtidal geoducks.
http://old.seattletimes.com/htiyd/businesstechnology12022497142 geoduckarsenicxml.html
Installing PVC tubes is self-defeating and short-sighted. While the market may later send a
signal objecting to the product of this practice, the microplastic will remain in Jefferson County's
benthic community, polluting it and the food chain that feeds on it, for the foreseeable future—
degrading our economic, environmental, and bodily health.
The County should insist on a full analysis of PVC tubes and related equipment in
Squamish Harbor. Questions include:
n) How many PVC tubes will be inserted in the site? What is the total weight and length?
o) What is the total area of netting that will be installed? What does it weigh?
p) What is the gauge and total length of rebar that will be installed? What does it weigh?
q) Where is the rebar manufactured? What is its content, beyond pure iron?
r) What is the expected degradation, whether from grinding or leaching, of the PVC tubes,
i.e., how much plastic or chemicals is expected to be separated from the tubes into the
sand or water?
s) What is the effect of microplastics on the benthic community? Is it ingested? Expelled?
t) What is the effect on fish and other sea life further up the food chain, including Marbled
Murrelets, Summer Chum salmon, and Chinook salmon—and the forage fish they feed
on, such as sand lance and herring?
u) After the harvest process, how much microplastic is upended and released into the water?
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MLA 19-00036, June 4, 2019
v) Once the upended microplastic settles, what happens to it when tidal action and storms
(fetch) move the sand to nearby locations?
w) How will the tubes affect the flow out of Bones Creek?
x) How will the tubes affect salmon and trout heading into Bones Creek?
y) How many acres, in total, in Squamish Harbor, including all currently or proposed tracts,
will be subject to insertion of PVC tubes and related equipment?
z) What kinds of digestive, hormonal, or biochemical effects result from the ingestion of
microplastic by humans?
As I mentioned, this is not a complete list of concerns or comments; it is a set of topics that need
to be addressed before one can even reasonably respond to the application.
Thank you for your consideration.
Sincerely,
ilfaztPyK SkeruaUez
Marilyn Showalter
1596 Shine Rd
Port Ludlow, WA 98365
Cc: Phil Hunsucker
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