HomeMy WebLinkAbout038 LetterDonna Frostholm
From: Marilyn Showalter <marilyn.showalter@gmail.com>
Sent: Monday, March 8, 2021 1:02 PM
To: matthewj.bennett@usace.army.mil; Daisy.P.Douglass@usace.army.mil
Cc: Donna Frostholm; Philip Hunsucker
Subject: Case Shoal (Squamish Harbor) Shellfish Operation NWS-2010-1039, Jefferson Parcel #s
721092001,003
Attachments: Case Shoal Showalter Letter to Bennett Douglass 3-8-2021.pdf
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Attached is a letter from me to Section Chief Bennett and Case Manager Daisy Douglass, cc to Donna Frostholm and Phil
Hunsucker, complaining against and objecting to permit(s) for commercial shellfishing at Jefferson Parcel #s 721092001,
003, and requesting relevant records from the Corps. --Marilyn Showalter
Marilyn Showalter
1596 Shine Rd
Port Ludlow, WA 98365
(360) 259-1700 (cell)
ma ri lyn.showa Ite r@gma i I.co m
LOG ITEM
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Wage i 0lf:Es
MARILYN SHOWALTER LOCH p7' m
1596 Shine Road # � �VJ
Port Ludlow, WA 98365 ��
marilyn.showalter@Rmail_com, 360-259-1700 g motif
March 8, 2021
Matthew J. Bennett, Section Chief
Corps of Engineers Regulatory Branch &
Daisy Douglass, Project Manager Biologist
Mattliew.J.Bennett@usace.qnny.mil
206-764-3428
Dais . P. Doug lass usace.arm .mil
206-764-6903
BY EMAIL
Re: Complaint/FOIA/Objection re Rock Point Case Shoal Permits
References: NWS-2010-1039, NWP 48; Jefferson County Parcel #s 721092001, 003
Dear Section Chief Bennett and Project Manager Douglass,
I write to object to the issuance or verification of an individual or nationwide permit for
commercial aquaculture at the above -referenced location. Also, please provide me with all
records relating to these parcels, 2005 through now, excepting those provided to Jan Wold.
As you know, I live on Shine Road, Squamish Harbor, Jefferson County, WA. I have owned
property here for 44 years. From my house, I look across Squamish Harbor to Case Shoal
(which is in Squamish Harbor) and the tidelands off South Point Road. In the past few years, I
have noticed an increase in what appears to be commercial shellfish activity there (mostly
oysters, I believe). It is unclear to me if geoducks have been planted or harvested, but in a
Jefferson County record regarding a different shellfish operation, it appears that geoduck farming
was authorized by the Corps for these parcels on August 18, 2017. (Jefferson County MLA19-
00036 BDN, Log Item 25, p 14.) At this point, and in light of recent Federal court orders, no
permit/verification should issue, for at least the following reasons:
Insufficient Environmental Analysis, Including Lack of Cumulative Effects Analysis
There has been inadequate evaluation of environmental effects, including cumulative effects,
regarding, among other things, endangered or threatened species in Squamish Harbor. These
include Hood Canal Summer Run Chum salmon and Marbled Murrelets and the local ecosystem
on which they depend. Squamish Harbor hosts native eelgrass beds and spawning grounds for
sand lance, herring, smelt, and rocksole. This is an incomplete list. A full environmental
assessment, with opportunity for public input, is imperative, when considering a new permit.
Insufficient Accounting of Acreage, Species, and Methods of Cultivation
There is inadequate accounting of how much acreage, for which species, with what equipment
has been planted or harvested over which periods of time. In particular, it is important to know,
for purposes of evaluating cumulative effects, the status of cultivation on these parcels in 2007,
as well as in subsequent years.
LOG ITE.N1
Ltr to Bennett and Douglass March 8, 2021
Re: Case Shoal (NWS-2010-1039) Page
Insufficient Information Bearing on Need for County Permit
Just as significant, it is important to know the status of cultivation (acreage, species, equipment)
on these parcels as of February 21, 2014, the effective date of Jefferson County's Shoreline
Master Plan (SMP).
Under current individual and NWP permits, the Corps states: "You must also obtain all local,
State, and other Federal permits that apply to this Project." (See, e.g., Case Shoal verification
letter dated August 18, 2017, page 3.) (Italics added.)
The Jefferson SMP requires a county permit if-
[t]he physical extent of the facility or farm is expanded by more than 25 percent or more
than 25 percent of the facility/farm changes operational/cultivation methods compared to
the conditions that existed as of the effective date of this program or any amendment
thereto. If the amount of expansion or change in cultivation method exceeds 25 percent in
any 10-year period, the entire operation shall be considered new aquaculture and shall be
subject to applicable permit requirements of this section
Jefferson County Code 18.25.440(4)(i)
Looking forward, in order to determine whether a County permit is necessary, both the Corps
and Jefferson County need to know the status of cultivation on February 21, 2014.
But also, looking backward, if, since February 21, 2014, Rock Point has expanded or changed
cultivation methods beyond the 25% limits, the company would be in violation of Jefferson
County code as well as federal authorization.
The cleanest way to address this issue, especially before any new authorization is considered, is
for Rock Point to provide a year -by -year accounting, from 2007 onward, including the February
21, 2014 date, detailing acreage under cultivation, type of species, and type of equipment and
methods used. This should be supplied to Jefferson County as well as to the Corps.
One caveat: I and my neighbors Jan Wold and Sue Corbett have made various requests for
information about Squamish Harbor that have not been answered by the Corps, including
information on the Case Shoal parcels (email from Jan Wold to Pam Sanguinetti, January 5,
2021). If and when we receive that information, it might prompt some modification of what I
have said here. But given the timeline of possible new permits, it was necessary to proceed
without it.
Thank you for your attention to this matter.
Sincerely,
iX.e"a" S<so ""rot
Marilyn Showalter
cc: Jan Wold, Sue Corbett, Donna Frostholm, Phil Hunsucker
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