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Home My WebLink About049 Email - DittmarDonna Frostholm_.,ae� From: Steve Dittmar <swdittmar@gmail.com> Sent: Friday, August 6, 2021 5:10 PMaF To: Donna Frostholm Subject: BDN - Smersh Geoduck Application - Community Feedback Follow Up Flag: Follow up Flag Status: Flagged CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. In 2012 my wife and I purchased one of the original houses here on Shine Road, build in 1928. Our property is located adjacent to (East of) the current Brad Nelson (BDN) geoduck farm. This, and the proposed Smersh geoduck farming operations are likely to have a very direct impact on our tidelands and the surrounding Squamish bay ecosystem. I have a few concerns I would like to bring to your attention with the hope that your determination will be that the Squamish bay tidelands are not appropriate for commercial intertidal farming operations, especially geoducks, now and in the future and specifically to deny the Smersh geoduck farming permit. My understanding is the current BDN geoduck farm (adjacent to our tidelands) is on 3.5 acres. PVC tubes 4" in diameter and about 10" long are planted in the sand approximately 1 every square foot which translates to about 43,000 tubes per acre. The math for this works out to about 35,300 feet of PVC tubing per acre in our tidelands, that's about 6.79 miles of pipe per acre soaking and being abraded by the waves and sand action day after day. If the current BDN 3.5 acre farm is all planted at the same time that would be 3.5 acres * 6.79 miles/acre = 20 miles of 4" PVC in our little Squamish bay. Now add the proposed Smersh farm planting operation of 5+ acres * 6.79 miles/acre = 34 miles for a potential total of 20 miles + 34 miles = 54 miles of PVC tubing here in Squamish bay. That's 54 miles of 4" PVC tubing polluting our little Squamish bay 24/7, 365 days per year, how is it possible to allow this? Recent studies show that toxins in PVC piping pollutes the ecosystem, enters the food chain and does not "burn off' but rather gets concentrated as it moves up the food chain from one predator to the next, birds of prey, mammals and us humans as we eat the shellfish here in the Shine area and throughout Puget Sound. With Puget Sound and especially Hood Canal already being challenged by other pollution sources it does not seem reasonable to add yet another source of pollution which is so easy to identify and stop. During our winters here on Shine Road we have strong southerly winds and big waves which dislodge many of the tubes. Some of the tubes wash up and litter the beach but potentially a greater number get sucked out to deeper water. I personally snorkeled out beyond the current geoduck farm on one of our low tides in May 2015 to inspect and count loose tubes that had been sucked out into the bay. I only had at most 15' visibility that day and I stopped counting loose tubes at around 100 but saw many more. I headed West to inspect and confirm that many tubes have been moved by the current to the West of the farm at least a couple hundred yards. I did not inspect very far to the East. The deeper I went out to the South of the current farm the more loose tubes I observed. Based on my personal observations there are easily many 100s and potentially 1000's of loose tubes out in our Squamish bay. The proposed Smersh farm would add yet another 5 acres of tubes to our bay which more than doubles the amount of lost tubes. This derelict geoduck gear is just left in our bay for the long decomposition cycle to release toxins into our waters and this delicate ecosystem for many years to come. Further, these tubes are constantly rolled around by the water currents in the bay disrupting and potentially killing new sprouts of eelgrass and other plant material. The geoduck growing operation leaves these unsightly tubes in the sand for about 2 years and then the geoducks are harvested in about another 4 years. Four "seed" geoducks are placed in each tube with the goal survival rate of 50% (per BDN). So the number of seed geoducks from BDN's original farm here in Squamish bay would add 4 seeds/tube * 43,000 tubes/acre * 3.5 acres = 602,000 juvenile geoducks. Over the next 6 years the number gradually declines by 50% to about 301,000 mature geoducks. If we then add in the proposed Smersh farm with 5+ acres which adds another 4 seeds/tube * 43,000 tubes/acre * 5 acres = 860,000 juveniles planted and 430,000 mature geoducks would bring the total adult geoducks added to our small Squamish bay to 731,000 adult geoducks. There is some staggering of the plantings but to maximize the yields these number are certainly close enough to get a sense for the gross magnitude of the impact. These animals are constantly extracting protein and other nutrients from the water column and leaving their waste. Assuming the ecosystem here in the Squamish bay was reasonably balanced before these farms, these numbers of animals is certainly sufficient to change the surrounding ecosystem balance and consume the nutrients that the other critters in the ecosystem have relied on. Other areas with geoduck farms have seen dramatic reduction in wildlife after the geoduck farms come in and we certainly do not want that here in our Squamish bay area. I personally have seen crabbing in our bay go from excellent to poor about 4 or 5 years ago which is just about the time BDN's geoducks were getting to a mature size. Just my subjective observation but one that is shared by all my other crabbing friends around our bay. To lose the balance of our ecosystem here in Squamish bay for the profit of these one or two farmers does not seem like good stewardship of our environment. The harvesting process I am told uses a water jet to basically liquefy the sand so the mature geoduck can be more easily extracted. Our tidelands are directly adjacent to the current Brad Nelson geoduck farm here in Squamish bay and about'/4 mile from the proposed Smersh farm. I am very concerned that both the ecosystem within the sand column and in the surrounding water column will be adversely impacted in this process. Much like logging disrupts the soil retention causing the loose soil to wash into the surrounding streams which affects the ecosystem of the stream, salmon spawning, etc, I am very concerned that liquefaction of the sand will impact the entire Squamish bay. My goal for our tidelands is to restore them as quickly as possible to their native state, these farming operations will be taking us a giant step backwards. I am told that the biomass of native geoducks in Puget Sound is greater than the any other biomass. With appropriate oversight to manage this native/wild resource in a sustainable way there should be no need to suffer the impact of intertidal farming of geoducks here in the Squamish bay or really anywhere else in Hood Canal or Puget Sound. We have enough existing challenges within the ecosystem of Hood Canal without adding additional stress and changes from farming operations which can be so easily avoided and stopped. The profits to so very few should not overrule the proper stewardship of such a fragile and dwindling natural public northwest treasure. My wife and I are very hopeful that the Army Corps of Engineers will weigh the benefits to a very few with the large impact to the ecosystem, native animals and all of us humans surrounding Hook Canal and we ask that Army Corps to stop existing intertidal geoduck farming and specifically this Smersh permit for geoduck farming here in Squamish bay. Thank you for your consideration of this input. Steve and Kathy Dittmar 30 Watney Lane Port Ludlow, WA 98365 206-619-6822 LOG ITEM CAge �-