HomeMy WebLinkAbout054 Email - Hood Canal Environmental CouncilDonna Frostholm
From: nana@hctc.com L� Jc
Sent: Friday, August 20, 2021 10:15 AM „uc 47
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To: Donna Frostholm ny`i
Subject: Letter to Jeff. Co. Page ��
Attachments: 8-15-21 Ltr. Jeff. Co. BDN-Smersh.doc
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Enclosed is a letter from the Hood Canal Environmental Council regarding the application from BDN/Smersh for a
geoduck farm at Sqaumish Harbor.
Thanks for providing the opportunity for us to comment on this application.
Donna M. Simmons, President
Hood Canal Environmental Council
(360) 877 -5747
nana@hctc.com
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HOOD CANAL ENVIRONMENTAL COUNCIL
P.O: Box 87 — Seabeck, Washington 98380
August 15, 2021
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, Washington 98368
E-mail to: dfrostholm co.'efferson.wa. ov
Re: BDN-Smersh Application for Geoduck Farm in Squamish Harbor
Attn: Development Review Division and Hearing Examiner:
The Hood Canal Environmental Council (HCEC) respectfully requests that Jefferson County consider
the following comments regarding the BDN-Smersh application for a 5.15 acre commercial geoduck
farm located off Shine Road in Squamish Harbor in Hood Canal. The HCEC urges the Jefferson
County Development Review Division and Hearing Examiner to deny permits for this proposed
operation for the following reasons.
Loss or degradation of eelgrass
The loss of native eelgrass throughout Hood Canal is well documented. Eelgrass (Zostera Marina)
supports important ecological communities in shallow bays like Squamish Harbor. Numerous fish and
wildlife species depend on eelgrass for their survival. The combination of existing geoduck farms and
the proposed farm will likely result in further threats to these species.
Loss of fish and wildlife
Also documented is a serious decline in populations of forage fish in Hood Canal, including sand lance
and herring. The importance of this resource cannot be overstated, especially as it provides food for
salmon and other finfish. Threatened and endangered species of finfish are found in the proposed site,
including Puget Sound steelhead, Bull Trout, Hood Canal Summer Chum salmon, Puget Sound
Chinook salmon, a number of species of rockfish, and transient Orcas. Marine and shoreline species of
birds are found in Squamish Harbor, including Marbled Murrelets, Pigeon Guillemots, Kingfishers,
Herons, Bald eagles, and Canada geese. Marine mammals include river otters, harbor porpoises, gray
and humpback whales and many others. All of these fish and wildlife species should receive the
highest level of protection from potential negative impacts, including noise associated with hydraulic
harvesting.
Environmental impacts from-geoduck farming practices
The farming practices involved in planting and harvesting geoducks causes serious disruption of
biologically rich substrates. The damage to tideland ecosystems from geoduck farming include the
placing of hundreds of PVC tubes which become dislodged and eventually break down into bits which
can be mistaken for food by birds and other species of wildlife - often with fatal results.
Potential cumulative impacts
The HCEC is particularly concerned about the potential cumulative impacts of permitting intensive
geoduck farming operations in a relatively small area. This raises the question as to whether the
Squamish Harbor can support another geoduck farm and still protect critically important marine and
other wildlife species. From a greater Hood Canal watershed perspective, it is worth noting that the
Army Corp of Engineers stated in a Draft Cumulative Impact Analysis that 19% of the canal's tidelands
are covered with commercial shellfish permits. Any impacts to fish and wildlife accruing from
geoduck aquaculture in Squamish Harbor must be considered within the larger watershed -wide context.
IncompatibilityIncompatibilily with recreational uses
The proposed geoduck farm is adjacent to the Hicks County Park. Residents of Hood Canal and
visitors use this popular park for swimming, boat launching, shellfish harvesting, picnicking, and other
recreational activities. When the tubes used in the process of geoduck farming are covered by water,
they can be hazardous, especially for children, as well as being unsightly for those enjoying the natural
setting.
Hood Canal is classified as a Shoreline of Statewide Significance. Priority uses are to "recognize and
protect the statewide interest over local interest, preserve the natural character of the shoreline, result in
long term over short term benefit; protect the resources and ecology of the shoreline; increase public
access to publicly owned areas of the shorelines; increase recreational opportunities for the public in
the shorelines" (Washington State Department of Ecology).
The HCEC partners with other concerned organizations and communities in working to protect the
overall environmental health of the Hood Canal watershed. One of our primary goals is to protect our
unique tideland ecosystems, including Squamish Harbor, from activities that pose a threat to these
ecosystems.
We sincerely hope that Jefferson County will consider our comments in its decision -making process.
Please include the HCEC on your list of interested parties and keep us informed of any 1tt#re. �wt ons
regarding the BDN/Smersh application. I_L_�+ I sv`
Sincerely,
page,
Donna M. Simmons, President
Hood Canal Environmental Council
(360) 877-5747
nana@hctc.com