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Donna Frostholm
From: Paul Steenberg <tanevaho@hotmail.com>
Sent: Friday, August 20, 2021 4:14 PM
To: Donna Frostholm; Jan Wold; Paul Steenberg
LOG IYep1J1'
Subject: Re:Urging Denial of BDN-Smersh Application MLA19-00036, SDP19-00008, for a
Geoduck Farm Off Shine Road, in Squamish Harbor, Hood Canal, WA
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Comments of Paul E. Steenberg, neighbor of proposed project:
I am commenting on the proposed Smersh Commercial Geoduck Farm Habitat Management Plan and No Net Loss
Report, FINAL REPORT, prepared for BDN, LLC, October 2019, Rev. September 2020, by Confluence Environmental
Company (Novak 2020), analysis funded by BDN LLC.
Given the deteriorating fisheries habitat quality in Hood Canal and Puget Sound, a primary biological concern is this:
What will be the effects of the proposed project on forage fish, upon which the entire food chain (fisheries, sea birds,
orcas) depends? Confluence contends that there could be two effects: "(1) spawning habitat could be overlapped, and
(2) forage fish spawning areas could receive suspended sediments during a harvest event." (p. 21).
Completely unexamined by the Confluence analysis is the primary biological effect of the proposed geoduck
aquaculture: Concentrated geoduck aquaculture filters out of the water column huge amounts of phytoplankton and
zooplankton, much of which would otherwise be used as a food resource by organisms such as copepods, consumed
and metabolized by forage fish. Each geoduck clam filters an estimated 43-127 (85 mean) gallons of sea water per day
(Straus et al., p.16). Assuming that Smersh's geoduck farm produces five geoducks per square meter (20,234/ac.) (Heath
2005), that equates to 20,234 geoducks/ac. X 5.15 ac. X 85 gal./day = 8,857,444 gal./day of sea water filtered by
Smersh's geoducks. Nearly nine million gallons of sea water per day! That amount of filtered water would fill more than
13 Olympic -sized pools — every day. How can a marine biologist contend that this is "no net loss of ecological function"
of the shoreline? The commercially farmed shoreline and associated intertidal area would be dramatically less
productive for forage fish than without the farm.
This proposal is "no net loss" only in an economic sense to BDN LLC, which would profit handsomely. BDN, LLC farms
geoduck clams for export to China. He privatizes the profits and sticks the public and the marine environment with
externality costs in the form of reduced fisheries habitat quality and productivity, as well as reduced commercial and
recreational fisheries catch in Hood Canal, Puget Sound and beyond. Such a deal, at least for Smersh and BDN.
Literature Cited
Heath, Bill Ph.D., P.Ag Shellfish Production Specialist Ministry of Agriculture and Lands. June 2005. "Geoduck
Aquaculture: Estimated Costs and Returns for Sub -tidal Culture in B.C." British Columbia Ministry of Agriculture and
Lands. Aquaculture Factsheet No. 05-01. 8 p.
Novak, Grant. October 2019, revised September 2020. "Smersh Farm Habitat Management Plan and No Net Loss
Report FINAL REPORT." Confluence Environmental Company, 146 N. Canal St., Suite 111, Seattle, WA 98103. 38 p.
Straus, Kristina M., MacDonald, P. Sean, Crosson, Lisa M. and Brent Vadopalas. School of Aquatic and Fishery Sciences,
University of Washington. Nov., 2013. "Effects of Geoduck Aquaculture on the Environment -- A Synthesis of Current
Knowledge" -- Washington Sea Grant Technical Report WSG-TR 13-02. 47 p.