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Home My WebLink About059 Email - WoldDonna Frostholm From: Janet <jestuary@hotmail.com> # Sent: Friday, August 20, 2021 4:27 PM paO To: Donna Frostholm �! Subject: Smersh Proposed Geoduck Farm Attachments: SmershJefCo82021 Sum.Ltr.Jan.docx CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Can you please let me know you received this? Thank you, Jan Wold # LOG� �ITE Pam z°s1D LOG ITEM Jan Wold # POB 1340 Page �- Df Poulsbo, WA j.creek@hotmail.com August 20, 2021 ATTN: Jefferson County Hearing Examiner Development Review Division, Jefferson County Department of Community Development 621 Sheridan Street, Port Townsend, WA 98368 By email: dfrostholm@co.jefferson.wa.us Re: Urging Denial of BDN-Smersh Application MLA19-00036, SDP19- 00008, for a 5.15 Acre Commercial Geoduck Farm Next to Shine Road, in Squamish Harbor, Hood Canal, Port Ludlow, WA Dear Development Review Division and Jefferson County Hearing Examiner: I urge you to DENY this Smersh application for a 5.15 acre geoduck farm next to Shine Road in the Squamish Harbor portion of Hood Canal. I am commenting on this county permit application that is under review. Please include my comments in your project file and add me to mailing lists regarding this review. My email is j.creek@hotmail.com. I have lived on Shine Road next to the Squamish Harbor portion of Hood Canal, one and a half miles west of the Hood Canal Floating Bridge, for the LOG ITEM "7age t last eight years, I have a number of years of experience observing the active 3.58 acre commercial geoduck farm operated by BDN. I have college degrees studying biology, aquatic biology and fisheries. I have worked in the fields of hydrology, aquatic biology, fisheries and forestry for the Environmental Protection Agency, Oregon State University and both the research and land management portions of the U. S. Forest Service. I have experience working on water quality issues in the Seattle, WA, Portland, OR, Corvallis, OR and San Francisco, East Bay, CA domestic watersheds. I spent the last seven years before retiring as Forest Supervisor in charge of a 1,000,000 acre National Forest. There is need for a very thorough review of this application along with information provided by the public before making a decision on a proposed 5.15 acre geoduck farm in such a highly sensitive and currently stressed marine environment. It will be critical to consider the unusually high number of threatened species in this location, this tideland's location in a herring spawning area and in or near a sand lance spawning area, critical nearshore habitat for threatened and endangered salmon and trout, dense eelgrass beds at the bottom of the property, shared boundary with Jefferson County's Hicks Beach Park and boat launch (celebrating its 75th. anniversary this year), present water quality issues including acidification in Hood Canal and navigation and public safety concerns. This proposed geoduck farm will have large impacts such as plastic pollution, release of carbon, increase in ocean acidification, disturbance of fish, wildlife, neighbors and park visitors, stress on threatened and endangered species, their spawning areas and food sources, loss of eelgrass, increased turbidity, ingestion of micro -plastics by food chain organisms, visual, water quality, navigation and public safety. Estuaries such as Squamish Harbor, the location of the proposed Smersh 5.15 acre commercial geoduck farm are some of the most important, diverse and imperiled ecosystems in the world. Millions of public dollars are being spent to restore Puget Sound habitat that is so important for dwindling numbers of forage fish, salmon, orcas, gray and humpback whales, marbled murrelets, common loons, western grebes, sunflower sea stars and numerous other species. Herring, sand lance and surf smelt populations continue to decline, yet are critical in the food chain for many other imperiled species. Eelgrass is also critical as habitat and the foundation for the food chain for so many of these species and their offspring. iJ,3 TEM a9C�. Of Numerous threatened and endangered species occur in Hood Canal, Puget Sound and the Salish Sea. It is my observation after decades of working in natural resource management and taking part in planning or supervising thousands of projects that I have not seen projects that have anywhere near the number of threatened, endangered and candidate species for listing as in the Smersh proposed commercial geoduck farm (Jan Wold, personal experience, whose last job before retirement was as the leader of a one million -acre National Forest). For this reason alone this proposal should be rejected. If not, then an Environmental Impact Statement (EIS) should be prepared. As an example, Hood Canal contains, populations of threatened Puget Sound steelhead (Oncorhynchus mykiss), threatened Puget Sound Chinook salmon (O. tshawytscha), threatened Hood Canal Summer -run Chum salmon (O. keta), threatened Canary Rockfish, threatened Yelloweye Rockfish, endangered Pinto Abalone and the critically endangered Sunflower Sea Star. Research published in Science magazine as reported in The Wall Street Journal by Jennifer Calfas, September 19, 2019 found that "North America's overall bird population has dropped 29% since 1970, with about 3 billion fewer birds now than nearly 50 years ago." The article continues, "Described as unprecedented by researchers and scientists, the findings display a new and unexpected assessment of the bird population across the continent. The areas that could be developed for or converted to geoduck farms are areas with large numbers of both migratory and resident bird populations. Marbled murrelets (Brachyramphus marmoratus) are a small seabird that is listed as a federally threatened species. The species has been recently up - listed to endangered by the State of Washington. Marbled murrelets are in Squamish Harbor because of the forage fish they eat and feed to their one annual nestling and because of the proximity to old -growth forest nesting habitat, especially in Olympic National Park. We should not further endanger their existence, habitat and food chain by allowing more impact to water quality without a thorough county analysis and public review. LOG ITEM M Page & 0 Millions of public dollars are being spent to restore Puget Sound habitat that is so important for dwindling numbers of forage fish, salmon, orcas, marbled murrelets, common loons, western grebes and numerous other species. Herring, sand lance and surf smelt populations that rely on clean water, eelgrass and undisturbed spawning and feeding areas continue to decline, yet are critical in the food chain for these other imperiled species. Herring, sand lance, smelt and rock sole spawn in or near many of the shellfish farms. Degrading water quality with increases in turbidity, disruption of substrate and release of micro -plastic and carbon into the water column will further stress these species and their food chain on which they depend. Shellfish aquaculture adversely affects marine life, including Chinook salmon which are essential to Southern Resident Killer Whale (Orca) survival. The 2017 Army Corps Draft Cumulative Impact Analysis (CIA) is a frank assessment of what science shows will likely happen if industrial scale aquaculture is allowed to continue, much less expand. The Corps concluded: "The proposed action (shellfish aquaculture permitting) is likely to adversely affect designated critical habitat for several species listed under the ESA including Puget Sound Chinook salmon, Hood Canal summer run chum salmon, and Puget Sound steelhead." Page 101 "Given the magnitude of the impacts in acreage, the importance of eelgrass to the marine ecosystem, and the scale of the aquaculture impacts relative to other stressors, the impacts are considered significant." Page 103 The Army Corps Draft Cumulative Impacts Analysis for the 2017 Nationwide Permit 48 lists the following statistics: -Twenty-six percent of Gray's Harbor, Willapa Bay, Hood Canal, and South and North Puget Sound tidelands combined were covered with commercial shellfish farming permits (page 55) at the time of the Corps' analysis. -There were at the time commercial shellfish permits approved for 19% of the tidelands of Hood Canal (page 55). LOG ITEM # -41 % of the continuingactive acreage of shellfish farm n Hood d Cah,fs 9 potentially co -located with eelgrass. Page 58 of the CIA lists 538 acres of Hood Canal tidelands potentially blanketed by shellfish cover nets on presently active commercial shellfish farms. Although this Smersh proposal does not include cover nets it will have additive cumulative impacts that need to be considered with those other area shellfish farms that do have them. The CIA, page 60, shows 510 acres of Hood Canal active commercial shellfish farms co -located with forage fish spawning areas (herring, surf smelt and sand lance). The number of shellfish permits has increased since the date of these initial calculations in 2017 or earlier. When the Army Corps was originally issuing commercial shellfish permits it suggested that the NWP 48 permit would be used about 250 times during a five year time frame. However, approximately 900-1200 commercial shellfish permits were issued. The environmental effects of abnormally large concentrations of both native and non-native shellfish filtering and removing nutrients and food web organisms from the waters of Puget Sound is occurring. The numbers of most of the threatened and endangered species dependent on these food sources are dropping precipitously. The Smersh proposed commercial geoduck farm is incompatible with the use and enjoyment of Hicks Park and boat launch. This year marks the 75th anniversary of Hicks County Park. This rare county park and public boat launch shares a common boundary with the proposed geoduck farm, both on land and in the tideland. The Smersh site plan provided with the county application is quite misleading (Log Item 39, Page 8 of 561). The site plan shows- -A blue square is used to show the proposed geoduck farm. The west boundary line is heading in a southern direction and is drawn to be moving away from Hicks Park and boat launch. The yellow rectangle (property 3) representing the Park shows no sharing of an entire boundary line, yet they do share the entire boundary. It also shows the yellow rectangle for the Park not going out into the tideland the same distance or more than the geoduck planting area. This gives the viewer the completely incorrect idea r .Q. 39 pu,q£ e /0- that the two areas are separated and the Park property does not go out into the tideland very far and does not share a boundary. Park visitors are often way out on the tideland for one of its more popular activities, shellfish digging. The visitors will be doing that activity right up to the line of the geoduck farm as will any other visitors out on the tideland. -the orange parcel (property 2) that is being proposed as a commercial business parking lot for the Smersh commercial business is drawn to look very small even though the property is much larger. The road access to this proposed parking lot goes directly through the 150 foot buffer of Bones Creek, a fish stream (F stream). See our description in the joint public comments in the section on "Bad Track Record." The various questionable and not permitted activities, some involving the fish stream, carried out by Smersh in the past are documented there. Even if the parking lot and road were not inside of the creek buffer it would be the last place that would make sense for a commercial parking lot —next to a fish stream, much less one that then immediately flows out onto herring, sand lance spawning areas, thick eelgrass beds and tidelands that support a number of threatened and endangered species. -Smersh states in the narrative for this site plan that: "Approximately 6-10 passenger vehicles or light trucks may be parked on this property in connection with these activities. This property is not not within 150 feet of any waterbody, and is not within 150 feet of any known Type F, N or S streams".... This statement is false as I am sure he knows since he lives right there and has been in trouble in the past for his actions involving this F stream (refer to our discussion in our joint comments titled "Bad Track Record." -If you view the aerial photos of this orange parcel, property 2 it is apparent that the driveway for the proposed commercial business parking lot is 75 feet or less from the F stream. It appears the north south property line on the west side of the parking lot property runs more or less up the F stream. It also appears that part of the parking lot is in the Bones Creek (F stream) buffer. There are also no restroom facilities at this location. It doesn't take much imagination to picture what happens after his employees have been in their cars driving for a while and arrive at the parking lot. Hopefully he is not planning on providing a restroom by using the County Park restroom at a cost to the county tax payers and in conflict with the Park visitors. If he LOG ITEM Page / plans to bring in a portable toilet it would seem that a location near a fish stream just feet from the waters of Hood Canal would not be a good plan. Tourists and county residents alike use Hicks Beach Park for crabbing, clamming, wading, swimming, paddling, floating, beach combing, launching kayaks/canoes and motor boats, barbecuing, picnicking, and just sitting and taking in the view. It is used in summer and winter, at high tide and low tide, week days and weekends. It is used by adults and children. Due to its rich environmental assets, Hood Canal has been designated by the state as a Shoreline of Statewide Significance. As a part of this Shoreline of Statewide Significance, Squamish Harbor, including Smersh's tidelands, teems with native eelgrass, which is critical habitat for herring, sand lance, salmon, steelhead trout, crabs, and many other sea creatures. There are many efforts around the state to protect and restore this foundation of marine ecology. It should be protected here rather than impacted by a 5.15 acre geoduck farm. See the discussion of the importance of eelgrass in my joint public comments. The operator -applicant has a bad track record in Squamish Harbor. "BDN" (Brad Nelson), the would-be the operator of the proposed geoduck farm, already operates a 3.58-acre geoduck farm in Squamish Harbor, 12 mile west of the proposed site. A long and serious list of complaints and failures is on file with the U.S. Army Corps of Engineers. Under BDN's Federal permit for his 3.58 acre active geoduck farm, he is prohibited from harvesting from February 1st through April 30th. This is for the protection of an endangered species, Hood Canal Summer -Run Chum. On six occasions during the prohibited period, February 7, 13, 14, 18, 20, and 22, 2021, BDN harvested geoducks in Squamish Harbor in violation of his permit. As far as I know there has been no action taken by anyone to correct this problem. But the important thing isn't that there is a permit violation. It is that each one of these actions is harming the juveniles of the the federally listed as threatened Hood Canal summer -run chum salmon and probably other listed species as well. In summary, this permit should be denied. At a minimum an Environmental Impact Statement needs to be prepared before making any decision other than denial. LOG ITEM Thank you for this opportunity to comment. Sincerely, Jan Wold