HomeMy WebLinkAbout2023 11 01 King - Additional Comments on SMP UpdateFrom:Gordon King
To:Josh Peters
Subject:Additional Comments on SMP Update
Date:Wednesday, November 1, 2023 4:17:05 PM
Attachments:Outlook-iysse0ml.png
Comments on Aquaculture SMP Update Table.docx
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Please find my comments on the suggested requirements and table for the Aquaculture
section of the SMP Update.
Table is in black my comments are in red.
Gordon King
Director of Mussel Farms
130 SE Lynch RD Shelton, WA 98584W: 360-432-3338| C: 360-490-9511gordonk@taylorshellfish.com
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Applica�on Requirement
a) Site Plan requirements
Perimeter of proposed aquaculture opera�on area Standard and seems clear.
Existing bathymetry depths based on MLLW This is reasonable and growers are required to
submit an eelgrass survey for the JARPA to get the mandatory Army Corps 401 permit for new
cultivation water depths are indicated on the eelgrass survey as well as the site plan layout.
For the JARPA maps, we need to indicate the extent of the operation which includes the
upper and lower tidal extent.
Adjacent upland use, vegetation, presence of structures, docks, bulkheads and other
modifications Will be part of JARPA, SEPA or NEPA so long as these documents are acceptable.
Areas where substrate modifica�on will take place or where structures or materials will be
constructed or installed(1) Fine
Numbers, types and dimensions of structures, apparatus, equipment, or other improvements
Fine
Access provisions for marine or vehicle traffic, processing structures or facili�es(2) Fine
Loca�on of storage or processing structures or facili�es Fine
(b) A baseline ecological survey, including a description of the following, and an assessment
of any direct, indirect and cumulative impacts on the items below BA / BE may be done for
new aquaculture, but the Services Programmatic Biological Assessment and Opinion
which comprehensively evaluated aquaculture operation impacts for existing and new
farms through 2035, should also be considered to meet the requirements here.
Existing and seasonal conditions This is not in the current SMP.
Why and what are they asking for? What use will the County have for such information? As per
above these parameters have been evaluated under the Army Corps Programmatic consultation
and biological assessment.
Water quality What parameters of water quality are they asking for and water quality is
monitored and controlled by the WDOH?
Tidal varia�ons This is the same information asked for in part “a”-“Exis�ng bathymetry depths
based on MLLW” Why does the County need this information twice? Really demonstrates poorly
written regulation and once again will be in the JARPA with the Army Corps permit.
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Prevailing storm wind conditions Properly managed farms which include standard BMPs
should address this concern. Unclear what the goal of the question is meant to accomplish, except that the grower is aware of the environment they are working in.
Current flows at each �dal cycle Finfish
Flushing rates Finfish
Litoral dri� Finfish
Sediment dispersal, including areas of differing substrate composi�on Finfish
Areas of aqua�c, inter�dal and upland vegeta�on complexes(1) Areas of kelp and eel grass is
information required for an Army Corps Section 10 permit.
Aqua�c and benthic organisms present, including forage fish, and spawning and other lifecycle
use of, or adjacent to, the site This information is required with a SEPA for a CUP and the County
requires a JARPA for an exception to a SDP or a CUP which would include this information.
(c) Opera�onal Plan:
Species and quan�ty to be cultured or reared on an annual basis I question what this has to do
with the County if it is a WDFW species approved for cultivation. Why is it the County’s business
if it is Crassostrea sikamea, Crassostrea gigas or Ostrea lurida. Surely WDFW is the agency with
the responsibility and knowledge to decide the appropriateness of the species. Volumes are
somewhat unpredictable and variable.
An�cipated size of species at harvest(3) Once again for shellfish not the county’s business and
specifying a size locks the grower into a static market which does not work in reality.
Source of eggs, juveniles, broodstock, or other aqua�c product. While the grower can give a
general answer farming husbandry is very dynamic and what might apply at the time of getting
is likely to change throughout the years. There a WDFW permits that control the transfer of
shellfish into and around the state and it really isn’t something the county is competent to get
involved in.
Narra�ve of implementa�on methods, including, as applicable, average and maximum stocking
density, plan�ng and harvest schedule/cycles, phasing op�ons, and �me of day, and poten�al
plans for future expansion or change in species grown or harvest prac�ces. As above. What if a
grower wants to grow Kumamoto oysters instead of gigas. The time of day is an issue as
growers need to work at night during the winter.
Schedule of development and maintenance Ok
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Predator control methods include exclusion devices Ok
Anticipated use of any feed, herbicide, chemicals Irrelevant for shellfish aquaculture as we
don't use any.
Anticipated levels of management practices to minimize the impacts from mooring, parking,
noise, light, litter and odor There are industry BMP’s which should cover this.
Methods and loca�on of waste disposal and sanita�on facili�es I assume they are talking about
having Sani cans?
Number of employees/workers necessary, include average and peak Usually quite variable and
often imprecise.
Methods to address pollutant loading Finfish
Schedule for water quality monitoring Finfish
Descrip�on of wastewater management Finfish
Measures to address impact to achieve no net loss of ecological func�ons For the Nationwide
Programmatic permit that was previously issued there was a Biological assessment completed
that covers “no net loss of ecological functions”
d) Visual Analysis: Required for floa�ng/hanging, or upland aquaculture use and development,
or botom culture involving structures or material installa�on These are relatively expensive
usually at least $5,000. I guess my question would be if these are tracts of tidelands designated
for shellfish aquaculture why does a grower have to make sure other citizens are happy with
how it looks? If an upland property owner builds a house should they have to do a visual impact
analysis for an adjacent shellfish grower?
Photo analysis and/or simulation of the proposed activity describing effects on uses and aesthetic
qualities of the shoreline within a quarter mile during a range of tides from mean high to mean
low, including what views in the vicinity would be altered or obstructed, such as public access
views and views from substantial numbers of private residences, and shall identify proposed
measures to reduce impacts. The analysis shall demonstrate that adverse impacts on the character
of those areas are effectively mitigated How? This is very subjective, and not in line with
direction from the SMA.
(e) Other applica�ons and reports, when applicable or requested, to ensure compliance with
permit condi�ons, which may include: (4)
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Proof of an accepted applica�on for aqua�c lands lease from DNR, including a waiver of
preference rights to access for naviga�on from the upland property owner, if applicable or proof
of lease or ownership if bedlands are privately held or private owner