HomeMy WebLinkAbout113023 email Requesting JeffCo Commissioners Decide to require standard Conditional Use Permit (CUP) for ALL geoduck applicationsALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them.
Dear Jefferson County Commissioners,
My wife and I live here in Shine and own the tideland parcel East (adjacent) of the current BDN geoduck farm in Shine. We own upland property directly above our tidelands so we look
out over the BDN geoduck farm. We see and are affected by each step of the geoduck farm operations from clearing and planting to maintenance to the final harvest… repeated on a 4 to
6 year cycle.
We submit to you commissioners that from the standpoint of both the environment and the actual land/sand area the geoducks are planted in, that “expansions” and “conversions” are no
different than a “new” planting and that all 3 should require a standard CUP during the permitting process. Here are some specific points to consider:
1. When “expanding” an area, the new area did not have geoducks prior to the expansion so the planted geoducks are really “new” to that expanded area. The area being “expanded”
into may very well have different environmental issues to consider. This means an “expansion” without a standard CUP would sidestep an important and reasonable initial process for considerating
adverse effects of geoduck farming. An “expansion” could be acres and acres with significant environmental impact with no initial chance for the comprehensive process of a standard
CUP.
2. “Conversions” from the viewpoint of the environment and the land being planted are really identical to both “expanding” and “new” uses.
3. If we only require a standard CUP for “new,” then it would be quite simple for a farmer to bypass a geoduck standard CUP by first growing oysters and later “converting” to geoducks.
Could be intentional or inadvertent but either way it would be tidelands “new” to aquaculture, eventually planted with geoducks and easily accomplished without a CUP.
4. To me, these distinctions between “new”, “expansions” and “conversions” only make sense from the viewpoint of the farmer wanting to avoid a reasonable process to evaluate planting
geoducks on a patch of tidelands that didn’t previously have geoducks. An oyster farmer with no experience with geoducks could “convert” to geoducks and easily sidestep the appropriate
CUP oversight.
5. As stewards of the land and environment for current and future generations, we request that you require a standard CUP for all 3 of these distinctions, as the land use and environmental
impact are really the same.
In the whole geoduck life-cycle there are 3 aspects that stand out to me that should be subject to further study and certainly more oversight:
* 43,000 4” PVC tubes per acre planted in abrasive sand for 2 years. Some of this PVC is abraded into microplastics which enters and travels up the food chain, eventually traveling to
us who live around here as we consume the crab & seafood here in our bay. Microplastics are not healthy for any animal in the food chain! These PVC tubes are lost in large numbers
into the environment. When washed onto the beach they are eventually picked up by neighbors or the farm caretaker. When washed out into deep water they are out of sight and out of mind.
I personally snorkeled out in deeper water beyond the BDN farm and counted at 100 to 200 loose tubes out beyond the farm. My count was cut short because I could only see to a depth
of 15’ or so. If tubes were pulled out that far it's reasonable to conclude there may be 100’s or 1000’s more out deeper… further polluting as the plastic degrades and disintegrates
further into more microplastics in our environment and our food chain only to be concentrated again as it works its way up the food chain to us local humans that eat our local seafood.
* Unnatural density of one species (planted geoducks) are consuming nutrients & plankton that would otherwise be available to support the other surrounding life in our bay, and some
of that plankton consumed by the geoducks would otherwise have grown up to be crab, oysters, clams, etc., naturally balancing out the animal life here. This unnatural density diminishes
the other native life by both diminishing the food supply for the other life and by consuming the early-stage critters (like crab) that are early in their lifecycle (plankton). I believe
this unnatural consumption of “nutrients” by planted geoducks needs to be studied to determine the effects of geoduck farming on the surrounding ecosystem.
* Liquification of the top 3 feet of sand in the harvesting operation likely destroys the ecosystem in the sand and certainly flushes any pollutants trapped in the sand out into the
surrounding environment.
A standard CUP for any additional tideland used for geoduck would hopefully force the consideration of these and other environmental issues specific to the immediate area prior to the
issuing of any geoduck farming permits.
Please eliminate these 3 distinctions and require a standard CUP for ALL future geoduck permit applications.
Steve & Kathy Dittmar
30 Watney Lane
Port Ludlow, WA 98365
206.619.6822