HomeMy WebLinkAbout010224 email Background information re_ aquaculture permittingDear Commissioners,
My name is Kim Thompson, I am the Executive Director of the Pacific Coast Shellfish Growers Association. I attended your commissioners meeting on December 11 during your initial consideration
of the planning commission's Shoreline Master Program (SMP) for Jefferson County.
During your discussion, there were a few inquiries regarding the current permitting process used for shellfish farms in Washington as well as what agencies and what types of standards
are part of the permit process.
As you prepare for the public hearing on Jan. 8, I wanted to provide background material and information that will shed light on this process. First, please know that all shellfish farms
cultivated on intertidal lands in Puget Sound are required to secure at least one federal permit from the Army Corps of Engineers, at least one state permit from Department of Ecology,
and notification to tribes in the county (in Jefferson County this includes 5 tribes). There are many other permits required if the farmer plans to harvest or sell the shellfish (which
most do).
As part of the Army Corps permit, there are 33 conservation measures and conditions that every farm must meet (see attached). These measures stem from a programmatic biological assessment
done by the services that was conducted in 2016 (see document here: PBO <https://www.nws.usace.army.mil/Portals/27/docs/regulatory/160907/NMFS_2016_09-02_WA%20Shellfish%20Aquaculture_WCR-2014-1502.p
df> ). This was a thorough and very extensive process that looked at current activities and also potential future farming activities. It is worth noting that they address a variety
of issues including the following:
* Site and action specific measures to protect eelgrass (3, 6, 26, 32)
* Requirements for use and storage of gear at different phases of production to reduce the risk of unintended impacts (e.g. escapes or navigational hazards) (11, 13, 14, 15, 18, 19)
* Measures to prevent adverse impact on critical spawning grounds and salmon habitat (e.g. restrictions on activity in specific areas during critical spawning times)
The Corps can add site-specific requirements to each permit, which they often do.
In addition, State permits may also have specific permit requirements including a water quality monitoring plan (standard when getting a 401 permit from Ecology) as well as a stewardship
plan which is required when leasing tidelands from DNR.
Finally, it is worth noting that during the county’s CUP permit process, parcel-specific conditions may be applied to a permit by permitting staff or the hearing examiner. This is regardless
of the size of the project or the location.
In addition to these requirements, PCSGA members agree to follow our Environmental Codes of Practice (ECOP), which are an added layer of voluntary practices to maximize the many benefits
shellfish farming can provide to ecosystems and communities (e.g. improved water quality and habitat) and reduce the risks. We do acknowledge there are farmers in your county who are
not our members and therefore do not have access to our ECOP.
I hope this information about the permitting process is helpful and shows the onerous permitting process that shellfish farmers have without considering the county process. If you have
any questions or would like additional information please don't hesitate to reach out. I can connect you with farmers who can share documents and their experience or connect you with
permitting staff if that is of interest.
Best,
Kim
Kim Thompson
Executive Director
Pacific Coast Shellfish Growers Association (PCSGA)
626-327-7723
PCSGA.ORG <https://pcsga.org/>