HomeMy WebLinkAbout010424 Standard Conditional Use Permits for All Geoduck CultivationALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them.
Below and attached are the Sierra Club’s comments urging the Board of Commissioners to require a standard conditional use permit for all geoduck cultivation applications. Please enter
this into your official record for the Monday, January 8th public hearing. Thank you.
January 3, 2024
Board of County Commissioners, Jefferson County
Port Townsend, WA 98368
jeffbocc@co.jefferson.wa.us <mailto:jeffbocc@co.jefferson.wa.us>
Dear Board of County Commissioners:
Re: Urging a Standard Conditional Use Permit for All Geoduck Cultivation Applications
On behalf of the 1,200 members of the North Olympic Group of the Sierra Club, we urge you, in your update of the Jefferson County Shoreline Master Program (SMP), to require a standard
Conditional Use Permit (CUP) for all proposals to cultivate geoducks.
Our tidelands and estuaries are the nucleus of our marine ecosystem. They are where eelgrass, spawning fish, young salmon, marine birds, native shellfish and crustaceans, and an entire
food chain intersect. They are also sought-after sites for commercial shellfish operations.
Modern geoduck cultivation involves extremely intense use of plastic (one PVC tube per square foot, plus netting) inserted into the tidelands—some seven miles and eleven tons of tubing
per acre. Each tube fosters, for about two years, the growth of three or four geoducks—a wholly unnatural density of very large clams that feed on marine organisms circulating in public
waters. Then, after five to seven years, harvesters use a hydraulic hose to liquify the substrate down to three feet deep, in order to extract the giant clam. This liquification,
which destroys marine life in the tideland, is conducted over and over, every square foot, until every geoduck is harvested. Then the whole process starts over again.
Geoduck cultivation raises many environmental concerns, among them: competition for nourishment, displacement of tideland marine life, and plastics pollution. For each proposed site,
before any permit might be issued, these concerns and others deserve a thorough review, including the cumulative effects of the proposal. The appropriate process is the one required
for a standard Conditional Use Permit (CUP) that includes:
* A decision by a neutral hearing examiner trained in the orderly conduct of these reviews;
* A decision based only on the record, which is transparent to all concerned; and
* A decision made only after a public hearing, which ensures that the decision-maker has heard the concerns of citizens, who often have detailed knowledge of the environmental features
and history of a proposed site.
The failure to employ these important features when reviewing such a significant environmental change is likely to result in confusion and mistrust. There is also no good policy or environmental
reason to distinguish (as recommended by the Jefferson County Planning Commission) between geoduck cultivation in “new” tideland vs. “expanded” or “converted” sites. Geoducks, plastic
tubes, and hydraulic harvesting are “new” in all cases.
Under the Shoreline Management Act, Hood Canal, including its tidelands and shoreline, and most of Puget Sound and the Strait of Juan de Fuca are Shorelines of Statewide Significance.
Jefferson County’s shorelines share common waters with shorelines of Kitsap and Clallam counties, both of which have adopted standard CUP requirements for geoduck proposals. We urge
Jefferson County to join its neighbors by responsibly requiring a standard CUP for all proposals for geoduck cultivation.
Sincerely,
Peter Guerrero, North Olympic Group, Sierra Club