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Home My WebLink About012124 Shoreline Master Program--Please Require a Standard CUP for All Geoduck Applications (0003)ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Hello, My name is Noreen Parks and I live at 52 Becker St., Port Townsend. I am writing to urge the commissioners to adopt a requirement for all geoduck cultivation applications, to qualify for a standard Conditional Use Permit, including expansions of operations as well as new ones. There are many reasons to adopt this policy, including the following: Geoduck cultivation is very intensive. It utilizes more than 11 tons of plastic per acre—plastic that breaks down and pollutes local waters and the greater watershed. With the plethora of information coming to light on the harmful effects of plastic pollution, we need to do all we can to eliminate plastics in the environment. Geoduck farming robs nutrients from local waters that are important for native forage fish, crabs, herring, young salmon, shorebirds and countless other types of marine life that depend on our tidelands and estuaries. As well, geoduck harvesting utilizes high-pressure hydraulic techniques harmful to eelgrass beds that support marine life, resulting in decreased biodiversity. This practice is utterly contrary to the ecological restoration of Puget Sound and other nearby constricted waterways, which state and local agencies have been striving for decades to achieve! Currently, the county has no formal oversight on geoduck operations. Instead, the county relies on overburdened state and federal agencies to nominally manage and control these operations. The local public and its representatives have no realistic idea of how much shoreline is being handed over to commercial operations or the degree of damage taking place on public shorelines and waterways. And yet, we taxpayers bear the burden for the external costs of geoduck farmers' private gain, such as the need to remove plastic debris and the loss of eelgrass beds. Each bay and tideland is different, thus each site needs to be fully evaluated before a permit is granted. Potential impacts on marine life at any particular site must be considered before issuing a permit. Citizens--who may well have specific concerns and information pertaining to a given site--should have the chance to weigh in before any such decision is made. As you are doubtless aware, until last October the JC’s Planning Commission’s SMP draft included a requirement for a standard CUP for all future geoduck applications—similar to state-approved CUP requirements in Kitsap and Clallam county SMPs. Then, in November, the Planning Commission inexplicably changed its original decision, stipulating that standard CUPs be required only for “new” geoduck operations, and allowing “discretionary” CUPs for “expansions” and “conversions” of existing shellfish tidelands. This seemingly small change has potentially huge consequences. As Al Bergstein, Former Chair of the Jefferson County Marine Resources Committee explains, “A discretionary CUP allows county staff to make the decision, after public comment but with no public hearing. Alternatively, staff, in its sole discretion, may (but need not, for any reason) refer the case to the hearing-examiner process. This scheme is arbitrary and discriminatory. It favors existing shellfish farmers over newcomers and over the citizenry, even though the environmental effects are identical. It is subject to evasion, for example, by first farming oysters on a new plot and then converting to geoducks. Also, of great concern: all (or possibly nearly all) existing shellfish farmers in Jefferson County are operating with no county shoreline permit whatsoever, so there is no baseline. The County simply doesn’t know how many acres might be converted or expanded under a discretionary CUP.” Jefferson County lies in close shoreline proximity to Kitsap and Clallam counties, sharing Hood Canal, Discovery Bay, and other waters of the Salish Sea. Notably, all of Hood Canal, including its tidelands and shoreline, and most of Puget Sound and the Strait of Juan de Fuca are designated Shorelines of Statewide Significance, under the state Shoreline Management Act. The logical and efficient permitting process demands that Jefferson County harmonize with Kitsap and Clallam counties in how they review commercial geoduck operations in our common waters. The commission has the serious responsibility of considering the ramifications of any and all policy decisions on our precious shared environment. Public waters are not the sole domain of industries such as geoduck cultivation. I trust you will make the right decision for the health of our ecosystems and the public. Thank you for the opportunity to comment on this important issue. 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