HomeMy WebLinkAbout011024 email Public Comment on JEFFCO SMP RevisionALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them.
Attention Jefferson County Commissioners:
R.e. Comment on SMP
I am following up my brief comments made yesterday during the public hearing reviewing the SMP for Jefferson County - I was honestly flummoxed due mainly that my oral testimony was timed
for three minutes and I was not prepared for the shorter testimony. I appreciate the opportunity to expand my thoughts in writing. My address is 10610 Manitou Park Blvd., Bainbridge
Island, WA, 98110.
I am a marine scientist and have been working in Puget Sound and Hood Canal for the last 40 years as a researcher and sea farmer. My late wife and I established Baywater Shellfish Farm
on Thorndyke Bay in 1990 as a way of providing a source of income for my family. My three children and at least 150+ mainly young people and other workers worked on the farm during
summers between 1990 up to and including last summer. We are as a small business quite simply in a wonderful position to be able to hire and teach young people the value of hard work
and a decent paycheck. In return, we have created over the last thirty-three years a successful sea farm growing oysters, clams and geoducks. My son, Caleb now manages the farm to my
sheer delight. I started a second sea farm (Blue Dot Sea Farm) in 2016 that focuses on growing sugar kelp and oysters. We are the only permitted seaweed farm in the State at present.
Both entities have proven to be examples of sea farms that have created economic value while producing sustainable, healthy seaweed and shellfish - using no fresh water, no chemicals
all the while reducing nutrient loading in Hood Canal.
My association with the County has therefore been significant. To that end, other than operating two businesses and owning property in the County, I also served on the Jefferson County
MRC between 2004 and 2010 and have maintained a life long and strong interest in sustaining and protecting Washington State’s marine resources.
To that end, I strongly urge the County to recognize and support Washington’s commitment to shellfish farming as a preferred use of tidelands and bedlands. This includes prioritizing
permits for shellfish farms and supporting farmers in their efforts to create new or expanded opportunities for shellfish farming - a process that results in cleaner water, living wage
jobs, a healthier marine environment and locally grown foods.
Briefly, I have four main points specific to the proposed SMP revisions:
1. I urge Jefferson County’s SMP to remain aligned with the Conditional Use Permit (CUP) requirements as established by the state for geoduck farming - this would mean a conditional
use permit would only be required for new geoduck farms/permit. Expansions or conversions would not and should not require a conditional use permit especially given the peer reviewed
and published scientific information commissioned by the State and administered by WA Sea Grant, as well as other scientific studies that demonstrate the value geoduck (and other shellfish)
offer with respect to critical ecosystem services including clean water and reduced eutrophication.
2. I urge the County remove the visual analysis requirement as part of the application process unless the farm is proposed for a residential area. Better clarity about what components
should be included in a visual analysis, when it is required, would be very helpful to prospective sea farmers. Examples might include a general visual description of the types of gear,
its use and duration by seasonality, general description of the color and height of gear above the tide flat. I should note here that the PCSGA maintains best management practices for
shellfish that include a visual component - all designed to minimize aesthetic impacts.
3. I urge the County to remove redundancies such as tribal approval, the requirement for water quality studies and specific gear requirements that are already a significant part of the
permitting process. From my read, there appears significant redundancy in the Jefferson County’s SMP that simply adds layers of complexity to an already highly regulated industry. As
an example, many of the concerns around farming near eelgrass and other species, including endangered salmonids, are specifically addressed in NOAA’s programmatic biological assessment.
4. The notion of requiring a CUP for revising or expanding existing geoduck farming is simply a death knell to the sea farmer - and essentially a situation of double jeopardy as that
business likely already navigated the permit process once for the original farm. I note that Mason County does not require a new CUP for farm revisions or expansions. Jefferson County
should follow suit.
A social equity issue is also in play here….I note that it already takes a minimum of at least 3 year and the financial capacity to navigate the multiple federal, state and local agencies/entities
required to get a permit to farm shellfish. There is, in my opinion, a significant social equity component associated with this process. The fact is that one needs to retain attorneys
and spend years attaining the permitting to start a small business is wrong because this limits the expansion of sea farming to a select few companies that can afford the process. Does
the County really intend to promulgate policies that exclude people with limited means that nonetheless have strong backs, and stronger wills to create new economic opportunities for
themselves and their families in often rural parts of the County? I sincerely hope not.
It is a fact that the folks making the most fuss over sea farming are wealthy, retired waterfront homeowners (e.g. the Shine neighborhood). These folks also tend to get many of their
“facts" dead wrong…With respect to a specific comment made yesterday about “micro plastics” and the use of plastic netting to cover PVC tubes for the nursery phase of geoduck culture,
it is necessary to point out that geoduck farmers today have mostly abandoned PVC pipe and net enclosures and moved to a single, reusable mesh polyethylene sleeve that is by design
and manufacture to NOT breakdown in the marine environment. There is NO shedding of plastics associated with this newer gear. This is one of many examples where the homeowner/environmental
advocacy groups get it wrong and I sincerely hope that the County will read and consider the abundant literature regarding the impacts - positive and negative - associated with farming
shellfish in County waters - and make your decisions based on facts and the science - both established and emerging.
To reiterate, the shellfish farms operating in Jefferson County are by in large contributors to the local economy, good neighbors and most importantly among the strongest of advocates
for retaining the County’s rural character, clean water and abundant marine resources. The proposed revised regulations will serve to discourage young people from attempting a sea farming
lifestyle to the detriment of the greater good.
Thank you for your consideration.
Jonathan (Joth) Davis, Ph.D.
10610 NE Manitou Park Blvd.
Bainbridge Island, WA 98110
206-799-7691
Now is our time to open the heart and lean into the unknown...