HomeMy WebLinkAbout030424 email - Clarification on Public Comments Today (3-4-2024)ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them.
Dear Commissioner Eisenhour,
I want to clarify (and should have clarified) that my comments this morning were not specifically about expansions or conversions for the purpose of geoduck cultivation.
I was addressing the general treatment of all shellfish operations under JCC 18.25.440(4):
Current Code
(b) Ongoing maintenance, harvest, replanting, restocking of or changing the species cultivated in any existing or permitted aquaculture operation is not considered new use/development,
and shall not require a new permit, unless or until:
(i) The physical extent of the facility or farm is expanded by more than 25 percent or more than 25 percent of the facility/farm changes operational/cultivation methods compared to the
conditions that existed as of the effective date of this program or any amendment thereto. If the amount of expansion or change in cultivation method exceeds 25 percent in any 10-year
period, the entire operation shall be considered new aquaculture and shall be subject to applicable permit requirements of this section;
I don't think these provisions are defensible under the SMA or SEPA. I think they need to be repealed and replaced. I'm working on alternative language that I hope to get to you in
a couple of days.
Thanks--Marilyn
Marilyn Showalter
1596 Shine Rd
Port Ludlow, WA 98365
(360) 259-1700 (cell)
marilyn.showalter@gmail.com <mailto:marilyn.showalter@gmail.com>