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Michelle MccinCnell Ai-t mcU
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Subject:
seablues Puddicombe [seablues@msn.com]
Saturday, January 03, 2009 1 :22 PM
sepacenter@dnr.wa.gov
jaym461@ecy.wa.gov; jdoh461@ecy.wa,gov; tcli461@ecy.wa.gov; plun461@ecy.wagov;
richard. doenges@dnr.wa.gov; jeffrey. schreck@dnr.wa.gov; kruppd@co.thurston,wa.us;
wilsonc@co.thurstonwa.us; Michelle McConnell; albergstein@gmaiLcom;
rockefeller. phil@leg.wa.gov; fraser. karen@leg.wa.gov; kilmer. derek@leg.wa.gov;
seaquist.larry@leg.wa.gov; ckleebe@co.pierce.wa.us; klarrab@co,pierce.wa.us;
drisvol@co.pierce.wa.us; tkantz@co.pierce.wa.us; vdiamon@co.pierce.waus;
merkkin@co.pierce.wa.us; tlee1@co.pierce.wa.us; dmuri@co.pierce.wa.us;
mkruger@co.pierce.wa.us; htaylor@co.pierce.waus; davearm@u.washington,edu; Glenn
Vanblaricom; pdalton@u.washington,edu
WDNRISEPA, Taylor Shellfish Totten Geoduck/Oyster Lease
From:
Sent:
To:
Cc:
To: WDNR SEPA Center, sepacenter@dnr.wa.gov
Letter to follow via certified mail.
Cc: Jaym461@ecy.wa.gov; JDOH461@ecy.wa.gov; Tcli461@ecy.wa.gov; plun461@ecy.wa.gov;
RICHARD.DOENGES@dnr.wa.gov; JEFFREY.SCHRECK@dnr.wa.gov; kruppd@co.thurston.wa.us;
WilsonC@co.thurston.wa.us; mmcconnell@co.iefferson.wa.us; albergstein@gmail.com;
rockefeller. phil@leg.wa.gov; fraser .karen@leg.wa.gov; kilmer .derek@leg.wa.gov; seaquist.1arry@leg. wa. gOY;
ckleebe@co.pierce.wa.us; klarrab@co.pierce.wa.us; drisvol@co.pierce.wa.us; tkantz@co.pierce.wa.us;
vdiamon@co.pierce.wa.us; merkkin@co.pierce.wa.us; tleel@co.pierce.wa.us; dmuri@co.pierce.wa.us;
mkruger@co.pierce.wa.us; htavlor@co.pierce.wa.us; davearm@u.washington.edu; glennvb@u.washington.edu;
pdalton@u.washington.edu;
From: Curt Puddicombe, CISA/CPPSH
Re: Totten/Taylor Shellfish lease, # 08-122201:
http://www.dnr.wa.gov/ResearchScience/Topics/SEP AAquaticResources/Pages/amp sepa aqr totteninlet feb.
aspx
Environ Technical Memorandum, Additional Comments
---- "There is, however, no science to support the case that (geoduckfarming) is not harmful, and there's
excellent reason to suppose that it is. "
----Ted Williams, Audubon, August 2008----
Main Points:
*Key findings are not complete and do not consider all known science.
*Conclusions do not consider all impacts and mitigation does not fully address impacts discussed in
MDNS.
*Conditions of approval are not shown to prevent probable adverse impacts.
--DNR has previously indicated that the initial trespass by Taylor Shellfish on Totten Inlet public tidelands was
16 acres according to DNR surveys, yet the lease area is now indicated as 21 acres. DNR should specify the
reason for this disparity.--
In the MDNS summary of findings, DNR states: "This lease will provide opportunity and significant funding to
study the effects of protective structures and geoduck harvest techniques on a South Puget Sound ecosystem in
various stages of geoduck culture and harvest." This area has been subjected to intense levels of shellfish
1
aquaculture for decades, including the cultivation and spread of invasive species, thus the natural 'ecosystem'
has been significantly altered, thereby limiting its value for future study.
In the MONS Key Findings, WDFW stated it is unlikely that the area contained significant geoducks, clams or
oysters. However, it is possible the area may have contained significant amounts of SA V (Submerged Aquatic
Vegetation) including eelgrass, which are critical in the efforts to maintain and restore salmon and forage fish.
The area may have also historically contained sand dollars. The area should be considered for natural fish
habitat restoration since fully 91 percent of Totten Inlet has already been modified for shellfish aquaculture,
most ofthat in the last 10 years or so.
ONR is not using unbiased and independent science to justify this lease, but is exclusively utilizing literature
from Environ that is sponsored by Taylor Shellfish. Environs' Technical Memorandum, 'An Analysis of the
Environmental Concerns Associated with Intertidal Geoduck Clam Aquaculture' is largely anecdotal and much
less scientific, and does not appear to represent a balanced approach to the issue. Again, this literature is funded
by Taylor Shellfish, is fully biased, and is not scientific and should not be used exclusively by DNR to justify
this, or any other lease.
Science by definition is not settled - there is no consensus. True scientists are skeptics. Their approach is to
present a hypothesis and then rigorously defend that hypothesis to see if it holds up to scrutiny. They invite
peer review and criticism. Scientists know there is a lot more we need to know about Puget Sound - we've
barely scratched the surface - yet the scientific community is grossly under utilized in efforts to preserve and
restore Puget Sound. Only 1.6 percent of the $570 million budgeted biannually for protecting the sound is
allocated toward scientific research!
What DNR and Environ are advocating here is really an 'Appeal to Ignorance': an argument for or against a
proposition on the basis of a lack of evidence against it or for it. A lack of evidence by itself in not evidence.
The burden of proof is on the individuals or groups making the new or improbable claims; in this case the
shellfish industry.
As we have seen, efforts to manage, preserve and restore complex eco-systems like Puget Sound have
historically failed despite generous public funding. One reason is that the applied science is out of date.
Another is that our environmental decision making tends to rely on intellectual beliefs and conventional wisdom
that lacks scientific foundation or historical knowledge. Our restoration efforts fail because they are largely
derived from the same worldview and assumptions that created the problem in the first place. This dominant
worldview defines ecosystems as warehouses for the storage and production of commodities, insists that
humans stand apart from those ecosystems, and demands that they control, manipulate and "improve" them.
It is interesting to note that despite shellfish industry claims of environmental benefits, 25 years of efforts and
hundreds of millions of dollars spent to restore Chesapeake Bay have resulted in very little progress. This year,
the bay suffered the fourth worst dead zone since 1985. The Bay's crab population is near historic lows. The
goal of removing the Bay from the federal 'dirty waters' list by 2010 will not be achieved.
In the MDNS, DNR quotes Environ: "In Puget Sound and elsewhere, the addition of structured habitat,
artificial or otherwise, to homogenous marine habitats like sand and mud has been recognized to increase the
types and numbers of colonizing fish, invertebrates, and aquatic plants in a given area (refer to An Analysis of
the Environmental Concerns Associated with Intertidal Geoduck Clam Aquaculture, 2008, by Environ).
This broad, general statement does not include the specific study of geoduck tubes and nets, yet it is attempting
to address this issue without pertinent facts. It does not account for the incessant disturbance represented by the
placement and removal of tubes and nets ad infinitum. It is not legitimately comparable to a 'static' reef
structure as it claims. Shall this statement also be used to justify the discarding of old tires, appliances, cars,
2
etc. in the tidelands because these 'structures' provide additional habitat? Why bother with beach clean-ups if
garbage or debris provides additional structure, or 'improved' habitat? Perhaps we should anchor it down rather
than remove it!
Environ makes the assumption that 'structured' habitat is inherently more valuable than unstructured habitat,
and therefore it is acceptable to 'bioengineer' the intertidal to 'improve' it. And yet, studies indicate that
'unstructured' intertidal estuarine habitats are critical for larger migratory mobile species (Crab, Salmon,
Flounder/Sole, Dogfish, etc.). (See 'Structural Complexity of Biogenic Habitats', K. Holsman, and 'The
Necessity for Intertidal Foraging by Estuarine Populations of Subadult Dungeness Crab', Holsman, Armstrong,
Beauchamp, Ruesink).
Environ also assumes that benthic community alterations and predator/prey dynamics via organic enrichment on
anti predator netting is a positive development, yet some benthos that are of known importance and value to
feeding juvenile Chinook and flounder or sole are developmentally suppressed by anti predator netting, ie, tube
building gammarid amphipods such as Amphithoe, Corophium, and other burrowing amphipods and
polychaetes. It should not simply be assumed that dominant benthic species shifts to the more mobile taxa are
positive events for all invertebrates in the intertidal, and consideration should be given to migratory species, as
this is not the case here. Salmon are among the oldest natives of the Pacific Northwest, and over millions of
years they have adapted and evolved to use the regions estuarine and marine habitats in specific ways. It' s
exceedingly arrogant and reflective of the dominant worldview that supposes, without reasonably certain
evidence, that habitat alterations and their subsequent mitigations or anthropogenic solutions are inherently
good or better than natural processes for all species. These same kinds of assumptions have resulted in the rapid
decline in salmon that we see today. (See 'Salmon without Rivers', J. Lichatowich)
Flounder and sole in Puget Sound also rely on intertidal unstructured habitat to hide from predation by partially
burrowing in the substrate. One study states: "Restructuring coastal fish nursery habitats by extensive shellfish
farming in the French part of the Bay of Biscay could influence fish physiology and behavior and affect the
ecological performance of the species." (See 'Testing the Potential Effects of Shellfish Farming on Swimming
Activity and Spatial Distribution of Sole', Laffargue, Be'gout, Lagarde're.) Environ seems to have drawn their
own hypothesis despite the lack of published data.
The most recent preliminary study presented to the PCSGAlNSA in Lake Chelan this last October, 2008, by P.
Sean McDonald tells us that, obviously, the addition of structures and a high density of filter feeding clams
represents a 'modification of the ecosystem'. The removal ofthe tubes and nets, again, changes the ecosystem.
Harvest represents another modification to the ecosystem affecting "nutrient release, sediment characteristics
and the infaunal community". The study detected a significant effect of habitat structure in the diets of staghorn
sculpin. The study, however, indicates significantly fewer numbers of sculpin in the structured area versus the
natural, unstructured habitat. Sculpin are not migratory, and generally seek out structure. They are also highly
predatory. Although shellfish industry proponents wishfully interpreted this study as a positive, the reality is
that it is entirely unknown how these changes and alterations will affect the ecosystem along its entire spectrum
of complexity.
Another false and misleading assertion advanced by Environ concerns SA V, or Submerged Aquatic Vegetation,
mainly eelgrass which is now recognized scientifically as critical habitat for both salmon and forage fish.
WDFW already recognizes the fact that subtidal geoduck harvest techniques are harmful to SA V through its
own scientific research. The shellfish industry is already well known to have removed SA V and sand dollars
(dendraster excentricus) to make way for geoduck plantings in the past. Sand dollars, a type of urchin, are also
a valuable species that contribute important habitat functions. Fly fishermen know very well that sand dollar
beds indicate a healthy beach for Sea Run Cutthroat. Sand dollars consume detritus, which is important in
maintaining healthy levels of dissolved oxygen, and they provide nourishment for shorebirds, Starry flounder
and crabs.
3
Both stake and rack methods of oyster culture result in significant decreases in the abundance of SA V. (See
'Effect of Oyster Mariculture on SA V', Everett, Ruiz, Carlton.) Eelgrass density is depressed by space
competition with farmed geoducks, and intertidal harvest reduces eelgrass density by more than 70 percent.
(See 'Geoduck Clam Aquaculture as Press and Pulse Perturbations to Eelgrass', Ruesink, Rowell.) An
evaluation by Entrix in 2004, also funded by Taylor Shellfish, Seattle Shellfish and Chelsea Shellfish, indicates
quite plainly that any SA V or eelgrass that develops within the confines of an intertidal geoduck site will be
destroyed at harvest. DNR BMP also makes this determination. Geoduck aquaculture therefore cannot
possibly provide a net positive affect for SA V and eelgrass, and by logical inference, for salmon and forage
fish, since geoduck sites preclude and exclude the existence and development of eelgrass. The affect is actually
a net negative. Some scientists suggest that the loss of eelgrass is costing Washington State residents millions
of dollars in lost revenues for the decreased availability of herring, crab and salmon. (See: Friends ofthe San
Juans).
Environ again draws on outdated (almost 30 years old) research in discussing forage fish. In referencing
Carlson (1980), Environ states that schooling forage fish like herring, sand lance and surf smelt use intertidal
habitat only for spawning purposes, otherwise the fish forage in deeper nearshore and offshore waters. This
statement is absolutely false and misleading. According to the Department of Ecology, sand lance and surf
smelt linger, rear and feed in shallow nearshore waters. According to Entrix, any herring spawn found on
geoduck aquaculture gear is extremely rare. Environ conveniently ignores the much more recent scientific
research by forage fish expert Dan Penttila, author of technical report "Marine Forage Fishes in Puget Sound",
2007. Penttila states: "These agencies (W A Dept. of Agriculture, WDNR), together with WDFW should seek a
coordinated approach to the management ofthe growing aquaculture industry, with an eye toward modification
of habitat damaging culture practices and the mitigation of existing habitat degradation for which the industry
has been responsible." "The bulk ofthe Puget Sound Basin's shoreline is now in private ownership. The
likelihood of continued financial and political pressure for shoreline modification by a landownership
population largely ignorant of nearshore resource values and conservation risks is high."
Environ goes on to mention "extensive work conducted in Canada" in reference to the Chris Pearce study,
which is hardly 'extensive' in reality, yet Environ mentions it 15 times in its technical memorandum analysis,
and 5 times in its supplemental analysis. Pearce's study was funded, as least in part, by Manatee Holdings, a
private shellfish company. The research plot was 20 meters by 3 meters in Nanoose Bay, much too small to be
of any scientific value and not particularly relevant to Puget Sound. The study was designed to determine
geoduck growth rates by varying sizes of PVC pipe. Core samples and data collection were done as a side
study. Tests were conducted after less than one year of grow out, which is, again not consistent with conditions
in Puget Sound. Pearce, however, does report impacts to benthic habitat, but describes these impacts as minor.
Here is what Dr. Pearce had to say during his presentation to the B.C. legislature describing the harvest: "He's
using the high powered water jet or stinger to liquefy the sediment and pull up the clams. It's a fairly disruptive
process. You're liquefying the sediment down to a depth of a meter or more." "... the harvest holes themselves
- where they've actually stung out the clams - he (Goodwin) found that the harvesting significantly decreased
the percentage of fine and course grained sediment." "I think we want to be careful and monitor the potential
impact of commercial scale aquaculture development. What we've done in the past - what these studies that I
have reviewed for you have done - is conducting research on typically smaller scale plots, not really
commercial sized. So we want to be careful and monitor potential impact of larger harvesting practices."
Without any substantive grounds, Environ opines that salmon is not likely to be affected by geoduck
aquaculture. Again, it can be scientifically shown that adult migrating salmon prefer unstructured habitat.
Adult Chinook diets in Puget Sound contain 60 percent Sand Lance. Geoduck aquaculture 'structure' logically
may actually, and mostly likely will, alter or upset predator/prey interactions between migrating adult Chinook
and Sand Lance. An 'anti predator' net is designed to exclude predator species from their natural habitat. The
structures provide unnatural refugia for prey species, thus altering complex interactions between species. At
4
this point, it is important to note that geoduck are mainly a subtidal animal, and are not natural or intrinsic to the
intertidal and would not survive there without PVC tubes.
Juvenile salmonids are skittish, and generally avoid structures of significance. Juvenile salmon will change
migration patterns when confronted with conflicts in preferences. Juvenile salmon usually migrate in shallow
water at depths of a few feet. A tube field of 4 inches in height would represent as much as 20 percent of that
depth. Studies show that juvenile Chinook do not respond to structures, except SA V and eelgrass. Juvenile
Chinook smolts would not respond to oyster clusters that are less than 4 inches in height in a recent study in
Willapa Bay. (See Semmons, B.x. 2006, PhD Dept. of Biology, UW) Why, then, would they respond to
geoduck tubes and nets? Millions of years of adaptation and evolution have imprinted Puget Sound salmon
with the preference for SA V and eelgrass exclusively, not structures. There is absolutely no scientific research
to substantiate Environs' claims. They are engaging in sheer speculation. I would prefer that we did not
'speculate' with endangered Puget Sound salmon populations at this point. Even Entrix' 2004 evaluation, also
authored in part by Environs' Jeff Fisher, states unequivocally that juvenile salmonids have the greatest
potential to be impacted by geoduck aquaculture.
Environ also attempts to draw correlation and causation between shellfish aquaculture and salmon runs in
Willapa Bay and endangered Puget Sound runs. Given the stark difference in human populations and historic
scales of anthropogenic impacts to spawning habitat, it's obvious why some Puget Sound runs would be
endangered as opposed to runs in Willapa Bay, and it has nothing to do with shellfish. The absolute facts are
that Willapa Bay runs have been negatively impacted by shellfish aquaculture, especially with respect to the use
of carbaryl and off bottom oyster culture as well. Migratory birds have also been impacted in Willapa Bay, and
also in Puget Sound. The shellfish industry has inundated both water bodies with harmful invasive species.
In addition, Environ suggests there is no evidence that existing shellfish aquaculture conditions in the Pacific
Northwest are compromising ecosystem function by exceeding carrying capacity. However, a recent study
indicates that Willapa Bay may be at carrying capacity now due to declining phytoplankton abundance
consistent with shellfish aquaculture. (See Tidal Exchange, Bivalve Grazing and Patterns of Primary
Production in Willapa Bay, Banas, Hickey, Newton, Ruesink, 2007).
Environ also suggests that "the 'environmental concern' raised by opponents to geoduck farming appears to be
based on factors independent of the potential for ecological impact, and stems from visual interpretations by
laypersons lacking the scientific background to objectively consider the ecological context of geoduck
aquaculture as it is practiced in Puget Sound". In other words, Environ joins with the shellfish industry in their
belief that shoreline citizens are only concerned with the appearance of geoduck aquaculture sites. The visual
impacts are pronounced, but I do not believe they are independent of citizens concerns over ecological impacts.
But, in terms of the visual impacts alone, it is important to observe that the Shoreline Management Act of 1971
states as its goals to "preserve the natural character of the shoreline", and "... the public's opportunity to enjoy
the physical and aesthetic qualities of natural shorelines of the state shall be preserved to the greatest extent
feasible... "
I also have some concerns on Environs' use of the penetrometer to evaluate sediment firmness (Environ
Supplemental Analysis). This is of some concern, because during geoduck harvest the sediment is liquefied
down to about one meter, yet the penetrometer is only useful in determining sediment firmness on the surface.
Dr. Murray Gingras, the designer of the penetrometer, confirmed this and said that if you wanted to determine
the firmness deeper than the surface you would need to take a core sample (at least 10cm in width), split it in
half, and then drop the ball on the area you wanted to test. His paper also stated that there was a measurement
error of +/- .25mm, whereas Environ measured down to +/- .05mm, putting into question whether the test was
administered correctly in the first place.
5
While native shellfish, in and of themselves can be of benefit to the ecosystem, the same can not be said ofthe
'culture' of shellfish. Depletion of native species, the introduction of harmful invasives, the use of carbaryl to
kill burrowing shrimp, unnatural modifications of habitat, impacts to endangered salmon and other fish,
predator exclusion controls and the killing of birds. These are all historical realities. Taylor Shellfish and DNR
are relying on biased, vague, generalized, not Puget Sound specific, self serving pathological junk science and
disingenuous evasion, along with decades of institutional memory that at its heart tends to distort, quash and
obfuscate truth, and continues to intentionally promote the fallacy that shellfish aquaculture is 'good' for the
environment and for Puget Sound. In truth, very few of these studies advanced by Environ are specific to Puget
Sound and none fully examine the complex relationships and interactions between species.
I have additional concerns on the Taylor Shellfish ECOP strategies for controlling "pests and predators".
According to the Taylor's ECOP, these include shore, rock and Dungeness crab, finfish such as flounder and
perch, and birds such as ducks and gulls. We're already aware of endangered Bald eagles becoming entangled
in geoduck aquaculture gear. Exclusion using nets and fencing is the preferred method, but hazing and hunting
is also acceptable according to the ECOP. I also object to the use of carbaryl or sevin to control shrimp and
other organisms. Taylor should include the effects of carbaryl in their ECOP.
I also have concerns regarding unfair influence and corruption within state agencies and environmental groups
with respect to members of the shellfish industry. Several members of the shellfish industry are deeply
entrenched in many facets of local and state government. An earlier problem occurred when DNR did not
utilize scientific research in their examination of the forage fish concerns; they only examined the WSFW
website. Some examples of culling influence include Taylor Shellfish providing free oysters at a meeting ofthe
Puget Sound Keepers fundraiser, and the PCSGA providing a free shellfish lunch at the South Sound Science
Symposium. If we are going to save the salmon, the Orca, etc., and Puget Sound habitat overall, we must look
much more to unbiased and independent scientific research in the future.
A Few Quotations:
"Shellfish aquaculture in South Sound alters plant and animal assemblages and results in the loss of shallow
nearshore habitat and habitat diversity important to salmon resources". "We hypothesize that shellfish
aquaculture reduces productivity, abundance, spatial structure, and diversity of salmon populations".
--South Sound Salmon Recovery Group, 2004--
"The artificial propagation of native and non-native fish and shellfish species in or adjacent to salmon EFH has
the potential to adversely affect that habitat by altering water quality, modifying physical habitat, and creating
impediments to passage." "Various methods of shellfish culture and harvest also have the potential to adversely
impact salmon EFH, such as dredging in eelgrass beds, off-bottom culture, raft and line culture, and the use of
chemicals to control burrowing organisms detrimental to oyster culture".
--Pacific States Marine Fisheries Commission--
"Cultivating shellfish in the South Sound results in the loss of shallow nearshore habitat and habitat diversity
that is important to salmon".
--South Sound Watershed Profile, 2007--
"It is an impossibly high standard to expect that bivalve aquaculture will not have any discernable effects on the
ecosystem." "Effects on the ecosystem is a subjective assessment, and what level of change is permissible
needs to be defined by discussion and concensus among all stakeholders."
--Dr. Roger Newell, Horn Point Labs, 2007--
"Nearly every just cause is a struggle between the good of the many and the greed of a few."
6
--Carl Safina, VP for Marine Conservation at the National Audubon Society and Founder of Audubon's "Living
Oceans" program.--
"If we are to have any hope of restoring the salmon to sustainable levels of abundance, we will have to begin by
paying more attention to the salmon's world - not as it exists today, but as it existed before we simplified,
controlled, and "improved" it. And in our restoration efforts, we must address entire watersheds - the whole
chain of salmon habitat, from headwaters to estuaries - and then beyond, to the ocean."
--Jim Lichatowich, Salmon without Rivers, 1999--
"Large scale bivalve farms filter phytoplankton and zooplankton out of the sea, substantially altering local food
webs."
--Davenport et aI, Aquaculture, the ecological issues--
Finally, I do not stand alone. I speak for more than one hundred dues paying members of the Case Inlet
Shoreline Association, and the more than one thousand citizens on our mailing list. I also speak for six
generations of my family that have lived on and near the beautiful shores of Puget Sound for 140 years.
Thank you.
Curt Puddicombe
Board Member
Case Inlet Shoreline Association
Member: Coalition to Preserve Puget Sound Habitat
Vaughn, W A
www.caseinlet.org
info@caseinlet.org
7
Totten Inlet Intertidal Shellfish Culture
Page 1 of3
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TOTTEN INLET INTERTIDAL SHELLFISH CULTURE
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CONTACTS
Aquatic Resources
Current SEPA Actions For:
For Information About
SEPA:
SEPA Center
360-902-2117
sepacenter@dnr.wa.gov
Totten Inlet Proposal - Comment Period Extended through January 8,2009
The above Aquatic Resources proposal is linked to several SEPA documents about the
proposal for your review:
. Comment Period Extension (26KB PDF)
. Cover Memo (Comment Period) (19KB PDF)
. Threshold Determination (158KB PDF)
. Environmental Checklist (1389KB PDF)
. Associated Map (725KB JPG)
FILES
RELATED LINKS
Other Associated Documents
. Technical Memorandum (285KB PDF)
. Supplemental Technical Memorandum (1195KB PDF)
. Environmental Code of Practice (1398KB PDF)
. DNR, Best Management Practices (46KB PDF)
. Washington Sea Grant Literature Review (456KB PDF)
. Department of Fish & Wildlife Survey Letter (36KB PDF)
Public Comments
. Wallace Comment (38KB PDF)
. Thurston County Comment (15KB PDF)
. Hendricks Comment (7763KB PDF)
. Marcus Comment (13KB PDF)
. Puddicombe Comment (16KB PDF)
. Lanier Comment (12KB PDF)
. Cogley Comment (15KB PDF)
. Paradise Comment (14KB PDF)
. Hopper Comment (13KB PDF)
. Gibbons Comment (14KB PDF)
. Brodie Comment (13KB PDF)
. Kennedy Comment (13KB PDF)
. Poole Comment (14KB PDF)
. Hickey Comment (14KB PDF)
. Mazanti Comment (14KB PDF)
http://www.dnr.wa.gov/ResearchScience/Topics/SEPAAquaticResources/Pages/amp_sepa_...l /6/2009
Totten Inlet Intertidal Shellfish Culture Page 2 of 3
. Sheldon Comment (18KB PDF)
. Zimmerman Comment (14KB PDF)
. Wooster Comment (33KB PDF)
. Mitchell Comment (14KB PDF)
. Carlson Comment (12KB PDF)
. Wenzel Comment (13KB PDF)
. Harris Comment (14KB PDF)
. T Carlson Comment (13KB PDF)
. Smith Comment (14KB PDF)
. Otness Comment (13KB PDF)
. Swecker Comment (13KB PDF)
. Matayoshi Comment (26KB PDF)
. Woodington Comment (40KB PDF)
. Rydell Comment (34KB PDF)
. Robbins Comment (13KB PDF)
. Moir Comment (14KB PDF)
. Gillies Comment (14KB PDF)
. Bright Comment (13KB PDF)
. Olson Comment (13KB PDF)
. Downey Comment (255KB PDF)
. R Wilson Comment (62KB PDF)
. Maggie Comment (13KB PDF)
. Wysocki Comment (13KB PDF)
. Puddicombe Comment 2 (39KB PDF)
. Jacobs Comment (13KB PDF)
. DeTray Comment (12KB PDF)
. Southall Comment (13KB PDF)
. Oberbillig Comment (13KB PDF)
. Kingman Comment (14KB PDF)
. Willits Comment (14KB PDF)
. Smutka Comment (13KB PDF)
. Dumbleton Comment (25KB PDF)
. B Bishop Comment (15KB PDF)
. Barth Comment (17KB PDF)
. Gaffney Comment (13KB PDF)
. Pinneo Comment (14KB PDF)
. White Comment (14KB PDF)
. Kettering Comment (30KB PDF)
. Cruver Comment (13KB PDF)
. Engel Comment (14KB PDF)
. Marra Comment (14KB PDF)
http://www.dor.wa.gov/ResearchScience/Topics/SEPAAquaticResources/Pages/amp_sepa_...1 /612009
Totten Inlet Intertidal Shellfish Culture
Page 3 of3
. Libstaff Comment (13KB PDF)
. H Marra Comment (13KB PDF)
. J Lentz Comment (52KB PDF)
. Schuyten Comment (8KB PDF)
. Tei Comment 1 (8KB PDF)
. McCann Comment (8KB PDF)
. Fenton Comment (8KB PDF)
. Engvall Comment (8KB PDF)
. Tei Comment 2 (8KB PDF)
. Berry Comment (9KB PDF)
. Luedtke Comment (15KB PDF)
. Kuno Comment (8KB PDF)
. Verrill Comment (8KB PDF)
. S Wilson Comment (11 KB PDF)
. L Bishop Comment (8KB PDF)
. Wiegardt Comment (16KB PDF)
. L Lentz Comment (63KB PDF)
. Buhl Comment (85KB PDF)
. Sloan Comment (8KB PDF)
. Lloyd Comment (44KB PDF)
. Camm Comment (8KB PDF)
. Vodopich Comment (8KB PDF)
. Clapp Comment (9KB PDF)
. Greene Comment (43KB PDF)
. Reeves Comment (9KB PDF)
. Ware Comment (9KB PDF)
Link to DOE Shellfish Aquaculture Regulatory Committee Information
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http://www.dnr.wa.gov/ResearchScience/Topics/SEPAAquaticResources/Pages/amp_sepa_...l /6/2009