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Michelle McConnell
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AI Scalf
Monday, February 02, 2009 5:07 PM
Stacie Hoskins; Michelle McConnell
FW: NWP 48 Dr. Jeff Fisher Tainted Science--Independent Sound Science Requested
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From: Laura Hendricks [mailto:laura.l.hendricks@gmail.com]
Sent: Monday, February 02,20097:15 AM
To: Lawrence.c.evans@usace.army.mil
Cc: Dan.Guy@noaa.gov; Andrea_LaTier@fws.gov; Laura.Hamilton@noaa.gov; Manning, Jay;
Peter.Goldmark@dnr.wa.gov; Kleeberg, Chuck; kruppd@co.thurston.wa.us; AI Scalf; Gbm@co.mason.wa.us;
Michelle. Walker@usace.army.mil; Pamela.Sanguinetti@usace.army.mil; corrie. veenstra@usace.army.mil; kathleen. drew;
sonntanb@sao.wa.gov
Subject: NWP 48 Dr. Jeff Fisher Tainted Science--Independent Sound Science Requested
Mr. Larry Evans
Army Corp of Engineers Regulatory Chief
Dear Larry,
During our recent review of the Taylor Shellfish Totten illegal use of state lands issue, we were surprised to
discover that Dr. Jeffrey Fisher, the scientist who is an integral part of your NWP48 scientific review, has been
a geoduck farmer in Totten Inlet since 6/25/05. Not only have you relied on his findings for the NWP48, but he
wrote the two scientific memos that Taylor Shellfish provided to our Department of Natural Resources to help
justify their leasing of state lands after their illegal trespass.
Dr Fisher will benefit as follows: Dr. Fisher will gain through his analysis and reports becoming validated as
part of a permit process; Dr. Fisher will gain through a permissive NWP 48 as well as Totten Inlet SEP A
threshold decisions being issued on a farm less than 1,000 feet away; and, Dr. Fisher will gain financially
through the successful harvest of his geoducks and other shellfish. This is a serious conflict which should have
been disclosed putting in question how objective his scientific studies and analyses are. Fisher's "Fisherport
LLC" is also certified by the DOH as a Washington Licensed Shellfish Co (W A-1549-SS); listed on the
Interstate Certified Shellfish Shippers List; and has a pending NWP48 application. We have found no evidence
that his millions of dollars that are being generated from this farm are destined for charity.
"Sound science must include explicit expression of underlying values, especially values that may cause serious
conflict (Barry and Oelschlaeger 1996; Allen et al. 200 I)." Scientific memos from Environ, authored by Dr.
Jeffrey Fisher, not disclosing that he and his wife own and operate a geoduck farm on Totten Inlet has violated
one of the most fundamental scientific principals there is. The only two principals of the Seattle Environ office
are Dr. Jeffrey Fisher and Greg Reub, both geoduck farmers. Fisher and Reub have written the main scientific
reports that have been submitted to federal, state and county officials to allow unlimited shellfish farming, never
mentioning their conflict of interest.
It must be noted that 9 of the 10 Puget Sound species identified as endangered or threatened rely on Nearshore
environments. Nearshore science clearly states that modification of the substrate and prey impede salmon
restoration and salmon restoration is one of the highest objectives of our state. It is an indisputable fact that
spraying 3 tons of carbaryl a year on Willapa Bay tidelands, smothering our Nearshore with masses of oyster
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bags and liquefying our tidelands during harvesting modify substrate and prey. I have included our slide show
link photo documentation of these Nearshore modifications for your review:
Coalition Slide Show--Aquaculture Feedlots Putting Our Native Species at Risk
http://www.coalitiontoprotectpugetsoundhabitat.com/uploads/Coalition-Aquaculture- Expansion- 2008-11- N ov-
Final. pdf
We strongly urge the Army Corp, the NMFS and the USF&W to discard Dr. Fisher's self serving reports and
ignore his consultation in this NWP48 process to insure that it did not minimize the significant
environmental impacts to the Endangered Species that depend on our Nearshore for survival. With recent
headlines full of self serving regulatory decisions causing major public harm, the public must be confident that
the new NWP48 and any other decisions are based on independent sound science and not manipulated for an
industry desired outcome.
Sincerely,
Laura Hendricks
Coalition To Protect Puget Sound Habitat
(253) 509-4987
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