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Michelle McConnell
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Subject:
seablues Puddicombe [seablues@msn.com]
Wednesday, March 04, 2009 9:01 PM
Michelle McConnell; albergstein@gmail.com; rockefeller.phil@leg.wa.gov;
fraser. karen@leg.wa.gov; seaquist.larry@leg.wa.gov
FW: Pierce County regs for aquaculture
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From: seablues@msn.com
To: jaym461@ecy.wa.gov
CC: kathleen.drew@gov.wa.gov; pmccart@co.pierce.wa.us; ckleebe@co.pierce.wa.us;
merkkin@co.pierce.wa.us; kvan461@ecy.wa.gov; drisvol@co.pierce.wa.us; terry .Iee@co.pierce.wa.us;
rbush@co.pierce.wa.us; sbunney@co.pierce.wa.us; joyce. mcdonald@co.pierce.wa.us;
bgelman@co.pierce.wa.us; kilmer.derek@leg.wa.gov; larry .seaquist@leg.wa.gov
Subject: Pierce County regs for aquaculture
Date: Mon, 2 Mar 200920:51:58 -0800
March 2, 2009
Jay Manning
WS Department of Ecology
Olympia, WA
Re: Pierce County Shoreline Master Program Limited Amendment Interim Regulations for
Aquaculture and Piers and Docks (Ordinance numbers 2007-34s2 and 2008-25)
Dear Jay,
It is disappointing that Ecology was unable to approve Pierce County's Shoreline Amendment
with respect to aquaculture. The Pierce County Council drafted the interim regulations in
response to our community, and we continue in our persistence that the proposed regulations
are consistent with the Shoreline Management Act. Weare concerned that, because of the
extraordinary delay in Ecology's decision, Pierce County will not have time to complete a
shoreline inventory and analysis before the Shoreline Master Plan update is completed.
We are also concerned with our state government's bias in favor of aquaculture.
In Ecology's Findings and Conclusions, and in the press release of February 26,2009, Ecology
overstates and misrepresents aquaculture's place in the Shoreline Management Act with
obvious bias and without consideration for tax paying citizens that are opposed to aquaculture
in their communities.
"Aquaculture is identified as one type of preferred use allowed in shoreline areas under the
Shoreline Management Act, which was passed by voters in 1972. The act has three broad
goals: protect shoreline natural resources, promote public access, encourage water dependent
uses, such as aquaculture, ports, and recreation. "
WS Department of Ecology, 02/26/2009
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This is not what the Shoreline Management Act says! Ecology is re-writing the Shoreline
Management Act here to enhance and promote aquaculture. This is not the purpose of the act.
The Shoreline Management Act states the following:
"The overarching policy is that the public's opportunity to enjoy the physical and aesthetic
qualities of natural shorelines of the state shall be preserved to the greatest extentfi?asible..."
Overarching means overriding, overruling, encompassing and overshadowing everything. It
means predominate and paramount. It means that everything else in the Shoreline Management
Act, including aquaculture, is under the umbrella of this one singular idea. This was the
intention of the voters when the SMA was enacted into law. The SMA also very clearly gives
priority to single family residences and shoreline recreational uses over aquaculture as a
preferred use.
The Shoreline Management Act also states:
"Alterations (~lthe natural conditions of the shorelines (<fthe state, in those limited instances
when authorized, shall be given priorityfor...development that will provide an opportunity for
substantial numbers o.f people to enjoy the shorelines o.f the state."
This statement clearly indicates that shoreline alterations will be (1), limited in instance, and
(2), prioritized toward recreational uses.
In 1972 when the SMA was drafted and approved by voters, shellfish aquaculture in Puget
Sound was localized and confined primarily to on bottom oyster culture. Today, we're seeing
millions of plastic tubes, plastic mesh bags, huge canopy predator exclusion nets, barges,
pumps, hoses and nozzles, and an unprecedented amount of anthropogenic activity and
disturbances to the ecosystem. This is not consistent with the SMA on several levels. It does
not preserve the natural character of the shoreline. It does not protect the resources and ecology
of the shoreline. It decreases recreational opportunities for the public in the shoreline area. The
public's opportunity to enjoy the physical and aesthetic qualities of natural shorelines is not
being preserved. It is an alteration of the natural condition of the shoreline.
It is clear that intertidal geoduck aquaculture is inconsistent with the Shoreline Management
Act. It is not a "reasonable or appropriate use". It does not "promote and enhance the public
interest". It is contrary to the state's policy of "protecting against adverse effects to the waters
of the state and their aquatic life". It is not a preferred use consistent with prevention of damage
to the environment. It does not meet the "no net loss of ecosystem function" criterion.
Intertidal geoduck aquaculture and harvest techniques adversely impact eelgrass, depress key
prey invertebrates important to endangered salmon, disrupt resident and migratory birds, and
significantly impact the aesthetic qualities of the shoreline.
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And while we agree that aquaculture is of state wide interest and can be a preferred use of the
"water area" when consistent with conditions specified by the SMA guidelines, it is absolutely
clear that aquaculture does not have priority over the rights of the people to quietly enjoy the
physical and aesthetic qualities of natural shorelines of the state.
Thank you.
Curt Puddicombe
Board Member
Case Inlet Shoreline Association
PO Box 228
Vaughn, VVA 98394
www.caseinlet.org
seablues@msn.com
206-730-0288
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