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Home My WebLink About2961-443w GMIl vv.{,~ Michelle McConnell -;,qh/ Subject: seablues Puddicombe [seablues@msn.com] Monday, March 23, 20096:33 PM plun461@ecy.wa.gov jdoh461@ecy.wa.gov; choI461@ecy.wa.gov; gwhi461@ecy.wa.gov; Michelle McConnell; albergstein@gmail.com; rockefeller. phil@leg.wa.gov; fraser. karen@leg.wa.gov; seaquist.larry@leg.wa.gov; jaym461@ecy.wa.gov; kathleen.drew@gov.wa.gov; pmccart@co.pierce.wa.us; ckleebe@co.pierce.wa.us; Mike Erkkinen; kvan461@ecy.wa.gov; Dave Risvold; kilmer.derek@leg.wa; laura.hamilton@noaa.gov; andreaJatier@fws.gov Additional SARC comments. From: Sent: To: Cc: March 23, 2009 Perry Lund Washington State Department of Ecology PO Box 47600 Olympia, W A 98504 Re: Additional SARC comments. Dear Perry Lund; Please accept the following comments on behalf of the Case Inlet Shoreline Association and enter them into the record. Thank you in advance for your time and attention. First, we are concerned with the varying interpretations of the Shoreline Management Act. We assert that the SMA is unambiguous. 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 extentfeasible..." 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. The SMA also very clearly gives priority to single family residences and shoreline recreational uses over aquaculture as a preferred use. Aquaculture is not a priority use. The Shoreline Management Act also states: "Alterations of the natural conditions of the shorelines of the state, in those limited instances when authorized, shall be given priority for...development that will provide an opportunity for substantial numbers of people to enjoy the shorelines of the state." 1 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. Now it involves millions of plastic tubes, plastic mesh bags, large 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. 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 and sand dollars. It depresses critical prey invertebrates important to endangered salmon, disrupts resident and migratory birds, and significantly impacts the aesthetic qualities of the shoreline. Dean Patterson of Future Wise offers an analysis of the Shoreline Management Act here: http://www.caseinlet.org/uploads/ASSESSMENT OF RCW 90 58 020 1 .doc Second, we ask that independent, unbiased third party scientific research is utilized in the guidelines process, and that no further expansion occur until all studies, including cumulative effect studies, have been completed. In October of last year (2008), Bill Dewey of Taylor Shellfish submitted comments and a technical memorandum for Ecology to review from Environ Corporation. This Environ Technical Memorandum: 'An Analysis of the Environmental Concerns Associated with Intertidal Geoduck Clam Aquaculture' should not be used in any part of the decision making process. It is very important that the State of Washington use only independent third party scientific research. The Environ literature is funded by Taylor Shellfish Company and is inordinately biased. The literature is primarily anecdotal, highly presumptive, and is lacking in reasonable scientific certainty. The primary author, Jeffrey Fisher, owns and operates a commercial geoduck aquaculture business in Totten Inlet. Because of this conflict of interest, 2 this information should be expunged from the SARC record and not used in the process of formulating guidelines. Generalized information on other forms of shellfish aquaculture from other ecosystems is not relevant to geoduck culture\ and there remains very little conclusive scientific research specific to geoduck aquaculture in Puget Sound concerning impacts to fisheries. The preliminary results thus far suggest that intertidal geoduck aquaculture is, in fact, detrimental to fisheries. Research conducted by Sea Grant indicates that geoduck aquaculture techniques significantly depress sediment organics, eelgrass and sand dollars, as well as sediment dwelling amphipods (Corophium spp.) and polychaetes2. Corophium is an important food for endangered Chinook, and polychaetes are a dominant food for juvenile salmon and flounder3. Both Dewey and Fisher are incorrect in their assumption that the interaction between geoduck aquaculture and fisheries are either benign or beneficial. The unreasonable opinion that all fish prefer structured habitat is not consistent with the available scientific data. Fisheries experts from the Oceans Conservancy4 and The Georgia Strait Alliance5 do not agree that artificial reefs are beneficial. Independent studies further indicate that unstructured habitat is necessary for larger migratory mobile species6. Dewey's and Environs' claims that there is little or no interaction between geoduck aquaculture and forage fish is also incorrect. Core samples taken by Sea Grant indicate a spatially consistent number of sand lance in the area of geoduck culture2. Ecology also notes the presence of forage fish in the intertidal areas of geoduck culture. Additionally, dive harvests are occurring in the intertidal during forage fish spawning cycles (January through March). Recently, dive harvests near shore were observed, documented and photographed in the North Bay area of Case Inlet known as the Engman site between January and March, 2009. Scientific research demonstrates that juvenile salmonids 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, but only to SA V and eelgrass. Juvenile Chinook smolts would not respond to oyster clusters in a recent study in Willapa Bay8. Research also demonstrates that adult migrating salmon prefer unstructured habitat as well, and adult Chinook diets in Puget Sound contain 60 percent sand lance7. Geoduck aquaculture 'structures' will likely alter or upset predator/prey dynamics between migrating adult Chinook and sand lance. An 'anti predator' net is obviously designed to exclude predator species from their natural habitat. The structures provide unnatural refugia for prey species, thus altering complex interactions between species. To say that artificial structures provide refuge from predation is to deny the predator species altogether. 3 As always, we appreciate your time and consideration. On behalf of CISA, thank you again. Regards, Curt Puddicombe Board Member Case Inlet Shoreline Association PO Box 228 Vaughn, VVA 98394 www.caseinlet.org seablues@msn.com 206-730-0288 1. Dethier, Sea Grant 2007: 2. VanBlaricom/Horwith, Sea Grant 2009: 3. Salmonid Dietary Analysis: http://www.kingcounty.gov/environmentlwatersheds/central- puget -sound/nearshore-environments/iuvenile-salmonid-report.aspx 4. Oceans Conservancy: http://www . ocean conservancy .org/site/PageServer?pagename=issues arti ficialreefs 5. The Georgia Strait Alliance: http://www.georgiastrait.org/?q=node/604 6. 'Structural Complexity of Biogenic Habitats', K. Holsman, and 'The Necessity for Intertidal Foraging by Estuarine Populations of Subadult Dungeness Crab', Holsman, Armstrong, Beauchamp, Ruesink. 7. Ecology: http://www.ecy.wa.gov/programs/sea/pugetsound/species/sandlance.html 8. Semmons, B.X. 2006, PhD Dept. of Biology, UVV. 4