Industry talking point: Only 150 acres of commercial geoducks Sound wide."


The shellfish industry has been aruging publicly that there are only 150 acres of geoduck aquaculture Sound wide, so what's the big deal? They ignored the expert scientist at the 2007 Sea Grant Shellfish Aquaculture workshop who said that comparing 150 acres to all of Puget Sound is not meaningful, that the acreage must be compared to a bay or smaller area.

On March 19, 2007, the Army Corp of Engineers issued their Nationwide Permit (48) Existing Commercial Shellfish Aquaculture Activities All commercial shellfish growers, under NWP48, were required to submit a form describing their existing operations. Public records requests yielded the following sets of documents:

--Department of Ecology list of ACOE forms that include geoduck aquaculture

--NWP48 froms for Mason, Thurston and Pierce Counties that include geoduck aquaculture.

The ecology list adds up to over 10,600 acres that include geoducks as the species cultivated or one of several species cultivated on that acreage. Only one grower delineated using maps the areas for different species cultivation. The South Sound List adds up to some "" acres that include geoduck aquaculture.

When questioned about this remarkably huge discrepancy (150 compared to 10,600 acres), the Department of Ecology, during the October SARC meeting, claimed that their list was a "working document" and that they were working with growers to distinquish "planted" vs. "planned" geoduck acreage. The industry representative claimed that the growers were doing "the best they could" in filling out the forms. Yet when subsequent questions were asked of individual growers why large oyster tracks in Oakland Bay, for example, had been included in the geoduck list, the growers claimed that geoducks would never be cultured in Oakland Bay because the sediment is too muddy. When DNR was asked if the 6000 acre parcel in Willapa Bay from Taylor Shellfish was a lease for geoduck aquaculture, they said 'no.' When DNR was asked if the lease of 10 acre on State tidelands on Harstine Island by Seattle Shellfish included geoducks, they said "no," only oysters and clams.

A review of the file at Ecology related to this issue during April 2008, revealed in substance only an email between a ECY representative and an industry representative, that indicated there were 525 acres of geoduck aquaculture "in production." Actual documents identifying this acreas and requested in April 2008 from Ecology have not yet been forthcoming.

The question remains: why would growers include geoducks on parcels where they only grow oysters and/or clams? The speculation is that since the NWP48 permits "existing" culture, and new operations and new species would require an individual permit with environmental review, that including geoducks on all this acreage would "grandfather in" geoduck culture.

Yet the Taylor Shellfish employee who is the industry representative on the SARC Committee continues to claim there are only 150 acres of geoducks being cultivated. This is the same employee who personally signed every NWP48 form for Taylor Shellfish for over 9000 acres that included geoduck culture, then bristled at the implication that the industry was being called a "lier" (her words) when the issue was raised for discussion.

Industry claims that the ACOE NWP48 permit is "robust" and is the only permit needed by the shellfish industry to continue their expansion in Puget Sound. It is more than obvious that the ACOE permit is completely ineffectual and does not represent in any way adequate regulation of this industry. We continue to state that shellfish operations must be subject to substantial shoreline development permit process. Taylor Shellfish is currently legally opposing this concept.

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Industry talking point: Shellfish "clean the water"


The shellfish industry cannot harvest shellfish without clean water. They need clean water certification from Washington State Department of Health (no fecal coliform bacteria or other bad bacteria) in order to harvest their farm product. It is a business objective of the shellfish industry to get all the rest of us to change our ways so that the water is free of these bacteria. The shellfish don't do this job. We would like the water to be clean too, because that's the right thing for Puget Sound. We just don't think that the shellfish industry should be allowed to destroy nearshore habitat while we pick up our doggy poop.

When growers say that shellfish "clean the water," they mean that shellfish consume phytoplankton from the water. In fact, in a documented entitled Geoduck Clam Research prepared for DNR by the Pacific Shellfish Institute in 2004, geoduck growers say they like installing their operations in South Puget Sound because of the abundance of phytoplankton (which feed on nutrients), the food for shellfish.

So when the growers say they are saving Puget Sound by getting rid of nutrients (the food for shellfish), they are making a circular argument. It also begs the questions: 1) Why is Totten Inlet, filled with millions of pounds of cultured shellfish, about to go eutrophic, a statement made by a DNR employee; 2) doesn't the industry need phytoplankton and isn't it true that geoducks are hard to grow in Hood Canal because there is not enough phytoplankton? 3) What will happen if we do collectively manage to limit the nutrients going into Puget Sound and there are not enough left for those millions of farmed shellfish (or for anything else, since phytoplankton are also the food for other creatures)? Will the shellfish industry then claim they need to use fertilizers to grow their farm product on our tidelands?

While industry representative rail against upland development in Totten Inlet as the cause of all the problems, a 2006 Powerpoint presentation by the shellfish industry entitled Profile of South PugetSound?s Health, in which the inlets of South Puget Sound are compared, gives give high marks to Totten Inlet for its rural character, low level of impervious surface, low rate of decline of forest cover, low amount of armoring (bulkheads) and "perfect scores" on the fecal coliform pollution index.

And what about all the shellfish waste (feces and pseudofeces)? A dive under the mussel rafts in December 2006 showed a dead zone.

In their talking points, the Shellfish industry does not distinguish between naturally occuring bivalves which have a ecological role in the marine environment and the planting of agricultural densities of geoducks for commercial purposes. According to industry documents, naturally occurring geoducks are .2 to 2 per square meter. In agricultural densities, harvestable geoducks are 19-23 per square meter.

Demonstrations in the lab of oyster (not geoduck) ability to filter phytoplankton out of the water are given as evidence for the benefits of all bivalves. However, what they don't show is the feces and pseudofeces at the bottom of the tank. Geoduck farms on the tidelands often reveal a different story, one with muddy waters and heavy siltation. And DNR with the help of lab experiments by Taylor Shellfish says that the loss of 4 million pounds a year of geoducks from the subtidal fishery isn't a big deal--its not a filtration loss.

Muddy waters over geoduck farm--Totten Inlet.

Totten Inlet geoduck farm - muddy water.

Many studies from around the world document waste from intensive shellfish aquaculture, in the form of biodeposits of feces and pseudofeces.

But the most important fact is that proliferation of shellfish farms into new areas is destroying habitat for other species.


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Industry talking point: Commercial plantings of geoducks will help "save Puget Sound."


DNR and industry say that planting commercial geoduck farms on the intertidal zone is important to the health of Puget Sound because geoducks 'clean the water,' meaning that they consume phytoplankton, their ordinary food. This is the major 'environmental' argument of the industry to promote commercial geoduck farming and densities on fragile tidelands. This is why it is troubling that in the Department of Natural Resouces Geoduck Habitat Conservation Plan the DNR states that lab studies done with Taylor Shellfish show that removing four million of pounds of geoducks from subtidal areas every year does not matter because that filtration is insignificant. This contradiction makes the argument that commercial geoducks help "clean the water" ridiculous and self-serving.

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Industry uses chemicals to destroy burrowing shrimp that also filter phytoplanton.


The shellfish industry is trying to promote industrial geoduck feedlots on the tidelands as beneficial to Puget Sound because geoducks consume phytoplankton. At the same time, they say that they like South Puget Sound because of the abundance of phytoplankton, the food source for their shellfish products. So while they are claiming heroism for getting rid of the phytoplankton that they must have for optimal growth of shellfish, they are busy destroying another native species in Willapa Bay that also filters phytoplankton from the water--burrowing shrimp--by spraying the tidelands with the chemical carbaryl.

An article from the University of Washington on mud shrimp states that "one of the creatures filtering the most water is the mud shrimp. In Oregon estuaries, mud shrimp filter as much as 80 percent of the bay water per day, estimates Ted Dewitt, an ecologist with the U.S. Environmental Protection Agency. They are also an important food source for birds, fish, and other animals." Yet also in the article, Bill Dewey, public affairs manager for Taylor Shellfish Farms, Inc., one of the largest commercial producers of shellfish on the West Coast, states that "burrowing shrimp as a whole have had a devastating effect on production in coastal estuaries. Controlling them is beneficial to the estuary because removing shrimp boosts diversity."

Mud or burrowing shrimp are a problem for oyster growers, because they burrow into the sediment and made it unstable for placement of oysters. So the the oysters growers spray carbaryl onto the tidelands in Willapa Bay, a practice which is supposed to be phased out by 2012. And now ironically a parasite has been identified as potential biocontrol agent for burrowing shrimp. "Two isopod parasites were shown to have potential to significantly reduce shrimp populations in estuaries by castrating their female shrimp hosts. One species was shown to potentially already be impacting mud shrimp populations in Willapa Bay and Grays Harbor which have declined substantially."

Bill Dewey says about the parasite, "One of the things growers have been looking at is biological controls," Dewey said. "We're searching for a suite of tools to put in our toolbox, and this isopod appears to be doing its job without our doing anything to enhance it."

But a University of Washington Scientist who has studied the shrimp for more than ten years, has a different take. '"Shrimp are a valuable part of the estuary, whether the growers want to acknowledge it or not," he says. "They're a native species and the oysters aren't.'

Like other arguments that the shellfish industry uses, they argue both sides--plant the filterers (geoducks) and claim industry is an evironmental hero; destroy the other filterers (mud shrimp) because this species gets in the way of production. It all depends on which side of the argument is convenient for industry business purposes.

For more information on carbaryl, read Exit Diazinon, Enter Carbaryl, Phaseout Leads to Risky Replacement, A Clean Water for Salmon Campaign ReportMay 2005, a publication of the Clean Water for Salmon Campaign, Northwest Coalition for Alternatives to Pesticides, Washington Toxics Coalition, by Erika Schreder and Philip Dickey.


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Industry talking point: commercial geoduck farms are planted on sandy beaches characterized as 'barren.'

Sandy beaches on Puget Sound are the precise areas that the shellfish industry desires for commercial shellfish aquaculture. Sandy beaches were described by Bill Dewey, winner of environmental awards and public affairs manager for Taylor Shellfish, at a Key Peninsula geoduck forum in May of 2007, as "barren."

But to the average observer, sandy beaches are not barren. The sandy beach habitat provides a "dramatic increase in life" such as "little-neck clams, green sea lettuce, red seaweed called Nori, amphipods..." according to biologist, David Jamison in The Olympian on May 5, 2008.

In South Puget Sound, only approximately 10% of intertidal beaches are public beaches and 90% are owned privately, so it is even more imperative that the state not lease these public beaches for commercial purposes.

On May 5, 2008, citizens from Harstine Island and Stretch Island presented their objections to the DNR geoduck aquaculture leasing program on public beaches to representatives from the Department of Natural Resources and the Department of Ecology.

Harstine citizens speak out on DNR leasing. Overview of citizen concerns regarding using public beaches for private profits, with doubts about the environmental stewardship of the DNR.
DNR Beach Lease Story Description of a public beach leased by the DNR for clam and oyster aquaculture with the question: Why is the DNR so interested in making money off our public beaches?
Q&A Two hours of questions and statements from the audience. With much passion, citizens ask "why is DNR doing this?"


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DNR talking point: geoduck aquaculture has minimal impact on forage fish spawning and habitat.

The DNR lease sites for commercial geoduck aquaculture are all on public beaches and most of them are in the vicinity of forage fish spawning habitat. Forage fish are important because they are a primary food source for endangered juvenile Chinook salmon and other species.

Citizen requests for documentation from DNR scientists related to the impacts of geoduck farming leases on forage fish have brought a consistent response from DNR that "our scientists have looked at the forage fish issue and determined that there would be a minimal interaction between the geoduck aquaculture methods and forage fish (sand lance and surf smelt)." Francea McNair, Aquatic Lands Steward, August 11, 2006.

After many public records requests, citizens finally learn in a letter from DNR in April 2008 that the the source for the DNR scientists' determination was merely a review of the WDFW website, not scientific studies. We continue to be astonished by the the apparently unprofessional use of unnamed scientists in DNR to support the conversion of the fragile tidelands of Puget Sound to commercial agricultural use.

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DNR talking point: 'the legislature made us do it."

DNR representatives have been telling citiznes for two years that the geoduck leasing program has been directed by the legislature. They imply that 'the legislature made us do it." But when we look at the 'fine print,' there is no mandate or directed request by the legislature. Here is what we find:

2003--Somebody (DNR, industry, legislator?) asks Govenor Locke to put the geoduck aquaculture feasibility study into his discretionary budget. This was passed under ESSB 5404: Section 308(15).

2003-2004--DNR contracts for the feasibility studies, Phase 1 of the DNR geoduck aquaculture program. The economic study suggests limiting acreage per year so as not to flood the market.

1)Geoduck Clam Research and Management: Pacific Shellfish Institute Component. Report on Potential Siting and Environmental Considerations in Geoduck Farming and Summary of Subtidal Methodology Advancements.
2)Identification of research priorities relevant to geoduck (Panopea Abrupta) aquaculture environmental impacts.
3)Assessment of the current knowledge of geoduck and other shellfish population structure, with general recommendations for the genetic management of cultured and wild geoduck clams.
4)Geoduck aquaculture environmental monitoring program DRAFT.
5)Report on research findings related to subtidal geoduck aquaculture.
6)The World Geoduck Market

2005--The DNR geoduck aquaculture website states that for Phase II, "Findings in the completed feasibility study led DNR to recommend to the 2005 Legislature that a limited geoduck aquaculture leasing program be implemented, to lease up to 25 acres per year for this activity. The Legislature amended state law to allow geoducks to be sold like other cultured shellfish?this removed the only impediment to a state leasing program."

2005-2006--DNR geoduck team meets to discuss program implementation.

2006-2007--First DNR lease offers for commercial geoduck aquaculture are all on public beaches and most of them are in the vicinity of forage fish spawning habitat.

2007--Due to opposition by citizen activists, the legislature passed HB 2200 limiting the number of acres offered for leasing for geoduck farming to 15 a year through 2013 after the initial 23 acres in 2006.

We cannot find any law or legislation that mandates or directs DNR to lease public tidelands for geoduck aquaculture. The statements that have been made by DNR representatives over the past two years have thus, to our knowledge, been misleading.


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Industry talking point: citizens should welcome what the industry characterizes as a "working waterfront."

Geoduck farms were praised as a "working waterfront" by a representative of the Pacific Coast Shellfish Growers Association in a Senate public hearing. Another shellfish industry spokesman said that the view of geoducks farms "is attractive." Key Peninsula Geoduck Forum, 4/5/07.

Click on any photo to enlarge

Totten Inlet geoduck farm.

The commercial shellfish industry says: "Private tidelands are misrepresented as residential/recreational beaches. The county must recognize that the primary purpose of privately held tidelands is shellfish farming and not residential recreation...moreover, shellfish farmers have every right to post these private tidelands and prevent trespass." --Letter from the Pacific Shellfish Growers Association, to the Pierce County Planning Commission, dated January 15, 2007

When the Governor is promoting the restoration and protection of habitat in Puget Sound as two of her top priorities, then citizens who view the new intensive methods of shellfish aquaculture and the conversion of natural ecological systems to agricultural use on our tidelands, do no welcome this type of activity.

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Industry talking point: the "livelihood" of small family shellfish farmers are at stake

We understand that shellfish farmers want to protect their livelihoods. The shellfish industry, according to one of the growers, is one of the "last unregulated industries in the country." The current acknowledgement that there must be regulation of this industry in order to balance uses of Puget Sound and account for environmental impact is obviously causing turmoil within the industry. If there is not a recognition of the conflicts by the industry, those conflicts will just become worse.

Some questions need to be addressed. For example, why should the shellfish industry be able to expand into residential shoreline communities using methods and practices that permanently convert the beach areas to agricultural use without environmental impact statements and without a permitting process or public commen, as is the case currently in most counties?. Is the filling up a sheltered cove with geoduck farms and other shellfish aquaculture a good idea for the environment or the neighborhood? Will this expansion of livelihoods cost the taxpayers in the future when we try to put things back the way they were before, which is the goal of the Puget Sound Partnership--to restore and protect habitat? We don't understand all the claims of benefits of shellfish farming when we look at the beaches in Totten Inlet.

If the industry had been content with its traditional shellfish growing areas, there would probably be no conflict. The conflict is in the expansion into residential neighborhood shoreline areas without monitoring, oversight or public comment, and introduction of new intensive methods without environmental impact statements. Pierce County currently is the only County that requires substantial shoreline development permits for this activity. The conflict is also in the lack of consistency between the goal of the Puget Sound Partnership to restore habitat and what we see happening on our beaches when the shellfish farmers come in.

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Industry talking point: gear (PVC tubes?) used in geoduck aquaculture provides habitat for grazing critters which is good for eelgrass growth.

Specifically, the Pacific Coast Shellfish Growers Association literature entitled Environmental Benefits of Shellfish Farming states that "Aquaculture gear used in raising oysters, clams, mussels, and geoducks provides additional habitat for epiphytic grazers, which may result in increased light absorption and enhanced eelgrass growth." PCSGA cites a study by Peterson and Heck entitled Positive interactions between suspension-feeding bivalves and seagrass--a facultative mutualism (2001) for this claim.

However, this study only addresses mussels, not oysters, clams or geoducks. In fact the annual progress report of another study by University of Washington biologist Jennifer Ruesink entitled "Scale-dependent and indirect effects of filter feeders on eelgrass: Understanding complex ecological interactions to improve environmental impacts of aquaculture" states that "we have observed direct negative effects of disturbance and of geoducks on eelgrass density: eelgrass-removal plots remain at low density, although vegetative regrowth has occurred from the edges; and plots with geoducks have lower eelgrass densities than do those without. On the other hand, we have seen little evidence of indirect positive effects of geoducks: porewater nutrient concentrations appear slightly higher when geoducks are present, but this 'fertilizer' effect does not result in enhanced growth rates of eelgrass."

Additionally the Heck and Peterson study uses densities of mussels which "approximate the range of abundances most often observed in the bay," not aquaculture densities. The last sentence of the study states that "Modern community ecology would benefit from a concerted re-examination of the role of positive interactions in the development, structure and organization of natural (our emphasis) communities."

PCSGA needs to address the discrepancies in their claims and the fact that they are using a study related to natural ecosytems to validate agricultural densities and that they are using a study of mussels to try to prove positive impacts of geoduck aquaculture on eelgrass, even though it is acknowledged in the Ruesink study that harvesting destroyes eelgrass. Additionally, as to mussels, residents in Totten Inlet say there use to be eelgrass in Gallagher Cove, but that it no longer exists, even though there are mussel rafts in Gallagher Cove.

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Industry talking point: geoducks will feed the masses.

An economic study commmissioned by DNR on the World Wide Geoduck Market states that "...geoduck is a super luxury item which only the rich can afford. The product's price in the Chinese market can reach $60 to $100 per pound. If the price of the product were to fall by 50 percent, it will still be out of the price range of most of the population."

We do not object to the shellfish industry making money. What we object to is taxpayers footing the bill to protect and restore habitat in Puget Sound while the shellfish industry is allowed to convert hundreds of feet of shoreline from the natural ecosystems we are trying to protect to agricultural use.

The shellfish industry has hired a PR firm as evidenced by this letter from a shellfish grower to his lessors to promote shellfish farming to the public. But to many citizens, the goals of the shellfish industry are in conflict with the goals to protect and restore Puget Sound habitat and endangered species.

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Industry talking point: citizen viewpoints are just "tit for tat" or "a tempest in a teapot.

The use of language such as this by shellfish industry representatives is an attempt to trivialize legitimate points of view in a serious discussion about the future of Puget Sound and to silence the voices of those who are rasing concerns about expansion of shellfish aquaculture in Puget Sound.

The Random House online Word of the Day states that "tit for tat" is an English phrase which "unfailingly has negative, adversarial connotations." It further states that the meaning of the term is "one thing in retaliation for another; payback in kind." This adversarial term is being used by industry spokespeople at high level meetings to characterize other points of view.

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Industry talking point: opponents to geoduck farming are just NIMBY's.

In the recent KPLU interview with Bill Dewey, Taylor Shellfish, and Laura Hendricks, leader of the Coalition to Protect Puget Sound Habitat, Dewey stakes his claim that farming some 90,000 cultured geoducks per tideland acre is good for Puget Sound and that the citizen opponents are just NIMBY's.

The Random House online Word of the Day states that "tit for tat" is an English phrase which "unfailingly has negative, adversarial connotations." It further states that the meaning of the term is "one thing in retaliation for another; payback in kind." This adversarial term is being used by industry spokespeople at high level meetings to characterize other points of view.

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Industry talking point: visibility of geoduck farms only 2-3%

The shellfish industry claims in Wikipedia that geoduck PVC tubes are "only visible 2-3% of daylight hours over a 6-year crop cycle. The reason for the low visibility is because geoduck are farmed in the lower elevations of the beach and are covered by water most of the time."

The Pacific Coast Shellfish Growers Association Geoduck Farming Fact Sheet states that during the grow-out cycle, the PVC tubes are only "visible approximately 2% of the time." However, industry representatives also state that the farms are rotational, so that the likelihood of tubes or vexar tunnels being present is ongoing.

We have done an analysis of visibility of geoduck tubes during summer months, since the lowest tides during daylight hours are in the summer (as opposed to the winter when lowest tides are at night). Visual and recreational impact of the tubes is greatest at the very time when the people of Puget Sound are likely to be using the beach and the waterways.

This Geoduck Farm Visibility Chart demonstrates that the average percentage of daylight hours per day between Memorial Day weekend and Labor Day that the farms are visible is 19%. The number of days during this season that farms are visible some portion of the day is 76%. This is calculated for geoducks planted to a +2 tidal level in Thurston County, Washington, one of the counties of South Puget Sound where the geoduck farms are clustered without any environmental siting criteria, public comment or environmental review. When calculated for a +3 tidal elevation, the amount of visibility rises to an average per day of 23% of daylight hours and 87% of the days of the summer.

According to the Geoduck Growers Environmental Codes of Practice the PVC pipes are "pushed into the substrate in the intertidal zone from approximately the -2 tidal elevation to the +3 tidal elevation (MLLW) about 12 inches apart. About 3-4 inches of the PVC pipe is left above the substrate."

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Industry talking point: armored beaches (bulkheads) are a lot worse than shellfish aquaculture and therefore citizens are to blame.

When citizens speak about their direct observations of the degradation of habitat on the tidelands due to high intensity shellfish aquaculture farming and harvest practices, both in hearings and meetings, the industry representatives attempt to change the subject by saying that armored beaches (bulkheads) are worse and that citizens are to blame. Interestingly, this talking point is actually a concession that shellfish aquaculture is bad for the tidelands. Also, this is comparing apples and oranges. If thoughtful people had known what is known now about bulkheads when they were first built, there might have been a conversation about bulkheads a long time ago. We are at the beginning of the shellfish expansion on the tidelands, and as a parallel to bulkheading, we don't want to wait 20 or 50 years to discover that we've made a terrible mistake.

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Industry talking point: most of the problems in Puget Sound are from upland development and shellfish aquaculture is so small by comparison that it should not be considered a problem.

We agree that increasing development of the watersheds around Puget Sound cause a myriad of problems. Those problems are being addressed by the multi-billion dollar long-term Puget Sound Partnership initiative. Just because one problem is grander than another does excuse us from addressing all problems that we face. HB 2220 is the legislation that mandates that we begin to address the problems associated with expanding shellfish aquaculture on our tidelands. We agree with all the objectives of the Puget Sound Partnership, two of which address habitat protection and restoration. These are the objectives that we are working on in relation to the tidelands of Puget Sound.

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Industry talking point: harvests have only localized, short term effects.

In the PCGSA article entitled Geoduck Farming is Good for Washington State industry states that harvests have only localized, short term effects. They says that "the beach recovers over a period of weeks to months depending on the time of year and location. Environmental Impact Statements (EIS) produced by the Washington State Department of Natural Resources on the effects of their geoduck harvest program found that geoduck harvest techniques result in only short term and localized impacts."

The premise of the harvest of native geoducks from the deep water geoduck fishery is that the entire area recovers before harvest can occur again. Recovery is approximately 39 years.

The premise of geoduck aquaculture is that there is no recovery to a natural state. It is a permanent conversion of the tideland from a natural state to commercial agriculture. Ironically, the PCSGA article also states that "another indication of the health of geoduck beaches is that growers can replant geoduck within days of harvest." Health of the beaches for what? Agriculture.

In fact a recent Taylor Shellfish legal document dated August 22, 2007, states that on their geoduck farm in Case Inlet, "Taylor plants and harvests the Foss farm on a rotation, farming it in segments...After the harvest of each portion, Taylor replants that segment of the farm such that the farm is in a perpetual cycle of planting, cultivation and harvesting."(Our emphasis)

So tideland areas are never left to recover to their natural state, but become permanent agricultural areas. Thus they produce long term and permanent effects.

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Industry talking point: geoduck farms are planted at densities similar to wild, undisturbed subtidal geoduck tracts."

The Pacific Coast Shellfish Growers Association paper entitled Geoduck Farming is Good for Washington State makes this specific claim. Yet this is contradicted by the Comprehensive Literature Review and Synopsis of Issues Relating To Geoduck Ecology and Aquaculture production prepared for the Department of Natural Resources by the School of Aquatic and Fishery Sciences (UW), Department of Biology (UW), and the Pactific Shellfish Industry, which states on page 36 that "the average densities on geoduck tracts were significantly different for geogrpahic areas, with South Sound the highest at 2.0 geoducks/sq meter, and North Sound the lowest at 0.2 geoducks/sq meter."Another subtidal geoduck survey by Guilder Associates shows a density of .43 to 1 per square meter on different sample plots. According to a farm manager on a Totten Inlet geoduck farm on 7/30/07, the survival rate is 75%.

The industry statistic for planting seed compute to approximately 24 geoducks per square yard or approximately 26 geoducks per square meter. We have requested a reconciliation of these conflicting statements from the Pacific Coast Shellfish Growers Association.

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Industry talking point: shellfish must be harvested to get rid of nutrients.

Industry doesn't address the fact that harvesting shellfish, particularly water jet harvest of geoducks, destroys eelgrass and destroyes habitat or that they are converting natural ecosytems to agricultural use.

This industry talking point is that shellfish must be harvested in order to help reduce nutrient loads in Puget Sound. This is found in the recent Olympian newspaper article about nutrient loads in Puget Sound, in which an industry member is quoted as saying "As long as you harvest them, shellfish are part of the solution." This notion is also promoted in theWikipedia article on geoducks and as an uncited claim in the Hood Canal Molluscan study.

Shellfish growers claim that shellfish in their growth stage assimilate a lot nutrients, more than the mature geoducks,and thus harvesting shellfish will reduce the nutrient load in Puget Sound and Hood Canal. Shellfish are thus portrayed as a kind of sponge that soaks up bad stuff--nutrients. One document that addresses this is Filter Feeding to Control Eutrophication by Michael A. Rice.

However, this 'solution' to the nutrient problem in Puget Sound does not take into account other impacts of intensive shellfish farming such as accumulation of shellfish waste in low flushing inlets and degradation of habitat. And nutrients are actually needed by industry because they are the food for shellfish. Industry likes South Puget Sound because of the abundance of nutrients. In areas with strong currents, there can be serious shellfish aquaculture debris problems, as evidenced in British Columbia and mentioned in the document prepared for DNR by the Pacific Shellfish Institute for intertidal and subtidal geoduck farming.

The industry appears to imply that 1) waste from intensively grown geoducks is not ever a problem and 2) to save Puget Sound from nutrients (food for shellfish) that we should plant millions of cultured geoduck for an accelerated agricultural cycle of planting/harvest. Is industry suggesting that we "clear-cut" native geoduck and put aquatic lands into a perpetual cycle of production? This argument certainly serves their economic interests, but at what cost to the environment?

Interestingly, shellfish do soak up and sequester in their bodies contaminants such as cadmium and toxins such as Paralytic Shellfish Poisoning (PSP) which makes eating them sometimes dangerous for human health.

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Industry talking point: holes creates by water jets are really just 'divots.'

Shellfish growers are now referring to the holes created by water jet harvest as 'divots.' From about.golf:

Definition: Most shots from the fairway with an iron will scrape off the top of the turf where the ball was resting. "Divot" refers to both the turf that is scraped up, and the scarred area in the fairway where the turf had been. A good divot will start just in front of where the ball was at rest - meaning that your club struck the ball first, then the ground. If the divot starts behind the ball, you have mis-hit the shot (this type of mis-hit is often called hitting the ball "heavy" or "fat"). If you create a divot with your shot, it is always appropriate to repair it (see How to Repair Divots). A "nice divot" is a divot that is sheared off very cleanly and thinly and remains in one piece.

This is an example of the shellfish industry entering a parallel universe where golf terms can be applied to water jet harvest in order to get into the imagination of the uninitated the mental picture of a bare scrape on the surface of the ground. We think even clam harvest causes more than a 'divot." Harvestable geoducks reside three feet down in the sediment, so we assume that the impact of the water jet is greater than three feet down, which is hardly a 'divot.'

In fact the term that growers are trying so hard not to use anymore is "in the hole," a term that refers to the fact that water jet harvest involves the harvester sinking down into the sediment, and is used and demonstrated by Mike Rowe on the geoduck 'Dirty Jobs' segment, and in many photos we have taken of geoduck harvesters.

A hole is a hole is a hole. A geoduck harvest hole by any other name will be as deep.

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Legislation: Pierce and Kitsap Bush Callow lands

This description and maps ofKitsap and Pierce County Bush Callow lands are tidelands originally sold in the 19th centurey for oyster farming. Based on recent legislation, these lands can now be used for any type of shellfish farming.

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