Comments needed on Dungeness National Wildlife Refuge

A corporation intends to industrialize 34-acres* of the publicly-owned Dungeness National Wildlife Refuge with 80,000 plastic bags of oysters.  The U.S. Corps of Engineers and the Washington State Department of Ecology are interested in your comments.

Submit comments by MAY 30, 2020.

The Dungeness National Wildlife Refuge in Washington State’s Salish Sea is one of the most pristine national refuges. This Refuge was dedicated in 1915 for its abundance of eelgrass which sustains migrating and resident birds, their feeder fish and salmon.  The site hosts more than 250 species of birds, some of which nest and raise their young here. The 5.5 mile spit is one of the longest in the world and is a major U.S. attraction.           

For background information visit:  http://www.protectpeninsulasfuture.org/dungeness-refuge-alert/

Comments are needed on any of the operation’s potential impacts:  Conservation, eelgrass, water quality, local and refuge economics, aesthetics, plastics, bird and fish feed, benthic life, shore erosion, cumulative impacts, and/or recreation, with as much back-up data as possible.

Click here to open Joint Public Notice

Where to submit your comments

Send your U.S. Army Corps of Engineers comments to:

U.S. Army Corps of Engineers, Regulatory Branch, Attention: Pamela Sanguinetti,

P.O. Box 3755, Seattle, Washington 98124-3755; email pamela.sanguinetti@usace.army.mil    Reference Case #: 2007-1213

Send your Washington State Department of Ecology comments to:

Washington State Department of Ecology,  Attention: Federal Permit Coordinator,

P.O. Box 47600, Olympia, Washington 98504-7600; email ecyrefedpermits@ecy.wa.gov

For more details on how to comment, visit:

http://www.protectpeninsulasfuture.org/how-to-comment/

*NOTE:

Due to the Applicant requesting a “phased “approach, the initial proposed work of ‘on-bottom bag culture” = 5 acres of 20,000 bags.  When the oysters grow to a certain size, they would be removed from the bags and spread on 29 acres of refuge beach shoreline to grow to commercial size and be harvested. Total allowable coverage is still 34 acres. The Applicant’s full plan is to cover 20 acres with 80,000 plastic bags of oysters.

This press release came from Protect the Peninsula’s Future

http://www.protectpeninsulasfuture.org/

 

Seafood Industry struggling to stay afloat amid outbreak – AP

Seafood industry struggling to stay afloat amid outbreak
The seafood industry has been upended by the spread of the coronavirus, which has halted sales in restaurants and sent fishermen and dealers scrambling for new markets. Seafood is a global industry that relies on a complex network of fishermen, processors, buyers and distributors, all of which have been affected by the virus. A lack of demand has sent prices tumbling and led some fishermen to tie up their boats until the outbreak subsides. Patrick Whittle reports. (Associated Press) See also: Coronavirus Devastates Geoduck Industry  Sara Thompson reports. (Key Peninsula News)

How Trump’s Environmental Policy Rollback Affects The Northwest -OPB

The Trump Administration has now gone after the heart of environmental protection in this country. This new rule change has been pushed by many companies here in the NW in their lobbying efforts. The rule change is totally opposed by the entire environmental community. It’s a horrible change, that we all expected would happen.

The NEPA has been a thorn in the side of many projects, and one of the parts discussed in the article is a new category, that is very unlikely to sustain judicial review. It states that “…projects with “minimal federal funding or involvement” wouldn’t require any kind of environmental assessment.”  This might mean that massive aquaculture farms put in the heart of environmentally sensitive areas  might be excluded from environmental review, for example.  The NEPA was an issue in the landmark court case against the Army Corps of Engineers & Taylor Shellfish last year. The cumulative affect of geoduck aquaculture, which the Corps own biologist had found to have terrible long term effects, (which they never published, it was a draft that was killed and only found by court discovery process), was at the heart of the judge’s decision.

In that decision, the court found in it’s blistering conclusions, “…that the Corps has failed to adequately consider the impacts of commercial shellfish aquaculture activities authorized by NWP 48, that its conclusory findings of minimal individual and cumulative impacts are not supported by substantial evidence in the record, and that its EA does not satisfy the requirements of NEPA and the governing regulations…the Court holds unlawful and sets aside NWP 48 insofar as it authorizes activities in Washington.” (emphasis mine)

It was reported on the web site run by the leading anti-aquaculture group, Protect our Shoreline News in 2015 that Taylor had hired The Glover Park Group (GPG) specifically to target the NEPA process. The web site stated that, “The Sunlight Foundation Reporting Group reports the purpose GPG has been enlisted by Plauche and Carr, fronting for Taylor Shellfish and the Pacific Coast Shellfish Growers Association, is to deal with “Federal permitting related to shellfish operations.” http://protectourshorelinenews.blogspot.com/2015/03/taylor-shellfish-has-new-friend.html

There’s never been a better time to donate to any of the groups that will fight this in court, such as Earth Justice, which has pledged to fight this. 

I’d love to hear from the aquaculture industry as to whether this was part of their lobbying efforts last year in Washington D.C. How much money did they give to the Trump Administration to promulgate a rule change like this? Following the money might be quite interesting in understanding just how much the shellfish industry tried to push this through. Looking forward to seeing some motivated young journalist dig this information up.

A new Trump administration plan to scale back a bedrock environmental law could affect all kinds of projects in the Northwest, including timber sales, hydroelectric dams, and large energy developments like the controversial Jordan Cove liquefied natural gas project with its 235-mile Pacific Connector pipeline.

https://www.opb.org/news/article/trump-environmental-policy-rollback-northwest/

Cooke Aquaculture pays 2.75 Million dollar fine for net pen collapse

The company responsible for the net pen collapse that released large numbers of Atlantic Salmon into Puget Sound has settled out of court in advance of a Monday court date.

Cooke Aquaculture has reached a settlement to pay $2.75 million in legal fees and to fund Puget Sound restoration projects, putting an end to a Clean Water Act lawsuit that followed the 2017 collapse of one of the fish-farming company’s net-pen structures. – Seattle Times. Read the full article here and consider subscribing to the Times and keeping local reporters working.

https://www.seattletimes.com/seattle-news/environment/cooke-aquaculture-settles-lawsuit-with-wild-fish-advocates-over-net-pen-collapse/

These funds will go to help pay legal expenses, and the rest of the funds will go to the Rose Foundation to fund environmental projects to protect wild salmon and killer whales in Puget Sound, as well as WFC’s litigation expenses. Cooke also agreed to change their practices and address additional dangers identified in the course of the lawsuit, according to Wild Fish Conservancy, who brought the lawsuit.

“This is truly a victory for the future of our sound,” said Kurt Beardslee, executive director of Wild Fish Conservancy. “Open water net pen aquaculture is a risky business, and thanks to this settlement we are one step closer to getting this dirty industry out of Puget Sound once and for all. This was long in coming. Last year, the public demanded an end to Atlantic salmon net pens. Just last week, thousands of people spoke out against switching these farms to different species. Now a federal judge ruled that Cooke broke the law. It’s time for this industry to leave Puget Sound.”

Cooke’s operations continue to put wild salmon and the health of Puget Sound at risk. Just weeks ago, one of the Bainbridge Island net pens began sinking due to a hole in a flotation pontoon; luckily, the damaged portion was not stocked with Atlantic salmon at the time but may have resulted in an escape were the pens occupied. Marine engineer Tobias Dewhurst, an independent expert testifying on behalf of Wild Fish Conservancy, reviewed conditions at each farm site and determined “conditions at each of its eight sites exceeded the maximum rated conditions specified by the net pen manufacturer,” and that as a result “pens and cages operated by Cooke were at risk of failure.” Even given subsequent changes, Dewhurst concluded, “certain remaining sites appear to be operating in conditions that exceed those specified by the net pen system manufacturers,” and therefore “may be at risk of partial or catastrophic failure.”

http://www.wildfishconservancy.org/cooke-aquaculture-to-pay-2.75-million-ending-wfc-lawsuit-over-net-pen-collapse-1

Recently, Cooke has partnered with the Jamestown S’Klallam to reopen the net pens in Port Angeles to raise native, but genetically modified steelhead. While the danger of these fish escaping and somehow altering native stocks is dramatically lessened, there is still the issue raised by Wild Fish Conservancy, of destruction of the environment in and around the feeding pens, along with possible affects of raising large quantities of fish in a small enclose. Virus and parasites are traditionally the concern, yet the Tribe has claimed that they are working on mitigation techniques. The Tribe has been researching raising these steelhead at the NOAA research facility at Manchester for the last few years. Their goal is to do this as environmentally responsibly as possible giving current scientific best practices. Many in the environmental community remain unconvinced that this won’t become another problem.

The Department of Fish and Wildlife has issued a mitigated determination of non-significance, which allowed only  a 21-day comment period. This requires neither a full environmental assessment nor environmental impact statement under the State Environmental Policy Act. Such an assessment would have considered the risks of diseases, pollution, further escapes and collapses, and the potential harm to federally-listed native steelhead. Kurt Beardsley of Wild Fish Conservancy said of the lack of EIS, “The 2017 collapse revealed that these pens are dramatically under-built for conditions in Puget Sound, and that Cooke’s recovery plan in the event of escapes was woefully inadequate. More escapes would directly threaten our wild salmon, steelhead trout, and endangered killer whales. Without a full EIS, the state cannot address the evidence from their investigations and WFC’s.

The Tribe at least brings a local group that has a a track record of being  concerned with long term viability of the resource, and is not going to be moving operations like many international corporations do.

Just to the north, on the Canadian Coast, a long running battle over farmed fish has pitted environmental scientist and activist Alexandra Morton against the fish farming industry. She has been working with the local tribes in documenting a horribly destructive virus that has appeared from Norway in both the local wild fish and the farm raised fish.

While Washington state passed legislation banning PRV-infected farm salmon, it is still an unknown as to whether the virus is affecting the ever decreasing numbers of wild chinook that are the primary food of the resident orcas. Reopening net pens here could provide a vector for fish carrying the disease that could be passing through the infected waters to the north on their way here.

(more on this story at The Georgia Straight News)

In October, Cooke paid another large fine in Maine for multiple violations of their laws for fish farming.  https://www.seafoodsource.com/news/aquaculture/cooke-to-pay-fine-for-overstocking-maine-salmon-farms-not-conducting-environmental-testing

In April, Cooke paid over $300,000 for water quality violations here in Washington.

Clallam County Planning Division Says No to Dungeness Spit Jamestown S’Klallam Oyster Farm

While a small victory for the opponents of the proposed oyster farm inside Dungeness Spit, it does not mean that the Hearing Examiner will actually follow their recommendation. The Planning Division stated that the farm is not consistent with the Natural Shoreline Designation, does not meat the CUP (Conditional Use Permit)  Criteria, and will negatively impact wildlife at Dungeness National Wildlife Refuge.

Oddly, though the current area is natural, because the location has been used in the past for oyster farming, the staff found that there would be no cumulative impacts. That flies in the face of the recent Army Corp of Engineers court loss, that discovered unpublished Army Corp scientific documents that clearly delineated the ongoing destruction of near shore from continuous use.

The staff also points out that “Based on the density of birds that visit the DNWR and their sensitivity for disturbance while migrating and foraging, even small impacts at this wildlife refuge could result in substantial detrimental effects (emphasis mine) to the public interest.”

The objective of the Natural designation are intended to preserve, maintain or restore such a shoreline as a natural resource relatively free of human influence; to discourage or prohibit those activities which might destroy or degrade the natural characteristics which make these shorelines unique and valuable. The applicant should address how the proposal with up to 80,000 on-bottom bags with year round gear maintenance of up to 6 people visiting the site for up to 6 hours 6 times a month within the migration and wintering periods for shorebirds and waterfowl is an appropriate use in the Natural Designation located off the Dungeness National Wildlife Refuge. (emphasis mine)

It seems it would be a good time for our state legislators and DNR  to step up, and work with the Tribe to swap this area for another spot. The risk of long term damage to our dwindling stocks of shorebirds, marine birds, herring, sand lance and the like at this critical location, close to the estuary and the preferred feeding area of nesting birds from Protection Island, poses the threat of irreversible  harm.

 

 

 

Federal judge rules Army Corps aquaculture permit is unlawful in Washington State.

In a surprise ruling with wide ranging consequences, a federal judge has ruled that the Army Corp of Engineers issuance of Nationwide Permits in the lower 48 (NWP48) authorizing commercial shellfish aquaculture is illegal. The suit, brought by The Coalition to Protect Puget Sound Habitat, a group that has been fighting large-scale shellfish aquaculture for years, and joined by the Swinomish Tribe, was focused against the Army Corp and Taylor Shellfish, along with the industry group, The Pacific Coast Shellfish Growers Association.

The plaintiffs argued that the Corps failed to comply with the Clean Water Act (“CWA”), the National Environmental Policy Act (“NEPA”), and the Endangered Species Act (“ESA”) when it reissued NWP 48 in 2017. They requested that the decision to adopt NWP 48 in Washington be overturned and that the Corps be required to comply with the environmental statutes before issuing any new permits  for commercial shellfish aquaculture in this State.

The court found in it’s blistering conclusions, “…that the Corps has failed to adequately consider the impacts of commercial shellfish aquaculture activities authorized by NWP 48, that its conclusory findings of minimal individual and cumulative impacts are not supported by substantial evidence in the record, and that its EA does not satisfy the requirements of NEPA and the governing regulations…the Court holds unlawful and sets aside NWP 48 insofar as it authorizes activities in Washington.” (emphasis mine)

Going beyond just the issue of the environmental consequences the judge stated that “The federal defendants state that additional …remedy should be permitted once the seriousness of the agency’s error is determined. The intervenors (the Corps and Taylor Shellfish) assert that (throwing out the permits and the Corps previous rulings) would cause disruption in the Washington shellfish farms and industry, including significant impacts to employees and the communities in which they live.Neither tact is compelling. The substantive defects in the agency’s analysis when adopting the 2017 NWP are significant.” (emphasis mine)

The case centers around whether or not the large scale conversion of natural shorelines to commercial aquaculture, happening now all around lower Puget Sound and in the Strait of Juan de Fuca, is more than “minimal” damage to the environment. Siting case law in relevant lawsuits in the Yellowstone Park area, the environmental group managed to persuade the judge that the Army was allowing something much more than minimal damage.

As stated by the plaintiffs, “Federal agencies are required to do an environmental assessment (“EA”) of their proposed action, providing a brief discussion of the
anticipated environmental impacts and enough evidence and analysis to justify a no-significant impact determination.  If the agency, after conducting an EA, is unable to
state that the proposed action “will not have a significant effect on the human environment,” a more detailed and comprehensive environmental impact statement (“EIS”) must be prepared. They also argued that the case law stated that if the Corps’ ruling was found to be “arbitrary, capricious, an abuse of discretion” and lacking in a scientific basis, that it must be thrown out.

The court found that , “… there is insufficient evidence in the record to
support the agency’s conclusion that the re-issuance of NWP 48 in 2017 would have minimal individual and cumulative adverse impacts on the aquatic environment for purposes of the CWA and that the Corps’ environmental assessment does not satisfy NEPA’s requirements.”

They judge then went on to point out that “the Corps acknowledges that commercial shellfish aquaculture activities can have adverse environmental impacts…marine debris is a serious impact on the marine environment…and that commercial shellfish aquaculture activities can result in conversion of substrates (e.g. mudflats to gravel bars), impacts to submerged aquatic vegetation, alteration in aquatic communities from native to non-native shellfish species, and water quality impacts from harvest activities.”

Given those findings, the judge went on to say, “Ignoring or diluting site specific,
individual impacts by focusing solely on a cumulative, landscape-scale analysis is not
consistent with the governing regulations.”

The scientific documents that the Corps presented as justification for it’s actions came under blistering criticism from the judge. “According to the Corps’ own summary of the paper, the authors evaluated only the effects of oyster aquaculture activities on submerged aquatic vegetation. The paper itself shows that Dumbauld and McCoy (a supposed scientific study that the Corps and Taylor were using) were studying the effects of intertidal oyster aquaculture on the seagrass Zostera marina. There is no discussion of the impacts on other types of aquatic vegetation, on the benthic community, on fish, on birds, on water quality/chemistry/structures, or on substrate characteristics. There is no discussion of the subtidal zone. There is no discussion regarding the impacts of plastic use in shellfish aquaculture and only a passing reference to a possible side effect of pesticide use. The Corps itself does not remedy these deficiencies: although it identifies various resources that will be adversely impacted by issuance of the national permit (along with resources that may benefit from shellfish production), it makes virtually no effort to characterize the nature or degree of those impacts. The Decision Document’s “Impact Analysis” consists of little more than an assurance that district engineers will consider the direct and indirect effects caused by the permitted activity on a regional or case-by-case basis.”

The judge went on to say, “In this case, the Corps acknowledged that reissuance of NWP 48 would have foreseeable environmental impacts on the biotic and abiotic components of coastal waters, the intertidal and subtidal habitats of fish, eelgass, and birds, the marine substrate, the balance between native and non-native species, pollution, and water quality, chemistry, and structure, but failed to describe, much less quantify, these.  The Corps cites the two Dumbauld papers for general statements regarding the positive or negative effects of shellfish aquaculture on certain aquatic resources or characteristics (focusing on seagrass), but it makes no attempt to quantify the effects or to support its conclusion that the effects are no more than minimal.”(emphasis mine).

As reported on some months ago in this blog, a draft cumulative impact statement, which only surfaced due to a discovery in this case,  “…generated in February 2017 dedicated twenty-five pages to discussing the wide range of work and activities covered by NWP 48 and noting the species dependent variability in cultivation techniques, gear, and timing. These variations gave rise to a wide array of effects on the aquatic habitat, none of which is acknowledged or evaluated in the national Decision Document.” (emphasis is mine).

The judge goes on, in plain language, “A reasonable mind reviewing the record as a whole would not accept Dumbauld and McCoy’s limited findings regarding the
landscape-level impact of oyster cultivation on a species of seagrass in the intertidal zone as support for the conclusion that entire ecosystems are resilient to the disturbances caused by shellfish aquaculture or that the impacts of those operations were either individually or cumulatively minimal.” The judge sites decisions back in coal country where the cumulative impacts of mountain top removal are similar and long lasting. “The governing regulations expressly impose upon the Corps the obligation to consider the ongoing effects of past actions when conducting a cumulative impacts analysis.”

The “NEPA and the CWA were enacted because humans were adversely affecting the environment to a noticeable and detrimental extent…Noting that a particular environmental resource is degraded is not an excuse or justification for further degradation. The Corps must analyze the individual and cumulative impacts of the proposed activity against the environmental baseline, not as a percentage of the decades or centuries of degrading activities that came before.

As to the use of pesticides by the industry, the judge has additional harsh criticism,”The Corps makes a similarly untenable argument whenever the use of pesticides in a
shellfish operation permitted under NWP 48 is discussed. While acknowledging that these substances are used and released into the environment during permitted activities, the Corps declines to consider the environmental impacts of pesticides because they are regulated by some other entity… Even if the Corps does not have jurisdiction to permit or prohibit the use of pesticides, it is obligated to consider “other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions.” The Corps’ decision to ignore the
foreseeable uses and impacts of pesticides in the activities it permitted on a nationwide basis does not comport with the mandate of NEPA or with its obligations under the CWA. Having eschewed any attempt to describe the uses of pesticides in commercial shellfish aquaculture or to analyze their likely environmental impacts, the decision to permit such activities through NWP 48 cannot stand.” (emphasis mine)

“The record is devoid of any indication that the Corps considered regional data,
catalogued the species in and characteristics of the aquatic environments in which commercial shellfish aquaculture activities occur, considered the myriad techniques, equipment, and materials used in shellfish aquaculture, attempted to quantify the impacts the permitted activity would likely have on the identified species and characteristics, or evaluated the impacts of the as-yet-unknown regional conditions…Faced with incredible diversity in both the environment and the activities permitted under NWP 48, the Corps effectively threw up its hands and turned the impact analyses over to the district engineers.”

In looking at the problem of plastic pollution in aquaculture the judge was additionally critical.”The Corps’ analysis with regards to plastic debris discharged into the marine environment is even more problematic. The Corps acknowledges the many public comments raising concerns about the introduction of plastics into the marine food web, but relies on the fact that “[d]ivision engineers can impose regional conditions to address the use of plastics” in response to these concerns. The Seattle District, for its part, declined to quantify the impact of plastics, instead noting that “it would not be a practicable solution to regionally condition NWP 48 to not allow the use of PVC and HDPE gear as there are no current practicable alternatives to use of the materials…The CWA requires the Corps to make minimal adverse effect findings before issuing a general permit. If, as appears to be the case with regards to the discharge of plastics from the permitted operations, the Corps is unable to make such a finding, a general permit cannot (be) issue(d). The Corps has essentially acknowledged that it needs to individually evaluate the impacts of a particular operation, including the species grown,
the cultivation techniques/gear used, and the specific location, before it can determine the extent of the impacts the operation will have.”

The decision is not trivial. It rips apart industry arguments made over the last decade that eelgrass recovery in aquaculture farms is a minor issue. The aquaculture industry and Taylor Shellfish in particular has put itself at the head of county agencies supposedly in the business to protect the nearshore from harm and then used these faulty scientific studies to promote their position.  The Jefferson County Marine Resources Committee, which claims on it’s web page to have the mission, “to protect and restore the marine environments of East Jefferson County by raising community awareness of issues…” has been chaired by an aquaculture industry spokesperson who routinely has used these same discredited arguments to suppress any discussion of negative impacts on the nearshore the MRC claims to protect.  The Committee has meekly gone along with the bullying tactics of the Taylor representative at public meetings, unwilling to push back on what the spokesperson has claimed to be ‘scientific  studies’.  The Committee in fact sponsored a ‘aquaculture educational day” to promote these same, now discredited scientific studies, offering no substantial criticism to the statements of the industry. The lack of any counter balance to the industry’s PR blitz angered many in the environmental community on the Olympic Peninsula toward this committee that had a long history of standing to protect the nearshore. The decision to not include substantial criticism of the industry led the long time environmental representative on the committee to resign.

The outcome of this case is unclear at the time of this writing. However, it will likely have a substantial effect on future shellfish farm permits, and may force the closure of some larger farms that were recently permitted, until such time as adequate scientific study on their effects is done. The ruling ends with the judge throwing out the Army’s ability to issue permits in Washington. However, the judge does say to Taylor and others that they can apply for individual permits. The Court has the ability to allow a “period of time in which growers can avail themselves of the process before the existing permits would be invalidated or to fashion some other equitable remedy to minimize both the risks of environmental harm  and any disruptive consequences.” So there is some wiggle room for the growers to get some activities going to mitigate the effects of this ruling.

This case also fully vindicates the environmentalists’ concerns over the ever expanding industry, it’s conversion of pristine shorelines to monoculture farming and the allies of this industry in city, county and state government. The industry is not down and out yet. It’s worth noting that Taylor has apparently spent tens of thousands of dollars lobbying back in Washington D.C. and is likely to support Republican efforts to roll back the Clean Water Act to eliminate the local nature of permitting to favor national ones. Given this ruling, that likely is a losing tactic.

This blog will continue to follow this breaking story with further updates as we receive them.

 

 

 

 

 

 

Their back! Cooke Aquaculture that is.

Proposal made to raise steelhead at area fish farms
The company whose collapsed fish farm off Cypress Island in August 2017 allowed hundreds of thousands of Atlantic salmon to be released into the region’s waters may use its remaining net pens to raise steelhead trout.  That company, Cooke Aquaculture, has applied for permits to begin raising steelhead at its floating facilities in Puget Sound, where the state Legislature no longer allows the raising of Atlantic salmon. On Tuesday, the state Department of Fish & Wildlife announced plans to approve those permits. Fish & Wildlife also determined the proposal doesn’t warrant an environmental impact statement, or EIS, under the state Environmental Policy Act. “This proposal will likely not have a significant adverse impact on the environment,” Fish & Wildlife documents state. Kimberly Cauvel reports. (Skagit Valley Herald)

Jamestown S’Klallam proceeding with Dungeness Spit Aquaculture Permit

Clallam County Department of Community Development has published that the Jamestown S’Klallam have applied to restart their permit application for an aquaculture permit inside the Dungeness Spit Wildlife Refuge. This highly controversial application has drawn criticism from the Refuge manager, in a detailed response to the previous application. (See below) Critics of the application have stated that any non Tribal organization wishing to seek to establish this kind of operation within a refuge would run into serious opposition from conservation organizations, and likely Tribes as well,  but due to this being put forward by the Tribe, criticism has been muted.  It will  be interesting to see how this plays out. With shorebird populations in decline, especially those using Protection Island and feeding underwater in this very location, it’s hard to understand how this will be allowed.  Then there is the growing problems of ocean acidification and the European Green Crab invading not far to the west of this spot. Could the State perhaps offer a trade off of shoreline to protect the Refuge?

DCD have tentatively scheduled the Public Hearing before the Clallam County Hearing Examiner for this matter for Thursday November 21, 2019 at 1 p.m..

More can be found at

http://websrv2.clallam.net/tm_bin/tmw_cmd.pl?tmw_cmd=StatusViewCase&shl_caseno=SHR2017-00011&projectcasetag=Y

Also this web site has published the letter of concern from the Refuge Manager.

https://olyopen.com/2018/04/10/concerns-raised-over-dungeness-spit-oyster-farm-application/

As stated by the Department of Interior letter, “The shores and tidelands in this area provide some of the most important wildlife habitat and supports the highest density of waterfowl and shorebirds within the refuge….These shorelines also support one of the largest Brandt haul out sites in the state of Washington….Shorebird densities are highest within the action area and the adjacent lagoon on Graveyard Spit.”

“Human-caused wildlife disturbance and habitat loss are two of the most pervasive threats to shorebird and waterfowl use of the Salish Sea….very little information is available on entrapment resulting from aquaculture structures.”

The Jamestown S’Klallam Tribe (JST) wants to proceed with the application after the Government to Government meeting with U.S. Fish & Wildlife (USFW). In a letter dated August 6, 2019

U.S.F.W rescinded their previous letter dated May 22, 2019 (See item B1.83 & B2.1 below for more information).

DCD will be providing notice and a SEPA threshold determination in the next couple of weeks.

We have tentatively scheduled the Public Hearing before the Clallam County Hearing Examiner for this matter for Thursday November 21, 2019 at 1 p.m..

 

 

The Battle Over Fish Farming In The Open Ocean Heats Up, As EPA Permit Looms – OPB

The Feds look to open up aquaculture into the open ocean. While this project is in the Gulf of Mexico, the threat to us here is very real. After watching the incredibly incompetent way that our legislators allowed the industry in this state to function with virtually no over-site because they fashioned the laws back in the 70s/80s to split enforcement  between two different government agencies (Department of Ecology and DNR) ending in the disastrous blow out of the Cypress Island pens. This finally led to regulation and a shutting down of the industry in this state, and we will never know the true cost of what allowing these pens into our waters meant to our endangered salmon. Old timers I interviewed talked of how wild runs collapsed in the Agate Pass area after the pens went in to the south side of Bainbridge Island. They suspected the wild fish were somehow compromised by the pens. While many other issues were simultaneously showing-up, rampant development, over-fishing in the Strait, etc. the old timers thought the timing highly suspicious. Now this. Whatever could go wrong?

States control up to three miles offshore from their coastlines, but between three and 200 miles falls under federal control. Attempts to introduce aquaculture in federal waters have so far been stymied by concerns about aquaculture’s impact on ocean ecosystems and wild fisheries.

https://www.opb.org/news/article/npr-the-battle-over-fish-farming-in-the-open-ocean-heats-up-as-epa-permit-looms/

Proposed EPA Rules Could Limit State And Tribal Power To Block Infrastructure Projects -OPB

Over the last few years, since Trump came to power, I have been hearing about companies, some here in the NW engaged in shellfish farming, that have been quietly spending tens of thousands of dollars lobbying the Federal government to strip away the capability of local jurisdictions, such as county, state and tribal governments, to create local rules that could stymie the businesses operations or licensing by the federal government, under the Clean Water Act. A goal of theirs has been to take away the ability of local environmentally concerned organizations to sue, other than at the federal level.  Now, it appears the Trump administration is acting on their lobbying efforts. Think about fish farming, pulp mills, or any other activity covered under the Clean Water Act.

The rules specifically would restrict these non-federal governments’ authority to review the water quality impacts of projects that require a federal permit or license. These projects range from pipelines to hydropower facilities to dredging — any development that result in “discharge” into U.S. waters.

DATES: Comments must be received on or before October 21, 2019. ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ– OW–2019–0405, at https://www.regulations.gov.

FOR FURTHER INFORMATION CONTACT: Lauren Kasparek, Oceans, Wetlands, and Communities Division, Office of Water (4504–T), Environmental Protection Agency, 1200 Pennsylvania Avenue NW, Washington, DC 20460; telephone number: (202) 564–3351; email address: cwa401@epa.gov.

Read the whole legal document (very long, very difficult to follow if not a environmental lawyer) at

Click to access cwa401certification_2060-af86_nprm_20190807_prepublication_version.pdf

https://www.opb.org/news/article/federal-water-quality-rules-energy-infrastructure/

State taking comment on permits for Atlantic salmon fish farms – PDN

Get your comments in now.

How to provide comments

We will accept comments from Dec. 27, 2018 until 11:59 p.m. on Feb. 25, 2019.

Online (preferred): Submit your comments through our online comments form.

http://ws.ecology.commentinput.com/?id=7kdj4
By mail: Rich Doenges
Washington State Department of Ecology
PO Box 47600
Olympia, WA 98504

The state Department of Ecology is taking comment now on permits for four Cooke Aquaculture Atlantic salmon farms — three in Kitsap County and one in Skagit Bay. Farming Atlantic salmon in net pens is officially banned from Puget Sound starting in 2022. Ecology is using the investigation from the 2017 Cypress Island net pen collapse to mandate more protective permit requirements. Cooke Aquaculture, the only company farming Atlantic salmon in Washington state, lost its lease in Port Angeles in 2017. Ecology is accepting comments on the permit through Feb. 25 and will make a final determination after reviewing them. Information on the draft permit, and a link to comment online, is available here. (Peninsula Daily News)

State taking comment on permits for Atlantic salmon fish farms

Northwest Watershed Institute study suggests reason behind eagle gathering at Dabob Bay – PDN

The Peninsula Daily News has a story about a new research paper created by Peter Bahls of the Northwest Watershed Institute (NWI).  Bahls and biologist Heather Gordon wrote the paper, “Bald Eagles, Oyster Beds, and the Plainfin Midshipman: Ecological Relationships in Dabob Bay,” which explores the relationship of eagles, oyster beds and a kind of forage fish called the Plainfin Midshipman. Read this fascinating story about what new research by the NWI has shown about the relationships, and how the Jamestown S’Klallam Tribe are working with the data to better protect the eagles and the spawning fish.

https://www.peninsuladailynews.com/news/northwest-watershed-institute-study-suggests-reason-behind-eagle-gathering-at-dabob-bay/

 

 

Zangle Cove Lawsuit Issues Bombshell Findings Against Aquaculture

The case moving through the courts at the present time to challenge the lack of Hydraulic Code Permits for the destruction of shorelines by aquaculture got a surprise boost yesterday.

Findings that contradict the testimony of the Army Corp of Engineers and Taylor Shellfish show that in 2017 the Army Corps had to create a Cumulative Impact Analysis that showed conclusively that there would be significant impacts from adoption of a Nation Wide Aquaculture Permit. The 117 page draft concluded that their would be significant impacts if adopted. The Corps has categorically denied such impacts.

The Corps admits that the aquaculture is likely to “adversely affect designated critical habitat for several species listed under the ESA including Puget Sound Chinook salmon, Hood Canal summer chum salmon and Puget Sound Steelhead…Given the magnitude of the the impacts in acreage the importance of eelgrass to the marine ecosystem and the scale of the aquaculture impacts relative to other stressors, the impacts are considered significant.”

The letter goes on: The proposed action is inconsistent with State requirements under the SMA to protect forage fish spawning habitat.”

The debate has been that the Army Corps of Engineers nor the State have ever considered the cumulative impact of aquaculture permitting on the overall shoreline and ecosystem of Puget Sound, focusing only on individual parcels. Now we know that they did consider the impact, and found it lacking.

The next steps on this lawsuit should be very interesting, judges don’t usually go against findings of fact such as this, and the Governor’s Orca Recovery Task force is currently about to publish it’s findings for saving habitat for the Orca and it’s food sources.

The full text of the findings are here:

http://users.neo.registeredsite.com/3/7/5/12218573/assets/2017_NWP48_Draft_Cumulative_Imapct_Analysis.pdf

Video on NOAA work to breed oysters resistant to ocean acidification – Crosscut & PBS

Local PBS show ReInventors highlights the work of NOAA Manchester’s research facility as they race to find a hybrid oyster that can survive ocean acidification. A very good quick look at the problem, with animation, and the possible solution. If we are going to have seafood survive, this will likely hold the possibility. As it is currently going, we don’t have long before the oceans will be too acidic for shellfish to survive.

The story

https://crosscut.com/2018/10/can-these-super-oysters-survive-our-screwed-oceans

The video

https://youtu.be/WP8J0-90VoM

After a decade of litigation, NOAA Fisheries and EPA will prepare a biological opinion on harm caused by Atlantic salmon net pens

From the Wild Fish Conservancy Press Release this morning. It’s unfortunate that those of us concerned about this issue needed to spend 10 years trying to force them to get to this simple issue. NOAA Fisheries have been one of the biggest boosters of net pen Atlantic salmon, never studying the wider effects of pens beyond a few hundred yards away from them. There has never been a wholistic approach to studying the effects of fish waste, food waste, chemicals added to the water, fish escapement, nor the issue that wild fish are attracted to the pens by food. What we learned from the net pen collapse last fall, was that the claims of the industry, repeated by spokesmen for Taylor Shellfish (who support net pens), that there was no way that Atlantic salmon would survive after escapement, were nothing but wishful thinking. Atlantic salmon from the pens were found far up the Skagit River basin and along the north outer shore of Vancouver Island. The misinformation campaigns of these industries that put profit ahead of environment are stunning in their audacity.


After a decade of litigation, NOAA Fisheries and EPA make the 11th hour decision to prepare a biological opinion on harm caused by Atlantic salmon net pens to ESA- listed salmon and steelhead.

The agencies have finally begun formal consultation under the Endangered Species Act (ESA) to evaluate the potential harm caused by Atlantic salmon net pens in Puget Sound October 11th, 2018

Duvall, WA – On the eve of court proceedings over a legal battle Wild Fish Conservancy initiated in 2015, NOAA Fisheries and EPA have entered into formal consultation under the Endangered Species Act, consultation that will lead to the issuance of a biological opinion.

Under the Endangered Species Act, a biological opinion evaluates the extent of harm a proposed action will have on threatened or endangered species and whether such harm could jeopardize the continued existence of the species. Biological opinions also include conditions for monitoring and reducing harmful impacts to protected species.

Considering the abundant scientific evidence that open-water Atlantic salmon aquaculture may harm threatened and endangered salmonid species, Wild Fish Conservancy first argued that formal consultation and a biological opinion was necessary back in 2008, when we argued against the agencies’ decision that Atlantic salmon net pens were ‘not likely to adversely affect’ threatened and endangered species. We won that case in 2010, with the court ruling that NOAA and EPA had failed to use the best available science when making their decision and must reconsider whether a biological opinion is necessary.

Less than one year later, after a brief consultation, NOAA and EPA again decided that a biological opinion was unnecessary. This decision was shortly followed by a large-scale disease outbreak in Atlantic salmon net pens off the coast in Bainbridge Island in 2012, which killed over 1 million pounds of farmed Atlantic salmon during a time when juvenile wild salmon were out-migrating through Puget Sound.

Wild Fish Conservancy again challenged the agencies’ decision to avoid a biological opinion in 2015, a case that prompted NOAA and EPA last week to announce their intention to re-initiate consultation and finally prepare a biological opinion. That decision came only after the Court soundly rejected the agencies’ efforts to dismiss the case and ruled that the duty under the Endangered Species Act to re-initiate consultation does apply to EPA’s underlying action.

Since the case was filed in 2015, we have learned far more about the potential for harm the Atlantic salmon net pen industry presents to wild salmon and steelhead. In 2017, a collapsed net pen off the coast of Cypress Island released over 260,000 farmed Atlantic salmon into Puget Sound, nearly all of which are estimated to have been infected with Piscine Reovorius, a highly contagious and potentially lethal virus that may infect wild salmon. A study in 2018

demonstrated that PRV leads to debilitating disease in Chinook salmon, the primary food source of endangered Southern Resident killer whales.

This case comes at a time when key provisions of the Endangered Species Act are under threat in the United States Congress and underscores the monumental importance of the ESA, an act that has been critical in providing key protections to over one thousand threatened and endangered species across the country.

“While it shouldn’t have taken ten years of litigation for our agencies to realize the necessity of a biological opinion,” said Kurt Beardslee, Wild Fish Conservancy’s Executive Director, “I am glad to hear they have decided to change course, and I am hopeful that a biological opinion will lead to conditions and terms that will limit and monitor the harm caused by net pens to ESA-listed salmon and steelhead.

“Taking the utmost precaution is necessary to avoid the extinction of imperiled Pacific salmon and steelhead species, especially when considering the dire plight of Chinook salmon and the Southern Resident killer whales that are starving due to their struggling population.”

Contact

Kurt Beardslee, Executive Director, 425.788.1167/kurt@wildfishconservancy.org

About

Wild Fish Conservancy is a science & research conservation non-profit dedicated to the preservation, protection & restoration of wild fish ecosystems in the Pacific Northwest. We are headquartered in Duvall, WA. Learn more at wildfishconservancy.org

Wild Fish Conservancy is represented in this matter by the law firm of Kampmeier & Knutsen, PLLC, with offices in Portland, Oregon and Seattle, Washington.

EVENT: Industrial Aquaculture Discussion – Sat Oct 13th 3 to 5 PM

aquaculturepanelposterprintpdf

Aquaculture MEDIA RELEASE – 2 October 2018

MEDIA RELEASE – 2 October 2018

CONTACT:         Darlene Schanfald, Vice-Chair

Sierra Club North Olympic Group

360-681-7565    darlenes@olympus.net

INDUSTRIAL AQUACULTURE  

FOOD or FOLLY?   LOSING THE WILD?

Saturday    13 October 2018     3–5 PM

Historic Dungeness Schoolhouse 

2781 Towne Rd, Just off E. Anderson Road

The Sierra Club’s North Olympic Group and the Sierra Club Chapter Water Salmon Committee invites the public to join them for this important forum about how our oceans are being commercialized for the few and the losses that follow.

We are pleased to have the following speakers present their work from years of experience.

Kurt Beardslee, Executive Director, Wild Fish Conservancy (WFC)

The Success of the Our Sound, Our Salmon Campaign: Phasing Out Atlantic Salmon Aquaculture in Puget Sound. 

Kurt Beardslee is the executive director and co-founder of the Wild Fish Conservancy. For over a decade Kurt and his science staff have investigated the substantial risk open-water Atlantic salmon aquaculture places on the Pacific Northwest’s wild salmon.

In spring of 2017, WFC launched the Our Sound, Our Salmon (OSOS) campaign with the goal of phasing out Atlantic salmon net pens from Puget Sound.  The OSOS campaign was fundamental to the passage of Washington’s recent net pen legislation marking the largest legislative removal of Atlantic salmon net pens in the world.

Following the 2017 Cypress Island collapse of Cooke Aquaculture pens that released 260,000 penned Atlantic salmon into the wild, WFC staff collected tissue samples from the escapees for that revealed 100% positive test results for Piscine Reovirus (PRV), a highly contagious and debilitating salmonid disease. Genetic sequencing revealed the virus to be of Icelandic origin marking the first time this foreign strain of the virus was found in Pacific waters.

In his talk, Kurt will discuss the numerous risks posed by farming Atlantic salmon in open-water net pens as well as potential land-based closed containment solutions for this industry. He will give a brief overview of WFC’s current litigation to hold Cooke Aquaculture accountable under the Clean Water Act for releasing 260,000 non-native Atlantic salmon into Puget Sound.  He will also discuss WFC’s ongoing Endangered Species Act (ESA) suit against the federal government for its failure to adequately protect ESA-listed species from the harm caused by industrial Atlantic salmon net pens.

 

Laura Hendricks, Founding Director Coalition To Protect Puget Sound.

Shellfish and Disappearing Beaches

Over the last 11 years, Laura Hendricks’s Coalition has educated the public and regulators on shellfish aquaculture’s harm to WA State’s marine life. Hendricks represented citizens against the shellfish industry at a hearing before the Washington State Shorelines Hearings Board and won the case to protect eelgrass, a WA State Appeals Court precedent-setting case.

Hendricks will give an update about pending legal action by the Coalition to Protect Puget Sound Habitat, Protect Zangle Cove, and Wild Fish Conservancy filed against the WA Department of Fish and Wildlife (WDFW).  That suit demands an end to WDFW’s exemption of industrial shellfish aquaculture projects from Hydraulic Project Approvals (HPA).  HPAs are state standards designed and required to protect fish and marine habitats.

“With threatened Southern Resident killer whales and endangered native salmon at extreme risk, our state agencies have failed to implement the environmental protections that are critical to the broad scale ecological recovery of Puget Sound,” says Patrick Townsend, president of Protect Zangle Cove. “The action we are taking today is one important step toward restoring sanity to the recovery process. We must protect the tidelands from further loss of ecological function or we will see the loss of iconic species so important to the people of Washington State.”

Alfredo Quarto, Co-director and Co-founder of Mangrove Action Project (MAP)

Question Your Shrimp, A consumer Awareness Campaign

For twenty-five years, Alfredo Quarto has worked with indigenous cultures around the world helping them restore their mangrove forests and way of life, prior to corporations having destroyed their ecosystems to industrialize the raising of shrimp. He will have a short video about these villages and mangrove trees.

Quarto is a veteran campaigner with over 40 years of experience in organizing and writing on the environment and human rights issues.  Formerly an aerospace engineer, his experiences range over many countries and several environmental organizations, with a long-term focus on ocean issues, forestry, indigenous cultures, and human rights.  Prior to MAP, he was the executive director of the Ancient Forest Chautauqua, a multimedia traveling forum with events in 30 West Coast cities on behalf of old-growth forests and indigenous dwellers.

Anne Mosness, Go Wild Campaign

Current and Pending Efforts of the Federal Government to Raise Penned Fish

Anne Mosness has been tracking the federal NOAA Department of Commerce in its push to raise penned salmon in offshore waters, beyond jurisdictions and regulations of states.  She will speak on the current pending efforts, and losses, of such government efforts.  The public will hear about the recent Center For Food Safety legal win for fishing and public interest groups that challenged the Department of Commerce’s rules permitting industrial aquaculture offshore in U.S. federal waters.

Anne Mosness is a fisherwoman that fished Copper River and Bristol Bay, Alaska for decades, a multi-general family profession.  She secured a position with the Institute for Agriculture and Trade Policy and founded the Go Wild Campaign. She has worked for several other national environmental and food organizations, received a fellowship from the W.K. Kellogg Foundation, represented US fisheries at UN forums and Slow Food/Slow Fish conferences in Italy, and other global and national events focused on sustainable foods and fishing, seafood labeling, organic certification, marine ecosystem health. Anne has been a long time contributor to the Puget Consumer Coop’s Sound Consumer magazine.  Her latest article in the PCC magazine is entitled,  “Wild salmon, killer whales and us” published July, 2018.

Cosponsoring the event are Friends of Miller Peninsula State Park, Olympic Environmental Coalition, Olympic Forest Coalition. and Protect Peninsula’s Future.

The October 13 event is free.  Handouts from the sponsoring and presenting organizations will be available.  Coffee and tea will be served.

####

 

 

 

 

 

 

 

More on the impact of farmed fish – The Nation

As if we needed more evidence. The Nation brings another damning indictment of raising farmed salmon. This time from Chile.

“The sea around the salmoneras is dead. The waste they produce falls to the seabed. The waters here used to be so clean.…”

The Eco-Disastrous Salmon

Farmed salmon is Chile’s second-biggest export. Twice, it’s proved an environmental hazard. By Cédric Gouverneur

https://www.thenation.com/article/the-eco-disastrous-salmon/

 

 

Mounting evidence affirms decision of Ecology to deny use of pesticide in shrimp farms – WA Dept of Ecology

The Department of Ecology has denied a request by oyster growers to use a pesticide called Imidacloprid on shellfish beds in Willapa Bay and Grays Harbor. This little known issue exploded into the open a few years ago when a scientist for the Department of Ecology, Rich Doenges, the water-quality manager for the state Department of Ecology signed off on use of the chemical even though the instructions for it clearly stated

“This product is highly toxic to aquatic invertebrates. Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark.”

Ecology noted the following environmental impacts as key reasons for denying the permit:

  • Significant, unavoidable impacts to sediment quality and benthic invertebrates.
  • Negative impacts to juvenile worms and crustaceans in areas treated with imidacloprid and nearby areas covered by incoming tides, including high mortality for Dungeness crabs.
  • Negative impacts to fish and birds caused by killing sources of food and disrupting the food web.
  • Concern about non-lethal impacts to invertebrates in the water column and sediment.
  • A risk of impacts from imidacloprid even at low concentrations.
  • Increased uncertainty about long-term, non-lethal, and cumulative impacts.

This will have significant effects on shellfish farmers in the two major bays on the west coast of Washington State. Some shellfish farmers may lose their farms over this decision. There are no known alternatives to kill the shrimp.

It has been claimed that this problem was caused by the introduction of the Columbia River dams in the 40s and beyond. Originally the plume of the river’s outflow of fresh water kept the shrimp under a natural control. With the lack of fresh water the shrimp were able to move into the bays and not have a natural control on their expansion.

The controversy was highlighted in a 2017 story on KNKX radio. http://www.knkx.org/post/questions-remain-about-pesticide-proposal-combat-burrowing-shrimp-infestation

Also more background on the controversy was reported in the Seattle Times.

https://www.seattletimes.com/seattle-news/environment/dept-of-ecology-growers-cancel-pesticide-permit-affecting-oysters-2/

and also in this Seattle Times story:

https://www.seattletimes.com/seattle-news/disbelief-over-state-plan-to-spray-neurotoxin-into-oyster-beds/

 

After considering and responding to more than 3,000 public comments, the Washington Department of Ecology has finalized its decision to deny the use of imidacloprid on shellfish beds in Willapa Bay and Grays Harbor. Mounting scientific evidence confirms the harm from this neonicotinoid pesticide poses too great a risk to Washington’s environment.

Shellfish growers from the Willapa-Grays Harbor Oyster Growers Association requested a permit from the state to spray imidacloprid on oyster and clam beds to control native burrowing shrimp. Ecology tentatively denied the request in April pending the evaluation and response to public comments.

https://ecology.wa.gov/About-us/Get-to-know-us/News/2018/Sept-27-Imidacloprid-denial

 

B.C. municipalities call for end of open-net fish farms -The Star Vancouver

Interesting article about what’s happening around net pens north of the border. While these calls for land-based farms are growing stronger by the month, there are plans afoot in Norway to rollout new designs for in-water pens. The issues will still remain, however. Norway has banned all in-water pens for a while now, but the fish farming industry there (the largest in the world) is rolling out new experimental pens that likely will be allowed by their government, and probably, by association, by Canada’s. This issue is far from finished being a lightning rod.

https://www.thestar.com/vancouver/2018/09/12/bc-municipalities-call-for-end-of-open-net-fish-farms.html

 

UPDATE: Nature Conservancy Supports Atlantic Farmed Salmon – Boycott Needed? No

As of today, the Nature Conservancy web site no longer shows the page referred to below. There is no mention of Mr. Jones, and a search of their listing of scientists, senior leadership, issue experts and volunteer leadership has no listing of Mr. Jones. The web site has some modifications showing the good work they are doing with aquaculture around the world, which I have always supported in the past. Since they have chosen not to communicate with me since my emails and phone conversations of two weeks ago, I am assuming that things have changed there, for what appears to be the better.

I am going to leave this original post up, because I am sure that people will wonder what happened to it if I take it down, and I want this post to show that I am asking any of you that reach this page to hold off taking any action against The Nature Conservancy until further notice. Given that The Nature Conservancy had such an interview in place for some time (weeks?) it would be good to see them post a page discussing the controversies here in the Pacific Northwest to show that there are environmental concerns we face, and are looking forward to working with the Nature Conservancy in the future to come up with solutions that can be supported by all of us.

Thanks in advance.  AL BERGSTEIN – EDITOR


THE ORIGINAL POST

The Nature Conservancy has come out in support of farmed Atlantic Salmon in their latest online and printed magazine. In an interview with aquaculture program manager Robert Jones, he states:

So can I buy farm-raised salmon?

I do. You have to compare it against every other terrestrial animal: Switching from beef to salmon or pork to salmon is a good environmental choice providing that the producer has done its job reducing the environmental impact. I think, for example, that the Norwegian industry is doing better than others. The Scottish also do a pretty good job. So, yes, I do believe that aquaculture, when done sustainably, is a smart environmental choice.”

Mr. Jones does not offer any explanation or overview of the controversy of net pens in British Columbia, Washington State, or Alaska (which has a ban on them). No mention of our Washington’s new ban on farming Atlantic salmon. No mention of massive overuse of anti-biotics to combat diseases rampant in the Pacific off Chile. Also not mentioned is the fact that Norway is shipping diseased fish embryos to North America. No mention of issues with farming shrimp around the world nor the documented slave trade of workers employed by the industry.

and https://www.washingtonpost.com/news/food/wp/2015/12/16/how-to-find-shrimp-thats-not-produced-by-slave-labor-in-thailand/?utm_term=.aab952613539

The Nature Conservancy refused to give me access to Robert before writing this article. In looking at his background on Linked In I find that Robert came from the very agency, NOAA, that has supported farmed salmon with spurious research that only looked at effects of the net pens in the waters under the pens, and ignored disease vectors, effects farther from the pens, sea lice, and the like.

Also, it appears Robert Jones has pulled his Linked In resume since my inquiries.

To be clear, I am not saying that all farmed fish is a problem. But it is clear that farming Atlantic Salmon has become a serious environmental issue in many parts of the world.

It is time to wake up The Nature Conservancy. They have allowed a person into their upper management who appears to be unable to view the environmental problems of the farmed Atlantic salmon industry with a non biased eye. Please feel free to forward this article.

Please join me and others in supporting a ban on donations to the Nature Conservancy in any form, until they change this position and offer a balanced approach to aquaculture around the world. Please call your local Nature Conservancy office and let them know you will be donating during the fourth quarter of the year to other environmental organizations. 

 

 

 

 

%d bloggers like this: