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.

 

 

 

 

 

 

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.

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Coalition Wins Shorelines Hearings Board Geoduck Aquaculture Appeal

The Washington Shorelines Hearings Board ruled in favor of the Coalition To Protect Puget Sound Habitat and reversing and dening the first subtidal/intertidal geoduck aquaculture permit approved in Washington by Pierce County (see attached decision).

The Board concluded that “This farm located on a shoreline of statewide significance means that particular consideration must be given to balancing aquaculture as one statewide interest, with other statewide interests like the ecological values and the public’s recreational use.”

“The careful review required for this shoreline of statewide significance weighs in favor of requiring a cumulative impact analysis of the impacts that might result from granting the first subtidal geoduck farm permit in Henderson Bay-in particular to assess the potential for longer term impacts to fragile resources like eelgrass, as well as unique use of the area by recreationalists like windsurfers.”

For more information on the work of the Coalition To Protect Puget Sound Habitat and the Washington State Sierra Club to protect fragile marine resources, please visit:

http://coalitiontoprotectpugetsoundhabitat.org/

http://washington.sierraclub.org/tatoosh/Aquaculture/index.asp

2013 NW Straits: Alexis Valauir -Ocean Acidification Effects on Global Communities

From the 2013 NW Straits Annual Conference, a most interesting talk:

Alexis Valauri-Orton recently completed a year-long Watson Fellowship investigating human narratives of ocean acidification in Norway, Hong Kong, Thailand, New Zealand, the Cook Islands and Peru. Over the year, she traded her lab coat for a pair of gum boots, experiencing firsthand the role marine resources play in coastal communities. Investigating narratives of acidification in such diverse communities, she discovered the importance of understanding and navigating the social structures that shape our vulnerabilities and responses to environmental issues. She holds a degree in Biology and Environmental Studies from Davidson College, in North Carolina, and now lives in her hometown of Seattle. She believes increasing scientific literacy and public awareness on issues like ocean acidification is the key to creating a sustainable future.

The Powerpoints of her talk are found at the NW Straits web site:

http://www.nwstraits.org/Whats-New/Meetings-Events/2013-MRC-Conference.aspx

or directly here (This downloads the presentation to your computer)

Click to access Valauri-Orton-OA.pdf

You can download this for use on a device like an ipod or iphone, or just listen to it right here on your computer.

 

 

Taylor Shellfish Denied Mussel Farm Expansion in Thurston County

Thurston County Commissioners have denied Taylor Shellfish’s mussel farm permit because cumulative impacts were not adequately considered. This doesn’t seem to mean that Taylor cannot come back with more data. The refusal had to do with not presenting what the Hearing Examiner, a lawyer by trade, felt was compelling cumulative impacts of the proposed farm.

The legal precedent behind this decision appears to have been from a variety of already resolved lawsuits, including one by the coalition of a group of six citizen organizations that have been fighting the expansion of shellfish farms, mainly in the South Sound.

Again, it’s interesting to note that the Puget Sound Partnership did not weigh in at all on this case, for either side.

Read the short PDF of the ruling here. There is a longer document of the actual findings from the Hearings Examiner available on line if you wish.

http://www.co.thurston.wa.us/permitting/hearing/decisions/2012/961372.bocc.decision.taylor.pdf

Thousands of pounds of illegal geoduck shipments seized at Sea-Tac

SEATAC, Wash. — State and federal wildlife officers spent Thursday doing what most of them dread most.
Pressure from poachers is threatening the survival of the giant clams in the wild. The busy cargo operations at Sea-Tac Airport don’t seem like the normal beat for fish and wildlife enforcement officers. But they were there gearing up for a day of activity most of these officers try to avoid. “We are up to our necks in paperwork,” said Washington State Fish & Wildlife Officer Tylar Stephenson

Geoduck Article–Kitsap Sun

Economic benefits, ecological questions stall geoduck industry’s growth ; Geoduck farming, a unique industry in the region, has been slowed by legal and scientific challenges”

http://www.kitsapsun.com/news/2011/jul/23/economic-benefits-ecological-questions-stall/

Washington poised to get tougher with shellfish operators

3/1 KPLU-FM
By Austin Jenkins and KPLU News Staff

Last summer, we brought you a story about gaps in the system that’s supposed to keep Washington shellfish safe to eat. Now state lawmakers appear ready to get tougher with shellfish operators who violate food safety laws.

Early last year, Washington Fish and Wildlife cops shut down a Hood Canal shellfish harvesting operation. They allege G&R Seafood poached $500,ooo worth of oysters and clams from state and private beaches.

But Fish and Wildlife police say even after the business was raided, the company’s owner – who denies any wrongdoing – was spotted selling shellfish at fairs and other public gatherings. But Chief Deputy Mike Cenci says there was nothing his officers could do since it was G&R’s harvesting license <http://wdfw.wa.gov/fishing/shellfish/>  that had been yanked:

More at
http://www.kplu.org/post/washington-poised-get-tougher-shellfish-operators

Superb video on local ocean acidification

Check out this 9 minute video from Oregon Public Broadcasting on the effects of ocean acidification on shellfish and animals at Tatoosh and the Oregon coast. A very good narrative of what’s happening to us right in our backyard of Tatoosh, and Hood Canal for that matter.

http://ecotrope.opb.org/2010/10/video-what-makes-oyster-larvae-unhappy/

State to take new look at how much fish is safe to eat.

ed- It is somewhat upsetting to read that the tribes found out (through a grant paid for by the taxpayers of the state), that levels of toxins were far higher than thought, or safe, and yet we have had no warning and apparently you could assume they were selling this to restaurants and grocery stores. So the question is, “is it safe to eat crab and flounder caught in Puget Sound?”  The answer appears, at least from reading this article, to be ‘no’.  The good news here is that this approach turns pollution control on it’s head. Instead of allowing pollution and reducing consumption, we now are saying that we are going to allow consumption and reduce pollution to achieve healthy goals.

The problem I see is that how do I know that I’m getting safe fish, if the levels have changed but the pollution is still out there in the fish? That seems oddly backwards. Like pretending that the current safe levels aren’t a factor. I think I need better reporting to assure me that I’m just reading this wrong.

 

7/25 Seattle Times
State takes new look at how much fish is safe to eat
By Cassandra Brooks
Seattle Times staff reporter
From the shores of Lake Washington to the Duwamish River and other state waters, signs alert locals about toxic fish:
Warning: Fish from these waters contain high levels of mercury.

Caution: Trout contain high levels of DDT.

Advisory: Shellfish contain high PCBs, do not eat!

Under state law, Washington’s lakes, streams, estuaries and nearshore coastal waters only need to be clean enough for residents to safely consume one serving of fish a month.
Yet, for many state residents, local fish and shellfish are a much bigger part of their diet than that, whether it’s bass caught from the dock of a lake, a dozen oysters served up at a waterfront restaurant or salmon grilled on a backyard barbecue.
And for many tribes across Washington, fish are not just central to their diet but a core part of their cultural and spiritual lives as well.
More at
http://seattletimes.nwsource.com/html/localnews/2012448836_tribalfish26m.html

Oyster Poaching Case Reveals Shellfish Safety Gaps

I visited Peter Downing at his Geoduck farm the other day, and he alluded to this situation. A real dark side to the whole aquaculture world. And the state funding for enforcement is virtually non-existant.  You can’t just legislate stuff, you have to provide money for enforcement, which has been a weak spot for years. Demand enforcement! – Editor

6/17 KPLU-FM

Austin Jenkins
OLYMPIA, WA (N3) – If you ever eat shellfish, you’ll want to listen to this story. A major oyster and clam poaching case has revealed gaps in the system that’s supposed to ensure Washington shellfish are safe to eat. Washington Fish and Wildlife cops recently raided a seafood operation on Hood Canal. They allege an outfit called G&R Quality Seafood was a front for a nighttime shellfish theft ring. KPLU’s Austin Jenkins has our story.
Listen at
Oyster Poaching Podcast

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