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 CPPSH REPORT, Dec. 2009          President's Message       CISA Mailing


Frequently Asked Questions

Q.  The shellfish aquaculture industry claims that shellfish and geoduck aquaculture is good for the environment.  Is this true?

A.  No, this is not true.  In reality, the shellfish industry is responsible for damage to the environment.  Depletion of native species, introduction of harmful invasives and the spread of alien organisms, the killing and hazing of shorebirds, the use of chemical poisons to kill native burrowing shrimp and disruption to fish habitat are just a few examples of environmental damage.  The shellfish industry commonly uses out of context self serving pseudo science to justify its harmful practices.

Q.  Is shellfish aquaculture sustainable?

A.  It depends on the practice and scale of the operation.  Based on the rapid expansion and intensity of techniques of shellfish aquaculture in South Puget Sound, many new techniques are probably not sustainable by any definition.  Generally, 'sustainable' means that the activity is capable of being continued without damage to the environment.  Other definitions relate to environmental stewardship, but also to the social implications.  Does the activity interfere with the commercial or recreational use of others?  Does the activity reduce the scope for future users to benefit from the commercial, environmental or recreational use of the area?  Does the activity alter or diminish the environment and biodiversity?  These questions also relate to the issue of sustainability.

95 percent of geoducks are shipped via air freight to Asian markets.  This carbon footprint precludes these commercial activities as "green" or "sustainable".

From The Association for Responsible Shellfish Farming, Definition of Sustainability:

"There are various forms of sustainability but, in essence, these condense around concepts relating to stewardship.  It is perfectly acceptable to exploit the environment, provided it is done in a way which:

a.  does not significantly interfere with the commercial or amenity use of that environment by others (although those others must also utilize the environment in a sustainable manner to preserve equity);
b.  does not reduce the scope for future users to benefit from the environmental resource; and
c.  does not significantly alter or diminish environmental quality and biodiversity per se."

Excerpt from: K.D. Black, 2001.  "Sustainability of Aquaculture" in K. Black (ed.), Environmental Impacts of Aquaculture.  CRC Press.  Pg. 199. 

Q.  The shellfish industry claims that shellfish aquaculture "provides ecological functions" and "improves water quality".  Is this true?

A.  No, this is false and misleading industry propaganda and public relations fraud.  Shellfish and geoducks filter and consume phytoplankton and detritus, and excrete feces and pseudofeces as waste.  Phytoplankton is an important aquatic plant and nutrient for a number of other aquatic species and is naturally present in the marine environment.  The shellfish industry actually wants to install their operations in areas of planktonic abundance.  In the wild, geoduck and other shellfish are stimulated to spawn due to increased water temperature and increased plankton blooms.  So the argument: "shellfish clean the water" or "shellfish provide ecological services"  are totally false and misleading statements.  Removing phytoplankton from the water column is not "cleaning" the water at all.  Shellfish filter everything out of the water column, including crab zoeas and fish eggs, and although this may temporarily clarify the water in the area of the shellfish farm, this can be harmful to other species. 

The shellfish industry's own scientific studies (Totten mussel raft EIS) indicate that shellfish aquaculture actually adds nitrogen to the water column, thereby increasing phytoplankton production and substantially decreasing dissolved oxygen by as far as 200 meters away, so the industry's claim of improving water quality is utterly false.  Mussel rafts, for example, actually contribute to nitrogen loading and increased phytoplankton blooms and anoxic/hypoxic or eutrophic/low oxygen conditions that can lead to fish kills.

According to a study by Pietros and Rice, in order for farmed shellfish to "clean the water", filtration rates must exceed phytoplankton regeneration.  In this particular mesocosm study, this does not occur.  In fact, phytoplankton production is actually stimulated from the wastes produced from shellfish farming.

No studies currently exist specific to South Puget Sound to corroborate the shellfish industry claim that farmed shellfish "clean" the water or are beneficial in any way.  In Willapa Bay, the shellfish industry has historically used Carbaryl, a chemical pesticide, to kill native burrowing shrimp to enhance oyster production.  Spraying Carbaryl on the tidelands also negatively affects salmon, steelhead and crab populations, and negatively impacts water quality.

The shellfish industry here in Puget Sound commonly uses studies by Roger Newell in Chesapeake Bay to claim that shellfish aquaculture is beneficial.  In Chesapeake Bay, an entirely different ecosystem than Puget Sound, the oyster reefs have been over harvested to less than one percent of historic levels.  Newell's studies address restoration of the oyster reefs in Chesapeake Bay, where reserves are set up and harvest is restricted.  Newell does not address aquaculture in Puget Sound.  The shellfish industry uses these studies disingenuously to mislead and manipulate government agencies and legislators to affect policy decisions in favor of the shellfish industry. 

Q.  Then why does the shellfish aquaculture industry claim themselves as champions of clean water?

A.  The shellfish industry is referring to pathogens, such as fecal coliform bacteria.  The shellfish industry cannot sell shellfish infected with pathogens from runoff or sewage contamination and is thus required to help monitor water quality regularly.  Typically, the shellfish industry establishes shellfish aquaculture districts with local governments requiring taxpayers to fund sewer systems or runoff containment and maintenance to protect their commercial interests.

Q.  The shellfish and geoduck industry promotes themselves as environmental heroes.  Are they considerate of fish and bird habitat?

A.  No, absolutely not.  They're interested in making money as a business by exploiting Puget Sound's tidelands.  If they were interested in fish, bird and other wildlife habitat of the intertidal, they would have waited to expand operations until baseline studies had been completed.  The shellfish industry removes and destroys eelgrass, sand dollars, starfish, and many other important native species and organisms that get in the way of their profits.  The shellfish industry is lying when they assert that they are environmentalists.  They're only interested in the environment to the extent that it benefits them.

Q.  Why do some environmental groups refuse to condemn the harmful practices of the shellfish industry?

A.  Many NGO's, or so called "non-profit environmental groups" accept money and large donations from the shellfish industry.  Groups such as People for Puget Sound, Puget Soundkeepers Alliance, Surfrider, Futurewise, the Nature Conservancy and the Puget Sound Restoration Fund all regularly take money or free shellfish from the shellfish industry.  Some groups, such as the Skagit Conservation Education Alliance, were started by the shellfish industry to promote shellfish interests.  Others, like the Puget Sound Restoration Fund, operate essentially as a public relations tool of the shellfish industry.

From the document "A Challenge to Conservationists":  "...NGO's entrusted with the enormous responsibility of defending the planet's natural ecosystems against the encroachment of the modern world in its most destructive manifestations have increasingly partnered with -- and become dependent on -- many of the corporations and governments that are most aggressively making this encroachment..."

Q.  What about Endangered Species Listed salmon and steelhead?

A.  The South Puget Sound Salmon Recovery Group lists shellfish aquaculture as a "stressor" to salmon populations.  The National Marine Fisheries Service (NMFS) and the Army Corps. of Engineers state that shellfish aquaculture is likely to adversely affect essential fish habitat for all fish, and to adversely affect critical habitat for endangered Puget Sound Chinook salmon and Hood Canal Summer-run Chum salmon.  Steelhead habitat has not yet been determined.  Ironically, the NMFS is a division of NOAA, a branch of the Department of Commerce, which is actively engaged in promoting aquaculture and funding various research and development projects that benefit the shellfish aquaculture industry. 

Q.  Is geoduck aquaculture consistent with the Endangered Species Act?

A.  No, intertidal geoduck aquaculture is not consistent with the federal Endangered Species Act of 1973.  As stated in section 2 of the act, it was designed to protect critically imperiled species from extinction as a consequence of economic growth and development untendered by adequate concern and conservation, and to protect the ecosystems on which these species depend.  Chinook, Coho and Steelhead are all listed under the ESA in Puget Sound.  American bald eagles are still listed as a species of concern.  The Puget Sound orca is also ESA listed and is dependent on increased salmon runs.
Q.  Is geoduck aquaculture consistent with the Magnuson-Stevens Act?

A.  No, intertidal geoduck aquaculture is not consistent with the federal Magnuson-Stevens Fishery Conservation and Management Act of 1996.  The underlying principle of the act is to promote the long term protection of essential fish habitat and to ensure the effective conservation and scientific understanding of recreational and commercial fishery resources.  It is documented that some methods of shellfish aquaculture negatively impact Essential Fish Habitat (EFH) for salmon.  It is documented that geoduck aquaculture negatively impacts eelgrass.  We also know that shellfish farmers have removed eelgrass and sand dollars to establish geoduck sites, and that once these sites have been established for geoducks, the eelgrass and sand dollars will not return and can no longer survive in these areas.  Eelgrass is EFH and is federally protected, and the Washington State Department of Ecology has a 'no net loss' policy on eelgrass.

Q.  Is geoduck aquaculture consistent with the Shoreline Management Act?

A.  No, intertidal geoduck aquaculture is not consistent with Washington State's Shoreline Management Act of 1971.  The overarching policy of the SMA is that the public's opportunity to enjoy the physical and aesthetic qualities of natural shorelines of the state shall be preserved to the greatest extent feasible.  One of the primary goals of the SMA is to preserve the natural character of the shoreline. Priority is to be given to developments that provide opportunities for substantial numbers of people to enjoy the shorelines of the state.  The SMA also implements the Public Trust Doctrine, limiting the public and private use of tidelands to protect the public's right to use the water.  Last year, the Pierce County Hearings Examiner (Taylor/Foss vs. Pierce County) concluded that geoduck farms are indeed a structure, that they obstruct public use of the water, and that they cause habitat disruption.  According to the SMA, aquaculture should not be permitted in areas where it would result in a net loss of ecological functions, adversely impact eelgrass and macroalgae, significantly conflict with navigation and other water-dependent uses or significantly impact the aesthetic qualities of the shoreline.  

Q.  How does shellfish aquaculture impact salmon and fish habitat.

A.  The shellfish industry uses plastic mesh bags, PVC pipes, and large anti-predator canopy nets to cover intertidal substrata areas.  Salmon, sole, flounder, and a large number of other aquatic species use the natural functions of this habitat for feeding.  Endangered Chinook salmon and flounder both have similar benthic diets, and some of these prey taxa are depressed by tubes and nets.  Conversely,  tubes and nets can provide a surface for algae growth and production of epibenthic prey, but it is not known if salmon will feed over geoduck sites.  It is also not known how geoduck structures affect migration patterns of salmon, or the effects of the constant ongoing removal/replacement of tubes, nets and bags.

Q.  Is intertidal shellfish aquaculture legal in Puget Sound?


A.  No, technically most methods that we see today, including geoduck aquaculture, are not legal.  But because of the industry’s long economic and cultural history, decades without regulations, corruption, feeble administration and misinterpretation of the Shoreline Management Act (SMA), plus very little enforcement efforts, it has been allowed to perpetuate largely unchecked.


The SMA is state law.  The over-arching policy of the SMA is to preserve the physical and aesthetic qualities of natural shorelines.  The SMA gives priority to developments related to residential and recreational uses over aquaculture as a preferred use.  Aquaculture may only be considered a preferred use if it does not interfere with residential and recreational uses, and if it does not interfere with the natural functions of the ecosystem.


The Shoreline Management Act also states:


Alterations of the natural conditions of the shorelines of the state, in those limited instances when authorized, shall be given priority for…development that will provide an opportunity for substantial numbers of people to enjoy the shorelines of the state.

This statement clearly indicates that shoreline alterations will be (1), limited in instance, and (2), prioritized toward recreational uses.


In 1971 when the SMA was drafted and approved by voters, shellfish aquaculture in Puget Sound was localized and confined primarily to bottom oyster culture.  Today, it’s millions of plastic tubes, plastic mesh bags, huge canopy predator exclusion nets, barges, pumps, hoses and nozzles, an unprecedented amount of anthropogenic activity and disturbances to the ecosystem.  This is not consistent with the SMA on several levels.  It does not preserve the natural character of the shoreline.  It does not protect the resources and ecology of the shoreline.  It decreases recreational opportunities for the public in the shoreline area.  The public’s opportunity to enjoy the physical and aesthetic qualities of natural shorelines is not being preserved.  It is an alteration of the natural condition of the shoreline.


It is clear that intertidal geoduck aquaculture is in violation of the Shoreline Management Act.  It is not a “reasonable or appropriate use”.  It does not “promote and enhance the public interest”.  It is contrary to the state’s policy of “protecting against adverse effects to the waters of the state and their aquatic life”.  It is not a preferred use consistent with prevention of damage to the environment.  It does not meet the “no net loss of ecosystem function” criterion.


Intertidal geoduck aquaculture adversely impacts eelgrass, depresses key prey invertebrates important to endangered salmon, disrupts resident and migratory birds including bald eagles, and significantly impacts the aesthetic qualities of the shoreline.


The Public Trust Doctrine is not statutory law, but is an ancient legal principle that certain resources are for public use, and that the government is required to maintain those resources for the public’s reasonable use.  The doctrine holds that the land between the tides and under navigable water is inalienably dedicated to public use.  This includes the biological resources contained within and dependent on that water.  A whole string of court decisions, both at the federal and state levels, have confirmed its validity for the present day.


Intertidal shellfish aquaculture negatively impacts public resources and restricts navigation and public access in violation of the Public Trust Doctrine.


The Precautionary Principle is a moral principle which states that if an action or policy might cause severe or irreversible harm to the public or to the environment, in the absence of a scientific consensus that harm would not ensue, the burden of proof falls on those who would advocate taking the action, and that a lack of full scientific certainty should not be used as a reason for postponing cost-effective measures to prevent environmental degradation.


Shellfish aquaculture is also outside the moral compass of the Precautionary Principle.   

Q.  The shellfish industry claims that shellfish aquaculture is a 'preferred use' of the shoreline according to the Shoreline Management Act.  Is this true?

A.  No,  most shellfish aquaculture techniques are not a 'preferred use'.  The activity must be environmentally neutral to qualify as preferred under state guidelines.  This is not the case with geoduck tubes, predator exclusion nets, grow bags, off bottom culture and 'kiddie pool' geoduck incubators.  Most other techniques also disrupt ecological processes to some extent. 

The SMA states: "The interests of all the people shall be paramount in the management of shorelines of statewide significance."  "Preferred" uses include single family residences, ports, shoreline recreational uses, water dependent industrial and commercial developments and other developments that provide public access opportunities. To the maximum extent possible, the shorelines should be reserved for "water-oriented" uses, including "water-dependent", "water-related" and "water-enjoyment" uses.  Preferred uses for Shorelines of Statewide Significance, in order of priority, are to "recognize and protect the state wide interest over local interest; preserve the natural character of the shoreline; result in long term over short term benefit; protect the resources and ecology of the shoreline; increase public access to publicly owned shoreline areas; and increase recreational opportunities for the public in the shoreline area."  The overarching policy is that “the public’s opportunity to enjoy the physical and aesthetic qualities of natural shorelines of the state shall be preserved to the greatest extent feasible consistent with the overall best interest of the state and the people generally. “Alterations of the natural conditions of the shorelines of the state, in those limited instances when authorized, shall be given priority for…development that will provide an opportunity for substantial numbers of people to enjoy the shorelines of the state.”  The SMA also implements the common law Public Trust Doctrine.  The essence of this court doctrine is that the waters of the state are a public resource for the purposes of navigation, conducting commerce, fishing, recreation and similar uses and that this trust is not invalidated by private ownership of the underlying land. The doctrine limits public and private use of tidelands and other shorelands to protect to public's right to use the waters of the state.

The SMA guidelines address aquaculture generally but do not have provisions related to geoduck specifically, as the SMA was drafted before the advent of intertidal geoduck aquaculture techniques.  The guidelines state:  “Aquaculture is the culture or farming of food fish, shellfish, or other aquatic
plants and animals.  This activity is of statewide interest.  Properly managed, it can result in long-term over short-term benefit and can protect the resources and ecology of the shoreline.  Aquaculture is dependent on the use of the water area and, when consistent with control of pollution and prevention of damage to the environment, is a preferred use of the water area.  Local government should consider local ecological conditions and provide limits and conditions to assure appropriate compatible types of aquaculture for the local conditions as necessary to assure no net loss of ecological functions.  Potential locations for aquaculture are relatively restricted due to specific requirements for water quality, temperature, flows, oxygen content, adjacent land uses, wind protection, commercial navigation, and, in marine waters, salinity.  The technology associated with some forms of present-day aquaculture is still in its formative stages and experimental.  Local shoreline master programs should therefore recognize the necessity for some latitude in the development of this use as well as its potential impact on existing uses and natural systems.   Aquaculture should not be permitted in areas where it would result in a net loss of ecological functions, adversely impact eelgrass and macroalgae, or significantly conflict with navigation and other water-dependent uses.  Aquacultural facilities should be designed and located so as not to spread disease to native aquatic life, establish new nonnative species which cause significant ecological impacts, or significantly impact the aesthetic qualities of the shoreline.  Impacts to ecological functions shall be mitigated according to the mitigation sequence described in WAC 173-26-020.” WAC 173-26-241(3)(b)

Joan K. Thomas, of the Washington Environmental Council (WEC) and one of the drafters of the SMA, spoke on the history of the act (page 16) at the
1991 SMA Symposium.  The WEC, along with citizen and environmental groups, were instrumental in the passage of the SMA, and in getting the SMA on the ballot.  In 1970, these groups had gathered over 160,000 signatures in 10 weeks.  The earlier versions of the act also provided for direct citizen enforcement.
Joan K. Thomas stated at the 1991 symposium:
“I have thought about this carefully over the years as I have seen my expectations frustrated.  We have lost the full potential of the SMA to protect a valuable resource through fainthearted administration.”
“When the SMA was written in 1971, aquaculture meant oysters and clams and one salmon raising operation.  This activity was recognized and protected as water-dependent.  I do not read the original intent or the original guidelines to promote the industry as we know it today.  In fact, the guidelines specified that navigational access not be restricted and that visual access of upland owners be considered.  Aquaculture has become a sore point between local governments and the Department of Ecology – a fraying of the partnership.”
Brian Boyle, 1991 Public Lands Commissioner, spoke on the Public Trust Doctrine (page 111):
“For the average family, a walk on the beach is a free and easy amusement.  It’s something most of us take quite for granted.  To a public land manager, however, that same walk represents the exercise of a right with roots that can be traced back through the foundation of our state, to the foundation of our republic, and beyond that to the laws of England and the statutes of the Roman Empire.”
“Our walk on the beach is, in fact, defended by a legal doctrine more than 1,500 years old – a doctrine that holds that the land between the tides and under navigable water is inalienably dedicated to public use.  This is the famous public trust doctrine, and a whole string of court decisions, both at the federal and state levels, have confirmed its validity for the present day.”
“Our stewardship has two separate but related goals.  The first is the preservation of values inherent in the public trust – waters where we can fish and swim and ecologically healthy bottom lands and beaches.  Although much of this effort is carried out by other state agencies, including the departments of Ecology and Fisheries and Wildlife, there is an important difference in emphasis and authority.  Those agencies rely on the police power of the state, which is subject to a number of constraints when it affects private property.”
“For example, when the state limits what private property owners can do with their property, as in zoning restrictions, property owners may object that the state has taken some part of the values of their property without compensation, which is a violation of the constitution.  But the situation is very different when the state acts to protect its own property, or the property rights it holds in trust for the people under the public trust doctrine.  Potentially, this is a much more powerful means of securing public rights, against which the “taking” argument has no effect.  The Washington Supreme Court held in the Orion case that private owners can expect no economic benefit from their lands if obtaining that benefit deprives the public of rights it holds under the public trust doctrine.”

Q.  Is shellfish aquaculture documented as a stressor to fish habitat and salmon populations?

A.  Yes.  For one example please:  
Click here. 

Q.  What about the social disruptions caused by shellfish aquaculture expanding into non traditional and residential areas?

A.  Profits are the primary goal of the expanding shellfish/geoduck industry in Puget Sound.

Q.  What about the loss of traditional and recreational sport fishing grounds?  Does the shellfish industry respond to this issue?

A.  No.  There has not been any consideration given to this issue by the shellfish aquaculture industry.  The industry uses non-scientific opinion as propaganda to suggest shellfish aquaculture enhances sport fishing.

Q.  Does the plastic tubes (PVC - polyvinyl chloride) used in geoduck aquaculture contain Bisphenol A (BPA) or Phthalates?

A.  Yes, the plastic PVC pipes used in geoduck aquaculture contain Phthalates.  According to a University of Washington study: 'Plastics: Possible Impacts on Children's Health', Pediatric Environmental Health Specialty Units: "Phthalates are man-made chemicals used as a 'plasticizer' in a variety of industrial and commonly used products.  These chemicals are anti-androgenic, and can adversely impact androgen sensitive tissues during specific windows of development."

The use of
PVC is banned in New York State and elsewhere because of it's negative environmental impacts.  Yet the shellfish industry places eight miles, or 150,000 pounds (75 tons) of PVC plastic PER ACRE of Puget Sound tidelands for geoduck aquaculture.  It then weathers and wears away directly into the environment.  PVC pipe was designed for indoor or underground construction use, not for outdoor use in the aquatic environment where it is exposed to UV light, wind and wave erosion.  No studies have been done to assess the long or short term impacts of this unprecedented amount of PVC plastics, literally millions of pounds, into the nearshore environment of Puget Sound.

In 1987, Congress enacted the 'Marine Plastic Pollution Research and Control Act', which is intended to reduce plastics in the marine environment.  

Throughout its entire life cycle, from manufacturing to disposal, PVC has high environmental costs.  It contains a high percentage of chlorine, is made with the carcinogen vinyl chloride, plus dioxin and ethylene dichloride are by-products of its manufacture.  PVC is not readily recyclable and when incinerated releases both the carcinogen dioxin and hydrogen chloride gas.

Q.  How many companies are pursuing geoduck aquaculture in South Puget Sound?

A.  Primarily five: Taylor Shellfish, Seattle Shellfish, Allen Shellfish, Arcadia Shellfish and Chelsea Shellfish.  Additionally, the Pacific Coast Shellfish Growers Association, the Washington State Department of Natural Resources, and various other private, state, county and federal agencies work to assist the shellfish aquaculture industry in expanding into inappropriate areas of South Puget Sound.

Q.  Is geoduck farmed in its natural habitat?


A.  No, geoduck is mainly a subtidal animal.  Geoduck is farmed in the intertidal zone using plastic PVC pipes and nylon nets for predator exclusion.  Geoducks cannot grow in the intertidal without pipes or nets.  

Q.  What about natural densities?  Are geoduck farmed in natural densities as they occur in the subtidal?

A.  No, absolutely not.  Not only are geoducks farmed in the intertidal, which is not their natural habitat, they are farmed in densities that are many times their densities in the wild. 

Q.  Has the Washington State Department of Natural Resources done a good job of managing the subtidal geoduck harvest?

A.  No.  Areas have been overfished and harvest boundaries have been violated on a number of subtidal tracts. 

Q.  Are geoducks an aphrodisiac or do they have properties of male enhancement?

A.  No, absolutely not.  Some Asian cultures believe this is the case because of the geoduck's profound phallic appearance.

Q.  Are geoducks a valuable food source.

A.  No.   Salmon has three times the calories, twice the protein, and five times the healthy Omega 3's as geoduck, but at one third the price.

Q.  Why is geoduck so expensive?

A.  The demand is driven by the false cultural belief that geoducks have properties of aphrodisia.  More than 95% of geoduck is sold to Asian markets. 

Q.  The shellfish aquaculture industry claims that geoduck farming is good for the economy.  Is this true?

A.  No, this statement has not been quantified or substantiated.  Because geoduck are largely exported, sales and excise taxes are avoided, depriving Washington state and Puget Sound counties of significant revenues.  Since tidelands are taxed at only $3. per acre, substantial tax revenues to Puget Sound counties are avoided.  Yet the shellfish industry's clean water initiatives, in which they gain financially, cause great expenses to be incurred by taxpayers in lieu of other programs.  The truth is: only a handful of individuals stand to gain substantially from geoduck aquaculture.

Q.  What about jobs?

A.  The shellfish industry claims to provide about 2,000 family wage jobs in Washington State.  For some perspective, the tourism industry in Washington State provides about 150,000 jobs. 

Q.  Does shellfish aquaculture help balance the seafood trade imbalance and the overall trade deficit.

A.  The U.S. exports over 70% of its seafood products to other countries while importing about 80% of seafood from foreign countries; primarily China.  We export our high quality seafood and import cheaper farmed seafood products to consume here.  This is a business and policy issue/problem that cannot ever be solved by exporting our shellfish overseas.  Click here for video.

Q.  What about the shellfish industry claim that shellfish aquaculture provides heathy protein for a growing population?

A.  This is typical false propaganda.  Shellfish are a luxury food, and as such will never be a staple protein source.  Six medium sized oysters contain about the same amount of protein as one egg.  Six medium oysters retail for about $5. or $6. dollars, compared to about .23 cents for one egg - a difference in price of about 95 percent.  Oysters and other shellfish are a luxury item that will never be found at the local food bank, nor will they ever be a viable protein source for feeding the masses.  The shellfish industry is not about an altruistic desire for clean water or feeding hungry people.  The shellfish industry wants to expand for the purposes of increasing profits at the expense of the nearshore ecosystem and public rights.

Shellfish are not necessarily a "healthy" food either.  Outbreaks of paralytic shellfish poisoning are relatively common, as is vibrio vulnificus in oysters.  Vibrio is one of the most deadly food borne illnesses known, killing half of all people that come into contact with it.  Oysters are number 4 on the FDA's top ten list of riskiest foods. 

Q.  Why is the shellfish aquaculture industry moving into traditional and historic recreational and residential areas of South Sound?

A.  Money and greed.  The South Sound has optimum conditions for geoduck aquaculture: clean pristine waters, abundance of planktonic nutrients, suitable intertidal substrate, proper salinity and proximity to processing facilities. 

Q.  Has the government of British Columbia, Canada, banned new intertidal geoduck aquaculture?

A.  Yes.  The B.C. Ministry of Agriculture and Lands used to state that this was: "due to the lack of understanding on the effects of geoduck aquaculture techniques to fish habitat".  Because of pressure from the shellfish aquaculture industry, this now says: "while the policy for intertidal geoduck culture is under review".

Q.  What is hypoxia?

A.  'Hypoxia' is low dissolved oxygen, or 'anoxia': absence of oxygen.  It is caused by a number of factors, including an over-abundance of shellfish.  Other causes: algal or plankton blooms, decaying plant and animal matter and riparian loss.  Plankton blooms can occur naturally and can be exacerbated by septic and fertilizer runoff. 

Q.  The shellfish aquaculture industry claims that geoduck farming improves hypoxia (low dissolved oxygen) in Puget Sound.  Is this true?

A.  No, this is not true and cannot be scientifically substantiated.  In fact, too much geoduck can contribute to hypoxia in two ways: geoduck as aerobic consumers of oxygen, and from feces deposition increasing organic carbon levels and hence, sediment oxygen demand.  Mussel rafts significantly contribute to the hypoxia problem according to the shellfish industry's own environmental assessments.

Q.  Is hypoxia caused by upland development?

A.  In Hood Canal, the hypoxic conditions are primarily caused by the nitrogen leached from decaying alder leaves and other deciduous trees, a result of massive clearcutting of native evergreens.  Reforestation to native conifers would be the best solution to hypoxia in Hood Canal.  Residential upland development (septic and fertilizer runoff) accounts for about 10% of the hypoxia problem in Hood Canal. 

Q.  What about oysters?  Are they good for the environment?

A.  Yes.  A natural abundance of shellfish are important to the ecosystem.  Oysters are particularly beneficial.  One oyster can filter about 30 gallons of water per day.  Oysters are superior at sequestering carbon and provide natural habitat to crab and other filter feeders, such as barnacles.

Q.  What about invasive species?

A.  The shellfish industry has introduced a number of harmful invasive species, while contributing to the near extinction of the native Olympia oyster.  The Pacific oyster is an invasive species, as is the oyster drill from Japan.  Mediterranean mussels are invasive, as are Manila clams.  Aquaculture is the number one method of introduction of invasive species in Puget Sound.   Marine invasive species are a major threat to biodiversity and have profound ecological and economic impacts.

Various forms of the Vibrio bacteria are most likely spread through human activity.  In Puget Sound, some shellfish diseases can be distributed through aquaculture activities from the spread of seed from hatcheries in California or outside the Puget Sound area.  Hatcheries are generally not regulated.  Parasites such as Orthione griffenis are distributed through human activities and may initially take root from ballast water.  Griffen's parasite threatens native mud shrimp with extinction, yet the shellfish industry continues to spray Carbaryl in Willapa Bay to kill mud shrimp and other burrowing shrimp. 

Q.  Does CISA oppose all shellfish aquaculture?

A.  CISA supports reasonable scale, properly sited eco-friendly shellfish culture techniques such as on bottom triploid oyster culture harvested by hand.  CISA does not support the use of carbaryl or other pesticides, nor will we support culture methods that negatively impact salmon and other valuable species.  CISA does not support further shellfish aquaculture expansion in Puget Sound without site specific unbiased scientific review and stakeholder participation.

Q.  How can I help?

A.  Call or write or email your local and state representatives.  Tell them that you do not want aquaculture expanding into Puget Sound without strict environmental regulations, public participation in the regulatory process, and exhaustive and unbiased scientific review.  Or email us at info@caseinlet.org with questions or comments.