Best Management Practices for California aquaculture – still waiting for them…

Below you will find an update on my ongoing efforts to protect Tomales Bay from the historically poor practices of shellfish growers, and a long history of virtually no oversight by the California Department of Fish & Wildlife (CDFW) and the California Fish & Game Commission (CFGC). The CFGC leases state water bottoms in California to shellfish growers. Given the shortage of suitable coastline with clean water, you’d think the CFGC would be charging a premium rent (supply and demand). You would be wrong. More on that in a future post.

If you care for Tomales Bay and want to protect it, please write the following people and tell them to implement and enforce strong Best Management Practices over shellfish growers. Tell them to fix the woefully inadequate escrow cleanup bond system. And kindly ask them to make a better effort at enforcing existing litter laws and to regularly monitor aquaculture statewide. Our state bays and estuaries are priceless treasures for ALL to enjoy.

Valerie Termini – Executive Director of California Fish & Game Commission (CFGC) – Sacramento, CA fgc@fgc.ca.gov

Susan Ashcraft – Marine Advisor to the California Fish & Game Commission (CFGC) – Sacramento, CA Susan.Ashcraft@fgc.ca.gov

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Responsibly practiced shellfish aquaculture, properly sited, adds value to life in the form of delicious shellfish, jobs and the continuation of a long tradition. Authentic stewardship is paramount to assuring this practice does no harm to the precious bays and estuaries of the ever changing (and rising) sea.

Three things I have been requesting since I set out to right numerous wrongs are:

1) Growers need to stop losing so much plastic, wood and other gear. They also need to regularly pick up the debris that they do lose. All of the legacy debris left by growers from days gone by needs to be removed from the bay.

2)      A. Best Management Practices (BMP) need to be developed and become an   enforceable part of being allowed to profit from public trust tidelands.

2)      B. The cleanup fund escrow system to address abandoned infrastructure and other damages done to a lease needs to be redone so that it is actually applied, AND is not based on cost estimates made by the growers themselves.

3) CFGC and CDFW need to actually DO their job: regular monitoring of leases, enforce existing laws, ensure growers are not diverting creeks with un-permitted structures or altering the bay-floor by dumping large quantity of oyster shells or other materials into the bay.

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Let’s look at each of these in more detail.

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1) Growers need to stop losing so much plastic, wood and other gear. They also need to regularly pick up the debris that they do lose. All of the legacy debris left by growers from days gone by needs to be removed from the bay.

This is taking place. The growers are losing less gear and making a noticeable effort to pick up that gear still getting loose.

There is still room for improvement, as bags and other culturing devices are still getting loose. But overall, a vast improvement!

Thank you growers!

Unfortunately, much of the legacy debris continues to blight the beauty of Tomales Bay. You can see what I am talking about here.

2-A Best Management Practices (BMP) need to be developed and become an   enforceable part of being allowed to profit from public trust tidelands.

On April 8, 2015 (1087 days ago and counting), a proposed list of BMP that I drafted were delivered to the CFGC at their commission meeting in Santa Rosa. The growers and numerous agencies have mulled over and massaged this list since then.

The latest revision put forth by the CFGC is very close to what I originally proposed, except it does not include that growers must mark all their gear with their name & phone number. Marking all gear is important in order to ensure growers practice authentic stewardship.

My most recent iteration of what I think are good common sense BMP are below.

 

These BMPs shall be an integral part of each lease. The practices shall be mandatory practices meant to ensure Tomales Bay and the ocean in general is kept free of lost plastic and other debris from aquaculture operations.

To have the intended effect of reducing litter in Tomales Bay attributed to aquaculture, it is imperative that these practices be adequately and regularly enforced.

Harming the environment is a criminal matter, not an administrative matter.

 

  1. Growers shall uniquely and clearly identify all of their gear with company name and phone number. Possible means of uniquely marking gear include: unique colors of bags, wires, tags, PVC pipes, rope, and “branding info into gear.”

 

  1. Growers shall train all employees in concepts of Leave No Trace, see http://LNT.org, or similar training about environmental stewardship.

 

  1. Growers shall continually improve gear and methods in a quest to lose less gear.

 

  1. Growers shall replace single use items (i.e. zip-ties, copper wires) with more durable items such as stainless halibut clips.

 

  1. Growers shall NOT use floats that are easily degraded by sunlight or pecked by birds in search of food.

 

  1. Growers shall securely tie large groups of non-floating bags together when deploying bags for future securing to anchor lines to ensure they do not drift.

 

  1. Growers shall remove all tools and materials each day after working on lease areas, including: fencepost drivers, gloves, water bottles, PVC pipes, wires, and ropes. Work barges shall be secured to ensure items are not blown into the bay.

 

  1. Growers shall NOT dump shells, lumber, bags or other debris on the bay floor to walk upon or for any reason.

 

  1. Growers shall promptly (within 90 days) remove culture structures and other items comprising a method that did not work as desired or is no longer used.

 

  1. Growers shall patrol lease areas and the shores of Tomales Bay on a monthly basis, twice monthly during windy or heavy surf times. Patrols must occur at both high and low tides to ensure gear buried in the mud is promptly collected.

 

  1. Growers shall uniquely and clearly identify all of their boats and barges. Boats should be clearly identifiable with binoculars from a distance of 1 mile. Unique color, large letter and/or number or combinations of these may work.

 

To support item 11 above, the below images show some of the boats used by various growers. Notice how many of the boats look identical. Also shown is one suggested ID method to allow distant observers to know which grower a particular boat belongs to. Also, how many of these boats are properly licensed?

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The reason for my concern centers on the damage done to the eel grass beds on or near the leases. Below are three images recorded from overhead, showing deep and permanent damage done to the eel grass by the propellers of boats accessing the lease areas.

Click on the image to enlarge it.

Click on the image to enlarge it.

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On numerous occasions I have witnessed oyster boats operating at low tides, attempting to access areas of the bay not deep enough to access without driving the prop of the boat into the bottom of the bay, destroying everything that the prop meets, like a blender, loudly throwing a tall, brown rooster-tail into the air, easily visible/audible from a mile+ away.

If boats were clearly labeled, interested stakeholders would be able to give the Commission/Department accurate information with which to hopefully take action.

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The below images show the reasoning behind item 8.

Growers shall NOT dump shells, lumber, bags or other debris on the bay floor to walk upon or for any reason.

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2-B The cleanup fund escrow system to address abandoned infrastructure needs to be redone so that it is actually applied, AND is not based on cost estimates made by the growers themselves.

The figure below (from K. Ramey files acquired via Public Records Access [PRA]) shows how much has been contributed (allegedly) by each grower. Total on account (allegedly) is $106,255.

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Click on the image to enlarge it.

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Below is an image showing part of the main contract paid by the NPS for the cleanup of aquaculture debris left by DBOC in Drakes Estero. This is not the entire sum. Beyond the $3,460,750 shown below were other substantial fees associated with the removal of oysters and clams left by DBOC.

Important to note is the self-assessed cleanup cost given to the Fish & Game Commission by DBOC for two years running: $10,000

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Click on the image to enlarge it.

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Below are images of some current leases, showing rough dimensions as well as the amount paid into the escrow fund.

These values are self-assessed cost estimates provided by the growers.

Have you ever been asked by a landlord how much of a cleaning deposit you think you ought to pay?

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3) CFGC and CDFW need to actually DO their job: regular monitoring of leases, enforce existing laws, ensure growers are not diverting creeks with un-permitted structures or altering the bay-floor by dumping large quantity of oyster shells or other materials into the bay.

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This request needs no further support.

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The slide seen below was created by the State Aquaculture Coordinator.
The yellow text I have highlighted reads: “Emphasize CA’s strict environmental standards as advantage”

How can one have an advantage based on strict standards if the laws those standards are based on are not enforced?

Please enforce current laws!

Click image to enlarge it.

If you care for Tomales Bay and want to protect it, please write the following people and tell them to implement and enforce strong Best Management Practices over shellfish growers. Tell them to fix the woefully inadequate escrow cleanup bond system. And kindly ask them to make a better effort at enforcing existing litter laws and to regularly monitor aquaculture statewide. Our state bays and estuaries are priceless treasures for ALL to enjoy.

Valerie Termini – Executive Director of California Fish & Game Commission (CFGC) – Sacramento, CA fgc@fgc.ca.gov

Susan Ashcraft – Marine Advisor to the California Fish & Game Commission (CFGC) – Sacramento, CA Susan.Ashcraft@fgc.ca.gov

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Best Management Practices (BMP) meeting audio, DFW presentation and audience comments

Click on the words above “Best Management Practices (BMP) meeting audio…” to see this entire post.

On 17 July, 2017 at the Marconi Conference Center in Marshall California, over 75 people from all aspects of shellfish aquaculture, including local and non-local residents attended. The announcement for this meeting may be found here.

Below are several audio files that I recorded that include the entire meeting, excluding some transition noise between speakers as well as some some audio at the end when the entire room erupted in conversation.

I apologize for the audio quality, though I think you will be able to hear most everyone. Possibly some quiet audience members in the back of the room may be hard to hear. Use of headphones will help.

Below the audio files you’ll find the presentation given by Kirsten Ramey from the California Department of Fish and Wildlife.

You’ll also find images of the audience comments taken by Randy Lovell and Susan Ashcraft, as well as these same notes transcribed to an MS Word file.

These presentation and notes files were sent to me by the meeting moderator, Heather Benko, Sea Grant Fellow.

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Introductions – Heather Benko – 12:19 minutes

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Randy Lovell – 17:32 minutes

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Susan Ashcraft – 21:04 minutes

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Kirsten Ramey – 12:27 minutes

Kirsten’s presentation is here.

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Audience input part 1 – 42:19 minutes

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Audience input part 2 – 43:59 minutes

Audience comments recorded by Randy Lovell here.

Audience comments recorded by Susan Ashcraft here.

Both sets of notes transcribed to text file here.
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Best Management Practices (BMP) Meeting change of venue, agenda available

All,

A larger room was need to accommodate the growing audience.

New room is named Buck Hall.

Everything else is the same

We also received an agenda today for the meeting on Monday.

Click the blue text for agenda, on window that pops up, click on document to see it.
REVISED Agenda-Map-Bckgrnd BMP stakeholder mtg (17Jul2017 Room change)

Respect Tomales Bay – Stakeholders meeting to discuss Best Management Practices for aquaculture

Click the words above “Respect Tomales Bay – Stakeholders meeting…” to see this entire post.

NOTE: the meeting has moved to a bigger room, see here for details.

The public is invited to a meeting hosted by the California Fish and Game Commission and California Department of Fish and Wildlife

Date: 17 July, 2017

Time: 1 pm

Location: Marconi Conference Center, McCargo Room

New location is Buck Hall

Please RSVP by sending an email to aquaculturematters@wildlife.ca.gov

map below

Here are a set of proposed Best Management Practices (BMP), most of which were submitted to the Fish and Game Commission on 8 April, 2015.

Proposed best practices for Tomales Bay Oyster Farmers

These BMP shall be an integral part of each lease. Mandatory practices meant to ensure Tomales Bay and the ocean in general is kept free of lost plastic from aquaculture practices.

 

1. Growers shall uniquely and clearly identify all of their gear with company name and phone number. Possible means of uniquely marking gear include: unique colors of bags, wires, PVC pipes, rope, “branding info into gear”.

2. Growers shall train all employees in concepts of Leave No Trace,
see http://LNT.org, or similar training about environmental stewardship

3. Growers shall continually improve gear in a quest for zero loss of gear.

4. Growers shall replace single use items (zip-ties, copper wires) with more durable items such as stainless halibut clips.

5. Growers shall NOT use floats that are easily degraded by UV, pecked by birds birds in search of food.

6. Growers shall securely tie large groups of non-floating bags together when deploying bags for future securing to anchor lines lines to ensure they don’t drift.

7. Growers shall remove tools each day after working on lease areas, including: fencepost drivers, gloves, water bottles, PVC pipes, wires, ropes.

8. Growers shall promptly (within 60 days) remove culture structures and other items comprising a method that did not work as desired desired or is no longer used.

9. Growers shall patrol lease areas and eastern shore of Tomales Bay on a bi-monthly basis, twice monthly during windy or heavy surf times. Patrols must occur at both high and low tides to ensure gear buried in the mud is collected.

10. Growers shall uniquely and clearly identify all of their boats and barges.
Boats should be clearly identifiable with binoculars from a distance of 1 mile.
Unique color, large letter or number or combinations of these may work.

 

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Respect Tomales Bay – Oyster growers making great strides to lose less gear, clean up what is lost

Click on the words above “Respect Tomales Bay – Oyster growers making great strides…” to see this entire post.

With much happiness I am seeing that the oyster growers of Tomales Bay are continuing to take positive steps to reduce the amount of plastic and other debris their operations routinely lose in Tomales Bay. Further, some are taking steps to redesign their gear to better withstand the harsh wind and waves that are a major factor in gear being lost.

The last several times I have had a look around the usual places where loose gear is deposited after storms, I’ve either found no grow-out bags! Or, only a few bags. An outstanding development from my perspective. Hopefully the number of floating bags carried out the mouth of Tomales Bay into open waters is equally small.

That said, we still have lots of oyster farming legacy (OFL) debris to remove from Tomales Bay.

As always, click on an image to see a larger version.

44 abandoned grow out bags recovered from NE corner of Tomales Bay.

Storms come from the south in these parts. Poorly secured bags and other gear is generally blown off the leases to the NE corner of the bay, where it festers and sinks into the quicksand-like mud.

I recently spent the better part of a day crawling around the eastern portion of lease M-430-15 recovering 44 vintage bags. Only one of which was leftover from the 1982 flood event that buried thousands of bags belonging to the now defunct International Shellfish Enterprises (ISE). Read more about ISE abandoned debris here. The rest were either from TBOC, or, from unknown growers. Unknown since the growers DO NOT tag their gear to make it easy to identify, yet.

44 abandoned grow out bags along with lumber that was once the support structure for “stanway” culturing tubes. Stanway are still used by one grower to hold many thousands of baby oysters.

One grower is changing the way bags of oysters are attached to iron racks. Instead of using plastic coated copper wires that are untied and dropped in the bay to pollute after one use, rubber ties are now used, which may be re-used, or more easily recovered so as not to litter beautiful Tomales Bay.

Wires collected from the mud after being dropped (the old way)

About 20 pounds of plastic coated copper wire i picked up from under the racks, laying in the mud on lease M-430-17, run by Point Reyes Oyster Company.

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First attempt at a new attach method – these rubber bands proved to be too weak and snapped under pressure from the tide.

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Second attempt at a new attach method – these bands look to be up to the task.

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This is looking more and more like Authentic Stewardship and I thank the growers for their efforts.

 

Growers

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Now is the time for the Fish & Game Commission and Department of Fish & Game to show similar improvements in their methods.

Regulators

Crab fisherman on strike for $3 a pound, should hold out for $6! Seafood tax a healthy idea.

Click on the text above “Crab fisherman on strike for $3 a pound…” to see this entire post.

Another crab season is upon us, like last year it is far from “normal”. But then again, with respect to the global environment, normal is undergoing radical changes.

Last year the season was delayed for months due to toxic levels of domoic acid in crab flesh (along with many other sea creatures).

This year the agency tasked with regulating crab fishing, the California Department of Fish & Wildlife has sequentially opened small regions of the California Coast to fishing as domoic acid levels drop below safe thresholds.

Instead of one price negotiation at the beginning of the season, wholesale buyers have decided to hold new talks for each region that opens up for fishing.

Bodega Bay fisherman are none too happy about this and have gone on strike. Fisherman want $3 a pound, buyers are offering $2.75 a pound.

Crab fishing is a boom and bust proposition, a few good years followed by a few not so good years. Fisherman try to offset these declines with a good salmon season, though “good salmon season” is a bit of a contradiction in terms of late.

Humans have for decades damned rivers, denying these ancient fish the spawning grounds they need, diverted water from rivers to give farmers water so they can grow almonds, cotton, pistachios and other high margin crops in what was originally the California desert. Pesticide and Herbicide use, clear-cut logging and creek-side construction have further degraded the environment to the point of near extinction for many historically huge salmon runs.

Both Salmon runs and crab populations are under attack, by humans!

Instead of asking for $3 a pound, I advocate crab fisherman hold out for $6.

Give fisherman $3 for each pound and put the other $3 into a fund used to undo the damage we humans inflict on the sea with our insatiable appetite for, well, damn near everything.

Think of it like a carbon tax. The new crab tax.

Set aside money for people like myself and the legions of others that walk our beaches picking up the mess of plastic ropes, plastic bait jars, plastic foam floats, crab traps left on our beaches each crab season to be ground in to a plastic soup by wave action. A soup that becomes part of the food chain of the planet See this post from two years ago for images of what crab fishing does to Point Reyes National Seashore each year.

Human trash collected from Point Reyes beaches during six visits

Research on how to collect crabs without endangering whales could be funded with this crab tax.

Humpback Whale entangled in crab fishing gear Photo: E. Lyman/HWS and NOAA

Humpback Whale entangled in crab fishing gear

Thankfully California has for the first time enacted a law that allows crab fisherman to collect abandoned gear after the season closes to reduce these horrible entanglements (and often deaths) caused to whales and other sea-life.

Reports of recent entanglements:

After huge blue whale gets tangled in crab lines, Californians struggle with elaborate rescue mission

Daring rescue of whale off Farallones

While we are thinking clearly and proposing that human harvesting activities pay the true cost to the planet, let’s double the price of salmon and oysters, clams and mussels. Set aside money to be used to clean up the messes we have made, and then figure out how to stop making new messes as we feed ourselves.

Four damns are soon to come down on the Klammath River, opening up over 300 miles of historic spawning grounds to a salmon run completely wiped out 80 years ago. Let’s restore the natural river habitat that nature found worked, instead of trying to use science to build fast growing salmon.
Another view of this troubling news here.

In a few months the California Dept. of Fish & Wildlife will be holding a meeting to discuss Best Management Practices (BMP) for oyster growers in California. A long needed set of common sense rules for an industry that has historically been operated in a “wild west” sense, with lax or little oversight. Please watch this space for an announcement on where and when that meeting takes place so you can voice your support for common sense rules in all leases for use of public lands/waters to profit by private companies. Send me your email address if you’d like to be notified.

Let’s make sure that Tomales Bay looks more like this

Great and snowy egrets in flight. Tomales Bay, mouth of Walker Creek.

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Instead of this

abandoned plastic trays

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