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)

Geoduck clam cultivation in Puget Sound, is Tomales Bay next?

Click on the above words “Geoduck clam cultivation in Puget Sound, is Tomales Bay next?” to see this entire post.

I support responsible, sustainable shellfish aquaculture, practiced in the public waters by authentic stewards of the land and sea.

The recent application from San Andreas Shellfish of Dillon Beach to cultivate, among other species Geoduck Clams in Tomales Bay is cause for concern.

Read about the lease application process here.

Citizens of the Puget Sound area have for many years been working hard to protect their beautiful coastal seascape from commercial geoduck clam cultivation. This practice, quite profitable to some, pollutes far and wide, contributing significant amounts of plastic to an already toxic sea, as well as turning an otherwise sublime natural scene, into a dystopian nightmare.

The images that follow show what the practice of geoduck clam cultivation does to the environment. Do these images portray authentic stewardship?

Tomales Bay is already significantly degraded by the current and past practice of oyster, clam and mussel cultivation. Over 140 years of aquaculture have left a deep, disgraceful legacy in Tomales Bay. Before any new leases are approved, the California Fish & Game Commission and California Department of Fish & Wildlife shall clean up the tons of debris littering the bay, the Oyster Farming Legacy (OFL – rhymes with awful).

See the OFL still polluting Tomales Bay here.

If you feel strongly about protecting the unique beauty of Tomales Bay, please write the following people and let them know you want them to clean up the Oyster Farming Legacy trash blighting Tomales Bay before any new leases are approved.

Diane Windham – Southwest Regional Aquaculture Coordinator, National Oceanic and Atmospheric Administration (NOAA) – Sacramento, CA
diane.windham@noaa.gov

Randy Lovell – State Aquaculture Coordinator – ‎California Dept of Fish & Wildlife (CDFW) – Sacramento, CA
randy.lovell@wildlife.ca.gov

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

Click on an image to see a larger version.
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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

High pressure water jets are used to liquify the substrate to loosen the clam for harvest. Damaging or destroying any other organisms in the area.

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

High pressure water jets are used to liquify the substrate to loosen the clam for harvest. Damaging or destroying any other organisms in the area.

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Image courtesy http://coalitiontoprotectpugetsoundhabitat.org

What Puget Sound looks like after harvest is complete.

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New Application to cultivate Shellfish in Tomales Bay

Click on the words above “New Application to cultivate Shellfish in Tomales Bay” to see this entire post.

On Thursday February 9th at a regular meeting of the California Fish & Game Commission (CFGC) in Rohnert Park, the CFGC received an application from Robert Brodsky and his company, San Andreas Shellfish. The application is to lease, from the public trust, approximately 45 acres of state water bottoms for the cultivation of shellfish within Tomales Bay. The application may be viewed here.

Below you can see one of the maps from the application that shows the area the application wishes to lease in bright yellow, superimposed upon a photograph of the area from above.

To see a larger version, click the image, on new page click the “1981×1180” above image and below the word donate

The general area up for consideration in the lease is the eastern portion of the bay between Tom’s Point and Lawson’s Landing.

The species which Mr. Brodsky would like to be able to cultivate are: Pacific Oyster, Atlantic Oyster, Kumamoto Oyster, Mediterranean Mussels, Goeduck Clam and Purple Hinged Scallop.

If granted, the lease could be a maximum of 25 years, per Fish and Game Code 15405.

Before a lease is granted, the following must occur:

1 The CFGC will refer the application to the California Department of Fish & Wildlife (CDFW). CDFW will evaluate the application and make a recommendation on whether or not the proposed activities are in the public interest (per Fish and Game Code 15404)

Once the evaluation is complete, the CDFW will provide a recommendation to the Commission.

2 CFGC will place the item on the agenda of the next CFGC meeting. The public will be able to comment on the item at this time regarding public interest.

If the CFGC determines that the area applied for is available for lease and that the lease would be in the public interest, CFGC shall publish a notice that the area is being considered for leasing. No aquaculture lease for state water bottoms will be approved until the Commission has held a public hearing at least 90 days after notice thereof has been published in a newspaper of general circulation within the county involved.

In addition, California requires state and local agencies to perform environmental impact analyses when granting permits. Potential environmental impacts are addressed primarily through the California Environmental Quality Act (CEQA) review of the proposed facility. Although not a permit, CEQA compliance is mandatory for state, local, and other agencies subject to the jurisdiction of California to evaluate the environmental implications of their actions.

After the CEQA process is complete, the CFGC will again:
3 Place the item on the agenda of a CFGC meeting where the Public may comment on the CEQA evaluation and final approval of the lease.

At this time, the CFGC will make a decision on whether to certify the CEQA document and whether to approve the lease.

Should a lease be approved, the applicant will also need a variety of permits and other authorizations, including from the Coastal Commission and U.S. Army Corps of Engineers.

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Read the next related post on this topic here.

Tomales Bay Disrespected – PROC still making a mess of Tomales Bay, FGC poised to renew leases anyhow???

Point Reyes Oyster Company (PROC) has been making a mess of Tomales Bay for decades. While long overdue, this past February the California Fish & Game Commission properly denied PROC’s 15-year lease renewal request on two leases to grow oysters & clams in Tomales Bay.

The leases were extended for up to twelve months to give PROC time to clean up the unacceptable mess of marine debris they’d made and show that they could raise oysters & clams in a responsible manner with a modicum of stewardship for our public lands.

When the agenda for the June meeting of the Fish & Game Commission arrived in my in-box last week, I was angry and disheartened because I knew that the substantial marine debris issues that I and others had raised previously have still not been addressed. This is very troubling, and that is why I plan to travel to Bakersfield next week to urge the Commission to continue to delay PROC’s 15-year lease renewal request until the company has demonstrated for a minimum of six (6) continuous months that it can be a responsible oyster operator on our public lands in Tomales Bay.

If you care about the health of our bay and the planet, please write California Fish & Game Commission at fgc@fgc.ca.gov and request that they NOT renew leases for Point Reyes Oyster Company until PROC proves it is a responsible grower and does everything possible to minimize loss of gear AND regularly patrols the bay and picks up the gear they do lose. I do not have a problem with our State leasing public water bottom lands for oyster growing so long as the oyster operators treat these leases as the privilege that they are, and exercise a stewardship ethic for Tomales Bay that is also part of the Greater Farallones National Marine Sanctuary, and don’t add significant amounts of marine debris to our ecosystem. Once PROC has actually demonstrated that it can be a responsible oyster operator for six months, I would be happy to support its longer lease renewal. However, I cannot support the company receiving a lucrative lease on our public lands at this time given their very poor care of Tomales Bay.

Here is text from the “outcomes” section of February’s FGC meeting during which the leases were NOT renewed:

 
11. Point Reyes Oyster Company, Inc. State water bottom leases for aquaculture

(A) Approve request to renew State Water Bottom Lease No. M-430-13
(Pursuant to Section 15406, Fish and Game Code)

(B) Approve request to renew State Water Bottom Lease No. M-430-17
(Pursuant to Section 15406, Fish and Game Code)

Received public comment.

The Commission approved a one-year extension of state water bottom lease Nos.
M-430-13 and M-430-17 under existing terms and conditions in lieu of lease
renewal, to allow the California Department of Fish and Wildlife Marine Region to
evaluate terms of a lease renewal, use of best management practices, and any other details that would be important for this lease. The Commission will consider renewal once lease practices and terms are clarified and resolved.

Ayes: E. Sklar, J. Hostler-Carmesin, A. Williams

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Have a look at the images below and decide for yourself if PROC has made any significant progress in reducing the amount of plastic, plastic coated copper wire, rubber and other gear abandoned in Tomales Bay as they profit from the the very same waters.

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Here we see a small portion of lease 17 near the mouth of Walker Creek where PROC appears to be growing oysters with the bag & rack method.

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This image was recorded on March 14, 2015 Notice the bags strewn all over the bay floor.
©RJames.IMG_0310

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Another image from March 14, 2015
©RJames.IMG_0311

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Shortly after their lease renewals were denied, PROC workers came out to collect loose gear and straighten up the same area. The workers told me to come out in two weeks and I would not recognize the place it would be so clean.
©RJames.IMG_3298

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©RJames.IMG_3297

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Two main things were done during this cleanup. 1) PROC workers collected dozens of bags no longer securely fastened to the iron racks designed to contain them. 2) Instead of securing the bags with plastic coated copper wire (which PROC has been dropping into the bay during harvest for many. many years), they changed fasteners and used rubber straps and plastic coated metal clips.

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18 days after the cleanup, we see the bags are starting to come loose again. Close inspection reveals the straps are being stretched too tight and snapping. I shared this information with DFW staff as well as two oyster growers (I did not have PROC email info at that time)©RJames.IMG_3830

©RJames.IMG_3828

©RJames.IMG_3826
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Nearly 4 months months after their cleanup, we see the area closely resembles how it looked 18 months BEFORE the cleanup, bags loose and again at the mercy of wind and tides.
©RJames.IMG_5356

©RJames.IMG_5374

©RJames.IMG_5369

©RJames.IMG_5368

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That tightly stretched rubber strap above is about to snap, letting this bag to be carried by wind and current.
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Not only is the new method to secure bags to racks by PROC NOT working, it is releasing yet another type of plastic debris into Tomales Bay. The image below shows what was collected in 1.5 hours from Lease 17 run by PROC.

plastic coated copper wire, rusty iron rods, white plastic coated metal clips, rubber straps, zip-ties and rope with stainless clips collected from lease 17 on 5 June, 2016.

plastic coated copper wire, rusty iron rods, white plastic coated metal clips, rubber straps, zip-ties and rope with stainless clips collected from lease 17 on 5 June, 2016.

The loose bags are bad enough when they blight our beaches, or in less than a month become embedded, invisible parts of the ecosystem.
©RJames.IMG_5423

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IMG_1075

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This bag lay here for less than 3 weeks.

This bag lay here for less than 3 weeks.

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The bigger problem is when these bags are struck by boat props and cut into pieces which present a hazard to wildlife which eat this small plastic debris. One local fisherman caught a tuna 50 miles offshore with a small piece of oyster grow out bag embedded in its flesh. Plastic like that below embedded in the flesh of tuna.

Tiny shards of plastic oyster farming debris collected in Tomales Bay. ©Richard James - coastodian.org

Tiny shards of plastic oyster farming debris collected in Tomales Bay.
©Richard James – coastodian.org

Shards of plastic oyster farming debris collected in Tomales Bay. ©Richard James - coastodian.org

Shards of plastic oyster farming debris collected in Tomales Bay.
©Richard James – coastodian.org

Shards of plastic oyster farming debris collected in Tomales Bay. ©Richard James - coastodian.org

Shards of plastic oyster farming debris collected in Tomales Bay.
©Richard James – coastodian.org

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If you care about the health of our bay and the planet, please write California Fish & Game Commission at fgc@fgc.ca.gov and request that they NOT renew leases for Point Reyes Oyster Company until PROC proves it is a responsible grower and does everything possible to minimize loss of gear AND regularly patrols the bay and picks up the gear they do lose. I do not have a problem with our State leasing public water bottom lands for oyster growing so long as the oyster operators treat these leases as the privilege that they are, and exercise a stewardship ethic for Tomales Bay that is also part of the Greater Farallones National Marine Sanctuary, and don’t add significant amounts of marine debris to our ecosystem. Once PROC has actually demonstrated that it can be a responsible oyster operator for six months, I would be happy to support its longer lease renewal. However, I cannot support the company receiving a lucrative lease on our public lands at this time given their very poor care of Tomales Bay.

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Save our Tomales Bay – 36 Please write Calif. Fish & Game Commission NOW

Oyster farming in Tomales Bay has been taking place for well over one hundred years. The nature of farming oysters means it is often done in hard to get to places, where common citizens seldom venture. During this lengthy time, a variety of growers with varying levels of respect for the environment, and poor to no oversight by the agencies tasked with protecting the coastal waters have left a legacy of trash throughout Tomales Bay that few people know is out there. Look here to see the many messes I speak of.
 

In the coming months, a number of oyster growing leases are up for renewal. It is critical that these leases, written decades ago, be updated to include Best Management Practices and that the loopholes in cleanup escrow accounts be closed so that each lease is clear on how Tomales Bay is to be cared for and the escrow funds can and will be used if need be for cleanup as intended.

 

These requests are not critical of Hog Island Oyster growing practices (whose lease is up for renewal at the 9-10 December CFGC meeting) and are intended as improvements to all leases for all growers. Hog Island is an exceptional grower that works hard to minimize lost gear and reduce the negative impacts of oyster growing on Tomales Bay. We want ALL growers held to the same improved standards and request that all future leases and lease renewals include the following language. Tomales Bay deserves improved protection from all oyster growers.

 

We also want the Fish & Game Commission and Department of Fish & Wildlife to use their role as “landlord” and “law enforcer” more effectively. Updating the lease language is a good first step and shows they intend to represent the best interests of the people of California. If California is to have one agency that both promotes oyster farming, as well as protects nature from oyster farming, that agency needs to take more seriously the protection part of their mission.

 

Lease M-430-15 held by Hog Island Oyster Company is up for renewal at the California Fish & Game Commission (CFGC) meeting in San Diego on 9-10 December.

 

Please write the Executive Director of the CFGC and request that all new leases include the Best Management Practices described here and that loopholes concerning the cleanup escrow account be closed.

 

 

Please write this individual now! He needs to hear from you before these meetings.

Mr. Sonke Mastrup
Executive Director
California Fish and Game Commission
P.O. Box 944209
Sacramento, CA 94244-2090

fgc@fgc.ca.gov
phone 916-653-4899

 

Director Mastrup, please include the following Best Management practices in all new leases, sub-lease agreements and lease renewals.

Best Management Practices Required of Tomales Bay Oyster Farmers

 

  1. Each grower must use uniquely identifiable gear
    Collected abandoned gear must have an easily known owner so that habitual litterers may be dealt with individually. To identify gear, growers must use unique bag colors and unique copper wire colors.

 

  1. Have 2 staff positions whose sole role is litter recovery
    One person that does nothing but litter patrol and cleanup. A second rotating position so that all employees see the issues and learn to reduce litter during daily operations.

 

  1. Growers must continually strive to improve gear design to reduce lost gear
    Conduct yearly meetings with third party monitor(s) to learn what is working, what is not.

 

  1. Replace single-use items such as litter-making zip-ties with reusable items such as stainless halibut clips
    If copper wire is used, each grower has assigned colors. Growers will recover all copper wire once bags are collected at harvest.

 

  1. Prohibit the use of plastic wrapped blue foam and other easily degradable floats
    Floats must be durable and resistant to pecking by birds. Floats must be securely attached to the oyster bag.

 

  1. Prohibit the current practice of tossing out loose bags at high tide
    All bags must be securely connected in a string to prevent drifting and loss during the time between mass deployment and being tied to anchor lines.

 

  1. Prohibit leaving of tools and materials leases, inter-tidal areas, and all nearby areas.
  2. Growers must remove all uninstalled PVC pipes, gloves, zip-ties, copper wire, ropes, hay hooks, bags and water bottles from lease areas each day.

 

  1. If a growing idea does not work, remove it promptly within 30 days.
    Abandoned pilings, posts, PVC, machinery and other debris left in and around Tomales Bay are no longer allowed.

 

  1. At a minimum, growers must ensure monthly patrols of lease areas and shoreline for lost gear
    Patrols will be increased to twice a month during high winds or storm events. Effective patrols must include walking shorelines and wetlands, and kayaks or other craft should be used for hard-to-reach areas to avoid damaging eelgrass with propellers.

 

 

Director Mastrup, please have third party, objective cleanup estiamtes done to determine the actual cleanup cost of all infrastructure used by oyster growers in ALL growing areas of California (Tomales Bay, Morro Bay, Humboldt Bay etc.). The Commission has made promises to address this since April, yet nothing has been communicated to interested parties on any progress in this very important matter.

 

 

Tomales Bay deserves strong protection so that future generations can enjoy this jewel.

Tomales Bay deserves strong protection so that future generations can enjoy this jewel.


 

 

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Next related post may be found here.

Previous related post may be found here.

See the first post in this series “Save our Tomales Bay” here.