Wild Fish Conservancy staff recently submitted comments to the Pierce County planning department on a draft Environmental Impact Statement regarding a proposed geoduck aquaculture project in Burley Lagoon. We outline several points of concern in our comments including:

• The DEIS environmental analysis does not adequately consider the impacts of this project on ESA-listed Chinook salmon and other juvenile salmonids that use Burley Lagoon as nearshore rearing habitat.
• Nearshore embayments are important rearing habitat for juvenile Chinook and other salmon species. Embayments like Burley Lagoon are used as rearing habitat by juvenile Chinook due to the opportunities for feeding and temperature regulation that are provided relative to adjacent open water nearshore sites. 
• The project will prevent the re-establishment of eelgrass beds in the area of the project footprint. Eelgrass habitats are a critically important nearshore habitat that provide food and shelter for juvenile salmon and forage fish. 
• The DEIS does not consider the effects of project operations on the detrital-based food web upon which juvenile Chinook salmon rely.

In summary, Wild Fish Conservancy believes that further analysis is necessary before a project of this nature can be approved. To prevent shifting baselines it is important to conduct an analysis of current and historic habitat available to juvenile salmonids in the vicinity of the project and to study the impacts caused by current geoduck aquaculture operations in embayments in Pierce County. Additionally, an analysis of the overlap between the modeled potential eelgrass habitat and the geoduck operations in embayments within the region should take place.

To read our full comments click this link.