Comments on Army Corps NWP Re-Issuance

On November 16, 2020 the ECSGA joined with the Pacific Coast Shellfish Growers Association (PCSGA) in submitting a comment letter to the Army Corps of Engineers on our general support for the use of Nationwide Permits (NWPs) for activities, such as shellfish farming, which result in no more than minimal individual and cumulative adverse environmental impacts.

The letter made clear that our two organizations believe that several statements and positions made in the proposal would benefit from further justification, and we requested that noted sources included in the letter be included in the Corps’ Decision Document.

Specifically, we requested that the Corps:
• provide further clarification regarding the placement of material, including shell for seeding;
• differentiate between “mechanical harvest” and dredging and fill. The terms are conflated in the document, and practices associated with shellfish culture are not equivalent to those traditionally thought of when using these terms; and
• add references provided in our response since several statements and positions made in the proposal would benefit from further documentation. Specifically, we noted many scientific studies confirming the Corps’ findings regarding the compatibility of aquaculture activities and submerged aquatic vegetation, and the ecosystem services provided by shellfish
aquaculture. We are hoping that these references, as well as others we provided, will help reinforce some of the rationale offered by the Corps for the changes and we requested that they be included in the Decision Documents, as appropriate.

The full text of the comment letter can be found at NWP Reissuance Comments 2020 under the Regulations tab of the ECSGA’s main menu.