What’s So Special About Burley Lagoon?

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Wildlife, nature’s aesthetics, family and community

Burley Lagoon is a unique body of water that deserves to be treasured and protected. As an estuary with two salmon-spawning streams running directly into it, a mixture of salt and fresh water is present.

The lagoon itself is an embayment that is partially blocked by a sandspit; only a narrow 300-foot channel allows the water level to rise and fall with the tide.

This narrow opening restricts its water exchange with Puget Sound.(1) Because open waters are partially blocked by the natural sandspit, the lagoon is a low-energy environment and serves as a refuge from incoming wave action from Henderson Bay.

The lagoon environment may be protected from the harsher open waters, but this leaves it with a limited flushing capacity. Flushing capacity is important to water quality, ecosystem functions, sedimentation, pollutant distribution and more.(2)

This estuary contains many different habitats, including salt marsh, wetlands, mudflats, rocky beach, tide pools, grass beds, and also provides 45 acres of forage fish habitat.

The lagoon floor itself sits just about a meter above sea level, allowing most of the water to drain out completely with the tide twice every day. This permits the mudflats at the bottom of the bay to be exposed during low tide, providing food sources for waterfowl. The mudflats themselves would typically teem with life. As the tide rises, they can provide feeding grounds for fish, and marine mammals like seals, otter, and sometimes even orca or gray whales. Eelgrass and other salt tolerant nearshore vegetation grow on the edges of the mudflats. Shellfish naturally grow on the rocky shoreline rather than in the mudflats themselves.

This combination of characteristics creates an ecosystem that sustains flora and fauna adapted for these unique living conditions. Friends of Burley Lagoon strives to protect this estuary for future generations, but is concerned this special environment may be at risk. See Our Concerns to see what’s going on in Burley Lagoon now.

(1) Kitsap County Health District Water Quality Program. Burley Watershed Prevention/Restoration Project. Burley Watershed Prevention/Restoration Project Fans Report. Section 2, Project Area Description. 2.1, Burley Lagoon
(2) Jiabi Du, Kyeong Park, Jian Shen, Brian Dzwonkowski, Xin Yu, Byung Il Yoon. (June 8, 2018). Role of Baroclinic Processes on Flushing Characteristics in a Highly Stratified Estuarine System, Mobile Bay, Alabama.


What Is Industrial Aquaculture?

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Plastic grow bags attached to lines on the Burley Lagoon substrate

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Industrializing the Burley estuary

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Geoduck site: Could this be coming to Burley Lagoon?

The definition of aquaculture is “the rearing of aquatic animals for food” (Oxford Languages). People have been eating the shellfish from Burley Lagoon for centuries. Early pioneers described a plentiful harvest that was abundantly found along the shore in its natural state. Aquaculture has been practiced for the past century, initially with simple methods to increase production along with the introduction of foreign bivalves to Puget Sound waters. Early shellfish growers cultivated oysters and clams alongside native flora and fauna with minimal impact to the environment. Residents began to see changes in Burley Lagoon in 2012 with the introduction of more industrial methods and gear meant to boost yields and profits.(1,2,3)

Washington State’s multi-million dollar oyster industry leads the U.S. in farmed bivalves. As of 2021, nearly 40% of all Puget Sound tidelands are currently devoted to commercial shellfish production. (4) The mudflats are prepared by adding layers of crushed shell and gravel on top of the benthos to imitate the natural habitat of wild oysters along the gravel shoreline, but this process also destroys the habitat of native species that reside in the mudflats.(5)

The gear and methods used to grow the shellfish can include raking the bed, use of tractors on the mudflats, “the use of cages, rack-and-bags, trays, surface or floating structures, or long lines suspended over the tide bed. These methods all involve gear, which is predominantly plastic.”(5) In Burley Lagoon, we have seen metal crates, plastic bags, poles, and “predator” netting. Much of the gear contains plastics which can leach into the water and make its way into the food web.(6) The netting not only repels birds and marine animals, but it can also trap them by entanglement or prevent them from reaching their natural habitat in the mudflats.

In addition to the gear, pesticides have been sprayed in Gray’s Harbor and/or Willapa Bay for years to eliminate the burrowing shrimp and non-native eelgrass that may interfere with the shellfish operation.(3,7) Imagine the collateral damage to other species that probably occurred with the application of those pesticides. Washington state allows shellfish growers to spray pesticides on their shellfish beds.(5) Could Burley Lagoon be next? The widespread use of pesticides on our waterways could have untold impacts on critical species.

While shellfish are a valued resource of the Puget Sound, Friends of Burley Lagoon believe industrial aquaculture methods of growing and harvesting have gone too far. We advocate sustainable practices that are environmentally safe and monitored.

(1) DeFracesco J., Murray, K. (2010,March 11). Pest Management Strategic Plan for Bivalves in Oregon and Washington, p. 27-68.
(2) Booth, S.R., (2014, January). Dichotomous key and illustrated guide to the pests of bivalve aquaculture in Washington and Oregon. Pacific Shellfish Institute.
(3) This Isn’t Your Grandfather’s Oyster Farm. (2013). Coalition to Protect Puget Sound Habitat.
(4) Puget Sound Vital Signs: Measures of Ecosystem Health and Progress Toward Puget Sound Recovery Goals. Area of Harvestable Shellfish Beds. (2021). Washington State Department of Health.
(5) Center for Food Safety. (2019, October). Shellfish Aquaculture in Washington: Pesticides, Plastics, and Pollution Impacts to Our Environment. Fact Sheet.
(6) Galloway, T. and Lewis, C. (2016, March 1). Marine Microplastics Spell Big Problems For Future Generations. PNAS. Vol. 113, No. 9, 2331-2333.
(7) History of the Control of Burrowing Shrimp and Non-Native Eelgrass. (2016, April 8). Commission Presentation. Washington Department of Fish and Wildlife.


Estuaries Should Be for Keeps

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Forage Fish, Burley Lagoon

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Find the industry pests in this photo: Sea star, sand dollars, crab and barnacles.

Estuaries are ecologically critical areas and considered one of the most biologically productive ecosystems on our planet. Many marine organisms, including salmon, spend part of their life cycle dependent on estuaries. They are crucial ecosystems that, ultimately, can offer essential life-giving processes and systems to all organisms. Thus, they may be considered invaluable.

An estuary is a transition area where fresh water from rivers or streams meets and mixes with salt water. It is a partially enclosed coastal body of water that has a path to the ocean. Estuaries offer essential nesting and feeding habitats for aquatic flora and fauna and are often referred to as the “nurseries of the sea.” (USEPA, 1993). They also act as buffer zones and provide water filtration which may render them nutrient rich but also subject to substantive pollution. Estuaries need cautious management and oversight to preserve and protect them as natural and essential habitats.

Friends of Burley Lagoon is concerned, not only about the use of plastics and industrial gear in the Burley estuary through proposed geoduck production and the harvesting process which disrupts sediment, but also about any proposals for the use of pesticides on shellfish bed areas in Washington State. (See Green Washington’s Shameful Little Secret here in Read & Learn.) What is allowed in one area can set precedent for others. Contaminants may infiltrate food chains and invade the food web, affect all consumers in the food web, including humans, and cause undue stress on the estuary ecosystem. The cumulative effects of these practices and stresses remain undetermined, and estuaries are not replaceable.


A Slight Disruption in a Food Web Can Cause Big Ripples

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The forage fish feed the salmon, and the salmon feed the orcas.
(Orca photo by Ingrid Shumway, Carr Inlet, 2021)

A food web is a complex, interconnected system that provides multiple options of nourishment for living organisms in an ecosystem. Food chains, formed by a lineal order of organisms with each becoming food for the next in the sequence, together create a food web. Food webs rely on adequate biodiversity, a wide variety of members, to maintain stability and sustain life forms in an ecosystem..

Even slight disruptions in the food web can have profound effects on the living organisms in an ecosystem, including extinction. Because each living organism’s role is interconnected to the others’ roles, if one species is impacted, the food web’s entire system of nourishment can be affected.(1) An initial long term study completed by the University of Washington and the National Oceanic and Atmospheric Administration’s Northwest Fisheries Science Center indicated the materials and practices used at industrial geoduck sites can cause change that could send ”problematic ripples throughout the entire ecosystem.”(2) The research determined the gear used to produce geoducks, not the geoducks themselves, impact the marine environment and its wildlife.

The Burley Estuary is already subjected to industrial aquaculture methods and gear with plastic netting stretching across tideland, added oyster shell and/or gravel altering its substrate, and collection bags and crates for clams or oysters sitting on its bed. The introduction of more plastics, along with the particular gear and practices of the proposed geoduck production, could additionally impact the numbers of existing resident species in the estuary. (See What Is Industrial Aquaculture? here in Read & Learn.) A change in numbers could trigger a domino effect in the food web, eventually reaching “birds like heron and eagles and predatory fish like salmon [that] have been deserting Puget Sound.”(3) At a time when much effort and funding are going into the protection, preservation, and restoration of aquatic environments and support of ecosystems to save marine life such as salmon and orcas, it seems contradictory to be simultaneously risking them and the food webs that sustain marine life.

The expansion and impacts of industrial aquaculture sites on our tidelands, particularly y geoduck production with its reliance on plastics and gear, may affect aquatic ecosystems across Puget Sound. Researchers have indicated “further studies are needed to determine the potential impact of more aquaculture activities on specific areas of the Sound.”(4) Existing and proposed aquaculture sites have different characteristics. Each site deserves to be scrutinized individually for the impacts it may sustain from industrialized aquaculture, and what those impacts could mean for the whole of Puget Sound.

(1) Setala, O. (2018). Microplastics in Marine Food Webs. Science Direct.
(2 & 3) Nozowitz, D. (2015, October 30). Is This 3-Foot Long Phallic Clam Killing Puget Sound, UW News, para. 4-6.
(4) Ma, M. (2015, October). Aquaculture gear, not geoducks, impacts ecosystem if farming increases. UW News, para.15.


Eelgrass: Spray It or Save It?

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Eelgrass and seaweed at low tide

Native eelgrass beds have been an integral part of the Burley Lagoon environment. In years past, numerous surveys have documented eelgrass beds in the Burley estuary. More recent data is conflicting, but has shown levels to be spotty and diminished, or there is insufficient data to make a determination.(1) Friends of Burley Lagoon questions what effect industrial aquaculture has had on eelgrass, and if its changing levels have been consistently monitored.

Eelgrass plays a vital role in the habitat of the estuary. Eelgrass meadows flourish in shallow, intertidal zones and the eelgrass roots anchor to the sediment at the bottom of the bay, preventing erosion and offering shelter and food for many fish and invertebrates.(2,3) While some waterfowl may feed on it, other smaller creatures use its cover to evade predators.

Many fish lay their eggs among the eelgrass blades, and young sea creatures use it as a nursery and thrive in its protective shade. Salmon feed on the forage fish that live in the eelgrass; and, in turn, our resident orcas feed on the salmon.(4)

The health of the estuary also depends on eelgrass to help filter and clean the water and produce oxygen while storing carbon dioxide. In fact, protecting eelgrass could have impacts on climate change. It has been shown that “an acre of seagrass can store about three times as much carbon as an acre of rainforest.”(4)

Eelgrass has been listed as a weed by the industry.(5) We are concerned that eelgrass may be impacted by the industry’s operation. Our estuary and our environment cannot afford to lose any more of this precious resource.

(1) Nearshore Habitat Eelgrass Monitoring. (2021). Washington State Department of Natural Resources.
(2) Conversation: All About Eelgrass. Richardson Bay Audubon Center & Sanctuary. National Audubon Society.
(3) Feature Story: The Importance of Eelgrass. (2014, November 7). National Oceanic and Atmospheric Administration (NOAA).
(4) Eelgrass: San Juan Islands Eelgrass Recovery Pilot Project. San Juan Islands Conservation District.
(5) DeFracesco J., Murray, K. (2010,March 11). Pest Management Strategic Plan for Bivalves in Oregon and Washington, p. 27, 50.


Pesticides: Green Washington’s Shameful Little Secret

Though pesticides are currently not used on shellfish beds within Puget Sound, they are used on some Washington coastal shellfish growing areas. Washington State, through the former Departments of Fisheries and Agriculture and the Washington Department of Ecology, has allowed the use of pesticides on commercial shellfish beds in Willapa Bay and/or Grays Harbor to eliminate burrowing shrimp and non-native eelgrass.(1) Because of this precedent, Friends of Burley Lagoon is concerned about future decisions that could permit wider pesticide use on Washington shellfish beds. Aquaculture is a large, influential industry, and it has been persistent in seeking state approval and legislation to support pesticide use over the years.  Washington State permits using pesticide on shellfish beds.(2)

Beginning in 1963, Carbaryl, an insecticide, was allowed in the coastal waters of Willapa Bay and Grays Harbor on large, commercial oyster beds to kill native burrowing shrimp. The amount of Carbaryl was later reviewed, and use allotments were reduced. A lawsuit in 2003 ended with shellfish growers consenting to cease using Carbaryl by 2012. A replacement pesticide treatment was sought by the industry.(3)

Imidacloprid, a neurotoxin and type of neonicotinoid, was deemed an alternative to Carbaryl, and the Washington Department of Ecology approved a permit for its use against burrowing shrimp in 2015.(4,5) However, neonicotinoids are a danger to bees and other pollinators and the Imidacloprid manufacturer’s warnings, quoted below, among others about the product, caused a public outcry against its use. The shellfish growers rescinded that permit and the product was not used.(6,7)

Do not apply directly to water, areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment wash waters. This product is highly toxic to bees exposed to direct treatment or residues on blooming crops or weeds…This product is toxic to wildlife and highly toxic to aquatic invertebrates... The use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in groundwater contamination... OBSERVE THE FOLLOWING PRECAUTIONS WHEN MIXING AND APPLYING IN THE VICINITY OF AQUATIC AREAS SUCH AS LAKES; RESERVOIRS; RIVERS; PERMANENT STREAMS, MARSHES OR NATURAL PONDS; ESTUARIES AND COMMERCIAL FISH FARM PONDS... Do not apply by ground within 25 feet, or by air within 150 feet of lakes; reservoirs; rivers; permanent streams, marshes or natural ponds; estuaries and commercial fish farm ponds.” (8)

Shellfish growers again applied for a permit to use Imidacloprid on commercial beds in 2016 but were denied the permit by the Washington State Dept. of Ecology. The growers appealed.  Eventually, an agreement was reached that Imidacloprid would not be used, and monitoring and studying of burrowing shrimp would be implemented. However, “while the use of Imidacloprid will be prohibited by the terms of the settlement, the agreement allows consideration of spraying alternative chemicals and includes no commitment preventing oyster growers from requesting a permit for Imidacloprid use in the future.”(9)

Another pesticide, Imazamox, has been used in Willlapa Bay to rid growing areas of non-native eelgrass. Non-native eelgrass, Zostera japonica, is thought to have arrived
here through oyster seed shipments from Japan to U.S. growers many decades ago. Non-native eelgrass has long been considered valuable along with native eelgrass, Zostera marina, because all eelgrasses provide habitat, shelter, and nourishment for marine life.(10) Eelgrass has been called the “foundation of the marine food chain” and is considered crucial fish habitat by the federal government. (11, 17) The shellfish industry, however, considers eelgrass, along with other aquatic grasses and algae, weeds.(12)

For years, non-native eelgrass was included with native eelgrass on the Washington Department of Fish and Wildlife Priority Species and Habitat list, but it lost that special status in 2011. Shellfish growers indicated it was overwhelming Willapa Bay, affecting the condition of the bay, and interfering with shellfish production. Native eelgrass, still protected, remained on the priority list.(13) In 2012, non-native eelgrass was labeled a class C noxious weed on commercial shellfish beds by the Washington State Noxious Weed Control Board.(14)

The Washington Department of Ecology, at the request of shellfish growers, then initiated the Environmental Impact Statement (EIS) process regarding control strategies.(15) During the EIS process, the Washington Department of Natural Resources questioned whether Imazamox applications on non-native eelgrass might also harm native eelgrass since the two eelgrasses often intermingle or grow close to one another. At the conclusion of the EIS process in 2014, a permit to use Imazamox in Willapa Bay until May, 2019 was issued, and use of the pesticide was allowed as of May, 2014.(15) In April, 2020, a general permit was granted for the use of Imazamox on clam beds in Wallapa Bay until March 3, 2025.(16)

Both native and non-native eelgrasses are considered detriments to productivity by the shellfish industry. A management guide for shellfish growers states: “Native eelgrass causes similar problems for bivalve production as Japanese [Zostera japonica] eelgrass. However, native eelgrass is regarded by the federal government as essential fish habitat…The appearance of native eelgrass on shellfish beds where it has never been previously, and the spread and growth of small patches within bivalve production beds, causes extensive crop, bed, and equipment damage. Crop yields, seed recruitment, and growth are reduced. Labor is increased due to fouling, and equipment damage is common. Thick eelgrasses can completely cover and hide shellfish on the beds, making harvest difficult. Thick stands of eelgrass are not conducive to geoduck farming; therefore, growers generally do not plant geoduck in existing beds of native eelgrass.”(17) Eelgrass, “the foundation of the marine food chain,” may cause problems for some shellfish growers pesticides might solve, but what problems might that remedy then cause?

Washington’s aquaculture industry provides a delicious and needed food source and is a welcome boon to the state’s economy. However, some commercial shellfish growers successfully farm without reliance on pesticides. Their model should be promoted.(18) Friends of Burley Lagoon supports responsible and environmentally sound decisions involving the aquaculture industry that preserve and protect Washington tidelands and waters. However, we should not have to sacrifice marine habitats and ecosystems to enhance commercial endeavors. To that end, we support a thriving, biodiverse aquatic environment in the Burley estuary and throughout Puget Sound that sustains a balanced marine polyculture of aquatic species without reliance on pesticides.

(1) WA Department of Fish and Wildlife. (2018, April 8). History of the control of burrowing shrimp and non-native eelgrass. Commission Presentation.
(2) Center for Food Safety. (2019, October). Shellfish Aquaculture in Washington: Pesticides, Plastics, and Pollution Impacts to Our Environment. Fact Sheet, pg. 3.3.
(3) WA Department of Fish and Wildlife. (2018, April 8). History of the control of burrowing shrimp and non-native eelgrass. Commission Presentation.
(4)Center for Food Safety. (2019, October). Shellfish Aquaculture in Washington: Pesticides, Plastics, and Pollution Impacts to Our Environment. Fact Sheet, pg. 3.
(5) WA Department of Fish and Wildlife. (2018, April 8). History of the control of burrowing shrimp and non-native eelgrass. Commission Presentation.
(6) Center for Food Safety. (2019, October). Shellfish Aquaculture in Washington: Pesticides, Plastics, and Pollution Impacts to Our Environment. Fact Sheet, pg. 3.
(7) WA Department of Fish and Wildlife. (2018, April 8). History of the control of burrowing shrimp and non-native eelgrass. Commission Presentation.
(8) Labeling Amendment to Imidacloprid. (2009, December 24,). Section: Environmental Hazards, No-Spray Zone Requirements for Foliar Applications. United States Environmental Protection Agency. Section: Environmental Hazards, No-Spray Zone Requirements for Foliar Applications.
(9) Center for Biological Diversity. (2019, October 21). Agreement Protects Willapa Bay, Grays Harbor from Spraying of Dangerous Pesticide, para. 6.
(10) Center for Food Safety. (2019, October). Shellfish Aquaculture in Washington: Pesticides, Plastics, and Pollution Impacts to Our Environment. Fact Sheet, pg. 3.
(11) Yeo, L. (2019, April 11,). OPINION: Loss of eelgrass can’t be ignored. Saltwater Network (online), para. 11.
(12) DeFracisco J, Murray, K. (2010, March 11). Pest Management Strategic Plan for Bivalves in Oregon and Washington, p. 27.
(13) WA Department of Fish and Wildlife. (2018, April 8). History of the control of burrowing shrimp and non-native eelgrass. Commission Presentation.
(14) Sierra Club, Washington Chapter. (2011, December 4). Shellfish Industry Plans to Eradicate Japonica Eelgrass in Washington Also Threatens Native Eelgrass, para 4.
(15) WA Department of Fish and Wildlife. (2018, April 8). History of the control of burrowing shrimp and non-native eelgrass. Commission Presentation.
(16) State of Washington Department of Ecology. (2020, March 4,). Zostera Japonica Management on Commercial Clam Beds in Willapa Bay ,General Permit.
(17) DeFracisco J, Murray, K. (2010, March 11). Pest Management Strategic Plan for Bivalves in Oregon and Washington, p. 50.
(18) Center for Biological Diversity. (2019, October 21). Agreement Protects Willapa Bay, Grays Harbor from Spraying of Dangerous Pesticide, para. 4.


Hazardous Waters: Recreation?

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Non-deployed buoy = Unmarked crate

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Water Hazard in Burley Lagoon

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Loose predator nets surround skidoo

Recreationists must certainly be responsible and remain cautious and alert for obstacles or dangers whenever they are on the water, but having added hazards because of industrial gear in a recreational area can discourage recreation and inhibit passage over the water. The Public Trust Doctrine protects the passage of citizens over the navigable waters of public and private tidelands, and the intent of the Shoreline Management Act, adopted by voters in 1972, declares recreation on Washington’s shorelines a preferred use.

Residents around the Burley estuary have concerns about industry practices that add what may be considered hazards for recreationists in the lagoon. Citizens have witnessed metal crates in the Burley estuary without clear markings to outline their perimeter configuration and location when covered by the water. The placement of these crates varies over time.

Boaters may not know how far out or in what direction the crates extend. The surface buoys can be difficult to see with the glare of the sun. Crate buoys, designed to float up to the surface, do not always deploy. At times, buoys have been placed across the water, limiting the space for boats passing to a narrow stretch along a perimeter section of the lagoon.

Anchored plastic poles used by the industry dot the estuary and can fall and be left protruding from the water at varying angles or floating on the surface of the water. These can be dangerous to boaters, skiers, and tubers who glide out beyond the wake of a boat. Nets have come loose and floated upward. One boater’s outboard engine became entangled in a net, causing an abrupt stop. Passengers were thrown forward from their seats, and a boater hit his head on the windshield. Jet skiers have also encountered loose nets floating just below the surface of the water.

Washington’s Shoreline Management Act “reflects the strong interest of the public in our shorelines and waterways for recreation, protection of natural areas, aesthetics, and commerce.”(1) Friends of Burley Lagoon believes the interest of the public’s recreational opportunities on Washington waters, along with the enjoyment and beauty of natural areas, should receive no less consideration and support than private industry.

(1) Dept. of Archeology & Historic Preservation. (no date). Shoreline Management Act. www.dahp.wa.gov


Water Quality Is Not Just for Shellfish

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Family Recreation

Burley Lagoon has been monitored for fecal coliform bacteria levels by the WA State Dept. of Health for many years because commercial clams and oysters are grown in its waters. Citizens have access to the data from the Burley Lagoon Water Quality Team through meetings and online. Friends of Burley Lagoon members have attended the meetings as interested citizens for many years.

The water quality of the Burley estuary is based on coliform counts and has fluctuated among the classifications of the WA State Dept. of Health. The classifications include: Approved, Conditional, Prohibited, Restricted, and Unclassified. Based on the various classifications of water quality, shellfish may or may not be harvested for human consumption. Residents, however, are concerned about the water quality, not only for shellfish, but also for the sake of the estuary itself, its resident flora and fauna, and for those who frequent its shores.

After concerning downgrades in water quality in 1999, the Burley Lagoon Water Quality Team, a collaboration of department representatives from Washington State and Pierce and Kitsap Counties, began to seek solutions. Input from shellfish industry representatives and citizens has been included at the meetings. In 2018, when 101 acres of the lagoon were downgraded to Conditionally Approved, a Closure Response Plan was developed to determine actions to take to improve and, hopefully, maintain adequate water quality for shellfish harvesting.

Citizens continue to worry about what the cumulative impacts of intensive industrial aquaculture and the conversion of 25 acres of lagoon tideland into a farmed geoduck site, if approved, could have on the water quality of the lagoon overall. Particular geographic and geologic characteristics of the Burley Lagoon area may render it less capable of withstanding the stress of intensive, industrial aquaculture. (See What’s So Special About Burley Lagoon? here in Read & Learn.) Our concerns go beyond fecal coliform counts and include lagoon capacity, its low-energy flushing capability, plastics contamination, acidification from sediment disruption and suspension, oxygenation, nutrient levels, and more.

Information about the Burley Lagoon Water Quality Team and lagoon data may be found at: