This is the first paragraph of the News release prompted my reply:
larry.ragonese@dep.state.nj.us
larry.hajna@dep.state.nj.us
IMMEDIATE RELEASE:
June 7, 2010
Contact: Lawrence Ragonese (609) 292-2994
Lawrence Hajna (609) 984-1795
COMMISSIONER AIMS TO PROTECT PUBLIC HEALTH AND SHELLFISH INDUSTRY
(10/P53)TRENTON* Commissioner Bob Martin today banned research-related
gardening of commercial shellfish species in coastal and inner
harbor waters
classified as contaminated, and also is seeking immediate removal
of species
now being grown in such waters. The goal is to protect the public
health and
the economic health of the state's nationally significant shellfish
industry.
Towards those goals, the Commissioner also said he intends to
revamp the
state's long-term shellfish gardening rules, and announced the DEP
will not
issue new permits for gardening of commercial shellfish, even for
ecologicalrestoration projects, in prohibited or restricted waters.
Reply:
July 13, 2010
Dear Commissioner Martin:
We would like to take issue with the contents of the news release issued by your office on June 7, 2010 (10/P53)
I am the volunteer president of an education and outreach organization called ReClam The Bay, Inc. (RCTB). Through the Barnegat Bay Shellfish Restoration Program we are partners with Rutgers Cooperative Extension, The County of Ocean, Barnegat Bay Partnership (formerly Barnegat Bay National Estuary Program) and in fact, DEP. We use shellfish to educate people; especially the relationship of shellfish health and bay water quality. We have seen, first hand, how growing shellfish attracts young and old. It is estimated that we have reached over 20,000 people since starting in 2005 on a one to one basis, several hundred thousand more through our radio spots. In 2008 our unique approach to environmental education for tourists (ecotourism) with our Clam Trail earned RCTB the Governor’s Award for Excellence in Tourism because it encourages people to come to NJ to learn about the environment. This translates into an educated public and tourist revenue.
A number of us firmly believe that a correctable mistake is being made and we ask that you please reconsider the decision outlined in the news release that will effectively eliminate an extremely powerful tool to combat water pollution; public involvement. We also note that the news release really sounds like the old DEP and the old way of doing business and is wasting taxpayer money.
You and Governor Christie have said publically that you are going to change the way that DEP does business. The news release underscores that things at the DEP have not changed. The statements contained in the news release (some of which are simply wrong) have been kicking around DEP for at least 5 years. DEP spent hundreds, if not thousands or hours and convened meetings at tax payer expense to address the many short comings in the original statement that is obviously the basis of the news release. A major meeting dealing with this very topic was held in June of 2009 at the Assumpink Wildlife Refuge. After all the time and money was invested, the contents of the news release completely ignored the points raised at the meeting and in a draft policy that Bob Connell authored. Rather than using the consensus and knowledge, DEP issued this tired, old, unchanged, unwise and in some cases inaccurate statement. The draft ruling to which I refer was circulated, and we were led to believe that “after a few minor changes” it would be enacted. The old DEP did not keep its word and the policy to which the news release refers has yet to be formalized through any proper regulatory process. DEP has had a bad reputation for “bait and switch” activity. Issuing this news release says “business as usual”.
Here is a simple example of what is wrong. Quoting the DEP statement:
…In those endeavors, a variety of commercial shellfish, including oysters, hard clams and blue mussels, are grown for study purposes. However, poachers could target those locations and steal the shell fish, which could be sold to consumers.
Your staff concealed the fact that the clams and oysters which most education and outreach organizations grow are two to three years away from being the size that consumers would buy. Also, is your staff not aware that Interstate Shellfish Sanitation Commission still seems to allow the use of seed which is at least 6 months from harvest size for shellfish gardeners? We do not grow “poacher worthy” market ready shellfish in contaminated water. We do grow shellfish seed, in this kind of water because we need to grow them where the public can see them and they fall well within the Interstate Shellfish Sanitation Commission guidelines. They are less than 20mm (the size of your pinky) when we put them in the bay. And we only put them in legal areas.
One other suggestion which came from your Department was to use non-edible shellfish in restoration projects. That completely misses the point. Clams and oysters are part of the heritage and even pride of the coastal waters in NJ. The reason people participate in these shellfish restoration programs is because they can relate to clams or oysters, they really don’t care about ribbed mussels. Since the use of noncommercial shellfish was raised by DEP in that June 2009 meeting we conducted a survey of our members. We asked how many would be participating in our project if we were working with ribbed mussels. Not one person responded positively.
We understand that the NY/NJ Baykeeper is more targeted by DEP for how they operate, than is our program. If the Baykeeper’s program is dismantled rather than altered to meet some concerns, then who will focus the water quality issues on the northern Monmouth County waters? With budget cuts, there is no way that DEP will try to raise awareness there.
Local people can, and do, use their knowledge to cause behavioral change and that is the most effective way to improve water quality. Barnegat Bay is not as bad as those waters north of here, yet! We all know that the waters that NJ/NY Baykeepers are trying to restore fell into decline because people were not involved, and did not care. An ounce of prevention is worth a pound of cure. This is why closing education out is so shameful. The DEP, by denying public use of our endangered estuaries, is actually playing a major role in the estuaries demise.
I truly understand the DEP concern about contaminated shellfish being consumed by humans. Tiny shellfish are of no value to poachers. But they are extremely valuable as teaching aids. Shellfish are used to have citizens monitor size, understand the need for control, and learn about a living creature and it relationship to its environment.
In 2009 RCTB spent $110,000 (most of it from privately raised donations) and $275,000 in volunteer hours to raise public awareness. Where would the state come up with $385,000 to raise awareness and teach people the importance of water quality?
You may wonder if what we are doing effective? The answer is YES, we can document people who have changed their daily activities because of what they have leaned in the program. We welcome change at DEP, but please enlist the aid of those who deal with this day to day. If you were to use the draft policy that taxpayers already paid for your NEW policy, it can protect the industry AND enable the general population to play a major role in improving water quality. Please reconsider your decision to eliminate the growth of juvenile shellfish for educational purposes.
Sincerely,
Rick Bushnell, President ReClam the Bay
