A Major Threat for Tomales Bay:
Proposed Lease by San Andreas Shellfish Company

Proposed aquaculture areas at Brazil Beach (San Andreas Shellfish Co, Revised Project Description, 2024)

On November 7, 2024, the San Andreas Shellfish Company (SASC) presented to the California Fish & Game Commission (Commission) its latest proposal for an aquaculture lease next to Brazil Beach in Tomales Bay. While scaled back from its original 2017 proposal, it still presents the risk of significant environmental impacts, especially given the ecological importance of Tomales Bay. EAC and other organizations have been tracking this lease proposal since 2017, voicing concerns throughout the process publicly and with agency staff.

We believe this shellfish proposal will have significant negative impacts on Tomales Bay, including impacts on shorebirds and waterbirds, endangered species, nursery grounds, harbor seal pupping and haul-out areas, eelgrass beds, water quality, sedimentation, noise levels, visual quality, and public recreational access. There could not be a worse choice for siting a new aquaculture lease on the Bay.

Join the environmental action committee of west marin, the Public Lands Conservancy, and the alliance to protect brazil beach and tomales bay and oppose this lease!

Why are Tomales Bay and Brazil Beach important?

Tomales Bay supports a diversity of habitats, including seagrass beds, intertidal sand and mud flats, open bay water, island habitats, and salt and freshwater marshes. The bay is especially important to approximately 20,000+ wintering shorebirds, seabirds, and waterbirds, including threatened western snowy plovers. It is also critical habitat to many fish species, including salmon, sharks, sturgeon, halibut, threatened steelhead, endangered coho salmon, and Pacific herring that rely on extensive eelgrass beds to spawn. The juveniles of species like salmonids, ling cod, rock fishes, and Dungeness crab use the Bay’s eelgrass beds as protected nursery grounds. The bay also supports a major breeding harbor seal population and pupping area.

Due to EAC’s advocacy, Tomales Bay is a RAMSAR site (wetland of international importance), partly due to the presence of 1,288 acres of eelgrass—9% of California’s total eelgrass habitat! 

Point Reyes National Seashore and the Golden Gate National Recreation Area have boundaries that include parts of Tomales Bay and are adjacent to Brazil Beach, indicating its national significance. Tomales Bay is also part of the Golden Gate Biosphere Reserve because of its biodiversity and coastal environment.

The Greater Farallones National Marine Sanctuary (Sanctuary) also protects waters including the greater Tomales Bay and the proposed lease area, both within a designated Special Wildlife Protection Zone and Eelgrass Protection Zone. 

Brazil Beach is an increasingly rare expanse of the relatively undeveloped eastern shore of Tomales Bay. Its productive, expansive mudflats and adjacent eelgrass beds and shoals make it a unique and significant aspect of the Tomales Bay ecosystem.

Aerial image of Brazil Beach. Photo Credit: J. Gilardi

The Potential Impacts will be Significant

The proposal requests that over 38 acres of intertidal and shallow subtidal areas be planted with bags on the ground, floating long lines, anchored grow-out rafts, “floating operations” platforms/rafts, and large anchored vessels. 

See examples from SASC’s proposal:

The proposal suggests that wildlife will be avoided and that eelgrass beds will not be affected. Unfortunately, we do not see how that will be possible. The intertidal area would be covered with about 16,500 oysters and clam bags covering 119,316 square feet (not including areas between bags that will be impacted by traffic from aquaculture operators). The application proposal covers over 34 acres of intertidal habitat that directly conflict with bird habitat. The area is so shallow and the margins so tight that propeller cuts to eelgrass, shading, and sedimentation will also likely be issues.

We believe this shellfish proposal will have broad and likely significant effects on the ecosystem of Tomales Bay and the adjacent region.

The areas of potential negative impacts are many, but direct and indirect impacts on shorebirds and waterbirds, endangered species, nursery grounds, harbor seal pupping areas, and eelgrass are primary concerns. We are also concerned about water quality, sedimentation, noise, visual impacts, and reduced recreational access.

Join the Alliance for Brazil Beach

This proposal has widespread opposition from the community and environmental groups. An informal alliance is dedicated to providing comments to ensure the Fish and Game Commission receives detailed information regarding environmental, recreational, and other concerns. If you share our concerns about this problematic lease site, email us to get on our mailing list!

The following groups have signed on to provide extensive feedback to the Commission during upcoming hearings:

Susan Jordan, Executive Director, California Coastal Protection Network 

Gerald H. Meral, Ph.D., Director, California Water Program, Natural Heritage Institute

Jeff Miller, Senior Conservation Advocate, Center for Biological Diversity

Ashley Eagle-Gibbs, Esq., Executive Director, Environmental Action Committee of West Marin

Barbara Salzman, President, Marin Audubon Society

Neal Desai, National Parks Conservation Association, Acting Regional Director, Pacific Region

Frank Egger, President, North Coast Rivers Alliance

Don Neubacher and Catherine Caufield, Advisors, Public Lands Conservancy

Chance Cutrano, Director of Programs, Resource Renewal Institute

Megan Isadore, Executive Director, River Otter Ecology Project

Eric Brooks, San Francisco Bay Chapter of the Sierra Club

Phil Francis, Board Chair, The Coalition to Protect America’s National Parks

Tom Gaman, Tomales Bay Foundation

Ken Bouley, Executive Director, Turtle Island Restoration Network

Laura Chariton, Watershed Alliance of Marin

  • Harbor seals use both Seal and Clam Islands year-round, and both sites are important breeding areas. The most recent report from the National Park Service Pinniped Monitoring Program documented around 400-500 seals, including over 100 pups, on Clam Island adjacent to Brazil Beach.  

    This has continued to be one of the more important seal locations in Point Reyes as coyotes cannot access the sandbars and kill pups compared to other locations. The proposed aquaculture lease directly affects this haul-out site, and subsequent activity will likely substantially increase disturbance to seals, jeopardizing pupping here.

Shorebirds on essential foraging habitat, including western sandpipers and dunlins, which have been experiencing significant declines on Tomales Bay

  • Most of the intertidal area that will be affected is the mudflat adjacent to Brazil Beach—an essential forage habitat for migratory shorebirds. Research has shown that the northern area of Tomales Bay supports more shorebirds than the south in early and late winter. A high abundance of semipalmated plovers, black-bellied plovers, killdeer, willets, marbled godwit, sanderlings, dunlins, western sandpipers, and federally listed western snowy plovers have been documented in the proposed lease area.

    Tomales Bay has experienced significant shorebird decline (66%) from 1989 to 2018 (Audubon Canyon Ranch). Dunlins and western sandpipers have experienced more significant declines. As proposed, this lease will not avoid significant impacts on shorebird habitat, and from their perspective, may be in the worst location within Tomales Bay.

Brandts eating eelgrass

  • Eelgrass is especially vulnerable to human activities like aquaculture and is in urgent need of improved management and protection.

    Eelgrass habitat is of such importance that, under Target 3.1.4 of the Ocean Protection Council’s strategic plan and connected to the California Eelgrass Mitigation Policy, California has committed to “work with partners to preserve the existing, known 15,000 acres of seagrass beds and create an additional 1,000 acres by 2025.”

    Due to their ecological importance and vulnerability, eelgrass beds are protected in several different ways: they are designated as “special aquatic sites” under Section 404(b)(1) Guidelines of the Clean Water Act; designated as Essential Fish Habitat under the Magnuson-Stevens Fishery Conservation Management Act; and protected under California Department of Fish and Wildlife regulations. Sanctuary regulations also offer protection through prohibiting vessel anchoring within Tomales Bay Seagrass Protection Zones.

Close to 400 hauled-out harbor seals

  • Cleaning and processing oysters from floating platforms are significant concerns. The environmental impacts of noise, air, and water pollution must be addressed. Multiple pumps and generators will be needed to power almost all work that would take place on boats and floating work platforms.

    Tomales Bay is currently impaired (under the Clean Water Act 303(d) list) for sediments. Cleaning and processing will likely cause direct discharges into the Bay, concentrate sediments, potentially spread non-native organisms, and adversely impact noise and water quality. The California Coastal Commission has typically required other Tomales Bay operators to move their cleaning and processing to land-based systems.

    Recreation and public access will likely suffer due to the development of shellfish growing bags and racks. Noise from generators and washing tumblers may cascade across the Bay, and the visual effects of floating barges and work sheds could be substantial.

Tax - ID #23-7115368

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