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Seeking Input from Shellfish Growers and Tribes for Washington State Department of Health Regulatory Improvements
Greene Economics is excited to announce our partnership with the Washington State Department of Health (DOH) to conduct a comprehensive review of the state's shellfish regulatory program. This initiative aims to improve licensing, testing, certification practices, and fee-setting processes that impact shellfish growers and tribes across Washington.
Invitation for Stakeholder Input
As part of this process, we invite feedback from all stakeholders. Your insights are crucial to ensure that the regulatory framework supports the industry effectively. Here is the update from the DOH.
Message from the Washington State Department of Health:
Hello Shellfish Growers and Tribes,
The last update we sent was a notice of the fee rulemaking withdrawal. The message explained a budget proviso was passed by the legislature for DOH to hire a third-party consultant to review the department's commercial shellfish regulatory program, including fee setting, licensing, testing, and certification practices and requirements.
Per the deadline set forth in the proviso, we have a fairly tight timeline to complete the work. Our department is committed to completing the work, meeting the tasks outlined in the proviso, and by the deadline. We look forward to the process and believe it will be valuable for all parties.
We wanted to keep you all posted as we work through this process.
Where Are We in the Process?
Our leadership team created a Statement of Work crafted from the language in the proviso. We then selected and met with 4 different consultant firms to see which was best qualified to do the work. After meeting with each and reviewing their proposals, we chose Greene Economics, LLC. They have done similar work with other state agencies and local health jurisdictions in Environmental Health. They also have a subject matter expert in LEAN, who is a Six Sigma Green Belt.
How Were the Interview Consultants Selected?
With guidance from our DOH policy team and the DOH Contracts office we followed related RCWs and chose consultants who were vetted and had existing contracts with the Department of Enterprise Services (DES) Statewide Contracts program. We read through their scope statements to select 4 to interview and ultimately selected a vendor that is also a small women owned business.
Will Greene Work with Growers and Tribes?
Yes. They will reach out directly. If you have not seen the proviso language, it is here:
(132)(a) $450,000 of the general fund—state appropriation for fiscal year 2025 is provided solely for the department to contract with an independent third-party consultant to review the department's commercial shellfish regulatory program, including licensing, testing, and certification practices and requirements. The consultant must assess how the department sets commercial shellfish fees under RCW 43.70.250.
(i) The consultant must seek input from the department, the commercial shellfish industry, and tribes and must consider:
(A) Data sources and methods used by the department in setting or proposing increases to commercial shellfish fees;
(B) All costs associated with administering the department's regulatory authority over the testing of shellfish, the certification of operations and the issuance of licenses, and issuing export certificates for the commercial shellfish industry;
(C) Activities conducted by the department related to regulating the shellfish industry's regulatory activities that should be exempt from inclusion in the fee; and
(D) Relevant fees, methods, and considerations from other states that regulate the commercial shellfish industry under the Model Ordinance of the Interstate Shellfish Sanitation Conference for comparable services the department is providing the shellfish industry.
(ii) The consultant must also evaluate the viability of the industry to support full cost recovery as required under RCW 43.70.250 and recommend strategies to address any shortfalls. The consultant shall submit a report to the governor and legislature by June 30, 2025.
(b) Using the amounts provided in this subsection, the department shall also contract with a LEAN management consultant to review the shellfish licensing and certification program to identify program improvements and consider methods to offer data transparency to the industry and measures to potentially reduce program administration costs. The LEAN assessment must be completed and provided to the department by June 30, 2025.
(c) The department shall not increase commercial shellfish fees under RCW 43.70.250 during fiscal year 2025.
We Want Your Insights!
Greene Economics is committed to transparency and collaboration throughout this process. We will engage directly with shellfish growers and tribes to ensure their perspectives are included in the review. If you haven’t already, please review the language in the budget proviso above to understand the context of our work.
Your input is vital to the success of the Shellfish Permit Review and LEAN assessment processes. Hearing directly from those impacted is crucial for creating effective recommendations.
Our final report, which will include strategies for improvement, is due to the governor and legislature by June 30, 2025. We value your insights and look forward to your participation in shaping the future of shellfish regulation in Washington.