[From the U.S. Government Printing Office, www.gpo.gov]




     Final Programmatic
     Environmental Impact Statement




     Fish Culture in Floating Net-Pens
     Washington Department of Fisheries


















     January 1990




    SH
    151
    T482
    1990
    V. i





FINAL PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT
FISH CULTURE IN FLOATING NET PENS

Prepared for:
WASHINGTON STATE DEPARTMENT OF FISHERIES
115 General Administration Building
Olmpia, WA 98504

Prepared by:
PARAMETRIX, INC.
13020, WA 98005

January 1990

LIBRARY
NOAA/CCEH
1990 HOBSON AVE.
CHAS.SC 29408-2623












    105UH R. SLUM
       Oireacr

                                             STATE OF WASHNaON
                                       DUARTMENT OF FISHEM
               115 Cow* Adnnwaten &Aft * 0knpa wa0r@ 9M 9 (2M) 753-66W             (SCAN) 234-MW





                MEMORANDUM                                                       January 29, 1990



                TO:         All Interested Parties

                FROM:       Washington State Departments of Agriculture.
                            Ecology, Fisheries and Natural Resources

                SUBJECT:    Fish Culture in Floating Net Pens in Puget Sound Management Plan



                Enclosed is a copy of the final Programmatic Environmental Impact Statement on
                Fish Culture in Floating Net Pens in Puget Sound (EIS). This EIS consists of
                three voluses: the mazn body of the EIS itself; the comment letters received
                and the response to comments; and the technical appendices (not required by
                SEPA but included for informational purposes).

                This EIS represents existing knowledge regarding potential environmental
                impacts of siting fish farms in Puget Sound, and also identifies issues
                on which information may be lacking. The EIS is based on two identified
                alternatives: the "no-action:1 alternative which evaluates siting of fish
                farms based an existing regulations and guidelines; and the "preferred"
                alternative which evaluates siting of fish farms based on expanded regu-
                lations. Videlines. and scientific research. The document thus provides
                a foundation upon which decision-makers may evaluate project proposals.

                The four state agencies involved in the preparation of this EIS (listed above)
                are- establishing a broad-based public process to develop a management plan
                for the siting of fish farms in Puget Sound. A management plan would apply
                the findings of the PTS in the development of a common framework among state
                and local agencies for use in evaluating and deciding an fish farm proposals.

                The agencies welc  ome comments on this final EIS which could provide guidance
                for the development of a subsequent management plan. Since DNR will be the
                lead agencv in the development of the management plan. please address
                pertinent comments to:

                               Ann Morgan. Manager
                               Division of Aquatic Lands
                               Depart=ent of Natural Resources
                               202 John A. Cherberg Building
                               Olympia. WA 98504


                Thank you.











  JOSEPH R. BLUM
    Director


                                        STATE OF WASHINGTON
                                   DEPARTMENT OF FISHERIES
           115 General Administration &jilding e Olympia, Washington 98504 * (206) 753-6600 a (SCAN) 234-6600
                                        January 31, 1990









           Dear Reader:


           The attached document, together with the separately bound "Response to
           Comment," and "Technical Appendices," comprise the Final Programmatic
           Environmental Impact Statement (FEIS) for "Fish Culture in Floating Net
           Pens in Puget Sound." This HIS was prepared at the direction of the
           Washington State Legislature by the Department of Fisheries (WDF).
           Throughout preparation, WDF consulted extensively with the Departments
           of Agriculture, Ecology, and Natural Resources, and with numerous county
           officials, scientific researchers, and private individuals.

           The HIS was prepared to assist state, county, and local decisionmakers
           in evaluating proposals for fish farm sites by compiling existing knowledge
           regarding potential significant environmental impacts of siting fish farms
           in Puget Sound, and also by identifying areas where information may be
           lacking.

           An array of issues concerning the natural and built environments has
           been considered, with the principal ones being impacts on sedimentation,
           water quality, and aesthetics. The HIS is constructed on two identi-
           fied alternatives: the "no-action" alternative which evaluates siting
           of fish farms based on existing regulations and guidelines; and the "pre-
           ferred" alternative which evaluates siting of fish farms based on expanded
           regulations, guidelines, and recommended WAC adoptions.


           WDF wishes to thank those to took the time to review the draft EIS and
           to provide the comments incorporated into the final document.

                                             Sincerely,




                                                ey     Blum
                                             Director














                                                          FACT SHEET



           A.       Nature and Location of Proposa : This non-project, or programmatic Final EIS (FEIS) evaluates
           the environmental impacts of the commercial culture of fish in floating fish farms under two regulatory
           alternatives.   The objective of this FEIS is to provide information to regulators, the public, and the
           Legislature for assessing the adequacy of existing regulations that affect the fish farming industry in
           Washington, as well as presenting a Preferred Alternative that identifies actions that State and local
           governments can undertake to avoid significant adverse environmental impacts.

           The location of the proposal encompasses all Washington State marine waters from the west end of the
           Strait of Juan de Fuca, north to the Canadian border and south to Olympia. This area includes Hood
           Canal and all marine bays, harbors, inlets, and passages in Puget Sound.

           B.       Proponent and Date of Implementation: At the direction of the Washington State Legislature, the
           Department of Fisheries is preparing this EIS in consultation with the Departments of Ecology, Natural
           Resources, and Agriculture. The nominal lead agency is the Washington Department of Fisheries.

           C.       Lead Agency. Responsible Official, and Contact Person:

                    Responsible Official:       Duane E. Phinney, Chief
                                                Habitat Management Division
                                                Washington Department of Fisheries


                    Contact Person:             Judith Freeman
                                                Assistant Director
                                                Washington Department of Fisheries
                                                115 General Administration Building
                                                Olympia, WA 98504
                                                (206) 753-6772

           D.       Licenses Reguired: No licenses are required for this proposal. Numerous permits and approvals
           are required for specific fish farm projects (see Appendix F).

           E.       Authors and Principal Contributors:


                    Nam                                 Areas of Contribution


                    Parametrix, Inc.                    Principal author
                                                        Bottom sediments and benthos
                                                        Fish farm modeling
                                                        Water quality
                                                        Fish and shellfish
                                                        Importation of new fish species


                                                                                                                       Page i











                                                      Genetic issues
                                                      Marine mammals and birds
                                                      Odors
                                                      Noise
                                                      Upland and shoreline; use
                                                      Visual quality
                                                      Navigation
                                                      Commercial fishing
                                                      Recreation
                                                      Local services


                   Battelle Pacific NW Labs           Disease
                                                      Human health
                                                      Chemicals


                   Rensel Associates                  Phytoplankton



           F.      Date of Issue of Final EIS: January 31, 1990.

           G.      Nature and Date of Final Action: No specific action is proposed by the Department of Fisheries
           at this time.


           H.      Type and Timing of Subseguent Environmental Review: Individual fish farm projects will be
           reviewed case-by-case under the State Environmental Policy Act (SEPA') as they are proposed. Any
           subsequent regulations or policies developed by State or local officials pursuant to this FEIS will be subject
           to review under SEPA.


           1.      Location of Background Data: Copies of the background data used in the preparation of this EIS
           are available for review at the Department of Fisheries (see location in Item C above).

           J.      Cost to the Public for Copy of Final EIS: Copies will be provided at no cost to libraries, State
           and local agencies, legislators and associations with a known interest, and persons/entities providing
           comments on the Draft EIS. Copies will be available to all others at a cost based on the actual cost of
           reproduction and mailing.


















           Page ii









                                                      TABLE OF CONTENTS


                                                                                                                                     Page


            FACT SHEET        ........................................................                                                   i


            SUMMARY          .........................................................                                                   xi


            1.       BACKGROUND AND OBJECTIVES OF THE EIS                            ..........................                          1
                     1.1      BACKGROUND              ...........................................                                        1
                     1.2      OBJECTIVES          .............................................                                          2


            2.       BACKGROUND OF THE FLOATING FISH FARM INDUSTRY                                     ................                  4


            3.       LOCATION          ...................................................                                               7


            4.       DESCRIPTION OF ALTERNATIVES                     ..................................                                  8
                     4.1      PERMITS AND APPROVALS                  ..................................                                  8
                     4.2      STATE AGENCIES              .........................................                                    10
                     4.3      LOCAL GOVERNMENT                 ......................................                                  11
                     4.4      FEDERAL AGENCIES               .......................................                                   11


            5.       THE NATURAL ENVIRONMENT                       ....................................                                13
                     5.1 BOTTOM SEDIMENTS AND BENTHOS                         ..............................                           13
                              5.1.1        Affected Environment        .................................                               13
                              5.1.2        Impacts of Fish Farms on Benthic Communities                ................                15
                              5.1.3        Mitigation Measures and Unavoidable            Significant  Adverse   Impacts     ....      26
                     5.2      WATER QUALITY              .........................................                                     26
                              5.2.1        Affected Environment        .................................                               26
                              5.2.2        Impacts on Water Quality           ..............................                           34
                              5.2.3        Mitigation Measures and Unavoidable            Significant  Adverse   Impacts     ....      40
                     5.3      PHYTOPLANKTON              .........................................                                     40
                              5.3.1        Affected Environment        .................................                               41
                              5.3.2        Impacts on Phytoplankton           ..............................                           45
                              5.3.3        Mitigation Measures and Unavoidable            Significant  Adverse   Impacts     ....      52
                     5.4      CHEMICALS           .............................................                                        52
                              5.4.1        Affected Environment        .................................                               52
                              5.4.2        Impacts of Chemicals        .................................                               55
                              5.4.3        Mitigation Measures and Unavoidable            Significant  Adverse   Impact     .....      57
                     5.5      FOOD FISH AND SHELLFISH                  .................................                               57
                              5.5.1        Affected Environment        .................................                               57
                              5.5.2        Impacts on Food Fish and Shellfish           ........................                       59
                              5.5.3        Mitigation Measures and Unavoidable            Significant  Adverse   Impacts     ....      61
                     5.6      IMPORTATION OF NEW FISH SPECIES                        ..........................                        61
                              5.6.1        Affected Environment        .................................                               61
                              5.6.2        Impacts of Importation of New Fish Species               ..................                 62
                              5.6.3        Mitigation Measures and Unavoidable Significant             Adverse   Impacts     ....      64




                                                                                                                                 Page iii









                                                           TABLE OF CONTEN,rs (Continued)

                                                                                                                                  Page


                      5.7     GENETIC ISSUES           ..........................................                                  64
                              5.7.1         Affected Environment      .................................                            65
                              5.7.2         Genetic Impacts     .....................................                              67
                              5.7.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....     70
                      5.8     DISEASE       ................................................                                       70
                              5.8.1         Affected Environment      .................................                            70
                              5.8.2         Impacts of Diseases      ..................................                            72
                              5.8.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....     74
                      5.9     MARINE        MAMMALS AND BIRDS              ................................                        74
                              5.9.1         Affected Environment      ..................................                           74
                              5.9.2         Impacts on Wildlife      ...................................                           78
                              5.9.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....     81

             6.       THE BUILT ENVIRONMENT                 ........................................                               83
                      6.1     VISUAL QUALITY             .........................................                                 83
                              6.1.1         Affected Environment      .................................                            83
                              6.1.2         Impacts on Visual Quality       ..............................                         84
                              6.1.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....     97
                      6.2     NAVIGATION          .............................................                                    97
                              6.2.1         Affected Environment      .................................                            97
                              6.2.2         Impacts on Navigation     .................................                            97
                              6.2.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....     99
                      6.3     COMMERCIAL FISHING                .....................................                              99
                              6.3.1         Affected Environment      .................................                            99
                              6.3.2         Impacts on Commercial Fishing         ...........................                     106
                              6.3.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....    109
                      6.4     HUMAN HEALTH             ...........................................                                109
                              6.4.1         Affected Environment      ..................................                          109
                              6.4.2         Impacts on Human Health         ...............................                       111
                              6.4.3         Mitigation and Unavoidable Significant Adverse;        Impacts    ...........         112
                      6.5     RECREATION           .............................................                                  112
                              6.5.1         Affected Environment      ..................................                          112
                              6.5.2         Impacts on Recreation        .................................                        113
                              6.5.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....    114
                      6.6     NOISE     ..................................................                                        114
                              6.6.1         Affected Environment      .................................                           114
                              6.6.2         Impacts of Noise     ....................................                             115
                              6.6.3         Mitigation Measures and Unavoidable         Significant  Adverse   Impacts    ....    116
                      6.7     ODORS       .................................................                                       116
                              6.7.1         Affected Environment      .................................                           116
                              6.7.2         Impacts of Odors     ....................................                             117
                              6.7.3         Mitigation Measures and Unavoidable Significant Adverse Impacts               ....    118





            Page iv








                                                          TABLE OF CONTENTS (Continued)


                                                                                                                                Page


                    6.8      UPLAND AND SHORELINE USE                    ...............................                         119
                             6.8.1        Affected Environment        .................................                          119
                             6.8.2        Impacts on Upland and Shoreline Use            ......................                  119
                             6.8.3        Mitigation Measures and Unavoidable          Significant Adverse    Impacts     ....   122
                    6.9      LOCAL SERVICES             .........................................                                122
                             6.9.1        Affected Environment        .................................                          122
                             6.9.2        Impacts on Local Services        ..............................                        122
                             6.9.3        Mitigation Measures and Unavoidable         Significant  Adverse    Impacts    ....    123

            7.      CUMULATIVE IMPACTS ON PUGET SOUND                           ...........................                      125


            8.      RELATIONSHIP TO LAND USE PLANS AND REGULATIONS                                  ................             131
                    8.1      LOCAL JURISDICTIONS                                                                                 131
                    8.2      STATE AND FEDERAL JURISDICTIONS                      ..........................                     133
                    8.3      PUBLIC TRUST DOCTRINE                ...................................                            133
                             8.3.1        Historical Basis     .....................................                             133
                             8.3.2        Public Trust Doctrine in Washington           .......................                  133
                             8.3.3        The Public Trust and Fish Farms           .........................                    134


            DISTRIBUTION LIST            .................................................                                       135


            REFERENCES          ......................................................                                           139


            APPENDICES (Note: The Technical Appendices are included in a separate volume.)

            A       Assessment and Prediction of the Effects of Salmon Fish Farm Culture on the Benthic Community

            B       Modeling of Particulate Deposition Under Salmon Fish Farms

            C       Phytoplankton and Nutrient Studies Near Salmon Fish Farms at Squaxin Island, Washington

            D       Infectious Diseases of Salmon in the Pacific Northwest


            E       The Economics of Salmon Farming

            F       Permits That May Be Required for Aquaculture Projects

            G       Viral Hemorrhagic Septicemia

            H       Norwegian and British Columbia Information


            I       Land-Based Tank Farms


            J       Legislation Authorizing EIS



                                                                                                                              Page v










           APPENDICES (Continued)

           K       Real Estate Report

           L       Economic Aspects of Salmon Aquaculture




                                                                                                                                      
                                                                                                                                      







                                                                                                                                      














                                                                                                                                      


                                                                                                                                      
                                                                                                                                      
                                                                                                                                      
                                                                                                                                      

                                                                                                                                      
                                                                                                                                      


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           Page vi                                                                                                                    I
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                                                               LIST OF FIGURES




             Figure 1.           Vicinity Map       ................................................                                                  3

             Figure 2.           General Locations of Existing Commercial                 Fish
                                 Farms      . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   5


             Figure 3.           Example of a Fish Farm and Various Pen
                                 Configurations      . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    6

             Figure 4.           Generalized Trends in Organism Diversity                 . . . . . . . . . . . . . . . . . . . . . . . . . . . .  20

             Figure 5.           Major Sills in Puget Sound            ......................................                                      28

             Figure 6.           Generalized Surface Water Movement at Flood Tide
                                 in Puget Sound          .............................................                                             29

             Figure 7.           Generalized Surface Water Movement                at Ebb Tide in
                                 Puget Sound         ...............................................                                               29

             Figure 8.           Simplified Diagram of Circulation and              Sedimentation
                                 in Puget Sound          .............................................                                             30

             Figure 9.           Theoretical Dispersion of Water Parcels in Puget
                                 Sound      ...................................................                                                    32


             Figure 10.          Washington Department of Ecology Water Quality
                                 Monitoring Stations and Their Relation to Dissolved
                                 Oxygen Standards          ............................................                                            33

             Figure 11.          Schematic Representation of the Processes Simulated
                                 in the Kiefer and Atkinson Phytoplankton - Nutrient
                                 Model      ...................................................                                                    50


             Figure 12.          Seal and Sea Lion Haulouts in Puget Sound                  . . . . . . . . . . . . . . . . . . . . . . . . . . .  76

             Figure 13.          Major Waterfowl Habitats in Puget Sound                  . . . . . . . . . . . . . . . . . . . . . . . . . . . .  77

             Figure 14.          Topography of the Shoreline and Views of Fish Farm
                                 Facilities   ..................................................                                                   85


             Figure 15.          Visual Effect of Distance and Observer Position                  . . . . . . . . . . . . . . . . . . . . . . . .  87








                                                                                                                                             Page vii








                                                               LIST OF FIGURES (continued)



               Figure 16.          Schematic Example of View Impacts Related to
                                   Distance and Orientation of Fish Farms                   .............................                              88


               Figure 17.          Effect of Fish Farm Orientation and Observer Distance
                                   on Visual Impact         . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    89

               Figure 18.          Hypothetical Layout of Five Fish Farms in a Puget
                                   Sound Embayment: Carr Inlet Sample                     ..............................                               91

               Figure 19.          Fish Farm Density Control, Area by Square Footage                        .....................                      92

               Figure 20.          Fish Farm Density Control, Area by Shoreline Footage                       . . . . . . . . . . . . . . . . . . . .  93

               Figure 21.          Fish Farm Density Control, Area by Radius                   . . . . . . . . . . . . . . . . . . . . . . . . . . .   94

               Figure 22.          Northern Puget Sound Commercial Salmon Management
                                   and Catch Reporting Areas              ......................................                                      102

               Figure 23.          Southern Puget Sound Commercial Salmon Management
                                   and Catch Reporting Areas              ......................................                                      103

               Figure 24.          Population Distribution in the Central Puget
                                   Sound Region         . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   . . . . . . . . . . .   120

               Figure 25.          Land Use in the Planning Area                ...................................                                   121

               Figure 26.          BOD Loading from West Point and Renton Wastewater
                                   Treatment Plants, Rainier Brewery, and Different
                                   Levels of Fish Farm Development                 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    128

               Figure 27.          Nitrogen Loading from Tidal and Freshwater 'Inflow,
                                   Renton and West Point Wastewater Treatment Plants,
                                   Stillaguamish, and Skagit River, and Various Levels
                                   of Fish Farm Development              . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . .   129















               Page viii








                                                                 LIST OF TABLES


                                                                                                                                                T-4z-e

              Table 1.           Summary of alternatives          . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    xxiii

              Table 2.           Agencies with specific authority and/or expertise                 . . . . . . . . . . . . . . . . . . . . . .     xxvii

              Table 3.           List of abbreviations and acronyms used in this FEIS                    . . . . . . . . . . . . . . . . . . . .   xxix

              Table 4.           Marine water quality standards in Washington
                                 State    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .    39


              Table 5.           Effect of five farms in an embayment on the nitrogen,
                                 phytoplankton, and zooplankton concentrations for
                                 summer and winter conditions based on the Kiefer and
                                 Atkinson model (1988)           . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   51

              Table 6.           Number of Puget Sound salmon, bottomfish, and shellfish
                                 commercial fishing licenses by gear type, 1986                  . . . . . . . . . . . . . . . . . . . . . . . .   100

              Table 7.           Generalized salmon management periods by management
                                 area    ....................................................                                                      104


              Table 8.           Total commercial net catch of Pacific salmon in Puget
                                 Sound by management area, 1988                 .................................                                  105


              Table 9.           Maximum allowable one-hour environmental noise
                                 levels    ...................................................                                                     117

              Table 10.          Loading of BOD, particulates (feed + feces), and
                                 dissolved nitrogen from different levels of fish
                                 production in fish farms          . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   127




















                                                                                                                                               Page ix














                                                                SUMMARY


           OBJECTIVE OF PROPOSAL:                                                      then additional monitoring would be used
                                                                                       as a mitigation measure for an individual
           The objective of this Final EIS (FEIS) is to                                farm.
           evaluate the environmental impacts of the
           commercial culture of fish in floating fish farms                           The     other     approach      used    in    the
           under two alternatives:                                                     recommendations          is   to   establish     a
                                                                                       performance standard. For example, the
                ï¿½    No-Action - Existing Regulations and                              Preferred        Alternative       recommends
                     Guidelines. This alternative evaluates the                        guidelines such as siting a farm near the
                     impacts of floating fish farms under the                          shoreline to reduce the impact on
                     regulations and guidelines that presently                         navigation. However, if the objective of
                     affect the fish farming industry. Included                        reducing the impact on navigation can be
                     in this alternative are relevant State and                        accomplished without          employing this
                     federal regulations, local shoreline master                       guideline, then it need not be used.
                     programs, and guidelines such as the
                     Recommended Interim Guidelines for the                            If the recommendations for expanded
                     Management of Salmon Net-Pen Culture in                           regulations included in this FEIS are not
                     Puget Sound, and the Aquaculture Siting                           adopted into WACs, they would still
                     Study.                                                            function as existing guidelines for State
                                                                                       and local governments. State and local
                ï¿½    Preferred Alternative.       This alternative                     governments       can     use    all    of    the
                     evaluates the impacts of floating fish                            recommendations          in   this   FEIS       as
                     farms under existing regulations with                             mitigation measures through          the SEPA
                     recommendations            for       expanded                     process for individual farms.
                     regulations, additional guidelines, and
                     additional scientific research.             This         PURPOSE OF THIS EIS:
                     alternative recommends measures              that
                     State and local governments can take to                  Recent commercial fish farming has been marked
                     avoid significant adverse impacts.                       by controversy and concern that the fish farming
                                                                              may harm the marine environment, conflict with
                     The recommendations in the Preferred                     existing uses of the water, and be incompatible
                     Alternative     comprise      two      different         with shoreline residential use. This controversy
                     approaches.              Some        of      the         has resulted in litigation, legislative action, anger,
                     recommendations        include      establishing         and frustration by all parties.
                     regulations as a minimum standard. For
                     example, the recommendation to adopt                     To assist in the resolution of this conflict, the
                     into the WACs the annual monitoring                      Washington State          Legislature directed the
                     discussed in theInterim Guidelines creates               Department       of Fisheries        to   evaluate     the
                     a standard that will be applied in each                  environmental impacts of fish farms on                 the
                     fish farm proposal.          If site specific            biological and built (human) environments. This
                     conditions warrant additional monitoring,                FEIS was prepared by the Department of


           Summary                                                                                                              Page xi









             Fisheries in consultation with the Departments of               particles may enhance the abundance of the
             Ecology, Natural Resources, and Agriculture.                    established benthic community by providing an
             This information is intended to assist State,                   additional food or energy source for deposit- and
             county, and local decisionmakers in evaluating                  filter-feeding organisms and for scavengers.
             fish farm proposals.
                                                                             WDF has the authority to preserve, protect,
             To assist the reader in reviewing this document,                perpetuate, and manage food fish and shellfish
             the following three tables are included at the end              resources in Washington. The HPA permit and
             of the Summary: (1) Table 1 britfly summarizes                  SEPA review processes provide WDF with the
             the alternatives presented in this FEIS, (2) Table              opportunity to evaluate specific conditions, and
             2 identifies State, local, and federal agencies with            approve or deny individual. fish farm proposals on
             authority and/or expertise in relation to the                   a case-by-case basis using the most current
             issues discussed in this document, and (3) Table                information available for a specific site. Ecology
             3 provides a list of abbreviations and acronyms                 is developing sediment quality standards that will
             used throughout the FEIS.                                       specify the degree, of effects allowed in sediments
                                                                             throughout Puget Sound.
             The following section summarizes the findings of
             the FEIS for each issue that was discussed in the               The site surveys ;and mon4oring requirements in
             FEIS.                                                           the Literim Guidelines weire found to provide an
                                                                             adequate framework for determining potential
             SUMMARY BY ELEMENT OF THE                                       impacts to the benthos. The Guidelines took a
             ENVIRONMENT:                                                    conservative approach to preventing benthic
                                                                             impacts, and the depth and current guidelines
             Bottom Sediments and Benthos                                    shoulld continue to be used.


             The settling of organic matter, mostly from excess              It is' recommended that the site surveys and
             food and feces from the fish farm, is the source                monitoring requirements identified in theInterim
             of impacts to bottom-dwelling plants and animals                Guidelines be adlopted into WACs.           It is also
             (benthos) from fish farms. The severity of the                  recommended that DNR, Ecology, and WDF
             impacts depends on several factors including                    annually review monitoring, reports from farms to
             loading (poundage of fish raised in the farm),                  determine if depth and current guidelines should
             pen size, water depth and current velocity, pen                 be revised.
             configuration, bottom current velocity, feed type,
             feeding    method,     and    the   existing bottom             Significant adverse impacts to the benthic
             sediments and benthic community.                                community can be avoided by conducting site
                                                                             surveys prior to construction of fish farms and by
             Sedimentation from fish farms decreases benthic                 monitoring the area annually after a farm is
             sediment oxygen levels by increasing the demand                 installed. NPDES permit requirements and the
             for oxygen, and by decreasing both diffusion -and               State sediment quality standards will provide
             water flow into the interstitial spaces of the                  adequate regulatory control to avoid significant
             sediment.      As increasing amounts of fine                    impacts to the benthos.
             sediment accumulate, the depth to which oxygen
             penetrates is reduced, and the underlying                       Water Quality
             sediment layers become devoid of oxygen and
             unable to support animal life.                                  Several water quality variables including turbidity,
                                                                             p1l, temperature, fecal coliforms, nutrients,
             Organic enrichment from fish food and feces                     toxicity, and dissolved oxygen were researched to
             which are high in organic carbon and nitrogen.                  determine if fish farms would have potential
             At low levels of nutrient enrichment, these                     significant adverse. impacts. It was found that for


             Page xii                                                                                                      Summary









            the variables of pH and temperature, the impacts                completed before starting the permitting process,
            from fish farms would be negligible. Turbidity                  and that annual monitoring of water quality
            would increase, primarily during net cleaning.                  parameters be completed for each site.
            Higher turbidity levels during net cleaning
            activities would not adversely affect aquatic                   Significant adverse impacts to water quality can
            organisms, but would reduce the clarity of the                  be avoided by adopting provisions of the Interim
            water.    The potential for toxicity would be                   Guidelines into WACs and by monitoring turbidity
            greatest from the increased production of                       during net cleaning operations during periods of
            dissolved nitrogen (including ammonia) that is                  high natural turbidity.      These measures, along
            typically associated with fish farms. However,                  with implementation of the NPDES permit
            even within fish farms, un-ionized ammonia levels               requirements, will ensure that no significant
            are well below the maximum four-day, chronic                    adverse impacts will occur as the result of fish
            exposure level recommended by EPA.                              farm development.

            The variables of nutrients and dissolved oxygen                 Phytoplankton
            have the largest potential to be affected by fish
            farms. The effects of nutrients are analyzed in                 Salmon farms may cause or increase blooms of
            the discussion on phytoplankton.                                phytoplankton by localized nutrient enrichment.
                                                                            This enrichment could occur when excessive
            Dissolved oxygen consumption by fish, and by                    dissolved nutrients are discharged into semi-
            microbial decomposition of fish wastes and excess               enclosed waters with limited tidal mixing and
            food,     could      reduce      dissolved       oxygen         strong vertical stratification. However, in all but
            concentrations near a fish farm.           In general,          a few localized areas of Puget Sound, limited
            however, the dissolved oxygen requirements of                   increases in phytoplankton production would have
            salmon raised in farms limit the impact fish                    no adverse effect and would merely contribute
            farms can have on the environment. Salmon are                   more food to the food chain.
            sensitive to the level of dissolved oxygen, and the
            water quality criteria for oxygen are based in                  The Interim. Guidelines provide an adequate
            large part on the requirements of rearing salmon.               framework for establishing which embayments are
            The impact of low dissolved oxygen is likely to                 nutrient sensitive.       The Guidelines used a
            affect the farm before having an effect on the                  reasonable approach to ensure that fish farms
            surrounding environment.          Most studies have             would not create significant impacts on potentially
            shown that fish farms do not have a significant                 nutrient sensitive areas.
            adverse impact on dissolved oxygen. Exceptions
            to this have occurred during summer or autumn                   It is recommended that the areas defined as
            at sites that had low background dissolved oxygen               sensitive in the Guidelines (Holmes Harbor, Budd
            levels and did not have adequate current flow                   Inlet, and Hood Canal south of Hazel Point) be
            through the nets. One of the beneficial impacts                 identified as such in WACs. For these areas, it
            of fish farm development is that fish farms                     is also recommended that fish production be
            monitor water quality parameters at their sites                 limited to that which will not adversely affect
            and can provide an early indication of water                    existing biota.      Use of predictive models is
            quality problems in an area.                                    recommended to estimate allowable production
                                                                            levels in sensitive  areas.
            Commercial fish farms producing more than
            20,000 lbs per year are required to obtain a                    It is also recommended that the maximum
            NPDES permit to ensure that the farm will not                   production levels for fish farms in the 19
            exceed State and federal water quality standards.               embayments identified in the Guidelines be
            The Interim Guidelines recommend that a                         adopted into WACs. Any subsequent fish farm
            hydrographic survey of the fish farm site be                    proposals must demonstrate to State resource


            Summary                                                                                                         Page xiii








             agencies by field and modeling studies that                       potential amounts of antibiotics in sediments near
             additional     proposed      development      will     not        fish farms, if sediments occur.
             adversely affect existing biota.
                                                                               Use of existing regulations with the adoption of
             The adoption of provisions in the Guidelines into                 these recommendations would be adequate to
             WACs and the case-by-case SEPA process will                       avoid significant adverse impacts.
             ensure that no significant adverse impacts occur
             to biota in nutrient sensitive embayments as a                    Food Fish and Shellfish
             result of fish farm development.
                                                                               The primary impacts floating fish farms are likely
             Chemicals                                                         to have on food fish and shellfish populations are
                                                                               from sedimentation that may occur under the
             Fish farming    involves the use of antibiotics and               farm and the farm structure itself.
             antifoulants.        Studies     indicate     that     the
             concentrations      of    antibiotics    reaching      the        At low rates of sediment deposition, filter feeders
             environment from fish farms are very small.                       such as clams may be enhanced. Previous studies
             Also, there seems to be little potential for                      have found that mobile predators/scavengers, for
             shellfish near fish farms to bioaccumulate                        example crabs, are attracted to the area around
             antibiotics used at the farm. Shellfish held within               aquaculture facilities to feed on excess food and
             a fish farm did not accumulate detectable levels                  on the small organisms which are enhanced
             of the antibiotic OTC. This observation, and the                  around the farm.
             calculated dilution of any quantities of antibiotics
             away from fish farms, suggest that any quantities                 At high levels, immobile organisms will be
             of antibiotics accumulated in shellfish, or other                 displaced from the area below the farm. Fish
             benthic or planktonic marine invertebrates, if any,               and shellfish could also be adversely affected by
             would be below levels of concern.                                 the deposition of organic sediments upon
                                                                               important habitats. For example, a farm directly
             The transfer of drug resistance           from fish to            above a clam or geoduck bed could create an
             human pathogenic bacteria seems unlikely.               It        azoic zone immediately below the farm, killing all
             appears such transfer is a laboratory phenomenon                  the shellfish within the zone. Sedimentation over
             that requires highly controlled conditions and is                 spawning areas could smother eggs and eliminate
             not representative of phenomena that occur in                     the area for fuither spawning use.
             the natural environment.
                                                                               The farm structures provide a habitat in the
             Other than requiring the use of FDA-approved                      open-water environment to attract fish, such as
             antibiotics, there are currently no State standards               surfp(,rch and rockfish, in larger numbers than
             for the use of antibiotics at fish farms and some                 would. normally be found. Fish farms and their
             risk of adverse impacts could -exist if farms are                 floats also provide a substrate on which algae and
             inappropriately sited, or mismanaged.              it is          invertebrates grow, providing a food source that
             recommended that any potential risk could be                      attracts various fishes. Fish associated with farms
             minimized by: (1) using      vaccination to reduce the            in Puget Sound include shiner perch and other
             need for antibiotics, (2)    requiring farms to report            surfperch, true cod, lingcod, dogfish, sculpins, and
             antibiotic use to the State, (3) developing                       flatfish.
             programs to educate farmers on the use of
             antibiotics and vaccination, (4) undertaking                      There, are several, permitting procedures and
             additional research to verify that shellfish held                 regulations which will ensure that fish farms do
             near fish farms in various environments do not                    not have a significant adverse impact on food fish
             accumulate significant amounts of antibiotics, and                and shellfish resources. These include: the HPA
             (5) undertaking further research to establish any                 and NPDES permits, SEPA review, DNR's


             Page ,dv                                                                                                           Summary









           Aquatic Land Lease program, and the habitat                        evaluation of proposals using the most current
           management policy of WDF. These mechanisms                         information.        The existing regulations are
           also provide protection for habitats such as                       adequate to avoid significant adverse impacts to
           herring spawning areas.                                            indigenous species of food fish and shellfish.

           The Intefim Guidelines recommend that fish farms                   Genetic Issues
           not be sited where they are likely to adversely
           affect habitats important to commercial or sport                   Farm-reared fish can only have a genetic impact
           food fish or shellfish fisheries, that are of critical             on wild fish populations if the following three
           ecological importance, or that are especially                      conditions are met: (1) significant numbers must
           sensitive to degradation by cultural activities.                   escape from fish farms, (2) the escapees must
           The Guidelines also establish buffer zones around                  survive and return to mix with a wild population
           habitats of special significance.                                  on the spawning grounds in numbers large
                                                                              enough to affect the wild population, and (3) if
           It is recommended that the habitats identified in                  the other two conditions have been met, the
           the Guidelines should be adopted into WACs as                      escapees must have the genetic capacity to either
           habitats of special significance.            It is also            breed with or outcompete the wild population.
           recommended that a case-by-case evaluation of
           potential additional habitats of special significance              As stated above, past experience indicates that
           and the need for buffer zones around habitats of                   Atlantic salmon are not capable of effectively
           special significance be incorporated into WACs                     competing with Pacific salmon and trout.
           using the distances discussed in the Guidelines as                 Furthermore, Atlantic salmon are genetically
           a reference.                                                       incapable of breeding with Pacific salmon and
                                                                              trout and producing viable offspring.
           Importation of New Fish Species
                                                                              If the escapees were farmed Pacific salmon,
           The introduction of a new species into an area                     interbreeding with wild populations would be
           always poses some level of risk. While this risk                   genetically possible.      The impacts to the wild
           can be minimized, it cannot be entirely                            population, if any, may be a genetic alteration of
           eliminated.      In order for Atlantic salmon to                   the population.       Without constant infusion of
           affect    existing    fish   populations,      significant         genes from escaped fish, any maladaptive genes
           numbers would have to escape from a fish farm                      would disappear rapidly due to selective pressure.
           and then be able to outcompete resident stocks                     Therefore,     any genetic        impacts would be
           of salmon and steelhead.                                           temporary.

           Intentional and accidental releases of Atlantic                    WDF has the responsibility to preserve, protect,
           salmon into Puget Sound and other northeastern                     perpetuate, and manage fisheries resources. This
           Pacific waters have all been unsuccessful in                       responsibility provides WDF with the authority to
           establishing self-sustaining runs. Based on this                   ensure that fish farm proposals would not have
           persistent lack of success in establishing Atlantic                an adverse impact on indigenous fish.                    In
           salmon where other salmonid populations exist, it                  addition, the SEPA review and HPA permitting
           is unlikely that they could establish self-sustaining              processes provide an opportunity to evaluate fish
           runs in Washington rivers.                                         farm proposals on a case-by-case basis at specific
           There are several federal and State regulations                    sites using the most current scientific information.
           that have been           designed     to   ensure      that        It is recommended that the following three
           importation of new species does not adversely                      guidelines be used by WDF when reviewing fish
           affect existing species. In addition, the HPA and                  farm proposals: (1) when Pacific salmon stocks
           SEPA review processes allow a case-by-case                         are proposed in areas where WDF determines


           Summary                                                                                                              Page xv









             there is a risk to indigenous species, WDF should                 exotic salmon diseases with infected eggs. While
             only approve those stocks with the greatest                       the current regulatory policies allow some
             similarity to local stocks near the farm site, (2)                controlled risk, the development of a local brood
             in areas where WDF determines there is a risk of                  stock     would      further     reduce      the      risk.
             significant interbreeding or establishment of                     Implementing the recommendation in conjunction
             harmful self-sustaining populations, WDF should                   with the use of existing regulations would avoid
             only approve the farming of sterile or monosexual                 any significant adverse impacts.
             individuals or genetically incompatible species,
             and (3) in areas where WDF determines that wild                   Marine Mammals and Birds
             populations could be vulnerable to genetic
             degradation, WDF should establish a minimum                       Construction and operation of a fish farm would
             distance of separation between farms and river                    alter habitats for birds and mammals.                Some
             mouths.                                                           species can tolerate or benefit from the presence
                                                                               of a fish farm facility, while species sensitive to
             The potential for significant genetic impacts                     human activity are forced to seek habitat
             resulting from farm escapees interbreeding with                   elsewhere. The siignificance of potential impacts
             wild stocks is low. Use of existing regulations                   will depend on site specific considerations such as
             with the guidelines identified above are adequate                 types and numbe:rs of species in the area and
             to avoid significant adverse impacts.                             proximity to sensitive habitat areas. Disturbances
                                                                               would probably be greatest during construction of
             Disease                                                           the facility.

             The primary concern with the growth of the fish                   The use of lethal methods. to control predators,
             farming industry in Washington has been the                       if widespread, could have an adverse impact on
             possibility of increased risk of introduction of                  marine mammal and bird populations. However,
             exotic diseases. However, this increased risk is                  because non-lethal methods provide effective
             minimal because regulations currently in place                    control, significant impacts on populations are not
             restrict   the    importation     of    serious     exotic        expected.
             pathogens of salmon.
                                                                               The existing State and federal review processes
             The risk of transmission of disease from farms to                 allow site specific factors and the most current
             wild fish is not likely a significant problem.                    data to be considered in the process of siting fish
             Diseases observed in fish farm culture of                         farms, In areas where WDW, NMFS, or USFWS
             salmonids in Washington result from the holding                   indicate that predators may be present, it is
             of the fish in captivity. Such diseases are non-                  recommended that fish farmers be required to
             exotic; infectious agents that cause such diseases                use anti-predator nets. This requirement should
             originate from environmental sources or wild fish.                be adopted into the appropriate WACs. The use
                                                                               of the current regulations along with the
             There is no impact related to infectious diseases                 suggested anti-predator nrt requirement would
             on    invertebrate     populations      that   can     be         avoid significant adverse impacts to marine
             reasonably predicted as a result of salmon                        mammals and birds.
             farming practices. This is because fish pathogens
             are largely distinct from invertebrate pathogens.                 Visual Quality

             Existing    regulations      allow    a    small,     but         The visual impact of fish farms on observers
             manageable potential for adverse impacts. It is                   varieE, considerably with the distance between the
             recommended that enough regional brood stock                      observer and the farm, the altitude of the
             to support the salmon farming industry be                         observer, and the surrounding views.                While
             developed to eliminate the risk of importing                      location and observer posit.iion are very important,


             Page xvi                                                                                                           Summary









          the attitude of the observer is also critical. Some           review and shoreline permitting processes. These
          would consider a farm to be a visual intrusion,               reviews ensure that fish farm proposals are
          while others would consider the same facility to              considered on a case-by-case basis using the most
          be a neutral or interesting part of the visual                current information about navigation patterns,
          environment.                                                  and that they will not be sited in established
                                                                        navigation areas. DNR requires a bond from fish
          Visual quality impacts from fish farms are site               farmers to ensure cleanup of any debris caused
          specific.   The various factors influencing the               by any accidental destruction of the farm.
          potential for impacts (topography, number,
          location, attitudes of observers, and existing visual         It is recommended that local governments provide
          and development character) vary within Puget                  major recreational and commercial boating
          Sound and adjacent waters. Given this variability,            organizations with SEPA and shoreline permit
          specific visual quality guidelines that would apply           notices to help identify areas           of special
          throughout the region are not appropriate.                    importance to boaters.         In addition, it is
          Specific guidelines are best determined by local              recommended that local governments notify
          jurisdictions, and expressed as policies and                  recreational and commercial boating organizations
          regulations    in   individual    shoreline    master         and all marinas and ports near the farm of their
          programs.       It is recommended that local                  precise location and their aids to navigation.
          governments adopt measures that modify either
          the design or location of farm facilities to                  The SEPA and Section 10 permitting processes
          minimize visual impacts.                                      allow fish farm proposals to be evaluated on a
                                                                        case-by-case basis in consideration of local
          Navigation                                                    navigational use. The use of existing regulations
                                                                        and the implementation of the two notification
          Fish farms can affect navigation if sited in                  recommendations       are    adequate     to    avoid
          established navigation lanes, narrow channels, or             significant adverse navigation impacts.
          where boats would be unable to navigate safely
          around them. In addition, if fish farms break                 Commercial Fishing
          loose from their anchors during severe weather
          conditions they could become a hazard to vessel               The direct impact of floating fish farms on
          traffic. If fish farms are inadequately lighted or            commercial fishing is the potential for collision or
          made visually unobtrusive, they pose a greater                entanglement of the fishing nets with the farms,
          risk to navigating vessels and may be a significant           resulting in damaged gear and a loss of available
          safety hazard, especially at night or during                  fishing time and area. Results of this impact can
          inclement weather. The further offshore a farm                be displacement of fishers from a productive and
          is located, the greater the navigational risk                 accustomed fishing area, lost harvest potential,
          because. structures are not expected, reference               and reduced opportunity of the fishers to catch
          points are not nearby, traffic is more intense, and           their allotment of salmon. The significance of
          vessels are usually travelling faster.                        the potential impact depends on site-specific
                                                                        conditions.     If non-tribal fishers have the
          Fish farms may also have a beneficial impact on               opportunity to catch the same fish in another
          navigation by providing a point of assistance or              area, the displacement of the fishers from a
          refuge to boaters.                                            particular site may not be a significant adverse
                                                                        impact.    The potential displacement of tribal
          The USCG has the responsibility for reviewing all             fishers could also occur. If a farm prevents a
          proposed structures in Puget Sound for potential              particular tribe from fishing in their "usual and
          navigation hazards through the ACOE Section 10                accustomed" fishing areas, the tribe would have
          permitting process.       Local governments also              nowhere else to fish and a significant impact
          consider navigation issues during the SEPA                    could result.


          Summary                                                                                                   Page xvii









            WDF is required to promote orderly fisheries,                     this, but further research is necessary to
            and enhance and improve recreational and                          determine whether these findings have any
            commercial fishing in Washington. WDF has the                     general applicability.
            authority to ensure that a fish farm would not
            interfere with an orderly fishery. The SEPA                       The FDA, DOH, and WSDA are responsible for
            review process, and the HPA and Section 10                        regulating the safety of food fish. DOH regulates
            permitting     programs      allow    a     case-by-case          food protection and storage.           They are also
            evaluation of fish farm proposals using the most                  charged with approving shellfish growing areas
            current information about a specific site.                        and    assuring     that   these    areas,    and     the
                                                                              commercially harvested shellfish from these areas,
            It is recommended that local governments                          are not contaminated.       WSIDA prohibits the sale
            implement the following two measures through                      of fish which are          decomposed or contain
            their SEPA and shoreline permitting processes:                    antibiotic residues.
            (1) provide commercial fishing organizations and
            tribes with SEPA notices related to fish farm                     While human health risks appear to be minimal,
            proposals to help identify areas of special                       it is recommended that the following four
            importance, and (2) provide commercial fishing                    measures be implemented to further reduce any
            organizations and tribes with the precise location                potential impacts on human health: (1) site fish
            of farms and the layout of their anchor lines.                    farms in areas providing water quality compatible
                                                                              with good husbandry practices to ensure that
            The SEPA review, and HPA and Section                    10        farms are not sited in warm, rich embayments of
            permitting processes also allow a case-by-case                    Puget Sound susceptible to seasonal increase
            assessment of fish farm proposals using the most                  levels of V. parahaemolyticus, (2) conduct further
            current information regarding commercial and                      research       to     determine         bacteriological
            tribal fishing activities.      The use of existing               characteristics of fish food, (3)      conduct further
            regulations and the         implementation of the                 research to validate the geographic distribution of
            recommendations described above are adequate to                   lowered parasite loads in farmed fish, and
            avoid significant adverse impacts.                                (4) provide advisory notices to fish farmers about
                                                                              the proper storage of fish food.
            Human Health
                                                                              Implementing the measures recommended above
            Fish farming activities will not contribute                       in conjunction with existing federal health
            bacterial human pathogens to the environment                      regulations would. avoid significant adverse
            because the bacteria associated with salmonid and                 impacis.
            other cold water fish farming activities are
            distinct from human pathogens. In addition, the                   Recreation
            occurrence       of     Vibrio      parahaemolyticus
            gastroenteritis is relatively rare and is most                    Fish    farms    have    the    potential    to     affect
            commonly associated with poor food handling                       recreational activities by obstructing access to
            processes. Fish farming appears unlikely to have                  shore or water areas traditionally used for
            an    effect     on    cases     of      parahaemolytic           recreation, or disrupting the intrinsic      and visual
            gastroenteritis       associated        with      eating          quality of the area. Floating fish farms can also
            contaminated raw shellfish.                                       have positive impacts on recreational activities,
                                                                              because personnel from farms could provide
            Preliminary research indicates that salmon raised                 assistance during boating emergencies.                 In
            in fish farms have an absence of parasitic worms                  addition, the farm structure itself could be used
            that sometimes afflict humans eating raw salmon                   for temporary moorage during an emergency.
            in products such as sushi or sashimi. Fish farms
            may have a slight beneficial impact because of


            Page xviii                                                                                                        Summary









           WDF is required to promote orderly fisheries,                  Odors
           and enhance and improve recreational and
           commercial fishing in Washington. WDF has the                  Vish farms have the potential to be a
           authority to ensure that a fish farm proposal does             concentrated source of odors because of the large
           not interfere with an orderly recreational fishery.            amount of organic matter associated with marine
           The SEPA review process, and the HPA and                       facilities. All.odor impacts would be occasional
           Section 10 permitting programs also provide an                 and intermittent. The major potential sources of
           opportunity to assess the potential impacts of a               odors are spilled or improperly stored fish food,
           fish farm proposal on a case-by-case basis.                    air drying of nets fouled with attached marine
           These review and permitting processes allow the                life, and dead fish. In addition, decaying organic
           most current information on recreational activities            matter from all of these sources can accumulate
           at a specific site to be incorporated into the                 on the farm walkways.           Boats servicing the
           decisionmaking process.          These review and              facility and internal-combustion motors used to
           permitting processes and the use of existing                   power pumps and aeration equipment would
           regulations are adequate to avoid significant                  contribute minor amounts of exhaust fumes to the
           adverse impacts to recreation.                                 immediate area of the facility.

           Noise                                                          Most local shoreline master programs discuss
                                                                          odor in relationship to aquaculture facilities, and
           Potential noise impacts would primarily occur                  some shoreline programs require the proper
           during daytime hours when farm operations take                 disposal of wastes. It is recommended that best
           place. Sources of noise from fish farms would                  management practices be developed for the fish
           include boats servicing the farms, motors,                     farming industry to include measures such as:
           compressors for aeration, and incidental noise                 (1) daily removal and disposal of dead fish and
           from personnel working on the facility. Because                cleanup of spilled food, (2) regular cleaning of
           of the usual absence of obstructions above the                 nets, (3) storage of food in closed containers, and
           water surface, any noise produced by farm                      (4) use of walkways that are designed to allow
           operations will tend to carry farther than would               spilled food to readily fall into the water.          In
           be expected for a similar noise source located on              addition,    local   governments      may want        to
           land.                                                          encourage sites downwind of residences, and         sites
                                                                          that increase the distance between the farm and
           There are a number of State, federal, and local                residences in areas where this would not increase
           regulations and guidelines that address the                    potential navigation conflicts.
           impacts from noise. It is recommended that local
           governments implement the following three                      Use of existing regulations and the development
           measures through their shoreline permitting                    of best management practices for the fish farming
           process to further reduce potential noise impacts              industry would avoid significant adverse odor
           related to fish farms: (1) require installation and            impacts.
           regular maintenance of mufflers on all motorized
           equipment, (2) require enclosures on all                       Upland and Shoreline Use
           motorized equipment, and (3) require farms to
           use electric motors to operate pumps and                       Fish farms have the potential to influence future
           compressors when the farms have access to                      development patterns in an area. Fish held in
           shoreline electrical power (for example, adjacent              pens are particularly sensitive to degradation of
           to a dock). Use of existing State noise standards              water quality. Once a fish farm is installed it
           and the implementation of the three measures                   will highlight water quality concerns in the area.
           identified above would avoid significant noise                 Therefore, greater attention may be brought to
           impacts from fish farms.                                       bear on activities that are not presently meeting
                                                                          water quality standards, or proposed activities


           Summary                                                                                                       Page xix









            which could adversely affect water quality. This              impact on local services, the size of the
            increased concern may result in local and State               cumulative impact of several farms would be
            agencies placing additional restrictions on upland            minor.
            projects to prevent water quality degradation.
            Upland users may also be subject to liability if              There are numerous State regulations that
            their action, in violation of pollution laws, were            address local services such as fire and police
            to damage the fish in the pens.                               services, sewage and water services, and landfills.
                                                                          It is :recommended that local governments require
            Highlighting activities that may degrade water                fish farm applicants to provide the following
            quality and subjecting them to greater regulatory             information as part of their shoreline permit
            control would not be an adverse impact.            All        application: (1) a high and low estimation of the
            activities along the shoreline should minimize or             volume of waste that may be produced by the
            prevent water quality degradation. If a fish farm             proposal, including potential catastrophic losses,
            serves to increase awareness of water quality                 and (2) the process by which the farm will
            needs, or results in changes to upland activities             dispose of its waste.
            that are degrading water quality, it would be a
            beneficial impact.                                            Use of existing regulations with implementation
                                                                          of the recommendations above would avoid
            Some local shoreline master programs include                  significant adverse impacts to local services.
            provisions for protecting aquaculture activities
            from incompatible upland uses.          In addition,          Cumulative Impacts
            some local shoreline programs include provisions
            that require farms to properly dispose of waste to            The potential cumulative impacts from fish farm
            prevent the degradation of associated upland                  development in Puget Sound would be minimized
            area.                                                         by the, evaluation process :resulting in the proper
                                                                          siting of individual farms. Siting five farms in an
            Existing regulations are adequate to avoid                    embayment, or a number of farms throughout
            significant adverse impacts to upland and                     Puget Sound, would not have a cumulative impact
            shoreline uses.                                               on the elements of the environment discussed in
                                                                          this FEIS if the locations of other nearby farms
            Local Services                                                were considered in the permitting process.

            The operation of fish farms does not require                  The -process of analyzing cumulative impacts of
            large amounts of fresh water or electricity. Fish             fish farms must be sequential. Individual farms
            farms must dispose of solid waste generated at                would receive their own site specific SEPA review
            the farm site.     The major component of this                and -undergo scrutiny for compliance with the
            waste is fish that die and are not harvestable for            regulations discussed throughout this FEIS,
            commercial sale. There are three ways that fish               including consideration of nearby fish farm
            farms presently dispose of their dead fish: (1)               develc)pment.
            dispose of the fish at landfill sites, (2) reprocess
           .the fish into fish food, and (3) incorporate the              PHASED REVIEW:
            fish into local agricultural activities. Fish farms
            would not have an impact on other local services.             This is a programmatic EIS that assesses the
                                                                          environmental impacts of floating fish farms. It
            Increasing the number of farms in a localized                 does not assess the impacts of any individual
            area would probably result in a cumulative impact             proposal. Public officials and agencies may elect
            on local services, because any particular service             to utilize the information presented in this FEIS
            would likely be provided by a single purveyor.                to develop policies and rules for floating fish
            Because any one farm results in an insignificant


            Page xx                                                                                                   Summary









          farms in Puget Sound. These actions would then
          be subject to SEPA.

          Fish farms that are proposed subsequent to this
          FEIS must comply with the provisions of SEPA
          on their own, individual merits. State agencies
          and local governments can use the information
          provided in this FEIS to assist them in making
          SEPA threshold determinations and shoreline
          permitting decisions, help them define specific
          additional information that may be necessary
          from fish farm proponents, and help them
          properly site floating fish farm proposals in Puget
          Sound.













































          Summary                                                                                        Page3od









             Table 1. Summary of alternatives.


                               No-Action Alternative                                                 Preferred Alternative



             BOTTOM SEDIMENTS AND BENTHOS

             Intefirn Guidelines include minimum depth and current                Continue to use depth and current guidelines. Adopt
             guidelines, and bathymetric, diver, and baseline surveys.            surveys and annual monitoring identified in the
             Annual monitoring of sediment impacts under fish farms.              Guidelines into WACs. Annual review of monitoring
             Ecology sediment quality standards. SEPA and HPA                     reports by Ecology, VVDF, DNR to determine if depth
             case-by-case review.                                                 and current guidelines should be revised.

             WATER QUALITY

             Ecology will receive NPDES permits for commercial                    Adopt surveys and annual monitoring identified in the
             farms producing over 20,000 lbs of fish per year.                    Guidelines into WACs. During periods of naturally high
             Compliance with State water quality regulations.                     turbidity, require farmers to monitor turbidity net
             Hydrographic survey of site before permitting. Annual                cleaning activities, and increase the frequency of net
             water quality monitoring. SEPA review.                               cleaning to ensure compliance with State water quality
                                                                                  standards.


             PRYTOPLANKTON

             Guidelines define geographical areas in Puget Sound that             Identify Holmes Harbor, Budd Inlet, and Hood Canal
             are nutrient sensitive, and maximum production limits in             south of Hazel Point as nutrient sensitive in WACs. Limit
             embayments.                                                          total fish production within these sensitive areas to that
                                                                                  which will not adversely affect existing biotas. Adopt
                                                                                  maximum production levels for the 19 embayments
                                                                                  identified in the Guidelines into WACs and require any
                                                                                  subsequent fish farm development to demonstrate with
                                                                                  field and modeling studies that further development will
                                                                                  not adversely affect existing biota.

             CHEMICALS

             Use of FDA-approved chemicals. SEPA review.                          Recommend using vaccination to reduce use of
                                                                                  antibiotics, requiring farms to report antibiotic use to the
                                                                                  State, developing educational programs to educate
                                                                                  farmers on use of antibiotics and vaccination, undertaking
                                                                                  research to verify shellfish near fish farms do not
                                                                                  accumulate significant amounts of antibiotics, and
                                                                                  undertaking additional research to establish any potential
                                                                                  amounts of antibiotics in sediments near fish farms, if
                                                                                  sediments occur.

             FOOD FISH AND SHELLFISH

             HPA, Section 10, and NPDES permits required for fish                 Adopt habitats of special significance identified in the
             farms. VVDF authority to "preserve, protect, perpetuate,             Guidelines into WACs. Adopt a requirement for a case-
             and manage. . ." food fish and shellfish resources. DNR              by-case evaluation of both the need for additional habitats
             Aquatic land Lease program. Guidelines include siting                of special significance, and the need for buffer zones
             criteria for fish farms and buffer zones around significant          around habitats of special significance into WACs.
             habitats. Diver survey to aid in identifying habitats.
             SEPA review.





                                                                                                                                    Page xxiii








              Table 1. Summary of alternatives (continued).


                                No-Action Alternative                                               Preferred Alternative



              IMPORTATION OF NEW FISH SPECIES

              Several State and federal regulations designed to ensure            Existing regulations are adequate to avoid significant
              importation of new species does not adversely affect                adverse impacts. No additional recommendations.
              existing species.    HPA and Section 10 permitting
              processes. SEPA review.

              GENETIC ISSUES

              WDF has responsibility to preserve, protect, perpetuate,            Recommend V11DF use of following guidelines when
              and manage fishery resources. Authority to ensure fish              reviewing fish farm proposals. When indigenous stocks
              farms would not have an adverse impact on indigenous                are piroposed for farms, WDF should only approve those
              species. Hydraulic Code and HPA permit review. SEPA                 with the greatest similarity to local stocks. In areas with
              review.                                                             risk Df significant interbreeding or establishment of
                                                                                  deleterious self-sustaining populations, WIDF should only
                                                                                  approve the farming of sterile or mono-sexual individuals.
                                                                                  Establish minimunt distance between farms and river
                                                                                  mouths in areas where wild populations could be
                                                                                  vulnerable to genetic degradation.

              DISEASE

              Washington State and federal laws require certification             Require development of enough regional broodstock to
              that all salmon eggs not contain any virus or other                 support the Washington fish farming industry.
              significant fish pathogens before fish can be placed in
              State waters. Finfish Transfer/Import permit.

              MARINE MAMMALS AND BIRDS

              Various local, State, and federal laws and programs                 Adopt requirement into WACs for the use of anti-
              include language protecting marine mammals and birds.               predator nets in areas identified by WDW, USFWS, or
              These include local shoreline master programs, the                  NMFS as areas where predators may be present.
              Marine Mammal Protection Act, the Migratory Bird
              Treaty Act, the Endangered Species Act, and the Bald
              Eagle Protection rules. The Guidelines recommend
              separating fish farms 1,500 ft from habitats of special
              significance depending on the site characteristics an     'd
              nature of the farm. Non-lethal techniques (foll. i
                                                                    owing
              federal and state rules) should be used to discourage
              predators. SEPA review and the Section 10 permitting
              processes allow evaluation of proposals using the most
              current information for a specific site.












              Page xxiv









            Table 1. Summary of alternatives (continued).


                              No-Action Alternative                                                 Preferred Alternative



            VISUAL QUALITY

            The Shoreline Management Act and local shoreline                     Local governments should adopt measures to modify
            programs include broad guidelines for addressing visual              either the design or location of farm facilities to minimize
            impacts. TheAquaculture Siting Study includes general                visual impacts.
            design and location guidelines and recommends siting fish
            farms 1,500 to 2,000 ft offshore to minimize visual
            impacts. SEPA review. Ecology review of shoreline
            permits.

            NAVIGATION

            Section 10 permit. USCG review for potential navigation              Recommended that local governments: (1) provide major
            hazards. USCG may require fish farms to install private              recreational and commercial boating organizations with
            aids to navigation. DNR requires a bond from the fish                SEPA and Shoreline permit notices, and (2) notify
            farm to ensure cleanup in case of accidental destruction             recreational and commercial boating organizations and
            of the farm. SEPA review.                                            marinas and ports near the farm with its precise location
                                                                                 and aids to navigation. In suitable areas, place farms
                                                                                 close to shoreline or near existing impediments to
                                                                                 navigation such as marinas and docks.

            COMMERCIAL FISHING

            WDF required to promote orderly fisheries, and enhance               Recommend that local government: provide commercial
            and improve commercial fishing. HPA and Section 10                   fishing organizations and tribes with SEPA notices, and
            permits, and SEPA review, allow case-by-case review of               notify commercial fishing organizations and tribes of the
            individual proposals using current information on fishing            precise location of farms and anchor lines. In suitable
            activities. The U.S. v. Washington (Boldt decision states            areas, place farms close to shoreline or near existing
            that treaty tribes in Puget Sound shall be allowed to fish           impediments to navigation such as marinas and docks.
            in their "usual and accustomed" fishing areas.

            HUMAN HEALTH

            FDA, DOH, and WSDA have the responsibility for                       Recommend four measures: (1) site fish farms in areas
            regulating the safety and food fish. DOH regulations                 that provide water quality compatible with good
            food protection and storage. WSDA prohibits sale of                  husbandry practices, (2) conduct further research to
            adulterated fish, which includes decomposed fish and fish            determine the bacteriological characteristics of fish food,
            containing antibiotic residues.                                      (3) advise fish farmers on proper storage for fish food,
                                                                                 and (4) conduct additional research to validate the
                                                                                 geographic distribution of a lower number of parasites in
                                                                                 farm fish.


            RECREATION

            WDF has responsibility to promote orderly fisheries, and             Site specific review and permitting processes are adequate
            enhance recreational fishing in Washington.            Local         to avoid significant adverse impacts to recreation.
            shoreline, SEPA, HPA, and Section 10 permitting
            processes allow case-by-case analysis to incorporate the
            most current information on recreational activities for a
            particular site. WSPRC review near State marine parks.




                                                                                                                                    Page xxv








              Table 1. Summary of alternatives (continued).


                                No-Action Alternative                                               Preferred Alternative



              NOISE

              Noise sources other than recreational watercraft are                Recommend that local governments require mufflers and
              subject to the State Maximum Environmental Noise                    enclosures on all motorized fish farm equipment, and
              Levels. EPA noise guidelines. SEPA review.                          require farms to use electrictnotors in areas with access
                                                                                  to electricity such as adjacent: to docks.

              ODORS

              State laws prevent nuisances to individuals. Language in            Develop best management practices to reduce odor
              local shoreline master programs concerning odor and                 including: (1) daily removal and disposal of dead fish, (2)
              proper disposal of wastes. SEPA review.                             regular cleaning of nets, (3) storage of food in closed
                                                                                  containers, and (4) use of walkways that readily allow
                                                                                  spilled food to fall into the Nvater. Local governments
                                                                                  may also want to encourage sites that increase the
                                                                                  distance between farms and residences and encourage
                                                                                  farms to be placed downwind of residences.

              UPLAND AND SHORELINE USE

              Some local shoreline programs provide regulations that              Use of existing regulations are adequate to avoid
              protect fish farms from incompatible upland uses. Some              significant adverse impact to upland and shoreline uses.
              local programs include provisions that require farms to
              properly dispose of wastes to prevent degrading upland
              areas. SEPA review.


              LOCAL SERVICES

              Numerous State regulations that address local services              Recommend that local goverrunent require a high and
              such as police and fire, landfills, and water and sewer             low estimation of the volume of waste to be produced by
              service. SEPA review.                                               the farm, including catastrophic losses. Also recommend
                                                                                  that local government require information on the process
                                                                                  by wbich the farm will dispose of its waste.





















              Page xxvi










                         Table 2. Agencies with specific authority and/or expertise.



                                                                                STATE AGENCIES                            LOCAL                      FEDERAL AGENCIES

                                     ISSUES                  WDF     WDOE      WOW     WSDA     DNR     WSPRC     WDOH    LOCAL      EPA      USFWS     NMFS      USCG       FDA

                         NATURAL ENVIRONMENT
                         Sediment & Benthos                   X         x                        x                                    x                   X
                         Water Quality                        X         X                                          X                  X                                       X
                         Phytoptankton                        X         X                                          X
                         Chemicals                            x         X               x                                             X                                       x
                         Fish & Shellfish                     x                         x        x                                              X         X
                         Importation of New Species           x                         X
                         Genetic Issues                       X                         x
                         Disease                              x                         x
                         Marine Mammals  & Birds                                X                                                               X         X
                         BUILT ENVIRONMENT
                         Visual Quality                                 x                                                    x
                         Navigation                                     x                        x-                          x                                      X
                         Commercial Fishing                   x                                                                                 X         X
                         Human Health                                                   X                          x         x                                                X
                         Recreation                           x         X       x                         x                  x                  x                   X
                         Noise                                          X                                                    x        X
                         Odor                                           X                                                    x
                         Upland & Shoreline Use                         x                                                    x
                         Local  Services                                                                                     x

                         State  Agencies:                                                                                 NOTE:   Any of the Listed agencies can participate
                                WDF         Washington  Department of   Fisheries                                                 in the environmentaL review of these
                                WDOE        Washington  Department of   Ecology                                                   issues through the SEPA process.
                                WOW         Washington  Department of   Wildlife
                                WSDA        Washington  Department of   Agriculture
                                DNR         Washington  Department of   Natural Resources
                                WSPRC       Washington  State Parks &   Recreation Commission
                                WDOH        Washington  Department of   Health

                         Local Agencies:
                                LOCAL       Local County Government


                         Federal Agencies:
                                EPA         U.S. Environmental Protection Agency
                                USFWS       U.S. Fish & Wildlife Service
                                NMFS        National Marine Fisheries Service
                                USCG        U.S. Coast Guard
                                FDA         U.S. Food & Drug Administration









         Table 3.       List of abbreviations and acronyms used in this FEIS.


         ACOE                                 Army Corps of Engineers
         AHD                                  Acoustic Harassment Devices
         BOD                                  Biochemical Oxygen Demand
         BMP                                  Best Management Practice
         dBA                                  Decibel (A-weighted)
         DEIS                                 Draft Environmental Impact Statement
         DNR                                  Department of Natural Resources
         Ecology                              Department of Ecology
         EIS                                  Environmental Impact Statement
         EPA                                  Environmental Protection Agency
         FCR                                  Food Conversion Ratio
         FDA                                  Food and Drug Administration
         FEIS                                 Final Environmental Impact Statement
         FICUN                                Federal Interagency Committee on Urban Noise
         HPA                                  Hydraulic Project Approval
         Leq                                  Equivalent Constant Sound Level
         MHHW                                 Mean Higher High Water
         MLLW                                 Mean Lower Low Water
         MMPA                                 Marine Mammal Protection Act
         MT                                   Metric tons
         mv                                   Millivolt
         NMFS                                 National Marine Fisheries Service
         NPDES                                National Pollution Discharge Elimination System
         NTU                                  Nephelometric Turbidity Units
         OTC                                  Oxytetracycline
         PEIS                                 Programmatic Environmental Impact Statement
         PSP                                  Paralytic Shellfish Poisoning
         PSWQA                                Puget Sound Water Quality Authority
         RCW                                  Revised Code of Washington
         RPD                                  Redox Potential Discontinuity
         SCUBA                                Self-Contained Underwater Breathing Apparatus
         SEPA                                 State Environmental Policy Act
         SMA                                  Shoreline Management Act
         TOC                                  Total Organic Carbon
         VHS                                  Viral Hemorrhagic Septicemia
         WAC                                  Washington  Administrative Code
         WDF                                  Washington  Department of Fisheries
         WDOH                                 Washington  Department of Health
         WDW                                  Washington  Department of Wildlife
         WPRC                                 Washington  Parks and Recreation Commission
         WSDA                                 Washington  State Department of Agriculture
         USCG                                 United States Coast Guard
         USFWS                                United States Fish and Wildlife Service






                                                                                                        Page xxix













                             1. BACKGROUND AND OBJECTIVES OF THE EIS


            1.1          BACKGROUND                                             To address these concerns, the Washington
                                                                                Department of Fisheries (WDF), with funding
            Raising fish in floating fish          farms has been               from the Department of Ecology (Ecology)
            practiced in Puget Sound for almost twenty years                    through the Coastal Zone Management Act,
            by public agencies and private individuals. Much                    contracted the University of Washington to review
            of this early culture was experimental and                          fish and shellfish culture around the world to
            concentrated       on     raising     Pacific      salmon.          assess its possible impacts to the aquatic
            Commercial culture began in the early 1970s and                     environment (Weston 1986). On the basis of this
            one very large salmon farm has operated near                        information,' Ecology, WDF, the Department of
            Manchester in. Kitsap County for the entire time.                   Natural Resources (DNR), and the Department
            Salmon fish farms now common in Europe, were                        of Agriculture (WSDA) developed a set of
            based upon this early work in Washington State.                     recommended guidelines. These guidelines, the
                                                                                Recommended         Interim     Guidelines for          the
            In Norway, the national government saw the                          Management of Salmon Fish Farm Culture in
            farming of Atlantic salmon as a means to                            Puget Sound, were intended to assist State and
            economically stimulate the more rural and                           local decision makers in assuring that fish farms
            economically depressed         coastal areas of the                 were located in areas that would avoid significant
            country. Many of these         areas depended largely               adverse impacts to the aquatic environment
            on commercial fishing, which had declined                           (SAIC 1986).
            severely.     Consequently, a major effort was
            directed at developing salmon farming as a                          These efforts, however, did not completely
            cottage industry, especially for former fishers.                    address the issue of fish farms. Shoreline
            The    success     of    this   effort    is  now      well         residents, the commercial fishing industry, and
            documented.         Norway has become a major                       other citizens expressed concern about the
            exporter of salmon, with anticipated production                     possible effects of an expanding fish farm
            exceeding 100,000 metric tons (220 million                          industry on other traditional uses of the State's
            pounds)      annually.      (By      comparison,        the         waters. In response to these concerns and the
            Washington commercial salmon fishing industry                       growing controversy, the Washington State
            produces about 2,950 metric tons [6.5 million                       Legislature     directed     WDF      to    prepare      an
            pounds] of Pacific salmon each year.)                               environmental assessment of the impacts of fish
                                                                                farm culture in Puget Sound (see Appendix J).
            The success of these efforts, and the          dominance            WDF elected to prepare this assessment as a
            of the United States as the market for salmon,                      programmatic environmental impact statement
            led to rapid growth of salmon farm culture in                       (EIS) following the procedures of the State
            Washington State. This growth was unexpected,                       Environmental Policy Act (SEPA) for non-project
            and has resulted in numerous conflicts between                      EISs.     WDF also contracted to complete a
            culturists and other users of the State's shores                    separate report (not a SEPA requirement) on the
            and waters. Numerous environmental concerns                         economics of salmon farming (see Appendix E).
            have also been raised that have not been
            adequately answered.



            Background and Objectives                                                                                               Page 1









            On September 30,         1987, WDF issued a                 to avoid significant adverse; impacts. See Section
            Determination of Significance for the evaluation            4 for a further discussion of the alternatives.
            of fish culture in floating fish farms. Pursuant to
            WAC 197-11-408, WDF requested written                       The intent of this FEIS is to provide information
            comments on the scope of the programmatic EIS.              to regulators, the public, and the Legislature for
            In addition, WDF held three public meetings to              assessiing the adequacy of existing regulations that
            receive public comments.          The dates and             affect the fish farming industry in Washington, as
            locations of the meetings were:                             well as presenting; a Preferred Alternative that
                                                                        identifies actions that State and local governments
                    October 13, 1987: Port    Townsend                  can undertake to avoid significant adverse
                    October 14, 1987: Port    Orchard                   environmental impacts.
                    October 15, 1987: Mt. Vernon
                                                                        While no activity can occur without some level of
            Written comments received in response to the                impact, it is the goal of this FEIS to ensure that
            scoping notice and audio tapes of the public                all reasonable efforts be made to limit impacts
            meetings are on file with WDF in Olympia.                   from fish farms. Howeve.T, any impacts to food
                                                                        fish and shellfish or their habitats must be fully
            WDF issued the Draft EIS (DEIS) on February                 mitigated. The ultimate goal of the WDF is to
            6, 1989, and invited written comments from                  ensure the continued viabillity of Puget Sound as
            agencies, local governments, tribes, and interested         a resource to be used and appreciated by a wide
            citizens. Because of the complex nature of the              variety of users.
            document, WDF extended the 30-day SEPA
            review period to two months and accepted
            comments until April 7. In addition to inviting
            written comments, WDF held two public meetings
            to receive comments on the DEIS. The dates
            and locations of these meetings were:

                    March 1, 1988: Silverdale
                    March 9, 1988: Mt. Vernon


            Responses to the written comments received by
            WDF are included in this Final EIS (FEIS) in a
            separate volume.

            1.2        OBJECTIVES


            The objective of the FEIS is to assess the
            potential environmental impacts of fish farm
            development in Puget Sound (see Figure 1) under
            the following two alternatives: (1) the No-Action
            Alternative evaluates the potential impacts from
            floating fish farm development under the existing
            regulations and guidelines currently affecting the
            fish farming industry in Washington, and (2) the
            Preferred Alternative evaluates the potential
            impacts from fish farms under existing regulations
            with recommended additional measures that can
            be taken by State agencies and local governments


            Page 2                                                                               Background and Objectives









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    SCALE IN MILES
                                                                                                                                Figure 1.
    0          10          20                                                                                                   Vicinity Map













                            2. BACKGROUND OF THE FLOATING FISH FARM P4DtJSIW



             Floating salmon farms have been in Washington                  A cross-section of a typical floating fish farm is
             waters since the early 1970s.       In Puget Sound,            illustrated in Figure 3. The primary component
             commercial farms are primarily used to raise                   of a floating fish farm is a group of pens that
             coho (Oncorhynchus kisutch) or Atlantic (Salmo                 float in the water separated by walkways 1 to 2
             salar) salmon.    Presently, there are 13 floating             in (3-.6 ft) wide. The number of pens at a fish
             commercial fish farms facilities operating in                  farm, and the amount of surface water they
             Puget Sound (see Figure 2). There are also nine                cover,, varies considerably. Currently, all new fish
             research and delayed-release facilities used by                farnis in Washington are limited to a total
             agencies, tribes, and private recreational sports              surface area of less than two acres (8,100 in).
             groups    to   enhance     Puget     Sound      salmon         Examples of a wide variety of pen configurations
             populations. Delayed-release farms are used to                 are shown in Figure 3, but most farms in Puget
             hold salmon for one to six months before release               Sound are either square oi rectangular structures
             into the wild after the fish have lost their                   consisting of up to 50 pens. The most typical
             inclination to migrate out of State waters. This               size is a complex 30 by 300 in (100 by 1,000 ft).
             FEIS does not specifically evaluate the impacts of             Recently, fish farms have been proposed using
             delayed-release farms.      However, many of the               circular pens of up to 30 in (100 ft) in diameter,
             environmental impact discussions in this FEIS                  arranged in clusters of three or four pens. For
             also pertain to delayed-release facilities though              the purposes of assessing the impacts of fish
             their smaller size and temporary nature will                   farmf; in this FEIS, it is assumed the pens are
             result in proportionally reduced impacts.                      arranged in a 30 by 300 in (100 by 1,000 ft)
                                                                            rectangle.
             A typical floating commercial fish farm operating
             in Puget Sound receives young fish from a                      Floating fish farrns are typically constructed with
             freshwater hatchery.       These fish are placed               galvanized steel, plastic pipe, or wood. Railings
             directly in pens floating in Puget Sound.          The         around each individual pen support the net about
             fish are fed daily with pelleted dry food until                1 in (3-4 ft) above the water.           Some farm
             they reach a marketable size. Harvest size and                 operations in Puget Sound have a maintenance
             timing depends on the fish species and market                  building on the farm sii:e to store food and
             demands.         Proper      husbandry       practices,        equipment, provide temporary shelter for workers
             vaccination, and the periodic use of antibiotics in            during inclement weather, and provide security.
             the food protect the fish from disease.          Extra         These buildings vary considerably in color and
             nets surround the pens to protect the fish from                shape, but most are roughly 3 in (8-10 ft) high
             predators.                                                     and 9 to 12 m2 (80-120 fe) in size.

             For the purpose of the impact analyses in this                 Nets, hung from the pen railings, have a 10 to 30
             FEIS, a typical floating fish farm is described                mm mesh (depending on the size of the fish),
             below.   This farm is modeled after the farms                  and are commonly about 12 in (40 ft) square and
             currently used in Puget Sound.                                 5 to 8 in (16-25 ft) deep. This size net provides
                                                                            a total volume of 40,000 to 65,000 W in the
                                                                            typical farm. A net is commonly placed over the
                                                                            top of nursery pens to prevent birds from eating


             Page 4                                                                        Background of Fish Farming Industry









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                                                                                    UNITED STATES









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                                                                                                Figure 2.
     SCALE IN MILES                                                                             General Locations of Existing
                                                                                                Commercial Fish Farms
     0         10        20




























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                                                                                . ..........                                                                     .... .. .
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                                                                                                                                                                                                                                                                    Note: 36 Pens
                                                                                                                                                                                                                                                                                  3' wide walkways between
                                                                                                                                                                                                                                                                                  Pens, 91 center walkway.





                                                                                                                                                                                                                                       V DIAMETER                                      31
                                         FLOAT                       1" CABLE                                                                                                                                                          PIPE RAILING
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                                                                                                                                                                                                                                                 Figure 3.
                                                                                                                                                                                                                                                 Example of a Fish Farm and
                                                                                                                                                                                                                                                 Various Pen Configurations








           small fish. A larger mesh perimeter net is used                             3. LOCATION
           around the farm for protection from potential
           aquatic predators.                                           The geographical focus of this document is on all
           The pens are held in place by a series of                    marine waters of Washington State from the west
           anchors, anchor lines, and floats. A short length            end of the Strait of Juan de Fuca, north to the
           of cable or rope attaches the pens to a large                Canadian border, and south to Olympia (see
           float from which a long piece of cable, chain, or            Figure 1). This area includes Hood Canal and
           rope connects each float to a 1,360 to 2,270 kg              all marine bays, harbors, passages, and inlets of
           (3,000-5,000 lb) anchor on the bottom.            The        the Strait of Juan de Fuca, Strait of Georgia,
           floats moderate the effects of weather or tidal              Admiralty    Inlet, and "Puget Sound".         Unless
           currents that may tend to pull the pens down.                otherwise  qualified, the term Puget Sound in this
           Although the number and placement of floats and              document refers to the greater Puget Sound
           anchors at an individual facility varies by site,            marine area just described.
           anchors are usually placed four times the water
           depth away from the pen's perimeter.          Of the
           farms currently operating or proposed in Puget
           Sound, the area typically occupied by the anchors
           is five to ten times the surface area of the farms.


           Most fish farm operations in Puget Sound are
           located away from shore, necessitating the use of
           boats.   Boats at farms are used to transport
           personnel, fish, fish food, and all other supplies
           needed at the site. Boats are typically in the 5
           to 11 m (16-36 ft) range with varying amounts of
           horsepower.

           Presently, the predominant species cultured at
           farms is Atlantic salmon, which have been semi-
           domesticated and may be stocked at relatively
           high densities. In Norway, where pen sizes have
           been limited to 8,000 m3 to encourage a small
           cottage industry, pens are stocked to maximum
           densities that may exceed 40 kg/m3.                 In
           Washington, where larger farms are allowed, fish
           are stocked at optimal densities for growth and
           disease prevention. These stocking densities are
           generally 5 to 7 kg/m3. Thus, a two-acre farm
           would produce 225 to 450 MT (metric tons)
           (500,000-1,000,000 lb) of salmon annually. For
           the purpose of this EIS, it is assumed the
           average farm is two acres in surface area and
           produces 340 metric tons (750,000 lb) of fish per
           year.







           Background of Fish Farming Industry                                                                         Page 7













                                                        4. DESCRIPTIO14 OF ALTERNATIVES


             The two alternatives evaluated in this FEIS are:                 summary of the primary regulations affecting fish
                                                                              farm development follows:
             No-Action - Existing Regulations and Guidelines.
             This     alternative     evaluates      the    potential         State Environmental Policy Act (RCW 43.21C,
             environmental impacts from floating fish farms                   WAC 197-11). The State Environmental Policy
             under the existing regulations and guidelines that               Act (SEPA) was implemented to ensure broad
             affect the fish farming industry in Puget Sound.                 consideration of the social and environmental
             These regulations include relevant State and                     impacts of proposed actions before approval is
             federal    regulations,    local    shoreline    master          granted by State or local governments.             SEPA
             programs;      and     guidelines      such    as     the        requires      the   lead    agency     (usually      local
             Recommended        Interim      Guidelines     for    the        government in     the case of fish farms) to consult
             Management of Salmon Net-Pen Culture in Puget                    with agencies with specific expertise in the
             Sound, and theAquaculture Siting Study.                          environmental     issues involved. If a proposal is
                                                                              likely to have    significant adverse environmental
             A brief discussion of some of the          permits and           impacts, then the ' lead agency shall require
             approvals necessary for a fish farm proposal is                  preparation of an EIS.           Determining that a
             included in Section 4.1.       A list of government              project has significant adverse impacts does not
             groups that regulate the fish farming      industry are          preclude that project.          However, an EIS is
             briefly described in Section 4.2, and      Table 2 lists         required to allow the agency making the decision
             the agencies with authority and/or expertise in                  to be fully informed of the, possible environmen-
             relation to specific elements of the       environment           tal consequences of that decision. Most permits
             discussed in this FEIS.                                          issued by State and local governments are subject
                                                                              to SEPA.
             Preferred Alternative.     This alternative evaluates
             the impacts of floating     fish farms under existing            Shoreline Management Acl (RCW 90.58).                 The
             regulations with recommendations- for expanded                   Shoreline Management Ace (SMA) of 1971 was
             regulations,    and     additional     guidelines     and        implemented to assure appropriate and orderly
             scientific research. This alternative recommends                 develDpment of the State's shorelines, and provide
             additional measures that should be taken by State                for State shoreline management by planning for
             agencies     and    local    governments      to    avoid        and fostering all reasonable and appropriate uses
             significant adverse environmental impacts as a                   in a manner that enhances the public interest,
             result of fish farm development.                                 protects against adverse environmental impacts,
                                                                              and preserves the natural character of the
             4.1          PERMITS AND APPROVALS                               shorelines.


             While existing rules and regulations form the                    The SMA was established as a cooperative
             regulatory     framework       for     the    No-Action          management program between local governments
             alternative, they would continue to apply to                     and the State. Within State guidelines, each local
             future development. However, these rules may                     jurisdiction is responsible. for developing and
             be modified as the result of this FEIS. A brief                  administering its own local shoreline master
                                                                              program with goals, policies, and regulations


             Page 8                                                                                        ]Description of Alternatives
                                                                                                               Permits and Approvals










           adjusted to fit local conditions. Ecology provides                Waste Discharge Permit (RCW 90.48).                  Any
           technical assistance, reviews shoreline permits,                  activity discharging waste that may adversely
           and approves master program amendments and                        affect water quality must have prior approval
           conditional use and variance permits to ensure                    from Ecology. Ecology currently requires waste
           that state-wide issues are addressed.                             discharge permits for commercial fish farms
                                                                             producing less than 20,000 lbs of fish per year.
           Substantial development activities          within the            Also, see National Pollution Discharge Elimination
           shoreline environment, which are           not exempt             System Permit. In addition, Ecology is developing
           from shoreline permit requirements, are subject                   sediment standards for activities in Puget Sound.
           to local shoreline master programs and the SMA.                   When implemented, these standards will also
           Projects must demonstrate compliance with both                    apply to fish farms.
           local and State regulations through the substantial
           development permitting process.                                   Recommended Interim           Guidelines           These
                                                                             guidelines were developed by Ecology, DNR,
           Aquatic Lands Lease (RCW 79.90-.96).                  The         WDF, and WSDA to provide guidance to State
           Department of Natural Resources (DNR) acts as                     and local agencies concerning proper siting of
           the proprietary manager for State-owned public                    fish farms to avoid significant adverse impacts to
           lands.    Aquatic land uses, such as fish farms,                  the aquatic environment. These Guidelines were
           require ground leases from DNR. Leases specify                    the best available knowledge of the agencies at
           location,    structural    development,      operational          the time of publication (1986).         Parts of these
           practices,  lease terms, environmental monitoring,                Guidelines may be adopted into Washington
           rent, and other requirements.             Lessees must            Administrative      Codes      (WACs)        as     State
           obtain all  local, State, and federal permits.                    regulations based   on information presented in this
                                                                             FEIS.
           Hydraulic Project Approval (HPA) (RCW
           75.20.100,   WAC 220-120).           All construction             Section 10 Permit.       The U.S. Army Corps of
           projects are subject to approval by WDF or the                    Engineers (ACOE) reviews projects in State
           Department of Wildlife (WDW) to ensure that                       waters for their probable impact on the public
           food fish and shellfish, and their habitats, are                  interest.   Factors that are considered in their
           protected. Projects must demonstrate that they                    review include: general environmental concerns,
           are designed to provide for the adequate                          historic     values,     economics,        conservation,
           protection of fish life which includes fish habitat.              aesthetics, fish and wildlife values, land use,
                                                                             navigation, recreation, water quality, safety,
           Finfish Import/71ransfer Permits (WAC 220-77-                     energy needs, and in general, the needs and
           030).     Under the authority of RCW 75.58,                       welfare of the people. As part of theSection 10
           Aquaculture Disease Control, permission is                        permit review, State agencies and other federal
           required from the Director of WDF for anyone                      agencies such as the National Marine Fisheries
           who wishes to import aquatic organisms into                       Service (NMFS), U.S. Fish and Wildlife Service
           State waters for culture purposes, or transfer                    (USFWS), U.S. Coast Guard (USCG), and the
           these organisms from one area to another. The                     Environmental Protection Agency (EPA) also
           purpose of this permit is to assure that diseases,                review the permit request.
           pests, or predators are not introduced into State
           waters. All introductions of new species will be                  National Pollution Discharge Elimination System
           assessed during SEPA review to determine their                    Permit (NPDES) (40 CFR 122.21).                  NPDES
           potential environmental impact.                                   permits are required for all point source
                                                                             discharges. The permit system for fish farms will
                                                                             include siting and monitoring requirements to
                                                                             ensure that farms are in compliance with State


           Description of Alternatives                                                                                         Page 9
           Permits and Approvals









            and federal water quality laws. NPDES permits              of competing interests in the use of these
            will be required for all commercial fish farms             resources.     Ecology is the primary agency
            producing over 20,000 lbs of fish per year. The            responsible for controlling pollution, ensuring
            NPDES permit system is administered in                     wate:r quality standards are maintained, and
            Washington State by Ecology, but EPA issues                enforcement of federal and State environmental
            NPDES permits for federal facilities and Tribal            laws.
            projects on Tribal lands.
                                                                       Department of Wildlife. While WDW has no
            4.2         STATE AGENCIES                                 direct managemerit function related to fish farms,
                                                                       they are responsible for managing and protecting
            In addition to the specific regulations, there are         game fish and animals including steelhead and
            a number of different State, federal, and local            cutthroat trout, marine mammals, and birds.
            agencies involved with regulating the fish farm            WDIV reviews -proposed projects through SEPA,
            industry. A brief description of these agencies            SMA, and the ACOE Section 10 permitting
            follows:                                                   process.   They may also require permits for
                                                                       planting, holding, and importation of steelhead or
            Department of Fisheries. It is the responsibility of       othex game fish, except when used in aquaculture
            WDF to preserve, protect, perpetuate, and                  operations.
            mandg-e the food fish and shellfish in the waters
            of the State (RCW 75.08).         This jurisdiction        Washington Pa&i., and Recreation Commission.
            includes all species taken commercially and                The     Washington     Parks     and     Recreation
            recreationally from marine waters, except for              Commission (WPRC) does not issue permits for
            steelhead and cutthroat trout, which are managed           aquaculture activities, but does review project
            by WDW. In addition, WDF is responsible for                proposals. WPRC administers many of the public
            -disease control and prevention for all aquatic            parks along the shores of Puget Sound for
            organisms cultured commercially, and registration          recreation and protection of scenic and natural
            and maintenance of statistics on the aquaculture           attractions.   The WPRC specifically reviews
            industry.                                                  projects via SEPA and the SNIA for compatibility
                                                                       with boating and other recreational activities.
            Department of Natural Resources. DNR acts as
            the proprietary manager for State-owned aquatic            Department of Agriculture. WSDA prohibits the
            lands. These lands are managed for a balance of            sale of fish which are decomposed or contain
            public benefits including environmental quality,           antibiotic residues (RCW 69.04).      WSDA does
            public access, water-dependent uses, renewable             not issue permits, but is responsible under RCW
            resources, and revenue (RCW 79.90.455).           In       15.85 for fostering the development of the State's
            addition, DNR is charged with fostering the                aquaculture    industry  and    providing market
            commercial and recreational use of the aquatic             assistance.   WSDA jointly developed disease
            environment for the production of food, fiber,             control and prevention rulles with WDF.
            income, and public enjoyment (RCW 79.68.080).
                                                                       Puget Sound Water Quality Authority.            The
            Department of Ecology. Ecology was created in              Washington State Legislature established the
            1970 as the central State agency concerned with            Puget Sound Water Quality Authority (PSWQA)
            protection of the environment.      It consolidated        in 1985 in recognition that Puget Sound is a
            the regulatory programs involving air and water             unique and unparalleled resource" and that its
            resources, with the influx of environmental                utili2ation carries a "custodial obligation for
            legislation in the early 1970s, such as the State          preserving it" (RCW 90.70.001). The Legislature
            Environmental Policy Act and the Shoreline                 charged this agency with preparing the Puget
            Management Act.        In addition, Ecology is             Sound Water Quality Management Plan, to be
            responsible for planning for the accommodation             implemented     by   existing   State   and    local


            Page 10                                                                                         State Agencies









          government agencies. The Puget Sound plan was               U.S. Fish and Wildlife Service. USFWS reviews
          originally adopted in December 1986 and was                 ACOE permits and makes recommendations to
          recently revised and adopted in October 1988.               ensure that the proposed projects are compatible
          While this plan imposes no additional permitting            with protection of freshwater and anadromous
          requirements on floating fish farms or other                fish, marine fish, shellfish, marine birds and
          aquaculture facilities, State agencies, and local           mammals, and their habitats.
          governments are required to carry out their own
          statutory mandates in a manner consistent with              National Marine Fisheries Service.     NMFS also
          the plan.   The goal of the plan is to prevent              reviews ACOE permits to assure protection of
          increases in the introduction of pollutants to the          marine mammals and fish.
          Sound and its watersheds and to reduce and
          ultimately eliminate harm from the entry of                 Environmental Protection Agency.          EPA is
          pollutants   to   the   waters,   sediments,     and        responsible for overall protection of the nation's
          shorelines of Puget Sound.                                  water   quality.      EPA     oversees     Ecology's
                                                                      administration of the NPDES permit program,
          4.3         LOCAL GOVERNMENT                                and issues NPDES permits for federal projects
                                                                      and tribal projects on tribal lands.
          Local governments review fish farm proposals
          through SEPA and local shoreline master                     Food and Drug Administration. The Food and
          programs.    Any upland portion of a proposal               Drug Administration (FDA) is responsible for
          would be reviewed under the existing zoning and             ensuring the safety and quality of food entering
          building codes, comprehensive plans, and other              interstate commerce.      Consequently, they are
          regulations. See Section 8, Relationship to Land            responsible for approving any chemicals, such as
          Use Plans and Regulations, for a further                    antibiotics used in fish farm operations.
          discussion of existing plans and regulations
          pertaining to local governments.                            U.S. Coast Guard. The USCG reviews ACOE
                                                                      permits to ensure fish farm proposals will not be
          4.4         FEDERAL AGENCIES                                a hazard to navigation. The USCG may require
                                                                      the farmer to supply aids to navigation to help
          Federal involvement in regulating and     permitting        achieve that goal.
          fish farms is initiated through the ACOE Section
          10 permitting process.     If a federal permit is
          required, review of the project by other federal
          agencies is required under the National Environ-
          mental Policy Act (Public Law 91-190) and the
          Fish and Wildlife Coordination Act (16 USC Sec.
          661).


          U.S. Army Corps of Engineers. ACOE administers
          the Section 10 and Section 404 federal permitting
          programs. Permits are required under Section 10
          of the Harbors and Rivers Act of 1899 (33 USC
          403) for any activity that may affect navigation,
          and under Section 404 of the Federal Water
          Pollution Control Act (33 USC 1251) for any
          activity that discharges materials.





          Federal Agencies                                                                                        Page 11














                                        5. THE NATURAL ENVIRONMENT


           5.1         BOTTOM SEDIMENTS                                    fine-grained sediments and moderately flat
                       AND BENTHOS                                         bottoms.

           Settling of organic matter, mostly from excess                  The substrates found in this nearshore zone (10-
           food and feces from the fish farm, affects                      60 m) range from very fine-grained unconsolidat-
           bottom-dwelling plants and animals (benthos). At                ed sediments (clays and silt) to solid rock, and
           virtually all fish farm sites studied (Gowen and                include all intermediate combinations of mud,
           Bradbury, 1988; Earll et al. 1983; Weston and                   sand, gravel, cobble and boulders. The substrate
           Gowen 1988; Rosenthal et al. 1988; Institute of                 at any given site is determined by current
           Aquaculture 1988), the deposition of organic and                velocities along the bottom. At higher velocities,
           inorganic particulate matter changes the bottom-                currents will erode finer materials and at lower
           dwelling plant and animal communities beneath                   velocities allow sediment in the water to be
           and immediately around the farm. Accumulation                   deposited. Other factors, such as the slope of
           of organic matter and the changes in these                      the bottom and the organisms present, can also
           communities are the readily visible impacts of                  affect sediment type. The. resultant substrates are
           fish farm culture on the aquatic environment.                   quite uniform over many broad areas (for
           Consequently,      these    effects   have     received         example, the broad mud flats of estuaries). Or,
           considerable study around the world.                The         more commonly, they are a complex array of
           following discussion describes the changes to the               sediment types in apparently random patches.
           bottom sediments and to the organisms living
           within these sediments. The effects on larger,                  Because they vary in physical characteristics,
           mobile species are discussed in Section 5.5, Fish               substrates can be inhabited by a variety of
           and Shellfish.                                                  species, depending upon such factors as sediment
                                                                           mineral composition, salinity, slope, depth, and
           5.1.1       Affected Environment                                the organisms already present (Gray 1974;
                                                                           Rhodes 1974). Given the complex interactions
           General.      Fish farms are usually       located in           that determine an organism's presence, which
           nearshore   waters 10-60 m (30-200 ft) deep with                specific organisms will be present in each habitat
           relatively  flat bottoms and moderate currents.                 type or their abundance, cannot be predicted.
           Depth of the nets and the need for water                        However, the types of organisms that will be
           circulation below the farm prevents all but very                found can be predicted (Lie and Evans 1973).
           small farms from being located close to shore.                  Thus, it may be impossible to predict the
           Conversely, difficulties in anchoring in deeper                 abundance      of   a   particular     deposit-feeding
           water, as well as navigational concerns, usually                organisms but it is possible to predict the relative
           prohibit deep sites.        The nearshore benthic               dominance of sediment-deposit feeders as a
           (bottom) habitats beneath or near the farm can                  group.
           support a broad and diverse range of biological
           communities. The dominant factor determining                    The two most important determinants of species
           the nature of these communities is substrate                    groups present in an area are substrate type and
           (physical bottom habitat) type (Lie 1968; Kozloff               the amount of available organic material. Marine
           1987). Most fish farms are sited in areas having                benthic communities in Puget Sound are found in


           Sediment and Benthos                                                                                           Page 13









              sediments ranging from fine silts to rock cobble                 invertebrates are important to society because
              in environments with very little available nutrients             they provide the food sources that support many
              to those that have substantial added organic                     of the economically important fish, crab, and
              material (Lie 1968). The type of community will                  shrirn.p harvested in Puget Sound.
              depend upon the interaction of these two
              components. In some areas, the        type of sediment           The small invertebrates that live on and within
              can vary over      a few meters, yielding several                the soft substrates feed by filtering particles of
              different benthic assemblages in a relatively small              orgardsms from the overlying water (suspension
              geographic area    (Shimek 1983).                                feeders), or by collecting organic material from
                                                                               the sediment (deposit feeders).          Both require
              Habitats.      The marine habitats potentially                   organic material and some oxygen in either the
              affected by fish farms are generally close to                    overlying water or the interstitial water (water in
              shorelines in relatively shallow-water. Depending                the pores of the sediment).           Thus they may
              upon physical conditions, each of these habitats                 benefit from additions of organic material or be
              can support a range of biological communities                    eliminated     by large      quantities    of organic
              (known as assemblages) of animals and plants.                    sediment. The types of organisms present and
              Areas affected by fish farms could contain                       their relative numbers          are   determined by
              examples of virtually every shallow marine benthic               historical factors and ecological interactions
              community found in the greater Puget Sound                       (Birkeland 1974; Woodin 1974) in addition to
              region. Generally, these areas contain a mosaic                  organic concentrations.
              of at least several assemblages. Although these
              communities have often been described in the                     Soft substrates are also commonly inhabited by a
              technical    and     popular     literature,     specific        variety of large, mobile invertebrates that include
              ecological relationships within most of them 'are                primarily shrimp and crabs. Although crabs and
              poorly understood.                                               shrimp may burrow into sediments, they move on
                                                                               the &urface for feeding and reproduction. Some
              The following' is a    general description of these              species undergo daily or seasonal migrations of
              habitats:                                                        considerable distances (hundreds of meters to
                                                                               kilometers). The shrimps include the spot prawn
              Soft Substrates.     .Clay and silt together with                (Pandalus platycerous), coonstripe shrimp (P.
              variable quantities of sand, gravel, and shell                   danae), and the sidestripe shrimp (Pandalopsis
              fragments     form     unconsolidated       or     "soft"        dispar) which are harvested by commercial and
              sediments.. This general substrate type is typical               recreational fishers. The economically important
              of most of the flatter portions of Puget Sound.                  Dungeness crab (Cancer magister) and other
              It: is inhabited by a wide variety of marine                     species are found throughout Puget Sound on soft
              invertebrates.    Although shallow portions (less                substrates.
              than 15 m [50 ft] MLLW) may have eelgrass
              (Zostera marina), the deeper areas do not                        Several other invertebrates also inhabit soft
              typically have aquatic vegetation growing on these               substrates. These include, organisms such as sea
              soft substrates.      A large variety of macro-                  pens (Ptilosarcus gurneyi), heart urchins (Bfisaster
              invertebrates and fishes also live in these areas.               latifrons), and many members of other taxonomic
                                                                               groups    that    are   not    of direct       economic
              The invertebrates that live within the surface                   importance but which forra basic parts of benthic
              layer of soft sediments are generally of three                   communities.
              major groups: polychaete worms, bivalve molluscs,
              or crustaceans.       These groups include many                  Many fishes, including flatfish and cod, feed in
              different forms and sizes of organisms ranging                   these soft- bottom areas on the invertebrates
              from microscopic crustacea and worms. to the                     described above.       The potential effect of fish
              geoduck clam (Panope,abrupta). Most of these


              Page 14                                                                                           Sediment and Benthos









           farms on these fish are discussed in Section 5.5,                       Pen size. In comparing two different size
           Fish and Shellfish.                                                     farms with the same amount of loading,
                                                                                   the larger farm will deposit sediments
           Hard Substrates.         Gravel, cobble, and rock                       over a proportionally smaller area than
           substrate occur in      Puget Sound in areas of                         the smaller farm (Earll et al. 1984).
           relatively high current velocity and/or steep
           slopes. In general, these substrate types occur in                  0   Water depth and current velocity.            In
           areas not particularly suited to fish farms. Some                       deeper water and faster currents, the
           of the areas considered for fish farms might have                       dispersion of wastes will be greater.
           hard-packed sand or gravel substrates or other
           hard substrates nearby.                                             0   Pen configuration. Pen configuration and
                                                                                   orientation to the predominant currents
           Hard substrates support a different group of                            can significantly affect the dispersion of
           organisms than the soft substrates.          Generally,                 wastes (Fox 1988, see Appendix B).
           these substrates are populated by organisms that
           live on the surface or in crevices in the surface.                      Bottom current velocity.       High bottom
           They include sea cucumbers, sea urchins,                                current velocities can erode and disperse
           anemones, snails, abalone, chitons, barnacles, and                      sediments regardless of dispersion in the
           many other invertebrates.     Both the pink scallops                    total water column.
           (Chlamys hastata) and the      rock scallop (Hinnites
           giganteus) are common in      such areas.                               Feed type. Different feeds have different
                                                                                   settling rates. Slower rates allow greater
           Kelp such as the bull kelp (Nereocystis luetkeana)                      dispersion.    In addition, feed that has
           occur only in hard substrate areas.               Many                  lower carbon and nitrogen levels and
           varieties    of   kelp    provide     food     sources,                 higher digestibility will produce less
           reproductive sites, and refuge for a wide variety                       organic matter on the bottom.
           of invertebrates and fishes. Herring commonly
           spawn on some of these algae as well as on                              Feeding method. Feeding methods can
           eelgrass. Most of the kelp are found in relatively                      affect both wastage of feed and utilization
           shallow water, few occur deeper than 30 m (100                          of that feed by the fish. In one study,
           ft) in the north Pacific region. In Puget Sound,                        hand feeding resulted in 3.6% wastage,
           most occur in areas no deeper than 15-20 m (50-                         and up to 27.0 g/m2/day organic matter
           66 ft).                                                                 deposition on the bottom.        The use of
                                                                                   automatic feeders resulted in wastage of
           5.1.2        Impacts of Fish Farms on                                   8.8% and a maximum deposition of 88.1
                       Benthic Communities                                         g/m2/day (Cross 1988).

           The following are factors that determine the                            Bottom sediments and community. The
           impacts of fish farm on the bottom sediments and                        benthic community will also affect the
           benthos:                                                                impact.      Areas of high biological
                                                                                   productivity can assimilate higher organic
                    Loading. The poundage of fish reared in                        deposition.    However, adverse impacts
                    the farm is proportional to the amount of                      may have greater significance due to the
                    organic matter deposited from the farm.                        importance of such productive areas.
                    The greater the density of fish, the more
                    concentrated the deposition of organic                Sedimentation effects are the result of two major
                    waste.                                                factors, additional particulate organic input from
                                                                          uneaten food and . fish feces, and inorganic
                                                                          sediment     deposition.       Another     source     of


           Sediment and Benthos                                                                                          Page 15









            sedimentation is organic matter that grows on               Even with the best FCRs, a portion of fish food
            nets and is dislodged from the net during                   is not eaten and settles to the bottom.         Food
            cleaning. This source contributes relatively little         wastage has proven difficult to determine in field
            to the total sedimentation generated by a fish              conditions. Howover, sevcral studies in Europe
            farm operation (Weston 1986). The organic input             have suggested that a range. of 1-30% of the feed
            from these sources affects both the chemical                may be lost (Gowen et al. 1985; Pencsak et al.
            composition of the sediments and the responses              1982).   Dry food consistently showed the least
            of the organisms in the sediment (Pearson and               amount of wastage (1-5%) while 5-10% of moist
            Rosenberg 1978).       However, due to lack of              fish foods were lost (Gowen and Bradbury 1987).
            knowledge and the diversity and variability of              In Putget Sound farms, fish growers report that
            habitats, qualitative predictions can be made, but          food wastage is typically less than 5% (Weston
            predictive quantification of responses in the               1986).    Specific studies of food wastage at a
            benthic community is impossible.                            commercial (chinook) salmon farm in Sooke Inlet,
                                                                        B.C., showed that hand feeding, the most
            Particulate Organic Input - Uneaten Food. A                 common practice in Puget Sound, resulted in
            typical fish farm producing 340 metric tons                 wastage of 3.6%. The use of automatic feeders
            (748,000 lbs) of fish annually will utilize 340 to          increased wastage to 8.8% (Cross 1988).
            680 metric tons (748,000-1,496,000 lbs) of food.
            Fish are fed a variety of foods, ranging from               Since food pellets do not decompose appreciably
            minced fish, to semi-moist pellets of minced fish           as they settle to the bottom, their nitrogen and
            and various binders, to dry pellets. Semi-moist             carbon is unlikely to be reduced either through
            or dry pellets are used exclusively in Puget Sound          solution or microbial activity, before depositing
            fish farms and consist of a combination of fish             on the bottom (Collins 1983, in Gowen and
            meal and vegetable matter, mixed with vitamins              Bradbury 1987).      Thus, any food particles or
            and other organic material. If the fish become              pellets lost during feeding will retain their
            diseased during culture, antibiotics may be added           nutrients essentially unaltered. Development of
            to the feed for treatment.                                  slower settling food, which is available to the fish
                                                                        in the farm for longer periods, and food with
            Fish farmers measure the effectiveness of their             more uniform size have reduced wastage.
            feeding by calculating a food conversion ratio              However, the amount of wastage is still highly
            (FCR). An FCR is the ratio of food fed (dry                 dependent upon the care used by the fish farmer
            weight) to fish produced (wet weight). Typically,           during feeding.
            average FCRs range from 1:1 to 2:1. That is, for
            every pound of fish produced, 1 to 2 lbs of feed            Particulate Organic Input - Fish Feces. Of the
            were introduced into the water. The amount of               food consumed, about 269,; is lost as feces (Butz
            food used depends primarily upon the type of                and Vens-Capell 1982). Fish feces are smaller
            food used, the size of the fish, and the water              and less uniform in size than food pellets.
            temperature. It may be assumed that fish feed               Consequently, the settling rate of these particles
            includes about 7.7% nitrogen (Edwards 1978) and             will mry greatly, but will. be less than that of
            44% organic carbon (Gowen and Bradbury 1987).               food pellets.     The composition of the feces
            A major research goal for the fish farming                  depend on the chemical composition of the food
            industry is to develop lower-cost food that                 and its digestibility. Gowen and Bradbury (1987)
            provides    maximal     digestibility   and     food        estimated from the literature that about 30% of
            conversion, and minimal environmental impacts.              the consumed carbon would be excreted in the
            Because of this research, there has been a steady           feces, along with about :10% of the consumed
            decline in the FCR values. In some laboratory               nitrogen.
            experiments, FCRs of less than 1:1 have been
            achieved, and most fish farmers now claim values
            between 1 and 1.5.


            Page 16                                                                                    Sediment and Benthos









           From the information presented in the above                   such, as clams.       At low sediment rates, the
           paragraphs, estimates of the total particulate                organic matter may provide an additional food
           matter emanating from fish farms, for eventual                source for these animals.        However, at higher
           deposit on the sea bed, have been calculated.                 rates the energy cost to clean the filtering
           Weston (1986), assuming a FCR of 2 with 5%                    apparatus can exceed the energy derived. At very
           wastage and one-third of the consumed food                    high rates, these animals may actually be buried.
           being lost as feces, estimated that 733 kg (1,600
           lbs) of sediment would be produced for every                  Sedimentation from fish farms decreases benthic
           metric ton (2,200 lbs) of fish grown.              The        sediment oxygen levels by increasing the demand
           Institute   of   Aquaculture      (1988)     estimated        for oxygen, and by decreasing both diffusion and
           sediment production of 820 kg (1,800 lbs),                    water flow into the interstitial spaces of the
           assuming 20% wastage and 30% feces loss.                      sediment.      As increasing amounts of fine
                                                                         sediment accumulate, the depth to which oxygen
           Review of these calculations indicate that they               penetrates    is   reduced,    and   the    underlying
           are very sensitive to changes in the FCR and                  sediment layers become devoid of oxygen (anoxic)
           wastage rate, factors over which the grower has               and unable to support animal life.          The only
           some control through his selection of feeds and               organisms found in such sediments will be those
           feeding procedures. Reducing the FCR from 2 to                that have access to the surface waters for
           1.5 (which may better represent current practice)             respiration via burrows or siphons, and anaerobic
           would reduce the total sediment production by                 bacteria, which can utilize organic material in the
           25%.     Using the Institute of Aquaculture's                 absence of oxygen.
           estimate of sediment production as one extreme,
           the total sediment production from one typical,               Chemical change due to organic enrichment is the
           340-metric-ton farm would be 279 metric tons                  other major mechanism affecting the benthos. As
           (307 tons) annually. Assuming a FCR of 1.5 and                previously discussed, fish food and feces are high
           5% wastage, sediment production could be                      in organic carbon and nitrogen. At low levels of
           reduced by 40% to 171 metric tons (188 tons).                 nutrient enrichment, these particles may enhance
           Organic carbon introduced to the sediments range              the abundance        of the established benthic
           from 84 to 51 metric tons (92-56 tons) and                    community by providing an additional food or
           nitrogen would range from 11 to 7 metric tons                 energy source for deposit- and filter-feeding
           (12-8 tons) with 81% of the carbon and 71% of                 organisms and for scavengers. At higher rates of
           the nitrogen coming from the feces.                           deposition, organic matter will accumulate on the
                                                                         substrate surface and be subject to biological
           Oreanic Enrichment of the Benthos..           Pearson         decomposition       by    bacteria    and     chemical
           and    Rosenberg      (1978)     present     a     very       decomposition.       Both processes, along with
           comprehensive review of the impacts of organic                respiration by infaunal animals, consume oxygen.
           enrichment on bottom sediments and the                        Consequently, oxygen available for exchange into
           associated benthic community. Sources of this                 the sub-surface sediments is reduced.
           enrichment include deposits of natural organic
           matter from seaweed or from terrestrial sources,              OUSen Depletion of the Benthos. In undisturbed
           and organic matter introduced from human                      sediments, oxygen is only able to penetrate a
           activities, such as sewage, pulpmill effluent, and            short distance. How far oxygen may penetrate in
           sediment from log storage.                                    undisturbed sediments depends upon sediment
                                                                         porosity, the presence of burrowing organisms,
           Organic sediments affect the seabed and benthos               and current velocity, which controls the rate at
           by two mechanisms. One is the physical effect of              which oxygen is renewed at the sediment surface.
           the continual deposition of organic or inorganic              Oxygenated sediments are typically light tan to
           fine particles. At high rates, these may clog the             light grey. Below this oxic layer, sediments are
           filtering apparatus of filter-feeding organisms               oxygen depleted (anoxic). Anoxic sediments are

           Sediment and Benthos                                                                                         Page 17








             characterized by their dark black color, and the              is in equilibrium with the oxygen supply from
             distinct aroma of hydrogen sulphide.          As the          surface waters. In enriched sediments, the RPD
             amount of organic enrichment and sedimentation                moves closer to the surface and the depth of this
             increase, the anoxic layer moves closer to the                boundary can be used as an estimate of organic
             surface. In areas of high organic deposition, the             enrichment (Pearson and Stanley 1979).
             anoxic layer will reach the sediment surface,
             coloring it black.     In these cases, the organic            The redox potential (positive = oxic; negative
             material often forms a layer over the original                anoxic) gives a relative indication of the degree
             sediments. In stagnant areas of poor circulation,             of enrichment. Pearson and Stanley (1979) used
             oxygen demand by the anoxic sediments will                    the redox potential measured at 40 min to
             reduce the dissolved oxygen in the overlying                  characterize the degree of enrichment and relate
             water. Anaerobic decomposition of the organic                 these to changes in the benthic community. In a
             matter under these conditions may lead to                     study around an alginate factory discharge, the
             production of methane in sufficient quantities to             redox potentials of undisturbed sediments were
             produce visible bubbles at the surface. At this               typically 300 to 400 mV while potentials less than
             point hydrogen sulfide (H2S)             will reach           -150 mV corresponded to anoxic sediments devoid
             concentrations that allow its distinctive "rotten             of animals. Potentials between -150 and 200 mV
             egg" smell to be detected in the water. H2S is                were sediments dominated by opportunistic
             highly toxic, making these sediments toxic, and               species and potentials of 200 to 300 mV were
             at higher concentrations can lead to mortality of             "transitional" or enhanced. The specific values
             the fish in the fish farm.                                    for a particular habitat will largely depend upon
                                                                           the sediment particle size.      Weston and Gowen
             Determination of Benthic Organic Enrichment.                  (1988) recommend use of redox potential in soft
             Several methods are used by researchers to                    sediments to measure enrichment impacts beneath
             quantify organic enrichment.       The most direct            fish farms because it is effective, relatively
             methods of measuring enrichment are to collect                inexpensive, and can be conducted in the field.
             bottom sediment samples and analyze these for                 They caution that in fine sediments (mud) the
             various nutrients. Since organic carbon controls              RPD is so close to the surface that the probes
             the productivity of the benthic community,                    used for measurement could not reliably measure
             increases in total organic carbon (TOC) result in             the variations in redox potential.
             increased oxygen consumption.             Levels of
             nutrients, nitrogen compounds and phosphates,                 In    addition,    visual    observations      provide
             and sulfides are useful indicators of enrichment,             indications of the area affected by enrichment.
             and can be measured chemically in sediment                    Food pellets are readily detectable, and feces
             samples. Benthic oxygen consumption is a direct               produce a flocculent deposit. Sediment color also
             measure of the oxygen demand by respiration and               changes with enrichment.         In addition to the
             chemical    decomposition      of the      sediments.         normal oxic light grey, and      the highly enriched
             Benthic oxygen demand is expressed as milliliters             anoxic black, intermediately     enriched sediments
             of oxygen consumed per square meter per hour                  may show areas of orange or red. A common
             (mL 02 /m2 /hr).                                              indicator of enrichment is the filamentous,
                                                                           sulphide-reducing bacteria, Beggiatoa. Beggiatoa
             Another method for assessing the impact of                    is commonly found in dense whitish mats on
             organic deposition is the reduction oxidation                 surface sediments or decomposing plant material.
             (redox) potential. The redox potential measures               It grows in the presence of oxygen and 142S, and
             sediment oxygen content at different depths to                is thus found in the transition zone between oxic
             determine the depth of the boundary between                   and anoxic sediments (Jorgensen 1977).
             aerobic and anaerobic sediments. At this point
             (the redox potential discontinuity or RPD),
             oxygen consumption by the decomposing material


             Page 18                                                                                      Sediment and Benthos








            Changes in the Benthos due to Organic                         oxygen to penetrate the sediments. Thus, while
            Enrichment.     Pearson and Rosenberg (1978)                  the number of organisms increases dramatically,
            related   general     changes     in   the     benthic        the diversity of species declines (Figure 4).
            communities as the result of      increasing organic
            enrichment (Figure 4).       The figure does not              At higher rates of sedimentation, even the
            provide units of measure for the organic                      opportunists cannot survive. At this point, the
            enrichment because the level at which these                   anoxic layer reaches the sediment surface,
            changes occur is highly dependent upon the                    depriving the animals of oxygen and exposing
            nature of the benthic community affected. The                 them to toxic 1-12S.       In these sediments, the
            following discussion follows the progression of               surface is black and devoid of any animals
            changes as an observer proceeds from an affected              (azoic). Methane and toxic H2S are produced
            environment to the fish farm. It must be noted                and escape as bubbles into the water. Gowen et
            that transitions from one zone to another occur               al. (1988) estimated that input of organic matter
            along a continuum, generally with no clear                    at rates greater than about 8 g carbon/m2/day
            boundaries.     Depending upon the amount of                  resulted in the production of methane and azoic
            organic material deposited and the existing                   conditions.     At low concentrations, H      2S    can
            benthic community, the more affected zones may                reduce fish health through gill damage and at
            or may not be present under any specific pen.                 higher concentrations be toxic to fish in the farm
                                                                          above the sediments (Braaten et al. 1983). Such
            A stable, diverse benthic community comprised        of       effects have only been reported in stagnant areas
            filter-and   sediment-feeding      organisms       and        with little water circulation.
            predators exists in undisturbed sediments. Many
            of these animals are large and live in the                    Azoic zones (zones devoid of any animals) are
            sediment. As organic matter is introduced into                reported under most fish farms, except those in
            an undisturbed environment,         it provides an            areas of depth greater than about 60 ft and/or
            additional source of nutrition      for the benthic           high currents and the affected area is limited to
            organisms.      This additional     organic matter            that immediately below the farm (Weston 1986).
            benefits the existing filter- and deposit-feeders,            Earll et al. (1984) found dark, black sediments
            and encourages colonization by additional species.            under most fish farms observed. This zone was
            Thus, both species diversity and biomass (total               usually demarcated by a "halo" of dense Beggiatoa
            weight) of the benthic organisms increase, and                mats, which covered and stabilized the underlying
            the benthic community is enhanced. Pearson and                sediments. The absence of Beggiatoa under the
            Rosenberg (1978) refer to this as the "transition             farm was attributed to its need for both oxygen
            zone."                                                        from surface water and H2S from the anoxic
                                                                          sediments.    In areas of poor water circulation,
            Pearson and Rosenberg (1978) observed that as                 the water immediately above the substrate may
            the level of organic input increases, the normal              become anoxic, precluding Beggiatoa growth. No
            community changes as many species, especially                 live animals were observed in this zone, although
            filter feeders, are displaced.       The sediments            occasional dead starfish, nudibranchs, and sea
            become progressively dominated by various                     cucumbers were observed on the surface. Gas
            opportunistic deposit feeders, which flourish                 bubbles (methane) were evident in the sediment
            under these conditions. The most notable deposit              and redox potentials were severely depressed.
            feeder is the small, common polychaete worm                   Stewart (1984) observed these conditions to
            Capitella    capitata,    indicative    of     organic        extend to about 3 m (10 ft) from the farm
            enrichment.       Under these conditions,           the       perimeter.
            abundance of these opportunistic species can
            reach very high densities, to the exclusion of                ExamRles or Benthic IMRICts - Scotland. Earll
            other species. Elimination of the larger, deeper              et al. (1984) observed benthic conditions below 25
            borrowing animals further reduces the ability of              fish farms facilities in Scotland located in


            Sediment and Benthos                                                                                         Page 19

















                                               OPPORTUNISTIC
                       AZOIC                       SPECIES                                           TRANSITION                               REFERENCE
                     CONDITIONS                   DOMINATE                                              ZONE                                 CONDITIONS















                                                          de

                                                       4f





                                               J#


                                      41.0




                                                                             INCREASING ORGANIC INPUT







        Source: Pearson and Rosenberg 1978





        S Number of Species
                                                                                                                                                  Figure 4.
        B Biomass                                                                                                                                 Generalized Trends
        A Total Macrotaunal Abundance                                                                                                             in Organism Diversity








            relatively shallow water (mean depth 9.5 m). He                    benthic communities extended to within 150-450
            noted that the redox potentials were reduced                       m (492-1,475 ft) of the farm. This site is of one
            within a distance of 20-30 m (66-99 ft) from the                   of the world's largest fish pen facilities and has
            farm and that Beggiatoa first appeared 10-15 rn                    been in operation for 17 years.                    Other
            (33-49 ft) from the pen perimeter. Outside this                    observations at the same site (Pease 1986) noted
            zone, the sediment surface appeared normal and                     an increased abundance of geoducks in the area,
            was light brown with a thin covering of diatoms.                   and abundant congregations of anemones near the
            Predator     species     such    as    crab,      flatfish,        farm wherever objects provided solid substrate for
            nudibranchs, and anenomes were abundant.                           attachment.     They noted that in rocky areas
            Scallops, starfish, and sea cucumbers were also                    having stronger currents, this zone apparently
            observed.     Stewart (1984) noted that organic                    extended to the boundary of the farm. The only
            loading,    carbon:nitrogen      ratios,    and     redox          deposits of food occurred in the lee of protruding
            potentials were essentially normal beyond 40 rn                    rocks. Elsewhere, the rocks were almost totally
            (131 ft) of a pen site. He concluded that the                      covered with anenomes, and kelp was also
            transition zone extended 37-100 m (121-328 ft)                     abundant. Mobile predators are also abundant in
            from the farm.                                                     this area, including flat fish (Pease 1988) and
                                                                               crab (Cross 1988). Weston and Gowen (1988)
            High      species     abundance        and      diversity,         concluded     that    changes     in   the     biological
            representing both     pre-existing species and newly               community extended beyond the zone where
            colonized species,   were found in a zone 15-120 m                 chemical changes were            detectable.         This
            (49-393 ft) from     farm by Brown et al.          (1987).         observation     indicates     the    increased      biota
            Gowen et al. (1988) observed that total           organic          consumes the organic matter, not allowing it to
            carbon, redox potentials, and dissolved oxygen                     accumulate.
            levels were normal beyond 15 m (49 ft) of the
            farm. He also found that opportunistic             species         Gowen et al. (1988), and Brown et al. (1987)
            dominated the zone between 15 and 120             m (49-           observed that the area between 3 and 15 m (10-
            393 ft), with the inner boundary of the transition                 50 ft) was almost exclusively dominated by
            zone being 20-25 m (66-82 ft) from the farm                        opportunistic polychaete worms, especially C
            boundary.                                                          capitata.    The total number of species in this
                                                                               zone was about 20% of that in undisturbed
            Gowen et al. (1988) reported an azoic zone                         sediments. However, the number of individuals
            extending 3 rn (10 ft) from the farm. In this                      was 2 to 3 times normal with total biomass
            zone, total organic carbon levels are about twice                  slightly below normal. All of the organisms were
            background     levels and redox potentials were                    polychaete worms, with C capitata representing
            consistently less than -100 mV, despite seasonal                   80% of the total organisms. Gowen et al. (1988)
            variations.    Dissolved oxygen in the overlying                   observed that the total organic carbon was
            water was reduced and gas bubbles were                             slightly elevated while the redox potentials at 40
            observed.      Hall and Holby (1986) measured                      mm were near zero. Dissolved oxygen in the
            chemical changes below a small fish farm. Both                     overlying water was not affected.               Seasonal
            total organic carbon and nitrogen concentrations                   changes were observed, with increased effects
            were increased ten-fold above background levels,                   being noted during the summer.             The authors
            and benthic oxygen consumption was increased 12                    concluded these severely disturbed conditions
            to 15 times. Deposition under these farm was 50                    existed when the rate of organic loading exceeded
            to 200 g/m2/day total solids, about 20 times                       1.8 to 4 gC/m:2/day. It was estimated that the
            higher than background.                                            total area affected below this fish farm (540 m2-)
                                                                               was 6,000 m2. Similar observations from studies
            ExamRles of Benthig ImRacts - Washington. In                       of pulp mill and sewage treatment plant
            studies conducted at Clam Bay, Kitsap County,                      discharges reported an affected area of 5 to 23
            Weston and Gowen (1988) estimated that normal                      km:2.


            Sediment and Benthos                                                                                                Page 21








             Earll et al. (1984) observed that redox potentials              consumption (BOC) in Puget Sound.               Typical
             were depressed within 20-30 m (66-98 ft) of the                 BOC for Puget Sound sediments was 4 to 56 mL
             farm. Sediments were brown to grey without the                  02/m2/hr. Under one fish farm complex, BOC
             diatom covering noted outside this zone. The                    averaged 125 mL 02/m2/hr.              Pease (1984)
             inner boundary was frequently indicated by a mat                observed that the area under the farm was
             of Beggiatoa. The only large organisms observed                 completely covered by Beggiatoa            and food
             in this zone were occasional anemones and small                 particles, overlying a layer of black sediment 1 to
             crab and fish which foraged into the area. The                  2 inches deep. Under this layer, was a substrate
             presence of anemones was explained by their                     suitable for geoducks, which are abundant in the
             ability to extend above the sediments into                      area.    However, no geoducks were observed
             unaffected water. Stewart (1984) concluded that                 under the farm. The covering mat of Beggiatoa,
             this zone extended from 3-37 m from the farm.                   unlike the bare sediment reported by Earll et al.
             This relative smooth zone did not have mounds                   (1984), suggests that the current velocities over
             and burrows typical of animal activity in                       the sediments are strong enough to maintain
             undisturbed sediments (Institute of Aquaculture                 sufficient dissolved oxygen levels near the
             1986).                                                          sediment surface for bacterial growth.

             Weston and Gowen (1988) observed increased                      Weston and Gowen (1988) (see Appendix A)
             concentrations of carbon and nitrogen, and                      found the greatest benthic impacts in the
             reduced redox potentials between 15 and 60 m                    direction of the dominant current.           Sediment
             (50 and 200 ft) down current (east) from fish                   traps under the farm estimated deposition of 52.1
             farms at Clam Bay. These changes extended only                  kg dry wt./m2/yr and 29.7 kg dry wt./m2/yr at
             15 m (50 ft) to the south, and 30 m (100 ft) to                 the farm perimeter. This deposition equates to
             the northwest. Redox potentials in undisturbed                  36.4 and 9.9 kg carbon/m2/day, respectively.
             sediments were about 350 mV at the sediment-                    According to Gowen et al.               (1988), this
             water interface and 250 to 300 mV (millivolt) at                enrichment rate should result in methane gas and
             40 mm depth. Redox potentials remained positive                 H2S production that would affect oxygen levels in
             to within 30 m down current. Up current, these                  the water. However, Weston and Gowen (1988)
             potentials were positive to the pen perimeter.                  reported no measured effect on dissolved oxygen.

             The abundance    of organisms was approximately 4               The redox potential at the southeast corner was
             times greater     than' background at the farm                  strongly negative at 15 m (50 ft) downstream at
             perimeter and    declined to background levels at               both the sediment surface and at 40 mm. Under
             about 45 m,      with C capitata the dominant                   the pens, toward the upcurrent end of the farm,
             species. Biomass was reduced to about 45 m and                  redox potentials were still positive at the surface.
             increased moderately between 90 and 150 m.                      These potentials corresponded with the pattern of
             Normal conditions were reached between 150 and                  enrichment shown by carbon and nitrogen, with
             450 m from the farm. Pease (1984) reported that                 the greatest enrichment occurring at the eastern
             geoduck abundance increased in this area away                   end of the complex.
             from the farm. No geoducks were found in the
             area occupied byBeggiatoa. However, in a more                   Not all fish farms will have an associated azoic
             recently developed site in British Columbia,                    zone. Weston and Gowen (1988) also observed
             geoducks were observed within the more distant                  a small (20 metric tons [22 tons]) pen complex
             area occupied byBeggiatoa (Cross 1988).                         near Squaxin Island. This complex is located in
                                                                             only about 10 m (33 ft) of water, yet no
             An azoic zone has been observed beneath       the fish          significant chemical changes were observed.
             farm complex at Clam Bay (Weston and            Gowen           Increased numbers of opportunistic species were
             1988; Pease 1984).        Pamatmat et al.       (1973)          observed, indicating that biological changes were
             conducted an extensive study of benthic         oxygen          beginning. The impacts of the farm may have


             Page 22                                                                                        Sediment and Benthos








            been limited by their recent operation (18                      Weston (1986) reviewed several sediment models
            months) and/or the relatively high current                      and concluded that none were adequate to predict
            velocities over a relatively smooth bottom which                the fate of particles deposited from a fish farm.
            may    tend     to  disperse     deposited      matter.         As part of a multi-year study of fish farm impacts
            Maximum currents were 31 cm/sec and 23                          in Scotland, Gowen et al. (1988) presents a
            cm/sec measured at two nearby locations.                        conceptually simple model that divides a farm
            Currents greater than 24 cm/sec have been                       into 1-meter squares and calculates where
            observed to scour waste from fish tanks (Institute              particles of food and feces from each square will
            of Aquaculture 1988).                                           accumulate on the sea bed after several tidal
                                                                            cycles. Tests of the model at six relatively small
            Duration of Oreanic Enrichmgnt ImRacts. The                     (672-2460 m2) fish farms in Scotland showed
            effects of organic enrichment of the sediments                  good correlation between predicted and observed
            begins quickly after installation and operation of              redox potentials at all six farms.          Predictions
            the fish farm.       Weston and Gowen (1988)                    correlated with species diversity in 4 of 5 farms.
            observed only limited changes in the community                  Weston and Gowen (1988) also tested this model
            at the Squaxin Island site after 18 months of                   at two farm sites in Puget Sound -- a very large
            operation.       Recovery of affected benthic                   (14,560 m2) farm at Clam Bay, Kitsap County
            communities may take months or years.                           and a 1184 m    2  farm at Squaxin Island. Again,
            However, the benthic sediment chemistry appears                 predicted redox potentials correlated well with
            to recover to normal levels relatively rapidly. In              observed values at both farms. Measured carbon
            Puget Sound, Pamatmat et al. (1973) observed                    levels correlated well with predicted values at
            normal benthic oxygen consumption 2 months                      Clam Bay. Possible resuspension of sediments at
            after pen removal.       Dixon (1986) noted that                Squaxin Island, the short time of operation (18
            bottom sediments appeared normal at two pen                     months), and problems with the use of sediment
            sites in the Shetland Island, 12 months after                   traps may explain the lack of significant
            removal of the farm.       Biological recovery may              correlation at the Squaxin Island site, where the
            take longer depending on the successional                       model estimated a greater impact than was
            colonization of the area by different species and               observed.
            normal     recruitment      cycles    (Pearson      and
            Rosenberg 1978). Species abundance will recover                 In general, the model has proven a good
            more quickly than biomass due to the growth                     predictor of general sediment impacts at farm
            rates of the larger animals. Rosenberg (1976)                   sites, despite its inherent limitations.             The
            observed     that   the   recovery     of the       area        model's limitations include using only single
            surrounding a pulp mill discharged required three               settling velocities for excess feed and for feces,
            to eight years to recover.                                      not allowing for turbulence or changes in current
                                                                            velocity and direction at depth, and assuming a
            5.1.2.1          Modeling of Benthic                            level bottom below the farm. In addition, the
                             Impacts                                        model must rely on assumed data for feed
                                                                            wastage. However, the model's ability to evaluate
            General.       While the previous information                   the    effects   of    different    pen    sizes     and
            describes the types of impacts that have occurred               configurations in different siting conditions makes
            at various farm sites, they do not allow prediction             it valuable for predicting sediment impacts, for
            of sediment impacts at a specific site. Weston                  selecting suitable sites, and for optimizing the
            (1986) concluded that the primary factors                       deployment of farms (Gowen et al. 1988). See
            determining the probable pattern of sediment                    Appendices A and B for further discussions of
            enrichment were current velocity, water depth,                  this model and comparison with other models.
            and loading (pounds of fish).




            Sediment and Benthos                                                                                            Page 23








             Methods For Minimizing ImRact.                 Potential        areas have been identified by the environmental
             methods of minimizing impacts to benthic                        surveys included in the Intefim Guidelines
             communities      can    be    classified    as    either        discussed below under Section 5.1.2.2. Rotating
             technological or siting methods.                                farms between multiple sites would allow an area
                                                                             to recover, or the rotation could be timed to
             Technological methods that minimize impacts to                  move the farm before impacts could occur.
             the benthos below farms include vacuuming the                   Rotating farms would minimize potential impacts
             sediments under the farm, "diapers" under the                   to the benthos.        However, the possibility of
             pens, and blowers. Vacuuming under the pens on                  obtaining all the necessary local, state, and
             an annual basis, for example, could remove                      federal permits for numerous sites associated with
             wastes    that    accumulate     under     the     farm.        one farm is remote and this would not be a
             However, the vacuuming process would likely                     feasible alternative in most cases.
             remove more than just the farm waste, and would
             probably have an impact on the benthic                          Methods to minimize benthic impacts that involve
             community. A system of tarps under the farm to                  orientation and configuration of the pens tend to
             collect wastes could also be used to reduce the                 increase the possibility of increasing impacts in
             potential impact to benthic communities. This                   other areas such as navigation and aesthetics.
             technology is relatively unproven though some                   Although orienting the configuration of the farm
             sites in Europe have used it with mixed success                 so that its long axis is perpendicular to prevailing
             (Braaten et al. 1983).         There are problems               currents will reduce benthic impacts, it would
             associated with upland disposal of the farm waste               increase potential navigation conflicts.          Using
             from a collection system. The waste collected in                individual clusters of pens rather than a single
             a "diaper" system would have to be dewatered                    array, and using single-point moorage to allow a
             before disposing in a landfill, and the salt content            farm to swing over a larger area would reduce
             in the waste would have to be removed to avoid                  benthic impacts, but would increase the potential
             water quality problems at the landfill. A system                for aesthetic and navigation conflicts.
             of blowers beneath the farm could be used to
             increase dispersion of the waste. This technology               Other potential methods for reducing impacts to
             is also unproven, but could probably be used in                 the benthos are related to the operation of the
             areas with marginal circulation. If the blowers                 farm. The use of feeding methods that maximize
             failed, waste from the farm could have an impact                ingestion and the use of slow-settling, highly
             on benthic communities. Siting farms in areas of                digestible feed to maximize food conversion
             sufficient tidal currents would achieve the same                would reduce benthic impacts. These practices
             effect as blowers.                                              are in the best financial interest of the farmer
                                                                             and would be expected to be incorporated into
             Siting methods to   reduce potential impacts to the             standard operating procedures at each farm. One
             benthos below farms include selecting areas of                  last potential method for reducing benthic
             deep water and/or high currents, siting farms in                impacts would be to spread out the concentration
             areas with low biological productivity, avoiding                of waste deposition from a farm over a wider
             sites above important biological communities,                   area by establishing a maximum density of fish in
             rotating farms between different sites, and                     the pens. For example, instead of a farm raising
             different orientations and configurations of the                1,000,000 lbs a year under the current two-acre
             farm.     Using models to select areas with                     maximum size guideline, the same level of
             sufficient depth and currents to avoid impacts to               production could be achieved in a three-acre
             the benthos is feasible, and the models are                     farm. However, this measure would increase the
             currently available.        Avoiding sites above                potential for navigation and aesthetic conflicts.
             important biological communities and siting farms
             in areas of low biological productivity would
             avoid significant impacts to the benthos. These


             Page 24                                                                                         Sediment and Benthos









           5.1.2.2           No-Action Alternative -                                0    WDF has the authority to "preserve,
                             Existing Regulations and                                    protect, perpetuate, and manage..." food
                             Guidelines                                                  fish and shellfish resources in Washington
                                                                                         (RCW 75.08). WDF requires a Hydraulic
           The following existing regulations and guidelines                             Project Approval (HPA) permit for
           affect the potential impacts of fish farms on                                 virtually all work within the ordinary high
           benthos:                                                                      water    mark      of    marine      waters     in
                                                                                         Washington (RCW 75.20 and WAC 220-
                     Ecology is presently developing sediment                            110). The HPA process provides WDF
                     quality standards for adoption by June                              with permitting authority to ensure that
                     1990.    These standards will specify the                           food fish and shellfish habitats are
                     degree of effects allowed in sediments                              protected from any significant adverse
                     throughout      Puget      Sound,       including                   impacts.
                     sediments occurring below fish farms.
                     The goal of these standards is to ensure                            The SEPA review process provides WDF
                     that "no acute or chronic adverse affects                           with the opportunity to evaluate individual
                     on biological resources and no significant                          fish farm proposals on a case-by-case
                     human health risk" occur as a result of                             basis. This mechanism allows WDF to
                     any outside interference (Ecology 1989).                            evaluate each farm proposal for its
                                                                                         potential impact to the benthos with the
                     The    standards     will    include    a rule                      most current, available information.
                     addressing       sediment        contamination
                     cleanup.     If an abandoned or "out-of-                            The Interim Guidelines (SAIC 1986)
                     operation" fish farm is responsible for                             present minimum depth and current
                     unacceptable historic contamination of the                          recommendations for siting fish farms of
                     sediments, Ecology may determine the                                various     sizes,    based      on     reported
                     need for sediment cleanup.              Sediment                    observations of sediment accumulations
                     cleanup action or the designation of a                              reported in Weston (1986).                 These
                     "sediment recovery zone" may be required                            recommendations provide a "best guess" of
                     (Ecology 1989). These standards will be                             the conditions under which sediment
                     implemented through the NPDES permit                                dispersal by currents would prevent any
                     for fish farms.                                                     significant    accumulations       of     organic
                                                                                         material below the farm. In general, the
                     The Interim Sediment Quality Evaluation                             Guidelines      recommend         that     large,
                     Process is a set of Ecology guidelines                              commercial fish farms be located in areas
                     containing chemical and biological criteria,                        with a minimum average current of 5
                     as well as instructions to other Ecology                            cm/sec (0.1 knot), and at least            60 ft
                     programs regarding the use of the interim                           between the bottom of the farm and the
                     criteria.   Developed as outlined in the                            sea bed.
                     Puget Sound Water Quality Management
                     Plan, the interim criteria will be subject                          The Interim Guidelines recommend a
                     to      "best    professional        judgement"                     bathymetric survey be performed as part
                     requirements associated with nonadopted                             of an overall site characterization survey
                     guidelines.          These       criteria      are                  in order to apply the guidelines pertaining
                     implemented through NPDES permits for                               to depth and current, and to identify the
                     fish farms. These interim criteria will be                          presence of any bathymetric feature which
                     replaced by the sediment quality standards                          might affect bottom accumulation of
                     discussed above in June 1990.                                       excess feed and feces. The area covered
                                                                                         by this survey is the seabed directly


           Sediment and Benthos                                                                                                   Page 25









                     beneath the farm site and within 300 ft of            With the State sediment quality standards,
                     the farm perimeter. This survey provides              Ecology's implementation of the NPDES permit
                     initial environmental information before              system will provide adequate regulatory control to
                     permitting the farm.                                  avoid significant impacts to the benthos.

                  ï¿½  The Guidelines recommend a diver survey               It is recommended that data collected by DNR
                     be included in the site characterization              from annual monitoring reports from farms be
                     study.      This survey would identify                reviewed    annually by the Ecology, WDF, and
                     important biological communities to be                DNR to      determine if the depth and current
                     avoided.                                              guidelines should be revised.

                  ï¿½  The Guidelines also recommend a baseline              5.1.3       Mitigation Measures and
                     survey for farms with annual production                           Unavoidable Significant
                     amounts greater than 100,000 lbs per year.                        Adverse Impacts
                     This survey takes place after the farm is
                     sited, but before fish are placed in the              In addition to implementing the NPDES permit
                     pens. This survey should include sediment             system, adopting the site surveys and monitoring
                     chemistry and benthic infauna sampling,               requirements in theInterim Guidelines, the State
                     and could include a diver survey as well.             sediment quality standards, and the annual review
                     This    information "characterizes"        the        of farm monitoring data by DNR, WDF, and
                     seabed before fish are placed in the pens.            Ecology into WACs will avoid, significant adverse
                                                                           impacts to the benthos.         The SEPA review
                  ï¿½  In addition to the surveys discussed above,           process and the HPA permit will allow proposals
                     the Guidelines also recommend annual                  to be reviewed on a case-by-case basis and no
                     monitoring of potential changes in the                additional programmatic mitigation measures are
                     sediments below farm sites. This annual               necessary.
                     monitoring would assess the extent of
                     solids accumulation on the bottom near                5.2         WATER QUALITY
                     the farm and the biological effect of this
                     accumulation.                                         Fish farming depends on high water quality but
                                                                           has the capacity to adversely influence water
                  ï¿½  Reports produced under the Guidelines                 quality. The successful culture of fish requires
                     are submitted to DNR for distribution                 clean, oxygen-rich water. On the other hand, the
                     and review to other appropriate state                 intensive   culture   of fish     introduces    large
                     agencies.                                             quantities of nutrients that can alter existing
                                                                           water qpality conditions.      The effect of this
             5.1.2.3         Preferred Alternative                         nutrient introduction, and the measure of its
                                                                           significance, is the biological response of plankton
             The site surveys and annual monitoring         in the         and eventually fish and shellfish to these changes.
             Interim Guidelines provide an adequate framework
             for determining potential impacts to the benthos.             5.2.1       Affected Environment
             The Guidelines take a conservative approach to
             preventing benthic impacts. Given the existing                Puget Sound Water Circulation. To understand
             data, the present depth and current guidelines                the potential water quality impacts of floating fish
             should continue to be used. It is recommended                 farms in Puget Sound, it is desirable to
             that the surveys and annual monitoring identified             understand the basic water circulation patterns of
             in the Interim Guidelines be adopted into WACs.               Puget Sound.




             Page 26                                                                                     Sediment and Benthos









          For this EIS, Puget Sound includes all marine                 Nisqually, Deschutes, and Skokomish Rivers
          waters of Washington State inland from and                    (Strickland 1983; Duxbury 1988).
          including the Strait of Juan de Fuca.            Puget
          Sound is a large sunken valley connected to the               Freshwater is less dense than saltwater and floats
          Pacific Ocean by the Strait of Juan de Fuca. It               on the surface. Tidal currents gradually,mix the
          consists of several interconnecting fjord-like                freshwater with saline oceanic water to create a
          basins often separated by relatively shallow sills            brackish surface layer extending down 10-50 m
          that transverse the entrances to these basins (see            (32-160 ft). The brackish layer flows by gravity
          Figure 5).     The main basin of Puget Sound,                 towards the ocean with assistance from winds
          inland from Admiralty Inlet, has an average depth             from southerly storms.         The saltwater layer
          of 64.1 m and a maximum depth between Point                   beneath flows inward from the Pacific to replace
          Jefferson and northwest Seattle of 283 m. The                 the saltwater lost by mixing with the upper
          main basin alone covers an area of 2,630 km2                  brackish layer that flows seaward. This seaward
          (768 square nautical miles) at high tide with a               movement at the top and landward at the bottom
          volume of about 169 km3 (26.5 cubic nautical                  exists throughout the Sound and is typical of
          miles).                                                       fjords with river-dominated circulation. As a
                                                                        result of this seaward movement, surface current
          Puget Sound is strongly affected by the force of              velocities are generally stronger on ebb tides than
          tides,  which provide most of the energy for                  on flood tides, which tends to carry dissolved
          movement of water in the Sound.                  Tidal        materials out of the Sound and to the ocean
          exchanges, from low to high tide, can be as great             (Figure 8).
          as 5 m (16 ft) resulting in an average of        about
          3.25 km.3 of water moving in and out with each                In addition to tidal driven water exchanges,
          of the twice-daily tidal changes. This daily tidal            meteorological     conditions    can cause       large
          displacement represents over 9 billion tons of                intrusions of saline, coastal water. According to
          water (Metro 1988). The movement of this water                Cannon (1983), "in the Strait of Juan de Fuca,
          also produces strong currents in many channels                the waterway connecting the Sound with the
          which commonly exceed 3 knots (1.5 m/sec) and                 Pacific Ocean, winter storms with predominantly
          may exceed 6 knots (6 m/sec) in narrow channels               southerly winds along the coast are capable of
          such as Deception Pass and the Tacoma Narrows.                significantly reversing the normal estuarine flow
          Figures 6 and 7 show generalized surface water                and causing large intrusions of coastal water
          movement at flood and ebb tides.                              lasting several days." This phenomenon can also
                                                                        occur during the summer when low-pressure
          As is typical of estuaries, Puget Sound is                    systems may persist off the coast long enough to
          dominated by a two-layer flow of water with a                 change the circulation pattern in the Strait
          mid-depth oceanic inflow and a less saline surface            (Cannon 1983).
          water outflow resulting in a continual, slow
          replacement of these waters.          The inflowing           Another important feature of Puget Sound is the
          oceanic    waters    are    characterized . by     low        presence of major sills such as those at the
          temperature, high salinity, and low dissolved                 entrance of Admiralty Inlet and at the Tacoma
          oxygen.                                                       Narrows. These shallow areas cause turbulent
                                                                        mixing of deep and surface waters as tidal action
          Freshwater inflow drives the flow of water out of             forces the water back and forth over the sills.
          Puget Sound.       Freshwater is supplied to the              South of Admiralty Inlet, this mixing tends to
          Sound by surface runoff, with two-thirds coming               restrict the flushing of surface waters by forcing
          from the Skagit, Stillaguamish, and Snohomish                 the seaward-moving surface water to partially mix
          Rivers. Smaller amounts are contributed by Lake               with deeper water and to partially recirculate.
          Washington and         the Duwamish,         Puyallup,        Surface waters of the main basin (Admiralty Inlet



          Water Quality                                                                                               Page 27







                                                                                 CANADA
                                                                     - - - - - - - - - - - - ---
                                                                               UNITED STATES










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                                                                                   NISOUA Ly,              1-5

                                                                                                          UALLY
                                                                                                      NISO
        Source: Strickland 1983                                                                       RIVER
                                                                                DESCHU       OLYMPIA
        Note: Depth in meters.                                                       RI






        SCALE IN MILES                                             Main Basin of
        F-I--F----]                                                Puget Sound                           Figure 5.
        0         10        20                          .... .... Sills                                  Major Sills in Puget Sound













                                                                                                                 CANADA
                                                                                                   - - - - - - - - - - - -
                                                                                                              UNMED STAMS






                                            VANCOUVER                                                                                              BE LINGHAM                                                          VANCOUVER
                                               IZSLANIJ                                                                                                                                                                   ISLAND







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                                                                                          P                                                                                                                                                                           PORT
                                                                                        ANGELES                                                                                                                                                                     ANGELES


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                                                                                                                                                  1-5

          Source: Puget Sound Water Quality                                                                                    OLYMPIA                                               Source: Puget Sound Water Quality
                   Aullvnty 1986
                                                                                                                                                                                              Auffionly 1986
          4@                                                                 Current Movernent             Figure 6.                                                                 4@
          SCALE IN MILES                                                                                   Generalized Surface Water                                                 SCALE IN MILES
                                                                              EdIdy                                                                                                  F-L-F--]                                                  ---110- Current Movement
                      lo           2o                                         SLack                        Movement at Flood Tide                                                    o            Io           20                                         Eddy
                                                                                                           in Puget Sound
















               NORTH

                 0-



                                                         ....... ..........
                                                                  ...........
                                                                 ...........
                                                                .............
                                                                  ..........



               200-





         LU
         U-

               400-



         w
                                                                              .......................




               600-








               800-








                                                                                                                     N



      Source: Water Quality Status Report
            for Marine Waters 1987




                          Natural Sediment Deposition
                                                                                                            Figure 8.
                                                                                                             Simplifie
                                                                                                            and Sedi









           to the Tacoma Narrows) take about a week to                     is a deep stratification that limits the intensity of
           travel from Elliott Bay to the sill at Admiralty                algal production by mixing phytoplankton to
           Inlet. After mixing, a portion of this water will               depths where the light levels are too low to
           travel back to Elliott Bay in about 10 days. On                 sustain photosynthesis.      However, this constant
           average, the seaward-moving water must go                       mixing also maintains high levels of nutrients,
           through this cycle twice before clearing the sill               which produce phytoplankton, and result in a high
           and reaching the Strait of Juan de Fuca (PSWQA                  rate of annual primary production.
           1986). This finding agrees with a 50% average
           recycling of surface water at the Admiralty Inlet               In terminal areas of some bays, such as Budd
           sill (Duxbury 1989 personal communication).                     Inlet, the lack of flushing combined with shallow
                                                                           waters and summertime stratification, provide
           The course of 400 computer modeled parcels of                   stable conditions for phytoplankton growth.
           water instantaneously released into the Sound and               Phytoplankton populations are maintained in the
           carried by currents is shown in Figure 9.                       surface    layer    until   the    nutrients     become
           Approximately half of the parcels are left in the               exhausted. In extreme cases, death of these cells
           south after three months. Six months after the                  may consume the available oxygen, contributing to
           water parcels are released, 25% remain. After a                 fish kills typical at the head of Budd Inlet.
           year, 5% of the parcels are still in the south.
           These numbers indicate how portions of the                      Hood Canal is adjacent to, but separate from, the
           parcels are recycled at the sill (PSWQA 1986).                  main basin of Puget Sound with a 51 m (167 ft)
                                                                           deep sill near its entrance. The Canal extends
           Another effect of this mixing results in a                      about 80 km (50 miles) to the south.               Hood
           continual replenishment of nutrients into the                   Canal has received relatively little study compared
           surface waters (this mixing is also demonstrated                to some of the other areas of Puget Sound, but
           by Puget Sound's typically cold surface water                   the water in the central and southern Canal
           temperatures). During summer, many fjords are                   appears to be slowly flushed (Cannon 1983).
           characterized by strongly stratified layers with                Despite the presence of a sill near the entrance,
           little exchange between deep and surface waters.                relatively little turbulent mixing occurs and the
           Surface layers are typically low in nutrients and               central and southern Canal has typical fjord
           salinity, overlying nutrient-rich, oceanic waters.              characteristics - nutrient    poor    surface     waters
           Consequently, the productivity of these fjords is               overlying nutrient-rich waters.           Consequently,
           often limited. Locally, this situation is typified by           primary     production      is   relatively   low,     as
           central and south Hood Canal. By comparison,                    demonstrated by the growth rates of oysters that
           surface waters in the main basin of Puget Sound                 feed on this phytoplankton.          In Hood Canal,
           are rich in nutrients and relatively saline. These              oysters typically attain harvest size in about five
           conditions support abundant and sustained                       years, while in south Puget Sound only about
           phytoplankton growth (the basis of the aquatic                  three years is required.
           food chain) and also support a great variety of
           both     oceanic     and      estuarine      organisms.         Water Quality Monitoring in Puget Sound.
           Consequently, Puget Sound is considered one of                  Ecology water quality monitoring stations in
           the richest, most productive estuaries in the                   Puget Sound are presented in Figure 10. This
           world.                                                          figure identifies monitoring stations that have
                                                                           fallen below State standards in the last five years.
           Differences in the    degree of mixing in different             Whether a station meets the dissolved oxygen
           basins play a major role in the biological nature               standard is based on the 1988 Water Quality
           of individual bays and inlets. For example, the                 Index calculated by Ecology from data collected
           main Puget Sound basin is characterized by a                    at the surface and depths of 10 and 30 m (30-
           high rate of tidal flushing and turbulent mixing                40 ft) during the summer months of the last five
           from tide and wind-induced currents. The result


           Water Quality                                                                                                   Page 31















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                                                                                                                     A
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                                                        1AUOMA                                                              TACOMA.
              Instantaneous Release                                               After 3 Months                              13
              In East Passage of                                                  193 of 400 in                              6
                                               OLYMPIA                                                             OLYMPII
              400 Particles                                                       Puget Sound








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                                                       TACOM/'                                                             TACOMA
                                                          2
              After 6 Months                                                      After 12 Months
                                                                                                                           2
              105 of 400 in                    OLYMPIA                            24 of 400 in                    -OLYMPIA
              Puget Sound                                                         Puget Sound
                                                                                              @
                                                                                                  T
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                                                   . 4-B












            Source: Puget Sound Water Quality
                   Authority 1986

                                                                                                      Figure 9.
                                                                                                      Theoretical Dispersion of
                                                                                                      Water Parcels in Puget Sound








                                                                                                        CANADA
                                                                                          - - - - - - - - - - -
                                                                                                     UNITED STATES










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                                                                                                                                       1-5


       Source: Ecology 1988b                                                                      BUDDINL.ET          OLYMPIA

                                                                                                                       Figure 10.
                                                              Meets Claw AA                                            Washington Department
                                                              Does Not Meet Class AA (7 mg/1)                          of Ecology Water Quality
      SCALE IN MILES                                                                                                   Monitoring Stations and
                                                          A Does Not Meet Class A (6 mg/1)                             Their Relation to Dissolved
      0           10           20                         + Does Not Meet Class B (5 mg/Q                              Oxygen Standards








             years (Ecology 1988b).        This five-year average            problem in certain portions of Puget Sound
             masks unusually low or high values in the data                  (Ecology 1988a).
             set. In other words, stations that do not meet
             State standards on rare occasions are not                       Exacerbation of organic enrichment and dissolved
             identified as such in Figure 10.                                oxygen problems are a potential water quality
                                                                             concern for the operation of fish farms. These
             Twenty-five of the 46 monitoring stations do not                problems     are interrelated in that           organic
             always meet the Class AA standard for dissolved                 enrichment fuels bacterial decomposition and
             oxygen (see Figure 10).            This means that              results in oxygen depletion.          This depletion
             dissolved concentrations less than 7.0 mg/L have                occurs primarily by microbes in the water and
             been observed at over half of the monitoring                    sediment consuming oxygen as they decompose
             stations on several occasions in the past five                  organic matter. In addition, inorganic nutrients
             years. Only 10 of these stations do not meet the                (nitrogen, phosphate) are a cause of organic
             standard for their class of waters. Four stations               enrichment because they are converted to organic
             do not meet the Class A standard of 6.0 mg/L.                   matter by algae and bacteria that consume them.
             They are Holmes Harbor at Honeymoon Bay,                        It is the rapid consumption of nutrients by
             Hood Canal at Pulali Point, Hood Canal at                       phytoplankton      that     results    in     excessive
             Eldon, and inner Budd Inlet. One station, Hood                  phytoplankton growth (blooms) in shallow or
             Canal at Sisters Point, does not meet the Class B               stratified embayments.
             standard of 5 mg/L.
                                                                             Phytoplankton blooms may increase dissolved
             In summary, dissolved oxygen problems in Puget                  oxygen through photosynthesis during the day,
             Sound     most    commonly       occur    in     certain        and decrease oxygen levels by respiration during
             embayments that have poor circulation, such as                  the night.    Oxygen levels may decrease in the
             southern Hood Canal, Budd Inlet, and Holmes                     surface waters when the surface waters mix with
             Harbor. These problems typically occur during                   oxygen- deficient bottom waters. This may occur
             periods of low tidal exchange in late summer and                in the summer and autumn from the upwelling of
             autumn, and are related to phytoplankton blooms.                very deep water during incoming tides. It also
                                                                             occurs in stratified embayments that are vertically
             5.2.2       Impacts on Water Quality                            mixed in the autumn by winds and tides (Collias
                                                                             et al. 1974).
             General.    The primary causes of water quality
             impairment in the State's estuaries are bacteria,               A decrease in dissolved oxygen becomes a
             organic enrichment, and low dissolved oxygen.                   problem when marine organisms are subjected to
             The primary sources of bacteria problems are                    stress. The degree of stress depends on both the
             from agricultural runoff, failed onsite wastewater              level of oxygen and the length of time an
             disposal    systems    (septic    tanks),    municipal          organism is exposed to low oxygen levels. It is
             wastewater     (sewage)    treatment     plants,    and         also dependent on many other physical, chemical,
             stormwater.      Other sources of water quality                 and biological conditions, such as temperature,
             impairment   include erosion from forest practices              toxicity, and food availability.
             and streambank alteration and loss of water
             quality   functions    due    to   degradation      and         The following is a discussion of the potential
             destruction of wetlands. Natural factors such as                impact that a fish farm may have on several
             phytoplankton blooms and the upwelling of                       water quality variables:
             bottom waters are the primary source of organic
             enrichment and dissolved oxygen problems in                     Turbidity. Turbidity is a variable that indicates
             Puget Sound. Toxic metals and organic chemicals                 the clarity of water.        During net cleaning,
             from urban and industrial sources are a serious                 turbidity could significantly increase downcurrent
                                                                             of farms. The degree of turbidity increase would


             Page 34                                                                                                 Water Quality









            depend on the amount of material washed off the                 all sites on all other occasions.           Some pH
            nets, which in turn would depend on the                         changes may also have been due to tannic acids
            accumulation rate of material on the nets and on                and other acidic products of wood decomposition
            how often the nets were cleaned.              Cleaning          in the log rafting area. Pease reported that tidal
            severely fouled nets could possibly increase                    factors were the primary factor regulating pH at
            turbidity by more than 5 NTU (nephelometric                     all sites. His observation of the daily variation of
            turbidity units) over background and violate the                pH showed that it was between 0.1 and 0.2 units
            State standard in the immediate vicinity of the                 higher at high tide than low tide.
            farm. The loss of fish food and feces from farms
            would also increase turbidity, but to a much                    Temperature. The operation of fish farms would
            lesser degree than net cleaning.        It is unlikely          not affect water temperatures in Puget Sound.
            that food and wastes will increase turbidity                    Fish farms have no features that would
            sufficiently to cause a turbidity exceeding water               measurably change heat loss or heat gain by
            quality criteria.   Higher turbidity levels during              Puget Sound.
            net cleaning activities would not adversely'impact
            aquatic organisms, but would reduce the clarity of              Fecal Coliforms.       Fecal coliform bacteria are
            the water.                                                      produced in the intestines of warm-blooded
                                                                            animals and are a relative measure of sanitary
            A study in Clam Bay, Washington, reported that                  quality (APRA 1985). Fish farms do not directly
            floating fish farms did not affect turbidity (NMFS              affect    ambient      (existing)    fecal     coliform
            1983). Although turbidity ranged from 0.5 to 2.0                concentrations in Puget Sound because fecal
            NTU throughout the study, measurements were                     coliforms are not produced in fish.           However,
            not taken during net cleaning (Damkaer 1988).                   fecal coliform levels could indirectly increase near
                                                                            farms from increased marine bird and mammal
            pH. pH is a water quality variable that indicates               activity (See Section 5.9, Marine Mammals and
            how acidic or basic the water is. The range of                  Birds). Or fecal coliform levels could possibly
            possible values is 1 to 14 with lower numbers                   increase from the failure of a facility's sanitary
            being categorized as acidic.         Fish excrement             holding tank.
            includes the passage of carbon dioxide and
            ammonia through the gills, as well as feces and                 Nutrients.     Nutrients are primary substances
            a very small amount of urine (Lagler et al. 1962).              organisms require for growth.           Some of the
            Since carbon dioxide is a weak acid and ammonia                 essential nutrients include nitrogen, phosphorus,
            is a weak base, the net pH effect of fish                       hydrogen, and carbon. The operation of farms
            excrement through the gills is neutralized. The                 releases nutrients into the water from fish feces
            pH of feces is buffered by pancreatic secretions                and from uneaten feed. The primary nutrients of
            (Lagler et al. 1962). Because of tidal dilution                 interest in relation to fish farms are nitrogen and
            and the relatively high buffering capacity of Puget             phosphorus. Both may cause excess growth of
            Sound waters, fish excrement would not result in                phytoplankton and lead to both aesthetic and
            a measurable change in pH down current of                       water quality problems.        Generally in marine
            farms.                                                          waters, phytoplankton growth is either light or
                                                                            nitrogen limited, and phosphorus is not as critical
            Pease   (1977) reported that a fish farm in a                   a nutrient as it is in fresh water (Ryther and
            poorly  flushed, log rafting area (Henderson Inlet,             Dunstan 1971; Welch 1980).
            Washington) did not affect pH. He made five
            monthly observations (May through September) of                 Nitrogen may be categorized as: (1) inorganic
            pH at three sites near farms and at a control                   (nitrate, nitrite and ammonia and nitrogen gas);
            site. On one occasion the pH was between 0.15                   and (2) organic (urea and cellular tissue). Most
            to 0.3 units less at the three farm sites than at               of the waste food and feces from fish farms is
            the control site. The pH was within 0.15 units at               composed of organic carbon and nitrogen (Liao


            Water Quality                                                                                                   Page 35








              and Mayo 1974, Clark et al. 1985). About 22%                    through fish hatcheries. It is a condition that
              of the consumed nitrogen is retained within the                 requires treatment in reuse water systems
              fish tissue and the remainder (78%) is lost as                  (Burrows and Combs 1968; Liao and Mayo 1974).
              excretory and fecal matter (Gowen and Bradbury                  Salmon and many.freshwater fish are considered
              1987).    Approximately 87% of the metabolic                    more sensitive to the effects of ammonia toxicity
              waste nitrogen is in the dissolved form of                      than most invertebrates, including bivalves such
              ammonia and urea; the remainder (13%) is lost                   as clams and oysters (EPA 1986).               Although
              with the feces (Hochachaka 1969).                               exposure to low concentrations of ammonia may
                                                                              occur in freshwater facilities and not produce
              Salmon will produce approximately 0.22 to 0.28                  lethal effects, if sufficiently high, it causes chronic
              grams of all forms of dissolved nitrogen per day                adverse effects including reduced stamina, growth,
              per kilogram of fish produced annually (Ackefors                and disease resistance (Burrows 1972).
              and Sodergren 1985; Penczak et al. 1982; Warren-
              Hansen 1982, as cited in SAIC 1986, or that cited               At pH 7 and below, ammonia is never a limiting
              by Weston 1986).         Ammonia and urea are                   factor in freshwater salmon production. Near a
              essentially interchangeable       as    phytoplankton           pH of     8, loading limitations (limitation of
              nutrients.    Immediately downstream of most                    nitrogen   output from fish farms) are necessary
              farms (6-30 m [19-90 ft]) the concentration of                  when the density of fish is great (above 8 lbs per
              ammonia diminishes greatly. This decrease is                    gallon per minute). The pH of Puget Sound
              probably due to the natural microbial process of                waters is generally about 8 (on a scale of I =
              nitrification (oxidation of ammonia to nitrites and             very acidic to 14 = very basic) and varies little
              nitrates).    Rapid rates of nitrification are                  due to the natural carbonate buffering system of
              expected     in   any     well-oxygenated       aquatic         seawater (Stumm and Morgan 1981). Saltwater
              environment (Harris 1986).                                      rearing of salmonids is affected by many of the
                                                                              same biological restraints common to freshwater
              The 'effects of nutrients will not be discussed                 hatchery culture, except relatively greater volumes
              here, but will    - be covered in Section 5.3,                  of water per unit of fish production typically pass
              Phytoplankton.                                                  through farms.       This results in much greater
                                                                              dilution of waste products such as ammonia in
              Toxicity.     Toxic chemicals would not be                      farms when compared to freshwater hatcheries or
              introduced into the fish farm from fish food.                   municipal sewage discharges (Weston 1986).
              The potential impact of toxicants leaching from
              treated nets and of antibiotics is discussed in                 Recent nearfield studies in Washington (Milner-
              Section 5.4, Chemicals.                                         Rensel 1986; Rensel 1988b,c) have shown
                                                                              increased concentrations of ammonia immediately
              Ammonia in the un-ionized form (NH3) is toxic                   downstream or within the farms. Total ammonia
              to fish at high concentrations depending on water               values typically have   'increased from 3 to 55%
              temperature and pH (Trussel 1972; EPA 1986).                    above the low background levels. The highest
              High ammonia levels in fish excrement have                      observed concentrations were only a small
              raised ambient (existing) ammonia concentra-                    fraction of the maximum four-day, chronic
              tions. Normal concentrations of ionized and un-                 exposure level recommended by EPA (1986).
              ionized ammonia in Puget Sound are very low,                    These studies have shown variable amounts of
              with some variability. A small percentage of the                dissolved nitrogen produced from salmon farms
              ammonia originating from farms in Puget Sound,                  (ammonia plus nitrate and nitrite) not explained
              typically about 2%, will be toxic and un-ionized.               by variations in water velocity.             Additional
                                                                              studies, at larger facilities, are presently being
              Excess ammonia, which is undesirable for                        completed and may allow more accurate
              sensitive coldwater species such as salmonids, has              estimation    of rates      of dissolved       nitrogen
              not been an acute problem for typical flow                      production indexed to 'the size of the facility,


              Page 36                                                                                                  Water Quality









          biomass of the fish, and rate of water flow                In generali the dissolved oxygen requirements of
          through the farm.                                          salmon raised in farms limit the impact fish
                                                                     farms can have on the environment.            Water
          A long-term study, under worst-case conditions in          quality criteria for oxygen are based in large part
          southern Puget Sound, found that the greatest              on the oxygen requirements of rearing salmon.
          concentration of total ammonia observed at any             The lowest oxygen levels caused by fish farms are
          time was 0.176 mg/L, equivalent to 0.006 mg/L              likely to occur within the farm and immediately
          un-ionized ammonia, well below chronic exposure            downcurrent. Thus, the impact of low dissolved
          threshold (Pease 1977).                                    oxygen is likely to affect the farm before having
                                                                     an effect on the surrounding environment.
          In summary, increases in dissolved nitrogen
          (including ammonia) are typically seen within              The impact of fish farms on dissolved oxygen
          salmon farms. Immediately downstream, nitrogen             have been estimated by mathematical modeling
          or ammonia levels may also be elevated compared            and field measurements at existing sites. Model
          to ambient, upstream values. However, results              predictions indicate a decrease in dissolved
          are variable. In some cases, concentrations were           oxygen concentration of less than 0.3 mg/L
          greater or much less than expected compared to             (Weston 1986). Field studies of dissolved oxygen
          predicted values based on freshwater hatchery              concentrations near several farm sites have shown
          data. However, even within the fish farm, un-              a decrease in dissolved oxygen ranging from near
          ionized ammonia levels remain well below toxic             0 to 1.5 mg/L. These farm sites were located in
          concentrations.                                            Port Angeles Harbor (Milner-Rensel 1986; Rensel
                                                                     1988), Deepwater Bay off Cypress Island (Rensel
          Dissolved Oxygen. Dissolved oxygen consumption             1988), Clam Bay   (NMFS 1983; Damkaer 1988, see
          by fish, and by microbial decomposition of fish            Appendix A), in Henderson Inlet (Pease 1977),
          wastes and excess food, could significantly reduce         Squaxin Island (Fraser and Milner 1974; see
          dissolved oxygen concentrations near the farm.             Appendix A), and in Sechelt Inlet, British
          Depending on feeding rates, the oxygen consumed            Columbia (Black and Carswell 1986). Generally,
          by microbial decomposition may equal or exceed             the decrease was less than 0.35 mg/L and did not
          that of fish (Institute of Aquaculture 1988).              exceed State water quality standards. Instances
          Most of the microbial decomposition is associated          in which the State standards were exceeded
          with solids that settle to the bottom (Institute of        occurred in areas of poor circulation and
          Aquaculture 1988). Thus, th    'e greatest potential       naturally occurring low oxygen levels during
          for oxygen consumption would be from fish                  August and September.
          respiration near the surface and microbial
          decomposition near the bottom.                             Cumulative ImRacts of Multiple Farms.           The
                                                                     presence of more than one fish farm in an
          The total effect of oxygen consumption from farm           embayment may cause a greater reduction of
          operations on dissolved oxygen concentrations              dissolved oxygen if the area of decreased oxygen
          near the farm is highly variable.      The loss of         from one farm overlaps the area of decreased
          dissolved oxygen depends on the water exchange             oxygen from another farm. In this case, both
          rate near the farm, fish density, and fish feeding         farms may be capable of operating without a
          rate. If the water exchange rate near the farm is          significant reduction in dissolved oxygen, but the
          high, there will be less reduction of dissolved            proximity of one farm to another could result in
          oxygen. If the fish density and fish feeding rate          localized dissolved oxygen reductions in violation
          are high, there will be decreased dissolved                of State standards.
          oxygen.






          Water Quality                                                                                          Page 37









              Field measurements around individual farms                               non-commercial facilities, the NPDES
              indicate that the region of dissolved oxygen                             permit will be discretionary. However, all
              impairment around a farm is less than 50 in (165                         fish farms must meet the substantive
              ft).   Consequently, the potential of one farm                           requirements of the policy, regardless of
              affecting the dissolved oxygen near a second farm                        procedural requirements.
              is highly unlikely if the farms are placed even
              100 in (330 ft) apart. It is highly improbable                           The NPDES permit application will
              that sediment impact requirements and aesthetic                          provide the specific information needed to
              considerations would allow siting farms closer                           make permitting decisions on fish farms.
              than a few hundred meters apart. As previously                           Proposed guidelines include both siting
              discussed, a single farm rarely reduces dissolved                        and monitoring requirements.              Siting
              oxygen concentrations to the point of violating                          requirements will include compliance with
              State standards. Consequently, the potential for                         existing and subsequent revised siting
              five farms violating the dissolved oxygen                                guidelines       and       recommendations.
              standards is no greater than for one farm unless                         Environmental monitoring will also be
              the farms are placed extremely close together.                           required        to     characterize          any
                                                                                       environmental       impacts      from       farm
              In summary, most studies have shown that fish                            operations,      and     demonstrate        that
              farms do not have a significant adverse impact on                        operations do not violate water quality
              dissolved oxygen.        Exceptions to this have                         standards or applicable sediment quality
              occurred during summer or autumn at sites that                           standards.           Specific       monitoring
              had low background dissolved oxygen levels and                           requirements will be developed by EPA
              did not have adequate current flow through the                           and Ecology, and     may include bathymetric
              nets.                                                                    and hydrographic surveys, water quality
                                                                                       measurements, sediment chemistry, and
              5.2.2.1          No-Action Alternative -                                 biological sampling.
                               Existing Regulations and
                               Guidelines                                              Fish farming operations must comply with
                                                                                       State water quality regulations.          Water
              The following existing regulations and guidelines                        quality in Puget Sound is monitored,
              affect the potential impacts of fish farms on                            assessed, and protected by Ecology.
              water quality:                                                           Water      quality    criteria    have      been
                                                                                       established in WAC Chapter 173-201,
                      In May 1989, EPA determined that                                 Water Quality Standards for Surface
                      NPDES permits would be required for                              Waters of the State of Washington.
                      certain salmon farms in Washington.                              Marine waters are classified as Class AA
                      Ecology is currently incorporating this                          (extraordinary), Class A (excellent), Class
                      determination into policy and developing                         B (good), and Class C (fair). The water
                      a draft NPDES application for marine fish                        quality criteria associated with this
                      farms. When issued, NPDES permits will                           classification are summarized in Table 4.
                      satisfy both federal and state laws.
                                                                               Most of Puget Sound is classified as Class AA or
                      The NPDES requirement will apply                         A. Everett Harbor, inner Commencement Bay,
                      primarily to fish farms producing over                   Budd Inlet, and Oakland Bay are classified as
                      20,000 lbs of fish per year and using more               Class B. The Tacoma City Waterway is the only
                      than 5,000 lbs of food per month.              A         marine water classified as Class C.
                      State waste discharge permit will be
                      required for commercial farms producing
                      less than 20,000 lbs of fish per year. For


              Page 38                                                                                                   Water Quality









            Table 4.           Marine water quality standards in Washington state.


            Criteria                                                           Waterbody Classification


                                                             AA                A                  B                  C


            Fecal Coliforms (#/100 mL)
                  upper limit                                14                14                 100                200
            Dissolved Oxygen (mg/L)
                  lower limit                                7.0               6.0                5.0                4.0
                  decrease fimiiP                            -0.2              -0.2               -0.2               -0.2
            Temperature C C)
                  upper limit                                13                16                 19                 22
                  increase limip                             +03               +03                +03                +03
            pH
                  range limit                                7.0-8.5           7.0-8.5            7.0-8.5            6.5-9.0
                  inc./dec. limif                            +/-0.2            +1-0.5             +1-0.5             +1-0.5
            Turbidity (NTU)
                  increase limit                             +5                +5                 +10                +10

            Toxicity, Aesthetics             See Chapter     173-201 WAC for narrative and numeric criteria.


            a decrease limit if background is less than lower limit
            b increase limit if background is greater than upper limit (see Chapter
              173-201 WAC for specific equations for increase limit)
              increase or decrease limit for man-caused activities



                  ï¿½   Water quality standards for dissolved                                  concentrations near fish farms.                   No
                      oxygen have been developed from an                                     recommendations          are     made in          the
                      extensive data set on the effect of oxygen                             Guidelines concerning specific changes in
                      on freshwater fish and invertebrates.                                  the concentration of dissolved oxygen or
                      EPA (1986) reported that a minimum                                     nitrogen.         Instead,      the Guidelines
                      dissolved oxygen concentration of 8 mg/L                               evaluated monthly Ecology water quality
                      would not impair the production of                                     data and identified areas that already
                      juvenile or adult salmonids, or of inverte-                            have low dissolved oxygen concentrations
                      brates.         Light-to-severe        production                      at depth and persistent nitrogen depletion
                      impairment would occur at 6 and 4 mg/L,                                in the surface waters.                From this
                      respectively.      The limit to avoid acute                            assessment, the Guidelines recommended
                      mortality is 3 mg/L. Thus, according to                                that fish farm development be restricted
                      federal water quality standards, dissolved                             in these areas unless the applicant can
                      oxygen problems could occur when the                                   demonstrate that the biochemical oxygen
                      concentrations are sustained below 6                                   demand from the farm will not depress
                      mg/L.                                                                  dissolved oxygen concentrations and the
                                                                                             nutrient input from the farm will not
                  ï¿½   Water    quality concerns are addressed in                             affect phytoplankton blooms.
                      theInterim Guidelines (SAIC 1986). The
                      primary issues raised are changes in
                      nitrogen        and       dissolved         oxygen


            Water Quality                                                                                                                Page 39








                     In addition to the restriction of certain             that water quality would not suffer significant
                     areas in Puget Sound from fish farm                   impacts. It is recommended that the surveys and
                     development,      the     Guidelines      also        monitoring requirements outlined in the Interim
                     recommended production limits in defined              Guidelines be adopted into WACs.
                     geographic areas.        These areas and
                     production limits are defined in the                  Ecology's implementation of the NPDES permit
                     Guidelines, but the production limits range           system for fish farms will provide adequate
                     from 50,000 lbs per year in Sequim Bay to             regulatory control to ensure that fish farms will
                     5,900,000 lbs per year in Skagit Bay. In              be in compliance with all state and federal water
                     areas where there are no water quality-               quality laws.
                     based limits on production levels, the
                     Guidelines recommended a maximum                      It is recommended that the following measure be
                     production level of 1,000,000 lbs per year            required of fish farmers:
                     per square nautical mile.
                                                                                   During periods of naturally high turbidity,
                 ï¿½   The Guidelines also recommend that a                          farmers should monitor turbidity during
                     hydrographic survey of the site be                            their net cleaning operations.        If this
                     completed before starting the permitting                      monitoring' identifies turbidity levels over
                     process. The hydrographic survey should                       State water quality standards, then the
                     include  three components:       (1) current                  farmers should increase the frequency of
                     velocity and direction; (2) circulation                       their net cleaning to assure that State
                     patterns using drogue tracking techniques;                    standards are not exceeded.
                     and (3)  vertical profiles of temperature,
                     salinity, and dissolved oxygen.          This         5.2.3      Mitigation Measures and
                     information provides initial information to                      Unavoidable Significant
                     apply the depth and current guidelines                           Adverse Impacts
                     and to predict the dilution and dispersion
                     of excess feed and waste.                             Adoption   of the Guidelines and the monitoring
                                                                           requirement for net cleaning operations identified
                 ï¿½   Annual monitoring for changes in water                in the Preferred Alternative   into WACs with the
                     quality near the farms is also recom-                 implementation      of    the     NPDES        permit
                     mended in the Guidelines. Water quality               requirements will ensure       that no significant
                     parameters included in the sampling                   adverse water quality impacts occur as a result of
                     program     include:    dissolved     oxygen,         floating fish farm development.       No additional
                     temperature, salinity, pH, ammonia, and               mitigation measures are necessary.
                     nitrite/nitrate. Results from these annual
                     reports are submitted to DNR for                      5.3        PHYTOPLANKTON
                     distribution and review by other State
                     agencies.                                             Phytoplankton, small plants suspended in the
                                                                           water, form the base of the marine food chain.
            5.2.2.2         Preferred Alternative                          There are generally three major forms of
                                                                           phytoplankton     in   Puget     Sound:      diatoms,
            The hydrographic surveys and annual monitoring                 dinoflagellates, and flagellates.      Most larger
            in the Interim Guidelines provide an adequate                  phytoplankton cells in Puget Sound are diatoms
            framework for determining potential impacts to                 or dinoflagellates.    Diatoms are      free-floating
            water quality. In establishing areas where farms               plant cells or chains of cells and are the most
            should be restricted, and limiting production                  abundant phytoplankton group in central Puget
            amounts for specific geographic areas, the                     Sound (Anderson et al. 1984). Typically, they are
            Guidelines used a conservative approach to ensure              most abundant in any area where there is a


            Page 40                                                                                               Water Quality









           moderate amount of vertical mixing.           Dinofla-         periods in the spring (Taft and Taylor 1976,
           gellates are protozoan, able to move in the water              McCarthy et al. 1977). When seasonal depletion
           column, and some have plant-like qualities. A                  of nutrients occurs in semi-restricted marine
           few species of phytoplankton, mostly dinoflagel-               areas, the limitation found has always been
           lates, may have adverse effects upon man or                    nitrogen (URS 1986, SAIC 1986, Tetra Tech
           marine animals. Other forms of marine algae                    1988).    Nitrogen depletion is caused by the
           include macroalgae (or seaweeds) such as kelp                  physiological requirement for this nutrient, which
           and marine flowering plants such as eelgrass.                  is many times greater than the need for
                                                                          phosphate.
           In many marine environments, there is a general
           seasonal succession of phytoplankton types. This               Although not documented, increased plankton
           begins with diatoms in the spring, shifting to                 growth from fish farms would not necessarily be
           dinoflagellates in the late summer and early fall,             an adverse effect since phytoplankton are the
           and returning to diatoms in the late fall and early            base of the marine food chain. However, greatly
           winter. The succession is influenced by seasonal               increased growth of marine phytoplankton could
           water column stratification and overturn.            In        have    adverse    effects   on    dissolved     oxygen
           many areas of Puget Sound this seasonal                        concentrations, on fish and shellfish survival, and,
           succession is not observed. For example, in main               in rare cases, on aesthetics of nearshore waters.
           channel areas, diatoms tend to dominate all year,
           while the inner portions of restricted embayments              5.3.1       Affected Environment
           tend to be dominated by dinoflagellates during
           summer     and fall.         Although     studies    of        General.     Phytoplankton are present in Puget
           phytoplankton species dynamics are limited in                  Sound throughout the year, although their winter
           Puget Sound, there have been several studies of                abundance is normally reduced.          Winter et al.
           discrete sub-areas (Johnson 1932; Phifer 1933;                 (1975) found that growth rates of phytoplankton
           Thompson and Phifer 1936; Chester et al. 1978)                 populations were high in the central basin of
           and studies using chemical measures of phyto-                  Puget Sound        compared     to    coastal waters
           plankton abundance (Campbell et al. 1977;                      worldwide.     This high growth rate was partly
           Chester et al. 1978; Anderson et al. 1984).                    attributed to Puget Sound's strong, persistent
           Additionally,     Ecology       maintains       regular        upwelling of nutrients and algal cells from depth.
           monitoring of chlorophyll a (chemical measure
           of phytoplankton density) at many stations                     When a combination of suitable physical and
           throughout marine waters of Puget Sound.                       chemical     factors   occur    simultaneously      and
                                                                          sufficient seed stock is present, a "bloom" is
           Phytoplankton populations in marine waters are                 possible. A bloom is an outburst of growth in
           regulated in part by nutrients. Salmon farming                 the phytoplankton that produces a large crop. It
           produces     nutrients     that    could      stimulate        commonly occurs in the spring in most temperate
           phytoplankton blooms if phytoplankton growth is                seas and in Puget Sound may reoccur throughout
           nutrient limited. This potential effect is different           the summer. Exceptional blooms are those that
           from the dissolved oxygen effects discussed in the             are grossly noticeable or may have significant
           previous section. Phytoplankton blooms would be                impacts on human activities and may be
           a secondary, biological effect caused by a water               reoccurring over long time scales (Parker and
           quality change, not a direct effect of fish farms.             Tett 1987).

           It is universally agreed that the primary growth-              The question of what factors limit the crop size
           limiting nutrient in marine waters for virtually all           of phytoplankton in natural waters may be
           types of phytoplankton is dissolved nitrogen.                  difficult to answer for at least three reasons.
           Exceptions exist, such as in the Chesapeake Bay                First, the population of microscopic phytoplank-
           area where phosphate may be limited for short                  ton is very dynamic.        Both growth rates and


           Phytoplankton                                                                                                 Page 41









             death rates are usually very rapid.          Typically,        nutrient loading are large relative to natural rates
             phytoplankton live no longer than several days,                of nutrient supply to the phytoplankton. Under
             thus, temporal changes in the crop size are                    such circumstances, the plankton community may
             determined by imbalances in the rates of growth                be significantly altered, and the distribution of
             and rates of death. Grazing by zooplankton also                nitrogen between dissolved, phytoplankton, or
             contributes to the dynamics of phytoplankton                   zooplankton phases significantly changed.
             populations.
                                                                            Transitional or boundary areas between strongly
             Second, the size of the phytoplankton crop may                 stratified embayments and well-mixed main
             be directly controlled by the availability of                  channel areas often have the greatest density of
             materials necessary for the production of new                  phytoplankton, based on chlorophyll a concentra-
             cells. Direct control occurs solely by chemical                tion (Pingree et al. 1978; Jones et al. 1982;
             factors such as the concentrations and rates of                Gowen 1984).        While these areas are not
             nutrients and trace metals supplied.                           provisionally mapped in western Washington, their
                                                                            occurrence is fairly predictable.
             Finally, the crop size may be indirectly controlled
             by factors that determine the growth and death                 There have been several attempts to map the
             rates of the cells that comprise the population.               distribution of phytoplankton in portions of Puget
             Physical factors that exert indirect control on the            Sound. These studies were based on short time
             size of the crop include light intensity, water                scales (Munson 1969) and on an annual basis of
             temperature, and water movement (vertical mixing               total productivity in certain regions (Stockner
             caused by tides and weather and transport to the               1979). Although phytoplankton may be inherently
             ocean by horizontal flow).        These factors are            patchy in their distribution, replicate samples of
             most important in controlling phytoplankton crop               chlorophyll a from the same station often show
             size in the main channels of Puget Sound (Winter               little more variability than can be attributed to
             et al. 1975).                                                  statistical error (Platt et al. 1970). Anderson et
                                                                            al. (1984) found variation between nearby stations
             Thus, depending on the physical, chemical, and                 (not replicate samples at one station) on any
             biological state of the planktonic community,                  specific day to average 15% for nutrients, 30%
             nitrogen loading can have several effects. It can              for plankton biomass measures (chlorophyll a),
             lead to increases in either the concentration of               and 40% for species abundance.
             dissolved nitrogen in the water, phytoplankton
             concentration, zooplankton concentration, or any               Nutrient Sensitive Areas In Pueet Sound.
             combination of these three.            The fate of             Certain . portions of Puget Sound may have
             discharged nitrogen is difficult to assess.                    restricted water movement and other conditions
                                                                            that encourage the growth of phytoplankton. In
             However, the fate of nitrogen discharged from                  these areas, surface waters may be measurably
             farms will generally be the same as that of                    depleted of dissolved nitrogen for sustained
             naturally occurring nitrogen.        If the natural            periods during summer and early fall (SAIC
             concentrations     of   organic    nitrogen     in    a        1986). At least four of these areas have been
             phytoplankton crop and zooplankton stock are                   characterized in government sponsored reports as
             high relative to the concentration of dissolved                presently   sensitive   to   nutrient     enrichment.
             nitrogen in the water, then the waste or                       Sinclair Inlet, Budd Inlet, Oakland Bay and South
             discharged nitrogen will be assimilated into the               Hood Canal have a combination of factors
             plankton.    If organic nitrogen concentrations                including relatively poor flushing, human sources
             within the plankton are lower than natural                     of nutrients, and a degree of density stratification
             nutrient concentrations in the water, then                     in summer months that combine to make them
             discharged nitrogen will not be assimilated. This              sensitive to nutrient enrichment (Tetra Tech
             rule-of-thumb may not be valid when rates of                   1988). Other areas of Puget Sound (south Puget


             Page 42                                                                                                Phytoplankton









           Sound inlets and some of its passages, Dyes Inlet,          for   Puget    Sound    suggests   that    nearshore
           Liberty Bay, Agate Passage, marine waters east of           eutrophication is not a serious problem in most
           Whidbey Island, Northern Hood Canal, Discovery              of Puget Sound at this time. However, it was
           Bay and Sequim Bay) have varying degrees of                 suggested that increased discharge of nutrients
           flushing, density stratification, and flux rates of         due to population growth would possibly first be
           nitrogen.  These areas vary in their ability to             noticeable in the shallow, nearshore waters of
           assimilate additional nutrients.                            embayments less subject to strong physical mixing
                                                                       processes. Physical processes (water currents and
           EPA sponsored a study of water quality trends in            circulation) are the prime determinant of the
           13 of the potentially sensitive subareas of Puget           degree of nutrient trapping and potential for
           Sound (Tetra Tech 1988). In recent years the                eutrophication (Thom et-al. 1984, 1988).
           concentration of nitrate has declined in Port
           Gardner (surface and near surface water), Carr              Existing    Marine     PhytoRiankton       Problems.
           Inlet (surface water), and possibly central and             Although in most areas, including Washington
           southern Hood Canal (near surface and sub-                  State, there has been no systematic attempt to
           surface water). The cause of the reduced levels             assess the trends, the incidence of noxious or
           in central and southern Hood Canal may be                   harmful phytoplankton blooms may be increasing
           related to sub-surface phytoplankton activity in            worldwide.     Historical records are limited in
           southern Hood Canal.       The decrease in Carr             scope and of little statistical value, although most
           Inlet is possibly related to phytoplankton use.             observers agree that the increase is actually
           Ammonia is rapidly converted to nitrate in most             occurring (Ayres et al. 1982; Tangen 1987; White
           oxygenated aquatic environments (Harris 1986)               1987).    Because noxious or toxic blooms may
           and occurs at low concentrations in most of                 adversely affect shellfish and finfish aquaculture,
           Puget Sound. Thus, there were no analyses of                there is a continuing and increasing monitoring
           ammonia concentration trends.                               effort worldwide (Tangen 1987), and specifically
                                                                       in the Pacific Northwest (Rensel et al. 1989).
           Another nutrient required by      phytoplankton is
           phosphate. Long-term phosphate concentrations               The term "red tide" refers to toxic and non-toxic
           decreased since the 1950s in seven of nine areas,           blooms of phytoplankton, bacteria, ciliates or
           both urban and rural (Tetra Tech 1988). Recent              even small zooplankters (Steidinger and Haddad
           increases were seen in six of the study areas, all          1981). Often, red tides are dominated by one or
           near urban centers.     The significance of these           just a few species. Although dinoflagellates cause
           changes is unknown, but such increases are likely           most of the red tides, only 20 of the more than
           insignificant due to the abundant natural nutrient          1,200 described dinoflagellates cause toxic red
           concentrations.                                             tides. For example, commonly seen red tides in
                                                                       southern and other parts of Puget Sound are
           The shallow, nearshore environment has had less             related to blooms of a large heterotrophic
           attention in oceanographic and routine water                dinoflagellate, Noctiluca miliaris. This organism
           quality sampling programs in the past. One study            may alter surface water coloration to a very
           suggests conditions in very shallow, nearshore              noticeable orange-red tomato soup like color, and
           waters of central Puget Sound may be extensively            may accumulate along beach areas, but it is
           depleted of dissolved nitrogen during late spring           generally considered non-toxic to fish and marine
           and early summer (Thom et al. 1984, 1988). The              life.
           depletion occurred during a period of increasing
           light intensity coupled with enrichment from                In areas of Puget Sound with restricted water
           several Sources, especially an urbanized creek that         movement, dinoflagellates are the dominant
           flowed onto the beach. The enrichment resulted              phytoplankton in nutrient-depleted areas during
           in excessive seaweed growth and odor when the               calm weather periods (Cardwell et al. 1977,
           algae began to decay. The published literature              1979). Dinoflagellates often migrate vertically in


           Phytoplankton                                                                                            Page 43








             the water column to obtain nutrients at depth                    specific conditions such as greater depth and
             during the night and use sunlight near the surface               existence of a underlying nutrient-rich layer make
             durin g the day. Another possible reason for this                comparison to other areas with PSP difficult.
             dominance is that they avoid being eaten by                      Diurnal vertical migration has been demonstrated
             zooplankton by this migration.           Estimates of            for Protogonyaulax spp. in Washington State
             dinoflagellate migration rates for many species                  (Nishitani et al. 1988) and elsewhere (Eppley and
             range from about 0.5 to 2.0 m/h (Darley 1982) to                 Harrison 1974).
             20 m/h (Paerl 1988). To some degree, these
             dinoflagellates operate independently of nutrient-               Although trace nutrients such as iron, copper,
             depleted surface water conditions, because they                  zinc, boron, sodium, and vitamin B12, are also
             can obtain adequate inorganic nitrogen below the                 important for the growth of phytoplankton, for
             surface stratum.      However, when there is an                  marine waters they are considered of secondary
             adequate concentration of inorganic nitrogen                     importance.     This has been shown by culture
             below the surface, self shading and available light              experiments where major growth response is
             may be more important limitations to growth than                 elicited by addition of nitrogen, not minor
             nutrient concentration.                                          elements or vitamins (Welch 1980). Therefore,
                                                                              phytoplankton growth is essentially determined by
             Because it is the sole source of paralytic shellfish             the amount of one nutrient which is in shortest
             poisoning (PSP) in Washington, the most                          supply, not by a conglomeration of different
             important species of noxious phytoplankton in                    nutrients (Raymont 1980).
             Puget Sound is the dinoflagellate,Protogonyaular
             catenella (formerly Gonyaulax catenella).            PSP         Elevated concentrations of biotin, present in fish
             may occur throughout Puget Sound, but regular                    food in small amounts (1 gram in 1,000 kg of
             outbreaks are restricted to certain bays such as                 food), has been found in the laboratory to
             Sequim     Bay     and     Quartermaster        Harbor.          increase    the    toxicity   of one       species     of
             Although coastal areas may be seeded from                        dinoflagellate, Gyrodinium aureolum, which was
             offshore blooms that move onshore, it appears                    responsible for fish kills in the north Atlantic
             that embayments are the source of PSP blooms in                  ocean (Turner et al. 1987).              The relative
             Puget     Sound       (Nishitani     1988      personal          significance of this finding is small, since there
             communication).       Worldwide, there has never                 would have to be virtually no water movement for
             been any evidence that fish farms caused or                      many months to allow the necessary level of
             increased a bloom of noxious phytoplankton. In                   biotin to leach from uneaten food beneath a
             many@cases, noxious and exceptional blooms have                  typical-fish farm. Turner et al. (1987) noted that
             originated offshore and drifted inshore where                    most of the biotin is metabolized by the fish and
             they are noticed (Steidinger and Haddad 1981;                    would accumulate @ locally only under "adverse
             Parker 1982).                                                    hydrographic conditions." The organisms most at
                                                                              risk from biotin accumulation causing a possible
             PSP-causing dinoflagellates may form resting cells               bloom would be farm-reared salmon.
             (cysts) that fall to the bottom and later germinate
             under    favorable     conditions    or    with     time         Noxious phytoplankton appear to have caused
             (Anderson and Keafer 1987).             Protogonyaulax           occasional kills of fish reared in farms in
             catenella requires a stable water column (no wind                Washington State. Unlike fish kills in Europe,
             or strong currents), light, nutrients, a seed                    which are usually associated with dinoflagellates,
             population, and 13* to 17* C water temperature                   most of the problems in Washington state have
             for optimum growth (Nishitani et al. 1988). In                   been related to blooms of diatoms, especially
             other cases, low concentrations in surface water                 certain members of the genus Chaetoceros (Bell
             of nitrogen and possibly phosphorus has been                     et al. 1974; Rensel et al. 1989). Although there
             proposed as a growth limiting factor for this                    has been no detailed research on the issue, it
             species in Quartermaster Harbor. However, site-                  appears that simple mechanical clogging and


             Page 44                                                                                                    Phytoplankton








           abrasion of the gills may be the main source of                     result in (1) shading of the bottom which
           this mortality rather than toxicity.         Diatoms of             prevents the establishment of larger attached
           the genus Chaetoceros are very common in Puget                      algae and (2) the buildup of high levels of
           Sound.       Most species of Chaefoceros                are         organic matter on the bottom (phytoplankton
           considered benign or beneficial as food for                         cells).    During nighttime, when there is no
           shellfish and zooplankton.                                          sunlight     for     photosynthesis       and       oxygen
                                                                               production,      phytoplankton       consume       oxygen.
           5.3.2        Impacts on        Phytoplankton                        Thus, there can be wide variations in the
                                                                               dissolved oxygen levels from day to night, and in
           Salmon farms may cause          or increase blooms of               extreme      cases,    nighttime      respiration      and
           phytoplankton by localized nutrient enrichment                      decomposition of decaying phytoplankton may
           (Weston 1986; Gowen and Bradbury 1987). This                        reduce dissolved oxygen to levels that cause fish
           enrichment could occur when excessive dissolved                     kills. An example of this situation is the extreme
           nutrients are discharged into semi-enclosed waters                  southern     end     of Budd        Inlet,   which     has
           with limited tidal mixing and strong vertical                       experienced fish kills during the summer.
           stratification.
                                                                               In all but a few localized areas of Puget Sound,
           Impacts on Phytoplankton in Nutrient Sensitive                      limited increases in phytoplankton production
           Areas.       The addition of nutrients to an                        would have no adverse effect and would merely
           embayment can increase the production of                            contribute more food to the food chain. Even in
           phytoplankton.       Phytoplankton forms the basis                  situations such as Budd Inlet, fish and shellfish
           for the aquatic food chain in all aquatic systems                   are abundant. Shellfish in the area grow rapidly,
           and moderate increases in primary production will                   feeding on the phytoplankton. As a comparison,
           usually increase the production of zooplankton,                     commercially grown oysters in the nutrient- and
           filter-feeding fish and shellfish, and the larger                   plankton-rich waters of south Puget Sound reach
           predator fish harvested by sport and commercial                     market size in two to three years, while those
           fishermen. Phytoplankton is also a major source                     grown       in   the     relatively     nutrient-      and
           of dissolved oxygen.                                                phytoplankton-poor waters of Hood Canal reach
                                                                               market size in four to five years.
           However, in unusual cases, eutrophication way
           result in excessive growth of phytoplankton. This                   In the past, Puget Sound farms located in
           occurs in poorly flushed, shallow bays where                        restricted embayments (Henderson Inlet in
           hydrographic conditions allow a high-density of                     southern Puget Sound and Shoal Bay near Lopez
           phytoplankton growth. Eutrophic bays may have                       Island) suffered severe losses of salmon and other
           an accumulation of small attached algae near                        aquaculture species in some years (Rensel and
           shore and decaying macroalgae and phytoplank-                       Prentice 1980; Bill 1988 personal communication).
           ton. This accumulation of organic matter results                    Such losses contributed to the eventual removal
           in the same sediment impacts as described under                     of those facilities. Presently, there are no large,
           farms, with the reduction of organisms in the                       commercial farms operating in restricted Puget
           sediment and the production of oxygen-depleted                      Sound waters.
           sediments. Hydrogen sulfide from these anoxic
           sediments and the decay of organic matter can                       Since few fish farms have been located in
           result in obnoxious odors, a naturally occurring                    nutrient sensitive areas of the state, there has
           situation in some small bays.                                       been little study of the possible effects of
                                                                               nutrient discharge on phytoplankton.                   One
           The above description represents an extreme                         detailed study, conducted under worst-case
           situation that occurs only in very limited areas of                 conditions in Henderson Inlet, suggested that
           Puget Sound for short periods.            In the water,             there was no effect from salmon farms on
           prolonged or successive intense algae blooms can                    phytoplankton populations (Pease 1977).                The


           Phytoplankton                                                                                                         Page 45









             study area had very limited water circulation, a                 of nitrogen from the farm could not have had a
             condition worsened by the study area location                    stimulating effect on their growth.
             within a shallow log dumping and storage area.
             Establishing reference ("control") areas for these               Although the timing and conditions of this study
             worst-case studies of fish farm impacts on                       were appropriate to maximize the effects of the
             phytoplankton is difficult. There is a possibility               fish farm on phytoplankton, and some effects
             that the effects of this farm on phytoplankton                   were observed, most of the statistical tests
             were overlooked by selecting reference areas too                 indicated that phytoplankton growth rate did not
             close to the farm location.                                      significantly vary among stations or times except
                                                                              during one monitoring period.               The first
             The effects of a salmon fish farm on dissolved                   experiment further served to illustrate the
             nutrient concentration, phytoplankton density, and               complexity of monitoring phytoplankton in the
             growth rates were investigated in a shallow                      field.
             passage of southern Puget Sound, near Squaxin
             Island, Washington (Rensel 1988c).              It was           The second type of experiment that Rensel
             hypothesized that if background levels of                        (1988c) conducted involved nearfield monitoring
             dissolved nitrogen were low for long enough                      of nitrogen produced from the fish farm. During
             periods, excreted nitrogen from the fish could                   the period of maximum fish biomass, minor
             have enhanced the growth of phytoplankton. The                   increases in dissolved nitrogen (N03+NO2+NH4)
             fish farm complex was the largest in western                     were seen downstream of the farm during one
             Washington located in surface waters that were                   tidal period, but not the next.        Although total
             depleted of dissolved nitrogen for at least        some          ammonia was significantly elevated within the
             period of the time.           Accordingly, the site              farm compared to ambient concentrations,
             constituted a "worst-avail able case" for fish      farm         concentrations were well below the chronic
             in western Washington.                                           exposure concentration for salmonids and other
                                                                              sensitive coldwater fish. At a distance of 30 m
             Two experiments were conducted.              The first           downstream of the fish farm, approximately 80%
             measured phytoplankton      density and growth rates             of the ammonia was nitrate, presumably oxidized
             at the farm site during a period of maximum fish                 through microbial nitrification.
             biomass and one month later during similar tidal
             and weather conditions, but after release of 60%                 Recent studies in Scotland (Gowen et al. 1988)
             of the fish.   Monitoring of reference stations at               focused on phytoplankton density and growth
             both ends of the passage, beyond the immediate                   rates in a restricted, fjord-like sea-loch that had
             area of the fish farm, was conducted to assess                   slow water movement (maximum flow of 16 cm
             source water   conditions and provide a comparison               seCl )   and    a    large,     salmon    fish    farm.
             to the farm site.                                                Additionally, water exchange into the 50 m (164
                                                                              ft) deep Loch    Spelve is restricted by a shallow
             The results of the first experiment suggested no                 sill, only 4 ms (13 ft) deep. Although localized
             consistent and significant effect of the fish farm.              elevated   ammonia was         seasonally observed
             However, natural variation of dissolved nitrogen                 immediately around the fish farm, study results
             concentrations confounded possible correlation                   indicate no measurable effect of the farm on
             between phytoplankton density/growth rate and                    phytoplankton density.          Carbon-14 isotope
             the fish farm or reference stations. Moreover,                   productivity data did not show any effect of the
             only two of twelve samples were collected when                   farm, although the authors felt that this portion
             major dissolved nutrients could have been limiting               of their study was based on insufficient data. In
             to    phytoplankton       growth.            Therefore,          spite of slow water flow near the farms, the
             phytoplankton cells were usually not limited by                  residency time of water was too brief to allow
             the ambient nitrogen concentration, and addition                 measurable increases in phytoplankton density or
                                                                              growth rates.


             Page 46                                                                                                   Phytoplankton









           Stockner (1979) has suggested that an observed                   proposed farm site within a sensitive area has a
           increase of phytoplankton stocks in the Strait of                tremendous bearing on the probability of
           Georgia, British Columbia, was correlated with                   measurable impacts.        These factors should be
           increased nutrient discharge in Vancouver, B.C.,                 considered on a site-specific basis in potentially
           municipal wastes. Nitrogen and phosphorus waste                  nutrient sensitive areas listed in the affected
           loading doubled during the period 1951 to 1977,                  environment section.
           and dispersion into the Strait was enhanced by
           locating the discharge in the Fraser River plume.                5.3.2.1          Modeling Phytoplankton
           Nutrients are limiting to phytoplankton growth in                                  Impacts
           that area at some places and times from July
           through September. Although the author did not                   Modeling (mathematical simulation of the
           prove a causal relationship, he suggested that                   biological processes occurring in a bay) can allow
           nutrient enrichment could produce a positive                     estimation of potential impacts. Modeling of the
           effect by providing an expanded base for the                     entire Puget Sound basin is highly impractical
           aquatic food web, which includes stocks of                       (Winter et al 1975). However, an incremental
           commercially valuable fish such as salmon.                       approach, addressing certain potentially sensitive
                                                                            sub-areas, is possible using the tools of physical,
           Sensitive Area Management. There are a number                    chemical, and biological oceanography. Modeling
           of factors that contribute to the nutrient                       of environmental effects upon water quality, a
           sensitivity of any specific sub-area of Puget                    science developed largely to study industrial waste
           Sound. In general, the area is more sensitive if                 discharge, has recently been adapted to salmonid
           the following conditions exist:                                  aquaCUltUTe.      Near- and farfield nutrient and
                                                                            phytoplankton modeling fish farming has recently
                ï¿½   Strong density gradient (salinity and to a              been developed (Parametrix Inc. et al. 1988;
                    lesser extent, temperature) during calm                 Kiefer and Atkinson 1988).
                    summer and fall periods
                                                                            Nearfield impacts (ammonia production and
                ï¿½   Low rate of water exchange with an                      oxygen consumption) from farms may be easily
                    outside water source                                    modeled      using    models     that     conservatively
                                                                            approximate a pipeline passing through the farm.
                ï¿½   Low rate of dissolved nitrogen flux into                These models neglect lateral mixing that would
                    and out of the system                                   tend to reduce the measurable effects. Farfield
                                                                            models are much more complex and have been
                ï¿½   Low phytoplankton          crop    (low    total        developed for potentially nutrient sensitive areas.
                    nitrogen       load     that      could       be        Calibration of these models must account for
                    proportionately more perturbed by added                 existing conditions of temperature, nutrients,
                    nutrients)                                              hydrodynamics, mixing rates with outside waters,
                                                                            variability of phytoplankton standing stock, and
                ï¿½   Dissolved oxygen depletion, usually at                  other factors.
                    depth
                                                                            Phytoplankton enhancement models assume a
                ï¿½   Presence of sufficient seed stock of                    two-layer (box) system commonly used by
                    noxious phytoplankton species such as                   oceanographers to describe surface and deep
                    Protogonyaulax catenella.                               layers of aquatic systems (Broeker and Peng
                                                                            1982).     Such box models are generally valid
           Sufficient data exist in many of the potentially                 because of limited mixing between surface and
           sensitive sub-areas to rank the sensitivity for all              deep waters (Brooks 1960). These models are
           but the last factor. However, a ranking is not                   useful to estimate both surface and nearbottom
           included here, since the specific location of a


           Phytoplankton                                                                                                     Page 47









             impacts on dissolved oxygen, sedimentation, and                The Kieffer-Atkinson model simulates the
             nutrient-phytoplankton interactions.                           nitrogen cycle within an embayment (Figure 11).
                                                                            The model considers three nitrogen pools:
             The most important component of         these models           aqueous nitrogen, nitrogen in phytoplankton, and
             is the physical oceanography of the area:                      nitrogen in zooplankton.          The nitrogen is     '
             flushing rates and circulation patterns. Estimates             exchanged among the different nitrogen pools
             of flushing can be made based on drogue and                    through photosynthesis, respiration, grazing,
             current meter studies, studies of conservative                 excretion, basal metabolism /mortality, and loss
             properties of seawater such as salinity, and                   from the system through the zooplankton pool.
             through the study of the biota that reflect the                Photosynthesis is either light or nitrogen limited,
             physical and chemical conditions. Once flushing                while zooplankton grazing depends on the
             rates are known, site-specific water chemistry                 concentration of phytoplankton. In the simulation
             data and laboratory- derived and predictable                   of summer conditions, when biological activity is
             features of phytoplankton growth may be applied                high, the model predicts the steady-state nitrogen,
             to estimate response of phytoplankton to added                 phytoplankton, and zooplankton condition of the
             nutrients.   Such models have been verified as                 embayment.
             effective in predicting nutrient and phytoplankton
             conditions   in actual practice (Atkinson 1984;                For the hypothetical embayment, a surface area
             Atkinson et al. 1984).                                         of 1.7 x (1C7) m2 was chosen to represent a
                                                                            smaller bay near full development with five farms
             The analysis of the impact of one farm on the                  in operation.
             phytoplankton population in an embayment
             previously discussed may not be an accurate                    A dilution rate (D) of 20% was selected using an
             estimate of the actual impact of a fish farm if                exchange rate with source waters outside the
             other farms are in the same embayment. The                     embayment of 27% per tidal cycle based on data
             area immediately around the farm (nearfield) is                from the 19 sub-areas of Puget Sound discussed
             usually independent of other farms as long as the              in theInterim Guidelines (SAIC 1986). Assuming
             farms are adequately spaced as discussed in the                a reflux coefficient of 0.5, the flushing factor
             dissolved oxygen section. The farfield consists of             would be 13.5% per tidal cycle. With approxi-
             the remainder of the embayment and is affected                 mately 1.5 tidal cycles per day, this results in
             by the cumulative effect of all the farms in the               20.2% flushing per day.
             embayment.
                                                                            In winter, when biological conditions are low, the
             To estimate the cumulative effect of several farms             model simplifies to a single expression for       ' the
             on   phytoplankton      in   a   nutrient     sensitive        mass loading to the embayment and resulting
             embayment, knowledge of three factors is                       change in the nitrogen concentration (SN) given
             necessary.     They are (1) the size of the                    by:
             embayment, (2) mean depth (or mean mixed layer
             depth for a stratified embayment), and (3) the                         6N          J * F
             dilution or flushing rate of the embayment. For                                A * Zm * D
             this analysis, it is necessary to consider a
             hypothetical embayment.        This embayment is
             tidally flushed, is relatively small, has five farms,          where: J        mass nitrogen loading from the
             and is vertically stratified with a relatively shallow                         farms (kg/day)
             mixed layer. A suitable model for this type of                                 F        the fraction of nitrogen
             analysis was developed by Kiefer and Atkinson                                           produced by the farms that
             (1988) for use in western Washington.                                                   enters the embayment
                                                                                            A        surface    area     of    the
                                                                                                     embayment (m2)


             Page 48                                                                                                 Phytoplankton








                        ZM       mean depth or depth of the
                                 mixed layer (in)                             During summer steady state conditions, the model
                        D        dilution rate of the embayment               assumes the partitioning of phytoplankton biomass
                                 by tidal exchange (dail)                     into one-half as much zooplankton biomass.
                                                                              Non- steady-state conditions are included in the
           The fraction of nitrogen released from the farms                   model, but the other calculations are elaborate
           and remaining in the embayment (F) was                             differential and simultaneous equations that
           estimated at 95%.           Normally, this nitrogen                involve use of a mainframe computer. See Kiefer
           quantity would be based upon site specific studies                 and Atkinson (1988, 1989) for a more detailed
           and may range from a low value of 10% to as                        description of the model, including necessary
           much as 95%. For this worst-case estimate, a                       equations.
           value of 95% is very conservative.
                                                                              Based on the model, the summer phytoplankton
           Loading of dissolved nitrogen produced by fish                     crop would increase approximately 2% from five
           per day was taken as 0.25 g/kg fish per day and                    farms.     This run of the model assumes that
           for a typical 500,000 lb/year facility would be                    nominal conditions of phytoplankton abundance
           56.8 g/day times the percent soluble (87%) for a                   are 3.0 yll, chlorophyll 2.             Under normal
           total of 50 kg/day.        The depth of the surface                conditions, there is a range of phytoplankton
           mixed layer was conservatively assumed to be 5                     abundance varying from about 1 to 15 yll,
           in.                                                                chlorophyll _4.

           Model results for five 500,000 lb/year farms in a                  This modeling assumes a well-mixed condition
           single embayment are presented in Table 5.                         throughout the surface layer and ignores nearrield
                                                                              effects from the farms.         It also conservatively
           For winter conditions, the average increase in                     assumes no mixing of nutrients from the deeper
           nitrogen concentration throughout the embayment                    layer with the surface. The actual siting of fish
           would     be     0.0085     mg/L.         The      natural         farms could be determined from modeling embay-
           concentrations of nitrate plus nitrite and ammonia                 ments to determine their flushing rate and
           at this time of year is about 1.5 mg/L.                            circulation patterns, and evaluate nearfield
           Therefore, the increase in the concentration of                    conditions around the proposed farm.
           dissolved nitrogen would be less than 1%. This
           one-percent nitrogen increase would be negligible                  Modeling is more critical in the siting of more
           as there are already abundant natural sources of                   than one farm in an embayment. In particular,
           nitrogen that are not utilized during the winter.                  the farm should be situated such that the
                                                                              nearfield conditions from multiple farms do not
           During the summer, the model used here assumes                     overlap and cause high localized concentrations of
           that 95% of the dissolved nitrogen excreted by                     nutrients and phytoplankton or low concentrations
           the    salmon      will  be    incorporated by the                 of dissolved oxygen.
           phytoplankton within the embayment. In many
           areas, this would be too conservative an                           In summary, the nitrogen added to a small
           assumption, but it is used here as a worst-case                    embayment from five farms is not expected to
           approximation.           Under      nutrient      limiting         adversely affect the embayment's phytoplankton
           conditions, the concentration of dissolved nitrogen                abundance. Extremely small, shallow, or poorly
           in surface waters may be very low during the                       flushed bays would be more sensitive to nutrient
           summer in many of the embayments, less than 0.1                    loading from fish farms, but proper analysis of
           mg/L, and in many cases 0.05 mg/L or less.                         proposed      farm     sites   could     identify     such
           There may be large amounts of total nitrogen at                    embayments.
           this time in the standing crop of phytoplankton,
           particularly in the late spring and early summer.


           Phytoplankton                                                                                                        Page 49



















                                                     NET-PEN



                                                           (LOADING
                                                            RATE)



                                                    DISSOLVED
                                                    NITROGEN


                                       (RESPIRATION              (GROWTH
                                          RATE)                    RATE)


                                                 PHYTOPLANKTON                (BASAL METABOLISM AND
                                                    NITROGEN                      MORTALITY RATE)


                              (TIDAL
                             DILUTION                     (GRAZING
                              RATE)                         RATE)
                                                        if

                                                  ZOOPLANKTON
                                                    NITROGEN




                                                           (SYSTEM LOSS
                                                               RATE)




                                0
                                    FLOW
                                  UT
                                  FROM
                                                 ......... . ..... . .... .. . ......... .
                                EMBAYMENT

                                                    SEDIMENT













                                                              Figure 11.
                                                              Schematic Representation of the
                                                              Processes Simulated in the Keiffer
                                                              and Atkinson Phytoplankton-Nutrient Model








           Table 5.       Effect of five farms in an embayment on the nitrogen, phytoplankton, and zooplankton
                          concentrations for summer and winter conditions based on the Kieffer and Atkinson model
                          (1988).


                      Dissolved Nitrogen                     Phytoplankton                 Zooplankton
                          (mg/L)                             (mg/L)                       (mg/L)
                      Ambient     Increase               Ambient     Increase              Ambient     Increase



           Winter     1.5         0.0085                 0.012        0                  0.003         0


           Summer     0.012          0                   0.186      0.004                0.186        0.004




           5.3.2.2        No-Action Alternative -                           situation is actually much more complex
                          Existing Regulations and                          and the guidelines result in a very
                          Guidelines                                        conservative estimate of nitrogen flux.
                                                                            Many of the embayments are relatively
           The following existing regulations and guidelines                deep and may have a two-layer, stratified
           affect potential impacts of fish farms on                        system with nutrient depletion only
           phytoplankton:                                                   present in the surface layer.           The
                                                                            Guidelines rely upon measurement of
              ï¿½   The     SEPA     process    provides     the              dissolved nitrogen in the surface layer
                  opportunity for State resource agencies to                only, and not the deeper, nutrient-rich
                  evaluate individual fish farm proposals at                layer which may be much larger (such as
                  specific sites on a case-by-case basis using              in central Hood Canal). The Guidelines
                  the most current, available information.                  result in a much more conservative
                                                                            estimate of the 1% flux because only data
              ï¿½   State water quality standards do not set                  from the nutrient-depleted surface waters
                  limits   or  targets   for    phytoplankton               are considered. (Duxbury 1988 personal
                  concentration.    The Interim Guidelines                  communication).     Thus, the deeper the
                  (SAIC 1986) do not set specific values for                embayment, the more conservative the
                  phytoplankton production near fish farms.                 existing guidelines are for the true 1%
                  The Guidelines deal with the issue of                     flux of nitrogen.
                  potentially    excessive     phytoplankton
                  productivity  near farms by proposing                     In addition, the calculation of nitrogen
                  limits on the dissolved nutrient production               flux in the Guidelines does not consider
                  from farms.      See Section 5.2, Water                   the biological conversion of dissolved
                  Quality.                                                  inorganic nitrogen (ammonia and nitrate)
                                                                            to organic nitrogen (plankton tissue).
                  The limit on nutrient production from a                   The rate of nitrogen cycling ("turnover
                  farm relates to flux of nitrogen from a                   time") within an embayment depends on
                  farm compared to the total tidal flux of                  several factors including phytoplankton
                  nitrogen into an embayment. A maximum                     crop size, phytoplankton growth rate,
                  1% increase in the flux (not to be                        grazing by zooplankton, and to a lesser
                  confused with the concentration) due to                   degree, sedimentation (Harris 1986).
                  fish farming is recommended. Yet, the


           Phytoplankton                                                                                        Page 51








                     The Guidelines legitimately did not                          Where the maximum production level is
                     consider these unquantified factors, and                     attained in any of the 19 embayments,
                     sought instead to use the existing Ecology                   subsequent fish farm proposals must
                     database.       That    database     includes                demonstrate to State resource agencies by
                     dissolved inorganic nitrogen (that is,                       field and modeling studies that additional
                     nitrate, nitrite and ammonia) and ortho-                     proposed development will not adversely
                     phosphate. While nitrogen to phosphorus                      affect existing biota.
                     concentration has been used as an
                     indicator of nutrient depletion in surface           5.3.3       Mitigation Measures and
                     waters, the method is complicated in                             Unavoidable Significant
                     coastal waters by the relative rates of                          Adverse Impacts
                     water exchange through a restricted area
                     and varying rates of internal biochemical            Adoption    of the, measures identified in the
                     processes acting to adjust the ratio of N:P          Preferred  Alternative will provide a conservative
                     availability (Smith 1984; Harris 1986;               approach   to avoiding significant adverse impacts.
                     Paerl- 1988).                                        The SEPA process allows a case-by-case
                                                                          assessment of fish farm proposals and their
            5.3.2.2         Preferred Alternative                         potential affect on nutrient sensitive areas, and
                                                                          no additional mitigation measures are necessary.
            The Guidelines provide an adequate framework
            for establishing which embayments may be                      5.4         CHEMICALS
            nutrient sensitive. By establishing areas where
            farms should be restricted, limiting production               This issue involves the use of antibiotics and
            amounts for specific geographic areas, and using              antifoulants in fish farm operations. Concerns
            a conservative methodology for estimating a 1%                include the environmental risks associated with
            flux of nitrogen; the Guidelines used a reasonable            chemical usage, accumulation of antibiotics in the
            approach to ensure that fish farms would not                  environment or tissues of indigenous biota, and
            create significant impacts on potentially nutrient            whether the use of'antibiotics encourages growth
            sensitive areas. It is recommended that the areas             of bacteria resistant to antibiotics.
            defined as sensitive in the Guidelines (Holmes
            Harbor, Budd Inlet, and Hood Canal south of                   5.4.1       Affected Environment
            Hazel Point) be identified as such in WACs.
                                                                          Antibl'otics. For fish farming applications, two
            For areas so defined, it is recommended that the              antibiotics are currently registered by the U.S.
            following additional guideline be adopted into                Food and Drug Administration (FDA). These
            WACs:                                                         are (1) oxytetracycline (OTC), and (2) a potenti-
                                                                          ated sulfonamide marketed under the trade name
                     Limit total fish production       within a           Romet. Other antibiotics, such as oxolinic acid,
                     sensitive area to that which will not                may be used on a limited basis if special
                     adversely affect existing biota. The use             permission is granted by the FDA.
                     of predictive models to estimate    allowable
                     production levels in sensitive     areas is          OTC, marketed under the trade name Terramycin
                     recommended.                                         or TM-50, is the most commonly used antibiotic
                                                                          in salmon farms.      It is generally regarded as
            The maximum production levels for fish farm                   highly effective against vibriosis. It is also used
            development in the 19 embayments identified in                to treat furunculosis.    (See Appendix D for a
            the Guidelines should be adopted into WACs with               further discussion of fish diseases.)
            the following additional measure:



            Page 52                                                                                               Phytoplankton









           Romet is a relatively recently-licensed antibiotic             research     provides     estimates     of     probable
           for use in fish farming.      It has been effective            concentrations of antibiotics leaving freshwater
           against furunculosis and enteric redmouth disease              fish farms. The estimated dilution of OTC, based
           in freshwater fish hatcheries, and has also been               on maximum allowable levels of administration,
           demonstrated to be effective in saltwater pens                 was I part in 50,000,000.         This dilution was
           against vibriosis.                                             regarded as a worst-case estimate, based on no
                                                                          retention of the administered drug in the fish.
           The FDA practices a more conservative policy                   Thus,    Austin     (1985)    concludes     that     the
           toward licensing drugs for use in aquaculture                  concentrations of drugs reaching the environment
           than do governments of many other countries.                   are very small.
           Thus, drugs such as oxolinic acid and chloramine-
           T, which are effective against certain bacterial               Austin (1985) noted that use of antibiotics in fish
           diseases of salmon, are commonly used in other                 farms could lead to an increase in antibiotic
           parts of the world, but are not used in the                    resistance among bacteria in the farm effluent.
           United States.                                                 Other authors have reported the phenomenon of
                                                                          antibiotic resistance of bacteria near fish farms in
           The digestibility of OTC, oxolinic acid, and                   which the medications are applied (Aoki 1975,
           chloramphenicol was tested in rainbow trout in                 1988; Aoki et al. 1971, 1972b, 1974, 1977, 1980,
           freshwater by French scientists (Cravedi et al.                1984, 1985, 1986a, 1987a; Aoki and Takahashi
           1987).     These researchers found that the                    1986; Takashima et al 1985; Bullock et al. 1974;
           digestibility of OTC was 7 to 9%, in comparison                Toranzo et al. 1983). Bacteria can gain antibiotic
           with chloramphenicol's 99% and oxolinic acid's 14              resistance through the selection of bacteria that
           to 38%. Chloramphenicol is not used in animal                  contain resistance factors, or plasmids, some of
           husbandry in the United States due to its high                 which may be transferable from one fish
           toxicity and, as noted above, oxolinic acid is not             pathogenic bacterium to another under certain
           licensed for general use in aquaculture in this                conditions (Akashi and Aoki 1986b; Aoki and
           country.     According to these authors, the                   Kitao 1985; Aoki and Takahashi 1987; Aoki et al.
           relatively low level of digestibility of OTC may               1972a, 1986b, 1987b, 1981; Mitoma et al. 1984;
           result from its affinity for calcium. Calcium is               Toranzo et al. 1984). In addition, plasmids, or
           present in fish food in the form of shell or fish              resistance factors, can confer resistance to more
           bone. The authors also note about 90% of OTC                   than one antibiotic when transferred from one
           administered in fish feed is excreted in the feces             bacterium to another (Aoki et al. 1987a). The
           as the parent compound (that is, as the chemical               presence of plasmids has been documented in
           form added to the feed). That means use of the                 both fish pathogenic bacteria (see above citations)
           drug could contribute to the accumulation of                   and in native aquatic bacteria (Burton et al.
           OTC in the sediments below a farm and possibly                 1982).
           to the development of antibiotic resistance in
           bacteria in these sediments.        Austin and Al-             A FDA study to evaluate the use of OTC for
           Zahrani (1988) found that OTC and other                        aquatic applications, analyzed the environmental
           antibiotics altered the number and type of                     impact of the antibiotic on disease control in
           bacteria in the digestive tract of rainbow trout               lobsters held in impoundments (Katz 1984).
           fed antibiotics.                                               Based on seawater dilution and lack of long-term
                                                                          selective pressure favoring the persistence of
           Austin    (1985)     discussed     the    effects    of        OTC resistant organisms, Katz (1984) concluded
           antimicrobial compounds used in fish farming that              that "there should be no build up of antibiotic
           may escape into the environment. He noted that                 resistant populations of microorganisms from the
           data are not available on the quantities of                    use of OTC in treating gaffkemia in lobsters." In
           antimicrobial      compounds         entering       the        the same report, Katz concluded that "the
           environment from fish farming.         However,     his        potential of R-factor (resistance-factor) transfer


           Chemicals                                                                                                     Page 53








              between organisms should be minimal" as a result                  extensively used in aquaculture, drug-resistant
              of dilution,      low levels of nutrients, low                    strains of the V. parahaemolyticus have never
              temperatures, and high salinity of seawater.                      been found in the environment.

              The technical literature cited above indicates                    Toranzo et al. (1984) reported the transfer of
              several factors.      The occurrence of antibiotic                drug resistance from several bacteria isolated
              resistant bacteria in association with aquaculture                from rainbow trout to the bacterium, Escherichia
              depends on the diversity, frequency, and dosage                   coli. The transfer of resistance was performed
              and     type      of     antibiotic      administration.          under laboratory conditions at 25*C (77*F). The
              Environmental factors including temperature and                   studies demonstrated thc., potential for transfer
              rate of dilution will affect the probability of                   under controlled laboratory conditions.             These
              generating antibiotic resistant bacteria.                         authors concluded that "Responsible use of drugs
                                                                                in aquaculture will aid in minimizing the
              Reports of antibiotic resistance from        Japan (see           development and spread of R+ factor-carrying
              citations    above)     are    from    very     intensive         microorganisms that malt confer drug resistance
              aquaculture      sites    characterized      by     warm          . . . .
              temperatures, high densities of fish grown in
              confined ponds, and the use of a variety of                       The accumulation of antibiotic residues in
              antibiotics not registered for use in the United                  shellfish near fish farms has received some study.
              States.    As well, the dosage and duration of                    In the Puget Sound area, Tibbs et al. (1988)
              antibiotic treatment in Japan appears to exceed                   found that mussels, oystcrs, and clams suspended
              both legal and general practices in the United                    within a matrix of net pens in which coho salmon
              States.    Thus, while these studies document                     were being given food supplemented with OTC
              antibiotic resistance in fish pathogenic bacteria as              had no detectable levels of the antibiotic in their
              a result of the administration of antibiotics, they               tissues. That study examined the phenomenon of
              should not be interpreted to indicate that similar                antibiotic accumulation in shellfish under worst-
              antibiotic resistance will occur under very                       case conditions for the distance between the fish
              different environmental conditions and fish                       pen and shellfish (the shellfish were placed within
              husbandry practices.                                              the matrix of fish pens). Weston (1986) noted
                                                                                the large dilution factor that would occur when
              Importantly, other studies have noted that the                    antibiotics are used in a fish farm.            He,made
              increased level of antibiotic resistance associated               conservative calculations and computed a diluted
              with antibiotic use around fish farms was soon                    level of 3 parts per billion of OTC in a parcel of
              reduced after antibiotic use stopped (Austin 1985;                water passed through a fish pen receiving
              Austin and Al-Zahrani 1988; Aoki et al. 1984).                    medicated feed. Given this dilution factor and
              This phenomenon has also been observed in                         the water-soluble nature of antibiotics like OTC,
              human medicine (Forfar et al. 1966) where                         Weston concluded that there was little potential
              dramatic declines in resistance levels of bacteria                for bioaccumulation of antibiotics used in fish
              occur after antibiotic treatments are stopped.                    farming.

              The possibility of transfer of drug-resistance                    Jacobsen and Bergline (1988) reported the
              factors from a fish disease-causing bacteria to a                 persistence of OTC in sediments from fish farms
              potential human disease-causing bacteria, Vibrio                  in Norway.         These authors also conducted
              parahaemolyticus, was investigated in Japan                       laboratory tests and contluded that the half-life
              (Hayashi et al. 1982). Using test tube conditions                 (time required for a given concentration to decay
              and temperatures of about 86*F to 96*F, these                     to 50% of the starting concentration) for OTC in
              authors were able to transfer drug resistance to                  marine sediments was about 10 weeks, but would
              V. parahaemolyticus. These authors also noted                     likely depend on sediment type and other factors.
              that in Japan, where antibiotics have been                        They examined sediments from underneath four


              Page 54                                                                                                           Chemicals









            farms, but did not report the duration or                        difficult to make generalizations, their study
            quantities of OTC applied at each location. OTC                  indicated that two freshwater fisheries they
            was found in sediments from the four farms at                    monitored did not produce "a major imbalance in
            levels from 0.1 to 4.9 mg/kg (ppm [parts per                     the aquatic bacterial communities."
            million]) of dry matter at up to 12 weeks
            following the administration of antibiotic. This                 Romet is a relatively new antibiotic on the fish
            level would potentially be high enough to inhibit                farming scene. The approved dosage and length
            marine    bacteria     (1-2   ppm      is    considered          of treatment is one-half that of OTC. Therefore,
            inhibitory), including vibrios. However, since the               one would expect its effects to be significantly
            concentration is reported relative to dry weight,                less than that of OTC. The use of vaccines has
            it overestimates the actual concentration in                     been effective in reducing the amounts of Romet
            hydrated sediment. The study does demonstrate                    or OTC used in fish farms.
            that measurable OTC can accumulate below fish
            farms.      Conservatively, the study can be                     Antifoulants. Organic tin compounds, known for
            interpreted to show the highest concentrations                   their toxicity to marine invertebrates (Hall and
            were just above inhibitory levels on a dry-weight                Pinkney 1985) and salmon (Short and Thrower
            basis. The authors also noted that the oxidation                 1987), were once used in Washington. Their use
            state of the sediments would affect the half-life                for most purposes is now prohibited by State
            of OTC. In a preliminary study conducted in the                  legislation.   Therefore, organic tin antifoulants
            Puget Sound region, no OTC was found in                          are no longer used by the fish farming industry
            sediments near fish farms (Wekell 1989).                         in Washington. Their use has also been virtually
                                                                             eliminated in fish farming in other parts of the
            The Wekell (1989) study included the analysis of                 world.    No other chemical means of reducing
            shellfish tissues placed near fish farms in Puget                fouling on nets is in use.
            Sound for the presence of OTC.                 In this
            preliminary study, no OTC was detected in the                    In Norway, netting containing copper wire is used
            shellfish tissues.                                               to reduce fouling, and in British Columbia, waxy
                                                                             antifouling compounds have been used recently
            An Environmental Assessment of OTC by the                        for the same purpose.
            FDA (USFDA 1983)         concluded that "the use of
            OTC is beneficial to     control diseases in aquatic             5.4.2       Impacts of Chemicals
            environment and does     not pose adverse effects on
            this compartment.       However, steps should be                 Although some technical details require further
            developed to avoid the emergence of drug-                        study, the issues surrounding antibiotic use in fish
            resistant organisms."                                            farming have received detailed study.             Those
                                                                             studies demonstrate that antibiotics will be
            Accumulation of antibiotics in marine sediments                  released into the environment when used as a
            is also a function of the dilution factor (which                 medication for farmed fish. Antibiotics have not
            determines the level of antibiotic reaching the                  been detected in       shellfish held near salmon
            sediment), biotransformation of the compound in                  farms.         One      Norwegian       study      found
            the sediment, oxidation state of the sediment, and               concentrations     of one       antibiotic   close     to
            water solubility of the antibiotic. Levels of OTC                inhibitory    levels    in    four    farms.         The
            such as those calculated by Weston (1986) to                     concentrations of      antibiotics outside of the
            reach sediments are not likely to have inhibitory                immediate proximity of the fish farm are
            effects on non-pathogenic bacteria, which are                    regarded by most authors as being too low to
            little affected at levels below 1 ppm (Carlucci and              have adverse effects.
            Pramer 1960). In their study of the microbial
            quality of water in intensive fish rearing, Austin
            and Allen-Austin (1985) note that while it is


            Chemicals                                                                                                        Page 55








             The presence of plasmids, a mechanism by which                is one key environmental factor that will prevent
             bacteria transfer resistance, is documented in                the laboratory-documented resistance transfer
             pathogenic     and     native    aquatic      bacteria.       from occurring in association with salmon farms
             Antibiotic resistance has been recorded in                    in Puget Sound.
             bacteria around fish farms. Most of the technical
             literature describing antibiotic resistance in fish           5.4.2.1          No-Action Alternative
             pathogenic bacteria is based on studies of                                     Existing Regulations and
             aquacultural     practices     and      environmental                          Guidelines
             conditions not comparable with salmon farming in
             the Puget Sound region.           These conditions            The following    existing regulations and guidelines
             include high temperatures, high densities of fish,            affect the potential impacts of chemicals:
             close proximity of multiple farms, and use of a
             variety of antibiotics not used in fish farming in                     FDA is charged with regulating the safety
             the United States.      Conditions in the studies                      of food fish. FDA has an active research
             reporting    antibiotic    resistance     favor     the                and regulation program aimed toward
             development of resistance.          In comparison,                     determining and implementing food safety
             salmon farming in the Puget Sound region is                            requirements.        Procedures      involving
             much less likely to favor development of                               efficacy, toxicity, and chemical residues
             antibiotic resistance due to lower densities of fish                   are   required    for    the   licensing     of
             farms, fewer antibiotics in use, and lower water                       antibiotics for use on food animals.
             temperatures.     In addition, federal regulations
             that apply to the use of         antibiotics in fish                   The Interim Guidelines mention organic
             farming in the   United States   appear to be much                     tin compounds and the use of FDA
             more stringent  than those that apply in Japan and                     approved antibiotics.      Other than the
             Europe, where most of the technical literature                         licensing of these antibiotics, there are
             has originated.                                                        presently no State standards for the use of
                                                                                    antibiotics at fish farms.
             Shellfish held    within a fish farm did not
             accumulate detectable levels of OTC.              This        5.4.2.2          Preferred Alternative
             observation, and the calculated dilution of
             antibiotics away from fish farms, suggest that any            Some risk of adverse impacts exists.             These
             quantities of antibiotics accumulated in shellfish,           impacts can be effectively, managed by taking the
             or   other    benthic     or    planktonic     marine         following recommended steps:
             invertebrates would be below levels of concern.
                                                                                0   Vaccination     by     effective     protocols
             The lack of   antibiotic resistance in a potential                     currently in  place will reduce the use of
             human disease-causing bacteria such as V.                              antibiotics. It is recommended that an
             parahaemolyticus in Japan, despite the extensive                       educational   program be undertaken for
             use of antibiotics in aquaculture there, indicates                     fish farmers  on the use of vaccination.
             the transfer of    drug resistance from fish to
             human pathogenic    bacteria is unlikely. It appears               0   Fish farms should report antibiotic use to
             such transfer is a laboratory phenomenon that                          a State regulatory agency.
             requires highly controlled conditions and is not
             representative of phenomena that occur in the                      0   Appropriate State agencies    should present
             environment. The Toranzo et al. (1984) study                           educational programs for fish farmers on
             further demonstrates the potential for drug                            the use of antibiotics.
             resistance transfer under controlled conditions
             (77*F). The lower temperature range found in
             Puget Sound (and required for salmon farming),


             Page 56                                                                                                    Chemicals











                   Further research should be undertaken to
                   verify that shellfish held near fish farms                In addition to the commercial fishing industry,
                   in various environments do not accumulate                 recreational fishing is a major activity gaining
                   significant levels of antibiotic, as well as              increased emphasis. In 1986, about 1.2 million
                   research     to    establish    any     potential         angler trips were made to catch 830,000 salmon,
                   amounts of the antibiotic in sediments                    and 1.8 million trips were made to harvest 4.6
                   npar fish farms in Puget Sound.                           million lb of clams, oysters, crab, and shrimp. In
                                                                             addition, 756,000 marine fish were taken by boat-
           5.4.3        Mitigation Measures and                              based sport fishers.
                        Unavoidable Significant
                       Adverse Impact                                        The following are some of the species and
                                                                             important habitats that could be affected by fish
           No significant environmental impacts were                         farms:
           identified under the legal use of antibiotics in
           fish farming in Puget Sound.           However, since             Clams and Oyster . A variety of clams are found
           some risk of drug resistance can result from                      on intertidal beaches and subtidally to about 21
           improper and excessive antibiotic use, all use of                 m (70 ft) in Puget Sound.                 Butter clam
           antibiotics should be conducted in a controlled                   (Saxidomus       gigantens),       littleneck       clams
           and documented manner.                                            (Protothaca staminea and Tapes japonica), and
                                                                             horse clam (Tresus capax) are found in dense
           If the     recommendations         in   the Preferred             beds in substrates of mixed mud, sand, and
           Alternative are adopted, they, in conjunction with                gravel. There are an estimated 84 million kg
           existing regulations, would be adequate to avoid                  (170 million lb) of clams in beds covering.about
           significant adverse impacts.            No additional             5,400    acres.       Geoduck      clams    are     taken
           mitigation measures are necessary.                                commercially from depths of 6 to 18 m (18-60 ft),
                                                                             but they occur at     depths of at least 110 m (360
           5.5          FOOD FISH AND SHELLFISH                              ft). Subtidal sand    and mud provide major habitat
                                                                             for geoducks. About 34,000 acres of geoduck
           This issue  concerns the potential effect fish farms              beds     exist    in    Puget     Sound       containing
           may have    on existing fish and shellfish resources              approximately     30,000 metric tons of clams.
           in Puget    Sound. There is concern that farms                    Approximately 1,800-2,300 MT (4-5 million lb) of
           may cause a degradation of commercially valuable                  geoducks are     harvested annually at a value of
           species and potentially affect sensitive habitat.                 about $5 million.

           5.5.1        Affected Environment                                 Two oysters are found in Puget Sound, the native
                                                                             oyster (Ostrea lurida) and the imported Pacific
           There are several commercially valuable species                   oyster (Crassostrea gigas). Oysters are generally
           of food fish and shellfish harvested in Puget                     limited to intertidal beaches where they would
           Sound. Commercial landings of salmon average                      not be directly affected by fish farms.               All
           44 million pounds (20,000 MT) per year in Puget                   commercial oyster harvest is from farmed beds
           Sound. Marine fish landings average 5000 metric                   that also provide the basis for populations on
           tons (11 million lbs) and shellfish landings                      recreational beaches.
           average 5.6 metric tons (13 million lbs). The
           total landings of all species in Washington have                  Octopu . The giant octopus (Octopus dofleini)
           a process value of around $300 million (Ward                      prefers rocky, high current areas for spawning
           and Hoines 1987).          The size of commercial                 and foraging. They appear to feed on any fish or
           fishing industry and the potential impacts of fish                invertebrate they can catch. They are commonly
           farms on the industry are discussed in Section                    harvested from soft bottom areas by traps
           6.3, Commercial Fishing.                                          (Mottet 1975).


           Food Fish and Shellfish                                                                                            Page 57









             Sea Urchins. Two commercially harvested sea                 the same basic rearing and migrational patterns
             urchins occur in Puget Sound waters: the red                of salmon but spend less time in Puget Sound as
             urchin (Strongylocentrotus franciscanus) and the            juveniles. Searun cutthroat are different in this
             green urchin (S. droebachiensis). They occur at             regard since they normally remain in Puget
             depths extending from intertidal to depths of               Sound. They live primarily in and around river
             several hundred feet, generally on rock and other           mouths as adults.
             solid substrates, but also use soft substrates.
             Urchins tend to eat algae, but use many food                Herrin . Pacific herring (Clupea harergus pallasi)
             sources including dead animals and algae. They              occur throughout Puget Sound.         These pelagic
             will also eat organic matter discharged in sewage           fish spawn from late winter through spring in
             (Mottet 1976).                                              eelgrass and algae beds at certain locations.
                                                                         Herring tend to spawn each year in the same
             Crab and Shrim          Dungeness crabs (Cancer             areas, some of which have been mapped by WDF.
             magister) and red rock crab (Cancer productus)              All such areas are intertidal to shallow subtidal
             are common predator/scavengers of Puget Sound               (about -20 ft MLLW) although herring spawn
             feeding on small clams, worms and other                     have been found as deep as 40 ft (Haegele et al.
             organisms.   Both use intertidal and nearshore              1981).
             areas as nursery areas with adults found in
             nearby water offshore. Dungeness crabs are the              Juvenile   herring    are   commonly found in
             primary species harvested commercially and                  nearshore waters during spring and summer.
             recreationally, and are most abundant north of              These pelagic fish migrate in large schools,
             Everett and in Hood Canal. Red rock crab are                gradually moving into offshore waters as they
             found throughout Puget Sound. Seven species of              grow. Adult herring occur throughout the deeper
             shrimp such as the spot prawn (Pandalus                     waters of Puget Sound at most times of the year.
             platyceros), coonstripe shrimp (P. danae), and              Herring are harvested for both food and bait.
             sidestripe  shrimp    (Pandalopsis dispar)        are
             harvested in Puget Sound. They are generally                Smelt.    Surf smelt (Hypomesus pretiosus) are
             harvested from soft bottom areas although                   pelagic fish that spawn on some intertidal
             coonstripes are common in rock riprap areas.                beaches in Puget Sound at tidal heights of about
             Shrimp are also predator/scavengers feeding on              + 7 to + 13 ft MLLW. They spawn throughout
             small organisms in the sediments.                           the year on beaches of' coarse sand to small
                                                                         gravel (Penttila 1978).
             Salmonid . Five species of Pacific salmon are
             present, at times, in Puget Sound. These include:           Pacific Sand Lance.           Pacific sand lance
             chinook (Oncorhynchus tshawytscha), coho (0.                (Ammodytes hexapterus) are common and live in
             kisutch), chum (0. keta), pink (0. gorbuscha), and          a number of habitats in Puget Sound. They can
             sockeye (0. nerka). Juveniles, after rearing in             be found offshore, in shallow water, and partially
             freshwater, forage on small epifaunal and                   buried in beach sand. Adults feed mainly on
             planktonic organisms in shallow nearshore areas.            copepods but also on other organisms of similar
             Most salmon migrate out of Puget Sound as                   size (Hart 1980).
             juveniles to forage in the open ocean, although
             some coho and chinook remain in Puget Sound                 Lingcod. Lingcod (Ophfodon elongatus) spawn
             year-round. Adults migrate through Puget Sound,             preferentially in rocky areas in the winter, and
             concentrating near points of land and river                 juveniles use nearshore areas as nursery grounds.
             mouths.                                                     They are found from intertidal depths to the
                                                                         deepest portions of Puget Sound. Lingcod are a
             Two species of anadromous trout are present in              bottom-oriented fish that prey on other fish and
             Puget Sound waters: steelhead (0. mykiss) and               large invertebrates.
             searun cutthroat (0. clarkii). Steelhead follow


             Page 58                                                                                  Food Fish and Shellfish









           Rockfish. Rockfish of many species are taken                   Weston       (1986)     reported      that      mobile
           both commercially and recreationally.            Many          predators/scavengers are attracted to the area
           species of rockfish are found in Puget Sound.                  around aquaculture facilities to feed on excess
           They occur from shallow subtidal depths to the                 food and on the small organisms, including
           deepest portions of the Sound. Although they                   opportunistic worms, which are enhanced around
           are often associated with rocky areas, they are                the farm.    Weston's review reported increased
           found near all bottom types. They are predators                densities of crab, flatfish, starfish, perch, lobsters
           of other fish and large mobile invertebrates.                  and other predators and surface feeders from
           They are often attracted to submerged structures               sites around the world. In Puget Sound, Pease
           such as artificial reefs.                                      (1977, 1984) observed increased numbers of crab,
                                                                          and various fish around farms and mussel rafts.
           Perch.    There are three seaperches that are                  It is likely that shrimp numbers near farms will
           common in Puget Sound, the pile perch                          also increase.
           (Rhacochilus    vacca),     the   striped     seaperch
           (Embiotoca lateralis) and the small shiner perch               The farm structures also provide a habitat in the
           (Cymatogaster aggregata).      Perch are harvested             open water environment to attract fish such as
           both commercially and by sports fishermen. Each                surfperch and rockfish in larger numbers than
           of these species inhabits nearshore areas and are              would normally be found in an open-water
           often attracted to submerged structures.                       portion of Puget Sound.        Fish farms and their
                                                                          floats also provide a substrate on which algae and
           Cod.    Pacific cod (Gadus macrocephalus) are                  invertebrates grow, providing a food source that
           harvested by sports fishermen in Puget Sound.                  increases the attraction of various fishes. These
           Although they may be found at times throughout                 organisms, along with waste food, would provide
           the deeper waters of Puget Sound, they are                     an available food source attractive to many fish.
           harvested primarily from channels where they
           congregate to spawn in late winter. The sports                 Floating objects apparently protect small fish
           and commercial harvest of cod in Puget Sound is                from predation (Mitchell and Hunter 1970). In
           about 160,000 kg (350,000 lb) annually.                        Japan, floating structures have been used
                                                                          intentionally to attract fish, and in Puget Sound,
           Flatfish. Flatfish of many species occur     in Puget          artificial reefs of rock and concrete have been
           Sound.    These fishes reside at essentially all               constructed    to   provide    vertical   relief and
           depths on the mud and gravel bottoms. They are                 substrate for benthic organisms. Fish associated
           harvested by both         commercial and sport                 with farms in Puget Sound include shiner perch
           fishermen. Many species use shallow nearshore                  and other surfperch, true cod, lingcod, dogfish,
           areas of nursery grounds.                                      sculpins, and flatfish.

           5.5.2       Impacts on       Food Fish and                     Fish and mobile invertebrates are expected to be
                       Shellf-ish                                         attracted to the periphery of fish farms, unless
                                                                          organic deposition results in anoxic conditions in
           The primary impacts floating fish farms are likely             the water. This is only likely in areas with very
           to have on food fish and shellfish populations are             poor circulation (Earll et al. 1984). This effect
           the result of the farm structure and sedimentation             would be self limiting in that anoxic conditions
           that may occur under the farm. The effects of                  would have the same adverse impacts to the fish
           sedimentation upon the benthic- community have                 farm as they would to wild fish.
           been discussed in Section 5.1, Bottom Sediment
           and Benthos.        In general, at low rates of                Fish and shellfish could also be adversely affected
           deposition, filter  feeders such as clams will be              by the deposition of organic sediments upon
           enhanced, but at    high levels immobile organisms             important habitats. Clams and geoducks occur in
           will be displaced   from the area below the farm.              dense beds. A farm directly above such a bed in


           Food Fish and Shellfish                                                                                       Page 59









             shallow water could create an azoic zone                                   2.   Restore    the productive capacity of
             immediately below the farm, killing all the                                     habitats  that have been damaged or
             shellfish    within    this   zone.        In    addition,                      degraded by natural causes, or as a
             sedimentation over spawning areas (such as for                                  result of  human activities.
             lingcod and octopus) could smother eggs and
             eliminate the area for future spawning use. For                            3.   Improve    the productive capacity of
             many species, the availability of spawning habitat                              existing    habitat    and create        new
             determines the ultimate abundance of the species.                               habitat.
             Other species may have different habitats that
             are critical to specific life stages, which could be                       WDF has the authority to "preserve,
             adversely affected by sedimentation.                                       protect, perpetuate, and manage. . ." food
                                                                                        fish and shellfish :resources (RCW 75.08).
             The depths of water regulated for fish farms                               This authority can be used to protect
             preclude direct impacts to intertidal shellfish and                        habitat not explicitly covered under the
             fish habitats.                                                             Hydraulic Code.

             5.5.2.1           No-Action Alternative                                    As proprietary manager of state-owned
                               Existing Regulations and                                 aquatic lands, D'NR is concerned with
                               Guidelines                                               impacts to shellfish resources on these
                                                                                        lands.     DNR evaluates the impacts of
             The following     existing regulations and guidelines                      proposed leases to shellfish and other
             affect the potential impacts of fish farms on food                         aquatic land uses. When necessary, siting
             fish and shellfish:                                                        and operational adjustments may be
                                                                                        required to protect shellfish resources. In
                      WDF or WDW require                a   Hydraulic                   cases where shellfish productivity is lost,
                      Project Approval (HPA) permit for                                 reimbursement will be required.
                      virtually all work within the     ordinary high
                      water mark of fresh or salt       waters in the                   Ecology administers a water quality anti-
                      State of Washington (RCW 75.20). The                              degradation policy through the NPDES or
                      WDF issues nearly all permits in areas                            State     Waste       Discharge       permitting
                      accessible to salmon. The HPA provides                            programs. This policy prevents impacts
                      WDF with permitting authority to ensure                           to existing beneficial resources including
                      that fish farm proposals do not have a                            existing food fish and shellfish resources
                      significant adverse impact on food fish                           (WAC 173-@01-03'5).
                      and shellfish species, or their habitats.
                                                                                        The SEPA review process provides all
                      The      objective     of     WDF         habitat                 State     resource      agencies     with      an
                      management policy is to achieve a net                             opportunity to review individual fish farm
                      gain in the productive capacity of food                           proposals on a catse-by-case basis. This
                      fish and shellfish habitat in Washington.                         mechanism allows each proposal to be
                      This objective is achieved by pursuing                            evaluated      using    the    most       current
                      three goals:                                                      information    available for a specific site.

                      1. Maintain       the     present    productive                   The Interim     Guidelines recommend that
                          capacity of all food fish and shellfish                       fish farms should not be sited where they
                          habitat.                                                      are likely to adversely affect habitats
                                                                                        important to commercial or sport food
                                                                                        fish or shellfish fisheries, that are of
                                                                                        critical ecological importance, or that are


             Page 60                                                                                           Food Fish and Shellfish









                   especially sensitive to degradation by                         The habitats identified in the Interim
                   culture activities. The Guidelines identify                    Guidelines should be included in the
                   WDF as the agency with expertise and                           appropriate WACs as habitats of special
                   responsibility for the designation of and                      significance.
                   assessment     of    impacts      on     plant,
                   invertebrate, and fish habitats of special                     A case-by-case evaluation of the need for
                   significance.                                                  buffer zones around habitats of special
                                                                                  significance should be incorporated into
               ï¿½   The Guidelines establish a buffer zone                         WACs. The distances discussed in the
                   around habitats identified by WDF as                           Interim Guidelines should be used as a
                   being of special significance.       In areas                  reference.
                   where water depths are less than 75 ft, a
                   distance of 300 ft in the direction of                 5.5.3       Mitigation Measures and
                   prevailing tidal currents and 150 ft in all                        Unavoidable Significant
                   other directions should separate farms                             Adverse Impacts
                   from habitats of special significance.
                   Habitats that have been defined by WDF                 The SEPA process provides State agencies with
                   as of special significance are listed in the           an opportunity to assess potential impacts of
                   Guidelines. These areas include eelgrass               floating fish farms on food fish and shellfish on
                   and kelp beds, rocky reef habitats,                    a case-by-case basis using the most current
                   habitats with significant geoduck and                  available information for a specific site.           In
                   hardshell    clam    populations,      habitats        addition to the use of existing regulations,
                   important to Dungeness crab, herring, and              adoption of the measures identified in the
                   other species of fish. Other habitats may              Preferred Alternative would avoid significant
                   be    determined      to   be    of     special        adverse impacts to food fish and shellfish
                   significance as determined on a case-by-               resources. No additional mitigation measures are
                   case basis through SEPA review.                        necessary.

               ï¿½   In addition to the habitats of special                 5.6         IMPORTATION OF NEW
                   significance, the Guidelines also address                          FISH SPECIES
                   sedimentation impacts to the benthos
                   which affects food fish and shellfish                  Commercial farming of fish frequently involves
                   habitat. See the discussion of the depth               the use of species not indigenous to the area or
                   and current guidelines in Section 5.1,                 specifically bred for use in fish farms. There is
                   Bottom Sediments and Benthos.                          a concern that Atlantic salmon would escape
                                                                          farms and compete directly with native Pacific
               ï¿½   The Guidelines also recommend that a                   salmon populations.
                   diver survey be performed at a proposed
                   farm site to help identify habitats of                 5.6.1       Affected Environment
                   special significance.       DNR presently
                   requires information from this diver                   Fish farming in Washington State is presently
                   survey as part of its Aquatic Lands Lease              limited to coho, chinook and Atlantic salmon and
                   application.                                           steelhead trout. In the future, other species may
                                                                          be employed if market conditions and culture
          5o5.2.2          Preferred Alternative                          technology permit profitable culture.               For
                                                                          example, culture technology for turbot, halibut,
          In addition to the use of existing regulations, it              cod, eel and other cold-water species of fish are
          is recommended that the following measures be                   being developed in Europe and Asia.          Some of
          undertaken:                                                     these species may eventually be economically


          Food Fish and Shellfish                                                                                        Page 61








             feasible for culture in Puget Sound.          Atlantic        plants in small lakes, and the Pacific (Japanese)
             salmon are presently the species of choice for the            oysters - the basis of the state's oyster industry,
             salmon aquaculture industry in Europe and                     etc.   Accidental introductions have also been
             Washington State. This preference is due to the               common. For example, a variety of invertebrates
             established marketability of Atlantic salmon, and             have been introduced around the world as fouling
             their adaptability to cu-Iture (for example,                  organisms attached to the hulls of ships or
             tolerance to high density stocking and resistance             released with the discharge of ballast water.
             to disease).
                                                                           5.6.2       Impacts of Importation of New
             As with all new introductions, the importation of                         Fish Sped I
             any plant or animal, terrestrial or aquatic, may
             pose a threat to native species if released into              General.   The introduction of a new species into
             the wild.    Many introductions of new species                an area always poses unavoidable risks. While
             worldwide have led to ecological disasters. Not               risks can be minimized, all introductions involve
             only might the animal itself spread unchecked,                a level of unpredictability and environmental risks
             but diseases these animals may carry might be                 cannot be completely eliminated.
             spread to native species (see Section 5.8,
             Disease). . Therefore, new species imported to                Perhaps the greatest movement of fish species in
             Washington must be screened, evaluated, and                   history is occurring due to the development of
             monitored with the utmost precaution.              The        fish farming. Rainbow trout, native only to the
             actual risk of harmful impacts to native species              western United States, is the foundation of the
             depends upon the species proposed for culture                 European trout industry. African tilapia is grown
             and the culture system.      Given the number of              all over the world.          Pacific salmon from
             species considered for culture it is impossible to            Washington are being farmed in eastern Canada,
             examine their possible interactions with native               Chile, New Zealand, and Japan. Atlantic salmon,
             fish stock. As an example of the possible genetic             the basis for the salmon farming industry, is now
             interactions and possible mitigation measures, the            grown in the northeast Pacific.
             introduction of Atlantic salmon into Puget Sound
             will be evaluated.                                            Atlantic Salmon. The potential for impacts from
                                                                           introducing Atlantic salmon to Puget Sound
             While the introduction of new fish species into               depend on two variables:        (1) that significant
             habitats far removed from their native ranges has             numbers of fish escape from fish farms, and (2)
             provided    man     with    many    benefits,     each        the ability of fugitive fish to outcompete resident
             introduction poses a risk to the indigenous                   stocks of salmon and stzelhead. Two hundred
             aquatic organisms of the new environment. Fish                and five Atlantic salmon were reported captured
             and shellfish have been and continue to be                    in 1988, and only twenty-five have been reported
             introduced into new areas for several reasons.                thus far in 1989.     There is a strong economic
             They increase sport and commercial fishing                    incentive to prevent this escape given that smolts
             opportunities and replace native stocks decimated             are worth around $3 each and a harvestable fish
             by disease, environmental changes, or over                    may be worth over $60 to the grower.
             harvest.    Fish and shellfish have also been                 Technology in fish farm engineering is developed
             introduced in new areas to.control pests and for              to the point where such. catastrophic structural
             commercial culture.                                           failure is rare. There aire, however, uncontroll-
                                                                           able events, such as ships straying from shipping
             Examples in Washington include the introduction               lanes or perhaps a 1,000-year storm event, which
             of Atlantic trout and salmon species into                     may break up farms. However, fish farms are
             freshwater lakes and streams for sport fishing,               normally placed well out of shipping lanes and in
             mosquito fish (Gambusia) for insect control in                relatively calm waters.      The major source of
             eastern Washington, grass carp to control aquatic             escapement appears to be from "leakage" where


             Page 62                                                                            Importation of New Fish Species








           a few fish at a time escape through small hole's                   addition, over the past       12 years about 3,000
           in the nets or during handling and transfer. The                   Atlantic salmon have         escaped from NMFS
           most critical stage may be as smolts, when there                   research farm at Clam Bay in Puget Sound.
           is a wide range in fish size, are introduced into                  These escaped fish were     sea-conditioned Atlantic
           the farm. If the mesh size of the net is too                       salmon weighing between      0.5 and 13 lbs (Waknitz
           large, or if it is an old net with small holes,                    1988 personal communication).                In 1988,
           some of these small fish may pass through.                         commercial salmon boats reported picking up
                                                                              Atlantic salmon in their nets while fishing in
           An ecological threat to Pacific salmon and           trout         northern Puget Sound and a few fish were
           is theoretically possible should Atlantic salmon                   reported caught by Canadian trotters of the west
           establish a wild run in Washi@gton waters.                         coast of Vancouver Island.            All these fish
           Atlantic salmon are reared commercially at 13                      weighed between 4 and 12 lbs. This indicates
           seawater sites in Puget Sound (DNR 1987).                          that Atlantic salmon are escaping from fish farms
           Additional freshwater hatcheries produce smolts                    and surviving in the wild.
           used to stock these farms. All culture opera-
           tions have the potential to make inadvertent                       Occasionally, Atlantic salmon have also been
           releases.     Theoretically, these releases could                  observed in the Nooksak, Skagit, and Nisqually
           establish a wild population of Atlantic salmon in                  Rivers and are being monitored by WDF, WDW,
           Washington.                                                        and tribal fisheries biologists. Lindbergh (1984)
                                                                              estimates that government agencies have released
           There have been scattered, qualified successes in                  about five million Atlantic salmon in British
           maintaining Atlantic salmon populations in fresh                   Columbia, Washington, Oregon, and California
           water (Lindbergh 1984; MacCrummon and Got                          waters.      Despite these propagation efforts,
           1979). Attempts to establish Atlantic salmon in                    intentional and accidental releases of Atlantic
           lakes have been moderately successful in                           salmon into Puget Sound and other northeastern
           Washington and Oregon.              However, Atlantic              Pacific waters have all been unsuccessful in
           salmon have only become established in takes                       establishing     self-sustaining    runs.         Similar
           when planted as the only salmonid species in the                   introductions to establish wild populations have
           system or in combination with brook trout                          also been attempted in 36 countries around the
           (Salvelinus fontinalis).        Atlantic salmon are                world.    The only successful introductions have
           apparently unable to compete with rainbow trout                    been in the Faeroe Islands near Iceland, which is
           (Oncorhynchus mykiss [formerly Salmo gairdneri 1)                  in the natural range of Atlantic salmon, and in
           effectively.     Lindbergh (1984) interviewed a                    southern       Argentina        (Lindbergh         1984;
           number of researchers with WDW, NMFS, and                          MacCrummon and Got 1979). Based on this
           the Oregon Department of Fish and Wildlife                         persistent lack of success in establishing Atlantic
           involved with the take planting programs in                        salmon where other salmonid populations exist, it
           Oregon and Washington. The consensus was that                      is unlikely that they could establish self-sustaining
           rainbow trout clearly dominate the Atlantic                        runs in Washington rivers.
           salmon and that Atlantic salmon would be
           displaced by native trout, if not naturally, then                  5.6.2.1          No-Action Alternative -
           from continual restocking by the various natural                                    Existing Regulations and
           resource agencies.                                                                  Guidelines

           In the past, WDF and WDW have released                             The following    existing regulations and guidelines
           Atlantic salmon into Washington waters with the                    affect the impact of introducing a new species.
           intention of establishing permanent runs. They
           released Atlantic salmon smolts into two Puget                             Federal law (CFR 16.13, Title 50)
           Sound tributaries: Chambers Creek in 1950 and                              prohibits the entry of live fish or eggs of
           Minter Creek in 1980 (Lindbergh 1984).                  In                 salmonids unless such importations are by


           Importation of New Fish Species                                                                                     Page 63









                    direct shipment, accompanied by a                              (RCW 75.08). This authority can be used
                    certification that the importation is free                     to prevent the intrc)duction of species that
                    of the protozoan MyNosoma cerebalis and                        could have an advrrse impact on existing
                    the virus      causing viral hemorrhagic                       food fish and shellfish species.
                    septicemia (VHS). This certification must
                    be signed by a fish pathologist recognized                     The SEPA process provides WDF with
                    by the Department of Interior.                                 the opportunity to review individual fish
                                                                                   farm proposals on a case-by-case basis.
                 ï¿½  In addition to Title 50 requirements,                          This mechanism allows WDF to evaluate
                    WDF prohibits importation of any live                          each f'arm proposal[ with the most current,
                    salmonid product, save that of inspected                       available information.     In addition, the
                    eyed eggs and sperm from outside North                         SEPA process allows WDF to assess
                    America. Where eggs are being imported                         potential impacts of the proposed fish
                    into Washington, WDF also requires that                        stock to be raised in relation to a specific
                    the Title 50 inspector in the country of                       site.
                    origin send laboratory tissue and fluid
                    samples from the broodstock from which                5.6.2.2          Preferred Alternative
                    the eggs will be derived to WDF for
                    examination for pathogens.                            Existing regulations shoulld continue to be used
                                                                          to manage the introduction of new species to
                 ï¿½  WDF requires a Finfish Import/Transfer                Washington. No further recommendations are
                    Permit for importation of any aquatic                 being made.
                    organism into the State for culture
                    purposes, or for any transfer of these                5.6.3        Mitigation Measures and
                    organism within the State (WAC 220-77-                             Unavoidable Significant
                    030). The purpose of this permit is to                             Adverse Im acts
                                                                                                     jL---
                    ensure that diseases, pests, or predators
                    are not introduced into State waters. In              The use of existing regulations to control the
                    addition, a Fish Health Certificate, issued           introduction of new species for commercial
                    by a WDF-recognized fish pathologist,                 culture in Washington -is adequate to avoid
                    must accompany all import or transfer                 significant adverse impacts to indigenous species
                    operations. On-site inspections are made              of food fish and        shellfish in the State of
                    by WDF staff at fish farms to @ monitor               Washington.       The SEPA review and HPA
                    compliance with provisions and conditions             permitting processes   allow case-by-case evaluation
                    prescribed in import/transfer permits.                of proposals and no further programmatic
                                                                          mitigation measures    are necessary.
                 ï¿½  WDF requires a Hydraulic Project
                    Approval (HPA) permit for virtually all               5.7          GENETIC ISSUES
                    work within the ordinary high water mark
                    of salt waters in Washington (RCW                     There are two major issues involved in the
                    75.20). The HPA process provides WDF                  potential genetic impacts that fish farms may
                    with permitting authority to ensure that              have on wild salmon populations. The first is
                    any species proposed for culture in a fish            the    potential    impact     non-native      species,
                    farm would not have a significant impact              specifically Atlantic salmon, may have on wild
                    on indigenous populations.                            populations of native salmon. The second is the
                                                                          potential genetic impact of rearing native Pacific
                 ï¿½  WDF has the authority          to "preserve,          salmon in fish farms. The relationships of these
                    protect, perpetuate, and manage..." food              two different situations to existing conditions are
                    fish and shellfish resources in Washington            quite different, thus the potential for genetic


           Page 64                                                                             Importation of New Fish Species









           impacts are quite different.         The following           propagated with fish this way after major natural
           discussion describes how these two situations                disasters in the river system, such as landslides
           relate to existing conditions.                               and volcanic eruptions. In nature, the incidence
                                                                        of straying is limited, thus new genetic traits can
           5.7.1      Affected Environment                              be incorporated into an existing population
                                                                        without diluting the existing genetic traits.      If
           Only Pacific salmon and not Atlantic salmon are              large populations of genetically distinct fish were
           present as wild populations in the Puget Sound               to interbreed, then such dilution could occur.
           region. These wild populations are supplemented
           by State and federal hatcheries that release more            In some special cases, farmed Pacific salmon may
           than 100 million juvenile fish into Puget Sound              or may not be grossly different from stocks in
           waters each year.     Nearly all wild populations            adjacent rivers.    This variation could lead to
           have intermixed to some degree with hatchery-                interbreeding with indigenous populations. While
           reared fish. Existing hatchery practices will allow          speculative in nature, there are theoretical
           this intermixing to some          degree for the             grounds for this concern.
           foreseeable future.
                                                                        One concern is the potential for wild populations
           Local experts agree that widespread farming of               to be genetically altered by genes from Pacific
           Pacific and Atlantic salmon in Puget Sound poses             salmon farm escapees that are inappropriate for
           a minimal threat to wild salmon populations in               natural conditions.     There are two potential
           terms of genetic degradation (Mahnken 1988;                  sources of Pacific salmon for fish farms that may
           Hershberger 1988; Waples 1988). The subject is               be grossly different genetically from wild fish.
           somewhat complex, however, and will be                       One source might be fish from a river system
           discussed below in some detail.                              that is geographically distant and environmental-
                                                                        ly different from the river system closest to the
           Different river systems generally have genetically           farm site.   The other source might be Pacific
           different stocks of Pacific salmon. Because the              salmon from a nearby river system that are highly
           characteristics of each river are unique, selective          inbred due   to long-term genetic manipulation
                                                                        within a hatchery environment.
           pressures on the populations in those rivers have
           lead to genetic adaptations that favor their
           survival. For example, salmon that spawn in the              In hatcheries, fish are actively or passively
           upper reaches of long river systems (for example,            selected for many genetic traits suiting them to
           the Fraser or Columbia) must make much longer                that environment. These traits may be useless or
           journeys to spawn than salmon from shorter river             even harmful in the natural environment. Passive
           systems, such as those of Puget Sound. Thus,                 selection includes such traits as tolerance to
           fish from the upper reaches of longer river                  crowding, stress, disease, low water quality,
           systems have become more robust and store                    reduction in fright susceptibility and aggressive
           larger amounts of energy in order to sustain the             behavior, and adaptation to hatchery diets. For
           long journey. Because introduced fish lack the               example, aggressive behavior is a waste of energy
           energy reserves to make the entire trip to spawn,            to a'hatchery fish. In the wild, it is a necessary
           attempts to stock these upper reaches with fish              behavior pattern. Traits actively selected for in-
           from shorter rivers have been unsuccessful.                  breeding programs, such as egg size, flesh color
           Therefore, there is concern that if distinct fish            and taste, fat content, and maturation rate, have
           stocks mix, important adaptive genetic traits                no use in wild conditions. Traits such as rapid
           would be diluted.                                            growth rates are only beneficial when food is very
                                                                        abundant. Where food is limited (as is usually
           Some interbreeding of Pacific salmon stocks                  the case in the wild), this trait might be
           occurs naturally as fish stray from one river                detrimental. However, a large portion of salmon
           system to another.     Rivers are often naturally            in the North Pacific are from hatchery stocks. In


           Genetic Issues                                                                                            Page 65









             the natural environment, these fish are exposed                   in trout and Atlantic salmon (Aulstad et al. 1972;
             to all the environmental pressures of wild fish,                  Kincaid 1976a and 1976b; Ryman 1970) it has not
             which will tend to select against genetically                     been documented in Pacific salmon (Oncorhyn-
             maladapted individuals. The successful return of                  chus sp.) This lack of documentation may be due
             these fish to their hatchery streams indicates the                in part to the lack of totally captive (captive
             retention    of sufficient beneficial traits for                  throughout their life cycle) populations of Pacific
             survival.                                                         salmon. The exception is Domsea Farms in Clam
                                                                               Bay,     Washington,      which      has      genetically
             The interbreeding of two grossly different wild                   manipulated coho for over 10 years. However,
             stocks can occur by transplanting eggs from one                   this effort encompasses only seven generations.
             distant river system to another. In the natural
             environment, salmonids tend to evolve into                        The degree of genetic degradation in wild
             genetically discrete stocks adapted to specific                   populations by farm Pacific salmon escapees
             ecological conditions within nearby river systems                 depends on two basic factors: first, the extent of
             with similar geography (such as southern Puget                    genetic difference between the farmed and wild
             Sound).     In fact, there are over 100 stocks of                 fish.    Second, the degree of interbreeding
             chinook salmon in      North America identified as                between the two groups. "Normal" hatchery fish
             genetically discreet (Mahnken 1988; Hershberger                   (released into marine waters, growing to maturity
             1988).    Genotypes (the genetic makeup of an                     in the wild) may be very different from wild
             organism) adapted to one region cannot be                         populations in the vicinity. Frequently, wild fish
             expected to survive as well in a distant region as                are used as supplementary broodstock in WDF
             the genotypes of the resident population.                         and WDW hatcheries; and hatchery fish are
             Therefore, interbreeding of two distant wild                      frequently planted into wild populations. This
             stocks could reduce the fitness of the progeny.                   can result in homogenesis between the two
                                                                               groups.
             Another concern is the high degree of genetic
             variability      within      salmon        populations.           Farm fish differ from "normal" hatchery fish in
             Maintaining this variability may be important to                  that natural selection in the ocean is replaced by
             the long-term fitness (reproductive ability) of wild              artificial selection in the hatchery. This allows
             populations by providing the plasticity they need                 aquaculturists to genetically manipulate the stock
             to survive sudden changes in environmental condi-                 more extensively.      However, farm fish do not
             tions.   Genetic variability may be reduced in                    necessarily have to be very different from wild
             hatchery populations even if random selection is                  fish. Efforts can be made to infuse wild genes
             practiced during spawning.               Nonintentional           into the hatchery population if desired.
             (passive) selection occurs in the form of different
             survival rates, favoring fish best suited for                     The degree of interbreeding between farm
             hatchery conditions.      Since hatchery conditions               escapees and wild fish del   '3ends on the proportion
             are relatively stable, genotypes capable of                       of the two populations within a stream and the
             tolerating environmental extremes are gradually                   spawning times of the two groups. For the farm
             lost.                                                             and wild populations to interbreed, the spawn
                                                                               timing of the two groups must overlap.               The
             Several    studies     have     demonstrated        lower         greater the overlap, the greater the potential for
             variability in hatchery trout stocks (Salmo sp.)                  interbreeding.     If the two groups are widely
             compared to wild stocks (Allendorf and Phelps                     divergent in spawn timing, no interbreeding can
             1980; Ryman and Stahl 1980; Stahl 1983).               In         occur.    The following four factors affect the
             some cases, this condition causes development of                  number of farm fugitives entering any particular
             undesirable traits, such as lower viability            of         stream are the following:
             gametes     (cells capable of participating            in
             fertilization). While this has been demonstrated                          the number of fish escaping


             Page 66                                                                                                    Genetic Issues








                *   the marine mortality rate (determining the              have the genetic capacity to either breed with or
                    number surviving to adulthood)                          outcompete the wild population if they have
                                                                            mixed in sufficient numbers.
                0   the success of homing these fish to the
                    farm site                                               Fish do escape from fish farms, but generally in
                                                                            very low numbers compared to adjacent wild and
                0   the proximity of the farm to the stream of              hatchery populations. Because of these relatively
                    interest.                                               low numbers of escapes, there is little potential
                                                                            for genetic impacts in most situations. However,
           Homing ability in salmonids is influenced                        in the case of a major disaster that destroys fish
           primarily by imprinting on the water odor                        farms, there is a theoretical potential for
           components at the release site (Hasler et al.                    sufficient numbers of fish to escape to cause a
           1978). Imprinting ability is greatest during the                 potential genetic impact, if other conditions are
           smolting period, when juveniles are typically                    also met.
           transferred from freshwater hatcheries to farm
           sites. However, the homing/imprinting process in                 Are escapees likely to survive and return to mix
           salmonids has a genetic factor (Bams 1976). This                 with a wild population on the spawning grounds
           factor may either be diminished or inappropriate                 in sufficient numbers to cause a genetic impact?
           for successful homing in farm fish transplanted                  It does appear that escapees from fish farms
           from distant locations. Such fish, fugitive from                 survive at rates roughly comparable to the
           fish farms, would be expected to stray farther                   survival of hatchery fish. However, few if any of
           than strays from locally derived stocks (Quinn                   these survivors are likely to reach spawning
           1988). It should be pointed out that wild fish                   grounds of wild fish.         In most cases, these
           stray to some degree naturally. Quinn (1988) has                 escapees will return to the location of the farm
           proposed      that   straying    is   a     evolutionary         from which they escaped. Only if this location is
           alternative to homing and that the two processes                 near a spawning stream could any appreciable
           are in dynamic equilibrium.                                      portion of the survivors be expected to stray into
                                                                            the stream. If the escapees were reared in the
           Hatchery trout have demonstrated lower survival                  stream water as juveniles, and held in pens near
           rates than wild trout in the natural environment                 the stream, then major portions of the surviving
           (Chilcote et al. 1985; Reisenbichler and McIntyre                population of escapees would be expected to
           1977). In these experiments, hatchery/hatchery                   enter the stream and mix with the wild
           crosses survived best under hatchery conditions                  population.         Thus,    only     under      unusual
           while wild/wild crosses survived best in natural                 circumstances can a sufficient number of escaped
           streams (Reisenbichler and McIntyre 1977).                       fish be expected to mix with wild fish on the
           Impacts to wild populations would then be                        spawning grounds and provide a real potential of
           temporary and in the form of wasted reproductive                 a genetic impact.
           effort (less fit genotypes would be lost due to
           natural selective pressures).                                    Should escapees mix on the spawning grounds in
                                                                            sufficient numbers the potential impact from
           5.7.2        Genetic Impacts                                     Atlantic salmon and Pacific salmon would be very
                                                                            different. The Atlantic salmon cannot genetically
           For farm-reared fish to have a genetic impact on                 mix with the wild population of Pacific salmon.
           wild salmon populations, three conditions must                   Theoretically, they could establish a natural
           occur.    First, significant numbers must escape                 spawning population of this non-native species.
           from fish farms.        Second, the escapees must                Such a theoretical population could compete with
           survive and return to mix with a wild population                 the wild population. Thereby, reducing the wild
           on the spawning grounds in sufficient numbers to                 population to a sufficiently low level that a
           affect wild populations. Third, the escapees must                genetic component is lost from this wild

           Genetic Issues                                                                                                   Page 67








            population. However, past experience indicates                    0   Escapement rate from "leakage" = 0.5%
            that Atlantic salmon are not capable of effectively                   (Forster 1989 personal communication)
            competing for Pacific salmon even when the
            Atlantics are intentionally introduced into a                     0   Escapement to rivers = 0.2% (Rensel et
            stream.                                                               al. 1989)

            Atlantic Salmon. Atlantic salmon, which belong                    0   One major escapement (75% loss) in a
            to the genus Salmo, are genetically incapable of                      model year in farms raising coho or
            breeding with Pacific salmon of the genus                             chinook salmon
            Oncorhynchus. They are genetically very different
            from and genetically incompatible with Pacific                    0   10% of farms use native salmon species,
            salmon (chinook, coho, chum, pink, and sockeye),                      90% use Atlantic salmon.
            which belong to the genus Oncorhynchus. Thus,
            it is essentially impossible that Atlantic salmon             Escapement to rivers:
            pose any direct genetic threat to these species.
            Under      the    best     conditions      (laboratory            0   From "leakage losses": 30 adult fish in a
            experiments), researchers have been unsuccessful                      normal year
            at crossing these two groups (Lindbergh 1984;
            Refstie and Gjedren 1975).                                        0   From major escapement: 1,125 adult fish
                                                                                  in a model year
            In addition, Atlantic salmon spawn several
            months earlier than Pacific Coast steelhead and                   0   Total salmon escapement to Puget Sound
            cutthroat trout, and would have little opportunity                    rivers in a bad year: 1,155.
            to attempt such hybridization (Heggberget 1988;
            Malinken 1988).                                               The 5-year average escapement of wild coho and
                                                                          chinook salmon to Puget Sound rivers is 259,520
            .Pacific Salmon.   At this time, nearly all Pacific           (Flint 1989 personal communication). Chinook
            salmon reared in the Puget Sound region are                   average 51,700/yr and coho 207,820/yr. If all of
            reared in hatcheries or delayed release facilities            the escapees were coho, the potential for
            by the state or federal government, or tribal                 interbreeding with. wild fish in the rivers would
            entities for release into Puget Sound. Few fish               range from 0.1 to 0.5%. If all were chinook, the
            farms raise Pacific salmon in the Puget Sound                 potential would be from 0.6 to 2.2%. Impacts
            region. To evaluate the potential genetic impact              would not be significant unless the percentage of
            of future farms, we have conducted a reasonable               fish interbreeding with wild fish (assuming that
            worst-case escapement analysis as follows. To                 the farmed fish were grossly maladapted for
            keep this analysis in perspective, the reader                 existence in the wild) reached the 10 to 20-
            should recognize      that even this theoretical              percent     range     (Waples      1989      personal
            condition is highly   unlikely  in terms of existing          communication). The potential risk of an all-
            hatchery practices.                                           coho or all-chinook escapement in the model is
                                                                          reduced by 90%, considering only about 10% of
            Assumptions:                                                  the farms will have native species.

                .   40 farms in Puget Sound                               To put this in perspective, the present hatchery
                                                                          system (State, federal, and tribal) releases about
                0   750,000     lbs   production     per     farm         100 million chinook and coho smolts per year
                    (approximately 750,000 fish [0.1 to 10 lb             into Puget Sound waters. (WDF 1988). If 1%
                    range])                                               return as adults, and 1176 of those stray from
                                                                          hatchery release sites (Quinn 1988), then about
                                                                          10,000 hatchery fish are straying.       About 8.5


            Page 68                                                                                              Genetic Issues








           million chinook and coho smolts are intentionally               5.7.2.1          No-Action Alternative -
           released from fish farms in Puget Sound by WDF                                   Existing Regulations and
           and tribal facilities (WDF 1988). From these,                                    Guidelines
           about 2,890 fish enter rivers to spawn (Rensel et
           al. 1988). Adding these two sources of strays,                  The following    existing regulations and guidelines
           about 13,000 hatchery fish enter rivers to spawn                affect the potential for genetic impacts to
           every year. This amounts to about 5% as many                    indigenous species:
           hatchery fish as wild fish (coho and chinook).
           To date, no adverse genetic effects have been                            WDF has the responsibility to preserve,
           identified.   The strays from the,regular WDF                            protect, perpetuate, and manage fisheries
           hatchery system and the delayed-release program                          resources (RCW 75.08). WDF requires
           are not as genetically modified as future                                that all stocks used in the fish farming
           commercially farmed fish might be. However,                              industry have prior approval from WDF to
           there would be 10 to 1,000 times as many fish                            ensure that farm fish will not have an
           from the WDF hatchery system as there would be                           adverse genetic impact on indigenous
           from commercial fish farms.                                              species. This authority also allows WDF
                                                                                    to deny any transfer or importation that
           Considerable interbreeding has already occurred                          poses a potential risk to native fish or
           between wild stocks in Puget Sound and stocks of                         other aquatic or marine organisms.
           different origin.       Transplantation of stocks
           between river systems has been a common                                  The Hydraulic Code and the HPA permit
           practice for nearly 90 years in Washington. In                           system (RCW 75.20) provides WDF with
           addition, straying rates for transplanted fish are                       the authority to ensure that fish farm
           greater than wild or           established hatchery                      proposals do not have a significant
           populations (Bams 1976). As a result, few if any                         adverse impact on indigenous fish.
           wild populations of coho, chinook, or steelhead in
           Puget Sound have escaped at least some inter-                            The SEPA review process provides WDF
           breeding with fish of different genetic character.                       with an opportunity to review fish farming
                                                                                    proposals for any potential genetic impacts
           Assessing the potential impact of farmed Pacific                         related to siting farms near streams with
           salmon or steelhead on wild populations is                               indigenous salmon populations.           SEPA
           difficult given the speculative nature of the issue.                     review allows WDF to evaluate proposals
           However, local experts agree that significant                            using    the    most     current      scientific
           genetic impacts on wild populations due to                               information available for a specific site.
           widespread fish farming in Puget Sound is
           unlikely     (Seidel     1988;     Mahnken         1988;                 WDF      considers     it   undesirable       to
           Herschberger 1988).        The worst-case scenario                       interbreed     indigenous      wild    salmon
           would be where many genetically maladaptive                              populations with stocks of grossly different
           escapees ascended a stream with a relatively                             genetic character.        Reasons for this
           small wild population. The impacts to the wild                           recommendation are discussed above in
           population, if any, would be reduced fitness of                          Section 5.7.1.
           the interbred progeny. Without constant infusion
           by many escaped fish, these hypothetical                        5.7.2.2          Preferred Alternative
           maladaptive genes would disappear gradually due
           to selective pressure, making any impacts                       It is recommended that the following guidelines
           temporary.                                                      be used by WDF when reviewing fish farm
                                                                           proposals:




           Genetic Issues                                                                                                  Page 69








                     When Pacific salmon stocks are proposed              Japan and other countries as well. Coho salmon
                     for farms in areas where WDF determines              (Oncorhynchus kisutch) farming was developed in
                     there is a risk to indigenous species, WDF           the Puget Sound region beginning in the 1970s by
                     should only approve those stocks with the            the National Marine Fisheries Service, the
                     greatest similarity to local stocks near the         University of Washington, and at the commercial
                     farm site.                                           site near Manchester, Washington. Subsequent-
                                                                          ly, farming of this species expanded in other
                     In areas where WDF determines there is               countries, surpassing that practiced now in Puget
                     a risk of significant interbreeding or               Sound.    Atlantic salmon (Salmo salar) is the
                     establishment of harmful self-sustaining             species now most commonly reared commercially
                     populations, WDF should only approve                 in marine fish farms in 'Washington state. Past
                     the. farming of sterile or monosexual                research on diseases of salmonids has emphasized
                     individuals, or genetically incompatible             conditions occurring during their freshwater phase
                     species.                                             of development.     With the increase in marine
                                                                          aquaculture, infectious diseases of salmon from
                     In areas where WDF determines that wild              farms in Washington waiters have recently been
                     populations could be vulnerable to genetic           described in the literatuire (Harrell et al. 1976;
                     degradation, WDF should establish a                  Hoffman 1984; Harrell and Scott 1985; Harrell
                     minimum distance of separation between               et al. 1986; Elston et al. 1986, 1987; Kent and
                     farms and river mouths.                              Elston 1987a; Kent et al. 1988a,b). The major
                                                                          issues are discussed in the sections immediately
            5.7.3       Mitigation Measures and                           following this paragraph. See Appendix D for a
                        Unavoidable Signiricant                           discussion of the specific infectious diseases of
                        Adverse Impacts                                   salmon in the Pacific Northwest and Appendix G
                                                                          for a discussion of VHS disease of fish.
            WDF -and other local experts agree that the
            potential for significant genetic impacts resulting           Introduction of Exotic Pathogens.         Some fish
            from farm escapees interbreeding with wild stocks             diseases are restricted in their geographic
            is low. Existing regulations and the use of the               distribution since t'he affected fish are limited to
            guidelines indicated in the Preferred Alternative             their natural geographic range. Thus, a risk of
            are adequate to avoid any significant adverse                 introducing exotic fish pathogens (that is, those
            impacts and additional mitigation measures are                that do not exist in an area receiving imported
            not necessary.                                                fish) exists when fish are transported to a new
                                                                          location. Occurrences of exotic fish pathogenic
            5.8         DISEASE                                           parasites (Becker and Brunson 1968; Hoffman
                                                                          1970; Bauer and Hoffman 1976; Hoffman and
            Concerns about disease in the aquaculture                     Schubert 1984; Johnsen and Jensen 1988),
            industry involve the potential for introducing                bacteria (Whittington et al. 1987) and viruses
            exotic harmful pathogens in eggs imported from                (Sano et al. 1977) in new locations have been
            other geographic areas, transferring of diseases              attributed to the transfer of fish. However, the
            from farmed salmon to wild salmon, and                        actual geographic and host distribution of many
            transmitting diseases from farmed salmon to                   fish diseases is unknOWTIL.    Following more in-
            shellfish near the aquaculture facility.                      depth studies, some pathogens considered "new
                                                                          introductions" have been found to have been
            5.8ol       Affected Environment                              established for many years but previously
                                                                          unidentified (Hedrick et al. 1985).
            Infectious Fish Diseases. Fish farm       rearing of
            salmon is well established in Norway and
            Scotland and practiced in Chile, New Zealand,


            Page 70                                                                                                     Disease









           The study of diseases of farm-reared fish has led              wild fish if the captive fish are infected by exotic
           to the discovery of previously undescribed                     pathogens.       Thus,    the   state   and federal
           diseases.      Research on fish diseases has                   regulations now in place are essential for the
           previously been directed toward those diseases                 protection of fishery resources.
           occurring in freshwater because the major fish
           culture operations were freshwater hatcheries.                 However,      diseases    have     apparently     been
           The observations of new diseases in marine fish                transmitted to wild fish from hatchery fish. The
           farms are indications that those diseases occur                diseases were passed either following stocking of
           naturally in wild salmon during their seawater                 hatchery fish into natural waters, or to wild fish
           phase of development, or are a result of the                   downstream       from    a    freshwater      hatchery
           intensive husbandry of the fish.                               containing diseased fish when the diseased
                                                                          condition of the stocked fish was not determined
           To prevent importation of exotic diseases, some                or recognized. Parasites can also be transferred
           states such as Alaska restrict aquaculture to                  by movement of an exotic species into a non-
           indigenous stocks. Of specific concern in North                indigenous area. In fresh water, infections of an
           America, are Atlantic salmon eggs imported from                external parasite, Gyrodactylus salaris, occurred in
           Europe and the potential risk of introducing viral             wild and farmed Atlantic salmon in certain
           hemorrhagic septicemia disease (VHS) (see                      Norwegian streams following introduction of
           Appendix G).                                                   salmon parr from infected public hatcheries in
                                                                          Sweden (Johnson and Jensen 1988).                  The
           Transmission    of Disease to Wild Fish.          Wild         parasite, Nitsztchia sturionis, was introduced to
           animals act as reservoirs for several diseases of              the Aral Sea with sturgeon larvae transported
           domestic animals. The most dramatic example is                 from the Caspian Sea, and the parasite decimated
           probably in Africa where one-third of that                     the native sturgeon following its introduction
           continent is unsuitable for rearing domestic                   (Dogiel and Lutta 1937; Dogiel 1954).
           livestock because of the reservoir of Trypanosoma
           parasites in wild game (Murray and Trail 1986).                In Washington State, trout in two lakes became
           Conversely, there are a few examples of                        infected with the bass tapeworm (Proteocephalus
           transmission of disease from domestic mammals                  ambloplitis)    following    the    introduction      of
           to wild mammals.            An example of this                 largemouth bass (Becker and Brunson 1968).
           phenomenon is also in Africa, where the viral                  The role of the tapeworm in disease was not
           disease "Rinderpest" is transmitted from domestic              determined and Becker and Brunson (1968)
           cattle to wild hoofed animals.                                 reported that "whether infections influence the
                                                                          survival of young rainbow trout is conjectural in
           In the aquatic environment, wild fish can act as               the absence of controlled experiments." Yoder
           reservoirs for serious diseases of cultured fish.              (1972) observed the parasite, Myxobolus cerebralis
           These include bacterial kidney disease (Evelyn                 (which causes whirling disease), in wild brook
           1988) and infectious hematopoietic necrosis                    and brown trout, downstream from a hatchery
           (IHN) virus.       IHN infects returning sockeye               with infected rainbow trout.              From this
           salmon in all major production populations in                  observation, he concluded that the source of the
           Washington (Amend and Wood 1972). Examples                     infection was the hatchery.
           of this phenomenon also exist in fish farms.
           Wild salmon and non-salmonid fish can be                       Transfer of Disease to Shellfish. Although at
           reservoirs for ectoparasitic sea lice (Copepoda) of            least one author has speculated that shellfish can
           pen-reared salmon, Cod are apparently the                      be reservoirs for fish pathogens such as viruses,
           reservoir of Parvicapsula (Protozoa: myxosporea),              no definitive research has been conducted on this
           which causes kidney disease in pen-reared coho                 point (Meyers 1984). Meyers (1984) speculated
           salmon     (Johnstone 1984).      A significant risk           that bivalve molluscs could serve as reservoirs for
           exists for transfer of pathogens from captive to               fish viruses such as infectious hematopoietic


           Disease                                                                                                       Page 71








             necrosis virus (IHNV), which occurs in wild                 5.8.2      Impacts of Diseases
             stocks of sockeye salmon and other salmonids.
             In addition, Meyers (1979) demonstrated that                Introduction of Exotic Pathogens. As discussed
             viruses pathogenic for freshwater fish can be               above in Section 5.8.1, a primary concern with
             isolated from oysters from Long Island Sound,               the growth of the fish farming industry in
             New York.      Although shellfish are known to              Washington is the possible increased risk of
             concentrate certain chemicals and viruses, there            introduction of exotic diseases. This increased
             is no evidence this ability has any significance for        risk is minimal because regulations are in place
             disease transmission to wild stocks of fish and             to restrict importation of serious exotic pathogens
             shellfish.                                                  of salmon.     These regulations are discussed
                                                                         further in Section 5.8.2.1.
             Many reports indicate that vibriosis is a
             significant disease of both shellfish and fish in           Fish eggs are currently being imported into
             intensive husbandry (Elston 1984; Egidius 1987).            Washington on a limited basis for existing
             Vibriosis can be an important problem in fish               freshwater aquaculture industries, with each case
             farming when proper husbandry and, in some                  reviewed by the appropriate state agency. Live
             cases, vaccination, is not performed. In bivalve            salmonids cannot be imported. State regulations
             mollusc hatcheries, vibriosis is considered a               (WAC 220-77) to control importation of exotic
             husbandry disease controlled by proper hygienic             fish pathogens are administered by WDF.           In
             practices (Elston 1984). One report (Tubiash et             addition, salmonid eggs imported from foreign
             al. 1973) cites "cardiac vibriosis" as a disease of         sources must be individually permitted and
             adult American oysters, Crassostrea virginica. The          inspected by a USFWS agent under Title 50 of
             disease, which occurred in about 0.04% of oysters           the U.S. Code of Federal Regulations.
             in a sample in from Chesapeake Bay, caused
             enlargement of the pericardium, but the oysters             Transmission of Disease To Wild Fish. Review
             were otherwise normal. Although these authors               of the technical literature indicates the risk of
             suggested that the disease could be due to ribrio           transmission of disease from farms to wild fish is
             anguillarum, a fish pathogen, they were not able            possible, but not likely a significant problem.
             to substantiate this claim with experimental                Fish disease control regulations, cited below in
             research.   Other reports (Brown 1981a,b and                Section 5.8.2.1, are in place in Washington to
             other authors; see Elston 1984 for review)                  prevent the importation of exotic infectious
             indicate that V. anguillarum can cause disease in           diseases which could pose a significant risk to
             bivalve mollusc larvae in intensive shellfish               native fish. In addition, experience with other
             culture. In practice, this bacterium has not been           domesticated animals indicates that husbanded
             important in mollusc husbandry in the Pacific               stocks of animals are usually at a greater risk
             Northwest. A relatively newly designated species,           from the transmission of infectious diseases than
             V. tubiashi (Hada et al. 1984), is recognized as a          wild stocks.   Diseases observed in fish farm
             bivalve mollusc pathogen at certain locations in            culture of salmonids in Washington are husbandry
             Europe and North America. It should be noted                diseases resulting from holding the fish in
             that reports of vibriosis in mollusc larvae all             captivity. Such diseases Eire non-exotic; infectious
             refer to conditions and diseases in intensive               agents that cause such diseases originate from
             hatchery culture of these animals. There is no              environmental sources or wild fish.
             evidence that vibriosis is important in limiting
             natural populations of bivalve mollusc larvae, but          Cultured salmon and trout have been and will
             this has not been systematically investigated.              continue to be released throughout Washington
                                                                         by State and federal hatcheries. Though the risk
                                                                         is minimal, the possibility of transmission of
                                                                         pathogens from released hatchery-reared fish to
                                                                         wild fish exists today. This risk is likely greater


             Page 72                                                                                                  Disease









           from the many hatchery fish released into state                             regarding the health of the received eggs
           waters, than from the relatively small numbers of                           by the importer.       Thus, introduction of
           captive fish in farms.                                                      fish or eggs into Washington is limited
                                                                                       under     existing     federal     and      State
           The carcasses of dead fish from fish farms are                              regulations. No salmon eggs or fish from
           potential vectors of infectious fish diseases                               Japan are allowed in Washington State.
           although there is no evidence indicating that this
           has   been     a    significant    mode     of disease                 0    Vibrio salmonicida is apparently the only
           transmission.     In the interests of good animal                           known and exclusively marine pathogen of
           husbandry practices, dead fish should be removed                            salmon exotic to the Pacific Northwest.
           from the pens regularly, then stored and disposed                           This disease is contracted in seawater and
           to prevent the potential spread of infectious                               only fish in their freshwater phase of
           disease agents which they may contain.                                      development or eggs held in freshwater
                                                                                       are transported into Washington.             The
           Transmission of Disease To Shellfish.           There is                    risk of introduction of this bacterium,
           no impact related to infectious diseases on                                 therefore, is minimal.             A parasite
           invertebrate populations that can be reasonably                             occurring in Europe, Gyrodactylus salaris,
           predicted as a result of salmon farming practices.                          has not been observed in the Pacific
           Fish pathogens         are    largely distinct       from                   Northwest and salmon from Europe must
           invertebrate pathogens. Although some technical                             be    free    of     this   parasite      before
           reports cite V. anguillarum, a known fish                                   importation. Eggs imported from Europe
           pathogen, as a mollusc pathogen, the examples                               are    disinfected      as    part     of     the
           cited in these reports are exceptional cases from                           requirements of the WDF. Thus, the risk
           industrialized locations in Europe and North                                of importation of this parasite is minimal.
           America.      They refer to cases occurring in                              Other species of Gyrodactylus occurring
           intensive husbandry of bivalve larvae. Important                            naturally in the Pacific Northwest are
           mollusc pathogens such as V. tubiashi are distinct                          associated with fishes, but are not
           from fish pathogenic vibrios.                                               considered a serious problem in salmon
                                                                                       culture.
           5.8.2.1           No-Action Alternative -
                             Existing Regulations and                                  The level of fish farming in Puget Sound
                             Guidelines                                                will not directly affect the implementation
                                                                                       of the regulations designed to prevent the
           The following regulations and guidelines affect                             introduction of exotic fish pathogens.
           the potential impact of disease:                                            Additional staff time may be required
                                                                                       from WDF and USFWS if increased
                    Washington State importation laws (WAC                             requests for importations are made.
                    220-77), administered by WDF, and                                  However, a higher level of Puget Sound
                    federal statutes protecting fish (Title 50                         farm production has already increased the
                    of the U.S. Code of Federal Regulations,                           financial incentive to maintain regional
                    part 16.13), administered by USFWS,                                broodstock and egg production.               This
                    require certification that all salmon eggs                         increased local production of salmon eggs
                    not contain any virus or other significant                         should reduce the number of salmon egg
                    fish pathogens before fish can be placed                           importations and the associated risk of
                    or cultured in state waters.                Such                   disease introductions.
                    certification     includes       source       site
                    inspections, quality control specifications,                       DOH      is    authorized     through       RCW
                    inspection      of     arriving       shipments,                   43.20.050 to protect the health, safety,
                    quarantine, and reporting requirements                             and well-being of the public and to


           Disease                                                                                                              Page 73








                        prevent the spread of disease.              DOH           5.9.1 Affected Environment
                        regulates food protection and storage
                        (WAC 248-84). They are also charged                       Animal DeRredation. The presence of captive
                        with approving shellfish growing areas and                fish and a floating habitat usually attracts
                        assuring that these areas,            and the             predatory birds and marine mammals to fish
                        commercially harvested shellfish from                     farms.     Herons may Rand on walkways and
                        these areas, are not contaminated (RCW                    attempt to capture small fish through the netting.
                        69.30, WAC 248-58).                                       Larger predators, such as harbor seals, California
                                                                                  sea lions, and river ottrr, may attempt to get
              5.8.2.2           Preferred Alternative                             larger fish through the underwater netting.
                                                                                  Attempts by these animals to capture penned fish
              Existing regulations still allow a small but                        can damage nets, and if the predators are
              manageable potential for adverse impacts.                In         successful, kill or injure fish. To protect their
              order to avoid significant adverse impacts, the                     investments, fish farmers have developed methods
              following measure is recommended:                                   to discourage or prevent depredation by birds and
                                                                                  marine mammals.
                        Development of enough regional brood
                        stock to support the salmon farming                       The severity of the problem depends to some
                        industry. This would eliminate the risk of                extent on the location of the site, and on the
                        importing exotic salmon diseases with                     species that inhabit the area. Marine mammals
                        infected eggs.     Thus, while the current                are generally regarded as more damaging than
                        regulatory policies allow some controlled                 birds.
                        risk, any trend in the industry to develop
                        a local brood stock would further reduce                  Predators have been successfully controlled in
                        that risk.                                                Washington waters with anti-predator nets.
                                                                                  There     are    only    isolated     instances     where
              5.8.3         Mitigation Measures and                               intentional killing has occurred. Killing is usually
                            Unavoidable Significant                               the result of inadequate protection by harass-
                            Adverse Impacts                                       ment techniques or antii-predator nets (Forster
                                                                                  1988;    Lindbergh       1988).        Most      available
              Implementing        the    recommendation         in    the         information shows that early preventive actions
              Preferred Alternative in conjunction with          existing         can reduce predator problems. Once predators
              regulations is sufficient to avoid significant                      establish use patterns around a facility, the
              adverse impacts.           No additional mitigation                 problem is difficult to correct (Jefferies 1988;
              measures are necessary.                                             Scordino 1988).

              5.9           MARINE MAMMALS AND                                    Marine Mammals. Marine mammals live along
                            BIRDS                                                 much of the shoreline and in most of the open
                                                                                  waters of Puget Sound.           Four species are of
              There are two issues of concern regarding               the         concern to fish farms in Washington. These are
              relationship between wildlife and salmon                fish        the harbor seal, California sea lion, northern sea
              farms. First, is the effect of animal predation on                  lion, and river otter. Killer whales also occur in
              captive fish, and the counteracting effect of anti-                 Puget Sound.        Although there have been no
              predator      measures      on animal populations.                  reports of problems associated with fish farms in
              Second, is'the impact of farms sited near sensi-                    Washington, killer whales are a predator of fish,
              tive wildlife habitats.                                             seals, and marine birds (Maser et al. 1981).





              Page 74                                                                                         Marine Mammals and Birds









          Seals and sea lions rest or haul out on shorelines          Strait of Juan de Fuca, Whidbey and Camano
          and floating objects such as log rafts (Figure 12).         Islands, Padilla and Skagit Bays, and the San
          Both harbor seals and northern sea lions reside             Juan Islands.
          in Washington year round, with harbor seals
          being the most widely distributed of the two.               Predation. Predation by marine mammals occurs
          California sea lions reside in Washington waters            at some Washington fish farms. Most workers
          during the winter months (October through May)              characterize predation by marine mammals as a
          and use haulout sites in southern Puget Sound               minor to moderate problem (Gibson 1988;
          (near Fox Island), northern Puget Sound (Port               Lindbergh 1988).      At the NMFS facility near
          Gardner), and in the northern San Juan Islands              Manchester, Kitsap County, fish have escaped
          (Sucia Island) (EPA 1987).                                  through nets damaged by California sea lions
                                                                      (Scordino 1988). Gibson (1989) speculates that
          California sea lions do       not appear to use             marine mammal predation could be a significant
          potential haulout sites in   central Puget Sound.           problem at the SeaFarm Washington facility in
          However, during the last several winters they               Port Angeles Harbor if predator control methods
          have been consuming steelhead and salmon                    were not used.
          entering Lake Washington at the Ship Canal, and
          in the Duwamish River.         Sea lions are also           Harbor seals and sea lions may damage and kill
          commonly observed in southern Puget Sound.                  fish by biting through the netting of the rearing
                                                                      farm.     Occasionally the attacks damage the
          Since implementation of the Marine Mammal                   netting, which in addition to predation, may allow
          Protection Act, many seal and sea lion populations          many valuable fish to escape. Observers often do
          in Puget Sound and other Washington bays have               not distinguish between California and northern
          increased in size and range. WDW estimates that             sea lions, but biologists believe most sightings
          the harbor seal population in Puget Sound is                involve California sea lions (Jeffries 1988;
          increasing at the rate of 8% annually. Northern             Scordino 1988).      While predation by marine
          sea lion population in the Pacific Northwest is             mammals occurs throughout the year, reports are
          considered stable      (Scordino    1989 personal           most frequent during the winter, when California
          communication).          However,     the     Alaska        sea lions are present (Lindbergh 1988).         Even
          populations of northern sea lions are being                 though river otters occasionally injure or kill farm
          considered for designation as "depleted" under the          fish without damaging the netting, in some areas
          Marine Mammal Protection Act.                               they are the main predators of farm fish.

          Resident killer whales forage     regularly in the          Birds. Puget Sound attracts both open-coast bird
          waters of Puget Sound. Although they will eat               species and those common to protected marine
          any sea animal, their primary food resource in              habitats. Prevalent groups include grebes, alcids,
          this area is fish, such as salmon, rockfish, and            shorebirds, gulls, cormorants, diving ducks, and
          cod. They are apparently well-adapted to human              birds of prey (Figure 13). Species that have been
          activity  and    tend   to    avoid   people     who        identified as predators on farm fish include great
          intentionally interfere with them (Angell and               blue herons, belted kingfishers, pigeon guillemots,
          Balcomb 1982).                                              cormorants, grebes, and mergansers.

          River otters are found primarily in quiet                   Predation by birds is not a significant problem at
          shoreline areas containing freshwater streams               most fish farms due to the use of anti-predator
          (EPA 1987). Otters can be found in appropriate              nets, strings placed in parallel over the farm, and
          habitats throughout southern Puget Sound, around            the normal level of human activity associated with
          Vashon Island, in Hood Canal, and on the Kitsap             farm operation. Birds are only a problem while
          Peninsula.     Other areas where they forage                small fish are available. Once farm fish have
          offshore and along the shoreline include the                grown too large for birds to eat, there is little


          Marine Mammals and Birds                                                                                 Page 75








                                                                         CANADA
                                                                - - - - - - - - - - - ---
                                                                       UNITED STATES






                                                                          00                    B.ELLINGHAM
                                                                     00
                                 VANCOUVER                                           00
                                   ISLAND






                                                                                   0
        UAiv@@' 4N                                                                                     1-5
                        A-1
                        01C.






                                                             00







                                                          PORT
                                                         ANGELES



                                                                                                        EVERETT


                                                                                 101


                       101










                                                                                                    SEATTL


                                                                                  BREKIERTO

                                                                             Q
                                                                            IF.










                                                                                                TA OMA





                                                                                               1-5
      Updated: Jeffries (WDW) 1988
      Source: Puget Sound Water Quality                                           OLYMPIA
           Authority 1986





      SCALE IN MILES                                                                 Figure 12.
                                                                                     Seal and Sea Lion
      0       10        20                                                           Haulouts in Puget Sound







                                                                                        CANADA
                                                                             - - - - - - - - - - - - -
                                                                                      UNITED STATES








                                  VANCOUVER                                                                         BELLINGHAM
                                     ISLAND
                                                                                                        0









                                                                                                     0
         IDS 4%                                                                                                               1-5






                                                                    00







                                                                     ANGELES



                                                                                                                                      T
                                                                                                                                EV   T




                         101











                                                                                                                          S     LE


                                                                                                   BREMERTON














                                                                                                                     TACOMA





     Source: Puget Sound Water Quality
                                                                                                   . . . . . . . . . .
            Authority 1986
            Adapted from Washington
                                                                                                    OLYMPIA
            Marine Atlas 1977
     777@@;












     SCALE IN MILES                                                                                     Figure 13.
                                                                                                        Major Waterfowl Habitats
    0          10         20                                    Waterfowl Area                          in Puget Sound









             need for netting over the farm. Some farmers                    has shown that California sea lions initially
             use dogs to chase birds off the farm.                           respond to AHDs by leaving the area of the
                                                                             noise. However, the animals typically become
             Fish farms may benefit some bird populations by                 accustomed to the disturbance and return because
             providing     food    resources    (such    as    algae,        there is no negative stimulus to accompany the
             invertebrates, and herring, sticklebacks and other              noise (Jeffries 1988).
             small fish attracted to the farm) and feeding and
             resting habitat. Observations by workers at the                 A few fish farmers have also used AHDs.
             Domsea and NMFS fish farm operations near                       Marine mammals sometimes evade the noise by
             Manchester suggest that bald eagles prey on                     approaching the farm with their heads out of
             waterfowl attracted to the farm.          No one has            water, or approaching within the acoustic shadow
             observed the eagles taking fish from the farm                   formed by the farm (Boldt 1988).              Resource
             (Mahnken 1988).                                                 agencies and farm managers report AHDs do not
                                                                             provide effective long-term control of marine
             Predator Control Methods. Surrounding farms                     mammals (Juelson 1988; Scordino 1988).
             with protective nets is the primary predator
             control method at Washington fish farms. These                  Chemical taste aversion using lithium chloride has
             anti-predator nets prevent birds and marine                     also been tried in several experiments at the
             mammals from reaching the interior pen below                    Ballard Locks and by a farmer. It has showed
             the water, or gaining access to the pen interior                limited success in predator control (Forster 1988;
             from walkways on the water surface.                Anti-        Lindbergh 1988). No Washington fish farm uses
             predator nets are typically attached to a walkway               lithium chloride for predator control (Gibson
             or outrigger approximately three feet from the                  1989).
             inside net. The anti-predator net extends below
             the growing pen 3 to 9 ft and loops back to the                 Sensitive Wildlife Speci!s and Habitats.            The
             opposite side, enclosing the pen. Weights are                   USFWS, NMFS, and the WDW maintain
             attached to the predator net to keep it taut and                databases identifying sensitive wildlife species and
             reduce movement toward the fish-rearing pen.                    habitats.   Examples include bald eagle nesting
                                                                             and roosting sites, peregrine falcon nesting and
             Anti-predator nets generally provide effective                  wintering areas, marine bird nesting colonies, and
             control.     With their use, marine mammal                      marine mammal haulout areas.
             predation at Washington fish farms is not a
             significant problem. Minor problems can occur                   5.9.2       Impacts on Wildlife
             when strong currents push the pen and anti-
             predator nets together, allowing seals or sea lions             Construction and operation of a fish farm would
             to reach the penned fish more easily than when                  alter habitats for birds and mammals.             Some
             the nets are not affected by the currents.            In        species can tolerate or benefit from the presence
             addition, marine mammals occasionally charge the                of a fish farm facility, while species sensitive to
             fish farm, driving the anti-predator and pen net                human activity are forced to seek habitat
             together and biting through the nets.                           elsewhere. The significance of potential impacts
                                                                             to wildlife will       depend     on    site    specific
             Fish farmers also use other non-lethal     methods to           considerations such as types and numbers of
             discourage predation by marine mammals.                         species in the area and proximity to sensitive
             Acoustic harassment devices (AHDs) have been                    habitat areas.
             developed to create loud noises and scare animals
             away. Near the Ballard Locks in Seattle these                   Fish farms may create; disturbances through
             AHI)s have been used extensively to attempt to                  several types of activities.      Noise and human
             control predation by sea lions which threaten the               activity would generally be low during operations
             wild steelhead run. Experience in Puget Sound                   and would not cause significant impacts on


             Page 78                                                                                   Marine Mammals and Birds








           nearby wildlife populations.        This assumes the                       activity   near      farms     and      farmers
           farm is not located near habitats of special sig-                          interaction with these animals.           NMFS
           nificance. Noise and activity would probably be                            has enforcement authority to fine or
           greatest during construction of the facility.                              incarcerate offenders (Scordino 1988).

           The widespread use of lethal methods to control                            USFWS administers a permit system that
           predators could have an adverse impact on                                  allows selected killing and trapping of
           marine mammal and bird populations. However,                               nuisance birds to protect aquaculture
           because non-lethal methods provide effective                               facilities (Juelson 1988). 77se Migratory
           control, significant impacts on populations are                            Bird Treaty Act and various state statutes
           not     expected.       Anti-predator       nets     have                  protect birds from unlawful killing or
           occasionally drowned marine mammals (Scordino                              trapping.    It is the regional policy of
           1988).    But properly hung and maintained anti-                           USFWS not to issue these permits to
           predator nets should cause little harm to these                            private facilities     occurring in public
           creatures.        Taste    aversion     and      acoustic                  waters.
           harassment appear to have no adverse impacts on
           marine mammal and bird populations.                                        Peregrine falcons and bald eagles are
                                                                                      protected by the Endangered Species Act.
           5.9.2.1           No-Action Alternative                                    Neither of these species is a threat to
                             Existing Regulations and                                 farm fish, but both may be affected by
                             Guidelines                                               fish farm siting decisions.             USFWS
                                                                                      reviews     ACOE       permits      and     may
           The following existing State, federal, or local                            recommend conditions to the permit as
           regulations and guidelines affect the potential                            necessary to protect any endangered
           impacts of fish    farms on marine mammals and                             species.
           birds:
                                                                                      WDW also has protection responsibility
                    In 1972, Congress enacted the Marine                              for the bald eagle through its newly
                    Mammal Protection Act (MMPA) to                                   adopted Bald Eagle Protection Rules. The
                    prohibit the killing or harassment of any                         new rules require that individual site
                    marine mammal, except in situations                               management plans be prepared for
                    where life or property are in imminent                            developments affecting eagle nest and
                    danger due to the mammals (for example,                           roost sites on public and private lands.
                    commercial fishers may kill seals to                              These management plans are based on
                    protect their nets). In 1988, the MMPA                            local conditions and may include a zone
                    was revised to require all persons seeking                        of separation restricting development
                    to harass or kill marine mammals that                             activity near eagle nest and roost sites.
                    endanger their property to obtain an
                    exemption from the provisions of the                              WDW reviews proposed fish farms during
                    MMPA. This exemption does not allow                               the SEPA review process.            Using the
                    killing northern fur seals, northern sea                          most current data available, WDW
                    lions, or killer whales.                                          determines if a proposed farm is near a
                                                                                      habitat of special significance, such as
                    NMFS has jurisdiction over marine                                 near a marine mammal haulout area or
                    mammal protection with support from                               bald eagle nesting site.         If necessary,
                    WDW. NMFS is presently implementing                               WDW would recommend measures such
                    the provisions of the revised MMPA and                            as site specific buffers around sensitive
                    may require fish farm operators to                                habitat areas to ensure that no significant
                    maintain written logs of marine mammals


           Marine Mammals and Birds                                                                                           Page 79








                      adverse impacts would occur to birds or                        Some local shorel    ine programs include
                      marine mammals.                                                specific regulations that prohibit killing or
                                                                                     abusive harassmcnt of birds or mammals
                      The ACOE permitting process provides a                         that may visit a farm.       The San Juan
                      similar review by NMFS and USFWS.                              County Shoreline Master Program states
                      Both of these agencies provide comments                        that
                      and recommendations to ACOE before
                      they issue the necessary permit to the                             "Predator control shall not involve
                      farm proponent.        This review allows                          killing or abusive harassment of birds
                      federal agencies with the expertise and                            or mammals.         Approved controls
                      responsibility    of    protecting      marine                     include but are not limited to double
                      mammals and birds an opportunity to                                netting for seals, overhead netting for
                      recommend conditions to permits that                               birds, and three-foot high fencing or
                      might influence siting decisions.                                  netting for otters."

                  ï¿½   The Interim Guidelines recommend that                          Some counties in Washington provide
                      fish farms be located at least 1,500" ft                       rules for the protection of marine
                      (457 m) from bird and mammal habitats                          mammal and bird habitat. For example,
                      of special significance where the farms                        San Juan County requires that aquaculture
                      are incompatible with these habitats.                          not be allowed in areas near National
                      Depending on the characteristics of the                        Wildlife Refuges or "critical habitats"
                      site and the nature of the fish farm                           where the proposed activity will adversely
                      proposal, this separation may be increased                     affect the refuge/habitat use or value
                      or reduced as appropriate. Particularly                        (Shoreline Master Program [San Juan
                      sensitive features may require more than                       County], Chapter 16.40.503).
                      1,500 ft (457 m) as a buffer, while other
                      features may require less.                            5.9.2.2          Preferred Alternative

                  ï¿½   The Guidelines also recommend using                   The existing State and federal review processes
                      non-lethal techniques to protect farmed               allow site specific factoirs and the most current
                      fish from predators.       Predator control           data to be considered in the process of siting fish
                      methods must follow federal and state                 farms.
                      rules, and fish farm operators must
                      possess all necessary permits. There are              In areas where WDW, NMFS, or USFWS indicate
                      no guidelines specifying the size of anti-            that predators may be present, it is recommended
                      predator nets.                                        that the use of anti-predator nets be required of
                                                                            fish farmers through adoption of this requirement
                      WDW and the Wildlife Commission are                   into the appropriate WA,Cs. In these areas, the
                      charged with protecting, preserving and               anti-predator net should be installed before fish
                      perpetuating wildlife within Washington               are placed in the pens.
                      State (RCW 77.12). Prohibited acts and
                      penalties for wasting, mutilating, taking of          In areas where WDW, NMFS, or USFWS require
                      protected species, etc. are also defined              anti-predator nets, it is recommended that the
                      (RCW 77.16). WDW's policy is to assure                following guidelines for net size and placement
                      no outside intervention results in any net            be used by agency personnel when permitting fish
                      loss of wildlife habitat. Other goals and             farm proposals:
                      policies are implemented through the
                      various programs of the agency.



             Page 80                                                                                  Marine Mammals and Birds









               ï¿½  The anti-predator net should be separated
                  from the fish net by at least 3 ft (0.9 m),
                  either by suspending it from the outside
                  cage walkway or from an outrigger
                  structure.


               ï¿½  The anti-predator net should extend 3 to
                  9 ft (0.9 to 2.7 m) below the bottom of
                  the fish net, loop back up to create a
                  bag-type structure and be weighted
                  sufficiently to remain taut.

               ï¿½  The anti-predator net mesh size should be
                  less than 5 inches (12.7 cm) to avoid
                  accidental entrapment of animals.

               ï¿½  Perimeter fencing should be installed to
                  prevent resting and haulout of seals and
                  sea lions on the pens.

               ï¿½  A 7-inch (17.8 cm) stretch mesh net, or
                  parallel strings over the top of the fish
                  pen to stop birds from entering from
                  above should be installed.

          5.9.3       Mitigation Measures and
                      Un voidable Significant
                      Adverse Impacts

          The existing State and federal review processes
          provide an opportunity for all agencies with
          expertise to assess the potential impacts of fish
          farms on marine mammals and birds. A case-
          by-case evaluation of proposals allows these
          agencies to use the most current information to
          assess a proposal at a specific site.

          The use of existing State and federal regulations
          with    the    anti-predator    net     requirement
          recommended in the Preferred Alternative will
          avoid significant adverse impacts to marine
          mammals and birds. No additional mitigation
          measures are necessary.










          Marine Mammals and Birds                                                                               Page 81














                                         6. THE BUILT ETSWIRONMENT


          6.1         VISUAL QUALITY                                    Views from these shorelines and from the water
                                                                        vary considerably. Along the Straits of Juan de
          The issue of visual impact involves      how different        Fuca and Georgia, the opposite shoreline typically
          people perceive the same structure,      how structure        lies at a considerable distance  from the observer
          design and location can be altered to reduce                  so that views are dominated by the sky and a
          potential visual impacts, and what types of                   broad, flat expanse of water.      Depending upon
          controls    can   be     implemented     to    address        the weather and sun position, the water surface
          cumulative impacts.                                           may appear monotonal and static on cloudy, calm
                                                                        days, or dynamic and highlighted on windy, sunny
          Fish farms are commonly placed in        open water           days.
          where no manmade structures exist.       The above-
          water portion of these farms alters      views from           In other locations, where the waterbody is not as
          adjacent vessels or boats and may        alter views          broad, the shoreline and nearby land areas are
          from nearby land areas. Many people perceive                  more evident and form the dominant visual
          any structure placed in open water as creating an             element. In these areas, the landscape appears
          adverse visual impact.                                        more complex and intimate to the viewer. Tree-
                                                                        covered slopes, rocky headlands, or steep bluffs
          6.1.1       Affected    Environment                           rise from the water in many areas and create a
                                                                        visually varied landscape.
          Puget Sound and adjacent waters, where fish
          farms would be located, provide views     that are of         Human activity affects views along the inland
          interest to nearly all residents and visitors.                marine waters of western Washington. It varies
          These waters, which include the Strait of Juan de             from the intense and diverse activities associated
          Fuca on the west, the Strait of Georgia on the                with the metropolitan areas in central Puget
          north, Puget Sound on the south, and the                      Sound to the near absence of activity in sparsely
          waterways in between, form an intricate landscape             inhabited areas. In no portion of these inland
          of bays, channels, and islands.          This inland          waters are views of human activity completely
          embayment is the drowned portion of a broad                   absent. Docks, boats, houses, or other signs of
          hilly lowland flanked on the west by     the Olympic          human presence are almost always within view of
          Mountains and on the east by the Cascade                      shoreline residents and visitors. In some areas of
          Mountains. The Olympic Mountains rise above                   the Puget Sound region, overwater structures,
          Hood Canal on the west side of Puget Sound and                such as log rafts, docks, boats, or marinas,
          closely above the southern shore of the Strait of             dominate the marine view.
          Juan de Fuca.      The Cascade Mountains stand
          further back from the east shore of Puget Sound               Despite the rather uniform views provided by the
          and the Strait of Georgia, except in the north                inland marine waters of western Washington,
          where foothills extend to saltwater south of                  particular areas are visually unusual or distinctive.
          Bellingham. From most vantage points, these two               An example of an aesthetically unusual location
          ranges form a jagged skyline that appears as rows             is Dungeness Spit. In size and form, Dungeness
          of green-sloped mountains with craggy and snow-               Spit is a landform unique to the study area, and
          covered peaks.                                                the view from the south across the spit and the


          Visual Quality                                                                                             Page 83









             Strait of Juan de Fuca beyond is therefore                    Fish farm structures become less evident as the
             visually unique.                                              observer/facility distance increases. Typical farm
                                                                           facilities at distances greater than 458-610 in
             Other locations   may be visually distinctive within          (1,500-2,000 ft) appear as a thin line on the
             the study area,   but they are not unique because             horizon for observers at about the same elevation
             they share certain attributes with other portions             as the water surface (FDAW and CH2M Hill
             of Puget Sound and adjacent waters. An example                1986).   For two observers at the same distance
             of such a distinctive area would be the west end              from a fish farm, the facility would be more
             of Fidalgo Island and the adjoining San Juan                  evident  to the observer who is higher above the
             Island archipelago.                                           water surface.    For two observers at the same
                                                                           height above the water surface, farms would be
             This EIS does not    attempt to identify unique or            more evident to the less distant observer (see
             visually distinctive views; these must be identified          Figures 14 and 15).
             by shoreline regulators. This analysis discusses
             potential impacts on these views from farms, and              Structure color also affects visual distinctness.
             possible subsequent mitigation measures.                      Brightly colored structures are generally more
                                                                           evident than somber-toned structures; and grays,
             6.1.2      Impacts on Visual Quality                          blues, and greens are generally less evident than
                                                                           reds, yellows, or oranges. Structures composed
             Visual quality impacts are subjective and difficult           of reflective materials are more evident to an
             to quantify.     Attitudes and perceptions vary               observer than structures composed of materials
             considerably, so that two observers often perceive            with matte surfaces. Lights, particularly blinking
             their views to be differently impacted by the                 or rotating ones, greatly increase the visual
             same facility. This section describes the features            distinctness of a structure at night. The visual
             of fish farms that may affect views, how these                impact of structures varies with sun orientation,
             features may be perceived, and how alternatives               wave action, and cloud cover, factors that are not
             may affect views.                                             constant at any particular site.

             Background. Impacts to visual quality from fish               Attitudes toward fish farms vary significantly for
             farms depend on several variables.              These         different observers. Some observers consider a
             include: the location, size, and design of the                farm to be a visual intrusion, while others
             facility, the number and location of observers and            consider the same facility to be a neutral or
             their attitudes about the facility, and the nature            interesting part of the visual environment. Some
             of the surroundings.                                          observers find fish farms interesting and attractive
                                                                           in a manner similar to a fish hatchery.
             Fish farms have floats and railings that typically
             extend about 1.5 in (60 inches) above the water.              Observer attitudes will be affected by the overall
             They also commonly include a small building                   visual environment near a farm site. Observers
             extending about 3 in (10 ft) above the water (see             in an area with few human-made structures would
             Section 2, Background, and Figure 3).                         probably perceive a farm as visually intrusive. A
                                                                           farm facility in a complex: landscape dominated by
             Like many human-made objects, the         form of a           man-made objects, such as an urban area, may be
             fish farm is dominated by straight lines and a                visually unobtrusive.
             regular pattern.   These characteristics, together
             with, the immobility of a fish farm structure,                Description of Impacts.      The visual impact of
             contrast with the water surface and tend to draw              fish farms depends on tl-.ie distance between the
             the attention of observers.                                   observer and the farm, on the altitude of the
                                                                           observer, and on the surrounding views.             In
                                                                           general, only viewers within about 2,000 ft


             Page 84                                                                                              Visual Ouality

























                                        View From House 1                                                  View From House 2















                                                                                                                                               HOUSE
                                                                                                                                                  2




                                                                                                                               HOUSE




                  100 FEET                                                                      100 FEET









                                                                                                                           Figure 14.
                                                                                                                           Topography of the Shoreline
                                                                                                                           and Views of Fish Farm Facilities









             (610 m) are likely to see a fish farm as anything              has greater visual impact at distances greater
             more than a thin line on the horizon (EDAW                     than 600 ft (185 m) off to the side. However, at
             and CH2M Hill 1986). Viewers in the immediate                  these distances, the visual impact in either case
             vicinity of the farm could have their view                     would probably not be substantial. Although the
             substantially altered by the presence of the farm.             farm would occupy a definite horizontal angle in
                                                                            the field of view of an observer at water level, at
             The relationship between the location of the                   distances approaching or exceeding 2,000 ft (610
             observer and the distance of the farm from shore               m), the farm would tend to merge with the water
             affects visual impacts. Views from residences on               line and be nearly indiscernible to the observer.
             the shoreline are primarily oriented toward the
             water and often toward landmarks on the far                    Some residents and visitors will be visually
             shore. A schematic representation of the impacts               affected by the presence of a fish farm. Whether
             associated with the placement of a farm relative               or not it substantially alters their view, these
             to the shoreline can be seen in Figure 16. in                  people will be affected because they consider any
             this example, the predominant viewscape is                     structure and its operation, such as a fish farm,
             assumed to be oriented directly out over the                   an undesirable intrusion into what they perceive
             water. Situation A of Figure 16 places the farm                as an unaltered natural environment.
             300 ft from shore.       While the facility will be
             visible along the shoreline, it will not be a major            Placement of several farms in proximity to each
             visual impact to the observer in the example.                  other can result in cumulative visual impacts. A
             However, when the farm is moved 1,000 ft (305                  greater number of farms would probably increase
             m) from the shoreline, as in situation B, it falls             the number of observers whose views would be
             within the predominant viewscape of the observer.              impacted. For a particular observer, an increase
                                                                            in the number of farms in an area may or may
             Yet, now, the facility in situation B is visible               not   result    in   greater    potential     impacts.
             from only 3,944 ft (1,202 m) of the shoreline.                 Additional farms placed at greater distances from
             This hypothetical example is included to indicate              an observer than an existing farm would probably
             that placing a farm as far from shore as possible              not result in substantially greater visual impacts.
             is not always the most effective way to minimize               The nearer, existing far;n or farms would have
             visual impacts.     Because the orientation and                the primary effect on. views.              Conversely,
             location of views will vary from case to case,                 additional farms placed closer than or at similar
             each fish farm proposal should be evaluated                    distances from an observer may substantially
             separately to determine the effect of distance and             increase visual impacts.
             orientation on views.
                                                                            The overall cumulative impact resulting from five
             The horizontal angle of view occupied by a farm                farms in an embayment, for example, would vary
             depends on its orientation and the position of the             considerably depending on whether there were
             observer as illustrated in Figure 17. There are a              other human-made structures in the area and on
             variety of farm configurations; however, a farm                observer attitudes. Placement of several farms in
             facility (100 ft by 1,000 ft [30 m by 305 ml) at a             an embayment that had few other human-made
             distance of 1,000 ft (305 m) from shore is used                structures might be perceived by some observers
             as an example.       For observers on the shore                as altering a natural environment to an urbanized
             immediately in front of the farm, an orientation               environment. Other observers may not perceive
             with the long dimension parallel to the shore                  any significant visual change due to an increase
             results in a substantially greater impact than an              in the number of farms because they do not
             orientation with the long dimension perpendicu-                perceive fish farms as a visual intrusion, or they
             lar to shore. As an observer moves along the                   perceive any fish farm to be a visual intrusion.
             shore in either direction, the farm orientation
             with the long dimension perpendicular to shore


             Page 86                                                                                                Visual Quality








                   z  cf)
                      0
                                                                                                                        INCREASING FEET ABOVE WATER
           'co (A 0)
           009        m
              0       0
                                                          105 FEET ABOVE WATER                                                   55 FEET ABOVE WATER                                                      5

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                                                       -Nor DIMINISHING VIEW IMPACT                       DIMINISHING VIEW IMPACT ]N-
                                                    LAND                                    4,955'                                 OBSERVER
                 SHORELINE
                                                   WATER


                                             2,000,
                                                                                            1,000'                                PREDOMINANT
                                                                                                                100,               VIEWSCAPE






                  L                                                                         4,464'
      SHORELINE                                     LAND                                                                           OBSERVER
                                                   WATER




                                                                                                                                  PREDOMINANT
                                                                                                                                   VIEWSCAPE
                                            "000,                                                                                            6P1
                                                                                                                                          fill





         SHORELINE                                                                          1,000,
                                                                              J I I I 1         11,11, 'H+H100,

          PERIPHERAL                       PERIPHERAL
          VIEWSCAPE                        VIEWSCAPE

                         PREDOMINANT
                           VIEWSCAPE
                                                                                                                              @PRE    OMINANT\
                                                                                                                JW                 VIMSCAPE



























         Note: Refer to text for
              discussion of this figure.

         SCALE IN FEET                                                                                            Figure 16.
         FI-T7                                                                                                    Schematic Example of View Impacts
         0      250      500                                                                                      Related to Distance and Orientation of Fish Farms









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              r,                                                                   0
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                                                                                                      HORIZONTAL VIEW ANGLE
                                                                                                 OCCUPIED BY FISH FARMS (DEGREES)
                                                                   1,000'         10


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             A hypothetical placement of five farms in a                           regarding visual impacts. For example, in
             typical Puget Sound embayment using the upper                         Kitsap County's Shoreline Management
             end of Carr Inlet as an example is illustrated in                     Master Program, preference is given to
             Figure- 18. A 2,000-foot (610-meter) radius is                        uses which "actively promote aesthetic
             drawn around each farm to illustrate the probable                     considerations" (Part 7).
             maximum extent of visual impact. This figure
             illustrates that at a density of more than five                       The regulations for developing local
             farms per embayment, the farms could be spaced                        shoreline   master     programs      contain
             so that no shore observer is within 2,000 ft                          guidance for local governments on specific
             (610 m) of more than one farm at any time.                            uses such as aquaculture (WAC 173-16-
             This indicates that with adequate spacing of                          060 [21). The language involving visual
             farms, the cumulative impact of several farms in                      impacts includes:
             an embayment could be minimal.             In other
             situations where there are few visually sensitive                     -  "Recognition should be given to the
             observers, it may be appropriate to more closely                         possible       detrimental        impact
             space farms to avoid placing farms in areas                              aquacultural   development might have
             having more observers.                                                   on the visual access of upland owners
                                                                                      and on the general aesthetic quality of
             The cumulative visual impact of many farms sited                         the shoreline area.
             closely together would be greater than the visual
             impact of one farm. Methods of spacing farms                          -  As aquaculture technology expands
             to reduce this cumulative effect are illustrated in                      with    increasing      knowledge     and
             Figures 19, 20,.and 21. Combined with controls                           experience, einphasis should be placed
             on the distance from shoreline, these three                              on     structures    which      do     not
             methods     would     achieve     similar     results.                   significantly interfere with navigation
             Regulations incorporating these types of controls                        or impair the aesthetic quality of
             could be adopted into local shoreline master                             Washington Shorelines."
             programs.
                                                                                   In response to these guidelines, counties
             6.1.2.1        No-Action Alternative -                                have included policies and regulations on
                            Existing Regulations and                               aquaculture in their shoreline programs.
                            Guidelines                                             Specific regulations vary from program to
                                                                                   program, but most local programs include
             The following existing regulations and guidelines                     language addressing visual impact values.
             affect potential visual quality impacts:                              For   example,     the   following     broad
                                                                                   language is used in the Kitsap County
                     State regulatory language for consideration                   program:
                     of visual impact values is based on the
                     Shoreline Management Act (RCW 90.58),                            "Aquacultural development shall
                     and is found in varying degrees in                               be designed and constructed to
                     different local shoreline master programs.                       harmonize insofar as possible with
                     The Shoreline Management Act requires                            the local environment, and shall
                     local governments, when appropriate, to                          be maintained in a neat and
                     include a conservation element in their                          orderly manner."
                     shoreline programs that addresses the
                     preservation    of    natural      resources,                 There are no specific regulations in place
                     including scenic vistas and visual impacts                    that define the maximum number of fish
                     (RCW 90.58.100 [2][9).          Most local                    farms that can be placed in a given area.
                     programs     include    general     language


             Page 90                                                                                             Visual Quality

















                                                                                                         10
                                                                                                      0-
                                                                                                  '04








                             A


                                                                                            ALLEN
                                                                                             POINT






                                THOMPSON
                                    SPIT
                                                                                  2,000'
                                                                                                      RAFT
                                                                                                     ISLAND







                                                                                      KAPACI@IUCK
                                                                                      STATE PARK
















                                                                      FOREST'
                                                                       BEACH
















        SCALE IN FEET                                                                                    Figure 18.

                                                                                                         Fish Farms in a Puget Sound
                                                                                                         Hypothetical Layout of Five

        0      2,000     4,000                                         Households                        Embayment: Carr Inlet Sample























                                                         L-5
                                                         w
                                                         LL



                                                         (0



                                                                          6,000 FEET                                  UPLAND












                                                                                       2,000 FEE7


















                                                                                                             Figure 19.
           SCALE IN FEET                                                                                     Potential Method of
           FI-F---]                                        r@ 100' x 1,000'                                  Fish Farm Density Control,
           0 - 1,0W        2,OW                                       Fish Farm                              Area by Square Footage








































                                                                                                                                   UPLAND
                               t7u
                               111                                                                  2,000 FEET
                               LL

























                                                                                                                           Figure 20.
            SCALE IN FEET                                                                                                  Potential Method of
            F-Lf---]                      -                                   100' X1,000,                                 Fish Farm Density Control,
          .0       1,000     2,000                                            Fish Farm                                    Area by Shoreline Footage


















                                                                                             1,500 FEET




                                                                                       ru
                                                                                       w
                                                                                       ILL


                                                                                       C)
                                                                                       C6













                                                                                                                        UPLAND
































                                                                                                                  Figure 21.
            SCALE IN FEET                                                                                         Potential Method of
                                                                          100' x 1,000'                           Fish Farm Density Control,
            0      1,000    2,000                                         Fish Farm                               Area by Radius









                     However, DNR presently uses a distance                                          Of a color which complements the
                     guidelines of one mile to separate farms.                                       dominant blue/green           colors of
                                                                                                     Puget Sound
                     Guidelines for minimizing potential visual
                     impacts from aquaculture operations are                                         Ordered and of limited variations
                                                                                                                                to
                     included in the Aquaculture Siting Study                                        in material and color.
                     (EDAW and CH2M Hill 1986).                      This
                     study divides the guidelines into two                                  one method of visual analysis is set forth
                     areas,     alternate     site    selection,      and                   in the Aquaculture Siting Study (EDAW
                     modification of siting and design.              The                    and CH2M Hill 1986).               This method
                     following is the language used in the                                  consists of a series of formalized rating
                     guidelines:                                                            sheets which provide an inventory of
                                                                                            existing    conditions      (including       scenic
                            W h e n       f e a s i b I e ,                                 quality, sensitivity level, and visibility) and
                           aquaculture         facilities                                   an assessment of visual impact.             Visual
                           should be located in waters                                      impact can be rated by considering the
                           offshore:                                                        various elements of the existing conditions
                                                                                            inventory.      Thus, a facility with high
                           -   Culturally modified          landscapes,                     visibility in an area of high scenic quality
                               preferably those with existing                               with viewers or uses with high sensitivity
                               commercial/industrial           maritime                     was rated as having a high visual impact.
                               activity                                                     This method has the advantage of
                                                                                            providing a structure and consistency to
                           -   Rural or uninhabited shorelines                              visual impact analyses.          On the other
                                                                                            hand, this method tends to be rigid, and
                           -   Low bank shorelines                                          may be insufficiently detailed to adequate-
                                                                                            ly distinguish the range of situations
                           -   Open shorelines.                                             occurring in the Puget Sound area.

                           When feasible, aquaculture facilities                            The EDAW study also includes a brief
                           should be sited or designed to be:                               listing of factors which contribute to
                                                                                            potential for cumulative visual impacts
                           -   At least 1,500 to 2,000 ft offshore                          such as the size of project, size of the
                                                                                            embayment, distance offshore, and viewing
                           -   Horizontal in profile                                        height, but does not offer any specific
                                                                                            guidelines.
                           -   Incorporated       as    part    of,    or
                               designed to appear as, docks or                    6.1.2.2            Preferred Alternative
                               marinas
                                                                                  Visual quality impacts from fish farms are site
                           -   Limited in overall size and surface                specific.     The various factors influencing the
                               coverage so as not to cover more                   potential for impacts (for example, topography,
                               than 10% of normal cone of vision                  number, location, attitudes of observers, and
                               (dependent on the degree of                        existing visual and development character) vary
                               foreshortening created by distance                 within Puget Sound and adjacent waters. Given
                               offshore to the facility and the                   this variability, uniform, specific visual quality
                               height of the observer above sea                   guidelines that would apply throughout the region
                               level)                                             are not appropriate.


           Visual Quality                                                                                                             Page 95












                              I
              Although specific guidelines regarding visual                                 Where it would not significantly affect
              quality are inappropriate, more general guidelines                            existing navigation patterns, design
              could be applied throughout the region. These                                 farms as small sets of pens grouped
              are:                                                                          together instead of a large pen
                                                                                            complex, thus avoiding extensive visual
                   ï¿½   In areas of high residential use or                                  elements.
                       sensitive uses such as shoreline parks, or
                       natural visual character, fish farm facilities                       Design     matcrials     used    in     farm
                       should be designed and located to reduce                             structures     tic)  be     non-reflective,
                       their visual obtrusiveness as much as                                somber-hued, and gray, green, or blue
                       possible                                                             in color.

                   ï¿½   In areas of high residential or sensitive                            Design lightil'ng provided on the
                       use, fish farms should be sufficiently                               structure to be the minimum necessary
                       separated to minimize the cumulative                                 for safe operation and navigation, and
                       visual impact on these uses                                          directed away from land areas, if
                                                                                            possible.
                   ï¿½   Potential visual quality impacts should be
                       assessed on a case-by-case basis to                                  Plan    storage     on    land    for    the
                       determine       appropriate         mitigation                       equipment used in the farm operation
                       measures.                                                            that is not a functional part of the
                                                                                            farm structurc.
              Specific guidelines are best determined by local
              jurisdictions, and expressed as policies and                                  Maintain the minimum number and
              regulations    in   individual     shoreline      master                      size of buildings on the floats
              programs.       It is recommended that local                                  necessary for the safe,            efficient
              governments adopt measures that use design or                                 operation of the facility.
              location guidelines to address local concerns
              regarding visual impacts.                                            Location.      Farms sited 1,500 to 2,000 ft
                                                                                   offshore will prevent significant adverse visual
                   Design. The design      of farm structures may                  quality impacts to shoreline areas. However,
                   serve either to increase their visibility or to                 increasing the distance between farms and
                   visually submerge them in their surroundings.                   adjacent shorelines may increase conflicts with
                   For example, increasing visibility could serve                  navigational use and commercial fishing. It is
                   as  an    architectural    statement     and     be             recommended that local governments allow
                   appropriate in some urbanized areas.              In            flexibility in their policies to accommodate
                   many areas, however, fish farm structures                       site specific conditions that may warrant
                   should be designed to be visually unobtrusive.                  different separation distances.        Where low-
                                                                                   level shorelines are nearby, the farms can be
                   The following measures describe some design                     sited 600 m (2,000 ft) or more from shore to
                   features that would help visually submerge a                    minimize visual detection of the farms. In
                   farm structure:                                                 areas of high shoreline bluffs and adequate
                                                                                   nearshore water depth and currents, the visual
                          Limit the distance structures that                       impacts may be minimized by placing the
                          would project above the water surface                    farms close to the shoreline where they can
                          to that distance necessary for the safe                  only be seen from the edge of the bluff.
                          and efficient operation of the facility.




              Page 96                                                                                                   Visual Quality








              .ImRIementation.         Design    and     location         obstructions in the water since the latest chart
              measures described in this section could be                 was issued.
              implemented through the shoreline permitting
              process. As an alternative to the analytical                Most large ocean-going ships travel within the
              framework outlined in theAquaculture Siting                 established shipping lanes clearly marked on
              Study, fish farm proposals could include a                  nautical charts. Vessels in the state ferry system
              visual    quality    analysis    describing      the        have established routes in Skagit, San Juan,
              proposal's    compliance with design and                    Island, Snohomish, King, Kitsap, and Pierce
              location guidelines. Without prescribing         the        counties.   In addition, some counties such as
              nature of the visual impact analysis,           this        Skagit and Whatcom provide their own small
              requirement would not be particularly rigid,                ferry service.
              and it could be adapted to the needs of each
              local jurisdiction.                                         Other commercial shipping does not have
                                                                          established routes identified on nautical charts.
          6.1.3        Mitigation Measures and                            For example, the towboat industry hauls barges
                       Unavoidable Significant                            and logs all over Puget Sound. Towboats use the
                       Adverse Impacts                                    main shipping lanes, but will also hug shorelines
                                                                          if they offer protection from wind, strong
          If guidelines in the Preferred Alternative are                  currents, or wave conditions that would jeopar-
          tailored to address local concerns and adopted by               dize the cargo or delay delivery.
          local governments through their shoreline master
          programs, significant adverse visual impacts will               Puget Sound is also the location of some of the
          be avoided and no further mitigation measures                   finest recreational boating opportunities anywhere
          would be necessary.                                             in the nation.     Data are not available on the
                                                                          densities of recreational boaters at specific
          6.2          NAVIGATION                                         locations and the routes used by boaters to get
                                                                          from their point of origin to their destination.
          Concerns have been raised        that fish farms will           However, destinations usually have some amenity
          impair normal navigation routes and present a                   such as access to a state marine park, public
          hazard to commercial and recreational vessel                    beach, recreational fishing "hole," marina, or
          traffic.   An additional issue is the potential                 retail goods like restaurants and stores.            In
          impact of numerous aquaculture facilities in an                 addition, many commercial and recreational boats
          area restricting access to popular cruising, fishing,           will use protected bays for shelter during storms
          and moorage areas.                                              (see Section 6.5, Recreation).

          6.2.1        Affected Environment                               6.2.2       Impacts on Navigation

          The waters of Puget Sound comprise roughly                      A fish farm, like an island or dock, is a fixed
          6,500 km2 (2,500 square miles) of surface area.                 object in the water.       Fish farms can impact
          Vessels using Puget Sound vary from large ocean-                navigation if sited in established navigation lanes,
          going bulk cargo and container ships, to ferries,               narrow channels, or where boats would be unable
          towboats, commercial fishing boats, recreational                to navigate safely around them. In addition, if
          boats, and other assorted water craft.                          fish farms break loose from their anchors during
                                                                          severe weather conditions they could become a
          Nautical charts showing depths, obstructions, and               hazard to vessel traffic.        If fish farms are
          aids to navigation are available for all of Puget               inadequately lighted or made visually unobtrusive,
          Sound.     In addition, boaters can receive the                 they pose a greater risk to navigating vessels and
          Notice to Mailners publication. This publication                may be a significant safety hazard, especially at
          identifies changes in navigation aids and new                   night or during inclement weather.


          Navigation                                                                                                    Page 97









             Placement of one or more fish farms in an                               proposals, including fish farms, will not
             embayment may affect safe anchorages. During                            be sited in estabfished navigation areas.
             inclement weather, recreational boaters and
             towboats may seek sheltered bays for protection                         The USCG is allso responsible for es-
             from storms.     If floating structures restrict the                    tablishing and maintaining a series of
             use of a sheltered bay for anchorage by blocking                        public buoys and lights to aid navigation
             channels or limiting maneuverabil       'ity, towboats                  through Puget Sound and may require
             and other boaters may have to travel to the next                        structures such as fish farms to install
             available safe anchorage.        Depending on the                       private aids to navigation to reduce the
             weather conditions, this could create a hazard for                      potential for collision.    The USCG has
             the boat, passengers, or commercial cargo.                              established    a     minimum       brightness
                                                                                     standard that requires navigational lights
             Fish farms located near shore would affect                              to be visible on a clear night for at least
             navigation in a manner similar to a long dock, a                        one mile (1.6 km).         In addition, the
             marina, or a series of anchored boats.            Most                  USCG standardized a 6-second flash rate
             commercial traffic will tend to stay in deeper                          (0.5 seconds on and 5.5 seconds off) for
             water, thus avoiding such areas. However, some                          lights associated with fish farms.         The
             commercial traffic such as towboats towing barges                       number and placement of any required
             or log rafts may hug the shoreline. The further                         private aids to navigation is at the
             offshore the farm is located, the greater the                           discretion    of     the   USCG        District
             navigational risk because structures are not                            Commander (Title 33 CFR Part 66).
             expected, reference points are not nearby, traffic                      Also, structures in the water that receive
             is more intense, and vessels are usually travelling                     the appropriate permits will be included
             faster.                                                                 in the Notice to Mariners and will be
                                                                                     placed on charts when updated.
             Fish farms may also have a beneficial impact on
             navigation.    In more remote areas, typical of                         DNR requires a bond from fish farmers
             recently permitted farm sites, fish farms can                           to ensure cleanup of any debris caused
             provide a point of assistance/ refuge for boaters.                      by accidental destruction of the farm.
             The farm sites usually have some form of sea-                           This bond would ensure that impacts to
             to-land communication.                                                  navigation caused by the breakup of a
                                                                                     farm during a storm would be temporary.
             6.2.2.1         No-Action Alternative -
                             Existing Regulations and                                The    Washington      State    Parks      and
                             Guidelines                                              Recreation Commission (WSPRC) reviews
                                                                                     applications for proposed fish farms under
             The following existing regulations and guidelines                       SEPA. This review specifically evaluates
             affect potential navigation impacts:                                    the   potential    navigation    hazard     to
                                                                                     recreational boaters visiting Washington
                     Presently, siting decisions    for fish farm                    marine parks.
                     proposals are made on a case-by-case
                     basis. Any structure that may interfere                         The impacts of a fish farm on navigation
                     with navigation must receive an ACOE                            are also considered by local government
                     Section 10 permit. The U.S. Coast Guard                         as part of the permitting process under
                     (USCG)      has the responsibility for                          the Shoreline Management Act.              For
                     reviewing all proposed structures in Puget                      example,    Kitsap     County's    Shoreline
                     Sound for potential navigation hazards                          Management Mai-ter Program provides
                     through the ACOE permitting process.                            rules for fish farm establishment with
                     The USCG review ensures that all                                respect to navigation. The Program states


             Page 98                                                                                                    Navigation









                   that "aquacultural structures [fish farms]                      structures such as docks and marinas to
                   shall be placed, when practicable, so as to                     reduce impacts to navigation.
                   minimize      interference     with     surface
                   navigation" (Part 7, Chapter 11).          The         6.2.3        Mitigation Measures and
                   Program also states that fish farms that                            Unavoidable Significant
                   are hazards to navigation should be                                 Adverse Impacts
                   suitably marked for day and night
                   visibility.                                            The SEPA review and ACOE Section 10
                                                                          permitting processes allow an opportunity to
           6.2.2.2         Preferred Alternative                          evaluate fish farm proposals on a case-by-case
                                                                          basis. These mechanisms provide the assessment
           It is recommended that local governments                       of navigation impacts to be determined using the
           implement the following measures through their                 most current information for a specific site.
           SEPA    and shoreline permitting processes to                  Local implementation of the two notification
           reduce  impacts to navigation:                                 measures      recommended       in    the     Preferred
                                                                          Alternative and the use of existing regulations
               ï¿½   Provide      major       recreational       and        are   adequate     to   avoid significant       adverse
                   commercial boating organizations with                  navigation impacts.       No additional mitigation
                   SEPA and shoreline permit notices to                   measures are necessary.
                   help identify areas of special importance
                   to boaters.                                            6.3          COMMERCIAL FISHING


               ï¿½   Provide notification to recreational and               Since fish farms occupy space in the water, there
                   commercial boating organizations and all               is the potential for commercial fishing boats to
                   marinas and ports near the farm of the                 run into or have their nets become entangled
                   precise location of farms and their aids               with the farms.      The resulting displacement of
                   to navigation.                                         fishers from accustomed fishing areas is therefore
                                                                          the larger issue. This displacement could reduce
           There may be site specific conditions that                     the overall catch to a fishery, or affect the
           warrant additional siting considerations to further            attainment of court-ordered allocations between
           reduce the potential impact on navigation. These               tribal and non-tribal fishers. The reduction in
           siting considerations include:                                 catch and damage to fishing gear represents a
                                                                          loss of income to individual fishers.
               ï¿½   In areas suitable for raising fish and with
                   high-bank shorelines, low boating use, and             6.3.1        Affected Environment
                   adequate currents and depth to avoid
                   biological impacts; it is recommended that             General. The State of Washington has an active
                   local governments encourage siting farms               commercial fishing industry. Ward and Hoines
                   near the shoreline. Thus, in areas where               (1986) estimate the total catch value of all
                   the site does not exacerbate other                     Washington      sea   products    (salmon,      halibut,
                   problems, impacts to navigation would be               shellfish, bottomfish, and other marine fish)
                   reduced.                                               caught by the industry in 1986 was worth roughly
                                                                          132 million dollars. Many boats in the fleet will
               ï¿½   In areas suitable for raising fish and                 pursue more than one species of fish during the
                   where adequate depth and currents exist                year. While there are many different fish species
                   to    avoid   biological    impacts,    it    is       caught by the commercial fishing industry, the
                   recommended that local governments                     dominant species sought in Puget Sound are
                   encourage siting farms adjacent to existing            salmon: chinook, coho, chum, pink, and sockeye.
                                                                          Gillnetters are the dominant salmon fishery in


           Commercial Fishing                                                                                            Page 99









              Puget Sound with almost 1,200 licensed boats in                     maintain the court-ordered balance of allocation
              1986 that harvested 19 million pounds.                  The         between treaty and non-treaty fishers.
              number of licenses issued to various segments of
              the Puget Sound commercial fishing industry in                      A primary consideration in the Puget Sound
              1986 is listed in Table 6.                                          harvest management process is the determination
                                                                                  of the harvestable amount of each salmon run

              Table 6.          Number of Puget Sound salmon, bottomfish, and shellfish commercial fishing licenses by
                                gear type, 1986.


              Gear Type                                                                Number



              Salmon
              Gill Net                                                                  1188
              Purse Seine                                                               343
              Reef Net                                                                   50
              Troll                                                                     707


              Bottomfish
              Bottomfish Pot                                                               9
              Dip Bag Net                                                                84
              Drag Seine                                                                 66
              Handline/Jigger                                                           595
              Lampara/Round Haul                                                         19
              Otter Trawl                                                               108
              Purse Seine                                                                  2
              Set Line                                                                  278
              Set Net                                                                    55
              Troll                                                                     232


              Shellfish
              Beam Trawl                                                                 26
              Geoduck Clam                                                               13
              Ring Net                                                                  178
              Shellfish Pot (Crab)                                                      247
              Shellfish Pot (Non-crab)                                                  173


              Source: Ward and Hoines 1986.


              Management of fishery resources in Washington                       returning to Puget Sound. The process begins
              is complex. In an effort to effectively manage                      with estimates of expected populations of
              fishery resources to achieve a sustainable yield,                   returning runs for each species on each river.
              the  State and treaty tribes regulate where, when,                  The optimum number of fish needed for hatchery
              and  for how long the commercial fishing industry                   and natural spawning is then determined. This
              can  fish for specific species. Although WDF and                    escapement goal is subtracted from the total run
              the  tribes administer many management programs                     forecast to achieve a harvestable number of fish.
              for  commercial finfish and shellfish harvesting,                   In a lengthy series of court decisions culminating
              the  most complex is the salmon program. That                       in a 1979 U.S. Supreme Court opinion, the tribal
              program is designed to meet the specific                            right to harvest fish-a right first established by
              spawning requirements for each salmon stock, and                    the District Court in U.S. v. Washington in


              Page 100                                                                                                 Commercial Fishing









          1974- was found to be guaranteed by the treaties               for specific runs of fish in specific management
          between the United States and Indian tribes in                 areas.
          Washington.
                                                                         The active use of Puget Sound waters for
          In order to ensure the proper implementation of                commercial fishing varies in intensity.          Some
          this treaty right without court intervention, the              areas experience extreme congestion during a
          salmon and steelhead originating from Puget                    commercial opening while other areas are not
          Sound are cooperatively managed by the tribes                  used at all.       The State establishes which
          and the State.      Harvest management, artificial             management areas will be open for commercial
          and natural production, and other issues affecting             fishing at a particular time during the season and
          the survival and abundance of the fisheries                    for how long a specific gear type can fish during
          resource are cooperatively addressed by state and              the opening. The number of salmon caught in
          tribal fisheries managers. Tribal review of, and               1986 by various gear types for the various
          comment on, issues affecting the marine habitat                management areas is shown in Table 8.
          are based in part in their role as a manager of
          the fisheries resource.                                        The number of areas in Puget Sound open simul-
                                                                         taneously for commercial salmon fishing ranges
          Each year, a management plan is established                    from one to nine (Clocksin 1988). When only a
          between the tribes and WDF for each salmon                     few areas are open at one time, commercial boats
          species. This   management plan includes harvest-              from all over the Sound will congregate in these
          able amounts for each species, the time periods                areas, creating a lot of congestion. This conges-
          during which    fish will be harvested, and specific           tion is exacerbated at some management area
          harvest plans   and conservation measures.                     boundary lines, where fishers line up to get "first
                                                                         crack" at fish entering the management area open
          Treaty tribes fish in "usual and accustomed"                   for fishing.
          marine and freshwater fishing areas throughout
          the fresh and salt waters of the Puget Sound                   The Hood Canal bridge is the northern boundary
          Basin. Non-Indian fishers harvest in these same                line of management area 12 and is a prime
          areas.   In order to facilitate management, the                example of this congestion. At times when area
          marine   areas of Puget Sound and the Strait of                12 is open for commercial salmon fishing, as
          Juan de Fuca have been divided into numerous                   many as 100 boats will congregate at the bridge
          management areas to create discrete geographical               to catch fish bound for streams that drain into
          areas within which distinct populations of fish can            Hood Canal.
          be managed.          The Puget Sound salmon
          management and catch reporting areas are shown                 Puget Sound Commercial Fishing Techniques.
          in Figures 22 and 23. Within these areas, fishery              The Puget Sound commercial fishing fleet uses a
          managers can reasonably predict the origin of a                variety of techniques to catch fish.            These
          particular stock of fish, or the mix of stocks.                techniques can be categorized into three groups
                                                                         (stationary, powered, and drifting) according to
          Management      periods define the time "window"               how they move through the water.
          during which    fishery managers will regulate the
          harvest    of   each   fish   stock.      The     basic        Stationary techniques include reef nets, set
          management periods for each species and                        gillnets, and crabbing. The technique of fishing
          management      area are provided in Table 7.                  with reef nets involves creating a false reef using
          Management      periods are based on the central               stationary nets near the shoreline that intercept
          80% of the run, and considering "early arrivals"               fish in their migration routes. Fish swim between
          and "stragglers," fish runs extend over a lengthy              two nets hung vertically in the water forming a
          time period.      These management periods are                 "V" that leads into a third net. This net forms
          individually established by WDF and the tribes                 an artificial reef which can be lifted to entrap the


          Commercial Fishing                                                                                          Page 101








                                                                                                                                                             CANADA

                                                                                                                                                          UNITED STATES




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               QYVljj,@@ pq
                                                 014-
                       4B
                                                                                                                                                                   7
                                               4%





                                                                                                                                         00
                                                                                                                             00  00  00
                                                                                                         naft            00


                                                                                                     6C                                    6





                                                                                                                            PORT
                                                                                                                         ANGELES


         Source: WDF 1987


         SCALE IN MILES                                                                                                                             Figure 22.
                                                                                                                                                    Northern Puget
         0        5        10                                                                                                                       Management an















                          PORT
                        ANGELES                                                                                            8D..



                                                                                                9                         EVERETT








                                                                                        2

                                                                             12A




                                                                          120                                 10


                                                                                                                   E      LE


                                                                     y
                                                                           BREMERTON:







                                                      12C'
                                                                    12D



                                                                             .13
                                                                                          A


                                                                                                             I I A


                                                                                                          ACOMA


                                                                               13
                                                                                              13
                                                          131'

                                                                                                     1-5
                                                                 3G     i3F


                                                                             OLYMPIA



          Source: WIDIF 1987





                                                                                                               Figure 23.
                                                                                                               Southern
          SCALE IN MILES                                                                                       Puget Sound Commercial
                                                                                                               Salmon Management and
         0        5        10                                                                                  Catch Reporting Areas








               Table 7.      Generalized salmon management periods by management areal.


                                                                                                                    E. Stuart          Mid-Late
                                                                                                                    and Puget          Fraser R.
               Area      SP Chin           S/F Chin                 Pink          Coho               Chum           Sound Sock.          Sock


               4B        4/15-6/15         6/26-8/16                8/14-9/9      8/13-10/5          10/5-12/14     6/1-7/28           6/20-10/1
               5         4/15-6/15         6/26-8/16                8/14-9/9      8/13-10/5          10/5-12/14     6/1-7/28           6/20-10/1
               6         4/15-6/15         7/1-8/29                 8/14-9/11     8/21-10/13         10/3-12/17     6/3-8/4            6/20-10/1
               6A        4/15-6/15         6/16-9/6                 8/4-9/13      8/29-10/21         10/3-12/17     6/3-8/4            6/20-10/1
               6B        4/1576/15         7/7-9/4                  6/30-9/11     8/24-10/15         8/7-12/19      6/3-8/2            SNP
               6C        4/15-6-15         7/1-8/21                 8/14-9/9      8/13-10/5          10/5-12/14     6/1-7/28           6/20-10/1
               6D        4/15-6/29         7/21-9/21                6/30-9/21     9/20-10/28         10/27-12/7     SNF                SNP
               7         4/15-6/15         6/16-9/6                 8/22-9/13     9/1-10/12          10/1-12/17     6/5-7/28           6/20-10/1
               7A        4/15-6/15         6/16-9/13                8/25-9/14     8/22-10/18         10/3-12/17     6/5-7/28           6/20-10/1
               7B        4/15_2            -9/72                    6/30-8/17     9/8-10/26          10/27-12/14    ***                SNP
               7C        4/15-             -MID OCT                 SNP           10/15-10/26        10/27-12/7     SNP                SNP
               7D        SNP               -9/7                     SNP           9/8-10/26          10/27-12/14    -SNP               SNP
               8         4/15_2            -8/13                    8/22-9/15     9/2-10/27          10/25-11/28    6/211-7/13         SNP
               8A                          7/21-9/9                 8/9-9/9       9/10-10/12         10/22-11/30    *-*                SNP
               8D        SNP               7/21-9/21                SNP           9/22-11/12         11/11-12/17    SNP                SNP
               9         4115-6115         7/12-9/4                 7/11-9/5      8/24-10/15         8/12-12/25     6/3-8/4            SNP
               10        4/15-6/29         7/1-9/7                  8/18-9/19     9/8-10/12          9/8-1/1        6/10-8/4           SNP
               10A       SNP               7/1-9/14                 SNP           9/15-11/2          11/3-11/30     6/10-8/4           SNP
               10C       SNP               7/1-9/28                 SNP           9/28-11/30         SNP            6/10-12/31         SNP
               10D       SNP               7/15-10/5                SNP           10/6-12/14         SNP            6/10-12/31         SNP
               10E       SNP               7/1-9/13                 SNP           9/14-10/11         9/28-12/31     SNP                SNP
               1OF       SNP               7/1-9/14                 SNP           9/15-11/30         SNP            6/10-8/4           SNP
               10G       SNP               7/1-9/28                 SNP           9/29-11/30         SNP            6/10-12/31         SNP
               11        4/15-6/29         7/1-9/10                 8/18-9/10     9/11-10/21         9/10-1/8       ***                SNP
               12        4/15-6/29         7/17-9/6                 7/16-8/24     9/7-10/18          8/16-12/7      SNP                SNP
               12A       4/15-6/29                                                9/6-10/7           8/26-12/21     SNP                SNP
               12B       4/15-6/29         7/17-9/6                   /16-8/24    9/7-10/18          8/16-12/14     SNII               SNP
               12C       4/15-6/29         7/24-9/6                 7/23-8/31     9/11-10/25         8/26-12/21     SNP                SNP
               12D       4/15-6/29         7/24-9/6                 SNP           9/11-10/25         8/26-11/27     SNP                SNP
               13        4/15-6/29         7/1-9/24                 8/10-9/25     9/25-11/6-         9/17-1/15      SNP                SNP
               13A       4/15-6/29         8/8-9/16                 8/16-9/17     9/17-11/9          10/23-12/31    ***                SNP
               13C       SNP               7/15-10/13               SNP           10/14-11/30        10/12-1/16     SNP                SNP
               13D       SNP               7/1-9/21                 SNP           9/22-10/12         9/17-12/31     SNP                SNP
               13E       SNP               7/1-9/21                 SNP           9/22-10/12         10/12-12/31    SNP                SNP
               13F       SNP               7/1-9/21                 SNP           9/22-11/6          11/7-12/12     SNP                SNP
               13G       SNP               7/1-9/21                 SNP           9/22-11/6          11/7-12/12     SNII               SNP
               13H       SNP               7/1-9/21                 SNP           9/22-10/12         10/12-12/31    SNP                SNP
               131       SNP               7/1-9/21                 SNP           9/22-10/12         10/12-12/31    SNP                SNP
               13J       SNP               7/1-9/21                 SNP           9/22-10/12         9/22-12/31     SNP                SNP
               13K       SNP               7/1-9/21                 SNP           9/22-11/6          9/22-12/31     SNP                SNP

               'Management periods adjusted annually for administration of fisheries.
               2Management period currently under technical dispute; subject to change according to long range management planning.
               *** Stock present but no management period established.
               SNP - Stock not present.


















               Page 104                                                                                                        Commercial Fishing








            Table 8.         Total commercial net catch of Pacific salmon in Puget Sound by management area, 1988
                             (in numbers of fish).


                             Non-Indian                         Indian                          Other
            Area       GW              Pï¿½5__           GW              Sw             PSP         Gear TypesF       Total


            4B               82         ---          8,675           3,921              ---             16         12,694
            5             5,930         ---        250,442           3,568              ---             ---       259,940
            6           36,927          ---          9,093              ---             ---             61         46,081
            6C               135        ---          1,667           1,984              ---             16          3,802
            6D            6,787            3            ---          1,820              ---             ---         8,610
            7          314,386     720,604         431,330           5,850         730,374         89)66.5P     2,292,209
            7A         202,526     563,013         259,858          15,194         181,086              70      1,221,747
            7B          98,471       31,915         90,259          26,800           16,643             ---       263,088
            7C            3,538         ---            316              ---           212               ---         4,066
            7D            7,449         ---            501              ---             ---             ---         7,950
            7E          45,723        1,461             ---             ---             ---             ---        47,184
            8           28,921        4,568         12,173             755            580            7,879         54,876
            8A          32,434     138,020         170,745           2,973              83           5,684        349,939
            8D            4,420       6,351            632          28,664                           3,399         43,466
            9           43,234          ---            250           8,618              ---             ---        52,102
            9A               ---        ---             ---          5,998              ---             ---         5,998
            10         112,363     180,574          79,702           2,750          57,286              ---       432,675
            10A              ---        ---         41,744           2,456              ---             ---        44,200
            10E              ---        ---         13,052          21,917            379                 6        35,354
            1OF              ---        ---          3,587          34,618              ---             ---        38,205
            11          28,406     117,268          18,452              90              ---             18        164,234
            11A              ---        ---         41,254             854              ---                        42,108
            12          59,635     328,001         206,652           3,326            866               ---       598,480
            12A           1,202         777          8,501          23,951              ---          1,847         36,278
            12B           3,295      10,592         22,421           5,539              ---             25         41,872
            12C           1,938      15,887         43,877          60,379              ---          4,732        126,813
            13               ---        ---            910             802              ---          1,712          3,424
            13A           2,782       1,739         30,914          18,442              ---          4,944         58,821
            13C              ---        ---             ---             ---                          4,930          4,930
            13D              ---        ---         19,994          93,282              ---          2,213        115,489
            13F              ---        ---             ---            302              ---             ---            302

            Totals     1,039,584  2,120,773       1,767,001         374,853        987,509         127,217      6,416,937


            Source: WDF 1988.
            a Gillnet
            bPurse Seine
            cSet Net
            dBoth Indian and non-Indian. Includes reef nets, beach seines, and other gear types.
            eAll fish caught by reef nets.










            Commercial Fishing                                                                                   Page 105








            fish. Reef netting zones, established by statute,              Gillnetting is the primary commercial fishing
            are primarily located in the San Juan Islands.                 technique that involves d6fting with the current.
                                                                           As with set gill nets, the intent of the fisher is to
            Set gillnets are vertically hung nets anchored       in        block the path of the fish so they swim into the
            migration routes. Fish will swim into the mesh                 vertically hung net'and become entangled. Most
            of the net and become entangled. To help keep                  gillnet boats will use a nel: 550 m (1,800 ft) long
            the net vertical in the water, it is supported at              by 9 to 30 m (30 to 100 ft) deep. The net is
            the surface by a series of floats and weighted at              supported at the surface by floats, and kept
            the bottom.      Set gillnets can be attached to               relatively vertical in the water by a weighted line
            shore, dock, or other shoreline feature, and are               on the bottom of the net.
            usually anchored to the bottom at the net's other
            end.                                                           Gillnetters set their nets perpendicular to the
                                                                           prevailing current to block the migration route of
            The  crabbing industry uses round traps (1-meter-              the fish. They then drift with the current, and
            diameter pots) that rest on the bottom.           Each         when the skipper determines that sufficient time
            crab boat has many baited crab pots, which are                 has passed, the net is pulled back on the boat by
            attached to a line with a float, and then dropped              a power-operated drum, and the fish are removed
            overboard. The pots sit on the bottom until they               from the net. The amount of time necessary to
            are retrieved for harvesting.           The smaller            "pick" the net will vary from about 20 minutes to
            commercial shrimp fishing industry uses similar                an hour depending on the amount of fish and
            gear.                                                          debris in the net.         During the process of
                                                                           retrieving the net and harvesting the fish, the
            Commercial fishing techniques that use motor                   boat continues to drift.
            power to fish include purse seining, trolling, and
            trawling. Purse seine fishing involves encircling              6.3.2       Impacts on Commercial
            a school of fish with a net and then gathering the                         Fishing
            bottom of the net, forming a purse that traps fish
            inside. While setting the net, usually about 550               Fish farms  are a physical obstruction in the water
            m (1,800 ft) long, a small power skiff is used to              which, along with the area encompassed by their
            hold the end of the net in place while they drift              anchor lines, pose a threat to commercial fishing
            with the current.    When the school is completely             like that described in Section 6.2, Navigation.
            surrounded by the net, the bottom is closed off,               This potential problem is complicated by the
            and the fish become trapped. The seine boat                    complex     nature    of   fisheries     management,
            then retrieves the net from the water and                      especially for managing the various salmon
            harvests the fish.                                             species.

            Trolling involves a boat slowly moving through                 The direct impact of floating fish farms on
            the water, trailing lines with baited hooks in the             commercial fishing is the potential for collision or
            water.   Fish are retrieved from the lines after               entanglement of the fishing nets with the farms,
            they take the bait, and the hooks are baited again             resulting in a loss of available fishing area and a
            and set back into the water.                                   financial loss because of damaged or destroyed
                                                                           gear.   The probability of such an occurrence
            Another technique for catching fish using motor                depends upon the location of the farm, and the
            power is the trawl. Various types of trawls (for               type and intensity of fishing in the area. Results
            example, otter and beam) are used to catch                     of this impact can be displacement of fishers
            several species of bottomfish and shrimp. This                 from a productive and accustomed fishing area,
            method consists of dragging a large bag-shaped                 lost harvest potential, and reduced opportunity of
            net at various depths, most commonly along the                 the fishers to catch their allotment of salmon.
            bottom. Fish are caught in the net as the boat
            drags the net through the water.


            Page 106                                                                                         Commercial Fishing









           Gillnetters are the group potentially most affected          the boats, other types of gear would be less
           by the placement of fish farms because the                   affected. Purse seiners have greater control over
           number of boats using this technique is greater              the location of their sets and could fish close to
           than all other techniques, they have limited                 the farm, especially on the down current side.
           maneuverability, and they fish at night when                 Trawlers could fish close to the farm site,
           visibility is limited. Placing a fixed object in the         excluded only from the area occupied by the farm
           middle of a drift forces gillnetters to avoid the            and anchor lines. Crab and shrimp fishers could
           immediate area, or attempt to pull their nets                set pots within the perimeter of the anchors. For
           near the farm and risk entanglement.             Drift       those gear types able to fish close to the farm,
           netters must also avoid natural and manmade                  there may actually be benefits to the fishers
           obstacles as part of their fishing effort. These             because    of the    attraction   of commercially
           include islands, points of land, rocks, docks,               desireable fish and shellfish to the area of the
           buoys, and bridge supports.                                  floating fish farm, especially crab. Migratory fish
                                                                        may also be concentrated as they navigate around
           Because drift netters rely    on currents to carry           the pens.
           their nets while fishing, the potential conflict is
           increased.     Similar current areas are also                The displacement of fishers from an established
           desirable for fish farms which need moderate                 fishing area may have an effect on the
           currents to flush the pens and to minimize                   commercial fishing industry, but the significance
           sediment accumulations. However, the areas of                of the potential impact depends on site specific
           greatest conflict are not only determined by                 conditions.     If non-tribal fishers have the
           current or other factors, but also by the location           opportunity to catch the same fish in another
           of WDF management area boundaries along                      area  opened for fishing, displacement of fishers
           which most fishing is concentrated.                          from  a particular site may not exclude those non-
                                                                        tribal fishers from catching fish. This may be the
           The size of the area from which        drift netters         case  in situations where a relatively large area
           would be prevented from fishing         depends on           exists between the farm site and the management
           many factors, especially the distance of the farm            area boundary.
           from shore.      The further offshore the farm
           extends, the greater the area affected. Moving               The potential displacement of tribal fishers could
           pens offshore 610 in (2,000 ft), as previously               also occur. Tribal fishing efforts are restricted to
           suggested to minimize visual quality impacts                 their "usual and accustomed" fishing areas. Each
           (Section 6.1, Visual Quality), increases the                 of the treaty tribes included in U.S. v. Washington
           impacted area by extending the farm further into             (Boldt decision) have specific areas of Puget
           fishing channels, while also excluding the standard          Sound that are designated as their "usual and
           550 m (1,800 ft) net inshore of the farm.          In        accustomed" fishing areas. If a farm prevents a
           addition, some fishing boats use tapered nets that           particular tribe from fishing in these areas, the
           allow them to fish close to shore in areas where             tribe would have nowhere else to fish, and a
           the bottom is free of objects that could entangle            significant impact could result.
           their nets. In intensely fished areas, such as the
           waters near the Hood Canal Bridge, the presence              In some cases, fish may not be available to the
           of a fish farm could result in intense conflicts             same fishing group. If opportunities for harvest
           with fishers, and significant risk of collision and          are reduced in established non-tribal fishing
           entanglement during the fishing season. In other             areas, and the fish migrate into areas open only
           areas where fishing is much less congested, a fish           to tribal fishing (generally closer to the mouths
           farm would have proportionately less impact.                 of spawning rivers), the non-tribal fishers may
                                                                        lose part of their salmon allocation. The current
           While the fishing area for gillnetters affected    by        salmon management plans would be disrupted,
           fish farms is relatively large due to the size     of        and adjustments would be required.
           the nets used and the limited maneuverability      of


           Commercial Fishing                                                                                       Page 107









             A third potential impact would be that the fishing                        The U.S. v. Wa,-,,hington case (Boldt
             opportunity is lost to all fishers, and fish return                       decision) determined that treaty tribes in
             to their native streams.        Because salmon are                        Puget Sound shall be allowed to fish in
             already managed to assure that adequate numbers                           their "usual and accustomed" fishing areas.
             of fish return to the streams to maintain viable
             runs, these additional fish would be surplus. Any                6.3.2.2          Preferred Alternative
             surplus to the needed number of spawners that
             eludes tribal and non-tribal fishers would                       The existing requirement that WDF promote
             represent an     unnecessary loss to the fishing                 orderly fisheries (RCW '75.08) is adequate to
             industry.                                                        protect commercial fisbing from significant
                                                                              adverse impacts related to the siting of fish
             6.3.2.1          No-Action Alternative -                         farms. The review of proposals under SEPA and
                              Existing Regulations and                        the ACOE Section 10 permit provide ample
                              Guidelines                                      opportunities to identify important commercial
                                                                              fishing areas and supply decisionmakers with
             The following regulations and guidelines affect                  appropriate information regarding siting of fish
             the potential impacts of fish farms on commercial                farms.
             fishing.     Regulations      related    to    potential
             navigation impacts are discussed under Section                   It is recommended that the following measures
             6.2, Navigation.                                                 be implemented by local governments through
                                                                              their SEPA and shoreline permitting processes to
                 ï¿½   WDF is required to promote               orderly         further  reduce impacts to tribal and commercial
                     fisheries, and enhance and              improve          fishing  activities-
                     recreational and commercial fishing in
                     Washington (RCW 75.08.012). WDF has                               Provide commercial fishing organizations
                     the authority to ensure that a fish farm                          and tribes with SEPA notices related to
                     does not interfere with an orderly fishery.                       fish farm proposals.         This will help
                                                                                       identify areas of special importance to
                 ï¿½   WDF reviews fish farming proposals for                            tribes and commercial fishing groups.
                     potential impacts to commercial fishing
                     through the SEPA process. This process                            Provide notification to the tribes and
                     allows WDF to identify whether a                                  commercial fishing organizations of the
                     proposal is near an important commercial                          precise location of farms and the layout
                     fishing area and provide their expertise                          of their anchor lines.
                     to     the   SEPA , lead       agency when
                     determining a proper farm location.                      As with navigation issues, there may be site
                                                                              specific conditions that warrant additional siting
                 ï¿½   WDF also reviews projects under its        HPA           considerations to further reduce the impacts on
                     permit process (RCW 75.20).                 This         fishing  activities. These include:
                     mechanism allows WDF an opportunity to
                     modify a fish farm proposal to ensure that                        In a suitable fish farming area with low
                     the commercial fishing industry is not                            visual impact potential (for example, high-
                     significantly affected.                                           bank shorelines), adequate currents and
                                                                                       depth to avoid biological impacts, and
                 ï¿½   The ACOE Section 10 permit process also                           significant fishing activity occurring more
                     provides    an    opportunity to        identify                  than 2,500 ft offshore; it is recommended
                     important commercial fishing areas. WDF                           that local governments encourage siting
                     provides their input to Ecology for                               farms close to shore, and aligning them
                     inclusion in the State response to ACOE.                          parallel to the shoreline.



             Page 108                                                                                            Commercial Fishing









                  In areas suitable for raising fish where           Vibrio anguillarum is the best known and most
                  adequate depth and currents exist to avoid         widely distributed of the fish pathogenic vibrios.
                  biological impacts, it is recommended that         There are four other species of fish pathogens:
                  local governments encourage siting farms           V. ordalff, V. damsela, V. carchariae and V.
                  adjacent to existing structures such as            salmonicida (Egidius 1987).        Other authors
                  docks and bridge supports to reduce                (Colwell and Grimes 1984) have cited vibrios
                  potential impacts to tribal or commercial          known to be human pathogens as fish pathogens.
                  fishing activities.                                These pathogens include V. alginolyticus, although
                                                                     this is not generally regarded as a fish pathogen,
          6.3.3       Mitigation    Measures and                     and V. parahaemolyticus, which the authors
                      Un voidable Significant                        describe as rather obscure in fish. As cited by
                      Adverse Impacts                                Egidius (1987), an isolate of V. cholerae has been
                                                                     associated with fish disease in Japan by Muroga
          The SEPA review and ACOE Section 10                        et al. (1979) and Yamanoi et al. (1980), and V.
          permitting   processes    allow   a    case-by-case        vulnificus, biogroup 2 (Tison et al. 1982), is
          evaluation of proposals using current commercial           reported to cause disease in eels. However, as
          fishing conditions. Local implementation of the            also noted by Egidius (1987), the literature on
          two notification measures identified in the                these four species of Vibrio as fish pathogens is
          Preferred Alternative     and use     of existing          "restricted and somewhat contradictory," and they
          regulations are adequate to avoid significant              have only been reported from warm water
          adverse impacts to the commercial fishing                  aquaculture sites.  Thus, there is no literature
          industry. No additional mitigation measures are            citation from the large knowledge base on
          necessary.                                                 vibriosis which demonstrates that the vibrio
                                                                     pathogens of salmon are human disease-causing
          6.4         HUMAN HEALTH                                   organisms.

          Human health concerns have centered around the             The documented fish pathogenic species which
          possible bacterial contamination of shellfish by           affect salmonids in intensive husbandry (V.
          fish farming practices. This issue is discussed            anguillarum, V. ordalff, and V. salmonicida) are
          below in addition to the risks of parasitic                distinct from the known human pathogenic vibrios
          diseases that might be contracted from farm-               potentially causing gastroenteritis. The vibrios
          reared fish.                                               that cause gastroenteritis include V. cholerae and
                                                                     the   closely related V.      mimicus     and V.
          6.4.1       Affected Environment                           parahaemolyticus.    Other species such as V.
                                                                     alginolyticus and V. vulnificus may be pathogenic
          The primary concern with bacterial contamination           through the infection of wounds or other means
          in the marine environment affected by fish                 (Blake 1984). However, V. alginolyticus is one of
          farming practices has centered around members              the most commonly occurring species in marine
          of the bacterial genus Vlbfio. Vibrios are among           coastal environments and is not generally
          the most commonly occurring bacteria in the                regarded as pathogenic for humans.
          marine environment and include a diversity of
          species that may be non-pathogenic, human                  Vibrio parahaemolyticus can cause gastroenteritis
          pathogenic, or animal pathogenic.             Many         following consumption of contaminated fisheries
          environmental isolates of this common group do             products.     The number of cases of V.
          not appear to fit into presently described species.        parahaemolyticus gastroenteritis is small in the
          The animal pathogenic species are known                    United States and the disease is not considered
          primarily for their effects on intensively cultured        "reportable" by the Centers for Disease Control.
          animals. Thus, vibriosis of fish and shellfish is          In the Puget Sound area, only three cases were
          regarded as a disease of animal husbandry.                 reported between 1982 and 1986 (Weston 1986).
                                                                     Environmental isolates of V. parahaemolyticus are


          Human Health                                                                                         Page 109








             common and more than 99 percent are                             reported preliminary data which suggested that
             considered non-pathogenic (Sakazaki et al. 1968;                the risk of parahaemolytic food poisoning is no
             Thompson       and    Vanderzant      1976).        The         greater from eating clatns from a polluted area
             pathogenicity of isolates of V. parahaemolyticus                than that of eating clams from a relatively clean
             is practically determined by the presence of a                  area. Thus, while vibrios are commonly found in
             thermostable hemolysin (Miyamota et al. 1969) in                the marine environment, the problems of seafood
             an assay known as the Kanagawa test.               This         contamination and subsequent gastroenteritis with
             species of Vibrio increases in abundance in the                 this species are most often linked with poor food
             summer and fall (Bartley and Slanetz 1971).                     handling processes.
             Thus, both the known human pathogenic species,
             if not the actual pathogenic strains of Vibrio, as              Wekell and associates (1989) conducted a
             well as non-pathogenic species are indigenous, if               preliminary study between December 1987, and
             not common, in the marine environment                 at        August 1988, comparing the bacteriological
             certain times of the year.        The probability     of        characteristics of shellfish held near three salmon
             encountering      Kanagawa-positive       strains     of        farms in Puget Sound to those of shellfish from
             V. parahaemolyticus      increases     during     warm          three comparable sites not near fish farms. In
             months and in embayments susceptible to                         this study, the researchers examined the shellfish
             warming as the overall concentration of V.                      for the presence of a variety of human pathogens
             parahaemolyticus increases. In Puget Sound, the                 (indicators)    including    Vibfio    cholerae,     V.
             highest concentrations of this species of bacteria              parahaemolyticus,            Yersinia,     Listeria ,
             occur in summer months in warm shallow                          Campylobacter, Salmonella, and Clostridium
             embayments such as Oakland and Rocky Bays                       perfringens, and fetal cotiforms as well as other
             (Kaysner and Weagant 1982).                                     non-pathogenic species including aeromonas and
                                                                             V. alginolyticus.    Sediment samples were also
             Watkins and Cabelli (1985) investigated the                     taken from beneath the pens and at nearby
             relationship of sewage enrichment in Narragansett               control sites. The preliminary study found no
             Bay to the concentration of V. parahaemolyticus.                differences in the bacteriological character of the
             They reported that nutrient enrichment did not                  shellfish from the fish farin sites compared to the
             produce an effect on V. parahaemolyticus levels                 other sites. No VINio cholerae, Yersinia, Listefia,
             but hypothesized an indirect effect. The bacteria               or Campylobacter were found in any samples. V.
             did increase in conjunction with some types of                  parahaemolyticus was found in a few samples.
             particulate matter.     The concentrations of this
             vibrio decreased sharply with depth      'and distance          These authors also performed bacteriological test
             from the sewage source. There are no reports of                 on several lots of fish feed and isolated
             a change in the prevalence of V. parahaemolyticus               Salmonella cubana from one sample of moist feed
             gastroenteritis in association with fish farming                as well as other bacteria. No Salmonella was
             (Weston 1986).                                                  found in oyster, sediment, or water samples from
                                                                             the farm sites or other sites.
             Blake (1984) notes that 3,71brio parahaemolyticus,
             the most common cause of disease among these                    Three parasites of salmon have been reported to
             Vibrio species, in this country is almost invariably            infect   humans     in   the     Pacific    Northwest:
             associated with eating cooked seafood which has                 Nanophyetus salmincola (Digenea, a trematode
             been mishandled after cooking, allowing the                     worm) (Eastburn et al. 1987), Diphyllobothrium
             organism to multiply." Vibrio parahaemolyticus                  sp., a tapeworm, (Margolis et al. 1973; Ruttenber
             gastroenteritis can result from eating raw shellfish            et al. 1984), and anisakine nematode worms
             contaminated with the bacteria although the                     (Deardorff et al. 1986, 1987).           Salmon are
             number of such cases is    small. Blake (1984) also             infected with Nanophyetus and Diphyllobothrium
             notes the importance of water temperature,                      during their freshwater phase of development.
             season and adequate cooking for reducing the                    Nanophyetas infects fish by direct penetration of
             risks due to this disease. Greenberg et al. (1984)              the cercarial stage of the worm, whereas fish

             Page 110                                                                                               Human Health








           become infected with Diphyllobothrium               by        The vibrios of fish are distinct from the human
           ingesting infected copepods. Fish are infected                pathogens.    While highly contaminated areas of
           with anisakine worms by ingesting infected                    Puget Sound may contain shellfish, such areas are
           arthropods or fishes in seawater.                             not suitable for fish farming. Furthermore, there
                                                                         is no direct correlation between human sewage
           These parasites are prevalent in wild salmon                  enrichment      and     concentrations       of     V.
           throughout the Pacific Northwest (Margolis 1982),             parahaemolyticus (Watkins and Cabelli 1985).
           and all reported human infections from salmon                 Fish farming may help prevent shoreline activities
           have been associated with wild caught fish.                   that   contribute    bacterial   contamination      to
           Deardorff and Throm (1988) found a mean of 46                 embayments around the Sound because such
           anisakine worms per fish in wild salmon examined              contaminated activities would degrade water
           from fish markets in Seattle. Wild salmon from                quality, making the areas less suitable for fish
           drainages in Washington, where the snail                      farming.
           intermediate host is present, show a high
           prevalence    and    intensity    of   infection    of        Sale of salmon for raw consumption is a
           Nanophyetus (Milleman and Knapp 1970), and                    relatively small portion of the salmon market
           Diphyllobothrium spp. occur frequently in wild                today. However, raw salmon is eaten as sushi
           Pacific salmon (Margolis 1982). In contrast, a                and sashimi. It seems likely that parasitic human
           survey of salmon from two fish farms in                       diseases from the consumption of raw salmon
           Washington revealed none of these parasites in                would decrease as a result of fish farming
           236 market-size fish (Deardorff and Kent 1989).               activities if farmed salmon products have an
           Absence of anisakine worms was attributed to the              absence of parasites as research indicates. While
           fish feeding almost exclusively on pelleted feed              examining fish from only two fish farms, the
           through their grow-out phase in seawater.                     studies by Deardorff and Kent (1989) indicated
           Nanophyetus and Diphyllobothrium infections were              that the farm-reared fish had no worms infectious
           apparently prevented at the freshwater hatcheries             to humans. This absence of parasites, the study
           before introduction to fish farms.                            concluded, occurs because farm-reared salmon
                                                                         live in a controlled environment during their
           6.4.2       Impacts on Human Health                           freshwater development and are fed commercially
                                                                         prepared diets during seawater growth. However,
           Because the bacteria associated with salmonid                 further studies over a broader geographic range
           and other cold water fish farming are distinct                will be necessary to determine whether these
           from human pathogens, there is no foreseeable                 findings have general applicability.
           way fish farming activities will contribute
           bacterial human pathogens to the environment.                 6.4.2.1         No-Action Alternative -
           In addition, it is clear that the occurrence of V.                            Existing Regulations and
           parahaemolyticus gastroenteritis is relatively rare                           Guidelines
           and is most commonly associated with poor food
           handling processes. Fish farming appears unlikely             The following regulations affect potential impacts
           to have an effect on cases of parahaemolytic                  on human health:
           gastroenteritis      associated      with       eating
           contaminated raw shellfish.                                           The U.S. Food and Drug Administration
                                                                                 is charged with regulating the safety of
           The single isolation of Salmonella    from fish feed                  food fish.      The FDA has an active
           (Wekell 1989) indicates that care must be                             research and regulation program aimed
           exercised in the production and      storage of fish                  toward determining and implementing
           feeds.                                                                food safety requirements.          Procedures
                                                                                 involving efficacy, toxicity, and chemical
                                                                                 residues are required for the licensing of
                                                                                 antibiotics for use on food animals.


           Human Health                                                                                               Page 111








                      DOH     is   authorized through RCW                           Further     research     to    validate    the
                      43.20.050 to protect the health, safety, and                  geographic distribution of lowered parasite
                      will-being of the public and to prevent the                   loads in farmed fish is desirable, because
                      spread of disease. DOH regulates food                         fish farming activities may increase the
                      protection and storage (WAC 248-84).                          safety of eating raw salmon.
                      They are also charged with approving
                      shellfish growing areas and assuring that                     Provide advisory notices to fish farmers
                      these   areas,   and    the     commercially                  on proper storage conditions for fish food.
                      harvested shellfish from these areas, are
                      not contaminated (RCW 69.30, WAC 248-                 6.4.3       Mitigation and Unavoidable
                      58).                                                              Significant Adverse Impacts

                      WSDA, through the Washington Food                     Implementing      the    recommended         measures
                      Drug and Cosmetic Act (RCW 69.04),                    identified in the Preferred Alternative in
                      prohibits    tale    of    adulterated      or        conjunction with the existing federal health
                      misbranded food. This relates to the fish             regulations will avoid significant adverse impacts
                      farm industry in that it would prohibit               to human health. No further mitigation measures
                      sale of fish which are decomposed or                  are necessary.
                      contain antibiotic residues because they
                      would be considered adulterated under                 6.5         RECREATION
                      RCW 69.04.210.
                                                                            This section discusses the potential impact of fish
             6.4.2.2         Preferred Alternative                          farms on both aquatic and shoreline recreation.

             While human health risks appear to be minimal,                 6.5.1       Affected Environment
             it is recommended that the following measures be
             implemented to further reduce any potential                    Puget  Sound offers some of the finest oppor-
             impacts on human health:                                       tunities in the country for recreation in a marine
                                                                            environment.     The area is popular both with
                 ï¿½    Fish farms should    be sited in areas that           boaters and with persons using its beaches.
                      provide water quality compatible with                 Although recreation occurs in a variety of
                      good husbandry practices and productivity             settings, areas with public access are generally
                      to ensure that farms are not placed in the            more heavily used than are other areas.            For
                      warm, rich embayments of Puget Sound                  example, recreational boaters will typically seek
                      susceptible to seasonal increased levels of           a destination that provides an amenity, such as a
                      V. parahaemolyticus.                                  state marine park, pubfic beach, or access to
                                                                            retail goods such as shops or restaurants. If a
                 ï¿½    Further     research       to      determine          destination does include an onshore amenity,
                      bacteriological characteristics of fish food          boaters will try to anchor close to shore to
                      is desirable, since typical levels or                 reduce the distance necessary to row to shore in
                      significance of bacteria in fish food are             a dinghy.
                      not known. Although there is no informa-
                      tion to indicate the presence of a                    The depth of water in an embayment is also a
                      significant  human      health    risk,    the        factor in deciding wheire to anchor a boat.
                      preliminary findings of Wekell and                    Because the average length of anchor line on
                      associates (1989) indicate that further               recreational boats is 200 ft, most boats will
                      studies may be warranted.                             anchor in water less than 15 m deep (Boyce
                                                                            1988).      Boaters also use embayments for
                                                                            temporary   or overnight protected moorage during
                                                                            inclement   weather. In addition, wind direction,


             Page 112                                                                                              Human Health









          wave conditions, water depth, and currents are               If farms are located in areas used for recre-
          factors boaters will consider when deciding which            ational boating or fishing, they could reduce the
          bays to pull into to wait out storms.                        use of these areas, or require recreational boaters
                                                                       to travel around the facility (see Section 6.2,
          Other recreational users of the state's beaches              Navigation). Recreational anglers could entangle
          usually seek a destination with good road access             their fishing lines on farm anchor lines.
          and intrinsic natural values. Many people use the            Generally, fish farm anchors are placed at a
          public shorelands around Puget Sound for                     distance away from the farms equal to about
          sunbathing,   picnicking,    birdwatching,     beach         four times the water depth. Thus, trollers may
          combing, and general relaxation.       In addition,          risk entanglement within about 100 yards (91 m)
          persons with waterfront property use their own               of a fish farm. Other fishers who are mooching,
          private beaches for recreational pursuits.                   jigging, or trolling near the surface could fish
                                                                       closer to the farm, or in between the anchor
          Recreational fishing can occur throughout Puget              cables. Shoreline use could also be reduced by
          Sound, but tends to concentrate in specific areas            boat docks or other land-based installations
          at certain times of year.         The areas used             associated with the farm.        Odors and noise
          intensively for recreational fishing depend upon             resulting from fish farms may also adversely
          the species of fish being sought and the                     impact recreational users (see Sections 6.6 and
          accessibility of the area.                                   6.7, Noise and Odors).      Fish farms could also
                                                                       adversely affect the visual quality of an area (see
          In addition to boating, fishing, and recreational            Section 6.1, Visual Quality) which may reduce
          use of the shoreline, other recreational pursuits            the value of an area for recreational use.
          in Puget Sound include activities such as SCUBA
          diving, water skiing, swimming, kayaking, and                Floating fish farms can also have positive impacts
          windsurfing.     Swimming and SCUBA diving                   on recreational activities. Personnel from farms
          generally take place in waters less than 30 m                could    provide    assistance    during      boating
          (100 ft) deep; the other activities can occur                emergencies, and the farm structure itself could
          anywhere in Puget Sound.                                     be used for temporary moorage during an
                                                                       emergency.
          Several agencies have authority over public
          recreational lands in and near Puget Sound.                  6.5.2.1         No-Action Alternative -
          These agencies include the Washington State                                  Existing Regulations and
          Parks and Recreation Commission, DNR, WDW,                                   Guidelines
          WDF, USFWS, and the National Park Service.
          There are also a variety of county and local parks           The following   regulations and guidelines affect
          located on the Sound.                                        the potential impact of fish farms on recreation:

          6.5.2       Impacts on Recreation                                    The SEPA review process allows the
                                                                               potential impacts of fish farms on
          Fish farms have the potential to impact recrea-                      recreational activities to be examined on
          tional activities by obstructing access to shore or                  a case-by-case basis. In all proposals for
          water areas traditionally used for recreation, or                    sites near State marine parks, the lead
          disrupting the intrinsic and visual quality of the                   agency under SEPA seeks input regarding
          area (see Section 6.1, Visual Quality).          Fish                potential impacts from the Washington
          farms may positively affect recreation by causing                    State Parks and Recreation Commission
          local increases in the numbers of crab and finfish                   (WSPRC). Federal agencies such as the
          near the farm site.                                                  USFWS, National Park Service, and the
                                                                               U.S. Forest Service can also participate in
                                                                               the SEPA review process for proposals
                                                                               near lands under their jurisdiction.


          Recreation                                                                                               Page 113









                       Potential impacts of fish farms on                        6.5.2.2           Preferred Alternative
                       recreational      activities   can     also     be
                       addressed in local shoreline permitting                   The SEPA review and Section 10 permitting
                       processes.      Both the SEPA and local                   processes provide a case-by-case evaluation of
                       shoreline permitting processes allow all                  fish farm proposals. These mechanisms allow the
                       agencies and groups concerned with                        most current information about the recreational
                       potential impacts to recreation to provide                activities at a specific site to be considered
                       input to the decisionmaking process.                      during the siting process. No additional measures
                                                                                 are recommended.
                       WDF is required to promote orderly
                       fisheries, and enhance and improve                        6.5.3        Mitigation Measures and
                       recreational and commercial fishing in                                 Unavoidable Significant
                       Washington (RCW 75.08). WDF has the                                    Adverse I pacts
                       authority to ensure that a fish farm does
                       not interfere with    an orderly recreational             The use of existing regulations is sufficient to
                       fishery.                                                  avoid      any   significant    adverse     impacts      to
                                                                                 recreation and no additional mitigation measures
                       WDF reviews fish farming proposals for                    are necessary.
                       potential impacts     to recreational fishing
                       through the SEPA       process. This process              6.6          NOISE
                       allows WDF to identify whether a
                       proposal is near an important recreational                Sources of noise from aquaculture facilities
                       fishing area and provides WDF with an                     include boats to service fish farms, pumps and
                       opportunity to contribute their expertise                 generators      necessary      for     operation,      and
                       to     the   SEPA      lead     agency      when          communication between workers. Concerns have
                       determining a proper farm location.                       been raised about the potential impact to nearby
                                                                                 residences.
                       WDF also reviews projects under its          HPA
                       permit process (RCW 75.20).                  This         6.6.1        Affected Environment
                       mechanism allows WDF an opportunity to
                       modify a fish farm proposal to ensure that                Existing noise levels on and along the shore of
                       recreational fisheries are not significantly              Puget Sound vary due to differing land uses and
                       affected.                                                 overwater activities. Daytime noise levels (meas-
                                                                                 ured Leq, see below) are about 45 dBA to 50
                  ï¿½    The ACOE Section 10 permit process also                   dBA in areas adjoining rural residential land uses
                       provides    an    opportunity to         identify         and having little -overwater activity.           Daytime
                       important     recreational     fishing     areas.         noise levels can be 70 dBA or higher in areas
                       WDF provides their input on fishing areas                 adjoining urban land uses and having considerable
                       and potential impacts to Ecology for                      overwater activity (EPA 1974). The unit dBA
                       inclusion in the State response to ACOE.                  indicates decibels, which are units of sound
                                                                                 measurement weighted to approximate the
                  ï¿½    As stated in Section 6.5.2, fish farms                    response of the human ear to sounds of different
                       could disrupt the visual quality of                       pitches.     Noise levels in some sheltered bays
                       recreation areas. TheAquaculture Siting                   during calm weather have been measured to be
                       Study    recommends        that     aquaculture           less     than    30    dBA      (Hurlburt,       personal
                       facilities be sited 1,500 to 2,000 ft                     communication 1988).           The designation Le
                       offshore. This guideline could effectively                indicates an equivalent constant sound level, M
                       prevent any significant adverse impacts to                is used to compare noise sources whose levels
                       the visual quality of state, local, or federal            vary over time.
                       shoreline recreation areas.


             Page 114                                                                                                           Recreation








          6.6.2        Impacts of Noise                                      operation, noise levels could vary from those just
                                                                             described. Noise-producing equipment such as
          Potential noise impacts would           primarily occur            generators, pumps, and boats are usually only in
          during daytime hours when farm          operations take            operation intermittently.
          place. Sources of noise from fish farms would
          include boats servicing the farms, motors,                         6.6.2.1            No-Action Alternative
          compressors for aeration, and incidental noise                                        Existing Regulations and
          from personnel working on the facility. Actual                                        Guidelines
          noise levels would vary depending on the
          equipment being used and the activities taking                     The following regulations and guidelines affect
          place.    Pumps and compressors are only used                      the potential impacts of noise from fish farms:
          during unusual conditions. Usually, they are used
          during certain summertime periods when algal                                 Noise is regulated by Ecology which has
          blooms or low oxygen conditions necessitate                                  established noise standards for various
          aeration to circulate the water. Because of the                              environments and activities (see Table 9).
          usual absence of obstructions above the water                                Local government may adopt stricter noise
          surface, any noise produced by farm operations                               standards. In fact, some local shoreline
          will tend to carry further than would be expected                            programs include language regulating
          for a similar noise source located on land. Some                             noise related specifically to aquaculture
          noise would also result from truck traffic                                   (fish farming) activities. For example, the
          servicing the land-based portion of the facility.                            San Juan County Shoreline Master Program
                                                                                       states that:
          In rural areas, the relatively low existing noise
          levels would make additional noise noticeable,                               -   Aquaculture activities shall comply
          even though resulting noise levels may be                                        with all applicable noise standards.
          allowable under state regulations.               Hurlburt
          (1988) observed that under unusually quiet                                   -   All projects shall be operated and
          conditions (background noise <30 dBA), the                                       maintained to minimize noise.
          sound of a small engine-driven pump (74 dBA at
          4 ft [1.2 ml) was still detectable to the human                              -   Aquaculture       activities     shall     be
          ear at 158 m (520 ft), although the measured                                     restricted to reasonable hours and/or
          level was less than 5 dBA above existing levels.                                 days of operation when necessary to
          Noise from 5-8 cm (2-3 inch) waves produced                                      minimize significant adverse impacts
          similar noise levels at the receiving property                                   from noise.
          during the same study. In non-rural areas, noise
          generated by a fish farm may not be noticeable                               Also,    Kitsap     County     requires      that
          because of higher levels of surrounding activity.                            "aquaculture development shall make
                                                                                       reasonable provisions to control nuisance
          An acoustical evaluation prepared for a proposed                             factors such as noise. . .            (Shoreline
          salmon farm in south Puget Sound predicted                                   Management Master Program, Part 7,
          noise levels that would be generated by that                                 Chapter 11). However, most jurisdictions
          facility (Towne et al. 1988). This study estimated                           have not adopted such standards and
          an ambient peak hour L. of about 43 dBA at a                                 noise is regulated by the State standards.
          distance of 488 m (1,600 It), with levels up to 48
          dBA occurring under certain weather conditions.                              Noise sources other than recreational
          Results of the study predict that under the                                  watercraft are subject to the Maximum
          observed conditions, the increase in noise levels                            Environmental Noise Levels (WAC 173-
          due to the fish farm would be less than 3 dBA.                               60). Maximum environmental noise levels
          Depending on facility-receiver separations and                               are defined by this regulation and depend
          the nature of equipment used in the farm                                     on the type of activity, source, and


          Noise                                                                                                               Page 115








                      receiving property.     The highest noise            6.6.2.2         Preferred Alternative
                      levels are allowed where both the source
                      and receiving properties are used for                It is recommended that the following measures
                      economic or industrial activity (including           be implemented by local governments through
                      agriculture).    The lowest noise levels             their shoreline permitting process to reduce any
                      allowed occur where both properties are              potentially adverse noise impacts:
                      used for residential or similar uses. . The
                      maximum allowable one-hour noise levels                  0   Require      installation     and      regular
                      are shown in Table 9. Depending upon                         maintenance of mufflers on all      motorized
                      the categorization of fish farm activity as                  equipment.
                      a commercial or industrial use, the
                      maximum allowable daytime one-hour                       0   Require enclosures on all           motorized
                      noise level at a residential receiving                       equipment.
                      property is 57 dBA or 60 dBA.
                                                                               0   In areas with access to shoreline electrical
                  ï¿½   The State also regulates noise created by                    power (for example, adjacent to a dock),
                      waterborne activities.      The Watercraft                   require farms to use electric motors to
                      Noise Performance Standards (WAC 173-                        operate pumps and compressors.
                      62) sets noise standards for recreational
                      watercraft, but exempts           commercial         6.63        Mitigation Measures and
                      watercraft from its specific regulation.                         Unavoidablle Significant
                      Recreational boats may not exceed 64                             Adverse Impacts
                      dBA between sunset and sunrise or 74
                      dBA during the day when measured at a                Use of the existing State noise standards and
                      residential property.                                implementation of the measures in the Preferred
                                                                           Alternative are adequate to avoid significant
                  ï¿½   EPA Region Ten (Washington and other                 adverse impacts to shoreline residents or other
                      northwest states) has set forth guidelines           shoreline users.        No additional mitigation
                      for evaluating the impact of increased               measures are necessary.
                      noise levels on residential or other
                      sensitive receptors. These guidelines state          6.7         ODORS
                      that an increase of less than 5 dBA would
                      have a slight impact, an increase between            Concerns have been raised about the potential
                      5 and 10 dBA would have a significant                smell of fish farms. There is concern that odors
                      impact, and an increase greater than 10              will occur near the farat from rotting dead fish,
                      dBA would have a very serious impact                 drying nets, and fish feed left out in the sun.
                      (EPA 1980).      The Federal Interagency
                      Committee on Urban Noise (FICUN) has                 6.7.1       Affected Environment
                      established guidelines for maximum noise
                      levels considered allowable for residential          Existing odors along the shore of the Puget
                      environments. The maximum 24 hour I'dn               Sound are mostly the result of natural processes.
                      or daytime L     level is 65 dBA (FICUN              The predominant source of natural odor along a
                      1980).        eq                                     shoreline is from the decay of organic material
                                                                           such as algae and zooplankton on the beaches.
                  ï¿½   In addition to the regulations listed above,         On muddy beaches at low tide, especially during
                      the SEPA review process allows any                   warm summer weather, the predominant odor can
                      concerns about significant noise impacts to          be from hydrogen sulphide ("rotten egg" smell)
                      be considered in the decisionmaking                  release from the anaerobic decay of organic
                      process.                                             material in the sediments. Additional odors are
                                                                           produced by vegetation,, animals and decay of

             Page 116                                                                                                       Noise









          Table 9.        Maximum allowable one-hour environmental noise levels. (These levels are 10 dB lower
                          during nighttime hours.)



                                                                  Activity at Receiving Property
          Activity at Source Property                 Residential          Commercial              Industrial



          Residential                                 55 dBA               57 dBA                  60 dBA
          Commercial                                  57                   60                      65
          Industrial                                  60                   65                      70




          Source: WAC 173-60.



          organic material from these sources.               In        organic matter from all of these sources can
          residential and rural areas, additional odors result         accumulate on the farm walkways.
          from a number of sources: fireplaces, furnaces,
          burning yard debris, automobile exhaust, fertilizer          Finally, boats servicing the facility, and internal-
          applications, or domestic animals. In commercial             combustion motors used to power pumps and
          and industrial areas, a wide variety of odors may            aeration equipment, would contribute minor
          result from these activities.                                amounts of exhaust fumes to the immediate area
                                                                       of the facility.     In many cases, attributing
          The nature and extent of these odors will depend             particular odors to  a fish farm may be difficult,
          upon the type of odor and its source, the location           because other activities in the area, manmade or
          of the receiver (people) relative to the source,             natural, may produce similar odors.
          the sensitivity of the receiver, the direction and
          velocity of the wind that carries and dilutes the            All odor impacts would be occasional and
          odors, and other factors such as temperature and             intermittent. The impact of odors on people in
          humidity.        The     environment,     and     the        the area of the farms would depend on the
          appropriateness of the odor to that environment              factors presented above, such as odors from other
          (for example, the natural aroma of a marine                  sources, the distance between the facility and the
          beach would be very noticeable in a forest                   receiver, and weather. If good management prac-
          environment), can also affect how odors are                  tices are not followed, there is a potential for
          perceived.                                                   strong, unpleasant odors near the farm. These
                                                                       practices include removal of dead fish, cleanup of
          6.7.2       Impacts of Odors                                 spilled feed, and general maintenance of the
                                                                       facility.
          Because a large amount of organic matter is
          associated with marine facilities and fish farming,          The placement of several farms in a localized
          farms have the potential to be a concentrated                area could result in cumulative odor impacts.
          source of additional odors. Most of these odors              With an increased number of farms in an area,
          are similar to those occurring naturally on                  odor impacts would probably be more frequent,
          beaches (for example, decay of organic matter in             although still intermittent due to weather. The
          a saline environment).       The major potential             extent of odors at some locations could increase
          sources of odors are spilled or improperly stored            depending on facility locations.
          fish food, air drying of nets fouled with attached
          marine life, and dead fish. In addition, decaying



          Odors                                                                                                    Page 117








            6.7.2.1          No-Action Alternative -                                    County Shoreline Master Program, page
                             Existing Regulations and                                   30).
                             Guidelines
                                                                            6.7.2.2         Preferred Alternative
            The following regulations and guidelines affect
            the potential impacts of odors from fish farms:                 It is recommended that best management
                                                                            practices (BMPs) be developed for the fish
                 ï¿½   There are general laws in the State of                 farming industry.     These BMPs would address
                     Washington that prevent nuisance to                    issues such as odor and would include measures
                     individuals. Relief from a nuisance such               such as:
                     as excessive odors would be sought
                     through the judicial system.                               0   Daily removal and disposal of dead fish
                                                                                    and cleanup of spilled food.
                 ï¿½   Most shoreline master programs mention
                     odor in their aquaculture regulations in                   0   Regular cleaning Df nets.
                     a general way.        For example, Kitsap
                     County's aquaculture regulations state,                    0   Storage of food in closed containers.
                     "aquaculture [fish farm] development shall
                     make reasonable provisions to control                      0   Use of walkways that are designed to
                     nuisance factors such as noise or odor"                        allow spilled food to readily fall into the
                     (Kitsap County Shoreline Management                            water.
                     Master Program, Part 7, Chapter 11). The
                     San Juan County Master Program also                    Local   governments may want to implement
                     requires that all aquaculture projects be              additional siting considerations to further reduce
                     operated and maintained to minimize                    the potential impacts of odors on nearby
                     odor.                                                  residents. These factors could include:


                 ï¿½   Master programs also typically contain                         Encouraging sites that increase the
                     language requiring proper disposal of                          distance between the farm and residences.
                     wastes.    Regulation of waste disposal                        These sites would have to be in areas
                     would reduce the potential for odors.                          without intensive navigation use to avoid
                     Two examples from the City of Anacortes                        increasing potential navigation conflicts.
                     and San Juan County master programs
                     include:                                                       Encouraging sites downwind of residences
                                                                                    (especially during prevailing summer
                     -   "Aquaculture operations shall not                          winds).
                         generate nuisance or dispose of wastes
                         which would degrade the shoreline or               6o7.3       Mitigation Measures and
                         reduce water        quality"    (City of                       Un avoid able,_S i gn ificant
                         Anacortes Shoreline Master Program,                            Adversg 1mjRasJ1
                         page 16)
                                                                            Use of existing regulations and the development
                     -   "Aquacultural wastes shall be disposed             of BMPs would avoid significant adverse odor
                         of in a manner that will ensure                    impacts. No additional mitigation measures are
                         compliance      with     all    applicable         necessary.
                         governmental waste disposal standards.
                         No garbage, wastes, or debris shall be
                         allowed to accumulate at the site of
                         any aquaculture operation" (San Juan



            Page 118                                                                                                         Odors










             6.8         UPLAND AND SHORELINE                                   conflicts between these diverse users of the
                         USE                                                    state's shorelines and aquatic areas.

             The issue   in this section involves the potential                 6.8.2        Impacts og Upland and
             displacement of existing uses and also potential                                Shoreline Use
             shoreline and upland uses near a fish farm.
                                                                                An impact    to land and shoreline use that has not
             6.8.1       Affected Environmpnt                                   already been discussed in other sections of this
                                                                                EIS is the potential for fish farms to influence
             Over 2,000 miles of shoreline border          the inland           future development patterns in an area.
             marine waters of Washington state.                 Twelve
             counties with a combined population of 2.9                         Fish held in pens are particularly sensitive to
             million people share this shoreline. This amounts                  degradation of water quality. Salmon have been
             to 65% of the state's population residing in only                  held in small cages near industrial and municipal
             one-quarter of the state's land area. The spatial                  outfalls to monitor compliance with discharge
             distribution of the population is shown in Figure                  standards (if the fish die, the discharge is not
             24. The greatest concentration of people occur                     meeting state and federal standards).                  The
             on the eastern coastal plains of Puget Sound,                      presence of commercial fish farms will serve a
             particularly in King, Pierce, and Snohomish                        similar function to monitor water quality.
             counties. General land use patterns in the Puget
             Sound area are shown in Figure 25.                                 Fish growers will obviously avoid areas of
                                                                                potential poor water quality, such as near
             Since 1940, when the growth rate in the 12                         industrial and municipal sewage outfalls, and
             county region intensified, the population has been                 large storm water outfalls. A grower may also
             increasing at a rate of nearly half a million                      want to avoid sites near marinas, shoreline
             people every 10 years (approximately 50% of the                    facilities that handle petroleum products, and
             statewide growth).       In the next several decades,              areas dredged or used for dredge disposal which
             population in the Puget Sound region is expected                   could potentially introduce pollutants into an
             to grow moderately, between 1.6 and 2.0%. The                      area.
             most rapid percentage growth has been in the
             more rural counties outside incorporated areas,                    Once a fish farm is installed, it will highlight
             such as San Juan, Island, and Thurston counties.                   water quality concerns in the area. Therefore,
                                                                                greater attention may be brought to bear on
             This increasing population will have several                       activities that are not presently meeting water
             impacts, including a growing demand for                            quality standards, or proposed activities which
             residential property, especially along the water                   could adversely affect water quality.                  This
             front.    This growth will continue to displace                    increased concern about water quality way result
             forest and agricultural uses of the uplands                        in local and state agencies placing additional
             adjacent    to    the    water.       This      increasing         restrictions on upland projects to prevent water
             development will bring growing water pollution                     quality degradation. Upland users may also be
             problems     from     point    sources     (sewer      and         subject to liability if their actions, in violation of
             industrial discharges), and non-point runoff from                  pollution laws, were to damage the fish in the
             uplands. In addition, the growing population will                  pens.
             expect    recreational     facilities    and     activities
             associated with the water, such as marinas, parks,
             and fishing opportunities.         At the same time,
             existing commercial users, such as fishing and
             towboat industries, and public ports will demand
             maintenance of their existing activities.            Thus,
             population growth will only increase the existing


             Upland and Shoreline Use                                                                                             Page 119












                                                                                                                                             f












                                                                                                                                                           EVERETT














                                                                                                                                                                                                                  SNOHQ-K4t-SH
                                                                                                                                                                                                                     @ING





                                                                                                                                   SE#YTLE

                                                                                                                                                                    0 -





                                                                                                        ."A
                                                                                                         :%

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                                                                                                                                                                          ..........
                                                                                                                                                                                                               r
                                                                                                                                                                  ...........



                                                                                  A

                 Source: Mary Stewart
                            Department Of Geography,
                                                                                    U,
                            University of Washington,.-                               V.
                            1987 Puget Sound
                            Water Quality Management Plan





                 SCALE IN MILES                                                                                                                     Figure 24.
                 1 - L-F---]                                                     Each Dot                                                           Population Distribution
                 0             5            10                                   Represents 100 Persons                                             in the Central Puget Sound Region








                                                                                                         CANADA

                                                                                                       UNITED STATES









                                                                                                           .000
                                                                                                      00                                  BELLINGHAM


                                             VANCOUVER
                                                ISLAND





                                                                                                                        09
                                                                                                                                                       1-5

                                 C
                                      'Woe


                                                 4%
                                                                                          00
                                                                                       00












                                                                                                                                                        EVE


                                                                                                                     101


                              101                                                                                       in





                                                                                                                                                           K.,





                                                                                                                                                 SEATrL


                                                                                                                            ERTO













                                                                                                                                             TACOMX--.-.-.






       Source: Puget Sound and Adjacent Waters, 1971                                                                  ..:0   FY11




                                                               Built up Area                       Cropland
      SCALE IN MILES                                           (Urban/Suburban)                    Range                              Figure 25.
                                                               Forest                                                                 Land Use in
                                                                                                   Grass, Brush,
     0            10           20                              Rural Non-Farm                      and Barrens                        the Planning Area








            6.8.2.1         No-Action Alternative                        that are degrading water quality, it is considered
                            Existing Regulations and                     a beneficial impact.      Existing regulations are
                            Guidelines                                   adequate to avoid significant adverse impacts to
                                                                         upland and shoreline uses and no additional
            The following existing regulations and guidelines            mitigation measures are necessary.
            affect the impacts of fish farms on upland and
            shoreline use:                                               6.9         LOCAL SERVICES

                    Some counties in Washington provide                  The issue here is whether the presence of fish
                    regulations for fish farming with respect            farms will  impair the ability of governments and
                    to the surrounding uplands and shorelines.           utilities to provide their services.
                    For example, Kitsap County requires that
                    "aquaculture [fish farm] wastes shall be             6.9.1       Affected Environment
                    disposed of in a manner that will prevent
                    degradation of associated upland, inland,            Most local services in the Puget Sound area are
                    [and] away from the shoreline proper,                provided by local agencies or utilities. Fire and
                    when practicable" (Shoreline Management              emergency services are usually provided by either
                    Master Program [Kitsap County], Page 7,              a district within the      local county or by a
                    Chapter 11).                                         municipal jurisdiction.      Solid waste disposal
                                                                         services are provided     by local government or
                    Also, the San Juan County Shoreline                  private businesses. Police services are provided
                    Master Program       states that, "Legally           by county or municipal jurisdiction. Sewer and
                    established     aquacultural      enterprises,       water services, where available, are usually
                    including authorized experimental projects,          provided by purveyor districts in rural areas and
                    shall be protected from incompatible uses            by municipalities in more urbanized areas.
                    which may seek to locate nearby.                     Electrical power is supplied by state regulated
                    Demonstration of a high probability that             utilities throughout the Puget Sound area.
                    such an adjacent use would result in
                    damage to, or destruction of such an                 6.9.2       Impacts on Local Services
                    aquacultural enterprise shall be grounds
                    for the denial of that use."                         The operation of fish farms does not require
                                                                         large amounts of fresh water or electricity.        If
            6.8.2.2         Preferred Alternative                        the project is located close to shore, a waterline
                                                                         could be installed to provide fresh water for
            Existing regulations are adequate to avoid                   drinking, spraying down nets, and rinsing
            significant adverse impacts to upland and                    walkways.    In addition, an electric cable can
            shoreline uses and no additional recommendations             power electrically-powered. pumps, feeding mecha-
            are being made.                                              nisms, and lights.

            6.8.3       Miligation Measures and                          When a farm is located a considerable distance
                        Unavoidable Significant                          offshore, bottled water would be used for
                        Adverse Impacts                                  drinking, and a portable pump installed to wash
                                                                         down nets and walkways. Sites located offshore
            Highlighting activities that may degrade water               would use portable generators. In remote areas
            quality and subjecting them to greater regulatory            without available water or electricity, wells and
            control is not considered an adverse impact. All             electrical lines may have, to be installed in the
            activities along the shoreline should minimize or            upland area.
            prevent water quality degradation. If a fish farm
            serves to increase awareness of water quality
            needs, or results in changes to upland activities


            Page 122                                                                               Upland and Shoreline Use








          Fish farms must dispose of solid waste generated                        and therefore have not been an issue for
          at their farm site. The major component of this                         regulation.
          waste is fish that die and are not harvestable for
          commercial sale.       There are three ways that                6.9.2.2         Preferred Alternative
          existing farms in the Puget Sound region dispose
          of dead fish: (1) dispose of the fish at landfill               It is recommended that local governments require
          sites, (2) reprocess the dead fish into fish feed,              fish farm applicants to provide information
          and (3) incorporate the fish into local agricultural            regarding solid waste disposal as part of their
          activities. These means of disposal have been                   shoreline permit application.       This information
          adequate to handle the volume of dead fish                      should include:
          produced by the fish farming industry.
                                                                              0   A high and low estimation of the volume
          Fish farms would not have an impact on other                            of waste that may be produced by the
          local services. Portable toilet units are used on                       proposal inicluding potential catastrophic
          the farms. Fish farms are not expected to have                          losses.
          significant demands for police or emergency
          services. Use of existing boat ramps during farm                    a   The process by which the farm will
          operations may impact ramp facilities, but the                          dispose of its waste.
          impact would not be significant because farm
          operations involve only a few boat trips per day.               6.9.3       Mitigation Measures and
                                                                                      Unavoidable Sianificant
          Increasing the number of farms in a localized                               Adverse Impacts
          area such as an embayment would probably result
          in a cumulative impact on local services, because               Costs incurred by service purveyors would be
          any particular service would likely be provided by              reimbursed through utility fees paid by the
          a single purveyor. Because any one farm results                 farmer.    Use of existing regulations and the
          in an insignificant demand on local services, the               implementation of the recommendation in the
          size of the cumulative impact of several pens                   Preferred Alternative is adequate to avoid
          would be minor.                                                 significant adverse impacts to local services. No
                                                                          additional mitigation measures are necessary.
          6.9.2.1          No-Action Alternative -
                           Existing Regulations and
                           Guidelines


          The following regulations affect the impacts of
          fish farms on local services:


              ï¿½    There are numerous State regulations that
                   deal with local services such as fire,
                   police, landfills, and sewer and water
                   services.    None of these regulations
                   specifically identify fish farms as a use
                   that requires special concern.

              ï¿½    Local shoreline master programs do not
                   contain guidelines or regulations that
                   discuss potential impacts on local services
                   from fish farms. These potential impacts
                   have generally been found insignificant



          Local Services                                                                                                Page 123













                            7. CUMULATIVE IMPACTS ON PUGET SOUND



          The potential cumulative impacts from fish farm               limit on the capacity of Puget Sound for farms
          development in Puget Sound would be minimized                 within projected levels of fish farm development.
          by the evaluation process resulting in the proper             This upper limit is the point beyond which
          siting of individual farms.     Theoretically, siting         additional farms will reduce water quality in the
          five farms in a small embayment on an individual              Sound as a whole. The intent of such analysis is
          basis, without consideration of other farms in the            to show if projected levels of fish farm develop-
          area, could have a cumulative impact on one or                ment will adversely affect Puget Sound by exceed-
          more elements of the environment discussed in                 ing the assimilative capacity of the Sound. This
          this EIS. However, siting five farms in an em-                analysis assumes that the farms are dispersed
          bayment, or a number of farms throughout Puget                throughout the Sound.        It is not intended to
          Sound, would not have a cumulative impact on                  supplant the need for a thorough and detailed
          those identified elements of the environment if               analysis of localized environmental effects around
          the locations of other nearby farms were consid-              a fish farm.
          ered in the permitting process. Individual farms
          would receive their own site-specific SEPA review             In addition, basin-wide analysis serves to put the
          and undergo scrutiny for compliance with the                  inflow of nutrients and organics from farms in
          regulations discussed throughout this EIS, includ-            perspective by comparing them to other sources
          ing consideration of nearby fish farm develop-                of nutrients and organics, both man-made and
          ment.                                                         natural.   If the amount of nutrients from the
                                                                        farms is extremely small compared to the amount
          The process of analyzing cumulative impacts of                from naturally occurring inflows, then it is rea-
          fish farms must be sequential. Decisions made                 sonable to argue that the Sound can sustain that
          on individual farm proposals and the adequacy of              level of impact without excessive degradation.
          a specific site will be made with knowledge of
          other nearby farms and those that are proposed                For purposes of analysis, four hypothetical pro-
          for a particular area. All fish farm proposals will           duction levels were selected for the typical farm
          include cumulative impact analysis, an analysis               described in Section 2, Background:
          that will occur in the time between the submis-
          sion of an application for a fish farm and the                    1.  13 farms, 4,400 metric tons (10 million
          issuance of the SEPA and shoreline final permit-                      pounds) production
          ting decisions.                                                   2.  25 farms, 8,600 metric tons (19 million
                                                                                pounds) production
          The following discussion focuses on the potential                 3.  50 farms, 16,400 metric tons (38 million
          cumulative impact on Puget Sound water quality                        pounds) production
          from a range of fish farm development, because                    4.  100 farms, 34,100 metric tons (75 million
          the analysis can be done without site specific                        pounds) production
          information.
                                                                        The first production level of 4,400 metric tons is
          Analysis of the impact of various levels of fish              approximately equal to the estimated production
          farm development on the entire Puget Sound is                 from the 13 existing farms in Puget Sound.
          an exercise to determine if there is an upper                 Production levels 2 through 4 represent an ap-


          Cumulative Impacts                                                                                        Page 125








             proximately two-, four-, and eight-fold increase                and treatment plants, but farm sources would
             over current production. The 100-farm produc-                   remain unchanged.
             tion level is considered by some to be in excess
             of the maximum number of farms that could be                    The impact of fish farms on Puget Sound can
             permitted, considering the number of competing                  also be evaluated by presenting the loading from
             uses for potentially suitable sites.                            farms as an overall change in nitrogen concentra-
                                                                             tion throughout the Sound. This analysis treats
             A summary of loading rates for          various water           the entire Sound as a well-mixed water body. A
             quality indicators is given in Table 10.            The         more conservative approach is to assume that the
             values in the table were computed from loading                  loading only affects the surface mixed layer, such
             analyses for the Discovery Bay fish farm (Kieffer               as the case of a dissolved! substance released near
             and Atkinson 1988; Parametrix 1988) assuming                    the surface. Assuming a mixed layer from mean
             loading rates of 0.59 kg BOD/kg fish produced,                  low water to approximately 20 meters (66 ft), the
             0.55 kg feed+feces/kg fish, and 0.074 kg N/kg                   total loading from the farm would mix with 36
             fish.                                                           km3 of water (McLellan 1954). The mass loading
                                                                             of 1.8 MT/day of dissolved nitrogen would result
             While farm effluents cannot be directly compared                in an increased nitrogen concentration of 0.05
             with sewage, components like BOD (biochemical                   ug/l/day. Similarly, loading from 50 and 100
             oxygen demand) and dissolved nitrogen loads                     farms.would increase dissolved nitrogen concen-
             were compared to various other sources of                       trations by 0.09 and 0.19 ug/l/day. These con-
             loading to Puget Sound. The BOD was compared                    centrations are one hundred to one thousand
             to wastewater       treatment effluents from two                times lower than levels that could have an impact
             Metro treatment plants and to one industrial                    on Puget Sound. Given the strong tidal exchange
             source (Figure 26). In this comparison, 25 and                  and the high nutrient outflow rate, the small daily
             50 farm capacities are similar to a large wastewa-              increase in nitrogen would not accumulate to
             ter treatment plant, while 100 farms is consider-               problem levels.
             ably larger than any single treatment plant on the
             Sound.    However, the farms represent a more                   In summary, the impact of 25, 50, or 100 farms
             diffuse source of BOD loading than a treatment                  on the overall water quality of Puget Sound
             plant.                                                          would be minimal and largely negligible. Conse-
                                                                             quently, the farms production in Puget Sound will
             For nitrogen loading, the fish farm production                  be limited by the availability of sites that can be
             levels were compared to two wastewater treat-                   developed without significant local impact to
             ment plants and to the inflow of nitrogen to the                water quality and degradation of benthic commu-
             main basin of Puget Sound from the surrounding                  nities. Furthermore, conflicting uses of the water
             land (Figure 27). The nitrogen inflow to Puget                  (navigation, fishing, aesthetics, etc.) may limit the
             Sound is dominated by the natural movement of                   number of farms to production levels well below
             nitrogen with the tides and with fresh water                    the maximum production level considered here.
             inflow. Compared to the tidal inflow, all other
             nitrogen sources are insignificant, and even the
             100-farm production level does not represent        I  a
             large input of nitrogen. It should be noted that
             not all of the nitrogen sources shown in Figure
             27 are for the same nitrogen compound; tidal
             fluxes are only for nitrate, the treatment plant
             loadings are only for ammonia, and the farm
             loadings are for nitrate plus ammonia. A com-
             parison of nitrate and ammonia for all sources
             would increase the inflow of nitrogen from tides


             Page 126                                                                                          Cumulative Impacts







           Table 10.     Loading of BOD, particulates (feed+feces), and dissolved nitrogen from different levels of
                         fish production in fish farms.



                                                                                           Dissolved
           Number                Production         Total BOD          Feed + feces        Nitrogen
           of farms                (MT/yr)          (MT/yr)             (MT/yr)            (MT/day)


           13                      4,400                7.3                6.8                 0.9
           25                      8,600                14                 13                  1.8
           50                     16,400                27                 25                  3.3
           100                    34,100                55                 52                  6.8









































           Cumulative Impacts                                                                                 Page 127














                                                                      60-


                                                                                                                                                                                                                                                                 (55)



                                                                      50-







                                                                      40-

                                                                                     (36)



                                                             E                                                                                                                                                                                             . . . . . . . . . . . . . . . . . . . . . . .
                                                                      %IV
                                                             0
                                                             z                                                                                                                                                                       (27)




                                                             0        20
                                                             ca


                                                                                                                                                                                                        (14)


                                                                      10
                                                                                                                                                                           (7-3)
                                                                                                                                                                                                                   ...                                               ........
                                                                                                                                              (4.3)
                                                                                                                 (1.3)

                                                                              ........ ............                                                                                                                                                            ..........
                                                                        0
                                                                                   WEST                       RENTON                      RAINIER                     13 FARMS                     25 FARMS                    50 FARMS                    100 FARMS
                                                                                   POINT                       WWTP                      BREWERY
                                                                                   WWTP









                                                                                                                                                                                               Figure 26.
                                                                                                                                                                                               BOD Loading From West Point and Renton Wastewater
                                                                                                                                                                                               Treatment Plants, Rainier Brewery, and Different
                                                                                                                                                                                               Levels of Fish Farm Development









                                 890-  (886)

                                 880-

                                          am
                                 8,70


                                      . .. . ... .
                                 860


                                 100


                                  go
                            E
                            z     80

                            0
                                   . ....................
                                  70 -       ix


                                  60
                            >
                            0     50
                            Co/)
                            Cl)

                                  40


                                      ----------
                                      i.
                                  30


                                  20


                                  10                          (6.9)                 (7.3)                                       (6.8)
                                                                         (3.0)                            (1.8)      (3-3)
                                                   (2-4)
                                                                                               (0-9)
                                   0
                                        PUGET    RENTON      WEST STILLAGUAMISH SKAGIT       13 FARMS  25 FARMS    50 FARMS  100 FARMS
                                       SOUND      WWTP       POINT      RIVER      RIVER
                                       INFLOW                WWTP







                                                                                               Figure 27.
                                                                                               Nitrogen Loading From Tidal and Freshwater Inflow,
                                                                                               Renton and West Point Wastewater Treatment Plants,
                                                                                               Stillaguamish and Skagit River, and Various Levels
                                                                                               of Fish Farm Development














                                 8. RELATIONSHIP TO LAND USE PLANS
                                                    AND REGULATIONS


          The geographical focus of this EIS is Puget                     ture industry within the state." However, process-
          Sound and its adjacent marine waters. This area                 ing, wholesale transactions, and other activities,
          includes counties, incorporated cities and towns,               which may be associated with a fish-growing
          and large tracts of land under State or federal                 operation, can be considered commercial uses.
          jurisdiction.
                                                                          Consistency with the goals and policies of a
          8.1          LOCAL JURISDICTIONS                                comprehensive plan is addressed as part of
                                                                          permit review. The permits required by a local
          Local jurisdictions have a variety of land use                  jurisdiction will depend on the project and the
          policies and regulations that affect the construc-              site. A shoreline permit is required for a sub-
          tion and operation of fish farms. The land use                  stantial development within shoreline jurisdiction.
          policies are generally expressed in comprehensive               A use permit may be required if upland portions
          plans and shoreline management master pro-                      of the project are not permitted outright in the
          grams. Land use regulations are embodied in                     zoning ordinance.
          zoning codes, the use requirements of shoreline
          management master programs, and performance                     Shoreline Master Proaram.          Shoreline master
          regulations (for example, noise ordinances).                    programs contain both policies and regulations
                                                                          affecting substantial development within shoreline
          ComRrehensive Plans. The comprehensive plans                    jurisdiction.    "Shorelines" are defined as all
          of local jurisdictions generally contain goal state-            waters of the State, including reservoirs and their
          ments and policies that seek to protect the envi-               associated wetlands. The exceptions are stream
          ronment and avoid incompatibilities with sur-                   segments on rivers having a mean annual flow of
          rounding uses.      To this end, agricultural and               less than 20 fO/sec and segments on lakes less
          commercial development is usually considered                    than 20 acres.      "Associated wetlands" include
          appropriate in designated areas.              However,          areas within 200 ft of these shorelines, together
          approval of a proposed activity usually hinges on               with marshes, bogs, swamps, floodways and
          a demonstration that the project will not adverse-              floodplains that influence or are influenced by
          ly impact adjacent uses, and can be operated to                 these waterbodies (RCW 90.58.030).
          prevent environmental degradation.
                                                                          The policies contained in local shoreline master
          An aquaculture operation can have both agricul-                 programs reflect the priorities and guidelines of
          tural and commercial elements. The Legislature                  the State Shoreline Management Act (90.58 RCW)
          of the State of Washington has determined that                  and regulations for implementing it (WAC 173-
          aquaculture, including the raising of fish, is an               14 through 173-22). Although local governments
          agricultural enterprise (RCW 15.85). This legisla-              are given wide latitude in tailoring shoreline
          tion states in part:     "The legislature finds that            master programs to meet local needs, the policies
          aquaculture should be considered a branch of the                and regulations must be consistent with these
          agricultural industry of the state for purposes of              state laws.    To this end, all master programs
          any laws that apply to or provide for the ad-                   must be reviewed and approved by Ecology.
          vancement, benefit, or protection of the agricul-


          Relationship to Plans and Regulations                                                                         Page 131









              Of specific importance to the development of                  at the local level has been a difficult task, and
              local policy on aquaculture is the state policy on            shoreline master programs vary widely on the
              "shorelines of statewide significance." The Shore-            approach used to achieve a balance.
              line Management Act states that in the case of
              shorelines of statewide significance, local master            Fish farms must receive a shoreline substantial
              programs shall give prioritized preference to uses            development permit in order to operate.             Sh-
              which:                                                        oreline substantial development permits are ap-
                                                                            proved if the proposed development is consistent
                  ï¿½   recognize and protect the state-wide                  with the local shoreline :master program. Shore-
                      interest over local interest                          line permit decisions are reviewed by Ecology,
                                                                            and both permit approvals and denials can be
                  ï¿½   preserve the natural character of the                 appealed by this agency to the Washington State
                      shoreline                                             Shorelines Hearings Board. If a shoreline condi-
                                                                            tional use permit or variance is involved, Ecology
                  ï¿½   result in long-term over short-term benefit           has the authority to deny a permit that has been
                                                                            approved at the local level.
                  ï¿½   protect the resources and ecology of the
                      shoreline                                             In many local jurisdictions, the shoreline master
                                                                            program is adopted as an element of the compre-
                  ï¿½   increase public access to publicly-owned              hensive plan. When this, is the case, approval of
                      areas of the shoreline                                a shoreline substantial development permit is
                                                                            contingent upon a finding that the proposal is
                  ï¿½   increase recreational opportunities for the           consistent with the comprehensive plan.
                      public in the shoreline
                                                                            ZoninE and Other Regulations. Local jurisdic-
                  ï¿½   provide for any other element as defined              tions would also regulate upland portions of a
                      in RCW 90.58.100 deemed appropriate or                floating fish farm operation or tank farm through
                      necessary.                                            zoning regulations. Zoning regulations normally
                                                                            include limitations on the bulk of structures, and
              A shoreline of state-wide significance includes all           also some site design requirements, such as
              subtidal lands, as well as specifically designated            setbacks from property lines.           Whether the
              intertidal areas, lakes, and rivers.       Therefore,         facility is permitted or requires conditional
              local government must give priority in these areas            approval, it would have to meet the requirements
              to developments meeting the criteria listed above.            of the underlying zone. Zoning ordinances are
              It is the policy of the State to encourage the                the implementing arm of' the local comprehensive
              development and expansion of aquaculture (RCW                 plan.   Therefore, approval of a zoning permit
              15.85).   In addition, the State guidelines for               requires a finding that all portions of the propos-
              shoreline master program development indicate                 al are consistent with the policies of the compre-
              that aquaculture is a water dependent use that, if            hensive plan.
              properly sited and managed to avoid environmen-
              tal degradation, is a preferred use of the water              Regulations on other aspects of land uses, such
              area (WAC 173-16-060 (2)).                                    as noise and air pollution, may be included in
                                                                            zoning regulations or separate legislation. These
              It is in this context that floating fish farms are            regulations are discussed in appropriate sections
              evaluated in local shoreline master programs.                 of this document.
              Local shoreline administrations have attempted to
              account for statewide interests, while taking into
              consideration local land and shoreline use issues.
              The adoption of aquaculture policy and regulation


              Page 132                                                                      Relationship to Plans and Regulations










           8.2         STATE AND FEDERAL                               ments to hold certain natural resources in trust
                       JURISDICTIONS                                   for the people.      In addition, the government
                                                                       could not relinquish its responsibility through a
           Locating a fish farm in the marine waters of                transfer of property. Lands to which the doctrine
           Puget Sound would require leases and permit                 applies carry the burden of the public trust to the
           approvals from several Washington State agencies.           private land owners. In fact, American courts
           In addition, the federal government has specific            have occasionally expressed the view that waters
           authorities over navigable waters and wetlands of           by their nature are incapable of private ownership
           the State. A list of the permits which may be               (Stevens 1980).
           required for a floating fish farm development is
           shown in Appendix F and discussed in Section                8.3.2       Public Trust Doctrine in
           4.1, Permits and Approvals. As stated earlier,                          Washington
           this list covers both salt and freshwater, floating
           or land-based aquaculture operations. Some of               Early court cases in Washington recognized the
           these permits may not be applicable to all pro-             State's public trust responsibilities. These cases
           posed projects.                                             related to the sale of tidelands and shorelands
                                                                       and affirmed ownership rights of the state and
           .8.3        PUBLIC TRUST DOCTRINE                           the absence of riparian rights in Washington.
                                                                       The  courts also recognized, in theory, that the
           The public  trust doctrine is a common law princi-          state held the rights of navigation and fishing in
           ple which recognizes the right and responsibility           trust for all the people of the State. By 1970,
           of each state to protect certain inalienable public         the legislature and courts expressly began to
           rights in coastal resources.     The State has a            recognize that private property ownership of
           responsibility to manage its aquatic lands for the          aquatic lands must be reconciled with the public
           benefit of all citizens and to make resource                trust easement or rights retained by the public.
           allocations in a conservative and responsible
           manner.     The public trust doctrine considers             That the state has asserted its ownership of
           aquatic lands to include both private rights which          aquatic resources is evidenced by the thousands
           can be sold and public rights which cannot be               of aquatic land leases, easements, and rights-of-
           sold.   Thus, even when selling tidelands, the              way granted over the years.          Most recently,
           public  maintains a kind of easement which re-              legislative direction for managing aquatic lands
           quires  that the State continue to protect the              came in the 1984 Aquatic Lands Act. Consistent
           public's rights in navigation, fishing, commerce,           with the tenants of the public trust doctrine, the
           and recreation.                                             legislature directed these lands to be managed "to
                                                                       provide a balance of public benefits for all
           8.3.1       Historical Basis                                citizens of the state. The public benefits pro-
                                                                       vided by aquatic lands are varied and include:
           The historical origins of the public trust doctrine         (1) encouraging direct public use and access; (2)
           are found in ancient Roman and English common               fostering water-dependent uses; (3) ensuring
           law. The concept of the public trust in navigable           environmental protection; and (4) utilizing renew-
           water was adopted early in the United States. In            able resources. Generating revenue in a manner
           1821, an American court (Arnold v. Mundy)                   consistent with subsections (1) through (4) of this
           declared the law of public trust as it is known             section is a public benefit." (RCW 79.90.455).
           today. The court found that rights in the beds of           The public trust doctrine has been substantiated
           navigable waters had been held by the Crown in              in the Shoreline Management Act (SMA), enacted
           trust for the common use of the people, the                 by the state legislature in 1971.         The State
           states succeeded to this trust, and a grant divest-         supreme court has stated that the requirements
           ing the citizens of these common rights was void.           that the public trust doctrine impose on the state
           It thereby became incumbent upon state govern-              are "fully met" by the Shoreline Management Act


           Relationship to Plans and Regulations                                                                   Page 133









            (Bodi 1989). The Act established a regulatory                 as "a covenant running with the land (or lake,
            scheme and public involvement process for tide-               marsh, or shore) for the benefit of the public and
            land and shoreland development. Some of the                   the land's dependent wild][ife."
            stated policies underlying the Act are "to provide
            for the management of the shorelines of the state             8.3.3      The Public Trust and Fish
            by planning for and fostering all reasonable and                         Farms
            appropriate uses, "to ensure the development of
            these shorelines in a manner which, while allow-              The aquatic lands on which fish farms will be
            ing for limited reduction of rights of the public             developed will remain in State ownership. There-
            in navigable waters, will promote and enhance the             fore, issues of delegation from public trust to
            public interest, and to "protect against adverse              private land ownership are not involved.         The
            effects to the public health, the land and its                State's public trust responsibilities are carried out
            vegetation and wildlife, while protecting generally           through both the State's aquatic land proprietary
            the public rights of navigation and corollary                 management and shoreline management programs.
            rights incidental thereto."                                   Responsible resource martagement is the goal of
                                                                          both programs.
            In 1987 and 1988, the Washington Supreme Court
            issued two major decisions that strengthened the              The public trust doctrine is not automatically
            public trust doctrine in the state. One challenged            violated by net pens locating in navigable waters
            the State's authorization of development.         The         because the state retains ownership of the
            other challenged the State's prohibition of devel-            bedlands and leases the land for relatively short
            opment. In Caminiti v. Boyle, the court rejected              terms. Each site is evaluated on a case-by-case
            a challenge by public recreation users to a State             basis through both the aquatic land and shoreline
            law authorizing shoreline property owners to                  management programs.
            install and maintain private docks. In upholding
            this curtailment of public use, the court elabo-
            rated upon the nature of the public trust doctrine
            in Washington. The court found that the State
            law authorizing docks did not violate the doctrine
            because the law allowed the State to relinquish
            forelatively little control", promoted the interests
            of members of the public (waterfront property
            owners), and did not substantially impair public
            uses (Bodi 1989).

            The Washington Supreme Court addressed the
            public trust doctrine in 1988. Orion Corp. v.
            Washington was the first time the court explicitly
            addressed the applicability of the public trust
            doctrine to Washington tidelands. In this case, a
            private landowner (Orion) challenged the State
            regulatory action that had prevented dredging and
            filling thousands of acres of tidelands. Under the
            Shoreline Management Act, the State had classi-
            fied Orion's tidelands for preservation because
            they supported unique and fragile resources,
            including fish and shellfish.     The court found
            support for the State prohibition in the public
            trust doctrine. The court described the doctrine


            Page LU                                                                      Relationship to Plans and Regulations











                                             DISTRIBUTION LIST



              Federal Agencies


              U.S. Fish and Wildlife Service
              U.S. Army Corps of Engineers
              U.S. Coast Guard
              U.S. Food and Drug Administration
              National Marine Fisheries Service
              National Park Service
              Environmental Protection Agency
              Bureau of Indian Affairs


              Tribes and Tribal Organizations


              Northwest Indian Fisheries Commission
              Duwamish Tribal Office
              Point No Point Treaty Council
              Jamestown-Klallam Tribes
              Klallam Tribe
              Lower Elwha Tribal Council
              Lummi Business Council
              Makah Tribal Council
              Muckleshoot Indian Tribe
              Nisqually Indian Tribal Council
              Northwest Indian Fisheries Commission
              Port Gamble Business Committee
              Puyallup Tribal Council
              Sauk-Suaittle Indian Tribe
              Skokomish Tribal Council
              Small Tribes of Western Washington
              Squaxin Island Tribal Council
              Stillaguamish Tribal Council
              Suquamish Tribal Council
              Swinomish Tribal Council
              Tulalip Board of Directors
              Upper Skagit Tribal Council

              State Agencies and Elected QMcials


              Office of Governor Booth Gardner
              Senate Environment and Natural Resources Committee
              House Environmental Affairs Committee
              House Fisheries and Wildlife Committee
              Office of the Attorney General


                                                                                                       Page 135









              Department  of Agriculture
              Department  of Community Development
              Department  of Ecology
              Department  of Health
              Department  of Natural Resources
              Department  of Parks and Recreation
              Department  of Trade and Economic Development
              Department  of Wildlife
              Puget Sound Water Quality Authority
              Washington Parks and Recreation Commission
              Interagency Commission on Outdoor Recreation
              Shorelines Hearings Board


              County Governments


              Washington State Association of Counties
              Whatcom County
              Skagit County
              San Juan County
              Island County
              Snohomish County
              King County
              Pierce County
              Mason County
              Thurston County
              Kitsap County
              Jefferson County
              Clallam County

              Regional Agencies

              Thurston Regional Planning Council


              Libraries

              Copies of this EIS will be distributed to major libraries along the Puget Sound basin.

              Organizati ns


              Puget Sound Gillnetters Association
              Washington Aquaculture Council
              Washington Environmental Council
              Washington Fish Growers Association
              Interclub Boating Association
              National Audubon Society
              Washington State Sports Council
              Marine Environment Consortium
              Washington Trollers Association
              American Waterway Operators


              Page 1M











             Trout Unlimited
             Sierra Club
             Northwest Towboat Association
             Inner Sound Crab Association
             Interclub Boating Association
             Purse Seine Vessel Owners Association
             Puget Sound Alliance
             Seattle Aquarium
             Washington Steelheaders Association
             Save Our Shores


             Persons. Agencies, Tribes, and Associations Commenting on the DEIS


             Skagit and Island Counties
             Jamestown Klallam Tribe
             Jefferson County Planning and Building Department
             Richard E. Warren
             Kitsap County Department of Community Development
             William G. Langdon
             Save Our Shores
             The Mountaineers
             Washington Department of Natural Resources
             Nooksack Indian Tribe
             Northwest Indian Fisheries Commission
             Northwest Towboat Association
             Washington State Parks & Recreation Commission
             Point No Point Treaty Council
             Port Gamble Klallam Tribe
             T. Carl Pickel, Jr.
             Puget Sound Water Quality Authority, Katherine Fletcher
             Puget Sound Water Quality Authority, Kirvil Skinnarland
             Deanne Roth
             Thomas C. Santos
             Saratoga Cove Foundation
             Marie J. Pickett
             Seahorse Siesta Club
             Clark G. Sherwood
             Sierra Club - Cascade Center
             Department of Social and Health Services
             Squaxin Island Tribe
             James Stapleton
             Rodney H. Stebbins
             Maynard A. Steinberg
             Solveig H. Thompson
             The Tulalip Tribes
             U.S. Fish and Wildlife Service
             Puget Sound Alliance
             Washington Aquaculture Council
             Washington Environmental Council


                                                                                                 Page 137








               Washington Fish Growers Association
               Arthur H. Whiteley
               Washington Department of Wildlife - Fred Maybee
               Washington Department of Wildlife - Jim Watson
               Lowell & Beverly Wohlhueter
               Margaret Yeoman
               E. Zahn
               Fred C. Zwickel
               Jeff Bakeman
               Camano Cove Community Club
               Zella M. Lutterloh
               Terry Maxwell
               Pacific Troller Association
               Marie J. Pickett
               Robert H. and Gladys Shipek
               South Point Coalition
               Barbara Stenson
               Jacqueline Maner
               University of Washington, Friday Harbor Laboratories
               Rodney L. Brown, Jr.
               Annamarie K. Johnstone
               Hattie L. Berglund
               Doris R. Betzold
               Alexander H. Bill
               Charles D. Broders
               Donald R. Cady
               Benella Caminiti
               Board of Clallam County Commissioners
               Clallam County Economic Development Council
               Larry Collinge
               United States Army Corps of Engineers
               Thomas Croley
               Jim Sanford
               Washington Department of Ecology
               Peter J. Eglick
               Carol Ehlers
               Marvin E. Eisenbach
               Fred Felleman
               Dale E. Fisher
               United States Food and Drug Administration
               James Fox
               Friends of the Earth
               Barry L. Graham
               Greenpeace
               Lorna Parent Haycox
               Robert F. Hull
               Norwegian Directorate of Fisheries, Institute of Marine Research
               Norwegian Directorage of Fisheries



               Page M














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                Chilcote, M.W., S.A. Leider, and J.J. Loch. 1985. Hatchery summer-run ssteelhead natural
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                Clark, E.R., J.P. Harman and J.R.M. Forster. 1985.           Production of metabolic products by
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                    27:381-393.


                Clocksin, T.    1988.   Personal communication of November 28.           Washington Department of
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                Cravedi, J.P., G. Choubert and G. Delous. 1987. Digestibility of chlorampbenicol, oxolinic acid
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