Final programmatic environmental impact statement, fish culture in floating net pens

[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

I
I

Page vi I

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
� 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
� 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

CANADA

UNITED STATES

IS>

OA-
VANCOUVER
ISLAND

BE'LLINGHAM

SAMISH,
fj 5 BAY
cc

cc
1-5

100

ANGELES
PORT

EVERE

101 POSSESSION,'
SOUND r'
2

SEATTLE
PACIFIC
OCEAN
BREMERTON
ri L

COMMENCEMENT
BAY

TACOMA
--,STUDY
NARROWS.'
AREA

TACOMA

1-5

OLYMPIA
C'q
.10

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

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

00
00 BELLINGHAM

VANCOUVER
ISLAND
&PRESS ISLAND,
(DEEPWATER BAY)

LONE TREE
POINT

4111`
00 00
900
ftwoo 000
PORT
ANGELES

PORT
PORT
TOWNSEND
ANGELES

EVERETT
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101

RICH
S
L
PASSAGE S
E ERTON" 'CLAM
-.'CLAM
G
BAY

TAC
OMA

SOUAXIN
ISLANE
1-5
Note: Cypress Island and
Rich Passage Sites Have
More than One Commercial OLYMPIA
Fish Farm

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

....... ...

. .........

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

...........

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

.. . .......

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

. .......... .... .. .
... . . . . . . .---
50' x 50' with
Note: 36 Pens
3' wide walkways between
Pens, 91 center walkway.

V DIAMETER 31
FLOAT 1" CABLE PIPE RAILING
51 DIAMETER --f- v. 2'
1 Y T I f

111211 ROPE

50'
ANCHOR Detail

I I I I I I Li L 1 1. 1-1 L I
11111111111p 111111 c8D (9

Examples of Various Pen Configurations

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

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.

� 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.

� 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
� 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
� 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

BE LLINGHAM

VANCOU
VER
ISLAND

ER
S
ROSARI
..STRAIT
55M

DECEPTION
NEW SMITH
PASS
uQ4 DUNGENESS ISLAND
12M
115M 40m
-..'@4NAIDA
C

ADMI
A..M.
INLET
6
m
4M

PORT Xiii
ANGELES

TT
tp
HOOD:
CANAL,
50M
101

DABOB
BAY
120m
S GTON
IOTT"

BREMERT

ISLAND
24m
0,

10
LVOS
t PASSAGEK:@-
AST
AS E
MARRO
THE

44m

X -

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

1-5 s@
0@

Air

P PORT
ANGELES ANGELES

EVER

lol

lol
lo

SEATTL

TACOMA

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

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

200-

LU
U-

400-

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

600-

800-

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

BELLINGHAM BELLINGHAM

VIC TORIA'. VIC, RIA
IL

t..38
PORT' 00 "T'
EVERETT EVERETT
ANGELES ANGELES

..SEATTLE 'SEATTLE
18

A
400 4 33

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

BELLINGHAM BELLINGHAM
do

VICTORIA VICTORIA.:.

22 4

PC RT PORT
ANGELES EVERETT ANGELES EVERETT

34 10

SEArrLF SEATTLE
18' 2
4 16 4

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
@ICT

. 4-B

Source: Puget Sound Water Quality
Authority 1986

Figure 9.
Theoretical Dispersion of
Water Parcels in Puget Sound

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

BELLINGHAM

VANCOUVER
ISLAND

%S17A 1-5
Ql@
01,

HOLMES
HARBOR

ANGELES

Vn
T
EVERET

101

SEALTLE

B ERTON
Icy
4z

1ACOMA
NARROWS

TACOMA

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

� 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
� 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,
� 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
� 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
� 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
� 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.
� 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
� 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
� Dissolved oxygen depletion, usually at other factors.
depth
Phytoplankton enhancement models assume a
� 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
� 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
� 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
� 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.

� 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
� 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.
� 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
� 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.
� 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
� 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.

PORT
ANGELES

EVERETT

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

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."

� 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

� 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

� 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.

� 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.

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

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

� 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

:3
Q@ 0
0 00
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:3

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00

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-n
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on
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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

0
>
r, 0
m m
2 m
n r-
m z
m m

m z

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

-------------

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00 0
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a 80
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m
V

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

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

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
� 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.

� 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.
� 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
� 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

� 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.
� 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
� 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

6q
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

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 P�5__ 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
� 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
� 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
� 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
� 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
� 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
� 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
� 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
� 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
� 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
� 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.
� 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
� 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.
� 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:

� 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

EVERETT

SNOHQ-K4t-SH
@ING

SE#YTLE

0 -

."A
:%

I TSAP
-T
K

X
z

.44

@%NG
..........
r
...........

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:

� 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.

� 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)

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

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
� 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
� 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
� result in long-term over short-term benefit has the authority to deny a permit that has been
approved at the local level.
� protect the resources and ecology of the
shoreline In many local jurisdictions, the shoreline master
program is adopted as an element of the compre-
� 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
� increase recreational opportunities for the consistent with the comprehensive plan.
public in the shoreline
ZoninE and Other Regulations. Local jurisdic-
� 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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