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




      Final Programmatic
      Enviro-i)mental Impact Statement




      Fish Culture in Floating Net-Pens
      Washington Department of Fisheries














                                          Response to Comments

      January 1990




















              FINAL PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT
                         FISH CULTURE IN FLOATING NET PENS






                               RESPONSE TO COMMENTS




                                      Prepared for:

                    WASHINGTON STATE DEPARTMENT OF FISHERIES
                             115 General Administration Building
                                   Olympia, WA 98504





                                      Prepared by:

                                  PARAMETRIX, INC.
                                   13020 Northup Way
                                  Bellevue, WA 98005




                                      January 1990



C!i-





                                   LIBRARy
                                  NOAA/cCEH
      GO                       1990 HOBSON AVE.
                              CHAS.SC 29408-962,9










                                                INTRODUCTION


            This section includes the responses to comments received on the Draft Programmatic EIS
            on Fish Culture in Floating Net Pens. The response is organized as follows:

            General responses to frequently asked questions.

            Numerous letters in response to the Draft Programmatic EIS had similar comments or
            questions. In order to reduce repetition, these questions are answered once at the
            beginning of this volume and cross-referenced when appropriate. These questions are
            numbered individually. When they are referred to as a response to a comment, they will
            be called a Question (i.e. See the response to Question 5).

            Comment letter.

            Each letter submitted on the Draft EIS has a unique letter number in the upper right
            corner of the first page. Comments made within each letter are sequentially numbered
            in the left margin. A list of reviewers with their respective letter numbers is included
            at the beginning of this volume.

            Response to comment letter.

            The responses to comment letters follow the text of each letter.            Each comment
            identified in a letter has a corresponding response. As noted above, some responses will
            direct the reader to the categorical responses at the beginning of this volume. To
            further reduce repetition, some responses will direct the reader to a response already
            made in a previous letter, such as "See the response to Letter 4, Comment 6."

            The complete text of a letter is followed by the complete set of responses to that letter.
            Then, the text of the next letter is followed by the responses to that letter. To aid in
            locating the responses to letters, vertical lines are placed in the right margin of the pages
            with responses.










                                            LIST OF REVIEWERS


          1.    Skagit and Island Counties
          2.    Jamestown Klallam. Tribe
          3.    Jefferson County Planning and Building Department
          4.    Richard E. Warren
          5.    Kitsap County Department of Community Development
          6.    William G. Langdon
          7.    Save Our Shores
          8.    The Mountaineers
          9.    Washington Department of Natural Resources
          10.   Nooksack Indian Tribe
          11.   Northwest Indian Fisheries Commission
          12.   Northwest Towboat Association
          13.   Washington State Parks & Recreation Commission
          14.   Point No Point Treaty Council
          15.   Port Gamble Klallam Tribe
          16.   T. Carl Pickel, Jr.
          17.   Puget Sound Water Quality Authority, Katherine Fletcher
          18.   Puget Sound Water Quality Authority, Kirvil Skinnarland
          19.   Deanne Roth
          20.   Thomas C. Santos
          21.   Saratoga Cove Foundation
          22.   Marie J. Pickett
          23.   Seahorse Siesta Club
          24.   Clark G. Sherwood
          25.   Sierra Club - Cascade Center
          26.   Department of Social and Health Services
          27.   Squaxin Island Tribe
          28.   James Stapleton
          29.   Rodney H. Stebbins
          30.   Maynard A. Steinberg
          31.   Solveig H. Thompson
          32.   The Tulalip Tribes
          33.   U.S. Fish and Wildlife Service
          34.   Puget Sound Alliance
          35.   Washington Aquaculture Council
          36.   Washington Environmental Council
          37.   Washington Fish Growers Association
          38.   Arthur H. Whiteley
          39.   Washington Department of Wildlife - Fred Maybee
          40.   Washington Department of Wildlife - Jim Watson
          41.   Lowell & Beverly Wohlhueter
          42.   Margaret Yeoman
          43.   E. Zahn
          44.   Fred C. Zwickel
          45.   Jeff Bakeman
          46.   Camano Cove Community Club










               47.    Zella M. Lutterloh
               48.    Terry Maxwell
               49.    Pacific Troller Association
               50.    Marie J. Pickett
               51.    Robert H. and Gladys Shipek
               52.    South Point Coalition
               53.    Barbara Stenson
               54.    Jacqueline Maner
               55.    University of Washington Friday Harbor Laboratories
               56.    Rodney L, Brown, Jr.
               57.    Annamarie K. Johnstone
               58.    Hattie L Berglund
               59.    Doris R. Betzold
               60.    Alexander H. Bill
               61.    Charles D. Broders
               62.    Donald R. Cady
               63.    Benella Caminiti
               64.    Board of Clallam County Commissioners
               65.    Clallam County Economic Development Council
               66.    Larry Collinge
               67.    United States Army Corps of Engineers
               68.    Thomas Croley
               69.    Jim Sanford
               70.    Washington Department of Ecology
               71.    Peter J. Eglick
               72.    Carol Ehlers
               73.    Marvin E. Eisenbach
               74.    Fred Felleman
               75.    Dale E. Fisher
               76.    United States Food and Drug Administration
               77.    James Fox
               78.    Friends of the Earth
               79.    Barry L Graham
               80.    Greenpeace
               81.    Loma Parent Haycox
               82.    Robert F. Hull










                             ABBREVIATIONS AND ACRONYMS


         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
         1*                             Equivalent Constant Sound Level
         iahHW                          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                            Nephelomietric 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
         VvrDW                          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









                                           GENERAL QUESTIONS


           Question I       What is the purpose of a programmatic EIS?

           A programmatic, or non-project, environmental impact statement is appropriate at the
           level of planning when broad decisions, such as policy formulation, are being made. It
           is part of the phased review process allowed under SEPA (WAC 197-11-060(5)). Phased
           review allows reviewers the opportunity to focus on issues that are ready for decision and
           exclude from consideration issues that are not ready. Phased review starts with broad
           policy documents and then moves to documents of a narrower scope. For instance,
           while this document addresses issues related to floating fish farms such as water quality,
           it does not list all the places in Puget Sound where water quality would prohibit the
           placement of farms. An advantage to phased review is that it allows agencies and the
           public an opportunity to be involved with the planning process at an early stage.


           Question 2       Why were consultants chosen to work on this project when they have
                            done previous work for the aquaculture industry? Isn't there a conflict
                            of interest?

           The basic process used for selecting consultants for this project is the same process used
           by all agencies in selecting outside contractors for technical assistance in a variety of
           environmental areas. When choosing a consulting team, agencies look for a demon-
           strated ability to perform the work through previous experience and an understanding of
           the project. This project requires previous experience in assessing the environmental
           impacts of aquaculture projects. Such experience is not a conflict of interest.

           The consultants used on this project have been in the business of providing objective
           environmental information to decisionmakers in the Northwest for many years. Their
           continuing business success depends upon their ability to provide objective and impartial
           products for their clients. The information developed by any consulting firm for a project
           must be defensible through existing appeal processes and the courts. Therefore, biased
           reports are not in the best interest of either the consultants or the agencies.

           Question 3       Is it the intent of the state to site 100 farms in Puget Sound? How was
                            the number 100 chosen?

           It is not the intent of the State to site 100 farms in Puget Sound. As stated in the first
           sentence of the Description of Alternatives section in the DEIS, "The objective of this
           programmatic EIS is to assess the environmental impacts of fish culture in floating net
           pens in Puget Sound." The State Environmental Policy Act (SEPA) requires EISs to
           include a discussion of reasonable alternatives that could feasibly attain or approximate
           a proposal's objectives. The 25 farm alternative was chosen by roughly doubling the
           existing 13 farm alternative. The 50 farm alternative was chosen by doubling the 25
           farm alternative, and the 100 farm alternative was chosen by doubling the 50 farm
           alternative. As stated in the third sentence of the Description of Alternatives section od
           the DEIS, '"Ibe range of development assessed is intended to bracket the range which








               is likely to occur within the next few years, depending upon the decisions made by state
               and local agencies."

               Question 4       Why aren't all possible sites for fish farms in Puget Sound identified?

               To determine the availability of all sites in Puget Sound would require analysis of site
               specific information which is outside the scope of this EIS.

               Question 5       Why can't the deadline for comments be extended?

               SEPA requires a thirty day review period for commenting on a DEIS (WAC 197-11-
               455(6). The DEIS was issued February 6 with a comment deadline of March 23
               representing an initial 45 day review period. WDF extended the deadline for comments
               to April 7 because of the large, complex scope of the document.

               Question 6       What is the LENKA project in Norway?

               The LENKA project is a coastal zone management program started in Norway in 1987
               to assess the suitability of the Norwegian coast for aquaculture. See Appendix H for
               further information.

               Question 7       Will you issue the EIS again as a Draft and accept public comments?

               No, this is a Final EIS. However, the State will continue developing plans and policies
               for managing the fish farming industry. The public is welcome to submit their comments
               on this document to appropriate agencies to aid them in subsequent planning efforts.

               Question 8       What is the role of the tribes in the environmental review process for
                                fish farms?

               While Tribes do not have direct management authority over the fish farming industry,
               they should be consulted early in the SEPA process. Siting a fish farm in a location
               that affects the Tribes' ability to catch fish in their usual and accustomed fishing areas
               could create a significant impact on the Tribes.

               Question 9       Who will enforce compliance with permit conditions derived from the
                                information suggested in the EIS?

               The enforcement of permit conditions required of the fish farming industry will be done
               in the same manner as with any other development. Agencies with authority such as
               WDF (Hydraulic Project Approval and Disease Control), DNR (Aquatic lands lease), and
               Ecology (Shoreline permits and NPDES in 1990) will continue their present level of
               random checks of permit holders. If a problem is brought to the permitting agency's
               attention by another agency or citizen, then special efforts are made to assure that
               conditions of the permit or lease are being complied with.

               Local government would continue to handle permit compliance in the same manner as
               they do now. If a citizen brings a potential shoreline permit problem to their attention,








            local government will enlist the support of the appropriate state agencies to bring the
            permit holder into compliance with their permit requirements.

            Question 10       There are conflicts between some of the mitigation measures such as
                              between aesthetics and navigation. Why doesn't the EIS resolve these
                              conflicts?

            The role of the   EIS is to evaluate the environmental effects of a range of alternatives.
            The EIS suggests mitigation measures that could be implemented to eliminate or reduce
            impacts. Resolution of conflicting mitigation measures suggested in this EIS will have
            to be determined on a case-by-case basis using site specific conditions.

            Question 11       What is the Public Trust Doctrine and how does it relate to the fish
                              farming industry?

            The public trust doctrine is a common law principle which recognizes the right and
            responsibility of each state to protect certain inalienable public rights in coastal resources.
            The State has a responsibility to manage its aquatic lands for the benefit of all citizens
            and to make resource allocations in a conservative and responsible manner. The State's
            public trust responsibilities are carried out through both the State's aquatic land
            proprietary management and shoreline management programs.

            The public trust doctrine is not automatically violated by fish farms locating in navigable
            waters, because the State retains ownership of the bedlands and leases the land for
            relatively short terms. Each site is evaluated on a case-by-case basis through both the
            shoreline and aquatic land management programs.

            For a further discussion of the public trust doctrine, see Section 8.3 of the FEIS.

            Question 12       Why wasn't a thorough economic analysis of the fish farming industry
                              included in the EIS?

            SEPA does not require an economic analysis to be included in an EIS. WI)F included
            two economic discussions in the FEIS Technical Appendices to provide additional
            information on the fish farming industry.

            Question 13       What programs and efforts are underway that address water quality
                              issues?

            See Section 5.2 of the FEIS for a discussion of the NPDES permit system related to fish
            farms. In addition, the Puget Sound Water Quality Authority is instigating a number of
            programs related to general water quality concerns.            Contact PSWQA for further
            information on those programs.

            Question 14       What chemical and physical factors related to water quality may be
                              affected by flsh farms and how might they be affected?

            Chemical factors affected by fish farms include: dissolved oxygen, nutrients, dissolved
            organics, suspended organics (BOD), and turbidity. Generally, dissolved oxygen will








               decrease while nutrients, dissolved and suspended organics and turbidity will increase.
               The decrease in dissolved oxygen is related to the respiration of fish as well as the decay
               of organic matter. Much of the increase in turbidity is related to the increase in
               suspended organic matter. The increase in nutrients can contribute to other water
               quality changes, in particular, increases in the phytoplankton population. Large increases
               in the phytoplankton population can cause supersaturated dissolved oxygen concentrations
               near the surface from photosynthesis and a decrease in the dissolved oxygen concentra-
               tion from decay of phytoplankton detritus near the bottom.

               Physical changes due to fish farming are largely limited to aesthetics such as changes in
               turbidity, phytoplankton blooms, and sedimentation. The accumulation of organic matter
               under farms can lead to changes in biological diversity in benthic communities.

               Question 15       What are the "models" used to simulate "real life" and why are these
                                 particular models used?

               Models are used to simulate the interrelationship among the physical, biological, and
               chemical environment. In modelling, mathematical relationships are developed to express
               how a process is related to individual parts of the environment. For example, a model
               would describe how photosynthesis is related to phytoplankton concentration and nutrient
               concentrations.    The model is then the collection of all the processes considered
               important to the problem. Properly developed and applied, a model provides informa-
               tion on how changes in one part of the environment affect other areas of the environ-
               ment.    Models of this type are usually developed for specific projects since few
               generalized models exist.

               Question 16       How are fish farms affected by other water and upland uses?

               Fish farms can be affected by pollution from point or non-point sources. Point sources
               of pollution include wastewater treatment plant outfalls, storm drains, and industrial
               discharges. Non-point sources include overland runoff from farms, feed lots, yards and
               streets that do not flow into storm drains or sewer systems. The primary concerns would
               be low dissolved oxygen in effluent waters, high BOD concentrations that could cause
               low dissolved oxygen concentrations in the pens, contaminants that are toxic to fish or
               may bioaccumulate in the fish, and pathogens. Proper siting of farms would ensure that
               other sources of pollution are sufficiently well removed from the farm site to minimize
               the impact.

               Question 17       Why wasn't a discussion of the NPDES requirement for fish farms
                                 included in the EIS?

               The DEIS was      issued in January 1989, and EPA did not decide to require NPDES
               permits of floating fish farms until May 1989. Ecology is administering the NPDES
               program and has not finalized the specific requirements necessary for fish farms.
               However, a discussion of the NPDES program related to fish farms has been included
               in Section 5.2 of the FEIS.








            Question 18      Why weren't specific siting guidelines and regulations given in the EIS
                             to protect water quality?

            As a programmatic EIS, this EIS does not analyze specific situations. The document is
            not intended to determine how many sites are available and where they are located.
            The siting conditions at specific sites for hypothetical or existing farms is done for the
            purpose of example, and not for the purpose of endorsing fish farms or sites for future
            development.

            The FEIS includes an evaluation of the environmental impacts of the fish farming
            industry under two regulatory alternatives: (1) existing regulations and guidelines (No-
            Action Alternative), and (2) recommendations for WAC adoptions, additional guidelines,
            and further research (Preferred Alternative). Section 5.2 of the FEIS discusses the
            regulations and guidelines related to protecting water quality, and the Preferred
            Alternative includes recommendations for actions to ensure that water quality standards
            are not exceeded.

            Question 19      Was the Kiefer Atkinson phytoplankton model verified by field studies?

            The Kiefer Atkinson phytoolankton model has been verified in the field from prior
            studies by Dr. Kiefer in California and Hawaii, where there was a measurable "signal to
            noise" ratio that had an effect on phytoplankton. See Kiefer and Atkinson (1988 and
            1989) for more details and references. The model run used in the DEIS is based on
            a typical, but theoretical embayment, so of course it could not be field verified. In fact,
            it would not be possible to field verify the model in Puget Sound unless a fish farm with
            much larger production was located in a nutrient sensitive embayment, an unlikely
            scenario.

            Question 20      What is the relationship of the Squaxin site to other sites and what is
                             its worst-case identification based upon?

            The Squaxin Island site is one of only 2 farm sites of any significant size located in
            semi-restricted waters of Puget Sound that have extended periods of surface water
            nutrient depletion. The other site is at Fox Island, operated by WDF. The Squaxin
            site's production is greater than the Fox Island site, thus the description "worst-available-
            case" that was used in the text. This rationale has been included in the text of the EIS
            and in the abstract of Appendix C.

            Question 21      What effect will delayed-release fish have on wild and hatchery stocks
                             and fisheries based on these stocks?

            The delayed-release program is conducted by WDF and some tribes. This EIS is limited
            to an evaluation of commercial fish farms whose fish are not intentionally released. A
            discussion of the impacts associated with delayed-release facilities is beyond the scope of
            this EIS.









               Question 22       What is the likelihood of Atlantic salmon escapees establishing
                                 themselves in the wild and competing with native stocks of salmon and
                                 trout?

               The likelihood    of Atlantic salmon escapees establishing themselves in the wild is very
               small. All attempts to intentionally establish runs of Atlantic salmon outside of their
               natural range where there are indigenous salmonid populations have failed.

               Question 23       What do Atlantic salmon escapees prey upon and what impact will they
                                 have upon prey populations?

               Atlantic salmon basically feed on the same organisms that Pacific salmon do. Therefore,
               the impact on the prey population would be the same as the impact from additional
               Pacific salmon.

               Question 24       Why does MMF feel that the genetic issue is, not a significant issue?

               V*(DF agrees that protection of the genetic resources for Pacific salmon is of vital
               importance to the citizens of Washington. The DEIS does not conclude that there are
               "no problems" associated with the culture of Atlantic and Pacific salmon in fish farms.
               WDF recognizes that there could be significant genetic problems in uncontrolled
               situations. However, WDF does conclude that given the current culture techniques for
               Atlantic and Pacific salmon in Washington and the existing regulatory review mechanisms
               such as the HPA permitting program, there appears to be little potential to significantly
               affect the genetic viability of native stocks.    In addition, there appear to be little
               potential to successfully compete with native stocks.

               However, future introductions of new species may      pose potential threats. WDF lists
               some ways to minimize or prevent such threats (listed on page 75 of the DEIS). It is
               impossible to predict what might be proposed for future culture. Decisions about these
               proposals must be made on a case-by-case basis at that time with the best available
               information.

               The genetic discussion in the DEIS provides an adequate description of current potential
               genetic impact from fish farm observations and provides useful information to assist state
               decisionmakers to evaluate requests for farm sites. Ile WDF will be involved in the
               review of every proposed fish farm project through the SEPA review process and the
               HPA permitting program to ensure that genetic concerns are, evaluated.

               Question 25       What are the disease problems found elsewhere and how are they
                                 managed?

               VIRAL

               Infectious hematopoietic necrosis (caused by IHN virus [IHNV]) is known to occur in
               North America, Asia, and continental Europe. Primary management is by avoidance;
               i.e. not moving infected fish into non-infected areas. Once disease is enzootic (regularly
               affecting animals in a particular district or at a particular season), it is managed by
               health inspections and fish culture practices. Vaccines are currently being developed.









           Infectious pancreatic necrosis (caused by IPN virus) is known to occur in North America,
           Asia, and throughout Europe. Management is similar to IHNV.

           Viral hemorrhagic septicemia (caused by VHS virus) is known to occur in continental
           Europe and has been isolated at three sites in Washington: Makah National Fish
           Hatchery (USFWS), Glenwood Springs (WDF), and Lummi Island Sea Ponds (Lummi
           Tribe). All isolations were made from adult broodstock returning to hatcheries in
           Washington in 1988 and 1989.

           In Europe, VHS is managed in the same manner as IHNV. Current practice in North
           America is the eradication of infected fish (see Appendix G).

           BACTERIAL

           The following bacterial diseases occur worldwide as well as in Washington State.
           Avoidance is often difficult or impossible because these pathogens occur in all anadro-
           mous stocks and are often present in a clinical "carrier" fish. These diseases are
           managed by avoidance, sanitation, and good fish culture practices. Their impact is
           reduced by preventive vaccines and antibiotics.

           Vibriosis is the most common saltwater bacterial infection. There are many species and
           varieties. Vaccines have proven quite effective for disease prevention.

           Furunculosis (caused by Aeromona salmonicida) is a common freshwater disease but
           also causes loss in sea pens. Vaccines are available, though not as effective as the
           vaccines for vibriosis.

           Bacterial Kidney Disease - BKD (caused by Renibacteriu salmoninaru ) is a common
           disease that causes loss throughout the life of salmon in both fresh and salt water.
           Vaccines are in development. The disease is effectively managed by avoidance and by
           fish culture practices which includes antibiotic therapy (by injection) in adult broodstocks.

           Other common diseases are "redmouth" (caused by Yersinia ruckeri) and "coldwater"
           disease (caused by Flexibacter psychrophila).

           PARASITIC

           There are hundreds of types of parasites of fish to include mycotic diseases, protozoan,
           metazoan, etc. These diseases generally have worldwide distribution and occur more
           frequently in wild fishes than in cultured fishes. They are managed by fish culture
           practices which reduce exposure of the cultured fish to the natural reservoir. Some
           ectoparasites are controlled by the bathing of infected fish in therapeutic baths of
           approved chemicals.

           Question 26       What are the disease differences, if any, between hatchery and
                             commercially farmed fish?








                The pathogens which are found in freshwater culture activities may also be found in
                saltwater fish farm culture. The occurrence of disease is usually more of a function of
                the life stage of the fish. For example, the viruses discussed in Question 25 typically
                do not affect larger fish such as those in pens; however, they often cause a loss of fry
                in freshwater facilities. The bacterial diseases cause a loss in both hatcheries and farms,
                with BKD and vibrio being the most significant in farms.

                Question 27       What potential exists for fish in fariins to develop more virulent forms
                                  of disease?

                There is no greater potential for a pathogen to mutate and become more virulent in a
                fish farm environment than in a freshwater environment.

                Question 28       What is the disease risk from fish feed and what handling techniques
                                  will minimize the risk?

                Fish food ingredients are pasteurized and the presence of human bacterial pathogens
                would be due to casual contamination during manufacture or storage. These bacteria
                can and should be reduced by proper manufacturer and storage procedures. The only
                human health risk would involve fish culturists who feed the food to the fish. Naturally,
                they should wash their hands before handling food for their own consumption.

                Question 29       What are the implications and risks of -the VHS disease             recently
                                  discovered in Puget Sound?

                Viral hemorrhagic septicemia virus (VHS) was identified for the first time          in North
                America in returning adult broodstock at the tip of the Olympic Peninsula and on Orcas
                Island. Our information suggests that these fish became infected during residence in the
                .ocean. We have not observed disease or mortality caused by this virus.

                In Europe, VHS causes loss in rainbow trout in freshwater hatcheries. VHS has not
                been known to cause loss in Pacific or Atlantic salmon. Though research is being
                conducted in Europe on the Washington state isolate, no in vivo research has been
                conducted on Washington fish stocks. Therefore, it is premature to speculate on the
                disease risk to our stocks, let alone the implication and risks of VHS.             Refer to
                Appendix G for further information.

                Question 30       What are the impacts to bald eagles and peregrine falcons and what
                                  are the current and proposed protection measures?

                Resident and migratory populations of bald eagles and peregrine falcons occur along
                coastal and inland waterways of western Washington. They u-se a variety of habitats and
                specific areas for nesting, perching, roosting, and foraging. If birds are present, fish farm
                construction and operation could affect any of these activities by altering the behavior
                of the birds (e.g. changing nest, perch, roost, foraging areas), or affecting their food
                resources (e.g. altering the distribution of waterbirds in an area).

                The type and degree of potential impacts will be site-specific, depending entirely on the
                location of a particular proposed farm. As mentioned in the text, federal and state








            protection for bald eagles and peregrine falcons ensures that a proposed operation will
            not adversely affect these species. The SEPA and Section 10 permitting programs will
            provide the site specific review of individual farm proposals to ensure that the potential
            effects of fish farms on these birds are evaluated.

            Question 31        What are the potential impacts to bird populations due to lethal
                               removal and habitat and food alteration?

            As discussed in the text, the potential impacts to bird populations of lethal removal will
            depend on the degree and extent of its use and on the population size of the affected
            species. Lethal removal used on an occasional basis likely will have no impact on bird
            populations. If used continually at a fish farm, lethal removal could eliminate local
            populations of specific birds (e.g. herons, grebes); if used continually over a widespread
            area which included many farms, it could substantially reduce populations of a given
            species.   Presently, the U.S. Fish and Wildlife Service does not issue permits to
            commercial fish farms in public waters that would allow birds to be killed.

            Question 32        Why was the section on Land-Based Tank Farms included in the EIS?

            The section on     Land-Based Tank Farms was provided for additional information on
            other technologies being used to commercially raise salmon. This section has been
            moved to Appendix I in the FEIS Technical Appendices.

            Question 33        What is the risk to human health from the consumption of fish and
                               shellfish taken near fish farms due to antibiotic residuals and/or human
                               pathogens associated with the farms?

            As a rule, aquacultural use of antibiotics is far less than that of the livestock and poultry
            industries. Use of antibiotics in all of these industries is regulated by the FDA to
            protect both human and animal health. Regulations controlling the use of antibiotics are
            developed. only after extensive scientific studies are conducted which document their
            efficiency and safety. Use of antibiotics in accordance with regulations, therefore, is
            recognized as safe and effective.

            Antibiotic residuals would be expected to be low to non-existent in fish or shellfish taken
            near fish farms for reasons outlined in Section 5.4 of the FEIS; therefore, risk to human
            health would be negligible to none. Consumption of these fish or shellfish would not
            likely result in concentrations of antibiotics sufficient to affect bacterial flora of humans.
            Even in salmonids receiving a complete oxytetracycline medicated feed treatment, the
            drug is metabolized quickly following cessation of treatment. The FDA requires only a
            21-day period from date of last treatment until treated fish can be consumed. Fish or
            shellfish near fish farms would, at most, digest much lower concentrations of antibiotic
            than would farm fish and would be expected to metabolize the lower levels of drug more
            quickly. Successful vaccination programs would reduce the need for antibiotic treatments
            of captive fish, which would reduce the risk to human health.

            As outlined in this EIS, few fish or shellfish bacterial pathogens are human pathogens.
            Human bacterial pathogens that are associated with fish or shellfish generally become a
            problem due to improper food preparation techniques. Given that published reports








                cited in the EIS do not indicate increased isolation of human pathogens from fish or
                shellfish near fish farms, there is no reason to believe that consumption of these is a risk
                to human health.

                Question 34       How does the use of antibiotics lead to the development of resistance,
                                  and what are some case studies?

                Resistance of bacteria to antibiotics may occur in several ways. Spontaneous mutations
                in bacterial populations may produce organisms that are resistent to certain antibiotics.
                If these relatively resistant mutants are present in populations of bacteria exposed to
                antibiotics, they may be selected for and become more numerous since susceptible
                organisms will be killed or controlled by the antibiotic, leaving only resistent organisms.
                These remaining bacteria may or may not be susceptible to other antibiotics and might
                be controlled using alternative treatments.         Bacterial populations usually contain
                organisms that vary somewhat in the degree of susceptibility to antibiotics.

                Selection for the more resistent organisms can occur through the improper use of
                antibiotics. If incomplete or reduced antibiotic treatments are administered to infected
                animals or humans, only the most susceptible bacteria will likely be eliminated. The
                remaining bacteria will require higher doses of the same a:ntibiotic to be controlled.
                Repeated misuse of antibiotics in this way can eventually result in the selection for and
                establishment of bacteria that, if not totally resistent to that antibiotic, will require very
                high doses to be controlled. Again, treatment with alternative antibiotics might be
                effective.

                An additional mechanism for development of antibiotic resistance involves the transfer
                of small portions of genetic material, called plasmids, from one bacteria to another.
                Plasmids contain genes responsible for a variety of bacterial characteristics including
                antibiotic resistance. However, not all plasmids are responsible for the ability to resist
                antibiotics. Antibiotic resistance in a previously susceptible bacterial population can
                develop by the transfer of a resistance plasmid from a resistent bacterium to a
                susceptible bacterium, followed by the reproduction of the new plasmid-containing
                bacterium. The two bacteria involved in this process may be from the same or unrelated
                species. The transfer of resistance plasmids does not necessarily guarantee the survival
                and reproduction of resistent bacteria, since other selection pressures might favor other
                forms.    Elimination of other competing bacteria with antibiotics might favor the
                establishment of a population containing resistance plasmids, however.

                ne EIS cited several references regarding the development of antibiotic resistance in
                aquaculture. Human and veterinary medical literature also contains numerous papers
                addressing the topic. Natural resistance can occur in bacterial populations without the
                presence of antibiotics or other intervention by man.

                Question 35       What are the potential dangers of antibiotic accumulation in the
                                  sediments under the pens?

                The potential dangers of antibiotic accumulation in sediments under pens would vary
                depending on such factors as the diversity and the biotic coimnunity in and near these








           sediments, the rate and frequency of medicated feed used, and the type of antibiotic
           used.

           In fish farms and freshwater aquaculture, antibiotics are not used on a continual, long-
           term basis as they often are in other types of animal husbandry. Rather, they are used
           over short periods (5-14 days) to control outbreaks of disease.

           Antibiotic accumulation in sediments would be expected to alter the microfauna in these
           sediments.   Susceptible bacteria would likely be eliminated, provided the level of
           antibiotic in the sediments was high enough to inhabit them. Whether the remaining
           bacteria could transfer their resistance to human pathogenic bacteria is unknown, but is
           probably unlikely since few human pathogens have been seen to be associated with fish
           farm aquaculture.






                                                                                                    LETTER NO. 1






















                       COMMENTS OF SKAGIT AND ISLAND COUNTIES CONCERNING
                        DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT
                                  ON FISH CULTURE AND FLOATING NET PENS














                                                                     Prepared By:

                                                                     William C. Smart
                                                                     Leonard B. Barson
                                                                     Keller Rohrback




















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                                       TABLE OF CONTENTS



             1.    CONFLICT OF INTEREST     ....................................


             2.    BUDGET


             3.    THE DRAFT PEIS DOES NOT MAKE PROVISION FOR
                   AREAS OF PARTICULAR CONCERN PREVIOUSLY IDENTIFIED
                   BY STATUTE, REGULATION AND MANAGEMENT PLAN, NOR
                   DOES IT MAXE ANY SPECIFIC RECOMMENDATIONS CONCERNING
                   THE SEPARATION OF WILD POPULATIONS AND FARMED FISH       ....... 3

                   a. Washington's Conceptual Plan for Shoreline
                        Regulation   ..........................................     3

                   b.   Norway Has DevelORed a Coastal Zone!
                        Management Program which PrOROSMS 12
                        SeRarate Net Pens from Wild Salmon Rivers       ........... 7

                   ce   Recommendations for Drafters Con ming
                        Compatibility (oK Lack Thereof) between
                        Salmon Farms and existing Regulatims       ...............  8

                   d. The Public Trust Doctrine     ............................    9


             4.    GENETIC CONCERNS   ....................

                   a.   The evid2nce at this atage does not warrant
                        the drafter's conclusign that nQ gcnetic
                        effects are likely to result from interbreeding
                        .between escaRed and wild fish   ..........           ..  oil

                   b.   The DeRartment of risheries has Rerformed
                        no studies .......                           000 ........  is

                   C.   Conclusions of Draft PEIS Are ngt based on
                        the literatu 2 or indeR2nd2nt research     .............  16

                   d.   The mitigating measures Rroposed axe
                        contradictory or ineffective   ............  00000*00*0019

                   ee   The drafters do not mention Norway's LE
                        Project.... ... o..o ................................   o.21

            5.     DISEASE





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                a.    Nature of the disease problem.........       ... ... ......  23

                b. Mechanism for Transmission of Disease        ....  .............26

                c.   VHs ...            ...........................................28

                d.   The current Washington regulations are
                      inadequate to assure protection of wild or
                      hatchery fish...   ..... ....................................30

                e.    Conclusion of PEIS...........................................34

          6.    WATER QUALITY STANDARDS,       ...........  .......................36

                a.    Dissolved Oxygen..............................................36

                b.    Phytoplankton.................................................37

                c.    Fecal Coliform oooo ... ..................................... 40

          7.    EFFECT ON THE BENTHOS...............................................43

                a.    Feed Wastage Rates...................................... .... 43

                b.    Diver Study and Baseline Survey................................44

                c.    Eel Grass....................................... .... .....  ..45

          8.    EFFECTS ON MARINE MAMMAL AND BIRDS...................................46


                a.    Mammals. ......................................................46

                b.    Birds..........................................................47

                c.    Predators.  .......  ..........................................48

                d.    PEIS Conclusion  ..... .........................................5O

          9. CHEMICALS................................................................51

          10. ECONOMICS.    ..... ....................................................57

          11. NEED TO MAINTAIN COUNTY AUTONOMY .......................................60

          12. THE NEED FOR ENFORCEMENT................................................61

          13. CONTRADICTORY MITIGATION MEASURES ... ..................................63






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                14.   AESTHETICS    ...................                               .... 64

                15.   NOISE   ...                                                      ....66


                16.   ODOR  ...  ...                                                 ....68


                17.   COMMRCIAL FISHING       ................     69


                18.    RECREATION................................................71
             19.  NAVIGATION         ..........................................74


                20   HUMAN HEALTH...........................................75


                21.   UPLAND AND SHORELINE USE..          ...............76


                22.   LOCAL SERVICES..................................................77

                23.   CUMULATIVE IMPACTS............................................79

                24.   LAND-BASED TANK FARMS.........................................80


                25.   THE NEED FOR ANOTHER DRAFT...         ......   .............81





































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                          COMMENTS OF SKAGIT AND ISLAND COUNTIES CONCERNING
                          DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT
                                    ON FISH CULTURE AND FLOATING NET PENS


                       Skagit and Island Counties respectfully submit these

               comments on the Draft Programmatic Environment Impact Statement

               (PEIS) on Fish Culture and Floating Net Pens prepared for the

               Washington Department of Fisheries and issued February 6, 1989.



               1.      CONFLICT OF INTEREST

                       The principal consultants who prepared the Environmental

               Impact Statement for the Washington State Department of

               Fisheries were Parametrix, Inc., Batelle Pacific Northwest Labs

               and Rensel Associates. These organizations or their employees

               have been retained under contract by applicants for fish farm

               permits. In fact, at the time the PEIS was being prepared,

               each of these organizations or their employees had contracted

               to provide expert consulting assistance to at least four

               different industry applications.

                       Although there may be no legal requirement that experts

               hired on a contractual basis refrain from participating in

               state contracts such as the draft PEIS,l the Counties believe





                       1  The Executive Conflict of Interest Act, RCW 42.18 and 42.22, precludes state
               employees from participating in transactions involving the State where the employee "has a
               substantial economic interest of which he may reasonably be expected to know." RCW 42.18.260.
               Why it would be a good idea for independent contractors to be involved in such transactions is

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            that this practice represents a clear conflict of interest.

            Consultants should not be allowed to draf t important state

            policy documents that are in any way related to the subjects on

            which they are working on behalf of industry applicants. Given

            the nature of contested cases today, it is unlikely that the

            experts did not acquirq some flavor of partisanship during the

            contested cases. Hiring such "experts" to draft the PEIS is

            highly questionable under any analysis.



            2.   BUDGET
       G        The Environmental Impact Statement lists 19 areas of
            inquiry that it is intended to address. These include

            sedimentation, net-pen modeling, water quality, introduction of

            Atlantic Salmon, genetic impact, marine mammals and birds,

            odors, noise, upland and shoreline use, aesthetics, navigation,

            commercial fishing, recreation, local services, disease, human

            health, chemical and phytoplankton. It appears from a review

            of the Draf t PEIS and Technical Appendices that independent

            research was only performed on three subjects:         (1) the

            sedimentary ef f ects of net pens on the benthic community;






            (Continued)



            unclear. The participation of the consultants in partizan proceedings must be considered when
            determining the overall balance of the Draft PRIS.




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         (2) phytoplankton; and (3) economics. The rest of the report

         apparently is based on a review of existing literature. Most

         of this literature does not bear on local applications of net

         pen farming or the specific conditions existing in Puget Sound.

              No independent research was commissioned, by the State on

         perhaps the two most important issues in the report, disease

         transmission and genetic impacts. Without independent research

         into these and other areas, it is difficult to envision how

         local governments can evaluate the potential effects of any

         particular net pen site on wild populations of fish. Skagit

         and Island Counties believe that a proper PEIS should include a

         budget for independent study on these areas of concern.



         3.   THE DRAFT PEIS DOES NOT MAKE PROVISION FOR AREAS OF PARTI-
              CULAR CONCERN PREVIOUSLY IDENTIFIED BY STATUTEF REGULATION
              AND MANAGEMENT PLAN, NOR DOES IT MAKE ANY SPECIFIC RECOM-
              MENDATIONS CONCERNING THE SEPARATION OF WILD POPULATIONS
              AND FARMED FISH.

              a.  Washington's ConceRtual Plan for Shoreline Regulation.

              The principal regulations governing the shorelines of the

         State of Washington are the following:

              1.   The Shoreline Management Act (SMA), RCW 90.58, et.

         seq.

              2.   WAC Regulations implementing the Shoreline Management

         Act found at WAC 173-14 et. seq.

              3.   The various county Shoreline Management Master

         Programs.




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                 4. The Washington Coastal Zone Management Program

            (WCZMP).

                 The basic premise behind the SMA is that no activity is

            allowed on the state shorelines that is inconsistent with the

            Act or local implementing master programs. RCW 90.58.140. The

            master program classifies each stretch of shoreline under a

            shoreline designation area, natural, constervancyl aquatic,

            rural and urban areas. These designations, which are similar

            to zoning map classifications, specify the uses permitted in

            each area. Certain of the shorelines in the State of

            Washington are "shorelines of statewide significance."

            RCW 90.58.030(2)(e)(ii). Such shorelines are

                important to the state. Because these shorelines are
                major resources from which all people in the state
                derive benefit, the guidelines and master programs
                must give preferences to uses which favor public and
                long range goals.

            WAC 173-16-040(5). All waters in Puget Sound and the Strait of

            Juan de Fuca lying seaward from the line of extreme low tide,

            as well as Skagit Bay and the adjacent area, and Padilla Bay,

            are shorelines of statewide significance. A&& RCW

            90.58.030(e). In order to protect this statewide interest,

            local government, the Department of Ecology, the Department of

            Fisheries, and others, must comply with the use preferences set

            forth in the act which are to:

                (1) recognize and protect the statewide interest
                     over local interest;





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              (2)  preserve the natural character of the shoreline;

              (3)  result in long-term over short-term benefit;

              (4)  protect the resources and ecology of the
                   shoreline;

              (5)  increase public access to publicly owned areas
                   of the shoreline;

              (6)  increase recreational opportunities for the
                   public in the shoreline RCW 90.58.020.

              The WCZMP, which was promulgated by the Department of

         Ecology has specifically recognized certain areas of this State

         as being areas of "particular concern." For instance, Skagit

         and Padilla Bays are identified as the "most diverse, least

         disturbed, most biologically productive of all the major

         estuaries on Puget Sound."    (WCZMP p. 16).  It is noteworthy

         that the WCZMP is not even mentioned in the Draft PEIS.

              In addition, estuaries are also specifically designated in

         the WAC regulations implementing the act as areas deserving of

         special protection. WAC 173-16-050(5) states:

              Estuaries are zones of ecological transition between
              fresh and salt water. The coastal brackish water
              areas are rich in aquatic life, some species of which
              are important food organisms for anadromous fish
              species which use these areas for feeding, rearing
              and migration . . . because of their importance in
              the food production chain and their natural beauty,
              the limited estuarial areas require careful attention
              in the planning function.

              A further protective classification is found at

         WAC 173-16-040, which requires counties to categorize

         shorelines in their master programs as either aquatic, natural,





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            conservancy or other designation. It is clearly the policy of

            the SMA and the implementing WAC regulations to protect those

            areas designated natural or conservancy with substantially

            greater restrictions than other environments. For instance, as

            to the natural environments,

                 The main emphasis on regulation in these areas is on
                 the natural systems and resources which require
                 severe restrictions of intensities and types of uses
                 to maintain them in a natural state. Therefore,
                 activities which may degrade the actual or potential
                 value of this environment are to be restricted.

            WCZMP p. 32.

                 Although aquaculture is allowed under the Shoreline

            Management Act, it is allowed if, and only if, the proper

            environmental safeguards and procedures are followed:

                 Pro2erly managed, aquaculture can result in long-term
                 o_- short-term benefit and can protect the resources
                 and ecology of the shoreline.        Aquaculture is
                 dependent on the use of the water area and, when
                 consistent with control of Roll.ation. iknd 2revention
                 of damage to-th         nment, is a pref erred use to
                 the water area. WAC 173-16-060(2) (emphasis added).

                 Given the paramount goal of protecting the natural systems

            that exist in the State of Washington, it is curious that the

            Draft PEIS proposes no specific reservations of waters or types

            of waters to be removed from salmon net pen culture nor does it

            discuss in any detail the philosophy behind the existing

            regulations that govern separation of uses. This shortcoming

            is particularly important in view of the f act that most not

            pens are proposed in areas that are either estuaries,





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         shorelines of statewide significance, areas designated for

         special protection under the WCZMP, or some combination of the

         above. In other countries, such as Norway, where salmon

         farming has reached a more advanced state, regulations of this

         type are being proposed, as is described in the next section.

              b.   Norway Hag DeveloRed a Coastal Zone Management
                   Program which PrOROses to SeRarate Yet Pens frgm Wild
                   Salmon Rivers.

              In Norway, the LEWKA Project proposes a restriction of

         disallowing salmon farms from locating within 20 kilometers of

         salmon producing rivers.   In addition, many fjords, including

         the Trondheim Fjord (which is 120 kilometers long) are proposed

         to be completely closed to new salmon farms. The reason for

         this is the Norway's extensive experience with aquaculture,

         which has resulted in grave concern over the effects of farm

         salmon on the wild stocks both as to disease and genetic pollu-

         tion. one obvious solution to these concerap is to locate the

         fish farms as far away from salmon producing rivers as

         possible. Especially where salmon farms are located in

         estuaries, on shorelines of statewide significance, and near

         migratory routes or feeding grounds for important wild species,
    0    it would seem that the unknowns of salmon farming impose a
         significant conflict with the existing regulations that cannot

         be resolved by the optimistic tone of the draft PEIS that

         "proper siting," even in sensitive areas, can avoid adverse

         impacts.




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                  ce   Recommendations for Drafters Cong=*ning Cg=atibilily
                        (or Lack Thereof) between Salmon Zarms and- gxistiDZ
                       Regulations.

                  The three page discussion of the relationship between

             proposed salmon net pens and existing land use regulations (see

             pp. 141-143) glosses over the inherent conflicts between salmon

             farms and the legal requirements of the SMA. For instance, it

             does not appear that salmon net pens can do anything affirm-

             ative to:

                  (a) preserve the natural character of the shoreline;

                  (b) protect the resources and ecology of the shoreline;

                  (c) increase public access to public areas of the

             shoreline; or

                  (d) increase -recreational opportunities for the public in

             the shoreline. As stated in the SMA,

                  In the implementation of this policy, the public's
                  opportunity to enjoy the physical and aesthetic
                  qualities of the natural shorelines of the state
                  shall be preserved to the greatest extent feasible
                  consistent with the overall best interest of the
                  state and the people generally.      To -this end uses
                  shall be preferred which are consistent with control
                  of pollution and prevention of damage to the natural
                  environment . . .

             RCW 90.58.020. The very nature of salmon farming requires a

             lease of public waters to one individual or organization.        It

             is completely unclear whether such a lease comports with either

             the spirit or the letter of Washington law.

                . The Counties believe the drafters must address salmon net
       Opens in the context of the SMA to a greater extent than has


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         been done in the current PEIS. Failure to clarify the rela-

         tionship between the net pen operations and the existing

         regulatory framework will leave local government with the

         difficult proposition of attempting to rationalize mutually

         conflicting criteria for the evaluation of net pen projects.

         Currently the Draft PEIS fails to reference the WCZMP, fails to

         comment on the protection of unique and fragile environments,

         fails to comment on the concept of implementation of farm free

         zones (except to say that this might be a mitigation measure to

         mitigate a problem the drafters do not recognize to exist),

         fails to address possible need for protection of estuaries,

         fails to address possible needs for protection of nursery areas

         for young fish, and fails to incorporate these areas of concern

         into the overall statutory and regulatory framework currently

         existing for the protection of the shorelines of the State of

         Washington.

              d. The Public Trust Doctrine.

              The public trust doctrine, as recently set out in the case

         of Caminiti v. Boyl&, 107 Wn.2d 662, 668-69, 732 P.2d 989

         (1987), cert. den. 56 U.S.L.W. 3460 (1988), is based on the

         principle that the public has an overriding interest in

         navigable waterways and lands.       The doctrine resembles "a

         covenant running with the land (or lake or marsh or shore) for

         the benefit of the public and the land's wildlife department."

         Reed, "The Public Trust Doctrine: Is It Amphibious?, 1 J.




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            Envtl. L. & Litigation 107, 118 (1986); see Also Orion Cor2ora-

            tion v. State, -109 Wn.2d 621, 747 P.2d 1062 (1987), cert. den.

            56 U.S.L.W. 3805 (1988).

                1 Historically, the public trust doctrine developed out of

            the public's need for access to navigable waters and

            shorelands, and, as a result, it encompasses the right to

            navigation and fishery. Caminiti, 107 Wn.2d at 669. However,

            recognizing science's ability to further expand the concept of

            public need, the courts have extended the doctrine beyond its

            navigational aspects.    Thus, the Washington Supreme Court has

            had occasion to extend the doctrine to include%

                 incidental rights of fishing, boating, swimming,
                 water skiing, and other related recreational purposes
                 generally regarded as corollary to the right of
                 navigation and the use of public waters.

            Wilbour v. Gallagher, 77 Wn.2d 306, 315-16r 462 P.2d 232, 40

            A.L.R.3d 760 (1969), cert. deU_. 400 U.S. 878, 27 L.Ed.2d 115,

            91 S.Ct. 119 (1970).

                 The public trust doctrine has particular relevance in this

            area, since the waters impacted by proposed project generally

            are protected areas which are to be preserved by the State

            under its public trust. The drafters of the PEIS need to
       0    demonstrate how the public rights to recreation, boating and
            fishing will no t be restricted by net pens and therefore how

            local decision makers can avoid conflicts with the public

            trust.






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        4.   GENETIC CONCERNS

             a.    The evidence at this.- stage does not warrant the
     0             drafter's conclusion that no genetic effects are
                   likely to result from-interbreeding between escaRed
                   and wild fish.

             The conclusions of the Draft PEIS with regard to genetic

        concerns start with the following proposition.

             While the current culture of Atlantic and Pacific
             salmon appears to have little potential to
             significantly effect the genetic viability of native
             stocks, or to successfully compete with these stocks,
             future introductions of new species may pose poten-
             tial threats. (Draft PEIS, p. 75.)

             It is difficult to determine what information has been

        used in arriving at the conclusion that the culture of

        indigenous Oncorhynchus species will have no effect on the,

        genetic makeup of the wild stocks. The Draft PEIS is replete

        with apparently conflicting statements.

             For instance, the draft PRIS recognizes the following

        facts:

             (1) Different river systems have genetically different

        stocks of wild salmon (Draft PEIS at p. 69).      The genetically

        different stocks have been naturally selected for specific

        characteristics that give rise to the ability of those fish to

        survive in and return to particular river systems.

             (2) The Washington Department of Fisheries considers it

        undesirable to interbreed different stocks of wild salmon

        because such interbreeding decreases the genetic variability in



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            those fish (Draft PEIS at p. 70).   The reason that a decrease

            in genetic variability is undesirable is that any loss of

            genetic traits that are specifically related to a fish's

            ability to return to and survive in a particular river system

            is likely to decrease the viability of the population as a

            whole.

                 (3) Currently there are no regulations that require

            farmed or hatchery populations of indigenous species to be of

            the same genetic make-up as those in the natural rivers near

            the site of the pen-raised population. There are similarly no

            regulations or guidelines that prohibit genetic manipulation of

            wild stock.

                 (4) In fact, the PEIS admits that genetic manipulation of

            coho salmon has and does occur by fish farmers (Draft PEIS at

            p. 71).

                In addition to the evidence outlined in the Draft PEIS

            that suRRorts the existence of a potential problem, there is a

            great deal of information not cited by the drafters that

            further leads to the conclusion that net pen fish may

            significantly harm important genetic characteristics of wild

            population of salmon.

                With Atlantic salmon, extensive genetic manipulation has

            been carried out by fish farmers. The goal. of this manipula-

            tion is to develop a fish that can survive better in a net pen

            environment. Essentially, what the fish growers look for are



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             traits of "docility" that allow fish to grow large in the

             shortest possible time frame and with the greatest degree of

             ability to survive stress in close quarters. These traits of

             docility are unlikely to aid the salmon to survive in the wild.

             In his work The Environmental Effects of Floating Mariculture

             in Puget Sound (1986), Dr. Weston outlined the theoretical

             dangers of interbreeding cultured and wild salmon populations.

             These include:

                            (a) Salmon tend to evolve genetically discreet
                    and ecologically specialized subpopulations. Natural
                    selection can therefore lead to development of
                    characteristics optimally adapted for a particular
                    habitat. Cultured fish, however, are not preadapted
                    to the habitat in which they are placed.

                           (b) net pen fish may have been bred for charac-
                    teristics that are undesirable under cultured condi-
                    tions but are maladapted in the wild.

                           (c) Cultured fish may have reduced genetic
                    variability, limiting their abilities to cope with
                    environmental change.

             Id. at pp. 92-95.

                    The theoretical dangers outlined by Weston have actually

             occurred with respect to Atlantic salmon in Norway. Svein

             Mehli2 testified in a recent net-pen case in Washington that

             interbreeding may lead to changes in migration patterns of








                    2 Svein Mehli is the section head of the Directorate ror Nature Management in Norway
             with responsibility for wild runs of anadromous fish. He testified in Lacey, Washington in
             November, 1988. Despite the relevance of his testimony, no one from either the Department of
             Ecology, the Department of risheries or Department of Wildlife came to listen to his.


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            formerly wild fish or to decreases in productivity, especially

            in successive generations. It was estimated by Mehli that

            escaped salmon constitute approximately 40 percent of the fish

            entering Norway's natural salmon producing rivers. These fish

            are mature and ready to spawn. Some Norwegian scientists have

            predicted startling sequelae to the interbreeding between

            farmed and wild fish:

                The most alarming and pessimistic prognosis by one
                the leading experts in Norway on genetics, professor
                Harald Skjaevold at the Norwegian Agriculture
                University, anticipates that we may have 50% reduc-
                tion of the natural genetic variety in the course of
                a period of 7 to 10 years.

            Lundgren.  "Protective Zones for Salmon - A Concept for the

            Preservation of Genetic Diversity of Wild Salmons and Reduction

            of the Spreading Diseases Between Domestic and Wild Salmons."

            Ministry of Environment,, Norway,, p.3.

                Dagfinn Gausen, a fisheries biologist in Norway, states

            flatly that:

                Escapes by salmon from fish farming pens to the seas
                represent a new and potentially greater threat to
                natural genetic resource than gyrodactylus or acid
                rain.

            Gausen, The Establishment of a Salmon gVerm Bank in Norway

            (1988), p.l.

                As a result of the concern over genetic pollution, Norway

            has had to establish, at great expense, a sperm bank to

            preserve the identity of the wild stocks of fish. jd., Gausen

            says that a failure to act would mean:




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              destruction of the natural genetic resources which
              have the greatest value, even for the fish farmers
              themselves. If you destroy the original resource,
              what can you do if you have problems with the strains
              you are working with? You cannot back up.

         G. Meggs, "Journey to the Future" (1988) at p.7.

              b.   The De2artment of Fisheri2s has Rerformed no studies.
       0      There are no studies cited by the drafters of the PEIS on

         the effect of reduced genetic variability in Northwest stocks
         of coho, chinook, or other wild salmon.      The Department of

         Fisheries apparently has not done this work nor have the

         drafters of the PEIS.   There are, however, significant works

         that show that genetic variability is decreased in local

         populations of fish. For instance, Campton and Johnston

         performed a study in 1984 showing that non-native genetic

         material was introduced into the gene pool of rainbow trout in

         the Yakima River.   (2= Campton and Johnston, "Electrophoretic

         Evidence for a Genetic Admixture of Native and Non-Native Trout

         in the Yakima River, Washington". Transaction of American

         Fisheries SociSU, 114:782, (1985).      Similarly, researchers

         have found genetic differences in growth and survival of

         juvenile hatchery and wild Steelhead trout (see Reisenbichler

         and McIntyre "Genetic Differences in Growth and Survival of

         Juvenile Hatchery and Wild Steelhead Trout", J. Fish. Res,

         Board Can, 34:123-128 (1977)l and Brown trout (me& Ryman and

         Stahl, "Genetic Changes in Hatchery Stocks of Brown Trout",,

         Can. J. Figh. Aquat. Sy.1- Vol. 37, 1980.)  There is extensive




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            evidence that salmon farming and salmon hatcheries have altered

            the genetic variation between natural population and hatchery

            stocks of Atlantic salmon.      See, e.g., Stahl "Differences in

            the Amount and Distribution of Genetic Variation between

            Natural Populations and Hatchery Stocks of Atlantic Salmon",

            Aguaculture Vol. 33, p. 23 (1983); G. Naevdal, "Fish Rearing in

            Norway with Special Reference to Genetic Problems" Ecological

            Bulletin (Stockholm) 34:85 (1981); Ryman and Utter (EDS)

            Population Genetics and Fisheries Management (1987).
         8       C.    Conclusiong of Draft PEIS are iot based on the
                       literature or indeRendent research.

                 Despite the fact that reduced genetic variability has been

            found in numerous hatchery and farm population of fish where it

            has been studied, the conclusion of the Draft PEIS is that

            "local experts agree that widespread net-pen culture of Pacific

            salmon in Puget Sound poses a minimal threat to wild salmon

            populations in terms of genetic degradation."        (Draft PEIS p.

            69.)   It is interesting to note that this      conclusion was not

            made on the basis of any published literature but rather on

            "personal communications."

                 The drafters of the PEIS premise their conclusion on the

            unfounded assumption that breeding between hatchery or farmed

            fish and wild fish does not occur with frequency in nature.

                 This discussion considers potential impacts of
                 escaped fish interbreeding with wild stocks on purely
                 theoretical grounds. Impacts associated with inter.-
                 breeding between wild stock and net-pen fish is




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            undocumented. Since potential impacts can only occur
            with returning, mature, escaped fish (and major
            escapements are rare), the numbers of fish involved
            are expected to be small.

       (Draft PEIS, p. 72)   This statement is false or misleading in

       several respects.   Although it is true that no research has

       been done on the frequency of interbreeding of Washington

       farmed fish, there does exist information with regard to inter-

       breeding in Norway. Mehli testified that in 1988 40% of the

       fish found in Norwegian salmon rivers were farm fish, and that

       the serious reduction in genetic variation caused by inter-

       breeding had led directly to Norway's decision to establish a

       sperm bank to protect genetically distinct native stocks of

       fish. Testimony of Svein Mehli, Skagit System CooRerative v.

       Skagit County, SHB No. 88-14 (November 14, 1988), pp. 54-55

       (hereinafter "Transcript").

           One of the most significant and disturbing aspects of the

       reduction of genetic variability is Mehli's observation that

       succeeding generations of salmon are apparently less fertile.

       (Transcript, p. 56). In other words, when less competitive

       characteristics are injected into a gene pool, even though some

       salmon may return to the river, they may produce fewer fertile

       offspring, and those salmon may produce fewer yet in succeeding

       years. On page 70 of the Draft PEIS, the drafters seem to

       conclude (on no authority) that because some hatchery-raised

       salmon returned to the rivers, they have retained sufficient





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             genetic characteristics to indicate a lack of a problem in

             reduced genetic variability. This seems to 'be result-oriented

             science at its best. There has been no quantitative analysis

             regarding the number of returning salmon,, no studies with

             regard to the reduction in genetic variation, and no studies

             with regard to the effect of reduced genetic variation on

             fertility of succeeding generations.

                  Given the evidence that reduced genetic variability

             results in less fertile fish in rivers and that wild fish

             interbreed with hatchery fish, we believe that the Department's

             conclusion that "current culture of Atlantic and Pacific salmon

             appears to have little potential to significantly affect native

             stocks," is not only unsupportable, but flies in the face of

             the literature.   Since the drafters have done no independent

             research in this regard and since the effects of genetic

             variability reduction may be irreversi      ble, we consider it

             exceedingly unwise to adopt a "no problem" attitude as appears

             to have been done in the Draft PEIS.

                 The PEIS concludes that because hatchery releases by the

             State are large, the effect of net pens cannot be significant.

             This presumes that the hatchery releases have not had a nega-

             tive effect. Since no studies were performed, there is no

             basis to conclude that the hatcheries have not had a negative

             effect on the breeding of wild fish. We do know, however, that






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              wild breeding populations of fish continte to decline.3                                        In

              fact, the populations of coho stemming from the Skagit River

              (for instance) are so low that no commercial season for coho is

              currently allowed by the Department of Fisheries.

                      If the hatchery program were working as suggested by the

              drafters, one would expect to have increasing numbers of

              returning breeding fish. Since we do not, it would appear that

              there is at least circumstantial evidence supporting the

              proposition that wild stocks are losing their ability to

              reproduce naturally. We do not know whether this effect stems

              from reduced genetic variability of the wild stocks because of

              the hatchery program or because of salmon escaping from fish

              farms.       Given our knowledge of a-imilar problems in Atlantic

              salmon, however, it would be exceedingly unwise to allow

              wholesale licensing of Pacific salmon farms in areas where

              salmon would likely enter streams with wild spawning popula-

              tions.

                     d.      The mitigation measures RroRosed are contradictory or
                             ineffective.

                     It is also interesting to note that the Draft PEIS

              provides for mitigation measures that attempt to preclude the





                     3 To take just one example, on the upper Baker River, which is a tributary of the
              Skagit River, the average annual run of sockeye salmon from 1925 to 19S3 was 3,000. The
              average annual run of echo was 10,000 (Washington Department of Fisheries statistics). During
              the period from 19S4 to 1978, the average annual sockeye run declined to 2,547, and the
              average coho run declined to 6,003 (Paget Power and Light statistics). Since 1978, there has
              been an alarming decrease in the number of returning adult sockeye and echo. In 1985p only 21
              sockeye and 463 coho returned to spawn. Concrete-Rockport Environmental Assessment (Western


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           mixing of escaped f arm populations with wild stocks entering

           the river. On page 75, the Draft PEIS states:

                Where necessary, established minimum dis  *tances net-
                pens should be sited away from streams with wild
                populations vulnerable to genetic degradation.

           The rest of the report, however, acknowledges no circumstances

           under which this would be necessary and citeS none of the data

           or literature that currently exists on the potential for

           genetic pollution. The Draft PEIS leaves local governments no

           criteria upon which to make a decision concerning which

           streams, which populations, and what deleterious effects are

           thought to be avoided by the mitigation meaSures, and how far

           away the pens should be located.   Indeed, the PEIS identifies

           no adverse effects.

                On page 75 of the Draft PEIS, a proposed mitigation

           measure suggests:

                Where significant risk of interbreeding or establish-
                ment of deleterious self-sustaining populations
                exist, only permit the culture of sterile or
                monosexual individuals.

           As above, the Draft PEIS identifies no situations where

           significant risk of interbreeding or establishment of

           deletorious self-sustaining populations exist.   The Counties

           are therefore left with no scientific evidence or guidelines





           (Contlnued)



           Washington University 1986).


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         concerning the risks sought to be avoided and the method for

         avoiding them.

              Other mitigation measures with regard to genetic pollution

         seem ineffective or unwise.    On page 75 of the Draf t PEIS the

         authors propose to:

              Encourage commercial, sport, and tribal fisheries to
              harvest escaped fish, and/or permit farm operators to
              conduct a targeted fishery for escaped fish in the
              immediate vicinity of his pens.

         If escapees are a native species, how will the fisherman know

         if it is a pen f ish or a wild f ish? Will not such a f ishery

         cause an incidental catch of wild f ish, especially where net

         pens attract wild fish? What data suggest escapees stay in the

         vicinity of the net-pen so that the harm from incidental catch

         of wild f ish will not outweigh the benef it of the increased

         fishery for the escapees?     If this f ishery is allowed, what

         ef f ect will it have on the rights of traditional tribal and

         non-tribal fisherman to catch their allocated share of

         returning runs? If pen fish do not harm the gene pool, why do

         we need this measure in the first place?
     G        e.   The drafters do not mention Norway's LEWKA Projmt.
              One of the most significant aspects of the LENKA Project

         is its recommendations to move the sites f or new location of

         salmon farms out of the fjords and toward the coast of the open

         ocean. The reason for this proposal is the fear that escaping

         net-pen f ish will breed with wild f ish in the salmon rivers.





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           Minimum distances f or location of salmon f arms f rom the mouths

           of rivers have been proposed for Norway. Under the proposal,

           no salmon farm will be located closer than :20 kilometers from

           the mouth of a salmon producing river (Transcript, pp. 30-35).

           We have been informed by Mehli that the LEN:KA recommendations

           will be implemented by this Spring or Summer.       No similar

           proposal, study, or concern is expressed by the draft PEIS.

                In summary, no data exist regarding the escapes of farmed

           Pacific species because no studies have been done.   Data from

           Norway and elsewhere indicate possible permanent, irreversible

           damage may be done to the fertility and survivability of

           distinct populations of wild fish.    The mitigation measures

           proposed are either insufficient, contradictoryt or not likely

           to have any effect. For the Department of Fisheries to say

           that no threat is posed to wild stocks is without basis given

           the available evidence and the potential damage that could

           occur (and may now be occurring) to our wild runs. We recom-

           mend detailed studies of the effects that current hatchery

           programs have had on wild fish runs, a careful evaluation of

           those data, separation of any pen fish from all wild stocks,

           and a monitoring program, the cost of which is borne by the

           industry, to make sure that the deleterious@ genetic effects

           found elsewhere do not happen in Washington.








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         5.   DISEASE

              a.   Nature of the disease problem.

              There are two methods of disease transference among

         salmon, generally known as horizontal and vertical disease

         transmission. Horizontal transmission occurs when a virus or

         bacterium is spread through the water or through bodily contact

         from fish to fish. Vertical transmission occurs when the

         bacterium or virus is transferred through the egg to the newly

         hatching fish. It is known that some varieties of bacteria and

         viruses can survive intra ovum and be transmitted vertically.

              There are a variety of diseases which affect net-pen fish,

         many if not all of which are highly communicable. Dr. Elston,

         who is an employee of Batelle, one of the drafters of the PEIS,

         has identified the three most important diseases as vibriosis,

         furunculosis and bacterial kidney disease (BKD).     In addition

         to these three indigenous diseases, a number of other diseases

         can affect farmed salmon. In fact, Elston has stated that the

         number of fish diseases recorded in the literature can be

         directly correlated with the number of people performing

         research on such diseases. Recent articles co-authored by Dr.

         Elston describe two new such diseases. See L.W. Harrell, R.A.

         Elston, et al., "A Significant New Systemic Disease of Net-Pen

         Reared Chinook Salmon Brood Stock, Aquaculture 55:249 (1986);

         see also, M.L. Kent, R.A. Elston, et al., "Cranial Nodules






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            Associated with Cranial Fenestrae in Juvenile! Atlantic Salmon,,"

            Journal of Fish Diseases Vol. 10, p. 419 (1987).

                  There is documentation in the literature of examples of

            transmission of disease from net pen to wild fish. Moring

            states that after a very serious outbreak of furunculosis in

            National Marine Fisheries net pens, "The disease spread to wild

            fishes in Clam Bay".      Moringr AsRects-9d Growth. and the

            Effects of Some Environmental Factors on Pen-Reared Chinook

            Salmon, pp. 148-49. A recent study by Malcolm C.M. Beveridge,

            performed under the auspices of the Food and Agriculture

            Organization of the United Nations, noted several instances of

            apparent transmission of disease from cage to wild fish.

            M.C.M. Beveridge, "Cage and Pen Fish Farming" (1984), pp. 13-

            14. Even one of the recent articles co-authored by Dr. Elston

            warns of the danger of transmitting a newly discovered pen fish

            disease to wild fish. Harrell, Elston &t al., "A Significant

            New Systemic Disease of Net-Pen Reared Chinook Salmon Brood

            Stock," Aguaculture 55: 249-262 (1986) at p. 261.

                 Svein Mehli's testimony regarding the experience of Norway

            is also highly instructive.    Since the advent of net-pens in

            cultured fish, Norway has experienced the introduction of a

            number of new diseases that had not been found in Norway

            before, including BKD and redmouth disease, as well as the

            parasite gyrodactylus salarls (Transcript, pp. 43-46).






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              Mehli states that net-pens are viewed in Norway as multi-

         plying stations for disease, which thereby put pressure on the

         natural stocks which did not exist before the pens were

         installed (Transcript, p. 101).      One example of this effect

         occurred when there was an outbreak of f urunculosis in a net-

         pen. Five thousand diseased salmon escaped into the wild.

         Subsequently, wild fish were found infected with furunculosis

         (Transcript, pp. 95-96).      Similarly, BKD did not exist in

         Norway before 1980. After first infecting net pen and hatchery

         fish, BKD is now present in the rivers in wild stocks,

         including rivers into which farmed fish have escaped (Trans-

         cript, pp. 98-99).

              Perhaps the most spectacular example of an environmental

         impact was that caused by the parasite gyrodactylus which has

         multiplied and spread to 30 rivers in Norway. The only way to

         stop the spread of this parasite has been to poison the rivers

         with Rotenone thereby destroying all fish life within the

         rivers.  The rivers were then restocked.       Mehli also stated

         that he had witnessed the transport of yyrodactylus by pen-

         reared Rainbow trout (Steelhead) (Transcript, p. 41-43. 50,

         94). Gyrodactylus may survive in brackish waters of up to 18

         per cent salinity. One obvious measure to prevent introduction

         or spread of gyrodactylus is to preclude net pens in waters of

         low or fluctuating salinity. No such measure has been recom-

         mended or discussed in the Draft PEIS.




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                 b. Mechanisms for Transmilsigh of Disease

                 There are a number of ways in which disease can be trans-

            mitted from net pen to wild fish. First of all, it is well

            documented that net pens attract wild fish.      Weston (1986)

            acknowledges that, "Wild f ish are f requently observed in high

            densities around cages containing cultured fish." Id. at p.

            76.  Mr.. Mehli also testif ied to his f amiliarity with this

            phenomenon (Transcript, p.67). Since many areas of Skagit and

            Island County shorelines are migratory routes for all five

            species of wild salmon, as well as for three species of wild

            trout, and given the highly communicable nature of diseases

            such as vibriosis, furunculosis and BKD, the potential for

            contamination is highly significant. It would,therefore seem

            especially important not to locate net-pens in migratory routes

            for wild salmon.

                Second, there is the potential for transmission of disease

            through escaped pen salmon, as discussed by- Mehli in the case

            of furunculosis. Mehli stated that escaped Atlantic salmon

            from net pens constituted in 18% of the fish found in Norway's

            rivers in 1987, and that preliminary estimates for 1988 indi-

            cated a use in this figure to 40%. Beveridge described escape-

            ment of pen fish as a common occurrence:

                Cage and penned fish frequently escape through
                netting or mesh damaged by predators, floating
                objects, or rough weather and in this way foreign or
                exotic species can be introduced to an environment.
                In any commercial cage or pen operation it is




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              inevitable that some fish escape. In one lake in
              Poland, Penczak estimated that 4 tonnes of trout
              escaped in one year.      There are many records of
              escaped or deliberately transplanted fishes on
              indigenous fish stocks, and these include the
              extermination of local fishes through predation or
              competition, interbreeding with native fishes and
              adulteration of the genetic pool, habitat destruction
              and the outbreak of disease epidemics.


         (Exhibit R-23, p. 305).    Most recently, in February, 350,000

         chinook and coho salmon escaped from net pens during a storm in

         British Columbia.

              There is also evidence of Atlantics escaping from net pens

         in Washington. Mature Atlantic salmon have now been f ound in

         the Nisqually and Nooksack Rivers.     These fish are sexually

         mature and ready to spawn.      The Washington Department of

         Fisheries, has documented the catch of over 200 escaped fish.

         Moreover, as Eric Hurlburt, the Department's Aquaculture Coor-

         dinator stated, "these numbers surely underestimate the number

         of Atlantic salmon which are in the wild." Letter from Eric

         Hurlbert to Len Barson, p. 1. Greg Peterson, the Executive

         Director of Puget Sound Gillnetters, has stated that a number

         of Atlantics were caught early in the fishing season and

         counted as coho. He estimated that approximately 1,000 Atlan-

         tics had been caught this year. At the hearing in Mt. Vernon

         on the Draft PEIS, two commercial fishermen stated that just

         between the two of them, they had caught 83 Atlantic salmon the

         past year. Because of the growing number of escapes in





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         0   Washington, the Counties recommend that fish farmers be
             required to report all escapes of farm fish to the State.

                  It is often stated that transmission of disease f rom pen

             fish to wild fish will not occur because pen fish are stressed,

             while wild fish are not.    However, juvenile fish which have

             just come into salt water from fresh water, such as the salmon

             f ry that migrate in Skagit Bay, are indeed stressed. Stober

             and Salo discuss the increased susceptibility of salmon f ry to

             environmental hazards, and note particular concern for pink and

             chum fry because of their small size and limited opportunity to

             adjust to salt water. Stober and Salo, Juvenile galmonid

             Migration Through North Skagit Bay, p. 35.

                 Moreover, Moring actually documented the presence of

             juvenile pink salmon inside net pens at Kiket Island, in Skagit

             Bay, and Manchester. Moring (1975), p. 147. This is clearly a

             dangerous situation, since the juvenile pinks would be exposed
             to diseases in the pen at precisely the time they are most

             stressed.


                 co VHS


                 The Draft PEIS states:

                 The current system of certifying salmon eggs has been
       G         effective in preventing the introduction of exotic
                 diseases such as viral hemorrhagic septicemia.

             This statement has been thrown into substantial doubt recently

             by the appearance of the VHS virus in two hatcheries in

             Washington. At least one official from the U.S. Fish and Wild-




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         life Service (Jerry Grover) stated that there is a strong

         possibility that the disease was introduced to the United

         States through fish farming operations for Atlantic salmon.

              Dr. Ken Wolf, perhaps the foremost expert on the disease,

         has theorized that VHS was probably first found in one or more

         of Europe's salmonids, such as Atlantic salmon. The virus has

         proved highly virulent among Rainbow trout; however, a 1982

         study by de Kinkelin confirmed that the disease can also affect

         Atlantics as well. The de Kinkelin study concluded,

              In conclusion, taking into account the availability
              of viruses to produce variance and the fact that VHS
              viruses are able to grow in Atlantic salmon. VHS is
              obviously a potential threat to intensive salmon
              culture. Any project to rear Atlantic salmon should
              apply strict sanitation rules towards VHS.


         de Kinkelin and J. Castric, "An Experimental Study of the

         Susceptibility of Atlantic Salmon Pry, Salmo salar, to Viral

         Hemorrhagic Septicemia," Journal of Fish Diseases, 5:57-65

         (1982) at 65.

              Neither the Department nor the drafters of the Environ-

         mental Impact Statement has done any independent research on

         VHS. Contrary to the position taken by the Department of

         Fisheries, Dr. Wolf states that: .

              Egtved Virus (VHS) was probably first found in one or
              more of Europe's salmonids - Atlantic salmon, Danube
              salmon, or Brown trout. Among these, the Brown trout
              is usually considered to be the prime or initial
              source species, because of its widespread original
              habitat, abundance, and comparatively high resistance
              to VHS. Although less common, the Atlantic salmon,




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                 Danube salmon, Greylings, and Whitefishes must remgin
                 suspect as the possible original sourc-a -or sources.
                 (Emphasis added.)


            The Washington Department of Fisheries performs a variety of

            hatchery programs using Brown trout, as well as Atlantic

            salmon. No mention is made in the Draft PEIS of the potential
       0    for salmon farms (which are not limited to :raising any parti-
            cular species) to pick up exotic diseases through species other

            than Atlantic salmon.

                Whether the virus came from Brown trout, Atlantic salmon,

            or some other sourcel it is now in Washington, and is probably

            here to stay.   It is a significant example of the potential

            impact that culture of exotic species can have on the environ-

            ment.

                d.   The current Washington regulations       inadeguate to
                     assure protection of wild or hatchery-fish.

                The existing regulations regarding Aquaculture Disease

            Control are found at WAC 220-77      seg. They are completely

            inadequate to accomplish any of the mitigation measures set

            forth on pages 80 and 81 in the draft PEIS.

                First, WAC 220-77-030 relates only to diseases that result

            from the importation of eggs or fish into Washington and thus

            does not apply to di seases such as vibriosis,, BKD,, or furun-

            culosi.s. Only four diseases are directly mentioned by the

            regulations. Significantly absent are redmouth disease, or






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          other diseases that have been a problem elsewhere, as well as

          gyrodactylus, which is a parasite.

               The regulations are only as good as the inspection f or
          disease that is performed. Mehli testified that gyrodactylus

          was introduced into Norway because the inspectors did not know

          where to look or what to look for (Transcript, p. 113). In

          Kent and Elston's article concerning cranial nodules in

          Atlantic salmon a recent disease imported to Washington was

          traced back to eggs imported from Finland. Again, the

          inspectors presumably did not know what to look for or where to

          look. They certainly received no instruction from the regula-

          tions themselves concerning investigatory techniques or methods

          that should be employed in order to determine the existence of

          these exotic diseases.

              Second, although WAC 220-77-070 provides for measures such

          as quarantine, the safeguards envisioned by the regulations are

          entirely dependent on notification by the operator that a

          disease is occurring at the net-pen sites.       Amazingly, such

          notification is not reguired by the regulations unless there

          has been a conf irmed diagnosis of one of the f our diseases.

          Therefore, as to any disease not mentioned in the regulation,

          there is no requirement of reporting. As to any disease which

          is suspected, but not confirmed, there is no requirement of

          reporting.






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                 obvious economic reasons exist why an operator would not

            provide notice voluntarily, since that could result in elimina-

            tion of a pen stock by order of the Department. Moreover,, even

            assuming good faith efforts by an operator, many diseases are

            not visible until long after they become conununicated to other

            fish.   For example, the effects of BKD are generally noticed

            only after a year or two of rearing. Fish also may begin to

            die from vibriosis before any external signs are apparent. See

            Margolis and Evelyn, "Aspects of Disease and Parasite Problems

            in Cultured Salmonids in Canada, with Emphasis on the Pacific

            Region and Regulatory Measures for their Control," pp. 5-6;

            Moring, "Aspects of Growth and the Effects of Some Environment

            Factors on Pen-Reared Chinook Salmon," p. 149.

                 By the time of detection, a great deal of damage can

            already have been done.    Detection of disease in wild fry is

            also extremely difficult. The Norwegian experience amply

            demonstrates the potential for the spread of disease despite

            the fact that regulations in Norway are much more stringent

            than those in Washington and the United States.

                The third problem involves the current methods of handling

            egg importation. Horizontal transmission of bacteria, viral

            disease and parasites can be controlled through treating the

            eggs with an iodine bath. In order to be effective, all eggs

            must be treated in the bath for at least six minutes. No







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          information is presented by the Draft PEIS to establish the

          frequency of extra-legal importation of eggs, the existence of

          any black market, or other factors that might lead to the

          importation of eggs that are not properly treated. We know of

          no mechanism employed by the Department of Fisheries or the

          State of Washington to investigate and stamp out extralegal

          importation (and none is discussed by the drafters).

          Regulators, therefore, must rely principally on voluntary

          compliance with the regulations. Of course, voluntary

          compliance is not necessarily the rule in every for profit

          business.

               Vertical transmission of disease provides a further level

          of complication to the already existing difficulties in

          controlling disease from imported sexual products.         Iodine

          baths do not kill viruses or bacteria inside the ovum. In

          order to determine whether any batch of imported eggs carries a

          virus or bacterium that is potentially harmful, the eggs must

          be quarantined.

               According to Kevin Amos, a Department of Fisheries

          pathologist, there is no centrally located or state supervised

          quarantine facility. Rather, quarantine operations are carried

          out by unlicensed, untrained individuals at the fish growers'

          places of business and under conditions that are only sporadi-
          cally inspected.    Therefore, the very people who are the

          subject of the regulatory process are the ones carrying out the



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           quarantine procedures.    Such a mechanism f or enforcement of

           regulations is unlikely to result in a foolproof method of

           disease control.

                In Norway, a state run veterinarian service is charged

           with the detection and prevention of disease.      There is no

           vehicle proposed by the draft PEIS to promote any preemptive

           steps to combat disease until after a problem develops. Under

           current conditions, therefore, there is no state or county

           agency that provides a comprehensive method of enforcement

           against disease. S-imilarly, there is no money to pay for such

           enforcement measures even if a county were to adopt, on its

           own, a regulatory mechanism that provided for better control

           over diseases.

                Despite the veterinarian service, comprehensive regula-

           tions, and greater experience, diseases have entered along with

           fish farms in Norway. Washington State is in a far worse posi-

           tion than Norway to detect or prevent the introduction of

           exotic diseases.

                e.   Conclusion of REIS

               The drafters of the programmatic PEIS cite some of the

           literature which indicates that transfer has and does occur

           whenever exotic species are introduced in new areas. The

           drafters conclude however, that the risk of transmission to
           wild stocks is "minimal" (PEIS p.80) and that adverse impacts

           can be mitigated through the measures of:




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                     (1)    Development of legal measures;

                     (2)    Development of regional brood stocks;

                     (3)    The regulatory frame-work now in place;

                     (4)    Education of regulatory agencies and fish
                            farming industry;

                     (5)    Technical certification procedures; and

                     (6)    A requirement for the recording of fish disease
                            outbreaks.


                    Mitigation measures 1, 2, 4, 5 and 6 are not currently

             found anywhere in the existing Washington regulations. No

             specific proposal to implement the general concerns have been

             made in the draft PEIS.

                    Given the extremely damaging results that might occur from

             the introduction of exotic diseases, the Counties believe that

             absent specific implementation of new regulatory and enforce-

             ment procedures, pen raised salmon pose a unique threat to our

                                                    4
             wild and hatchery fish.                     Given the economic and social

             interest relating to healthy wild stocks of salmon, the risks

             to these stocks do not justify the introduction of exotic

             species where it is known that such introductions have histori-










                    4 It should be remembered that hatchery f ish are grown with public money for public
             benef it under conditions similar to farming operations. To subject our investment to a risk
             that only benefits private growers raises substantial questions concerning the economic costs
             of salmon not pens that have not been addressed in the Draft PEIS.



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           cally carried with them parasites, bacteria, and viruses that

           have infected the native populations.



           6.   WATER QUALITY STANDARDS

                a.    Dissolved OXygen

                The Draf t PEIS concludes that "net-pens would have an

           impact on dissolved oxygen and turbidity in Puget Sound.

           However, the impact would not be significant enough to violate

           state water quality standards." (Draft PEIS, p. 43.) On the

           same page, the Draft PEIS suggests that the most effective

           mitigation measure for dissolved oxygen impact would be to

           locate the net pens in areas that have historically had oxygen

           levels above six milligrams per liter.

                It is known that dissolved oxygen is traditionally low in

           some places in Puget Sound, especially during the fall months.

           See,, e.g., Colias, Atlas of Physical and Chemical Pro2erties of

           Puget Sound and ita ARRroaches (1974). Water low in dissolved

           oxygen enters the Puget Sound from the ocean. There is

           generally an upwelling of this ocean water in the late summer

           or the fall. Some of the water can have oxygen levels as low

           as 2.0 milligrams per liter at the time of upwelling. These

           periods of low oxygen, even in waters that are substantially

           oxygenated for the rest of the yearF may occur for extended

           periods of up to a week or two. There is no discussion in the

           Draft PEIS as to what effect the biological oxygen demand from




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          a net-pen will have on benthic or other species living near the

          net-pens when they have to suffer through the combined effects

          of seasonal low oxygen and high BOD from the net-pens.

               The Counties believe that the drafters of the PEIS should

          investigate and discuss the effects of locating net-pens in

          areas where seasonal reductions in dissolved oxygen are known

          to occur.    Moreover, as indicated in the draft PEIS, actual

          field studies have shown a decrease in dissolved oxygen as much

          as 1.5 milligrams per liter in the area of net-pens (Draft

          PEIS, p. 42). There is no discussion in the Draft PEIS of the

          cumulative impact of the natural decrease in dissolved oxygen

          combined with this additional effect from net pens. The

          Counties believe that this too should be remedied in the Final


          PEIS.

              b.    PhytoRlankton

              The draft PEIS statest "Worldwide, there has never been

          any evidence that net-pens caused or increased a bloom of

          noxious phytoplankton." (Draft PEIS, p. 48.) This statement

          does not seem to be supported by the literature. For instance,

          Dr. Weston in his August 1986 study, "The Environmental Effects

          of Floating Mariculture in the Puget Sound" states:

              Although not conclusively demonstrated, mariculture
              may be responsible, in part, for phytoplankton blooms
              observed in other countries, with Japan being the
              most notable example.       Arakawa (1973) corrolated
              phytoplankton blooms with the culture of oysters in
              Hiroshima Bay. The frequency of the blooms closely
              paralleled historical trends in oyster production




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                 within the Bay, however, it should be noted that the
                 correlations in time are,often spurious. . . .
                 Laboratory studies have also implicated yellow tail
                 feces as a potential contributing factor in
                 phytoplankton blooms (Nishimura, 1982), and yellow
                 tail culture operations have been adversely affected
                 by blooms, with consequent production losses.
                 Although the causative factors have not been clearly
                 demonstrated, the Japanese have found phytoplankton
                 blooms appearing with greater frequency than in the
                 past. . 9 *

                 Outside of Japan there are few reports of mariculture
                 potentially contributing to phytoplanktan blooms. At
                 one site in Ireland (Doyle, et al. 1984) a bloom
                 occurred that was localized around a culture opera-
                 tion, and the fish culture operation was believed to
                 be a contributing factor . . . The potential for
                 changes in phytoplankton community composition as a
                 result of mariculture activities has not been
                 addressed.


           Weston, "The Environmental Effect of Floating Mariculture in

           Puget Sound" (1986) at pp. 41-45.

                 The 1988 ICES report similarly identifies the potential

           for algal blooms and concludes that there has not been enough

           work performed yet to determine what the precise effects of

           salmon culture are on this aspect of water quality.

                 The study group recognizes that mariculture activity
                 could bring about changes in the natural population
                 in marine algae (phytoplankton and macroalgae) in the
                 vicinity of the farm or at a distance where flushing
                 action is vigorous. These effects include stimula-
                 tion of primary production, changes in.the species
                 composition of the phytoplankton, reduction of
                 phytoplankton's standing crop, senescence of
                 phytoplankton blooms with subsequent localized areas
                 of low dissolved oxygen, and enhancement of macro-
                 phyte growth. These effects have implications for
                 public health, natural populations of marine
                 organisms, and the viability of mariculture
                 industries.         Byproducts of fish metabolism and




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            feed leachates represent a source of nutrients for
            phytoplankton growth and could, given suitable
            hydrographic conditions, stimulate primary production
            of phytoplankton if nutrients are controlling growth
            at the time. . . 0 Organic waste from fish farms
            might also play a role in stimulating the growth of
            specific algal species.       For example, Nishimura
            (1982) has shown that fish farm by-products (fish
            carcasses and feces) enhance the growth of at least
            one red tide forming dinoflagellate. Biotin has been
            implicated in the ef f ects of gyrodinium aureloum
            (Turner et al. , in press) and Vitamin B-12 is a
            growth requirement for the toxic microphlagelate
            prymnesium parvum. Biotin and Vitamin B-12 are
            constituents of fish feed but their fate in the
            marine environment is poorly understood. . . .
            Toxic algal blooms are known to have killed wild fish
            (A. White unpublished data) and have been implicated
            in mass mortalities in farm fish in European waters
            (Doyle, et al., in press; Jones, et al. 1983) and
            shellfish (Buestel, et al. 1986). These problems are
            the subject of an ICES working group on exceptional
            algal blooms and are not discussed in this report.


      Rosenthal, et al. "Environmental Impact of Nariculture (1988).

      at p.7. Finally, NASCO, the North Atlantic Salmon Conservation

      organization, also recognizes that there have been examples of

      localized phytoplankton blooms occurring in enclosed sea lochs

      causing mortality of farm stock. "Potential Impacts of Salmon

      Farming on Wild Stocks," NASCO Council paper CNL (88) 21.)

            Since 1978, the consequences of phytoplankton blooms,

      especially those causing PSP, have plagued the counties in

      Puget Sound. PSP was largely unknown in the Sound before 1978.

      It is unknown why these episodes began in 1978, but they are

      generally regarded as being influenced by additional nutrients.

      Net-pens introduce disproportionate amounts of nutrients into





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               Net-pens introduce disproportionate amounts of nutrients into

               the water.

                     Because of the association of nutrient loading and algal

               blooms, and because of the low level of understanding that

               scientists have regarding the relationship between the nutrient

               loading, other promoting growth factors, and fish farms, it

               appears that the drafters have arrived at their opinions prema-

               turely and without sufficient study.

                     C.   Fecal Colifo

                     Virtually no space is given in the draft PEIS to the

               problem of fecal coliform. No impact is identified and no

               mitigation measures are proposed to avoid fecal coliform prob-

               lems.

                     The sum total of the Draft PEIS comments on fecal coliform


               are as follows:

                     Fecal Coliforms. Fecal coliform bacteria are
                     produced in the intestines of warm-blooded animals
                     and are a relative measure of sanitary quality (APHA
                     1985).   Net-pens do not directly affect ambient
                     (existing) fecal coliform concentrations in Puget
                     Sound because fecal coliforms are not produced in
                     fish. However, fecal coliform levels could
                     indirectly increase near net-pens from increased
                     marine bird and mammal activity. Or fecal coliform
                     levels could possibly increase from the failure of a
                     facility's septic system.

                     A great many of Puget Sound's waters surrounding areas

               where net-pens might be proposed are contaminated by fecal

               coliforms that come from failed or malfunctioning sewer

               systems. Recorded fecal coliform rates as high as 32 million




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         per hundred milliliters of water have been measured within

         several miles of proposed net-pen sites. Beaches in these

         areas have been closed to shellfish as a result of the high

         pollution load.

               The question then becomes whether the existence of net-

         pens can exacerbate already existing problems. In this regard,

         scholars seem to agree that insufficient work has been done to

         evaluate the interrelationship between coliform rates and net-

         pens:

               The effect of culture activities on coliform, and
               specifically, faecal coliform bacteria is of parti-
               cular interest because of the importance of this
               group in water quality monitoring. Finnish
               authorities have found elevated concentrations of
               coliform and fecal streptococci bacteria in effluents
               from freshwater trout ponds (Haavisto, 1974). 0 0 0
               Increased total coliform concentrations have also
               been reported in receiving waters near several fresh-
               water hatcheries in the Western United States
               (Hinshaw 1973), although a large freshwater trout
               f arm in Norway caused no change in f ecal colif orm
               numbers in receiving waters (Bergheim and Selmer-
               Olson, 1978). Near surface waters near marine salmon
               net cages in Seshelt Inlet, British Columbia were
               seen to have a higher total coliform concentration
               than comparable reference areas.        The increase,
               however, was not statistically significant (E. Black
               and B.L. Carswell, unpublished data). We are in need
               of a clear differentiation between fecal and total
               coliform, because the counts obtained with methods
               usually employed to evaluate sewage effluents in
               waste waters originating from human activities, may
               not adequately reflect the species and type composi-
               tion encountered in fish farm effluence. The
               development of sound hygienic criteria, specifically
               adapted to the marine environment is urgently needed
               (emphasis added).

        Rosenthal et al., "Environmental Impact of Mariculture," p.5.





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                 Prior to arriving at a conclusion that fish farms do not

            have an exacerbating ef f ect on areas already contaminated by

            fecal colif orm (a position not shared by the world's foremost

            ,scholars), we believe that the department should either perform

            independent research on the subject or fairly identify the

            current unknowns in the literature.      A description of the

            potential impacts on human health as a result of exacerbation

            of existing fecal coliform conditions should also be included

            in the PEIS.

                 A further dimension to the problem is added when

            considering what organisms should be considered to make up

            "total coliform." The assumption by the drafters of the PEIS

            is that fish do not produce bacteria that pose dangers of

            infection to humans.    That assumption is not entirely well

            grounded. In recent years, important work has been done on the

            classification of pathogenic bacteria that may provide human

            health problems through poor water quality. Some of this work

            has called into question the previous classification of

            bacteria as "coliform." The committee in charge of revising

            the Publication.of Standard Methods (a treatise jointly

            produced under the auspices of the American Public Health

            Association,, The American Water Worker Association, and the

            EPA) is considering a reclassification of coliform, bacteria to

            include species in the aeromonas genus. It has been found that






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          certain aeromona species, which are known to be produced by

          aquaculture activities, can cause infection in humans. For

          instance, operators of shrimp culture pens in Hawaii have been

          found to be infected by the aeromas bacteria carried by the

          shrimp. Dr. Ted Wetzler (Personal Communication). Salmon also

          are known to carry and distribute aeromonas. If the concept of

          total coliform is re-classified to include aeromonas bacteria,

          net pens will necessarily be seen as having a substantial

          impact on total coliform concentrations.      Such a result would

          more accurately ref lect the pens I potential as a source f or

          health problems.



          7.   EFFECT ON THE BENTHOS
       0       a.   Feed Wastage Rates.
               Feed wastage rates were reported at levels between 1 and

          30 percent. The drafters stated that "feed wastage has proven

          difficult to ascertain in field conditions." It is unclear

          from the draft PEIS whether investigation was made into actual

          wastage rates; the only information used appeared to come from

          growers' reports. Independent work should also be undertaken

          in order to properly calculate FCRs (food conversion ratios).

          The assumption of a 1 to 1 or less than 1.5 to 1 FCR should

          require some substantial investigation.       None seems to have

          been done, and even in Norway, such low FCRs are not claimed to

          occur in the industry.




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                 Conversion efficiency obtained with the same food can
                 vary enormously according to the method of feeding
                 and the general skill of    the fish farvier.   For wet
                 foods, containing about 12-1300 kcal of available
                 energy/kg, conversions as   low as 4 and as high as 16
                 to one have been reported, but the average is around
                 6 or 8:1. For dry foods,    better (lower) conversions
                 can be obtained with small  fish up to about 50 g, and
                 for these figures as low as 1:1 have been claimed
                 with high energy foods (about 3670 kcal available
                 energy/kg). For larger fish, conversions from lh to
                 3:1 have been reported, but around 2:1 is normal both
                 for salmon and rainbow trout.

            D. Edwards, Salmon and Trout Farming in Norway (1978).

                 The reason these two issues are important is that modeling

            of sedimentary deposits is now performed on a regular basis in

            net-pen application materials. The result of any sedimentation

            model will depend in large part on the assumption for feed

            wastage and FCR that goes into the model. It does not appear

            that much credence can be given to the assumptions set out in

            the Draft PEIS since they are not the result of independent

            work or study.

                b.    Diver StUdy.-and BaReline Benthig Survey.

                The interim guidelines do not require that a diver study

            be performed on areas deeper than 75 feet. A baseline benthic

            survey is required, but only after deployment of the net pens.

            The Draft PEIS should remedy these defects and require both a
            diver study and benthic analysis prior to application for any

            salmon net-pen.   If this is not done, local governments will

            not have sufficient information on what species exist in the





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         area of the net-pens so as to be able to fully evaluate the

         potential impact of the pens.

               C.   Eel Grass.

               Some of the richest eel grass meadows in the world are

         located in Island and Skagit Counties.        Eel grass forms the

         basis of the f ood chain f or many if not most of the important

         recreational and commercial fish species. A number of proposed

         sites for salmon net-pens occur in "holes" that are surrounded

         by shallows containing vast eel grass beds. There is, however,

         no discussion in the Draft PEIS of the effect of nutrient

         loading, dispersed fish waste, BOD, or the like on eel grass

         populations.

              Since the principal recommended mitigation measure is

         dispersal of the waste, (j= mitigation measures found on pages

         26 - 27), it is undoubted that eel grass and dispersed waste

         will come into contact even in areas where the pens are located

         in water deep enough so that no eel grass grows directly

         beneath the pens.     It is important from the Counties' stand-

         point for the PEIS to make a biological assessment of the

         impact these wastes will have on the eel grass. Nutrient

         loading of the water may promote the growth of epiphytic algae

         which in turn could have the effect of choking off eel grass.

         Given the extreme importance of eel grass in maintaining

         healthy populations of all naturally occurring marine organisms

         in our estuaries, this is an extremely important issue that




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             bears inquiry by the drafters.



             8.   EFFECTS ON MARINE MAMMALS AND BIRDS


                  a. Mammals.

                  Sea lions., harbor seals and otters, the three marine

             mammals most likely to be found in net-pen sites are protected

             by the Marine Mammal Protection Act, 16 USC 1361, et seq.

             Siting of net-pens almost anywhere in Puget 111-3ound will generate

             a conflict with these marine mammals. Mitigation measures such

             as those described on p. 88 of the draft PEIS, including siting

             net-pens more than 1500 feet away from known haul-out areas,

             would seem to be ineffective in stopping marine mammals from

             visiting net-pen sites. Recently, at least six sea lions which

             were trapped by the Department of Fisheries at the Ballard

             Locks and released more than 200 miles away on the coast of

             Washington returned to the Ballard Locks to continue their

             feeding on migrating steelhead.    It therefore does not appear

             that a 1500 foot distance presents much of a protective

             measure.  Perhaps of even more concern to the counties, who

             must consider the protection of marine mammals (as must other

             agencies), is the fact that the conflicts between net-pen oper-

             ators and marine mammals may result in increased death rates of

             the marine mammals.

                 Finally, the proximity of marine mammals to salmon net-

             pens also substantially increases the risk of escapes.         Not



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          long ago, a sea lion tore a large hole in a pen in West

          Seattle, allowing thousands of salmon to escape. Such inci-

          dents are only likely to increase if net-pens become more

          prevalent.

               b.   Birds.

               Skagit and Island Counties are located directly in the

          migration routes of an extremely large number of aquatic birds

          and birds who feed in aquatic areas. These range all the way

          from ducks to peregrine falcons and bald eagles. In fact, more

          peregrine falcons feed in or near Skagit and Padilla Bays than

          anywhere else in the state.

               Peregrine falcons and bald eagles are threatened species
     &    and therefore protected by federal statute.          There is no
          specific discussion of particular recommendations with regard

          to either of these two birds. Rather, the drafters simply

          mention some newly adopted "bald eagle protection rules," and

          say nothing with regard to peregrine falcons. (See p. 87.)

          Because these birds are both found in substantial quantities in

          Puget Sound, a better treatment of the subject is necessary.

               Skagit and Padilla Bays are also extremely important

          migratory areas for non-endangered species. Only a general

          conclusion that "net-pens should not be located near wildlife

          habitats of special significance" isstated in the draft PEIS.

          In fact, however, neither the Department of Fisheries nor the

          Department of Ecology has opposed net-pen proposals in Skagit




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            Bay despite the f act that Skagit Bay is identif ied as an area

            of "Particular concern" (in part because it is such an

            important bird habitat) in the WCZMP. We believe that the

            Draft PEIS should further define the habitats of special

            significance with respect to aquatic birds, and should conform

            to the protective guidelines of the WCZMP with respect to any

            recommendations.


                 ce    Predators

                 There is ample documentation that net pens attract wild

            fish. As Weston explains,

                 Wild fish... are attracted to the culture operations
                 for several reasons. In part, there is a behavioral
                 tendency for fish to congregate around floating
                 objects.    A floating mariculture facility also
                 increases the availability of food in the area.

            Westone "Environmental Effects of Floating Mariculture in Puget

            Sound," pp. 76-77. It has also been theorized that the

            curious nature of wild fish attracts them to the pens.

                 In addition, it is beyond debate that, net-pens attract

            predators. Moring documented the attraction of spiny dogfish,

            otters, grebes and other diving birds, gulls, and blue herons,

            to net pen sites to feed on salmon. Moring, "Aspects of Growth

            and the Effects of Some Environmental Factors on Pen-Reared

            Chinook Salmon,w p. 153-4. Marine mammals such as seals are

            also predators of salmon.

                 Beveridge has noted the attractiveness of net-pens to

            predators of salmon. He states,




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              Cages and pens of fish seem to act as a magnet to a
              wide range of both obligate and facultative fish-
              eating vertebrates. The range of species reported to
              cause problems at cage and pen farms . . . includes
              fish, reptiles, birds and mammals.        Many of these
              species move into an area where a fish farm has been
              established, attracted by the large number of readily
              detected fish and also by the bags of commercial feed
              occasionally left unprotected on the cage walkways.
              Even comparatively rare species, such as the osprey
              (Pandion haliatus) in Scotland will travel
              considerable distances in order to visit a fish farm.

         Beveridge, "Cage and Pen Fish Farming" (1984) p. 14. Osprey

         are also present in Skagit and Island Counties. The draft PEIS

         in fact acknowledges this attraction and states that the net-

         pens may operate as a beneficial source of food for bird and

         other predator populations (Draft PEIS at p. 84).

              The penned fish, of course, are generally protected from

         predators by the nets. The wild stocks, who are also attracted

         to the net-pens, are a different story. Beveridge acknowledges

         that, "Predation of wild fish may increase through the attrac-

         tion of predators to the enclosure site." Beveridge at p. 14.

         Especially where net-pens are sought to be located in migratory

         routes, nursery grounds, or other places where wild fish

         congregate, it appears that the net-pens will act as an

         "attractive nuisance" which will result in a substantially

         increased predation on the wild fish.

             No studies or estimates are cited by the drafters of the
    G    PEIS to determine whether this potential increased predation
         will be significant in terms of reducing wild fish. Moreover,





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            no mitigation measures are proposed that would alleviate the

            damage to wild populations by this increased predation.       This

            tendency for increased predation to occur is an additional

            reason suggesting that net-pens should not be! placed in or near

            the mouths of salmon-producing rivers. At letast until research

            is done to disprove the theory, congregations; of predators near

            net-pens should be viewed as a potential thretat to wild fish.

                            (d) PEIS Conclusion.

                 The conclusion of the Draft PEIS is:

                 Properly sited and operated net-pens will not have
                 significant adverse impacts on marine mammals or
                 birds. Some habitat loss may occur for some species,
                 while other species may benefit.     Specific impacts
                 will depend on the pen site and the associated wild-
                 life.

                 This conclusion may or may not be true. The discussion in

            the Draft PEIS does not consider much of the important litera-

            ture in the area. No independent research was performed, and

            no discussion of certain complicating factors, such as the

            Marine Mammal Protection Act, is presented.      It is therefore

            the position of the Counties that a good deal of additional

            work is needed on this section before it can be incorporated

            into the Final PEIS.




                  9. CHEMICALS

                 The section in the draft PEIS on Chemicals deals primarily

            with the issue of antibiotic usage in fish farms.       No inde-





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         pendent research was performed by the authors of the draft in

         this area. Nonetheless, the authors, contrary to the general

         trend of the literature, conclude there are no substantial

         environmental impacts that might result from the use of

         antibiotics in fish farms in Puget Sound. To reach this

         conclusion, the authors selectively cite from the literature,

         and ignore strong cautionary warnings that there is much more

         that needs to be known before there can be a definitive answer

         in this area.

              It is well known that drug resistant plasmids appear in

         bacteria at fish firm sites.         Lqffl_l e.g., T. Aoki, Drug

         Resistant Plasmids from fish pathogens, Microbio           logical

         Sciences. 5(7) 219-223 (1988).    Resistance occurs because non-

         resistant bacteria are killed by the antibiotict leaving only

         the resistant strains remaining. Many bacterial fish diseases,

         including furunculosis and vibriosis, have developed resistance

         to antibiotics. In addition, plasmids have appeared which are
 Al      resistant to as many as 2 to 8 antibiotics, including
         resistance to antibiotics with which the organism was not

         treated. Id.

              The presence of resistant strains of pathogenic bacteria

         in a net pen makes it more difficult to control disease in the

         pen. This may increase the danger that disease will be trans-

         mitted from pen stocks to wild stocks. Should disease transfer

         occur, the effect on the wild stocks could be severe, given the




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            fact that unlike the net pen fish, the wild fish are not caged

            in a small area where treatment can quickly be provided.

                 The transference of resistant plasmids also creates poten
        8 tial dangers to human health. One study by Hayashi
                                                          b,          _qJ al.

            cited in the Draft PEIS shows that in a laboratory experiment

            resistant plasmids transferred from V. anquillarum, a fish

            pathogen, to V. parahaemolyticus, a human pathogen.           The

            danger, of course, is that it becomes more difficult to treat

            humans when antibiotic resistant plasmids are transmitted

            together with the disease.      The draft PEIS discounts this

            danger, stating that transference is solely a laboratory

            phenomenon. This conclusion appears hasty in light of the

            literature documenting transfer of resistant plasmids under

            natural conditions. Colwell, R. R. and Grimes, D.J., Evidence

            for Genetic Modification of Microorganisms Occurring in Natural

            Aquatic Environments, Aguatic 3:oxicology and Envir,!2nmental

            Fate: Ninth Volume. ASTM STR 221, T.M. Poston and R. Purdy,

            Eds., American Society for Testing and Materials, pp. 222-230

            (1986).  A more recent article, Olmorchoe " Al., Conjugal

            Transfer of R68.45 and FPS between Pseudomanas aeruginosa

            Strains in a Freshwater Environment, ARRIied Envirgnmental

            Microbiology, 54: 1923-29 (1988) contains an actual demonstra-

            tion of the conjugal transfer of plasmids in a natural environ-

            ment, and concludes, "The studies reported here demonstrate

            that conjugal transfer of plasmids such as R68.45 and FPS can




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         and does occur under conditions found in nature." Id. at 1929.

         Testimony provided in recent Shoreline Hearings Board proceed-

         ings is to the effect that it is a question of when, not if,

         such transfers will take place.

              It is not the Counties' purpose in these comments to docu-

         ment on a point-by-point basis the dangers of antibiotic usage

         in net pens.   It is disturbing, however, that the authors of

         the Draft PEIS have seen fit to selectively quote from the

         publications they cite in order to reach the conclusion they

         apparently wished to reach from the outset: that is, that the

         use of antibiotics in Puget Sound poses no environmental risks.

         In doing so, they ignore a host of cautionary warnings that far

         more study is needed before any conclusions can be drawn in

         this area.

              For example, the Draft PEIS cites the work of Austin and

         Al-Zahrani, The Effect of Antimicrobial Compounds on the

         Gastrointestinal Microflora of Rainbow Trout, Salmo Gairdner!

         Richardson, Journal of Fish Biology 33: 1-14 (1988). This is

         an important work, because it is one of the few studies that

         actually attempts to document the effect of chemotherapeutic

         regimes on the microflora of fish. Nonetheless, nowhere in the

         Draft PEIS is the conclusion of this report:

              It may be perceived that there could be a problem
              associated with the release of antibiotic-resistant
              organisms into the aquatic environment.       If the
              resistance mechanism is plasmid-mediated, as has been
              found commonly in fish pathogens and native aquatic




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                 bacteria, then there could be a problem associated
                 with the transfer of resistance to other organisms of
                 human and/or veterinary significance. This could be
                 of prime concern in the use of antimicrobial
                 compounds in aquaculture.

            Id. at 13 (citations omitted).

                 The authors of the Draft PEIS also cite a 1983 FDA
         G  Environmental Assessment of oxytetracyline (OTC) for the
            proposition that the use of OTC does not pose adverse environ-

            mental effects.    OTC is currently the most commonly used

            antibiotic at U.S. fish pens. There is no mention of this

            passage written by Dr. Weston in 1986 on the need for      more

            research regarding OTC:

                 Assessment of the environmental consequences of OTC
                 usage in net-pens is severely hindered by a lack of
                 available information on fate and effects of the
                 antibiotic in the marine environment. In addition to
                 the literature reviewed for this study, a
                 computerized literature search on the drug has been
                 reviewed, the Washington Department of Agriculture
                 has attempted to obtain information from the Food and
                 Drug Administration and I have made inquiries with
                 the manufacturer. All efforts have met with little
                 or no success to date. Thus, all conclusions must be
                 regarded as tentative, having been based on limited
                 and in some cases conflicting data.

            Weston, D.P. The Environmental Effects of Floating Mariculture

            in Puget Sound at 97 (1986).

                 The Draft PEIS also attempts to allay concern about the

            use of antibiotics by citing studies indicating that the

            increased level of resistance associated with antibiotic use

            around fish farms is soon reduced after the use has stopped.

            One study cited (Austin 1985) may be of limited utility since




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         the samples were obtained f rom ef f luent f rom a f low-through

         system, and it is possible that there was a dilution effect

         rather than loss of resistance in the same bacterial population

         over time. See Rosenthal, H., Weston D. et al., Report of the

         ad hoc Study Group on "Environmental Im act of Mariculture".
                                                  p

         ICES, Cooperative Research Report No. 154 at 12 (1988).

         Indeed, another work by Austin suggest a less optimistic

         conclusion:

              On a note of caution, however, it has been estab-
              lished by microbiological assay that some compounds
              linger in fish tissue for much longer than may have
              been previously realized. McCracken %t Al. (1976)
              established that trimethoprim remained in rainbow
              trout muscle for 77 days after administration...
              Similar results were reported by Salta and Liestol
              (1983) ... we do not dispute the results published by
              these two groups, but it is worthwhile to emphasize
              that microbiological assays are not nearly as sensi-
              tive as the more modern physico-chemical methods,
              such as high-pressure liquid chromatography.
              Conceivably, use of such ultra-sensitive methods may
              have revealed that the drugs were retained in fish
              tissues for much longer periods.

         B. Austin and D.A. Austin, Bacterial Fish Pathogens: Disease

         in Farmed and Wild Fish (1987) at 344.

              The Draft PEIS also contends that fewer problems are

         likely to arise in the United States because federal regula-

         tions are so stringent. That statement is correct in one

         sense, but deceptive in another.   It is true that the United

         States prohibits the use of certain antibiotics that can be

         used in other countries. On the other hand, countries such as

         Japan and Norway regulate the apRlication of antibiotics to a




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                much greater degree than the United StateB., requiring that

                antibiotics be obtained from a state veterinarian, and that all

                usage be strictly monitored. These latter requirements are not

                currently in place in Washington State.
                       in fact, both of these strictures are suggested as

                possible mitigation measures in the Draft PEIS. Adoption of

                both proposals would be an important first step toward the

                proper regulation of antibiotics in Washington. The suggestion

                that further research be done regarding the effect on shellfish

                of antibiotics, and that additional research be done on the

                accumulation of antibiotics in sediments near fish farms in

                Puget Sound, is also clearly a good one.'

                      In the end,, however,, the Draft PEIS, after raising issues

                of potential concern about antibiotics, dismisses those issues

                with too little thought or consideration. This is clearly a

                subject where further study is urgently, needed.                           As the

                Rosenthal and Weston (1988) report states,

                      Antibiotic resistance has been shown to be stimulated
                      by antibiotic use in fish culture but more work on
                      the subject is urgently needed. The development of
                      antibiotic resistance is obviously of significance to
                      the culturist, but it is only one of the environ-
                      mental issues for which there are at best limited
                      data. Other issues of equal concern include persist-
                      ence of antibiotics and other mariculture chemicals,







                      5 This is particularly true given that the study by Tibbs et al. (1988) is flawed,
                since the shellfish were suspended below the pens, rather than on the bottom where sediments
                could accumulate, as would be the case under natural conditions.


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             bioaccumulation potential, and toxic effects on
              indigenous biota.

        Rosenthal and Weston (1988) at 12.      This is a topic on which

        no ultimate conclusion can be reached based on the present

        literature, and for the Draft PEIS to attempt to do so is

        unwarranted.




        10. ECONOMICS

             The report entitled "The Economics of Salmon Farming," by

        Robert Stokes is not included in the text of the draft PEIS,

        but rather is set out separately in the Technical Appendices.

        Neither the methodology nor the numerical results of this study

        appear sound, and they certainly do not justify the sweeping

        conclusions, uniformly favorable to aquaculture, that are drawn

        from the analysis. Because this report is fundamentally
        flawed, it should be dropped in its entirety from any,final

        PEIS that is issued.

             Dr. Stokes' report is based on a form of economic analysis

        in which key variables are selected at the "high end" of prob-

        ability ranges to give an overly optimistic estimate of

        economic benefits that can be derived from net pens.      Several

        examples serve to illustrate this point. The typical fish farm

        is assumed to employ 20 persons at an average wage of $25,000

        per year, or about $12/hour.     Fish farms do not employ that

        many people. A recent proposal near Gig Harbor, which would be





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            as large as permitted under current DNR guidelines, has stated

            it would only employ 5-10 workers, and gave! 8 workers as the

            most likely number of workers to be employed. A smaller farm

            proposed in Skagit County south of Hope Island was estimated to

            create at most five new jobs. Norwegian fish farms employ on

            the average 6 to 8 persons. For similar reasons, the estimate

            of 40-51 additional jobs per farm within counties is equally

            unrealistic.     Dr. Stokes' salary figures are similarly

            unrealistic, since most of the work only requires unskilled or

            semi-skilled personnel. Rates of $5-$7/hr. are far'more likely

            for all but one or two supervisory personnel.

                 Stokes also assumes that the entire product of the fish

            farm will be sold out-of-state for $5.00 per pound.        First,

            this assumption, which was made to result in the most favorable

            economic contribution of aquaculture, appears to conflict with

            the assumption that development of a local net pen industry

            will displace the need in Washington for imports of farmed

            salmon from other countries. Second, $5.00/pound is not the

            average current price of farmed Atlantic salmon. Four dollars

            per pound is much closer to current market price, and James

            Anderson of the Department of Resource Economics at the

            University of Rhode Island (among others who have done work in

            this area) predicts that as supplies of farmed salmon increase,

            there will actually be a drop in real prices over the next few






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          years. In fact, it is currently possible to buy farmed coho

          salmon in the Seattle area for $2.99/pound.

               Dr. Stokes' discussion of the effect of net pens on prop-

          erty values is also lacking in merit. The purported measure of

          loss in economic value resulting from adverse environmental

          effects is the product of a series of unsupported assumptions:

          that deviations from mean real estate value contain a

          measurable component reflecting aesthetic characteristics; that

          these effects are equally distributed within an arbitrarily

          selected distance from pen sites; and that the equally

          arbitrary selection of a proportion of deviations from mean

          values is a meaningful estimate of losses in aesthetic values.

               Finally, the Benefit-Cost Analysis is also without merit.

          Even if all of Dr. Stokes' faulty assumptions are accepted, it

          is not possible to compare the benefits lost from aquaculture

          with the benefits gained, since this is a classic case of

          comparing apples and oranges. It is also highly significant to

          note that nowhere does the report discuss the economic implica-

          tions or potential costs of aquaculture due to fish disease,

          pollution, or displacement of existing industries such as

          commercial or recreational fishing. Nor is any attention paid

          to the increased costs to government of aquaculture, in the

          form of regulatory outlays, research and promotion that are

          currently borne by the State and local governments.






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                  In sum, both Dr. Stokes' methodology and his numerical

            results appear invalid, and certainly cannot be used to justify

            the sweeping conclusions (which are uniformly favorable to

            aquaculture) that are drawn from the analysis.          Statistical

            jargon and computer graphs cannot gloss over the dubious

            validity of Dr. Stokes, procedures. The report should there-

            fore be removed from any final PEIS that is issued.



            11. NEED TO MAINTAIN COUNTY AUTONOMY

                 The current Recommended Interim Guidelines for the Manage-

            ment of Salmon Net-Pen Culture in Puget Sound state that they

            were developed entirely with the goal of environmental

            protection, and "do not address social, economic, aesthetic or

            water/land use conflicts which must be given consideration on a

            case-by-case basis." It is unclear from the Draft PEIS whether

            this policy will be continued. It is the strong belief of the

            Counties that it should.

                 Several provisions in the Draft PEIS lead to this concern.

            For example, on page 2, the Draft PEIS states that it will be
            used by decision makers at the local level to make permitting

            decisions. The aesthetic analyses proposed on page 102 of the

            report raise at least the possibility that they could be used

            to usurp or lim-It the authority of local governmental agencies

            to make siting determinations.






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               The guidelines established in the PEIS may be appropriate

          in the case of some environmental decisions regarding the

          project, although even in those situations many factors (such

          as flushing and impact on the site's existing biology) require

          a site-by-site analysis.     It may also be appropriate for the

          State to establish some minimum threshold which must be met in

          the case of aesthetic and site conflict issues.      The ultimate

          determination on these issues, though, must be left to the

          local governments through implementation of SEPA and their

          Shoreline Master Programs, after a site-specific review of the

          testimony regarding the individual characteristics of the site.

               At the public hearing on the Draft PEIS, Mr. Westley, the

          project manager for the PEIS for the Department of Fisheries,

          stated that it was not the intention of the authors of-the

          report to alter the need for a site-by-site analysis of each

          proposed site. Mr. Westley also indicated his belief that most

          projects that are proposed will require a separate Environ-

          mental Impact Statement. The Counties are encouraged by these

          remarks, and strongly encourage their incorporation in the

          final PEIS, particularly with regard to aesthetics and use

          conflict issues.




          12. THE NEED FOR ENFORCEMENT

              A number of the mitigation measures proposed in the Draft

          PEIS involve the imposition of conditions on the manner in




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                 which aquaculture projects will be run.                            ]For example, with

                 regard to the control of odor, net pen operators are directed

                 to follow "best management practices" and maintain "the general

                 cleanliness of the facility."                      in addition, nets are to be

                 cleaned regularly, feed stored in closed containers, and/or

                 only dry feed used. Limitations on the manner in which pens

                 are to be run are also included in the sections on aesthetics

                 and noise.6 The ultimate premise in many sections of the Draft

                        that there will be no significant environmental impacts is

                 based at least in part on fulfillment of these mitigation


                 measures.

                        The problem, however, is that there is no system in place

                 to ensure that the conditions set out in these measures are in

                 fact met.         Counties generally do not have the resources to

                 provide detailed enforcement of site conditions, and there is

                 no mechanism currently for the Counties to pass these costs on

                 directly to the net pen operators. Moreover, to date the State

                 has apparently not been willing to come forward and fill this

                 ,gap in enforcement. The bottom line is that it is unrealistic

                 to premise a finding of no significant impact on the fulfill-






                       6 other conditions on the manner in which the Pon should be run are set out in Section
                 II.A.1, Impacts of projects to Bottom Sediments and Senthos (I&IL US* S'OW-**ttling' highly
                 digestible feed, use feeding methods that maximize ingestion and food conversion)l Section
                 II.A.2.(a),  Water Quality Standards (monitoring during net cleaning); Section 11.Ao2(b),
                 Phytoplankton (reduce feed wastage through careful fish cultural practices); and Section
                 II.A.4, Marine Mammals and Birds (follow established procedures for-controlling predators).


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          ment of conditions which most likely will not be ef f ectively

          monitored.




          13. CONTRADICTORY MITIGATION MEASURES

               A number of mitigation measures that are recommended are

          internally inconsistent. Although the Draft PEIS occasionally

          notes the inconsistency, it does nothing to ultimately resolve

          these conflicts and determine whether there in fact might be an

          impact on the environment resulting from the siting of a net

          pen.

               Several examples jump out of the report. Net pens should

          be non-reflective and somber-hued for aesthetic purposes; for

          navigation, they should be highly visible. For commercial

          fishing and navigation purposes, pens should be sited close to

          shore; in areas of low level shorelines, pens should be sited

          away from the shore.    If pens are cited close to shore in an

          attempt to mitigate impacts on fisheries and residents on high

          shorelines bluffs, there is still the problem of mitigating

          odor impacts that may emanate from the project.

              The question raised but never addressed in the Draft PEIS

          is whether these conflicting requirements can be resolved so

          that a pen can ultimately be sited without causing problems in

          one area or the other. Resolution of this problem in the final

          PEIS is a necessity.






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            14. AESTHETICS

                 Perhaps the first problem of the Draft PEIS in this area

            is that it attempts to divide three components of aesthetic

            impact--visual impact, noise and odor--into different sections

            without any discussion of their connection. A discussion of

            one of these factors without the others is generally meaning-

            less, since it is most often their combination which causes the

            intense opposition of residents living near proposed net pen

            sites.   Instead of being broken up into separate sections,

            these issues should all be addressed under one section so that

            the full aesthetic impact of a project can be considered as

            whole.

                 There is no question, as the Draft PEIS states, that

            visual impacts are "subjective and difficult to quantify."

            Having said that, the Draft PEIS then attempts to quantify such

            impacts using computer modeling studies by ZDAW and CH2M Hill

            which do not accurately reflect real-life conditions. These

            studies are premised on the assumption that the viewer is

            located in a fixed spot and has a 60* cone of vision. A real

            person does not spend his life fi  xed to the same spot without

            turning or moving his head.    In addition, the studies do not

            consider the existence of structures or people at the site.

            There is ample testimony in prior Shoreline Hearings Board

            proceedings that even though a project may be 2,000 feet away






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         f rom a residence it does not appear as a "thin line on the

         hori z on. "

               At other times, the Draft PEIS falls into the trap of

         meaningless doublespeak, as in the case of the following

         paragraph:

               The overall cumulative impact resulting from five
               net-pen farms in an embayment, for example, would
               vary considerably depending on whether there were
               other man-made structures in the area and on observer
               attitudes. Placement of several net pens in an
               embayment that had f ew other man-made structures
               might be perceived by some as altering a natural
               environment to an urbanized environment. Other
               observers may not perceive any significant aesthetic
               change due to an increase in the number of net pens
               either because they do not perceive net pens as a
               visual intrusion. Or they may perceive any net pen
               to be a visual intrusion.

         (Draft PEIS, p. 95).     If the authors of the Draft PEIS have

         ever attended any public hearing on a proposed net pen, they

         would know that the attitude of nearby residents on the siting

         of even 2M pen is almost universally hostile and antagonistic.

         To say that the above paragraph does not adequately reflect the

         likely reaction of nearby residents if fj,.v
                                                      & such projects were

         proposed is a major understatement.

               The Counties do agree with the ultimate conclusion that

         there generally will be adverse visual impacts resulting from

         siting net pens in Puget Sound. Although aesthetic analyses,

         design and location guidelines may partially assist planners in

         evaluating the impact of a project, the ultimate determination

         in this area must be made by the local governmental authority



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                  taking into account its Shoreline Master Program and the testi-

                  mony of its constituents at public forums.



                  15. NOISE

                         The issue of noise is a significant one because residents

                  .in areas where net pens are proposed often live there because

                  of the quiet and pristine nature of the environment.                                       New

                  sources of noise (as well as of visual impacts and odor) are

                  thus far more significant than in more urbanized areas.

                         The Draft EIS discussion of noise impacts does touch on a

                  number of the objections commonly raised by nearby residents at

                  public hearings, although perhaps not in sufficient detail.

                  Because of the fact that the pens are sited over water, noise

                  tends to carry much farther, and to be f ar                          more noticeable,

                  than over land.            The impact of increased truck and vehicle

                  traffic receives only one sentence in the report, but is a very

                  real issue to residents of areas where there generally is

                  little traffic.' Noise may be increased in situations where

                  there is a steep entrance or egress from projects, or where

                  road quality is poor, as is often the" case in rural







                        7 Increased traf f ic resulting from not pens can also present safety problems for resi-
                  dents of rural comunities where there is currently little or no traffic. This is particu-
                  larly the came in areas where children will be present.       There is also the question of
                  revenues for improved streets and traffic control, all of which are "costs, borne by the
                  counties and their residents.



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         communities. Any program of the operator for visitors to the

         pens may result in additional impacts. There is no mention of

         radios or other artificial sources of noise resulting from

         workers at the project, but both testimony at public hearings

         and common sense indicates that this too is a potential source

         of problems.

              The suggestion that net pens should not be sited in small,

         populated, sheltered bays where low background back noise

         levels would increase the impact of noise is a good one, and

         might serve as a minimum threshold under which projects can be

         evaluated.    However, because many of the other mitigation

         measures proposed depend on monitoring of activities at the

         project which may not in fact take place (see discussion above

         on Enforcement), the impacts of the project may be greater than

         the drafters of the report realize.

              The Counties disagree with the report's conclusion that

         any increase in local noise levels "is not expected to have

         significant impact on shoreline residents or other users of the

         adjacent water and shoreline," since this conclusion does not

         follow from the discussion of potential impacts from projects.

         Rather, a number of potential net pen sites pose the spectre of

         unacceptable increases in noise. Each site must be considered

         on its own merits, and approved only after careful considera-

         tion by the local government of the noise impacts the project

         realistically will create.




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            16. ODOR

                  Testimony at public hearings confirms that net pens do

            emit bad odors. For example, at a recent Shorelines Hearings

            Board case on the Skagit System Cooperative Project, a number

            of nearby residents testified about the unpleasant smell

            emanating from the American Aqua Foods project. There was also

            a good deal of testimony about odors coming both from the Amer-

            ican Aqua Foods and Cypress Island projects at the Mt. Vernon

            hearing on the Draft PEIS. This issue is thus a very important

            one, and is one of the primary reasons that. nearby residents

            tend to generally oppose net pens.

                 The mitigation measures proposed in the report may in fact
        Greduce impacts in this area, although there are no studies that
            confirm whether or not this will be the case. Moreover, as

            previously noted, many of the measures proposed depend on

            adequate enforcement, and there is no guarantee that project

            operators will in fact meet these standards. The siting

            suggestions are even more problematic. Increasing the distance

            of pens from the shore may increase visual impacts, or conflict
       S    with navigation or fisheries activities. Siting the project
            downwind from one residence may simply transfer the impact to

            another residence. Finally, locating the pens in areas where

            there are already odors hardly appears to be a workable solu-

            tion, since the appropriate government response in that case is



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         to reduce the source of the existing odor rather than add an

         additional source.

                Odor is a problem that must be dealt with on a case-by-

         case basis. It may be, as in the case of noise and visual

         impacts, that otherwise adequate sites for net pens will be

         disqualified by local governments because of the overall

         aesthetic effects of the project. This point should be

         directly acknowledged in the Draft PEIS so it is understood

         that in the end the ultimate decision-maker in this area is the

         local government entity.



         17. COMMERCIAL FISHING

              This issue is an extremely important one, since a

         significant portion of the economy in both Skagit and Island

         Counties is dependent on the commercial fishing industry.       It

         should be noted that many of the issues previously discussed,

         such as disease and the effect of projects on the surrounding

         biology, have a direct impact on commercial fishermen.      It is

         the position of the Counties that foremost consideration must

         be given to preservation of wild and hatchery runs of salmon,

         and that if there is any question these might be jeopardized in

         any way by the siting of a net pen, the site should not be

         permitted.

              Although the discussion on potential impacts on commercial

         fishing is good in some respects, there is no discussion of the




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            effect that the anchors of a project will have in deterring

            fishing in a particular area. In the case of the recent Skagit

            System Cooperative application to site a pen just south of Hope

            Island in Skagit County, testimony was provided that the net

            pens would close the entire area between Hope Island and Seal

            Rock to gillnetters. This is because gillnetters would have to

            start pulling their nets out of the water about two miles away

            from the site in order to avoid the risk of snagging their nets

            on the project's anchors. In a similar vein, the total impact

            of 100 net pens on commercial fisheries appears to be under-

            stated, since the anchoring system of some pens (such as the

            site now proposed in Colvos Pass north of Gig Harbor) can

            extend over 30 acres, and because the need for fishermen to

            pull out their gear well before reaching these sites has not

            been factored in.

                Another problem is that pens are often sited in areas
      @,where fishing is most productive. As Greg Peterson, the Execu-

            tive Director of the Puget Sound Gillnetters recently noted,

            the pens are usually in tidal activity areas which are good

            gill-netting areas.   The report also does not specifically

            acknowledge the fact that opportunities to harvest fish are

            often extremely limited in time. If net pens are sited so as

            to preclude fishing in areas where it is most efficient to

            harvest fish, fishermen will fail to catch the share allotted

            to them by the State. Table 5, which was supposed to show the




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         number of salmon caught in 1986 by various gear types for the
         various management areas, is missing from the report.

              Locating pens near shore, as suggested in the mitigation

         measures, may not necessarily reduce the impact of a project,
      0  and in many cases may make it worse. Near shore siting may
         interfere with favored gillnet fishing areas, as it does in the

         case of the proposed Colvos Pass project.     It may also inter-

         fere with the route of migratory adult and fry salmon, and with

         the habitat of other sensitive species such as herring or eel

         grass.   In addition, it may affect recreational fishing for

         cutthroat trout, and, as noted previously in the report, can

         create visual impact, noise and odor problems for nearby resi-

         dents.

              The Counties do agree that pens should not be sited in
    G    areas of "intensive" fishing. If the State wishes to designate
         certain areas where net pens would not be acceptable because of

         their impact on commercial fishing, that would be appropriate.

         Any such designation, however, should not preclude the Counties

         from considering this issue independently and determining that

         a proposed project should not be approved because of its impact

         on commercial fishermen.




         18. RECREATION

             Although short, the discussion of potential impacts on

         this subject is a reasonably good one. There is, however, no




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          0  specific mention of kayaking, wind surfing and canoeing, all of
             which are popular recreational activities. :Recreational crab-

             bing is not discussed. The report seems to assume that

             mooching can be substituted for trolling without any effect on

             the sportsman.    This overlooks the fact that some sites are

             simply traditionally fished by trolling,.and that mooching is

             not an acceptable substitute. It should also be noted that on

             page 119, it is stated that net-pen anchors are placed at a

             distance away from the pens equal to about three times the

             water depth at the pen's perimeter, while on page 7 it is

             stated that the correct figure is four times the water depth.

                  There is no discussion in the report of the mandate in the

             Shorelines Management Act that for Shorelines of Statewide

             Significance, proposed projects should "'              recreational

             opportunities for the public in the shoreline."

             RCW 90.58.020(6) (emphasis supplied). Shorelines of statewide

             significance include all waters in Puget Sound and the Strait

             of Juan de Fuca, as well as Skagit and Padilla Bays. The Act

             provides that the "natural character of the shoreline [of

             statewide significance] should be preserved," and implementing

             regulations provide that "areas which contain a unique or

             fragile natural resource" should be left undeveloped. WAC 173-

             16-040(5)(d)(i).    It is well established that developments

             proposed on shorelines of statewide significance must be

             reviewed for consistency not only with the local Master Program




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         but also with the policy of the Shoreline Management Act.

         Washington Environmental Council v. Dept. of Transportation,

         SHB No. 86-34.

              The mitigation measures appear to suggest the use of

         -delayed release" programs to offset any negative impacts of a

         proposed project on recreational interests. It should first be

         noted that this would only mitigate the impact on one category

         of recreational users, fishermen, and would do nothing for the

         others. More importantly, there are a number of significant

         questions about delayed release programs. First, they may not

         fit in with existing programs of the Department of Fisheries or

         Wildlife. Second, there are concerns about the possible trans-

         mission of disease f rom net pen f ish to the f ish that will be

         released. This could in turn provide a means for transmission

         of disease to wild fish. Genetic pollution is an another

         serious problem. There are currently no regulations that

         require genetic matching of released f ish with those of the

         nearest river system.

             The report concludes, "With proper net-pen site selection,

         there will be no significant adverse impacts to recreational

         activities." This statement in and of itself is meaningless,

         for the task of local government is to figure out which sites

         are "proper". As in the case of the discussion on commercial

         fishing, the Counties have no objection to the designation of

         certain areas by the State as per ae inappropriate for net pens




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            because of their impact on recreational uses.      This may be

            particularly appropriate in the case of areZLs near Washington

            State Park beaches. As in the case of commercial fishing,

            however, any such designation should not limit the ability of

            Counties to determine that a particular site is inappropriate

            for net pens because of its impact on recreational users.



            19. NAVIGATION

                 For shorelines of statewide significance, it is required

            that proposed projects "increase public access to publicly

            owned areas of the shoreline." Although net pens decrease,

            rather than increase, public access, there is no discussion of

            this directive in the report's section on navigation.

                As noted above, many of the specific mitigation measures

            proposed for navigation conflict with mitigation measures in

            other sections. Navigation lights and bright colors will cause

            visual impacts to nearby residents. Siting pens close to shore

            may cause visual, noise and odor impacts to residents, and may

            interfere with commercial and cutthroat trout fishing, as well

            as with the migratory routes of salmon and other sensitive

            species.  Consolidating farms into areas of limited naviga-

            tional use may also unduly increase impacts on nearby residents

            or fishermen.

                As the -draft report concludes, there u ndoubtedly will be

            adverse impacts on navigation caused by net pens. As in the




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          case of other use conflicts, it may be appropriate for the

          State to determine that certain areas are not suitable for net

          pens; in all other cases, the final decision should rest with

          local government.



          20. HUMAN HEALTH

               The issue of whether there are potential human health

          impacts resulting from the siting of salmon net pens is

          obviously a question that is of great importance to the

          Counties.   From the discussion in the Draft PEIS, it appears

          that a great deal more needs to be    done before a final answer

          can be provided. As the report        acknowledges, the typical

          levels of significance of bacteria    in fish feed is not known.

          What is known is that Salmonella      cubana, as well as other

          bacteria that are unidentified,      have been isolated in one

          sample of moist fish feed. The Counties believe that further

          research to determine bacteriological characteristics of fish

          feed is not only "desirable", but mandatory. In addition, the

          transferability of resistant plasmids also presents dangers to

          human health that have not been resolved to date (see discus-

          sion in Chemicals section).

              Given the present state of knowledge, to conclude that NNo

          significant impacts were identified", is presumptuous. This is

          an issue where further work is urgently needed, and until it is

          performed, no final conclusions should be drawn at this time.




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                  21. UPLAND AND SHORELINE USE

                         The initial sentence of this section states that, "The

                  issue in this section involves the displacement of existing and

                  potential uses of shoreline and upland uses near an aquaculture

                  facility." In spite of this statement, the bulk of the section

                  on impacts is devoted to the unlikely asseetion that net pens
                  will be beneficial because they will highlight water quality

                  concerns in areas where they are sited.                       It is hard to under-

                  stand how a facility which itself contributes between 1600 and

                  1800 pounds of sediment consisting of fish feces and uneaten

                  food for every metric ton of fish grown is supposed to bring

                  about an improvement in water quality. It is far more likely

                  that net pens will increase public understanding of water

                  quality needs due to opposition to their siting than through

                  their presence and operation.

                        Perhaps more importantly, this section correctly identi-

                  fies that growth in the region will create need for additional

                  recreational opportunities, as well as increase pressures on

                  commercial users such as fishing and towboat industries. The

                  section also might have noted that growth will increase the

                  numberlof nearby residents who will be affected by proposed net
                  pen projects.8 After raising this point, however, the section




                        8 For example, from 1980-07, Island County was the fastest growing county in the State
                  on a percentage basis, and its population is projected to increase by 35% in the next ton


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          does not discuss it any further, and, contrary to the report's

          assertion, there is D_Q discussion of the ef f ect of growth in

          the individual use conflicts sections (let alone the visual

          impact, noise and odor sections).

                Finally, Figure 25 in this section is totally out of date

          and therefore meaningless, since it is based on 1971 data. For

          example, the land use in Island County is listed as primarily

          forest, when in fact most of the county is zoned residential or

          rural residential.

               This section really serves no point. Although the identi-

          fication of the effect of growth on existing issues is an

          extremely important issue, it should be addressed in the

          individual sections relating to aesthetics and use conflicts.

          The contention that net pens will somehow serve to highlight

          water quality concerns is of extremely dubious validity, and

          should be dropped from the report.



          22. LOCAL SERVICES

               This section is flawed because, in reaching the conclusion

          that there will be no significant impacts on the provision of

          local services, it f ails to consider the variety of increased






          (Continued)




          years.



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            responsibilities imposed by net pens on local governments.

            Local government will be required to provide fire, rescue,

            medical aid, garbage disposal, police protection and emergency

            services to net pen structures and to the persons working at

            the facilities.    They will be asked to provide landfill space

            for both unsalvageable pens and floats and for incidental fish

            kills.   Finallyo as discussed above, many of the mitigation

            measures that have been proposed require monitoring of the

            conditions, or manner of operation, at the net pen site.

                 To take just one of these examples, the report neglects to

            discuss the possible need for increased landfill space due to

            burial of net pen fish that have died. In British Columbia,

            this has been a very significant problem.       Geoff Powers, the

            planning manager for the Sunshine Coast Regional District

            (where a number of aquaculture projects are located) has

            expressed concern that dead fish will eventually fill up the

            dump, and stated that currently a third of the district's land-

            f ill space is now going to dead farm salmon. Also in that

            location, local government is burdened with the disposal of

            approximately one million empty plastic feed racks annually.

            More generally,- the potential impacts on human health, wildlife

            and water quality realting to the disposal of diseased fish

            should be discussed in the report.

                This section should completely be re-done to include a

            more complete discussion of the actual impact of net pens on




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         local governments.

         23. CUMULATIVE IMPACTS

               The cumulative impact analysis performed in the Draft PEIS
         is extremely weak. Cumulative impacts are in f act considered

         f or only two issue areas: BOD loading and nitrogen loading.

         With regard to BOD loading, the report actually concludes that

         25 and 50 net-pen capacities are similar to a large wastewater

         treatment plant (as if this presents no additional problems)

         while 100 net pens are Nconsiderably larger" than any single

         such plant. Nonetheless, the report concludes that any impacts

         would be "very weak" and "largely negligible", apparently

         because of the statement that, "The net pens represent a more

         diffuse source of BOD loading than a treatment plant." This

         does not constitute a reasoned or thorough consideration of the

         problems that are raised by this issue, and more analysis needs

         to be done before any conclusions can be drawn.

             . Other than these two issues, the section is silent with

         regard to the multitude of other cumulative impact problems

         that 25, 50 or 100 net pens would create. Attempts to deal

         with this subject in other sections of the Draft PEIS are

         either inadequate or non-existent. For example, with regard to

         commercial fishing, the report states that the area occupied by

         100 pens would only take up a small portion of Puget Sound

         Basin. As discussed above, however, there are a number of

         problems with the figures used by the report. In addition, it




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             is apparent in the case of commercial fishing (or of recreation

             and navigation) that the location of one project will shift the

             use to another area. If this is repeated several times, it is

             easy to see that the pens may totally preclude a particular use

             in a given area. Nonetheless, there appears to be no recogni-

             tion of the danger that this might occur in the Draft PEIS.

             Multiple projects also present obvious probl(ms in the areas of

             aesthetics and visual impacts. Moreover, because there is not

             an adequate discussion of the effects of growth in Puget Sound,

             potential impacts are further understated.

                 The cumulative impact analysis is not satisfactory.        It

             only considers in any detail at all two of the many issues

             relating to net pen siting. Even as to one of those issues,

             the discussion is inadequate. In other areas, there is limited

             or no recognition of the effects that multiple projects would

             have on alternative uses of Puget Sound, or on nearby resi-

             dents.  The cumulative impact analysis should be re-worked

             entirely to consider all of these issues.



             24. LAND-BASED TANK FARMS

                 Because no application for land-based tank farms have been

             made in either Skagit or Island County, the'Counties are less

             familiar with the potential impacts that such projects might

             entail. Although they may include some features that are

             preferable to net pens (particularly with regard to disease and



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          prevention of escapement), it appears that many of the concerns

          expressed above apply equally to land-based tanks.          Several

          other areas appear to present problems that are unique.

               Obviously there is a significant concern about the

          concentrated discharge from tank farms. Extreme care must be

          taken to ensure that the discharge will be into areas of rapid

          dispersion, or the result will be either the creation of new

          pollution problems or the exacerbation of old ones.

               The report does not appear to adequately consider what

          might be envisioned as one of the principal objections to tank

          farms, the impact on nearby residents. There is no question

          that the tanks, and the increased noise, traffic, odor and

          visual impact they entail will result in a substantial impact

          on nearby residents.

               The Counties commend the authors for inclusion of this

          subject in the Draft PEIS, and recognize the potential benefits

          of the technology. It appears however, that more information

          will be required before the feasibility of these projects can

          be adequately assessed.



          25. THE NEED FOR ANOTHER DRAFT

               Because of the number of comments that will be received by

          the Department of Fisheries, and the need for extensive revi-

          sions to the original draft, the Counties respectfully suggest

          that a supplemental draft be released before any final PEIS is




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           adopted. This is particularly appropriate given the current

           need f or additional information about the source of VHS in

           Washington State, and the research that it; currently being

           performed by the State on the issue.

                Skagit and Island Counties appreciate the opportunity

           provided by the Department to comment on the Draft PEIS.    if

           there is any additional information we can provide, please do

           not hesitate to contact us.
                DATED this  6   day of April, 1989.



                                Willi   C. Smart
                                Leonard B. Barson
                                KELLER ROHRBACK
                                Attorneys for Skagit and Island Counties








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           RESPONSE TO LETTER NO. 1: SKAGIT AND ISLAND COUNTIES



           1.      See the response to Question 2.

           2.      One of the roles of the EIS is to present available data and point out where the
                   data are sufficient and where they are insufficient. Independent research is not
                   necessary for every issue involving the fish farming industry. The Preferred
                   Alternative in the FEIS recommends additional research in Sections 5.4 and 6.4.

           3.      The individual local shoreline programs in conjunction with State policies and
                   regulations constitute the Washington Coastal Zone Management Program
                   (WCZMP). The WCZMP states that "Aquaculture is a preferred use in suitable
                   water areas but should be conducted with due consideration for navigation rights
                   and visual quality."

           4.      The DEIS discusses the possible use of locational controls to mitigate potential
                   impacts of fish farms in several places in the text. However, the specific nature
                   of those controls is a management issue and should be part of a management plan
                   on the fish farming industry.

           5.      General conclusions about the suitability of locating fish farms in specific types of
                   areas of the Sound are not warranted. Locational decisions should be made
                   based on more detailed analysis than is possible in a programmatic EIS. "Proper
                   siting" procedures include the development of broad management guidelines for
                   fish farms, together with detailed environmental analysis of specific fish farm
                   proposals. These local legislative and environmental procedures will assure that
                   fish farms are properly sited.

           6.      Comments noted. The EIS has been revised to evaluate the fish farming industry
                   under existing regulations and guidelines.

           7.      The Public Trust Doctrine does not preclude multiple uses of the waters of Puget
                   Sound. Fish farms are not a permanent dedication of the resource, and siting
                   decisions are based on a full consideration of all competing demands on the
                   resource. See the response to Question 11 and Section 8.3 of the FEIS for a
                   further discussion of the Public Trust Doctrine.

           8.      As the following lists demonstrate, the differences between the situation in Norway
                   and Washington are substantial:

                   Nonmay

                   0  786 farms
                   0  Very small wild populations
                   0  Farms in fjords (river mouths)
                   0  Production (1989): 125,000 metric tons
                   0  Production: 100% Atlantic salmon
                   0  Wild population: 100% Atlantic salmon








                Response to Utter No. 1: Skagit and Island Counties (continued)

                           Fish farm stock: genetically altered.

                       Washington


                           30-50 farms
                           1/2 of all product in Puget Sound is from wild fish
                           Farms generally placed away from river mouths
                           Production potential: 10,000 to 17,000 metric tons
                           Production: 11% native species
                           Wild population: 100% native species
                           Fish farm stock: not highly altered genetically

                       It is apparent that the potential for environmental im1pact to wild stocks due to
                       genetic disturbance is much lower in Washington than. it is in Norway by virtue
                       of scale. In addition, Svein Mehli's testimony did not demonstrate a cause-and-
                       effect relationship between the Norwegian salmon farming industry and any genetic
                       changes to their wild salmon populations.

                       The low genetic variability in some river systems in Norway is better explained by
                       genetic drift due to very small population numbers.            Genetic drift causes
                       inbreeding effects even in natural populations. The low numbers of wild fish in
                       Norwegian rivers is a result of overfishing, acid rain, and hydroelectric
                       development.

               9.      The reviewer implies that the loss of genetic variability is the same as the injection
                       of maladaptive genes. However, they are not the sarne. Of the seven articles
                       cited, only one supports the comment. That article, Reisenbickler and McIntyre
                       (1977), uses wild and hatchery steelhead trout stocks to show that hatchery fish
                       performed worse in the wild than wild fish in two out of four cases. In the other
                       two cases, they performed similarly.

                       In the one case where a large difference in performance was seen between wild
                       and hatchery stocks, the cross between the two had twice the performance of that
                       of pure wild stock. Scientific documentation of the genetic mixing of wild and
                       hatchery stocks does not demonstrate a significant impact. The potential for
                       genetic impacts is very low. See the response to Question 24.

               10.     Skagit and Island Counties suggest that because 40% of' the Atlantic salmon found
                       in Norwegian rivers were farmed fish, we can expect the same percentage of
                       farmed Pacific salmon in Washington. New text added to Section 5.7 of the FEIS
                       estimates that the maximum expected ratio of wild fish to farm fish in Washington
                       rivers to be between 0.1 and 0.5%. According to Dr. Robin Waples (a geneticist
                       with the National Marine Fisheries Service), a 2% interbreeding rate would not
                       be expected to cause a perceptible impact on a wild population. However, he
                       noted that a 10 or 20% rate might be significant.








           Response to Utter No. 1: Skagit and Island Counties (continued)

                  Regarding the establishment of the Atlantic salmon sperm bank, that concept was
                  developed in response to wild stock extinctions caused by acid rain not by the
                  presence of salmon farms (see Gjedrem 1981).

                  The reviewer states that hatchery fish are lowering the reproductive ability of
                  wild populations. Actually, salmon numbers are increasing in Puget Sound. In
                  addition, there are several factors which affect wild salmon production such as
                  urban development, pollution, forest practices, overfishing, and hydroelectric
                  development. The example of the upper Baker River, does not support the
                  argument made by the reviewer. YVFDF does not have a sockeye hatchery in
                  western Washington. Therefore, hatchery fish could not be affecting the sockeye
                  run in the upper Baker River.

           11.    WDF has the responsibility and the expertise to make the decisions necessary to
                  protect salmon resources of Washington. WDIF uses the SEPA review process to
                  provide the necessary technical assistance to local governments during the siting
                  of fish farms. In addition, WDIF uses the HPA permit to ensure that existing
                  salmon populations and habitats are not adversely affected by any proposed
                  development.

           12.    See the response to Comment 11.

           13.    There is no evidence anywhere to suggest that wild salmon are attracted to farms.
                  However, there is plentiful evidence that new escaped juveniles and previously
                  escaped returning spawners are attracted to farms. Studies were conducted to
                  look at this phenomenon by WDF at the Squaxin Island site and by NMFS at
                  their Manchester facility.

           14.    The LENKA project in Norway is a coastal zone management program. Different
                  countries with fish farming industries have different programs for managing the
                  industry. A discussion of management programs is outside the scope of the EIS
                  and would be more appropriate in a management plan document. However, a
                  description of the LENKA project has been included in Appendix H to provide
                  additional information.

           15.    Because a species of Gyrodactylus caused fish loss in Norwegian rivers and was
                  likely introduced from another country and spread by the Ministry of Nature
                  Management in Norway with their hatchery release program has no bearing on
                  the siting of farms in brackish water. There are native monogenetic trematodes
                  (including Gyrodactylus species) in Washington State that occur naturally on
                  hatchery and feral anadromous stocks in freshwater. T'he State does not allow the
                  importation of live fish from Europe. These parasites are not transmitted by eggs.

           16.    See the response to Questions 25 and 26. Diseases are not transmitted; pathogens
                  are. The pathogens found in fish in farms are also in feral and hatchery stocks.
                  The phenomenon of disease is a result of the number of pathogens, host
                  susceptibility, and environmental conditions or stress. It is highly unlikely that








                Response to Letter No. 1: Skagit and Island Counties (continued)
                       migrating fish would be exposed to pathogens to which they had not previously
                       been exposed to. It is even more unlikely that diseases would result if an
                       infection occurred.


                17.    Comment noted.

                18.    There is no evidence that VHS was introduced by eggs from Europe.
                       Additionally, there is no documentation of VHS being found in the geographic
                       areas where Washington State imports eggs. Mr. Jerry Grover (USFWS) is not
                       a Fish Health Specialist and has publicly acknowledged that his statement was
                       in error. Dr. Ken Wolf, while being a recognized fish virologist, is not the
                       foremost expert in VHS. His remarks about VHS occurring in Atlantic salmon
                       is conjecture since VHS has never been found in hatchery or feral stocks of
                       Atlantics. For further information, see Appendix G on VHS.

                19.    VHS has, in fact, been found in brown trout, not Atlantics. Furthermore, the
                       WDW, not VVDF, has a hatchery program with brown trout. Brown trout, though
                       cultured for over a century in the U.S. and widespread throughout North America,
                       were introduced from Europe. VHS was not found in Washington State in
                       Atlantics or brown trout, but in chinook and coho.

                20.    See the response to Comment 19.

                21.    The opinion by Skagit and Island Counties is not substantiated by available
                       technical knowledge. Many of the mitigative measures noted in pp 10-11 of the
                       DEIS are addressed in WAC 220-77 and supporting policies.

                22.    Extra-legal importation of fish eggs or any fish product is outside the scope of this
                       EIS. V*TDF employees consult on a regular basis with USFWS inspectors at ports
                       of entry and verify imporfs with federal monitoring.

                23.    Regulatory authority and the disease control program exists and is administered
                       by the State (RCW 75.58, WAC 220-77 and supporting policies).

                24.    Item 6 is required by statute. Items 2, 4, and 5 are ongoing activities, though not
                       required by law.

                25.    Comment noted.

                26.    The effect of fish farms on biochemical oxygen demand is discussed in Section 5.2
                       of the FEIS. Field studies by various researchers have found that decreases in
                       dissolved oxygen near farms ranged from 0 to 1.5 mg/L. State water quality
                       standards for dissolved oxygen are based in large part on the oxygen requirements
                       of salmon. The effect on the benthic community is discussed in Section 5.1 of the
                       FEIS and in Appendix A.









           Response to Utter No. 1: Skagit and Island Counties (continued)

           27.     Areas known to have low seasonal dissolved oxygen are unsuitable for fish farm
                   development. and therefore were not discussed.

           28.     The additional effect of fish farms on dissolved oxygen is the same regardless of
                   the ambient dissolved oxygen concentration. The effect of the decrease may be
                   more severe at low ambient dissolved oxygen concentrations, but typically the
                   salmon in the farm would be affected before other organisms.

           29.     There have been numerous studies concerning the relationship of nutrients and
                   other growth-limiting factors. These studies are applicable to fish farms because
                   inorganic ammonia from fish farms is chemically and biologically indistinguishable
                   from other sources. The same applies to other waste products such as nitrate and
                   trace minerals. Numerous studies have repeatedly demonstrated that inorganic
                   nitrogen is the factor most likely to be limiting to phytoplankton growth in certain
                   marine waters, at certain times, second only to sunlight.

                   There is no evidence that the occurrence of paralytic shellfish poisoning in Puget
                   Sound is related to nutrient concentrations or trends. In fact, EPA sponsored a
                   recent study of recent and long-term trends in water quality (Tetra Tech 1988)
                   that found little long-term increase in nutrients concentrations in both the main
                   body and restricted portions of Puget Sound that were examined. Only in Carr
                   Inlet was a slight decline in nutrient concentration thought to be related to
                   increased phytoplankton production.

           30.     Comment noted.

           31.     Fish food conversion ratios (FCR) have improved significantly in the last decade.
                   A 2 to 1 ratio is no longer considered the standard. A ratio of 1.5 to 1 is a more
                   typical goal for a fish farmer to set. Considering the improvements made recently
                   in diets, and the achievement of FCRs as low as 0.8 to 1 in experimental settings
                   at the Norwegian Institute of Aquaculture Research (AsgArd et al. 1988), it is not
                   unreasonable to use a working figure of 1.5 to 1 and speculate the usage of a 1
                   to 1 ratio in the future.

           32.     The Intedin Guidelines specifically state that the baseline survey be done after the
                   pens are in the water, but before the farm is stocked with fish. The baseline
                   benthic survey is recommended after deployment of the pens to ensure that the
                   specific area beneath the farm is identified. This recommendation is reasonable
                   and not a defect in the Interim Guidelines.

                   Diver surveys are used to rapidly, and relatively easily, assess the presence of
                   large, or mobile organisms, primarily geoduck clams (Panope abrupta) or
                   Dungeness crabs (Cancer magister). Diver surveys in depths greater than 75 ft
                   would likely involve decompression diving. Decompression diving is hazardous,
                   and the information gained from such a survey must be balanced against the risks
                   to the personnel involved.









               Response to Letter No. 1: Skagit and Island Counties (continued)

               33.    Eelgrass provides a substrate for some of the prey of most of our recreational or
                      commercial fish species. It can provide a habitat refuge for various life stages
                      of some of these species.

                      An increase of the nutrient loading of the water in the areas near eelgrass beds
                      might promote the increase in epiphytic algae, which would shade the eelgrass
                      blades (Sand-Jensen 1977) and restrict the lower depth to which the eelgrass
                      could grow. However, the eelgrass-epiphyte system is not simple. It involves a
                      number of small herbivores specialized to eat the epiphytic material, chief among
                      them, the caprellid amphipod, Caprella Ideviusculd.

                      The presence or absence of these amphipods, not ambient water nutrient loading,
                      largely determines the extent of epiphytic algae (Caine 1980). The amphipods,
                      in turn, are prey for nudibranchs Welibe leonina) and some fishes, including some
                      of the recreational and commercially important species.

                      If the increased nutrient load resulted in an increase in the epiphytes, it is likely
                      that the populations of their herbivores would show a corresponding increase.
                      That increase would result in a general epifaunal population increase in the eel-
                      grass communities, and an enrichment up the food chain. The enrichment up the
                      food chain would include an increase in the prey for commercially or recreationally
                      important fish species.

               34.    Comment noted. The 1,500 ft distance is a guideline.              With site specific
                      information, VVFDW, USFWS, or NMFS can recommend different distances if
                      necessary.

               35.    See response to Question 30.

               36.    Habitats of special significance are defined by WIDW using an evolving information
                      system based on continually updated information. More specific discussion of
                      these habitats is appropriate during SEPA reviews for each proposed farm, when
                      the most current data are available.

               37.    Weston (1986) cites four papers claiming that fish farms attract wild fish species.
                      Three of those papers deal with cage culture of catfish in lakes, which is not
                      applicable farming in the marine waters of Puget Sound. A review of the fourth
                      (Beaveridge 1984) did not find the referenced statement on page 14.
               38.    When fish farms undergo SEPA review at the local level, the lead agency under
                      SEPA sends a copy of the proposal to all agencies with jurisdiction. In the case
                      of birds and marine mammals, this state agency is WDW. WIDW has the expertise
                      and responsibility to ensure that wildlife populations are not adversely affected by
                      any type of development proposal.
                      Fish farms are also required to obtain an ACOE Section 10 permit. During this
                      federal permit process, the proposal is reviewed by USFWS and NMFS- These









           Response to Utter No. 1: Skagit and Island Counties (continued)

                  agencies also have the expertise and responsibility of protecting bird and marine
                  mammal species. A discussion of the MMPA has been added to Section 5.9 of
                  the FEIS.

           39.    Bacteria, in some situations, will have resistance to certain antibiotics. Resistance
                  may be induced, as well as occur naturally. In freshwater environs as well as
                  seawater, in cultured and feral fish, drug resistance may be observed. Once again,
                  this would not pose a new risk to "wild" fish, and as previously stated, pathogens
                  not diseases, are transmitted.

           40.    This issue is addressed in Section 5.4 of the FEIS and has never been
                  demonstrated to occur in nature.

           41.    Failure by Weston to retrieve information does not mean that FDA!s evaluation
                  in 1983 is invalid. As a side note, use of OTC at fish farms has been substantially
                  reduced because of the use of vaccines.

           42.    Persistence of an antibiotic in fish tissue for lengthy periods only increases the
                  likelihood that the bacteria will be eliminated, and not develop a resistant strain.

           43.    Use of antibiotics in fish and other food products are tightly controlled by the
                  FDA. Fish food manufacturers are closely monitored when adding antibiotics to
                  fish food. Fish farmers have no more opportunity to add medications to the fish
                  than do other livestock farmers. Very few antibiotics are approved by the FDA
                  for use in food.


           44.    Comment noted.


           45.    Comment noted.

           46.    See Section 2 of the response to comments after the text in Appendix E.

           47.    See Section 2 of the response to comments after the text in Appendix E.

           48.    See Section 4 of the response to comments after the text in Appendix E.

           49.    See Sections 1, 3, and 5 of the response to comments after the text in Appendix
                  E.

           50.    Addressing aesthetic and use conflict issues is a matter for local government and
                  should be done on a case-by-case basis. The aesthetic analysis you refer to on
                  page 102 of the DEIS is a tool for local government that provides an analytical
                  structure to the discussion of aesthetics rather than relying on a simple poll of
                  opinions.

           51.    Comments noted.








               Response to Letter No. 1: Skagit and Island Counties (continued)

               52.     Comments noted. Each future fish farm proposal will be reviewed under SEPA.
                       This will allow all agencies with expertise to review the proposals in relation to
                       their specific sites with the best information available at the time.

               53.     See the response to Question 9.

               54.     See the response to Question 9.

               55.     See the response to Question 10.

               56.     The aesthetics section has been retitled "Visual Quality." As with many broad
                       subjects in an EIS, the discussion has been divided into different topics for
                       convenience and clarity.

               57.     The discussion on visual impacts was "quantitative" in some respects to give the
                       reader perspective on the magnitude of visual impacts. While it is true that
                       observers do not remain fixed in one location looking in one direction, many
                       observers view fish farm facilities from a restricted location range (for example,
                       their house and yard). Further, while observers constantly change their direction
                       of view, if they stay in a relatively restricted range of locations, the facility will
                       occupy the same portion of their angle of view as long as the facility is entirely
                       within their view even if they move their head. Some observers, such as boaters,
                       may view a fish farm from a wide range of locations. Nonetheless, the attempt
                       to "quantify" aspects of visual impact by discussing angle of view provides an
                       indication of the magnitude of impacts. It is true that where fish farms include
                       overwater buildings and extensive human activity, the farms would be more visually
                       evident.

               58.     More observers would be visually affected by five fish farms than one farm.
                       However, if the five fish farms are adequately spaced, an" individual observer may
                       not experience any greater impact from five facilities than from one facility
                       because the four additional facilities are too distant to be seen. The nature and
                       magnitude of these impacts will depend on their numbers, locations, and the
                       attitudes of observers. Figure 18 is included in the EIS to illustrate the basis for
                       these conclusions.

               59.     The comment regarding the increase in noise attenuation over land relative to
                       water was noted on page 122 of the DEIS. The other comments on potential
                       sources of noise are noted.

               60.     The discussion of unavoidable adverse impacts does acknowledge that noise levels
                       from fish farm facilities could unacceptably affect nearby residential uses.
                       However, these unacceptable impacts could be adequately mitigated through
                       proper siting of facilities and minimization of unnecessary noise. An example of
                       the latter mitigation involves enclosing machinery. The statement that each site
                       must be considered on its own merits and that the potential environmental impacts
                       of each proposal be carefully considered is correct.









           Response to Letter No. 1: Skagit and Island Counties (continued)


           61.    While studies that substantiate the actual effect of measures to mitigate potential
                  odors may not exist, common sense would support the conclusion that containing
                  or removing odor-producing material would reduce the dispersal or generation of
                  odoriferous compounds.

           62.    The comment that mitigation measures are only effective if they are implemented
                  and that the implementation of mitigation measures may require adequate
                  enforcement is acknowledged. See the response to Question 9.

           63.    The comment that the effect of a mitigation measure on all elements of the
                  environment should be considered before the measure is required in a specific
                  case is acknowledged. In addition, decisions on location or mitigation should be
                  made only after all potential impacts are considered.        See the response to
                  Question 10.

           64.    Locating fish farms in areas already experiencing odors may be appropriate where
                  the surrounding land uses are compatible, for "ample non-residential industrial
                  and commercial areas. Local jurisdictions have traditionally allowed a higher level
                  of odor in certain areas rather than apply the same standard everywhere.

           65.    The comment that individual proposals for fish farms may be denied if the
                  decisionmaking body finds that unacceptable unavoidable significant adverse
                  impacts will occur is acknowledged.

           66.    Comments noted.

           67.    Anchor lines were mentioned in the first sentence of the discussion of impacts in
                  the DEIS. Additional wording has been added to Section 6.3 of the FEIS to
                  clarify that the potential impacts of fish farms on commercial fishing includes the
                  area used by the anchor lines.

           68.    'nis issue was addressed in the discussion of impacts in the Commercial Fishing
                  section of the DEIS.

           69.    Additional wording has been added to Section 6.3 of the FEIS to clarify the time
                  element. The table showing catch statistics has been added to the FEIS (Table
                  8).

           70.    The first mitigation measure in the Commercial Fishing section of the DEIS
                  recommends siting farms away from areas of intensive fishing. This includes
                  areas near the shore as well as those further offshore.

           71.    Comments noted. Identifying special areas of concern would be part of an overall
                  management program for the fish farming industry and is outside the scope of this
                  EIS.








                Response to Letter No. 1: Skagit and Island Counties (continued)
                72.    Kayaking and windsurfing were mentioned on page 11SO of the DEIS as examples
                       of other recreational activities. The list provides examples of recreational activities
                       and is not meant to include all possible recreational pursuits.

                73.    This section of the DEIS describes the types of potential impacts fish farms can
                       have on different groups of anglers using different techniques. Fish farms have
                       a different potential impact on trollers than they do on people who fish by
                       mooching. The point is that fish farms should not be sited in areas that are
                       intensively used for recreation.

                74.    This discrepancy has been corrected in the FEIS.

                75.    The referenced section of the Shoreline Management Act states that counties, in
                       developing their local shoreline master programs for shorelines of state-wide
                       significance, should "give preference" to uses that satisfy criteria related to state-
                       wide significance; of which increasing recreational opportunities is sixth in a
                       descending list of priorities. RCW 90.58.020 does not say that all proposed
                       projects in shorelines of state-wide significance should increase recreational
                       opportunities.

                       The discussion of shorelines of state-wide significance and the list of prioritized
                       preferences was included in the DEIS under the Relationship To Land Use Plans
                       and Regulations section.

                76.    The use of any delayed-release program as mitigation for a fish farm would have
                       to be coordinated with the appropriate state agencies. See the response to
                       Question 21.

                77.    It is outside the scope of this EIS to determine which areas of Puget Sound are
                       inappropriate for fish farms due to significant recreational use conflicts. However,
                       it may be appropriate for local government, in cooperation with appropriate state
                       agencies and in accordance with the Shoreline Management Act, to determine which
                       areas within their jurisdiction have significant aquatic recreational use and revise
                       their local shoreline regulations accordingly.

                78.    See the response to Comment 75. Proposed projects in shorelines of statewide
                       significance are not required to increase public access to publicly owned areas of
                       the shoreline.

                79.    See the response to Question 10.

                80.    It is outside the scope of this EIS to determine which areas of Puget Sound are
                       inappropriate for fish farms because of significant navigation conflicts. Local
                       governments have established policies and regulations in their shoreline master
                       programs that address navigation. nese policies have been, and will continue to
                       be, used to evaluate proposals on a case-by-case basis for potential impact to
                       navigation.








           Response to Utter No. 1: Skagit and Island Counties (continued)


           81.    Comment noted. See the response to Questions 28 and 33. Recommendations
                  for further research to determine the bacteriological characteristics of fish feed is
                  included in the Preferred Alternative of the FEIS. There is no evidence of
                  resistant plasmids being transmitted from fish pathogens to human pathogens.

           82.    A request for further work is premature at this time because a problem has not
                  been identified.


           83.    Comments noted.


           84.    Comment noted.

           85.    Land-use and zoning classifications are not the same. This figure shows broad
                  land-use categories such as forest, rural non-farm, and urban/suburban
                  development. It is not intended to show zoning classifications such as residential,
                  urban, commercial, or industrial. Though Island County may be zoned residential
                  or rural residential, the island is still covered with many forests.

           86.    Comment noted.


           87.    The increase in demand for local services as a result of new fish farm facilities
                  is similar to the increase in demand for local services as a result of other new
                  developments. With normal rates of fish mortality, the landfill capacity in Puget
                  Sound jurisdictions should be sufficient to accommodate any waste from fish
                  farms.

           88.    The Preferred Alternative in Section 6.9 of the FEIS includes a recommendation
                  that local governments require information about disposal of farm waste as part
                  of their shoreline permit application.

           89.    The primary effect of fish farms on the environment is the addition of nutrients
                  and organic material (BOD). Since the Sound is nitrogen limited, nitrogen is
                  the critical nutrient for analysis. BOD is related to decreased oxygen concentra-
                  tions and therefore is also important. Other factors, such as turbidity, are more
                  localized and are not considered in a cumulative, Puget-Sound-wide impact
                  analysis. Comparison of farms to a treatment plant is done only for order of
                  magnitude purposes and should not be misconstrued to mean that 50 farms at one
                  site has the same impact as 50 farms distributed over the length of Puget Sound
                  from the Straits of Juan de Fuca to Dana Passage. The wide distribution of fish
                  farms in this analysis would have an effect more similar to many small treatment
                  plants spaced throughout Puget Sound. As a widely distributed source of BOD
                  and nitrogen, the analysis is sufficient to indicate that Puget Sound as a whole will
                  not be adversely affected by fish farm development.

           90.    Con-unents noted.








              Response to Letter No. 1: Skagit and Island Counties (continued)
              91.   Comment noted. All proposed tank farms will be subject to SEPA review. A
                    thorough discussion of the potential impacts of land-based tank farms is outside
                    the scope of this EIS.

              92.   Comments noted. See the response to Question 32.

              93.   See the response to Question 7.





                                                                                 LETTER NO. 2

                                Jamestown Klallam Tribe
                                          305 Old Blyn Highway 9 Sequim, WA 98382
                                         Phone: (206) 683-1109 - (Fisheries) (200683-1001






                                         April 6, 1989





          Joseph R. Blum,Director
          Washington Department of Fisheries
          115 General Administration Building
          Olympia, WA. 98504


          Dear Mr. Blum:

          We have had the opportunity to review in detail the Draft Programmatic EIS on
          Fish Culture in Floating Net Pens. As a Tribal governmental entity concerned
          with management and protection of fishery resources, and as an applicant for a
          commercial floating fish farm, the Jamestown Klallam Tribe has a unique
          perspective on fish farming and its potential impacts. we are very familiar
          with the issues involved. We are confident that our own proposed site will
          result in no adverse impacts, and we believe that properly sited fish farms
          pose no threat to the State of Washington. However we strongly support the
          need for appropriate state regulation of the fish farming industry and for
          careful examination of each project for site-specific considerations.

          The EIS contains good technical information. We are pleased to see that some
          of the extensive work we have done on our proposed site in Discovery Bay has
          provided data for the technical studies. These studies should aid in
          eliminating fears by the general public of some of the generic impacts of fish
          farms, and help policy makers to focus on site-specific considerations in the
          permitting process. However we find in many sections that the editing of the
          document is poor or even erroneous. We urge that every section be carefully
          reviewed for accuracy, since public interest in, and misinformation concerning,
          fish farming is considerable.

          The EIS focuses on potential negative impacts of net pens, and does not give
          attention to the positive benefits of fish farming. These are the economic
          benefits in terms of employment and income generation, as well as contribution
          to the world's food resources and, for the Jamestown Klallam Tribe, a means to
          increase our economic self-sufficiency while retaining our traditional reliance
          on marine resources.

          A major question arising from the PEIS is how its findings will now be used to
          improve the permitting process for fish farms, and how current regulations
          found to be conservative by the PEIS will be adjusted. Our Tribe has suffered
          as much as any other.entity from the process as it now exists.

          Attached is a more detailed review of the PEIS prepared by my staff, Lou and
          Lyn Muench, Aquaculture Planners.






             Jamestown Klallam Tribe                                 Joseph R. Blum








             Thank you for giving us the opportunity to review the PEIS. It is a welcome
             addition to the body of information the State has kx!en providing on the
             potential for fish farming in our area. with suitable revision the Final EIS
             should be a useful document for decision makers in reviewing net pen permits.


             Sincerely,
             A04-T. WVUO
             WM R. Allen, Chairman/Executive Director












          MEMO TO:       Ron Allen, Executive Director

          FROM:          Lyn and Lou Muench, Aquaculture Planners

          SUBJECT:       Draft Programmatic Environmental Impact Statement: Fish Culture
                         in Floating Net Pens: Review by Jamestown Klallam Tribe

          DATE:          April 1, 1989

          We have reviewed the PEIS, in consultation with the Fisheries manager and the
          Timber/Fish/'Wildlife Biologist. The sections where we find need for revision
          are itemized below.


          SUHMRRY:

               The summary as written does not accurately reflect the technical elements
               of the study and omits entirely the positive findings of the PEIS. In
               particular, Major Conclusions should include the fact that no unavoidable
               adverse impacts were found.

               Positive impacts of fish farming identified in the PEIS which should be
               included in the summary are to be found on pages 81, 89, 104, 114, 118, 120
               (two), and 129. Other positive impacts which should be discussed in the
               text and summarized here include the role of fish farms in monitoring water
               quality, the economic benefits to the State in terms of employment, income,
               tax revenue, and import substitution, and finally, the contribution to
               world food resources.       At the very least these benefits should be
               identified in the Summary as not covered by the PEIS.

               The Summary also does not identify or discuss the regulations currently in
               force which would prevent many of the potential negative impacts
               identified. Since the PEIS includes mitigation measures, and other actions
               intended to minimize potential impacts, existing regulations need to be
               described.   In several instances current regulations are more restrictive
               than would be necessary under the findings of the PEIS : what actions have
               been proposed to relax these regulations?

          B.   BACKGROUND OF THE NETPEN INDUSTRY (page 4)

               The purpose of delayed release pens is to increase the size and survival
               rate of salmon, and consequently increase the commercial and sport salmon
               harvest. The technique inhibits their inclination to migrate but does not
               eliminate it. This section should be rewritten to reflect these facts.

               It is unfortunate that the environmental impacts of delayed release
               facilities were not given greater attention, since local governments have
               conditioned or refused permits for these facilities on environmental
               grounds in the past. Furthermore the fact that the fish are released into
               the public water makes the impacts on aquatic organisms substantially
               different than from commercial fish farms. obviously delayed release net
               pens have a significant beneficial impact on commercial and recreational
               fishing.




                                                Page 1







              Jamestown Klallam Tribe                                       PEIS Review




              I. ALTERNMM: PERMITS AND APPROVALS: (page 8)

                  We urge that the Tribes be included among the state, federal and local
                  agencies involved with management and review of 'the net-pen industry
                  beginning on page 10. As co-managers of fisheries resources with the
                  State, the Tribes have a review role over net pen projects as they impact
                  treaty fishing and wild fish/shellfish habitat. A separate but important
                  route by which Tribes comment on net-pen projects is through the Army Corps
                  of Engineers Section 10 permit process, where interference with treaty
                  fishing rights is a specific consideration. Tribes regularly review net
                  pen proposals at local and state permitting levels, and where a project
                  poses a threat to treaty fishing rights, have recourse to the Federal
                  courts if such a conflict is not resolved. The earlier in the process
                  potential conflicts are identified and dealt with, the better for all
                  parties concerned. we therefore suggest that the Tribes be listed in this
                  section.

                  The Tribes should also be identified along with WDF and commercial fishing
                  organizations as those groups to be contacted to identify areas of
            0     intensive fishing, under the first Mitigating Measure at the end of the
                  Commercial Fishing section, page 114.

              II. AFFECTED ENVIEWNW:

                  NOTE:    Throughout the PEIS, mitigation measures are suggested which are
                  already  in force. These should be so designated, to prevent regulations
                  from being duplicated. For example, conditions were recommended for our
                  county permit for the Discovery Bay project already enforced by DNR.

             A. NATURAL

                  1.   SEDIMENTS: ( page 13)

                  It would be extremely useful to include a chart showing all existing net
                  pen sites and their hydrographic characteristics. This information is
                  important since many of the impacts discussed in this section are the
                  result of sites developed before the Interim Guidelines, and would not
                  apply to sites in deeper water with stronger currents.
                  It would be preferable to identify the location and site characteristics     of
                  net pens studied when authors are quoted (page 23) because as written it
                  gives the impression that all existing net pens pre-dating the Interim
                  Guidelines have azoic areas beneath them, which is not the case.

                  2.   W%TER QUALITY: (page 27)

                  This section is particularly useful in containing new information on
                  phytoplankton.    It also recognizes that the Interim Guidelines limitation
                  of fish farm production to one percent of nitrogen flux in 19 embayments is
                  based on "a very conservative estimate of nitrogen flux" (because it
                  considers only average surface levels of inorganic! nitrogen but ignores
                  organic nitrogen and dissolved nitrogen at depth). An additional factor
                  to consider is actual tidal nitrogen flux, which can be substantially
                  greater (about four times) than average surface levels within the bay. If
                  the one percent limitation is to continue to be used, the PEIS analysis
                  should be the basis of a new system for calculating nitrogen flux.

                                                   Page 2







         Jamestown KlallaM Tribe                                       PEIS Review





              Just how conservative the Interim Guidelines can be is shown by the studies
              conducted for our proposed fish farm site in Discovery Bay. The Interim
              Guidelines assume that 100% of the dissolved nitrogen emitted from a fish
              farm initially stays within an embayment. Our proposed site, however, lies
              near the mouth of the bay and the emissions would be transmitted northward
              toward the Strait of Juan de Fuca during ebb tide. In addition, the site
              lies within the area of a variably sized and located eddy which appears
              during flood tide. During some flood tides the flow from the site is also
              northward towards the Strait. This eddy also ensures that substances which
              do not get all of the way out of the Bay during ebb tide would continue on
              through the mouth to the Strait during the subsequent flood and ebb tides.
              Less than 50% (the best statistical estimate is 8%) of the dissolved
              nitrogen emissions would flow deeper into the Bay and thereby conform with
              the Interim Guidelines assumptions.
              Taking these findings, Kiefer and Atkinson (1988) estimated that durijg a
              summertime period of very substantial nitrogen depletion (0.2 mg-at/m ),
              our proposed fish fam would increase phytoplankton Soncentrations by
              two-thirds of one percent, from 3.00 to 3.02 mg-at/m .        In contrast,
              phytoplankton in Discovery Bay have been found to naturally oScur, during
              the summer months, in concentrations ranging up to 15 mg-at/m . In other
              words, the increase attributable to the fish fam would be 1/600th of the
              natural flux.

              The point to be made here is not only that the Interim Guidelines can be
              extremely conservative in certain situations, but that there is no
              mechanism for formally relaxing them in such situations. In contrast,
              there are several stages in the permitting process where they can be
              reinforced or augmented by stricter control. Their flexibility is one-way.

              The positive role of fish farms in monitoring water quality, alluded to in
              a later section, should also be addressed in the water Quality section.
              Fish farmers, monitoring water quality on a daily basis, can provide a
              significant resource for water quality monitoring for the benefit of the
              public.   As fish farmers are economically dependent on maintaining clean
              water, they are uniquely placed to act on any threats to water quality
              identified through their monitoring.

              3.b.   IMPORIPMCK OF        C FISH SPECIES: (page 68)

              This section is confusing, as it mixes up true exotics (Atlantics) with
              intra-regional natives (Pacifics). Pacifics are routinely introduced into
              State waters as part of Washington's enhancement program, but are not the
              preferred species for fish farmers in Washington. Yet the discussion is
              devoted to interbreeding, possible with Pacifics but not Atlantics.
              Negative impacts if any from accidental escape of famed Pacifics would be
              insignificant compared to the large release program by the Tribal, State
              and Federal governments. This is referred to on page 72 and 73, but should
              be highlighted at the beginning of the section. Since "genetic impacts" is
              a commonly expressed fear of the general public, and poorly understood,it
              is extremely important to write this section clearly. The long list of
              mitigation measures given, in spite of the little potential for adverse




                                               Page 3







              Jamestown Klallam Tribe                                        PEIS Review




                  impacts, gives credence to this fear. These should be replaced with a
                  caution that future introduction of exotic species; should be carefully
                  reviewed for potential negative impacts. One important safeguard against
             G    successful colonization of an exotic species not included in the list of
                  mitigations is the maintenance of healthy natural production of native
                  stocks, and protection of habitat.

                  3.c.   DISEASE (page 76)
             0
                  The discussion of VHSD, p77, needs to be revised, to include recent
                  experience with this disease.

                  4.a.   KARIM NNOOM (page 83) Figure 12: Seal and Sea Lion Haulouts in
                  Puget Sound. This figure includes haulouts in both Sequim and Discovery
                  Bays, locations with which we are familiar. We have! not observed haulouts
                  at either place. The Sequim. Bay spot is at the site of the John Wayne
                  Marina of the Port of Port Angeles. Marina staff reported verbally that
                  in the past four years only a single seal has teen seen up on the
             0    breakwater.     The source of Figure 12 is given as the Puget Sound Water
                  Quality Authority, updated by Jeffries, WDW. Mr. Jeffries, Marine Mammal
                  Specialist for WDW, has verbally informed us that he updated the PSWQA
                  figure by adding haulouts known to him, but that he did not delete any
                  haulouts they had identified from other sources. VUW records do not show
                  haulouts at either location. Both locations are sites proposed for net
                  pens.   Could you please verify whether the two sites were included on the
                  PSWQA map by mistake, and if so, delete them.


             B. BUILT ENVIEF"RUNT

                  1. AESTHETICS: (page 89)

                  The information contained in this section was not reflected in The
             G    Economics of Salmon Farming,Technical Appendix E. As a consequence the
                  analysis of impacts of net pens on real estate values is seriously flawed.

                  While it is true that some people may perceive any structure placed in open
                  water as having a negative aesthetic impact, others would not. The
                  statement in the introduction to this section in paragraph two that "many
                  people" perceive any structure as negative is vague and not substantiated
                  in the PEIS findings. (See for example page 91, paragraphs 4 and 5.) The
                  many examples of high value residential development overlooking harbors,
                  marinas, log boom operations and net pen complexes is evidence that
                  structures in the open water are not aesthetically offensive to "many
                  people."

                  Figure 14 misrepresents the structure viewed from House 2 as wider than it
             0 should be. Figures 14 through 21 use different dimensions and sizes, and
                  cannot be used for comparative purposes. They should all be redrawn using
                  the same dimensions.       Figures 19, 20 and 21 as labelled are open to
                  misinterpretation, as they appear to suggest possible densities for net pen
                  development, rather than a theoretical aid to regulating the distance
             G    between net pens.

                                                    Page 4







          Jamestown Klallam Tribe                                        PEIS Review




          3. COMMCIAL FISHIM: (page 105)

              References in this section to the impact of net-pens on the allocation of
              fish between treaty and non-treaty fisheries are confusing, and present a
              highly unlikely scenario. There is no evidence cited to show how net pens
              might affect fish migration. If there was an impact on migration, it would
              more likely adversely affect tribal fisheries than non-tribal, since tribal
              fisheries are limited to specific places and stocks. The management plans
              to attain treaty/non-treaty allocation are flexible and can usually adjust
              fishing opportunity to account for localized displacement in fishing
              activity.

              Under mitigation measures, page 114, reference is made to the potential for
              use of available pen space for raising of Pacifics for release and
              commercial harvest. This does not adequately explain the potential benefit
              of commercial net pens to provide staff and facilities to operate
              enhancement programs for Pacific salmon which would otherwise not be
              affordable by public or tribal fisheries entities. Thus net pens can
              mitigate for displacing fishing activities and beyond that, may increase
              enhancement efforts.       There are already examples, such as at Squaxin
              Island, where enhancement and commercial net pens are jointly operated.
              The Jamestown Klallam Tribe also plans to include an enhancement element in
              its commercial fish fam operations when appropriate under the Management
              Plan.

          Technical Appendices: E. Economics report

              This highly academic approach to an economic analysis of the fish farm
              industry needs a common sense summary. Unfortunately this will be
              difficult since one of the three factors analyzed, real estate values, is
              predicated on the erroneous assumption that net pens can have an impact on
              a five to ten mile radius. As established in the EDAW study and others,
              fish farms are virtually invisible at distances greater than one half mile,
              and could therefore have no impact on real property values further away.
              The Technical Appendix also makes an assumption that an aesthetic loss due
              to net pens that is not justified within the report or by external sources.
              In the absence of hard information on this subject, the Jamestown Klallam
              Tribe commissioned a study of net pen impacts on real property values in
              1988.     The Skagit System Cooperative and Swecker Seafarms Limited also
              participated.     The economics report references and quotes that study,
              "Influence of Floating Net Pens on Residential Property Values". We
              suggest that this study, which is based on actual property transactions in
         0
              the vicinity of existing net-pens, be incorporated into the PEIS as a
              technical appendix. Since Alpine Appraisal Service has updated that study
              as of 3/89, the most current version should be used.


          Overall, the PEIS contains much useful technical information, some of it new.
          If the Summary is rewritten to more accurately reflect the findings, and it is
          carefully edited, the Final EIS will serve well as a guide to policy makers in
          dealing with generic issues relating to net pens. It should be especially
          useful for local officials, to separate out the generic issues from the site
          specific characteristics that need local review.



                                                Page 5










           RESPONSE TO LETTER NO. 2: JAMESTOWN KLALLAM TRIBE


           1.     See the response to Question 12.

           2      The text has been revised to evaluate existing regulations and guidelines in the          0
                  FEIS.

           3.     See the response to Question 12. The Summary has been rewritten to discuss                0
                  each issue individually.

           4.     See the response to Comment 2.

           5.     The scope of this EIS does not include evaluating the impacts from fisheries
                  enhancement programs.        However, there are significant commercial and
                  recreational benefits from the delayed-release program.

           6.     See the response to Question 8. The list of agencies in Section 4 of the FEIS
                  includes agencies with management authority over the fish farm industry. The text
                  in Section 6.3 of the FEIS includes tribes as an entity to notify during the SEPA
                  and shoreline permitting processes.

           7.     The text in Section 6.3 of the FEIS has been written to clarify that commercial
                  fishing organizations includes tribes.

           8.     Including information from specific farm sites is beyond the scope of this EIS.
                  However, the information you request can be obtained from DNR or local
                  planning departments.

                  Comment acknowledged. Not all farms sited before the Interim Guidelines have
                  azoic conditions beneath them.

           9.     Section 5.2 of the FEIS indicates that farms monitor water quality parameters
                  daily.

           10.    This section has been reorganized in the FEIS. While it is true that Atlantic
                  salmon are currently the species of choice, the EIS must consider Pacific salmon
                  genetic issues as well.

           11.    The DEIS concludes that significant genetic-related impacts are unlikely. However,
                  anything that can be done to minimize the small level of impacts is beneficial and
                  should be pursued where practical. If genetic impacts are a problem in the future,
                  there are measures which may be taken to eliminate or lessen the problem.

           12.    See the response to Question 29.








                Response to Utter No. 2: Jamestown Klallam Tribe (continued)

                13.   Haulout sites identified in Figure 12 are based on information provided in Angel
                      and Balcomb 1982. This document was based on the following study:

                      Everitt, R.D., C.H. Fiscus, and R.L Delong. 1980. Northern Puget Sound Marine
                          Mammals. DOC/EPA Interagency Energy/Environment R & D Program
                          Report. EPA #600/7-80-139. Environmental Protection Agency. Washington,
                          D.C.

                      Figure 12 indicates haulouts that have been used at some point in the past. Site
                      specific review of fish farm proposals will identify which haulout areas are
                      important.

                14.   The analysis of impacts of fish farms on real estate values used an empirical
                      approach. This approach involved determining whether the proximity of fish farms
                      to properties was associated with any detectable change in property values. Thus,
                      while this approach did not explicitly include the various factors that could affect
                      property values, these factors, which include aesthetics,, were implicitly included.

                15.   The statement that "many people" perceive any structure as negative is a reflection
                      of the numbers of people expressing opposition to fish farms at public hearings
                      on individual projects. It is not meant to indicate the relative proportion of those
                      who do not favor fish farms versus those who do.

                16.   Figure 14 has been modified to show structures with the appropriate widths.

                17.   Figures 14 through 21 illustrate the affect of different locational parameters on
                      visual impact and cannot be directly compared. However, the sizes of the facilities
                      in the various figures have been revised to 100 by 1,000 ft.

                18.   The titles of these figures have been changed to indicate the hypothetical nature
                      of the examples illustrated.

                19.   The Commercial Fishing section of the DEIS has been revised to clarify the
                      potential impact of fish farms on the allocation of salmon between treaty and non-
                      treaty fisheries. There is no evidence that farms affect the migration of fish.
                      However, fish farms may affect the ability to catch salmon as they migrate past
                      a farm.


                20.   Comment noted.

                21.   See Section 4 of the response to comments after the text in Appendix E.

                22.   See Section 4 of the response to comments after the text in Appendix E. The
                      real estate report to which you refer has been added to the Technical Appendices
                      as Appendix K





                                                                        LETTER NO. 3



                                               JEFFERSON COUNTY

                                    PLANNING AND BUILDING DEPARTMENT


                                                      P.O. Box 1220
                                               Port Townsend, Washington 98368

                                                   Planning (206) 385-9140
                                                   Building (206) 385-9141


      JEFFERSON COUNTY COURTHOUSE               David Goldsmith, Director




          April 7, 1989

          Mr. Ron Westley, Project Manager
          Washington State Department of Fisheries
          115 General Administration Building
          Olympia WA 98504

          Re: Draft Programmatic Environmental Impact Statement on Fish
               Culture in Floating Net Pens

          Dear Mr. Westley:

          I have reviewed the draft EIS and have the following comments:

          1.   The issues of introduction of exotic pathogens into the waters
               of Puget Sound and the transfer of diseases from cultured fish
               to wild stocks are not adequately discussed.           These are
               technical issues which have also generated great concern and
               controversy among local governmental agencies and interested
               citizens.    The draft EIS presents an ideal forum for the
               Department of Fisheries and its consultants to provide a
               detailed, thoughtful discussion of these issues, potential
               impacts, possible means of preventing their occurrence and
               mitigating their impacts. The draft EIS fails to accomplish
               this.
          2.   The discussion of the direct and indirect impacts of net pen
               culture on Puget Sound Water Quality was thorough and well
               done.   However, in order for this material to be of use to
               local governments and planning agencies in their environmental
               review of net pen proposals, this discussion should be
               supplemented by the following:

               a.    Detailed studies of those areas of Puget Sound where net
                     pen facilities should not be sited due to lack of
                     adequate flushing, the potential for plankton blooms, etc.










              Page 2
              Mr. Ron Westley
              April 7, 1989

                   b.    Detailed studies of those areas in Puget Sound where net
                         pen facilities might cause water quality standards to be
                         lowered (for instance from Class Alk to Class A).
                   C.    A discussion presenting detailed and, specific suggestions
                         to local planners and permitting agencies for baseline
                         and ongoing water quality studies to require during the
                         environmental review of net pen proposals.

              Inclusion  of this material will go a long way In making the EIS a
              valuable tool for local governments to use in reviewing net pen
              proposals.

              Since




              Ji6 Pears
              Associate Planner


                 :mkg
              ji  -Pe
                 o
                   I
                   c


                  mka










           RESPONSE TO LETTER NO, 3: JEFFERSON COUNTY PLANNING AND BUILDING
           DEPARTMENT


           1.    The DEIS did discuss potential impacts and mitigation measures to reduce              U
                 potential disease impacts. See Section 5.8 of the FEIS.

           2.    See the response to Question 1.

           3.    See the response to Question 1.

           4.    Specific water quality studies that should be required of permit applicants is
                 outside the scope of this EIS. NPDES permits are now required of fish farms and
                 permit conditions will require specific water quality monitoring.





                                                                    LETTER NO. 4
      KATO & WARREN, INC.
     2001 WESTERN AVENUE * SUITE 555 * MARKET PLACE ONE & SEATTLE. WASHINGTON 98121 (206) 448-4200






            March 14, 1989                                       -





            Ron Westly, Project manager
            Washington Department of Fisheries
            115 General Administration Building
            Olympia, Washington 98504

            Re: Fish Culture EIS
                 Comments on Draft EIS


            Dear Mr. Westly:

            I am writing to comment on the draft EIS prepared by the
            Department to justify approval of more fish farming permits
            in Puget Sound.

            This document is totally self-serving.        If it had been
            written by the industry itself, it could not have been worded
            better to support their position.

            The document totally ignores the very large pollution load
            even a modest fish pen operation places on the receiving
            waters.   The draft EIS and the Weston guidelines deal only
            with issues to prevent the self destruction of the fish
            farming operation from its own waste.           The so-called
            assimilation capacity of the Sound totally ignores the
            ongoing long term concern for Puget Sound water quality
            expressed by the public, the legislature, DOE, and the PSWQA.
            This is nothing more than the old "dilution is the answer to
            pollution" approach that was abandoned by the State and
            responsible industry decades aqo.

            At a time when Puget Sound residents are spending several
            billion dollars to provide improved waste treatment to remove
            nutrient loads, it is inconceivable that a State agency, and
            perhaps even the governor, are promoting an industry that
            will create a massive nutrient loading with no treatment.










            Mr. Ron Westly
            March 14, 1989
            Page Two



            The draft EIS is f lawed by its failure to recognize the
            overall potential impact of this industry on Puget Sound
            water quality. If, as a mitigation, full secondary treatment
            of f ish f arm ef f luent were required as is done for upland
            hatcheries, we would f ind that this industry can only exist
            at the expense of the public. -

            Approval of this EIS will cast serious doubts on the
            integrity of the Department and can only result in increased
            litigation as citizens are forced to do what the State should
            be doing - protect Puget Sound.

            Best regards,

            KATO & WARREN, INC.



            Richard E. Warren, P.E.
            Principal

            REW/ap

            cc: Governor Booth Gardner
                 Ms. Chris Gregoire, Director DOE
                 Ms. Kathy Fletcher, PSWQA
                 John de Yonge, Seattle P.I.

























                                                         KATO & WARREN. INC.










          RESPONSE TO LET17ER NO. 4: RICHARD E. WARREN

                                                                                                          W
                                                                                                          E
           1.    Section 5.2 of the FEIS discusses the potential effect of fish farms on water
                 quality. It also discusses regulations such as the NPDES permit program that             U
                 ensure compliance with water quality standards. Section 5.3 of the FEIS discusses        0
                 the potential impacts on nutrient sensitive areas of Puget Sound.
                                                                                                          W





                                                                            LETTER NO. 5


                       KITSAP COUNTY DEPARTMENT OF COMMUNITY DEVELOPMENT
                       (206) 876-7181 (WASH. 1-800-872-4503)            RON PERKEREWICZ, DireCtor
                       614 DIVISION STREET PORT ORCHARD, WASHINGTON 98366






           March 30, 1989






           Mr. Ron Westley
           Project Manager
           Washington Dept. of Fisheries
           General Administration Building
           Olympia, WA 98504

           Re: Draft Programmatic Environmental Impact Statement, Fish Culture in Floating
                Net Pens


           Dear Mr. Westley:

           Having reviewed the above-referenced document, it is clear that it should be
           considered as being a quite comprehensive study of the net pen industry from a
           technical aspect. However, as to the accuracy or adequacy of the technical
           reports cited, there remains some question. In part, this concern lies with the
           State's position regarding net pen fish culture, in that by becoming an advocate
           for the industry their creditability from the publics perspective has been
           severely compromised.

           The approach of anaylzing "four different levels of development" as possible
           alternatives is somewhat disappointing and the repeated statement "with proper
           siting" leaves the question; what is proper siting unanswered. In fact, the
           entire PDEIS process seems to have created more questions than answers and more
           unsolved problems unresolved.

           The major concern is with the concept of the State's commitment to "properly
           site" 100 new net pen facilities. Is this truly the intent of the State? If so,
           then one must question why the PHIS has been drafted in the first place,
           especially in light of the four conclusions outlined (page ix) and of the listed
           major potential impacts (pg ix, x). These items 1 through 8 do nothing to
           resolve the numerous conflicts which plague net pen proposals, if anything they
           emphasis the State's commitment to support the net pen industry regardless of the
           environmental impacts, water quality issues, sediment loading, disease or land
           use conflicts.

           The State's answer to these issues remains; "with proper siting".

           During the scoping process for the PDEIS we were lead to believe that the
           document would "provide a single authorative discussion of the possible impacts
           for use by State agencies, local government, fish farmers and interested
           citizens". And that we could look forward to being provided with "the guidelines
           necessary for proper management of the industry".









             Ron Westley
             March 30, 1989

             Page 2





             The document currently being circulated falls short of meeting our expectations.
             The document does, however, support one position quite strongly; the position
             local government has stated all along.  There is DO CIE!ar, concise, quick way to
             resolve the conflicts stemming from net pen projects. Local government has been
             struggling with this fact for sometime, without the benefit of support from the
             State agencies, who up until now have been holding on to their mandate to support
             the industry. If the PHIS does achieve one goal it will be to alert the State
             agencies that the issues are broader and more complicated than can be resolved by
             a document prep-=red in light of the industry's desires.

             'Bes Regards,



              e ee Beam
             Shorelines Administrator

             RB:jmm










           LE=R NO. 5:              KITSAP COUNTY DEPARTMENT OF COMMUNITY
           DEVELOPMENT



           1.     Comment noted.

           2.     The alternatives have been revised in the FEIS to evaluate the impacts of fish
                  farming under a No-Action Alternative of existing regulations and guidelines, and
                  under a Preferred Alternative of expanded regulations, additional guidelines, and       0
                  recommendations for further research.

           3.     See the response to Question 3.

           4.     Comment noted.





                                                                       LETTER NO. 6




                                                                  March 15, 1989

           Mr. Ron Westly
           Project Manager
           Washington Department of Fisheries
           115 General Administration Building
           Olympia, WA. 98504

                                                    Re: Draft PEIS-January,1989

           Dear Sir:


                As a shoreline land owner and resident of Whidbey Island, I,
           along with other residents and countless visitors, have enjoyed
           observing and using the magnificent, pristine waters of Puget
           Sound for fishing, crabbing, clamming, swimming, boating, water
           skiing and     most of all, enjoying the special views over
           undisturbed waters.


                Plans of the State        of   Washington     to   continue the
           commercialization of Puget Sound by increasing the salmon net
           pens placed by industry disturbs me a great deal.        I strenuosly
           object to this exclusive use of PUBLIC property. These waters
           have always been for the use and enjoyment of EVERYONE.

                I have studied the Draft PEIS published by the Department of
           Fisheries and wish to make the following comments:

                      1. For many years our goal has been to eliminate the
           discharge of  waste such as human sewage and industrial wastes
           into Puget    Sound.     To this end we have constructed treatment
           plants, both  primary and secondary.      The PEIS states (Summary,
           page ix,1.) "The major impacts of net pen culture can be
           prevented by  proper farm siting to assure dispersion of wastes,
           flushing of   the site, and protection of sensitive areas." YET
           SINGLE NET PEN PRODUCES POLLUTANTS EQUIVALENT TO UNTMTED SE
           FROM APPROXIMATELY 10,000 PERSONS!' (Taken from article by
           columnist John de Yonge in Seattle Post Intelligencer, March 5,
           1989.)   Allowing discharge from salmon net pens certainly is not
           consistent with the requirements for discharge from sewage
           treatment plants.

                      2. The PEIS also states (Summary, page ix,6.) "The
           accidental introduction of an exotic disease into state waters
           remains a risk." This I believe happened in Norway (where fish
           pens were  permitted) and their wild fish runs were virtually
           destroyed. Recently VHS (a very dangerous fish disease) was found
      0    in two of  our state hatcheries, necessitating the destroying of
           all fish. This has never occurred before in our state. It must
           have been  brought in from Europe but to date no answer has been
           found. We  should not take these unnecessary chances. Our natural
           salmon runs are too valuable.












                                           -2-


           Mr. Ron Westly, Project Manager
           Washington Department of Fisheries




                     3. The COMP05ers of the PEIS admit that visual impacts
           cannot be avoided. Puget Sound is known worldwide for its beauty
           and has been enjoyed by all. We should not impair this wonderful
           natural body of water by corrupting it with more salmon pens.

                     4. No mention was made in the PEIS of the possible
           effects on humans from the use of antibiotics, and chemicals used
           to treat or prevent fish diseases.     We also do not know what
           effect these chemicals would have on other sea life.


                     5. The PEIS speaks of reviews by many state and federal
           bodies such as Departments of Fisheries, Ecology, Environmental
           Protection, Coast Guard, etc. What power do these agencies have
           when it comes to regulation of aquaculture? AND WHAT SAY DO
           LOCAL RESIDENTS, PRIVATE CITIZENS AND OTHER INTERESTED PARTIES
           HAVE IN    ESTABLISHING NEW    commikciAL NET    PENS AND OTHER
           AQUACULTURE IN PUGET SOUND?

                     6. Evidently industry would be required to submit
           reports on their waste discharges, chemicals used, number of
           salmon harvested, etc. I believe that this is too serious a
           matter to allow 5elf-policing.    Industry should be required to
           pay for established, competent      independent laboratories to
           inspect and test their sites periodically.

                Again I emphasize that most aquaculture has no place in
           Puget Sound. I am firmly convinced that particularly salmon pens
           in any number would do irreparabl damage t @the    waters.




                                         William G .Langdow
                                          3159 S. Eastpoint' r.
                                         Langley, WA. 98:260
                                                     tp

                                                          t I),














                                                                                                             W
           RESPONSE TO LEITER NO, 6: WILLIAM G. IANGDO


           1.     Mr. de Yonge, of the Seattle Post Intelligencer, quoted from the document, The
                  Environmental Effects of Floating Mariculture In Puget Sound by Weston (1986).
                  Mr. de Yonge neglected to add the last half of the sentence from which he
                  quoted. The language from Weston (1986) follows:
                                                                                                             rA
                     The quantities of nutrients and associated BOD from the culture of                      0
                     250,000 kg of salmonids are comparable to those produced by about                       W
                     10,000 persons, but the water which passes through the net-pens on
                     a daily basis is equivalent to the domestic use of 25 million persons
                     (based on 0.25 cubic meters per day per individual). Thus, the
                     concentrations of nutrients and BOD are very dilute compared to
                     sewage and most other discharges to the marine environment.

           2.     See the response to Question 29.

           3.     Comment noted.


           4.     Antibiotic use in fish and associated human health concerns are noted in Section
                  5.4 of the FEIS.

           5.     The regulations used by State and federal agencies to manage the fish farm
                  industry are discussed throughout the FEIS. Local citizens can participate in the
                  decisionmaking process through a variety of means such as the SEPA review and
                  the local shoreline permitting process.

           6.     See the response to Question 9.





                                                                                       LETTER NO. 7




                                                        4042 Smuggler5 Cove Rd.
                                                         Greenbank, WA 98253
                                                         March 16, 1989

           Ronald E. Westley, Project Manager
           Washington Department of Fisheries
           115 General Administration Building
           Olympia, WA 98054


                                PEIS Fish Culture In Floating Net Pens

           The following comments are offered on behalf of SAVE OUR SHORES, a
           citizen organization on Whidbey Island:

           We f Ind this document Inadequate and disappointing for a number of
           reasons. As nearly as can be discerned, the consultants employed
           represent organizations that have a previous history of advocacy for the
           Industry as well as those agencies that have been promoting the
           aquaculture Industry for a number of years.

           The choice of alternatives does not Include a Null Alternative, but rather
           starts f rom the position that there w I I I be a f Ish pen Industry, and that
           the question Is not debatable. What then follows Is an organized attempt
           to refute all previously expressed objections. In short, the Fisheries
           Department has abandoned objectivity and Instead developed an advocacy
           paper. The report is further burdened by an Inadequate budget for a study
           of such a complex subject.

           The most glaring deficiency In the report is the section on disease.
           Obviously the recent revelation of the presence of VHSD in Puget Sound
           renders this portion of the study obsolete and Incorrect. It calls for a
           major supplement that Includes a broadening in terms of the list of
           potential diseases and a description of disease problems in Canada, Europe
           and As I a. I t shou I d address the I ncreased suscept I b I 11 ty o f penned f I sh to
           d I seases wh 1 ch are carri ed by w 11 d f I sh, and the probab I I I ty o f the
           development of more dangerous strains of those diseases. It Is
           Inconceivable that the discussion of VHSD was treated so carelessly, when
           f Isherles scientists have known of Its existence for some weeks, and were








                   PEIS Comments                        -2-                L. Joe M! I ler



                   also aware that other areas--Oregon, Idaho and British Columbia--
                   consider It to be so dangerous that they will no longer accept f Ish or eggs
                   from Washington State hatcheries.

                   The report makes extravagant claims about the high quality of Puget
                   Sound's water, yet makes no mention of the massive cleanup program that
                   Puget Sound Water Quality Authority has been asked to study. PSWQAhas
                   named the 1 mpact of f I sh pens on water qua I I ty as an Issue f or I ts f uture
                   study agenda.

                   There Is presently a good deal of concern about the proliferation of
                   plastics in marine waters, yet the report does not mention how net pens
                   could exacerbate this problem. The Sechelt Peninsula In British Columbia
                   has experienced severe problems from the more than one million plastic
                   f eed bags used in that smal I area each year. There w I I I undoubtedly be
                   additional problems with the larger pieces of plastic broken from the pens
                   that were destroyed during this winters' storms.

                   During the scoping meetings we were assured that negative economic
                   Impacts would be assessed and weighed against those that are positive.
                   This has not been done in the report. However, the appendix includes
                   unsubstantiated sweeping statements to the effect that the positive
                   factors outweigh the negatives. This work should be done correctly and
                   incorporated into the main report or be stricken from the appendix.
                   Fisheries staff has advised us that because the work was of such poor
                   quality it was not included In the report.

                   In view of the fact that no assessment of regulatory and monitoring costs
                   has been included in the report, It Is assumed that the industry Is to be
                   self-regulating. If that Is true, the report should so state.

                   The local Impact section Is not well developed. For example, much could
                   be learned from the Canadian experience In terms of dtsposal of dead f Ish
                   (359), amounting to more than one hundred tons In the local landrIll
                   annually. Beginning In 1985, this burden has shortened the capacity of the
                   Sechelt land f fit by three years. Also, there has been a substantial
                   Increase in burglary and vandal Ism In the area, beginning shortly after the
                   Industry arrived in Sechelt, and there is reason to believe some of It may
                   be do;      jnf lux of casual laborers, who are employed only on an hourly







               PEIS Comments                      -3-               L. Joe MI I ler



               basis, as slaughtering and processing require them. In addition, the
               Industry has placed new burdens on roads and traff Ic control. Local
      G        governments are Involved In all of these effects- monitoring, complaint
               response, and development of regulatory programs and litigation.

               The choice of sites for the study of dispersion of wastes was unfairly
               conceived. One site is in an area well known for its strong currents, and
               the other Is a relatively new site. It was predictable that only small
               accumulations of waste would be found beneath these pens. The
               Department Is well aware which sites would have revealed a much
               different picture. It is also well known that In both Canada and Norway
               the Industry has requested -rai low,, sites because most pens must be
               relocated every few years.

               The limitations of the dispersion model as described in the appendix
               (P. 53 - 58) reveal that it has little validity and should not be relied upon.
               It Is not enough that there Is no better model available. The use of such a
               model violates the principles of acceptable scientific practice.

               or great public concern Is the Issue of proliferation. There Is no defined
               outer limit of floating aquaculture, but this report suggests It will Include
               at least one hundred salmon "farms". The report should Include a map
               Illustrating what Puget Sound would look like with one hundred salmon
               0
               farms", together with the projected seaweed, oyster, mussel and other
               f loating Installations.

               The report did not Include freshwater f Ish pens, although the Industry Is
               already moving toward such Installations In the Columbia River,
               Lake Roosevelt, Rufus Woods Reservoir, and elsewhere.

               The report Ignores the Federal Clean Water Act and its NPDES permit
               requirement. This question may be decided in litigation brought by the
               Sierra Club Legal Defense Fund, but It certainly should be addressed In the
               PEIS.

               The report should properly discuss the Industry's f Inancing problems,
               Including the reluctance of Canadian and American banks to underwrite
               these ventures because of the high risk Involved, This matter has become








                    PEIS Comments                      -4-                  L. Joe 1111 ler




                    more urgent since the announcement In British Columbila that Norwegian
                    banks plan to withdraw from further funding, unless support Is
                    Immediately forthcoming from the B.C. government or private sources.

                    Critical questions have been raised concerning the Industry's displacement
                    of other users, and the study should include an extensive analysis of the
                    Public Trust Doctrine as it applies to floating aquaculture.

                    The comments on aesthestIcs speak only to how net pens look under Ideal
                    conditions. The suggestion Is made that some viewers may even f Ind f Ish
                    pens attractive. Whereas there are many examples of attractive of f Ice
                    buildings, apartment houses, and industrial parks, the basic principles of
                    land use planning would preclude them in residential areas because or
                    their different and, incompatible character. Exactlythesame
                    compatibility rules that guide land use decisions can and should apply to
                    aquatic areas as they relate to upland properties. Additionally, the visual
                    Impact study considered only a low prof Ile style of f Ish pen, when in fact
                    they may be almost any height. One example is an application in Clallam
                    County for permission to site pens that would stand 25 feet above the
                    water.


                    The sect I on on I and based f I sh pens was f a I My we I I done but neg I ected to
                    mention two key elements. The high capita) cost of such a rearing
                    technique is largely offset by Its ability to produce an eight pound fish In
                    twelve months. In addition, diseases that may be Impossible to contain in
                    water-based pens can be controlled in those on land, and they do not
                    endanger.wild stocks. Also, the report should note that land based
                    facilities are subject to local zoning codes. Most of trhe siting problems
                    might be solved if the same rules applied in the aquatic environment.

                    The study was contradictory In a number of Its mitigation suggestions.
                    For example: "if the pens Interfere with navigation they can be moved
                    closer to shore" -- "ir the pens Impair the views rrom upland property they
                    can be moved further out." "Bright colors should be used to protect
                    navigation" -- "Aesthetic views will be enhanced by neutral colors."

                    The report minimizes the potential ror escape by large numbers of penned
                    f Ish. Note should be taken of the massive escape of f I Sh rrom pens In







               PEIS Comments                                           L. Joe Miller



               British Columbia during the winter storms of 1988-89. Estimates of
               escape In the Jervis Inlet area range from 100,000 to 2,000,000. Last
               autumn Seattle area newspapers carried a story concerning a large
               escapement brought about by seals tearing holes in fish pens. The report
               should address the impacts of large scale escapes, however unlikely they
               may be.

               Finally, It is urgently requested that this study be given a major revision
               and supplementation, particularly in the disease and pollution section. If
               the study Is not to be expanded there must, at the very minimum, be a
               substantial extension of the review and comment period, perhaps 120 to
               180 days. The study embraces a number of extremely complex Issues, with
               more, apparently, to be faced, and they should be treated comprehensively.




                                                                                  OL, V-










            RESPONSE TO LETTER No. 7: SAVE OUR SHORES


            1.     See the response to Question 2.
                                                                                                               U
            2.     SEPA requires a No-Action Alternative which was represented in the DEIS by the               0
                   13 farms which currently exist in Washington. The FEIS evaluates the fish
                   farming industry under two regulatory alternatives: (1) The No-Action Alternative
                   is the existing regulations and guidelines that presently affect the industry, and (2
                   the Preferred Alternative which includes expanded regulations, additional                    W
                   guidelines, and recommendations for further research.

            3.     Comment noted.

            4.     See the responses to Questions 25, 26, and 27.

            5.     See the responses to Questions 25, 26, 27, and 29.

            6.     See the response to Question 13.

            7.     This has not been a problem in Washington. The Preferred Alternative in Section
                   6.9 of the FEIS recommends that fish farm proponents supply information on
                   waste disposal as part of their shoreline permit application.

            8.     See the response   to Question 12.

            9.     See the response   to Question 9.

            10.    See the response   to Letter 1, Comment 88.

            11.    Comment noted.

            12.    Comment noted.

            13.    Comments noted.     The choice of sites illustrates the need for adequate circulation
                   around farm sites. European and Canadian fish farms typically have much higher
                   fish densities and less rigorous siting review processes and consequently do not
                   provide legitimate examples of the extent of sedimentation that could occur here.

            14.    See the response to Question 15. It is important to realize the limitations of any
                   tool for assessing environmental impacts. However, limitations in a mathematical
                   model does not mean that the model is invalid as you suggest. Limitations of a
                   model such as this must be considered when reviewing the results from the model.
                   As stated by Weston in Appendix A, "the model has performed well in both Puget
                   Sound and Scotland."

            15.    See response to Question 3.








                Response to Letter No. 7: Save Our Shores (continued)

                16.    A map such as you describe would be misleading for          two reasons. First, the
                       figures in this document, such as Figure 1, are drawn to    a scalle of 1 inch equals
                       16 miles. A square drawn on the map to represent a fish farm with sides 1/16
                       of an inch in length would be 640 acres in size. Therefore, a typical 2-acre fish
                       farm would not be visible at this scale. Second, there is no way to project the
                       number or locations of floating seaweed, oyster, mussel, or salmon facilities that
                       may be sited in the future.

                17.    The scope of the EIS is limited to the marine waters of the greater Puget Sound
                       area and is not intended to discuss any freshwater fanning activity.

                18.    See the response to Question 17.

                19.    There is no requirement in SEPA to evaluate the specific financial status of an
                       industry in an EIS.

                20.    A discussion of the Public Trust Doctrine has been included in Section 8 of the
                       FEIS.


                21.    Comments noted.


                22.    Comment noted.

                23.    Comments noted. Land-based tank farms are outside of the scope of this EIS.
                       This discussion has been moved to Appendix I -of the FEIS.

                24.    See response to Question 10.

                25.    When the EIS talks about potential impacts of farm fish interbreeding with or
                       competing with native stocks, it is addressing large-scale escapements. Small-
                       scale escapements would be of negligible concern.

                26.    Comment noted.

                27.    Comment noted. See response to Question 7.





                                                                   LETTER NO. 8
           The Mountaineers
           300 Third Avenue West0Seattle, Washington 98119 (206) 284-6310

           BRANCHES IN TACOMA, EVERETT, OLYMPIA AND BELLINGHAM



                                        March 22, 1989



        Mr. Ron Westley
        Project Manager
        Washington Department of Fisheries
        115 General Administration Building
        Olympia, WA 98504

             RE: Draft Programatic Environmental Impact Statement on
                  Fish Culture and Floating Net Pens

        Dear Mr. Westley:

        The Mountaineers is a conservation/outdoor club with more than
        11,000 members, primarily in the Puget Sound corridor. We have
        consistently supported a clean and naturally productive Puget Sound
        for fisheries and other aquatic life and for recreation. We'd
        like to offer the following comments on the Draft Programatic EIS
        on Fish Culture and Floating Net Pens.

        Based on the information in the DEIS, the Mountaineers feels the
        biological impacts on water quality from aquaculture requires
        serious concern. There is no evidence that Atlantic salmon pens will
        not have a negative impact on native salmon runs. The fact exists
        that escaped exotic fish like the Atlantic salmon could establish
        self-sustaining populations and compete with indigenous fish such as
        steelhead trout.

        The DEIS also does not discuss the problems occurring in the
        established fish pen industry in Norway where wild Atlantic salmon
        runs have been devastated from diseases associated with the net pens.
        There is alot to be learned from an established aquaculture industry
        that the DEIS does not consider.

        Based on the information in the DEIS the Mountaineers can only
        support a total moratorium on further siting of net-pen fish farms.
        Until more in-depth information is researched and made available
        to prove that the biological vigor   and ecological health of the
        Puget Sound will not be harmed, we cannot support additional fish
        pens in our waters.

                                        Sincerely,
                                        The Mountaineers




                                        Carsten Lien
                                        President



        ... TO EXPLORE, STUDY, PRESERVE AND ENJOY THE NATURAL BEAUTY OF THE NORTHWEST










                RESPONSE TO LETTER NO. 8: THE MOUNTAINEERS


                1.    The fact that all previous attempts, including several in the Pacific Northwest, to
                      establish Atlantic salmon outside of their natural range in areas with indigenous
      0               salmonid populations have failed is evidence of the minimal risk of establishment
                      here.

                2.    The wild Atlantic salmon stocks in Norway were not devastated by diseases
                      associated with the fish farming industry. A serious reduction of the population
                      was the result of acid rain, overfishing, and hydroelectHc development before the
                      fish farming industry was established. The situation in Norway is very different
                      than what would occur in Puget Sound. In Norway, fish farms sited in fjords are
                      essentially situated in river mouths of rivers with small, fragile populations of
                      salmon. In Puget Sound, the small likelihood of impacts from escapement would
                      be spread throughout the system. A small number of strays relative to a larger
                      population of salmon is a natural occurrence.

                3.    Comment noted.





                                                                            LETTER NO. 9



                 WASHNGTON STATE DEPARTMENT OF
                 Natural Resources
                                                                                   BRIAN BOYLE
                                                                       Commissioner of Public Lands

           April 5, 1989                                                     OLYMPIA, WA 98504



           Ron Westley, Project Manager
           Washington Department of Fisheries
           Mail Stop AX-11
           Olympia, WA 98504

           Dear Ron:

           We have reviewed the "DPEIS, Fish Culture in Floating Net Pens". This appears
           to be a thorough, accurate report which we believe will be very helpful in
           resolving siting conflicts.

           We suggest a correction to the list of permits and approvals on page 9.
           "Marine Lands Lease" should be changed to "Aquatic Lands Lease" and the
           citation should be RCW 79.90. On page 10, the discussion about DNR should
           read as follows:

                 The Department of Natural Resources acts as the proprietary manager for
                 state-owned aquatic lands. Aquatic lands are managed to provide a
                 balance of public benefits for all citizens of the state. These
                 benefits include encouraging direct public use and access, fostering
                 water-dependent uses, ensuring environmental protection, utilizing
                 renewable resources, and generating revenue in a manner consistent with
                 the above benefits.

           Thank you for coordinating with us during preparation of this document. We
           look forward to the final EIS.

           Sincerely,
           .1@

           Steve Tilley, Assistant Manager
           Division of Aquatic Lands
        lip
       L UP
      IV
    ï¿½;IMPA
















           c: Stan Biles


                                                                                     t.32










                     RESPONSE TO LETTER NO. 9: WASHINGTON DEPARTMENT OF NATURAL
        
                     RESOURCES
        
        
        
                     1.        The language has been revised for the FEIS.
       
        




                                                                      LETTER NO. 10

                          A
                                                      NOOKSACK INDIAN TRIBE

                                                            UW[hg, Washingtor SM44
                                                            'telephone 1206) 592-51M

                                                            Marrn7 22, 1989

       Duane E. Phinney, Chief
       Habitat Management Division
       Washington Department of Fisheries
       115 General Administration Building
       Olympia, Washington 98504

       Dear Mr. Phinney:

             We received a copy of the Draft Programmatic Environmental
       Impact Statement: Fish Culture in Floating Net Pens last week.
       I called your division to see if the deadline for comments had
       been changed, since the copies were so late in distribution---
       and was told that there was no change, except that they would
       accept comments until Friday, March 24th. Our Tribe would like
       to make a response to the document, but under this schedule we
       will-not be able to make the deadline with the kind of detail a
       response like this requires.

             There are three salmon net pens being proposed in our area
       at this time, and we have taken the time to research something
       of the nature of potential threats we perceive from developments
       of salmon aquaculture like these.

             Establishing salmon aquaculture needs to be examined in th&
       contexts of non-point pollution (especially under the Puget Soand
       Water Quality Authority programmes of Monitoring and Rezearch),
       fiaherica manauement, and the more Ueneral aspects of environment
       4--hat- are tvaaitional uses fov impact statements. Since there is
       a current epidemic of a virus (the VHS reported on Orcas Island
       and at Neah Bay) that has never been reported in our area before
       and we do not know how it was transferred to our area --- it seems
       that this problem needs considered attention and not a hurried
       process without the benefit of the independent biological staff
       such as is represented by our tribe and others.

             Legislation that has been sponsored for consideration by
       Harriet Spanel of our District has passed the House of Repre-
       sentatives and is now in the Senate. This would require that
       guidelines to regulate the operations of floating aquaculture
       facilities would be written into local Shoreline Master Plans.
   (D  In our experience, going before the County Hearing Examiner to
       describe our concerns with the salmon net pens proposed in our
       area, the ambiguity in the local shoreline plan was a difficulty.

             We feel that more time is needed to adequately review the
       DPEIS you have circulated, and so we must ask that the deadline
       be extended for comments on the document.


                                                           Sincerely,
                                                           Dozas E. Dobyns









             RESPONSE TO LETTER NO. 10: NOOKSACK INDUN TIIUBE


             1.   See the response to Question 5.

             2.   Comment noted.

             3.   See the response to Question 29.

             4.   Comment noted.





                                                                                              LETTER NO. I I

         0
                 Ilk Northwest Indian Fisheries Commission

                               6730 Martin Way E., Olympia, WA 98506 Phone (206) 438-1180 FAX #456-3032 FTS #434-9476
     %0001  ..A
         'Row



                                                   April 4, 1989



            Mr. Ron Westley
            Project Manager
            Washington Department of Fisheries
            115 General Administration Building
            Olympia, Washington 98504

            Dear Mr. 'Vicstle-y:

            The Northwest Indian Fisheries Commission is providing the following comments on your
            Draft Programmatic Environmental Impact Statement - Fish Culture in Floating Net Pens.

            We are pleased to see that the PEIS addressed this topic in such a comprehensive manner.
            This document addresses many of the topics brought up before State and local hearings
            regarding floating net pens, and therefore should be very valuable to those decision making
            bodies, which must address permit applications.


                                              SPECIFIC COMMENTS


            Section 3, Page 105 -
            This section does not adequately address the rights of Treaty Indians to fish in their Usual
            and Accustomed Fishing Areas. U & A's can be described as broad geographic areas and
            also as site specific locations. The right to fish in these areas cannot be permitted away by
            local, State, or Federal permitting agencies. The only way that a site, which conflicts with
            treaty fishing can be permitted, is with the agreement from all tribes who fish at that site.
            Obtaining agreement from the tribes may require some form of mitigation, depending on
            t@e i-rportance of the site. important fishin- locations mav have to be excluded ftom
            consideration for net pen siting.

            Section 11(3c), Page 77 -
            Unfortunately, with the recent discovery of Viral Hernniorhagic Sep+.;cemia (VHS), ii,
            Washington, the section on VHS needs to be re-vaitten. The comments pertaining to VHS
            transmission need to be more carefully worded to explain that vertical transmission (inside
            the egg) rarely, if ever, occurs arld that horizontal transmission (fish to fish or on the
            outside of the egg) is the most common route (see Holt, ODF&W Studies at Elk River on
            IIINV transmission; Ken Woffe's book "Fish Viruses & Fish Viral Diseases"). In lieu of
            this, I would like to change the opening sentence on page 77 to include "for introducing
            exotic pathogens in or on eggs imported..."










               Mr. Ron Westley
               April 4, 1989
               Page 2


               Appendix D - Infectious diseases of Salmon
               This section should be strengthened with increased descriptive rnaterial about the problems
               that pathogens cause, i.e. the how, when, where and why pathogens may have impacts on
               net pen reared fish and the implications of each in terms of transferring that pathogen to
               wild fish in the area.    The current discussion has also left out LPN, and needs to be
               updated to include VHS.

                                                         Sincerely,


                                                                       r% -L
                                                                    r1V -

                                                         TERRY E. WRIGHT
                                                         Manager, Enhancement Planning


               TEW:cac:netpen.wp














                                                                                             M
         RESPONSE TO LETTER NO. 11: NORTHWEST INDUN FISHERIES COMMISSION


         1.    The text has been revised for the FEIS to include a more detailed discussion of
               Treaty Indian rights. See Section 6.3 of the FEIS.

         2.    Comment noted. See the response to Question 29.

         3.    See Appendix G.




                                                                      LMER NO. 12
                                                                MEMBERS

                                               Dunlap Towing Company Manson Construction & Engineering Co.
                                               Foss Maritime Company Olympia Towing Company
                                               General Construction Company Puget Sound Freight Lines
                                               Knappton Maritime Corporation Puget Sound Tug & Barge Company










 '45 N.W. 85th STREET. SUITE 103 SEATTLE. WASHINGTON 98117 (206) 782-3M


                                                    23 March 1989

           Mr. Ron Westley. Project Manager
           Washington Department of Fisheries
           General Administration Building
           Olympia, WA 98504

                                          Ref: Draft Programmatic E.I.S.
                                                Fish Culture in Floating Net Pens

           Dear Mr. Vestley:

           The comments submitted by the Northwest Towboat Association apply
           to the section on Navigation commencing on page 102 of the E.I.S..
                  a. Reference is made throughout this section to Puget Sound
                     while the study area includes a much greater area than
       0             just Puget Sound. Are the contents of this section
                     applicable to just Puget Sound or are they to be applied
                     to the entire study area?

                  b. Page 103, 3rd Para.,3rd Sentence. Suggest rewording as
                     follows " Towboats with large barges normally use the
                     main shipping lanes while towboats with log tows and
                     small barges may hug shorelines...".

                  c. Page 104, 2nd Para. In the past, at present and in the
                     future log towing will be a part of the maritime business
                     in the E.I.S. study area. Essential to the safety and
                     economics of log towing is the continued availability
                     of anchorages for both safety from wind and waves and
                     while awaiting favorable tidal/current conditions. In
                     particular, few people understand the damage that wind
                     and waves create for log tows and realize the drastic
                     affect adver.se currents/tides have on the speed of advance
                     of a large log tow capable of making only a few knots.
                     Therefore, the loss of a currently used embayment is a
                     serious set back to the log towing industry.The establish-
                     ment of a fish pen in a location needed by the log towing
                     industry results in the loss of that area for 24 hours
                     every day of the year. Vhile the paragraph suggests " tow-
                     boats and other boaters may have to travel to the next
                     available safe anchorage" this option may not be available
                     and thus comes the problem.

                  d. Page 104. 3rd Para. The comparsion of net pens to a long
                     dock, a marina or series of anchored boats as stated in
                     the first sentence is not a valid comparsion. lv-@'hile the






             Northwest Towboat Association
             Mr. Ron Westly - Draft E.I.S.
             23 March 1989
             Page 2

                       distances from shore and depths of water vary by large
                       amounts, net pens may be 800 feet or more from the shore
                       and in depths of water exceeding 60 feet.The pens thus
                       create obstructions to navigation much greater than the
                       comparsion stated in the first sentence. The last sentence
                       is the more likely situation, with the net pens located
                       far enough off shore to hazard log towing operations.

                    e. Page 104. 4th Para. The statement that location of net
                       pens in more remote areas is typical of recently permitted
                       pen sites is subject to debate. When navigating over the
                       water a remote area is difficult to define as all areas
                       are equally accessible. Perhaps the reference is made to
                       land areas and the presence or non--presence of homes,
                       buildings, etc. determines if the area is "remote".

                    f. Page 104, Section c., Mitigation Measures. Generally
                       speaking, the listed measures appear to be a partial
                       answer to reducing impacts to navigation, but upon
                       close examination that may not be the case. Examples:
                          (1) Avoid Placing nets in established areas - In the
                              study area I believe any agency will find it
                              difficult to locate an area which is not an
                              established area to some group of maritime users.

                          (2) Site pens close to shore - Inadequate water depth*
                              more pollution of the bottom, insufficient flow
                              of water appear to be problems.

                          (3) Place pens adjacent to existing structures - Same
                              concerns as noted above.

                          (4) Consolidate farms in area of limited navigatio,n -
                              Comments in (1) apply plus concern of concentration
                              of fish pens causes impact on water quality and
                              bottom pollution.

                    g. Page 105. d. Unavoidable Adverse Impact. Concur with this
                       statement, but should include study area not just Puget
                       Sound. This one sentence sums up the position of the
                       Northwest Towboat Association on the subject of placing
                       net pens in the navigable waters of the study area.

             The Association appreciates the opportunity to comment on the Draft
             E.I.S. on the Fish Culture in Floating Net Pens. The Association
             also request full consideration be given to our concerns in the
             final draft of this document.

                                                     Sincerely,
                                                     Northwest TOW+oat Association
                                                              C_
                                                     Boone C. Tay,
                                                     Executive Secretary










           RESPONSE To LETEER NO, 12: NORTHWEST TOWBOAT ASSOCUTION


           1.     As stated in Section 3 of the FEIS, the term "Puget Sound" in this document
                  refers to the greater Puget Sound marine waters from the west end of the Strait             U
                  of Juan de Fuca, north to the Canadian border, and south to Olympia. Tlis
                  includes Hood Canal and all marine bays, harbors, inlets, and passages.

           2.     Comment noted.


           3.     Comments noted.

           4.     As was stated in   the text, a farm located close to shore would have the same
                  effect on navigation as would anything, such as a dock, that extends from the
                  shore. The paragraph goes on to say specifically that 'The further offshore the
                  structure is located, the greater the navigational risk . . ."

           5.     The context of the paragraph is the relationship of fish farms to potential boating
                  emergencies.     Recently permitted farm sites are in areas without upland
                  development that could provide quick assistance to boaters, and that is why the
                  term "remote" was used'.


           6.     Comment noted.

           7.     Siting a farm near the shore would reduce the potential impact on navigation, but
                  may increase other potential impacts. Evaluation of potential farm sites should
                  include an assessment of navigation as well as other factors such as water depth
                  and current.

           8.     Placing farms adjacent to an existing structure such as a dock, that already affects
                  navigation, would minimize the effect of the farm on navigation. See the response
                  to Comment 7 above.

           9.     See the response to Comment 7.

           10.    See the response to Comment 1.




                                                                                        LETTER NO. 13

                                                    STA
                                                                                                      IN-
                                                                                                      "'g

  JAN TVETEN
   Director                                          1 89


                                            STATE OF WASHINGTON
                  WASHINGTON STATE PARKS AND RECREATION COMMISSION

                     7150 Cleanwater Lane, KY-11 9Olympia, Washington 98504-5711 * (206) 753-5755


                                             March 23, 1989



            TO:             Mr. Ron Westley, Project Manager
                            Washington Department of Fisheries
            FROM:           Ron Effland, Environmentalist     Z_1@
                            Environmental Coordination

            SUBJECT:        Fish Culture in Floating Net Pens Draft Programmatic EIS
                            (DPEIS).


            The following  are comments from the staff of the Washington State Parks and
            Recreation Commission on the above subject.

            Recently we received a News Release from the U.S. Fish and Wildlife Service
            dated February 24, 1989.      The information in that paper seems to require
            that diseases on page 77, paragraph 2 in the DPEIS be rewritten.

            The news release reported      that at the Makah National Fish Hatchery 3.4
            million viral hemorrhagic septicemia (VHS) infected fry and fingerling
            coho, chum and fall chinook    salmon, steelhead trout and fish eggs had to be
            destroyed in an effort to      contain the virus.      This disease is native to
            Europe but i s new to North    America.    The report also says the virus could
            pose a major threat to Pacific salmon and steelhead resources. Some of the
            infected adults migrated to the hatchery's water supply and infected other
            salmon and steelhead being raised there.

            The paper reported further that a VHS-like virus in chinook salmon was
            discovered at the Glenwood Springs salmon rearing facility on Orcas Island.
            435,000 chinook salmon fry and fingerlings had to be destroyed and the
            hatchery disinfected.     The article goes on to say that VHS is native to
            Europe, where it is known to cause high mortalities in salmonid species,
            particularly in the commercial production of rainbow trout.               Biologists
            cannot yet explain how a disease from Europe suddenly surfaced in western
            North America.     For more than 20 years, the U.S and Canadian governments
            have required    the inspection of European salmon and trout and their eggs
            before they enter the two countries in an effort to prevent introduction of
            any potential diseases.

            The News Release was very informative.        We have also heard speculation on
            the news that there is a high probability that the virus VHS came from
            Atlantic Salmon eggs imported from Europe and that Washington's Pacific
            salmon and steelhead are in danger.









               Mr. Ron Wesley, Project Manager           -2-               March 23, 1989
               Wash. Dept. of Fisheries


               We agree with the mitigation measures to reduce potential                impacts on
               navigation addressed on pages 104 and 105 except the use of highly visible
               colors in the design of the facility.        The requirement to have navigational
               lights on all four sides of net pen facilities has less visual impact and
               greater safety.

               The Washington State Sport Catch Report says that in 1987, 456,000 sport
               anglers caught an estimated 783,000 salmon.           672,OCO of the salmon were
               caught in marine waters.      The salmon anglers took nearly 1.5 million trips
               averaging 1.97 fish per person and 0.44 fish per trip.              This shows that
               there is a lot of salmon sport fishing taking place.

               Finally, the mitigation     measures for impacts to recreation listed on page
               120 (copy enclosed) in      the DPEIS should have a recreational dollar value
               applied.    If a proposal   occupies a recreational salmon fishing hole or area
               and the project can not be located elsewhere, the proponent should provide
               contributions to a Pacific Salmon raise, hold and release project in the
               area.    Should the proposal displace an area that is a recreational bottom
               fish site the proponent then should make contributions to construct an
               underwater reef park near by the project location.               The amount of the
               proponents contribution should be based on TABLE 6, Page A-7 in the
               Department of Community Development document titled Economic Impacts and Net
               Economic Values Associated with Non-Indian Salmon and Sturgeon Fisheries.
               Table 6 (copy enclosed) shows recreational benefit values per salmon
               fishing trip    to various areas through out the state.,         These values range
               f rom a I ow    of $71.08 in South Puget Sound to a high of $136.24 on the
               coast.    Each  net pen proposal must be analyzed on a site by site basis for
               mitigation of impacts to recreation, and the analysis shown in the project
               EIS.

               Thank you for   the opportunity to comment.

               vc
               Enclosures
               cc: Tom France, Assistant Director
                     Dave Heiser, E.P. Chief, Environmental Coordination
                     John Pitts, Dept. of Agriculture









              Floating net pens can also have positive impacts on recreational activities.        Personnel
              from net-pen facilities could provide assistance during boating emergencies, and the net
                                                                                     0
              pen structure itself could be used for temporary moorage during an emergency.

              C.     Mitigntion Measures

              Recreational activities within an area proposed for a net-pen facility will be dependent
              upon the nature of the area, its intrinsic value, presence of destination objectives, and
              its accessibility to the public. Efforts to avoid or minimize adverse impacts on recreation
              must, therefore, be based upon an evaluation of the specific nature of recreation in the
              area. Below    is a list of some measures that could be used to reduce any impacts.

                             Avoid the placement net pens in areas of high recreational use or value
                             when the farm will adversely affect those values.

                             Consult with resource agencies (especially W`PRC and W`DF), with the local
                                                     0
                             planning department, and with local user groups (fishing clubs, dive clubs,
                             yacht clubs) to identify current recreational uses and potential conflicts.

                             Avoid areas of intense recreational use (such as fishing, "holes", SCUBA
                             dive sites, or destination moorage areas).

                             Avoid areas where pens would adversely affect the intrinsic recreational
                             value (for example, within 2000 feet (616 m) of state park beaches).

                             In other areas, minirnize adverse impacts on recreational use, including
                             navigational, aesthetics, noise and odor. Specif-c mitigation measures are
                             discussed in the appropriate sections of this PEiS.

                             Provide public benefits to offset any adverse impacts to recreation. Specific
                             activities will be project specific an@ would depend upon agreement between
                             the net-pen propon,-.nt and interested parties. Such activities could include:

                             -improving public access at access sites used for farm operations;

                             -cooperative projects with fishing clubs, schools, tribes and the state to use
                             available pen space to enhance wild fish stocks.


              d.     Linavoidable Adverse Impacts

              With proper net-pen site selection, there will be no significant adverse impacts to
              recreational activities. Vrhere lesser impacts are unavoidable, these can be minimized
              through the design, configuration, and placement of the pens at the site. In addition,
              activities can be undertaken in association with the net-pen operation to enhance
              recreational uses in the area.


                                                           120








                                                                                              TABLE 6


                                                                                  RECREATIONAL BENEFITS PER TRIP




              CROUP                                         THE                THE         PUGET SOUND       PUGET SOUND           COLUMBIA         WASHINGTON
              NUMBER         USER GROUP                   COAST            STRAITS             NORTH             SOUTH              RIVER             STATE
                                                                               (2)              (3)                (4)               (5)



                   COMMERCIAL (no-Indian)


                 I    Ocean Troll - Large                             0                 0                 0                  0                 0


                 2    Ocean TroLL - Smelt                             0                 0                 0                  0                 0                  0


                 3    GiLLnets                                        0                                                      0                 0                  0


                 4    Purse-Seines                                    0                 0                 0                  0                 0


                 5    Reef Nets                                       0                 0                 0                  0                 0


                         AVERAGE COMMERCIAL                           0                 0                 0                  0                 0                  0




                  RECREATIONAL


                 5    Shore Fishermen                          $79.26             $79.26            $79.26            $57.21             579.2S           $79.17


                 7    Private/RantaL       Boats               $87.19             587.19            $87.19            $69.73             $87.19           $80.75


                 8    Charter/Party Boats                     $177.94           $145.51           $155.51            $123.81           $120.61            $164.14


                      AVERAGE RECREATIONAL                   $136.24              393.00           $90.59             $71.08            $83.00            $88.53





                        AVERAGE WASHINGTON
                              (norr-Indi an)



                                                                                         estimates; these were corroborated with the results ef other s4m4lar
                 Is the dollar value of a recreational fishing trip ma
              :e-!rzined by surveys of recreational fishermen's "willinullevs to         studies and used to estinate mid-point values for each type of
              :4? to fish or their "willingness to accept payment" to forego the         recreational fishing used in the analysis.
              :;;o.-tunitv to fish. This dollar value is always at least as high
              -.he dollar amount recreational fishermen actually spend to ongage         Selected References used include: 10, 11, 13. 14, 15. 16, 17. 1S,
              r                                                         at               19, 25. 30. 33. 38. 40, 42. 43. 44. 49. 51, 55, 57. 62, 63. 66. 69.
              ecreational fishing. The difference between the amou
              '%.eational fishermen would be willing to pay per trip (B/T) and           70. 72. 73. 76, al.
              :-6-e azount they actually pay (e/T) represents the net economic
              :entflts -Pe,: trip (see documentation for Table 17).                      Comments

                                                                                         1)  On a statewide basis, the relationship between Benefits and
                                                                                         Expenditures by various recreational userg can he sumn6nrized as
              --mary data collection .as undertaken for this study. instead              follo.s:
              -%e results of a number of recent surveys and economic analyses                                                  Charter     Private      Bank
              'elated to Pacific coast recreational fishing and northwest salmon                                                Boat           Boat
              '.344'a in Particular were used to estimate values.     Although
              4,;:.l poorly designed surveys of recreational fishermen conducted         Recreational Benefits Per Trip         S164         $ 81       S 79
              recent "era have resulted in outrageous esumates of                        Expenditures per Trip                   115           56         32
              .I-
              'reational value, many well-designed surveys have been conchicted                                                 ----         ----       ----
              .t.zh provide credible and fairly consistent estimates of gross and        Net Recreational Benefits per   Trip   $ 49         S 25       S 47
              economic values for various kinds of salmon fishing.
                                                                                         2) Recreational benefits wcre not assigned to       fishisis: runductcd
                                                                                         under a commercial licenne (sea Section 2.1.1 C!absifying
                                                                                         Fishermen).
              --Q;..&h direct research and subcontracts. all empirical economic
              .Jdies of U.S. recreational fisheries using the Contingent
              .ï¿½:'-'&tion Method (CV4). Travel Cost Method (TCM). and Nedonic
              ,'-tlng Method (P?M) were reviewed and summarized. Several studies
                   V-1. and OSU provided the most recent and the most obective

                                                                                  A-7









          RESPONSE TO LETTER NO, 13: WASHINGTON STATE PARKS & RECREATION                    W
          COMMISSIO


          1.   See the response to Question 29.

          2.   Comment noted.


          3.   Comment noted.

          4.   Calculating the compensation value for any adverse impact to recreation can be
               done several ways and should be determined on a case-by-case basis.





                                                                 LETTER NO. 14


                           Point No Point Treaty Council
                           Port Gamble Klallam * Lower Elwha Klallam e Jamestown Klallam * Skokomish





         April 5, 1989



         Mr. Ron Westley
         Project Manager
         Washington Department of Fisheries
         115 General Administration Building
         Mail Stop AX-11
         Olympia, WA   98504

         RE: DRAFT PROGRAMMATIC EIS ON FISH CULTURE IN FLOATING NET PENS


         Dear Mr. Westley:

         The Point No Point Treaty Council has had an opportunity to
         review the draft PEIS on Fish Culture in Floating Net Pens.
         Although some of the member tribes of the PNPTC may wish to
         submit their own detailed comments on the PEIS, the following
         general comments are submitted on behalf of the four member
         tribes: the Skokomish, Port Gamble Klallam, Jamestown Klallam,
         and Lower Elwha Klallam.


         PERMITS AND APPROVALS

         It is imperative that tribes be listed on pages 10-12 among the
         governmental entities or agencies who review permit applications
         for fish farms. The Point No Point Treaty Council regularly
         reviews any new development located within the usual and
         accustomed fishing area of our member tribes to determine the
         effect of the project on treaty fishing activities and finfish
         or shellfish habitat. While many tribes, such as the Jamestown
         Klallam, do not oppose some net pen development in their usual
         and accustomed area, location of a net-pen at a usual fishing
         station could constitute an illegal infringement on treaty
         fishing rights. If such a conflict cannot be resolved with the
         affected tribe(s) during the permitting process, the tribes have
         recourse through the Federal court to block such a project.

         Although we have established contacts with local permitting
         entities such as county planning offices, occasionally the
         tribes or PNPTC fail to receive the appropriate notification.
         This situation occurred regarding a fish farm shoreline permit
         application in Jefferson County in 1987. The County's failure
         to notify us became the grounds for an appeal to the Shorelines
         Hearing Board. Notification to tribes at the earliest possible
         stage of a proposal will help to alleviate potential conflicts.







           Mr. Ron Westley
           April 5, 1989
           Page 2



           Section II. E, Relationship to Land Use Plans and Regulations,
           discusses the role of local governments rel4ted to planning
           efforts in the siting of aquaculture facilities. As local
           governments, tribes must be included in any planning efforts
           pertaining to floating net pen facilities, and be given full
           opportunity to establish their own net pens for either fish
           farming or enhancement.

           COMMERCIAL FISHING

           In this section several references are made to the impact of net-
           pens on the allocation of fish between treaty and non-treaty
           fisheries which are biased towards non-treaty commercial
           fishermen. Page 113, paragraph 5 states that, "if opportunities
           for harvest are reduced in established non-tribal fishing areas,
           and the fish migrate into areas open only to tribal fishing .....
           then the non-tribal fishers may lose part of their court ordered
           allocation of salmon." There are three factors which make this
           statement erroneous. In the first place, there is no allocation
           reserved to the State. Only the treaty fishery is a distinct
           right which is reserved to the tribes. As stated in the
           conclusions of law in U.S. v. Washington:

                Because the right of each treaty tribe to take
                anadromous fish arises from a treaty with the United
                States, that right is reserved and protected under the
                supreme law of the land, does not depend on state law,
                is distinct from rights or privileges held by other,
                and may not be qualified by any action of the state.

           Secondly, we wish to point out that the attainment of treaty/non-
           treaty allocation is subject to management plans which allow the
           State considerable flexibility in adjusting fishing opportunity
           across a wide geographical area and schedule. A scenario
           opposite to the one outlined on page 113 is more likely to
           happen, since tribal fisheries are place and stock specific.
           For example, a tribe which is displaced from Quilcene Bay cannot
           move to Bellingham Bay to fish. This lack of geographical
           flexibility makes it more likely that if a net pen were to
           displace fishing activities, it would preclude opportunity for a
           tribe rather than the state, and disrupt inter-tribal fishing
           allocation agreements.

           Page 113 goes on to say that fishing opportunity could be lost
           to all fishers and, "fish return to their native streams-"
           Since the state prohibits commercial fishing in rivers, it is
           possible that some non-Indian harvest would be lost in the
           unlikely event that a fish farm eliminated all commercial
           harvest in a marine terminal area. However, it. is doubtful that
           the tribes would also forego the opportunity to harvest fish in
           the freshwater terminal area and allow, "an unnecessary loss to
           the fishing industry."







        Mr. Ron Westley
        April 5, 1989
        Page 3


        In summary, it is our opinion that the section on commercial
        fisheries does not accurately describe the management system as
        it currently operates, particularly with respect to the
        attainment of treaty/non-treaty allocation. since conflicts
        with treaty fisheries are an important consideration in the
        siting of net-pens, the section should be rewritten.

        DELAYED-RELEASE PENS

        The PEIS is deficient in its discussion and evaluation of
        environmental impacts related to delayed-release net pen
        projects. Discussion is restricted to Section B., Background on
        the Net-Pen Industry, page four, where it is stated:

             11 ... this PEIS does not specifically evaluate the
             impacts of delayed-release pens. However, many of the
             environmental impact discussions in this PEIS also
             pertain to delayed-release pens recognizing that the
             smaller size and temporary nature of the net pens will
             result in proportionally reduced impacts."

        The last sentence is true as far as it goes; however, the PEIS
        fails to recognize significant differences and potential
        interactions between delayed release and commercial net pen
        projects that are important in considering environmental
        impacts.

        Should limitations on net pen siting be imposed, either for all
        of Puget Sound (as implied by the listing of alternative levels
        of development on page eight) or in localized areas, then
        consideration of factors not included in the PEIS becomes
        important. This holds true particularly if the number of sites
        (surface area) is restricted.

        Delayed-release net pens are salmon enhancement projects. They
        produce fish that benefit the recreational and commercial
        fisheries of Washington State, whereas, commercial net pens are,
        to date, either strictly private ventures or tribal economic
        development enterprises. If there are a limited number of sites
        available for net pens, and as permits are issued to commercial
        net pen projects, then the potential opportunity for development
        of delayed-release programs may be restricted, and in some
        cases, eliminated. In other words, the development of
        commercial net pen projects could restrict future development of
        salmon enhancement projects of benefit to recreational and
        commercial fisheries. This constitutes an impact on commercial
        and recreational fisheries that is not addressed in the PEIS'
        discussions of impacts - Section B.3., commercial Fishing and
        Section B.5., Recreation.

        It is possible that a delayed release program could be
        incorporated into a commercial project as a mitigation measure.
        This option would only be possible if it were consistent with
        the regional fishery management provisions of the area where the







            Mr. Ron Westley
            April 5, 1989
            Page 4


            project is located. Development of such a delayed release
            program would need to be in cooperation with 'the State and
            treaty fishing Tribes of the area.

            IMPORTATION OF EXOTIC SPECIES

            We agree that the potential for adverse impacts from the
            accidental release of atlantic salmon is small. However, it is
            important to remember that salmon plants into the Great Lakes
            were unsuccessful for 100 years before the great successes of
            the 19601s. The inadvertent release and subsequent: explosion of
            the pink salmon population in Lake Superior is another example
            of unexpected and unwanted consequences of exotic releases. One
            safeguard against a successful colonization of an exotic such as
            atlantic salmon is the maintenance of healthy natural production
            of native stocks. Pacific salmon in the Great Lakes did not
            succeed until the native species were essentially replaced or
            depleted.

            DISEASE


            In view of the recent outbreak of VHS virus in local freshwater
            hatcheries, we recommend an updated discussion of this disease
            including its origins and method of transmission. The statement
            on page 77 that "this viral disease may be transmitted
            vertically from the adult brood fish to eggs and fry 11 conflicts
            with other recent information and should be clarified.

            The PEIS should elaborate on disease risks to wild fish from
            existing freshwater culture facilities to allow comparison of
            risks relative to net-pen operations. The severity of measures
            that are now used to correct an introduction of an exotic
     ED     disease necessitates an impact evaluation in the PEIS. We are
            referring to the decision to poison the Sooes River in response
            to the discovery of VHS disease at the Makah facility.

            ECONOMICS

            Economic impacts covered in the Appendix were largely limited to
            employment, state and local revenues, and waterfront property
            values. A detailed and informed discussion of the potential
            economic and cultural displacement of treaty and non-treaty
            commercial fishing communities is needed to complete the
            economic analysis of commercial net pen fish culture.

            Sincerely,



            Randy S. Harder
            Treaty Council Director

            RSH:ys










            RESPONSE TO LETTER NO. 14: POINT NO POINT TREATY COUNCI


            1.      The agencies listed in Section 4 are directly involved in regulating the fish farming
                    industry.   The Preferred Alternative in Section 6.3 of the FEIS includes
                    recommendations that tribes be notified of fish farming proposals through the
                    SEPA review and shoreline permit public notices to ensure that important fishing
                    areas are identified. See the response to Question 8.

            2.      See the response to Comment 1.

            3.      The text has been revised for the FEIS to clarify the       allocation process.

            4.      The scenario you suggest is also a possibility and has      been added to the FEIS.

            5.      Comment noted.

            6.      See the response to Question 21.

            7.      See the response to Question 21. The potential environmental effects of delayed
                    release facilities are substantially different in scale than commercial fish farms.
                    It is unlikely that commercial farms and delayed-release facilities will compete for
                    similar sites.

            8.      As stated in the discussion of mitigation measures in the Commercial Fishing
                    section of the DEIS, final approval of a delayed-release program incorporated into
                    a fish farm would require approval by both YVDF and tribal biologists.

            9.      Comments noted.

            10.     See the response to Question 29.

            11.     Comment noted. See the response to Question 26, and the response to Letter
                    1, Comment 16. The scope of the EIS does not include an evaluation of
                    freshwater hatchery facilities.

            12.     See the response to Question 12.





                                                                 LE17ER NO. 15


                 PORT GAMBLE KLALLAM TRIBE

                 P.O. BOX 280
                 KINGSTON, WASHINGTON 98346                          206-297-2646
                                                                       4784W3
                                                                       464-7281




       April 5, 1989




       Joseph R. Blum
       Director
       Washington Department of Fisheries
       115 General Administrative Building
       Mail Stop AX-11
       Olympia, WA  98504

       Re: Draft Programmatic EIS on Fish Culture in Floating
           Net Pens.


       Dear Mr. Blum,

       The Port Gamble Klallam Tribe appreciates this opportunity to
       review the draft PEIS on Fish Culture in floating net pens.
       The scope of the PEIS needs to be defined, please consider
       this definition, net pen culture of fish: The rearing of fish
       pecies under artificial conditions, in marine and fresh
       waters and meeting the following criteria inclusive. Fish held
       Sin unnaturally high densities that are fed a formulated diet
       and are not allowed to reproduce naturally within the culture
       operation. This definition is intended to exclude operations
       which would not functionally impact the environment as would
       net pen culture of salmon. Operations excluded from this PEIS
       would then be:


           1.   Kelp and algae culture
           2.   Herring spawn on kelp fisheries
           3.   Oyster and mussel intensive culture
           4.   Clam relay and intensive pen cu'Lture
           5.   Abalone culture where a formulated diet is not
                utilized


       Salmon net pen operation is technically advanced while the
       others listed are just developing technically in Washington
       State. To view, for permit consideration, these developing
       technologies in the same light as Salmon Net Pen operations
       will confuse, and have already caused serious confusion, to
       the very agencies that the PEIS is directed at to aid, further
       it will strongly tend to delay development and diversification
       of marine aquaculture. This very diversification of resource
       utilage is viewed by this tribe as instrumental for the futuxe
       of it's cultural development and economic viability.












             Joseph Blum
             Page two



             Please consider two major categories of net Pen fish rearing:
             1) primary rearing which is best done in sheltered, low flow
             areas and optimizes conditions for fish from smolt size to
             about .75 fish to the pound and; 2) secondary or growout
             rearing best done in high flow deep water areas. The 2
             operation modes are quite distinct in facilities, operation
             and potential impact. By requiring separation of the
             categories optimum utilage of available space will be ensured
             and impacts of every sort minimized while reducing inherent
             risk to the fish farmers. Sites under approximately 100 feet
             deep at low water should probably be reserved for the primary
             rearing mode while sites of high flow and deep water reserved
             for the 2nd mode. By formalizing this principal, which is
             .6
             already widely accepted as an optimal culture scenario by the
             industry and making it mandatory it would ensure that
             competition between farms would be directed -towards greater
             efficiency in both economic and environmental terms. I
             suggest making this principal a planned benefit of the PEIS
             that would then be quickly realized by the industry it
             self.


             Consider requiring that as a nev net pen farm is proposed that
             an intregal part of each proposal be a full economic
             evaluation aimed at predicting how the farms' production will
             effect prices paid to local commercial fishermen for their
             catch. This will incrementally tend to develop and expand the
             market available and benefit both farmer and fishermen with
             more stable growth market. *Without an indepth and responsible
             assessment of market impacts of farmed salmon upon commercial
       (D    fishermen, commercial fishermen, particularly many tribal
             fishermen, will not be able to accept the risk. Representing
             Port Gamble Klallam Tribe 'throughout the Tribes Usual and
             Accustomed fishing area, this type of economic risk combined
             with loss of fishing-area and opportunity will continue to
             prevent acceptance of large scale net pen operations. if
             other Tribes view the concern similarly the area available for
             private net pen operations in the State of Washington will
             never expand significantly over what is now already utilized.
             It would be in the best interest of all parties concerned to
             have an ongoing economic assessment built into the
             Programmatic Environmental Impact Statement.
            a
             S,
                 erel



            'Crr-ai g A. Olds
             Port Gamble Klallam Tribe
             Fisheries Manager










          RESPONSE TO LETTER NO. 15: PORT GAMBLE KLALLAM TRIBE


          1.     The scope of the EIS is defined in the Fact Sheet and Summary as the evaluation
                 of the commercial culture of fish in floating net pens. The other forms of
                 aquaculture you mention are not within this sco e.                                    0
                                                                p

          2.     Comments noted.

          3.     Comments noted. It is outside the scope of this  EIS to evaluate the economic
                 relationship between farm fish production and prices paid to the commercial
                 fishing industry.





                                                                           LETTER NO. 16







             18 March 1989



             Ron Westley
             Project Manager
             Washington Department of Fisheries
             115 General Administration Building
             Olympia, Wa. 98504
             (206) 753-6642




                         COMMENTS ON FISH CULTURE IN FLORTING NET PENS


                                        JRNURRY 1989 PEIS



                  My review of this PEIS left me with two separate categories of feeling.
             The first was one of outrage and indignation over the fact that the
             Department of Fisheries would have the audacity to use public monies to fund
             such a blatant attempt to favor a category of private special interests which
             the general public has expressed not only no support of, but generally has
             vigorously opposed. The second was of greater distress to realize that the
             same department had accepted a product from a consultant that not only is
             extremely lacking in objectivity, but is simply not accurately done, and thus
             of little or no value. The comments which follow are intended to develop
             these two lines of thought.



                                   OUTRRGE RNO INDIGNRTION COMMENTS


             .1.  After a review of SEPA Rules under Chapter 197 - 11 WAC, I have
             concluded that I am unable to find any legitimate status for a
             "Programmatic" Environmental Impact Statement as part of the SEPA
             process. Time for commenting does not permit a thorough research of this
             point, however even if there is some administrative practice or regulation
             for doing a PEIS, the Department of Fisheries should remain in a regulatory
             role not an advocacy role. This PEIS is simply a thinly veiled attempt to
             provide a "Generic" EIS for all time for net pens in Puget Sound.







                                                                                        2


              2.    The statement of item "J" of the Fact Sheet needs to be clarified by the
              inclusion of a statement saying "this PEIS was conducted for evaluation
              purposes only and the required case-by-case SEPA reviews conducted on
              subsequent projects are not limited in any respect by the findings or
              conclusions herein". This would make this item consistent with the
              statement on page x following Phased Review.

              3.    1 find it difficult to understand why the Department of Fisheries would
              issue a document such as this. Your proper role is to manage the natural and
              hatchery fishery resources of this state for the benefit of: state as a whole,
              commercial and sport fishery alike. This proposal has significant negative
              impacts to both. It competes with and offers high risks to the very resources
              you are supposed to be protecting and enhancing. Why should the public tax
              itself to clean up the Sound while you actively promote a program which
              introduces vast new pollution sources?

              4.    Public money would be better spent on puttin(
                                                              .) together a strong WAC
              which covered "Minimum Functional Standards for Fish Culture in Floating
              Net Pens". The remaining questions regarding Net Pens can be accommodated
              within the SEPA Rules process alone, at the local level.


                             Lack of Objectivity and Rccuracy Comments


              1.    The Summary or Abstract of a document is very important because
              most  people trust them, and in fact will either read only the Summary or
              perhaps at least decide how much of the rest of the report to read, based
              upon what they find in it. The Summary presented on pages ix and x is not
              objective nor is it accurate. It does not even coherently convey the material
              contained within itself. The Summary does not even make good sense on its
              own terms. An example of this is contained on page x which I have reproduced
              below:


                    "UNAVOIDABLE SIGNIFICANT ADVERSE IMPACT: No unavoidable
              adverse impacts were noted; however, efforts to minimize some impacts may
              exacerbate others. Thus in particular situations adverse impacts may be
              unavoidable." (sic)

                    This passage is perhaps the most specious one in the entire report.
              Notice first that the key word SIGNIFICANT appears only in the bold and
              underlined subtitle, not in the statement that follows it. The writer would
              like us to believe that there are some adverse impacts, that efforts to







                                                                                        3


            minimize them may make some some of these worse, and perhaps unavoidable
            in particular situations. Most of all, the writer wants us to believe that none
            of these unavoidable adverse impacts could possibly be SIGNIFICANT! The
            factual material in the text of the report itself will not support this view,
            even those facts contained elsewhere in the Summary will not.

                  Is what we are asked to believe true? I do not think so, but let us
            check. Examine the preceding section of the Summary, and note that the
            writer lists eight categories of "MAJOR POTENTIAL IMPACT". Here again the
            writer chose not to use the word Significant, which has a clearly defined
            meaning under SEPA. The word Major was used, which has no meaning under
            SEPA when used independent of Significant (please see WAC 197-11-764 and
            794). The heading should read "MAJOR POTENTIAL SIGNIFICANT IMPACTS...."
            since there is a reasonable likelihood of more than a moderate adverse
            impact on environmental quality in each of these eight areas of concern.

                  Having established that the PEIS has identified eight Potentially
            Significant Impacts; the question is simply which, if any, are unavoidable.
            Actually there are only seven impact areas because of Item 8. on page x . This
            Item does not even come under the title given on page ix. Item 8. is a non
            sequitur, since it does not cite a major or significant adverse anything,
            impacts included. Nor does this Item present any mitigating actions. My view
            is that all of the remaining seven are unavoidable. For sake of argument, I
            submit that five of these are clearly unavoidable based on simple logic and
            the facts stated in the summary alone. These are Items 1,3,4,6,&7. The
            reasons are explained in individual paragraphs that follow.

            2.    The impact to navigation in item 7. is clearly an unavoidable one. We
            are not considering the installation of a small floating aids to navigation
            here. We are not talking about a clam or oyster bed either. The size, profile,
            and obstructive nature of their presence, makes floating fish pens a hazard
            to safe navigation; particularly at night and during low visibility. There is no
            means to effectively mitigate against this hazard. As the summary correctly
            states, the mitigations of items 1.and 6. conflict with attempts to mitigate
            this problem.

            3.    The very wording of item 6. says "Visual impacts cannot be avoided and
            their significance will depend upon the specific site and the perceptions of
            the viewers". This is probably the most accurate statement of fact in the
            report. I think it means the visual impact is "unavoidable". Since the
            significance of visual impacts are dependent upon the perceptions of the
            viewers, this in itself betrays a recognition by the writer of a definite
            unavoidable element in impact assessment.







                                                                                               4



                4.    Item 4. is missing the word the before greatest, but goes on to say
                that careful screening can minimize, but not eliminate the risk of disease.
                That appears to be a fair description of an unavoidable situation. The report
                itself contains the following statement on page 73:1 "The introduction of an
                exotic species into a new area always posses (sic) unavoidable risks." This    is
                an example of how the authors have correctly reported a fact within the
                report, but turned it around and put a "good face" cn it by the time it got to
                the Summary. Fortunately, the document was done incompetently enough to
                include a spelling error at this key point. Thus one has reason to pause here
                and reflect upon what is being said, and compare it to what had been stated
                previously in the Summary. There is no question that risk of disease is an
                Unavoidable and Major Potential Significant Adverse Impact within both the
                context of this PEIS itself and SEPA.

                5.    Item 3. says escaped non-native fish could establish self-sustaining
                populations and further that some escape is inevitable. The mitigation
                proposed is mere fantasy; however, the facts stated clearly describe an
                "unavoidable impact" and one that is as inevitable as escapes are.

                6.    Item 1. describes the process by which the pollution from a net pen
                eliminates all animals immediately below it unless the material is dispersed
                by currents and deep water. Therefore dilution is the solution to the
                pollution. This clearly indicates that the pollution itself is unavoidable but it
                can be mitigated in some cases. The question is, should all of these
                additional unavoidable sources of pollution be placed in the Sound? The PEIS
                is strangely silent in this regard.

                7.    The part of the Summary titled MAJOR CONCLUSIONS OF THE DRAFT
                PEIS, is where the authors failed most in providing good service to the
                taxpayer. These are not conclusions of the kind one finds in a competently
                prepared technical paper or proposal. One where the foundation is evidence
                and verifiable facts that are assembled within the limits of a disciplined and
                proscribed process. One where opinions are always based on the evidence or
                facts from which the they were derived. Finally, where conclusions can be
                traced back thru the opinions to the basic facts and evidence. This document
                severely lacks that integrity and has lost contact with the facts along the
                way. We are offered illusions under the heading of conclusions! A brief
                discussion of each of the four Items in this section follows:

                      ITEM 1 - This statement has the same problem with the lack of the
                word significant and improper use of major as was: explained in paragraph 1.
                above. The implied conclusion is that there are no significant impacts and all







                                                                                          5


            that remain are trivial and can be made to go away in every case by site
            selection alone. The unfortunate truth is that the body of the report does not
            support such a conclusion. The impacts to pollution, navigation, and visual
            are potentially significant in every instance. Mitigation measures for these
            criteria are generally mutually in conflict with each other. To say that these
            impacts "can be prevented by proper siting" is simply not true. This
            conclusion should be reworded to read "The major significant impacts of net-
            pen culture can be mitigated in some cases by proper farm siting to assure
            dispersion of wastes, flushing of the site, and protection of sensitive areas.
            Success will be limited because many of such measures will be in direct
            conflict with each other."


                  ITEM 2 - The idea that the removal of net pens holds the key to reversal
            of any and all impacts is ridiculous. How can native stocks killed off by
            exotic disease and non-native self-sustaining populations of the inevitable
            escapees which successfully replace native stock, be reversed by pen
            removal? A proper conclusion is that some, but not all impacts, can be
            reversed by pen removal.

                  ITEM 3 - This report makes no basis to support the use of the word
            accidenta    in this conclusion. The conclusion is correct when accidental is
            deleted. We are intentionally introducing non-native fish that present
            definite risks of carrying exotic diseases such as VHS, known to be common
            to them yet,  disastrous to native species due to their susceptibility. We are
            not talking about an accident, this is an anticipated event for which we
            simply do not know the exact where or when it will occur. Introduction of
            disease will not be accidental, it will be the proximate result of an
            intentional action.


                  ITEM 4 - The report quite definitely does not support the conclusion
            that 100 farms would not have a significant impact on the aquatic
            environment. The section titled CUMULATIVE IMPACTS IN PUGET SOUND, on
            pages 131,132 and 135 says the opposite. There we read that the 100 pen
            production level is considered by some to be in gKcess of that which could be
            permitted. We also read that 100 pens produce a BOD loading greater than any
            single sewage treatment plant. This section ends with the statement
            "Furthermore, conflicting uses of the water (navigation, fishing,aesthetics)
            may limit the number of farms to production levels well below the maximum
            production levels considered here." These are hardly the kind of factual
            statements needed to support such a sweeping conclusion regarding the
            probable impact of 100 pens! The statements in the text are accurate. The
            conclusions provided in the Summary clearly show a distortion that is not
            consistent with the facts reported in the text.







                                                                                          6





                                           RECOMMENURTIONS:


                    I recommend that this PEIS be rejected as unacceptable by the
               Department of Fisheries due to the many inaccuracies it contains and the
        G
               lack of professional competence that it exhibits. This document reflects
               unfavorably upon the Department and the State of 'Washington itself. No
               further expenditures of public funds should be awarded to the parties who
               prepared it. The possibility of recovering as much public money as possible
               from the contractor(s) involved should be investigated.

                    In conclusion, I strongly suggest that the Department of Fisheries
               concentrate the limited resources it has on creating and maintaining a strong
               WAC that establishes a rigorous set of "Minimum Functional Standards for
               Net Pens". Your job is to protect and enhance the natural fishery resources of
               this state, not to help pave the way for their elimination for the financial
               benefit of a few!



               Sincerely



               T. Carl Pickel Jr.
               P.O. Box 869
               Allyn, Wa. 98524

               Phone: (206) 275 - 4680

               Copy to:

                   Puget Sound Water Quality Authority
                   Hood Canal Environmental Council
                   Mason County Commissioners









            RESPONSE TO LETTER NO. 16: T. CARL PICKEL, JIL


            1.    Comment noted.
                                                                                                           U
            2.    See the response   to Question 2.

            3.    A programmatic EIS is called a nonproject EIS in SEPA (WAC 197-11-774). See
                  the response to Question 1.

            4.    Review of proposals under     the State Environmental Policy Act should use all
                  relevant and available information.         This EIS provides information to
                  decisionmakers and does not limit any future SEPA review.

            5.    As stated in Section B of the Fact Sheet, V;DF was directed by the Washington
                  State Ugislature to prepare this EIS.

            6.    Comment noted.

            7.    The Summary of the EIS has been rewritten for the FEIS to include a brief
                  discussion of each issue.


            8.    Comment noted.

            9.    Comments noted.     See the response to Question 10.

            10.   Comment noted.

            11.   Comments noted.     It seems as though the reviewer is saying that unless there is
                  absolutely no possibility of any risk, the EIS must state that exotic disease
                  introduction is a potential significant adverse impact. We do not agree.

            12.   See the responses to Questions 22, 23, and 24.

            13.   Dispersion of waste from farms over a larger area minimizes significant
                  accumulation and allows bottom organisms to assimilate the organic waste.

            14.   The purpose of an EIS is to discuss the environmental impacts of a proposal and
                  provide information to decisionmakers to allow them to make intelligent decisions.
                  The format and purpose of an EIS is not the same as that of a scientific research
                  paper.

            15.   Comments noted.


            16.   Comment noted.


            17.   Comments noted.








              Response to Utter No. 16: T. Carl Pickel, Jr. (continued)

               18.    Item 4 inthe DEIS Summary states that 100 farms, pro].:)erly sited in Puget Sound,
                      would not have a significant impact on the aquatic environment. However, Item
                      4 goes on to state that small bays could be adversely affected by overdevelopment.

                      The Cumulative Impact section of the DEIS states in the first paragraph that the
                      analysis of different levels of farm development was used to determine if there
                      was an upper limit of fish farm development in Puget Sound beyond which water
                      quality as a whole would be reduced. The EIS found that the effects of 100 fish
                      farms properly dispersed throughout Puget Sound would not have a significant
                      impact on Puget Sound water quality.
                      In addition to the existing 13 farms, the alternatives of 25, 50, and 100 farms
                      represent a range of development. As stated in the EIS, the number of uses
                      competing for space on Puget Sound will probably prevent 100 farms from being
                      sited. Competition for space on Puget Sound will limit the overall development
                      of the fish farm industry, not the effect on the aquatic environment of properly
                      sited farms.


               19.    Comments noted.






                                                                   LETTER NO. 17
                                         STA



 KATHERINE FLETCHER
     Chair

                                  STATE OF WASHINGTON
                     PUGET SOUND WATER QUALITY AUTHORITY
                   217 Pine Street, Suite I I(A) 0 Seattle, Washington 98 101 o (206) 464-7320





          March 20, 1989

          Ron Westley
          Project Manager
          Washington Department of Fisheries
          115 General Administration Building
          Olympia, Washington 98504

          Dear Mr. Westley:

          Thank you for the opportunity to comment on the Draft
          Programmatic Environmental Impact Statement for Fish Culture in
          Floating Net Pens. The document provides a great deal of useful
          information that should help resolve issues surrounding the
          development of this industry in Puget Sound, and we commend the
          ef f ort your staf f has put into it.   We do feel that additional
          documentation and analysis is needed on certain of the topics
          covered. Our comments address those areas.

          our primary concern is that while the document is titled
          "programmatic", it proposes and analyzes no program for managing
          net-pen development in Puget Sound.       The draft PEIS concludes
          that up to 100 farms could be properly sited in Puget Sound. To
          translate this conclusion into a programmatic proposal, it will
          be important for the public to evaluate how siting and mitigation
          decisions will be made and by whom. It is our hope that the
          Department of Fisheries will clarify in the PEIS (1) what
          implementation steps are being proposed; and (2) how public
          comment will be considered before the program is put into effect.

          We suggest reframing the alternatives analysis from numbers of
          farms (25, 50, 75, 100) to types of management strategies,
          including a preferred alternative management system. Our reading
          of the legislation (ESHB 1221) leads us to think this kind of
          analysis would be consistent with your charge.

          Additional general comments on major elements of the draft PEIS
          are listed below:


          1.   A discussion should be included in the final PEIS to clarify
               the use of the PEIS versus the need for site-specific EISs
               for new proposed facilities given that specific siting is
               such a key concern.     This issue is obviously linked to the










             Mr. Ron Westley
             March 10, 1989
             Page  2



                   nature of the management/siting program discussed above.

             2.    How does this document relate to the existing Recommended
                   Interim Guidelines for the Management of Salmon Net-Pen
                   Culture in Puget Sound? The final PEIS should evaluate the
                   effectiveness of these guidelines and recommend revisions
                   where necessary,    assuming that these guidelines will
                   continue to be used.

             3.    As correctly stated in the Summary, efforts to minimize some
                   adverse impacts may exacerbate others. This document could
                   help resolve this problem by weighing the pros and cons of
                   the actions that are designed to minimize each environmental
                   impact.   The environmental trade-offs associated with the
                   proposed mitigation actions should be more thoroughly
                   addressed in the final PEIS.

             4.    This document should include an analysis of how many
                   potential sites actually may be available for the siting of
                   floating net-pen facilities in Puget Sound, given the full
                   range of environmental constraints that are discussed in the
                   document.   It should be possible to do some modelling to
                   generally identify the number acres of potential sites (not
                   specific locations or boundary delineations).

             5.    While we assume that avoiding impacts to wetlands will
                   be part of the siting criteria, the PEIS should include
                   a discussion of the potential for significant adverse
                   impacts to wetlands in the development of net-pen
                   support facilities.

             6.    The impacts associated with each alternative listed on page
                   8 should be discussed more specifically.

             7.    The final PEIS should include a discussion of the components
                   of a detailed water quality monitoring program for each net
                   pen facility.

             8.    Especially given the high degree of public interest and
                   the sometimes conflicting information in the media and
                   @lse where, a more thorough discussion should be
                   included about the net-pen industry and research on the
                   occurrence of fish diseases in Norway and British
                   Columbia and other countries.

             The   Authority staff will provide additional specific comments

                                               2











       Mr. Ron Westley
       March 10, 1989
       Page 3



       under separate cover f or your use in revising the PEIS.      These
       comments focus on issues of water quality, fish disease and
       genetic impacts, and impacts on benthic biota.

       Thank you for the opportunity to comment on this Draft PEIS on
       f ish culture in floating net pens. If you have any questions
       regarding these comments, please feel free to contact me or my
       staff Joanne Richter at Scan 576-6891.


       Sinc e y,



        atherine Fletcher
       Chair
        1
         n   ely'
          c
          r@
         t r
       ;@ahe ine Fletcher






                                        3









                RESPONSE TO LETTER NO. 17: PUGET SOUND WATER QUALITY AUTHORITY
                KATHERINE FLETCHER


                1.     The DEIS did not conclude that 100 farms could be properly sited in Puget
                       Sound. As stated in the DEIS Summary, with proper siting 100 farms would not
                       have a significant impact on the aquatic environment. There has been no attempt
      0
                       to evaluate site-specific factors to identify 100 potential farm sites. The text has
                       been revised for the FEIS to evaluate regulations and guidelines and includes
                       recommendations for further actions that State agencies and local governments can
                       take to further address potential adverse impacts.

                2.     Comment noted. The alternatives have been changed for the FEIS to evaluate
                       the regulatory framework that affects the fish farming industry.

                3.     The text has been revised to assess current regulations and guidelines in the FEIS.
                       As stated in the FEIS Summary under Phased Review, this FEIS can be used by
                       state agencies and local governments to assist them in making SEPA threshold
                       determinations, shoreline permitting decisions, help them define additional
                       information that may be required of a fish farm proponent, and help them
                       properly site fish farms in Puget Sound.

                4.     The EIS has been revised to include an evaluation of existing regulations and
                       guidelines, and includes recommendations for revisions to the existing framework
                       for managing the fish farming industry.

                5.     See the response to Question 10.

                6.     To produce a reasonably accurate count of potential sites in Puget Sound would
                       require considerable site-specific analyses, which are outside the scope of this
                       programmatic EIS.

                7.     The scope of this EIS does not include an evaluation of the potential environmen-
                       tal impacts of support facilities associated with floating fish farms. Any land-
                       based support facilities would have their own SEPA review process.

                8.     The alternatives have been changed for the FEIS.

                9.     A detailed water quality monitoring program should be addressed in a manage-
                       ment plan. It is outside the scope of the EIS.

                10.    The Appendices have been expanded to provide additional information on
                       management programs and regulations in Norway and British Columbia. See
                       Appendix H.





                                                                                              LETTER NO. 18

                                                           STA



 KATHERINE FLETCHER
       Chair

                                                  STATE OF WASHINC;TON
                              PUGET SOUND WATER QUALITY AUTHORITY
                           217 Pine Street, Suite 11W 9 Seattle, Washington 98101 e (206) 464-7320





                                                     March 21, 1989

               Ron Westley
               Project Manager
               Washington Department of Fisheries
               115 General Administration Building
               Olympia, Washington 98504

               Dear Mr. Westley:

               Attached are additional specific comments from PSWQA staff on the
               draft PEIS for Fish culture in Floating Net Pens. We hope these
               comments are helpful to your and your staff. We would be happy to
               sit down with you to discuss these comments, if you like, and
               provide specific language or other assistance. We are certainly
               aware of all the hard work and long hours that must of gone into
               preparing the draft and hope that the attached comments will
               assist in your revisions.

               Please feel free to call either me or my staff Joanne Richter
               (Scan 576-6891) if you have any questions regarding the comments,
               or if you would like to set up a meeting in Olympia.

               Sincerely,


               Kirvil Skinnarland
               Director of Planning and Compliance












             ADDITIONAL PSWQA STAFF COMMENTS ON NET PEN DRAFT PEIS




             Pacre                              Comment


                        The   document should discuss the possibility             of
                        eliminating imported broodstock in favor of reliance on
                        Puget Sound (Pacific salmon) stocks.

                2       The second paragraph from the bottom should reference
                        the page numbers in the document where "approaches to
                        regulatory agencies could use to best manage this
                        industry" are discussed. This is a major issue for the
                        PEIS to analyze.      We were not able to locate this
                        discussion in the document.

                4       Background should include a discussion of tribal
                        involvement in net pen operations. Also, there should
                        be a recognition that siting criteria must include a
                        requirement that there be no interference by net-pen
                        operations with tribal usual and accustomed fishing
                        areas.


                8       Under Permits and ARDrovals, further discussion is
                        needed on how "these rules may be modified as the
                        result of this PEIS.11

                8       Under Substantial Development Permit (WAC 90.58) insert
                        "except    single    family    residences"    after     "All
                        development activities."

                9       Under Water Discharge Permit (RC.W 90.48) update the
                        discussion to reflect Ecology's recent adoption of
                        policy on state waste discharge permits for aquaculture
                        facilities.

               11       The discussion on Section 404 should be moved to page
                        10 under Permits and Approvals.       Also, at the end of
                        this sentence add "into waters of the state."
                        Following the description of the            Department    of
                        Agriculture, include a discussion of the Puget Sound
                        Water Quality Management Plan.            We suggest the
                        following language:

                        Puget Sound Water Quality Authority.        The Washington
                        State Legislature established the Puget Sound Water
                        Quality Authority in 1985 in recognition that Puget
                        Sound is a "unique and unparalleled resource" and that
                        its utilization carries a "custodial obligation for

                                                1









                    preserving it"    (RCW 90.70.001).      The Legislature
                    charged this agency with preparing the Puget Sound
                    Water Quality Management Plan, to be implemented by
                    existing state and local government agencies.          The
                    Puget Sound plan was originally adopted in December
                    1986 and was recently revised and adopted in October
                    1988. While this plan imposes no additional permitting
                    requirements   on    net-pen   or    other    aquaculture
                    facilities, state agencies and local governments are
                    required to carry out their own statutory mandates in a
                    manner consistent with the plan. The goal of the plan
                    is to prevent increases in the introduction of
                    pollutants to the Sound and its watersheds and to
                    reduce and ultimately eliminate harm from the entry of
                    pollutants to the waters, sediments, and shorelines of
                    Puget Sound.

           13       Under   Affected   Environment,   clarify   whether    the
                    discussion pertains to net pen facilities located in
                    Puget Sound or located around the world. For example,
                    are most net pens in Puget Sound "sited in areas having
                    fine-grained sediments and moderately flat bottoms?"

           17       In the last sentence of the fourth paragraph, clarify
                    what the ranges of organic carbon and nitrogen values
                    refer to (i.e., worst case vs. typical Puget Sound?).

           17       Last paragraph: Benthic infauna and small epifauna are
                    of greater importance to the benthic food web than
                    macrofauna.    Infauna and small epifauna should be
                    highlighted (or at least mentioned) for risk for burial
                    and filter clogging due to excessive sedimentation of
                    organic matter.

           24       In the second sentence of the second paragraph, clarify
                    where the "redox potential at the southeast corner was
                    strongly negative."

           24       The second to last sentence in the third paragraph is
                    misleading. Few net pens have been installed using the
                    Recommended Interim Guidelines, and they have not been
                    in place long enough to show significant accumulation
                    of sediment (whether they were sited properly or not).
                    This statement also highlights the need for the final
                    PEIS to include an analysis of the adequacy of the
                    interim siting guidelines and specific recommendations
                    as to how they should be amended, based on information
                    developed for the PEIS.

           25       Factor 2. Pen size needs to be rewritten to clarify.
                    For example, "with the same loading" (as what?); "over
                    a relatively smaller area" (than what?)        "thus the

                                           2









                        effects" (of what?); "the area affected is less" (than
                        what?).

              27        Under Mitigation Measures, the recommendation to "use
                        mechanical techniques such as vacuuming to remove
                        accumulated wastes under the pens" should be deleted.
        G               This practice could result in significant harm to
                        existing benthic communities, which might be worse than
                        allowing wastes to accumulate.

              27        In the second sentence under Unav)idable Adverse
                        ITD@cts,   indicate that "impacts Rrobably can be
                        minimized  ...  by the methods presented above."        The
                        methods may not always minimize every benthic effect in
                        every situation.

              28-33     There are inaccuracies in the description of Puget
                        Sound circulation, as well as omissions as to seasonal
                        effects on stratification. Authority staff could work
                        with WDF staff to improve discussions of vertical
                        stratification   and   its   effect   on   nutrient     and
                        phytoplankton dynamics.

              35        The first sentence under Affected Envirgnment should be
                        followed with:    "In addition, the Puget Sound Water
                        Quality Management Plan lays out a coordinated long-
                        range strategy for protecting Puget Sound and its
                        resources.    It is implemented by Ecology and other
                        state   agencies   and   by   local   governments,     with
                        cooperation by the tribes and federal agencies."

              35        In the second sentence of the last paragraph, clarify
                        that failed on-site wastewater disposal systems are a
                        primary source of bacteria problems, and add the
                        following sources to this list: stormwater, and boats
                        and marinas.     Also add:     "Other sources of water
                        quality   impairment    include   erosion    from    forest
                        practices and streambank alterations, and loss of water
                        quality functions due to degradation or destruction of
                        wetlands."


              35        The third sentence in the last paragraph needs to be
                        referenced to properly document the statement that
                        "natural factors ... are the primary source of organic
                        enrichment and dissolved oxygen problems in Puget
                        Sound." How does "natural" organic enrichment compare
                        to organic loadings contributed from municipal sewage
                        treatment plants, combined sewer overflows, failing
                        septic tanks, stormwater, and industrial sources such
                        as pulp mills?


                                               3









            37        The last sentence in the second to last paragraph
                      needs to be referenced to substantiate the statement
                      that  "dissolved oxygen problems also occur in many
                      areas  in summer and fall from the natural upwelling of
                      deep  bottom waters.       This is generally not true in
                      Puget Sound.

            39        Under Turbidity, the second to last sentence in the
                      first    paragraph     needs     further     discussion      to
                      substantiate the statement that "the loss of fish food
                      and feces from net pens would also increase turbidity,
                      but to a lesser degree than net cleaning."

            45        Second to last paragraph:           Effects of additional
                      nutrient inputs to the water column are described which
                      do not take into account whether waters are nutrient
                      limited.     If nutrient limitation is not occurring,
                      ratios of nitrogen in the water column and in
                      phytoplankton are irrelevant. Also, it is confusing to
                      say that plankton assimilate nitrogen from the water-
                      zooplankton excrete dissolved nitrogen.

            46-47     References     to   Thom    et   al.    (1984,    1988)     are
                      inappropriate as these studies were all conducted in
                      waters of less than 10 meters depth. Net pen siting in
                      such shallow waters is not practicable.

            48        The second sentence on this page should be preceded by
                      a description of the October 1988 outbreak of PSP in
                      South Puget Sound.

            48        After the second sentence of the first paragraph, note
                      "however, some researchers believe nutrient blooms may
                      contribute to outbreaks of some Gonvaulax.11

            49        Third paragraph:       Nutrient limitation is again not
                      taken into account in this rationale.

            51        Sensitive Area Management: In Puget Sound embayments,
                      temperature,     rather than salinity        is the major
                      contributor to vertical stability, particularly during
                      the summer and fall periods cited.

                      Areas with low phytoplankton standing crop- should be
                      targeted only if they are not nutrient-limited at any
                      time throughout the year.

            51-52     The discussion of using nitrogen flux as an index of
                      nutrient sensitivity is very hard to follow. It is not
                      clear where nitrogen is fluxing from, or to; nitrogen
                      is thought to flux from the atmosphere, from below the
                      pycnocline, from plants, animals, and detritus.

                                               4












               52-55     The nutrient box model shown is difficult to follow.
                         The implication that phytoplankton respire dissolved
                         nitrogen is difficult to understand.           Leakage from
                         phytoplankton and zooplankton are not shown (or that
                         "phytoplankton     respiration"'),    and    detritus     (the
                         largest source and sink of small particulate nitrogen
                         in the system) is not shown at all.

               56        Table 2: Units in this table should be checked.

               57        Mitigation Measures, bullets 8 & 9:           Use of slower
                         sinking feed and more digestible feed are a two-edged
                         sword - both will increase the diffusion and leakage of
                         nitrogen from feed into the water column, thus
                         increasing the nitrogen source which the measures seek
                         to control.

               59        The entire fourth paragraph should be rewritten for
                         clarity.

               64        We question whether operation of' aerators under low
                         hypoxic conditions could result in net-pens having a
                         positive impact on dissolved oxygen.           Occurrence of
                         such low oxygen conditions might indicate either
                         excessive crowding, or inappropriate siting in areas
                         prone to low dissolved oxygen problems.

               65        Oysters are not limited to intertidal beaches.           Puget
                         Sound also contains areas where oysters are cultured
                         subtidally.

               67        In the second line, add the word "invertebrates"
                         between "immobile" and "will."

               69        In the second to last sentence in the second paragraph,
                         add the word "species" after "native."

               70        The last sentence in the third paragraph needs to be
                         rewritten because it tends to downplay the possibility
                         that net-pen Pacific salmon and indigenous populations
                         of salmon could interbreed.        More discussion of this
                         issue is needed.

               71        Statements    in the second paragraph need to be
                         substantiated with references.

               71        The last paragraph states that "net-pen fish do not
                         necessarily have to be very (genetically] different
                         from wild fish.      Efforts can be made to infuse wild
                         genes into the hatchery population if desired."           What
                         source of wild genes is envisioned for this purpose?

                                                  5









                    This concept seems inconsistent with the Mitigating
                    Measure on page 80 recommending development of regional
                    broodstock.

           72       Statements  in   the   third  paragraph   need   to be
                    substantiated with references. Deleterious genes which
                    undergo balancing selection can persist in populations
                    indefinitely.

           73       The second sentence on this page could be misleading.
                    Not all of the nine million cultured smolts that are
                    released annually into Puget Sound live to reproduce,
                    as implied. Since post-smolt salmonids have much lower
                    mortality rates than juveniles, escaping sub-adults
                    fish may actually have very high rates of survival.

           73       A worst case estimate of escapement from net pens
                    should be provided.   The statement that "it is highly
                    unlikely that escapement from net-pen farms would
                    approach this number" needs to be substantiated by
                    reference. There are indications that large numbers of
                    Atlantic salmon have been accidentally released in
                    Puget Sound. An estimate of these releases and their
                    impacts on Puget Sound fish and fisheries should be
                    included.

           74       In the last paragraph, "Waknitz 198811 needs to be added
                    to the list of references.         Also, a referenced
                    discussion should be added as to whether Atlantic
                    salmon are caRable of spawning in Puget Sound rivers,
                    and if not, why not.

           75       In the first clause under Mitigation Measures, how is
                    "probable risk"    defined or determined?      (in the
                    statement "deny applications that pose a probable risk
                    of adversely affecting native fish stocks").

           75       We suggest that these Mitigation Measures be clarified
                    and elaborated on. For example, should stocks be used
                    which have the greatest similarity or dissimilarity
                    from nearby wild stocks? Which alternative is better?
                    What minimum distances should net pens be sited away
                    from streams with wild populations?     Should net pens
                    also be sited minimum distances from hatcheries?       Is
                    the technology of producing sterile or mono-sexual fish
                    currently available?    Do any existing operations use
                    this technology? Also, because so many concerns about
                    disease and genetic impacts hinge on escapement rates,
                    we suggest that the following be considered: that some
                    percentage (five percent, or so) of all net pen fish be
                    coded wire tagged so that escapements can be monitored.
                    If recovery in fisheries and on spawning grounds proves

                                          6









                        to be minimal over a f ive to ten year period, tagging
                        could be discontinued.


              75        Mitiaation Measures should address the need for
                        specific, practical measures for maintaining adequate
                        genetic   diversity,    with    or   without     continued
                        importation of gametes.    The  long term propagation of
                        finite breeding populations inevitably leads to loss of
                        genetic diversity, and this loss may be accompanied by
                        a gradual increase in disease susceptibility over many
                        generations.

              77        The last sentence in the third full paragraph needs to
                        be replaced with a description of the February 1989
                        occurrence of VHS and an analysis of its probable
                        origin. The discussion should also include possible VHS
                        prevention measures.

              78        In sentence one of the f irst paragraph, add the words
                        "and tribal" between "state" and 11resources.10

              79        Given the recent heightened public concern about f ish
                        diseases, it would be useful to include a discussion of
                        disease problems associated with Atlantic salmon
                        farming in Norway and Scotland or elsewhere in the
                        world.

              so        In paragraph one, the appropriateness of the statement
                        that husbanded stocks of animals are usually at greater
                        risk from the transmission of infectious diseases from
                        wild stocks should be documented.            Unlike many
                        domesticated    animals,   net-pen    salmon   exist     in
                        environments containing large populations of wild fish.

              80        The document does not discuss Canadian regulations to
                        prevent introduction of diseases.        With the large
                        numbers of net-pen farms in British Columbia, are
                        adequate measures in place to reduce the risk of
                        disease transmission across the Canadian border?

              95        Modify the f ourth sentence in the second paragraph as
                        follows: "...perpendicular to shore has the greater
                        visual impact at distances greater than 600 feet,
                        although... 11

              96        Figure 17 should be clarified by the following
                        additions:   the units of the horizontal axis of all
                        three diagrams should be labelled as being in feet; and
                        the horizontal angles of view occupied by the net pen
                        should be added in diagrams A and B.

              98        In the second paragraph, it needs to be clarified what

                                               7










                   Figures 19, 20, and 21 are trying to show. Is net-pen
                   density control using area by square footage preferable
   G               to using area by shoreline footage or area by radius?
                   What are the advantages and disadvantages of each?
                   Clarify what "similar measures could be adopted into
                   local shoreline master programs."

         107       Table 5 is missing from the document.

         113       Fourth paragraph:   It may not be possible to provide
                   fishers with compensatory fishing opportunities for
                   fishing areas displaced by net-pens. Depending on the
                   specific site, fishing even in relatively nearby areas
                   may result in decreased catch per unit effort or
                   undesirable levels of harvest of non-targeted stocks,
                   thus upsetting harvest management or allocation goals.
                   Consideration should be given to avoiding the siting of
                   facilities in areas where such conflicts could occur.

         114       In the first Mitigation measure, insert "the tribes,"
                   before "commercial fishing organizations." In the last
                   Mitigation Measure, insert the words, "and tribal"
                   after 11WDF.11

         117       In the third paragraph under Impacts to Human Health,
                   the first two sentences are not well linked; there
                   appears to be some missing information.       Also, as
                   stated in the last sentence of this paragraph, it is
                   doubtful that "fish farming may help prevent shoreline
                   activities that contribute bacterial contamination to
                   embayments..."

         118       In the first sentence under Mitigation Measures, insert
                   "that are" after "Puget Sound."

         120       In the first clause under Mitigation MeAsures, insert
                   "of" after "placement."

         121       The first paragraph under Affected Environment needs to
                   be rewritten to clarify what Leq refers to.            In
                   addition, insert the fourth sentence after the first.

         122       In the last sentence of the second paragraph, define
                   Ldn-

         12 6      This section needs to discuss wetlands protection, as
                   explained in comment #5 under general comments.        it
                   should also discuss the need for sources of fresh water
                   to supply on-shore ancillary hatchery facilities.

         126       The Authority's State of the Sound Renort projects a 20
                   percent population increase in Puget Sound by the year

                                         8










                        2000.    The Authority could assist WDF in obtaining
                        accurate population growth projections.

             129        The   discussion    of    Impacts    of   Alternatives     is
                        incomplete. For example, no analysis of' the impacts of
                        net-pen facilities on shoreline property values is
                        discussed.

             130        The last paragraph under Impacts to Local Services
                        needs to be rewritten for clarity.

             131        In the section titled CUMULATIVE IMPACTS IN PUGET
                        SOUND, the analysis of the impact of various levels of
                        net-pen development should include additional factors
                        besides water quality.        The upper limit of Puget
                        Sound's capacity for net pens is not limited only by
                        water quality concerns, but by a whole suite of siting
                        criteria as discussed in the PEIIS.       In addition, the
                        reference to "excessive" degradation in the second
                        paragraph is inconsistent with state and federal water
                        quality laws that include an anti-degradation policy.

             131        Second paragraph:      Scientists and managers no longer
                        feel that assimilative capacity is a valid concept that
                        can be used to examine loading to complex estuaries
                        like Puget Sound.         Nearshore areas and isolated
                        embayments in Puget Sound are at, risk from nutrient
                        loading and degraded water quality, whereas the deep
                        basins and high current areas are less likely to be
                        affected.   By using assimilative capacity to determine
                        the upper limit of nutrient loading in Puget Sound,
                        nearshore areas and isolated embayments may be put at
                        risk for extensive degradation.       This analysis could
                        encourage     numerous      erroneous    conclusions      and
                        misquotations about this report.

             131        The   last sentence in paragraph          four should be
                        referenced. As stated in our official comment letter,
                        there should be a discussion of how many potential net-
                        pen sites there are in Puget Sound, given all of the
                        constraints that are imposed by physical and biological
                        siting requirements and competing uses.         Finally, in
                        this section or elsewhere in the document, the PEIS
                        should lay out a preferred alternative management
                        structure that includes the prevention of negative
                        cumulative impacts to Puget Sound.

             135        The first sentence in the first paragraph needs to be
                        qualified.    The impact of net pens on the "overall
                        water quality in Puget Sound would be very weak and
                        largely negligible" only if the pens were distributed
                        throughout the Sound and not concentrated in only a few

                                                9















                    areas.


          135       The remainder of the first paragraph needs to be
                    expanded into a much more thorough discussion of the
                    availability of sites in the Sound.      How many sites
                    exist where both the effects on water quality and
                    benthic   communities,   and   the   interference     with
                    conflicting uses, could be minimized?

          135       The section titled LAND-BASED TANK FARMS needs an
                    introduction to clarify whether tank farms are being
                    proposed as an alternative to net pens.

          135       Add to the list of primary features at the bottom of
                    the page:     "A discharge pipe to dispose of effluent
                    from the rearing tanks;"

          136       Add to the second to last paragraph the advantage that
                    effluent from rearing tanks could be treated before
                    discharge into Puget Sound.

          138       In the third sentence in the second paragraph of the
                    WATER QUALITY section, explain where in Washington the
                    three onshore tank farms are proposed or are being
                    built, and what criteria were used to determine that
                    these are "located in non-nutrient sensitive waters.11

          138       Last paragraph:     Fish reared in tanks can become
                    susceptible to disease under certain conditions (e.g.,
                    excessive crowding) just as they can in net-pens.
                    Therefore, antibiotic use in tank farms may not be less
                    than in net-pen farms.

          141       In the section titled RELATIONSHIP To LAND USE PLANS
                    AND REGULATIONS, add a discussion of how this PEIS
                    relates to land use plans and regulations. How could
                    or should the information contained within the PEIS be
                    used by local governments?

          143       The following language should be added before Zoning
                    and Other Regulations:

                    Wetland Protection L)rograms.     The Puget Sound Water
                    Quality Management Plan requires local governments in
                    Puget Sound to adopt Wetland Protection Programs that
                    meet state standards to be promulgated in rule by the
                    Department of Ecology by September 1989. Local wetland
                    programs may result in additional restrictions to
                    siting of aquaculture support facilities in or adjacent
                    to wetlands.

          145       The Puget Sound Water Quality Authority should be

                                           10









                        listed as a state agency, not a regional agency.

             Figs. 7,   The references for Figures 7, 9, 12, and 13 should be
             9, 12,     cited as "Puget Sound Water Quality Authority 1988,11
             13         not 1986.














                                                                                                           rA
          RESPONSE TO LETTER NO, 18: PUGET SOUND WATER QUALITY AUTHORITY
          KIRVIL SKINNARLAND


          1.     The EIS discusses the issue of broodstock importation because this is a worst-           Q
                 case situation. Actually, such importation would not be permitted and only Puget          0
                 Sound stock would be used.

          2.     Comment acknowledged.         The text has been revised to evaluate existing
                 regulations and guidelines in the FEIS.

          3.     See the response to Question 8. Tribal usual and accustomed fishing areas are
                 discussed in Section 6.3 of the FEIS.

          4.     The FEIS evaluates existing regulations and guidelines, and the Preferred
                 Alternative recommends WAC adoptions, additional guidelines, and further
                 research that can be undertaken.

          5.     There are a few exemptions to the permitting requirements of the Shoreline
                 Management Act. The text has been revised in the FEIS to reflect this.

          6.     See the response to Question 17.

          7.     The text has been revised for the FEIS to include a discussion of the Puget Sound
                 Water Quality Authority.

          8.     The geographical scope of the EIS is the greater Puget Sound area described in
                 Section 3 of the FEIS.

          9.     The ranges of organic carbon and nitrogen indicated are the range of values
                 estimated to be introduced to the sediments under a typical farm given an
                 estimated FCR of 1.5:1 as one extreme and an estimated FCR of 5:1 as the
                 other.

          10.    The benthic infauna are a diverse array of organisms differing substantially in
                 feeding methods, size, and mobility.      The responses of the infauna to the
                 increased particulate deposition would largely be based on relative size and
                 mobility. Immobile organisms would be buried. Mobile infauna could maintain
                 their depth in the sediment if the sediment deposition rates, measured as units of
                 depth per units of time, did not exceed the locomotory rates of the organisms, as
                 measured on the same scale. Some of these species would be expected to migrate
                 laterally out of the area of impact.

                 While some of the infauna are suspension-feeding organisms, many are not. The
                 relative abundance of the suspension-feeders is dependant upon physical sediment
                 effects and interactions with other biota. Suspension-feeders would have their
                 filters clogged if the particulate deposition rates were high. At lower rates, at
                 least some of the increased particulate matter would probably be eaten.








                Response to Letter No. 18: Puget Sound Water Quality Authority, Kirvil Skinnarland
                (continued)

                       Deposit-feeding infauna would become more common lmder the farms as long as
                       there was sufficient oxygen. Deposit-feeding infauna, such as capitellid polychaete
                       worms, are characteristically members of the guild of opportunistic species that
                       have been seen to increase under farms.

                       Small, mobile, epibenthic organisms, mostly small crustaceans, worms (polychaete
                       annelids, nemerteans, and turbellarians), and gastropods, would likely not be
                       buried since they would be able to move up and around any deposited particulate
                       material.   Most of these animals are micro-scavengers, deposit-feeders, or
                       predators, and their feeding apparatus would not be clogged by the addition of
                       particulate material.

                       Small, immobile, epibenthic or epifaunal organisms, mostly small tubicolous
                       polychaete worms, bryozoans, hydroids, barnacles, or bivalves, would be found on
                       rocks, shells, or other hard substrata. Most of these animals are suspension-
                       feeders and their filters would be clogged or they would be buried by excess
                       sedimentation. At lower rates of particulate deposition, they would feed on the
                       particulate material.

                11.    The redox potential at the southeast comer of the Clam Bay farm complex was
                       strongly negative.

                12.    The has been revised for the FEIS to evaluate existing regulations and guidelines.

                13.    Comment acknowledged. The text has been revised for clarification.

                14.    Comment noted. Section 5.1 of the FEIS includes a discussion of vacuuming
                       under the farm.


                15.    Comment noted.


                16.    Comment noted.


                17.    T'he text in the FEIS has been reworded.

                18.    The text has been revised as suggested.

                19.    The reference for that statement is the 1988 statewide water quality assessment
                       Ecology (1988a). It is beyond the scope.of this EIS, to discuss the difference
                       between the organic enrichment from phytoplankton blooms and upwelling, and
                       the organic loadings from municipal sewage, combined sewer overflows, and failing
                       septic tanks.

                20.    The text has been rephrased to "shallow bottom waters in poorly flushed
                       embayments."









           Response to Utter No. 18: Puget Sound Water Quality Authority, Kirvil Skinnarland
           (continued)

           21.     It is reasonable to expect that cleaning heavily fouled nets would increase turbidity
                   to a greater extent than the normal operations of a fish farm.

           22.     Phytoplankton assimilate nitrogen even when not nitrogen limited. Excess uptake
                   of nitrogen is well documented. Zooplankton do not directly assimilate nitrogen
                   from the water, but do assimilate nitrogen from ingested phytoplankton. Healthy
                   zooplankton will ingest more nitrogen than they excrete.

           23.     Thom's studies were included as indicative of the recent trend toward research in
                   considering nearshore conditions in Puget Sound as early warning zones for
                   impacts to Puget Sound. Typically, fish farm siting studies involve drogue and
                   current meter studies that may demonstrate periods of flow towards the shallow
                   sub-tidal zone. If farms of significant size were to be located in such areas, and
                   ambient nutrients were severely limited, a farm could enhance the growth of
                   attached algae in the lower intertidal or subtidal zone. Accordingly, Thom's
                   studies were included, and he reviewed the pertinent portions of the text.

           24.     Carr Inlet is only one area in Puget Sound that appears to have annual blooms
                   of PSP-causing dinoflagellates that develop from with the area. The reference to
                   Nishitani in the previous paragraph refers the reader to her discussion of this
                   topic. Other than studies conducted by one of the authors of this EIS, there was
                   no state, federal, or private investigations of water quality dynamics during that
                   event.


           25.     According to the available literature, this does not appear to be true. In fact, the
                   opposite is more likely since dinoflagellates generally prosper in the upper layers
                   of stratified water masses that are deplete of, rather than replete with nutrients.

           26.     See the response to Comment 25 above.

           27.     Comment noted.

           28.     The nitrogen flux discussed in the text, and in the Interim Guidelines, is in and
                   out of embayments.       The other sources mentioned in this comment are
                   insignificant compared to oceanic source found in tidal flux. During summer
                   months vertical mixing is relatively minor in these areas unless strong storms of
                   sufficient duration occur.

           29.     Respiration includes a series of physiological processes measured by, but not
                   limited to, the consumption of oxygen. These metabolic pathways are a function
                   of the consumption of photosynthetic products during both light and dark periods.
                   This involves the Calvin-Benson cycle ("dark reactions") and the production of
                   glycolate, the major source of protein (nitrogen containing amino acid chains)
                   synthesis.








               Response to Utter No. 18: Puget Sound Water Quality Authority, Kim.'I Skinnarland
               (continued)

               30.    The units are correct. Although molecular (atomic') units are preferable to
                      oceanographers and others working in marine research, the mg/L units were used
                      to avoid confusion of the lay public.

               31.    The assumption that slower sinking feed will cause an increase in water column
                      nutrients is incorrect. In most areas where fish farms are located, there is no
                      nutrient limitation of phytoplankton growth, or only the surface waters are
                      seasonally limited. Binders incorporated into the feed allow relatively long
                      soaking periods before the pellets disintegrate. These, periods are hours, at a
                      minimum, thus the excess pellets are to be found intact, upon the bottom. This
                      has repeatedly been observed in field studies. Finally, if the entire water column
                      is nutrient depleted, more slowly sinking pellets can only aid in mitigating the loss
                      of nutrients into the water column because the fish are more likely to consume
                      the pellets and dispersion of uneaten pellets is greater.

               32.    Comment acknowledged. The text has been revised.

               33.    Properly sited, a fish farm would not need an aerator. In low-oxygen conditions,
                      any aerator that caused more oxygen to be dissolved than the amount utilized by
                      the farm operation would cause an overall increase in dissolved oxygen. However,
                      it is not recommended that fish farms be sited in areas where the use of aerators
                      may become necessary.

               34.    Comment noted.

               35.    The word organism has been added to the sentence for the FEIS.

               36.    The phrase "fish stock" has been added to the text of the FEIS.

               37.    The four pages of text following the third paragraph on page 70 in the DEIS
                      discuss this issue.


               38.    Comment noted.

               39.    There are many hatchery stocks in Puget Sound that are indistinguishable from
                      the "wild" fish in the same river system. This is not inconsistent with the intent
                      of the mitigation measure suggested on page 80 of the DEIS. That measure was
                      suggested in the context of eliminating the potential risk of introducing exotic
                      pathogens.

               40.    Seriously maladaptive genes would probably not be balanced as in balancing
                      selection. However, you are correct in stating that genes of a less serious nature
                      could persist through this process.
               41.    This is true. However, if you were to assign a 50-percent reduction survival
                      potential to smolt as opposed to post-smolts, the worki   ng number would only be









           Response to Utter No. 18: Puget Sound Water Quality Authority, Kirvil Skinnarland
           (continued)

                  reduced from 9 million to 8.5 million. The 8 million smolts, intentionally released
                  are "delayed-release" fish or post-smolts.

           42.    A worst-case scenario impact assessment has been included in Section 5.7 of the
                  FEIS. This would only apply to escapements of Pacific salmon (and very few
                  farmers are apparently interested in using Pacific salmon). In the case of Atlantic
                  salmon, there is no danger of genetic impacts as they can't interbreed with
                  indigenous species.

           43.    There is little doubt that the physical requirements that Atlantic salmon need to
                  spawn successfully are present in Puget Sound rivers. The question is whether or
                  not they can compete with the steelhead and salmon as juveniles. Based on the
                  lack of success of efforts to establish them, it is apparent they cannot.

           44.    Probable risk is determined by the best professional judgment of experts within
                  WDF.

           45.    The answers to the first three questions have not been determined at this time.
                  Setting a minimum distance from hatcheries would not be useful unless the
                  hatchery was an integral part of the wild stock. The technology for producing
                  sterile or monosexual fish is available and beginning to be implemented on a
                  production basis in Europe. The idea of requiring the tagging of a portion of all
                  farm fish may be a good one and should be evaluated further.                Another
                  alternative would be to require genetic markers on all broodstock.

           46.    This measure should be self-regulating. It is in the farmer's best interest to
                  formulate broodstock programs which maintain genetic variability in the
                  population. The cases where genetic variability reduction have been documented
                  are cases where broodstock programs were ill-conceived, such as where founder
                  population numbers were too small. This happened in some places back when the
                  problem of low genetic variability was not known. Farmers today are aware of
                  the potential problems and take steps to ensure they don't occur.

           47.    See the response to Question 29.

           48.    The text has been revised for Section 5.8 of the FEIS.

           49.    See the response to Question 25.

           50.    See the responses to Question 26 and Utter 1, Comment 16. Cultured fish are
                  at high risk because they are exposed to pathogens from feral fish, like other
                  domesticated animals such as livestock and poultry which are exposed to
                  pathogens from wild game.

           51.    State and federal laws (Title 50) are in place to reduce the risk of disease
                  transmission in stocks from Canada.        Title 50 is currently under revision.








               Response to Utter No. 18: Puget Sound Water Quality Autliority, Kirvil Skinnarland
               (continued)

                     Appendix H includes some of the British Columbia regulations for your
                     information.

               52.   The text has been modified to reflect your comment.

               53.   These changes have been made to Figure 17.

               54.   This paragraph has been revised to clarify the intent of Figures 19-21.

               55.   This table has been included as Table 8 in the FEIS.

               56.   Comment noted.

               57.   Comments noted.

               58.   Comment noted.

               59.   Comments noted.

               60.   Floating fish farms in marine waters will not affect wetlands. Evaluation of the
                     possible onshore components of floating fish farms such as ancillary hatchery
                     facilities are outside the scope of this EIS.

               61.   Comment noted.

               62    See the response to Question 12.

               63.   Comment noted.

               64.   The DEIS noted that conflicting uses of the water would probably limit
                     development of the fish farming industry in Puget Sound before the cumulative
                     impact on water quality becomes a concern.

                     Text has been added to Section 7 of the FEIS to clarify that assessing the
                     cumulative impacts of fish farming on the various elements of the environment
                     discussed in the FEIS is a sequential process. Cumulative impacts would be
                     considered during the SEPA review process for each farm proposal using site
                     specific information and the knowledge of other nearby farms.

               65.   Assimilative capacity analysis does not preclude the importance of proper site
                     selection. The comment raises concerns about localized problems from farms
                     which are largely related to proper siting. See the first two paragraphs of the
                     Section 7 of the FEIS.

               66.   See the response to Question 4. The EIS evaluates environmental impacts and
                     is not a management plan for the fish farming industry.








           Response to Letter No. 18: Puget Sound Water Quality Authority, Kirvil Sldnnarland
           (continued)


           67.    The distribution of the farms throughout the Puget Sound is an essential condition
                  of this analysis. See the response to Letter 19, Comment 65. Also, see the first
                  three paragraphs of Section 7 of the FEIS.

           68.    See the response to Question 4. See the first three paragraphs of Section 7 of
                  the FEIS.

           69.    It is not an objective of the EIS to evaluate land-based tank farms. The land-
                  based tank farm section was added to provide additional information on another
                  form of commercially raising fish and has been moved to Appendix I of the
                  Technical Appendices in the FEIS.

           70.    Comment noted.


           71.    Comment noted.

           72.    Land-based tank farms have been considered in Clallam County along the Strait
                  of Juan de Fuca, in the San Juan Islands, and near Westport on the Pacific coast.
                  The Strait of Juan de Fuca and the San Juan Islands were not considered nutrient
                  sensitive in the Interim Guidelines. The Westport area was not evaluated in the
                  Guidelines. However, over the last six years at Ecology's North Whitcomb Flat
                  water quality monitoring station near the proposed tank farm, only 7% of the
                  observations showed nitrogen concentrations (sum of ammonia, nitrite, and nitrate)
                  less than 0.1 mg/L

           73.    Comment noted.

           74.    See the response to Letter 17, Comment 3.

           75.    The scope of this EIS is limited to floating commercial fish farms. Restrictions
                  that may affect siting of onshore facilities associated with floating fish farms is
                  outside the scope of this EIS.

           76.    The Puget Sound Water Quality Authority is an agency with involvement in the
                  Puget Sound region. The text has been revised for the FEIS.

           77.    Figures 7, 9, 12, and 13 were based on figures found in the State of the Sound
                  1986 report.






                                                                            LETTER NO. 19






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      RESPONSE TO LETTER NO, 19: DEANNE ROTH
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                                                                     I




                                                              April %, 1989 LETTER NO. 20

                                                              Thomas C. Santos
                                                              243 Dungeness Meaaows
                                                              Sequim, WA 98382
       Department of Fisheries                                (206) 683- 7112
       Ron Westley
       115 General Administration Bldg.
       Olympia, WA 98504


       Dear Mr. Westley:


       I would like to submit the following for consideration of the WDF in setting
       policy for fish culture in floating fish pens.


       The primary concern at this time should be the VHS disease, which is believed
       to have originated in Europe, where it wiped out entire runs. It is also
       associated with trout. Not unlike the steelhead, the Atlantic salmon is a
       trout. The Atlantic salmon is suspect of being a carrier of VHS, without
       itself displaying the symptoms.


       Second-ly, there is evidence of much waste matter under fish farm net pens,
       which can increase the BOD to lethal levels. The aquaculture fact finding
       study done in Norway by Will Soltau mentions one meter deep rotting jelly
       like material under the pens, encrusted with bacteria that not only puts a
       huge demand on oxygen, but releases dangerously potential amounts of hydrogen
       sulfide and methane. This report says that 1 ppm of dissolved H2S is toxic
       to salmon. This same study speaks of many hazards, both potential and real,
       all the way from residual antibiotics to viruses and parasites. It also
       discusses the 13% of net pen fish that escape, with escapes up to 40%.


       Other reports on Puget Sound spealc of the 13 commercial fish pen farms in
       the Sound creating six times more wastage than does Metro's Renton Waste

       Treatment Plant.



       My recommendations would be: (1). No more licensing of fish pen farms until
       the VHS matter is resolved. (2). Use only native salmon species. (3). All
       farms to be located off of the water, using tanks. (4). All waters to be
       filtered in and out of tanys. (5). Pump sea water from areas least likely
       to affect crab larvae and other small sea life. (6). Locate farms where
       they would minimize esthetic values. (7). Never locate any fish farm in
       any bay or harbor.
                                                 Sincerely,










               RESPONSE TO LETIrER NO. 20: THOMAS C, SANTOS

      M


               1.     See the res onse to Question 29.
                                 p

      a        2.     Proper siting of fish farms is essential to mitigate effects such as excessive
                      accumulation of organic matter. This is currently part of fish farm siting studies
                      and
                          can be expected to remain so. Problems in Norway are probably due to the
                      much higher fish densities used there and differences in siting requirements. The
                      Norwegian government has moved many farms to deeper water with more water
                      circulation to correct siting errors made 15 to 20 years ago.

               3.     Comments noted.




                                                                   SARATOGA COVE FOUNDATION                                                                 LETTER NO. 21
                                                                            Robert J. LaLanne
                                                                       2257 E. Eastpoint Dr.
                                                                            Langley, WA 98260

                                                                                                April 5, 1989



                         Ron Westley, Project Manager
                         Washington Department of Fisheries
                         115 General Administration Building
                         Olympia, Wa 98054

                                                             Net Pen Fish Culture P.E.I.S.

                                     When reviewing the P.E.I.S., we found no cognizance
                         taken of the historic public policy against the appropria-
        (D               tion of public lands for any private use which would exclude
                         all other uses.

                                     Rather, we found a document purported to be a scien-
                         tific, unbiased study, unmasked as a largely "piecemealed"
                         compilation of prior publications by known paid consultants
                         of the salmon pen industry--some who have openly espoused
                         proponent positions.

                                     Department of Fisheries has touted these preparers as
                         "experts and the best available", yet one of the major
                         contributors recently had a fish pen E.I.S. rejected both
                         for inadequacy and failure to address important issues. one
                         must conclude that this firm is either biased or
                         unqualified.

                                     We note that the P.E.I.S. and its appendices are liber-
                         ally strewn with the words "probably", "possibly",
                           approximately", "assumed", and "perhaps". These, coupled
                         with statements saying "no samples taken", "sampling not
                         possible", "lacking measurement specifics", and "somewhere
                         in between", are the indecisive conjectures used to make
                         positive statements and declarations.

                                     We also find in the draft report that an admittedly
                         unreliable model (actually undergoing testing at the time)
                         was used in studies as a basis for findings and conclusions,
                         that, under the given circumstance, can only be regarded as
                         promotional material.

                                     Regrettably, the                        preparers selected Clam Bay and
                         Squaxin Island as test sites. Both are atypical of Puget
                         Sound pen locations. The highly questionable results may
                         well have been quite different had established operations in
                                                                                                            ........ .......*........... -- ------- . .... . .....*----- - -------*...... . ...........
                         more common tidal currents been chosen.

                                     The appendix sections on aesthetics and property values
                         attempt to show the positive economic benefits of fish
                         farming through the work of an author who states his
                         inability to assess what, if any, negative effects can be
                         attributed to fish farms.








             Ron Westley, Project Manager
             Washington Department of Fisheries
             April 5, 1989
             Page 2



                  This author then proceeds in attempts to establish the
             economic impact on view property by using an elaborate equa-
             tion formula--virtually any real estate broker specializing
             in waterfront properties could have supplied better answers.

                  There is no place for this mediocre work in either the
             P.E.I.S., or its appendices.

                  The draft P.E.I.S. also fails to include substantial
             available data from qualified scientists, researchers, and
             other authorities who hold and present compelling arguments
             of refutation to conclusions in the draft.

                  Those responsible for the P.E.I.S. have given dismal
             treatment to the subject of fish disease. A "passing fancy"
             attitude of "oneliners", and a few paragraphs which state
             the unlikely possibility of major disease problems, is no
             substitute for a comprehensive study.

                  On this subject we find the state and federal agencies
             holding diametrically opposing views on VHS. Coinciden-
             tally, other authorities are propagandizing that VHS 'has'
             never been found to occur in Atlantic salmon--this at
             precisely the same time Clallam County commissioners are
             being presented copies of scientific journals-stating VHS
             outbreaks have been documented in Atlantic salmon.

                  Rather than the present cursory treatment found in the
             draft report, a study must be done, not by public relations
             employees of industry, but by qualified independent
             scientists.


                  It is our conclusion that the P.E.I.S. should not be
             removed from draft status until disease and the many other
             incorrect, incomplete, biased, and deficient sections are
             corrected, revised, or deleted--finally allowing presenta-
             tion to the public of a professional authoritative,
             scientific document instead of the present embarrassing
             proposal.

                  The Saratoga Cove Foundation supports the comments
             submitted separately by its secretary, Marie Pickett, and
             endorses the position paper filed by "Save Our Shores"
             president, L. Joe Miller.




                                           Robert J. LaLanne, President
                                           Saratoga Cove Foundation
                                           2257 E. Eastpoint Dr.
                                           Langley, WA 98260

             RJL/rt










          RESPONSE TO LETTER NO. 21: SARATOGA COVE FOUNDATION


          1.     See the response to Question 11.
                                                                                                        U
          2.     See the response to Question 2.                                                        0

          3.     Comment noted.

          4.     See the response to Question 15.

          5.     The fish farm in Clam Bay is one of the largest farms in the world and has been
                 in operation longer than any other farm in Puget Sound. The Squaxin farm is
                 smaller and has only been in operation since 1987, but is sited in an area with
                 different hydrographic characteristics. The use of these sites is appropriate to
                 describe a range of impact levels.

          6.     See Section 4 of the response to comments after the text in Appendix E.

          7.     Comment noted.

          8.     See the response to Question 29 and Appendix G.

          9.     Comments noted. See the response to Question 27.





                                                                 LETTER NO. 22




                                            3653 S.Bells Beach Road
                                            Langley, Wa 98260

          Ronald E. Westley, Project Manager
          Washington Department of Fisheries
          115 General Administration Building
          Olympia, Wa. 98054

          Re: PEIS Fish Culture in Floating Net Pens

          This document starts from the position that there will be net
          pens for raising fish in Puget Sound and this position is not
          debatable. It then proceeds, time after time, to state
          mitigation measures in order to make adverse impacts tolerable.

            "Mitigation' means "to lesserl a force or intensity; to make
          less severe. Applying this meaning to the adverse impacts
          suggests the following assumptions:

                   There is a force that could cause major impacts so it
                    needs to be lessened, softened, or tolerated.
                    In other words, folks, any adverse significant
                    impact of net pens are to be tolerated because steps
                    are suggested to lessen the impact.

                 The stated purpose (page 1X) of this document is "to
          evaluate the environmental impacts of net pens on biological
          and built (human) environment. Evaluate means "weighing the
          negative and positivell.This document contains support for the
          pens. It disregards adverse impacts on the environment.

          An appropriate description of the contents of this PEIS would
          be that of a POSITION paper written by consultants known to be
          hired advocates for the aquaculture industry.

          To enable this PEIS to be usable by planners and citizens
          alike, it should have a major overhaul. It needs a careful
          definition of terms and standards. Furthermore it needs to
          revise the glaring omissions, contradictions, startling
          deficiencies in order to accomplish its goals.

          AMBIGUOUS STRUCTURE;

          Let me illustrate with two examples to indicate how terms need
          to be define in a variety of ways and structures must be
          changed to make the meaning precise.

          The words "significant adverse impacts"( page X) means that
          fish pens do have adverse impacts. Some impacts are more
          significant than others. Significant to whom? What measures
          are used to determine when an impact is significant?












             Page 2 - Pickett



                    The statement in the summary "No unavoidable adverse
             impacts" is particularly ambiguous. The word "avoid" according
             to the dictionary means "keep clear of or keer) away from" The
             prefix "un" means "not" a    when combined with avoid creates a
             reversal of a meaning. Then add the word "no" and one can only
             guess that the statement means that there are no adverse
             impacts that can be avoided.

             These are only two of the words and sentences throughout the
             document that require revision in order to be clearly
             understood.



             GLARING OMISSIONS


                    1. WASTE MANAGEMENT;

                     Waste management, I understand, is a county
             responsibility. However, shouldn't there be a reference to the
             possibility of large numbers of dead fish,proliferation of
             plastic feed sacks, and other wastes from the fish pens causing
             the life-span of a waste disposal site to be shortened by as
             much as one-third?. This is occurring in British Columbia at
             the present moment. Shouldn't suggestions be made that
             counties put into place measures to take care of this problem
             before fish pens are sited?.

                    The Federal Clean Water Act and its NPDES permit
             requirement are ignored. Although this question may decided in
             the courts it certainly should be addressed/

                    2. REGULATIONS;

                      There is no assessment of the costs of regulation, or
             the monitoring and enforcement of regulations. If they are to
             be done by the industry it should be so stated. However, there
             is always danger when an industry regulates itself.

                    In Kicket Bay property owners have noted flagrant
             violations, increased traffic and noise, etc. Repeated calls
             reveal no one is in authority to enforce any type of regulation
             and no financial resources available to do any enforcement.













          Page 3-Pickett




                 3.PLANKTON BLOOM


                 Fish pen operators in British Columbia (Sechelt
          Peninsula) are concerned with the dire effects of the plankton
          bloom on the fish.Their pens are sited in more-or-less ideal
          conditions in deep water (300-600feet) near isolated shores in
          remote areas. However after two and one-half years they have
          established during the dangerous summer months plankton bloom
          watches. Why? Has the plankton bloom increased? Is there a
          relationship between the weather,increased number of fish
          farms, and the increased amount of plankton bloom? Such
          questions deserve scientific examination.

                 on page 57 we find a number of mitigation measures which
          appear to be testing requirements prior to siting, i.e. test
          the proposed site to evaluate the nutrients and algae density
          and then restrict (?) fish farms in areas exhibiting
          hypernutrification. These seem logical.

                 In British Columbia the pens are sited in areas with
          ideal water volume and flushing and are not in confined
          embayments and yet they have a problem. In view of such a
          condition paragraph No. 4, page 57 seems redundant and
          contradictory.

                 4.BROODSTOCK


                 The problem of a sufficient supply of broodstock is not
          addressed, particularly in the light of proposed increases in
          the number of fish pens. Since some of our hatcheries have
          destroyed their stock due to VHSD there is bound to be a
          shortage. Will fish stock be allowed from other areas or
          countries? Shouldn't the siting of a farm be dependent upon
          the amount of broodstock available?.



                 5. LAND BASED FISH PENS


                 The high capital cost of the rearing equipment and
          technique should be offset by its ability to produce a more
          favorable looking product in a shorter period of time. Also
          the reduced amount of antibiotics, feed should also be
          considered. Less risk of disease should be am important factor
          along with less danger to wildstock.

                 INADEQUATE TREATMENT

                 It seems to me that the PEIS should describe a process
          for disseminating recent developments in fish disease.











             Page 4-Pickett

                     other facets that have not been properly dealt with
             are: the industry's displacement of historical uses of the
             waters, the potential for fish escapement,effect of storms,
             reluctance of banks to finance this endeavor-, the findings of
             Puget Sound Water Quality regarding clean-up, necessary in Puget
             Sound and of course the risk of damage to the natural stock by
             fish disease.



                     Lastly, I would like to call your attention to RCW
             79.90.460 in which it states: The management of state-owned
             aquatic lands shall preserve and enhance water-dependent
             uses .... In cases of conflict between water-dependent uses,
             priority shall be given to uses which enhance renewable
             resources, water-borne commerce, and the navigational and
             biological capacity of the waters. Doesn't the RCW preclude
             thee establishment of net pens in areas that: do interfere with
             navigational and biological capacities of the waters?

                     In WAC 173-16-060 paragraph 2 it states "Aquaculture is
             dependent on the use of the water area and, when consistent
             with control of pollution and prevention of damage to the
             environment, is a preferred use of the water area."

                     The indefinite article "all is defined in a Random House
             dictionary as meaning "not any particular or certain one of a
             class or group such as: a man, a house. "The" is used
             especially before a noun, with a specifying or particularizing
             effect as opposed to the indefinite or generalizing force of
             the indefinite article a or an. For example: the book you gave
             me, the past.


                     All of the above references and statements are cited to
             point out that aquaculture is ONE of the many uses of the
             waters. RCW 79.90.450 deals with the management of public
             aquatic lands and articulates a philosophy. RCW 79.90.455
             states that there should be a balance of public benefits for
             all citizens of the state and then lists them.


                     I believe the citizens of the state would NOT support
             destroying that balance by allowing one commercial industry to
             DISPLACE navigational and towboat lanes, commercial and sport
             fishing, or affect the ecosystem of aquatic waters. There is no
             justification for thist


             Marie J. Pickett, Secretary
             Saratoga Cove Foundation
             3653 S. Bells Beach Road
             Langley, Wa. 98260










            RESPONSE TO LETTER NO, 22: MARIE 1. PICKETT


            1.     Significant, as used in SEPA, means a reasonable likelihood of more than a
                   moderate adverse impact on environmental quality.       Significance involves context        U
                   and intensity and does not lend itself to a formula or quantifiable test (WAC 197-
                   11-794).

            2.     None of the issues you mention have been identified as problems associated with
                   any of the existing farms in Puget Sound. See the response to Letter 1, Comment
                   88.                                                                                          99

            3.     See the response to Question 17.

            4.     See the response to Questions 12 and 9.

            5.     Comments noted. The evaluation of plankton blooms on British Columbia fish
                   farms is outside the scope of this EIS.

            6.     There is a large surplus of eggs from WDF hatcheries in most years. In 1989,
                   over 50 million eggs of coho and chinook have been bought from WDF and sold
                   to fish farmers and other hatchery operations around the world.              There is
                   currently a state of near self-sufficiency in Atlantic salmon broodstock in the Puget
                   Sound area. As the demand increases, so will supplies. Many fish farmers will
                   rear their own broodstock to ensure supplies.

            7.     Comments noted. It is outside the scope of this EIS to evaluate all aspects of
                   land-based tank farms.

            8.     The process of disseminating information on fish diseases is largely a professional
                   issue. For regulatory purposes, new information on infectious diseases of fishes
                   is currently monitored by WIDE         Thus, this function is covered within the
                   responsibilities of the professional staff in the area of fish pathology in the WIDE

            9.     Fish farms are not appropriate in areas heavily used for navigation. When there
                   is a case of conflicting water-dependent uses for a particular site, priority will be
                   given to the use that meets the criteria stated in RCW 79.90.

            10.    DNR will evaluate the impacts of fish farms on a case-by-case basis. Navigation
                   is a high priority use over aquatic lands and siting decisions will consider potential
                   conflicts with navigation and other aquatic land uses and values.





                                                                                LETTER NO. 23







                                                       4654 S. Strawbridge Lane
                                                       Langley, Washington 98260


                                                       March 31st, 1989



            Project Manager Ron Westley
            Washington Department of Fisheries
            115 General Administration Building
            Olympia, Washington 98504

            Dear Sir:


            Members of Seahorse Siesta Club community wish to go on record
            for rejecting the Programmatic Environmental Impact Statement for Fish
            Culture as it is written.


            The draft:

                        1.  is negligent in providing credible findings.
                        2.  appears to be biased toward the aquaculture industry
                            in its omission of up-dated research and economic
     0                      studies.
                        3.  ignores public rights, fishermen, and navigation problems.
                        4.  does not provide funds for controlling the industry.

            Much work is necessary to remove the assumptions and inconsistencies
            contained in the PEIS.


                                                       Res- tfull     urs,





                                                       Frank  re    President
                                                       Seahorse Siesta Club
                                                         s' tfu,@
                                                       Fra @Grele' , Prr=









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                                                                             LETTER NO. 24


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                                                                   LOPEZ MANO, WA 98261














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                                                                   LETTER NO. 25






                            SIERRA CLUB -CASCADE CHAPTER
                                Water Quality Chair


         Mr. Ron Westley
         Project Manager
         Washington Department of Fisheries
         115 General Administration Bldg.
         Olympia, WA 98504                              1 April 1989

         Re: Draft Programatic EIS for Fish Culture in Floating Net Pens

         Dear Mr. Westly,

         We sincerely appreciate for the opportunity to comment on the Draft
         Programatic EIS (PEIS) for Fish Culture in Floating Net Pens. While
         useful information is being provided in the technical appendix, we
         regard the application and interpretation of such information in
         the first volume of the Draft PEIS as most inadequate.

         While the document is titled "programatic", it does not provide
         the required informed basis for net pen site selection, net pen
         management, compliance with aquatic quality preservation and
         anti-degradation requirements.

         The document fails to convey the fact that conflicts for uses of
         Puget Sound marine waters range from high to very high and that
         net pens can or will create another "use" burden. Not least are
   (D    the very high public demands to prevent and/or strictly control
         "Aesthetic Pollution" especially noise, visual, odor and solid
         waste pollution.

         The find the attitudes of net pen promoting state officals
         denigrating as "elitists" those concerned about the mounting
         degradation of "aesthetic quality" around Puget Sound as most
         reprehensible. The FOEIS needs to address the issue of
         "Aesthetic Quality" not as an impediment to net pens but as a
         positive requirement to preserve citizens rights to enjoy unpol-
         luted open spaces.

         The PEIS should consider that a " not in my frontyard " citizen's
         requests for non siting of net pens in front of residential shoreline
         comunities rates just as high as citizen's demands to control gravel
         pits, garbage dumps, urban sprawl, high rises and neon jungles.

         To that effect, the document needs to provide a detailed analysis
         of how many potential sites might be available for net pen siting
         considerations, given the full range of environmental and public
         contraints that must be considered.





                                      1








               HIS relationship to the "Interim Guidelines for the Management of
               Salmon Pen Culture in Puget Sound.

          While the statement is made on p.10 of the DEIS; that            these
          guidelines will. be updated and possibly formalized as the result,
          in part, of information developed in this PEIS", discussion on how
          the information developed in the DEIS will be applied to up date
          the guidelines is lacking.    The DEIS needs to provide an in depth
          evaluation of the effectiveness of the Interim Guidelines and
          demonstrate how the new information will be used to make the up
          dated guidelines more effective in imposing the required stricter
          environmental protection demands.

          * Cumulative Impacts.

          The document lists some alternatives but makes little or no
          serious attempts to distinguish between them in terms of
          anticipated impacts. The?DEIS fails to follow the required EIS
          format to discuss in detail the anticipated impacts of the various
          alternaives being considered. This particularly evident from a
          scant two pages limited discussion.

          The document implies that if 100 or so pens were implanted into
          Puget Sound, their cumulative impacts would be almost nil. Such
          an implication is seriously flawed and we strongly recommend that
          the entire section be rewritten accordingly. The rewrite should
          be resubmitted as an amended REIS.

          * NPDES Permit Requirements.

          Section 502 (14) of the Clean Water Act defines ff concentrated
          animal feeding operations " as Point Source. Section 502 (13)
          defines "toxic pollutants" as pollutants or combination of pollu-
          tants, including disease-causing agents which after discharge and
          upon exposure        can cause death, diseases            Sec 502
          (12) defines disharge of pollutants as " . . . addition of any
          pollutants            The discharges from net pens fulfill the
          intent and substance of the above definitions, thus the require-
          aments for the net pen pollution be controlled under a NPDES
          permit is fully mandated. The threat of potential contamination
          by the exotic Viral Hemorragic Specticimia Disease (VHSD) fully
          mandates that strict eflluent quality control be imposed. The
          PDEIS must fully discuss the needs and methodology for effluent
          control, preferably through pretreatment of the effluent, prior
          to discharge.

          Net Pens are essentially "aquatic feed lots" and as such are major
          point source polluters. D. P. Weston in his 1986 Report on the
          "Environmental Effects of Floating Mariculture in Puget Sound"
          (p137 - U of W School of Oceanography Report 87-16) projects that
          a 50,000 Kg salmon net pen facility " . . . would have loading
          of nitrogen, phosphorus and BOD equivalent to untreated sewage
          from approximatly 10,000 persons", not counting the solid wastes.



                                       2









        Weston estimates that a 250 metric tons of net pen salmon will
        generate about 175 metric tons of solid wastes per year, mostly as
        feces and uneaten food.

        For certain, mostly unpolluted embayements net pens are the major
        pollution source. This fact must be objectively recognized and
        discussed in the PDEIS. For example, Discovery Bay on the south
        shore of the Strait of Juan de Fuca has a combined population of
        less that 1500 peoples dwelling along the immediate perimeter of
        its shoreline. All household are on septic /leach field systems
        with no direct discharges into the Bay.

        Good circulation combined with sufficient water depth to "flush"
        the wastes are considered the essential attributes to net pen
        site selection.   D.P. Weston and R.J. Gowen " Assessment and
        Prediction of the Effects of Salmon Net Pen Culture on the Benthic
        Environment " in Appendix A provides some interesting insights on
        the potential behavior and fate of solid waste material generated
        by net pens.

        Of special interest are the behaviors in current patterns illust-
        trated in Fig.2, p.12 and Fig.11, p.31. The figures illustrate
        the marked differences in current directions and oscillatory
        petterns for two different stations within the same net pen sites.
        The figures serve to illustrate the shortcomings of the Interim
        Guidelines followed almost without questions by net pen applicants
        to measure current velocity and direction 6 feet below the surface
        and at mid-depth at the center of the potential net pen site during
        a period of "average tide" to determine the "mean velocity".

        What constitutes an "average tide" to determine "typical current"
        can be questioned by scrutiny of the attached illustration on the
        range variability of the mixed type of tide of the Pacific Coast.
        The progressive current vectors shown in Figs. 2 and 11 exhibit
        tidally induced fluctations in speed and direction. The use of
        progressive current vectors however do not provide information on
        the eddy motion regime controlling the areal deposition of net
        pens solid wastes. The PDEIS must be redrafted to incorporate the
        actual field of motion that will control the deposition patterns
        of net pen solid wastes.

        Conclusions and Recommendations.

        The above brief comments illustrate some of the shortcomings of
        the PDEIS. The document should be considered as an uncomplete
        early draft document in needs of up dating and revision.

        How the information developed in the document will be applied
        towards integrated, long range planning for net pens, considering
        all of the environmental, technical and public acceptance constraints
        for in many instances already "over used" marine environment must
        still be developed.










          We strongly recommend that the PDEIS be recalled and redrafted
          accordingly.

          Again, we sincerely appreciate the opportunity to comment on the
          PDEIS and shall be most willing to interface with you and your staff
          in its redraft.


          Sincerely     yours,


          M. Pat   
We nnekens PhD
          Chair
          c/o 399  Norman Street
          Sequim, WA 98382
          (206) 683-4007
                  






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               RESPONSE TO LETTER NO, 25: SIERRA, CLUB - CAS DE CE



               1.     See the res onse to Question 1.
                                  p

      0        2.     Comments noted.

               3.     Comments noted.

               4.     See the response   to Question 4.

               5.     The text has been revised to evaluate existing regulations and guidelines in the
                      FEIS.

               6.     See the response to Question 7.

               7.     See the response to Question 17 and Letter 6, Comment 1.

               8.     No current vectors are found on figures cited. Also, eddy currents contribute to
                      diffusion of waste material which causes a larger areal distribution, but a lower
                      areal loading. Since impacts are related to areal loading rates, the use of average
                      tidal currents is more conservative than the use of tidal and eddy currents.

               9.     This FEIS provides information on potential environmental impacts from floating
                      fish farms. The information in this FEIS can be used by State agencies and local
                      goverm-nents in any subsequent planning efforts related to the management of the
                      fish farming industry.





                                                                                   LETTER NO. 26
                                                    A
                                                      0


 @ichard J. Thompson                       STATE OF WASHINGTON
 Acting Secretary        DEPARTMENT OF SOCIAL AND HEALTH SERVICES
                                         Olympia, washington 98504-0095

                                               March 29, 1989







             TO:          Ron Westley, Project Manager
                          Washington Department of Fisheries
             FROM:        Gary Plews, Supervisorv
                          DSHS Shellfish Section  rij

             SUBJECT:     Draft Programmatic Environmental Impact Statement:
                          "Fish Culture in Floating Net Pens"



             Thank you for the opportunity to review the above referenced document. It is
             a thorough, well-researched treatment of this controversial subject. We
             believe human health concerns have been adequately addressed in the document,
             and therefore have no comments to make at this time.









        @O            RESPONSE TO LE=R 26: DEPARTMENT OF SOCULL LND HEALTH SERVICES
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                                                                LE17ER NO. 27



                                          SQUAXIN ISLAND TRIBE









        April 6, 1989


        Duane E. Phinney, Chief
        Habitat Management Division
        Washington Department of Fisheries
        115 General Administration Building
        Olympia, Washington 98504


        Re: Programmatic Environmental Impact Statement
             Fish Culture in Floating Net-pens

        Dear Mr. Phinney:

        This letter represents the comments of the Squaxin Island Tribe on
        the PEIS for net-pen culture. We are in a unique position from
        which to evaluate this document as we have been extensively
        involved in net-pen culture for over 15 years and we are the
        subject and site for several studies done in conjunction with this
        document. We believe we have perhaps the best characterized net-
        pen site in Puget Sound and the expertise with which to critique
        your PEIS.

        In general we f ind that the EIS is a well written document that
        accurately and fairly portrays potential impacts associated with
        pen culture. We would suggest stronger coverage of issues related
        to implementation of a net-pen permitting program.      It appears
        certain that every site proposed in Puget Sound will have to
        provide extensive and site specific environmental documentation.
        We feel that a better analysis of the programmatic consequences of
        net-pen permitting and management should be forthcoming.

        A different way of presenting the information and alternatives in
        the PEIS may be appropriate. While alternatives ranging up to 100
        farms may be an acceptable way of addressing the potential of
        cumulative environmental impacts, it does not appear to adequately
        analyze what type of local and state processes might be used to
        achieve the permitting and management of 100 such structures. One
        is left to ask the  question if 100 pen facilities are possible in
        the current regulatory atmosphere. Pen proponents and the general



       NATURAL RESOURCES DEPARTMENT      West 81 Highway 108 / Shelton, WA 98584
                          FAX 426-3971   Phone (206) 426-9783










           Duane E. Phinney - Net-Pen PEIS
           April 6, 1989
           Page 2

           public need to have a better understanding of how net-pen proposals
           will be evaluated in the future.

           Currently siting criteria are controlled by the ]Recommended Interim
           Guidelines for the Management of Salmon Net-Pen Culture in Puget
           Sound.    What relationship does this document have to those
           guidelines? Will we continue to use the guidelines or will we
           develop new guidelines? Are the current guidelines adequate to
           address the concerns noted in the PEIS?         Are they excessively
           restrictive? The PEIS is conspicuously silent. on a large number
           of issues relating to current and future regulation and management.
           We suggest that the PEIS specifically address the current
           management structure in relation to the environmental impacts
           documented or demonstrated by this document.

           What is the intention of the PEIS regarding the management of
           delayed release net-pens? These facilities are surely net-pens and
           likely will fall under many of the same management constraints.
           Yet, they have different management concerns and therefore have
           different impacts on the environment.        The PEIS makes a weak
           attempt to distinguish between strategies, however, on many issues
           they are innately linked. Is it the intention of the Department
           of Fisheries to conduct a separate environmental analysis specific
           to delayed release facilities? If so, then they should be clearly
           excluded from consideration in this PEIS.           If, however, the
           intention is to include delayed release pens in this environmental
           analysis, they should be clearly and specifically included
           throughout the analysis with similarities and differences included
           on the discussion of each topic.

           We believe that net-pen structures can have beneficial impacts on
           some environments.       Biostimulation can occur from increased
           nutrient loads in an otherwise limiting environment. Perhaps more
           importantly, the physical structure of the pens can act as a
           floating reef. This introduced habitat may serve as an attachment
           point for marine invertebrates and marine flora. Mobile organisms
           may -.L:ind shelter at a net-peii site.    In short, a whole marine.
           community can develop on and around a net-pen site. We do not see
           this effect documented in the PEIS, and we feel that it should be.
           These communities themselves have apparent. -effects on the
           environment, many of which may be positive. Additionally, these
           impacts may offset other impacts which are perceived as negative.

           Commercial fishing is included as a potential impact or
           interaction.    The analysis focused on negative effects of gear
           interaction.     Why did you not examine- the potential positive
           contribution to commercial fishing? Even though you seem to have
           set aside the delayed release facilities as an issue which I noted
           earlier, net-pens also can serve as an attraction to free swimming
           fish. This concentration of fish in proximity to net-pens can aid









         Duane E. Phinney - Net-Pen PEIS
         April 6, 1989
         Page 3

         the commercial as well as the sports f ishery in targeting their
         efforts. We feel that this potential should be noted.

         The PEIS attempts to examine floating net-pens. This is conveyed
         in the title and the introduction.    Why then do you include a
         section on tank farms? These operations are very dissimilar and
         their mention only serves to cloud the issue. Or, alternatively,
         if the intention is to look at all forms of fish culture, perhaps
         you should expand the scope to include hatcheries.

         As we have stated, we feel that WDF has done an excellent job of
         characterizing the "Affected Environment", including the range of
         impacts that might be expected and the potential mitigation that
         could minimize those impacts. We are hopeful that the PEIS can
         also better address the real programmatic issues involving net-
         pens. As you state on page 8, existing "rules may be modified as
         a result of this PEIS11. What we all need is an analysis of what
         modifications are in order and a series of alternatives which give
         real options for how to proceed.

         The Squaxin Island Tribe is in a unique position.        It is a
         proponent of properly sited net-pens and has considerable
         experience upon which to base its judgments. Yet the Tribe would
         vigorously oppose poorly sited pens that would have a negative
         impact on the resources of importance to the Tribe.     The Tribe
         actively participates in research to broaden our understanding of
         resource impacts.      The Tribe's desire is to develop an
         understanding of whether net-pen management will proceed in a well
         documented scientifically based manner. Much good information has
         been presented in the PEIS document.       What we do with that
         information is the focus of our concerns. We urge the Department
         of Fisheries and the drafters of the EIS to examine more closely
         the objectives of the document and to provide a better analysis of
         where we go from here.



         Sincer



         Jef   ickison, Biologist
         Sincer




         Je









               RESPONSE TO LETTER NO. 27: SQUAXIN ISLAND TRI13E


               1.    Comments noted. The information in this FEIS can 'be used by State agencies
                     and local governments in their subsequent planning efforts related to the fish
                     farming industry.

               2.    The text has been revised to evaluate existing regulations and guidelines in the
                     FEIS.

               3.    See the response to Question 2.

               4.    See the response to Question 21.

               5.    The creation of new habitat on and near fish farms was noted in the text of the
                     DEIS under the impacts portion of the Fish and Shellfish section.

               6.    Fish may be attracted to the farm site, but commercial fishing boats would be
                     unlikely to operate close enough to the farm to bene-Fit from. any fish near the
                     farm. The positive aspects of farms on the recreational. fishing you mention were
                     noted on page 119 of the DEIS.

               7.    See the response to Question 32.

               8.    The text has been revised to evaluate existing  regulations and guidelines in the
                     FEIS.     In addition, the Preferred Alternative in the FEIS includes
                     recommendations for expanded regulations and additional guidelines.





                                                                 LETTER NO. 28








                Comments on DPEIS: Fish Culture in Floating Net Pens



           General Comment


               One potentially serious problem is that this PEIS will be
           (and @Iapparently already has been) used by local officials to
           avoid,the site specific review process. The main conclusions of
           the report indicate, however, not that there are no important
           impacts but that they depend heavily on the specific site.
           Proper siting" is the key issue in 2 of the 4 major conclusions
           and 7 of the e impact areas cited. I think the Department should
           make this chief implication of the EIS clear - that site specific
           reviews are essential, that this document can be used as
           background material, but in no case should it be employed as an
           excuse to avoid a site specific EIS. This should be stated
           clearly and upfront in the final version.


           Comments on Appendix E, Economics of Salmon Farming

           Purpose

               'The Statement of Work for the economics section of this PEIS
           reads,as follows: "What is the potential impact a+ net-pen
           operations on the local economy, on the value of adjacent
           property, and on the local fishing industry?" However the present
           report deals principally with the fiscal impacts on state  &
           county government, as well as the impacts on business revenues!1
           income & employment. The report addresses but comes up with no
           valid conclusions an the issue of property value (see below) and
           fails to address the question of impacts on local fisheries in an
           unaggregated -form. The statewide assessment and assessment of
           impacts on local government were unasked for.

           Methodology

                Input/output (1/0) is a standard methodology that puts heavy
           demands on available quantitative data. In the time-honored
           tradition, this approach simply ignores impacts which are hard to
           measure. Stokes follows the tradition. In the present case the
           important issues of loss of tourist income and the general
           perception of lowered recreational value are not dealt with.

                1/0 was developed in the 1930's before the economic
           implications of environmental deterioration were widely
           appreciated. In the 1970s the inventor of the procedure, W.
           Leontief, and several of his followers (R. Costanza, B. Hannon)
           broadened the approach to take into account environmental losses

           Fishpen Comments                 Page I                 Stapleton












             due to economic activity. Unfortunately Stakes does not use these
             more comprehensive matrices, and so misses, in my Judgement, one
             of the major points to be made here - that salmon farming has
             serious economic consequences precisely because of its
             envionmental impact. For example I have heard one estimate of the
             BOD load of a moderately sized fish pen as equivalent to a city
             of 10,000 people. In the modern methodology this cast (which is
             easily calculated in $/lb BOD) would be factored into the
             calculations.


             Regional Economic Impacts

                  Using highly aggregated matrices (e.g. Table 2.1), as is
             done.here, hides specific but important impacts. A case in point
             is tourism, a flourishing industry in many of the impacted areas.
             Tthe inputs and outputs of tourism are (probably) divided up
             among Agriculture, Construction, Retail Trade, Real Estate &
             Services. There is no way to separate out the? impacts on tourism
             from this analysis. But a decision maker in an area with a
             decaying resource extraction industry and a strong and growing
             tourist industry and will want to do precisely this in ardor to
             forecast the longer term implications of fish farming.

                  Another question regarding tourism is: How well is this
             industry represented behind these other categories.      Probably
             not well. It is typical of number crunching awthods that they
             under-represent areas in which numerical data is difficult to
             obtain. Tourism is one of these. The true dollar flow in the
             tourist industry is usually much more than is recorded in any
             statistical summary. However an accurate representation of the
             tourism industry is critical to this analysis, since tourism may
             suffer one of the heaviest negative impacts of fish farming.

             State & Local Fiscal Impacts

                  The net impact on state finances of a 5 million lb net pen
             industry, as reported on pp 35-40. are quite ambiguous. Three of
             the four measures of economic viability indicate a net loss. Yet
             this basic result is not highlighted. On the contrary the tone of
             the executive summary in reporting these results is quite
             optimistic and indicates an unexceptional positive impact
             "...Washington's economy would, in any event, benefit from
             further growth in fish farming..." a conclusion Table 5.5
             contradicts.


             Property Values

                  The property value analysis Section VI is gratuitous,
             leading to no conclusion relating to the question at hand
             whether salmon farms reduce property values. The author states
             that answering this question is beyond the resources currently
             available, which may be true, but does not justify the inclusion

             Fishpen Comments                 Page 2                 Stapleton












          of this irrelevancy here.

              The author restricts his analysis of the potential impacts
          of fish pens on property values to visual amenity. The latter is
          only one of several negative factors associated with fish pens.

              The mathematical procedure seems flawed. The author would
          explain through multiple regression the factors that enter into
          the determination of the price of real estate and thus show the
          maximum that visual amenity might contribute to that price. The
          logic is this: if 90% of the variability in the price of similar
          land (ocean front property) can be explained by other factors
          (location, bank size, improvements, etc) then visual amenity must
          account for no more than 10% of the variance. Unfortunately these
          variables (location, bank size, visual amenity) are not at all
          independent of one another, and a great deal of covariance
          exists. Using such variables undermines the mathematical
          robustness of multiple regression. The dependant variable can be
          over-determined (explanatory power over 100%) in these cases,
          making the exercise very dubious. - In any case this analysis
          seems to lead only to an estimate of the $ value of visual
          amenity in general, rather than to an estimate of the impact of
          fish pens, the question at hand.

          Benefit/cost Analysis

               It is surprising to see the author use benefit/cost analysis
          as a summary measure of economic feasibility rather than more
          balanced measures like net present value or internal rate of
          return. Benefit/cost ratios simplistically emphasize the short
          term considerations (money that changes hands each year), at the
          expense of long-term values (property value appreciation, water &
          air quality). Net present value would have been a more realistic
          measure.


               The assumptions an page 57 (10-20% range of reduction in
          visual amenity, 25-50 miles of affected shoreline) are wholly
          gratuitous inventions of the author. They are of course labelled
          as such in the accompanying text. Unfortunately all of the
          conclusions share this weakness. The entire exercise of Section
          VII is for "illustration." This characterization of the section
          by the author is further justified by his selective use of costs
          and benefits (see below). The underlying assumption of this
          section, that fishpens have little impact on visual amenity is
          supported by citing the opinion of an unnamed appraiser in an
          unpublished report.

               The point is that such academic exercises as Chapter VII
          have no place in an EIS. The task put to the author is to deliver
          the economic facts, both experential and inferential, about fish
          farming. The danger is that someone (probably many people) will
          read the conclusions of this chapter as facts, rather than the

          Fishpen Comments                 Page 3                 Stapleton












            results of a classroom drill. In fact a reader of -the glowing
            executive summary would be drawn to this erroneous
            interpretation, if he/she failed to read the proper caveats into
            such ambiguous expressions as "externally provided assumptions",
            & "necessary subjective judgments". I suggest that Chapter VII be
            deleted in the final EIS.



            In Conclusion


                  If the present report is flawed in what it delivers, it
            fails more importantly in what it fails to deliver. There are
            many more impacts with economic implications than Stokes deals
            with here, for example a wide range of lost recreational
            opportunities by landowners, residents, and tourists from visual,
            olfactory, & tactile impacts in the water and air as well as on
            shore. None of the potentially catastrophic issues raised
            elsewhere in the DPEIS, such as introduction of exotic species
            and chemicals, is even mentioned here. Some of the fish pen sites
            under consideration are retirement communities. Locational
            decisions by future retirees will be severely affected by the
            suspicion.of potential amenity loss (a suspicion strongly
            associated with fish pen farming at the present time), whether
            the suspicion is justified or not. Not included in this analysis
            is the tourist dollar loss to the affected community due to the
            perception that the area is no longer as pleasant a place to
            visit, to fish, and to walk the beach. Such costs are very
            difficult to quantify, but they are real. By electing to use a
            highly quantitative analytical method, the author has not simply
            overlooked these difficult-to-quantify or non-quantifiable costs,
            he has in fact given them a dollar value of zero.

                 The economics of this project is obscure and the present
            report has thrown only a little light on it. A simple descriptive
            balance sheet of private and public costs and benefits including
            the impacts mentioned above would have been useful in order to
            clarify the issues at hand. This analysis should have better
            incorporated the results of the other sections of this PEIS
            including especially Section E:aesthetics, K:upland & shoreline
            use, & Strecreation. Laying out the relevant factors, quantifying
            those that lend themselves, and leaving the-rest to the balancing
            judgment of the decision maker would seem to serve the public
            need better than delivering a table of 64 dubious numbers that
            fall out of an admittedly irrelevant methodology.




            James Stapleton, Ph. D. (Environmental Science)
            P.D. Box 52
            Joyce, WA 98343




            Fishpen Comments                  Page 4                  Stapleton














                                                                                                                           @n
             RESPONSE TO LETTER NO, 28: JAMES STAPLETON


             1.      As stated in the Summary under Phased Review, each fish farm proposal must
                     comply with the State Environmental Policy Act. Local jurisdictions will use the
                     best available information when completing SEPA review to determine the
                     significance of potential impacts related to specific proposals.

             2.      Comments noted. See the response to Question 12.                                                      0

             3.      See Section 1 of the response to comments after the            text in Appendix E.

             4.      See Section 1 of the response       to comments after the      text in Appendix E.

             5.      See  Section   1 of the  response   to comments     after the  text in Appendix    E.

             6.      See  Section   3 of the  response   to comments     after the  text in Appendix    E.

             7.      See  Section   4 of the  response   to comments     after the  text in Appendix    E.

             8.      See  Section   4 of the  response   to comments     after the  text in Appendix    E.

             9.      See  Section   5 of the  response   to comments     after the  text in Appendix    E.

             10.     See  Section   4 of the  response   to comments     after the  text in Appendix    E.

             11.     See  Section   4 of the  response   to comments     after the  text in Appendix    E.

             12.     See  Section   1 of the  response   to comments     after the  text in Appendix    E.

             13.     See  Section 5   of the  response   to comments     after the  text in Appendix    E.





                                                                        LETTER NO. 29


                                    RODNEY H. STEBBINS
                                    205 SWINOMISH DRIVE
                                LACONNER, WASHINGTON 98257
                                                         April 7, 1989

              Ron Westly
              Washington Department of Fisheries
              115 General Administration Building
              Olympia, Washington 98504

              Dear Mr. Westly:

              Please see the enclosed copy of my letter oif March 12, 1989 addressed
              to Betsy Stevenson of the Skagit County Planning Department in
              which I express my opposition to the proposed seaweed farm in
              Northern Padilla Bay and to any further placement of fish-rearing
              pens in the waters of Skagit County.

              Please include the contents of the enclosed letter copy-in your-
              compilation of objections to,any further expansion of aqua-
              culture projects within the waters of Western Washington.

              Since writing my letter to Ms. Stevenson, I have learned that
              the State of Washington may well be in violation of our state
      (D      constitution which appears to prohibit the rental/leasing of
              the waters in question for any purpose. whatsoeverL It may be
              claimed that the State is onlly leasing the bottom land rather than
              the surf ace waters. T-f such is: the caire plea e be sure that all
              aqua---ultur-e facilities are located at the bottom rather than on the
              surface of the waters in question.

              Please be good enough to keep me informed as to the final disposition
              of this matter.


              M     ince   y
                   si
                     @cert y
              :Tni @_y __ ft ins.
                      0 tebb










                                RODNEY 14. STEBBINS
                                205 SWINOMISH DRIVE
                            LACONNER, WASHINGTON 98257   March 12, 198!)
         Me. Betsy Stevenson
         Skagit County Planning Department
         County Administration Building
         Mount Vernon.-Washington 98273

         Dear Ms. Stevenson:

         This is to record my total opposition to the proposed seaweed (Nori)
         farm proposed for the Guemes-Jack Island area in northern Padilla
         Bay and to any further placement of fish-rearing pens in our County.

         Why the Skagit County Commission even considers the approval of
         such projects is beyond my comprehension. I grant that our County
         needs to encourage new business in order to increase job opportunitiess
         and to enlarge the tax base4 Howeverl these enterprises offer very
         little in the way of new employment opportunities for our citizens
         and their existence is bound to lower the value of nearby real
         estate, thus reducing property tax revenues.

         The proposed seaweed farm will adversely affect commercial and
         sport fishing and crabbing and will prove to be a serious hazard
         to navigation for the commercial and pleasure boaters who@make
         extensive use. of the waters involved.-

         When major efforts ar-e underway to clean up wters of the Puget
         Sound area it seems ridiculous to encourage the expansion of
         activities which must surely conioibute to the lessening of water
         quality.

         The negative aspects of these projects so greatly outweigh any
         benefits as to make approval by the County Commission totally
         inappropriate and not in the best interest of the residents of
         Skagit County*
         Mos   inc7rely..
                "tALL-1
         Rod Stebbins
         LaConner

         ect Skagit Valley Herald
             Channel Town Press
             Anacortes American
          08










         RESPONSE TO LETTER NO. 29: RODNEY H. STEBBINS



          1.   Comments noted.


          2.   See Section 8.3 of the FEIS which discusses the Public Trust Doctrine.







                                                         A-@
                                                               LETTER NO. 30






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        @O            RESPONSE TO LET17ER NO. 30: MAYNARD A. SIZINBEIRG
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                       1.       Comments noted.
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                                                                   LETTER NO. 31


      Solveig H, Thomson, Ph.D., P.S.
             Clinical Psychology
               Psychotherapy                               1107 N.E. 45th street, suite z05
                                                             Seattle, Washington 98"05
                                                             Telephone: (206) 547-117-06

                                                     April 4, 1989
            to.,


            eir
            0 LN ^110MJ

           btat 8 lirb

           We are writing to oppose placing aquaculture pens for salmon
           breeding in proximity to environmentally sensitive shorelands
           such as near the Cam Beach recreational area close to Camano
           Island State Parks

           At this time, there are too many serious questions about too many
           aspects of this plAh. Some typical issues include intermingling
           of wild and farmed fish, gene pools, disease (see Dr. Whiteley's
           accompanying article), water quality, noxious bottom sediment,
           effects on birds, mammals, plankton, predators, and chemical
           effects altering natural immunity of fish. Also more issues
           relate to aesthetics, noise, odor, human health, recreation,
           navigation, and upland and shoreline use.       Economic issues and
           local government input are further concerns.            Who really
           benefits and at what cost?      What about more focus on building
           natural fish runs and land-based tank farms?           Pollution is
           pollutioni     Let us not move hastily on placing questionable
           salmon pens in our treasured Northwest environment.

                                                     Sincerely yours,






                 Sea farm study deficiencies noted



               By CAROL BYNG                               *Nor were the effects on mam-           health, recreation, navigation.
               Island County Correspondent               mals, birds and predators addressed.      upland and shoreline use were skim-
                                                           .Chemicals, including antibiotics      med over and the long-term effects
                 Shoreline Planner Mike Morton           and alterations of natural immunity       were not addressed.
               gave the Island County Cornmis-           of local fish were not part of the           Land-based tank farms were not
               sioners a brief review of the Depart-     study.                                    mentioned.
               ment of Fisheries environmental im-         *Economics were not addressed.            *And last, but not least, the need
               PACt statement covering the effects         *There are no plans giving local        for another draft will be discussed
               of salmon-net fish farming in Puget       autonomy to the county.                    Public written comments will be'
               Sound.                                      The EIS did not evaluate the im-       accepted until April 7 and can be
                 Then he listed the deficiencies         pact on local government services,        mailed to: Ron Westley, Washington
               Island  County's attorneys, Keller        especially the need for enforcement.      Dept. of Fisheries, 115 General Ad_
               Rohrback of S-attle, intend to file        -Aesthetics, noise, odor, human         min. Bldg., Olympia, WA 98504.
               with the Department of Fisheries
               during the comment period:
                 -The draft EIS lacks specific
               recommendations about separation
               of wild populations and farmed fish,
               and they will cite Norway's Coastal                                BOOTH GARDNER
               Zone Management Program. They                                      Washington's governor
               Will call for an analysis of the com-
               patibility between salmon farms and
               existing regulations. And they want                                                     When Jean and
               the Public Trust Doctrine included.                                                     I want to get
                 *Department. of Fisheries has not                                                     away for a
               performed any studies about the                                                         weekend,our
               genetic effects if there is inter-                                                      favorite trip is
               breeding between escaped and wild                                                       to go home to
               fish, such as dilution of the gene pool                                                 our cabin on
               for wild fish. The mitigating                                                           Vashon Island.
               measures proposed are contradic-                                                        There's nothing
               tory or ineffective. Conclusions                                                        quite like a walk
               drawn in the EIS are not based on ac-                                                   on the beach at
               cepted literature or independent                                   Vashon, with the waves rolling in
               research.                                                          from the Sound, the huge trees all
                 *Diseases are not adequately ad-                                 around, the calls of birds, every-
               dressed and state regulations are in-                              where the signs of life, in water, on
               adequate to guarantee protection of                                land and-in the Ear.
               Wild or hatchery fish.                                              Our special get- away is very
                 "Several aspects of water quality                                much like many other quiet,peace-
               standards were omitted, including                                  ful island retreats sports throughout
                                                                                                       po s     0
               the effects of dissolved oxygen,                                   Puget sound and up to the San
               phytoplankton and fecal coliform.                                  Juan Island. We've never found a
                 'Many effects on the bottom sedi-                                place where it's easier to unwind,
               ment were not covered.                                             to relax, to renew our energy,
                                                                                  restore inner calm and prepare to
                                                                                  make a fresh start in tackling the
                                                                                  day-to-day challenges of life and
                                                                                  work. And besides, no pla ce       we
                                                                                                             
                                                                                  know of is more certain to   encour-
                                                                                  age an a reciation o the environ-    we hope ha   
                                                                                  men with which we in the North-      includes
                                                                                  West have been truly-blessed.        Cama Beach
																				on Camano		              

~0













         DANGER OF VHS VIRUS


                                                                              The report by the Fisheries Department (Bill                  and Wildlife Service thinks so, too.                               eggs can b
         ~q&~qO~qP ~qn~qr~luacu~2qf~2qture                                                 Dietrich's articl~qi in the March 2 Times), that VHS has                Instead of dodging this issue, the Fisheries and               quarantine
                         ~0qM~qi                                               not been found in countries from which the aquacul~-               Agriculture Departments should make certain that                   which ma
                                                                          ~ture indus      im rts Atlantic salmon eggs (Scotland,            net-pen a uaculture of Atlantic salmon has not                     not carrie
         of At~ql~6qe ~0qM~-~6qf~6qic s~6qdmon                                              Norway a~qo~6qVin ~2qrnd) is incorrect. It has been                       ~in~troduc~q:~q5 this virus into Washington. Oregon, Idaho                  Such e
                                                                          reported from Norway. from which much of our net-                 and British Columbia have placec~f an embargo on                    to inactiva
                                                                          pen culture stems.                                                                                                                   VHS virus
         Arthur H. Whiteley                                                   The department is ~%~@~-rong also in its contention                                                                                 be protect
         Special to The Times                                             that Atlantic salmon ~!~u~i- ~r~he virus only if they are                                                                                 enter our
                                                                          injected with it ~q(a~f~th~o~ugh ~ihis alone shows that                    Instead of dodging the is-                                         ent. Unti
                                                                          A~t~lantics can ca~r~7-~; th~a~v~irus).                                                                                                      possibili~qtie
                                                                              At~lantics swimming briefly in water containing the             sue, state officials should                                       exotic spe~qc
                N MARCH 2~,your editorial called for cessation             virus can pick it lip and ~r~c~.~-~I~f~icate it extensively in                                                                                 We do
                of "~in~qxer-~qpointi~n~i~e~' at the source of th~er               their bodies, without d~c~v~e~l~qb~q@~in~- symptoms, according                  be certain that net-pen                                        this ~V~i~n~qi~qs is
         Osa~i~                  ~. ~qV~qRS~, which has appeared in              to studies in 1982 and 1965. ~'                                                           ~F                                           population,
         our waters. ~T~qhose of us in the Marine Environmental                  Thus Atlantic salmon can harbor and replicate this                    operations have not                                        and sports
         Consortium agree: We need to get at the probable                 virus without themselves being destroyed, and can                                                                                       These
         cause ~nd correct It (if it is not too late).                    thereby carry the virus. The 1982 researchers                         introduced the disease                                         steelh~e~qad
           This admonition applies to the marine consortium,              concluded:                                                                    into Washington-                                       disease. Th
         co    e~cial d            fishermen, and most of a~l~l to              "Taking into consideration ~ihe ability of viruses to                                                                             ~qh~i~r~ther at
         the=le in~ia~nt~qhe=ash~ing~ton Departments of                         produce variants and the fact that VHS viruses are                                                                                     Until ~qd~qd
         ~F~shenes and Agriculture - and u in the media.                   able to grow in Atlantic salmon, VHS is obviously a                                                                                  Atlantic ral
           The su estions made by Mr. ~qb~q"~lum of the                        potential threat to inte~ns~i~v~. salmon culture. Any                 importation of salmon smolts and eggs from Wash-
         Fisheries apartment, that the VHS virus came in on               project to rear Atlantic s~2~f~tnon should apply strict              ~i~n~4q%on~q, re are plenty of                                            place and
         rubber boots or in ship bilge, are improbable.                   sanitation rules tow~a~rdv~-~PS~.~"                                                               ~2qzues~tions that need answers.             demand ~qsw
         Rha~bdoviruses, including VHS virus;, are coated with                 We don't know if this sod disease has been                    Do any aquacul~ture faci 'ties in Washington have this
         a lip~d envelope and am fragile. VHS virus is                    introduced here by A~tlan~i ~ic salmon products or on                virus.                                                             ~4q0 Arthur
         inactivated by drying or by suspension in water for a            someone's boots, but ~v~@e feel that the latter is the less           The state has a three-month quarantine on                        zoology kit
         few days.                                                        probable. We get the impre~rsion that the U.S. Fish                imported exotic fish eggs before the fry from such
 








    @O       RESPONSE TO LETTER NO, 31: SOLVEIG H. THOMPSON
    M


             1.    Comments noted.

    0        2.    The purpose of this EIS is to present the existing information regarding potential
    n              impacts of siting floating fish farms in Puget Sound, and identify areas where
    0              information may be lacIdng.

    CD





                                                                                                                                                LETTER NO. 32




                                                                                                  lillllllllwe@ nQ -
    Board Of Directors:                                       T H E T U UiMr-14                              92 %-a                       The Tulalip Tribes are the successors
    Herman A. Williams, Sr., Chairman                                                                                                             in interest to the Snohomish,
    Bernard W. Gobin, Vice-Chairman                                      6700 TOTEM BEACH ROAD                                               Snoqualmie and Skykomish tribes
    Debra L. Posey, Secretary                                              MARYSVILLE, WA 98270                                         and other tribes and bands signatorv to
    Stanley G. Jones, Jr., Treasurer                                                 653-4585                                                                                Ott.
    Stanley G. Jones, Sr., Member                                                 FAX 653-0255
    Dawn E. Simpson, Member
    Roy E. Hatch, Member
    Clarence H. Hatch, Executive Director



                    Mr. Ron Westley                                                                                                 March 20, 1989
                    Project Manager
                    Washington Department of Fisheries
                    115 General Administration Building
                    Olympia, Washington 98504


                    Dear Mr. Westley,


                    The Tulalip Tribes would like to submit the following comments
                    regarding the Draft Programmatic Environmental Impact Statement
                    for Fish Culture in Floating Net Pens.

                    While we believe the document provides much useful information
                    regarding many important issues which must be addressed prior to
                    large scale net pen operations in Puget Sound, the document fails
                    to offer any specific recommendations for mitigating likely
                    impacts, does not mention several types of potential impacts to
                    existing fish stocks, and fails to recognize Treaty Fishing
                    rights, including co-management authority of anadromous fish.

                    Specifically, we believe the following should have been addressed
                    in the DEIS:

                              1. The DEIS does not clearly outline what management action
                    is being proposed. The document discusses potential impacts of
                    floating net pen culture in a generic sense but does not propose
                    any specific plan to control future development of this industry.
                    It is not possible for us to assess the advisability of increased
                    net pen culture until a specific management plan is proposed and
                    discussed.

                              2. The document outlines many valid concerns regarding the
                    effects of net pen facilities on such resources as water quality,
                    benthic biota, marine mammals and birds, commercial and
                    recreational fishing, etc. While this discussion is informative,
                    the document fails to identify any specific proposed mitigation
                    measures.               While it may be true that many of the potential
                    impacts to existing resources can be mitigated through proper
                    siting and              management, no siting criteria or siting processes are
                    proposed.               Without the description and discussion of specific
                    mitigation              measures for site specific conditions, it is not














           possible to make any meaningful comments regarding increased net
           pen operations on Puget Sound.

                3. While the document mentions that non-Indian fishing
           activities might be disrupted (pg 113 ) , thereby placing the
           state in violation of federal court orders, the document fails to
           discuss impacts to Indian fishing and their related legal rights.

           It has been our experience that state and local government have
           very little knowledge of treaty fishing activities and have
           generally taken the position that the tribal fisherman can be
           displaced to "other fishing areas". Tribal fishing activities
           are restricted to Usual and Accustomed fishing, areas which are
           limited in size. This is not the case for the: non-Indian
           fishermen. Further, many areas are either less desirable for
           fishing or are not fishable at all. Reduction. of fishing area is
           of great concern of the Tribes, particularly in the absence of
           any state policy designed to protect them.

                4. Several potential biological effects are not covered by
           the DEIS. Net pen operations could deplete important populations
           of food organisms used by existing salmon populations. The fish
           within the pens are also predators on juvenile fish migrating
           past and through the net pens. While these impacts would occur
           locally, they could well have impacts on fish stocks which are
           important regionally. Without specific locations identified for
           net pen sites, it is not possible to assess these impacts.

                5. The document does not mention tribal co-management
           authority with the State of Washington over anadromous fish
           resources. The further development of net pen facilities will
           effect these resources, their management, and t.heir value, as
           described by the DEIS and our comments. We believe it is clear
           that the Tribes share management authority with the state over
           this matter and should be included in the decision making process
           as equals with the State.

           In summary, the document fails to propose any specific management
           plan or mitigation measures such as siting criteria, is not
           supported by any site specific analysis of impacts to the
           environment, does not describe in any way the impacts to Treaty
           fishing, and does not recognize the co-management authority of
           the the Tribes. These deficiencies should be corrected in a
           revised DEIS.















        Net pen aqualculture has the potential to benefit all residents
        of the state, however this DEIS fails to adequately address the
        serious issues which must be resolved prior to large scale
        development of this industry.

        Finally, we ask that the State establish a forum for working
        cooperatively with the Tribes to develop the recommended
        management plan. It is our desire to develop the potential of
        net pen aquaculture while protecting existing resources and
        resource users.



        Sincerely,
        The Tulalip Tribes





         e    Williams
          sheries Director









               RESPONSE TO LETTER NO, 32: THE TULA-LIP TRIBES


               1.     The EIS evaluates potential environmental impacts associated with fish farms, but
                      is not a management plan for the aquaculture industry.

               2.     Every element of the environment in the DEIS, such as water quality, commercial
                      fishing, and aesthetics, includes a section on specific: mitigation measures that
                      could be used to minimize potential impacts. T      'be text has been revised to
                      evaluate environmental impacts of the fish farmin      g industry under existing
                      regulations and guidelines in the FEIS. In addition, the Preferred Alternative
                      includes recommendations for expanded regulations and additional guidelines.

               3.     The Commercial Fishing section of the DEIS stated that treaty tribes can only fish
                      in their usual and accustomed fishing areas. The text has been revised for the
                      FEIS to clarify the potential effects of fish farms on tribal fishing efforts.

               4.     If the reviewer is speaking of the loss of salmon food organisms on the bottom,
                      the issue is discussed in Section 5.1 of the FEIS. If the reviewer is speaking of
                      farm fish consuming zooplankton, one has to bear in rMind that farm fish are fed
                      many times per day. Zooplankton would constitute a very small portion of their
                      diet. Prey fish would not be expected to enter the pens in significant numbers If
                      hundreds of predators were inside. If prey fish are seen in the pens, then Salmon
                      are not eating them.

               5.     The DEIS specifically stated that the tribes and VVDF establish a management
                      plan every year for each salmon species.





                                                                              LETTER NO. 33


                        United States Department of the Interior

                                    FISH AND WELDLEFE SERVICE


                                        Ecological Services
                                    2625 Parkmont Lane SW Bldg B
                                     Olympia, Washington 98502
                                      206/753-9440@ FTS 434-9440

                                           March 22, 1989


          Mr. Ron Westly, Project Manager
          Washington Department of Fisheries
          115 General Administration Building
          Olympia, Washington 98504


          RE: Programmatic Environmental Impact Statement - Fish Culture in Floating Net
             Pens


          Dear Mr. West]W:

               The Fish and Wildlife service (Service) will be unable to provide
          detailed review comments on the above referenced document.


               The document contains considerable valuable information for the future
          evaluation of proposed projects subject to federal permits for which the
          Service has review responsibilities.  This additional and separate evaluation
          by the Service would be conducted pursuant to the Fish and Wildlife
          Coordination Act (16 U.S.C. 661, et seq), or with other relevant statutes. In
          the review of site specific project proposals, the Service may concur, with or
          without stipulations, or object to the proposed work, depending on specific
          development practices which may impact fish and wildlife resources.

               In the event that a permit from the Corps becomes necessary, the project
          sponsor is encouraged to contact our office (above phone/address), prior to
          permit application. We may be able to give guidance on design criteria which
          will facilitate the permit review process.

               We appreciate notification of this project and the opportunity to
          comment.


                                             Sincerely




                                             David C. Frederick
                                             Field Supervisor

          JWC:dj
          cc: WDE, WDW, EPA





                I




        @O           RESPONSE TO LETTER NO, 33: U.S. FISH AND WILDLIFE SERVICE
        M
        W
        v
        0
        0
        rA            1.        Comments noted.
        M
        Owt.
        0
        n
        0
        S
        S
        M
        w
        "-P.
        W




























    I





                                                                    LETTER NO. 34

                                                   4516 University Way N.E.
                                                  Seattle, wA 98105
                                                  March 22t 1989



         Ron Wastley
         project Manager
         Washington Department of Fisheries
         115 General Administration Building
         Olympia, WA 98504

         Dear Mr. Westley,

              The members of the Board of Puget Sound Alliance would like
         to express their appreciation for your efforts in sending us a
         copy of the EIS on Fish Culture in Floating Not Pons.

              We would urge you to establish a moratorium pending additional
         information and assurances that the biological integrity of Puget
         Sound and ihs living resources not be compromised.

              We feel that there are too many issues for which we do not
         have definite answers such as:
              Where did the HSV come from since it has not appeared in
              our wild stock before?
              What impact will the fascal waste from the net pens have
              on the benthic life in the area?
              What impact will the Atlantic salmon have on our native stock?
              Will the Atlantia salman d8 in 8ue stselhead?
              Why should we dirty up the waters of Puget Sound by net pens
              when we have been trying so hard through the Puget Sound
              Water Quality Authority to clean up the Sound?

              We urge that additional studies be carried out in an attempt
         to answer some of these questions before we would feel comfortable
         in having fish pen aquaculture carried out in our waters.

              Thank you for your consideration.

                                                 Sincerely,
                                                           921
                                                 Sally J. van Niel
                                                 Secretary
                                                 Puget Sound Alliance









               RESPONSE TO LETTER NO. 34: PUGET SOUND ALLUNCE


     W         1.    Comment noted.
     M
     P-01
     0         2.    See the response to Question 29 and Appendix G.

               3.    See Section 5.1 of the FEIS.

               4.    Atlantic salmon pose a very low environmental risk. Steelhead out compete
                     Atlantic salmon in freshwater as juveniles and adults. Competition in the marine
                     environment would only be of concern if the carrying, capacity of the ocean is
                     exceeded. See the discussion in Section 5.6 (Importation of New Fish Species)
                     and Section 5.7 (Genetic Issues) of the FEIS.

               5.    Comment noted.





                                                               LETTER NO. 35





        April 5, 1989




        Washington Aquaculture council
        1625 Grant street
        Port Townsend, Washington 98368


        Washington Department of Fisheries
        General Administration Building
        Olympia, Washington 98504
        Attn: Ron Westley, Project Manager


        Re: Draft Programmatic Environmental Impact Statement

        Dear Ron,



        After careful review of the Draft and Technical Appendices, I
        would like to thank you for a job well done. The documents do
        not whitewash the net-pen industry, but do provide a filter of
        rationality for most of the hysterical and/or scientifically
        undocumented claims on the negative impacts of salmon farming.
        The document also highlights the fact that this state has no
        intention of duplicating some other country's past siting
        mistakes. one reoccurring attitude I see prevalent with
        opponents to net-pen culture is the refusal to admit that
        Washington State already has extensive permitting structures in
        place to prevent siting errors. Regarding the more technical
        biological aspects of the document, such as plankton bloom
        activity, etc., there will be scientists and industry specialists
        whose comments will be more useful to you.

        The major problem I see included in the document is described
        succinctly in the Summary on page x. This is under Major
        Potential Impacts and Actions to Minimize These Impacts, number
        3. Essentially, this statement recommends the use of SEPA to
        empower localities to pass judgement on which stock can be grown
        by an individual project. I would like to remind Department
        staff of a statement which was reiterated with great emphasis at
        a recent SEPA workshop. This was a conference held on "The
        Limits of Land Use Regulatory Authority," December 8, 1988 and
        sponsored by the Institute for Environmental Studies at the
        University of Washington and the Environmental and Land Use Law
        Section of the Washington State Bar Association.










           This statment is that the SEPA process is an overlay. It is
           designed to fill gaps in regulatory efforts to prevent
           environmental harm. The SEPA process in itself, is not
           independent of any other level of authority nor specific
           regulation that may concern a project. Regarding the choice of
           stock selection which a net-pen farmer can use, this choice is
           already subject to regulation by the Department of Fisheries.
           This regulation must be done in conjunction with the Department
           of Agriculture, which has equal rule making power over the
           aquaculture industry and shares this jurisdiction by state law.
           This ability to regulate all forms of aquaculture if; already
           available to these Departments, and using SEPA authority is
           unnecessary and inappropriate. SEPA is a tool for protection
           which is not provided, not an extra layer of regulation
           duplicating or conflicting with existing oversight.

           If i growing a particular animal is a threat to indigenous fish,
           this threat does not end within a limited geographic boundary.
           The threat, (if it is not simply a vague potential,) affects
           stocks in all related waters and must be regulated on a state
           level. SEPA authority could be abused to pass locally convenient
           judgements on what animals cannot be grown. This action is quite
           possible in light of the present (and possibly illegal)
           moratoria. Such action will not protect public fishery stocks.
           This action will result in the very hodgepodge of inadequate
           regulation motivated by concerns other than environmental
           protection, that the Shoreline Management Act was designed to
           prevent.



           Sincerely,





           Lee Ann Bonacker









           RESPONSE TO LETTER NO. 35: WASHINGTON AOUACULTURE COUNCI



           1.     Comments noted.
                                                                                                          U
           2.     Comments noted.    The statement in the DEIS says that the State Environmental          0
                                                                                                          *a
                  Policy Act can be  used to prevent damage to local stocks. The SEPA review              W
                                                                                                          rA
                  process is used   by both local government and state agencies to review
                  development proposals. Local government does not have the expertise to make
                  decisions regarding fisheries resources. WDF has the expertise and responsibility
                  to manage all fish in marine waters except for steelhead and cutthroat trout,
                  which are managed by WDW. VVDF, not local government, uses the SEPA
                  process to review which stock may be appropriate for a proposal.






                                                                                                                                                                                      LETTER NO. 36
                                                Wasungton
                                                Environmen
                                                Council

              :PJDXN*44W                          4515 Univ. Way NE April 5, 1989
              Seattle, Washington 9810!k 5
              206-623-1483


              AA1JW - Washington Slate Division
              Admiralty Audubon Society
              Air Quality Coalition
              Alpine Lakes Protection Society
              Audubon Nature Center at Nisqually Reach                     Mr. Ron Westley, Project Manager
              Black Hills Audubon Society                                  Washington Department of Fisheries
              Blue Mountain Audubon Society
              Camano Island Homeowmer's Association                        115 General Administration Building
              Cascade Bicycle Club
              Cascade Wilderness Club                                      Olympia, WA                         98504
              citizens to Save Puget Sound
              Council for Land Care " Planning
              Everett Garden Club                                          Re:                  Draft               Programmable                            Environmental                                Impact
              Evergreen I lands Inc.
              Floating Hornes Amociation                                                 Statement (DPEIS) on Fish Culture in Floating
              Friends of Cypress Island
              Friends of the Columbia Gorge                                              Net Pens
              Friends of Discovery Park
              Friend of the Earth - E. WA, N. ID.
              Green=-Seattle                                               Dear          Mr. Westley:
              Hanford Oversight Committee of WA.
              Hood Canal Environmental Council
              Issaquah Alps Trails Club
              Izaak Walton League of America                                             Thank you for the opportunity to comment on
              Kengley Rural Association                                    the above-referenced DPEIS.
              K!tW Audubon Society
              Lower Columbia Basin Audubon Society
              Mt. Baker Watershed Protection Association
              North Cascades Audubon Society                                             WEC is committed to long term preservation
              North Cascades Conservation Council                          and            enhancement                             of Washington's                                      environment.
              North Central Washington Audubon
                Society                                                    Largely responsible for the passage of the State's
              North University Garden Club
              Northwest Fly Anglers                                        Shorelines Management Act, we have consistently
              Northwest Steelhead Salmon Council
                Of Trout Unlimited                                         worked to prevent unnecessary degradation of the
              Oak Harbor Garden Club                                       shorelines and waters of this State.                                                                                     We are
              Olympic Park Associates
              Olympic Peninsula Audubon Society                            gravely concerned that the DPEIS fails to                                                                              disclose
              People for Fair Taxes in Washington
              PlIchuck Audubon Society                                     the full array of probable environmental impacts
              Plateau Preservation Society                                 f rom additional salmon pen development.                                                                                Further,
              PRO-Salmon
              Protect the Peninsula's Future                               the proposed mitigation measures do not reflect
              Recreational Equipment, Inc.
              Save A Valuable Environment                                  the full array of appropriate mitigation for the
              Seattle Audubon Society                                      significant environmental impacts which may occur.
              Seattle Shoreline Coalition
              Sierra Club - Cascade Chapter
              Spokane Mountaineers, Inc.
              Spokane Audubon Society                                                    A general defect in the DPEIS is its f ailure
              Tahoma Audubon Society
              The Ptarmigans                                               to          follow the                           normal                 format                 for            an EIS                     of
              The Mountaineers                                             discussing in detail the anticipated impacts f rom
              Town Forum, Inc.
              Vancouver Audubon Society                                    the different alternatives but makes no serious
              Washington Citizens for Recycling
              WA. Council of Fed. of Fly Fishers                           attempt to distinguish between them in terms of
              Washington Fly Fishing Club
              Washington Kayak Club                                        anticipated impacts. This is particularly evident
              Washington Roadside Council                                  in the extremely brief discussion of participated
              Washington Trollers Association
              Wetlands of West Hytebos                      0              cumulative impacts, which is limited to two pages.
              Western Washington Solar Energy
               Association                                                 The implication is that if 87 additional salmon
              Whidbey Island Audubon Society                               pen farms were immediately placed in Washington
              Wildlife Society - Washington Chapter
              Yakima Valley Audubon Society                                waters there would be no significant cumulative
                                                                           impact as a result.                                              This is such an obviously
                                                                           flawed conclusion that it is evident that the
                                                                           cumulative impact section needs to be entirely
                                                                           rewritten.










             Mr. Ron Westley
             Page 2
             April 5, 1989

                   Unless the cumulative impact section is done adequately
             we would submit it would be illegal under SEPA for any particular
             new salmon pen applicant to rely on the conclusions in the DPEIS
             as a justification for avoiding a site-specific 13IS which fully
             addresses the state-wide cumulative impact. issues.          Of most
             concern on a state-wide basis are the potential for irreversible
             impacts from spread of disease to wildstocks from pen salmon and
             the potential for genetic alteration of native stocks from
             escaped pen salmon.     These and other issues are discussed more
             fully below.     In responding to these comments, please provide
             complete and detailed information.

                   Potential Disease Impact.     It is critical that a thorough
             review be presented of the disease transmission to wild stocks
             .experienced in Norway. Salmon pens have been, implicated as a key
             vector for the disease Gryodactylus salaris. The document fails
             to fully explore the likelihood of the salmon pens in the
             Washington waters acting as "multiplying stations" for this and
             other diseases, thereby putting pressures on the wild stocks
             which did not exist before.      The opportunity for wildstocks to
             swim in, or otherwise have contact with disease from, salmon pens
             needs to be addressed in greater detail, as does the need for
             mitigation measures by way of design and siting to avoid any
             disease transmission.

                  A continuing problem in the document is that it assumes that
             prevailing technology for salmon pens will be used in the
             future, without proposing as appropriate mitigation measures
             better design of salmon pens to prevent escaped :fish.        specific
             mitigating measures, such as strengthened anchoring           systems,
             multiple- fail-safe enclosure systems, and criteria to prevent
             location of net pens in weather-exposed areas must be fully
             considered.     Technical solutions designed to minimize the
             deposition of potentially contaminated fish feces must be
             considered to mitigate potential disease transmission.          It is
             technically feasible to use collection tarps, marine vacuums,
             Tumps and other devices to minimize the broadcasting of
             potentially infectious material into the waters surrounding net
             pens.   The DPEIS completely fails to consider these alternative
             technologies.

                  The DPEIS fails to consider the additional mitigation of
             specific improvements to Washington's regulations with respect to
             importation of eggs or fish to prevent the introduction of new
             exotic diseases.    At page 80, it is ironically stated that the
             current regulations have effectively prevented the introduction
             of VHS.     The fact that VHS has since arrived, whatever the
             source, underscores the need for more comprehensive regulations.
             It would be irreversibly disastrous if new exotic diseases were
             introduced to wild stocks through the import process.










          Mr. Ron Westley
          Page 3
          April 5i 1989

               Genetics:   The DPEIS appears to assume that any negative
          genetic impacts from escaped Pacific salmon from net pens will be
          minimal in comparison to the existing genetic impact on wild
          stocks associated with the massive hatchery release programs.
          This neglects the fact that a number of rivers in Puget Sound are
          not used for hatchery release. The potential genetic impact of
          escaped Pacific pen salmon on these river systems must be
          addressed. The DPEIS fails to propose as a mitigation measure
          specific siting criteria designed to prevent these potential
          impacts. Again full consideration of Norweign wild stock genetic
          problems caused by pen salmon must be addressed.

               The genetics section also fails to fully consider the link
          between inbreeding depression and long-term development of
          disease susceptibility in captive fish populations for those fish
          growers who use their own brood stocks. It is critical that the
          possible impact on the genetic structure of wild fish populations
          from unintentional releases particularly of Chinook and Coho from
          net pen farms be better addressed.       This section should also
          include a full discussion of first generation hybrid vigor,
          balancing selection, and other factors which can allow
          deleterious genes to persist in populations indefinitely.

               The document jumps to the conclusion that even if pen salmon
          escaped and even if some breeding stocks became established, they
          would be eliminated by natural selection. The selection      process
          is far more complex and must be fully explained.            A full
          discussion of the alternatives of prohibiting the use       of non-
          native Pacific salmon stocks and/or prohibiting excessive    genetic
          manipulation of local ct6ckn nagdg to ba addraccad          in tha
          mitigation section.

               With respect to both disease and genetics there is     a clear
          need for better biological inspection and oversight of the actual
          practices engaged in by fish farmers. This must be proposed as a
          mitigation measure.

               Other Concerns: The section on impacts to bottom sediments
          and the benthos fails to consider as a mitigating measure the
          imposition of National Pollution Discharge Elimination System
          permits under Section 402 of the Clean Water Act.       Further, as
          previously mentioned, possible mitigation by technical solutions
          to the deposition of feed and other materials which fall out of
          salmon pens must be fully considered.










            Mr. Ron Westley
            Page 4
            April 5, 1989

                 The section relating to impacts on water quality standards
            fails to integrate the presentation in the cumulative impact
            section regarding the very alarming levels of biological oxygen
            demand (BOD) that are likely to result from the proposed numbers
            of salmon pens.   Lay readers of this document need far greater
            information on the significance of BOD.

                 With respect to antibiotics, existing Washington regulations
            and laws appear inadequate to regulate their use on fish farms.
            There are negative effects from excessive use of antibiotics.
            The DPEIS should propose as a mitigation measure far greater
            controls on the procedures and quantities of antibiotics used.

                 With respect to preventing problems with Rredators, the
            DPEIS is inadequate in proposing as a mitigation measure that all
            net pens farmers should be "encouraged" to install anti-predator
            nets. (page 88).     This sort of easily achievable technical
            solution to prevent the possibility of massive releases of pen
            salmon due to net holes caused by seals and sea lions must be
            required rather than encouraged.

                 With respect to the problems caused by pdor, noise, garbage,
            and lights, the DPEIS authors apparently failed to investigate
            the actual experiences of neighbors of existing salmon pens in
            order to determine future likely impacts and the need for
            mitigation measures. There needs to be a thorough discussion of
            the situations where odors have been emitted from existing net
            pens, where lights have caused disturbance of neighbors and where
            garbage has washed on nearby shores.        Specific mitigation,
            including more strict enforcement of existing regulations, and
            consideration of additional regulations necessary to prevent
            these problems must be considered.

                 With respect to the discussion of upland tank farms, we
            consider this limited analysis to be inadequate to serve any
            useful purpose with respect to the future proposals for specific
            upland projects.    There are numerous additional potentially
            significant environmental impacts associated with upland tank
            farms that require consideration through a separate EIS.










          Mr. Ron Westley
          Page 5
          April 5, 1989

               conclusion:      The DPEIS is an inadequate basis for
          consideration of the probable impacts from future net pen
          development in Puget Sound. It is unreasonable to conclude that
          immediate development of up to 100 salmon net pens would have no
          signif icant impact.   This is obvious from the admitted fact in
          @he DPEIS that mitigation for certain potential significant
          impacts, such as navigation conflicts, can thereby cause other
  G       significant impacts, such as aesthetic problems.         A f ar more
          detailed and specific discussion of the probable cumulative
          impacts f rom, the alternative levels of development is absolutely
          essential if this document is going to be of any use in
          considering future salmon pen proposals.

               We look forward to receiving a copy of the f inal DPEIS in
          which the problems and defects set forth above have been fully
          remedied.
                                    Very truly yours,




                                  ,,@'rETIER T. JEICK;Ng'
                                     o-Chair, Co2rst & Shorelines Committee
                                    2121 4th Avenue
                                    Suite 2300, Fourth and Blanchard Bldg.
                                    Seattle, Washington 98121




                                    DAVID BkICKLIN, President
                                    Suite 1015
                                    Fourth and Pike Bldg.
                                    Seattle, WA    98101
          L0028









            RESPONSE TO LETTER NO. 36: WASHINGTON ENVIRONMENTAL COUNCIL


            1.     The FEIS includes an evaluation of the environmental impacts of fish farms under
                                                                                                              0
                   two regulatory alternatives: (1) existing regulations and guidelines (No-Action           U
                   Alternative), and (2) recommendations for expanded regulations, additional
                   guidelines, and further research (Preferred Alternative).

                   As described in the first three paragraphs of Section 7  of the FEIS, the process          0
                   of analyzing cumulative impacts is sequential. Decisions made on an individual
                   farm will be made with the knowledge of other nearby farms and other farms
                   proposed for an area.

            2.     See the response to Letter 1, Comments 15 and 16. Gyrodactylus salaris appears
                   to have been introduced into Norway by infected Atlantic salmon smolts which
                   were released into rivers for a "wild" fishery by the Ministry of Nature
                   Management not by aquaculture or fisheries.

                   Because of many factors discussed in Section 5.8 of the FEIS, it is highly unlikely
                   that fish farms would serve as a focus for new infections in feral stocks.

            3.     If fish farms were frequently breaking loose from their anchoring systems, specific
                   measures for stronger anchoring systems would be appropriate. However, a need
                   for stronger anchoring systems has not been shown to be necessary. Farmers
                   have a considerable economic investment in their facilities and would not be
                   expected to design insufficient anchoring systems.

                   The FEIS discusses techniques such as vacuums and blowers as a means of
                   reducing waste below the pens in Section 5.1.

            4.     Comment noted. See the response to Question 29.

            5.     The statement made does not neglect the fact that many rivers are not
                   supplemented by hatchery releases. Strays from any hatchery do not necessarily
                   miss the hatchery and continue upstream. It is more likely to miss the river all
                   together and enter another system.

            6.     An EIS should be readable by the lay public. For that level of detail about the
                   mechanisms of genetics refer to Population Genetics and Fishery Management by
                   Ryman and Utter, 1987.

            7.     The statement was made that maladaptive genes would eventually be eliminated
                   by natural selection, not that breeding stocks would be eliminated. There is no
                   reason to use non-local stocks of Pacific salmon because Pacific salmon are readily
                   obtainable here. The comment about prohibiting excessive genetic manipulation
                   is mentioned in the FEIS. Only three out of the 27 pending permit applications
                   are planning to use Pacific salmon.

            8.     See the response to Question 9.








               Response to Letter No. 36: Washington Environmental Council (continued)


               9.     See the response to Question 17.

               10.    See the response to Question 3. The concern with high biochemical oxygen
                      demand (BOD) levels at a specific site is the potential for the high BOD to lead
                      to a decrease in dissolved oxygen which could affect. marine organisms. The
                      potential impacts of a fish farm on dissolved oxygen levels are discussed in Section
                      5.2 of the FEIS. The effect of BOD is incorporated into the discussion of
                      decreased dissolved oxygen concentrations near fish fairms.

               11.    Comment noted. Regulation of use of antibiotics are extensive and administered
                      by the FDA and USDA.

               12.    The text has been revised to evaluate existing regulations and guidelines in the
                      FEIS. The Preferred Alternative in Section 5.9 of the FEIS recommends that
                      anti-predator nets be required in areas where WDWjJSFWS, or NMFS indicate
                      that predators may be present.

               1@.    The discussions of these potential impacts is based on the authors' and lead
                      agency's experience both observing fish farm operations and hearing testimony of
                      people living near these facilities. While taking account of this experience, the
                      DEIS focused on mitigating potential impacts from current fish farming techniques
                      and operations. Many of the problems cited were the result of out-of-date
                      operational procedures and regulatory controls.

               14.    See the response to Question 32.

               15.    Comments noted.





                                                                                     LETTER NO. 37

                                                                (206) 329-FISH P.O. Box 4486 Rolling Bay, WA 98061







                                           A S S 0 C I A T 1 0 N


                                                                         April 6, 1989


           Joseph R. Blum, Director
           Washington Department of Fisheries
           115 General Administration Building
           Olympia, WA, 98504

           Dear Mr. Blum:

           The Washington Fish Growers Association welcomes the continued efforts of the
           State of Washington to provide accurate information on generic issues
           concerning fish farming. The Programmatic EIS is a valuable contribution to
           these efforts.

           Our comments on the PEIS focus on four areas: the need to rewrite the Summary
           to more accurately reflect the,findings of the PEIS; specific comments on the
           contents of the report; the need for the PEIS to reflect the regulations on net
           pen development already in force, especially in the proposed mitigating
           measures; and finally, the need to relate the      PEIS to the standing of the
           Interim Guidelines and to actions under SEPA and The Shoreline Management Act.
           The comments are lengthy, but we feel the import   of the PEIS and the issues it
           addresses are worthy of our detailed attention.

           I. SUMMM:

           The summary of major conclusions and findings is the most important section of
           the PEIS. It is the only section that will be read by most people, especially
           policy makers. It should be as accurate as possible as well as comprehensive
           yet brief.

           Unfortunately, the Summary of the Draft PEIS is an inadequate reflection of the
           fine technical work that went into the study. It is neither accurate nor
           comprehensive.    Despite the primary importance of this section, it appears to
           have been written in haste and without an adequate appreciation of the
           technical issues.      The sections on major Conclusions and major Potential
           Impacts are weak and unnecessarily negative while distorting the technical
           findings, as is detailed below. Perhaps most serious, the summary does not
           reflect the underlying intent of SEPA regarding environmental impact
           statements.   This is indicated by the section on the purpose of the study, as
           we will now discuss.
                                                    Its










































           PURPOSE OF THIS PEIS. The statement that the purpose of the PEIS is "to
           evalu-ate -the@-envir7o-r-m-ental impacts..." is misleading. It implies that all of
           the elements investigated would have an impact. More proper would have been to
           say that the purpose was 11 ... to evaluate alleged environmental impacts of net
           pens in terms of their potential, given current laws and regulations, for
           significantly adverse effects..."












             MAJOR CONCLUSICNS. These do not seem to have been carefully thought out. Only
             a couple ol 'major conclusions are presented. other important results have been
             ignored, yet several minor points are made.

             Conclusion 1.     This conclusion is the most important, yet it distorts the
             actual findings of the PEIS. It starts out with the negative premise that
             major impacts are inherent to floating fish farms: "The major impacts of
             net-pen culture can be prevented by proper farm siting to assure dispersion of
             wastes, flushing of the site, and protection of sensitive areas". The use of
             the word, major, is inappropriate here and below in Major Potential Impacts.
             The proper SEPA terminology is "significant adverse impact', of which there is
             considerable discussion and explanation in WAC 197-11. We do not believe the
             study has shown that net-pens inherently have any such significant negative
             impact within the intent of SEPA.

             The major Conclusions section, and the Sunswry as a whole, suffer f rom a
             simplistic approach to the conceptual issues involved. No recognition is made
             here or elsewhere on the relevance of scale of impact, as in the case where a
             significant adverse impact may occur but to an insignificant extent, as can
             happen to the benthos by sedimentation.        Nor is their recognition of
             probability, where an impact would be certainly significantly adverse, as in
             the case of importing exotic disease, but is extremely unlikely. Also no
             mention is made of existing regulations designed to prevent significant impacts
             in specific situations. For these reasons, we believe that a more appropriate
             conclusion is:

                 Net-pen fish farms will not have any significant adverse impact on the
                 environment when properly sited, at a suitable scale, monitored, and
                 employing standard husbandry techniques.

             Conclusions 2 and 3. The second major conclusion is reasonable, but we are
             perplexed by the third, regarding importation of exotic diseases. This
             conclusion is inappropriate here because it represents a level of greater
             specificity    than the other three conclusions. It is also very misleading,
       0     because fish farming in Washington.state does not use imported exotic "animals"
             (i.e., fish), only certified eggs.

             Conclusion 4. "Proper siting" would not permit overdevelopment of small bays.
             If the conclusion that the development of 100 farms would not have a
             significant impact on the aquatic environment needs any qualification, the
             qualification should be that the location of these 100 farms would depend on
             site characteristics and siting regulations. The Conclusion should be so
             worded. Alternatively the Conclusion that 100 farms would have no significant
             impact could be qualified by statement under UN&VOIDNMZ SIGNIFICANT ADVERSE
             IMPACT that siting considerations to minimize one potential impact may
             exacerbate another.

             WOR POTENTIAL IMPACTS....     We disagree with both the form and substance of
             t
              F- section. wp
                is              questioF-whether most of the items listed qualify as "major
             impacts". And, as stated above, we do not believe that "major impacts" is the
             proper terminology for a SEPA document. We agree that the items listed
             represent legitimate concerns for potential significant impacts at the time of
             Scoping. The purpose of the PEIS was to determine whether they indeed were


                                                  Page 2











           significant, and we believe that the PEIS has clearly shown that they are not.
           We suggest that the proper heading should be, Major Findings.

           In addition to the failure to use SEPA terminology, this section, and the
           Summary in general, are deficient in failing to consider existing laws and
           regulations. This section speaks of actions, but ignores the key actions which
           have already taken place. Regulations regarding siting and farm size make
           improbable any significant impact from sedimentation and nutrient emission.
           The potential for disease transmission is greatly reduced by the prohibition
           against importation of live fish and tight controls over the importation of
           eggs.

                1. The impact described is very unlikely to occur under existing
                @egulations, the Interim Guidelines, which are enforced by DNR. But even
                in those worst case situations where azoic conditions have been found, we
                have not seen any convincing argument that such situations represent a
                significant impact on the overall environment. Parking lots and other
                paved-over or built-over areas are also azoic, yet are permitted.

                2. Nutrients...   This statement transcends current scientific knowledge in
                stating that nutrients released from fish farms can stimulate plankton
                production. Such an occurrence has not been documented for Puget Sound and
                its nutrient rich waters. It is theoretically possible, however, and the
                statement should substitute "could possibly" for "can". This statement
                also suggests actions which could reduce the potential impact, but ignores
                current regulations aimed at doing just that.

                3. Escaped non-native fish....        This statement does not reflect the
                decades of failure by State and Federal governments to establish runs in
                the Pacific Northwest of Atlantic salmon, the currently preferred fish for
                cultivation in Washington. Given this history, it is not correct to say
                that "escaped non-native fish could establish self-sustaining populations".

                4. Introduction of exotic disease with imported fish...        It is highly
                speculative and misleading to say that this is the "greatest potential risk
                to native species". Speculative, because the impact would depend on the
                disease;    misleading, because the potential, i.e, probabilityp of this
                happening is very small given current regulations and procedures.

                5. Impacts to marine mammals and birds....    By saying these impacts "appear
                to be limited," this statement strongly suggests that the impact is not
                significant and should say so.

                6. visual impacts cannot be avoided....     This is basically true, although
                submerged fish farms have been attempted. But it is also true of virtually
                all development projects controlled by SEPA. The issue is whether they
                would have a significant adverse aesthetic impact, and the PEIS has not
                shown that they have (see comment   ...... below).

                7. Pens can interfere...    That net-pens can interfere with commercial and
                recreational navigation and commercial fishing does not mean they have an
                inherently significant adverse impact. Usually the impact would amount to
                slight inconvenience, except in intensive commercial fishing areas.
                However, such areas are protected under SEPA procedures and under Tribal
                treaty rights, which are vigorously enforced by the Tribes.


                                                   Page 3











                8. No probable adverse impacts....    This statement is made unclear by
                reference to "actions presented above". What actions? In any case, this
                statement is misleading insofar as impacts to human health are concerned.
                It suggests that there are potential impacts but which can be "resolved"
                through actions.    This suggestion does not represent the technical
                findings, which indicate that there is no probable health risk. Because of
                the importance of the human health element, this positive conclusion should
                be treated as a separate finding and not grouped with noise, odor, etc.

                Another major finding which should be included here is the positive role
                fish farms have in monitoring and ensuring good water quality, as discussed
                on p. 129. Although an EIS focuses on the potential for significant adverse
                environmental impacts and does not need to present a balanced view of all
                environmental consequences, there is nothing to prevent an EIS from
                including positive impacts.

                The Findings of Appendix E concerning the positive economic impact should
                be referenced in the Summary.

           UNAVOITAM    SIGNIFICANT ADVERSE IMPACT. This statement belongs in the major
           Conclusi    section.     -9t-atemen-t-Se-re should be None.


           II. SPECIFIC COM12M ON THE CONTENT OF THE PEIS

           1.   1. Alternatives: Permits and Approvals:

                The Tribes should be included among those agencies who review permit
                requests, pages 10-12. It has been the experience of our members that
                conflict with tribal fishing rights can prevent a site from development for
                fish farming. Resolution of such conflicts must be done directly with the
                Tribes concerned. In one case failure to notify the appropriate Tribes of
                a fish farm application was successfully used as grounds for permit appeal.

                At the end of the discussion of commercial fishing, under mitigation
                Measures on page 114, paragraph two should include the Tribes along with
                WDF and commercial fishing organizations.


           2. 11. Affected Environment: Natural: Impacts to Bottom Sediments.

                Technically, this section is very good. But it contains a serious flaw
                in that it tends to be biased towards worst-case situations which do not
                reflect most net-pen sites. This occurs in two ways. One is that most
                case studies have been conducted in atypical situations. Two of the
                earliest studies, which still remain influential, were of fish farms in
                Henderson Inlet, which was in very shallow and poorly flushed water, and
                Clam Bay, with respect to the world's largest (until recently) fish farm in
                fairly shallow waters. The second bias arises from the fact that these
                worst-case situations are the most interesting: the changes are more
                dramatic and there is more for the researcher to study and analyze.







                                                Page 4














             It is indeed useful to know what the worst-case situations can be. But it
             would be wrong, in a document such as this which is directed at policy
             makers, to stress atypical situations. Yet, this is what has happened.
             Prominent at the top of p. 23 is the statement, "Azoic zones are reported
             under most pens... " followed by several paragraphs of graphic descriptions
             of azoic conditions reported by a number of researchers. Although not
             intended (there are qualifications buried in the text), the reader is left
             with a strong impression that azoic conditions are typical underneath fish
             farms in Puget Sound.

             This impression is false. It is also unnecessary. Sedimentation conditions
             have been monitored under most, if not all, commercial fish farms in Puget
             Sound.   The normal condition ranges between no visible sedimentation to a
             spotty or light dusting of Beggiatoa. It would be very useful to have a
             table listing all of the sites in Puget Sound, as well as those cited in
             the text for other areas, describing benthic conditions as well as the key
             variables affecting these conditions: depth, current velocity, loading,
             and years of operation.

             As a final, editorial, comment, it would be useful for Section b., Impacts
     0       of New Pens on Benthic Communities, to have more subheadings.

         3.  Water Quality:

             This chapter is generally very good to excellent. we particularly welcome
             the advancements to prevailing knowledge contained in the section on
             phytoplankton.    This is one area where the PEIS goes beyond previous
             studies of the impact of net-pen culture in Puget Sound. In so doing,
             however, it raises questions over the suitability of the standards used by
             the Interim Guidelines in controlling nutrient emissions. It describes the
             standard of limiting fish farms to one percent of the nitrogen flux in an
             embayment as using a "very conservative estimate of nitrogen flux." This is
             because only average surface levels of inorganic nitrogen are used,
             ignoring typically nitrogen-rich waters at greater depths and organic
             nitrogen at all levels. (We would also add that it ignores the actual
             tidal nitrogen flux: the average concentrations of nitrogen in the water
             coming into the embayment at flood tide, which can be several times greater
             than average surface levels found within.) The importance of this issue
             is, of course, that the standard of a one percent increase is used to limit
             the size of fish farms in 19 embayments. If this one percent level is to
             be retained, it can be argued (and should be, in certain cases) that the
             production limits should be increased. This is one area where we expect
             the PEIS to lead to changes in the current regulations governing fish
             farms.

             Unfortunately, the expert understanding of phytoplankton does not always
             extend to other parts of the discussion of water quality. Is is wrong to
             assert, as at the bottom of p. 35, that (along with upwelling)
             phytoplankton is a primary source of oxygen problems in Puget Sound. Nor
             is it valid to strongly imply (previously on the same page) that excess
             phytoplankton led to low dissolved oxygen levels and subsequent fish kills
             in the innermost areas of Budd Inlet. The cause of these sporadic kills
             has not been established, and this is only one of several speculative



                                              Page..5











                  causes that have been suggested. It is also a rather gratuitous example
                  here, since no fish famer would consider locating in such poor waters.
                  what appears to be the problem here, and in other sections of the study, is
                  that the scale and significance of small or peripheral environmental
                  disturbances (often naturally occurring) are editorially exaggerated. In
                  other words, the proper perspective stemming from a technical understanding
                  becomes lost, especially in non-technical statements, such as introductions
                  or summaries.

                  On p.36, it is stated that phytoplankton blooms may increase dissolved
                  oxygen through photosynthesis during the day (emphasis added). We believe
                  enough is known about photosynthesis to use the word does rather than may.
                  During the life of phytoplankton, they are apt to be net contributors of
                  oxygen.   This is why we object to the statements, cited above, suggesting
                  that phytoplankton adversely affects dissolved oxygen levels. It can
                  happen in extreme situations, such a shallow or stratified embayments, but
                  generally the opposite is true.

                  The discussion on p. 53 uses an example of five net pens when it means five
                  clusters of net pens, or five farms. This distinction should be maintained
                  throughout the text.

                  The section consisting of the top three lines on p. 55 and following
                  formula lies outside the text (it is in the nature of a footnote) and
                  should so be identified.

                  We disagree with the statement an p. 60 that the accumulation of antibiotic
                  residues in shellfish near fish farms has receivkl little study, and we
                  believe the subsequent discussion on pp. 60 and 601 belies this claim.
                  Also, the reference to the Wekell (1989) study should be expanded to
                  indicate that OTC was not found in the sediment saz%)les.

                  The paragraph on fecal coliforms (p.39) is an example of silly speculative
                  groping for an issue, i.e., impact, when none exists.

                  The positive role of fish farms in monitoring water quality, alluded to in
                  a later section, should certainly be addressed here. The presence in the
                  public water of users who are dependent on high water quality and who as a
                  part of their operation monitor water quality on a daily basis provides a
                  significant resource for water quality monitoring for general public
                  benefit.

             4.   Impacts of Exotic Fish Importation

                  This section is confusing and needs to be reorganized. Only the first
                  three paragraphs deal with exotic fish, i.e., Atlantic salmon. The
          0       remainder, over three pages, is concerned with the issue of interbreeding
                  among indigenous Pacific salmon and is irrelevant to exotic fish.

                  Since Pacific salmon are raised and released on a large scale as a regular
                  part of the State's fisheries enhancement program for commercial and
                  recreational catch, the risks of escaped fish from farms are far less
          G       significant than any that might arise from the delayed release component of
                  the State's enhancement program. This is alluded to on page 72 and 73, but



                                                    Page 6










                   should be highlighted at the beginning of the section. Since "genetic
                   impacts" is a commonly sited concern of the general public, and used
                   by opponents to argue against fish farms, it is extremely important to
                   write this section clearly.

          5.  Impacts on wildlife

              References on pages 87 and 89 are made to "some species" which will be
              impacted. Specific examples would be helpful.

          6.  Disease

              The section on VHSD, p77, needs to be rewritten. Inclusion of recent
              experience with this disease would be helpful.

          II. Affected Environment: B. Built Environment


          7.  Aesthetics:

              The information presented here was not used by the author of the The
              Economics of Salmon Farming,Technical Appendix E. As a consequence his
              analysis of implications for real estate values is seriously flawed.

              The introduction to the Aesthetics section, paragraph 3 on page 89, states
              "Many people perceive any structure placed in open water as creating an
              adverse aesthetic impact." This does not reflect the findings of the EIS,
              for example on Page 91 paragraphs 4 and 5. It would be more accurate to
              say in the introduction that some people perceive any structure placed in
              open water as creating an adverse aesthetic impact, while others do not.

              The analysis makes no comparison with other phenomena which have a visual
              impact on the water and shoreline. This is a serious omission, since
              aesthetic views may be equally or more significantly affected by log boom
              operations, marinas, clearcutting or residential development than they
              would be by a fish fam.

              There are a number of problems with the Figures in this section. Figure 14
              seems to misrepresent the view from House 2 by denoting a structure
              significantly larger than in the view from House 1. Figure 15 shows a five
              acre fish fam, not permitted under current regulations. Figures 16 and 17
              show a structure 2001 by 4801, although the typical facility shown in
              Figure 3. and referred to in the text is 100, by 10001. Figure 18 uses a
              10001 long configuration, and Figures 19, 20 and 21 show "two acres of net
              pens", no dimensions given.       Since the Figures are intended to be
              illustrations of the visual impact of net pens, it is imperative that they
              consistently use one set of dimensions if they are to be useful at all.
              A two acre site, 100, by 1000, is the more typical configuration.

              Figures 19,20 and 21 are only briefly explained on page 98. Since there
              are many other siting constraints, it is unlikely that the densities shown
              on the figures would occur in the real environment. It would be preferable
              to label and describe these figures as possible systems for regulating the
              distance between farms, not, as implied, proposed density of development.




                                               Page 7












             8.   Camrcial fishing:

                  The section discussing the difference in potential impacts, on Tribal and
                  nontribal fishing rights (p 105-6) should be reviewed. The system of
                  court-ordered allocation between Tribal and non-Tribal fishery is complex,
                  but the EIS description does not correspond to our understanding of how it
                  works.    It is our impression that an imbalance between Tribal and
                  non-tribal catch in one area is offset by catches in other areas or changes
                  in fishing schedules. we find it implausible that fish farms could cause a
                  displacement of commercial fishing which could "place the state in
                  violation of federal court orders".    We also question whether the presence
                  of net pens can so greatly impact fish migration as to prohibit their
                  capture.   No basis for this scenario is presented in the EIS and we have
                  not previously heard anyone express such a concern.

             9.   Upland and shoreline use:

                  ,Buried under this sub-heading is the discussion of the most positive impact
                .a net pen can have on the environment: "it will highlight water quality
                  concerns in the area." In addition, fish farmers monitor water quality as
                  part'of their daily operations; we are likely to be among the first to know
                  when water quality is degraded or altered. We also supply regular water
                  quality information in areas where no one else is collecting water quality
                  information, or not on a regular or frequent basis. Because fish farmers
                  are economically dependent on*high water quality, we place a priority on
                  maintaining that water quality, to the benefit of the general public as
                  well as ourselves.' Your discussion should include these facts, and the
                  subject should be covered under the section on Water Quality as well.

             10.  Land Based Farms:

                  The initial, and most obvious, point to raise about this section is to ask:
                  why was it included? Land-based fish farms were not included in the
                  scoping process, and they would appear to be specifically excluded by the
                  statement of the "Nature and Location of Proposal" in the Fact Sheet.
                  moreover, only a very narrow and relatively new segment of land based
                  fish-farms is analysed: large scale efforts to raise marine species. No
                  mention is made of fresh-water fish farms, such as trout farms. we do not
                  understand the logic which led to giving this segment so much emphasis.

                  Having expressed our perplexity, we should mention that we have no inherent
                  objection to including land-based farms.        our membership includes
                  land-based fish farmers, and we welcome any reasonable effort to dispel any
                  misconceptions they might face from policy makers. However, the resources
                  allocated to, the PEIS were very limited to begin with, and we are disturbed
                  that some of these resources have been directed at issues beyond the stated
                  scope of the study. This point is even more relevant to the economic study
                  contained in.the Appendix and discussed below. We believe that the
                  analyses of pertinent substantive issues have suffered because of these
                  misdirected efforts.






                                                    Page 8











               Finally, there are many questionable assumptions and errors of fact in this
               section. Because this analysis may not be included in the Final PEIS, they
               will not be discussed in detail here. But if it is included, the editors
               should have it reviewed by operators of land-based farms growing marine
               fish.    A key misconception promoted in this section is that land-based
               fish farms are experimental. The Icelandic operation, referred to on p.
               135 and operated by the parent company of one of our members, has been in
               production for three years and there are at least two operating farms in
               eastern Canada.      Thus, there is considerable experience on hand for
               correcting the errors in the analysis.

          11.  Technical Appendices: The Economics of Salmon Farming

               The first paragraph of the executive summary of this report makes a clear
               statement that the salmon farming industry will have "positive economic
               gains under all assumptions and substantial gains under assumptions
               favorable to the industry. It is unfortunate that the body of the report
               itself is so academic, and includes such flawed assumptions, as to be of
               little practical use. Of particular concern is the analysis of potential
               impact on property values. It assumes a negative visual aesthetic impact
               and a direct negative impact on property values, although no evidence of
               such impact exists. The report completely ignores the findings contained
               elsewhere in the PEIS concerning aesthetic impact of net pens. It is well
               documented and generally agreed that net pens are virtually invisible from
               less than one half mile away (EDAW: 1500-2000 feet; Alpine Appraisal: 2,400
               feet.)   Yet this report assumes a preposterous five to ten mile range of
               impact.    Already opponents have selectively quoted from this section
               claiming that the PEIS proves that net pens will have a negative impact on
               property values.

               The report states, on page 40, that it does not examine the underlying
               assertion that net pens can have negative visual aesthetic effects. "A
               simpler method is offered instead, which relies only on publicly available
               property value data."       Yet the publicly available data on the actual
               impacts of existing fish    farms on real estate are not examined, except in
               Note 3 and the References. We propose an even simpler method: include the
               data referred to as part of the PEIS. It examines the direct effects of
               net pen development on property values in Kitsap, Mason and Skagit
               Counties. It is contained in a report entitled "Influence of Floating Net
               Pens on Real Property Values." It was updated in March,1989 and that
               version should be used.

               With respect to the assumptions contained in Table 3.2, we should point out
               that it is very unlikely for hatchery labor to be in the same county as a
               fish farm, and this component should have a minimum of zero percent. on
               the other hand, it is possible for debt service to have a county
               distribution.










                                                  Page 9

















              III. MITIGNTION MEASEMES

              outside of the summary, the portions of the PEIS most likely to be read and
              used are the mitigation measures proposed throughout the various subsections.
              They are likely to be used by project applicants, project opponents, and
              decision makers charged with reviewing permit applications, whether or not that
              was the intention of the PEIS. It is important that these measures should be
              clearly  written, and justified by the findings of the PEIS. We have several
              concerns with the mitigation measures as they are currently drafted.

                  1.   Included are some very good measures.            However many of them are
                       already in place through existing regulations such as the Interim
                       Guidelines, SEPA and SMA procedures, and DNR leasing conditions. For
                       example, sensitive habitats are required to be identified and "buffer
                       strips" specified in section 3.0 of the Interim Guidelines. They are
          0            also the subject of State and Federal regulation. Measures already in
                       force should be so noted, for two reasons. One is to avoid regulatory
                       duplication, such as a local government appending conditions on a
                       permit which are already enforced by the State. The other reason is
                       that the lay reader of the mitigation measures proposed in the PEIS
                       may be left with the impression that fish farming is an unregulated
                       industry, when in fact we are subjected to numerous restrictions.

                  2.   Some measures proposed are impractical, for example the suggestion
                       that net pens be sited in areas which historically have dissolved
                       oxygen levels above 6 mg/l. Ambient water, even in the Strait of Juan
                       de Fuca, falls below 6 mg/l at certain times of year. Such a
                       regulation could prohibit fish farming in the state. Any future
                       effort to introduce into regulation the mitigation measures proposed
                       in the PEIS should be done only after careful. consultation with fish
                       farmers to ensure that they are a practical means to achieve the
                       desired effect.

                  3.   Some of the measures proposed are not suitable for regulatory action,
                       but are "best management practices".          The Washington Fish Growers
                       Association endorses such practices as part of normal farm operations.

                  4.   Some measures are unfairly restrictive, such as requiring boats
                       serving net pens to meet recreational watercraft performance standards
           0           for noise.      Net pens should not be subjected to regulations more
                       stringent than those applied to other similar vrater users.

                  5.   Some mitigation measures are proposed for which there is no documented
                       need.     In one case, under importation of exotic species, a detailed
                       list of mitigations is given as remedies for possible future farmed
           0           species, although it is stated that those species currently farmed
                       require   no such mitigation.       The inclusion of detailed mitigation
                       measures where no significant adverse impact. is found seems to give
                       credibility to alleged impacts. An important contribution of the PEIS
                       should be to lay to rest fears of alleged impacts which are unfounded.




                                                    Page 10











          We urge that you review all the mitigation measures in each section with an eye
          to the way they will be interpreted by a permit reviewer anxious to make use of
          the PEIS for informed and accurate comment on a particular project.

          IV. PMAMON OF THE PEIS WITH EXISTING REGULAMCKS AND PROCEWRES

          An outstanding and urgent question is "What next?" How does the PEIS affect
          the Interim Guidelines?      How will the PEIS-be used in the permitting process
          under SEPA and SMA procedures? As part of, or as an addendum to the PEIS there
          needs to be a recommended course of action to implement its findings. The PEIS
          will have no meaning if local and State decision makers do not know how it is
          to be used.

          For the Interim Guidelines, an absolute minimum step should be to endorse the
          Interim Guidelines as setting adequate or more than adequate standards to
          safeguard the environment.        This endorsement should be part of the PEIS
          Summary.     In addition, any recommended course of action should include a
          mechanism to relax those Guidelines which are more restrictive than necessary.,
          according to the findings of the PEIS.

          For the SEPA and Shoreline Management Act process, the Summary should make
          clear that those aspects which have no significant negative impacts (such as in
          Finding Number 8) need not be considered in a generic sense in reviewing
          individual    net   pen projects.      of course we agree that site specific
          considerations will continue to need to be addressed.     The Summary could and
          should serve as a checklist for decision makers, identifying generic issues
          with which they need not be concerned.

          Our coments are lengthy and may appear to be critical. on the contrary, we
          welcome the considerable effort of the State to provide accurate information on
          fish farming.     our comments are offered in the spirit of improving an already
          praiseworthy effort.

          Sincerely yours,




          John Forster, President

















                                                Page 11









            RESPONSE TO LETTER NO. 37: WASHINGTON FISH GROWERS ASSOCIATION



            1.     Comments noted.


            2.     Comment noted.                                                                               0


                                                                                                                rA
            3.     Comments noted.       The wording has been changed to clarify the relative
                   importance of the impacts.

                                                                                                                Q
            4.     The Summary has been rewritten. The FEIS includes an evaluation of existing                 04
                   regulations and guidelines that affect the fish farming industry.

            5.     The Summary has been rewritten and expanded.

            6.     The text has been revised.

            7.     The Summary of the FEIS has been rewritten.

            8.     The text has been revised to evaluate existing regulations and guidelines in the
                   FEIS.


            9.     Comments noted.

            10.    See the response to Comment 5.

            11.    Even though all attempts to establish Atlantic salmon have failed, it is possible,
                   though highly unlikely.

            12.    See the response to Comment 8.

            13.    Comment noted..


            14.    Comments noted.


            15.    Comments noted.

            16.    See the response  to Comment 5.

            17.    The potential benefits of fish farms are indicated in the water quality, navigation,
                   recreation, and upland and shoreline use sections of the FEIS Summary.

            18.    The Appendices were included to provide additional information. There has been
                   no attempt to evaluate any of the Appendices.

            19.    See the response to Question 8. The agencies discussed on page 10 through 12
                   of the DEIS are agencies involved with management of the fish farming industry.
                   Tribes are affected by fish farm development if the farms conflict with tribal








               Response to Utter No. 37: Washington Fish Growers Assodiation (continued) .

                      fishing, but they are not directly involved with regulatory management of the
                      industry.

                      As noted in the Preferred Alternative in Section 6.3 of the FEIS, tribes should be
                      notified of fish farming proposals that may affect their fishing activities.

               20.    Comments noted. When evaluating potential impacts of a proposal, it is useful
                      to assess worst-case situations.

               21.    Comment noted. This information is available from MR.

               22.    Comment noted.

               23.    Comment noted. The flux of dissolved nitrogen in and out a semi-restricted
                      embayment may well occur as two discrete boxes, surface versus bottom. Toward
                      the entry of an embayment, one would expect to find a gradient of increasing
                      dissolved nitrogen due to inputs from an outer mixing zone or advection of water
                      of more recent oceanic origin. There may be periods of surface water nutrient
                      depletion and repletion at the surface in these outer areas, dependant on vertical
                      mixing associated with tidal action and/or wind. See the response to Question
                      18.

               24.    Oxygen depletion in lower levels of stratified systems due to decay of phytoplank-
                      ton settling from highly productive surface areas is well established. In such
                      instances, phytoplankton blooms are a negative impact on dissolved oxygen
                      concentration.

               25.    The text is correct as presented. While the reviewer's statement may be generally
                      true, it is difficult to separate the effect of surface water heating versus
                      phytoplankton oxygen contribution. See Raymont's discussion of photosynthesis to
                      respiration ratios in Plankton and Productivity in the Oceans (Raymount 1980).
                      Only in a detailed research mode such as that used by Emerson (1987) in
                      "Seasonal oxygen cycles and biological new production in surface water of the
                      subarctic Pacific" (J. Geophys. Res. 92:6535- 6544). The respected source of
                      Parsons et al. (1984) concur with this position. The situation becomes even more
                      complex in coastal waters due to water mass mixing.

                      Additionally, there is often no measurable oxygen saturation signal associated with
                      phytoplankton production due to the effects of horizontal and vertical mixing,
                      natural variation of water mass source and other factors. Respiration or decay of
                      large phytoplankton blooms is thought to be one factor responsible for low
                      dissolved oxygen values.

               26.    For clarification, the text has been revised for the FETS to use the term "fish
                      farm!' instead of net pens.

               27.    Comment noted.








           Response to Letter No. 37: Washington Fish Growers Association (continued)


           28.   The text has been revised.


           29.   Comment noted.

           30.   The text of Section 5.2 of the FEIS has been revised to note that the fish farming
                 industry monitors water quality parameters on a daily basis.

           31.   This has been reorganized for the FEIS.

           32.   Comment noted.

           33.   Comment noted.

           34.   See the response to Question 29.

           35.   Comment noted. See the response to Letter 2, Comment 12.

           36.   See the response to Letter 2, Comment 13.

           37.   Comparisons with other types of development are generally not made in the EIS,
                 because these types of development are not alternatives considered in the EIS.
                 Where the presence of other types of structures may affect visual quality, this is
                 discussed, but not in a comparative manner.

           38.   See the response to Letter 2, Comment 15.

           39.   See the response to Letter 18, Comment 54.

           40.   The text has been revised to clarify the allocation process.

           41.   See the response to Question 30.

           42.   See the response to Question 32.

           43.   Comments noted.

           44.   See Section 4 of the response to comments after the text in Appendix E.

           45.   See Section 4 of the response to comments after the text in Appendix E.

           46.   See Section 2 of the response to comments after the text in Appendix E.

           47.   The text has been revised for the FEIS to identify and evaluate existing
                 regulations and guidelines used to manage the fish farming industry.

           48.   Comment noted.








             Response to Letter No. 37: Washington Fish Growers Association (continued)


             49.    Best management practices would appropriately be part of a management plan
                    developed for the fish farming industry.

             50.    Comment noted.

             51.    See the response to Letter 2, Comment 11.

             52.    T'he FEIS includes many recommendations for WAC adoptions, additional
                    guidelines, and further research.

             53.    The FEIS evaluates the Intefim Guidelines.


             54.    Comments noted.






                                                                                 LETTER NO. 38




                                                   13244 40th N.E.
                                                   Seattle, WA 98125
                                                   April 6, 1989

             Mr. Ron Westley, Project Manager
             Washington Department of Fisheries
             115 General Administration Building
             Olympia, WA 98504

             Dear Mr. Westley:

                   I realize that the amount of money made available for the Draft
             PEIS* on Fish Culture in Floating Net Pens, and the time constraints for
             its completion, ordained that it would be incomplete, and that there
             would be no time or opportunity for research on relevant aspects,
             but I believe that you had the right to expect, as does the public, a
             learned and unbiased identification of problems that may exist, and
             plans for research that should be carried out to attack these
             problems.    Unfortunately, in the sections I have studied, essentially
             no critical questions are posed nor research identified that needs to
             be done to protect the Puget Sound environment from net-pen
             impacts.    The result is that, with respect to these sections, the
             document is badly flawed, remarkably biased, and leaves the marine
             environment of this state exposed to dangerous and damaging
             exploitation by the net-pen industry.     Therefore, I believe that any
             growth of this activity in our state should be halted until the
             problems that should have been dealt with by this PEIS have been
             properly solved.

                    Section II A c, Chemicals.

             Page Line

              59 7-8            The concentration of antibiotics free in the water is
                          of little consequence.   The concentrations of concern are
                          those retained within the tissues and gut of the farmed
                          fish, of other marine organisms, and in sediments. The
                          first and third are substantial in and under net-pens.
                          Concentrations of antibiotics in native fish attracted to
                          the pen site, either entering the pen or feeding under it,
                          have apparently never been measured, nor have
                          concentrations in macro -invertebrate fauna (crabs,
                          molluscs, polychaets, sea urchins, starfish, etc.) associated








                                                  2


                           with the sea bottom near the net-pen site.   These are
                           environments where resident bacteria play a
                           fundamental part in the food chain and in rec- cling of
                                                                          @y
                           organic material.  A number of the rnacro-invertebrates
                           are food organisms for humans. I believe research on the
                           impact of antibiotics in these environments, and the
                           potential for inadvertant entrance of antibiotics into
                           humans through these routes is necessary and should
                           have been called for by the PEIS.

               5911 et seq.      At the time of the meeting of the Technical
                           Advisory Committee, to which you appointed me, in
                           November, 1987, to consider the forthcoming PEIS, only
                           one or two papers on antibiotic resistance in -relation to
                           net-pens was known to the members of the committee.
                           Since then I have developed a bibliography of 30-40 such
                           references, and it is helpful that some of these have now
                           been considered in the PEIS. Unfortunately, this
                           consideration is incomplete, inaccurate and misleading;
                           nor is there any consideration of questions and problems
                           that remain.
                                 This literature shows that in essentially all forms of
                           fish aquaculture in Japan antibiotic resistant bacteria are
                           found in the tissues or guts of the farmed fish and in
                           many cases in bacteria in the water within the pens.
                           Resistant forms are found for essentially all of the kinds
                           of antibiotics used. In all cases multiply resistant
                           plasmids are found. In many cases , perhaps most, R-
                           plasmids can be transferred to other bacteria.  In  Spain
                           transferable multiply resistant plasmids are found in
                           aquaculture environments.    In Norway resistance toward
                           oxytetracycline, sulphadiazine, trimethoprim and    others
                           is routinely found, and the newly identified fish
                           pathogen, Vibrio salmonicida, which causes Hitra   disease,
                           commonly is resistant to oxytetracycline used to   comabt
                           it in salmon culture.  In Ireland, resistant bacteria are
                           found in salmon culture. In catfish culture in Louisiana
                           resistant Aeromonas pathogens are found. In British
                           ColumbiaVibrio anguillarum strains resistant to
                           sulfonamides are found in isolates from salmon fish
                           tissues from several farms in Area 14. 1 have never seen
                           that any studies for drug resistant pathogens have been
                           made on diseased salmon from pens in this state. If they








                                                    3


                           have, the results should have been reported to you, and
                           the public, in the PEIS. If they haven't, then it is a
                           significant omission that such studies are not called for in
                           the PEIS.


                                 The anecdotal comment at the bottom of page 59
                           that antibiotic treatment in Japan appears to exceed both
                           legal and general practices in the United States needs
                           documentation. The FDA permitted use of antibitotics in
                           this state calls for therapeutic, not prophylactic, use of
                           antibiotics in fish pens yet sworn testimony at hearings
                           indicates that prophylactic use occurs here.     It is general
                           knowledge that antibiotics are added to fish     food at farm
                           sites here and in British Columbia in excess     to that legally
                           provided in medicated food by the fish food
                           manufacturers - sometimes far in excess.       I presume     this
                           is what is meant by the phrase "general practices" on
                           page 59 of the PEIS. If the authors of the PEIS have
                           evidence that these legal and "general practices" here are
                           exceeded by those in other countries where resistant
                           pathogens are well documented, then the poundages,
                           dosages, and disposition into the environment of the
                           antibiotics used here need to be documented for you and
                           the public in the PEIS. If they don't have such evidence,
                           then the PEIS should contain recommendations on
                           monitoring and recording of antibiotic use in fish pens to
                           obtain it and make it available for policy makers.

              60    5-9          The inference from this paragraph may be taken to
                           be that, when antibiotics are taken away, resistant strains
                           will go away and therefore the antibiotic resistance
                           problem in fish culture isn't too serious. To be balanced,
                           it should have been pointed out that, often on
                           withdrawal, the decrease in the frequency of resistant
                           organisms is very slow compared to their initial
                           appearance, as is shown in the attached graph from a
                           paper by Stuart Levy, and secondly the organisms
                           containing the R plasmids haven't disappeared, but have
                           only diminished in proportions relative to the others, and
                           become reestablished on retreatment with antibiotics.


              60 11 et seq. and 62 26         The several references to R-plasmid
                           transfer occurring at"laboratory temperatures" and








                                                    4


                            "highly controlled conditions" lead the authors of the PEIS
                            to the conclusion that transfer "is not representative of
                            phenomena that occur in the environment".       This is
                            entirely misleading and would grossly misinform a lay
                            policy maker.    Controlled laboratory conditions are
                            typically used for comparative purposes and to accelerate
                            the transfer.  The essential point of such laboratory
                            experiments is to demonstrate whether the molecular
                            mechanisms permitting such R-plasmid transfer from one
                            species of pathogen to another are or are not present in
                            the genetic makeup of the plasmids and the molecular
                            structure of the bacterial surfaces.   There are a number
                            of experiments that demonstrate such transfer occurs
                            under typical environmental, as contrasted to laboratory,
                            conditions ( Colwell and Grimes, 1986; O'Morchoe et al.,
                            1988). When these PEIS conclusions were read to
                            scientists who work in this field, their unscientific
                            comment was "that is a lot of hogwash".
                                  The conclusions that should have been reached in
                            the PEIS are: (1) in almost all cases tested,, the molecular
                            mechanisms leading to R-plasmid transfer between fish
                            pathogens and other bacteria, including human
                            pathogens, are in place; (2) conjugal R--plasmid transfer
                            can and does occur under conditions found in nature. A
                            prediction which the PEIS could judiciously make from
                            these points is that, given time, the transfer of such R-
                            plasmids, carrying multiple resistance genes, is very
                            likely to occur from fish pathogens to other pathogens
                            including those of human concern. This prediction has
                            been made by research scholars in this area (e.g., Colwell
                            and Grimes, 1986).

               60 15-17           While the pathogen Vibrio parahaemolyticus is not
                            infrequently found on or in cultured fish products in
                            Japanese fish markets, to date isolates carrying R-
                            plasmids haven't been dectected in this human pathogen.
                            However, isolates carrying R-plasmids of another
                            bacterium pathogenic to humans and fish, Aeromonas
                            hydrophila, have been made from cultured fish which
                            had been treated with antibiotics.    It can be concluded
                            that use of antibiotics in fish culture has generated
                            human pathogens carrying resistance factors.








                                                 5


            60 41 et seq.      Jacobsen and Berglind reported persistence of
                         oxytetracylcine in sediments beneath all four fish farms
                         tested in Norway, not just three of the four as reported
                         here, and concentrations ranged as high as 4.9 mg/kg, not
                         4.0 as reported here.   Further, this highest concentration
                         was found in sediments 12 weeks after medication.
                               The tenor of this paragraph in the PEIS is to
                         indicate that the persistence of oxytetracycline in tank
                         sediments is measured by a half-life of only ten weeks,
                         and at concentrations that are barely inhibitory to
                         bacteria. Actually the article indicates that the
                         experimental conditions probably led ten weeks to be a
                         conservative estimate of the half-life persistence of
                         oxytetracycline in field conditions.   Moreover, anaerobic
                         conditions in the sediments enhanced by the OTC are
                         expected further to stabilize the OTC to degradaton. The
                         authors' overall conclusion, which is  minimized in the
                         PEIS, is that the levels of OTC in bottom sediments under
                         fish farms are such that antimicrobial effects in the
                         environment and (antibiotic) bacterial strain selection can
                         be expected in these sediments for more than 12 weeks
                         after administration of OTC in the fish feed.
                               Considering that OTC is often administered in Puget
                         Sound net pens for episodes of 10 days, 3 times a year,
                         this means that for about 40 of the 52 weeks a year these
                         conditions may be predicted to exist. This is a message
                         that the PEIS should have made to policy makers.

            61    22           Aside from the probability of selection of resistant
                         strains of bacteria in the pen sediments, the more
                         generalized ecological impacts of these sediment
                         antibiotics needs analysis.   The direct measurements of
                         amounts of sediment antibiotics by Jacobsen and Berglind
                         (1988) are more significant than the calculated levels of
                         OTC in fish pen sediments referred to here in the PEIS.
                         In their concluding paragraph Jacobsen and Berglind
                         suggest that these levels can be expected to have effects
                         on marine ecosystems, and in a letter (copy included)
                         indicates that a research program to assess these effects
                         is being launched in Norway. This observation of the
                         Norwegians opens up an impact of net pens that has been
                         essentially ignored, and that requires careful study.    This
                         conclusion has also been expressed by British Columbia








                                                      6


                              and Japanese microbiologists. I believe that the PEIS
                              considerably underplays this point.

                 61     45          It is difficult to understand these comments about
                              the concentrations of antibiotics in and near Norwegian
                              farms.   I refer you again to Jacobsen's letter and the
          G                   paper of Jacobsen and Berglind that document
                              development of resistant strains of bacteria in Norwegian
                              pen culture, and the high persistent concentration of
                              oxytetracycline in pen sediments, which stand in direct
                              contradiction to these statements.


                 62    7-17         The implications here that Puget Sound conditions
                              don't favor (permit?) development of antibiotic resistance
                              is truly hard to understand.    Resistance is found in
                              nearby British Columbia farms, and in Norwegian farms
                              (see above). Are the authors of the PEIS comments
                              proposing that Puget Sound conditions are so different, or
                              Puget Sound fish farmers so much better or more
                              constrained to follow the rules than those in BC and
                              Norway that the fundamental biological process of
                              conjugal R-plasmid transfer can't occur here?

                 62   23                  The PEIS has referred earlier and again here
                              to failure of Tibbs et al., in unpublished observations, to
                              find detectable levels of OTC in shellfish (mussels, clams
                              and oysters) suspended within coho salmon pens during
                              feeding of medicated food. These are filter feeding
                              organisms and would hardly be expected to engulf OTC-
                              laced particles the size of fish pellets. Nor would they be
                              expected to engulf OTC from solution in the sea water
                              after the antibiotic had leached from pellets or fish feces.
                                    The only critical point in these experiments would
                              have been to determine if these shellfish had filtered
                              from the water in the net-pen antibiotic resistant
                              bacteria generated either in the cultured fish or in the
                              net water environment.     Given that it is known that
                              antibiotic resistant bacteria are frequently found in the
                              sea water within net pens (many papers of Aoki), and
                              that shellfish easily concentrate bacteria from the
                              sewage-enriched sea water by filtration, including
                              pathogens carrying resistant plasmids (Morgan et al.,
                              1976),   it is surprising that this important feature








                                                7


                         apparently wasn't determined in these experiments, or
                         wasn't reported in the PEIS.
                              With reference to the statement that antibiotics
                         don't accumulate in marine invertebrates other than
                         shellfish, there is no documentation in the draft that any
                         such invertebrates have been tested by the authors of
                         the PEIS or the Department of Fisheries - either for
       G                 accumulation of antibiotics or resistant bacteria. In
                         preference to referring to negative results of experiments
                         that seem not to have been done, it would be more useful
                         for the authors of the PEIS to describe experiments that
                         should be done to obtain needed information.


            62    29                 It is correct that R-plasmid containing
                         variants of V. parahaemolyticus have not been reported
                         from Japan  to date.  There are honest differences in
                         opinions among investigators in this area whether this
                         signifies that transfer of R-plasmids from pathogens that
       G                 contain them, such as V. anguillarum, to the human
                         pathogen cannot occur, or whether it simply has not yet
                         been detected.   Among scientists and medical authorities
                         associated with the biology of V. parahaemolyticus,
                         however, it is essentially undisputed that this organism
                         causes human illness.   Reports that have been made
                         locally that this form of vibriosis causes trivial human
                         illness and is practically absent from Northwest
                         populations are quite at odds with the local medical
                         records. As long as we know that R-plasmids can
                         transfer from V. anguillarum (a fish pathogen) to V.
                         parahaemolyticus    (a human pathogen), it would seem
                         prudent to avoid conditions that would generate resistant
                         strains of the former in our marine waters.


             116 38            The finding by Wekell offalmonella cubana in
                         moist fish pellets raises the question whether other
                         species of salmonella that are pathogenic to humans are
                         present in this fish food and could enter the human food
         G               chain through this route. If there are, there is the
                         potenial that the use of antibiotics in fish culture would
                         lead to selection of resistant strains, thus adding to the
                         growing burden of salmonellosis in human populations
                         that has been related to the excessive use of antibiotics in







                                          8


                      animal husbandry (Cohen and Tauxe, 1986; enclosed
                      letter from Cohen).
                           Dr. Wekell's observation extends reports of other
                      recent instances of salmonella presence in fish moist
                      pellets in Northwest salmon culture. It would have been
                      prudent for the PEIS to have required an extension of her
                      observations to determine the frequency of such
                      contamination, and the presence or absence of resistant
                      salmonella in cultured salmon that might have been fed
                      .contaminated food.


            63 31-35       These two summary sentances are truly
                      remarkable. Antibiotics have indeed been shown to
                      select for resistant bacteria in any number of cases of fish
                      culture, in the field, in essentially all of the countries
        0             engaged in this aquaculture, perhaps excepting this state.
                      The relevant question is: why does not the PEIS call for a
                      strict search for resistant bacteria here?
                           The statement that "development of antibiotic
                      resistant bacteria in Puget Sound is virtually impossible"
                      is totally without merit.


                           An additional relevant topic seems to have been
                      excluded from consideration in the PEIS: what is the
                      duration of persistence of antibiotics -in cultured salmon
                      tissue after an episode of feeding with medicated pellets?
                      I believe FDA regulations call for a period of 21 days
                      after last feeding with medicated pellets before
                      harvesting the fish, but analyses reviewed by Austin and
                      Austin (1985) indicate that OTC may persist in fish
                      tissues after conventional feeding regimes for as long as
                      100 days, and they review relevant literature for some
                      other antibiotics used in fish culture. The Austins
                      indicate the need for additional examination of this
                      problem, which would have been an appropriate
                      recommendation for a PEIS considering impacts of
                      floating fish culture. This examination should include a
                      consideration by qualified public health officials of (a) the
                      potential for antibiotics carried over in marketed salmon
                      to cause microbial medical problems, and (b) the
                      potential for such entrained antimicrobials to cause
                      allergic reactions in consumers.







                                              9



            Summary.   I have attempted to indicate, and to document, that this
            section of the Draft PEIS presents for policy makers an incomplete,
            inaccurate, biased and erroneous consideration of the potential
            impacts of the use of antibiotics in floating fish culture. Should you
            need it, I will try to provide additional documentation on specific
            points.
                       I believe that this section should be withdrawn from the
            PEIS and redone by other authors.

            References cited:


            Austin and Austin, 1985. Bacterial Fish Pathogens: Disease in Farmed
            and Wild Fish. John Wiley and Sons.

            Cohen, M.L. and R.V.Tauxe, 1986. Drug-resistant salmonella in the
            United States:  an epiderniologic perspective. Sci., 234: 964-969.

            Colwell, R.R. and D.J.Grimes. 1986. Evidence for genetic modification
            of microorganisms occurring in natural aquatic environments.   in:
            Aquatic Toxicology. Ninth Volume, pp. 222-230.

            Levy, S.B., 1986. Ecology of antibiotic resistance determinants. in:
            Banbury Report 24: Antibiotic Resitance Genes: Ecology, Transfer, and
            Expression. pp. 17-29.

            Jacobsen, P. and L. Berglind. 1988. Persistence of oxytetracycline in
            sediments from fish farms.   Aquaculture, 70: 365-370.

            Morgan, R.C., P. Guerry, and R.R.Colwell. 1976. Antibiotic resistant
            bacteria in Chesapeake Bay. Chesapeake Science, 17: 216-219.

            O'Morchoe, S.B., O.Ogunseitan, G.S.Sayler, and R.V.Miller. 1988.
            Conjugal transfer of R68.45 and FP5 between Pseudomonas
            aeruginosa strains in a freshwater environment. Appl. and Env.
            Microbiol., 54: 1923-1929.





            Section 3a. Impacts to Aquatic Organisms. Fish and Shellfish.







                                                  10


                       In a state document that has as its objective "to assess the
               impacts of net pens on the biological environment..." it is unfortunate
               that, in the present section on aquatic organisms, only organisms of
               direct commercial interest are dealt with.  While surely these are
               important, equally@ important to the health of these marine waters is
               the well being of the entire biotic community. The basic
               communities of animals in Puget Sound are generally well known to
               zoologists, who also know that these communities are interacting
               networks of organisms, and that care must be taken in disrupting
               some components lest adverse effects be felt throu,ghout the whole
               community including those species of economic significance. This
               concept of ecological interdependance of the plant, animal and
               microbial members should play an important part in the discussions
               in this section, and instead plays no part. The impacts of net pens on
               Puget Sound water quality, and thereby on the viability and health
               of these intertwined assemblages must be evaluated by some
               significant state agency, and logically should at least have been
               touched on in this PEIS.
                       It is true that often a community is dominated by "key-stone"
               species that play distinct roles, and which, therefore, should receive
               special protection to maintain a healthy community.     Sea-urchins and
               geoducks are examples.    In the recent past and present, these
               animals have been unconscionably commercially exploited in Puget
               Sound, and the PEIS deserves credit for recognizing-, that net pens
               may impact them.

               PageLine
               67    1-9         The impact of these lines is to indicate that good
                           things will happen under pens. Reference should have
                           been made to the abundant literature that details the
                           desolation that occurs as sediment accumulates - at least
                           there should have been repetition of the relevant
                           comments from pages 19-20 that more adequately
                           describes the impact for the lay policy maker seeking to
                           understand the relationships.  Terms such as
                           flopportunistic worms" and "enhanced" (line 5), and
                           "indicative of organic enrichment" (p. 21, 1. 42), while
                           taken in context by the trained ecologist, are loaded
                           terms to the lay person. He should know that these
                           words mean that "the worm Capitella occupies a niche in
                           marine areas so degraded by pen sludge and sewage that
                           the normal communities of animals have been driven out,








                                                11


                         just as in freshwater environments of human sewage
                         plants the worm Tubifex displaces normal communities".

            67    1 1          The idea that excess pen food is an attractant to
                         wild fish and macro -invertebrates doubtless is true.    The
                         PEIS should point out that these organisms thereby
                         receive an unknown and unstudied dosage of antibiotics
                         from the pens, which may unwittingly be transmitted to
                         humans who catch and eat them. In addition these
                         organisms may be exposed to disease organisms from the
                         pens, as has been documented. The PEIS should have
                         recommended study of both of these issues.

            69    70           It is generally pointed out, as in the bottom
                         paragraph of this page, that penned stocks are selected
                         because they have different traits than wild or free-run
                         fish. The idea, in the last paragraph of p. 71, that this
                         difference can be undone by selective breeding therefore
                         becomes counterproductive.

            72    23           Here and at the bottom of the page it is argued that
                         gene differences would tend to disappear if escapes bred
                         with free-runs, and that genetic dilution isn't going to
                         occur significantly. This argument ignores the converse
                         experience of Norway, where destruction of wild runs
                         through this means is feared as the major deleterious
                         impact of net pen fisheries.
                               This section underplays the magnitude of the
                         problem of escaped fish, both Atlantic salmon here and
                         cohos and chinooks in BC. Norwegian officials report their
                         escapes measure in the thousands.    The big storms in the
                         Northwest this winter caused heavy damage to many
                         farms in BC liberating an anecdotally reported 100,000
                         onchorhychus.   Lesser storms badly damaged a pen in
                         North Skagit Bay. Local commercial fisherman report
                         catches of Atlantic salmon in numbers that imply
                         substantial populations of such fish in the wild.   These
                         are numbers that this PEIS should have documented
                         objectively before concluding that "major escapements
                         are rare".


            73     3           The conclusion from this argument is that one is
                         averaging the total escapement from farms over the







                                                     12


                             entire Sound.   The greater danger comes from
                             escapement from pens near major salmon river mouths.
                             The state has permitted one pen, and seeks to, add a
                             second, in the estuary of the Skagit River. One can
                             assume that escaped salmon from these. farms will
         0                   preferentially enter the Skagit, thus concentrating the
                             impact, rather than averaging out over the Sound, thus
                             diluting it as suggested by the PEIS.     The nature of this
                             impact in terms of disease transmission to "natural" fish,
                             eggs and fry, or by competition, or, if Onchorhynchus, in
                             genetic dilution should properly be dealt with by the
                             PEIS.


                 73    22          If these arguments are correct, why is the similar
                             problem in Norway found to be extremely serious?

                 74    10          As indicated above, the case can be made that
                             escapes in the Northwest and in Norway are much more
                             numerous than this paragraph suggests.

                 74    42          A point that needs evaluation by a     PEIS is whether
                             Atlantic salmon that have spent all their    lives in Puget
                             Sound pens, acclimating to these waters,     will survive
                             better when they escape from pens and        enter these
                             rivers as adult fish ready to spawn than     will Atlantic
                             salmon smolts freshly introduced from abroad. The two
                             are quite different experiments.

                                   Repeatedly this section has pointed up risks that
                             occur when exotic species are transplanted - the high
                             potential for introduction of new viral, bacterial and
                             parasite diseases; the genetic dilution questions; the
                             question of competition with native species.
                             Distinguished fish microbiologists and biologists have
                             urged that exotic species not be introduced for farming.
                             It remains unclear why, then, this dangerous and
                             probably unnecessary experiment has been permitted.



                 C. Disease


                             I have seen the critique of this section    developed by Dr.
                 Annamarie Johnstone, with which I am in agreement.








                                                 13



             77     12          In this paragraph concerning VHS there are two
                          significant exceptions from recent newspaper reports
                          attributed to WDF.
                                (1) This paragraph expresses concern about
                          importing this virus with Atlantic salmon eggs from
                          Europe, whereas WDF press releases have denied that
                          this is a possibility because of WDFs belief that Atlantic
                          salmon can't carry the virus, and
                                (2) this paragraph states that VHS may be
                          transmitted vertically from adult brood fish to eggs and
                          fry, whereas WDF press releases indicate that only
                          horizontal transmission from one fish to another through
                          the water is possible.
                                Policy makers and the citizens need explanations of
                          these discrepancies.

             77     25          1 believe that the Washington quarantine period
                          calls for a 90 day disease-free period prior to release of
                          exotic fish such as Atlantic salmon into state waters.
                          Here and elsewhere in this section it is indicated that this
                          is adequate - at least "successful to date" - to protect this
                          state against exotic diseases.  Some important diseases
                          have latent periods that extend well beyond this
                          quarantine period. Wolf (1988) reviews an outbreak of
                          VHS (viral hemorrhagic septicemia) 18 months after trout
                          were transferred from a farm registered free of VHS. He
                          reports that this virus "is silent or latent much of the
                          year" and that "low temperature is apparently required
                          for the virus to break latency".  He reports that this virus
                          is shed with eggs.
                                These points suggest that the Washington state
                          importation laws are not adequate to prevent importation
                          of exotic fish diseases, and leave open the possibility of
                          exotic disease organisms being introduced with fish eggs
                          and escaping detection for 90 days because of latency.
                                If this loop hole in the importation laws is correct,
                          the PEIS should discuss it and call for corrective
                          measures.   If it is not correct, the PEIS should clarify
                          why not.

             79     13          Clearly, the Washington State importation laws as








                                                   14


               80     3    administered by the Washington Department of Fisheries
               80    33
                           have been unsuccessful in preventing the serious exotic
                           disease, VHS, from being imported into our salmonid
                           fisheries.  The PEIS should recommend appropriate steps
                           to mitigate this situation and improve these importation
                           regulations and their enforcement, rather than indicate in
                           numerous places that the regulations are adequately
                           protective.
                                 This disease is now confirmed in coho, chinook and
                           steelhead in this state.  Whether this inixoduction is an
                           impact of the net pen fishery remains fully to be
                           determined. In view of the long latency, period for this
                           virus and the capacity for the virus to be transmitted
                           from farms registered free of VHS, (reviewed by Wolf as
                           described above) this determination for all of the farms
                           and brood stock hatcheries will be a difficult task.

               80     1          Sworn testimony by Svein Mehli, of the Norwegian
                           Directorate for Nature Management, in this state in
                           November, 1987, indicated that in Norway furunculosis,
                           BKD, redmouth and Gyrodactylus salaris in all probability
                           have all entered the Norwegian wild fishery from net pen
                           husbandry.   There are other instances cited by A.
                           Johnstone, page 5 in her critique of this PEIS, of
                           transmission of disease from pen to wild fish, and the
                           VHS issue in this state remains to be clarified.
                                 The PEIS cites no instance of a well conducted study
                           that clarifies this issue one way or the other.    Simple
                           repetition of the concept that disease organisms can move
                           only in one direction in this relationship is not a
                           substitute for such a study.
                                 A problem that relates to this issue evolves from a
                           consideration of net pen permitting policies of the state
                           agencies. As stated above, one salmon -farm has been
                           permitted just north of Hope Island, and a second is being
                           considered south of Hope Island, within a mile or so of
                           the mouth of the Skagit River, and clearly in its estuary.
                           The Kiket Bay study made in the early1970's in
                           evaluation of a nuclear plant on Kiket Island documented
                           that perhaps over 23,000,000 salmon fry- in a year may
                           pass through or very close (less than 1000 feet) to these
                           net pen sites.  These fry will be stressed osmotically,







                                            15


                       having just entered salt water, will be stressed by new
                       predators, different temperatures, and doubtless in other
                       ways. At this critical phase in their life they will passing
                       through waters that may be expected to carry fish
                       disease organisms enhanced by the presence of the net
                       pens, judging from the history of the salmon net pen
                       industry. If the PEIS is correct, then they will pass
                       through safely. If not, then the natural salmon runs of
                       this river may be adversely affected.

                             An issue that relates to disease transmission and
                       environmental impact from net pen husbandry that has
                       not been considered in the PEIS is the disposal of dead
                       fish from net pens. In BC it is well known that hundreds
                       of thousands of "morts" are disposed of in landfills
                       without disinfectant. It is surprising that the PEIS has
                       neither discussion of nor recommendation on the
                       important issue of the proper method of disposal of dead
                       and diseased fish from salmon farms.


            81    2          The Norwegians are often cited as pre-eminent in
                       this industry, and yet their literature has frequent
                       reference to illegal and incorrect voluntary efforts by
                       their operators in this husbandry that have created
                       pollution and spread disease. Although it is to be hoped,
                       it is unlikely that voluntary efforts on the part of net pen
                       operators here would be any better, and it is depressing
                       to think that the best the PEIS can suggest is that
                       11voluntary compliance with fish disease regulations is the
                       most effective insurance that regulations will be
                       followed".


            Reference  cited:


            Wolf, K., 1988. Fish Viruses and Fish Viral Diseases. Cornell Univ.
                       Press.  Chapter 18. Viral hemorrhagic Septicemia.


            Summary on Section 3.

                  The impacts on basic marine ecology have been badly
            understated, and generally couched in terms that appear to place a
            good  Ilight on an unsatisfactory situation. There is no consideration of








                                                16


              potential detrimental effects of pen wastes and residual antibiotics
              on the natural fauna, some of which may be consumed by
              humans.The magnitude of problems resulting from escapes from
              pens is minimized in light of recent experiences. Essentially no
              credence is given to substantial Norwegian experience with pen
              escapes, genetic dilution, and disease transmission.
                    Great emphasis is placed on the adequacy of the Washington
              regulations governing importation of exotic species and exotic
              diseases, which in fact have proven extremely inadequate to prevent
              importation of the serious disease, VHS. Among other things,   these
              regulations and their enforcement have inadequately taken into
              account the reality of latent periods in development of such diseases.
              The PEIS almost consistently takes the view of the pen aquaculturists
              that disease transmission can occur only from wild fish to the penned
              fish, ignoring the substantial Norwegian experience to the contrary,
              and the wisdom of many microbiologists, and nowhere provides any
              evidence supporting their stand, nor does the PEIS call for studies to
              test the issue. There is no comment or evaluation of permitting
              policies that have placed pens in estuaries in the direct path of
              outward bound salmon fry, stressed by entry into salt water and
              therefore, by the criteria of the net pen operators, highly susceptible
              to disease.
                    There is no consideration, evaluation, or proposal for mitigation
              of the serious problem of proper and sanitary disposal of the
              thousands of dead and diseased fish arising from net pen operation.
                    The suggestion that the most important mitigation procedure
              for the disease issues is "voluntary compliance with fish disease
              regualtions" is unrealistic in the light of experience.

                    In my opinion the document will serve no useful purpose for
              the citizens and policy makers of the state who are concerned with
              the broader issues of protection of the quality of waters of state wide
              interest, but instead will mislead them on many critical issues. It is
              improbable that a simple rewriting or even heavy editing will
              improve it adequately.  The issues are so important. to the health
              and welfare of these marine waters, and the various phases of the
              state economy that depend on the Sound, that the only prudent
              course, in my view, is a moratorium on this industry until these
              matters can be properly resolved.

                                           Sincerely yours,



                                              C







                                            17



                                        Arthur H. Whiteley
                                        Profesor Emeritus, University
                                             of Washington
                                        Member of the Technical Advisory
                                               Committee charged with
                                             considering issues for the PEIS
                                        tel.: (206) 364-3337





               Norwegian Institute for Water Research                                  N IVA


                                                                           Postal address
                                                                           FI.O.Box M3, Blindem
              Arthur H. Whiteley                                           PI-0314 Oslo 3, Norway
              Professor Emeritus                                           Telephone (+47 2) 23 52 80
              Department of Zoology                                        Location
              University of Washington                                     Elrekkeveien 19
                                                                           Telex 74190 niva n
              13244 40th N;E.                                              Cable Niva, Oslo
              Seattle, Washington
              98125 USA





               Your ref.           Your lefter          Our ref.             Date

                                                       JAC                  October 24, 1988
                                                       Snr:
                                                       Jnr:3330/88





              The widespread use of drugs        in aquaculture is. in my opinion, a
              problem which until now has been given to little attention. Except for
              the finding of resistant strains of fish pathogens, we know nothing
              about ecological impacts of antibiotics from fish farms.


              The information you request on resistant pathogens in relation to fish
              farms is availlable as laboratory reports (in norwegian). Resistance
              towards oxytetracycline. sulphadiazine, trimethoprim and others is
              routinely encountered in laboratories. I believe that resistance is
              coupled to processes in sediment. Land based systems seem, at least so
              far, to avoid this problem. As far as I know, nothing is published in
              english on resistance in norwegian aquaculture.

              Norwegi'an environmental authorities are launching a research program
              on effects on antibiotics on the marine environment -this year. We hope
              to   get    financial  support for further studies on persistence,
              biodegradation, toxicokinetics and effects on processes in marine
              sediment. We have not made any other studies on these matters than the
              one you are referring to.

              My knowledge on the biology and preferences of Gyrodactylus salaris is
              limited. The parasite has spread to many good salmon rivers in Norway.
              and caused serious effects on our populations of wild salmon.
              Eradication of fish and parasite by use of rotenone is tried in some







                                                                                   2/ 2






             rivers. I sure hope you will never see this pest in your part of the
             world.





             Yours sincerely
             NORWEGIAN INSTITUTE FOR WATER RESEARCH
           P
             P @Ai @1. 1, @se n










              RESPONSE TO LETTER NO. 38: ARTHUR H. WHITE



              1.     Comments noted.

              2.     See the response to Questions 33, 34, and 35.

              3.     Comment noted. As the reviewer points out, it is not uncommon for fish
                     pathogens to develop resistance to certain antibiotics.      Not surprisingly, this
                     phenomenon occurs in Washington State. When pathogens are to be treated, it
                     is a common practice to conduct drug sensitivity tests prior to the application of
                     antibiotics as is commonly done in human or other livestock treatments.

              4.     Comment noted. Regulations of the use of antibiotics is by FDA and USDA -
                      not the State of Washington.

              5.     Comment noted. The paragraph referred to is balanced in its presentation as it
                     stands.

              6.     The presentation in the DEIS is not "entirely misleading" as alleged in this
                     comment. The literature cited in the document indicates that plasmid transfer to
                     human pathogenic strains of bacteria such as rtbfio parahemolyticus has never
                     been found in Japan, despite extensive use of antibiotics and extensive surveys
                     attempting to demonstrate such transfer. It is well known that many processes can
                     be forced to occur under controlled laboratory conditions, but do not occur
                     outside of these highly controlled conditions.

              7.     Comment noted, but disagree with the suggested conclusions of the reviewer. The
                     treatment in the DEIS is the most appropriate interpretation of the available
                     technical data. The suggestion that the transfer of R-plasmids from fish pathogens
                     to human pathogens is very likely is not supported by the technical literature.

              8.     ne reviewer's conclusion is not supported by the technical literature.

              9.     The comment is correct, but the issue results from the cited study's use of the
                     terms "sites" and "farms." In the cited study, the authors state on page 368 that
                     "OTC was found on all but one site." However, OTC was found at another site
                     on the same farm.

                     The text has been revised in the FEIS to indicate concentrations of up to 4.9
                     mg/kg rather than the 4.0 mg/kg cited in the DEIS.

              10.    Comment noted. This subject is discussed to the extent that information is
                     available in the first paragraph on page 59 of the DEIS.

              11.    Not clear what comments the writer has difficulty with. The description of the
                     Jacobsen and Berglind study, as corrected, is accurate and reflects the substantive
                     conclusions that can be drawn from their data.








          Response to Utter No. 38: Arthur H. Whiteley (continued)

          12.    The DEIS does not state that antibiotic resistance could not occur in Puget
                 Sound. However, the last sentence in the second paragraph of the summary on
                 page 63 of the DEIS is inaccurate and has been eliminated. This is the sentence
                 that states, "The development of antibiotic resistant bacteria in Puget Sound is
                 virtually impossible at the low temperature and low concentrations of antibiotics
                 around net pens in the Sound." Once this sentence is removed, the DEIS
                 discussion gives, in the opinion of the writer, a balanced view of the estimated
                 risks in Puget Sound. Furthermore, the mitigation measures on pages 62 and 63
                 of the DEIS give additional measures to reduce the risks that do exist.

          13.    The Tibbs study is now published in the NW Environmental Journal. The
                 conclusions of the study are merited in the opinion of the EIS writer. Shellfish
                 would be expected to accumulate particulate material (disintegrating uneaten fish
                 feed or fecal material) and thus would serve to monitor the accumulation of OTC
                 in this material if it was present.

          14.    The DEIS does not state that antibiotics cannot accumulate in the invertebrates
                 other than shellfish. Recommendations for further research were made in the
                 DEIS and are part of the Preferred Alternative in Section 5.4 of the FEIS.

          15.    Comment noted. The interpretation of the available data as presented in the
                 DEIS is the most supportable conclusion in the opinion of the writer.

          16.    The DEIS contained recommendations for further research and better storage of
                 fish feed on page 118, and in Section 6.4 of the FEIS.

          17.    See the response to Comment 16.

          18.    Comment acknowledged. The sentence has been deleted from the FEIS.

          19.    This is an issue which is covered by the U.S. Food and Drug Administration
                 which has standards in place. If new information indicates that these standards
                 need to be modified, FDA is responsible for taking the necessary actions to
                 modify these standards.

          20.    Potential impacts to water quality were addressed in the Water Quality and
                 Cumulative Impacts sections of the EIS. In addition, the EIS discussed the
                 potential impact on phytoplankton. Section 5.1 of the FEIS discusses the potential
                 effects of farms on benthic communities.


          21.    Comment noted.

          22.    Capitella, and its relatives, while capable of withstanding and thriving in highly
                 organically enriched environments, are nevertheless normal and common species
                 in many of the marine benthic assemblages in Puget Sound (Lie 1968, 1974; Word
                 et al. 1984). Capitellid dominated communities are normal for an area receiving
                 substantial organic input. Although communities dominated by capitellids are not








               Response to Utter No. 38: Arthur H. Whiteley (continued)

                      diverse, they are productive and help to cycle the benthic nutrients into other
                      components of the food chains.

               23.    Comment noted.

               24.    Yes, it would be counter-productive to the fish farmer.

               25.    The fish farming industry was not responsible for the destruction of wild salmon
                      runs in Norway. The genetic impact potential is a function of the degree of
                      domestication of the farm stock and the proportion of interbreeding. In Norway,
                      there are over 780 farms producing an estimated (19139) 125,000 metric tons of
                      Atlantic salmon (275 million lb. or 27.5 million-10 Ib fish). Their rivers have
                      relatively small populations of wild salmon. The small wild populations resulted
                      from overfishing, acid rain, and other factors that occurred before the development
                      of the fish farming industry. In addition, the older Norwegian farms are not as
                      well constructed as more recent farms which utilize newer technology.

                      We have much larger populations of wild fish in general. The fish farming
                      industry in Puget Sound may never be the size of the Norwegian industry, and the
                      Puget Sound industry uses current technology. Therefore, the situation in Norway
                      is very different than here in terms of impact potential. The proportion of
                      escapees to wild fish in Norway is orders of magnitude higher than it will ever be
                      in Washington.

               26.    Major escapements are rare. The escapement to which you refer, was the largest
                      to date on the West Coast. Because one happened last year does not imply such
                      occurrences are frequent.

               27.    The issue of a farm escapement near a river mouth with a salmon population was
                      discussed in the DEIS.

               28.    The scope of this EIS does not include an evaluation of the fish farming industry
                      in Norway.

               29.    In Norway there are a lot of old, low technology fish farm operations which are
                      much more likely to have escapements.

               30.    Yes they are, and there are important differences. Survival in terms of natural
                      processes would undoubtedly be higher.        However, since a high degree of
                      residency would be expected (as in the case of fish in the WDF delayed release
                      program) a much higher rate of exploitation would occur on escapees than ocean-
                      going fish. Also contributing to that scenario is the fact that maturing fish will
                      have no home river attractions will wander, and thus become more vulnerable to
                      commercial and sport fisheries.

               31.    Actually, Atlantic salmon have a lower risk of environmental impact than Pacific
                      salmon. Most of the permits pending for fish farms in Washington are planning









           Response to Letter No. 38: Arthur H. Whiteley (continued)

                  to use Atlantic salmon (24 out of 28). The fish farm industry in Washington has
                  their own local Atlantic salmon brood stock and has a limited need to import.

           32.    See the response to Question 29 and Appendix G.

           33.    See the response to Question 29 and Appendix G.

           34.    The reviewer raises the issue of whether a 90-day quarantine period is adequate.
                  As he states, it is possible for pathogens to be latent for extended periods. The
                  WDIF disease control program does not rely solely on a quarantine period to
                  prevent pathogen introduction. WDF also considers additional factors such as
                  disease history of exporting facility and health certifications on the broodstock in
                  question. The reviewer cites an example of an outbreak of VHS 18 months after
                  trout were transferred from a "VHS" free farm and thus implies that the same
                  phenomena would occur here.

                  WDF allows eggs to be imported, not fish, and only from farm and geographic
                  areas where certain diseases are known not to exist.

                  Washington state laws and policies exceed federal and other state laws in
                  describing and taking precautions in preventing disease introduction. The risk of
                  introducing "exotic fish diseases" is very low. There are few activities in resource
                  management that are 100% risk free.

           35.    The comment that WDF policies have been unsuccessful is without merit. See
                  Appendix G.

                  There does not appear to be any relationship between the isolation of VHS in
                  Washington State and the administration of import laws by federal and State
                  authorities. See the response to Question 29 and Appendix G.

           36.    The testimony referred to is simply the opinion of the individual giving the
                  testimony. This individual does not have technical credentials in the area of fish
                  diseases. Thus, the conclusions in the DEIS arc professional opinions based on
                  the best available technical information.

           37.    Svein Mehli is not recognized as an expert on fish pathology or fish diseases. The
                  pathogens that are found in fish in fish farms are not unique to the farms.
                  Indeed, the freshwater pathogens that are carried to marine pens by the fish such
                  as BKD, furunculosis, and redmouth were likely as a result of infection of
                  hatchery stocks by the feral indigenous stocks. Pathogens contracted in seawater
                  are indigenous to the sea and, therefore, do not provide a new opportunity for
                  exposure to feral fishes.

                  Also see response to Question 29 and Letter 1, Comment 16.

           38.    Comment acknowledged. The text has been revised for the FEIS.








             Response to Letter No. 38: Arthur H. Whiteley (continued)

              39.   Comments noted.


             40.    Comments noted.




                                                                                        LETTER NO. 39
                                                      A



  CURT SMITCH
    Director                                         1 89


                                            STATE OF WASHINGTON

                                      DEPARTMENT OF WILDLIFE

                     600 North Capitol Way, GI-11 0 OlYmPla, Washington 98504-0091 (206) 753-5700



                                               March 7, 1989





             Ron Westly
             Department of Fisheries, AX-11
             115 General Administration Building
             Olympfa, Washington     98504

             Draft Programmatic Environmental impact Statement:              Fish culture in
             Floating Net Pens

             Dear Mr. Westly:

             Your document was reviewed by our staff as requested; comments follow.

             We found this document generally well written and very Informative.          It Is
             not clear, however, how It relates to the current Interim Siting Guidelines
             and It Is not clear which mitigation measures will actually be required.
             Long-term monitoring for example should be required.

             In the a,ffected environment section (p. 64) no mention Is made of
             anadromous game fish.      At least sea-run cutthroat and steelhead trout
             should be referenced In this section. Also, pages 69 and 70 are missing
             from our copy of the Impact statement.

             The map on page 85 of major waterfowl Is very general .           If desired, our
             agency can provide more detailed Information.

             As a f Ina I comment, discussions concerning VHSD should be updated In I Ight
             of the recent outbreaks of this disease. Apparently It can be transmitted
             horizontally as well as vertically.

             Thank you for the opportunity to provide comments at this time.


                                                     Sincerely,
                                                 @@'JQUA @
                                                     Fred Maybee
                                                     Regulatory Services
                                                     Habitat Management Division

             FM:mjf

             cc: Dept. of Ecology









             RESPONSE TO LETTER NO. 39: WASHINGTON DEPARTMENT OF WILDLIFE -
    W        FRED MAYBEE


             1.    The text has been revised to evaluate existing regulations and guidelines in the
    0              FEIS.

             2.    The text has been revised to include steelhead and sea-run cutthroat trout.

             3.    More detailed information will be required during reviews for specific fish farming
                   proposals.

             4.    See the response to Question 29 and Appendix G.




                                                                   I-Eff ER NO. 40

                                         A



  CURT SMITCH
    Direoor


                                  STATE OF WASHINGTON
                              DEPARTMENT OF WILDLIFE
                16018 Mill Crcek Blvd.. Mill Crcck, WA 98012 Tel. (206) 775-1311


                                                 March 24, 1989
         Ron Westley
         Project Manager
         Washington Department of Fisheries
         115 General Administration Building
         Olympia, WA 98504

         re: comments, DEIS Fish Culture in Floating Net Pens

         Dear Mr. Westley:

         Thank you for the opportunity to review the Draft EIS. The
         following are my comments on the DEIS specifically concerning
         bald eagle impacts as discussed on pages 86 and 87:

         Potential impacts of such projects on eagles are probably
         greater than implied by the discussion. The first impact is
         related to the loss of foraging habitat due to pen locations.
         Of five projects in northern Puget sound that are either
         proposed or eX15ting, every one is located Just below an active
  G      eagle nest. Since the majority of foraging by eagles that nest
         on shorelines usually takes place within a few hundred feed and
         Just below the nest tree, these projects may be eliminating
         that habitat. Evidently, eagles select the same calm
         embayments for foraging that are preferred for rearing fish.

         The second impact relates to disturbances associated with pen
         construction and operation. Pen construction can occur outside
         the nesting season to minimize the short-term impacts.
         However, the long-term impacts involve not only activities in
         the water, but also upland areas (boat launching, facilities
         etc.). These were not mentioned in the discussion.

         Therefore, simply moving the pens away from the nest tree may
         not be the only concern. No study has been conducted to
         determine the impacts of such projects on eagles, but as
         potential pen sites become more limited such a study will be
         imperative.

         My final comment concerns a correction to the information on
         page 87. The sentence that begins "When no federal permit..."
         is incorrect. The state mandate is for protection of eagle
         habitat on state and private lands and applies irregardless of
         the issuance of a federal permit. Counties or local
         Jurisdictions have the responsibility to notify the WDW of all
         proposed net pen projects prior to their approval so management
         plans can be developed as per WAC 232-12-292.


















             Please contact me if you have questions related to eagle
             protection.



                                               Sincerely,
                                               THE DEPARTMENT OF WILDLIFE
                                                  Jim Watson
                                                 Jim Watson
                                               Wildlife Biologist
             cc: Lora Leschner, WDW
                   
			DAVE MUDD, WDW-HABITHAT MANAGEMENT













                                                                                                rA
           RESPONSE TO LETTER NO. 40: WASHINGTON DEPARTMENT OF WILDLIFE
           JIM WATSON


           1.    See response to Question 30. A discussion of existing fish farms and evaluationU
                 of specific proposed facilities is not within the scope of this EIS.

           2.    See response to Question 30.

           3.    Comment noted.


           4.    The text has been revised for Section 5.9 in the FEIS.





                                                              LETTER NO. 41



















                                                     lag













        @O           RESPONSE TO LETTER NO. 41: LOWELL & BEVERLY IAIOHLIIUETE
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                                                                  LETTER NO. 42




        Ron Westly
        Washington Dept. of Fisheries
        115 General Adm. Bldg.
        olympia, WA    98504

        RE: Floating fish net pens E.I.S.

        Sir:

        I have the following questions regarding net pen culture which
        were inadequately addressed in the E.I.S.

        How much net pen farming is now being done in this state --
        By the Dept. of Fisheries itself?

        Under contract from the Dept. and, if so, with whom?

        By private enterprise?

        Where are these pens located?

        What is the present condition of surrounding sea bed, sea life,
        water quality?

        How much of the Department budget is devoted to fish pen farming
        or research there-on?

        Who is bringing in Atlantic salmon eggs to this state?

        How long has this been done?

        Where are the hatcheries for these eggs?

        Who operates these hatcheries, and under whose supervision?

        Who certifies eggs to be virus free?

        Where are eggs held in quarantinetime?

        Is 90 days sufficient quarantine-time?

        Why are atlantic salmon eggs imported from Norway, when it is
        known to be an area where Atlantic salmon are virus-infested?

        Is it true that Atlantic salmon have been imported in this state
        for 30 years?

        The E.I.S. mentions "local broodstock would be desirable". Has
        no regulation been developed concerning this?

        Are the private fish farms presently located in the state
        financially viable without public subsidy?

        What income from bed leases has accrued to the state?










          Why have any fish pens been allowed when regulations on sediment
          levels, disease controls, are not yet in place?

          How are the fish pens cleaned? It is stated that chemical anti-
          foulant is prohibited, but the accepted method is not: clearly
          stated, nor the effect on environment explained.

          Successful fish pen farming requires high quality of water, yet
          such farming proceeds to degrade such water quality.

          The remedies and/or costs to operators are not listed.

          No dollar value is given to water quality degradation, reduction
          of free passage in such waters by native fish or people. No
          comparison has been made of these costs in fish pen operation or
          promotion to the costs to restore and promote natural spawning
          stream beds in our state.


          If the environmental costs to our waters and the bureaucratic
          costs of supervision were actually charged the fish pen operator,
          would his fish farm still be financially feasible?

          Authority over our water resources is so spread out among
          national and state agencies that no one has enough authority,
          knowledge, or responsibility to govern the resource wisely.
          Before encouraging greater sea bed uses, may we have some
          remedies in this regard, and all regulations and safeguards in
          place.


          Respectfully,



          Margaret Yeonran
          1620 - llth St.
          Anacortes, WA    98221










           RESPONSE TO LETrER NO, 42: MARGARET YEONIAN


           1.     As stated in the EIS, there are currently 13 commercial fish farms in operation
                  in Puget Sound. Their locations are indicated in Figure 2. WDF manages some
                  net-pen facilities for research and delayed release enhancement programs. A                  0
                  discussion of these facilities is outside the scope of this EIS, but more information
                  can be obtained by contacting WDF or DNR.
                                                                                                               CL
                                                                                                               Q0
           2.     Your question is outside the scope of this EIS.   That information can be obtained           0
                  from WDF.

           3.     No permits have been issued in the last year or two for the importation of
                  Atlantic salmon from abroad. Atlantic salmon eggs were first imported into
                  Washington in the 1930s. The importation of Atlantic salmon eggs for the
                  purpose of seawater fish farm culture began in 1981. A number of hatcheries are
                  developing broodstock. They are spread throughout Puget Sound (South Sound,
                  Tacoma, Manchester, Port Angeles, San Juans). The donor stock for these
                  hatcheries originally came from the East Coast states, Canadian Provinces, and
                  Europe (Waknitz personal communication 1988).

           4.     Fish health inspections are conducted by qualified technicians approved by the
                  federal and Washington state governments. WDF also inspects laboratories and
                  methods used.

                  Eggs are held in quarantine on fish farms isolated from other fish stocks on the
                  farm. The effluent water is required to be disinfected.

                  See the response to Utter 38, Comment 34.

           5.     All eggs imported into Washington from other states or countries must come from
                  areas and parents demonstrated to be virus free. When eggs were allowed from
                  Norway, they were from virus-free parents as required in our rules and policies.
                  Since the enactment of state disease policies regulating imports in 1987, there
                  have been no import of Atlantic salmon eggs from Norway.

           6.     Atlantic salmon eggs were imported into Washington during the 1930s and 1950s
                  for unsuccessful attempts to establish Atlantic salmon runs. Eggs have been
                  imported into the State for commercial fish farming purposes since the mid-1970s.

           7.     There are no regulations requiring local broodstock.

           8.     Commercial fish farms in Washington do not receive any public money.

           9.     Your question is outside the scope of this EIS. That information can be obtained
                  from DNR.

           10.    There has been sufficient review of fish farm proposals through HPA, Shoreline,
                  and Section 10 permitting programs; as well as through the SEPA review process.









              Response to Utter No. 42: Margaret Yeoman (continued)


              11.    Fish farm nets in Puget Sound are typically cleaned with a water hose sprayed
                     against the net to dislodge any matter that has attached to the nets. The first
                     paragraph on page 16 of the DEIS states that Weston (1986) -found the amount
                     of material entering the water from net cleaning and settling to the bottom to be
                     a relatively small portion of the overall sedimentation from a fish farm. On page
                     39 under Turbidity, the DEIS states that cleaning a severel, fouled net may
                                                                                    y
                     increase turbidity levels beyond State water quality standards.

              12.    Comment noted.

              13.    Comments noted. See the response to Question 12.

              14.    Comments noted.





                                                       LETTER NO. 43























































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      Response to Comments            I -- 1.






                                                                                    LETTER NO. 44




                                                                   4 Apri1., 1989


               Ron Westley
               Project manager
               Washington Department of Fisheries
               General Administration Building
               Olympia, Washington 98504
               USA



               Dear Mr. Westley:

                    I am writing -with respect to the Draft Programmatic Environmental
               I m p a c t S t a t e m e n t - -Fish Culture in Floating Net Pens. I h a v e h a d a c h a n c e
               to give this document only a brief review., some sections more thorough
               than others, but would offer a few comments.

                   First, a general statement. In my view, it appears that at least some
               of the authors of this document were not sufficiently thorough in their
               approach. For example, I woul d ci te R.L. Stokes on The Economics, of
                                     bottom line according to some decision makers. I
               see no evidence that Stokes considered such things as the potential costs
               that might result from the introduction of exotic disease--such as VHS
               (now a reality)--to the natural fishery, both commercial and sport. Nor
               costs associated with maintaining regulatory agencies, nor those
               associated with a reduction in recreational opportunities, etc. The only
               costs he appears to have addressed in any depth are those associated with
               a reduction in land values of upland owners. This particular section seems
               very cursory and in my view, virtually meaningless. Yet., it is a very
               important section for decision makers.


                    Secondly, I believe many of the summaries relating to Mitigation
                  Measures       a n d Unavoidable Aderse impacts a t t e m p t t o m i n  m i z e p o t e n t i a I
               problems, most of which are not well understood. As an example, I rather
               doubt that, "adverse impacts can be mitigated through the measures
               i denti f i ed above and through the f i sh di sease control regulation now i n
               place" (pE 31) when it comes to the recent finding of VHS in Washington
               State (almost certainly due to the introduction of Atlantic salmon). That
               quote already is outdated. I have the impression that potential adverse










                  impacts on wildlife, on native fish populations, on shellfish, etc. are often
                  played down, though many of the real impacts are unknown. The tone of
                  the writing in these sections appears stronglLI biased toward furthering
                  expansion of the industry.

                       As another example of the latter concerns, I would cite quotes from
                  pp 72 and 73 concerning genetic impacts by escaped farm fish on wild
                  stock:


                       "This discussion considers potential impacts of escaped fish
                       interbreeding with wild stocks on purely theoretical grounds.
                       Impacts associated with interbreeding between wild stock and
                       net-pen fish is undocumented." (p72)


                       and, in two concluding sentences to this section, "Without constant
                       infusion by escaped fish, these maladaptive genes would disappear
                       gradually due to selective pressure, making any impacts temporary.
                       Compared with the large numbers of hatchery releases, the genetic
                       impact of escaped farm fish on wild stocks would be negligible."
                       (p73)

                  The first quote, as I read it, says we don't know what the impact might be,
                  and this, I believe. In view of this., I consider it unjustified to try to play
                  down the potential impact in the second quote. As well, as now seems to
                  be developing, there may be constant infusions of escaped fish into the
                  wild. And, to try to compare the release of hatchery fish to escapees from
                  f arms appears to be setti ng up a straw man, f or " 'normal ' hatchery f i sh
                  may or may not be very di f f erent f rom wi I d popul ati ons..." (p7 1 ), whereas,
                  with selective breeding and genetic engineering, farm fish likely soon will
                  be very different from wild stock.

                       I n my vi ew, there are too many unknowns to a] I ow a si gni f i cant
                  expansion of the net pen industry, as is, unfortunately, occurring here in
                  British Columbia. With new environmental horror stories surfacing almost
                  daily, a complete moratorium on any expansion of fish forming on this
                  coast, and close monitoring of present facilities for at least 10 years,
                  would seem the most judicious approach. I'm sorry, but I find many of      the
                  arguments in the PEIS not very convincing. I enclose a copy of a recent
                  manuscript about VHS prepared by my wife arid myself, soon to be released










               in a local newsheet, that illustrates in more detail some of our concerns
               about the development of this industry.

                    I hope that the f ew comments I have provided will be of some use to
               you in your deliberations. My major comment would be that I f eel that the
               general tone of the PEIS is t o downplay potential problems, at least one of
               which (VHS) has already surfaced, in favor of promoting the industry.


                                                                      Sincerely yours
                                                                    (5@Fel
                                                                      Fred C. Zwi    1
                                                                      Professor Emeritus
                                                                      Department of Zoology
                                                                      University of Alberta
                                                                      Box 81
                                                                      Manson's Landing, B.C.
                                                                      Canada VOP IKO







                 VHS--1FOR THE RECORD by Fred and Ruth Z%-tickel           (26 March 1989)

                     We have a new fish disease on our coast., virall hemorrhagic
                 septicemia, or YH5. Preyiously identified oinly from northern Europe,
                 VHS has recently been found in coho and Chinook salmon in Washington
                 State (according to reports, these fish had been in the wild). In vi ew of
                 its potential effects, it behooves us to know more about this disease.

                     In Europe, VHS has been found primarily in rainbow trout, and more
                 recently in Atlantic salmon. Two current publications provide revealing
                 information about this disease. Most quotes below are from Textbook o    f
                 Fish Health (1987) by Dr. George Post, but whE!re noted, are from the
                 WashingtonState Draft Programmatic Environmental Impact Statement on
                 Fish Culture in Floating Net Pens (January 1969), denoted here as PEIS.
                 Enclosures in brackets are ours.


                 On the Dangers of Introduction of VHS to North Aimerica: "VHS is
                     one of the highly contagious diseases which has not been brought to
                     North America., Fish health agencies should be especially alert to all
                     possible ways this virus could enter the continent and devise methods
                     to block entry ......

                     "Of specific concern in North America are Atlantic salmon eggs
                     imported from Europe and the potential risk of introducing viral
                     hemorrhagic septicemia..." (PEIS)

                     "A primary concern with the growth of thE! net pen industry in
                     Washington is the possible increased risk of introduction of exotic
                     diseases. This risk is minimal because regulations ere in place to
                     restrict importation of serious exotic pathogens of salmon. One such
                     pathogen., viral hemorrhagic septicemia (VHS), develops during the
                     salmon's freshwater phase. All eggs imported into Washington must
                     be certified free of VHS." (PEIS.)

                     "It is such diseases which could pose a sionificant risk to native fish."
                     (PEIS)


                     1. ...the risk of transmission of disease from net pens to wild fish is
                     possible but not likely a significant problem." (PEIS)

                 These statements are, of course, already largely out of date. VHS is here.

                 On Susceptibility to, and Mortality from, VHS: "The rainbow trout is
                     a relatively new introduction to the European continent and may have







                   no natural resistance to the virus ...... [rainbow and steelhead trout are
                   the same species]

                   "Morbidity [mortality) levels among rainbow trout in which epizootics
                   [outbreaks] are occurring is probably nearly 95%."

                   "The virus has been inoculated into brown trout, brook trout and coho
                   salmon... The same course of the disease follows as in rainbow trout."


                   one outbreak indicated that, "...severity in saltwater environments is
                   just as great as in freshwater."

                   in one study, brook trout were placed in contact with infected
                   rainbow trout and, "...all of the 24 experimental brook trout died."


               We can now add Chinook salmon to the list of susceptible species. All five
               Pacific salmon., and steelhead trout., none of which was previously exposed
               to this virus, may have little resistance to it. They are now at risk.


               On Carriers and Control of VHS: "Location of carrier fish is
                   di f f i cult..."


                   @"Survivors of the disease are always suspected carriers."

                   "...serological [blood] surveys of fish populations to locate
                   carriers-are impractical for control of the disease."


                   "One of the greatest problems in the control of fish virus diseases has
                   been the location of viral carriers in the tremendous populations of
                   fishes found in many fish culture facilities."

                   "There are no therapeutic [treatment] procedures for VHS. Prevention
                   is the best control."


               Present attempts to test for VHS in culture facilities and the wild may be
               fruitless., especially if it is dormant in carrier fish (VHS tends to be
               seasonal and, "highest mortalities occur during the winter months.").

               On Transmission of VHS: "Transmission ... is by contact with
                   vi rus-contomi noted woter."


                   "Water from fish culture facilities undergoing epizootics of VHS
                   could carry the virus to wild-ranging fish..."






                     "Demonstration of the virus in latent [dormant] cases is especially
                     difficult... Fish with latent VHS will beoin to shed large numbers of
                     viral particles when the latent stage chonges to acute as a result of
                     environmental stress."


                     "This virus can infect the egg while the Ingg is still in the mother and
                     be passed to offspring." (PEIS)

                 Note that identification of VHS is difficult, especially if dormant. And,
                 fish under stress, for example those in net pens, are especially
                 susceptible to it. Should they become carriers, they may serve as a
                 reservoir for the disease. Since VHS is waterborn, it can potentially be
                 introduced into the wild during tidal flushing through net pens, or in
                 waste-water from hatcheries. .


                 On Infectivity of VHS Outside Living Tissue: "The virus is extremely
                     heat sensitive (inactivated at 600C in 15 minutes, and loses at least
                     50% infectivity in 15 minutes at 310C)."

                     "The vi rus I oses i nf ecti vi ty i n dead f i sh ti ssue wi thi n 24 hours at
                     00C..."


                 Apparently VHS has a short period of infectivity outside living tissue, as
                 with some other viruses. If so, attempts to blame its introduction into
                 North America on the pumping of bilge water, from ships is a red herring
                 (hopef ul I y, VHS-f ree).

                 How Di d VHS Get Here? We %,Yi I I never know f or sure. Suggesti ons such
                 as pumping of ship bilges have been advanced by some proponents of fish
                 farming. But, the weight of evidence points strongly to its introduction by
                 the fish farming industry itself. It seems more than coincidence that VHS
                 arrived here only recently., following the expansion of Atlantic salmon
                 culture on this coast.


                 The warnings were here- Some, such as, "Transmission...,.-lith eggs is
                 suspected but not proved." were sounded in the 1960's. We consider it
                 irresponsible for governments to have allowed, and ent,repeneurs to have
                 introduced, Atlantic salmon into an area with an already thriving natural
                 fishery. Five species of Pacific salmon, plus steelhead trout, and perhaps
                 other species, are now in jeopardy. Hopefully, control measures taken to
                 date will stop the spread of VHS, but we mail not know for years to come.
                 The paternalistic "don't worry, be happy" assurances of some government
                 and industry experts, that everylhigg is/was under control, now, more than
                 ever.. ring hollow.













                                                                                                             M
           RESPONSE TO LET17ER NO, 44: FRED C. ZWICKE


           1.     See Section I of the response to comments after the text in Appendix E.
                                                                                                             U
           2.     Comments noted.                                                                            0

           3.     The DEIS addresses the interbreeding question on theoretical grounds because no            C
                                                                                                             0
                  scientific evidence exists to support interbreeding of salmon that escape from fish
                                                                                                             CA
                  farms with naturally occurring stocks. As noted in the third paragraph of page 69          W
                  in the DEIS, Atlantic salmon are not capable of cross-breeding with any of the             04
                  indigenous species.

                  The DEIS also addresses the concern that farmed Pacific salmon will escape and
                  interbreed with wild populations having an adverse affect on the wild-gene pool.
                  Paragraphs one and two on page 72 of the DEIS point out several natural barriers
                  that escaped farm fish would have to overcome prior to establishing an effective
                  reproducing population.

                  Ile meaning of the second paragraph quoted is "without constant inftision of I r e
                  number of escaped fish, maladaptive genes would disappear gradually due to
                  selective pressure." Even in the advent of major escapement, occasionally the
                  numbers of escapees returning to rivers would be relatively small (see Letter 1,
                  Comment 9 and Question 9). The FEIS text in Section 5.7 has new material
                  giving perspective to the relative numbers of wild salmon and predicted
                  escapement from fish farms.

           4.     Comments noted.






                                                                               LETTER NO. 45







            Ron Westley
            Wa. Dept. of Fisheries
            115 General Admin. Bldg.
            Olympia. WA 98504





            Mr. Westley,


            I am glad to have the opportunity to share my views on the net pen issue that
            has been heating up over the past few years.
            It seems the wheels have been once again set in motion to negatively impact the
            quality of life available here in the Puget Sound Area.
            Of course it is difficult to balance the needs of business, government, and the
            general public. In this case it is time to move strongly in the direction of
            what's good for Puget Sound and the general public that use and appreciate it
            so.
            This question has to be asked: Can we really justify the probable pollution,
            fish diseases, and eyesore brought on with these additional net pens?
                                       THE ANSWER IS NO!!
            Unfortunately, the door has been opened with some currently operating net pen
            operations. Even though this is taking place it doesn't mean we have to open the
            door further. The present operations should be given another three to four years
            and then be forced to-close.
            The parties in favor of these pens are only there because they stand to gain by
            having pens scattered throughout the Sound. It's a shame the the average
            citizens interests haven't been put above those of these special groups. It's
            time they were!
            I and many like me have lived, worked, and played on and around Puget Sound all
            my life. I've seen the slow decay of many different species of fish, animal, and
            bird. We have taken almost all that this fantastic body of water has to give. It
            is now time to vigorously defend the Sound and start putting back what we have
            taken.




            Sincerely,




             eff    eman

            509 NW 70th

            Seattle WA. 98117












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                           Response to Comments






                                                                                   LETTER NO. 46





                                                                    march 11., 1989



                  Dear Sir:

                       Thank you for allowing; me to comment on the P.E,I.S.. I

                  represent a community on Camano Island of 24 families, we are

                  angry over the -whitewash perpetrated on the public by this

                  biased and contradictory report. According to the authorss

                   there are no adverse impacts that cannot be "mitigated" by "if"s.
                  who is going to swallow this? The state wants at   least 100 more
                  salmon pens. These farms will produce 55 metric tons of oxygen-

                  demanding waste per day. That's 18 more tons a day than Metro' s

                  Renton and West Point treatment plants together produce from the

                  sewage of one million people. To say this will all be "mitigated"

                  by a hundred *if I's is patently ludicrous*

                     We want a non-political impact statement. If the state

                  ever comes out with one,, Puget Sound won't be paved with these

                  odorous obstructions.

                                                        Sincerely.,
                                                                      Carol church
                                                          Camano Cove Community club
                                                          Carol Church
                                                          16524-37th N.E.
                                                          Seattle., Via.., 98155









        @d           RESPONSE TO LETTER NO. 46: CAMANO COVE CO tUNI 'CLUB
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                                                                  LETTER NO. 47






        March 14, 1989

                        Re: Salmon Yish Pens

        Mr. Mark Westley:

             Read in the Skagit Valley Herald about the audience and

        statements made at the rubiic meeting about Fish Pens.

             We need salmon Pens; thev can be riaced at various places

        which can 'he judiciai-Ly thougnt out.

             It will employ a few neoDle. It will bring in tax money.

        Other countries have fish pens. I listened to news from Vancouv'er

        B.C. and heard thev did not have a fear of a virus. Also they

        keep check on what is going on in the world, havine scientists

        bactorioligists, etc.

             It is known that down thrul the ages people do not want

        change, especially if it is near their habitation.

             Get in the news what other countries are doing about fish

        Dens. Educate the people. The shoreline owners do not speak for all.

             We are urged to eat more fish for healthd sake. Now it is

        about $5.00 a pound whicn is very exrensive for senior citizens

        and folks on low sa-Laries.

                                            Thank you, Sincerely,










                                                            ZZLLA " LUTTERLOH
                                                            826 JA14ESOZ ST
                                                            SEDRO WOOL EY KA
                                                            95284 1724









        @O           RESPONSE TO LETrER NO. 47: ZELIA M. JTTERLO @
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                                                                              LETTER NO. 48















                                                  9327 220th S.W.
                                                  Edmonds, WA 98020

                                                  February 20, 1989



                  Eric Hurlburt
                  Aquaculture Coordinator
                  Department of Fisheries
                  Olympia, wA 985o4

                  Dear Mr. Hurlburt:

                       I am writing about the article, "Keeping the Old Farm Afloat"
                  dealing with fish farms. Many people are concluding that salmon
                  -Farms are polluting the environment. Also, the fish are weaker
                  than natural wild-run salmon. As a sports fisherman, I go along
                  with salmon farms. If not for fish farms, fishing season would
                  be short or not even at all for the fear of salmon extinction.
                  The fish farm makes for hours of fun time for sports fisherman on
                  a lazy, relaxing day.

                                                  Sincerely,



                                                  Terry Maxwell










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                                   Response to Comments






                                                                LE17ER NO. 49

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                                                                                                                            ~w I                                                                            M~r~b~l~i staid
                                                                             ~1~.~1~i~m~-~O~r"~I"~r           ~I~'~M~e~n~g~arr~r~i~l                ~i~l                                                                                            r~ed~e~s~i~n~i~o~t~h now is
                                                                             ~s~1~l. ~o~r~, ~s~-~r~o~y~s        it Call ~g~a~ve~r~a~l~a~v~e~l~l,                                                                                  pr~e~qr~s~o~l~. ~i~t~s 3110 ~Inc~Hi~Li~t~-~o last
                                                                             ~f~i~l~l~i~c~i~a~l.                                                                                                                    ~l~i~alt~a~nw~i~t until 19~9~f~l~i~.
                                                                                   Sv~e~h~i A~a~g~e Mr~-~l~d~i h~end ~f~i~t ~qb~i~r.
                                                                             d~i~v~i~q~i~,~o~a (of ~qN~t~)rw~ny~'                                                                                                        ~Li~all as n ~r~u~i~l~l~f~.~j~i~l~l~y~i
                                                                                                              ~S                                         ~1~7  ~T~.                                                                            ~s~I~n~tiOn far
                                                                                                                                                                                                           d~i~l~r~o~l~v~i~r~." ~M~P~2p~p~p~p~ni~t       "They will
                                                                             (for N~a~Lm~r~. Mn~a~n~s~t~r~i~a~r~al, whirl~, ~i~s                                                                                                                     ~6qT
                                                                             ~ch~ur~i~-~m~l With p~i~a~u~-~v                                                                                                          olive Rr~en~t~p~r d~i~s~en~s~e p~r~e~.~-~n~a~r~"~. ~a~a
                                                                                                                        of Willi
                                                                                                                                                                                                           ~l~a~s~tur~r~il ~q~1~t~wk~s ~th~r~i~l. we d~i~jh~j~'~L~s~f~v
                                                                                                                                                                                                           ~b~e~f~f~i~r~e ~n~t~,~L~l~w~e~s ~o~1~w~r~o~Li~a~s~t~s~.~"
                                                                             ~m~o~l~o~a~l~l~a~, ~t~a~ld a ~qw~a~sh~i~ag~u~n~l~iS~t~a~t~e
                                                                             ~1~1~.~1~,~1~0~:~1~1~.~a~r~y ~I~I~I~-~m~i~l~l~qi~, N~,~,v. 14 that
                                                                             ~!~0~1~00 ~h~irm~ed ~s~i~t oil,                                                                                                         M~P~I~l~Ii ~R~o~i~d r~a~r~d~irr n~1~v~id~i~e~r, ~w~o
                                                                                                                       ~i~n~"~"~qi~t~"~i~q"~,                                                                          ~- q
                                                                             wi~lh ~I~t~a, di~s~f~-~I~m~p                                 ~1~,                                                                         I-lot ~. ~L~rnyi~ag tit ~F~:~I~r~l~l~l~q~,~2p~p~ish ~h~i~l~i~t
                                                                             ~o~t~a~lm~o~v~er ~i~a~to ~I~l~qi~nt~i~s~a~i~l~lj~or~d~e~n                                                                                              rivers ~qh~Ow n ~sh~o~irp i~n~t~-~t~en~s~e i~t~s
                                                                             ~a~r~n~r M~u~l~,       l~e~.                                                                                                           ~Il~i~p l~in-~s~e~a~r~e n~l' ~Inr~a~w~n~i ~f~i~qh~. A
                                                                                   D~"s~i~v~i~t~e ~n~a ~i~"~1~4~"~I~siv~e ~li~q~l~i~rry Los                                                                                                 ~1~9 percent of Ills~, ~l~i~nh
                                                                                                                                                                                                           ~qI~qs~r~qZ~-~q'~qS~q'"~'~t~h~, ~-~i~%~vr~-~q ~s~h~edi~rd we~t~e
                                                                             ~v~a    1~~1~-~1~1 Ills~, ~l~i~q~l~l  ~n~a~l~l a system fit                                                                                   ~1~1 111
                                                                             tit-I. ~bar~ti~r~t~ed~e~s al. ~1.~l~a~- ~a~i~n~l~i~t~l~i~q ~af ~-                                                                                   of Was ~o~r~i~gi~a. In 19~1~4~8. Use ~f~i~t~,~.
                                                                                           rivers, ~a~r~s ~i~l~l~i~qm~ird fish                                 ~/~1~"                                                   tire, rose In 41~)                      too i~gi~l~l
                                                                             ~;168q=
                                                                             w~" ~1~0~1~1~1~1~1~1 ill            fresh water, lie                                                                                   ~w~n~q ~C~~"~I~f~f~i~r~l~i~t~ed Ivy ~rc~al~e ~s~o~u~np~ql~e~s
                                                                                   ~76qI~l~i~fi~r~i~l.                                                                                                               ~an~d ~e~le~c~t~r~op~h~n~8qW~qa~i~g.
                                                                                   .. I ~r I lie disease ~r~1~pr~en~t~i~q to no~.                                                                                   Asked if ~s~t~r~o~v~e~i~g ~r~rg~u~l~n~t~i~a~l~l~.~;
                                                                             ~1.~1~1r~a~l   stocks, file. ~si~l,~t~inLi~an ~m~ay                            a Sv~el~on A~n~g~e M~e~h~l~qk of Norway's                            could ~c~o~ut,~r~o~l di~s~e~n~s~r. M~r~i~ll~i
                                                                             ~f~a~- m~i~t of control in Norway,~"                                     environmental agency. testified                            agreed they could "~i~s~d~r~i~l~v~ai~R~e
                                                                             M~r.~b~li F~u~sid.                                                      last                                                       ~i~qm~b~l~e~m~s It ~t~he~y go for ~e~l ~u I
                                                                                                                                                month to a Washington Sliest~                              ~0qC~I~R~P~R~Y has not ~R~an~'~t~qe ~qr~.~1~1~q;
                                                                                   "I feel we ~a~re on a sharp ~P~d~qr~e                               regulatory agency.
                                                                                                                                  I                                                                        enough.
                                                                             with d~i~s~e~s~l~a~r~g~. If we have It ~i~e
                                                                             ~p~n~rn~Ri~IA~-1 ~(~;y~r~s~sdac~(y~It~L~q ~s~ta~la~r~& in,                             M~ch~l~i ~r~e~s~qC~anded angrily to                                 Norway Is proposing a ban an
                                                                                                                                                                                                           the transfer of ~e~g
                                                                             '"Orr rivers we may just accept.                                   ~su~a~r~e~nt~i~on~s y fifth form p ~qp~o~s.                            h ~tw~e~e~n                  ~qi~n nod f~an~o~lL~n
                                                                                                                                                ~n~en~t~a~t~l~i~n~t them in ~"~r~o~t~s~c~onc~h           r~d                 e         ~r~p
                                                                             ~o~ur will ~f~inl~in~on ~I~n extinct.~"                                                                               ~n~o~ov~e                      n~0qV~o~s~s~a ~a the country,
                                                                                   ~ir~i~t"!ncul~l~i~si~n in present in                                ~evid~e~r~s~qW of di~s~e~a~s~se lipreading                            h~e~r~i~a~ld,~on conR~ld~erin~g a Ivan an
                                                                             ~H.~C. writers and leads to loss of                                  to wild stocks from farms.                                 all Imports of sexual products
                                                                                                                                                                                                           like eggs and milt.
                                                                             ~a~l~l~q!~qr    i~t~@~.. ~f~l~aid retention, ~tilc~er~s                            "We are very c~an~c~e~r~n~p~(~l.~" lie                              Even ~th~ot~igh existing r~e~gu~l~a-
                                                                             ~.~1~1 ~q@~qL~v~e~n~t~t~j~n~l~ly d~e~n~Lh in tip ~to 60                                ~f~ulid. "it is not right to ask for                         on
                                                                             p~er~c~ent~o~l~a~f~f~ect~e~d stocks. I~thr~ul                                  conclusive evidence at such ~hn                             ~qV ~i~s Hot di~pe~o~ne~s which must.
                                                                             not ~b~e~rn found in Norway until                                     early ~a~l~a~g~e~.~"                                              not be present in Imported eg~F~x~,
                                                                             small~; ~qtr~an~n~f~er~s from outside the                                  F~i~er~unc~u~l~o~s~i~s ~i~m                                           the list~; in limited and "in N~erwe-
                                                                                                                                                                    to             I; I on                 inn ~c~n~ge culture. we know other
                                                                             c~o~a~m~I~ty were un~t~l~er~L~ak~en. ~Gyr~t~s.                                   ~s~m~o~lt~od~r~o~t~i~n~e~d ~T~1~1=~11~1~r~o~l~s~o
                                                                             dn~ort~y~lu~s~t ~nl~q~o line been linked to                                broke ~o~ut two years a                                      ~qli~t~s~e~n~s~e~e are knocking at ~t~h~e
                                                                                                                                                                                 ~,~q1~0 ~en~d                   dent."
                                                                             fish forming ~v~ind ~i~n ~tr~en~L~e~d by                                    ~oul,h~o~r~i~ti~es felt they he er~ad~i-
                                                                             ~hil~l~in~qT all bast Fish with rate.                                   ~c~a~t~ed it, lie stolid.                                      In theory, he artist. ~fi~nh ~f~a~n~n~e~r~s
                                                                             ~M~M~C~.                                                               This y~e~t~ur~'~s outbreak was a                                "want to get rill or disease.. but i~f
                                                                                   ~IV~I~VI~lli ~WFIR ~(~I~t~i~n~li~fi~r~d ~PR an                              attack. on wen the continued                               they we profit in t~he ~s~h~o~lt term
                                                                             expert; witness at a henrin~p in                                    ~"Pr~end of bacterial kidney di~s.                            ~t~hey may re~oc~t In a different
                                                                             L~i~v~e~r~qf~q, Wash~., or ~t~he Sh~o~qj~q;~qj~I~n~p                                    ~e~n~'~q"~. I ~qBK~qO~q)~, which ~qi~s very d~if~l~i.                         way.~"
                                                                             I ~1~,~.~n ~r   ~i~o~n l~i~n~s~otd~, which is h~e~n~r~-                             Cult ~to t~mn~t    even with ~a~u~t~qi~qb~qi~t~s-                        Will ~n~i~n~a confirmed ~f~en~r~q of
                                                                             ~i~n~g nn r~ipp~er~il of n ~Sk~i~s~pi~t ~Cnun~t~y                                tics.                                                      ~11~c~f~!~"~L~qiv~C R~el~l~e~t~ic ~e~ir~e~c~i~n of ~r~n~r~l~n~-
                                                                             ~d~e~c~l~i~t~i~on UP reject n fish (~ar~i~n In                                                                                           ~e~d ~l~i~ph ~o~i~l wild stocks it t~h~ey
                                                                                                                                                ~"~l~l~4q"~)~4qr~3~c~a~s~s' problem ~l~ornnt~'                               Interbreed. "We are very afraid It
                                                                             ~t~qh~e mouth of t~he Sl~o~a~l~ti~t.                                         ~u~rn       ~S~o
                                                                                                                                                I ~doc s~o b~ec~a~t~i~n~e it w~n~s di                                could affect their ability to
                                                                                                                                                ~n~o~.~,~w~i~ql for the ~qf~ir~ot time in I                            I       ~te~'~.
                                                                                   r~h~e fish farm proponents, n                                  o                                          ~3 ~1~0            ~i~n ~a~r~e
                                                                             ~t~r~i~b~i~l~l ~qF~r~o~l~ip, are appealing Lire                                 nil previously (lid not exist in
                                                                             ~r~e~f~u~nn of t~h~e S~qhr~i~gi~l, ~(~,~'~qm~I~l~l~ty                                   nature." M~el~d~i ~s~u~i~l~qd. ,It ~t~o~, very,                        N~e~tp~en ~P~olm~o~n have~under-
                                                                             ~C~o~l~l~i~n~l~i~s~p~l~o~n~e~r~n to ~i~s~su~r permits                                  easy to ~%~o~r a c~r~onn~e~c~tinn between I                        ~g~i~n~ie careful ~R~el~ec~ti~v~i~t~s ~f~ar size
                                                                             l~or ~t~h~e~. farm on ~t~h~e basis that it                                 HK ~D (i~n salmon forms) ~o~qn~s~qi wild                           ~and growth rate. he said, b~t~it
                                                                             ~thr~en~t~en~t~s Skagit ~sn~l~i~v~i~on and                                     stocks in ~th~e river."                                      ~r~e~s~e~s~ur~ch~er~s may hr~iv~e in~adv~er~.
                                                                             c~r~iuld pollute t~he sensitive ~e~stu-                                 "It's ~m~u~s~n~on~s~i~b~l~e to conclude"                             ~t~e~n~u~y~ne~l~e~ct4~ed~o~U~i~ercharacter~i~%~-
                                                                             a~r~y~.                                                               BK~O ~"~Pr~e~nd from ~f~n~r~tn~q~, lie Paid,                          ties which could have a negative
                                                                                   ~Pr~o~p~o~n~r~i~s~t.~q l~i~nv~e d~e~ni~"ll there                             ~an~d Norwegian ~aci~enti~o~L~s -sea                              Impact It reintroduced Into wild
                                                                             Is tiny evidence of n disease                                      logic in such a connection." UK D                          ~et~ock~s.
                                                                             Omni, to wild ~s~t~r~id~u~t train farmed                                 in diagnosed or suspected in 100                           "First there In a genetic p~r~ol~s~-
                                                                             ~qO~qn~In~qi~qo~qn~q.                                                           n~qet~qt~qien, operations and butcher-                           le~qr~qn ~qand second an ~qenvi~qr~qc~qor~qin~qi~qer~qs-
                                                                                   As n f~qe~qs~qu~qlt~q. Live appeal h~qe~qnrin~qr                             lea.                                                       in p~qr~qo~qb ~qc~qu~qt. If A~qt~qIn~qv~qot~qic: ~qP~qolm~qan
                                                                             has L~qu~qrn~qed into a deep i~qn~qv~qe~qntig~qn-                                  Antibiotic u~qse on N~qor~qw~qe~qg~ql~qi~qon                               ( ~q-     1~q01~q11~q19 in Pacific waters) h~qnv~qe
                                                                             Lion of Use environmental Impact                                   fish farms climbed to 48 t~qonn~qe~qs~qt                           Lie same r~qe~qt~qlui~qr~qrment~qo no c~qoh~qo
                                                                             ~qof~q.~q4n~qim~qon forms on wild stocks.                                    ~ql~qa~qnt year, e                                                       Mend trout - and we
                                                                                                                                                          ~80qgunI to the require.
                                                                             M~qr~qIdi won I l~qown front Norway to                                   ~qm~qr~qot~qs for     none u~qse and animal                          know that salmon ~qe~qx~qr~qop~qe In great
                                                                             t~qr~qatify on ~00qWh~qo~qolf of county ~qc~qa~qm~q.                                   hu~qs~ql~qa~qindr~,y combined.                                      numbers - then you will have
                                                                             m~qi~qs~qsi~qon~qer~qs, who hacked up their                                    ~q.~q. if~q0                  first ~qd~qi g~qn~qa~qs~qi~qa                    competition for space in the
                                                                             d~qeci~qni~qon by referring to the                                       of ~72q=~2qv~6qn~qi~qat~qch~qa~6qd'~4qI~6qs~2qe~qa~qse In ~qN~qn~qo~qr~qw~qa~8qy                            rivers."
                                                                             S~qt~qo~qr~q.ul~qti Foundation report on                                     ~q.t~, 1~q.             ~q09~q0~q, Win                ~q'~qq~qs~ql~q.           As to their ability to ~qap~qa~qv~qirn~q,
                                                                             ~qN~qnrw~qny called Journey to the                                       ~80qr~q1~q.~qS~qt~q.~qW~q.~q.~qO~76qV~2qe~qn~q1~q1~qr~qq`~4qLh~qs~qspp~qen_ ns~q-ch                          -we see them In rivers. they am
                                                                             Future.                                                            a case," Meh~qli cont~qin                  e ri-               mature, ready to ~qap~qown and we
                                                                                                                                                                                                           am very worried of what will
                                                                                                                                                                                                           happen.
                                                                                                                                                                                                           New z~0qd~qnln~qg regulations now
                                                                                                                                                                                                           be~ql~qp Implemented In Norway
                                                                                                                                                                                                           will ~76qLn farms within 20 kilo-
                                                                                                                                                                                                           ~qm~qi~ql~qtr~qe~qs of ~qb~qa~qlmon rivers and don
                                                                                                                                                                                                           en~0qU~qr~qe ~qf~6qi~qgr~qi~qll~qe to forming when
                                                                                                                                                                                                           salmon rivers an p ~qa~8qn L
 





                                            Fish farm use
                                            of antibiotics
                                            poses threat
                                               The wideprend use of antibi-       resistance can be transferred
                                            otics in fish culture poses n seri-      from one type of bacerin to
                                            Ous potential threat to public        another, Whiteley said, and can
                                            health, says a Washington State          create resistance to several types
                                            zoologist., and should be strictly        of antibiotic.
                                            controlled.                                 Whiteley said this type of
                                               Arthur Whiteley, a zoologist          transference has been docu-
                                            with a long-standing interest in         mented in Live case of a vibrio
                                            microbiology, told in Washington          bacteria which causes disease in
                                            State Shorelines I [caring Board         fish. In a laboratory, this resis-
                                            inquiry Nov. 14 that antibiotic          tance was transferred to differ-
                                            use on fish forms will produce           ent bacterin which exist in the
                                            antibiotic resistant bacteria in         North Pacific food chain and am
                                            the human food chain.                    pathogenic to humans.
                                               If these resistant bacteria              ... This has riot been observed in
                                            occur in humans. "the diseases           the wild," he said, "but them is      a
                                            caused  by that organism could           probability it could occur. Ex-
                                            not be medically treated.                periments indicate the genetic
                                               "It would eliminate from the          mechanism is in place ... and
                                            tools or the physician     those he      we can predict it will occur in
                                            would went to control disease."          nature under certain conditions."
                                                                                        The Centre for Disease Con-
                                               Whiteley was qualified as an           trol in Atlanta has found the
                                            expert witness in the hearing,           same phenomenon in beef and
                                            which was set up to hear on              poultry, he said. find blame it for
                                            appeal against a decision by             a dramatic increase in salmon-
                                            Skagit County to deny permits            ella.
                                            for a fish farm near the mouth of           The only solution, he said' his
                                            the Skagit River.                        to ban the use of antibiotics in
                                               Whitley produced a pile of            fish culture which am used in
                                            scientifiic studies which allow           human treatment.
                                            that "in almost every    case resist-       In B.C., both oxyfetracyline
                                            ant bacteria is selected by the          and erythromycin am used in
                                            use of antibiotics in fish culture."     fish culture even though they
                                               In other words. use of antibi.        also are used in human medicine.
                                            otics to treat bacteria causing          There is no inspection to deter-
                                            fish disease kill all but the bacte-     mine whether or not this trans-
                                            ria which is resistant to the            ference of resistance is occurring
                                            medication.                              in B.C. or whether fish sold to
                                               Studies have proved that this         consumers is free of antibiotics.










          RESPONSE TO LETTER NO. 49: PACIFIC TROLLER ASSOCIATIO


           1.    See the discussion of the potential for spread of disease in Section 5.8 of the
                 FEIS. Also, see the response to Questions 25, 26, 27, 28, and 29, and Technical U
                 Appendices D and G.

          2.     See the discussion of antibiotics in Section 5.4 of the FEIS.                    M
                                                                                                  0





                                                                    LETTER NO. 50






                                                          March 3,1989
           Ron Westley
           Project Manager
           Washington DOE
           115 Gemeral Administration Building
           Olympia, Wa. 98504

           To Whom It May Concern:


                I am requesting that the date of the March 23 deadline
           for comments on the PEIS be extended due to the following
           reasons:


                1. The PEIS, consisting of two volumes,has an issuance
           date of February 6, 1989 but we did not receive our copies
           until approximately two weeks later. Nov it is expensive for
           obtain additional copies that could be passed around for
           examination and study.


                In other words it costs money and takes a block of time as
           the'EIS, in certain areas, requires the use of people who will
           volunteer to interpret the meaning of much of the analysis of
           water quality, fish disease, etc. It takes time to find,
           contact, furnish copies, and give them time to study the
           proposal.

                Public meetings have been cancelled due to the inclement
           weather. Poor road conditions prevented many people in my area
           from going, in our caseI to Mount Vernon.This meeting I assume
           would be re-scheduled. That would require some time to advise
           interested parties.

                Right now there is a great deal of new information being
           released regarding the effect of fish disease, virus, etc. in
           Puget Sound. Waiting awhile may reduce hysteria and phobias
           and produce some facts.

                Please advise me as to when this cancelled open meeting
            will be re-scheduled. I do wish to be advised as to your
           decision regarding the extension of the comment period so that
           I can advise others.


                Thank you for your cooperation in this matter.

                                              Sincerely Xours,

                                              Marie J. Pickett
                                              3653 S. Bells Beach Rd.
                                              Langley, Wa. 98260
                                              1-206-321-4862








         @O             RESPONSE TO LET17ER NO. 50: MARIE J. PICKETr
         m
         rA
         v
         0
         0               1.         See the response to Question 5.
         W
         eD
         rq,
         0
         (n
         0
         S
         S
         M

         "I,
         w





















    I




                                                                               LETTER NO. 51







                                                     3643 South Bellis Beach Road
                                                     Langley, Washington 98260

                                                     March 10, 1989






               Project Manager Ron Westley
               Washington Department of Fisheries
               115 General Administration Building
               Olympia, Washington 98504

               Dear Sir:

               We find the Progranmtic Environmental Impact Statement for Fish
               Culture in Floating Net Pens unacceptable and incomplete. A revision
               and updating a new draft is recommended.

               The PEIS is inadequate:
                      using out-dated data
                      omitting specific scientific findings
                      excluding studies from other countries (Norway, Canada)
                      not considering recommpense for aesthetic damages
                      ignoring forfeiture of public rights
                      not providing funds for enforcement of pollution and noise
                            offenders
                      omitting adverse effects on clam and oyster beds
            0         confusing methods for evaluating economic effect on local
                            communities
                      not protecting the tourist dollar
                      not writing in straight forward way for general reader's
       (D                   comphrehension
                      not fully covering navigation problems.

               The report is full of assumptions and inconsistencies. A new PEIS
               should be prepared by persons not involved in the aquaculture industry.
               No conflicting interests please.

                                                      Respectfully yours,





                                                      Robert H. and Gladys Shipek









             RESPONSE TO LETTER NO, 51: ROBERT RAND G )YS S WE



             1.     Comment noted.

             2.     See the response to Question 6.

             3.     See the response to Question 12.

             4.     See the response to Question 11.

             5.     This document addresses only those issues which alter or affect the environment
                    near a fish farm. Questions concerning funding sources for enforcement are
                    beyond the scope of this document.

             6.     See Section 5.5 of the FEIS.

             7.     Comment noted.

             8.     See the response to Question 12.

             9.     Comment noted.

             10.    See Section 6.2 of the FEIS for a discussion of potential navigation impacts.

             11.    See the response to Question 2.




                                                                 LETTER NO. 52

                                                Gina McMather, President
                                                SOUTH POINT COALITION
                                                PO Box 506
                                                Port Townsend, Washington 98368
                                                March 5, 1989
        TO: Ron Westley
            Project Manager
            Washington Department of Fisheries
            115 General Administration Building
            Olympia, Washington 98504

        COMMENTS ON THE DRAFT PROGRAMMATIC EIS ON FISH CULTURE IN FLOATING
        NET PENS


        1.   1 regret I was unable to attend the public hearing on the draft
        EIS on net pens held March 1 at Silverdale due to weather conditiona and
        transportation difficulties.
             It was brought to my attention that Judith Freeman from WDF main-
        tained that VHS, which has recently infected stock in two Washington
 (D     hatcheries and whiLh has necessitated the destruction of nearly 4
        million salmon, could not be transmitted through eggs but was rather
        transmitted through water from fish to fish.
             I would like to point out that these observations are direct
        conflict to the discussion of VHS in the draft EIS which states on
        p. 77:
                of specific concern in North America are Atlantic salmon
             eggs imported from Europe and the potential risk of intro-
             ducing viral hemorrhagic septicemia disease (VHSD). This
             viral disease may be transmitted vertically from the adult brood
             fish to eggs and fry. The virus can infect the egg while the egg
             is still in the mother and be passed to the offspring.
             Is the draft EIS presentation defective? --Or is Freeman, a WDF
        shellfish director, misinformed? This is an official request: Will a
        recognized fish pathologist, with his reputation on the line, please
        answer this question?
             If the EIS is wrong, what else is it wrong about? If Freeman
        is wrong, at whose direction and for what purpose did she introduce
        this'informatiod at a public hearing?


        II. Here follows the general remarks on the draft EIS such as I
        might have delivered orally had circumstances permitted:

             I attended a public hearing on the scoping of this programmatic
        EIS held Oct. 13, 1987, in-Port Townsend. The overriding concern I
        expressed at that hearing was that the EIS be conducted objectively
        by an impartial agency. I find my fears were justified.

                                                              (more....







          McMather remarks p. 2


                Parametrix, the principal author for the draft EIS has performed
          as a paid consultant to fish farm developers. My contact with that
          company's work was with their EIS for International Marine Farms,
          which sought unsuccessfully to gain a permit to site net pens and
          a hatchery at Harding Creek in Kitsap County on the Hood Canal.
                Jack Rensel of Rensel Associates, another author has also served
          as a paid consultant to fish farmers.
                I think it is logical to assume both of these companies hope to
          stay in business supplying studies for fish pen developers. It is in
          their interest to appear to be objective. It is not however in their
          best interest to be truly objective,           :1 think this conclusion
          is borne out by their work. I am not surprised to have major objections
          to this document --more often for what it omits than what it includes.


                A quick perusal of the authorities cited in the reference
          section supports my concerns about this document being inherently
          biased. Parametrix cites itself as an authority twice, one of the
          references being the revised Final EIS sumbitted in support of the
          Harding Creek fish pens proposal. The sufficiency of that document
          was hotly contested. Although the Kitsap County commissioners returned
          a finding that the final version of the draft was not insufficient,
          they denied that permit by a 3-0 decision.
                Jack Rensel appears as an authority eight times --including
          reference to studies submitted in support of a net pen project
          for Discovery Bay. The permit for that project and the supporting
          data again has been vigorously challenged and a decision from the
          state Shorelines Hearings Board has not yet been rendered.
                J. Lindbergh, an "independent consultant" is, I presume, ion
          Lindbergh, known on the Olympic Peninsula for his long-time association
          with Sea Farms of Norway. Conrad Mahnken turns up in a number of
          citations regarding genetic impact without any reference to his
          contributions to the net pen industry.
                All of this might not be so distitrbing had I also seen a few
          authorities who are less sanguine about the future of fish farming.
          Why has not Svein Mehli been included, for instance? As Norway's
          Director of Nature Management with the responsibility for managing
          that country's anadromous fish stocks, his experience is invaluable.

                                                                   (more....








        mcmather remarks p. 3


        In fact, Norway's problems with disease transmision and genetic pol-
        lution of native stocks is ignored and/or downplayed in the draft EIS,
        both in the materials presented and in the conclusions drawn.
             For instance, one item in Mehli's testimony given in a recent
        hearing before the state Shorelines Hearings Board is relevent to
        the VHS controversy. He remarked that the number of fish diseases
        present in the country's wild salmon population increased dramatically
        following the growth of salmon net pen farming. In his estimation,
        net pens acted as "multiplying stations" for disease.
             Our state's aquaculture coordinator, John Pitts, testified in his
        official capacity (while at the same time being paid as a private
        consultant) to the effect that Norway's problems could not happen
        here. I have heard him say much the same thing on another public
        occasion. BUT IT IS ALREADY HAPPENING HERE!1 The draft EIS acknowledges
        the serious consequences posed by an outbreak of VHS but decides
        Washington's regulations are adequate. Clearly, they have not been
        adequatel
             Mehli also spoke of the great amount of penned fish escapement
        and the problems it has caused Norway. The draft EIS minimizes the
        present extent of escapement at the same time it fails to attach
        sufficient weight to the possible consequences. How about including
        information on the disappearance of a British Columbia net farm in
        the recent winter storms? Mehli's testimony before the Shorelines
        Hearings Board is now a matter of public record. There is no excuse
        for not including his expert testimony in the final version of this

        EIS.
             (Svein Mehli is not an unknown. I don't know why he was not
        included unless the draft's authors found his views inconvenient.
        He figured prominently in the Suzuki Report published in the
        British Columbian periodical, The Fishermen, which detailed the
        findings of a group of Canadian fishermen and writers who went to
        Norway to view fish farming first hand. What they found out about
        fish pens was seriously disturbing. Why have their sources not
        been contacted?)
             Speaking of commercial fishing, where did the authors come by their
        information on that subject? I don't see any input noted from the
        Puget Sound Gillnetters Association or the Purse Seine Owners Vessels
                                                       (more....








           McMather remarks p. 4


           Association representatives, for instance? The EIS section on
           commercial fishing appears to have been lifted from -the rough
           draft of the DOE's Boyce report, "Use Conflcits; and Floating Aquaculture
           in Puget Sound."
                When the draft of the Boyce report was issued, I submitted
           extensive comments --a large number of which found their way     into
           the final version released this past December. (Alas that the diagrams
           of hypothetical mitigation measures were not corrected by deletion.)
           Why must I now waste my time repeating many of the same obvious and
           not-so-obvious points that I ma& in commenting on the Boyce report?
                Just who did the EIS authors contact in compiling their
           section on commercial fishing? Nobody i-Arho ever left the dock on a
           fi shing boat, it seems to me. I submit, the authors of the EIS
           are aware of the existance of the South Point Coalition, as we
           were one of the first citizen groups to raise the issue of use
           conflicts with the commerical fishery. I submitted an entire notebook
           of evidence relating to the Hood Canal Bridge area to our county
           officials and I know one copy was sent on to the WDF. So, why does
           Parametrix feel free to cite examples from this same area without
           ever having contacted anyone in the Solath Point Coalition? I, myself,
           or another board member would have been glad to assist. Perhaps then,
           the authors might have been spared, for example, the damning and
           embarassing omission of the fact that non-Indian gillnetters fish
           AT NIGHT, a very material fact to the discussion of user conflicts
           between gillnetters and floating structures.
                I can only presume that, knowing of our existence, the authors
           chose not to contact me. Although the authors avail themselves of
           information from fish farmers and consultants "by personal communication,
           they used the telephone or interview process very selectively.
           I conclude I was never contacted because I have taken a public position
           opposing two net pen proposals which the authors have been allied with.

           THIS DOCUMENT HAS CLEARLY BEEN COMPILED BY AND DRAWN PRIMARILY UPON

           SOURCES WHO FAVOR DEVELOPMENT OF THE FISH FARM INDUSTRY.


           Having completed my preliminary observations and general remarks,
           I will go on to cite specific paragraphs where corrections are needed.
           This does not mean that these are the only cor3:ections and changes I
                                                      (more......







       McMather remarks p. 5


       would like to see made, merely the ones I feel best able to address.
       p,dditions are indicated by underlining.)
       DISEASE AND ESCAPEMENT

       P. 72 41 5........... Extend this discussion to include Norway's experience
             with escaped pen fish. Why discuss this "purely on theoretical
             grounds" when experience is available? Testimony by Svein Mehli
  0          refutes the contention that escapement numbers are small and the
             impact inconsequential. I suggest Greg Peterson, director of the
             Puget Sound Gillnetters Association, as a source for figures
             of Atlantic salmon appearing in the commercial catch.
       P. 73 113 ............ Local experts agree that significant genetic impacts
             on wild populations due to widespread net-pen farming in Puget
             Sound is unlikely." Who are these 'local experts?' Are they
             fish pen 'experts' as in Mahnken's case, or are they 'experts, on
             natural selection in wild fish populations?
                 To compare penned fish with fish hatchery-reared but released
             into the wild is to compare apples and oranges. Hatchery fish are
             of "wild" stocks and prove their fitness by returning to spawn.
             Increasingly, penned stocks of indigenous species will be interbred
             to promote rapid weight gain, docility and other characteristics
             desired by fish farmers. These characteristics would be maladaptive
             in the wild population, whether wild or hatchery-produced. (Note
             the research on interbreeding to produce more desirable pen fish
             being conducted at UW under the auspices of Washington Sea Grant
             studies.)
       P. 77, 78 re. VHS...See general comments above. What about new
             diseases? According to Mehli, how can you check for a disease
             which is has yet to be identified?
       P. 80 Mitigation measures ..... A requirement for reporting incidence
             of disease should be mandatory, and failure to do so incurring
             stiff penalties. However
                                    ,, how can you enforce this wher@ a) reporting
             a disease may be economically disadvantageous to the pen operators,
             b) nobody goes out to the pens except the fish farmers, c)by the
             time many diseases are detectable, the damage is done.
                 Who pays for the cost of the damage? Is the net pen industry
             going to pay for the 4 million salmon destroyed at the hatcheries
             infected with VHS? No way, Josel When even the Director of the
             WDF is pointing to mud on shoes as a possible source, and by
             the way, Atlantic salmon also get it, it only goes to prove that
             this state's administration is just going to nod sympathetically
             when fish pen operators shrug and swear, "It isn't us!"
                                  The taxpayer pays, that's who. And the
             commercial fishing industry, and the tribal fishermen, and
             the sports fishermen .....
       P. 74 (out of order) .... Ditto comments on escapement

       P. 75 Escapement mitigation measures... Encouraging commercial, sport
             and tribal fishermen to harvest escaped fish demands, a) the
             fish are of mature size and suitable fg.,@@qAt b) they can
             be caught in sufficient quantity tolg@zconomically viable,
     G       c) the fish are of a size to "fit" giAllnet mesh size for harvestable
             species, and D)that the escape occurs during a time of year when
             boats are geared up for fishing, and yet wouldInt have to forego
                                            (more .....







          McMather P. 6


                regular fishing opportunities and e) that the WDF is flexible
                enough to permit and/or direct such an operation, which is
                unlikely.
                     How would river mouths be closed to escaped fish found
                to be diseased? Note Svein Mehli's tap
                                                       ,timoney before the SSHB
                                                   11CAJ
                on how one batch of fish escapedOLnfected with furunculosis.
                They were intensively fished, and then 13 rivers were Sip_=d
                to the fish. Nevertheless, biologist found one diseased fish
                at least who made it up into spawning groundsl

          AESTHETICS
          P. 91 514 ............ Name six people who do not have a financial
                interest in a fish pen who find it entertaining, interesting
                and attractive to live next to a fish pen complex --and who
                wouldn't prefer that it wasn't the:re. To talk about a pen's
                entertainment value for nearby residents is ludicrous and
                insulting propaganda.
          P. 91, last several Is-The visual effect of a fish pen complex
                bears little relationship to the portion of the view it may
                occupy when it interjects a discordant note into the visual
                environment.
          Diagrams, figure 15..Line drawings do riot suffice to determine the
                impact. I drive past a fish pen complex every time I enter Port
                Townsend to my work. Only under overcast, stormy conditions,
                does it approach the relative inconspicuousness suggested by
                the line drawings. At most hours, the direction of the light
                reflects off the water at an angle., creating light play on the
                water. The fish pen complex stands out as a big, flat, gray,
                industrial structure that absorbs light rather than reflects
                it. It draws the eye in the manner of the proverbial "sore
                thumb."
                     Substitute these line drawings with color photos of
                real fish pens photographed at various distances under the
                following lighting conditions: bright overhead sunshine;
                oblique early morning light; cloudy, overcast conditions with
                diffused light; a highly colored sunset. This woutld give a
                far truer representation of what the viewer would see.
                A matte surface may reduce glare but it also exacerbates the
                tendency of the pens to appear as dark, gloomy globs on the
                water's surface.
          P. 104 ............... Net pen sites are usually staffed 24 hours
                a day." I question this statement., Even if a pen complex were
                regularly babysat 24 hours a day, which I doubt, all personnel
                would be removed for safety in stormy or windy conditions.

          COMMERCIAL FISHING
                     This section was written by someone who obviously has
                no first-hand knowledge of the subjectmor a source with first-hand
                knowlege. Why is this?
                                                         (more .....







        McMather remarks P. 7


        P. 105, lst I of section 3, 3rd sentence. (insert underlined text)
              "This displacement could reduce the catch potential for all
              fishermen fishing in a given area durin a given opening, reduce
              the overal catch..."
 8            [NOTE: We are not talking theoretical 'fishers' here. We are
              talking about real, honest-to-God, flesh-and-blood men and women
              who are out on boats, handling gear, dealing with the elements
              and trying to earn a living doing what they love to doll
        P. 107, last I  ....... Who is Clocksin? He does not appear in the
              references.
        P. 111 .............. This comment re. congestion at the bridge is less
              relevent to gillnetters than to seiners as more purse seiners
              can fish in a small area if they choose to do so. Gillnetters,
              by gear and technique differences must spread out over a large
              area.
                    I FIND NO REFERENCE TO THE VERY IMPORTANT FACT THAT NON-INDIAN
              GILLNETTING OCCURS, UNDER PRESENT MANAGEMENT, AT NIGHT1
        P. 112, !12 ...... ....shoud read: "...kept relatively vertical in the
              water by attaching a weighted line to the bottom of the net.
        P. 112 113..........."Gillnetters usually set their nets perpendicular..."
                fishermen may also set his net "up and down the creek," which
              is to say, parallel to the current, depending on the congestion
              of boats or the configuration of the shoreline or other factors.
                    "...by a power-operated drum and. The fish are removed or
              "picked from the net as the net is reeled aboard. The process
              of 'picking' typicallv takes twenty minutes to several hours
              de2ending on the Uke of fish caught and the amount and type
              of debris enEangled in' the net such as seaweed patches or logs.
              Mechanical breakdovAns, snagging the bottom or an obstacle or an
              adverse riptide can also aggravate the picking process. During.."
        Po 112 17oo_ ... ."Placing a fixed object in the midle of a drift forces
              forces gillnetters to avoid the immediate area or to attempt to
              pullpIck their neats near-the-penabefore approaching the pens and/or
              risk entanglement."
                    Note also this 1, current does not run through points of land,
              which generally aids the fisherman in avoiding land masses. Fish
              pens and other floating structures allow the current to go
              through and around them, which means they act as a seive, straining
              debris, nets, etc. from the water without redirecting the current.
        Po 112, 1 7  ....... ..The importance of WDF management boundaries are
              way overemphasized here.
                    Seiners are looking for the greatest concentrations of fish.
              Gillnetters need as much open water as possible before their nets
              (assuming fish are there). That may make the boundary a good spot
              but tight quarters. Gillnetters especially need to spread out and
              give their nets room to fish.
                    AGAIN, I CANNOT OVEREMPHASIZE THE IMPORTANCE OF THE FACT THAT
              ALL CITIZEN GILLNETTING OCCURS MAINLY DURING THE HOURS OF DARKNESS.
              IoE. POOR VISIBILITY
                    ALSO, DUE TO LIMITED NUMBER OF FISHING OPPORTUNITIES ("OPENINGS"
              IN FISHING LINGO), ALL CITIZENS FISHERMEN MUST FISH WHATEVER
              THE WEATER. WDF DOES NOT TAKE INTO ACCOUNT WEATHER CONDITIONS
              WHEN SCHEDULING OPENINGS. THEREFORE, ANY FISHERMAN WHO HOPES
              TO HAVE A PROFITABLE SEASON MUST BRAVE THE WEATHER AND FISH
              HIS BOAT TO ITS LIMITS, AND SOMETIMES BEYOND. A-DVER:51C WEATIAER
              Mz-ky RES'11bt1- Cl@we-Vcr-'@-ocAT)o4 A-141)       (mnrp ----









           McMather remarks    P. 8

           P. 113 11             "...during the fishing season. In some other
                areas, fishing is much less congested..." Obviously the
                writer has never observed fishing activity in Areas 9 or 10
                when the coho or chum are running. Concentrations of boats
                depend on a number of factors including: what other areas are
                open, concentrations of fish expected, concentrations of fish
    G           encountered, current and weather predictions, current and
                weather conditions as they develop.
                      Fishermen frequently change location, even travel from
                one area to another at some distance, during the opening depending
                on what success they are having arid what success fishermen elsewhere
                are having. (GMAOrem m@- rittkt, rememkv,!,-)
           P. 114, 12   .......  Crab are not necessarily attracted to fish pens.
                The area near Bluewater Farms (pens) in Port Townsend used to
                be a productive crabbing area. It no longer is.
           P.ï¿½ï¿½3 !j 4..........  Many errors in this paragraph.
                     Fishermen do not have the same opportunity to catch elsewhere.
                The fish are not always to be found in a given location... A seiner
                needs to take advantage of areas where fish have a tendency to
                school. Gillnetters like that too but need, more open water to
                drift. Both types of gear may be-       set 6T@F: the beach or may
                choose to fish midchannel --it all depends on the fish. Lots
                of variables here. All fishermen are to some extent dependent
                on luck in intercepting a profitable quantity of fish. Fish also
                travel at various depths, often below the depth of the nets,
                only to come up again elsewhere. There is no assurance that fish
                missed at one location can be intercepted in another. Besides,
                there are no 'relatively large' nuLnagement areas in Puget Sound
                given the large number of boats which can be expected to fish any
                given All Citizens opening.
           P. 113, last I . ........ an unnecessary loss to the fishing industry,
                TO THE COMMUNITIES WHICH DEPEND 014 THIS INDUSTRY AND TO THE STATE
       G        WHICH COLLECTS TAX ON THE ALL CITIZEN CATCH."
           P. 114 Mit. measure #1..."Such areas can be identified by consulting
                with'commerical fishing organizations, licensed fishermen and
                WDF,
                2nd: Locating net pens near existing obstructions, etc. is not
                necessarily a good idea in some cases, simply because it could
                reduce a marginal area to an impossible area.
                3rd: Not through the USCG notice to mariners alone.It should also
       0        go through organization newsletters and by prominent notice
                in the fishing trade publications such as Fishermen's News.
                4th:"locate pens neare shore..". Not good enough. If its deep
       &        enough for fish pens, ies like@to be deep enough for many
                net fishermen, especially those with nets tapered shallower
        36      at one end to let them get in closer to the beach.
       a    @   Sth: "Locate pens away f rom WDF salmon management boundaries.       gerw,
   Wk oc* --).td e60,",ct"?The only mitigative measure -that has any real merit is the
                one which says, site net pens away from areas of intensive fishing.
          P. 129 re water quality.."increased concern about water quality, etc."
                is ure progganda. Fish pens are marine feedlots. They produce
       0        polyution. his is an egregious wad unnecessary paragraph.
                                                                  (more...








       McMather P. 9

            What about lowering of property values? What about monitoring?
            All these discussioro of impacts rely., on standards being met
            and ideal husbandry practices being followed. But how to ensure
            that will happen?
                 Look at the e$ample of Jefferson County. No monitoring of
            any consequence, if any. No resources to do so.
       P. 131 !16 .......... Note: Parametrix was a paid consultant for a
            proposed net pen complex in Discovery Bay and the results of
            many of their tests are being contested before the state
            Shorelines Hear*ino Board. If these results are cited, conflicting
            data provided by opponents should also be incorporated.
                 Some of the data (and maybe all of it, for all I know) selected
            by Parametrix to support siting pens in Discovery Bay was conducted
            on tides which would produce readings favorable to the net pen
            project and purported to be typical" tides. The point that
            there is no such thing as a "typical" or "normal" tide was
            illustrated by oceanographer Pat Wennekens of the Sierra Club's
            Twanoh chapter at I:hqEIS Scoping hearing in October, 1988.
            Include Pat Wennekend as a source in this EIS. He too has
            conducted studies on Discovery Bay tidal action
       P. 132 ............ Note the comparison that 25 to 50 net pen capacities
            are similar to a large wastewater treatment plant. A large
            wastewater treatment plant is a horrendous polluter, one we are
            apparently stuck with due to human biological imperatives.
            Fish pens are not so necessary.
                 I have fished near Point Madison when the treatment plant   at West
            Point was discharging (i.e. on,the opposite side of that body
            of water). Our nets repeatedly came up coated top to bottom with
            brown, foul-smelling residue. It was so obnoxious that some
            boats in Port Townsend installed water pumping devices to wash
            the nets as they came aboard. 'A large plant such as this must
            have an incredibly adverse effect on Puget Sound. I think it is
            hardly a recommendation -"'t 100 fish pens, which this document
                                    TFL191
            seems to promote as a reasonable number, would equal two to four
            large treatment plants. I have seen what a single treatment plant
            can do and its appalling. To argue that the pens would be spread
           .apart only means that it might be less noticable --not that it
            wouldn't be there.
       APPENDICES .......... Finally, a note on that so-called study on the
            economics of salmon-farming by Robert L. Stokes. By virtue of being
            included in-a public document, does that render it in the nublir.
            domain for purposes of dramatic presentation? Please advise me.
            I have no idea what the chapter on property values is saying, if
            anything. But I don't think it matters since the author admits that
            he had insufficient time and resources to use such methods as those
            employed in empirical inquiries. As literature, it rates far below
            Lewis Carroll's Jabberwoc]7, but it has entertainment possibilities
            nevertheless. I am sure the owners of waterfront and water view
            properties will find it highly amusing reading or listening once
            they can get their blood pressures back down.

            A FINAL NOTE: WHERE DO THE AUTHORS GET THEIR AUTHORITY TO SUPPOSE
    8
       THAT 100 SALMON PENS IN PUGET SOUND IS A PLAUSIBLE OR ACCEPTABLE NUMBER?
       WH0 HAS DIRECTED THEM TO USE THAT AS SOME KIND OF GIVEN?

            HAS THE STATE DIRECTED THE AUTHORS TO DEVELOP A BIASED REPORT?










              RESPONSE TO LETTER NO. 52: SOUTH POINT COALT [ON


              1.     See the response to Question 29.

              2.     See the response to Question 2.

              3.     Svein Mehli is not an expert in salmonid diseases or genetics. See the response
                     to Question 25.

              4.     See the response to Questions 25, 26, 27, wad 29.

              5.     Svein Mehli is a natural resource administrator in Norway. There is some debate
                     concerning the validity of his testimony because his credentials are as an
                     administrator and not as a scientific expert in the field.

              6.     Comments noted.

              7.     Comment acknowledged. The text has been revised to clarify that gillnetters fish
                     at night.

              8.     Comments noted. See the response to Question 2.

              9.     Norway's experience with escaped farm fish is not as applicable to the situation
                     here as you indicate. See the response to I-A-Itter 38, Comment 25. Testimony by
                     Svein Mehli did not give the evidence of genetic impact that you implicate.

              10.    Svein Mehli is not an expert in salmonid populations genetics. Dr. Herschberger
                     is an expert on this subject as is Mr. Seidel.

                     While it is true that farm fish may be different in 20 to 50 years due to selective
                     breeding, they aren't different now. If farm. stocks become highly domesticated,
                     perhaps very few escapees will survive to maturity. 3 out of 27 pending permits
                     plan to use Pacific salmon. Genetic impacts are not an issue with Atlantic
                     salmon.

              11.    Methods of disease screening identify known, and previously unknown, pathogens
                     as well. Svein Mehli is not recognized as a fish disease expert.

              12.    Fish farm operators are required to report the occurrence of certain diseases.
                     Also, periodic visits are made to aquaculture- sites by WDF personnel.
              13.    This mitigation measure is not applicable to all situations. In all likelihood,
                     diseased escapees would be infected with pathogens already found naturally
                     occurring in our rivers.

              14.    The discussion of observer attitudes focused on visual quality and did not state
                     that some observers would find fish farms "entertaining" to watch. However,
                     some people do find over-water activity and structures visually interesting at








            Response to Utter No. 52: South Point Coalition (continued)

                   certain locations because these activities and structures add complexity to the
                   landscape.

            15.    Visual impact includes both whether the impact occurs and the magnitude of the
                   impact. A fish farm facility that can barely be seen will have a substantially
                   different visual impact than a facility that is immediately adjacent to the observer.
                   The discussion of how various locational parameters affect visual quality indicated
                   how the magnitude of visual impacts might change with observer location and
                   facility placement.

            16.    Comments noted. Color slides of various Puget Sound fish farms are available
                   from the Shorelands Division of Ecology.

            17.    Comment acknowledged. This statement has been deleted from the text for the
                   FEIS.


            18.    Comments noted.


            19.    Clocksin has been added to the references.


            20.    Comment noted.

            21.    Comment noted. See the response to Comment 7.

            22.    The text has been revised for the FEIS.


            23.    Comment noted.


            24.    The text has been revised to include the time element.


            25.    Comments noted.


            26.    Comments noted.


            27.    Comments noted.


            28.    Comments noted.


            29.    Comment noted.


            30.    Comments noted.

            31.    It is not within the scope of this EIS to evaluate potential positive and negative
                   economic effects of the fish farming industry.

            32.    Commercial fishing organizations include licensed fishermen.








               Response to Utter No. 52: South Point Coalition (continued)

               33.    The language in the EIS reflects that fish farms should be located near natural
                      obstructions which would normally force a gillnetter to avoid that area, or require
                      drift nets to be pulled before encountering the obstruction.

               34.    As stated in the DEIS, the Notice to Mariners was used as an example of a
                      means of notifying the commercial fishing industry. The Preferred Alternative
                      includes a recommendation for additional notification to the commercial fishing
                      industry.

               35.    There are areas in Puget Sound where commercial fishing activity takes place
                      close to shore with tapered nets. The text has been revised to clarify this point
                      in the FEIS.


               36.    Comment noted.

               37.    Comments noted.     See the responses to Questions 9 and 12.

               38.    Comments noted.

               39.    Comments noted.     See the response to Question 3.

               40.    Comment noted.

               41.    See the responses to Questions 3.



                                                                                        LETTER NO. 53




                                                    March 6, 1989


                    Governor Booth Gardner
                    Washington State Capitol Building
     Writing & Design Olympia, WA 98504
   -tor Public Relations
     seattle.WAM04                      re: emclosed
       (206) 622-2797
                    Dear Booth:

                           I realize you and your administration have been strong advocates of
                    expanding floating net pen aquaculture in our state, but as a Democrat I
                    hope you will support our Partys traditionally strong stand on
                    environmental protection now by calling a moratorium on any new
                    aquaculture projects until a politically neutral scientific inquiry can be
                    conducted.
                           In addition, I would like to suggest that you and the various relevant
                    state agencies contact Svein Mehli of Norway's Nature Management
                    Ministry as a valuable resource and possible consultant. I@ft. Mehli testified
                    on behalf of Skagit County last November on the environmental hazards
                    of salmon net pen aquaculture and has not only been involved in
                    Norways aquaculture issues, but also is a member of an international
                    North Atlantic agency addressing these questions. He also might be able to
                    suggest other scientists who would provide information and assistance in
                    determining how to prevent the spread of disease to our valuable salmon
                    resource. His address is:
                                  Svein Aage Mehli
                                  Head of Division
                                  Directorate for Nature Management
                                  Tungasletta 2
                                  N-7000
                                  Trondheim, Norway.

                           This is an extremely technical and complicated matter, but I
                    understand there is scientific evidence suggesting the initial Dept. of
                    Tisheries' statement that VHS has never appeared in Atlantic Salmon was
                    in error. For this reason, and because so many potential diseases threaten
                    salmon, I believe the only responsible thing to do now is to convene a
                    thorough scientific inquiry into this industry.

                                  Warm regards,



                                  Barbara Stenson
                                  Partner

                    copies: Karen Marchioro, Chair, Washington State Democrats, L Joe
                    Miller, President, Marine Environmental Consortium








                                           STA






                                           IP"

                                 STATE OF WASHINGTON
                                     OFF" OF TW GMRW)A

                                        OLYMPIA
                                         98504-W 13


          BOOTH GARDNER
              CUMMOR



          March 14, 1989




          Ms. Barbara Stenson
          Powers, Stensont Espinoza
          616 First Avenue
          Suite 200
          Seattle, Washington - 98104

          Dear Ms. Stenson:

          Thank you for your recent letter to Gcvernor Gardner regarding
          aquaculture. The Governor has asked that I respond to your concerns.

          I have attached a copy of the Governor-Is aquaculture policy which
          does not, as you say, strongly advocate expanding net pen aqua-
          culture. Rather, this state's policy is to recognize that properly
          sited, environmentally sound aquaculture facilities can play a role
          in enhancing the production of aquaculture products.

          The Governor is committed to environmental protection, and his policy
          reflects that commitment. The Department of Fisheries has expended a
          substantial amount of time preparing the draft programmatic environ-
          mental impact statement. Also, because of the importance to the
          state of our native salmon runs, the Department of Fisheries and
          Department of Wildlife are devoting extra time to disease issues.

          Again, thank you for writing, and know that I have forwarded your
          letter to Eric Hurlburt at the Department of Fisheries for reference.



                         w
          Kaleen Cottingh,@@
          Executive Policy Analyst

          Enclosure

          cc: Eric  Hurlburt













                                                                            rA
       RESPONSE TO LETTER NO. 53: BARBARA STENSON                           A-a
                                                                            0
                                                                            E
                                                                            E
        1.  Comments noted.                                                 0
                                                                            U
        2.  See the response to Question 29 and Appendix G.                 0
                                                                            ,*a
                                                                            w
                                                                            0

                                                                            0

                                                                            CA
                                                                            w
                                                                            9













































                                                                              I





                                                                                   LETTER NO. 54



                                                                     Marsh 10, 1989

                   Ron Wastley
                   Dept. of Fisheries
                   115 General Adainistration Building
                   Olympia, Wa. 98504


                   Dear Sir:

                   As a water front owner I am extremely concerned *about placement
                   of the salmon pens in Pugot Bound, A large group of then has been
                   zoned to be placed between Bells Beach and Fox Spit on Whidbey
                   I sland.

                   I read in the papers about the now study done by or for the Dept.
                   of Fisheries that says in one place that fish pens are good and
                   don't pollute but then seems the turn around and say that if they
                   are in the wrong place or poorly run they can cause environmental
                   problems. *Fish faces and uneaten food can accumulate on the bottom
                   and deplete oxygen making the sediment and water toxic,, Etc.*
                   It goes on to say these pens can cause odors and algae bloom.

                   Placement beside waterfront residential property has got to be
                   considered the wrong place by any criteria.used. The faces and axes*@
                   feed plus the antibiotics used will was onto the shores in front
                   of the homes. Last Fourth of July weekend I counted ever 100 mall
                   children playing in the sand and shallow water just within my
                   limited view. Hwy more would have been farther up the beach and
                   at Fox Spit. This happens most weekends during the summer. These
                   children should not be exposed to pollution from salmon pens

                   If you believe the fees@, ate* would be washed out rather than onto
                   the beashes all you would have to do in the saner i a got onto a
                   rubber raft and try to got *?At onto the water. If you don't raw you
                   are continually pushed onto the @here. The driftwood pieces follow
                   the same pattern. The south and of our beach is a prime collection
                   spot as is a the shore between Bella Beach and Fox Spit. So the tide a
                   would bring the pollution in, not out.
                   We also pick mussels on that beach. Just north of the last houses
                   is a great area, 'Lao mussels Crow large and sweet. They would be
                   inedible with the pens nearby.

                   I understand the Fisheries Dept. believes the fish on owners and
                   operators will not throw dead or diseased fish into the water. Oh
                   yes, just like the other industries did not dispose of their wastes














                    illegally. That I a why we are having to clean up so many site a now.
                    What make a you think the as people are more honest and sentientious
                    than other business people? Laws are needed to control the
                    operators, and most importantly salmon pan* need to be kept away
                    from residential property.

                    I firmly believe the somnties should have sentrol ever this place-
                    ment as they know their areas better than some one in Olympia
                    who probably has never seen most of the, sites.

                    Thank you for reading this letter.




                                                          Your a truly
                                                          Jacqueline Maner
									    2725 91st. S.E.
									    Everett, Wa. 98208








          RESPONSE TO LETTER NO, 54. JACQUELINE MANER


          1.   Comments noted. The EIS did not evaluate any     individual sites. See the
               response to Question 1.

          2.   Comments noted. See   the response to Question 9.

          3.   Comment noted. Counties and State agencies work together through various
               regulatory mechanisms such as the shoreline permitting program to ensure that
               fish farms are properly sited.





                                                                                 LETTER NO. 55



                                     FRIDAY HARBOR LABORATORIES
                                      UNIVERSITY OF WASHINGTON
                                         620 UNIVERSITY ROAD
                                       FRIDAY HARBOR, WA 98250
                                            3 March 1989


                Dr. Ron Westley
                Project Manager
                Washington Dept. of Fisheries
                115 General Administration Building
                Olympia, WA 98504

                Dear Dr. Vestley:

                This letter is a comment on the draft progammatic EIS, Fish Culture
                in Floating Not Penn,

                My first comment is that the effort that you and others at the State
                Dept. of Fisheries have put into it in greatly appreciated. The
                material will be a very useful reference.

                The programmatic EIS will be read and used by non-scientists. In
                reading sections on benthos I noticed several places where
                additional information or rephrasing would help non-specialists
                understand the probable and possible effects of not pens.

                Suggestions on mitigating impacts took good to me, but it is often
                unclear which procedures have been proven to work and which are
                expected to work on the basis of available evidence. It would take
                only a few additional statements to make the distinction obvious to
                the non-scientist.

                p. ix: Someone reading the ma  'for conclusions would not realize that
                immediately beneath and near the pens the sea life on the bottom is
                usually severely affected. Recovery times are a few years for many
                animals and probably much longer for others. I would expect
                recovery of geoducks to take quite a long time. It would be more
                informative to say, 'Locally the effects of sea pens on the seabed
                are usually severe, but these effects extend only a short distance
                from the pens and nearly complete recovery in expected within 5 to
                is yearn after removal of the pens." The question of recovery times
                also appears on p. 24. In addition to benthic surveys following pen
                removal, estimates could be based on rates of recruitment and growth
                of sedentary large animals such as clams.

                In the text, the order of presentation of effects on the benthos
                moves progressively towards the pens. Readers need some advanced
                statement of the range of effects. It would help to have a brief
       0        topic statement on the usual effect beneath the pens (anaerobic
                sediment with almost no macroscopic animal life) and the distances
                at which effects are usually indetectable.

                pp. 21, 22 and elsewhere: Species that are indicators of pollution
                should be described as such where they are mentioned. Capitella
       0        capitata in one example. "Indicative of organic enrichment" doesn't
                carry enough information to the non-specialist.










                    On mitigating impacts: I found it difficult to evaluate evidence
                    and criteria on mitgation of impacts and a few added statements
                    would help greatly. The qualifying statements on the model will be
                    useful for non-specialists. Can a similar brief evaluation of the
                    data be included?
                    I was left unsure about the expected time-course of changes under
                    peas over deeper water in faster currents. The Squaxin Bay study
                    (Technical appendix A) seems to suggest gradual changes over about
                    1.7 years but I could not tell if changes resulting from the pens
                    had stopped. Have studies continued long enough to determine
                    whether effects would continue to incre,ase in that situation? Are
                    there any long established peas here or in Europe or Japan that are
                    In deeper water with faster currents and have shown the effects over
                    a longer period? (Also, if there are no data for pens over deeper
                    water and faster currents beyond two years, this should be
                    mentioned.)
                    p@. 26: It would help if the merits of small effects over a larger
                    area were explicitly compared to severe effects in a smaller area.
                    p. 68: It is suggested "Where adverse impacts are unavoidable,
                    require mitigation through enhancement of the affected species at
                    the site or in the immediate area." I strongly agree with the
                    recommendation as far as it is practical. It would be very helpful
                    to give some practical examples and references for successful cases
                    for benthic animals.

                    It is outside my field, but is the viral disease now reported for
                    some salmon in Washington possibly from imported species? If there
                    is much reason to suspect this, i't should be mentioned in the
                    revised EIS.

                    Thanks for the opportunity to review the draft. I'm used to having
                    two or three reviewers for manuscripts. It must be interesting to
                    have hundreds.


                    Sincerely,




                    Richard Strathmann
                    Resident Assoc. Director, Friday Harbor Laboratories













                                                                                                               W
           RESPONSE TO LETTER NO. 55: UNIVERSITY OF WASHINGTON FRIDAY
           HARBOR LABORATORIES



           1.     Comment noted.

           2.     'Me text has been revised to   address your concerns.

           3.     Comment noted.
                                                                                                               rA
                                                                                                               W
           4.     Comments noted. The effect of fish farms on bottom-dwelling organisms cannot                99
                  be characterized as usually severe. Some of the Puget Sound farms sited in the
                  1970s, such as at Lopez Island, did have a severe impact on the benthos beneath
                  the pens because of inadequate depth and currents. However, with sufficient
                  depth and current velocity some of the more recently sited farms are showing
                  little impact on the benthos.

           5.     Comments noted. Distances at which effects are undetectable varies with site
                  specific conditions such as water depth and current velocity.          Studies that
                  measured the distances where a number of parameters were undetectable were
                  discussed in the EIS.

           6.     Comment noted. Capitella capitata is widely distributed throughout Puget Sound
                  in both enriched and non-enriched environments. It is not in-and-of-itself an
                  indicator of pollution, but rather it achieves high abundance in areas that have
                  significant environmental organic loading. "Indicative of organic enrichment" is a
                  more precise term than the general term "pollution" and is used here to
                  specifically indicate the type of perturbation occurring in the benthic environment.
                  See also the response to Letter 38, Comment 22.

           7.     Comment noted.

           8.     Iffiere are no known studies of long term impact of deposition under salmon
                  farms under similar conditions to those found in Puget Sound. European and
                  Canadian farms typically have much higher fish densities and less rigorous siting
                  review processes and consequently are not reliable sources of information on the
                  long-term impacts of sedimentation.

           9.     Concentration of the fish farm sedimentation in a smaller area could result in
                  substantial deleterious effects which were documented in the DEIS. Spreading the
                  same sedimentation and organic enrichment load over a larger area would dilute
                  the effects of the sedimentation and retain a more normal benthic community.

                  As the diversity of organisms would likely remain higher in the area where the
                  sediment deposition is more diffuse, the food-energy pathways would be more
                  diverse, and the increased nutrient effect of the sedimentation would be utilized
                  more rapidly. Thus, although the effects of the farm would be spread over a
                  larger area, the relative per unit area perturbation of the benthic community
                  would be less and of shorter duration.











              10.   Comment noted.

              11.   Viral infections of salmon such as IHNV, II?NV, VEN, and E'[Bs are indigenous
                    to Washington. VHS, which was found last year in a limited area in Washington
                    State, was not known to previously occur here. We have no evidence to suggest
                    that this pathogen was introduced in imports. See Appendix G for further
                    information.





                                                                   LE77ER NO. 56

        SUITE 4+00 - 1001 FOURTH AVENUE PLAZA SEATTLE, WASHINGTON 9815+ - (206) 624-3600
                     Riddelt) Williams  Bullitt & Walkinshaw

                                     LAW OFFICES


           January 29, 1988                               RODNEY L. BROWN, JR.




           Mr. Duane Phinney, Chief
           Habitat Management Division
           Department of Fisheries
           Mailstop AX-11
           Olympia, Washington 98504

                     Re: Aquaculture Programmatic Environmental
                          Impact Statement

           Dear Mr. Phinney:

                Our office earlier submitted comments on behalf of Save
           Our Shores, a citizens group concerned about the environmental
           and use impacts of salmon net pens in Puget Sound. We are
           now writing to express our concerns about some information
           that we recently received regarding the PEIS.

                We have recently been told that the Department of
           Fisheries will exclude from the PEIS the impacts of aquaculture
           on existing commercial and sport fisheries. If this informa-
           tion is correct, we want to register our strongest objections.
           Aquaculture in the' form of salmon net pens could have serious
           impacts on commercial and sport fisheries, both environmental
           and economic. For example, escaped fish can transmit disease
           and genetic deficiencies to the free-swimming fish population.
           Other environmental impacts, such as destruction of herring
           habitat or fish nursery sites, can also harm the fisheries
           resource. Finally, the physical obstruction of salmon net
           pens can remove certain waters from fishing.

                Since salmon net pens could cause these impacts and
           since the impacts would be severe, the PEIS should study
           these impacts on commercial and sport fisheries and should
           analyze alternatives to mitigate or prevent the impacts. We
           would appreciate hearing how the Department intends to
           address these impacts. If you have any questions, please do
           not hesitate to give us a call at any time.

                                          Sincerely,



                                          Rodney L. Brown, J
           RLB:aag                              .- ')       d
           cc: Mr. Joe Miller



                    TELEX RCA 296338 RWBW UR - TELECOPIER (206) 467-1914










            RESPONSE TO LETTER NO. 56: RODNEY L. BROWN, JR.


             1.    Comments noted. The FEIS discusses the potential impacts to commercial fishing
                   in Section 6.3, and recreational fishing in Section 6.5.





                                                                    LE17ER NO. 57



                                     AQUATOX

                                      p.O. BOX 53

                               INDIANOLA, WASHINGTON 98342






           March 14, 1989



           Ron Westley, Project Manager
           Washington Department of Fisheries
           115 General Administration Bldg,
           Olympia, Washington 98504



           Dear- Mr. Westley:



           Enclosed you will find a line item comment review of the Draft Pro-
           grammatic Environmental Impact Statement for Fish Culture in Float-
           ing Net Pens.



           Thank you for your attention.



           Sincerely,





           Annamarie K. Johnstone, Ph.D.
           Marine Microbiology, Toxicology




           cc: RM
               im
















                     DRAFT PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT


                                FISH CULTURE IN FLOATING NET PENS



                                       LINE ITEM COMMENTS


           Prepared by:


           Annamarie K. Johnstone, Ph.D.
           AQUATOX
           P.O. Box 53
           Indiano.la, Wa. 9834@

           Page Line

           P.16, L.28,29        Weston (1986) reported that food conversion ratios
                                for salmon raised in Puget Sound are typically 2:1,
                                the production of 1 kg of salmon requires 2 kg of
                                feed. The University of Stirling (1988) related a
                                typical feed conversion ratio (FCR) of 2:1 for
                                Scottish net-pen farms, as well.

           P.17, L.16,1-7       Weston (1986) estimated that 1600 lbs of solid
                                waste (excess feed and feces) would be produced for
                                every 2200 lbs of fish grown. The DPEIS used the
                                word sediment rather than the term solid waste to
                                describe his statement. I would argue that sediment
                                is not produced, rather that solid waste is produced.

           P.17, L.21,22        The DPEIS stated that an FCR of 1.5 may better re-
                                present current culture activities. Weston (1986)
                                related an FCR of 2:1 for Puget Sound.
                                Sediment is used again as opposed to solid waste.

           P.21, L.38           Reich (1972) suggested that the presence of large
                                numbers of Capitella capitata is indicative of pol-
                                luted and semi-polluced conditions.

           P.23, L.1-3          Methane production below salmon net-pens can stim-
                                ulate the growth of methaneogenic bacteria. These
                                bacteria are able to convert mercury to toxic methyl
       0                        mercury, which can be bioaccumulated in shellfish
                                and fish (Sieberth, 1979).

           L.23, L.3-6          Leiffrig (1985) described H2S production beneath
                                salmon net-pens to be IOX 6reater than reference
                                levels. A concentration of .002 ppm H2S is the
                                upper limit of continuous exposure for optimum
                                fish health. Jacobsen and Berglind (1988) reported
                                that the use of antibiotics in fish feed will cause
                                an increase in sulphide ion activity of 10 to lOOX
                                reference levels.











                                             2.


         Page  Line

         P.23 L.10-12         Beggiatoa bacteria result from overfeeding in
                              aquaculture and indicate an H2S habitat (Sie-
                              berth, 1979).

         P.23 L.37-39         Beggiatoa is found primarily in habitats rich
                              in H2S, such as waters polluted with sewage,
                              as this bacterial species utilizes H2S as an
                              energy source (Brock, 1970).

         P.60 L.29-35         The DPEIS indicated (p.16,line 40) that food
                              pellets do not decompose appreciably as they
                              settle to the bottom. Therefore, considering
                              5%-20% feed wastage (p.17, lines 14,17) and
                              20 to 30 days antibiotic treatment per year
                              (Weston, 1986), a significant amount of anti-
                              biotic could accumulate on the substrate be-
                              low the net-pens. In addition, 90% of the an-
                              tibiotic in ingested feed is excreted by the
                              fish (p.58, lines33-36) due to calcium affin-
                              ity. As feces account for 1/3 of all ingested
                              feed (Weston, 1986) and if 90% of the anti-
                              biotic in feed is excreted, approximately 33%
                              to 44% of antibiotic fed is eliminated from
                              the net-pens.

         P.60,L.39-40         Jacobsen and Berglind (1988) recorded the half
                              life of the antibiotic (OTC) in sediments be-
                              low net-pens to be about 10 weeks and in one
                              case as much as 12 weeks.


         p.60,L.40            Antibiotic accumulations were found to be rela-
                              tively persistent in anoxic sediments.

         P.60,L.42            In the field study, OTC was found in sediments
                              from four of the four farms surveyed. In eight
                              samples from the four farms only one was nega-
                              tive.


         P . 60 , L. 42
         P.61,L.1             Antibiotic levels in the sediments were 0.13
                              to 4.9 ppm.

         P.61,L.1-3           Jacobsen and Berg-lind (1988) reported that OTC
                              concentrations in the pilot study were high and
                              strong effects on microorganisms might be ex-
                              pected. The levels of OTC in fish farms indi-
                              cated that antimicrobial effects and strain se-
    G                         lection in the sediments could be expected for
                              more than 12 weeks after administration of OTC
                              to fish. They added that long term exposure of
                              microbes to low concentrations of antibiotics
                              was known to enhance development of resistant
                              microbial strains.








                                             3.


         Page   Line


         P.61, Line 4         Jacobsen and Berglind (1988) related that de-
                              gradation and leakage from the surface layer
                              was probably enhanced in their study because
                              of stirring and aeration due to sampling. They
                              indicated that the observed half-life of OTC
                              in sediments (10 weeks) may tie a conservative
                              estimate of the true half-life under similar
                              field conditions.
         P.61, Line 7,8       In the pilot study, the author's noted that OTC
                              enhances the development of anaerobic condi-
                              tions and is relatively stable in anoxic en-
                              vironments.


         P.61, Line 10,11     The Wekell (1989) citation is an unwritten study
                              at this time, so that a publication is not
                              available for perusal and critique. Information
                              concerning location of suspended oysters in re-
                              lation to net-pens (':)etween pens or below bot-
                              tom surface of pens), number and duration of
                              antibiotic treatments to fish, concentration of
                              antibiotic fed to fish, location of control shell-
                              fish in relation to the net-pens, specific species
                              and quantities of bacteria isolated from both
                              net-pen and control shellfish and duration and
                              dates during which the experiment was conducted
                              is not provided by tl,-ie DPEIS.

         P-61, Line 16-25     See Jacobsen and Berglind (1988) notes above.
                              and on page 2 of this comment, review.

         P.68, Line32-34
         P.69, Line 1,2       Atlantic salmon (Salino salar) are susceptible to
                              salmonid diseases of proven viral etiology name-
                              ly IPN, IHN and VHS (MacKelvie and Artsob, 1969,
                              Mulcahy and Wood, 11-936, Wolf,1988 and DeKinkelin
                              and Castric,1982) as well as diseases in which
                              a viral etiology is suspected such as VEN and
                              UDN (MacMillan, 1980,Lounatmaa and Janatuinen,
                              1978) . Bacterial diseases of proven susceptibil-
                              ity in S. salar include Bacterial Kidney Disease,
                              Cytopha-ga sp. infections, a new Aeromonas infec-
                              tion and Vibriosis (Paterson et al, 1981,Kent et
                              al, 1988a, Cox et al, 1986, Sawyer et al, 1979).
                              Salt water reared Atlantic salmon are subject
                              to pancreas disease of unknown but probably in-
                              fectious etiology. Documented protozoan para-
                                              U
                              site diseases of S. salar include Ichthyobodo.
                              Costia (Ellis and@-Wo'oten. 1978) and Kudoa thyr-
                              sitis (Harrell and Scott, 1985).



         P.69,Line 3-7        The disease effect of introduced non-native
                              stocks is subtle, according t.o Mills, 1982.
                              The causative agents of disease are already
                              present in the environment but do not normally










                                              4.


         Page  Line


         P - 6 9Line 3-7
               (cont.)         cause disease, as the native species usually
                               have developed the appropriate immunity. When
                               non-native species (such as the Atlantic salmon),
                               with no immunity, are introduced into the envir-
                               onment, they can be susceptible to the new dis-
                               ease agent. This allows the pathogen to become
                               more prevalent in the environment, which in
                               turn permits more virulent strains of the patho-
                               gen to be selected. The virulent strains can
                               then infect the native species of fish.

         P.73 Line 38-40       The risks involved with disease transmission by
                               an introduced exotic species may be predicted.
                               Introduced species can cause disease if they are
                               carriers of an exotic disease or if the intro-
                               duced species is without immunity to a disease
  0                            in the new habitat. Certification of eggs may
                               eliminate carriers, but the procedure will not
                               address immune deficiencies. A survey of known dis-
                               eases of the former and future habitats of the
                               proposed introduction (such as Salmo salar) will
                               indicate if introduction is a valid option.

          p.74 Line 9-13       Catastropic structural failure of net-pens is not
                               rare. A"1000-year" storm event,which caused the
                               break-up of net-pens, occurred during the week of
                               February 5th 1989 in British Columbia. Severe
                               winds were responsible for damage or loss of pens
                               at seven separate locations. Fifty percent of
                               the pens at one location were washed away and thou-
                               sands of fish escaped, all were Pacific salmon
                               species (Harrower.. 1989, Personal Communication)-
                               As net-pen farms are established in deeper water,
                               to facilitate better flushing:wind effects to
                               net-pen structures will become more of a problem.
                               Unfortunately strong winds occur frequently.

          P.76 Line 24-29      See comments to pp. 68, 69 of DPEIS on pp. 3,4
                               of this comment review.


          P.77 Line 10-15      Confirmatory tests have now established that re-
                               turnin,,, coho and chinook salmon at two hatcher-
                               ies in Washington state carried the VHS virus
                               (Viral Hemorrhagic Septicemia). Th,is disclosure
                               in February 1989 indicates that a European vi-
                               ral salmonid pathogen is now present in the
                               indigenous salmon species of the Pacific N.W.

                               Wolf (1988), in his noteworthy description of
                               VHS, related that a native, European salmonid
                               such as the Atlantic salmon (Salmo salar), Brown
                               trout (Salmo trutta) or the Danube trout (Hucho
                               hucho) were possibly the historical source of
                               VIIS disease in Europe, eons ago. Rainbow trout












                                                 5


            Page   Line

            P 7 7  Lines 10-15       Salmo gairdneri       indigenous to N. America,
                   Cont.          were introduced in Europe in 1879 where they were
                                  subjected to virulent epizootics of VHS disease,
                                  due to their lack of immunity to the viral patho-
                                  g e n .
                                  At this time, scientific evidence indicates that
                                  VHS virus is shed with the eggs, vertical trans-
                                  mission is rare, does not occur or has yet to be
                                  documented. Natural. infections are caused by hori-
                                  zontal transmission of waterbourne viruses, which
                                  are shed during ep-.Lzootics or by asymptomatic
                                  carriers (fish recovered from the disease) when
                                  water temperatures are low (Wolf, 1988).

            P-77 Lines 25,26      As VHS virus is now present in the indigenous
                                  Pacific N.W. salmonids, it is evident that fed-
                                  er-al and state regulations have not been success-
                                  ful in preventing the introduction of an exotic
                                  fish disease.


            P-77 Lines 41,42
            P.78 Line 1           A risk exists, as well, for transmission of dis-
                                  ease from pen-reared fish. Egidius et al (1983)
                                  reported that yearling Saithe (Pollachius virens),
                                  which had been attracted by salmonid feed, were
                                  trapped in net-pens at a commercial salmon farm
                                  in Norway. The fish died within a few days in
                                  June from Vibriosi'--;. Mortality amongst trapped
                                  Saithe ranged from 75'/,,' to 100%, possibly because
                                  Saithe in the salmon farm were novices to Vibrio
                                  epidemics and had riot experienced previous infec-
                                  tion.


            P 7 8  Lines25-28     Meyers (1984) also reported that salmonid strains
                                  of IPN (Infectious Pancreatic Necrosis) virus
                                  have been isolated from several species of marine
                                  bivalves. The isolates were biochemically, bio-
                                  physically and serologically indistinguishable
                                  from reference strains of IPN in fish and proved
                                  pathogenic for   rainbow trout   fry. The IPN virus
                                  was stable for   fiftty or more  days in the resev-
                                  oir shellfish.


            P 7 8  Lines 28-31    The example from ME@yers (1984),listed above, in-
                                  dicates concentration of 11"N virus in shellfish
                                                         ibility of disease transmis-
                                  uad the implied possl
                                  sion to wild fish and other shellfish. IPN' viruses
                                  (Birnaviruses) haVE! been associated with mortali-
                                  ties of Molluscs (Tellina sp.) in England and At-
                                  lantic menhaden (B7revoortia tvrannus) on the East
                                  coast of the USA (I'oranzo and Hetrick, 19821).












                                               6.


           Page Line

           P-78 Lines 41-43      DiSalvo et al (1978) reported that Vibrio-
                                 anguillarum was isolated as a pathogen of
                                 oyster spat from commercial culture in Cal-
                                 ifornia. The authors indicated that V. anguil-
                                 larum is routinely found in hatchery waters
                                 which are pumped from the ocean.

           P-79 Lines 5-7        Lovelace et al (1968) noted severe oyster
                                 mortalities in Chesapeake Bay where higher
                                 levels of Vibrio were present than at a commer-
                                 cially productive oyster ground.

           P-79 Linesl3-18       Isolation of VHS virus from returning Coho and
                                 Chinook salmon in Washington state last month
                                 indicates that the 90 day quarantine procedures
                                 in effect in this state are not adequate to pre-
                                 vent the spread of an exotic virus from Europe.
                                 British Columbia requires a minimum 12 month
                                 quarantine for imported eggs during which the
                                 young fish must be inspected at least 4X by a
                                 pathologist. The last inspection must occur af-
                                 ter smolting. In addition no importation of eggs
                                 is permitted from Europe or countries where VHS
                                 has been reported or is likely to be present
                                 (Weston, 1986).
                                 In comparison, Washington state policy allows
                                 Atlantic salmon eggs to be imported from Euro-
                                 pean countries which reportedly have had VHS
                                 epizootics. Viral inspection of imported eggs
                                 by DOF may occur.

           P-79 Lines 36,37      Currently there are 13 net-pen farms in Washing-
                                 ton state, a total of 100 are planned for in the
                                 future (DPEIS, 1989). Implementation of regula-
                                 tions designed to prevent the introduction of
                                 exotic fish pathogens has already failed with
                                 only 13 farms in operation.

           P - 79 Lines 4-1,42   An extremely serious disease introduction has
                                 occurred and possibly more will occur before
                                 broodstocks are sufficient to maintain 13 farms.

           P-80 Lines 1-3        The transmission of disease from net-pen fish to
                                 wild fish has never been adequately studied due
                                 to the inherent difficulties in research proced-
                                 ures and lack of fiscal support. The latter is
                                 probably the significant reason, as studies
                                 might indicate an impact on the environment
                                 from commercial culture.

           P-80 Lines 3,4        See comments to p. 79, lines 13-18 of DPEIS
                                 on p. 6 of this comment review.











                                                7


             Page  Line


             P.80 Lines 9,10      The diseases of net-pen cultured salmonids
                                  most likely occur with greater frequency and
                                  virulence due to captivity and crowding, but
                                  the diseases are infectious and are caused by
                                  pathogens. Susceptible wild stocks of fish
     0                            could be infected with these pathogens from
                                  cultured fish (See comments to p.77 lines 41,
                                  42, p.78,line I of DPEIS on p. 5 of comment
                                  review).


             P.80 Lines 14,15     Risk of disease tcansmission from captive net-
                                  pen reared fish will continue to increase as
                                  the number of salmon farms increase in number.


             P.80 Lines 16-18     Salmon net-pen wastes can enrich the bottom
                                  sediments so that opportunistic bacteria,such
                                  as the Vibrios,can be resuscitated and grow
                                  replacin-g--t-H-eresident species of bacteria.
                                  Vibrio anGuillar_U;z which is pathogenic to fish
                                  and possibly molluscs could be part of this
                                  floral bloom. Opportunistic bacteria can attach
                                  to fatty particles common in fish feed and
                                  ascend from deep 'water to surface waters due to
                                  bouyancy of the particles, At the surface, the
                                  bacteria can be rapidly dispersed toward shore
                                  by wind and wave action (Grimes et al, 1986).
                                  Shellfish can act as disease resevoirs (Meyers,
                                  1984) and accumulate the particles containing
                                  bacteria. Concentrated bacterial populations
                                  could be released by the shellfish during de-
                                  puration.

             P-80 Lines 19-21     Vibrio anguillarum has beE!n found in oyster
                                                    7-
                                  spat mortalities in California (DiSalvo et
                                  al, 1978), not just in Europe and the E. coast.

             p.80, Lines 25-30    Importation of salmon eggs from other continents
                                  is not advised as the current system of certi-
                                  fying salmon eggs has not been effective in
                                  preventing the introduction of exotic diseases
                                  such as VHS.


             P.116 Lines 25-28
                   Lines 32,33    By the process of elimination after reading
                                  this paragraph, I deducted that Clostridium
                                  perfringens. Vibrio parahaemolyticus and-Ti-brio
                                  alginolyticus wera possibly isolated in shell-
                                  fish samples in tiiis unwritten study (Wekell,
                                  1989, Personal Communication). The bacterial
                                  species described are known to be human patho-
                                  cens. Cln@,tridi_= porfringons is an excellent
                                  tracer for incursion of pollution into the sea,













                                               8.

          V age  Line


          P.116  Lines 25-28
                 Lines 32,33
                 Cont.            where the species can possibly incorporate
                                  into fish and shellfish (Sieberth, 1979).
                                  Clostridium perfringens causes mild food
                                  poisoning with the ingestion of contamin-
                                  ated fish (Zinsser,1980). The clinical affects
                                  of V. parahaemolyticus and V. alginolyticus
                                  were described on p.115, lines 23-26 of the
                                  DPEIS.


          P.116 Lines 34,35
          P-117 Lines 24,25
          P.118 Lines 8-10        1 would concur with Wekell (1989, Personal
                                  Communication) that further research to de-
                                  termine the bacterial characteristics of
                                  fish feed would be desirable. Although Sal-
                                  monella cubana, which was found in fish feed
                                  by Wekell and associates,is not a human patto-
                                  gen, its presence is an indicator of impro-
                                  per feed preparation or storage. Temperatures
                                  below 40OF halt Salmonella proliferation in
                                  foods, while temperatures above 140OF kill
                                  the organisms (Zinsser, 1980). A publication
                                  from one proposed salmon farm related that
                                  fish mortalities collected daily at the net-
                                  pen site would be resold to feed manufacturers
                                  for incorporation into their product (Swecker
                                  Salmon Farm,1988).



          Appendix
          Fish Disease
          P.2     Line 40         In vitro studies by Toranzo and Hetrick (1982)
                                  indicated that rHNV and rP.NV survived longer
                                  than Poliovirus in estuarine and sea water at
                                  150C. and 200C. The survival of IHNVwas fav-
                                  ored in fresh water as compared to IPNV.










                                          9.



                Summary:



                   The DPEIS appears to be biased in favor of net-pen finfish
                culture. To enhance this bias, data was arbitrarily selected
                from cited scientific literature. As an example, unproven, but
                possible viral accumulations in shellfish were described from
                Meyers (1984), while proven viral accumulations in shellfish
                were not reported from the author's paper (See p. 78, lines 25-
                28, 28-31 of line item comments).


                   In addition incorrect data was presented in the Statement
                as compared to data contained in scientific papers. For example,
                antibiotic accumulations in sediments and the number of sites
                involved were incorrectly reported from Jacobsen and Berglind
                (1988)(See p.60, line 42, p.6l,lines 1-3 of line item comments).

                   An unwritten study by Wekell (1989) was reported in the DPEIS
                which described an assay for human pathogens in shellfish near
                fin-fish net-pens. A reader is left with -the process of elimina-
                tion rather than information to ascertain the impact from accum-
                ulations of harmful bacteria, possibly three species of human
                pathogens were isolated (see p. 116, lines 25-28,32-33 of line
                item comments).


                   Rewriting the DPEIS will not correct the significant impact
                problems of net-pen culture, such as the occurrence of an ex-
                otic European disease in spite of-current quarantine procedures
                (See p. 79, lines 13-18,36,37,41,42 of line item comments). Dis-
                ease studies involving wild fish, exotic fish and cultured fish
                are needed (See p. 80, linesl-3,p. 68, lines 32-34, p.69, lines
                1,2), epidemiological surveys for the introduction of exotic
                species should be initiated (See p. 73, lines 38-40,p. 69, lines
                3-7) and radical changes in quarantine procedures for exotic
                egg imports are essential (p.80, lines 25-30). In my opinion, a
                moratorium in aquaculture development and egg imports from
                Europe is advised, until these problems can be properly addressed.











                                      10.



                                BIBLIOGRAPHY


           Brock, T.D. 1970. The biology of microorganisms. Prentice-Hall,
              New Jersey.

           Cox, D.I., C.M.Morrison, B. Zwicker and G. Shum. 1986. Report
              on a new Aeromonas species infecting skin lesions of Atlantic
              salmon (Salmo salar in sea water. Bulletin of the European
              Assoc. of Fish Pathologists. 6(4):100-102.

           DeKinkelin, P. and J. Castric. 1982. An experimental study of
              the susceptibility of Atlantic salmon fry (Salmo salar L.)
              to viral haemorrhagic septicemia. Jour. of Fish Diseases.
              5 : 5 7 - 6 5 -


           DiSalvo, L.H., J. Blecka and R. Zebal. 1978. Vibrio anguillarum
              and larval mortality in a California coastal shellfish hatch-
              ery. App. & Envir. Micro. Vol.35(i):219-221.

           Egidius, E., B. Braaten, K. Anderson, and S.L. Gokstad. 1983.
              Vibriosis in saithe (Pollachius virens) populations of the
              Norwegian coast. Reun. Cons. Int. Explor. Mer. 182:103-105.

           Ellis, A.E. and R. Wooten. 1978. Costiasis of Atlantic salmon,
              Salmo salar L. smolts in sea water. Jour. of Fish Diseases.
              1:389-393.


           Grimes, D.J., R.W. Atwell, P.R. Braaten, L.M. Palmer, D.M. Rol-
              lins, D.B. Roszak, F.L. Singleton, M.L. Tamplin and R.R. Col-
              well. 1986. The fate of enteric pathogenic bacteria in es-
              tuarine and marine environments. Microbiological Sciences.
              Vol.3(il):324-329.

           Harrell, L.W. and T.M. Scott. 1985. Kudoa thyrsitis (Gilchrist)
              Myxosporea:Multivalvulida in Atlantic salmon, Salmo salar L.
              Jour of Fis Diseases. 8:329-332.


           Harrower, W., 1989, Personal Communication. Ministry of Agri-
              culture and Fisheries, Victoria, B.C.


           Jacobsen, p. and L. Berglind. 1988. Persistence of Oxytetracy-
              cline in sediments from fish farms. Aquaculture. 70:365-370.

           Kent, M.L.,C.F. Dugan, R.A.Elston and R. Holt. 1988a. Cytophag@L
              sp. (Cytophagales) infection in seawater pen-reared Atlantic
              salmon Salmo salar. Diseases of aquatic organisms (In Press).

           Leiffrig, D.V.M. 1.985. The effects of hydrogen sulphide (H2S)
              on aquaculture production. M.Sc. Thesis. University of Stir-
              linG, Scotland.

           Lounatmaa, K. and J. Janatuinen. 1978. Electron microscopy of
              ulcerative dermal necrosis (UDN)-like disease in Finland.
              Jour. of Fish Disease. 1:369-375.













              MacKelvie, R.M. and H. Artsob. 1969. Infectious pancreatic necro-
                 sis virus in young salmonids of the Canadian maritime prov-
                 inces. Jour. Fisheries Res. Bd. of [email protected] (12):3259-
                 3262.


              MacMillan, J.R. 1980. Pathological manifestations of viral ery-
                 throcyctic necrosis in fish. Ph.D. Dissertation. University
                 of Washington, Seattle.


              Meyers, T.R. 1984. Marine bivalve mollusks as reservoirs of vi-
                 ral finfish pathogens: Significance to marine and anadromous
                 finfish aquaculture. Marine Fisheries Review. 46(3):14-17.

              Mills, S. 1982. Britain's native trout is floundering. New Sci-
                 entist. November 25, 1982,498-501.

              Mulcahy, D. and J. Wood. 1986. A natural epizootic of infectious
                 haematopoietic necrosis in imported Atlantic salmon, Salmo
                 salar L. , reared in the enzootic region. Jour. Fish Di7s-eases.
                 9:173-175.


              Paterson, W.D.,D. Desautels and J.M. Weber. 1981. The immune re-
                 sponse of Atlantic salmon, Salmo salar L., to the causative
                 agent of bacterial kidney &-isease,-7-enibacterium salmoninarum.
                 Jour. Fish Diseases. 4:99-111


              Reich, D.J. 1972. The use of marine invertebrates as indicators
                 of varying degrees of marine pollution. In Marine pollution
                 and sea life. Ed. M. Ruivo. FAO Fishing News Ltd., London.
                 404-411.


              Sawyer, E.S., R.G. Strout and B.A. Coutermarsh. 1979 Comparative
                 susceptibility of Atlantic (Salmo salar) and Coho (     Onchorhyn-
                 cus kisutch) salmon to three strains of Vibrio anguillarum
                 from the Maine-New Hampshire coast. Jour. Fish. Res. Bd. of
                 Canada. Vol.36(3)280-282.


              Sieberth, J.M. 1979. Sea Microbes. Oxford University Press, N.Y.

              Swecker Salmon Farm. 1988. Response to requests for additional
                 environmental information regarding the proposed salmon net-
                 pen aquaculture project in lower Case inlet. Rochester,Wa-

              Toranzo, A.E. and F.M. Hetrick. 1982. Compara'tive stability of
                 two salmonid viruses and poliovirus in fresh, estuarine and
                 marine waters. Jour. of Fish Diseases. 5:223-231.












                                     12.




           The Institute of Aquaculture, University of Stirling. 1988.
              The reduction of the impact of fish farming on the nat-
              ural marine environment. University of Stirling, Scotland.

           Wekell, M. 1989. Personal Communication. U.S. Food and Drug
              Administration, Seafood Products Research Group. Bothell,
              Wa.


           Weston, D.P. 1986. The environmental effects of floating
              mariculture in Puget Sound. Prepared by the University of
              Washington School of Oceanography for the Washington De-
              partment of Fisheries and Ecology. 148 pp.

           Wolf, K. 1988. Fish viruses and fish viral diseases. Cornell
              University Press, N.Y. Chap.17:217-249.

           Zinsser, H. 1980. Zinsser Microbiology.(Eds.) W.K. Joklik,
              H.P. Willett and D.B. Amos. Appleton-Century Crofts, N.Y.









           RESPONSE TO LETrER NO. 57: ANNAMARIE K. JOHNSTONE


            1.     A 2:1 food conversion ratio is considered conservative. Recent studies at the
                   Norwegian Institute of Aquaculture Research (AsgArd et al. 1988) have shown
                   FCRs as low as 0.94: 1. As stated in the text of the DEIS, FCRs, range from 1: 1
                   to 2: 1.


            2.     Comment noted.


            3.     Comment noted.


            4.     Comment noted.


            5.     Comment noted.

            6.     See the responses to Letter 38, Comment 22; and Letter 55, Comment 6.

            7.     Comment noted.


            8.     Comment noted.

            9.     Comment noted. This subject was discussed in the DEIS.

            10.    Comment noted. This subject was discussed in the DEIS.

            11.    Comment noted. This subject was discussed in the DEIS.

            12.    The text has been revised for the FEIS.


            13.    The text has been revised for the FEIS.

            14.    Comment noted. This subject was discussed in the text of the DEIS.

            15.    Comment noted. This subject was discussed in the text of the DEIS.

            16.    Comment noted. This subject was discussed in the text of the DEIS.

            17.    The information was obtained from FDA and is all that is available at the time
                   of publication.

            18.    The text has been revised for the FEIS.

            19.    The reviewer indicates that Atlantics are susceptible to infection by fish pathogens
                   that affect all other salmonids. The comment is a statement of fact.

            20.    It is true that in some situations, native stocks have more resistance to a "local"
                   pathogen that a non-native stock of fish. For example, steelhead trout native to
                   the Columbia River have more resistance to Cecatomyxa shasta than Oregon








               Response to Letter No. 57: Annamarie K. Johnstone (continued)

                      coastal stocks.   Observations of Atlantic salmon, which are native to North
                      America, appear to have more resistance to native pathogens than our native
                      stocks. Of particular note is the tolerance of BKD by Atlantics -while chinook and
                      coho are quite susceptible to bacterial kidney disease. It should be noted that
                      any disease occurrence comprises a complex situation involving the pathogen, the
                      environment, and the host. Though it may be possible for a susceptible (exotic)
                      host to amplify the number of pathogens more than indigenous stocks, this has not
                      been observed in net pen culture in Puget Sound. Furthermore, amplification of
                      a pathogen does not necessarily result in an increase in virulence.

               21.    Comment acknowledged. Prior to the introduction of an exotic species, it is
                      prudent to determine if indigenous pathogens could cause catastrophic loss in the
                      imported species. As stated previously, and in Comment 20, the disease process
                      is complex and composed of many elements. Your generalization concerning
                      pathogen amplification may or may not be Wid. Furthermore, Atlantic salmon
                      in particular are no longer considered to be exotic to Washington State or North
                      America. Their demonstrated ability to survive after exposure to indigenous
                      pathogen provides contrary evidence to youi comment.

               22.    Comment noted.

               23.    See response to Comment 19.

               24.    See Letter 1, Comments 18, 19, and 20. Also, see the response to Question 29.

                      Also, our native steelhead and rainbow experience loss to IHNV (a native
                      pathogen at a level which is equal to or eXceeds losses in rainbow to VHS in
                      Europe). The reviewer assumes that the isolation of VHS was the result of
                      transfer from Europe and inadequate regulations. There is no evidence to support
                      that hypothesis.

               25.    See response to Comment 24.

               26.    The study you site (Egidius et al. 1983) also pointed out the Saithe experience
                      mortality in natural environs due to vibriosis with no connection to fish farms.
                      However, it is not a surprise that a fish which likely was not immunized, as are
                      cultured fish, and was trapped in the pen ervirons subsequently became infected
                      and died. This in no way can be construed to demonstrate that pathogens in net
                      pens cause disease in wild stocks.

               27.    The draft contains an accurate summary of the study mentioned.

               28.    See the response to Comment 27.

               29.    As noted in the DEIS, Vibdo anguillarum is not a species of bacteria that has
                      been associated with oyster larval mortalities in the Pacific Northwest.








           Response to Letter No. 57: Annamarie K Johnstone (continued)

           30.    Ile association of oyster mortalities with areas high in vibrios does not
                  demonstrate cause and effect.

           31.    See Appendix G. There is no demonstration of connection between Atlantics
                  and isolation of VHS in chinook and coho. Furthermore, this phenomenon is not
                  related to a 90-day quarantine period. Washington State policy does not allow
                  any live eggs from any species to be imported from geographic areas where VHS
                  is known to occur.

           32.    See Appendix G.

           33.    See the response to Question 29.

           34.    See the response  to Question 26 and Letter 1, Comment 16.

           35.    See the response  to Question 26  and Letter 1, Comment 16.

           36.    See the response  to Question 26  and Letter 1, Comment 16.

           37.    See the response  to Question 26  and Letter 1, Comment 16.

           38.    The point of the comment is not clear. The subjects mentioned in the comment
                  are addressed in the DEIS and the FEIS.

           39.    Comment acknowledged. The phrase "the east coast of' has been eliminated from
                  the text of the FEIS.

           40.    See response to Comment 31.

           41.    The point of the cited study is to compare shellfish from fish farm and non-fish
                  farm sites. As noted, no differences were found.

           42.    Recommendations regarding food storage and further research were included in
                  the DEIS, and are included in the Preferred Alternative in Section 6.4 of the
                  FEIS.

           43.    Comment noted.      Even though IHSV and IPNV may survive longer than
                  poliovirus in seawater, that period is still very brief.

           44.    The important point is the meaning of results indicating the presence of fish
                  viruses in shellfish. The DEIS makes a reasonable interpretation of the technical
                  findings.

           45.    Comment acknowledged. The text has been revised for the FEIS.

           46.    See the response to Comment 41. At stated in Appendix G, the isolation of
                  VHS in Washington was not as a result of inadequate regulations.








              Response to Utter No. 57: Annamarie IL Johnstone (continued)


              47.    Disease studies continue throughout the world on a variety of species and
                     pathogen, and these studies need to continue. However, there is no evidence to
                     suggest that a moratorium on aquaculture development, or -the prohibition of
                     .importing eggs from Europe under the existing regulations and Policies, will result
                     in a decrease in risk to the wild or cultured resource. For informational purposes,
                     no legal Atlantic salmon eggs were imported in 1988 and 1989 and only a limited
                     number were imported in 1985, 1986, and 1987.





    These comments include pages 1 throuLft 3 and an addendum, page 4 which
    addresses fish pen net cleaning.
                                                                LETTER NO. 58

                                                Hattie L. Berglund
                                                1834 West 7th 3t.
                                                Port Angeles, WA. 98362
                                                April 41 1389
     Department of Fisheries                    page 1 of   pages
     Ron Westley
     115 General Administration Building
     Olympia, WAw. 98504

     Re: draft Programmatic Environmental Impact Statement
         Fish Culture in Floating Net Pens

     Following are comments-on the above draft environmental impact statement.

     I am making these comments because I live in Port Angeles, Washington
     and Sea Farms of Norway has the equivalent of 90 fish pens now sited
     in Port Angeles. Harbor.

     To my knowledge, the Sea Farms installations are totally free of any
     monitoring, regulation or enforcement by any State, County or City agency.
     How can the public be assured that there is no pollution of water,
     sedimentation pollution, damageto vegetation, natural sea life or shore-
     lines?

     Further, these 90 fish pens are not subject to real estate tax, sales tax,
     or B/O tax. Sea Farms is subject to a token fee of approx. @'250 per acre,
                                                                  4
     which amount's to approx. $2000. a year for their eight acre site.

     90 fish pens have the capacity to raise 900,000 lbs. of fish per year at
     a selling price of @3-50 to $5.00 per pound.

     What other business, major or small, in Washington State has this kind
     of tax advantage??

     Following is a brief history of Sea Farms of Norway, (name has, I believe
     now been changed to Sea Farms of Washington).

     The original permit for Sea Farms was to raise only Atlantic Salmon.

     In February, 1984 Sea Farms requested and received an amendment to their
     permit to also raise rainbow trout in their pens. The reason stated by
     Jon Lindbergh, Sea Farms' agent was that "The number of Atlantic salmon
     smolts available in 1984 will be less than anticipated and Sea Farms would
     like to use the pen space for another cash crop." The number of trout to
     be raised was never stated. (Daily News, Port Angeles, WA. Feb. 27, 1984)
     Sea.Farms is an international company and operates fish farms in Europe
     and North America as well as hatcheries which provide smolts (young
     salmon) to other salmon farms. Do they import these smolts from Europe
     and what kind of monitoring does the State do to regulate same?

     In December, 1984, Sea Farms began operation of a 50 pen fish farm in
     Port Angeles Harbor.

     August 15, 1985, their Dermit was amended to permit the raising of
     Coho and Chinook Salmon.
                                      -1-




                                                       Hattie L. Berglund
                                                        April 4, _. 198'
                                                       page 2 of 0 pages
       Dept. A:'isheries, Ron 4estley
       He: draft fish Guiture in -.2loating Net Pens

       In 1986, Sea Farms applied for a second fish farm site to house 50
       pens, (later reduced to 40 pens) to occupy a total of eight acres for both
       sites. I believe they hurried to site these additional pens in order
       to make sure they were not governed by the issuance of' State guidelines
       then in process for the siting of fish pens.

       In 1987 Sea Farms got a rpvision in thei.-r permitsto change plastic pens
       to galvanized ste&l and to increase the size of the pens but reduce
       the number of pens at the second site from 40 to 32.and still occupy the
       same harbor space and produce the same quantity of fish. (The two sites
       contain the equivalent of the original 91D total fish pens).
       What type andto what exte4 does pollution in various forms exist
       at the siteof t1lese Port Angeles fish farms? There is no way of knowing
       because there is no agency regulation of these fish pens, the water
       quality, sedimentatioh.-pollution below the pens, pollution of natural
       vegetation and sea life.
       The Puget Sound Water QWity Authority has stated: "Oadiment contaminatio
       has beenassociated with diseases in fish and damage to the other animals
       that live in and on the bottom. The fact that silnificant sediment contami-
       tion exists in Puget Sound, when water q_uality is considered good, implies
       that existing water quality programs have no@ protedted the s-ediments from
       degradation. Regulatory programs have focuse    almost entirely on water
       rather than sediment quality."

       Sea;Farms stated a 50 pen capacity gives them   capacity to harvest about
       500,000 poundsof fish per year. They have the   capacity for 90 pens which
       gives them the capacity for 900,000 pounds of   fish per year. Multiply
       product production by potential poilution areas and there is reason for
       ma,jor concern.
       Some of these potential pollution problems and other concerns of the
       public are mentioned hereafter.

       There is no guarantee Lhat the appearance- of the 'new fish virus called
       VHS has no relation to fish farming in Washington waters.

       Nutrients, fish feces, antibiotics do enter the water in the fish pens,
       around the fish pens and in the sediment under the fish pens.

       An article in the Seattle Times, March 115, 1989 speaks to problems with
       fish farms:

       "British Columbia fish farmers have been plagued with outbreaks of disease
       and plankton blooms that have decimated their crops ... estimated mortaility
       has averaged 30 percent." "estimated a third of the district's landfill
       space now going to dead farm salmon."' 1120qP00 (two hundred thousand)
       salmon smolts in a typical farm would consume a ton of fish food per day
       plus about 200 pounds of antibiotics over a ten day period."

                                         -2-






                                                      April 4, 1989
                                                      page 3 of 3 pages

     Dept.Fisheries, Ron I.."estley
     Re: Draft Fish Culture in Floating Net Pens

                                                    C_,ho
     The article also states that ,?acific salmon, e+ra and chinook species could
     interbreed with wild fish stocks. The 6ea2arms,fish pen sites in Port
     Angeles harbor have permitsto raise rainbow trout, Atlantic salmon and Coh
     and Chinook Salmon. How is this being regulated or monitored?

     It takes oneto three pounds of fish meal to produce one pound-of fish.
     What is the potential for pollution with this kind of demand for fish
 7)  meal, much of which has antibiotics added to it, in 90 fish pens in
     close proximity with the ability and capacity to produce 900,000 lbs. of
     fish per year? In Port Angeles harbor?

     The article also states "the "'isheries Department environmental impact
     study states if 100 fish farms were built in Puget @ound, they would
     produce 55 tons of oxygen consuming fish feces and uneaten food per day--
     more than that disc'I-Larged into the bound by the viest Eoint and Renton
     sewage treatment plants combined. '-@he 13 farms already here contribute
     7.3 tons."   A graph from the 'Wasrilington._@tate Department of Fisheries
     is reproduced in thearticle and shows said oxygen depleting waste wnich is
     produced by fish farms and comparedto other sources such as sewage treat-
     ment plants.

     The article elso states that the concentrations of nutrients andfoxygen
     depleting waste are very diluted compare4 to sewage and that there is
     dia.greement whether the pollution produced is serious enough to resttic#
     aquaculture.

     Port Angeles, Washington is under mandate to build a secondary treatment
     sewage plant. The mandate is from federal and state agencies.

     What impact will the potential for pollution from Sea Farms penshave
     on water quality in Port Angeles harbor?

     It is not enough to assume and speculate that all is well with the fish
     farming industry in ',@4ashington State. Each fish farm site must be monitored
     on a regular basis, as a separetLe entity, to truly determine the level
     and potential for pollution at -that site relating to water quality,
     natural sea life, sedimentation and surrounding waters and shorelines.
  3
     Siting of new fish farms should be stopped unt'-l factual information relat-
     ing to pollution of ail kinds, at each specifieV
  0                                                     pf each existing fish
     farm is documented.                              4Le-1
     Realistic lease fees must be levied on current and any new fish farm sites
     to pay for needed enforcement and monitoring by 6tate agencies qualified
     to do so.
     This is the only way the public can have a reasonable de-ree of confidence
     that there is a legal means to preserve our natural resources, Washington
     State's quality of lifeand the health and welfareof the general public-.

                                                     6
                                                     .ublikt &1_9_b@@#attt 1@[email protected] rg Ilan
                                                     1834 i4lest 7 h 6treet
                                                     Port Angeles, W". 98362







     Dept. Fisheries, Ron westley                                                                     Hattie L. Berglund
                                                                                                         April 4 1989
                                                                                                           Addendum page 4
                              Port Angeles Daily News
					Friday, June 110, 1988


                                                                                                   PA
                             Nets sea aroma wrinkles, PA noses

                               PORT ANGELES - Call it a sea smell             order to keep s.-als and other predators
                             that ripened.                                    away from the enclosures, said Ray
                               That's the aroma that was noticeable           Wilson. Sea Farm maintenance manager.
                             in parts of downtown Port Angeles on               The company periodically cleans the
                             Wednesday and Thursday when a                    nets of sea life bY trucking them to a farm
                             2,300-pound net covered with dead                near Joyce and spreading the nets in all
                             mussels, sea grass and kelp soaked up the        open field. Muscls and grasses dry and
                             sun on a port dock near North Oak                fall off of the nets in a couple ofmonths,
                             Street.                                          Boldt said. The nets are then reused.
                               Sea Farm Washington, an aquaculture              Boldt said Sea Farm- crews were
                             company that operates fish pens in Port          delayed in moving the net because they
                             Angeles Harbor, had removed the net              were busy with shipments of fish.
                             from one of its 43 fish pens in order to           But the nets' periodic days in the sun
                             clean it of mussels, kelp and grasses, said      may be coming to an end, Boldt said.
                             Dan Bold, Sea Farm manager.                     The company is looking into buying a
                               Sea Farm hangs the 255-square-meter            washer that would strip the nets f sea
                             nets underneath its floating fish pens in        life.


    The above newspaper headline, "Net's                                    sea aroMa wrinkles PA noses" poses-some
    important questions relating to the cleaning of fish farm pen nets.
    As stated, one net, from under one pen in Sea Farm Port Angeles fish farm
    operation weighs 2300 lbs. and was covered with dead mussels, sea grass and help
    Multiply this by the equivalent of 90 fish pens and the potential for water
    quality degradation and sediment contaminatiOn beneath the pens from the multi--
    tude of dead sea life and sea vegetation which can be caught and trapped in eacl
    net is tremendous. How much falls into the WEther and settles to the bottom wher
    ach net is removed for cleaning?

    The news article states that removing the netsand drying them in the sun off-sit
    will be discontinued-and cleaning will be accomplished. in awasher the company
    intends to buy and use which will strip the nets of sea life.

    This is a June 10, 1988 news release (almost a. year ago). Where is this
    washer sited? 
         How        are the nets removed for cleaning, or are they not removed?
    that is the water source for the washer? Does, the processinvolve addition
    of chemicals to aid in removing the dead sea life and vegetation and in the                                                                            
    disintergration of same? How is the water purified before disposal and where
    andin what quantities is it dumped?

    again, my comments include the history of Sea Farm fish pens in Port Angeles
                                    
    harbor because there is no real, factual data compiled. and documented by
    qualified State, County or City regulatory agencies which relate specifically
    to this site and this fish farm operation.                                                                                                             
    in, each site for fish pens needsto be regulated, monitored and enforcement
    policies adopted by law in order to adequately protect our environment and
    natural resources and the health and welfareof the general public.
                                                                                                Hattie L. Berglnual
                                                                                              Submitted by Hattie L. Berglund
                                                                                              1,834 West 7th Street
                                                                                              Port Angeles, ;VA. 98362














                                                                                                               r4o
            RESPONSE TO LETTER NO. 58: HATTIE L BERGLUND


            1.     The text has been revised for the FEIS to evaluate         existing regulations and
                   guidelines that affect the fish farming industry. See the  response to Question 9.          U

            2.     A discussion of taxation is outside the scope of this EIS.
                                                                                                               rA
                                                                                                               C
            3.     Comments noted. This EIS does not evaluate individual       sites. See the response         0
                   to Questions 1 and 9.                                                                       rA

            4.     See the response to Question 29.

            5.     Comments noted.

            6.     The FEIS contains an evaluation of existing regulations and guidelines. See the
                   response to Question 9.

            7.     A food conversion ratio of 1.5 pounds of feed to 1 pound of weight gain is more
                   typical of fish farms. Evaluation of specific sites is beyond the scope of this EIS.

            8.     Evaluation of specific sites is beyond the scope of this EIS.

            9.     WDF monitors every individual farm site. See response to Comment 8.

            10.    Comment noted.

            11.    The first paragraph on page 16 of the DEIS states that Weston (1986) found the
                   amount of material from net cleaning that enters the water and settles to the
                   bottom to be a relatively small portion of the overall sedimentation from a fish
                   farm.

            12.    Evaluation of the operation of the Port Angeles farm is beyond the scope of this
                   EIS.


            13.    Comments noted.





                                                                                  LETTER NO. 59
                                                     Mrs, Paul F. Betzdd
                                                PoA Office Box 152, Ffeekwid, Wa. 98249










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                                                          At    Paul f. Betzold
                                                    Poat Office Box 152, freekM, Wa. 98249







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               RESPONSE TO LETTER No. 59: DORIS P. BETZOLD


               1.    Comment noted. The regulations affecting the fish farming industry are discussed
                     in the FEIS. Shoreline property owners can make their concerns known to their
                     local government through the SEPA and shoreline permitting processes. In
                     addition, there are established processes for appealing, any decision made by a
     0               local government.

               2.    Comment noted. Drogue studies to determine current rates to calculate flushing
                     rates are incorporated into the Interim Guhiefines. Drogue studies have been a
                     component of most recent fish farm applications.

               3.    Comment noted. See the response to Question 2.





                                                                                                                          LETTER NO. 60

                                                     Alexander H. Bill, M.D.


            RT. I Box me
            LOPEZ, WA. 98M                                                                                       TELEPHONE
                                                                                                                08) 4*015


















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                                   Response to Comments





                                                                   LETTER NO. 61










                                   4503 old Gardiner Road
                                   Port Townsendq Washington 98368
                                  April 3, 1989





                Washin-ton State Department of Fisheries
                       0
                Olympia, Washington

                Dear Ron:

                      I would like to express my concern regarding

                fish culture in floating pens. I have recently

                become acquainted with a fisherman from 'ITorway.

                After hearing of the Norwegian problems with fish

                pens, I am totally opposed to their use in Wash-

                ington State.

                                           Yours truly.,



                                           Charles D. Broders,








    @O     RESPONSE TO LETTER NO, 61: CHARLES Do BROD
    m
    M
    10
    0
    W      1.   Comment noted.
    m

    0


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    5
    5
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                                                                                  LETrER NO. 62











                 P.O. Box 307
                 Belfair, WA 98528
                 March 21, 1989








                 Ron Westley, Proj. Manager
                 Wash. Dept. of Fisheries
                 115 General Administration Bldg.
                 Olympia, WA 98504

                 RE: Draft EIS
                      Fish Culture in Floating Net Pens


                 Dear Sirs:


                 After plowing through the DPEIS and the Technical Appendices some
                 thoughts  become quite clear. They are as follows:

                      1.   The State Dept. of Fisheries apparently is taking the
                           position of "Lead Agency" when in fact you should be
                           protecting/managing our resources, not doing the work
                           for the public sector.

                      2.   The addition of pollutants to our waters cannot be
                           deemed "acceptable" under any circumstances. This
                           report glosses over the water pollution factor, this
                           cannot be mitigated.

                      3.   Introducing non-native species and their diseases
                           (VRV.) is taking a risk with native stocks which are
                           already in jeopardy. This is fool hardy at best and
                           should not be endorsed by the very agency whose res-
                           ponsibility it is to manage our native salmon, etc.

                      4.   This report is a contradiction ofyour departments
                           mission.


                 The fact  the Dept. of Fisheries is embarking on this project when
                 its efforts should be concentrated on our already troubled resources
                 is very sad. I would like to ask "who is guarding the Hen House?"







                                                 -2-


                   Perhaps all involved should read "Mountain in the Clouds" by Bruce
                   Brown and then return to reality.

                   Finally the monies wasted on this should be recouped and put to
                   better use.


                   Resper-tfully yours,




                   D ald R.'Ca y
                   P.O. Box 307
                   Belfair, WA 98528


                   CC: PSWQA
                       Mason Co. Commissioners
                       Pt. No. Pt. Treaty
                    on









        RESPONSE TO LETTER NO, 62: DONALD IL                                   rA
                                                                              .0"


        1.   SEPA states that the "lead agency" is the agency with the main responsibility for
             complying with SEPA!s procedural requirements (WAC 197-11-758). WDF is not U
             taldng the role of a proponent.

        2.   Comment noted.                                                    W
                                                                               0
        3.   Comment noted. See the response to Question 29 and Appendix G.

        4.   Comment noted.



                                                         LETTER NO. 63    1@@`7`5
                                                                                W
             Re: Comments on HIS               2919 Mayfair Ave, North
                 Fish Culture in Floating      Seattle WA 98109
                 Net Pens                      April 4,1989


             Mr Ron Westley, Project Manager
             WA Dept. of Fisheries, Olympia, WA

             Dear Mr. Westley,

               Thanks to the Dept. for extension of time for reply to this
             DEIS. Events in past week of Alaskan oil spill and its future
             consequences makes the production of fish in Puget Sound waters
             even more important as a source of protein food for the state,
             nation and export markets.

               In this issue the so-called 'environmental' effects are of less
             import than the social and economic effects, yet the latter are
             only minimally considered in any EIS.
               Puget Sound waters are pastures of the sea and just as land
             pastures, they are and can be farmed for both vegetable and
             animal production. If similar constrictions and demands were
             placed on Kansas wheat or Iowa corn farmers as are on salmon net
             pen operators the nation would have a hunt-and-gather agricultural
             economy.

               The single important environmental problem is how the pen-reared
             fish will affect stocks and survival of native wild salmon. Unfor-
             tunately not the   Dept. of Fisheries - nor any other agency with
             responsibility for these animals - as the Corps of Engineers,
             Dept. of Ecology, irrigation districts, Bureau of Reclamation,
             etc, etc, - has done anything over the past years but make
             trivial gestures towards protection of the wild runs. On the
             contrary, these agencies have routinely promoted projects which
             destroy habitat, i.e. marinas in sensitive habitats as estuaries,
             U.S.Navy Homeport in Everett, clear-cutting in regions of spawning
             streams, refusal to renovate dams or their energy production means,
             failure to restrict river depletion by agriculture practises, etc.

                Is pen rearing now to be made the scape-goat for any future
             declines in wild populations?    On the other hand, is net pen
             farming the wave of the future to substitute for any intensive
        Q    effort to restore native stocks ?    Is restoration to the historic
             levels now an abandoned effort ?


        Q      Why has no EIS ever been issued which would bring together all
             facets of projects necessary to restoration of wild salmon runs ?
             Each facet, i.e. water quality, forest practises, marina develop-
    (D       ment,is dealt with individually with no effort to synchronize
             what is needed for volume production which could equal or better
             productivity from net pen rearing of Atlantic species .

             This DEIS should be corrected to display a comparison between
             potential productivity - that possible with significant actions
             by government agencies - of wild versus reared salmon.



             ** excepting DOI-FWS and NMFS






                            Page 2
                                              AESTHETICS               PAGE 89 +

                                  The EIS should be revised to present information relative to
                            property 'ownership' of the waters affected. My understanding is
                            that: the waters are not capable of 'ownership'. The State acts
                            as a trustee for the people of the state. The Corps of Engineers
                       5    is, in effect, the trustee for the nation as these are navigable
                            waters, protected by the navigation servitude. The Public Trust
                            Doctrine is now acknowledged to be affirmed in Washington, and it
                            thus shelters the use of waters to navigation, fisheries, and
                            recreational use requiring waters - as a more recent component.

                                    Where local regulations are put into effect, as components of
                            shoreline master programs or zoning prohibitions, limiting or
                       6    prohibiting mariculture or aquaculture, these are violations of
                            doctrinal policy. The DEIS should present legal priorities attached
                            to the usages of water stream and surface.

                                    The concerns of shorelines residents opposed to net pens were
                            an instigation for the EIS. The EIS should be revised to describe
                            how limited are the uses of Puget Sound waters due to such continual
                            objections. Such owners use the same pseudo-enviromental arguments
                       7    to exclude people from public-owned beaches and tidelands. With
                            the aid of their politicians they fight any state or local agency
                            trying to develop beach access facilities, claiming that a nearby
                            park will damage their private property values.



                                                                                                                
                                                                                                                                            C ON
                                                                                                                                planners reject beach improvements
                   COUPEVILLE - The Island County Planning Commission approved
                  consruction  of a new bulkhead at a little-known public beach on
                  Camano Island Tuesday, but balked at providing a boat ramp and                  
                  beach access because of concerns that residents wouldnt make the
                  public welcome.
                   The small public beach, called Tillicum Beach is snuggled between
                  two community beaches at Tillicum and Sierra Vista, making it hard
                  for the general public to find, said Camano planning board member
                  Maxine Geisel.
                   "I oject to the county spending money for a community beach that                  will only be used bY Its members,
                  will only be used by its members," she added. "If the county pays for 
                  it, the public should be able to find it and use it."
                   The county road department came before the planning board to ob-
                  tain permits to build a riprap bulkhead, a boat ramp and beach access,                :Total 'cost for both proJects wiis* - estimated 'at. $5,500, said Planning
                  total cost for both projects was estimated at $5,500, said Planning
                  Director Syd Glover.
                   But finding some of the smaller public beach accesses on Camano
                  and Whidbey Islands can be a problem, board members agreed.
                   Planners have tackled the dilemma in the past only to be thwarted by
                  neighbors who did not want strangers in their territory; said planner
                  Bruce Smith. Limited parking. Litter and a lack of security have 
                  prompted area residents to tear down county signs demoting the pub-
                  lic's right of access, he said. 
                   "The county wasted money putting signs up at a similar place at
                  Lagoon Point," said commissioner Marie Bevers."The longest lasted                                          
                  about two weeks."    
                   The board's final decision was to let the county pick up the tap for
                  the bulkbead.              
                
                                                                                                          Part 32V40U / Sund 32Nevember 29 l900





              Page 3


                But its not merely people whose use of beaches and waters
              in public ownership is denied. They also battle commercial
              farming of mussels and oysters, clam harvesting, and now salmon
              pens. They claim exclusive use of property for which they lack
              legal rights, the waters, and so decimate public rights, state
              and local revenues, and jobs that could be developed for recreation,
              tourism, and aquaculture industries. By limiting the use of waters
              to their personal enjoyment they reduce the supply of high quality
              protein food. Most of the canned seafood on grocery store shelves
              is imported from Thailand, Malaysia, or India, and may yet be
              salmon from Norway.

                A very significant study is in the appendices of this DEIS,
              that is the results of the survey of 335 shorelines properties
              in five Puget Sound counties which have potential for net pen
              siting. A standard ploy of shorelines property owners is that
              they should enjoy unimpaired views of the waters because their
              taxes are increased to reflect the value of the views.

                By showing that the taxes paid on assessed value are often
              miniscule relative to market values, and that this exists despite
              state legal standard of full market value for assessments, the
              DEIS performs a valuable public service.

                By showing that thelthreat' of net pens has not reduced the
              skyrocketing market values of these properties, not reduced their
              attractiveness to buyers, the owners' claims are shown to be
              specious.

              WATER QUALITY   PAGE 35+
        Q      To what extent have otherwise suitable pen sites been rendered
              unusable due to failing septic tanks and drainfields of shoreline
              residences ? How many known failing sewage systems like this have
              been corrected in past 5 years - sufficient to demonstrate improved
              water quality in the vicinity ?
               What  RRp&lqRVRd communities now meet federal or state water
              quality standards for effluent discharge of sewer treatment plants,
        Q     to secondary or better standards ?

              I ask these questions that you will evaluate the validity of the
              claims that water quality could depreciate by presence of fish
              rearing pens. A double standard should not be permitted relative
              to fecal matter of fish versus that of humans.

        Q     Toxic chemicals : What levels of toxic organic tin are presently
              measured in waters and sediments of marinas from prior or current
              use in anti-fouling paints on pleasure boats, and does this
              present a hazard to pen fish in the vicinity ?


               IMPAC-ZS OF EXOTIC FISH IMPORTATIONS -page 69+

                 "---a large portion of salmon in the North Pacific are from
               hatchery stocks."
               I contend that the high dependence of hatcherv rearing for salmon




                Page 4


                production is of greater hazard to the survival of wild stocks
                than is the pen rearing techniques. Hatcheries are located inland
                in streams and rivers where the food supply for smolts can be
                eradicated by released hatchery stocks - leaving a paucity for
                stocks of truly wild, free-living -which survive the'normal' hazards
                from egg production onwards.

          Q       Please evaluate the competition from hatchery production on wild
                stocks, and genetic integrity , survivabili'ty, etc. equally as you
                have that of pen rearing effects.

                RECREATION --- page 118+

                 The statement that'Puget Sound offers some of the finest oppor-
                tunities in the country for recreations in a marine environment'
                (page 118) is an extreme exaggeration. The opportunities are
                limited to those persons either living on the shores or owning
                a'boat.   Access to the beaches for all others is severely limited
                and such sites are frequently crowded or totally undeveloped where
                the property is in public ownership. Confirmation of is easily
                located , and references are provided in this response.
                Using data from DNR publication TOTEM of August 1986 one finds
                that where 78% of 370 miles of tidelands are in state ownership
                in the San Juan Islands, a mere 9.3 miles is usable by non-boat
                owners - at a mere three sites.. on three islands served by state
                ferries.

                Please examine the enclosed page from the Dept of Ecology 1983
                survey of public access volumes and the more recent DOE book
                Washington Public Shore Guide, Marine Waters, and reconsider how
                little sand or gravel beach is useable except by privileged groups,
                Shorelines public access is a farce in Washington State.


                                   GENERAL COMMENTS ON DEIS


                   In Washington these conditions here listed are ordinary
                activities, promoted and/or tolerated by government at all levels:;

                   I. Marina waters are known sources of fecal bacteria, oil
                      and overboard junk, with enforcement control casual at best.

                   2.Fish and invertebrate shallow water habitat,.3 are covered by
                     private and public marinas, and private docks which together
                     occupy more water surface than any amount of salmon net pens
                     now contemplatedi and are deteriorating to water quality and
                     fish survival.
                   3. Free use of public owned submerged land for private docks,
                                                    _. s encourag
                      encouraging habitat damage, L             ed by State Supreme
                      Court decision.
                   4. Port authorities fill tidelands and wetlands indiscriminately,
                      the Port of Seattle having filled 650 acres since 1965 at
                      the last count I have, and Congressional action was required
                      tocontrol the Port of Greys Harbor fills of habitat, after
                      it filled vast reaches of that estuary.

                   5. DesDite Dublicitv and rifi7pro Artivit-v  wpt- 1 And Q f i 1 1 Q n"d





                   Page 5



            6.  The Dept of Fisheries gave permission for a +35,000 cu yd
                fill on the beach and into the tidelands at the site of a
                now defunct marina project, the Elliott Bay Marina; this
                permitted the applicant to do the fill at a time which would
                normally be prohibited for such activity in interest of migra-
                tory species. Great volumes of this fill have since been
                washed into the waters, smothering a reasonably rich habitat
                in sand and gravel excavated from downtown Seattle. Pollution
                of the waters from the fill continues to be visible, nearly
                ten months later. The site, one of the last remaining feeding
                and resting areas for fish leaving the Duwamish river, is an
                ecological disaster with minimal control of future washout.


            7.            an exemDtion from control under the SMA, shoreline
                  residential property owners continue in the practise of bulk-
                  heading in the tidal shallows purporting erosion control and
                  using the newly created dry land for badminton courts and
                  landscape improvements, lawns, etc.
                  When Corps permis were required for this invasion of waters
                  the count of such bulkhead permits (always granted) was in
                  the hundreds per year.


            8.   Permits for new marinas in sensitive areas are routinely granted
                 by state agencies, Dept of Fisheries and Dept. of Ecology -
                 and are often funded with public moneys. SequimBay Marina,
                 East Bay Marina, Lummi Bay marina, Elliott Bay Marina, with
                 certain habitat damage derogated as 'insignificant' , and
                 no respect for the incremental consequences to fish stocks.

            9.   The commercial fishing industry opportunity for berthing
                 and working space continually declines by the gentrification
                 of urban waterfronts; the industry can't compete economically
                 with the condos, office buildings, restaurents,etc. which
                 local governments favor on the shores, however derogatory these
                 are in the long term to the states economic interests.
                 (example - H.C. Henry Pier,Seattle, noted on attached clipping)
            10.   While land-based farming is subsidized by multiple tax breaks
                  loans guaranteed, marine farming seems to be routinely
                  defeated and obstructed, esp. by local government bodies.

            11. The State legislature demonstrates its support for improved
                 water quality in Puget Sound by imposing a sin tax on tobacco
                 users.



            Since events and conditions listed above are routine and tolerated
            governmental hypocrisy is sovereign.   Under the policies listed
            in this DEIS the salmon net pen industry would be required to meet
            standards for siting and water quality not even met by the sewage
            systems industry. No other user or abuser of water quality has
            such conditions imposed. The "concerns" and the "growing contro-
            vers-y' (page 1) are generated as a means of stifling a new and
            competitive industry, render it economically infeasible.





              Page 6

                 For destroying one of the greatest gifts of nature than any
              country could be blessed with, and giving mean and stinting recom-
              pense for the crime, the state of Washington should be indicted
              at least for destruction of a food supply by other states of the
              Union, whose citizens had a right to productivity of navigable
              waters of the U.S.     The U.S. is now recognized for thecolonial
              status it has achieved, one that exports raw materials while importing
              finished manufactured - or canned goods.

                 For those who have forgotten or have never known of the extent
              of the criminal slaughter of billions fish since statehood, the
              book by Bruce Brown, Mountain in the Clouds, should be required
              reading. Wiping out Tfftire species and genera indiscriminately is
              not a practise limited to third world or uneducated peoples - as
              Washington's history proves.      (reviewj'of that book     enclosed)

                  Many people devoted to the cause of fish and wildlife survival
              and habitat protection are employed by goveri.-imental agencies here,
              but find their work tasks subverted by the state legislature with
              members having their own re-election survival as competing goal.


                 After careful examinationof theDEIS I must conclude that those
              persons interested in salmon net pen investments would be best
              advised to look to other countries.       This is only the first round
              the "programatic" EIS, and surviving this one only means that other
              rounds will be continuing. The shorelines residents are many of
              the most influential and affluent people in the state, and the effort
              to site pens - given the restrictions seemingly endless in number
              to be overcome     w.;11 b,5@ fiiti1e.There should be countries where
              food production     an essential for human survival - is valued.

                 Population expansion and increased water pollution are further
                 detrimental to expectation of business success. Rearing pens
                 will. not survive as a business given the delays in sewage treatment
                 plant funding, and poor levels of treatment consequential.
                 Nearly twenty years after the Clean Water Act the largest sewage
                 system in the state, King County's, has massive plant still using
                 primary treatment only at West Point operated by Metro - with the
                 cooperation of the EPA


                 I have tried to be optimistic in reviewing this DEIS - but REALITY
                 kept breaking through. I would not invest a dime in salmon net
                 pen rearing business - despite that I think it a necessity if the
                 state is going to raise anything but views from picture windows
                 from the waters of Puget Sound.

                 The 10 pages here attached are intrinsic portions of this EIS
                 comment, confirmation from various sources of statements made
                 herein.

                 I will be pleased to receive a copy of the Final EIS, and thank
                 you for receipt of both draft and final.

                                                Very truly yours.,


                                                 Ms Benella Caminiti






                  Books

                  Mountain in the Clouds                 record his meetings with each           torrent of documentation that
                  by Bruce Brown                         of the several species of Pacific       rushes by those boulders of per-
                  Simon & Shuster                        salmon: pink (humpback), sock-          sonal experience, is a litany of
                  pp. 239, $12.95.                       eye (red), chum (dog), coho (sil-       evidence that man is the salm-
                                                         ver), and chinook (king). Wad-          on's most destructive enemy-
                                                         ing in the stunning cold of the         especially 19th and 20th Cen-
                  by John N. Cole                        streams and rivers of Washing-          tury American Man wielding
                                                         ton's Olympic Peninsula, Brown          the implements of the Indus-
                  Telling us he has nothing more         meets salmon in the creature's          trial Age.
                  to write, Huck Finn ends his           element, and in prose that is as           Spawning streams blocked
                  narrative saying: "I reckon I got      crisp and lucid as the waters he        by dams without fish ladders,
                  to light out for the territory         walks, Brown reveals the depth          gravel beds scattered and silted
                  ahead of the rest, because Aunt        of his feeling for the fish. He is      by wanton lumbering, entire
                  Sally she's going to adopt me          not sentimental, he does not            rivers diverted for crop irriga-
                  and sivilize me, and I can't stand     indulge in Peter Rabbit, lippety-       tion, home waters heated be-
                  it. I been there before."              lop, green meadow nature writ-          yond tolerance by nuclear power
                    Bruce Brown, the angry au-           ing, nor does he preach about           plant discharge, and returning
                  thor of Mountain in the Clouds,        the glory of a salmon's presence.       salmon taken at sea by mecha-
                  share's Huck's view of civiliza-                                               nized trollers before the fish
                                                                                                 have a chance to reproduce the
                  tion. And, like Mark Twain,
                  Huck's progenitor, Brown knows                                                 species-these are the several
                  how to write memorably about                                                   systems working in combination
                                                                                                 to deplete the wild salmon that
                  the penalities civilization im-
                  poses on the free spirits of man                                               Brown sees as a metaphor for
                  and salmon.                                                                    all f what pure nature can mean
                                                                                                    01
                    "The . . .  process of civiliza-                                                  an.
                                                                                                 to in
                  tion," Brown writes in his open-                                                  And, as the salmon are dimin-
                  ing chapter, "has been at work                                                 ished, the struggle intensifies for
                  on the Pacific salmon since the                                                the few fish that remain. Com-
                  California gold rush of 1849.                                                  mercial fishermen and sports
                  During the intervening years,                                                  fishermen tussle with each other,
                                                                      N
                  Pacific salmon have declined to
                                                                                                 physically on stream banks and
                  less than half their former num-                                               metaphysically in the courts and
                  bers along the entire West Coast                                               state capitals. And then each
                  of North America. Many signif-                                                 joins the other as allies to oblit-
                                                                                                 erate In
                  icant runs have been wiped out                                                          than claims to salmon
                  entirely"                                                                      streams that have sustained the
                    It is a loss that Brown feels in                                             tribes of the Northwest for
                  his soul. He makes this clear in          What he     does is   rare:   he     10,000 years. In response, In-
                  the passages that describe and         writes matter-of-factly (as     the     dians become white, catching
                                                         journalist he is) about what he         illegal salmon for capital gain
                                                         observes. We feel the chill water       instead of sustenance.
                  John Cole is the author of             on our thighs, we see the 40-              Throughout the documenta-
                  Striper, A Story of Fish & Man.        pound salmon in their shallow       .   tion-detailed expository prose
                  Editor's Note: Since the publi-        home streams, we walk alone             charged with the invisible elec-
                  cation of Brown's book the Na-         with Brown on a midnight ex-            tricity of Brown's outrage-the
                  tional Marine Fisheries Service        ploration of a spawning bed.            author builds a careful, almost
                  has pressured the Oregon Fish          And through his observance and          judicial, case against man. He
                  and Wildlife Commission to stop        comprehension of these natural          has learned his journalistic les-
                  sports fishing for Coho salmon         events - episodes which rise            sons well; he cites chapter and
                  in state waters off the coast. The     here and there in narrative like        verse; he quotes directly from
                  action was taken in response           boulders in a rushing stream -          the record.
                  from fish biologists that this         we perceive the man's love and             Nevertheless, there will be
                  years run is the smallest in 20        respect for the creature that is        those in the Northwest who will
                  years. Continued fishing could         the hero and the chief protag-          dispute vehemently Brown's the-
                  have threatened the Coho run           onist of this fierce book.              sis. The salmon, some hatchery
                  with extinction.                         The book's mainstream, the            managers and state bureaucrats



                  62                                                                                   The Amicus Journal Fall 1982





                                                                                  NORI PRODUCTION' BEGINS IN
                                                                                               TRAMP HARBOR
                        will say, are not dangerously                         On September 18, 1983, the American Sea Vegetable
                        depleted, Indeed, the hatcheries                      Company of Vashon Island began implementation of the
                        which public funds and private                        research and development stage of nori production. Using
                        hush money have built are pro-                        seeded nets obtained from the Department of Natural
                        ducing more salmon each year                          Resources, the company placed one test frame work (with
                        Brown acknowledges the           i                    two to four nets) into the waters of Tramp Harbor. After a
                        hatchery fish, but, for him, they                     grow-out phase, the company (with assistance from the
                        are not salmon. His fish are wild;                    department) will harvest and reset the framework with new
                        they are the creatures that have                      seeded nets. This rotation will continue throughout the
                        followed the same incredible                          growing season.
                        urges for 10,()00 years-com-                          After harvesting, American Sea Vegetable plans to freeze-
                        pulsions that take them across                        dry the cut seaweed and ship it to Japan for processing.
                        thousands of miles of open ocean                      Processing is not yet available in the United States. After a
                        and then bring them back to                           year of testing the production potential of Tramp Harbor,
                        their home stream years later to                      American Sea Vegetable will seek funding for full scale
                        spawn and die. Hatchery fish,                         production beginning in 1984-85.
                        Brown tells us, are not the same:                     Getting into the water has been a lengthy process for
                        they are lesser; they are vul-                    A"American 'Sca Vegetable. Agn oppositiqjjg@oup appealed the
                        nerable to disease; and they
                        are not the possessors of wild,                       original King County shorJiine pe@r_iinii_t and further appealed
                        free souls.                                           a Shorelines Hearings Board decisioii_@@h_oTdl_rij@_ffiaC
                        In addition to its considerable                       permit (see Coastal Currents, May, 1983). A motions court
                        presence as the authoritative                         order of August 8 allowed the company to proceed with test
                        text on the west coast salmon                         farming while thp app@at_)Kent through Thurston County
                        decline, this book is also a per-                     Superior Court. Just prior to trial, the opposition group
                        sonal lament. It is Brown's cry                       dropped the, appeal. This outcome is of great importance to
                        for the loss of natural truths, for                   all aquaculturalists. This was the first aquaculture siting
                        the denial of the wild, the de-                       case taken before both the state Shorelines Hearings Board
                        struction of waters that once                         and the Thurston County Superior Court.
                        were pure. It is the fierceness of                    The Department of Natural Resources nori project (see
                        that lament that stays with the                       above) works closely with American Sea Vegetable. Ideas,
                        reader more powerfully than the                       equipment and expertise are shared in an effort to promote
                        sorry details of the salmon's                         a new, clean industry for Puget Sound.
                        destruction
                        "There is no saying where
                        the Northwest salmon story will
                        eventually conclude," the author
                        tells us, "but it is certain that                       Board Upho-lds Seattle on Controversial
                        Man and salmon will be linked,
                        for as the Indians said from the                                                  Permit
                        start: the fate of one mirrors the
                        fate of the other."                                      A recent decision by the Shorelines Hearings Board upholds
                        We, all of us, Brown tells us,                       the city's approval of a permit for a multiple use development
                        are as diminished and denied as                      on Lake Union. The heart of the controversy was the
                        the wild salmon by the excess                        displacement of several water dependent and water oriented
                        of our exploitation of natural                       uses now at the site. The existing businesses serviced marine
                        resources. If there is to be a                       vessels by providing dockside moorage, maintenance, repairs
                        cultural shift, an attempt to re-                    and refurbishing.
                        pair some of the damage, it will                        The proposed multi-use development includes restaurants,
                        be books like this one that will                     retail shopping, accessory offices, a 42-slip marina, and a two-
                        bring such change to pass. And                       level parking garage on the H.C. Henry pier.
                        if the people of the Northwest                          The board found the proposal to be consistent with the
                        want to know what has to be                          Shoreline 'Management Act and Seattle's Master Program
                        undone to restore the wild salm-                     policies and regulations. In the absence of a master program
                        on, they have this book to guide                     provision dealing with the displacement of existing preferred
                        them.                                                uses, it was felt that this alone was not a proper criterion for
                        They can start at the begin-                         overturning: the permit,
                        ning and undo each of the deeds,                       The city of Seattle is currently reviewing its master program
                        dams, and destructions Brown                         and the needs of water dependent uses. Perceiving a trend which
                        has so meticulously and pas-                         may be contrary to city goals and policies, city planning staff
                        sionately documented-                                may recommend amendments that clarify a shoreline priority
                                                                             for water dependent uses both existing and potential.

                        63
                                                                              ze                        Cat -1,old ;C-
                                                                                                                           0@@4 P_












                   6                         ARGUS                    November 19,1982
                                                       ORTHWEST                                                                                 E
                                           AU
                'Mountain in the Clouds': Babylon vs. Wild Salmon
                                     By KELLY T. SMITH

                Mountain in the Clouds by Bruce Brown. New York: Simon and                                                       V, 5
                Shuster. Cloth, 239 pp., $12.95.
                                                                                                                                                 Ain
                        HE BITTER AND PERSONAL power Bruce Brown
                                                                                                                                               7
                          sustains throughout Mountain in the Clouds: A
                TSearch for the Wild Salmon, can possibly be dated to
                the January, 1981 agreement between the state Department of
                Fisheries and the state Indian treaty tribes.
                   Through his book, Brown presents an historically
                methodical indictment of this state's fisheries management.                                                                    ANEW
                Mixing the most wondrous descriptions of the fascinating
                salmon creatures in our waters with a deep cultural and
                political awareness, Brown makes a passionate, if perhaps
                hopeless, plea for the survival of trickling wild salmon runs.
                   By the point late in the book when the 1981 agreement is
                discussed, we are hoping, like Brown, for some justice and a
                happy ending to the plight of the wild salmon. Instead we're
                presented with a sad irony.
                   After nearly a century of industrial assault and rapid
                displacement by the inferior, but proliferating, hatchery fish,
                Brown and no doubt others looked for the wild salmon's             Bruce Brown, author of "Mountain in the Clouds,           worked
                salvation in the so-called "Boldt 11" decision reached by U.S.     as a Seattle journalist and now lives with his wife, Lane
                District Court Judge William Orrick in September, 1980. The        Morgan, in the Fraser Valley.
                judicial followup to the 1974 Boldt decision giving the treaty
                tribes half the state's catch, the "Boldt 11" decision gave the    book that it's almost overlooked. Brown's review of the
                treaty Indians strong control over the environmental impact        history of Washington Public Power Supply System's nuclear
                on harvest.                                                        plant construction on the Satsop River is an illustration still
                   But this chance to remedy much of the abuse of the wild         vivid in our minds of the folly of such large-scale centralized
                salmon disappears as we recognize that the treaty Indians have     projects. It's the conflict with nature, mysterious and power-
                one important trait in common with the environmentally             ful in its intricacies, that Brown brings to contrast so well.
                ravaging industrialist, the bought-off politician and the             Recounting the WPPSS Satsop plants sliding down the
                empire-building bureaucrat: greed.                                 hillside during their 1979 erosion problems, Brown makes
                   The harbinger was the January, 1981 agreement, stipulating      clear the overriding sense of cultivating natural, wild salmon
                that plants of hatchery Chinook and coho would be increased        runs over those reared in concrete hatching ponds. It might be
                to the highest Chinook level on record.                            summed in the universal maxim: "Don't fool with Mother
                   That first-of-a-kind agreement also assured that the tribe      Nature. "
                would itself get into the salmon hatchery business. "Explain-         During the time that Brown appears to have concentrated
                ing why the fish are released at a stage that maximizes            on writing his book,- near that time around January, 1981,
                residualization (pooling in such large numbers that the food       other circumstances besides the Indian-state agreement were
                cycle is disrupted and both wild and hatchery fish die) and        looking black for his cause. The state's hatchery program was
                conflict with wild salmon, the tribe echoed the rationale used     burgeoning under the 1977, $43 million Salmon Enhancement
                by Washington Fish Commissioner A.C. Little in 1899. 'Rear-        Program. Brown notes the entry into the fish hatchery
                ing and releasing steelhead is an expensive venture,' said Terry   business of many of the same industrial powers that have
                Martin, tribal fisheries biologist. 'Ideally, the steelhead are    already stripped other resources at the expense of the wild.
                reared for two years until they become smolts and then releas-     salmon.
                ed, but costs (approximately $20,000) are prohibitive at this         "When the administration of President Ronald Reagan
                time for the tribe to hold them for that period."'                 killed--the effort, to place the wild salmon of the Columbia
                   The Indian's quick recognition that there was more to be        River on the threatened or endangered species list because
                made reaping half the catch of hatchery salmon, with the           'enough conservation programs already exist,' it appeared
                hatchery's promise of capital-intensive production, is a hard      that no one remained to speak for the wild salmon in their
                economic case to counter.                                          hour of greatest need."
                   But Brown does counter the hatchery policy with an even            But there was certainly Brown,. and with his book there will
                more powerful economic case, done with such subtlety in the        certainly be others.









                                     SOURCE:               AN EVALUATION OF PUBLIC ACCESS TO WASHINGTORIS
                                                           SHORELINES - Since passage of the Shoreline
                                                           Management Act of 1971,

                                                                                             State Dept.of Ecologyv SePt. 1983

                                                                                                  Flaw It


                                                                                             SHORELINE IMENVORY
                                                                                             (Distances In H1.19s)


                                                                           ALL SHORELINES                                                    WINE S"ORELINES
                                                                                                                               Publicly Owned
                                                                                                                il8LE
                                                    TOTAL                  PUBLICLY 000                  WaS.                   Tidelands With                OCEAH
                        ICOUNTY                   SHORELINE                   SHORELINE                  (SHORI"LINE              Coincident                        Seashore
                                                                                                                               Publicly Owned         Indian       Conservation
                                         Fr  shwater       Saltwater  Freshwater    Saltwater     Freshwater     Saltwater          Uplands        Reservation          Area


                        Adams                172.)                         16.4                          16.4
                        4sotin               255.)                         53.2                          53.2
                        Benton               109.9                         8).2                          72.4
                        Chelan               321.9                         65.1                          65.1
                        IClall&m       1     59).)     1   too.1    1      19.9    1     150.2   1       $.5    1     70.8            32.5             12.0             M.)
                        IClark         r-527.8                                .2                         46.2
                        IColumbia            152.1                         4.1                           4.1
                        ICowlitz             1229.6                        25.6                          25.6
                        IDouglas             209.3                         19.7                          6.5
                        Ferry                209.9                         6.7                           2.0
                        Franklin             190.6                         24.9                          24.9
                        Garfield             ".2                           1.6                           1.8
                        Grant                73J.0                         121.2                         121.2
                        Crays Harbor         1183.)        146.0           )).1          91.)            27.7         28.0            3.6              20.8             28.0
                    -A-Island                14.0      1   240.0           4.)     1     106.5   1       4.)   1      27.0    1       27.0       1                       --       I
                        Jefferson            16A4.6        206.7           Z9.6          110.4           29.6         $1.4    1       27.7       1      4.8             27.7
                        King                 11".8         903             246.6         14.1            144.0   --r4. -11            14.1       1
                        IKitsap              62.7          228.6           1.4           55.0            1.4          9.0             9.0
                        IKittitas            528.9                         44.9                          )0.9
                        Klickitat            375.8                         44.3                          .25.3
                        Lewis                1221.3                        38.3                          38.)
                        ILincoln       1     253.6     1                   96.0    1     --              96.0  1      --
                        Mason                476.5         1".5            15.1          58.1            15.1         6.7             6.1
                        Okanogan             1015.1                        lal.1                 1       163.8
                        Pacific              4". 8         155.2           10.)          56.7            10.3         56.7            33.4                              25.7
                        1Pend Oreille        297.4                         114.2                         5.0
                        IPierce        1     574.3     1   216.6    1      111.9   1     8.@             60.9         8.4             8.4
                        ISan 3uan      1     12.8          372.7           8.7          341.?            a.?          58.7            $8.7
                        ISkagit              724.2         127.0           95.4          17.7            95.4         17.7            17.7
                        ISkamanis            $21.9                         10.6                          10.)         --
                        Snohomish            IZ56.9        62.4            1)2.9         57.Z            139.9        7.5             7.5
                        Spokane              455.)                         34.4                          34.4
                        Stevens              369.)                         328.2                         328.2
                        Thurston             257.0         90.0            7.6           12.5            7.6          ).S             3.5
                        Wahkiskus            275.1                         12.0                          12.0
                        I Wall& Wall&  1     390.0     1 --                5.8     1     -               5.a   I      --
                        IWhatcom             447.2         105.9           196.a         7.0             121.8 1      7.8             7.8
                        IWhitman             454.0                         0.0                           8.0
                        IYakima              29J.0                         38.6                          35.0



                        TOTALS            111211.9         Z421.5       2274.9         1087.1        1905.4         )97.)            286.7             37.6            119.7



                        Sourcet Washington Department      of Ecology, and
                                 Washington Interagency Comulttee    for Outdoor Recreation
                                                                                                              @A-
                                                                                                         A,

                                                                                                   Ala?





                                                                  Making Waves
                                                                        Nancy Thomas


                                               Whose Coast Is It?
                                         While officials press for public access to
                            state-owned tidelands, coastal landowners resist what
                                    they view as intrusion on their private domain


         T
              o a child of the Northwest, going                                                             owned. An Oregon Supreme Court deci-
              o the beach is synonymous with                                                                sion and a Washington attorney general's
         summer. The beach is toe-warming sand                                                                                  7
                                                                                                            opinion agree that the ocean beach up to
         and gritty sandwiches, slippery cobbles
                                                                                                            the line of vegetation is open to the public
         and scuttling shore crabs. goose bumps                                                             through the doctrine of "custom." Es-
         and jittery teeth and the classic utterance.                                                       sentially, that means the people have a
         "I'm not cold and I don't want to go
                                                                                                            right to use it because they   al ways have
         home yet!"                                                                                         used it. (The Washington opinion excepts
            What most of us call "goincy       to the
                                                                                                            the Quinault Indian Reservation whose
         beach" has in the past decade been for-
                                                                                                            28 miles of ocean beach were closed in
         malized by officialdom. In government-                                                             1969, according to reservation attorney
                                                                                                            Bud Ullman, because of vandalism, the
         ese, it's called "public access." As a
         term, public access  'is doing very well. Its                                                      threat of development, and littering
         "enhancement" is a goal of every shore-
                                                                                                            by visitors.)
         line planning document. But somewhere                                                                Washington's inland saltwater beaches
         between the stated policies and their                                                              have a different historv. From the time of
         implementation, something is being lost                                                            statehood until the leizislature banned the
         -and, on the saltwater beaches of PuLet                                                            practice in 1971 the state could, and for
         Sound, Hood Canal and the San Juan                                                                 many years was required to, sell tide-
         Islands, that something is public access                                                           lands to the upland owner. Tidelands lie
         itself.                                                                                            between the line of ordinary high tide and
            Things are different on the ocean.                               4                              the extreme low tide line. Because of
         Oregon law requires access at least every                                                          these sales, more than half of %Vash-
         three miles along the ocean beaches.                                                               ington s inland saltwater beaches are
         Two-thirds of that state's parks and                                                               now in private hands, and much of this
          waysides" (day-use areas) are located                                                             private ownership is near the metropol-
         along or near the coast. "Fundamentally,                                                           itan areas where public recreation needs
         we haven't got an access problem on the                                                            are greatest.
         ocean beaches," said Neal Coenen of the
                                                                                                              The state retains about 1.100 linear
         Land Conservation and Development                                                                  miles of beaches, but oniv 222 miles
         Commission's coastal program. "And                                                                 have adjacent publicly owned uplands.
         it's usually pretty easy to find public                                      0,.%'                 The rest of these public tidelands front
         access on the estuaries."                                                                          private property. Upland owners, often
            Washington state parks planners were           Markers like this one desi)zna!e the             aided by local @fficials and sometimesbv
         less confident. partly because neither the        boundary between public and private              state legislators. are amazingly adept @t
         legislature nor the parks commission has          tidelands in Washington.                         keeping the public away from public
         addressed the question of access spacing                                                           beaches, beaches that then become the
         on ocean beaches. However. the state is                                                            upland owner*s defacto front yard.
         still acquiring and developing routes to                                                             The Department of Natural Resources
         the beach, sometimes with strong oppo-                                                             (DNR) manages most state-owned tide-
         sition from local residents.                                                                       lands. For more than a decade the depart-
           In both states, once you     get onto the                                                        ment has tried to get access from the
         ocean beach it's yours to roam. Almos!                                                             uplands to some of the public beaches,
         all of the ocean tidelands are publicly                                                            and to mark the ownership boundary on

         12      Pacific Nordift est - Nui ember 1980





                                                                        Making Wives
                                                                                (conitnued)



                                                                                                                  out rural beaches. Whidbey Island and
                                                                                                                  the San Juans are favorite destinations.
                                                                                                                  Island and San Juan counties have man%
                                                                                                                  expanses of public beach ideally suited
              "One fellow said, 'You'll be blown off this                                                         for beachcombin2 and clam dioe      .ine. but
              beach if you come to mark it,' but he must                                                          both counties have consistently stone-
                                                                                                                  walled state aeency efforts to get access
              have calmed down because we're still he.re"                                                         from the uplands.
                                                                                                                    About 10 years ago. DNR got an
                                                                                                                  easement for a path down a 100-foot bluff
                                                                                                                  to Taylor Beach at Whidbey*s Useless
                                                                                                                  Bay and bought several upland lots to
                                                                                                                  park 33 cars. Below the cliff is a p    ublic
              other beaches so boaters may use them.            phrased the landowners' concerns                  beach a mile and a half long. averaging
              On these public beaches the state owns            somewhat differently. "It's only fight that       1,000 feet in width at low tide.
              the tideland portion. but private parties         the public have access to lands that are            Earl), in 1971, the Useless Bay Home-
              own the uplands that extend onto the              rightfully theirs; after all. I'm the public      owners Protective Association sent a
              upper beach, usually down to the line of          too. What I object to is the lack of con-         letter to the department stating its mem-
              ordinary high tide. State markers there-          trols regarding trespassing on bordering          bers felt the proposal "infring@d on their
              fore must be placed at both ends of public        private lands and shellfish    depletion on       constitutional and statutory fights. was
              ownership and along the high tide prop-           public lands.                                     unrealistic. ill-conceived. iil-adcv7ised and
              erty line as well.                                   "I've worked for 30 years to buy               intolerable" and that the on]y -honest.
                "We usually get into a bi2 fight with           myself a quiet place outside the city             just, proper and logical solution- would
              local government," said Ralph Beswick.            and I don*t appreciate holier-than-thou           be to abandon the project. A department
              supervisor of the Department of Natural           bureaucrats telling me how to live."              interoffice memo dated a week later said
              Resources, "because the segment of                   DouL, Maeoon, natural resources man-           plaintively. "We have a rather serious
              society that lives along the shore knows          ager with DNR. said that there are                community relations problem ... which
              how to work the political system. Realis-         "inevitably a handful of trespass prob-           has now spread and is involving a num-
              tically, there's a limit to the amount of         lems" resulting from the opening of such          ber of legislators." State and county
              flack any agency finds it feasible to             beaches and that he doesn't know any              couldn't reach a compromise. Island
              take," he said. "As long as the silent            way around them. "Problems exist on               County denied shoreline and health per-
              majority stays silent. local residents will       both sides.- he continued, "but in the            mits. An interagency committee "post-
              use the Shoreline Manap-ement Act and             end it comes down to public rights versus         completion- report dated January, 1979,
              other permit procedures to block the              private rights."                                  said, "The site is currently undeveloped
              public from using public beaches. It's               The department does an annual litter           and receives no public use though it
              that simple."                                     pickup on marked beaches, but Winning-            provides access to an excellent stretch of
                Fred Winnin2ham headed DNR's tide-              ham said he thou2ht most of the litter had        sand beach on salt water."
              land marking program for five years.              floated in on the tide. "Funny thin2," he           "Thirty-five families have sole access
              Winningham says the department ex-                added. "with all the fuss beforehand. not         to a million dollars worth of public
              plains the program to the landowners              one owner has come back to complain               beach." said Terry House. a department
              before marking the beach and tries to             after we marked the public beach."                recreation specialist. -Technically it's
              settle objections. -Usually it's just one         Magoon reported that he had had only              usable if people know where the land is.
              or two owners who raise a howl.** he              one@or two complaints after the marking.          but some of our field staff were ordered
              said. The objections are nearl@ alwavs               The Interagency Committee for Ou-t-            off public property one day. It*s easy to
              the same: fear of trespass. fire. vandal-         door Recreation prepares the state's out-         outbluff people if they*re not sure they
              ism and littering. Owners of high-bank            door recreation plan and approves state           have a neht to be there. Besides. people
              property are just as likely to fiPht the          and local recreation projects for govern-         don't go to the beach to get in a hassle."
              marking as those with cabins right on the         ment matchin2 funds. -%'Vater access in             Bella Tierra. 20 acres near Lopez
              beach. "One fellow said. 'You*ll be               general is Washington's most critical             Island's Flat Point. has a paved coui;ty
              blown off the beach if you come to mark           recreational need.** said Gerald Pelton.          road on one boundary and 690 feet of
              it.' but he must have calmed down                 the committee's chief of planning ser-            waterfront opening to three and one-half
              because we're still here." Winnincharn            vice%. "It's one of our top priorities. If        miles of public beach on the other. The
              remarked. "A lot of Hood Canal land-              vou don*( include DNR tidelands. oniv             department bought it in 1976. intending
              owners didn*t want the beaches marked.            about five percent of the state's public          to develop three to five acres for bicycle
              but they thought nothing of' going, down          recreation sites are (in salt water.-             and boater camping with 20 parking
              and taking oysters from the public tide-             Most niatchine money now goes to               spaces for day users. Local residents and
              lands themselves.---                              growing urban areas. but 'fiLures show            San Juan County objected to the acqui-
                One long-time Hood Canal landowner              that people who live in cities still seek         sition. Faced %&ith likely refusal, the

              14      Pacifir Northivesi - Nt ivember 1980








                                                                                                            SALMON-PEN BATTLE
     department has not yet applied for devel-         fronts, street-end miniparks. and fishing            Pleme, keep them away
     opment permits. Like Taylor Beach.                piers. A Willamette Greenway Plan was                from my wateftnt home
     Bella Tierra is usable. if you know where         also adopted in Portland last year that
     it is.                                            will provide river access and h@king and                As a waterfront owner, I have been
        Tired of that rejected feeling. DNR            biking trails along the four-mile stretch            closely following the continuing saga of
     finally went to battle over a proposed            of the river south of the Broadway                   the salmon pens. It's been called a battle,
     boating campsite on San Juan Island.              Bridge.                                              and that is true.
     The county refused a shoreline develop-              "tities are becoming more livable                    Brian Boyle, commissioner of public
                                                                                                            lands, wants to raise money by leasing
     ment permit. The departme       Int appealed      now that interest is focused on the water-           fish pens he says in order to develop
     and won. Then the count% and some                 front," Peterson maintained. Seattle                 water-related public areas. To do this, he
     neighbors appealed the previous deci-             shoreline planner Rosemary Horwood                   is going to destroy the privately held
     sion. DNR won again. The case has now             agreed and said private projects are to              lands.
     escalated to the State Court of Appeals.          dle the major sources of new access.                    Around Whidbey Island, all areas
        Other agencies have similar stories.           If a proposed shoreline development                  zoned for fish pens are immediately upon
     State parks' envi ronmenta I plannerDavid         is not dependent on a waterfront site.               the sandy shores.
     Heiser says it's not by desire that his           Seattle's shoreline master program re-                  Boyle says the fish-pen developers
                                                                                                            want to come in because of our pure
     agency has no campsites on San Juan               quires that it compensate for the use of             water. How long would it stay pure with
     Island. "People see a park as a threat to         valuable shoreline by including public               the salmon pens in-place? Even the new
     the island life-style they moved up there         access and view corridors.                           study done by the Fish.eries Department,
     to get," he said.                                    Seattle does have several real beach              which is lauded as saying pens are good
        Several years ago. the parks depart-           projects planned: replacing the old sea-             and won't pollute the bay in general,
     ment had a somewhat heavy-handed plan             walls at Lincoln and Alki parks with                 does admit that, in the wrong place or
     to develop its land on Stuart Island.             gravel berms to make a more natural                  when oorly run, they can cause environ-
                                                                                                            mentafproblems.
     "We had to fight over everything, even            beach. and enlarging a small existing                  "Fish feces and uneaten food can
     the water system for fire suppression,"           beach at Myrtle Edwards Park.                        accumulate on the bottom and deplete
     Heiser said. "We gave up the dock, and               A big winner in city access programs              oxygen, making the sediment and water
     we let the county commissioners choose            is the Department of Fisheries' urban                toxic, etc." This is what Gov. Gardner
     .the campsites themselves. But we did             fishing pier. These are large-scale struc-           wants to put right by a beach where
     talk them out of making us build a chain          tures. each with 1,000 feet of fishing rail.         children play? Please!
                                                                                             C@               In addition, the same report. says
     link fence around the park."                      benches. shelters. restrooms. bait and               these pens cause odors and algae bloom.
        Petitions circulated by neighbors              tackle concessions. The first was built at           Should this be placed in residential
     helped block the Department oi Fish-              Edmonds, Washincton. and drew more                   areas? Even if the tide washed some
     eries from getting upland access to its           than 112.000 anglers and 63.000 other                effluent away, it would only go onto the
     public shellfishing beaches in Whidbey            visitors during its first year. Artificial           shores.
     Island's Penn Cove. The same device               reefs attract fish. but Edmonds also hung              This is the main reason for the
                                                                                                   -        salmon-pen battle - not visual problems,
     encouraged Skagit County to reject an             a salmon rearing pe  .n under its pier. NoW          although those are important too.
     interpretive center on the 6ame Depart-           the anglers are waiting to see whether the            The state says careful siting will take
     ment's 13,000-acre Skagit Wildlife Rec-           coho return to the pier as **fishable"               care of all the problems. All right, be
     reation Area. "Sure, some people do               adults. Fishing piers are also slated for            careful and don't place salmon pens by
                                                                                                            waterfront residences.
     cause problems for the neighbors.- said           Seattle. Tacoma and Bremerton.                                     Jacqueline Maner, Everett
     retired shellfish biologist Cedric Lindsay.          Street ends are legal accesses to the
     "But what it still bods down to is if you         water in many communities. but they are
     have a little private domain you don*t            seldom de%eloped for public use because
     want it available to the public e'ven when        the neighbors ob@iect. Seattle. however.
     the public owns it.**                             has mAe excellent use of street ends lor
        Department ot'Ecology shoreline plan-          parks and viewpoints. The Uni%ersit% of                            &A
     ner Don Peterson reluctantly a-reed that          Washiripton built one ubout six %ears a20
     .sorne good projects with public access           at the foot of Brookl%n Avenue N.E.
     have been turned down because local               It's partly on the street right-of-wa%      '
     property owners objected." He said                partly on universitv land. has trees.
     emphasis now is on redevelopment of               grass. benches. a lo%  ely view of Portage
     urban waterfront. that's where the plan-          Bu%. and it looks brand new. Univcrsii@
     ning grants are going and where new ac-           spokesman Rolle Kellor said they don t
     cess is opening up. Only a few of' these          get complaints about % andalism, trespass
     are beaches. More typical are museums             or litter.
     such as Bellingham's Maritime Heritage               -1b tell the truth." he said. "the
     Ccnter and Seattle*s Elliott Bay Shore-           biggest problem we have is cleaning up
     lines exhibit, walkways along city water-         after the ueese.--






            Tidelands

            Birds and wildlife abound
            
            John Edwards                                      debris, in many cases you are on                                                              
            Assistant Manage                                  private property.                                                                            
            Land Leasing and Recreation                          To keep these islands special                     
                                                              takes special care. 
                                                                 The majority of the public  
                                                              tidelands do not have any arnenities   
                                                              such as sanitation facilities or        
            Welcome to the San Juan Islands,                  garbage receptacles. Please honor
            one of the most beautiful and unique              the adjacent private upland owner's
            areas in the state of Washington.                 rights, keep to the public tidelands
            There are some 370 miles of                       and pack out all garbage.
            tidelands of which 78 percent are                    Islands are isolated. Many of 
            still state-owned. They typical San               the smaller islands in the San Juans                  
            Juan beach is narrow ,steep and                   are lacking ferry service, fire and
            rocky. However, the tidelands of                  police protection. To these island            Shark Reef--Lopez Island.                          
            the region vary from wide, sandy                  residents, fire is a major concern.           Griffin Bay--San Juan Island.                                    
            beaches to vertical cliffs-from open              Beach fires can easily spread to the          Pt. Doughty--Orcas Island.                                                       
            Birds and wildlife abound on                      adjacent uplands causing major                Cattle Point, Obstruction Pass
            many of the smaller islands and                   damage.                                    and Shark Reef can be reached by  
            rocks, which are part of the San Juan                During the dry season fires are         road, providing public access to
            Islands National Wildfile Refuge.                 prohibited. If you are building a          nonboatings islands visitors. Griffin                        
            Many of these seemingly                           beach fire with beach wood, you are        Bay and Pt. Doughty can only be                           
            insignificant islands and rocks are               probably trespassing when you go to        reached by water.                            
            important nesting and breeding                    the drift log area to obtain fire             A few of the sites have buoys,                         
            areas, Visitors are reminided to keep             wood.                                      Depending on location, other                  
            a safe distance to minimize                           Numerous developed recreation          facilities can include vault toilets,                        
            disturbance to wildlife.                          facilities are provided by the state       picnic tables and tent spaces. Water                             
             Because the abutting uplands are                     Parks and Recreation Commission,       is availabe at some sites.                          
            in private ownership many of the                  the Department of Natural                     There are many recreational                    
            public tidelands can only be reached              Resources and local government.            opportunities available in the San                            
            from the water.                                                                              Juans. The publication "Your Public 
             As a general rule the public                     DNR sites                                  Beaches--San Juan Islands" contains              
            ownership is only that portion of the                 The DNR manages five sites in          maps and photographs of public                       
            beach that extends seaward from                   San Juan County:                           access beaches. Write to Photo and              
            mean high water. Mean high water                      Cattle Point--San Juan                 Map Sales, 1065 Capitol Way South,                                                   
            delineated by deposits of kelp,                        Obstruction Pass--Orcas               Mail Stop: AW-11, Olympia, WA.                                                      
            debris and logs. If you are in an area            Island.                                    98504.    
                                                                         


                                                                                           
                                                                                                                                                


























           



                   the islanders                                                                                    ENETAI Aug 25-Sept. 8, 1980                                             chad haight

                        ORT WARD STATE PAM on the southern end of Bain-                                                                           pco       flution and threats to wildlife. Dale Spoor of the
                        bridge Island is aFrecious retreat from the populated                                                                     AuXto:Society read in impassioned plea for preservation of
                                              c
                   Find trafficked wor d around it. Ilic tree-ticred hillside                                                                     waterfront ecology and nesting habitats, asking for distinct
                   and low-bank shoreline are natural microcosms, minimally                                                                       modifications to accommodate the area's wildlife. Other at-
                   maintained, infinitcly appreciated and ecologically balanced.                                                                  tacks were made on the state's dcfinition of "recreation,"
                   The park is a wildlife sanctuary fi        ive human enjoyment                                                                 which lay immersed somewhere under concrete trails and
                   and recreation, a visible exanipleorMhat pastoral and wood-                                                                    "Maintenance-frec" facilities. Strenuous arguments were
                   land environs can be when left alone to thrive undisturbed.                                                                    directed, by Jack Cooper, at the state's assessment of the
                    Park neighbors respect the gates barring automobile traffic                                                                   plan's uinpact as   non-significant," and thus bypassing the
                   citing the parks' undevelope4 137.                 is ication for                                                              need for an Environmental Impact Statement.
                   such intrusions. Ibis assures uninterrup cd       ks, bicycle rides                                                               "How was it decided that your plan was environmentally
                   along the onc-lane roadway by the waterfront, or hikes up the                                                                  nonsignificant?" asked Cooper.
                   meandering trails that traverse the woods. Tbe still and quiet                                                                    "Because I made that cicternamiation, myself," replied
                   scenery is broken occasionally by soaring bald eagles and                                                                      David Heiser, head environmentalist for Washington State
                   hawks, the idle chatter of cormorants and gulls on nearby pil-                                                                 Parks.
                   ings and various hoots and screeches from the animals that
                                                                                                                                                     To many unhappy islanders it was a clear am of unsur-
                   take refugc there.
                     Now efforts are underway by Washington State Parks to                (a                                                      rendering appeasement by seasoned professional state plan-
                   begin incremental modifications of the park at Fort Ward,                                                                      ners who had obviously been throuFh the public forum
                   changes that are to begin soon with asphalt automobile park- a                                                                 gauntlet countless times before. Armed with documented ex.
                   ing areas and trailways, public "vault" latrines and waterside             7,                                                  pcnise and lists of prior example they calmly and methodically
                   picnic grounds before eventual implementation of RV facili-                                                                    answered questions and dispelled arguments with "proven"
                   ties, two 50-unit campgrounds and a peripheral roadway.                                                                        facts and rehearsed clarity; never bowing to tcmpcffnental
                   "We are under the gun to do something, " Larry Fankhauser,                                                                     rebuttal but instead unleashing their arsenal of state power.
                   superintendent of state parks, told a group of 40 distressed                                                                   legal precedence and "the people's will. "
                   islanders last lbursd2y at the high school.                                                                                       Ibc islanders' hopes of nullifying the proposed plan were
                     Standing in a battle zone between sets of comprehensive                                                                      apparently never an issue. The state officials had their plans"
                   blueprints of the state's proposed plans, color-coded for lim-                                                                 were obligated to hold a community hearing, but seemingly
                   minent and future prospects, and a roomful of concerned and                                                                    were not bound by local opinions or recommcnd2tons.
                                                                                                                                                  Redress was discouraged by the intertwining and confusing
                   vocal oppositon three state officials dutifully and c2teForically
                   explained the hands-tied position of the state: it is under                                                                    mandates of federal and state agencies, some no longer ex-
                                                                                 ederal                                                           isting, others far removed in Washington, D.C. and none
                   obligation to the conditions of acquisition from the f
                   government (thesark was part of the U.S. Army fort until                                                                       with any final jurisdiction over the matter. A Kitsap County
                   1962) to develop c site for recreational use; and more impor-                                                                  denial of a shoreline development license was all that the state
                   tantly, that $86,500 has already been appropriated by the                   Tom Baley                                          still needed before beginning immediate ground moving.
                   state legislature to be used before the end of the current bien-                                                                  There are few public areas that have retained a natural cohe-
                   nium, June 30, 1981. Failure to spend the money, they                                                                          sion of wilderness with limited public access. Indeed,
                   warned, would forfeit the funds and could jeopardize state                                                                     wherever man goes an altered state of affaitS exists. But in as
                   control of the park itself.                                                                                                    much as we, too, arc part of the environment, a cocxistant life
                     nc official deleg2tion's tack was straight into the wind.                                                                    form, a certain degree of "intrusion" is normal and only
                   Ibc gathering's vehement reaction could have blown' them                                                                       nominally upsetting. Fort Ward State Park is presently in such
                   into thc next biennium. Ibc officials asked for questions                                                                      a delicate balance but its frailty would be vulnerable and
                   about the specific plan and additional changes for recommcn-                                                                   threatened by skateboards, campers, noise and "main-
                   clations. What they got was something just short of total rciec-                                                               tenance-free" facilities.
                   tion of any and ail proposals, sometimes politely, often in-                                                                      The pleading words of Kenneth Brustad, whose house faces
                   toned with frustration and always e2mestly challenging.                                                                        the proposed entrance to the new 37-car parking lot, bespoke
                      Residents living near the   park objected to additional traffic,                                                            the islanders' consensus:
                   teenage noise and disturbances, concerns of sewage disposal,                                                                      "Isn't that enough?"














                                                                        4                         r




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                                                                                                                                            @7















                                                                       -,et,                                         0
                                                                                                                rl rp j% I VAIIE








       Hans Moser                                                                                                        1970 Hans Moser

                        (Great Cartoons of the World, Series Four
                           edited by John Bailey. Crown Publishers, Inc.. PI*Y. 1970)






                                    PHONEt 283-1052

                                            2919"Mayfair Ave, North
                                               Seattle, WA 98109
                                                  March 4, 1989


           Letter to the Editor, Seattle Times

           Dear Editor,
              In her letter a shorelines property owner protests
           the use of Puget Sound for salmon rearing pens, offering
           possible pollution of waters near her home as the reason
           (Times, March 2).
              Such owners use the same pseudo-environmental arguments
           to exclude people from public-owned beaches and tidelands.
           With the aid of their politicians they fight any state
           agency trying to develop beach access facilities, claiming
           that a nearby park will damage their private property
           values.
              They also battle commercial farming of mussels and
           oysters, clam harvesting, and now salmon pens. This
           privileged group claims exclusive use of property for which
           they lack legal rights, the waters, and so decimates
           public rightst state and local revenues. and jobs that
           could be developed for recreation# tourism and aquaculture
           industries. By limiting the use of waters to their
           personal enjoyment they reduce the supply of high quality
           protein food. our export market potential. Most of the
           canned seafood on grocery store shelves is imported from
           Thailand, Malaysia, or India, and may yet be salmon from
           Norway.
              What property taxes are paid for this exclusive use and
           views ? In appendices of the draft impact statement (DEIS)
           now circulating from the Dept. of Fisheries are revealing
           details. A survey study was made of 335 shorelines residential
           properties in Clallum, Jefferson, Kitsap, San Juan, and
           Skagit counties. The findings are that market values (asked
           or sold as reported by realtors and multiple listing
           services) were on average $223 per FRONT FOOT higher than
           the assessed values.







                Times Editor          Page 2


                   High value properties in San Juan County assessed
               at $305,000 have market value of $2,,000,000, Lesser
               valued properties assessed at $97,711 have market value
               of $164,000.   Similar discrepancies are common in
               those counties despite that current, full Aket value
               is the legal standard for property, assessment in Wash-
               ington.

                    Threat of salmon net pens has, not depreciated
               market values. Neither will it affect the many shore
               properties owned by the elite of the state's social.
               political and financial world who are able to prevent
               any salmon pens sited in their vicinity.

                     Officials of the Departments of Natural Resources
               and ]Fisheries are to be commended for efforts to enhance
               economic value of our natural resources and distribute
               these for benefit of the people of' the state. They
               deserve our support.


                                            Very truly yours,



                                             Ms Benella Caminiti









                                                    A 16 The Seattle Times           Thursday, March 2, 1989


                                               SALMON-PEN BATTLE

                                               Please, keep them away
                                               from my waterfront home
                                                   As a waterfront owner, I have been
                                               =
                                                           owing the continuing saga of
                                                         n" pens. It's been called a battle,
                                               and that is true.
                                                   Brian Boyle, commissioner of public
                                               lands, wants to raise money by leasing
                                               fish pens he says in order to develop
                                               water-related public areas. To do this, he
                                               is going to destroy the privately held
                                               lands.
                                                   Around Whidbey Island, all areas
                                               zoned for fish pens are immediately upon
                                               the sandy shores.
                                                   Boyle says the fish-pen developers
                                               want to come in because of our pure
                                               water. How long would it stay pure with
                                               the salmon pens in place? Even the new
                                               study done by the Fisheries Department,
                                               which is lauded as sayingrns      are good
                                               and won't pollute the       y  in general,
                                               does admit that, in the wrong place or
                                               when poorly run, they can cause environ-
                                               mental problems.
                                                   "Fish feces and uneaten food can
                                               accumulate on the bottom and deplete
                                               oxygen, maldrig the sediment and water
                                               toxic, etc." This is what Gov. Gardner
                                               wants to put right by a beach where
                                               children play? Please!
                                                   In addition, the same report says
                                               these pens cause odors and algae bloom.
                                               Should this be placed in residential
                                               areas? Even if the tide washed some
                                               effluent away, it would only go onto the
                                               shores.
                                                   This is the main reason for the
                                               salmon-pen battle - not visual problems,
                                               although those are important too.
                                                   The state says careful siting will take
                                               care of all the problems. All right, be
                                               careful and don't place salmon pens by
                                               waterfront residences.
                                                              Jacqueline Maner, Everett






       In 3 years in the Philippines. and the 2-fold and 4-fold
       increases in Romania and Poland. respectively, in 3                                   help to rehabilitate depleted natural stocks of certain
       vears.                                                                              sport and cornmercial fishery species:
                                                                                           -P introduce and maintain new commercial and recrea-
       -he importance of aquaculture in food production is
                                                      W                                    tional fisheries where they did not exist before;
       Derhaps best illustrated by the example of China. In his                              provide bait for recreational and commercial fishing;
       '975 survey, Pillay@' ranked China first in aquaculture                               convert low grade "trash fish" and organic waste
       :)roduction, with an estir-nated total yield ot some 2.5                            products into high grade animal protein for human
       -nillion metric tons. This amounted to about 40 percent of                          consumption;
       *otal estimated world production by aquaculture. More                               4o produce materials (e.g., pearls) for industrial applica-
       @ecently. however, Ryther*1 visited Chinese aquaculture                             tions;
       'acilities and estimated that annual production from fresh                          lk increase production of ornamental fish for domestic or
       ,vater aquaculture in China might approach 17.5 million                             export pet markets;
       metric tons! Marine aquaculture production was much                                 o assist in solving waste water treatment and energy
       smaller. but growing. If Ryther's estimate is more nearly                           production/conservation problems;
       @:orrect, then this one country's aquaculture production                            4, assist in the diversification and integration of farming
       -s more than four times that of the rest of the world                               operations-, and
       combined and equivalent to approximately 25 percent of                              41 increase domestic revenues and provide significant
       ,oday's total world fishery production.                                             agrarian employment opportunities.
       Even in the United States, which is not traditionally a                             However, as Pillay" has pointed out, much of this
       nation of fish eaters. aquaculture is quite significant.                            potential will remain unrealized without massive infu-
       producing more than 151,000 metric tons of fish and                                 sions of capital, much expanded extension programs for
       shellfish annually." Here private aquaculture alone pro-                            technology transfer, accelerated research and manpower
       juces some 78.000 metric tons of fishery products. which                            training efforts, and development of the necessary infras-
       3mounts to about 3 percent of the U.S. fishery landings                             tructure. Recognizing this, the FAO Technical Confer-
       and 2 percent of U.S. consumption of fishery products.'                             ence on Aquaculture, held in .12@@n Kyoto, Japan,
       This private production includes over 40 peicent of our                             adopted the following declaration in an attempt "to
       supply of oysters. 50 percent of our catfish and crawfish,                          elevate aquaculture to an appropriate level in national
       nearly 100 percent of ouir rainbow trout, pius smaller                              and international priorities:"19
       quantities of several other species.9 In addition, 30                                           Kyoto Declaration on Aq!_#aCt.,1r,_;r=2C
       ,,I,ercent or mofe of all Pacific salmon landed in the U.S.
       originated in public or private hatcheries.2 Besides these,                         "The FAO Technical Conference on Aquaculture, as-
       public (especially) and private aquaculture operations                              sembled in Kyoto, Japan, on 2 June 1976, after a week-
       sustain major recreational fisheries for troot, salmon,                             long review of present status, problems, opportunities
       striped bass, catfish and a number of other species.                                and potential -for the culture of fish, crustaceans, mol-
       These recreational fisheries   are probably worth, conser-
                                      ns of dollars. Nso, much of
       vatively. hundreds of millio                                                        Itiscs and seaweeds, declares:
       the substantial U.S. production of ornamental fish is                               (1) That aquaculture has made encouraging progress in
       through aquaculture.                                                                  the past decade, producing signficant quantities of
                                                                                             food, income and employment; that realistic estimates
       What Can Aquaculture Do In The Future?                                                place future yields of lood at twice the present level in
                                                                                             ten years. and five times the present level in 30 years if
       Based on his production estimates for           1975, Pillay",                        adequate support is provided.
       projected a doubling of aquaculture production by 1985                              (2) That aquaculture, imaginatively planned and intelli-
       just with expanded application of available technology                                gently applied, provides a means of revitalizing rural
       and a 5 to 10-fold increase by the year 2000. Such                                    life and of supplying products of high nutritional value,
       production levels could easily amount to 30-50 percent or                             and that aquaculture, in its various forms. can be
       more of total world fishery production, considering                                   practised in most countries, coastal and land-locked,
       present estimates of fishery potential and the aquaculture                            developed and developing.
       production example of China. In the U.S. a!one, aquacul-                            (3) That aquaculture has a unique potential contribution
       ture production has been projected to increase to per-                                to make to the enhancement and maintenance of wild
       haps as much as 1 million metric tons by the end of the                               aquatic stocks and thereby to the improvement of
       century.9 Thus, I believe that aquaculture can:                                       capture fisheries, both commercial and recreational.
                                                                                           (4) That aquaculture forms an efficient means of recy-
         contribute significantly to the animal protein resources                            cling and upgrading iow-grade iooa materiais an-
       of developing and developed countries;                                                waste products into high-grade protein-rich food.
       - increase signficantly the production of luxury seafoods                           (5) That aquaculture can, in many circumstances, be
       such as shrimp, salmon, lobsters. oysters, etc. for domes-                            combined with agriculture and animal husbandry with
       tic consumption or export:                                                            mutual advantage, and contribute substantially to
       o increase opportunities for and revenues from recrea-                                integrated rural development.
       tional fishing and shellfishing:                                                    (6) That aquaculture provides intellectual challenge to
                                                           v. 13 ri. 3     .4 -At; :9 T,*Er,",N( 1krY @;CCT:@Ty
                                                                                 R. Saandl   Ier                   XURNAL          vol. 13. .35-39,
                                                                                                                                    1979
                                                                                 necesslly for AqtuLcuilture .1eV-1o?--MPnt."









           RESPONSE TO LETTER NO. 63: BENELLA CAMINITI



           1.     Comment noted.


           2.     Comments noted. Evaluation of the current status of wild runs of salmon and the
                  measures necessary to protect them and restore them to historical levels are
                  outside the scope of this EIS.

           3.     See the response to Comment 2 above.

           4.     See the response to Comment 2 above.

           5.     See the response to Question 11.

           6.     Comments noted. A discussion of existing regulations and guidelines has been
                  incorporated into the FEIS.

           7.     Comments noted.

           8.     Evaluation of failing septic systems and their effect on water quality is outside the
                  scope of this EIS.

           9.     Comments noted. Evaluation of the status of wastewater discharge from Puget
                  Sound communities is outside the scope of this EIS.

           10.    Evaluation of the impact of organic tin (TBT) at marinas, relative to boat painting
                  activities, is outside the scope of the EIS.       Tributyl tin compounds are in
                  extremely low concentrations in the water and do not pose a threat to pen fish.
                  Higher concentrations are found in some sediments, but farm fish do not come
                  in contact with sediments since the pens do not extend to the bottom.

           11.    Comments noted.

           12.    The purpose of the EIS is to evaluate the commercial culture of fish in floating
                  fish farms in the Puget Sound region. An equivalent evaluation of fish from
                  hatcheries is beyond the scope of the EIS.           However, the subject of the
                  interaction of hatchery and wild stocks has been studied in other reports. Contact
                  VVIDF for further information.


           13.    Comments noted.


           14.    Comments noted.


           15.    Comments noted.





                                                                                LEITER NO. 64

                                                             CLALLAM COUNTY
                                                        COMMISSIONERS' OFFICE

             00 FIE,  LL                                               COURTHOUSE
                                                                    I EAST FOURTH STREET
         'Pt 0                   afik

                                                             PORT ANGELES, WASHINGTON 98362-3098

                                                                   (206) 452-7831. EXT. 233
    BOARD OF COUNTY COMMISSIONERS                                     SCAN 575-1234


    DAVE CAMERON, DISTRICT I
    DOROTHY DUNCAN, DISTRICT II
    LAWRENCE GAYDESKI, DISTRICT III


                                                                March 28, 1989



         Mr. Ron Westley, Project Manager
         Washington State Department of Fisheries
         General Administrative Building
         Olympia, WA 98504

         Dear Mr. Westley:

              Thank you for the opportunity to review the Draft Programatic
         Environmental Impact Statement regarding fish culture in floating net pens.
         Clallam. County looks forward to the development of a Final PEIS and,
         eventually, the adoption of siting guidelines for floating net-pen aquaculture by
         the state.

              The Board of Clallam. County Commissioners believes the following items
         should be addressed in the Final PEIS:

              - During numerous permit applications    'for salmon net-pen facilities in
              Clallam. County, there has been testimony to the Board to the effect that
              the Atlantic Salmon will consume juvenile salmon and herring attracted to
              the shelter of the pens.

              - There has also been testimony to the effect that these facilities attract
              baitfish and blackmouth to hold under and around the pens, thereby
              limiting their availability to sports fishermen.

              - Although there is a very detailed'description and analysis in the DPEIS
              of the potential hazards of disease, including the introduction of exotic
              diseases and the transfer of disease from penned fish to wild stock, this
              issue has been brought up continuously by concerned citizens.

              Because of these concerns, a more detailed description of the impacts of
              disease is warranted.    This description should include an analysis of
              existing regulations governing the control of disease in the State of
              Washington and the agencies which are mandated with this regulatory
              function.






          Letter to Ron Westley
          Draft PEIS, Floating Aquaculture
          Page 2


               Once again, Clallam County appreciates the opportunity to comment on the
          Draft PEIS and looks forward to reviewing the final document. If you have any
          questions regarding the above information, please contact the Commissioner's
          Office or Grant Beck of the Department of Community Development at 452-7831,
          ext. 324.


                                                 Sincerely,

                                                 Board of Clallam County Commissioners
                                                 Amx,
                                                 Dorothy Ijun'can, Chair



                                                 bave Cameron


                                                I-awrence Gayddpd



          C.   Grant Beck, Associate Planner
               Shoreline Advisory Committee


          corre: westley. doc









          RESPONSE TO LETTER NO. 64:              BOARD OF CLALLAM CO
          COMMISSIONERS                                                                   CU


          1.    See the response to Letter 32, Comment 4.

          2.    Sports anglers can fish around the farm. Fish farms would not attract a
                significant percentage of salmon to make a difference to sports anglers.

          3.    Comment noted. See the response to Question 29.





                                                                                                                                                                       LETTER NO. 65

                                                 CLALLAM COUNTY
                                                 ECONOMIC DEVELOPMENT COUNCIL


                 102 E. FRONT 0                         R 0. BOX 1065 0                         FORT ANGELES, WA. 96362                                           (206)457-7793







            OFFICERS:
            President                                        March 27, 1989
              Frank Ducceschl, Publisher
              Peninsula Daily News
            Vic@ President
              Bert Paul, Manager                             Ron Westley, Project Manager
              Forks Thrifty Mart                             Washington Department of Fisheries
            Secrotary/Trossurer                              115 General Administration Building
              Larry Lynam
              Assistant Vice President                       Olympia, WA 99504-6642
              Seafirst
            Past President                                   RE: Draft Programmatic Environmental Impact
              Kathy Northrop, Agent
              State Farm Insurance                           Statement: Fish Culture in Floating Net Pens
            Executive Director
              Kurt D. Sandell                                Dear Mr. Westley:
            DIRECTORS:
              Bob Barr, Owner                                The Clallam County Economic Development Council views
              Barr & Associates                              aquaculture in various forms as an extremely promising
              Ed Beggs, Mayor
              City of Sequim                                 industry for future economic diversification in our county.
              Gary Colley, Attorney                          We have worked with many net pen proposals during the
              Pon Angeles Chamber                            past several years and now have four years' experience
              Pa I Cornaby, President
              Peuninsula College                             actually living with Sea Farm Washington's two facilities in
              Dorothy Duncan, Commissioner                   Port Angeles harbor. We understand that the industry is
              Clallarn County                                not without potential problems and limitations, but our
              John Forster, Manager
              Sea Form Washington                            experience with well-sited pens operated under professional
              Gwen Frady                                     management has confirmed our assessment that these
              Sequim-Dungeness Chamber                       facilities can be a valuable addition to our local economy.
              Judy Hosto
              Forks Chamber                                  Most of the mitigating measures proposed in the DPEIS are
              Frank McPhee, Mayor
              C14 of Port Angeles                            measures which a professional, prudent fish farmer would
              Dennis Otterstetter                            need to adopt for good fish husbandry. In fact, it is fish
              Central Labor Council                          farming's need for continuing high water quality that makes
              Warren Paul, Mayor
              City of Forks                                  it compatible with so many of the other demands on our
              John Robben, Director                          marine resource. How often do mitigating measures imposed
              Business Development                           on an industry also lead to higher productivity?
              Jamestown-Kiallam Tribe

              John Ryan
              Clallarn Bay-Sekiu Chamber                     We have two specific comments: 1) The discovery of VHS in
              Lucille Schmitt, Partner                       two hatchery facilities in the state necessitates an update in
            e9
































              Thompson Mackellar                             the discussion of fish diseases. Again, it is important that
              Ted Simpson, Commissioner
              PLID No. 1                                     a standard, factual reference be available for decision
              Ted Spoelstra, Commissioner                    makers regarding the interaction of this virus with net pen
              Port of Port Angeles                           farming. It is also important that panic regarding this
              Russ Thomas, President
              Pay & Save Foods                               virus not be allowed to cloud discussion of other net pen
                                                             issues.















            2) We have also recently worked with a firm proposing a land--based tank
            farm in Clallam County, and suggest that the discussion of suitable Bites
            emphasize the rarity of, such sites. There are two site requirements not
            mentioned in the DPEIS which further limit suitable sites: The water offshore
            must meet very high standards, and there must be a high level of assurance
            the quality will remain high for about 20 yearE;. The level of investment
            cannot be made unless the facility can operate for at least that long. The
            other factor limiting sites which might be phyidcally suitable is the interest of
            the landowner in even considering such facilities.

            The DPEIS is an important step forward in bringing some standard basis of
            factual information to discussion of net pen facility development. A major
            impediment to the development of the industry has been lack of a standard
            reference for information about issues that rightly concern the citizens of the
            state: especially water quality and protection of other marine life. But how
            many proposals which can enhance rural economies would   result in the "no
            impact". or "low impact" conclusions that the DPEIS reaches regarding fish
            farm impacts? We will continue to encourage Clallam County residents to adopt
            an accommodating attitude to the visual and navigational concerns that arise.

            We urge your early adoption of a Final Programmatic. Enirironmental Impact
            Statement.


            Sincerely,
            Marga t :fford
            Assistant Director
            Marga rtC









          RESPONSE TO LETIrER NO. 65: CLALLW COUNTY ECONOMIC DEVELOPME
          .COUNCIL


          1.    See the response to Question 29.                                                U
                                                                                                0
          2.    Comments noted. Both floating fish farms and land-based tank farms require high
                quality water for their operations. A thorough evaluation of tank farms, however,
                is outside the scope of this FEIS.





                                                                  LETTER NO. 66





         April 1, 1989


         Ron Westly
         Dept. of Fisheries
         115 Gen. Admnin- Building
         Olympia, WA. 9850q


         Dear Sir;

               I appreciate the extension For public comment regarding the
         fish pen controversy your department has seen Fit to grant.
         With the rapid deterioration of water quality becoming an ever
         increasing reality, its time that government agencies stop
         treating our bays and oceans as dumping grounds, rearing pens and
         shipping lanes for gross profits at the expense of those who in
         the end must pay when things go wrong. The sad Fact is that
         "public comment " is usually disregarded while the "experts" rush
         head First into a controversy with little or no thought or
         preparation For what can be a disastrous end. To wit: Valdez AK.

               The relationship between an oil spill and a fish pen can be
         a very close one when you realize and ponder the nature of nature
         itself. Atlantic Salmon are being raised in pens of Pacific
         waters because the "Atlantic coast slips toward being a
         biological desert." to paraphrase a headline in the (1f12)
         Seattle Times. We can no longer accept the mentality that
         allows the disturbance of our waters in any way, shape or form.

               To permit a Canadian Firm the right and license to install
         fish pens in Kiket Bay against the wishes of the people of Skagit
         Co. and specifically the property owners in the surrounding region
         is as gross a violation as permitting oil tankers to be built without
         double hulls. The magnitude may differ "when somethig went wrong",
         but the blatant arrogance is an outrage none the less.

               In the past twenty years there have been nearly ten seperate
         Acts of Congress written to deal with and minimize ocean dumping
         and polluting, from the Ocean Dumping Act to the Water Quality
         Act. But the dumping and mismanagement of industries responsible
         goes on. We have the power to deplete our coastal waters of the
         oxygen that is vital to sustain sealife. Do we have the power to
         stop?




                                                Yo S Tru
                                                  14 s Tru

                                                       Sn

                                                        e
                                                  r yj
                                                 0




                                                 a
                                                 S20         s Rc
                                                              - 98E
                                                 a Conn
                                                             1@
                                                Lar y      n e
                                                         1 n
                                                1S20 Sn e-oos Rd.
                                                         , WA
                                                La Conne        982S7
                                                466-3q3l








        @O            RESPONSE TO LETTER NO. 66: LARRY COLLINGE
        m                                                                                   --
        rA

        0
        CA            1.        Comments noted.
        m
        F-P,
        0
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                                                                                                                                                                       I
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                                                                           LETTER NO. 67


                                 DEPARTMENT OF THE ARMY
                               SEATTLE DISTRICT. CORPS OF ENGINEERS
                                          P.O. BOX C-3755
                                   SEATTLE, WASHINGTON 98124-2255


                REPLY TO
                ATTENTION OF

                Planning Branch





                Ron Westley, Project Manager
                Washington Department of Fisheries
                115 General Administration Building
                Olympia, Washington 98504

                Dear Mr. Westley:

                    We have reviewed the draft environmental impact statement
                (EIS) for Fish Culture in Floating Net Pens with respect to the
                U.S. Army Corps of Engineers' areas of special expertise and
                jurisdiction by law as designated by the President's Council on
                Environmental Quality on December 21, 1984.

                    Technical Appendix F. Regarding permits which may be required
                for an aquaculture project, change the wording "Dredge and Fill
                Permits" to "Section 10 Permits." Generally, net pens do not
                require dredge or fill, but do require a Department of the Army
                permit under Section 10 of the Rivers and Harbors Act. Contact
                Sam Casne at the Regulatory Branch at telephone 764-3495 for
                further information.


                    Page 87, First Paragra . Clarify that the USFWS can
                recommend that conditions be attached to a permit. Final
                responsibility in this regard rests with the Corps of Engineers.

                    The following are offered as general observations and in the
                interest of improving the EIS.

                    o There are proposals in existence to site net pens for
                salmon rearing (including Atlantic salmon) in freshwater--
                specifically, at Lake Rufus Woods, at Chief Joseph Dam on the
                Columbia River. Suggest the final EIS include a brief overview of
                such proposals with some emphasis on potential differences with
                respect to key issues (water quality, benthic impacts and escape
                of reared fish, for examples).

                    o Page 19, first paragraph: Second sentence should read
                       at different depths in the sediment . . . " Should the
                fourth sentence be changed T77I_n,organically enriched sediments
                      (as opposed to oxygen-enriched)?









                                                  -2-





                       a Page 23, the last two lines: It appears the units in the
                  mathematical equation may not be accurate-should it really be hz
          0       carbon/m/yr (or g carbon/m/day)?
          0            op Page 67, line two: A word seems to be missing here.
                       a. Page 75: The fact of a successful introduction of Atlantic
                  salmon in Argentina is evidence that, while establishment of this
          0       species outside its normal range is unlikely, it is possible.
                  This indicates the need for extreme caution in setting up any new
                  operation. The presented guidelines look good.

                       4) Page 114: The mitigation for commercial fishery issues
                  states that pens should be aligned parallel with shore. However,
                  the organic waste mitigation guideline (page 26) states that pens
                  should be oriented perpendicular to currents. Since currents
                  often run parallel to shore, there seems to be a conflict between
                  these two guidelines.

                       lo There are several typographical errors, including the
                  generic name for lingcod on page 66 (should be Oph..;odo , not
                  2plIL)clon).

                       r
                       Thank you for the opportunity to review this statement.

                                                   Sincerely,
                                                  XFrederl;@@
                                                          ck C
                                                   Chief, Environmental Resources
                                                     Section










                                                                                                       IrA
           RESPONSE TO LETTER NO. 67: UNITED STATES ARMY CORPS OF ENGINEERS


           1.     The text has been revised.                                                           0

           2.     See the responseto Comment 1.

           3.     Freshwater aquaculture is outside the scope of this EIS.

           4.     The text has been revised for clarification.

           5.     Weston and Gowen (1988) report units of kg carbon/n-?/yr. Note, the values
                  reported in the EIS differ from the Weston and Gowen report in units of kg
                  carbon/n?/yr, but are the same as the Weston and Gowen report in units of kg
                  dry wt./n?/yr. The values have been modified to agree with Weston and Gowen
                  (1988).

           6.     See the response to Comment 1.

           7.     Comment noted. Despite numerous efforts to establish a run of Atlantic salmon
                  in the Pacific Northwest, all efforts have failed.

           8.     See the response to Question 10.

           9.     Comment noted. The document has been proofread in an attempt to eliminate
                  typographical errors.





                                                                    LETTER NO. 68




              Thomas Crolevo MD
              16407 Olympic View Rd. NW
              Silverdale, WA 98363
              (206) 692-1444

              21 March 1989

              Donald Weston
              Project Manager
              Washington State Department of Fisheries
              115 General Administration Building
              Olympia, WA 98504


              Dear Sir;



                   I am writing in response to the recently release Draft

              Programmatic Environmental Impact Statement (DPEIS),        Fi5h

              Culture in Floating Net Pens published by the Washington

              State Department of Fisheries, January 1989. 1 have had the

              opportunity to read this document in detail, and consider

              it at length. I will comment on what I consider to be its

              substantial incon-51stencies, conflicts, and inaccuracies.



              1. Conclusions reached by the DEPIS often appeared to be

              incompatible with the data presented in the report.           The

              term "significant" was used to verbally mitigate negative

              impacts.    What are the parameters used to establish the

              threashold of significant3 in each instance and how and who

              established them? Has this broad-brush approach    been used to

              avoid acknowledging negative impacts mentioned in the PDEIS

              and those eazily demonstrated at currently existing @sites?

              Common sense would lead one to believe that similar negative

              environmental effects could occur at new not-pen sites. An




                                         Page - 2







              example can be made of the reported effects of feces and

              uneaten food fallout upon benthic oxganiams located beneath

              net-pens. Some currently existing :sites have resulted in an

              azoic zone beneath net pens.        Y15t,  this profound And

              devastating change in      the local     environment is      not

              considered significant if it does not impact         Mmerciallz

              important   species.    I    disagree    with   the      reports

              interpretation of the observed effects. The report should

              not be limited to economic parameters. Setting thresholds cf

              what is concidered significant MU,5t honestly reflect the

             .effects on all species at the site. The same argument can

              be made regardihg, aesthetics, risk to indigenous species

              (e.g. VHS.), escape, recovery after removal and upland

              developemnent    associated     with   net-pen      opperationa.

              Perspective provided by the report is too narrow and favors

              commercial over environmental interests.



               2. The main contractor of this report, Parametrix, has also

              produced a DEIS for International Marine Farms (IMF),and

              their proposed Harding Creek Aquaculture Project in Kitsap

              County. How can the. public be reassured that a coporation

              working for salmon culture industry, will be able to

              produce and interpret data that is unbiased, and make

              interpretations from a perspective that does not favor

              industry and developement interests.           The fact     that

              Parame-trix is working for both the State and IMF leads to an

              immediate impression of conflict of interest. The suspicion





                                       Page - 3






           of conflict of interest is hightened by the conclusions of

           the report.







           3. No recommendations were made regarding monitoring of

           future aitez, and      no stratgies were discussed regarding

           what action could or would be taken in the event that built

           sites were found to be negatively impacting the surrounding

           environment. This omission is particularly surprizing and

           disturbing when one sees data presented which casts doubts

           on the accuracy of predictive models. (See page 26 and the

           dicusaion regarding the model of fallout from the pens        and

           comments which indicate that it is not predictive in          all

           cases).     if     pre-ziting current measurements are        not

           completely reliable or predictive, then monitoring              is

           essential. If      surprizes   are found,      such   as   those

           demonstrated at the Squaxin Island site, then all parties

           involved should know what actions will be taken in the event

           of unexpected outcomes.     This type of approach would be in

           the best interests of all those involved, developer, and

           resident &like.



           These comment reflect a global pattern in thia report.          it

           seems to attempt to juztify events that have clearly shown

           to be problematic... even in its own text. I would write the

           conclusions in the following manner!




                                            Page - 4










                            1.   Impacts of net-plen culture cannot be

                            prevented, and not all impacts can be

                            acurately predicted.



                            2.   Although the impacts of net pens are

                            reversible it may take many years for

                            affected areas to revert to their undistrubed


                            state.




                            S.   Unchanged.



                            4.   Siting of 100 farms would have impacts

                            on the aquatic environment. Small bays would

                            certainly be more severely affected.



                       This reports sould be reconsidered and the conclusions

                  redrawn prior to acceptance.     I would also hope that the

                  State will encourage further comment from the public in the

                  form of more public meetings and an extended period of

                  written comment. The adoption of this -technology in a wide

                  spread fashion 5t@ggested     by the reports       conclusions$

                  represents a step that should be taken very cautiously

                  irrespective of pressures for economic development.       These

                  projectz will probably draw outside capital and thuz lead to

                  outside profit. The working public will be offered few jobs

                  which pay less that average pay. The risk benefit ratio





                                      Page









           will be high and I question that this report in its current

           form will lead Washington State in the proper direction.




                                                Sincere               P.




                                               T
                                               T om    C 61ey, HD
                                                 ,@ncere
                                                 omaz C
                                                       V
                                                    az









              RESPONS P, TO LETTER NO. 68: THOMAS CROLEY


     W        1.     The word "significant" has a specific meaning in a SEPA document. A significant
                     impact is one that has "a reasonable likelihood of more than a moderate adverse
     0               impact on environmental quality' (WAC 197-11-794). SEPA also states that "EISs
                     need analyze only the reasonable afternatives and probable adverse environmental
                     impacts that are signific  (emphasis added) (WAC 197-11-402, [1]). The authors
                     of the EIS included a discussion of the issues of concern that were identified
                     during the scoping process.

              2.     See the response to Question 2.

              3.     The development of monitoring programs is not within the scope of this EIS. A
                     monitoring program would be a component of a management plan for the fish
                     farming industry.

              4.     Comments noted.

              5.     Comment noted.    See the response to Question 7.

              6.     Comment noted.





                                                                       LETTER NO. 69
                          b wt@ap lawiwf

                              LaConner, Washington 98257
                                   LaConner (206) 466-3114
                                   Everett (206) 259-4163




                                   March 28, 1989



           Mr. Ron Westley, Project Manager
           Washington Department of Fisheries
           General Administration Building
           Olympia, Washington 98504

           Re: Draft E.I.S. Fish Culture in Puget Sound

           Dear Mr. Westley:

           I would like to take this opportunity to comment on the draft
           E.I.S., Fish Culture in Floating Net Pens beginning on page
           103:

                1. Paragraph 3 suggests that towboats primarily use the
                   main shipping lanes. This is true for barge work but
                   when towing log rafts a tug will spend very little
                   time in the designated traffic lanes. Tugs with log
                   tows hug the shoreline to make use of favorable tidal
                   conditions as they move throughout the navigable
                   waters of the state.

                2. Page 104, paragraph 3 indicates that commercial
                   vessel traffic tend to stay in deeper water thus
                   avoiding areas where fish pens would be located.
                   It is my understanding that fish pens require a
                   minimum of 45 ft. of water, a depth which we consider
                   navigable. our log boats have a maximum draft of 12
                   ft. which is more than the log tow. We routinely tow
                   in water depths of 35 ft. or less.

                   Net pens can hardly be compared to a long dock or
                   marina. In some instances they can be located in
                   excess of 1000 ft. from the shore as in the case of
                   the proposed net pens in Discovery Bay. This would
                   create a much greater hazard to navigation than the
                   paragraph suggests.

                3. Page 105. d. There are unavoidable impacts that can't





                                                    e, amr=owo

                                 LaConner, Washington 98257
                                      LaConner (206) 466-31,14
           -I""?                       Everett (206) 259-4163



                                      March 28, 198S,



                     be mitigated that are especially threatening to our
                     operations. It should be pointed out that the
                     affected waters are all waters of the state, not just
                     Puget Sound as the E.I.S. suggests.

             I appreciate the chance to comment on the Draft E.I.S. put
             together by the Department of Fisheries. More consideration
             must be given to our concerns over navigation because it is
             an integral part of the economy of Washington State.



             Sincerel


             J;V-M Sary ord
             Dunlap 'Towing
                     porAd










           RESPONSE TO LETTER NO. 69: JIM SANFORD


           1.     The FEIS acknowledges that tugs towing log rafts will hug shorelines as conditions
                  warrant. The potential impacts to navigation are determined by the USCG as
                  part of each ACOE Section 10 permit.

           2.     Comment noted.

           3.     As stated in the same paragraph from which you quote, "The further offshore the
                  structure is located, the greater the navigational risk . .

           4.     While it is true that fish farming operations can be operated in a variety of
                  aquatic environments, the scope of this document is floating fish farms in the
                  Puget Sound region.





                                                                             LE"ff ER NO. 70
                                                STA r



  CHRISTINE C). GREGOIRE
       Director


                                         STATE OF WASHINGTON

                                   DEPARTMENT OF ECOLOGY

                        Mail Stop PV-11 9 Olympia, Washington 98504-8711 9 (206) 459-6000




                                             April 7, 1989







               Mr. Duane E. Phinney, Chief
               Habitat Management Division
               Washington.Department of Fisheries
               115 General Administration Bldg.
               Mailstop AX-11
               Olympia, WA 98504

               Dear Mr. Phinney:

               Thank you for the opportunity to comment on the Draft Programmatic
               Environmental Impact Statement on Fish Culture in Floating Net Pens.
               Following are our major comments on the DEIS. I have also attached a
               set of specific staff comments.

               The purpose of an EIS should be to provide decision makers with the
               information and analyses necessary to make decisions which might affect
               our environment. This document presents a great deal of good data. The
               compilation, collation and presentation of this data under tight time
               frames is particularly commendable.

               However, the wording regarding the lack of impacts from up to 250 acres
               of net pens should be reconsidered. Without saying how or where these
               would be sited, it leaves people with the impression that the State of
               Washington has concluded that 250 acres are acceptable. This could
               propel aquaculturists in actions based on a misunderstanding of overall
               approval.

               Secondly, this draft does not clarify the necessary management and
               policy issues. (The most serious question concerns the need for a
               program to develop net pen siting criteria.) To be useful to state and
               local officials, the FEIS should compare the environmental effects of
               different management approaches. The alternatives as written and
               analyzed do not lend themselves to impact comparisons since they all
               display the same lack of impacts.

               We would urge that a commitment be made to address differing management
               schemes to meet a common objective. For instance, alternatives could be
               built around the objective outlined on page 2 which is to manage the
               industry to ". . . assure farms are located in appropriate areas and











                 Duane E. Phinney
                 April 7, 1989
                 Page 2



                 operated in a suitable manner to prevent unnecessary impacts even if
                 these impacts are deemed to be non-signifLcant." Under this objective,
                 possible alternatives and subsequent analyses of mitigation measures
                 could be:


                      1.   Case by Case Approach: A management approach which would
                           require the evaluation of each proposal using modeling or
                           other approved techniques to determine anticipated impacts.

                      2.   State Siting Criteria: An approach which would establish
                           siting and operating standards which any proposal would be
                           required to meet. This alternative would be similar to
                           adopting the interim guidelines as mandatory regulation.

                      3.   Local Governmental Management Approach: This approach
                           envisions minimal state regulation and non-mandatory
                           guidelines. State requirements would basically be geared to
                           specific permit and leasing authorities of state agencies.

                 The document would lend itself to discussion of these alternatives.
                 Under these alternatives, each "environment" section would discuss the
                 relative environmental consequences of these alternative approaches.
                 Even if no preferred alternative were selected, such a discussion would
                 move us towards committing to the management framework that should
                 follow. Perhaps an introduction could carry the message of a commitment
                 to pursue an evaluation of management approaches.

                 In addition, we note there are references in the DEIS to requirements
                 currently in place regarding new and existing net pens (page 40).
                 However, the exact nature of these and other requirements and thus the
                 degree of public and environmental protection afforded is not contained
                 in the DEIS. The background statement should contain a stuamary of
                 existing rules, policies and programs which relate to net pen management
                 to be used as a common basis of departure.. This should include a fuller
                 discussion of the legislative background leading up to this EIS.

                 The FEIS should include general discussion of the public policy issues
                 associated with private use of a public resource. This would give the
                 reader and decision makers a better understanding of the nature of the
                 controversies and provide general guidance. Economic activities of a
                 permanent or semi-permanent nature occurring on public lands or, in this
                 case, on public waters are not necessarily governed nor should they be
                 governed by the same criteria as economic activities on privately owned
                 property.











                Duane E. Phinney
                April 7, 1989
                Page 3


                Again, thank you for the opportunity to comment. If you should have any
                questions, please contact Marvin Vialle at (206) 459-6018.

                                                      Sincerely,




                                                      Steve Hunter
                                                      Assistant Director
                                                      Central Programs & Enforcement


                SH:v
                0405b


                Enclosures


                cc:   Kaleen Cottingham, OFM
                      Carol Jolly, WDOE
                      Dick Cunningham, WDOE
                      Greg Sorlie, WDOE
                      Stan Springer, WDOE
                      Marvin Vialle, WDOE





















                                DEPARTMENT OF ECOLOGY STAFF COMMENTS


                          ON DRAFT PEIS - FISH CULTURE IN FLOATING NET PENS




                   Editing - an editorial review is needed to correct redundancies,

                   typos, etc. Some examples are:



                   Misspellings and typographical errors - the word "'south" should be

                   I'Sound: in the 3rd paragraph of page 33.



                   Incomplete sentences - lst sentence of 4th paragraph of page 49; lst

                   sentience of 4th paragraph of page 59.



                   Incorrect conversions of units and measures - 3rd paragraph of page

                   28, 6 knots - 3.1 m/sec, not 6 m/sec; 41--h paragraph of page 55, 56.8

                   g/day should be 56.8 kg/day.



                   Authoritative statements are often made without supportizrig evidence

                   or documentation. For example:



                   4th sentence of final paragraph of page 7 ("These stocking ... ff).



                   8th sentence of 3rd paragraph of page 24 ("Net pens











                  6th sentence of 2nd paragraph of page 40 ("Ammonia and    ... 11).



                  3rd sentence of 3rd paragraph of page 43 ("Current speed    ...



                  5th and 6th sentences of 5th paragraph of page 45 ("If the



                  5th sentence of 3rd paragraph of page 138 ("A dilution ...



                  Literature citations under "IV. REFERENCES" (pg. 149) are

                  inconsistent, incomplete, or missing altogether. For example:

                  Gowen and Bradbury, 1988 (pg. 13); Heggberget 1988 (pg. 69); and

                  Asgard et al 1988 (pg. 136).



             The following review comments are less general in nature and are

             presented in paginal sequence:




             Section       Page      Comment




             Summary         x       8th paragraph: Unavoidable impacts were noted

                                     (aesthetics and navigation).



             I.A&D         2,8       The basis for the upper range of industry

                                     development (100 farms) should be given earlier

                                     than page 131 (last sentence of 5th paragraph).

                                     Also, the phrase "within the next few years" should

                                     be defined.














              I.B            4      The HIS should evaluate the potential impacts of

                                    delayed-release pens because: 1) they have been
               0                    sited in restricted Puget Sound waters (pg. 49);
                                    and 2) WDF has proposed to greatly expand their use

                                    as part of a long-term. fishery enhancement program.



                             4      Paragraph 4 states that all new net pens are

                                    limited to ... less than two acres. Who limits


                                    them, who enforces, etc.?




                             9      Not all permits issued by state and local

                                    government are subject to SEPA.




                             9      Suggest combining Shoreline Management Act and

                                    Substantial Development Permit under common

                                    heading. Also "substantial development" permit

                                    should be corrected to "shoreline" permit to

                                    include other types of' required permits.

                                    Concerning such permits "uses and" should replace

                                    "development" in the corresponding paragraph.



                             10     An addition to the reference to Waste Discharge

                                    Permit (RCW 90.58) on page 10 would amplify and

                                    clarify the intent of the Department of Ecology.

                                    We suggest that the last sentence Of this paragraph

                                    be deleted and the following inserted: "These













                                    standards will include requirements for sediment

                                    dilution zones for discharge activities (sediment

                                    impact zones) and cleanup activities (sediment

                                    recovery zones). When adopted, these sediment

                                    dilution zone requirements may be incorporated into

                                    any waste discharge permits issued for net pen

                                    operations.






                           11       other entities with involvement include tribal and


                                    the Puget Sound Water Quality Authority.




            II.A.l.        13       As with other sections of the draft PEIS, the


                                    introduction to this section should describe the


                                    objective(s) of the mitigation measures presented


                                    within.




                           24       Last sentence of 3rd paragraph: The guidelines

                                    recommend a minimum depth of 20-60 feet, depending

                                    on mean current velocity and annual production.



                           25       lst paragraph: Intuitively, one would expect

                                    larger pens, with the same loading, to deposit

                                    sediments over a relatively larger area.



                           26       1st paragraph: The Gowen model predicts carbon

                                    deposition, not redox potential.














                                        5th paragraph: This mitigation measure implies

                                        that sites with low bjiological productivity are, to

                                        a certain extent, expendable.



                               26,27    Under mitigation measures it states, "Where

                                        accumulation is unavoidable, select sites having

                                        little biological productivity." Under Unavoidable

                                        Adverse Impacts it states, "If accumulation is

                                        allowed..." Both of -the statements imply that

                                        there are locations where accumulation can be


                                        avoided or techniques which can be employed which

                                        will prevent accumulation. If this is the case, to

                                        what degree will accunulation be permitted? Who

                                        will decide?




                               27       Add some discussion of the experience of collecting

                                        waste (from Braeten 183).




                II.A.2.        39       2nd paragraph: Were any turbidity measurements

                                        taken during or shortly after feeding, when feed
                   0                    wastage would peak and fish activity could di-slodge

                                        net-fouling organisms?














                           43      2nd sentence of 6th paragraph: Earlier discussion

                                   noted that violation of turbidity standards may

                                   occur during net-pen cleaning (pg. 39) and that

                                   violation of dissolved oxygen standards had already

                                   occurred (pg. 42).



                           43      Noise, odor, and water quality impacts resulting

                                   from cleaning of nets on the uplands need to be

                                   addressed.




                           46      Last 2 sentences of 2nd paragraph: Are these

                                   areas therefore considered "potentially nutrient

                                   sensitive" (pg. 51)?



                           50      Rensel's report (Appendix G) is reviewed later in
                                   this memo; some of' the review comments carry over

                                   to the discussion on page 50.



                           51      Ist complete sentence: Since this finding is not

                                   supported by sufficient data, it should not be

                                   presented in the PEIS,.



                            52     lst paragraph: Stratification limits mixing

                                   between surface and deep layers, thus nutrient-rich

                                   waters at depth may not contribute a significant

                                   nitrogen load to surface waters.














                                     2nd paragraph: This discussion is somewhat

                                     confusing and the point not readily evident.



                             53      Was Kieffer and Atkinson's phytoplankton-nutrient

                                     model verified by field studies'?



                             54      The model schematic requires clarification. For

                                     example, it is unclear how phytoplankton lose

                                     nitrogen through respiration. Also, nOn-grazing

                                     algal mortality does not appear to be accounted

                                     for.




                             55      lst paragraph and equation: Both are out of

                                     sequence. Also, the model equation is given for

                                     winter, but not summer.




                                     2nd paragraph: The model uses a value of 1.5 tidal

                                     cycles per day; 2 cycles per day would be a closer

                                     approximation.



                                     4th paragraph: It is unclear why a solubility

                                     correction of 87% is applied; the nitrogen load is

                                     already expressed as a dissolved value.




                             51      Table 2: Parameter coefficients and ... ass-balance


                                     results should be provided for each model run.














                          57       Paragraph 9: Nutrient production in sensitive

                                   areas could also be minimized through reduced fish

                                   loading during critical periods.



                                   Paragraph 11: It is unclear how an increase in

                                   nitrogen digestibility would reduce ammonia

                                   excretion since ammonia is largely excreted through

                                   the gills (Lagler et al., 1977. 'Ichthyology'.

                                   John Wiley and Sons, New York).



                           61      4th paragraph: The title of Carlucci and Pramer's

                                   paper implies the study of a single species, yet

                                   results are generalized to "non-pathogenic

                                   bacteria". The lst paragraph on this page

                                   indicates antibiotic effects may be exerted in

                                   sediments below fish farms. The potential impact

                                   of antibiotics on benthic detrital bacteria should


                                   be explored further, as loss of these forms would

                                   likely accelerate sedimentation beneath the pens.



                           63      Last sentence of 6th paragraph: The word

                                   "unlikely" should be substituted for the phrase

                                   "virtually impossible".

















                II.A.3.        79-81    Do the discussion and conclusions of this section


                                                                           -ecent discovery of
                                        merit revision in light of the z.

                                        viral hemorrhagic septicemia in Puget Sound salmon

                                        and consequent destruction of all fish at the two

                                        affected hatcheries?




                II.B.I.        91       Aesthetics:   No mention of sheds; or buildings

                                        occurred in  the text, frequency of sheds on

                                        existing 13  permits SILOUld be cited. Discussion of

                                        their impact should occur.




                II.B.3.        114      The 5th mitigation meiftSure is implicit in the lst

                                        measure. The 4th meassure potentially conflicts

                                        with a guideline to prevent sedimentation (item 4.*.

                                        on page 25) because current movement typically

                                        parallels the shore.



                II.B.7.        124      3rd paragraph-.' The mj'.tigation objective should be

                                        similar*to that for noise (pg. 121) -- i.e., to
          S                             prevent odors from adversely affecting nearby human
                                        activities, especiallir shoreline habitation.



                II.C.          131      6th paragraph: How do these loading rates compare

                                        to literature values? Why were the loading rates

                                        presented earlier (e.g., nitrogen - page 55) not


                                        used here?













                          132      7th sentence of last paragraph: What is the impact

                                   threshold and how was it derived? The cumulative

                                   impact analysis appears to exclude the 50% daily

                                   tidal reflux to Puget Sound (pg. 33).



                                   3rd sentence of 2nd paragraph: The progressive

                                   vector diagram of Weston and Gowen (Appendix A)

                                   suggests a net-southward transport of pen wastes.

                                   If true, perhaps the southern reference site would

                                   demonstrate far-field effects of nutrient


                                   enrichment.





                                              TECHNICAL APPENDICES




                            9      lst paragraph: The tidal data provided is

                                   insufficient for the reader to interpret survey

                                   results. The time and stage of all tides should be

                                   provided for both sampling dates. In addition,

                                   sampling times should be reported for all collected


                                   data.




                                   3rd paragraph: The distinction between inorganic,

                                   dissolved, and total nitrogen is unclear throughout

                                   the report. Nitrate, nitrite, and ammonia

                                   constitute "total inorganic nitrogen". If the

                                   sample is filtered prior to analysis, the complex












                                      is referred to as "dissolved incorganic nitrogen".

                                      "Total nitrogen" and "dissolved nitrogen" would

                                      include organic forms. Nutrient: results should  be

                                      expressed as mg-N/L or mg-P/L.



                               15     3rd sentence of lst paragraph:  If this; is true,

                                      wouldn't the same response be expected at the net

                                      pen site due to the influence of southern Peale

                                      Passage waters?



                                      Last sentence of Ist paragraph: The error bars

                                      should be included so the reader may confi= that

                                      the variation was small.




                                      2nd sentence of 2nd PZLragraph: This statement is

                                      misleading -- half of the nitrogen values in June

                                      were lower than the growth limiting concentration,

                                      compared to none in May.



                                      3rd sentence of 2nd paragraph:   It appears zhat the

                                      word "lower" should be replaced by "higher".



                                      Last sentence of paragraph 4: 'For clarity, the
                    C49)              phrase "near the net pens" should be inserted after
                                      "Productivity".














                            21     lst paragraph: Productivity patterns before and

                                   after release may have appeared similar, but

                                   variability was high. To this reviewer, a more

                                   'Istriking feature" of the analysis was the

                                   statistical difference in productivity between the

                                   net-pen and reference sites prior to release,

                                   compared with no significant differences after

                                   release.




                                   2nd paragraph: Nitrogen did not appear to be in

                                   short supply, but the ammonia excreted by fish may

                                   be more usable by phytoplankton.



                             22    lst sentence of 2nd paragraph: Reference stations

                                   should have been sited in shallow water to


                                   facilitate comparisons to the net-pen station.

                                   This sampling design would have reduced the "noise"

                                   associated with water depth, proximity to land,

                                   current movement, mixing, etc.



                             23    Last sentence of lst paragraph: This statement

                                   does not appear consistent with the data in Figure

                                   3a.













                                    Ist sentence of last paragraph: Given the problems

                                    with sampling design and data interpretation noted

                                    above, this conclusion may be premature.



                              25    Last sentence of 2nd paragraph: Source should be


                                    cited.




              In summary, most sections of the draft PEIS and technical appendices were

              reasonably comprehensive. However, several areas require further

              attention, namely:



                    A short section on net-pen culture in Japan, Norway and Scotland

                    would be beneficial and help to reduce much of the misunderstanding

                    surrounding net-pens. Included for each country should be a short

                    history of net-pen industry, any environmental impacts or concerns

                    of their relevance to the Puget Sound, current and historical

                    production levels, and existing and historical regulatory controls within

                    each of the countries to control environmental and disease impacts.






                    Proper documentation of source material. is essential. This would

                    included: 1) citation of authoritative statements; and 2)

                    cross-checking of citations in the text against the list of

                    references.














                 Impacts of delayed-release facilities should be evaluated in light

                 of their potential for future expansion, as well as their potential

                 for siting in restricted embayments.



                 The Kieffer-Atkinson model should be presented in greater detail.

                 The model's importance in assessing nutrient-phytoplankton dynamics

                 merits its inclusion as a separate technical appendix.




                 The discussion concerning land-based tank farming should either be

                 expanded or omitted entirely.  If an objective of the HIS was to

                 evaluate the impacts of land-based facilities, then a more detailed

                 environmental assessment is warranted, with provision of mitigation

                 measures mandatory.



                 Portions of Appendix C are unclear or misleading. Study findings

                 should be more carefully examined, especially as they relate to the

                 main bod-.- of the HIS (pg. 50).



                 Throughout the EIS, almost no discussion was made of the

                 technolozical methods that could be used to reduce or eliminate the


                 water or sediment impacts of net-pen culture. For example,

                 evaluation of sedimentation mitigation measures including feed/feces

                 collection of periodic removal of sediments below net-pens should be

                 included.













                    State law requires all discharges to state waters; be provided with

                    "all known, available and reasonable methods of treatment,"

                    regardless of receiving water quality. Are there reasonable methods

                    of treatment available for the wastes discharged from nIE't-pen

                    operations?









             RESPONSE TO LEWER NO. 70: WASHINGTON DEPARTMENT OF ECOLOGY


             1.     Comments noted. Proper siting of individual farms is essential to preventing
                    significant impacts.                                                                          U
                                                                                                                  0
                                                                                                                  4-b
             2.     The purpose of this EIS is to evaluate environmental impacts and a management                 0
                                                                                                                  W
                    plan is not included. The FEIS evaluates existing regulations and guidelines.
                    From this evaluation, a management plan can be formulated.

             3.     Numerous sections contain descriptions of regulations that affect the fish farm
                    industry. The EIS includes evaluations of existing regulations and guidelines that
                    are currently being used to manage the industry.

             4.     See the response to Question 11.

             5.     Comment acknowledged. The text of the EIS has been edited and proofread.

             6.     The Summary has been rewritten.

             T.     Comment noted.

             8.     See the response to Question 21.

             9.     A Commissioner's Order from DNR limited the size of fish farm proposals to two
                    acres or less.    This Order has expired, but the State, industry, and local
                    governments continue to use this size limitation as a guideline.

             10.    Comment acknowledged.

             11.    The shoreline permit and the Shoreline Management Act have been combined in
                    the FEIS.


             12.    Comment noted.

             13.    The list provided in Section 4 of the FEIS includes agencies directly involved with
                    the management of the fish farming industry.

             14.    Comment noted.


             15.    The text has been revised for the FEIS.

             16.    The reference cited used the ratio of impacted area to farm area and found this
                    ratio to be larger for smaller farms. The conclusion that the larger farms cause
                    higher concentrations of sediments is incorrect. The larger farms distribute the
                    sediment over a larger area and therefore have lower sediment concentrations.

             17.    Comment acknowledged.








                Response to Letter No. 70: Washington Department of Ecology (continued)

                18.   Comment noted.

                19.   Comments noted. The amount of accumulation allowed under fish farms will be
                      determined through siting regulations and guidelines, and the NPDES, permit
                      system. Ecology is currently formulating the NPDES permit requirements.

                20.   Techniques for collecting waste are described. in Section 5.1 of the FEIS.

                21.   No known measurements exist under the conditions described in the comment.

                22.   Instances when water quality standards were@violated occurred at farms located in
                      poorly circulated embayments. No violatiOn of standards are expected for a
                      properly sited fish farm. Part of proper siting is to-iletermine that the circulation
                      is sufficient to prevent violations of water quality standards.

                23.   The evaluation of activities associated with floating fish farms which occur on
                      upland areas are outside the scope of this 1EIS.

                24.   The specific areas mentioned at this point are potentially nutrient sensitive,
                      pending further studies and analyses of existing data. Nutrient sensitivity may be
                      viewed as a continuum in varying degrees, not a simple yes or. no situation.

                25.   Comment noted.

                26.   Other portions of the same referenced study were significant (e.g., the ammonia
                      levels noted around the pens) so the reference was presented. The study is useful
                      because it is one of the only other field studies conducted in recent years dealing
                      with phytoplankton production, radiocarbon. uptake, and salmon farms. It also
                      dernonstrates poor siting practices that have occurred in other countries (e.g., pens
                      sited within a fjord with a nearly-blocking sill at the entry).

                27.   The reviewer's statement is correct, nevertheless, the present m,ethod of -calculating
                      nitrogen flux in and out of embayments far understates the true amount as the
                      deep, waters are not accounted for in the analyses. The solution is to use a one-
                      box (surface) model in areas of limited vertical mixing for modeling during
                      summer conditions that may occur in embayinents, with strong thermal and salinity
                      stratification.

                28.   See the response to Question 19.

                29.   Respiration involves more than simple oxygen consumption and carbon dioxide
                                                                     P
                      discharge. See the response to Letter 18, Comment 29. Non-grazing algal losses
                      are covered by system loss rate, illustrated in the lower portion of Figure 11 of
                      the text.

                30.   The summer equation is the same as the winter equation during periods of steady-
                      state biological action, but column of Table 2 now shows that 95% of the








            Response to Letter No. 70: Washington Department of Ecology (continued)
                   nitrogen, as a worst case, is converted into phytoplankton biomass and is later
                   partitioned into 1/2 zooplankton biomass.         Non-steady-state conditions are
                   included in the model, but the other calculations are elaborate differential and
                   simultaneous equations that involve use of a main frame computer. See Kiefer
                   and Atkinson (1988) for a more detailed description of the model including those
                   equations. Dr. Kiefer and Atkinson's model is presently under study by EPA for
                   its broader application to all of Puget Sound's embayments.

                   The use of 1.5 tidal cycles per day is more conservative than 2 tidal cycles per
                   day since there is less tidal exchange in the later. Additionally, most areas in
                   Puget Sound and its approaches average about 1.5 or more tidal cycles per day.

                   The 87% is to account for the 13% portion of waste nitrogen that is present in
                   the feces and is generally transported to the bottom area, out of the surface layer.
                   The prior sentence has been altered to refer to total nitrogen (inorganic and
                   organic forms).

            31.    The coefficients of the steady-state model are given in the text. Additional non-
                   steady-state coefficients are given by Kiefer and Atkinson (1988, 1989).           A
                   sentence has been added to explain the partition of nitrogen between phytoplank-
                   ton and zooplankton stocks.

            32.    Comment acknowledged. The suggestion has been added to the text. Typically
                   fish biomass does not peak until the early winter period in most commercial
                   farms, so it is doubtful that the suggestion could have practical application.

            33.    The paragraph has been altered to discuss the providing of a balance of protein
                   (containing nitrogen), fats, and carbohydrates in the diet.       By providing the
                   optimum balance, proteins (amino acids) that may have been deaminated as an
                   energy source are "spared" for incorporation into fish flesh, resulting in reduced
                   excretion of nitrogen via the glutamine/glutaminase/carbonic anhydrase/gill
                   pathway.

            34.    Comment noted and WDF agrees.

            35.    Comment noted.

            36.    See Appendix G.

            37.    The more a fish farm projects above the water surface, the more visually evident
                   it becomes and the greater the resulting visual impacts. Sheds or buildings are
                   located on several existing farms and they increase the visual impact of these
                   farms. One of the design recommendations contained in the EIS text (page 98
                   of the DEIS) is that structures project a minimum distance above the water line.
                   Followed strictly, this could preclude placing sheds or buildings over the water.

            38.    Comment noted.








               Response to Letter No. 70: Washington Department of Ecology (continued)


               39.    Comment noted.

               40.    Loading rates on page 131 of the DEIS are annual rates and obtained from a
                      different source than the daily rates found oil page 55. Both are within the range
                      of literature values.

               41.    Impact estimate of nitrogen loading was based on amount of nitrogen required
                      to cause a noticeable increase in phytoplankton.          Since this is a subjective
                      estimate, the impact was given as an order of magnitude estimate only. The 50%
                      daily tidal reflux was not used in this calculation. The calculation was based on
                      a surface layer volume only. Refluxing of the surface layer entrains surface waters
                      into incoming marine water. No attempt wai made to estimate the rate of return
                      of refluxed surface water from the bottom water to the surface and the extent of
                      mixing with marine water. Finally, the order of magnitude estimate makes such
                      small. scale adjustments irrelevant.

               42.    Comment noted.

               43.    Times of sampling are given in Tables 2, 3, and 6 relative to high or low tide.
                      All sampling was conducted within an hour of the slack tide period.

               44.    The methods and references for nutrient analyses were cited on page 9. It was
                      stated that the sample was not filtered to avoid problems associated with that
                      method. The text was consistent in the use of the terms dissolved nitrogen or
                      total nitrogen. Dissolved nitrogen was defined as nitrate + nitrite + ammonium.
                      Most oceanographic researchers use this or a similar term since most nitrogen in
                      the sea exists as molecular forms such as nitrate, nitrite and ammonia in addition
                      to some amino acids and urea, not as particulate forms. The term "dissolved" has
                      no meaning without an accompanying filter size since it refers to that portion of
                      a sample whose particles pass through a filter of a certain SiZe (often 0.5 or 1
                      uM, See APHA 1985).

                      Total. nitrogen is all forms of nitrogen, inorganic and organic, and is generally less
                      useful in determining dynamic of phytoplankton processes as it includes forms that
                      are riot available for uptake and growth. To further clarify this situation, any
                      reference to total nitrogen and phosphate has been deleted from the text and
                      Table 4 has been revised to report solely the dissolved NY ratios and concentra-
                      tions..

                      There is no single correct protocol for reporting the results of nutrient studies,
                      although the reviewer should note that the units used by the Department of
                      Ecology (mg-N/L) are virtually never used in reporting the results of oceanograph-
                      ic studies, but stem from wastewater/engineering protocoll (APHA 1985).
                      However, it is universally agreed among oceanographic researchers that molecular
                      (atomic) units are most appropriate for these types of studies. The rationale for
                      not using the molecular units for most of the dissolved nutrients was stated at the








            Response to Letter No. 70: Washington Department of Ecology (continued)

                   end of the second paragraph on page 9. The units used conform with the Puget
                   Sound Water Quality Authority's Puget Sound Ambient Monitoring Program Final
                   Report recommendations (1988).

            45.    One might expect such a response, but there were only a few samples collected
                   between stations so there is no means to be certain. The text has been altered
                   to state that the pattern wasn't seen at high tide, when values were higher at the
                   farm site.

            46.    The sample variation was so small that it was graphically -impossible to show 5 of
                   the 6 error bars. Variation statistics are presented in Table 3 that would be more
                   useful to a critical reviewer than graphical values.

            47.    The statement in the text was correct and indicated the lack of any obvious
                   pattern of nutrient values after release of the fish.      As stated in the same
                   paragraph, there was no statistical difference between the samples, so the
                   discussion and comment are really moot. Both that sentence and the next have
                   been deleted.

            48.    See the response to Comment 46.

            49.    For clarity, the suggested word has been inserted in the text of the FEIS.

            50.    As stated in that paragraph and shown in Figure 5a, there was no difference in
                   productivity among the stations at high tide. Accordingly, it is incorrect to make
                   generalized statements about productivity from the samples collected before the
                   fish were released.

            51.    Ammonium is preferentially absorbed by most phytoplankton. See experiment B
                   and Appendix B of this same report for a discussion on the fate of ammonia.

            52.    Maximum depths in all but the most southern portions of Peale Passage are little
                   more than 10 m deep. There are no streams flowing into Peale Passage and
                   relatively little human development. It is unclear how moving inshore when the
                   entire passage was within the euphoric zone (see secchi disk values and apply
                   coefficient of 2 to 3), is unclear from the reviewer's statement. There was no
                   11noise" in the data attributable to any of the factors mentioned in this comment.

            53.    The text is correct. The term "similar" was applied in reference to the values 0.07
                   and 0.09 mg/l dissolved nitrogen, which is indeed a very small difference. For
                   example, this difference is much less than would be detectable in most analytical
                   instruments including Ecology's routine monitoring program which reports values
                   no smaller than 0.10 mg-NIL nitrate equivalent to 7.1 uM nitrate and 0.44 mg/L
                   nitrate.

            54.    There are no acknowledged problems with the sampling design. Nor are any of
                   the reviewer's comments acknowledged to be significant, as mentioned in the









               Response to, Letter No. 70: Washington Department of Ecology (continued)

                      above discussion. Moreover, prior to public and agency revi      .iew, the text was
                      reviewed by Dr. Donald Weston, aquaculture impacts expert, and Dr. Dale Kiefer,
                      widely known authority on phytoplankton ecology, as well as other phytoplankton
                      experts at the University of Washington. The conclusions of -experiment A are
                      rather clear since the objective of monitoring during a period of near nutrient
                      depletion was not possible.     Given the great variation in ambient nitrogen
                      concentrations seen during the study, the minor "signal" emitted by the nitrogen
                      release from the pens was totally lost.

                      Finally, the conclusions to experiment B are entirely straightforward.

               55.    Literally, thousands of scientific papers and many textbooks note nitrate is not as
                      preferred as ammonia by phytoplankton. There are exceptions, for example, at
                      low light levels there does not seem to be any advantage to some phytoplankton
                      in using ammonia versus nitrate (Thompson et al. 1989. Limnol and Ocean. 1014-
                      1024'
                          ). For a most recent study and review, see Davies and Sleep 1989, Journal
                      of Plankton Research 11:141-164.

               56.    It is outside the scope of this EIS to include a thorough discussion of the status
                      of fish farms throughout the world. Countries where fish farming is an active
                      industry have different hydrograpbic characteristics, different indigenous species,
                      and a different governmental structure and perspective. To include only a small
                      portion of that information may mislead readers into drawing erroneous parallels
                      to the situation in Puget Sound. See the response to Question 6.

               57.    Comments noted.

               58.    See the response to Question 21.

               59.    The model. is available to interested parties and has been described in more detail
                      in the by Kiefer and Atkinson (1988 and 1989). It is a highly technical model
                      that utilizes advanced mathematics and a mainframe computer due to the complex
                      calculations that are required. Therefore, the interested reviewer may contact Dr.
                      Kiefer, or examine the Washington State Shoreline Hearing Board proceedings
                      where the model has been presented on two separate occasions.

               60.    The section on land-based tank farms was included to provide the reader with
                      additional information on the commercial salmon farming industry. This section
                      has 'been moved to the Technical Appendices to clarify iLS purpose.

               61.    The final report has included modification to respond to the reviewer's comments,
                      where appropriate. The draft report was reviewed by a number of experts
                      including Dr. Donald Weston and Dr. Dale Kiefer, as mentioned in the text.

                      The conclusions of experiment A, put in veiy simple terms, indicate that ambient
                      water column values of nitrogen fluctuated more due to tidal stage than from any
                      possible human caused source. The study site and timing-, were the worst-








           Response to Letter No. 70: Washington Department of Ecology (continued)

                  available case and timing that could have been examined in western Washington.
                  This serves to illustrate how remote a fish-farm-caused phytoplankton bloom would
                  be in marine waters of Washington state, particularly under the current stringent
                  siting guidelines.

                  Few field studies of the effects of fish farms on phytoplankton populations have
                  been conducted anywhere in the world, compared to studies of nutrient discharge
                  and dissolved oxygen depletion.       This is due to the complexity of studying
                  phytoplankton in the field and to the general belief in the scientific community
                  that impacts from fish farms on phytoplankton populations in most cases are very
                  unlikely (Weston 1986).       Theoretically, nutrient effects from fish farms on
                  phytoplankton populations should be measurable only in summer, within nutrient
                  depleted surface waters of areas with strong vertical stratification and very limited
                  horizontal mixing. These conditions were sought in the present work through the
                  prior measurement of ambient nutrient conditions. The present study serves to
                  illustrate the complexity of field studies and the need for modeling (which has
                  been accomplished).

                  Ecology's specific comments about Appendix C are discussed at another point in
                  the EIS.

           62.    The text has been revised to include a discussion of technological methods that
                  could be used to reduce or eliminate sediment impacts. See Section 5.1 of the
                  FEIS.

           63.    Fish farms are now required to obtain NPDES permits which will ensure that
                  farms meet applicable State and federal water quality regulations.



                                                             Law Offices                            LETTER NO. 71
                                               Peter J. Eglick & Associates
                                                             Suite 1212
                                                     Batik of California Building
                                                        900 Fourth Avenue                              Carol Eychaner
             Peter J. Eglick                         Seattle, Washington 98164                          Land Use Planner
             Robert R. Meinig                             (206) 464-1435                              Deborah L. Dean
             Carolyn A. Anderson                          FAX 382-3450                                    Office Manager


                                                       April 6, 1989



              Mr. Ron Westley
              Project Manager
              Washington Department of Figheries
              115 General Administration Building
              Olympia, Washington 98504

                      RE: Comments to Draft Programmatic Environmental Impact
                              Statement--Fish Culture in Floating Net-Pens

              Dear Mr. Westley:

                      Thes@ doffitentS on the Programmatic Environmental Impact
              Statement (11PEIS11) on fish culture in floating net-pens in Puget
              Sound are submitted an behalf of the Gunstone family, which has
              commercially harVested native littleneck clams and other types of
              commercial clams in Clallam and Jefferson Counties for over 50
              years.         The Gunstones, as shoreline residents who earn their
              livelihood from the shoreline                   environment, are vitally concerned
              about the potential impacts of the development of commercial net-
              pen culture in the Puget Sound                  region and the efforts of the state
              and local governments to manage this burgeoning industry to prevent
              unacceptable impacts.                     The PEIS, a long-awaited document,
              unfortunately falls far short                   of our reasonable expectations for
              documentation and analysis of potential impacts from net-pen
              aquaculture.

                      These comments are submitted pursuant to WAC 197-11-455; we
              request substantive responses from the department as required by
              WAC 197-11-560.             These comments address the areas of particular
              concern to the Gunstone family in the order in which they appear
              in the PEIS.


                                                  I. General Comments

                      The impact of the PEIS can be enormous because, as the
              document acknowledges at i-ii, state and local officials will use
              it to "develop policies for future development and regulation of
              the net-pen industry. 11 As with any EIS prepared pursuant to the
              State Environmental Policy Act (11SEPA11), it is essential that the
              document impartially carry out its mandate.                                  SEPA regulations
              describe the purpose of an EIS as follows:









            Mr. Ron Westley
            April 7, 1989
            Page 2

                      An EIS shall provide imRar ial discussion of
                      significant environmental impacts and shall
                      inform decision makers and the public of
                      reasonable alternatives, including mitigation
                      measures, that would avoid or minimize adverse
                      impacts or enhance environmental quality.

            (Emphasis added) . WAC 197-11-400. Unfortunately, in this case,
            the list of authors and principal contributors, to the EIS at the
            beginning of the document raises a genuine concern of inherent 'bias
            which permeates its analysis.

                 The principal auth.c_r of the PEIS is Paramietrix, Inc., which
            has had numerous contracts with the aquaculture industry.
            Parametrix has prepared an EIS on an. application for a massive
            aquaculture complex, including net-perts, at Harding Creek on Hood
            Canal--an EIS initially declared inadequate by the Kitsap County
            Hearing Examiner on an application ultimately denied unanimously
            by the Board of Kitsap County Commissioners. Parametrix also has
            provided and is slated to provide expert testimony on behalf of
            net-pen proponents on a number of net-pen proposals throughout
            Puget Sound.

                 Another PEIS preparer is Jack Rensel of Rensel Associates,
            who has been a primary consultant and advocate for numerous net-
            pen proj ects.   The Gunstones are particularly concerned by Mr.
            Rensel's participation in light of his erroneous statements in
            reports prepared for the Discovery Bay net-pen proposal, now before
            the Shorelines Hearings Board for decision; Mr.               Rensel's
            misstatements concerning the commercial viability of the Gunstones'
            clam beaches--were made without even consulting the Gunstones.
            This is not a track record that breeds confidence.

                 Another of the PEIS preparers, Battelle Pacific Northwest
            Laboratories, has provided expert witness testimony on behalf of
            the net-pen industry in at least one contested case (Discovery
            Bay) , has assisted in another (the Harding Creek project in Hood
            Canal) , and is slated to provide such testimony in another net-pen
            case scheduled for an April hearing before the Shorelines Hearings
            Board.

                 While Dr. Donald Weston's track record may be less weighted
            toward advocacy of net-pen proposals, the PEIS fact sheet indicates
            that he provided only "technical review.11
                    P

                 The roster of PEIS authors and principal contributors thus,
            at the outset, creates a very significant appearance of Rartiality-
            -an appearance that clearly should have been avoided given the
            well-known   controversy    surrounding   the    issue   of    net-pen
            development. Where the principal author and major contributors to










          Mr. Ron Westley
          April 7, 1989
          Page 3

          the PEIS have and will continue to benefit economically from
          contracts with the net-pen industry, this appearance of partiality
          is unacceptable.

               The contents of the PEIS document validates this view.          it
          consistently cites sources who have supported development of the
          fish pen industry or who are a part of the industry itself, while
          neglecting qualified sources who have urged caution or have openly
          opposed headlong development of the industry. It is not an excuse
          for the Department of Fisheries to claim that it chose contributors
          with experience in aquaculture. The one-sided experience of those
          involved does not justify a draft PEIS that purports to be
          impartial 'Out is not, eilt-her in appearance or in practice.

               This concern should not be swept under the rug simply because
          the draft document has already been prepared. Any delay that might
          inhere in the selection of a new principal author and contributors
          with no such blatant biases will be more than of f set by the
          advantage of an impartial discussion of impacts and mitigation
          measures.


                                 II. Specific Comments

                1 .  Summary.   The PEIS will be used by local governments
          making decisions on the siting of net-pens.        As non-scientists,
          local officials will be particularly dependent upon summary
          sections. It is therefore extremely important that such sections
          be presented in an understandable, straight-f orward, and logical
          manner.   The initial PEIS summary, at ix-x, f alls short of this
          goal.   The first of the "Major Conclusions of the Draft PEIS11
          begins by stating that "the major impacts of net-pen culture can
          be prevented . . . 11 PEIS at ix. Stating that conclusion as such,
          rather than presenting, first, a summary of the major impacts
          before claiming that they can be prevented, reverses the logic and
          format of the EIS itself.

                This is not merely a question of semantics, but one of
          presentation and tone. The same defect is repeated in the other
          "major conclusions." The second conclusion is that the "impacts
          of net-pens [still not disclosed] are reversible, and after pen
          removal any affected areas will revert to their undisturbed state."
          PEIS at ix. This conclusion creates an unfortunate and incorrect
          impression that all net-pen impacts are reversible and that the
          adverse effects will disappear rapidly.       However, even the PEIS
          itself concedes potential genetic and disease impacts are examples
          of adverse effects that may not be reversible. See PEIS at 68-81.
          A report co-authored by Dr. Weston emphasizes that 11(t)he
          importation of an exotic species or disease organism poses the
          greatest environmental risk in mariculture, for unlike other
          environmental effects, the consecruences may be widespread and










           Mr. Ron Westley
           April 7, 1989
           Page 4

           irreversible."    (Emphasis added)    Rosenthal, Weston, Gowen, and
           Black, "Environmental Impact of Mariculture," Cooperative Research
           Report No. 154, International Council for the Exploration of the
           Sea (March, 1988) at 28.

                      The summary section is critical in any EIS because it
           sets the tone of the document and presents ZLn overview of its
           analysis and conclusions. While the summary, by definition, should
           be brief, it should not, as in this case, present inadequate and
           misleading conclusions.

                2.   Impacts to Sediments and Benthos.      This section of the
           PEIS (at 13-27) analyzes the effects of "sedimentation" and
           "organic enrichment" on the bottom environment and benthic
           community.   However, net-pens do not produce "sedilrLents.11      With
           respect to the impacts considered in thj;s section, net-pens produce
           solid wastes in the form of fish feces and laneaten fish feed,
           wastes which are commonly termed "polluttants.11 See, e.q., Weston,
           "Measuring the Effects of Organic and Toxicant, Inputs on Benthic
           Communities," in Proceedings: First Annual Meetincr on Pucfet Sound
           Research, Volume 11 (1988) (Dr. Weston uses -the terms "organic
           enrichment" and "pollutants" or "pollution" interchangeably) . The
           PEIS, however, appears to avoid appropriate terms such as "solid
           wastes" or "pollutants" in preference for terms which have little
           meaning for lay persons and have been criticized by experts. See
           PEIS comments submitted by Dr. Annamarie K. Johnstone, at 1 ("1
           would argue that sediment is not produced, rather that solid waste
           is produced. 11) ; PEIS comments by Dr. Richard Strathman, March 3,
           1989, at 1 ("species that are indicators of pollution should, be
           described as such when they are mentioned . . . 'Indicative of
           organic enrichment' doesn-It carry enough information to the non-
           specialist.").    The effect of Parametrix's deliberate choice of
           words is to down play the pollutant nature of what is produced by
           net-pen facilities.

                Further, the PEIS discussion of mitigation measures for
           impacts from solid waste accumulation on the bottom community (PEIS
           at 26-27) is far from adequate. That inadequacy begins with the
           claim that "measures can be taken to prevent harmful accumulations
           of organic wastes below net-pens."      PEIS at 26.    The mitigation
           measures proposed, however, will in most cases not prevent harmful
           accumul at, ions, but rather may serve to reduce (not eliminate) such
           accumulations, or, in some cases, remove them. Moreover,      there is
           little or- no discussion of the efficacy', practicality, or   even the
           possible adverse effects of the mitigation proposed. The      proposed
           use of underwater blowers, vacuuming under pens, and use of
           collection devices are, for example, only discussed in one    sentence
           each.    PEIS at 27.     These measures themselves raise      numerous
           questions, not discussed, such as the ultimate fate of the wastes
           (underwater. blowers) , impacts of turbidity created. (underwater










         Mr. Ron Westley
         April 7, 1989
         Page 5

         blowers), and effects on the benthic community by their use
         (underwater blowers, vacuuming, and collection devices).

               The mitigation recommended is so general as to provide little
         concrete guidance for local decision makers. For example, the PEIS
         recommends   "avoiding    sites   overlying   important     biological
         communities (for example, geoduck and other clambeds and important
         spawning areas) where they may be adversely affected." PEIS at 26.-
         This mitigation measure raises numerous questions.      For example,
         how close, as a general rule, can net-pens be located safely with
         respect to such communities?     The Department of Ecology Interim
         Guidelines for net-pens recommended specific distances between net
         pen facilities and important habitats. Indeed, the announced "goal
         of the guidelines" was "to avoid significant adverse environmental
         effects from net-pen operations permitted prior to completion of
         the Programmatic EIS.11 Interim Guidelines at 1. Yet the PEIS, in
         its draft form, makes no attempt through its recommended mitigation
         measures or elsewhere to either confirm the adequacy of the
         original guidelines or to offer revisions. The PEIS must evaluate
         these guidelines and recommend necessary revisions based on
         trustworthy original research by impartial scientists, not glib
         speculation by biased contributors. Otherwise, the PEIS is but a
         propoganda document that does not even measure up to the interim
         guidelines which were, themselves, inadequate.

              3. Impacts to Water Ouality. In the discussion (PEIS at 27,
         57), of "Impacts on Water Quality Standards," the problem of
         inadequate discussion of mitigation measures surfaces again. For
         example, in discussing cumulative impacts (with respect to
         dissolved oxygen only) of multiple farms, the PEIS states that "the
         potential of one net-pen facility affecting the dissolved oxygen
         near a second net-pen is highly unlikely if the net-pens are placed
         even 100 meters (330 ft.) apart." PEIS at 42-43. The impact on
         the surrounding environment, other than the net-pens themselves,
         is ignored and dismissed with the claim that the net-pen facility
         would be affected before the surrounding environment. PEIS at 42.
         The PEIS then cautions that "it is highly improbable that sediment
         impact requirements and aesthetic considerations would allow siting
         net-pens closer than a few hundred meters apart." PEIS at 43. Yet
         the discussion of mitigation measures in this section, as well as
         the sections on sediment (solid wastes-pollutant) impacts and
         aesthetics, do not provide guidance on acceptable distances between
         pens.

              Any   distance   limits   recommended    should,   however,    be
         conservative and based on, inter alia, research and answers to
         biological questions that are seemingly dismissed in the PEIS. The
         experience in British Columbia and in Norway, for example, where
         net-pen development is far greater than that in Washington, has
         prompted far greater restrictions than those vaguely suggested in










             Mr. Ron Westley
             April 7, 1989
             Page 6

             the PEIS.    British Columbia prohibits net-pen facilities from
             locating within three kilometers of other net-pen facilities.
             Norway prohibits net-pen facilities from locating within 500 meters
             of other facilities and within 20 kilometers (12 miles) of a salmon
             producing river.    Absent site-specific studies which would show
             that adverse effects are not possible at closer distance, net-pen
             facilities in Washington state should not be located within at
             least one mile of other facilities and other existing aquaculture
             uses.    Net-pen facilities should i.-iot be located at all in
             embayments with limited or poorly understood circulation.

                  The discussion of the effects of fish farms on phytoplankton
             productivity addresses the effect of nutrient input from fish farms
             only with respect to nitrogen despite the fact that other fish farm
             nutrient additions may also stimulate phytoplankton activity and
             blooms.   For example, the PEIS, at 40, discusses, the role of
             phosphorous in phytoplankton growth:

                       The Primary nutrients of interest in relation
                       to net-pens are nitrogen an phosphorous; both
                       may cause excess growth of phytoplankton and
                       lead to both aesthetic and water quality
                       problems.       Generally in marine waters,
                       phytoplankton growth is either light or
                       nitrogen limited, and phosphorous is not as
                       critical a nutrient as it is in fresh water.

             However, the two modeling approaches to phytoplankton impacts focus
             exclusively on nitrogen and the effects of phosphorous introduction
             from   net-pens    is   completely    ignored    despite    the     PEIS
             acknowledgement that it is one of the "primary nutrients of
             interest. in relation to net-pens."     If there is some scientific
             justification for this, it is not presented.        The lay reader is
             left to wonder about the significance of phosphorous input to
             marine waters from net-pens.

                  Similarly, there is no discussion, of other nutrient additions
             from net-pens that may potentially affect phytoplankton activity.
             For example, vitamins (biotin) introduced through fish feed (see
             attached. fish feed label) can be a factor in phytoplankton growth
             ("Nutrient Enrichment and Plankton. Ecology of Sequim Bay,
             Washington," Battelle Marine Research Laboratory (1984)), as well
             as enhancing the toxicity of dinoflagellates. See, "'The Reduction
             of the Impact of Fish Farming on the Natural Marine Environment,"
             University of Stirling (1988) at 109 ("Vitamins are important
             microbial growth promoters, and studies have shown that the
             toxicity, of the dinoflagellate Gyrodiiium aureolum is enhanced in
             the presence of biotin which could potentially leak from salmon
             diets. 11) . Although the ef f ects of vitamin and other additions f rom
             f ish f eed may not be as signif icant as that of nitrogen and









          Mr. Ron Westley
          April 7, 1989
          Page 7

          phosphorous, they nevertheless merit discussion concerning their
          possible contribution to phytoplankton growth.

               4. Chemicals. The use of antibiotics in fish farm operations
          raises potentially significant human health concerns that are
          inadequately addressed in the PEIS (at 58-61). In particular, the
          development of antibiotic resistance among bacteria in the marine
          environiftent, including resistance to antibiotics used in treatment
          of humaris (e.g., OTC), and the transfer of that resistance to human
          disease.-causing bacteria is a potentially very serious impact.
          Please 3.7eVieW the comments submitted, under separate cover, by Dr.
          Arthur H. Whiteley, who has studied this issue at length and
          presents an alternative view to that presented by fish farm
          proponents and regurgitated in the PEIS.           In particular, Dr.
          Whiteley emphasizes that, despite the evidence of antibiotic-
          resistant bacteria in net-pen culture in other countries (other
          than just Japan) , no studies have been conducted in this state nor
          does the PEIS call for any.      Dr. Whiteley also emphasizes that,
          contrary to PEIS dismissal of this potentially very significant
          issue, j:he transfer of resistance to pathogens of human concern is
          a very real possibility.

               5. Impact to Shellfish. A major concern of the Gunstones--
          impacts to intertidal shellfish beds--merits but one line in the
          PEIS discussion of shellfish impacts:       "The depths necessary for
          net-pens preclude direct impacts to intertidal shellfish and fish
          habitat!3.11 PEIS at 67. The sentence raises some obvious questions
          such as the following:     Apart from the lack of support for this
          sweepin('I conclusion, the sentence raises some obvious questions
          about issues not addressed.      Are there any indirect impacts to
          intertidal shellfish habitats?       What are those impacts and how
          could they be avoided?        How does the presence of significant
          intertidal shellfish habitats affect the siting of net pens?

               An EIS must discuss direct and indirect impacts. WAC 197-11-
          060 (4) (d).   Indirect effects to sensitive shellfish habitats
          located in the intertidal zone are certainly possible. Stimulation
          of a phytoplankton bloom for example, would have impacts well
          beyond the immediate area of the net-pens, and effect the
          intertidal zone. Other potential impacts may be more subtle, but
          cannot be completely ignored. For example, the effect of a large
          facility on water movement and wind or waves may affect beach
          productivity, the amount of food that will reach shellfish
          habitats, the composition of beach substrate, and larvae movement.
          Moreover, the use of antibiotics, inadequately discussed in the
          PEIS, can have significant implications for shellfish growers. The
          potential for the transfer of antibiotic resistance, including to
          human pathogens, can affect the marketability of shellfish which
          can function as bioaccumulators of such antibiotic-resistant
          strains.









           Mr. Ron Westley
           April 7, 1989
           Page 8


                Nowhere in the PEIS is there any acknowledgment that
           commercial clam harvesting is an acFaacultural use that merits
           protection from and on a par with otheir aquacultural ugdaj such as
           net-pen facilities.   Net-pen development in areas near eMistingi
           commercial shellfish harvesting areas, as identified 'in the ]MRS
           "Second Annual Inventory of Commercial. and Recreatichal 6heiiiish
           Areas in Puget Sound" (January 1989), should be avoiddd.i Potential
           impacts to littleneck clam harvesting areas r4ay bd ikkdVersible
           given that such clams seed naturally and atteMpts at, artificially
           seeding -them have failed.

                6. Disease. As you are undoubtedly aware, the! discovery of
           VHS virus in two hatcheries in the Puget Sound region highlights
           the potentially very significant impact of the introduction of
           exotic fish and shellfish pathos.       The PEIS must be revised
           accordingly to reflect the implications; of this outbreak, including
           the adequacy of federal and state :regulations to prevent the
           introduction of such exotic diseases. See, comment letter of Dr.
           Annamarie Johnstone at 5, submitted under separate cover ("As VHS
           virus is now present in the indigenous; Pacific N.W. salmonids, it
           is evident that federal and state regulations have not boo-H
           successful . . . 11).

                Moreover, the discussion of transmission of disease to wild
           fish, at 77-78, is confusing, and neglects some important sources
           of this phenomenon. The unstated assumption of the discussion is
           that the transmission of disease from pen fish -to wild fish has not
           occurred and, with the exception of exotic pathos, is not a
           significant risk.   PEIS at 77-78. There is no discussion of the
           Norwegian experience, which was comprehensively presented in
           November, 1988 by Svein Mehli, of Norway's Directorate of Nature
           Management, in testimony before the Shorelines Hearings Board. In
           his testimony, Mehli discussed how Norway's wild salmon populations
           have experienced a dramatic increase in disease since the
           development of that country's net-pen industry -and that the
           connection between the two phenomena is clear. Similarly, there
           is no reference in the PEIS to Moring's study entitled "Aspects of
           Growth, and the Effects of Some Environmental Factors on Pen-Reared
           Chinook," in which he describes the transmission of' furunculosis
           from penned fish at the NMFS facility in Clan Bay to wild fish.,
           Moring, at 148-149.     The failure of the PEIS to include these
           sources in its discussion of disease transmission is inexcusable.



                 Rensel, in his study of phytoplankton in the PEIS Technical
           Appendices, does refer to Moring's study, but not with respect to
           the issue of fish disease and its transmission from penned to wild
           fish.










           Mr. Ran Westley
           April 7,, 1989
           Page 9

               7. Impacts on Aesthetics. The PEIS section on aesthetics is
           tainted by its own background discussion.      PEIS at 91.    In our
           extensive involvement with net-pen proposals in numerous counties
           throughout the Puget Sound region, it is rare to find anyone, other
           than net-pen applicants and state employees promoting aquaculture
           development, expressing the opinion that net-pen facilities may be
           "interesting and attractive."       The overwhelming opinion of
           shoreline uses and residents is that net-pen complexes are an
           extremely adverse visual intrusion, except possibly in already-
           developed commercial or industrial areas, The effect of the PEIS
           claim is to undermine the credibility of its entire discussion of
           aesthetics.

                The PEIS would be much more helpful in presenting the
           aesthetic issue by printing honest (undoctored) photographs of
           actual net-pen facilities in the Puget Sound environment such as
           that now established in Kiket Bay, Skagit County. Line drawings,
           such as presented in the PEIS at 92-93, are uniquely incapable of
           presenting the reality of a net-pen's visual presence.

                Review of and reference to literature having to do with visual
           resource analysis would also be helpful in assessing aesthetic
           impacts.   There exists a body of literature on aesthetics that
           addresses viewer preferences in both natural and urban settings.
           It apparently was not even considered in the PEIS analysis.

                Further, the PEIS does little to resolve the complex issues
           involved with aesthetic impacts and efforts to mitigate them. For
           example, increasing the distance of net-pens from the shoreline to
           lessen their aesthetic impact, suggested in the PEIS at 98, can
           create greater impacts to navigation and commercial fishing, as
           acknowledged in the PEIS at 102. Yet the PEIS makes no effort to
           resolve such issues.       The potential siting of 100 net-pen
           facilities (see, PEIS at 131-135) would likely cause a chaos of
           conflicting interests--a prospect which concerns the PEIS preparers
           only in passing.

                In sum, aesthetics is a complex issue. While often belittled
           by net-pen proponents, it deserves a more thorough analysis than
           that presented in the PEIS.

                8. Cumulative Impacts in Puget Sound. This section should
           not be, but is no more than an adjunct to the section discussing
           water quality impacts.     The cumulative impacts considered here
           apparently relate solely to water quality. Thus, the conclusion
           that the impact of 100 net-pens in Puget Sound would be negligible
           is not based on a consideration of the myriad impacts that net-pens
           may cause. The PEIS discussion of cumulative impacts should extend
           to impacts on other aquacultural uses, navigational and commercial
           fishing impacts, aesthetics, and wildlife impacts including impacts










           Mr. Ron Westley
           April 7, 1989
           Page 10

           on wild fish. Further, the discussion of cumulative impacts should
           also consider the possibility of more than 100 farms being
           developed; although they are sorely needed, there are no
           regulations currently in place to prevent this. Far from using a
           worst case analysis, the PEIS uses an arbitrary limit on the number
           of pens and a narrowed focus of impacts to present a deceptive view
           of cumulative effects. While far fewer than one hundred facilities
           should be allowed, the industry to date has succeeded in blocking
           regulations which would limit its freedom of action ii-.i any material
           respect. Therefore, the PEIS should look at potential cumulative
           effects on a broad range of numbers, starting at ten and proceeding
           well past: one hundred.

                Finally, as recommended by the Puget Sound Water Quality
           Authority in its comments (March 20,     3.988 at 2) to 'the PEIS, the
           document "should include an analysis     of how many potential sites
           actually may be available for the        siting of flOaLting net-pen
           facilities in Puget Sound, given the     full range of environmental
           constraints that are discussed in the document."

                9.   Technical Appendices.     This letter will leave specific
           comments on the scientific studies presented in the technical
           appendices to those with expertise in those areas.        However, we
           will present a few general observations.

                With respect to Mr. Rensell's 111?hytoplankton and Nutrient
           Studies Near Salmon Net-Pens at Squaxin Island, Washington," it is
           unclear from reading the study why Mr. Rensel chose this particular
           site, involving a relatively small facility located in a channel,
           (as opposed to an embayment with a more complex and self-contained
           circula,ti.on), and what significance his results have with respect
           to much larger facilities in other locations with different water
           movement dynamics. Although the PEIS, at 50, claims the Squaxin
           Island presents a worst-case scenario, no basis for this conclusion
           is presented, nor, even absent his industry ties, is Mr. Rensel (a
           fisheries biologist but not an expert in water dynamics of
           oceanography) qualified to make this judgment which involves issues
           outside of his area of expertise.

                Further, the Rensel study admits some significant shortcomings
           not acknowledged in the PEIS.       At 22, Rensel claims that only
           11.[s]ome of the dissolved nitrogen concentrations during this study
           were below the threshold of limitations for dia-tom growth."
           Accordingly, Rensel admits that 11(t]o show maximum effects this
           study should have been conducted when surface water-s were nearly
           depleted of all forms of nitrogen (dissolved and total) , if it ever
           occurs, to test the possibility that the pens could cause or
           sustain a phytoplankton bloom." Id. This possibility is, however,
           the very possibility that the PEIS and studies conducted for it
           should have analyzed, but evidently did not.










         Mr. Ron Westley
         April 7, 1989
         Page 11


              The discussion of "The Economics of Salmon Farming," by Robert
         L. Stokes, is incomprehensible, except for the undocumented thread
         running throughout to the bald effect that salmon farming is of
         economic benefit because it is. Moreover, it is unfortunate that,
         in choosing to present an economic analysis, the PEIS authors
         completely ignored the experience and expertise of Dr. James A.
         Crutchfield who has spoken at numerous forums on the issue of the
         economic impact of aquaculture.

                                   III. CONCLUSION

              An adequate PEIS on net-pen aquaculture in Puget Sound should
         thoroughly and impartially disclose, discuss, and substantiate the
         impacts of net-pen development. The PEIS does not come close to
         meeting this standard.       Moreover, bias pervades the entire
         document.   This is an extremely important topic, on an issue of
         significant and widespread interest. The Department of Fisheries
         has apparently taken it too lightly.

              Consequently, a new draft by new authors should be prepared
         to overcome the inadequacies of the original draft. The new draft
         should then be recirculated for public comment, as required by WAC
         197-11-455.    Failure to do so will only result in continual
         controversy concerning the state's refusal to analyze honestly the
         environmental impacts of salmon net-pen facilities.

                                    Respectfully submitted,

                                    PETER J. EGLICK & ASSOCIATES




                                    Peter J@Ulick
                                    Robert R. Meinig

         RRM:dmc




         WESTLY-L.GUN













                                                                M0ORE CLARK'S SELECT
                                                             EXTRUDED SALMON PELLETS
                                                                          Guaranteed Analyals
                                                     Crude Protein Minimum....................45%
                                                     Crude Fat Minimum........................20%                                 
                                                     Crude Fiber Maximum...................... 3%    
                                                     Moisture Maximum.........................11% 
                                                     Ash Maximum..............................12%
                                                     Vitamin A Minimum...............15000 IU/Kg
                                                     Vitamin D3 Minimum............... 250 IU/Kg
                                                     Vitamin E Minimum................ 300 IU/Kg
                                                     INGREDIENTS: Fish Meal, Whole Wheat, Wheat Flour,
                                                     Soybean Meal, Fish 0il, Cane Molasses, Ascorbic Acid,
                                                     Cholfne Chloride, Vitamin Premix Containing: Vitamin A
                                                     Acetate, Pyridoxine Hydrochloride(B6), Vitamin B12, di
                                                     alpha Tocopherol Acetate (E); Menadione Sodium Bisulfitc 
                                                     Complex (K), Ribollavin (B2), Thimine Mononitrale, Niacin,
                                                     Inositol, d-Calclum Panthonic Acid, d-Biotin, Folic Acid,
                                                     Vitamin (D3), A Mineral Ptemix Consistling of: Zinc Sulfate,
                                                     Manganese Sulfate, Copper Sulfate, Ethyenediamine 
                                                     Dihydroiodide, Selenium, BHA-BHT an Antioxidant.
                                                     *Actual levels added and levels found naturally in the
                                                      ingredients far exceed these guaranteed minimums.
                                                     This feed must be stored in a cool,dry place.
                                                     FEEDING DIRECTIONS: Feed As The Sole Ration To
                                                     Salmon.                                     8/88 
                                                           Manufactured BY:      Canadian Agent:                 
                                                      MOORE CLARK CO.. Inc.      MOORE-CLARK CO.. Inc.
                                                        LaConner, WA 98257         1350 E. Kent Ave.
                                                         Net Weight 25 Kg.       Vancouver, B.C. V5X 2Y2
                                                                                    Reg. NO. 810650 












                                                                                                                  rA
             RESPONSE TO LETTER NO. 71: PETER J. EGLICK

                                                                                                                  W

             1.     Comments noted. See the response to Question 2.
                                                                                                                 U
             2.     Comments noted.


             3.     Some of the surficial sediment in Pacific Northwest benthic marine habitats                   rA
                    consists of particulate organic material, including fecal material from a large
                    number of animal taxa. Up to 20% of the benthic sediments may be particulate
                    organic material in some of the British Columbia fjords (Thomson 1981). In that              P4
                    most of the fish wastes and uneaten food are particulate organic material, once
                    they are on the substrate, they can be considered to be sediment. Organisms
                    living in and on the bottom will treat the material deposited under the pens as
                    sediment.

                    Many areas of Puget Sound have        *relatively low levels of particulate organic
                    material, and any increase in the organic content could be considered to be
                    pollution. "Organically enriched material," however, is a more precise term than
                    the general term "pollution" and was used here to specifically indicate the type of
                    perturbation occurring in the benthic environment.

             4.     Section 5.1 of the FEIS includes a discussion of collection devices, blowers, and
                    vacuuming under farm sites.

             5.     Comments noted. The text has been revised to evaluate regulations and existing
                    guidelines in the FEIS.

             6.     See the response to Question 18.

             7.     Comments noted. The Preferred Alternative in the FEIS recommends that the
                    hydrographic studies identified in the Interim Guidelines be adopted into WACs.

             8.     See paragraph 1, page 40 of the DEIS. The following sentence states: "Generally
                    in marine waters, phytoplankton growth is either light or nitrogen limited, and
                    phosphorus is not as critical a nutrient as it is in fresh water" (Ryther and
                    Dunstan 1971, Welch 1980). Additionally, salmon produce proportionately much
                    less phosphorus than nitrogen, and that phosphorus is mostly in the form of solids,
                    transported to the bottom and out of the surface waters. Note that phosphorus
                    is discussed again on page 46 of the DEIS and page 43 of the FEIS.

                    Although there has been no systematic comparison of NY ratios in every division
                    of Puget Sound, in every case where nutrient limitation was suspected, nitrogen
                    appears to have been the limiting nutrient or at least was in relatively less
                    abundance, using the index of Redfield ratio of N to P found in "normal" waters
                    (16:1 molecular ratio for plant tissue, about 10:1 molecular ratio for water samples,
                    see URS 1986).








                Response to, Utter No. 71: Peter J. Eglick (continued)

                9.     The first cited study did not show that leachates of other nutrients from farm
                       feeds influenced phytoplankton growth in Sequim Bay, because there are no
                       salmon farms in that bay.

                       The second study, referred to by the University of Sterling publication, indicated
                       that biotin increased the toxicity of one type of dinoflagellate (not found in Puget
                       Sound) under depleted conditions of that compound. Increased growth or toxicity
                       of a noxious dinoflagellate would be expected when a necessary ingredient was not
                       available in the culture system.      The real question is whether biotin is an
                       important regulator of either the toxicity or the growth of marine dinoflagellates.
                       The best answer is no. Biotin, like several other trace materials required by
                       certain algal forms, apparently doesn't limit their growth frequently in natural
                       systems. This has been repeatedly shown by the full-growth response nearly
                       alwa,    attained with the addition of nitrogen (Welch '1980) to marine
                           ys
                       phytoplankton cultures.

                       The cited report did not indicate that biotin is in short supply in the marine
                       environment. Moreover, the quote appears to be taken out of context without the
                       summarizing section which follows . . .         "At present, the leaching of these
                       compounds (i.e., vitamins) into the aquatic environment has riot been generally
                       recognized as an area for concern."

                       An important principal to this discussion was initially advanced by Liebig's in 1843
                       and is yet to be discredited. That principle states that plant yield is. essentially
                                                         e                                - st supply. There
                       determined by the amount of on nutrient which is in the shorte
                       is little doubt that nitrogen is the factor of concern for marine environments and
                       that if it is in short supply, any amount of biotin added to the water would not
                       have an effect on.algal populations.

                       Biotin, like many enzymatic precursors and cofactors, is required only in extremely
                       small amounts by cells. It is not an enerf;y source but is a catalyst of certain
                       reactions. In contrast, nitrogen is required at a much greater rate. Moreover,
                       biotin is a very small component of fish feed (0.03%) relative to nitrogen bearing
                       protein (40-50%). Uneaten food is transported by gravity to the bottom where
                       physical or biological processes remove biolin and other components.

                       There are many other trace minerals and vitamins that are sometimes required
                       by certain phytop'lankton under certain conditions. The DEIS did not address
                       these as they are generally recognized as of secondary importance. A short
                       discussion of biotin and other trace nutrients has been included in the same
                       section of the FEIS.

                10.    See the responses to Questions 33 and 34.

                11.    Significant shellfish habitat is protected through the HPA permitting and SEPA
                       review processes. V;DF has the responsibilily to preserve, protect, perpetuate, and
                       manage shellfish resources under RCW 75.08.








            Response to Letter No. 71: Peter J. Eglick (continued)


            12.    See Section 5.4 of the FEIS.             The Preferred Alternative includes a
                   recommendation for further research related to accumulation of antibiotics in
                   shellfish.

            13.    VMF protects shellfish habitat under RCW 75.08. The HPA permitting and SEPA
                   review process provide the opportunity to identify important shellfish habitats.

            14.    See the response to Question 29 and Appendix G.

            15.    See the responses to Questions 33, 34, and 35. Also, see the response to Letter
                   38, Comment 35.

                   Mr. Svein Mehli is not recognized as a fish health expert. While there are
                   situations in which the Norwegians believe that certain pathogens were introduced
                   into Norway as a result of moving infected smolts/fish into Norway from infected
                   sites, these fish were brought in and released as part of "Wild" or feral stock
                   enhancement, and not as a result of commercial marine fish farms. Furthermore,
                   a significant impact on stocks in Norway has been the result of eradication
                   programs and not necessarily clinical disease and mortality of fish. Inquiries on
                   fish health issues should be made to WDF.

            16.    See the responses to Utter 52, Comments 12 and 14. Literature on viewer
                   preferences indicates that the background setting contributes to a viewer's
                   It expectation" or sensitivity to alterations in visual character. In general, viewers
                   in a "natural" setting tend to expect fewer human-made alterations to the
                   landscape than they would in urban settings where the visual character may be
                   dominated by human artifacts. A fish farm facility would probably have fewer
                   visual impacts in an urban setting than in a "natural" setting. The type of activity
                   engaged in by the observer also affects their visual sensitivity.

                   A good reference for the issues relating to observer preferences are the articles
                   in the 1979 volume Proceedings of Our National Landscape edited by G.H. Elsner
                   and C. Smardon and prepared by the USDA, Pacific Southwest Forest and Range
                   Experiment Station, Berkeley, California. Other articles can be found in the
                   journals Landscape Planning and Landscape Architecture. For example, the 1977
                   article entitled "Who values what?: Audience reactions to coastal scenery" in
                   Landscape Architecture Vol. 67, pages 240-243.

                   Observer preferences, despite these studies, cannot be meaningfully summarized
                   for an area as large as Puget Sound. For this reason, the EIS discusses this topic
                   in a general way. Local jurisdictions may attempt to assess observer preferences
                   and take them into account when making changes to their local shoreline
                   programs.

            17.    See the response to Question 10.








                Response to Utter No. 71: Peter J. Eglick (continued)

                18.    See the response to Question 18.

                19.    See the response to Question 4.

                20.    The DEIS and technical appendix did not state that the Squaxin Island area was
                       a "worst-case analysis" as the reviewer asserts (see page 50, first full paragraph).
                       Ile text explicitly stated that the study area was the 'Worst-availabl case"
                       (emphasis added). See the response to Question 20 for further information on the
                       rationale.

                21.    The investigator had no control over the natural variation of nitrogen
                       concentrations in the study area. The study had to be conducted during a narrow
                       time, window of late spring when maximum fish biomass was present, during calm
                       weather, and moderate tidal exchange. Moreover, initial testing of the waters a
                       few days prior to the survey of late May was conducted to see if low nutrient
                       concentrations were prevailing. The results (DEIS, Technical Appendix C page
                       6 last paragraph) indicated that nutrients were in relatively short supply, and thus
                       it would be appropriate to conduct the study.

                22.    See Section 1 of the response to comments after the text in Appendix E.

                23.    Comments noted. See the response to Question 7.





                                                                               LETTER NO. 72





                                                                    ADril 7, 1989


          To: Ron Westley, Project Manager
          Washington Department of Fisheries
          11S General Administration Building
          Olympis, WA 98504



          From: Dr. Carol Ehlers

          1356 Wind Crest Lane

          Anacortes, WA 98221



          Re: DPEIS Fish Culture in Floating Net Pens


          I appreciate the opportunity to comment on those areas within my expertise and
          to add information or raise issues that should be of use.



          Housekeeping items:
          1) A postmark deadline is much more fair than a receipt deadline; it gives those of
          us miles from Olympia the same time for work and reflection as those in Olympia. I
          recommend that ALL future issues be given a post mark deadline.
          2) While I recognize that, in northern Puget Sound, WWSU, the University of
          Washington, Seattle and Everett city libraries are the depositories of Washington
          documents and are therefore, of course, sent such documents as the DPEIS, there
          are whole sections of the state affected by these documents who do NOT have
          access to these libraries. WDF should establish a list of county libraries where
          documents of this nature are received as a matter of course. Skagit Valley College
          has offered to house these at the main library in Mt. Vernon and the 3 branches
          on Whidbey Island. Anacortes library also wishes copies. Other areas should be
          asked if they wish to have them.
          I trust that I, and the above libraries, will receive copies of the final version

          of the EIS.



          PEIS text:
          The bibliography included in the text is characteristic of a research document.
          I note, however, that there are no references to guidelines established by other












                                                                                          2.
             nations or.states who have or are developing salmon-net pen culture. I find
             this a serious weakness in view of the extensive literature cited of problems
             extant and nascent in these other areas. For that reason I urge that the
             testimony of Svein Mehli before the Shoreline Hearings Board on November 14,
             1989 (SHB No. 88-14 Skagit Systems Cooperative vs. Skagit County and the
             Department of Ecology) be read and included in the PEIS. It is; now available
             in text form. (I received my copy this morning.) In view of the fact that
             Washington officially expressed concern this winter about the needs of sport
             f.,ishermen and that Mr. Mehli's job in Norway is to preserve wild runs for
             their g6netic value and for sport fishing, his concerns about the need for
             greater distances between net-pens and rivers containing wild salmon (p. 28),
             the establishment of security zones with no pens allowed at all. (29-40), the
             need for stricter guidelines (62-64, 68-69, and 106-136) and his comments on
             specific current Washington rules, guidelines and recommendations (reeent
             Norwegian experience indicates that some of these need major modification)
             should not be ignored.


             Washington should get the international organization regulations and guidelines
             and establish connections with agencies abroad that have current information.
             Again referring to the cited bibliography and to what I have heard at SHB
             sessions, It must be remembered that there is often a delay of several years
             between the recognition of a problem, admission of its size or potentiality, and
             solutions. Academic publications often never do address issues, so to depend
             heavily on these sources is foolhardy. Further, basic data and research may
             never be published; I am told'that the UW and WDF have extensive data on crab-,
             but it is unavailable to those who need it. Information unavailable cannot be
             helpful; those ignorant of data or problems are condemned to experience them
             just as those ignorant of history often find they are forced to repeat.


             Technical appendices:
             I note that Robert Stokes "The Economics of Salmon Farming" appears not in the
             text but only in the appendix. Despite the money paid for its production, it
             should be removed entirely. The explanations are difficult to follow - when
             given, the model flawed, and the data used are questionable. Astudy like this
             should be replicable, should have refernces and a methodology that can clearly












                                                                                     3.
           lead to the conclusions reached. I do not mean by this to criticize Mr. Stokes
           personally; he kindly gave me an explanation of his research methods that have
           improved the report and reduced the frustrations of those trying to read it.
           I have serious qualms about the results.


           I was bemused by his comment that the input-output model assumes that any job
           is filled by a newcomer to the area, with family, when the industry is
           promulgated as a way of reducing local unemployment. I worry about an assumption
           that ratios remain the same even though economic conditions nationally,
           regionally and locally are best represented by calculus showing non-concurrent
           cycles of growth and recession. I doubt models that show how wonderful X is
           after learning the number of times in history when the national or regional
           data, or model, shows all is well and the populace/small businesses are being
           destroyed. I question an algebraic model:  in the 1980's, major economist$ and
           industries are using calculus. The assumptions on pp. 13-1S are questionable;
           I find it fascinatin that these farms will impact mining and wholesale trade
           in San Juan county but not in others, and that the impact various so greatly
           re. federal, state and local government. What Tables 4.2-7 mean in real life
           is unclear. As I understand others will address the model, my comments will
           focus on the property section.


           The Skagit County Assessor, a member of the Board of Equalization and I have
           tried to replicate the data used for Skagit County. We cannot. The Assessor,
           Paul Mahoney, wishes to be able to address these issues to you directly. He
           notes that the assessment rates are vastly under reported, that it appears that
           tideland assessments were used rather than waterfront, and that the sites
           selected are not representative. Specifically, it is incorrect to compare
           assessed value (which mu@st be, by law, close to market value) with what is
           here called market value but really is asking price. On Burrows Bay recently,
           the asking price was $179,000; the price received was $105,000. The difference
           is too great +aiSnocain a study of this kind. There were to be no sites
           included within municipalities; of the 80 listed, 4 are in Anacortes. A map
           of the county shows that Sinclair Island is a small proportion of the total
           area and that there is no ferry; 11 of the sites, or 14% (608 acres) of the
           total sites are from Sinclair. While no site on the Guemes north Beach (where











                                                                                    4.
            aquaculture is proposed) is included, a site on Cypress Island ,Lbove at least
            three current salmon pen sites is - in an analysis of the potential of what
            might happen. All told, 30 sites of the 80 are on islands, som,e 37.5 %"
            Burrows Bay is represented by lots ranging from 3.92 to 206 acr,eas. We cannot
            find the 206 acre site, and Mr. Stokes agrees that it might not be there but
            somewhere else. But in Skagit County, where a site is makes all the difference
            in how it is assessed. The assessor notes also that, since the waterfront
            assessed valuation is much higher than describe@d, all conclusions arrived at
            via the computer program are incorrect. Further, if the data in other counties
            are parallel to those in Skagit, the whole study must be done over -- with less
            debateable methodology.


            I am equally concerned by how this data can be mis-used in the future. If, for
            example, the home sites on Burrows Bay really are that large, then the owners
            really would be wealthy. But neither is true. Most have front footage of
     G      75-100 feet, and depth of 100-200 feet. Instead of 4-206 acreas, most lots
            are .4-.8 acreas - not counting the land going vertically down a cliff. The
            implications are vastly different. I hope Skagit County will not have to spend
            money to defend itself from the mis-use of the data.









             RESPONSE TO LETTER NO. 72: CAROL EHLERS



              1.     Comment noted.


              2.     Comment noted.

              3.     Mr. Mehli provided testimony on the problems associated with the fish farming
                     industry in Norway. The environment and history surrounding the Norwegian
                     problems are different than what exists in Puget Sound and drawing simple
                     parallels would not be appropriate. Norway has natural wild runs of Atlantic
                     salmon whose populations have declined due to overfishing, acid rain, and
                     hydroelectric development. Norwegian fjords have poor water circulation. The
                     Norwegian governmental structure has a different means of reviewing development
                     proposals for environmental impacts.            Biologists, geneticists, and fish disease
                     experts working in Washington are aware of the problems in Norway and the
                     guidelines they use in management.

                     Mr. Mehli's testimony included an admission that he had no knowledge of the
                     fish farming industry in Washington, or the State regulations that currently exist
                     in Washington to prevent problems such as those found in Norway (page 13 of
                     the transcript).

              4.     Comments noted.


              5.     Comment noted.

              6.     See Section 2 of the response to comments after the text in Appendix E.

              7.     See Section 2 of the response to comments after the text in Appendix E.

              8.     See   Section 2  of the  response   to  comments    after  the text  in Appendix     E.

              9.     See   Section 2  of the  response   to  comments    after  the text  in Appendix     E.

              10.    See   Section 4  of the  response   to  comments    after  the text  in Appendix E.

              11.    See   Section 4  of the  response   to  comments    after  the text  in Appendix     E.





                                                                      LETTER NO. 73






                                                       12110 S.E. 16th Place
                                                      Bellevue, WA. 98005
                                                      March 20, 1989



            Ron Westley
            Project Manager
            Washington Department of Fisharies
            General Administration Building
            Olympia, Washington 98504


                      Reference: Draft      Programmatic Environmental Impact
            Statement


            Dear sir:


                 The referenced Programmatic Environmental Impact Statement
            does riot adequately address my concerns as a waterfront property
            owner adjacent to one of the planned sites. While the referenced
            Statement. addresses pollution, visual blight, and noise it does
            riot:
                 1. Recognize the impact on privately owned beach property
                 from the pollution washing ashore. My surveyed property line
                 is at approximately the mean tide level. Many waterfront
                 properties include the tide lands. Depending on the winds
                 and tides, debris is washed up on my property from the
                 adjacent waters. Salmon feed and fish feces would wash up on
                 privately owned land making that expensive land unsuitable
                 for the recreational pursuits which make the land valuable.
                 The state will undoubtedly be sued by property owners
                 because of the pollution of their private property from fish
                 feed and feces.
                 2. Recognize the extent. of the noise pollution in a quiet
                 area. Noise from the water carries extremely well in a quiet
                 environment. We can many times hear conversations from
                 people on boats. At rii,;ht the activity on salmor, per-is would
                 be the predominant noise in the whole area. Noise ir, a quiet
                 area has at-, enti-ely i-Jifferent impact than noise in a
                 noisier area, and that. is riot recognized in the statement.
                 .3. The importance of visual blight to expensive waterfront
                 property is not. recognized in the Statement. The loss of
                 revenue to the State from the decrease in property values
                 from that item alone is just riot adequately recognized.
                 4. Recognize the importance of easy access to open water for
                 waterfront property.
                 5. Recognize the large impact to the property tax revenue
                 that the state will receive, or the potential cost of suits
                 by private property owners when their property is polluted
                 because of actions of the state.


                                                 Yours truly,
                                                     4
                                                          4t@
                                                          v,n
                                                       Mar      . Eisenbach









     @O        RESPONSE TO LETTER NO. 73: MARVIN E. EISENBACIHI
     eD


                      Comments noted.
     eD
               2.     See the response to Letter 1, Comment 59. The different background levels of
                      noise: and the consequent differences in impacts are discussed on page 121 (third
                      paragraph) and 123 (first paragraph) in the DEIS, and in Section 6.6 of the FEIS.

               3.     Property values are discussed in Appendix E. The conclusion of this study is that
                      visual quality impacts associated with fish hirms may affect prOperty values, but
                      this affect is difficult to separate from the many other locational factors that could
                      affect property values.

               4.     The issue of navigation for both commercial and recreational vessel traffic is
                      discussed in Section 6.2 of the FEIS. A substantial impact would result if a fish
                      farm facility impaired navigation to and from a particular property.

               5.     SEPA does not require this type of analysis,





                                                                                LETTER NO. 74



             Mr. Ron Westley, Project Manager
             Washington Department of Fisheries
             115 General Administration Building
             Olympia, Washington 98504
                                                         7 April 1989

             Re: Draft Programatic EIS on Fish Culture in Floating Net Pens

             Dear Mr. Westley,

                 Thank you for the opportunity to comment on the DPEIS. Although I am not
             opposed to the practise of net pen culture in the waters of Greater Puget
             Sound, I feel strongly that the DPEIS does not adequately address a variety of
             concerns I have about the way in which such activities are currently
             conducted. In addition, the DPEIS does not provide adequate guidance for
             managers to make decisions critical to the siting of future operations in the
             Sound.


                  For this document to be useful for managers, it will be necessary to
             distinguish where its findings are in conflict with the current interim
             guidelines and to specify the types of monitoring programs needed to meet to
             the standards the State wants to uphold. In addition, the generic nature of
             this document cannot adequately address site-specific concerns. As written,
             this document does not do away with the need for individual impact statements
             to be written for each new site. This point is particularly relevant to the
             limited discussion on cumulati've impacts. Water quality impacts need to be
             addressed on a site by site basis, not in terms of the effects on the BOD of
             *the entire Sound.


                   While there has been substantial documentation of ways to mitigate the
             benthlc perturbations resulting from typical net pen operations, simply siting
             future net pens in regions of high current velocity does not preclude the need
             to obtain NPDES permits from EPA.  The justification for this ascertion is
             eloquently stated In Sierra Club Legal Defense Fund's February 8, 1989 letter
             of intent to sue EPA under Section 505(a)(2) of the Clean Water Act, 33 U.S.C.
             1365 (a)(2), for failure to require the State of Washington to require NPDES
             permits for salmon net pen facilities.

                  The primary concern I have with current net pen operations is use of
             Atlantic salmon species. On page 69 of the PEIS It Is stated that, "Many
             introductions of exotic species worldwide, however well meaning, have led to
             ecological disasters. Not only might the animal itself spread unchecked, but
             diseases these animals may carry might spread to native species-" There is
             still a paucity of information regarding the potential impacts to native
             salmon stocks from parasites and diseases introduced by non-endernic species
             commonly used in net pen culture. Regardless of the cause of the recent
             outbreak of VHS, the fact that it occurred demonstrates that our wild stocks
             are susceptible to diseases carried by Atlantic salmon and that our current
             precautionary measures are not adequate. The fact that an abundance of adult
             Atlantic salmon were caught in the San Juans this past summer (see enclosed
             article) and that the PEIS states that occassional Atlantic salmon have also
             been observed in the Nooksack, Skagit and Nisqually Rivers demonstrates that
             these issues still need to be adequately resolved. In the mean time,
             Washington State should put a temporary moratorium on granting new net pen



                                             -1-









               permits or at least fol low the example Alaska has set by I imiting their net
               pen Culture to species endemic to the North Pacific.

                    The extent to which Atlantic species have been observed in Washington's
               streams and fisheries should be better quantified in the final PEIS and a
               monitoring program should be specified. Although previous at-tempts to
               establish runs of Atlantic salmon have not been successful, it should be noted
               that those attempts were primarily limited to the Introduction of juvenile
               fish which have a low survival rate. A minimum siting distance from natural
               rivers should be established for all future operations to reduce the
               likelihood of net pen fish competing with natural runs. If it is found that
               Atlantic salmon have to be used, despite the risks they pose to this state's
               billion dollar sport and commercial fisheries, a sterile form should be bred
               to minimize the likelihood of impacting native runs.

                     I am also concerned about the potential net pens have of creating scenes
               throughout the sound like we have at the Ballard Locks. "Hershel" and his
               associates have shown us that marine mammals have the @ability to learn where
               the easiest meals in the Sound are to be found.    Once -these sea lion soup
               kitchens are discovered, they are not readily abandoned. Page 81 of the PEIS
               states, "The presence of captive fish and a floating habitat usually attracts
               predatory- birds and marine mammals." Page 82 of the PEIS states, "There are
               only a few isolated incidences where intentional killing (of marine mammals)
               has occurred." The number, location and spe:Ies of such Intentional killings
               should be! specified in the final PEIS as well as the number of permits
               currently held by net pen facilities to lethally remove salmon predators. The
               interim guidelines recommend that a net pen should not be sited within 1500
               feet of a marine mammal haul-out or bird colony. What Is the biological basis
               for this recommendation and what are the criteria that a permitting agency
               must follow to enforce such recommendations? Similarly, why is it only
               recommended, and not required, that net pens use anti-predator nets. The
               requirements should also specify the mesh size of such nets to minimize the
               likelihood of entangling marine birds and mammals.

                      The fact that killer whales were not mentioned as potential predators
               on net pen salmon is a particular oversight -to be addressed when considering
               siting of future net pens. Over 80 resident killer whales frequent the waters
               of Greater Puget Sound. Intensive field studies conducted since 1976 have
               shown that these animals movements and behaviors are adapted for salmon
               predation (Thomas and Felleman 1988; Felleman et al. 1989). Regions
               frequented by resident killer whales have been quantified (Helmlich-Boran 1988
               see figure). These regions should be avolded by net pen operations to prevent
               unnecessary interactions with a species too powerful to be restricted by anti-
               predator nets and too well loved by the public to be subject to intentional
               harassment.


                    Final ly, the DPEIS should compare the net economic benefits of standard
               net pens with land based tank farms. While it is asserted that tank farms
               have significantly higher start-up costs, these expenses should be evaluated
               in context with the various benefits tanks have over pens. It is my opinion
               that most of the concerns raised over net pens could be mitigated by the
               siting tank farms instead. These benefits include: 1.) overall higher survival
               rates and harvest rates; 2) decreased food costs because of higher conversion
               ratio; 3) greater control over the environment; 4) ability to add oxygen,



                                                -2-










            thereby lowering the risk of disease even at higher stocking densities; 5) not
            dependent on weather for routine operations; 6) no water dependent use
            conflicts; 7) avoidance of predator problems; 8) point source discharge can be
            treated and easily regulated with NPDES permits; 9) easier to observe and
            sample fish to monitor disease; 10) less need to use chemicals and
            antibiotics; 11) less likelihood of fish escaping, thereby enabling non-
            endemic species to be raised without jeopordIzIng native stocks.

                 The above mentioned benefits of tank farms amply justify a closer
            analysis of their net economic viability. However, special consideration
            should be made to the placement of the Intake pipes needed to pump water into
            the tanks. Regulations should be established which define the appropriate
            depth of the intake pipes and means by which entrainment of wild fish could be
            minimized.


                 In conclusionY the DPEIS does not provide adequate justification for Its
            conclusion that no significant impacts will occur with the Immediate
            development of up to 100 salmon net pens in Greater Puget Sound. I hope the
            above comments help to make this document more useful to managers and more
            responsible to the citizens of Washington State who greatly value and depend
            on the marine environment for the livelihood and enjoyment.




                                          Fred Felleman, MSc.
                                        Conservation Biologist
                                          4007 Latona Ave NE
                                          Seattle, WA 98105































                                             -3-
















                                                  REFERENCES

               Felleman, F.L., J.R. Heilmlich-Boran, R.W. Osborne (1989 1n press).    Feeding
               Ecology of Killer Whales (Orcinus orca) in Greater Puget Sound. In : K. Pryor
               and K.S. Norris (Eds) Dolphin Societies.   U. of California Press, Berkeley.

               Heimlich-Boran, J.R. (1988). Behavioral Ecology of Killer Whales (Orcinus
               orca) in the Pacific Northwest. Canadian Journal of Zoology 66(3):565-578.

               Thomas, G.L. and F.L. Felleman (1988). Acoutic Measurement of the Fish             
               Assemblage Beneath Killer Whale Pods in the Pacific Northwest. Rit               
               Fiskldeildar Vol. 11: 276-284.



                                      References Not Found in the DPEIS:


               MacCrummon and Got (1979)


               Quinn (1982)






































                                                   -4-


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    ~qU~~al fishermen were the first to catch Atlantic: salmon in Northwest waters. The fish have never been known to survive in the Pacific bef~s~qm.                 In e~xcha
                                                                                                                                                                has agree
                                                                                                                                                                against th
                                                                                                                                                                involved i
    Atlantic salmon caught ~4qM~_~*~q_ San Juans                                                                                                                       April 19~4q84
                                                                                                                                                                  Barry J~qo
                                                                                                                                                                hired by I~0qJ
             By ILENE ANDERSON                              'Nowhere have ~qA~ql~ql~ant~qic~s survived               said Austin.                                         the county
                 and JIM LEH~0qDE                              and repro~qd~u~tc~e~qd away from native                 The possibility of pen-reared fish                 admission
                                                                                                           escaping and mixing with wild breeds                 the ~settlem
     A~qUantic salmon began last week flop-                   ~qW~d ~qt ~e~qm.                                       raises many questions of genetics and                  The deci
    p~in~~ aboard gillnetters and se~qiners                                             Eric Hur~qiburt         disease control.                                     ance ~comp
    fishing Salmon Bank off San ~qju~an                             State Deparlment of ~6qR~sherles                                                                   company p
    Isl~nd~~i Cattle Point.                                                                                   ISLAND ~qF~qIS~4qME~4qRMEN are reporting                     than $100
     Never before have Atlantic salmon                lings acclimated in the wes~'~l~. or smolts             catching Atlantic salmon at a pretty fair            pay Grant
    been known to survive in Pa~qdific waters.          released, "never to be seen again once               ratio.                                               insurance
     Identifying characteristics are a wide           they were released Into the sea.                       ~'~@One to four fish per salmon landing              attorney ~0qfe
    mouth, X-shaped spots, and a fairly                 "Runs have not developed and It's                  have been reported by north Puget                      "I was
    straight tell with no spots, "resembling          been a universal situation - around t~qthe             Sound buyers," said Austin.                          them," Jo~0qh
    a steelhea~d as much as any breed," said           world - that nowhere have AtIantics~                   About three hundred are reported to                Involved.
    Dennis Austln~, chief of harvest manage-           survived and reproduced away from                    have been caught by an enterprising                  to do the ri
    ment o~fthe state Department of Fisher~-            native waters of the U.S. eastern                    sockeye seiner after chumming (with                    "Out) I
    les.                                              seaboard," he said.                                  rock-salt) what appeared to be a school              settlement
                                                        Theories are many and rumors                       of giant hungry trout on the surface.                was a chan
     ATLANTIC SALMON are successful-                  abound at the state level about where                  Fish buyers report the ~"hor new
    ly pen-raised In hatcheries, but have             the~qi~qi~qi fish came from, according to                  salmonid is commandingCoho prices of                   ~8qWWE
    neverbeen known to survive In the wild.           Austin.                                              between $1.50 to $2 a pound. The fish                ~qbly would
     Eric Hurlburt, aquaculture coordina-               Island fishermen speculate they                    weigh an average of nine to 12 pounds.               than that.
    ~for for the state Department of Fisher-           escaped from rearing pens on Cypress                   However, Austin said they're illegal               tial,~"Johns
    ies said there have been many unsuc-              Island, followed the wild sockeye out                to catch and sell commercially. ~"At~qian-                At one
    cessful attempts during the past 90               into the ocean and are coming back in.               tics in Washington are clas~si~qf~qled as a               Grant's leg
    years to introduce Atlantic salmon Into             Fisheries ~o~8qf~8qf~8qicials~.are guessing Atlan-            game fish unless being rea~re~-~qd in a pen.             Initially, G
    Pacific waters.                                   ties are. escapees from pens of U.S.                 ~qT~0qhey have to be treated ~*~:~xac~qUy as                   million.
     He said the attempts usually started             - -igin because of where they are being              incidentally-caught steeihead - releas-
    with either eggs hatched into finger-             caught. "But they can be Canadian,"                  ed live if possible."
 















                                              CAN. J. ZOOL. VOL. 66, 1988


                                         124*W,              123*W




                                                            V
                                                             ancouver.,,
                             VANCOUVER
                                                                  SER RIVE,7
                                ISLAND

                                                                          C
                                                                           ANADA
                                                                      . .............................. . .....
                           49*N
                                                                       UNITED STATES



                                                                        IrT) Beiiingham



                                     British Columbia

                                                                        V)
                                                    ytctoria







                                      Washington
                         @-48-N          RESIDENT WHALES                       ;)48*N-i;
                                     NO. OF ENCOUNTER DAYS
                                              El 0
                                               01-5
                                                 6-10                          seattle
                                                   >10

                          PACIFI
                                C
                           OCEAN           0 10 20 30 40 50
                                                kiiometres                   Tacoma

                                           0   10    20 30

                                                miles

                                        124'W              1243*W OlYMDia
                         r47*N        I   I                 -  A--- -
                                     MG. 3. Distribution map of resident whale encounters.






                                                  Source: Heimlich-Boran, J.R. (1988).










           RESPONSE TO LET17ER NO. 74: FRED FELLEMAN


           1.     The text has been revised for the FEIS to evaluate existing regulations and
                  guidelines. This EIS was not intended to replace site-specific analysis. See the           U
                  response to Question 1.                                                                    0

           2.     See the response to Question 17.

           3.     See the response to Question 29.                                                           W
                                                                                                             09
           4.     See the response to Utter 38, Comment 31.

           5.     Smolts may have a lower survival rate, and they have released about five million
                  to date without success. A minimum siting distance from rivers may be developed
                  as part of a management plan. The technology to produce sterile fish is available.

           6.     Comments noted. The Intedin Guidelines were developed using the best available
                  informatior@ professional judgement of experts in the field, and undertaking a
                  conservative approach. In Section 5.9 of the FEIS, the Preferred Alternative
                  includes a recommendation that anti-predator nets be required in areas where
                  WDW, USFWS, or NMFS indicate that predators may be present.

           7.     The text has been revised for the FEIS to include a discussion of killer whales as
                  potential predators at fish farms.

           8.     SEPA does not require this type of economic analysis. A complete evaluation of
                  tank farms and comparison to floating fish farms is outside the scope of this EIS.

           9.     Comments noted.





                                                                     LETTER NO. 75


                                                             March 20, 1989




             Mr. Ron Westley, Project Manager
             Washington Department of Fisheries
             115 General Administration Building
             Olympia, WA 98504

             Dear Mr. Westley:

             Thank you for the opportunity to respond to your Draft
             PEIS on salmon net pens in the Puget Sound region. My
             response includes a summary of my remarks at the hearing in
             Mount Vernon on March 9, and some additional information
             which there was not enough time to discuss at the hearing.

             I live just north of Hope Island on the bay. We have been
             living with fish pens for almost two years. The pens are
             located almost exactly 2,000 feet off shore from my home.
             There are no other commercial operations in this residential
             recreational area.

             I would like to address the sections in the PEIS relating to
             noise, odor, aesthetics and recreation.

             ODOR is addressed on Page 124 and we certainly agree that
             the odor is bad from the variety of sources listed. Odor is
             particularly objectionable on warm days with the prevailing
             winds. Odors are especially strong during net cleaning
             operations. Mitigating measures in the PEIS on Pages 125
             and 126 include increasing the distance of the pens from
             residents and placing the pens downwind to reduce the smell.
             Downwind just transfers the problem to someone else and
             moving them offshore would put them in shallow water and
             would move them closer to the State Park beaches. These are
             not practical solutions.

             NOISE (Pages 122, 123). We residents are bombarded by noise
             from a variety of sources related to the pens. These
             include trucks, automobiles, and loading operations at the
             shore launch site; motor boats going to and fro several
             times a day; radios and loud speech at the pen site (sound
             travels over water); and compressors running for long
             periods during net cleaning operations.     Employees at the
             site set out numerous crab pots and tend them from the pen
             site via the pen motor launches. Various night-time
             operations are conducted with larger vessels operating with
                                                              -hods such as
             flood lights. The PEIS suggests mitigating met
             farther away, avoid siting in small populated bays. These
             don't work in Skagit Bay because there are only two small
             restricted locations where fish farming is feasible even
             though the interim guidelines state differently.








              To: Mr. Ron Westley          -2-                March 20,1989


              RECREATION (Page 118). Again the mitigating factors
              sugges'fe'j-by the PEIS are largely impractical in the case of
              the net pens already in place. Example: avoid areas of
              intense recreational use such as fishing holes. The two
              fishing holes north and south of Hope Island are the only
              deep enough and protected places to put fish pens in Skagit
              Bay. Example: Avoid areas within 2,000 feet of State Park
              beaches. These pens are already there.

              AESTHETICS (Page 89). 1 live 2,000 feet from the fish pens.
              They j-o -n-ot appear as a line on the horizon. We see it all
              including-Tioats, nets, buoys, boats, people, a 10 x 20 foot.
              shack, stacked supplies, a 11fting boom, etc.

              On Page 4 of the PEIS the railing height of the pens is
              listed as 3 to 4 feet above the water surface. Figure 3
              drawing on Page 6 shows the railing height at 6 feet above the
              water. In the Aesthetics section of the PEIS where the
              visual effects of the pens are developed the railing
              height is specified as 1 meter or 39 inches. I personally
              measured it at just under 5 feet. Figures 14 through 18
              showing the pens as a line on the horizon at 2,000 feet are
              deceptive and unbelievable and should be redone using the
              actual railing heights used in practice.

              The mitigating measures listed for Aesthetics conflict with
              navigation and fishing regulations and are mutually ex.clusive.

              Example: "Materials used should be non-reflective and somber
                         hued .
              Navigation states: "Use highly visible-colors."

              Example: "Site pens further off shore.
              Navigation states: "Site pens CIOSE? to shore."

              Example: Use small sets of pens instead of one large
                        complex.
              Again, this conflicts with navigatir)n and fishing.

              Similar conflicts occur in the NoiSE! and Odor sections.

              A final Aesthetic conflict is.the effluent from these pens
              on top, of the existing fecal coliform pollutants coming from
              other sources.

              I conclude from reading your draft EIS that your proposed
              policy, is highly dependent on the "Recommended Guidelines
              for the Management of Salmon Net Pen Culture in Puget ,
              Sound." This document was issued in 1986 and while this was
              a useful document at that time, it should not in my opinion
              be Used now as a basis for policy. The reasons for this are
              manifold and can be summarized as follows:









            To: Mr. Ron Westley           -3-              March 20, 1989


            The Guidelines are not site specific and therefore should
            not be considered for the wide variety of potential
            locations in the Puget Sound area. This point was
            eloquently brought out by Svein Mehli, the Director of
            Nature Management for the Norwegian Ministry of Environment,
            in testimony before the Shoreline Marine Board in N-ovember,
            1988. He testified in opposition to the siting of salmon
            pens in Skagit Bay. When asked by the appellant's attorney
            if various of the Puget Sound Interim Guidelines were valid
            he refused to generalize and based on his 15 years of
            experience with over 700 net pen installations in Norway,
            testified that each site is unique and the Norwegian
            reg.ulations are far more specific and.stringent than the
            Washington Guidelines. Nevertheless they are still faced
            with numerous disease problems: Gyrodactylus Salaris -in
            30 rivers, BKD (Bacterial Kidney Disease) in 100 net pens,
            Red Mouth Disease in 300 facilities, and Furunculosis. The
            only way to eradicate some diseases from the rivers is to
            destroy all fish life in the rivers by poison and then
            restock the rivers, which they are doing. The Norwegian
            fish pen industry uses 48 metric tons (105,000 lbs.) of
            antibiotics annually attempting to control these diseases.

            Following are examples of some of the Norwegian regulations
            to prevent the spread of these diseases:

                 1) No pens sited within 20 Km (12.4 miles) of a salmon
            r i v e r .

                 2)  Establishment of 51 Security Zones within which no
            pens are allowed in order to separate existing pens from wild
            stocks.

                 3)  No pens allowed where water salinity is less than
            25 ppt (parts per thousand). Nowhere in your draft EIS do I
            find any reference to concerns about transfer of disease in
            brackish waters.

            The only site specific information contained in the Puget
            Sound Interim Guidelines is in Table 5 "Calculations for
            .Water Quality Guidelines." The authors developed an
            empirical formula based on the premise that nitrogen
            @oncentrations in each Puget Sound embayment could safely be
            increased by 1% as a result of effluent from fish pens.
            They then extrapolated this number into allowed fish
            production in pounds. In the case of Skagit Bay which is
            heavily polluted (the beaches are closed to shellfish
            collection and recreational use) and already has the highest
            nitrogen concentration of any bay in Puget Sound, the 1%
            increase by formula worked out to 5.9 million pounds
            annually. This, amazingly, in the shallow polluted estuary
            of the Skagit River, the largest salmon producing river in









              To: Mr. Ron Westley            -4-               March 20, 1989


              Puget Sound. This annual production number is far, higher
              than that for any other embayment and is always quoted by
              the fish pen proponents. Th.e reality is that there are only
              two small holes, one each north and south of Hope Island,
              that are deep enough for siting fish pens outside of the
              navigational channels. These holes are approximately 3
              miles north of the mouth of the Skagit River and are in the
              same tidal stream. Because of the fresh water effluent from
              the Skagit River the water salinity is low, and varies from
              7.3 ppt to 29 ppt. The examples of Norwegian regulations
              cited above, if implemented here, would prohibit fish pens
              anywhere in Skagit Bay on several counts instead of allowing
              5.9 million pounds of annual production.

              Finally, the Interim Guidelines on their face state they are
              not intended to replace existing regulations, Shoreline
              Master, Programs, or local ordinances. In developing these
              guidelines no public hearings were field and SEPA procedures
              were riot followed.

              Based on the above we are concerned that the guidelines are
              out o,f date and are being used far beyond their intended
              scope. Policy on net pen aquaculture should in our vievi--be
              driven by the Shoreline Management Act and updating of the
              Counties Shoreline Master Programs to reflect the current
              understanding of the technology. Your draft EIS falls short
              of providing the necessary information to accomplish this.



                                                        S i n c e r e 1 y
                                                        (z)XI "o, @-   -  zet
                                                        Dale E. Fi    er
                                                        1614 Snee Oosh Road
                                                        La Conner, WA 98257
                                                                    ier










            RESPONSE TO LETTER NO. 75: DALE E. FISHE


            1.    Placing a facility downwind of a residential area may reduce impacts if upwind
                  land uses are not sensitive (for example, industrial uses) or if upwind uses are        U
                  fewer than downwind uses. Placement of facilities in respect to predominant              0
                  wind direction is a locational parameter that should be considered in specific
                  cases. It may or may not provide a solution in an individual case.

                                                                                                           rA
            2.    Comments noted.

            3.    Fish farms sited before January 1989 did not have the information in the DEIS
                  available during the siting process.

            4.    Comment noted. Where structures such as sheds and buildings exist or where
                  equipment remains on the farm, the farm would be more visually evident.

            5.    Comments noted.

            6.    See the response to Question 10.

            7.    The text has been revised for the FEIS to evaluate the impacts of fish farming
                  under existing regulations and guidelines, including the Interim Guidelines. Mr.
                  Mehli testified at the Shoreline Hearings Board that he had no knowledge of the
                  existing regulations used in Washington to control disease.      Each fish farm
                  proposal is given site specific review through the HPA, Shoreline, and Section 10
                  permitting programs; and through the SEPA review process.

            8.    Comments noted.

            9.    The same concerns should exist for fish in salt, brackish, or fresh water. 'nere
                  is nothing unique about brackish sites in terms of pathogen movement.

            10.   Comments noted. The maximum production values in the Interim Guidelines are
                  not guaranteed amounts. 'nere was no site specific determination whether a
                  sufficient number of sites are available to reach that maximum production level.

            11.   Comments noted. The Interim Guidelines are guidelines and not regulations.
                  However, they could be adopted into WACs in the future.

            12.   Comments noted.





                                                                                               LETTER NO. 76

                DEPARTMENT OF HEALTH & HUMAN SERVICES                                    Public Health Service


                                                                                         Food and Drua Administration
                                                                                         Seattle Uistnct
                                                                                         Pacific Region
                                                                                         22201 23rd Drive S.E.
                                                                                         Bothell, WA 98021-4421
                                                     March 22, 1989                      Telephone: 206-486-8788

                Mr. Ron Westley
                Project Manager
                Washington Department of Fisheries
                115 General Administration Building
                Olympia, WA 98504

                Dear Ron,

                I have read the Draft of the Environmental Impact Statement for Fish Culture in
                Floating Net Pens. It is an impressive document. I have a few comments that
                are given below:
                I .  Most of the narrative regarding VHS will have to be rewritten due to the
                     recent finding of the virus in Washington State. In light of this, it might
                     be helpful to provide more details about how VHS is detected, how exactly
                     the eggs are certified as to being free of VHS and what exact precautions
                     are taken to avoid the introduction of this and other viruses. To put VHS
                     in proper perspective, it would be useful to discuss other viruses of
                     fishes.

                2.   p. 115
                     More information can be given on V. vulnificus. This species causes two
                     distinct clinical infections. Wound-infe-ctions can occur in healthy
                     individuals. The second more serious infection has most frequently been
                     associated with ingestion of contaminated raw oysters and can result in a
                     primary septicemia and a mortality rate exceeding 50% in individuals most at
                     risk (patients with prior or ongping. liver dysfunction resulting in high
                     serum iron levels). This organism is more prevalent on the Gulf Coast
                     compared to the West Coast. however. Kaysner et al (1987) found a low
                     incidence (5.9%) of V. vulnificus in water, shellfish. and sediment (N=529),
                     sampled on the WesFCo-a-s-t.-Tn-Washington State only I sample was found
                     positive for V. vulnificus of 112 samples analyzed of sediment, water, and
                     shellfish froFn @a-nous estuaries of the State. The positive sample of
                     sediment was taken from Willapa Bay. (I have enclosed some papers on V.
                     vulnificus).
                3.   V. parahaernolyticus was found specifically in 3/48 samples (6%) and only in
                     August it you need the exact level. Also, most of the predominant Vibrio
                     species we have found so far in our net pen study has been V..alginolyticus.
    7 @v*





























                     Although V. alginoiXticus is not considered a pathogen in the U.S., it has
                     been impfl-cai-ect in illness associated with consumption of seafood in other
                     countries (Chapman, 1987).
        0
                4.   p. 117
                     Regarding the fish feed. care may also need to be exercised in not only
                     storage but also production of fish feed.














                page 2
                Eric Hurlburt and I sampled Port Angeles and Manchester on 2/14/89. As soon as
                the data are available, I'll send them. We have to sample at Squaxin Island
                when we can arrange it. I hope these comments wi)[I be helpful to you. Best
                wishes.




                                                  Marleen M. Wekell, Ph.D.
                                                  Director, Seafood Products Research Center

                Enclosures

                cc: Dr. Ralph Elston









         RESPONSE TO LETIPER NO. 76:          UNITED STATES FOOD AND DRUG
         ADMINISTRATION


         1.    See the response to Question 29 and Appendix G.

         2.    Comment noted. See the response to Question 33.

         3.    See response to Comment 2.
                                                                                          rA
                                                                                          W
         4.    Comment acknowledged. Storage and production methods are important in order
               to maintain feed quality.






                                                                 LETTER NO. 77


                                     James Fox
                                   P.O. Box 1188
                              Friday Harbor, WA 98250
                                     378-5513







         April 6, 1989





         Mr. Ron Westley
         Project Manager
         Washington Department of Fisheries
         115 General Administration Building
         Olympia, WA 98504


         RE: Draft Programmatic Environmental Impact Statement
              Fish Culture in Floating Net Pens


         Dear Mr. Westley,

         Enclosed please find my comments on the draft PEIS, Fish Culture
         in Floating Net Pens. I have confined my comments to the
         section in the Technical Appendices titled The Economics of
         Salmon Farming by Robert L. Stokes.

         I appreciate the extension of the deadline for public comment on
         the PEIS. The document is highly technical and sufficient time
         was necessary for adequate public review.


         S
           ncerely,
          i
       '@mes R. Fox, Ph.D.









                                 COMMENTS BY J. FOX ON:

                           "The Economics of Salmon Farming"
                Technical Appendix to Fish Culture in Floating !qet Pens


           This study estimates the economic impacts of five "typical"
           salmon farms, one in each of five Puget Sound counti(Bs. For most
           of the counties the study appears to be based on a generic
           input-output model that has been scaled down to fit iLthe local
           economy. Since, to my knowledge no specific input-output model
           exists for all of these five counties, I feel that the county-
           level impacts (and therefore the sum of these impacts) must be
           viewed with great caution. The sensitivity analysis should also
           address the inadequacies of the model itself, in addition to
           testing the sensitivity to the assumptions concerning the inputs
           to the model.

           The estimates of state-wide direct and indirect impacts on
           employment (257-303 jobs) for 5,000,000 lbs/year fish production
           differ from numbers derived from estimates by Crutchfieldl,,
           suggesting 140-200 jobs resulting from a similar yearly
           production. Insufficient information is given by either author
           to evaluate this discrepancy. The difference may result in part
           by the use of a $4/lb sales price by Crutchfield and $5/lb by
           Stokes, which would effect the number of jobs created due to
           indirect effects.

           Competition with the commercial fishing industi:-x

           A major economic impact of salmon farming ignored in the PEIS is
           the effect of competition with the commercial salmon fishing
           industry., In 1987, 9.4 million lbs. of salmon were produced by
           salmon farms in Washington2 (or 3.4 million lbs as sIL-ated in the
           PEIS) compared with a commercial salmon landing of 56.4 million
           lbs3. However if the annual productio.n of farmed salmon reaches
           predicted levels of 45-75 million lbs (based on a prediction of
           $225,000,000 annual sales4) there will undoubtedly be competition
           with the commercial fishing industry for existing and new markets
           and a resulting price decrease.



                1 Crutchfield, J. Aquaculture: N rose with plenty of
           thorns. Pacific Northwest Executive 5:1, 1989.
                2 Heggelund, P. Salmon farming in Washington: The issues
           and the potential. Pacific Northwest Executive 5:1, pp 2-6, 1989.
                3 Washington Department of Fisheries, personal communication
                4 Heggelund, P. Salmon farming in Washington: The issues
           and the potential. Pacific Northwest Executive 5:1, pp 2-6,
           1989.










                                        2

         The economic impacts of Washington's commercial fishing industry
         have recently been estimated5. Due to diminishing natural runs,
         increased necessity for regulation, and to other factors, this
         industry is hovering on the point of extinction. A major reason
         for its continued viability is the connection with Alaska
         fisheries. The economic impact of the Alaska fishery on
         Washington (due to Washington boats and fishermen fishing in
         Alaska and to importation of Alaska-caught fish for processing)
         has also recently been estimated6. Were Washington to loose its
         commercial fishery, many Alaska fishermen would no longer have a
         reason to live in Washington and to base their boats here. Based
         on the above-mentioned studies, the combined effect of the Alaska
         and Washington fisheries on Washington employment (both direct
         and indirect) is over 11,000 FTE jobs. Thus any disruption of
         the Washington commercial fishing industry due to competition by
         salmon farming could have potentially serious economic
         consequences. The effect state-wide could more than negate any
         advantages of salmon farming, and on a local level where some
         communities depend to a great extent on commercial fishing for
         their economic survival, the results could be even more serious.

         Impact on government revenues and expenditures

         An economic impact on State and local government expenditures
         omitted from the PEIS is the cost of providing government
         services specifically to salmon farming. This includes support
         of the Aquaculture division of the Department of Agriculture, the
         cost of permit processing by a number of agencies, and the cost
         of monitoring compliance with requirements or restrictions
         placed on permits.

         Economic impacts to local governments were not considered in the
         PEIS. Local government incurs many costs in providing services
         to the industry (planning, permit processing, monitoring) as well
         as services to employees the industry will attract to the
         locality. The fraction of new salmon farm jobs filled by non-
         resident workers will be much greater on a county level than on a
         state level. In addition, the tax revenues generated by fish
         farming primarily go to the State and are not returned to the
         county. Thus, although the net economic impact of salmon farming
         to state government may be positive, it is more likely that the
         impact will be negative at a local government level. This means
         that local residents effectively will have to subsidize fish
         farms with their tax dollars. The net result will be determined


              5 Economic impacts and net economic values associated with
         non-Indian salmon and sturgeon fisheries. Washington State
         Department of Community Development, 1988.
              6 Bourque, P. Alaska economic impact on Puget Sound.
         Ranier Bank Economic Research, Columbia Group, 1988.









                                            3

           partly by the number of non-resident employees, the amount of
           non-local financing, and local economic: multipliers.

           Impacts on the local economy

           Discussion in the PEIS of the aesthetic impacts of fish farms
           took intoaccount only the impact on residents living within
           sight of the farm. The impacts on the general public and on
           visitors (tourists) was ignored. In San Juan County, as an
           example, the driving forces in the local economy are tourism,
           growth and retirement--all directly resulting from the quality of
           the environment, especially the visual environment. Anything
           that degrades that environment1will undoubtedly effect the local
           economy.

           One crude measure of the economic value of the "quality of life"
           of a region is the wages that workers are willing to sacrifice in
           order to live in that region. San Juan County had a 1987
           workforce of 5340 persons who worked for an average annual income
           per worker of $14,680, compared to a state average of $22,7277.
           The difference between the county and the state average income,
           multiplied by the number of County workers is nearly $43,000,000
           per year. Much of this can be attributed to the "quality of
           life" in the County.

           The value of the tourism industry to the San Juan County economy
           has been estimated as $15,000,000 per year in 1.982 in taxable
           retail sales directly attributable to @:ourism8.

           Although it is difficult to estimate the effect of degradation
           of the visual environment on these figures, it is clear that
           there would be some effect, and that tl.-iere is a lot at risk.

           Summary

           In conclusion, three major economic impacts were omitted from the
           PEIS: the! effect of competition with the commercial fishing
           industry; the effect on local government revenues and
           expenditures; and the effect of degradation of the visual
           environment on the local economy. Each of these factors could be
           hi ghly significant. Adding to these impacts is the risk of
           reducing the wild salmon runs due to disease 017 dilution with
           inferior fish and the resulting loss to the commercial and
           sports fisheries. .


                7 Fox, J. and Hodgkin, C. 1988 economic and demographic
           almanac of Washington counties. Infor).,nation Press, Eugene,
           Oregon, 1.988.
                8 Tourism in San Juan County: Fi.nal report of the San Juan
           County Tourism Planning Committee, 1985.










                                        4


        It seems that at best salmon farming simply trades one industry
        for another, redistributing jobs and wealth, but with a net
        advantage that, even if greater than zero, offers little compared
        to the unpopularity of the salmon farming industry and the risk
        to wild salmon runs--one of Washington's greatest treasures.









             RESPONSE TO LETTER NO. 77: JAMES FOX


             1.     See Section 2 of the response to comments after the text in Appendix E.

             2.     See Section 2 of the response to comments after the text in Appendix E.

             3.     See Section 1 of the response to comments after the text in Appendix E.

             4.     See Section 3 of the response to comments after the text in Appendix E.

             5.     See Section 1 of the response to comments after the text in Appendix E.





                                                                               LETTER NO. 78



                 FRIENDS OF THE EARTH                                7 April 1989



                 Ron Westley
                 WA Department of Fisheries
                 115 General Administration Bldg.
                 Olympia, WA 98504

                 Dear Mr. Westley:

                      We have received a copy of the Draft Programmatic Environmental
                 Impact Statement for Fish Culture In Floating Net Pens. The following
                 are the comments of the N.W. Office Friends of the Earth:


                 GENERAL COMMENTS

                      According to the DPEIS summary (p. W., the Washington State
                 Legislature directed the Departament of Fisheries to evaluate the
                 environmental impacats of net pens on the biological and built
                 environments. We are extremely disappointed that the Department of
                 Fisheries did not prepare this document under Its normal State
                 Environmental Pol Icy Act obi Igations. We do not bel !eve that It is
                 necessary for the State Legislature to activate the preparation of
                 Programmatic Environmental Impact Statements.
                      In addition, we find the DPEIS does not adequately present upland
                 fish farms as an alternative.
                      We further question the participation of Parametrix In the
                 preparation of this DPEIS. Please provide a listing of all contracts
                 which Parametrix has had with the fish-pen Industry, or any State Agency
                 on this subject.

                 More specific comments are as follows:

                 SUMMARY p. Ix. Please provide a copy In the Final PEIS of the
                 legislation directing the Departmebt of Fisheries to evaluate the
                 environmental Impacts of net pens.

                 B. DESCRIPTION OF ALTERNATIVES, p. 8

                      Up-land fish farming is a viable alternative to In-water net pens.
                 The advantages include being able to treat the effluent prior to
                 discharge Into a water body. An up-land fish farm operation has been
                 proposed for Westport, WA. While a discussion of up-land fish farms is
                 found beginning on page 135, it is clearly not one of the four
                 alternatives listed on page 8. We request that up-land fish-farms be-
                 considered as part of the alternatives to be considered.






                Northwest office 45 12 University Way NE Seattle, Washington 98 105 (206) 633-1661
                                                               V












                                                        -2-



                     Four alternative levels of development are proposed In this section. On
               what legal basis could the state set a maximum number or acrei-tige of fish
               farms? In other words, since there is no cur-rent mechanism for setting a
               maximum limit on fish farms, the "net" result for the state, will simply be
               the cumulative decisions of multiple local jurisdictions. Therefore, the PEI S
               must set out a "worst-case-scenario". With the state actively promoting fish
               farming and the Ecological Commission vetoing local efforts to managing this
               1 ndustry, the PEI S shou I d exam 1 ne a far grea-,@er number and acreage of f I sh
               farms than Alternative 4, which might result from these policiles.

               Permits and Approvals pp. 8-12.      According to the Department of Ecology,
               aquacu'Iture (include fish pens) is now a preferred shoreline use. Since the
               Departments of Natural Resources and Agriculture are firmly on record as
               promoters of this Industry, where in state government !is there an opportunity
               for an impartial decision on such developments?

               Department of Ecology p. 11.     Provide a reference for the statement that 11WDOE
               is responsible for planning for the accommodation of competing interests in
               the use of thes resources-" Ecology can not be both the protector and planner
               for development in this state.

               Environmental Protection Agency p. 12. Please add that under the Federal
               Clean Water, Congress established a national goal of zero discharge of
               pollution to our nation's waters.

               c. Mitigation Measures p. 26. "Dispersion" Is not a mitigation technique.
               While state law stlil permits dilution as a !solution to pollution, the Federal
               Clean Water Act does not provide for "dispersion" as either a best management
               practice or best available technology. We request that this section be
               deleted from the FPEIS.


               c. DISEASE pp. 76-81.    Please describe where and how the disposal of diseased
               fish is carried out.

                     What is the magnitude of the impact from transmission of disease to wild
               fish under a worst case scenario?


               Marine Mammals p. 82. Please list the number of marine mammals which have
               been killed by net-pen operators and the number of permits given by the
               National Marine Fisheries Service for this purpose since 1972.

               Birds.,p-. 84. Please list the number and species of birds which have been
               killed by net-pen operators and the number of permits given by the U.S. Fish
               and Wildlife Service since 1972.


               Description of impacts. p. 98. It states that net-pen density could be
               control I ed by measures adopted into I ocal shorel I ne master pr ograms. A I arge
        13     portion of Hood Canal, as well as other portions of Puget Sound are split
               between two counties. Just north of Henderson Inlet, for exanple, Mason,
               Pierce and Thurston Counties all cane together. How can local shoreline















                                                  -3-


           master programs take Into account what the adjacent local master programs
           contain? Doesn't It make more sense for a State Shoreline Management Act to
           set state policies and not rely on a a hodge-podge of local decisions?

           SLIMMARY


                In conclusion, we find the DPEIS has ignored a worst-case-scenarlo, both
           fran the standpoint of accidental Introduction of an exotic disease into state
           waters and from failure to examine the impacts from more than 100 farms. It
           Is inconsistent to state that the accidental Introduction of an exotic disease
           into state waters remains a risk and at the same time conclude that 100 fish
    0      farms would not have a significant impact on the aquatic environment.
                We find that there Is little to be gained and perhaps much to be lost In
           rushing ahead with fish-pen projects In Puget Sound. No further fish-pen
           projects should be permitted until the Puget Sound Water Quality Plan has been
           fully developed and Implemented. We do not need another polluting industry on
           Puget Sound at the same time extensive efforts are underway to clean it up.

                Please send us acopy of the Final PEIS when It Is available. Thank you
           for the opportunity to comment.

           IShcer
                r



           David E. Ortman
           Northest Representative

           DEO:jwp









            RESPONSE TO LETTER NO. 78: FRIENDS OF THE EARTH                                                   W



            1.     Comment noted.

            2.     The EIS evaluated the use of floating fish farms. The description of land-based
                   tank farms was included to provide additional information on the commercial fish
                   farming industry. This section has been moved to the Technical Appendices to
                   clarify that it is meant as additional information.

            3.     See the response to Question 2.

            4.     The legislation directing WDF to undertake an environmental assessment of the
                   fish farming industry is included as Appendix J.

            5.     Comments noted. See the response to Comment 2 above.

            6.     Comments noted. In the DEIS, the State did not set a maximum number or
                   acreage of fish farms, but rather presented a range of industry production levels
                   that the industry may or may not attain in Puget Sound.           See response to
                   Question 3.

            7.     The Legislature determined that aquaculture is a preferred use of the state's
                   shorelines.

            8.     The Shoreline Management Act (RCW 90.58.020) states: "It is the policy of the
                   state to provide for the management of the shorelines of the state by planning for
                   and fostering all reasonable and appropriate uses." Ecology is responsible for
                   administering the Shoreline Management Act.

            9.     Comment noted.

            10.    The fish farm industry will be required to obtain NPDES permits to comply with
                   federal water quality regulations. See Section 5.2 of the FEIS.

            11.    Dead fish from public and private hatcheries and fish farms are removed from the
                   site and disposed in a sanitary manner; such as at an approved landfill or sold
                   to a rendering plant.

            12.    Comment noted. See the responses to Questions 25, 26, 27 and 29. Also, see the
                   response to Utter 1, Comments 15, 16, 18, 19, and 20.

            13.    See the response to Question 30.

            14.    See the response to Question 32.

            15.    Establishing a maximum fish farm density to control potential aesthetic impacts
                   on a State level would not allow the necessary flexibility to account for different








              Response to Letter No. 78: Friends of the Earth (continued)
                     local conditions. Local government is the appropriate entity for determining what
                     aesthetic standards should be used for their jurisdiction.

              16.    Cornments noted.





                                                                                LETTER NO. 79



                                                                   April 6, 1989


        Ron Westley, Projectmanager
        Washington Department of Fisheries
        General Administration Building
        Olympia, Washington 98504

                                                  Re- Fish Culture in Floating Net Pens

        Dear Mr. Westley;

        Thank you for sending along to me copies of the Draft Programmitic Environmental
        Impact Statement- Fish Culture in Floating Net Pens. I have looked at the
        material in the copies sent and have also attended three workshops being held in
        my County@ As of this time I feel comments here regarding net pen culture would
        be too voluminous. In short, listed-b6luw are items that I feel still remain
        unsatisfactorily unanswered.

        1. Impact on water quality and bottom sediments in confined areas are bound to
            conflict with present conditions.
                 a. Fish and Shell fish
                 b. Aquatic organisms

        2. Impact on Built Environment would be almost uncontrolable regarding the
            following:
                 a. Aesthetics                            e.  Recreation
   (D            b. Navigation                            f.  Noise
                 a. Commercial  fishing                   g.  Odors
                 d. Human health                          h.  Oil spills

        3. Upland and Shoreline Use.
                 It is unfortunate that only five pages  were reserved for upland and
                 shoreline use.

        STATEMENT: Through all the hundreds of thousands of   dollars siDent In the
        introduction of Fish Culture in floating net pens in  Puget Sound, the thousands
        of hours of testimony                         untold dollars by opponents of
                                                  -@re those who live and work in
                               volunteer committees
        fish pen culture, it is unbelieveable ther
        Washington on or near the shores of the Sound are trying to find ways and
        justification for polluting "The Sound", endanger native fish and shellfish,
        and make this pristine body of water a cesspool and with the introduction of
        figating net pens armund its shore they would be allowing the introduction
        opVisual pollution as well       sofar as the citizens of the state are being
                                          it be upland where this commercial venture
        .r rced to accept aqualcultur4:t
        can be regulated as a business should be, and most unknows and critical impacts
        can be controled.


        Sincerly,
                              A,-
        Barry L/. Graham
        784 Olympus Blvd.
        Port Ludlow, WA. 98365









        @O            RESPONSE TO LETTER NO. 79: BARRY L GEAHAM
        M
        CA
        00
        0
        W             1.        Comments noted.
        M
        0-11
        0             2.       ComLments noted.
        r)
        0
        9             3.       Comments noted.
        9
        M

        V-41
        W





                                                                                                            LETTER NO. 80

                    ADELAIDE - AMSTERDAM - ANCHORAGE - AUCKLAND. BOSTON - BRUSSELS - BUENOS AIRES - CHICAGO - COPENHAGEN - DUBLIN
             FORT LAUDERDALE - GOTHENBERG - HAMBURG - LEWES - U.K. . LONDON o LUXEMBOURG - MADRID * MONTREAL - OSLO * PALMA DE MALLORCA
                    PARIS - ROME - SAN FRANCISCO - SAN JOSE - COSTA RICA - SEATTLE o STOCKHOLM - SYDNEY. TORONTO o VANCOUVER - VIENNA
                                                WA6HINGTON - WORLD PARK BASE - ANTARCTICA - ZURICH




                               Greenpeace USA e 4649 Sunnyside Ave N 0 Seattle WA 98103 0 Tel (206) 632-4326
                                                              Fax (206) 632-6122

                   March 21, 1989

                   Ron westleye Project manager
                   Washington Department of Fisheries
                   115 General Administration Building
                   Olympia, WA 98504
                   (206) 753-6642

                   RE: Draft Programmatic Environmental Impact Statement- Fish
                   culture in floating net pens. Washington Department of Fisheriest
                   January 1989.

                   Dear Mr. Westley:

                   Greenpeace U.S.A.r an environmental organization with 35s.000
                   supporters in the state of Washington# and one million supporters
                   in the United States, appreciates the opportunity to comment on
                   the above-referenced document.

                   Greenpeace is well established in environmental issues# and is
                   perhaps best recognized for work involving ocean policy and
                   marine wildlife. The culture of marine fish in floating net
                   pens, and the implications of its widespread practice in
                   Washington state's marine waters# is therefore within our
                   tradition scope of interest involving environmental and
                   ecological concerns about the ocean.
                   while in general we find that the Draft Programmatic
                   Environmental Impact Statement (DPEIS) discusses many relevant
                   issues regarding the placement and operation of aquaculture
                   facilities in state waters, we believe that in several areas the
                   DPEIS is inadequate. it is our desire that our comments be
                   utilized to develop a more adequate Programmatic Environmental
                   Impact Statement (PEIS).

                   In particular we believe the DPEIS to be inadequate in regards to
                   describing the species and population status of wildlife that are
                   likely to interact with the net pen facilitiest in assessing the
                   potential and probable impacts to marine mammals and marine-
                   birds, and in defining appropriate mitigation measures to limit
                   the impacts of net pens to wildlife.

                   A first example is that marine mammals and birds are extremely
                   mobile animals# and undoubtedly will be attracted to the
                   facilities. Mot only birdl seal and sea lion species have the
                   potential for interacting with aquaculture facilities. The very
                                  Gii












































                   real potential exists that orcas (killer whales) could discover
      (D           the feeding opportunities present at salmon pens. Orcas are
                   already documented to adapt to fish industry activities#
                   interacting on a regular basis with long-line and trawling
                   operations in Alaska, causing significant damage to harvests in
                                                R E r Y C L E D P A P E R











             the former (Matkin 1988p Dalheim 1988). The PEIS should discuss
             the forms of anti-predator nets that would be required to
             mitigate interaction between cetaceans and net pens because the
             newly reauthorized Marine Mammal Protection Act (MJRPA) prohibits
             any intentional harassment or killing of any cetacean, including
             orcas. The PEIS should also discuss siting that WIDUld prohibit
             the pens from areas frequented by orcas.

             A second example is that to truly anticipate sites where
             interactions may be likely to occur# siting criteria should be
             based not upon an arbitrary 1#500 f00t separation between
             habitats of special significance and pensy but instead upon a
             more comprehensive review of bird,, cetacean and pinniped movement
             patterns between migration, transit# haulout, feeding# and
             resting sites. And in any case, a mere 11500 foot separation
             between birds, marine mammals and net pens is unrealistically
             small as an effective mitigation measure.

             A third example is that the PEIS should discuss that the needs of
             aquaculture may compete with those of marine birds for
             euphausiidso an important prey for planktivorous birds. An
             example is the harvesting of euphausiids by fish farmers in
             British Columbia. At present the euphausiid fishery in British
             Columbia is small at 500 tons per years, but is projected to
             increase to 100#000 tons by 1995 if -euphausiids are used as the
             sole protein source in salmon feeds. if the trend of harvesting
             euphausiids continuesf many planktiv.orous birds may be
             detrimentally affected by the loss of a high-energ, food usually
                                                               .Y
             obtained prior to breeding (Vermeer -at al. 1987) (Vermeer and
             Morgan,, 1988).

             The PEIS should address whether euphausiid. harvesting will be
             allowed in Washington state's watersf whether imports of
             euphausiids harvested in British Columbia will be allowedp and
             the resulting potential impacts from this activity.

             Our general recommendations for adoption into finall regulations
             concerning the permitting of net pens are that:

             - anti--redators nets be mandatory at all net pen facilities,,
                   P
             and/or where they are not installed 'that any harassmentf
             trapping, or lethal removal of marine birds or mammals be
             explicitly prohibited;

             - siting criteria be strengthened to establish significantly
             greater separation than 1#500 feet between net pens and wildlife
             Ohabitat of special significancelm and that such habitat be more
             comprehensively definedl

             - the terms of the recently reauthorized and amended Marine
             Mammal Protection Act (MMPA) be reported in better detail to
             communicate that it is currently illegal to harass or
             intentionally take any cetacean (including orcas)v or
             intentionally lethally take any northern sea lion or northern fur
             seal. .











           - euphausiid harvesting in state waters, or importation from
           British Columbia, for fish feeds be prohibited until more is
           known about the harvestable euphausiid biomass and the importance
           of euphausiids to marine birds and other organisms.

           Our specific comments and questions on the DPEIS follow# along
           with recommendations for the PEIS:

           Page 73
           The PEIS should estimate the total number of net pen Atlantic and
           coho salmon that are expected to escape annually into Puget
           Sound, and/or estimate the escapes per net pen facility.

           The PEIS should discuss in greater detail the genetic distinction
           between hatchery-cultured fish already being intentionally
           released into Puget Sound, and the preferred net pen stocks# such
           as those of coho salmont that will be accidentally released into
           Puget Sound.

           The PEIS should include genetic models illustrating the potential
           impacts of net pen stocks of Pacific salmon interbreeding with
           variously sized populations of native salmon.

           The PEIS should explicitly state that the "differential
           mortality" that would result from native fish hybridizing with
           net pen fish possessing traits maladaptive to natural conditionst
           would result in a decline in fish survival rates in the wild.

           Page 74
           The PEIS should list in detail the anecdotal as well as
           documented captures by commercial and recreational fishermen of
           Atlantic salmon in the ocean waters of Washington and British
           Columbia during 1988 and earlier years# and attempt to explain
           the likely origin of the fish and the escape levels that produced
           them.

           The PEIS should discuss the ecological threat posed by escaped
           Atlantic salmon to native fish species under scenarios where the
           Atlantic salmon do and do not establish a breeding population.

           The PEIS should discuss in greater detail the funding and status
           of current and future monitoring programs to assess the level of
           mature Atlantic salmon and domestic coho salmon returning as a
           result of accidental releases to Pacific rivers and streams.

           Page 75
           The PEIS should describe the program in southern Argentina# in
           particular the number of fish releasedr which successfully
           establish Atlantic salmon outside the species' natural range.

           .Page 79
           The PEIS should describe in detail everything that is known about
           the disease and the recent outbreak of the serious exotic
           pathogent viral hemorrhagic septicemia (VHS)# in Puget Sound
           salmon.













             The PEIS should discuss the fish species known to carry and be
             effected by the disease.

             The PEIS should explore the likely vectors of VHSr such as
             imported Atlantic salmon eggs.

             The PEIS should describe the impacts to hatchery operations when
             VHS is discoveredr and the recommended protocols for preventing
             spread of the disease in hatcheries, net pens, and free-swimming
             populations such as those in rivers.

             The PEIS should assess the possibility of net pen fish acting as
             reservoirs of VHSj and describe the comprehensive itesting program
             that is, now necessary in Washington and British Columbia for all
             stocks to assess the spread of the disease.

             Page 81.
             The PEIS fails to discuss adequately the potential of direct
             .mpacts to marine birds by accidental entanglement and drowning
             In net pens# and by shooting of birds by farm operators,, and
             indirect impacts by alteration of the birds' habitat and food
             supply.

             The PEIS fails to discuss the regulations in Washington State and
             British Columbia concerning the inte.ntional lethal taking of
             predatory birds# such as those existing which prohibit killing of
             certain species under the Migratory Bird Treaty Act (MBTA). What
             regulations would prohibit or control shooting of birds?

             If circumstances exist which would allow the lethal removal of
             certain birds, the PEIS should estimate potential mortalities in
             Washington State and British Columbia, and assess potential
             impacts; to the appropriate resident and migrant bird population.

             Page 82
             Marine mammal interactions with the facilities are discussed and
             acknowledged to be likely to occur. However a recommended
             guideline that operators locate net pens at least 1,500 feet from
             mammal habitats of special significance is poorly defined,
             unrealistic and inadequate. What is a "marine-mammal habitat of
             special. significance?" For instance, numerous chanj,,iels between
             islands; are key transit points for animals between the various
             bodies of water. Are these areas con.Bidered "habitats of
             significance?"

             The PEIS should describe "habitats of significance" for cetaceans
             such as orcas, Dall's porpoise and harbor porpoise.

             The PEIS should list all permits that are required by net pen
             operators to harass and lethally control birds#, pinnipeds, and
             cetaceans, and list the species that can be controlled under such
             permits.













          The PEIS should list all facilities in Washingtonf or elsewhere
          in the U.S. which have successfully controlled predators with
          anti-predator nets.

          Population status and potential impacts to marine mammals are
          inaccurately and inadequately discussed. The statement "Since
          implementation of the Marine Mammal Protection Actr seal and sea
          lion populations in Puget Sound and other Washington bays have
          increased in size and range" is inaccurate concerning the
          northern sea lion# the population of which has not recovered
          significantly and remains low averaging around 250 animals during
          the winter months. This species is under consideration for
          designation as depleted under the KKPA. The PEIS should state as
          much.

          The PEIS fails to discuss the occasional presence of northern fur
          sealsw a depleted speciest in the state's marine waters.

          Page 83
          Are all haulouts shown in Figure 12 considered habitats of
          special significance?

          Page 84
          What marine mammal predator control methods referred to by Gibson
          are or were used at the SeaFarm Washington facility?

          Since "observers often do not distinguish between California sea
          lions and northern sea lionsup as a responsible conservation
          measure the PEIS might propose that no lethal take of sea lions
          be allowed because of the risk of killing rare northern sea
          lions. Such a measure would help insure from the outset
          compliance with the newly amended KMPAr which now prohibits the
          intentional killing of any northern sea lion, except to protect
          humans from physical injury.

          What predation control method is proposed for river otters? Are
          leg-hold traps a legal option for control of this speciest or
          pinnipeds?

          What bird speciest other than the example cited with bald eaglest
          are documented to be benefited by net pens?

          The PEIS should include a list of the permits, administered by
          the U.S. Fish and Wildlife Service, that are currently held by
          aquaculture operators to kill and trap nuisance birds in the
          stater and should also list permits and estimate kills of birds
          in British Columbia.

          The PEIS should estimate how many additional permits will be
          issuedr and the overall mortalityr harassment, and trapping of
          birds the could potentially result in Washington State and
          British Columbial as the bird populations are homogeneous.













             Page 85
             Doe Figure 13 illustrate marine bird habitats of special
                s
             significance?

             Page 86
             The PEIS should list or summarize all information   gained to date
             regarding harassment or selected killing of certain marine
             mammals that threaten aquaculture facilities.

             In past, years the National Marine Fisheries service issued
            -"certificates of inclusion" under the Marine Mammal Protection
             Act to various aquaculture operations in Washingtons, Oregonj, and
             California, that allowed if necessary the lethal removal of
             California sea lions and harbor seals. The PEIS should contain
             and list the holders of and numbers of certificates of inclusion
             issued# the required annual reports (describing marine mammals
             interacted with or killed, the marine mammal species involved,
             estimates of annual marine mammal harassment# injuryr or death
             under the certificates, and aquaculture losses to marine mammals.

             The PEIS should contain maps or other data describing and
             identifying sensitive wildlife species and habitati3j, if figures
             12 and 13 do not identify such.

             Page 81'
             The PEIS should describe the "zone of separation" utilized by the
             USFWS to protect bald eagles or other endangered species from
             development activities.

             The PEIS should describe what is meant by "potential impacts to
             wildlife will be dependent upon site-specific considerations such
             as types and numbers of species in the area and proximity to
             sensitive habitat areas" by establishing criteria of species
             types and numbers which when met would allow developments, or when
             not met, would prevent development.

             Please provide citations for the statementr "However# because
             non-lethal methods provide effective controll significant impacts
             on [marine mammal] populations are not expected", that would
             support a contention that lethal measures are not needed to
             control predation.

             Page 88
             The PEIS should contain the National. Marine Fisheries Service
             policy on the current and future actions that can be taken by
                   'ture operators to protect their facilities from marine
             aquacul
             mammals predation, including an estimate of the level of lethal
             removal that could be allowed under the recently reauthorized
             MMPA by the NMFS. The PEIS should also describe the reporting
             requirements and level of government: observation that will be
             required by the NMFS under the terms of the MMPA.- and the
             enforcement capability within the state.













         The PEIS should make clear that is is illegal for aquaculture
         operators to harm any cetacean, northern fur seal# or northern
         sea lion.

         The PEIS should describe the program that will allow operators to
         be educated to distinguish between northern sea lions, northern
         fur sealst harbor seals# and California sea lionst so that no
         lethal removal of the first two species occurs.

         Because salmon net pens could be considered an attractive
         nuisance to marine mammals, some non-lethal methods to reduce or
         control predation should be required rather than simply
         "recommended guidelines." Double-walled pens, designed to
         effectively protect the fish while preventing entanglement of
         seals or sea lionsl should be required on all fish pens.
         Ideallyr such anti-predator nets should be designed if possible
         to protect against predation from both marine birds and mammals#
         while minimizing the likelihood of entanglement of the animals.

         The PEIS needs to discuss the types of anti-predator nets that
         are most effective at reducing bird and marine mammal predation
         while simultaneously preventing entanglement of the birds and
         marine mammals. The mesh size specifications provided "less than
         five inches" very likely will result in marine bird entanglement.
         In addition, materials specifications are needed that discourage
         monofilament webbing that may increase entanglement. If there is
         a lack of accurate information on what sort of netting is most
         effective at reducing predation while preventing entanglement,
         such research should be performed and described in the report.

         In conclusiont Greenpeace U.S.A. appreciates the opportunity to
         comment on the DPEIS, sincerely hopes our questions and comments
         are integrated into the final PEISr and desires that our
         recommendations be incorporated into any final regulations that
         are developed. If you have any questions or comments regarding
         this document feel free to contact me at our Seattle office.













         Prepared by: Ben Deeble
                       NW ocean Ecology Campaigner
                       Greenpeacd USA


















            References

            Dalheim, M.E. 1988. Killer whale (Orcinus orca) depredation on
            longline catches of sablefish in Alaskan waters. National Marine
            Mammal Laboratory, NMFS NW. 31 p.

            Matkinr C.O. 1988. Status of Prince William Sound killer whales
            and the. sablefish fishery in late 1987. Unpubl. Rep. to
            University of Alaska, Sea Grant Advisory Programs, 10 p.

            Vermeer-, K., Szabo, and P. Greisman. 1987. The relationship
            between plankton feeding Bonaparte's and Mew Gulls and tidal
            upwelling at Active Passr British Columbia. J. Plank. Res. 9:
            483-501.

            Vermeer', K. and Ken H. Morgan, 1988. Mariculture and bird
            interactions in the Strait of Georgia. Canadian Wildlife
            Service# c/o Institute of Ocean Sciencesp PO Box 6000# Sidney,
            British Columbiap Canada. llp.










            RESPONSE TO LETTER NO. 80: GREENPEACE



            1.     Comment noted.
                                                                                                             U
            2.     The text of the FEIS now specifically notes the presence of killer whales in the          0
                   area. The Intefim Guidelines currently provide the ability to screen out areas
                   regularly used by killer whales by designating them as habitats of special
                   significance.

            3.     The 1,500-foot recommendation made in the Interim Guidelines is, intended to be
                   applied site-specifically, based on many factors including those mentioned in the
                   comment. This process will occur as proposals for each fish farm are reviewed.

            4.     A study of a potential fish food industry based on harvest of euphausiids is beyond
                   the scope of this EIS.

            5.     See the response to Comment 4.

            6.     The Preferred Alternative in the FEIS includes a recommendation for requiring
                   anti-predator nets.

            7.     Comment noted. 'Me FEIS includes an estimate of escapement in Section 5.7.

            8.     There is no perceptible difference between normal hatchery fish and farm fish
                   except perhaps at the Global-Aqua facility in Clam Bay where some selection has
                   occurred. There will probably be a difference in 30 to 50 years unless selection
                   programs are restricted.

            9.     Modeling is possible to forecast reductions in variability. However, modeling
                   fitness reductions due to the presence of hypothetical maladaptive genes which
                   may or may not exist in the future is not possible.

            10.    The text has been revised for the FEIS.

            11.    Comment noted. The FEIS includes information about the 1988 Atlantic salmon
                   catch statistics.


            12.    See Sections 5.6 and 5.7 of the FEIS.

            13.    SEPA does not require a discussion of funding issues in an EIS.

            14.    Release figures would be very hard to come by. The stocking program began in
                   1904 in Argentina, and a hatchery was established in 1937 in Patagonia. The
                   important point to note is that there was no competition from other salmonids in
                   their rivers; whereas there would be significant competition with existing salmonid
                   populations in our rivers.

            15.    See the response to Question 29 and Appendix G.








               Response to Utter No. 80: Greenpeace (continued)


               16.   As discussed in the text, the potential impacts to bird populations by lethal
                     removal will depend on the degree and extent of its use and on the population
                     size of the affected species. The USFWS does not allcw lethal removal of birds
                     that are a nuisance to fish farming activities.

               17.   The FEIS discusses existing regulations and guidelines.

               18.   The USFWS does not allow lethal removal of birds that are a nuisance to fish
                     farming activities.

               19.   The text of the FEIS discusses habitats of significance.

               20.   The text of the FEIS discusses the permit systems of NMFS and USFWS.

               21.   Comment noted.

               22.   Northern sea lion populations in the Pacific Northwest are coj--isidered stable by
                     NMFS. Section 5.9 of the FEIS discusses the federal status of this animal.

               23.   The EIS does not specifically discuss every species remotely occurring in the study
                     area, but instead addresses representative members of' those groups of animals
                     likely utilizing the area. Northern fur seals observed in Washington usually are
                     well offshore along the coast, and are not tYpical of the marine mammals found
                     in State waters.

               24.   Not all haulouts shown in Figure 12 are necessarily considered habitats of special
                     significance.   Habitats of special significance are defined. by the WDW.
                     Designation of these areas may change over time as additional information is
                     gathered by the agency.

               25.   Gibs on was referring to anti-predator nets used at the SeaFarrn facility when he
                     made his comment.


               26.   Comment noted.

               27.   Predation control methods for river otters are the same as for marine mammals
                     and birds: the primary method remains predator nets.

               28.   Species such as grebes may congregate at fish farms due to wild fish attracted to
                     the area and by additional feeding opportunities associated! with the added
                     nutrients of an artificial feeding system.

               29.   See response to Question 32.








            Response to Utter No. 80: Greenpeace (continued)
            30.    The necessity for additional permits will depend in large part on where the new
                   facilities are located and on the wildlife utilization of the area. Determination of
                   need for a permit will be made as each proposed farm is reviewed.

            31.    Figure 13 illustrates major waterfowl habitats in Puget Sound. WDW makes the
                   determination of whether each is a habitat of special significance.

            32.    See response to Question 30.

            33.    Certificates of inclusion are no longer issued by NMFS. Section 5.9 of the FEIS
                   discusses the new requirements of the revised Marine Marnmal Protection Act.

            34.    Sensitive wildlife species and habitats are defined by WDW using an information
                   system based on continually updated information. Discussion of these animals and
                   habitats is appropriate during reviews for each proposed farm, when more precise
                   location information is important.

            35.    Comment noted.

            36.    The current guidelines specify that fish farms be at least 1,500-ft from habitats of
                   special significance, as defted by WDW. Additionally, facilities must meet the
                   terms of numerous federal and state statutes relating to wildlife.             Current
                   procedures allow consideration of site-specific wildlife conditions; establishing more
                   specific criteria can remove the flexibility of the system, making it less responsive
                   to any special needs of an area. See the response to Question 1. This request
                   is outside the scope of this EIS.

            37.    The statement was made based on conclusions of resource managers and
                   individuals experienced in fish farming culture.

            38.    See the response to Question 31.

            39.    Comment incorporated into text.

            40.    Discussion of this program is outside the scope of this EIS.

            41.    Comment noted.

            42.    Comment noted. Section 5.9 of the FEIS includes a discussion of specific anti-
                   predator net requirements.








Letter No. 81

March 25, 1989

Ron Westly
Department of Fisheries
115 General Administration Building
Olympia, Wash, 98504

Dear Mr. Westely:

I am stongly against your policy to make Puget Sound into fish farm for 
three reasons

First, as a trained biologist and as a professional in the Environmental Health
field, I am concerned with the introduction of a foreign species into our
waters.  Historically, the introduction of new species has met with disaster
for the existing species.  In many cases the existing species did not complete
as well.  This could be due to aggressive feeding habits, aggressive breeding
habits, disease, etc.

This has been documented numerous times.  In the bird and mammal
kingdoms, the example are many.  Two well known examples are the 
introduction of starlings into North America and mammals into Australia.
There aggressiveness reduces the available food and habitat for the existing
species.  Man should not tamper with these gentle balances.

Secondly, I am also concerned with the salmon genetic gene pool.  The 
mixing of one new species into another can spell death to the original gene
pool.  Already these Atlantic salmon have been found in our salmon 
breeding grounds.

Finally, if as your Fisheries Department contends, the VHS virus that now
causes great concern to our fishery is not from the introduced species then
why has British Columbia now banned the import of live salomon?  I believe
that they must have suspicions ir they would not have taken such action. I 
see this policy as a license to degredate the wild salmon that have survived
here so long.







I believe that you want the best for the Puget Sound.  But if you really
believe in the protection of Puget Sound then do not tamper with this
precious ecological system.  It might be too late already.

If you truly want to preserve the special habitat and it's inhabitants, then
protect it from this aggressive policy and halt futher fish farms. At a 
minimun, impose a moratorium until all the facts are in.

Sincerely

Lorna Parent Haycox
1141 Bayview-Edison
Mt. Vernon, Wash.  98273

cc: Governor Booth Gardner
Sen. Pat McMullen
Rep. Harriet Spanel
Rep. Jim Youngsman











           RESPONSE TO LETTER NO, 81: LORNA PARENT HAYCO



           1.     See Section 5.6 of the FEIS.                                                          0
                                                                                                        U
                                                                                                        0
           2.     See Section 5.7 of the FEIS.

           3.     Comments noted. The State of Washington does not allow the importation of live        C
                                                                                                        0
                  fish. Only eggs certified to be free of disease are allowed. See the response to
                  Question 29 and Appendix G.






                                                                     LETTER NO. 82











                                        MEMORANDUM
                                       April 6, 1989


           To:       Ron Westley, Project Manager
                     Washington Department of Fisheries
                     115 General Administration Building
                     Olympia, WA 98504
           From:     Robert F. Hull
                     220 South Palmer Drive
                     Port Townsend, WA 98368                  U
           Subject:  Comment on Draft Programmatic Environmental Impact
                     Statement: Fish Culture in Floating Net Pens.

           The authors' recommendation in regard to impact of excess feed
           and fish feces is a good one for any of the impacts discussed:
           keep the fishpens remote from any environmentally-valued
           location.


           The authors' treatment of nutrient release is transparently
           superficial. There was a time when low concentrations of
           nutrient elements in marine waters were recognized to naturally
           limit the growth of phytoplankton, resulting in few algae in the
           water column. Nutrient-starved phytoplankton could not, it
           seemed, overaccumulate.

           Of the two principal nutrients involved, phosphorus and nitrogen,
           phosphorus is commonly bound in benthic sediments, while
           available oxygen in the overlying waters favors strong retention
           of phosphorus in those sediments. In late summer and early fall,
           when nitrogen inputs are naturally low and water temperatures
           rise, conditions of low oxygen concentration normally occur and
           the liberation of dissolved phosphorus by chemical processes is
           greatly accelerated. This occurrence of low oxygen concentration
           would arise in exacerbated fashion with sedimentation from
           fishfarms of excess food and fish feces.


           These elevated phosphorus levels do not stimulate growth in
           marine water systems of nitrogen-fixing organisms, which are
           capable of using gaseous nitrogen from the atmosphere. The
           nitrogen concentration in the water, in natural conditions,
           remains low enough to limit the growth of phytoplankton that are















            obligated to use bound nitrogen, not atmospheric nitrogen.
            During this crucial season of late suramer, early fall, however,
            additional nitrogen inputs, as from fishfarms, must be expected
            to increase the growth rates of nitrogen-limited phytoplankton.
            The fishfarm's input of dissolved nitrogen into the euphotic zone
            of the water column is much greater than its deposit of nitrogen-
            loaded sediments to the bedlands.

            Seasonally foreseeable is a self-acce "lerating phenomenon of
            phytoplankton increasing faster than they can be foraged by the
            consumer organisms of the food chain. These plants will cloud
            the waters and settle to depths where they die from lack of
            light. In death, they are food for bacteria which, growing
            beyond their normal bounds, can consume virtually all of the
            oxygen in their immediate environs and produce hydrogen sulphide.
            The resulting anoxia of the deep saltier layers of the marine
            waters is fatal to bottom dwelling organisms and it displaces
            fish and. other motile organisms from -that saline habitat.

            Of course, not all of the biostimulatted productivity of nutrient-
            enriched. waters disappears into the saltier depths. As pointed
            out by Thom et al (1988) in their argument for nutrient
            limitation in the nearshore system, seaweed and other organic
            detritus ends up in shallow waters and on beaches, with
            consequences to creatures inhabiting and foraging those areas
            including the human constituencies of the local*juriLsdictions.

            The authors are too facile in attributing adverse imapacts
            simplistically to "nutrient depleted, poorly I ''lushed bays," and
            in promising measures that "can prevent adverse plankton blooms."
            The measures advanced, "identification of sensitive bays, proper
            placement of pens, and limits on total fish production," will not
            flpz-event" biostimulation of plankton growth; they merely improve
            the fishfarmers' odds of avoiding mortalities among their own
            cultured fish.









            RESPONSE TO LETTER NO. 82: ROBERT F. HU



             1.     Comment noted.

            2.      This is incorrect. Virtually all scientific investigations have noted that light, not
                    nutrient, is the main controller of phytoplankton populations in most of Puget
                    Sound. Some of the semi-restricted embayments are subject to nutrient (nitrogen)
                    limitations at times, as discussed in detail in the text.

                    The reviewer's discussion of noxious phytoplankton blooms and their significant
                    adverse impacts generally applies only to very poorly flushed areas of the Sound
                    such as the inner harbor of the Port of Olympia. Location of fish farms in such
                    areas is not foreseeable. The identification and avoidance of fish farm placement
                    in nutrient sensitive embayments, is a primary basis for the State's Interim
                    Guidelines.

















































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