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Home My WebLink About054 Emails from ResidentsDonna Frostholm From: Penny Tripp <penny@juneau.com> Sent: Monday, August 18, 2025 1:52 PM To: Donna Frostholm Subject: Rock Island Oyster Permit Public Hearing Follow Up Flag: Follow up Flag Status: Flagged ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Dear Ms Frostholm, My name is Penny Tripp, and I live near the East end of Hood Canal on Shine Road. I have watched the progress of the proposed Rock Island Oyster Permit with some interest and doubts. I would like to see this Permitting process redone with more information provided to the general public in the area, and with greater opportunity for public input from them. Specifically, some of my personal worries, as a resident of the area, include the large size and visibility of the proposed "farm", the apparent lack of land access to the site and the availability of support utilities and maintenance. It will be important to hear the views of the permit applicants, County staff and concerned citizens during the hearing. Please count me as a "No" vote. I cannot see where this activity will enhance the livability of the area or the visitor's appreciation of its natural beauty. Thank you for your time. Penny Tripp Donna Frostholm From: Sue Corbett <suec71 @gmail.com> Sent: Monday, August 18, 2025 2:57 PM To: Donna Frostholm Subject: Comment on the Carson Rock Island Shellfish proposal Attachments: IMG_2054 jpeg; IMG_7607.PNG; IMG_7608.PNG Follow Up Flag: Follow up Flag Status: Flagged ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Donna, Please add this comment to the Carson Rock Island Shellfish hearing file. 1 would appreciate an email letting me know that you received this comment. I understand from the Carson application that he proposes to use SEAPA oyster baskets. I researched the SEAPA website and there is no specific wind speed rating when using SEAPA oyster baskets. There are a few testimonials but testimonials are not necessarily based on reliable facts, or facts relevant to Hood Canal and Squamish Harbor. The reason for my concern is that the Carson site is about 1/4 mile from the Hood Canal Bridge. The area is known for high winds and storms. The Hanukkah Eve windstorm on December 13, 2006 had 114 mph wind gusts and 74 mph winds at the Hood Canal Bridge. The most notable storm was on February 13, 1979. The estimated wind speed was 120 mph with sustained winds of 85 mph. Those winds basically tore the Hood Canal Bridge in half, sinking the west end. According to KOMO news and local wind researcher Wolf Reed, "The winds were perfectly aligned with the Hood Canal turning it into a wind tunnel aligned perpendicular to the bridge span". From my house, I have witnessed the whitecaps racing north towards the bridge countless times over the years. When looking over the Carson application, I did not see any mention of either typical or maximum wind speeds during storms in this area. There is no mention of how he plans to avoid problems caused by our high winds. One mitigation strategy I found is to choose a location with natural protection from prevailing winds. That would not be the Carson site. We have been experiencing more extreme weather. The king tides have wreaked havoc in our neighborhood. SEAPA baskets have been found on the public tidelands of DNR Beach 59 near the Carson site. The debris from oyster farms are found far and wide around Squamish Harbor. We don't need more. Another thing I can't find is how many of these SEAPA baskets and rebar supports will be installed in the tidelands. How much would it all weigh? Also, how deep into the tidelands will the rebar anchors be installed? We need more information on this particular proposal for SEAPA baskets, not just general information. As I said in an earlier comment, our community did not get proper notice of this application. If we had, we would have had more time to research some of these issues. I think this process should start over so that the community and the county have a chance to develop complete information on this proposal. Without it, the hearing examiner doesn't have all the information he needs to make an informed decision. I have attached informational images about the two above mentioned storms. Respectfully, Sue Corbett suec7l@gmail.com Hanukkah Eve windstorm of 2006 Powerful Hanukkah Eve Storm offshore Washington Coast taken on December 15, 2006 at Type Formed Dissipated Highest winds 2:00 UTC. Extratropical windstorm December 13, 2006 December 15, 2006 74 mph (119 km/h) at Hood Canal Bridge Highest gust 114 mph (183 km/h) at Mt. Weahn nronnn o ii en.mmikipedia.org ♦ Al Overview The highest wind speeds ever recorded in the Hood Canal area of Washington were associated with the storm that caused the west- ern section of the Hood Canal Bridge to sink on February 13,1979. Winds were estimated to have reached 120 mph (193 km/h) and sustained winds of 85 mph (137 km/h). This was a localized event caused by a mesoscale low pressure system forming in the lee of the Olympic Mountains. Here's a more detailed breakdown: February 13,1979 Storm: A powerful storm with strong winds caused the original Hood Canal Bridge to collapse. Estimated Wind Speeds: 5 / � / ƒ u t § 2 - % ®3 / to £ / « \ o 9-1 � § \ � / / 2 W 00 2 ƒ > \ E - 2 b ( 5 % E / 2 � u m = o ¥ / 1-0 G � 7 : N $ k a § G / 2 $ E 2 - S \ / E ± 2 ® m iR , bo £ aj @ t bO o % g [ (D / / k / « = cL £ u E LA y � EAo 2 2 E R E°� g � S# f ©° 2 k t k± £ 6 = 2° C 2 0 7 k E � \/� E g� / © 2® ° 2 a 6 x E w a £ cL E e k kƒ m o / / / k 7 / � 2 ƒ \ " E o $ Ln ƒ mLn \\ 7 2 2 /{ O O D E� 0 g E 12// U d [ [ / 2 ) / ° 0 k E 2 t: §ro S // b WOWM � / i § 0 ƒ ƒ - X/ ai\ M m Mr/ bo m o qj Q 6 %\ 0 k k m o / - © o|| ° g / / / / ' : / 2 %/ 7 E @� N w 2 a 3 Donna Frostholm From: cpmarquis@yahoo.com Sent: Monday, August 18, 2025 7:52 PM To: Donna Frostholm Subject: Public hearing on Rock Island Oyster Farm August 19 ,2025 Attachments: Rock Island Oyster farm Hearing.docx Follow Up Flag: Follow up Flag Status: Flagged ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Please see the attached document addressing our concerns on the Rock Island Oyster Farm. We would appreciated it being submitted at the hearing. Thank you Charles and Patricia Marquis We have concerns over the Rock Island Oyster farm application and would request they be submitted at the Public Hearing August 19 2025. We appreciate that the signage regarding the proposal was moved to Shine Road from the dead-end nonpublic road. However, we do not believe the community has had proper notice and adequate time to review it and submit their comments and request that proper notice be given. In addition, we have the following concerns and comments. 1. One of the reasons we moved to Shine was for the natural beauty of the Suquamish Harbor. We had previously kayaked in the Suquamish Harbor over the ten previous years. The natural beauty of the shoreline will be impacted by these three plus foot structures over two acres of tide lands. 2. The submerged and partially submerged SEAPA baskets and rebar will pose a threat to kayakers, paddleboarders, jet skis and boaters. This is a very popular recreational area for local residents as well as visitors during the summer months. This could lead to dangerous situations in which people could be hurt and property damaged. 3. The Suquamish Harbor shoreline is very exposed to high winds and strong currents which very likely will cause some damage to the SEAPA baskets. The HDPE plastic in the baskets might break and that may lead to environmental impacts as well as unsightly litter if they are damaged. 4. Undetermined environmental concerns may occur. We have seen a decline in eelgrass, and crab population over the past years since the commercial geoduck farms have grown. We believe any additional commercial shellfish development in Suquamish Harbor and this residential area will only increase these impacts. Additional comments: A large solar panel (permitted or not?) has been installed on the bank above the proposed area which reflects light onto the water and can be seen from the bridge. We do know if it would be part of the oyster farm. We would also like to know if there is any benefit to Jefferson County for these commercial shellfish farms. We don't see any benefit to Suquamish Harbor, the neighborhoods bordering Suquamish Harbor or people on the water. Thank you for your consideration of this very important issue to us as residents of the Shine community. Sincerely Charles and Patricia Marquis 1662 Shine Road Donna Frostholm From: Janet Wold <jestuary@hotmail.com> Sent: Monday, August 18, 2025 10:07 PM To: Donna Frostholm; Janet Wold Subject: Jan Wold's public comments: Carson (Rock Island Shellfish) proposed oyster farm permit (SDP2024-00006), impact on threatened salmon and trout and need for analysis of no net loss and cumulative impacts, 8/18/25 Attachments: Carson Oyst NoFish 81925.pdf ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Donna: Can you please include this second document of comments for the Robert Carson (Rock Island Shellfish) Kumamoto oyster farm proposed shoreline substantial development permit, SDP2024-00006? Please let me know you have received this comment. Thank you, Jan Wold Proposed Carson Kumamoto Oyster Farm Permitting: Populations of Threatened Puget Sound Chinook and Threatened Puget Sound Steelhead Continue to Decline to Critical Status Even With Greatly Increased Restoration Efforts in their Habitats in Freshwater and in Estuaries. August 18, 2025 Prepared by Jan Wold The proposed Carson Kumamoto Oyster Farm permit (SDP 2024-00006) is required to be in compliance with the Shoreline Management Act, including the requirement for no net loss and the need to address adequately any cumulative impacts. One must be concerned about the impact of introducing very high populations of an organism to a marine environment, whether it be a high number of a naturally occurring species or an alien species, such as Kumamoto oysters, and the impact on native species. This is especially true for threatened and endangered species, such as the threatened Puget Sound Chinook salmon and the threatened Puget Sound Steelhead. It is also critical to determine the impact on the endangered resident Orca who depend heavily on the shrinking numbers of Chinook salmon. In the recent research article "Why Aren't Salmon Responding to Habitat Restoration in the Pacific Northwest?", Bilby, Robert E., Currens, Ken P., Fresh, Kurt L., Booth, Derek B., Fuerstenberg, Robert R. And Lucchetti, Gino L., January 2024, Fisheries, vol.49, No.1, state on page 16 and 17: Given the effort and resources that have been dedicated towards Pacific salmon recovery in the Pacific Northwest over the past several decades the lack of population response to freshwater and nearshore habitat protection and restoration raises questions about the current approach. The restoration effort has been supported by a considerable investment; billions of dollars have been dedicated to Pacific salmon recovery over the past several decades in the Pacific Northwest... These authors suggest five factors that may be the cause of this lack of a positive response of these salmon species to intensive restoration efforts. One of the five factors is that ongoing habitat degradation is offsetting restoration benefits. They 1 of 5 do include aquaculture as part of this factor. They list both the threatened Puget Sound Chinook and threatened Puget Sound Steelhead as now in crisis. On page 19 they state: One of the processes that has been largely ignored in limiting factors assessments and restoration planning is food web dynamics... On page 25 they state: Habitat degradation is occurring rapidly enough in some watersheds to offset or mask benefits associated with restoration. Identifying and protecting high -quality habitat, therefore, is an essential component of any restoration program (Roni et al. 2002). A variety of tools exist for protecting habitat, including acquisitions, conservation easements, and regulations. Acquisitions and conservation easements are mostly applicable at a local scale, whereas zoning and other land -use regulations can provide broader protection. The continuing development of land across the range of Pacific salmon in the Pacific Northwest indicates that regulations will need to change to accommodate both fish and human needs. Comprehensive assessments of regulatory effectiveness are needed to do this,... The Army Corps of Engineers (Corps) 2017 Draft Cumulative Effects Analysis was based on data from 2016 and earlier. It found that twenty percent of all Washington tidelands were under permit for shellfish farms. Now, eight years later, about 30% of all Washington tidelands are covered by commercial shellfish farm permits according to the Center for Food Safety (Second Amended Complaint, Coalition to Protect Puget Sound Habitat and Center For Food Safety v. U. S. Army Corps of Engineers, Case No. 2:21-cv-0168-JCC-DWC, U. S. District Court, Western District of Washington at Seattle, dated June 10, 2022, page 18, lines 9-13). This would be about a 50% increase in permitted shellfish acreage in Washington state over eight years! These shellfish farms generally take up the most productive and most sensitive marine environments, including estuaries and spawning and rearing grounds for forage fish and salmon. The proposed action to approve shellfish farm permits under the 2017 Corps Nationwide Permit 48 was determined in the Corps 2017 Draft Cumulative Effects Analysis as likely to adversely affect designated critical habitat of several species listed under the Endangered Species Act (ESA), including Puget Sound Chinook 2 of 5 salmon and Puget Sound steelhead. These adverse effects were found to be due, in part, to impacts on eelgrass. Once again, this Corps 2017 Draft Cumulative Effects Analysis was based on far less commercial shellfish farming than is occurring at this time. The cover letter from the National Oceanic and Atmospheric Administration (NOAA) to the Corps on the Biological Opinion (NMFS No. WCR-2014-1502), dated September 2, 2016, states on page 1 that "NMFS also concludes that the proposed action is likely to adversely affect Puget Sound (PS) Chinook salmon (O. tshawytscha), Hood Canal summer -run chum salmon (O. keta), North American green sturgeon (Acipenser medirostris), and their designated critical habitat..." The proponent has the burden of proof to show that threatened and endangered species and their designated critical habitat are not impacted, that cumulative effects are addressed and that there will be no net loss. The steep decline in the Puget Sound Chinook salmon and Puget Sound steelhead in Puget Sound is occurring just as the amount of commercial shellfish farming has been increasing. The proponent has not shown that this Kumamoto oyster farm will not continue to add to this decline of these species in crisis. There are attempts to rely on the Corps' 2015 Programmatic Biological Assessment and the NMFS and USFWS Biological Opinions to assert there is no impact on these species. However, these biological assessments are very outdated and cannot be used while ignoring the more recent data showing critical declines in theses and other species. When ongoing attempts to counter the declines in these threatened species with very expensive restoration projects, it is still not enough to turn around the decline of these species. The counties in Washington state as well as the State of Washington apparently have no idea how many shellfish farms are located in the counties at this time due to most shellfish farms having been grandfathered in without any requirements for a county permit. Commercial shellfish farms are never required to obtain a Washington state Hydraulic Project Approval (HPA). An HPA is normally used to ensure that marine activities and construction in Washington state is done in a manner that protects fish and their aquatic habitats. This important review by the Washington Department of Fish and Wildlife is never undertaken for any shellfish farm. The counties and state have no specific information on the number of acres farmed for shellfish, the species of shellfish farmed, the methods used and the locations as 3 of 5 is occurring in 2024. This information was not provided by the proponent or the county. Organizations working on habitat restoration for these threatened salmon species that are in crisis also are not aware of the magnitude of shellfish farming or the location and size of all shellfish farms. A thorough cumulative effects analysis needs to be undertaken before this permit is approved. There are other species in Puget Sound that are also in critical downfall as well. These include the endangered marbled murrelet, Pacific herring, sunflower sea star (proposed for listing as threatened) and endangered resident orcas. The critical low numbers of Orca are due in large part to the lack of threatened Puget Sound Chinook salmon that provide most of their food. References Cited: Bilby, Robert E., Currens, Ken P., Fresh, Kurt L., Booth, Derek B., Fuerstenberg, Robert R. And Lucchetti, Gino L., January 2024, Why Aren't Salmon Responding to Habitat Restoration in the Pacific Northwest? Fisheries, vol.49, No.1, pages 16-27. Army Corps of Engineers 2015 Programmatic Biological Assessment. Army Corps of Engineers 2017 Draft Cumulative Impacts Analysis. Biological Opinion that was prepared for Shellfish Activities in Washington State, completed in 2016 by the U. S. Fish and Wildlife Service (USFWS), Reference Number OIEWFW00-2016-F-0121. Biological Opinion that was prepared for Shellfish Activities in Washington State, completed in 2016 by the National Marine Fisheries Service (NMFS), Reference Number WCR-2014-1502. Lance, Monique M., and Scott F. Pearson, March 2021, 2020 Washington At -Sea Marbled Murrelet Population Monitoring: Research Progress Report. McIver, W. R.; Baldwin, J.; Lance, M. M.; Pearson, S. F.; Strong, C.; Raphael, M. G.; Duarte, A.; Fitzgerald, K. 2023. Marbled Murrelet Effectiveness Monitoring, Northwest Forest Plan - 2022 Summary Report, Northwest Forest Plan Interagency Regional Monitoring Program. January 2023, final report. 25 p. 4of5 State of Salmon in Watersheds, Executive Summary, 2022, Salmon Abundance Chart, Governor's Salmon Recovery Office, Washington State Recreation and Conservation Office. The Second Amended Complaint, Coalition to Protect Puget Sound Habitat and Center For Food Safety v. U. S. Army Corps of Engineers, Case No. 2:21- cv-01685-JCC-DWC, U. S. District Court, Western District of Washington at Seattle, dated June 10, 2022, page 18, lines 9-13. The Fourth Amended Complaint, Coalition to Protect Puget Sound Habitat and Center For Food Safety v. U. S. Army Corps of Engineers, Case No. 2:21- cv-01685-JCC-DWC, U. S. District Court, Western District of Washington at Seattle, dated January 31, 2024, Exhibits C and D. 5 of 5 Donna Frostholm From: Janet Wold <jestuary@hotmail.com> Sent: Monday, August 18, 2025 8:30 PM To: Donna Frostholm; Janet Wold Subject: Re: Jan Wold's public comments: Carson (Rock Island Shellfish) proposed oyster farm permit (SDP2024-00006), impact of unnatural numbers of commercial shellfish, no net loss and cumulative impacts Attachments: CarsonOysAsiaClam 81925.pdf ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Please let me know if this worked. I have a new iPhone with some new glitches to deal with! I am sorry for the original format. Jan Wold On Aug 18, 2025, at 8:21 PM, Donna Frostholm <DFrostholm@co.jefferson.wa.us> wrote: Jan, It does not appear that I am able to open a .pages file. Please send as a Word file. Thanks, Donna Frostholm Jefferson County DCD From: Janet Wold <jestuary@hotmail.com> Sent: Monday, August 18, 2025 8:18 PM To: Donna Frostholm <DFrostholm@co.jefferson.wa.us>; Janet Wold <jestuary@hotmail.com> Subject: Fwd: Jan Wold's public comments: Carson (Rock Island Shellfish) proposed oyster farm permit (SDP2024-00006), impact of unnatural numbers of commercial shellfish, no net loss and cumulative impacts ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Donna: Can you please include these comments for the Robert Carson (Rock Island Shellfish) Kumamoto oyster farm proposed shoreline substantial development permit, SDP2024-00006? Please let me know you have received this comment. Thank you, Jan Wold Begin forwarded message: Impact of Unnatural Numbers of Filter Feeding Clams in Hood Canal Prepared by Jan Wold 8/18/25 The proposed Carson Oyster Farm permit is required to be in compliance with the Shoreline Management Act, including the requirement for not net loss and the need to address adequately any cumulative impacts. One must be concerned about the impact of introducing very high populations of an organism to a marine environment, whether it be a high number of a naturally occurring species or an alien species, such as Kumamoto oysters, brought in from other areas. Examples of clams introduced into estuaries in unnaturally high numbers are the invasive Asia clam in San Francisco (SF) Bay estuary in California and the geoducks and other shellfish in commercial shellfish farms in Washington state. The analysis by scientists on the impacts of unnaturally high numbers of Asia clams in SF Bay is provided. Some information is also provided on the number of commercial geoduck clams growing in the same area of Hood Canal. Asia Clams in San Francisco Bay Estuary in California: One example of the impact of adding unnatural numbers of clams to an estuary is the introduction of the alien invasive Asia clam into the marine environment of the SF Bay estuary in California. Asia clams, like geoducks, oysters and other Washington state commercial shellfish farm species, need to feed on something in the water column to survive and grow. A grown Asia clam is smaller than a penny, a fraction of the size of a planted geoduck clam or a Kumamoto oyster. Asia clams in the SF Bay estuary and commercially farmed geoducks, other clams and oysters are all occurring in unnaturally high numbers. In the case of unnaturally high numbers of geoducks and other species of clams and oysters, it is due to decisions to approve commercial shellfish farms. Due to their larger size, geoducks and Kumamoto oysters can feed on larger food web organisms than Asia clams. Even with this size difference, Asia clams have been able to displace virtually all other invertebrates, reducing biological diversity to almost zero in parts of the SF Bay estuary. Before the introduction of the alien Asia clam to SF Bay, the naturally occurring algal plankton fed huge populations of zooplankton that are so important 1 of 10 to the base of the aquatic food chain in the SF Bay estuary. The voracious Asia clams consumed large numbers of phytoplankton and young zooplankton. According to research by Glen Martin in "The Great Invaders/A New Ecosystem is Evolving in San Francisco Bay. We have no Idea What it is, or Where it's going", SFGATE, 2/5/2006: A drab, unassuming mollusk averaging the size of a thumbnail, the Asian clam ... has transformed San Francisco Bay. In vast portions of the estuary's intertidal zone, it has displaced virtually all other invertebrates, reducing biological diversity to almost zero. More than that: It has altered the very way energy flows through the bay's ecosystem. Before the clam showed up in the 1980s, large portions of the bay supported extravagant phytoplankton blooms. This algal plankton nourished huge populations of zooplankton, which buttressed a vast aquatic food web, ranging from tiny fish and crustaceans to big halibut and leopard sharks. But the clams, voracious consumers of both phytoplankton and young zooplankton, changed all that. They became so numerous -- in places reaching densities of 50,000 per square meter -- that they sucked up the plankton. All of it. For the most part, the plankton blooms are gone.... First noted in the mid-1980s, this bivalve probably constitutes most of the benthic biomass in the bay. Its vast numbers have resulted in a drastic reduction in plankton in the North Bay, which may be adversely affecting the delta smelt, an endangered native fish considered an indicator of estuary health. Stopping a Hostile Takeover of the Bay, 1/15/2019, San Francisco Baykeeper, states: A clam smaller than a penny stealthily enters San Francisco Bay waters. It begins quickly devouring the tiny plankton at the base of the Bay's food chain, causing small local fish to starve. It multiplies fast, soon overcrowding native species. 2of10 Global Invasive Species Database (2024) Species profile: Potamocorbula amurensis. 4/30/24, states: The suspension -feeding clam Potamocorbula amurensis has been designated as a major biological disturbance with significant ecological consequences. NIMPIS (2002a) states that \"the introduction of P. amurensis to the San Francisco Bay in California has resulted in dramatic changes to the soft sediment communities of the area. It is thought to be responsible for the collapse of some commercial fisheries in addition to the decline in the diversity and abundance of many benthic species in the area. The clam consumes large amounts of phyto- and zooplankton and therefore changes many of the existing community dynamics, resulting in many benthic species being unable to obtain enough food for growth. The clam is also a dominant species in the bay, accounting for 95% of the biomass in some areas. This reduces the amount of available space for other species to grow and reproduce\". Kimmerer, et. al., in "Predation by an introduced clam as the likely cause of substantial declines in zooplankton of San Francisco Bay", Marine Ecology Progress Series, volume 113, October 13, 1994, pages 81-93, states: The clam Potamocorbula amurensis was introduced introduced into theSan Francisco Bay estuary (California, USA) in 1986 and became abundant in late 1987. Within a year, chlorophyll concentration and the abundance of adults of 3 common estuarine copepod species had declined by 53 to 91 %, providing an opportunity to examine mechanisms by which benthic grazing might control the abundance of pelagic populations... Benthic grazing is believed to control phytoplankton biomass in some shallow waters (Cloem 1982, Officer et al. 1982, Nichols 1985, Alpine & Cloem 1992). A large body of literature indicates that certain benthic organisms can graze substantially on phytoplankton and small zooplankton (Williams 1980, Buss & Jackson 1981, Wright et al. 1982, Ertman & Jumars 1988, Bingham & Walters 1989, MacIsaac et al. 1991). Bivalves can influence benthic recruitment or reduce the abundance of certain zooplankton by consuming small, relatively slow -moving forms such as bivalve larvae (Williams 1980, Ertman & Jumars 1988)... 3of10 Since bivalves are an important component of shallow soft -bottom benthos (Nichols 1985), a significant predation rate by bivalves could be a key limitation to zooplankton abundance and species composition... This invasion, potentially disastrous to the food web of the upper estuary, offered a unique opportunity to observe the effects of benthic filter feeding on the plankton of the estuary... ...the abundance of several common estuarine copepod species declined markedly, leading to the belief that the clam was influencing copepod abundance either indirectly through reduction of food supply or directly through predation... This may be the first demonstration of a major impact by bivalves on populations of estuarine copepods... The finding that bivalves can have such an impact on copepod populations may have strong implications for all shallow estuaries with abundant bivalves.... To date, field consumption rates of phytoplankton by bivalves have been measured only a few times, usually under conditions of low flow velocities, shallow water, and high bivalve densities, such as over mussel beds... ...there is cause for concern: several species of fish that pass through their larval stages in the upper estuary are also in a serious state of decline (Stevens et al., 1985, Moyle et al. 1992). Puget Sound and Hood Canal Unnaturally High Numbers of Commercial Shellfish: In Puget Sound and Hood Canal we have been introducing very high, unnatural numbers of geoducks, clams and oysters in commercial shellfish farms. Some are species that occur here naturally and some are alien species, such as the Kumamoto oyster. Commercial geoduck farming is presently occurring and is proposed for more acres in Squamish Harbor near the Shine Road area. Extremely high, unnatural farmed numbers of native geoducks are presently growing in Squamish Harbor with proposed additional acres of geoduck farming. 4of10 PVC tubes are used at a rate of about one tube per square foot, or 43,560 tubes per acre. At a planting rate of three to four geoduck per PVC tube, this comes to up to 174,240 geoducks per acre when planted. It is suggested that eventually about half of these young geoducks will die prior to harvesting in six or seven years. That is still around 87,000 geoducks per acre in a commercial farm. The Habitat Conservation Plan for Washington Department of Natural Resources' Geoduck Fishery, July 2008, Aquatic Resources Program, Doug Southerland, Director of Public Lands, 105 pages, states for naturally occurring geoducks: The average density on commercial tracts in the South Sound management region is 0.12 geoducks per square foot. These commercial Washington Department of Natural Resources (DNR) dive harvesting tracts may have somewhat higher numbers of geoducks per acre than other parts of Puget Sound that are not in DNR geoduck dive harvesting tracts. Using this likely higher than normal number of 0.12 geoducks per square foot, one can calculate a total number of geoducks potentially occurring naturally at 5,227 natural geoducks per acre. Calculations can further consider the difference between how many total geoducks are expected naturally and how many farmed geoducks will be filtering food organisms out of the waters in adjacent portions of Hood Canal. Using the numbers above, on would expect 5,227 natural geoducks per acre and 87,000 or more geoducks per acre of farmed geoducks, or an increase of sixteen times more geoducks per acre filtering food organisms out of the food chain than would occur naturally. This excessive filtering of the food chain continues year round. This removal of an extreme amount of the critical food chain organisms that normally feed all of the natural species in the area, including the food chain for forage fish, threatened Chinook salmon, the endangered resident Orca who feed on them, threatened Hood Canal summer -run chum salmon and endangered marbled murrelets. The cumulative impact of this demand on the food web has been studied in SF Bay estuary with a disastrous result for many marine species. The cumulative impact of the extra planted commercial geoducks, clams and oysters per acre in active farms in Hood Canal, a known rearing area for threatened Chinook salmon, threatened Hood Canal summer -run chum salmon, endangered marbled murrelets and other species has not been studied or considered in conjunction with this proposed two acres of alien farmed Kumamoto oyster and all of the tideland construction that 5of10 goes with it. This impact to many Hood Canal species is even greater due to millions of commercially planted clams and oysters already filter feeding on the same Hood Canal and Squamish Harbor food chain. There is no analysis of the cumulative impact of the millions of oysters proposed in the Carson Rock Island Oyster Farm. In federal litigation in 2019 in The Coalition to Protect Puget Sound v. Army Corps of Engineers, the federal District Court for Western Washington invalidated the U.S. government's blanket permit (Nationwide Permit 48) for commercial shellfish operations in Washington state. The court found that the lead federal agency —the U.S. Army Corps of Engineers (Corps) —had failed to properly analyze the cumulative effects of operations in Washington state under its permit, and had failed to comply with the federal Clean Water Act (CWA) and with the National Environmental Policy Act (NEPA). According to the data in Building a more Productive Salish Sea for Chinook salmon, Coho salmon and steelhead, Findings of the Salish Sea Marine Survival Project by Long Live the Kings and Pacific Salmon Foundation, 2021, pages 1-14: Despite hundreds of millions of dollars invested in stream restoration and hatchery production, despite improved management of fisheries and fish hatcheries, many salmon populations have failed to rebound in this region that includes Puget Sound and the Strait of Georgia. One extraordinarily critical question has remained unanswered: Why are so many young Chinook salmon, Coho salmon and steelhead dying as they leave their natal streams and confront what appears to be an increasingly hazardous world in the Salish Sea marine environment? The Salish Sea was once a highly productive place for Chinook, Coho, and steelhead. However, things began to change abruptly through the late 1970s and 1980s, when marine survival rates plummeted in ways not seen in other populations along the Pacific Coast. This trend was seen in both wild and hatchery fish... The Committee's primary conclusion was that factors affecting food supply and predation are the largest contributors to the declines in marine survival of Chinook, Coho, and steelhead. Changes in environmental conditions have affected when, where, and how much food is available to juvenile Chinook and Coho, influencing their growth and survival. Food is not as significant 6of10 an issue for steelhead, which enter the Salish Sea in late spring and then swim quickly from their natal rivers to the Pacific Ocean in a few weeks. As young Chinook and Coho live through the summer, they must consume increasingly energy -rich food to grow fast enough to avoid predators and fat enough to survive the coming winter. Forage fish — in particular fish like Pacific herring, Pacific sandlance, anchovy and eulachon— become extremely important to Chinook and Coho once the salmon are large enough to eat them. Experts have found strong positive relationships between Chinook growth and the quantity of forage fish in their diet. Herring, the most abundant of Salish Sea forage fish, are of primary concern, because SSMSP scientists have found strong positive relationships between herring abundance in the Salish Sea and Chinook and Coho growth and survival. To the detriment of the salmon, herring populations have declined in many parts of the Salish Sea, and there is less diversity in spawning locations as well as spawn timing. Diet studies suggest that juvenile Chinook are eating fewer herring compared to the 1970s, when Chinook survival rates were higher. Since herring are less diverse and are on average spawning earlier in spring, young Chinook and Coho may not be able to find herring of the right size when they get large enough to eat fish. Similar to zooplankton, this may be another mismatch problem in the food supply. Habitat degradation began long before the late 1970s when salmon and steelhead survival began to decline. Still, the Synthesis Committee concluded that the quality of habitat is likely a contributing factor, with the largest concern for young Chinook entering degraded estuary habitats. Estuaries and the nearshore can be among the most productive marine habitats, providing food and shelter to young salmon as well as critical prey species, such as herring, sand lance, and crab. While many young Chinook rear for some time upstream in their natal rivers, over half of them migrate quickly downstream to estuaries soon after hatching. This behavior was rewarded over thousands of generations by historically rich habitats that provided shelter and food to grow before transitioning to the marine environment. SSMSP studies found that within the Salish Sea, small Chinook rearing in healthy estuaries have a much greater chance of surviving to adulthood compared to those that rear in degraded estuaries. Only 1 percent of the adult returning population were 7of10 composed of fry that reared in degraded estuaries, whereas 36 percent of the adult returning population were composed of fry that reared in healthy estuaries. This was the most direct evidence of habitat impacts, emphasizing the need for increased investments in estuary restoration. The charts of salmon and steelhead numbers from this document are shown below. 8of10 Uve ry i ew Salmon in the Salish Sea are in serious danger. Despite hundreds of millions of dollars invested in stream restoration and hatchery production, despite improved management of fisheries and fish hatcheries, many salmon populations have failed to rebound in this region that includes Puget Sound and the Strait of Georgia. a One extraordinarily critical question has remained =_ unanswered: Why are so many young Chinook salmon, Coho salmon and steelhead dying as they leave their natal streams and confront what appears to be an increasingly hazardous world in the Salish Sea marine environment? The Salish Sea was once a highly productive place for Chinook, Coho, and steelhead. However, things began to change abruptly through the late 1970s and 1980s, when marine survival rates plummeted in ways not seen in other populations along the Pacific Coast. This trend was seen in both wild and hatchery fish. Southern Strait of Georgia steelhead are not represented due to limited data but are also depressed. 9of10 Chinook Coho Steelhead 1990 2000 2010 Ocean Entry Year WA/BC Coast + Columbia — Puget Sound — Puget Sound + Keogh River Strait of Georgia As the number of permitted commercial shellfish farms and acreage devoted to commercial shellfish cultivation have continued to increase over a number of decades, there is still not a cumulative effects analysis of the impacts. When making decisions on such a sensitive area as Hood Canal and Squamish Harbor, extreme caution must be taken to avoid unknown impacts. This large removal of food chain organisms also does not meet the requirement of no net loss. This proposed permit should not be approved until the cumulative impacts and the existing net loss and potential additional losses are considered. References Cited: Global Invasive Species Database (2024) Species profile: Potamocorbula amurensis. 4/30/24 Kimmerer, et. al., in "Predation by an introduced clam as the likely cause of substantial declines in zooplankton of San Francisco Bay", Marine Ecology Progress Series, volume 113, October 13, 1994, pages 81-93. Long Live the Kings and Pacific Salmon Foundation, 2021, Building a more Productive Salish Sea for Chinook salmon, Coho salmon and steelhead, Findings of the Salish Sea Marine Survival Project. Martin, Glen, "The Great Invaders/A New Ecosystem is Evolving in San Francisco Bay. We have no Idea What it is, or Where it's going." SFGATE, 2/5/2006. Stopping a Hostile Takeover of the Bay, 1/15/2019, San Francisco Baykeeper. Doug Southerland, Director of Public Lands, The Habitat Conservation Plan for Washington Department of Natural Resources' Geoduck Fishery, July 2008, Aquatic Resources Program, 105 pages. 10 of 10 Donna Frostholm From: Janet Wold <jestuary@hotmail.com> Sent: Tuesday, August 19, 2025 3:15 AM To: Donna Frostholm; Janet Wold Subject: Jan Wold's public comments: Carson (Rock Island Shellfish) proposed oyster farm permit (SDP2024-00006), impact on threatened and endangered species, no net loss and cumulative impacts 8/19/25 Attachments: CarsonOyst T&E 81925.pdf ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Donna: Can you please include these comments for the Robert Carson (Rock Island Shellfish) Kumamoto oyster farm proposed shoreline substantial development permit, SDP2024-00006? Please let me know you have received this comment. Thank you, Jan Wold Inadequate Consideration of the Threatened, Endangered, Sensitive and Priority Species in and Adjacent to the Carson Proposed 2-acre Commercial Oyster Farm (Rock Island Shellfish), Including Birds, Mammals, Echinoderms, Amphibians, Salmon, Trout and Other Marine Fish August 18, 2025 Prepared by Jan Wold THREATENED, ENDANGERED AND CANDIDATE SPECIES Estuaries such as Squamish Harbor, the location of the proposed Carson 2-acre commercial Kumamoto oyster farm, are some of the most important, diverse and imperiled ecosystems in the world. Millions of public dollars are being spent to restore Puget Sound and Hood Canal habitat that is so important for dwindling numbers of forage fish, salmon, orcas, gray and humpback whales, marbled murrelets, common loons, western grebes, sunflower sea stars and numerous other species. Herring, sand lance and surf smelt populations continue to decline, yet are critical in the food chain for many other imperiled species. Eelgrass also provides critical habitat. It serves as the food chain foundation for so many of these threatened, endangered and candidate species. I am including this analysis of threatened and endangered species as data to support that there is a net loss of a number of these species that should dictate denial of this proposed permit. The data provided below also supports other public comments on some of these species. I have spent decades working in natural resource management and taking part in planning or supervising thousands of projects. My last job before retirement was as the leader of a one million -acre national forest for seven years. I have not seen projects that have anywhere near the number of threatened, endangered and candidate species for listing as with commercial shellfish projects in Hood Canal and Puget Sound. The tidelands in an estuary are critically important for the health of species in Puget Sound. The number of declining species in Hood Canal and Puget Sound should be reason alone for not approving this permit until such time as the cumulative impacts and there is adequate analysis to show that this oyster farm will not add to the continuing net loss of the species listed below. 1 of 51 THREATENED, ENDANGERED AND CANDIDATE BIRDS Research published in Science magazine as reported in "The Wall Street Journal" by Jennifer Calfas, September 19, 2019 found that: North America's overall bird population has dropped 29% since 1970, with about 3 billion fewer birds now than nearly 50 years ago.... Described as unprecedented by researchers and scientists, the findings display a new and unexpected assessment of the bird population across the continent. The research also is a grim indicator of the overall health of the environment and reflects what may be occurring in other less closely observed animals, said Ken Rosenberg, a bird conservation scientist at the Cornell Lab of Ornithology who was the study's lead author. MARBLED MURRELET State Endangered and Federally Threatened Species Marbled murrelets (Brachyramphus marmoratus) are a small seabird that is listed as a federally threatened species. The species has also been up -listed to endangered by the State of Washington. Marbled murrelets have been documented numerous times south of the Hood Canal Bridge and in Squamish Harbor. Marbled murrelets are found in Puget Sound because of the forage fish they eat and feed to their one annual nestling and because of the proximity to old -growth forest nesting habitat, especially in Olympic National Forest and Olympic National Park. They usually lay a single egg in a large, old tree in a flat spot on a large limb. Their existence will be further imperiled due to habitat loss, noise, disruption and loss of critical food chain organisms, such as forage fish, if this commercial oyster farm and other shellfish farms continue to be permitted in this designated shoreline of statewide significance. The executive summary of the "Washington Department of Fish and Game for the Periodic Status Review for Threatened and Endangered Species for the Marbled Murrelet in Washington (2016)," published in October of 2016 states that: 2 of 51 The marbled murrelet (Brachyramphus marmoratus) is a small seabird that inhabits near shore marine environment in western North America. The distribution of murrelets in Washington includes the southern Salish Sea and the outer coast. The species was listed as threatened under the U.S. Endangered Species Act in 1992 in Washington, Oregon and California and... was subsequently listed by the Washington Fish and Wildlife Commission as threatened in 1993.... Marbled murrelets forage in the marine environment and may fly up to 55 miles inland where they nest and rear a single young on large tree limbs in mature and old conifer forests. Murrelets prey primarily on a variety of forage fishes, and sometimes on larger zooplankton. They exhibit strong site fidelity to nesting areas, appear to nest in alternate years, on average, and have a naturally low reproductive rate. ... At -sea population monitoring from 2001 to 2015 indicated a 4.4% decline in the murrelet population annually, which represents a 44% reduction since 2001. The 2015 population estimate for Washington is about 7,500 birds. Sustained low juvenile recruitment has been identified as a main cause of the decline, ... A 20% nest success rate in Washington for the period 2004-2008 was attributed to nestling starvation or adults abandoning eggs before completing incubation, suggesting low prey availability. Human marine activities appear to influence murrelet abundance and distribution in the Salish Sea. Declines in populations of forage fish species such as herring and anchovy subsequently resulted in an increased use of lower trophic level, less calorie -rich food sources (invertebrates). Ultimately, these changes to the marine food web may have influenced reproductive output.... The magnitude of the population decline indicates that the status of the marbled murrelet in Washington has become more imperiled since state listing in 1993. Without solutions that can effectively address these concerns in the short-term, it is likely the marbled murrelet could become functionally extirpated in Washington within the next several decades (emphasis added). Therefore, our recommendation is to list the Marbled Murrelet as a state endangered species in Washington. The Marbled murrelet research paper titled, "Breeding Ecology of the Marbled Murrelet in Washington State, Five Year Project Summary (2004-2008)," May 3 of 51 2009, by Thomas D. Bloxton, Jr. and Martin G. Raphael, USDA Forest Service, Pacific Northwest Research Station, Olympia, Washington stated: ...only one nest was apparently successful in each year from 2004-2006, and in 2008, and none of the five nests monitored in 2007 were successful. The majority of nest failures appear to be related to nestling starvation (emphasis added) or adults abandoning eggs prior to completion of the incubation period (or eggs failing to hatch after 40+ days). The low observed rate of confirmed nest initiation in all years (2004 [3 of 27 adults], 2005 [8/40], 2006 [2/40], 2007 [5/32], & 2008 [2/18]) and high rate of nest failure (80%) is possibly due to low prey availability at sea (emphasis added). Lance, M.M., and S.F. Pearson. 2021. Washington 2020 at -sea marbled murrelet population monitoring: Research Progress Report. Washington Department of Fish and Wildlife, Wildlife Science Division, found that: The population estimate for Puget Sound and the Strait of Juan de Fuca in 2020 (Zone 1) was 3,143 birds (95% confidence interval = 2,030 — 4,585 birds) with a -4.96% (95% Cl = -7.01 to-2.86%) average annual rate of decline for the 2001-2020 period, assuming a constant rate of decline. (See table 3, photo number MM.j.2020, below, for a diagram showing the decline of marbled murrelets each year in Puget Sound and the Straight of Juan de Fuca). Research shows the annual percentage decline in numbers of the state endangered and federally threatened marbled murrelet in Hood Canal from 2012-2020 at -17.2%, a situation that is dire in Hood Canal (Lance, M.M., and S.F. Pearson. 2021. Washington 2020 at -sea marbled murrelet population monitoring: Research Progress Report. Washington Department of Fish and Wildlife, Wildlife Science Division). Also see the attached chart showing this decline. The latest marbled murrelet monitoring summary report in January, 2023, documents a drop of -4.2% per year in the entire state of Washington from 2001 through 2022. It is interesting that there has been an increase of +3.8% per year of marbled murrelets in California and an increase of +1.8% in Oregon during the same time period from 2001 through 2022 (McIver, W. R.; Baldwin, J.; Lance, M. M.; Pearson, S. F.; Strong, C.; Raphael, M. G.; Duarte, A.; Fitzgerald, K. 2023. Marbled Murrelet Effectiveness Monitoring, Northwest Forest Plan - 2022 Summary Report, Northwest Forest Plan Interagency Regional Monitoring 4of51 Program. January 2023, final report. 25 p.) There are likely not large differences in old growth timber harvest between these three western states, but Washington is the only state with large numbers of commercial shellfish farms that are impacting about thirty percent of the tidelands in the state. The largest drop in murrelet populations in Washington are in Puget Sound, location of the greatest number and acreage of commercial shellfish farms. Habitat associations of marbled murrelets during the nesting season in nearshore waters along the Washington to California coast, Martin G. Raphael, Andrew J. Shirk, Gary A. Falxa, Scott F. Pearson, Journal of Marine Systems, June 26, 2014, states: Whereas nesting habitat is essential to murrelet conservation, managers cannot ignore foraging habitat nor the availability of certain forage species, not simply because murrelets require prey but also because prey availability can affect murrelet nesting success (emphasis added) (Barbaree, 2011; Barbaree et al., 2014; Becker et al., 2007; Norris et al., 2007) and seabird survival (Sandvik et al., 2005)... Murrelet numbers have seriously decreased over the past decades and continue to decline in our study area, especially in the waters of Washington State (Miller et al., 2012)... Despite this relatively weak spatial relationship, marine factors, and especially decrease in forage species, may play an important role in explaining the apparent population decline (emphasis added), but this relationship is not evident in an analysis with such strong spatial factors. Indeed, for example, a number of smelt species, which as a group are important murrelet prey (Burkett, 1995), are themselves ESA listed within the murrelet's range. ...Murrelet abundance was greater in waters associated with sandy shores... The marbled murrelet is a pursuit diver that preys primarily upon small schooling fishes including sand lance (Ammodytes hexapterus), anchovy (family Engraulidae), herring (Clupea pallasii), and juvenile rockfish (Sebastes spp.) (emphasis added) during spring and summer (Burkett, 1995; Nelson, 1997). We did not have information on the spatial and temporal distributions of these forage fishes that we could include in our models. 5 of 51 This research emphasizes the importance of sand lance, herring and juvenile rockfish for marbled murrelet populations. The number of these forage fish are dropping and some are threatened, endangered or candidates themselves, or were being considered for listing. There are Pacific herring (a keystone forage fish species in the area and was a state candidate species for listing until recently) spawning areas, sand lance spawning areas and surf smelt spawning areas in Squamish Harbor not far from this proposed oyster farm. It is also a rearing area for these important forage fish. Continuing disturbance is ill advised, year after year, on 2 acres of this critical habitat for forage fish, marbled murrelets, Puget Sound Chinook salmon and so many other species. This has not been adequately addressed. The research article, "Marine Habitat Selection by Marbled Murrelets (Brachyramphus mar moratus) During The Breeding Season, by Theresa J. Lorenz, Martin G. Raphael and Thomas S. Bloxton, Jr., USDA, Forest Service, Pacific Northwest Research Station, Olympia, Washington," states: In particular, marine areas in close proximity to old -growth nesting habitat appear important for murrelets during the breeding season and should be priorities for protection... the conservation of marbled murrelets may hinge on protecting not only nesting habitat --the focus of conservation efforts to date --but also on foraging habitat. Sand lance (Ammodytes hexapterus) are considered an important prey of breeding marbled murrelets... They are associated with fine gravel or sandy - bottomed coastal waters ... Given the marine habitat selection we observed in this study, we suggest that marine areas that should be prioritized for protection are those in closest proximity to large tracts of nesting habitat, with low human footprint, and near sand or gravel beaches. Both the Olympic National Park and Olympic National Forest provide excellent nesting habitat a few miles west of the foraging areas in Squamish Harbor. As stated above in the executive summary of the "Washington Department of Fish and Game for the Periodic Status Review for Threatened and Endangered Species for the Marbled Murrelet in Washington (2016)," published in October of 2016: 6of51 Marbled murrelets forage in the marine environment and may fly up to 55 miles inland where they nest and rear a single young on large tree limbs in mature and old conifer forests. A Peninsula Daily News article, "Scientists consider starvation or illness in eastern Strait of Juan de Fuca bird die -off', by Jesse Major, on August 5, 2016, features a story describing how scientists investigating the death of 400 rhinoceros auklets who breed on Protection Island (in Puget Sound about 20 miles northwest of this proposed oyster farm) were likely starved because the size of the sand lance and herring they eat had become too small to satisfy their dietary requirements. Shellfish are touted as being important for cleaning the water of Puget Sound, but the extreme numbers found in shellfish farms may in fact be cleaning the water of the very organisms that serve as the base of the food chain for forage fish, salmon, trout, marbled murrelets and other threatened and endangered species. 7 of 51 2018 11 i , 40, • ::y EstlmaMd Mmlgr =1 0.5.23 'it 0 24-5.6 5.7-112 �. •. •• 11.3 - 22-5 226-434 �. 43 5 - 74 8 M 749-2054 W-- Hood Canal Bridge 0 1 2 4KM w:•wa rn. *r iu�w Figure 6. Relative density of marbled murrelet (Brachyramphus marmoratus) in line transect surveys of Hood Canal bridge, WA during steelhead outmigration 2017-2018 (n=14visits/year). Points represent observations. 8 of 51 20n \iarw,:j ifurrrlei Monitariny Report WPAington nepnnmem or Fish and WW14c to Figure 5. Washington marbled murrelet population density trend for 2001-2020 with 95% confidence band for Zone 1 (Puget Sound and Strait of Juan de Fuca). The trend is for a linear trend in the fog of density, We excluded 20DO From this analysis because distances to birds were not recorded and lever replicates were conducted in that year for Zone 2 and for Zone I Stratum 1. Marbled murrelet 3 ■ ■ / �e / 2 / • r.+ .N C / / 1 ■ Year 9 of 51 Fall -Spring 2019/2020 Marbled Murrelet Monitoring at Navy Facilities Table 3. Estimates of average annual rate of marbled murrelet population change based on at -sea abundance surveys in four strata in the Puget Sound region. Confidence limits are for the estimates of percent annual change. The P-value is based on a 2-tailed test for whether the annual rate of change is less than zero, significant values (p < 0.05) are shaded in gray. Annual 95% Conf. Limits Period of Rate of Adjusted P- Lower Upper Region (Stratum) Analysis Change (%) 2012-2020 -13.5 R2 value I 0.692 0.007 Puget Sound (all strata) -20.7 -5.6 Admiralty Inlet (S2) 2012-2020 -13.7 -23.5 -2.7 0.534 0.024 Hood Canal (S3) 2012-2020 -17.2 -29.1 -3.2 0.527 0.025 Whidbey Basin (S4) 2012-2020 -11.2 -20.3 -1.2 0.478 0.035 Central Puget Sound (S5) 2012-2020 -14.9 -31.5 5.7 0.248 0.119 Pearson, S. F. and M.M. Lance. 2020. Fall -spring 2019/2020 Marbled Murrelet At - Sea Densities for Four Strata Associated with U.S. Navy Facilities in Washington State: Annual Research Progress Report 2020. Washington Department of Fish and Wildlife, Wildlife Science Division, Olympia, WA., provides Table 3, above, showing the decline of marbled murrelets being the most severe in Hood Canal from 2012 through 2020, with a -17.2% rate of change. There was a 13.5% annual drop in Puget Sound and a 17.2% drop in Hood Canal. There were lesser, but still severe drops in murrelet populations in all other sampled locations. These severe drops in murrelet populations would have not been considered in the USFWS 2016 Biological Opinion. The Army Corps of Engineers (Corps) 2015 Programmatic Biological Assessment (PBA) states on page 81-82 that the baseline date of 2012 was used for the environmental baseline. Since the USFWS 2016 Biological Opinion was based on the PBA provided by the Corps, then none of this extreme drop in marbled murrelet numbers would have even been considered in the USFWS 2016 Biological Opinion. 10 of 51 This commercial 2-acre oyster farm should not be approved by Jefferson County due to the expected impact on this highly endangered marbled murrelet and its food source by commercial oyster farming. In the case of marbled murrelets, any impact will likely be permanent as their numbers are dropping so rapidly. WESTERN GREBE State Candidate Species The western grebe is a state candidate for listing as Endangered, Threatened or Sensitive. This species is seen feeding in Puget Sound and Hood Canal. The WDFW information sheet for the western grebe notes that the population is low and the trend suggests it is declining. According to the book, Birds of the Puget Sound Region, by Bob Morse, Tom Aversa and Hal Opperman, 2003, the western grebe feeds mostly on fish obtained by diving. The WDFW fact sheet on the western grebe states: Up to 20-25% of the world's population of western grebes overwinters in Washington. Fish can comprise over 80% of the diet and Pacific herring (Clupea pallasii) can make up more than 50% of their winter diet (emphasis added). The simultaneous declines of wintering western grebe populations and forage fish stocks... around which western grebe concentrations historically gathered, suggest that changes in food resources have played a role in the decline of wintering populations of this species in Washington. ...prey base appears to have declined in the Salish Sea. Action Needed: Determine causes of declining forage fish availability, manage causes of forage fish decline to enhance prey populations. CLARK'S GREBE State Candidate Species 11 of51 According to the book, The Birds of the Puget Sound Region, by Bob Morse, Tom Aversa and Hal Opperman, R. W. Morse Company, Olympia Washington, 2004, page 39, Clark's Grebe is a rare winter visitor in this Region. COMMON LOON State Sensitive Species Common loons are seen feeding year round in portions of Puget Sound. The numbers of common loon are dropping in part due to a lack of quiet undisturbed lakes necessary for their breeding, nesting and raising young and are very dependent on forage fish. According to the WDFW common loon fact sheet: It's overall range has contracted northward. Due to life history and a small population in Washington it is highly vulnerable to impacts (emphasis added).... Common loons feed mainly on fish, typically of a size between 0.35 to 2.45 ounces. Saltwater prey include eels, menhaden, herring, haddock, whiting, pipefish, shiner perch, sand lance, gobies, blennies, Irish lords, gurnards, sculpins, flounder, sole, and skates. They also occasionally take amphibians, crayfish, small crabs and dragonflies.... ....common loons do not begin breeding until at least 6 years of age. There are herring, smelt and sand lance spawning very near this proposed oyster farm. These species are important prey of loons. Noise and other disturbance at this proposed oyster farm, impact on eelgrass, reduction in the base of the food chain and forage fish would all be expected to negatively impact common loons. These impacts should be more carefully considered in a cumulative impact analysis. AMERICAN WHITE PELICAN Listed as a State Sensitive Species 12 of 51 American white pelicans have been observed in Squamish Harbor during the past two years. OTHER IMPORTANT BIRD SPECIES IN PUGET SOUND THAT ARE NOT PRESENTLY THREATENED, ENDANGERED OR CANDIDATE SPECIES GREAT BLUE HERON Priority Species Herons have been common all along Squamish Harbor in the past. Shellfish farming and harvesting make these areas, normally heavily used by herons, unavailable or less useable for catching fish for themselves and their nestlings. The impact of reduced water quality, disturbance, noise, release of microplastics, release of carbon and acidification of the water all negatively impact the food chain for herons and their ability to feed and rear offspring. There has been a steep decline in the number of successful nests around Puget Sound during the past few years. One of only a handful of heron rookeries in all of Hood Canal and the Olympic Peninsula is located about two miles due west of this proposed oyster farm. A recent article in the Port Townsend Leader (7/13/2022), "The mystery of the missing herons", Derek Firenze, reported the alarming news that there were no known active heron colonies in Hood Canal or on the Olympic Peninsula, which used to host many of them, as follows: In January 2020, a volunteer effort began to update existing great blue heron colony locations and nesting numbers to determine the status of the breeding population and distribution within the Puget Sound region. However, since then, absolutely no reports of heron colonies have come from the Olympic Peninsula or the Hood Canal. In the 1920s and '30s, Indian Island and Whidbey Island were home to thriving colonies of great blue herons that have since disappeared without a trace. The same is true of colonies up and down the Hood Canal. 13 of 51 The great blue heron breeding population and colony locations in the Puget Sound were last assessed in 2004-2005. However, in 2015, the great blue heron was removed from Washington's Species of Greatest Conservation Need list based in part on a lack of data to indicate the need for conservation. "They went from being on biologists' radar, to dropping off a cliff," said wildlife biologist and heron expert Ann Eissinger. Eissinger has been studying herons in the region for more than 25 years. This is the same Ann Eissinger who authored "Eissinger, A.M., 2007. Great Blue Herons in Puget Sound. Puget Sound Nearshore Partnership Report No. 2007-06. Published by Seattle District, U.S. Army Corps of Engineers, Seattle, Washington." Great Blue Herons in Puget Sound I Washington Department of Fish & Wildlife. The article notes that Ms. Eissinger is working on an update for which information is lacking. WDFW protections were apparently lessened for the great blue heron in 2015 when WDFW removed it from the Species in Great Conservation Need list in Washington state. The heron is still listed as a Valued Ecosystem Component (VEC) and a Priority Habitat Species in Washington state. Updated data is sorely needed to determine if the loss of heron nesting includes Burley Lagoon and the surrounding area. The link for additional information follows: htts:llwww. tleader.com/stories/the-m ste -of-the-missin -herons 84426 OSPREY Ospreys are completely dependent on fish for themselves and their offspring. There are osprey nests in the vicinity of this proposed oyster farm and they are frequently seen hunting for food in the area. BALD EAGLE A Washington Protected Species 14 of 51 Bald eagles feed and nest along Hood Canal. Fish are the main food for eagles in this area. This proposed oyster farm will create disturbance and noise, especially during construction, planting and harvesting. One would expect the amount of available food from the tidelands to also decrease if this 2 acres of Squamish Harbor is continually disturbed by an active commercial oyster farm. MAMMALS KILLER WHALE (SOUTHERN RESIDENT AND TRANSIENTS) Both are State Endangered Species and the Southern Residents are also a Federal Endangered Species According to the WDFW species sheet: Three populations of killer whales, known as the southern residents, transients, and offshores, regularly occur in Washington. The southern residents are listed as federal endangered species, but all three populations are state endangered species. Southern Resident Killer Whales (SRKW) did occur throughout Puget Sound in the past. Although SRKW are not generally located south of Seattle any longer, they are included in these comments for this commercial oyster farm due to the extreme importance of Puget Sound Chinook salmon (Federal Threatened Species and State Candidate Species) as the main food source in keeping SRKW from becoming extinct. These resident orcas have dropped in number from 98 whales in 1995 to 73 whales in 2022 and 75 whales during the July 1, 2023 annual census. However, one male has not been seen since August, 2023 and is presumed dead, leaving 74. A new male calf was born December, 2023 but has not been seen during a January 27, 2024 survey and is presumed dead on January 30, 2024. The annual census on July 1, 2024 was down to 73 individuals. These orcas are highly dependent on Puget Sound Chinook salmon, some of which rear in Squamish Harbor. Any impacts of commercial oyster farms on Chinook salmon food sources, rearing habitat and travel to the Pacific Ocean can then impact southern resident killer whales. Chinook salmon, in turn, depend of the food web in Squamish Harbor and Hood Canal for food. It is critical that this 15 of51 federally threatened species not be further impacted by continuing to approve more commercial shellfish farms in this critical habitat for Chinook salmon. Puget Sound Chinook salmon are federally listed as threatened. According to the 2022 State of Salmon in Watersheds, Executive Summary, Governor's Salmon Recovery Office, Washington State Recreation and Conservation Office, both the threatened Puget Sound Chinook and threatened Puget Sound steelhead populations are in crisis, the worst ranking among all salmon abundance in 2022 (see the chart below). Transient killer whales occur in Hood Canal. They feed heavily on harbor porpoises and seals, which, in turn, feed on a number of fish species. They too are dependent on the food web in Squamish Harbor. HUMPBACK WHALE State Endangered Species, Mexico Population Federally Threatened, Central America Population Federally Endangered Humpback whales occur in Hood Canal, most frequently during the summer months. According to Sato, C. and G. J. Wiles. 2021. Periodic status review for the humpback whale in Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 29 + iii pp.: The humpback whale is a large baleen whale found in nearly all of the world's oceans that forages on zooplankton and small fish primarily in continental shelf waters. The species undertakes long distance migrations between winter breeding grounds in tropical and subtropical waters and summer feeding grounds in high -latitude waters. Humpback whales have been listed as a state endangered species in Washington since 1981. In 2016 the National Marine Fisheries Service revised the federal Endangered Species Act listing for the humpback whale to identify 14 Distinct Population Segments (DPSs) worldwide, three of which visit Washington's waters. These include (1) the Mexico DPS, which comprises 27.9% of humpback whales present in the state and is federally Threatened, (2) the Central America DPS, which contributes the fewest 16 of51 animals (8.7%) among Washington's humpbacks and is federally Endangered, and (3) the Hawaii DPS, which comprises 63.5% of the humpbacks visiting Washington and is not federally listed. Humpback whales in the North Pacific remain vulnerable to a number of threats, including entanglement in fishing gear and marine debris, ship strikes, human -generated marine sound, the effects of climate change... Foraging and diet. Humpback whales are filter feeders but are unique among baleen whales for their ability to exploit a wide range of prey, including euphausiids (krill), crab, squid, and schooling fish (Witteveen et al. 2005, 2008, Ford 2014). Fish eaten in the northeastern Pacific include juvenile walleye pollock (Gadus chalcogrammus), Pacific herring (Clupea pallasii), Pacific sand lance (Ammodytes personatus)... (See discussion in section on Forage Fish, appeal item # 2.18). Washington Salish Sea sightings have been concentrated in the Strait of Juan de Fuca and near the San Juan Islands, but are also reported throughout Puget Sound, including Hood Canal and as far south as Olympia... Entanglement in fishing gear and marine debris. A growing concern to whale populations is the level of threat posed by entanglement in active drifting or stationary fishing gear (such as gillnets and vertical lines used to mark trap/ pot fisheries) or in discarded netting and other marine debris... Death, injury, or eventual starvation may result when entangled animals fail to free themselves of gear or debris. Risk of entanglement varies with species, the amount of spatial overlap with various fisheries, and the type of gear used in those fisheries. Humpback whales are especially vulnerable to entanglement because of their frequent use of shallower waters, combined with their large knobby pectoral fins and large flukes that make them prone to snagging lines and nets (Saez et al. 2013). Entanglements are the most commonly identified cause of death and injury among humpback whales along California, Oregon, and Washington... Vessel strikes. Whales swimming or resting near the ocean surface can be vulnerable to injury or death from collisions with large and small vessels, 17 of 51 especially in areas of frequent vessel traffic such as the U.S. west coast. Collisions can involve either blunt force trauma or propeller strikes. Disturbance from sound and vessels. Marine mammals in all oceans are exposed to increasing levels of underwater sound from vessels, seismic surveys, sonar, marine construction, and other human -related sources (Nowacek et al. 2007, 2015). Marine ambient noise levels at frequencies below 500 Hz, which overlap with the low -frequency calls of baleen whales, have increased by at least 20 dB (re 1 µPa) since pre -industrial conditions (Hildebrand 2009, Andrew et al. 2011, Redfern et al. 2017). Baleen whales rely on their acoustic sensory system for communicating with other individuals, sometimes at distances of hundreds of kilometers. Significant levels of anthropogenic sound can therefore interfere with communication by masking vocalizations (Erbe et al. 2016). Intense sound can also cause changes in surface, foraging, and vocal behavior, displace animals from occupied areas, and produce temporary or permanent hearing damage and physiological stress... Climate change. The effects of global climate change will likely become one of the greatest threats to many species of marine mammals in the coming decades because of its alteration of marine ecosystems and food webs through changes in ocean temperatures, currents, stratification, and nutrient cycling, and by causing higher sea levels and increased occurrence of unusual and extreme ocean conditions such as strong El Nino events (e.g., Doney et al. 2012) and marine heatwaves... The most recent size estimates place the Central America DPS at 783 whales and the Mexico DPS at 2,806 whales, and together, they comprise 36.6 percent of the humpback whales that visit the state's waters. Throughout their range, humpback whales face a number of known or potential threats such as entanglement in fishing gear and marine debris, ship strikes, human - generated marine sound, and climate change. These are most likely to adversely impact the Mexico and particularly the Central America DPSs because of their smaller sizes and heightened conservation status. GRAY WHALE 18 of 51 State Sensitive Species and Western North Pacific Stock is Federally Endangered According to the WDFW gray whale information sheet: Gray whales in the North Pacific are divided into two genetically -distinct populations (or stocks) known as the Eastern North Pacific and Western North Pacific stocks. The Western North Pacific stock is listed as federal endangered. Individuals from both stocks occur in Washington and are state listed as "sensitive" species. Gray whales face a number of known or potential threats, such as entanglement in fishing gear and marine debris, ship strikes, human - generated marine sound, and climate change. ...their sensitivity (to climate change) will most likely be driven by potential alterations in prey abundance. A combination of increasing ocean acidity, (emphasis added) increasing ocean temperatures, and other changing oceanographic patterns could lead to declines in the small benthic invertebrates that gray whales feed on (mainly amphipods, clams, and krill), as well as disrupt the timing and distribution of prey. Gray whales undertake the longest migration of any mammal, sometimes traveling more than 12,400 miles round-trip annually in coastal waters. PACIFIC HARBOR PORPOISE State Candidate Species According to the WDFW Species Fact Sheet: Very limited information is available regarding the sensitivity of the Pacific harbor porpoise to climate change, particularly for Washington populations. Their overall sensitivity is likely to be influenced by prey availability (e.g., small forage fish like herring, zooplankton (emphasis added)). Porpoises prefer areas with high prey density; thus, any changes in prey density, which could be prompted by climate factors like increasing ocean temperature or declines in pH (emphasis added) could limit prey availability for porpoises. 19 of 51 The diet of the harbor porpoise is primarily schooling fish, such as herring and mackerel, but can also include squid and octopus. An article in the Seattle Times, "Harbor porpoises now a common sight in Puget Sound", was originally published July 8, 2013 and Updated July 9, 2013, reported: Phocoena phocoena is a distinct species unique to Puget Sound's inside waters. They live out their lives near ours, foraging herring, smelt and sand lance in shallow nearshore waters, usually less than 500 feet deep. Living 15 to 20 years, females produce a calf each year for most of those years (emphasis added). Harbor porpoises can be impacted by shellfish farms due to reduced food availability (herring, smelt and sand lance), global warming and sensitivity to noise. The Pacific harbor porpoise is also important prey for the federally and state listed threatened transient orca. KEEN'S MYOTIS BAT State Candidate Species According to Hayes, G. and G. J. Wiles. 2013. Wasliinaton bat conservation plan. Washington Department of Fish and Wildlife, Olympia, Washington. 138+viii pp.: Keen's myotis has one of the smallest distributions of any North American bat, occurring in coastal areas from southeast Alaska to the Olympic Peninsula, Puget Sound, and Mt. Rainier in Washington (Burles and Nagorsen 2003, Boland et al. 2009b, WDFW WSDM database; Appendix A). In Washington, it has been recorded in San Juan, Clallam, Jefferson, Mason, and Pierce counties (van Zyll de Jong and Nagorsen 1994; E. Myers, pers. comm.; WDFW WSDM database). Riparian and estuarine habitats near mature conifer forests are important foraging sites on Vancouver Island (Burles and Nagorsen 2003). The Encyclopedia of Puget Sound, Keen's Myotis, Puget Sound Institute, University of Washington, WDFW, August 2013 states: 20 of 51 Keen's myotis are largely restricted to moist coastal forests of lower elevations dominated by western hemlock, Sitka spruce,and other conifers, although a few records come from urban sites... ... occurring in coastal areas from southeast Alaska to the Olympic Peninsula, Puget Sound, and Mt. Rainier in Washington... These bats occur in Pierce, Mason, Jefferson, Clallam and San Juan counties. ECHINODERM SUNFLOWER SEA STAR Certified as Critically Endangered by International Union for Conservation of Nature and Proposed for Listing as Federally Threatened The sunflower sea star (Pycnopodia helianthoides) has been pushed to the edge of extinction by sea star wasting disease. It's range used to extend from Alaska into Mexico, but it has apparently now disappeared from Oregon, California and Mexico. Scattered populations can still be found in parts of Puget Sound, including Hood Canal. They are the second largest sea star in the world and can have an arm span of over three feet. According to a newspaper article written by Chris Dunagan in the Kitsap Sun on December 11, 2020, ecologists say the sea stars are a key component of the complex marine food web. One important function is to prey upon sea urchins that consume a massive amount of vegetation such as kelp. The sea stars help keep the kelp beds productive. Kelp is also declining in Puget Sound. The listing of the sunflower sea star by the International Union for Conservation of Nature announced a 90-percent reduction in the overall population of sunflower sea stars. There are much reduced numbers in Puget Sound, Canada and Alaska. The entire coastline of western Washington is apparently now devoid of sunflower sea stars and it is only found in Puget Sound (including Hood Canal) and areas to the north. After intensive surveys there have been no signs of the population recovering. According to the Chris Dunagan newspaper article: Taylor Frierson of the Washington Department of Fish and Wildlife stated for a news release that: 21 of 51 The speed and scale of this widespread sea star die -off was absolutely perplexing ...and that the sunflower sea star has a ...fundamental role in the nearshore ecosystem. The Chris Dunagan article further states that in a captive -breeding program at Friday Harbor Labs, the first of its kind: After learning to feed and care for the animals, the challenge was to get the sea stars to spawn and then to help the free-swimming offspring survive and eventually settle down, according to senior research scientist Jason Hodin...'To me, this is the most radical transformation of any metamorphosis in the living world,' Jason said. `The larvae feed on micro algae (emphasis added), and they look nothing like adults. Then, at the ends of their larval period, they have to find their way to appropriate habitat and transform their bodies into a form that can live on the sea floor.' The larvae of the sunflower sea star are feeding on some of the very same organisms that millions of geoducks would be filtering out of nearly all of the water in Burley Lagoon (see Paul Steenberg's Burley Lagoon DEIS input letter, dated 12/3/2021 and forage fish, appeal item #2.18 and food chain, appeal item #2.20). This has not been addressed in a cumulative impacts analysis and is in violation of no net loss. An article in SciTechDaily titled Iconic Sunflower Sea Star Is Now Critically Endangered, by Oregon State University, 1/2/21 states: ...your chances of finding one (sunflower sea star) now are next to nothing in most of the contiguous United States - this listing is one step above extinction... Sunflower sea stars are a key predator of purple sea urchins and the sea star decline has helped fuel an explosion in the urchin population in many regions. An over abundance of urchins is linked to a decline in kelp forests already facing pressure from marine heat wave events, making the future uncertain for ecosystems that provide habitat for thousands of marine animals and help support coastal economies... In this same article, study co-author Sara Hamilton, a Ph. D. candidate in the Oregon State University College of Science states: We need to think creatively about how to keep our ocean healthy. While drawing down carbon emissions is the most pressing need, rebuilding key 22 of 51 predator populations, like the sunflower sea star, can be an important piece of the puzzle too. The oysters filter the water of the very organisms the larval stage of the sunflower sea star need to feed on to prosper. This impact has not been addressed. There has also been no Biological Opinion prepared for this species now that it is proposed by NMFS for listing as Threatened. Once again, there has apparently been no review of the impact of this proposed oyster farm cumulatively with the large number of commercial shellfish farms in Hood Canal on sunflower sea stars, its habitat and the species it feeds upon. Any impacts to this disappearing sunflower sea star need to be studied along with cumulative impacts prior to any county approval of this commercial oyster farm permit. AMPHIBIANS WESTERN TOAD State Candidate Species Squamish Harbor is an area where the Western Toad has occurred in the past (see map at the end of this section). According to the WDFW species sheet, This species is identified as a Species of Greatest Conservation Need (SGCN) under the State Wildlife Action Plan (SWAP) and is also identified as a Priority Species under WDFW's Priority Habitat and Species Program. The WDFW species sheet states: Conservation Threats and Actions Needed Fish and wildlife habitat loss or degradation o Threat: Transportation and service corridors — roads and railroads. o Action Needed: Avoid road building near breeding sites. o Threat: Road mortality when moving to and from breeding sites. Newly metamorphosed toads disperse en masse and gather in piles. When this happens on roads, thousands of toads can be killed by a single vehicle. Adults are also killed as they move to and from breeding sites. 23 of 51 o Action Needed: 1. Identify and map known crossings; 2. Avoid road building near breeding sites; 3. When possible, close roads to vehicles during dispersal periods (e.g., ATV use on gated dirt roads); 4. Create passage structures to circumvent roads. o Threat: Loss of upland habitat through the development on shorelines and around water bodies used for breeding. o Action Needed: Protect known pockets of abundance and breeding areas. o Threat: Habitat alteration and degradation. o Action Needed: Protect known pockets of abundance and breeding areas.... Analysis needs to be undertaken to determine if the western toad is located in the immediate area of the proposed geoduck farm and the supporting areas adjacent to the farming. 24 of 51 96 of 250 o wdfw.wa.gov Distribution Map Western Toad - Known Distribution FA06-20i6 4 ■ ! ■ 0 e� � ! a VAN;, A ' A AIgo A At w j LT. �,. � � nRrTa i &• T Try A&` V . �. •i �Cpwc:r; eA A,1..Ao aAti -a 25 of 51 aawr ' A�dY. YMirlIN .iir rewrnr 7�� MARINE FISH I have included a sampling of the marine fish that can be impacted by this proposed oyster farm, even if they are some distance away. WALLEYE POLLOCK (SOUTH PUGET SOUND) Was a State Candidate Species for listing in Washington as Endangered, Threatened or Sensitive, Is now a Priority Species According to the WDFW species sheet: In Puget Sound, walleye pollock can grow up to 3 feet (91.4 centimeters) in length and live up to 10 years.... Walleye pollock are likely to be sensitive to increases in sea surface temperature, particularly since Puget Sound is the southern limit of their range. Cooler waters support higher levels of pollock recruitment and larval survival because cooler waters promote increased production of primary prey species for pollock (e.g., copepods, euphausiids, other zooplankton). See my discussion regarding the food chain organisms being removed from the water by shellfish. The prey species needed by walleye pollock are likely the very same species that shellfish "clean" from the water. The impact of a two acre alien oyster farm with such a high, unnatural number of individuals would reduce the food organisms available for natural species, many of them showing net losses. PACIFIC COD (SOUTH AND CENTRAL PUGET SOUND) Was State Candidate Species for listing in Washington as Endangered, Threatened or Sensitive and is now a Species of Greatest Conservation Need and a Priority Species According to The Encyclopedia of Puget Sound, Puget Sound Initiative, University of Washington, Bentho-Pelagic Fish: Pacific cod occupy different habitats throughout their life cycle. Eggs are typically found in demersal habitats followed by a transition to the pelagic zone as larvae and small juveniles, settling to intertidal or subtidal sand or 26 of 51 eelgrass habitats (emphasis added) as large juveniles and moving to deep water as adults (reviewed by Gustafson et al. 2000). Juvenile cod feed on crustaceans such as shrimp, mysids and amphipods; the diet of adults is thought to reflect the relative availability of prey with some preference for walleye pollock in large (>70 cm) adults (Gustafson et al. 2000). Pacific cod are preyed upon by a variety of predators including pelagic fishes, sea birds, whales, halibut, shark and other Pacific Cod. According to the WDFW fact sheet Pacific cod are highly vulnerable to climate change and especially vulnerable to increases in sea surface temperature. It states: Pacific cod spawning and recruitment are strongly linked to temperature, with colder water supporting larger hatch size and maximizing growth performance. Cooler waters also support higher abundance of zooplankton prey (e.g., copepods), which is thought to be linked to increased recruitment... Pacific cod in Washington are already at the upper end of their thermal preference, which is likely to increase their sensitivity to any increases in temperature and could lead to northward population shifts. This species is quite dependent on sand and eelgrass habitats that will be negatively impacted by a commercial oyster farm. PACIFIC HERRING This is a Species of Greatest Conservation Need under the State Wildlife Action Plan, is a WDFW Priority Species and was a State Candidate Species for Listing in Washington as Endangered, Threatened or Sensitive until recently and a Federal Species of Concern The Washington State Department of Natural Resources, 2/25/2014. Aquatic Lands Habitat Conservation Plan— Species Spotlight, Pacific Herring, discusses: Importance in the ecosystem food web: Herring are a foundation food source in the food web because they are secondary consumers —eating smaller plant -eating animals. Recently emerged herring and juveniles feed on plankton. Adults feed primarily on planktonic crustaceans, such as copepods and other zooplankton (emphasis added). Approximately 50 to 70 percent of adult herring from Puget Sound are estimated as an important prey item each year for numerous marine animals, such as seabirds, marine 27 of 51 mammals, and other fishes. Herring stock strength is directly linked to the health and status of many such predators, including those protected by state and/or federal laws, such as the Endangered Species Act (ESA). Herring deposit transparent, adhesive eggs on intertidal and shallow subtidal eelgrass and marine algae. Eggs may be deposited anywhere between the upper limits of high tide to a depth of 40 feet. Eggs hatch in about 14 days, producing slender, transparent larvae. At this stage, they are at the mercy of currents and subject to heavy predation by larger organisms. At about three months of age and 11/2 inches long, herring metamorphose into their adult form and coloration. Pacific herring was a state candidate species for listing in Washington as endangered, threatened or sensitive until recently when it was considered a state priority species. It is a federal species of concern. The chart below shows Port Gamble Pacific herring stocks (including Squamish Harbor) are in decline in 2000 and critical by 2016. The decrease in forage fish species numbers since 2000 to 2016, the dates of the USFWS and NMFS Biological Opinions, and the impact of this decrease on the many species that rely on them for food have not been adequately addressed in the jouster farm analysis. The proposed oyster farm is just east of a Pacific herring spawning area and a sand lance spawning area and about two miles northeast of a surf smelt spawning area. Squamish Harbor is also a rearing area for Pacific herring and other important forage fish. Disturbance continuing year after year at an oyster farm on this important habitat for Pacific herring and the species dependent on them, some threatened and endangered, is not adequately addressed. It is apparent from this data in the attached chart that there is already a net loss of this species and their habitat. The Threatened Puget Sound Chinook salmon feed on these herring. The Chinook salmon are so critical as food for the endangered resident orcas. There has not been an adequate cumulative impact analysis on all of the impacts from this proposed and other proposed and active shellfish farms nearby. There has already been a net loss of Pacific herring as is evident from the attached chart. 28 of 51 o wdfw.wa.gov 2016 Washington Stale Herring Stock Status Report 72 76 o 9 Table 1. Status of herring stocks in the southern Salish Sea based on recent 4-year mean abundance compared to rolling long-term (previous 25-year mean) abundance. Inereasings- A stock with recent 4-year mean abundance more than 20% above the 25-year mean; Healthy.- A stock with recent 4-year mean abundance within 20% of the 25-year mean; Declining -A stock with recent 4-year mean abundance 21-50% below the 25-year mean; Depressed s- A stock w ith recent abundance 51-80% below the 25-year mean; Critieallii- A stock with recent 4-year mean abundance 81-99% below the 25-year mean; Uncletecteft- A stock that can no longer be found in a formerly consistently utilized spawning ground for four consecutive years; Unknowne- InsuDicient assessment data to identify stock status with confidence. Individual stocks in BOLD font are considered genetically distinct. The number to the right of each stock name indicates the number of years with biomass estimates available for the 25 year average (1988 through 2012) 2016 Washington State Herring Stock Status Report 73 29 of 51 ROCKFISH All of the following Rockfish were State Candidate Species for listing in Washington as Endangered, Threatened or Sensitive according to the WDFW in 2019 and have since been recognized as "Species of Concern". According to the Executive Summary, page 1, Rockfish Recovery Plan, Puget Sound, NOAA, dated October 13, 2017: Total rockfish abundance in Puget Sound has declined approximately 70% in the last 40 years. The Biology and Assessment of Rock -fishes in Puget Sound By Wayne A. Palsson, Tien-Shui Tsou, Greg G. Bargmann, Raymond M. Buckley, Jim E. West, Mary Lou Mills, Yuk Wing Cheng, and Robert E. Pacunski, Fish Management Division, Fish Program. Washington Department of Fish and Wildlife, September 2009 states: Rockfishes in Puget Sound are a diverse group that form mixed species assemblages and require species -specific habitats at different life -stages. Rockfish have evolved to complex life strategies adapted for long survival, slow growth, late age -at -maturity, low natural mortality rates, and high habitat fidelity... Population structure is highly dependent upon the evolutionary and ecological patterns of each species.... Rockfishes feed on a wide variety of prey, including plankton, crustaceans, and fishes. Rockfishes are prey for a variety of predators including lingcod and other marine fishes, marine mammals, and marine birds. ... larval and juvenile stages of some rockfishes make use of open water and nearshore habitats as they grow. Nearshore vegetated habitats are particularly important for common species of rockfish and serve as nursery areas for juveniles and later provide connecting pathways for movement to adult habitats (emphasis added). Among the potential stressors, fishery removals, derelict gear, hypoxia, and food web interactions are the highest relative risks to rockfish in Puget Sound. Chemical contamination is a moderate risk manifested by undetermined reproductive dysfunction associated with exposure to endocrine disrupting compounds, loading of larvae with persistent organics via maternal transfer, exposure of pelagic larvae to toxics via contaminated 30 of 51 prey, and exposure of long-lived adults to toxics like polychlorinated biphenyl compounds that accumulate over the life of the fish. Most prey studies conducted in Puget Sound and adjacent waters have focused on the diets of copper and quillback rockfishes and have found that shrimps, fishes, and crabs constitute the main components of their diets (Table 3.3). Rockfish size and location may be important factors in the types of prey selected. Murie (1995) studied rockfish diets in Saanich Inlet in the southwestern Strait of Georgia and found that copper rockfish mostly consume, by mass, Pacific herring (Clupea pallasii) (emphasis added), coonstriped shrimp (Pandalus danae), kelp perch (Brachyistius frenatus), pile perch (Rhacochilus vacca), and squat lobster (Munida quadraspina). The diet of copper rockfish depends upon fish size. Copper rockfish smaller than 20 cm in length feed upon demersal crustaceans or pelagic fishes (on a mass basis), while larger copper rockfish principally feed upon pelagic fishes. These feeding patterns are consistent for copper rockfish diets in Puget Sound, except surfperches and other fish are the principal fishes eaten with few or no herring found in the stomach contents. In South Sound, Hueckel and Buckley (1987) found surfperches, pandalid shrimp, greenlings, other fishes, and crabs are the most important prey items. See the Biology and Assessment of Rockfishes in Puget Sound September 2009 3-6. Copper Rockfish in South Sound eat pandalid shrimp, surfperches, and sculpins (Patten 1973). They also eat crabs and other fishes including Pacific herring, spiny dogfish (Squalus acanthias), eel -like fishes, and Pacific sand lance (Ammodytes hexapterus) (Washington et al. 1978). Juvenile copper rockfish from the Nisqually area of South Sound primarily feed upon crangonid and pandalid shrimps followed by fishes in importance (Fresh et al. 1978). Crabs are the second -most important prey item after fishes in the San Juan Islands (Moulton 1977). Miller et al. (1978) found that juvenile copper rockfish eat amphipods, fishes, and mysids as the three most important prey items. Quillback rockfishes consume similar prey items compared to copper rockfish except that demersal crabs and shrimps are usually the most important or highest mass items (Table 3.3). In the most detailed study of quillback rockfish food habitats (Murie 1995) found that the majority of quillback rockfish of any size feed upon pelagic fishes and pelagic and demersal crustaceans, such as squat lobster, euphausids, and coonstriped shrimp on a mass basis. The most important pelagic fish is Pacific herring, 31 of 51 but prey items vary by the size of rockfish. Small quillback rockfish less than 20 cm in length feed primarily on demersal crustaceans and pelagic fish, and to a lesser extent, pelagic crustaceans. In contrast, most of the food mass consumed by larger quillback rockfish (greater than 20 cm) consists of pelagic fishes. Studies from central Puget Sound also found that small and medium-sized quillback rockfishes primarily consume demersal crustaceans, including pandalid and hippolytid shrimp, amphipods, crabs, but also consume euphausids as an important prey category (Washington et al. 1978, Heuckel 1980). Large quillback rockfishes consume crabs, shrimp, fishes, and amphipods as their principal prey items, showing that fishes are important in larger rockfish diets, but there is still a high degree of dependence upon benthic invertebrates. Moulton (1977) examined stomachs from juvenile quillback rockfish from the San Juan Islands and found that crabs, fish, and shrimp are the most important constituents of their diets. There is some seasonality to the feeding patterns of copper and quillback rockfishes. Copper rockfish feed throughout the year, but quillback rockfish tended to have fuller stomachs during the spring and summer than during the winter and fall (Murie 1995). Both copper and quillback rockfishes feed on pelagic fishes during all seasons but pelagic fishes are more prevalent in rockfish diets during the winter. Demersal crustaceans are more important on a mass basis for copper rockfish during the spring and summer. Murie (1995) found daily variation in the feeding patterns of copper and quillback rockfishes. Copper rockfish have higher percentages of full stomachs after sunrise and sunset indicating crepuscular feeding activities. In contrast, quillback rockfish feed at mid -day. Moulton (1977) found a similar crepuscular pattern in daily feeding patterns for copper rockfish, but found that quillback rockfish in the San Juan Islands are also crepuscular feeders, not mid -day feeders. Limited food habit data for other rockfishes only allow for a general description and categorization of their feeding ecology. Brown rockfish in South Sound depend upon fish and demersal crustaceans, including crabs, pandalid and other shrimps, and isopods (Washington et al. 1978, Hueckel and Buckley 1987). One tiger rockfish sampled from the San Juan Islands only had crabs in its stomach, and one yelloweye rockfish had pandalid shrimp and nematodes (Miller et al. 1978). In South Sound, yelloweye rockfish feed on fishes, especially walleye pollock (Theragra chalcogramma), cottids, poachers, and Pacific cod (Gadus macrocephalus) (Washington et al. 1978). As expected, black rockfish feed upon pelagic prey 32 of 51 including fishes such as Pacific sand lance, Pacific herring, and sculpins, hyperiid amphipods, euphausids, chaetognaths, gelatinous zooplankton, shrimps, and crabs. Yellowtail rockfish, which often co -inhabits pelagic schools with black rockfish, feed upon fishes, shrimp, chaetoghanths, and euphausids, similar to black rockfish, but their diets also include mysids, crab larvae, calanoid copepods, and polychaetes (Moulton 1977, Miller et al. 1978, Washington et al. 1978). The diet of Puget Sound rockfish consists of small prey items such as calanoid copepods, crab larvae, chaetognaths, hyperiid amphipods and siphonophores (Moulton 1977, Miller et al. 1978). Rockfishes of all sizes are an important food resource for a variety of predators in Puget Sound. They are prevalent in the diets of lingcod, other marine fishes, marine birds, and marine mammals. Marine mammals.- Rockfishes are consumed in varying but low amounts by marine mammals including harbor seals (Phoca vitulina), California sea lions (Zalophus californianus), and orca (Orcinus orca) in Puget Sound. There are two types of killer whales (Orca) that inhabit Puget Sound, the "resident" whales that spend their entire lives in the Sound and "transient whales that move in and out of the Sound. The transient whales primarily consume marine mammals, while the resident whales feed on fish (Wiles 2004). Limited studies of the diet of resident killer whales found that during the spring, summer, and fall 22 species of fish are consumed. However, approximately 96% of the diet during these times consist of chinook salmon (Wiles 2004) (emphasis added). There has been one instance of a yelloweye rockfish being consumed by a killer whale (Wiles 2004). Rockfish can exhibit avoidance and other behaviors to stimuli. Rockfish exhibit strong depth and geographic movements in response to hypoxic waters, apparently avoiding waters with dissolved oxygen concentrations of less than 2 mg/L (Palsson et al., 2008). Rockfish, however, may also avoid warm, stratified water greater than 11 degrees C, remaining below the thermocline but above the oxycline when hypoxic conditions are not too severe... In addition to their behavioral response to hypoxia, mass mortality events have killed approximately a quarter of all copper rockfish present at a marine reserve in Hood Canal. The mortality event occurred when dissolved oxygen concentrations were likely below 1 mg/L (Palsson et al. 33 of 51 2008) (emphasis added), and smaller rockfish were affected more than larger rockfish. A recent study of climate change by the University of Washington concluded that profound changes have occurred in the Puget Sound environment over the past century and that the next several decades will see even more changes (Snover et al. 2005). Projected changes that could impact rockfishes include increases in water temperature and flooding, accelerated rates of sea level rise, loss of nearshore habitat (emphasis added), changes in plankton, and increased likelihood of algae blooms and low levels of dissolved oxygen (emphasis added). Loss of nearshore habitat that occurs with commercial oyster farm activities is a potential impact to rockfishes. BLACK ROCKFISH This species is identified as a Priority Species under WDFW's Priority Habitat and Species Program. Also according to WDFW Black rockfish can grow up to 69 cm (27.6 in) in length, and 5 kg (I I lbs) in weight. Maximum age is 50 years old. Ecological Research on Rockfishes in Puget Sound, NOAA, no date given, states: Relative Importance of Pelagic, Kelp Forest and Eelgrass Habitats to Rockfish ... In the Puget Sound, bull kelp (Nereocystis luetkeana) and eelgrass (Zostera marina) are important biogenic habitats providing shelter for various valued species (emphasis added). As such, they are the focus of restoration efforts. BOCACCIO ROCKFISH Listed as a Federal Endangered Species in Puget Sound. Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: ....rockfish habitat utilization in Puget Sound indicate that nearshore vegetated habitats are particularly important for some species and serve as 34 of 51 nursery areas for juveniles (Palsson et al., 2009) (79 FR 68042). Juvenile bocaccio settle to shallow, algae -covered rocky areas or to eelgrass and sand (emphasis added).... According to NOAA Fisheries, Fish Watch, Species Directory, no date: Boccaccio larvae are opportunistic feeders. Early on, larvae mostly eat copepod nauplii and eat some invertebrate eggs. As they grow, larvae start eating copepodites adult copepods, and euphausiids. Within the first year of their lives, Boccaccio begin foraging on other young fishes. The following rockfish are also listed or were candidate species for listing. See the descriptions of some of their prey items and other information about them in the main discussion above, under the Rockfish heading. BROWN ROCKFISH This is a species of greatest conservation need and a priority species. According to the WDFW fact sheet: The main sensitivity of brown rockfish to climate change is likely to stem from changes to their prey base. Warmer ocean conditions could lead to decreases in prey (e.g. zooplankton) for both juveniles and adults, prompting decreases in adult fecundity and juvenile survival. Additionally. Nearshore habitat loss due to sea level rise could impact juvenile survival, as juveniles tend to use nearshore habitat as nursery and foraging area. COPPER ROCKFISH This is a species of greatest conservation need and a priority species. According to the WDFW fact sheet: The main sensitivity of brown rockfish to climate change is likely to stem from changes to their prey base. Warmer ocean conditions could lead to 35 of 51 decreases in prey (e.g. zooplankton) for both juveniles and adults, prompting decreases in adult fecundity and juvenile survival. Additionally. Nearshore habitat loss due to sea level rise could impact juvenile survival, as juveniles tend to use nearshore habitat as nursery and foraging area. CANARY ROCKFISH Was previously federally listed as a threatened species in Puget Sound until recently. GREENSTRIPED ROCKFISH QUILLBACK ROCKFISH This is a species of greatest conservation need and a priority species. REDSTRIPE ROCKFISH YELLOWEYE ROCKFISH Federally listed as threatened species in Puget Sound. YELLOWTAIL ROCKFISH SALMON AND TROUT INTRODUCTION Squamish Harbor and Hood Canal contain populations of the federally threatened and state candidate species for listing as State Endangered, Threatened, or Sensitive, Puget Sound steelhead (Oncorhynchus mykiss); federally Threatened, state Species of Greatest Conservation Need and a state Priority Species, Puget Sound Chinook salmon (O. tsha cha); federally Threatened, state candidate species for listing as State Endangered, Threatened or Sensitive, Bull trout (Salvelinus confluentus), and federally threatened Hood Canal summer -run chum salmon. 36 of 51 Shellfish aquaculture adversely affects marine life, including Puget Sound Chinook salmon which are essential to Southern Resident Killer Whale (Orca) survival. See the discussion of this species in the section in this document on killer whales in the mammal section. The 2017 Army Corps Draft Cumulative Effects Analysis is a frank assessment of what the science shows will likely happen if industrial scale aquaculture is allowed to continue, much less expand. The Corps concluded: The proposed action (shellfish aquaculture permitting) is likely to adversely affect designated critical habitat for several species listed under the ESA including Puget Sound Chinook salmon ... and Puget Sound steelhead (Page 101). Given the magnitude of the impacts in acreage, the importance of eelgrass (emphasis added) to the marine ecosystem, and the scale of the aquaculture impacts relative to other stressors, the impacts are considered significant (Page 103). The conclusion therefore is that significant cumulative effects to surf smelt and sand lance spawning habitat would occur due to the proposed action (shellfish aquaculture permitting) (emphasis added) (Page 112). The proposed action (shellfish aquaculture permitting) is inconsistent with State requirements under the SMA to protect forage fish spawning habitat (emphasis added) (Page 111). These determinations make clear that shellfish aquaculture is impacting these threatened and endangered salmon and trout as well as the eelgrass and forage fish that are important for their food, habitat and survival. See the discussion Pacific herring in this document for more detailed information. Programmatic Biological Assessment, Shellfish Activities in Washington State Inland Marine Waters, U.S. Army Corps of Engineers Regulatory Program, Seattle District, October 2015, states: 8.1.3. Effect Determination. The proposed action (shellfish aquaculture permitting) may affect, likely to adversely affect Puget Sound Chinook 37 of 51 salmon and Puget Sound Chinook salmon designated critical habitat. [Page 106] 8.6.3. Effect Determination. The proposed action may affect, likely to adversely affect bull trout and bull trout designated critical habitat. [Page 112] 9.2.... As discussed in the PBA and summarized above, the activities authorized under the proposed action would affect EFH (Essential Fish Habitat). While these effects would be minimized by the implementation of the many Conservation Measures, the proposed action would result in adverse effects to EFH for groundfish, coastal pelagic, and Pacific salmon species. [Page 126] STEELHEAD, PUGET SOUND DISTINCT POPULATION SEGMENT Federal Threatened Species and state candidate species for listing as State Endangered, Threatened, or Sensitive Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: The winter -run steelhead is the predominant run in Puget Sound, in part because there are relatively few basins in the Puget Sound DPS with the flow and watershed characteristics necessary to establish the summer -run life history (National Marine Fisheries Service, 2016c). All summer -run stocks are depressed and concentrated in northern and central Puget Sound and Hood Canal..... NMFS (2016a) indicated the principal factor for decline for Puget Sound steelhead is the present or threatened destruction, modification, or curtailment of its habitat or range. Within Puget Sound, these threats may include barriers to fish passage, adverse effects on water quality, loss of wetland and riparian habitats, and other urban development activities contributing to the loss and degradation of steelhead habitats (National Marine Fisheries Service, 2016a, 2016c). 38 of 51 NMFS (National Marine Fisheries Service). 2019. ESA Recovery Plan for the Puget Sound Steelhead Distinct Population Segment (Oncorhynchus mykiss). National Marine Fisheries Service. Seattle, WA, states: Unlike salmon species, steelhead are iteroparous, capable of repeat spawning in successive years, and they have a resident life -history form (Rainbow trout) that is capable of producing anadromous offspring and interbreeding with anadromous life forms. Adult steelhead also have a leaping ability that exceeds salmon, which allows them to migrate far into the headwater reaches of watersheds. Adult Puget Sound steelhead commonly return from the ocean after two to three years to spawning and rearing habitats in independent tributaries that flow into Puget Sound, Hood Canal, and the Strait of Juan de Fuca. The recovery team identified 10 primary pressures associated with the listing decision for Puget Sound steelhead and subsequent affirmations of the listing. These "pressures" are human activities and natural events that cause or contribute to the species' decline in viability. The 10 primary pressures are: .... juvenile mortality in estuary and marine waters of Puget Sound; and climate change. High mortality of juvenile Puget Sound steelhead during their migration through the marine environment of Puget Sound remains a primary factor limiting the species' survival and recovery. Puget Sound steelhead early marine mortality is generally defined as mortality that occurs as steelhead smolts (juveniles) enter the marine environment and die during a short outmigration window though the Sound before entering the Pacific Ocean. Steelhead spend a few days to a few weeks migrating through Puget Sound, and the mortality rates during this short period of their life cycle are critically high. Puget Sound steelhead marine survival rates are lower than for populations from other nearby regions, including for coastal Washington and Columbia River populations. The high mortality rates currently observed in steelhead smolts migrating through Puget Sound towards the ocean represent a major bottleneck to the productivity and abundance of steelhead on a regional basis. These high mortality rates are unsustainable over the long term, since they are seriously impairing the VSP components of steelhead (especially productivity), and thus the recovery of the Puget Sound steelhead DPS (emphasis added). 39 of 51 Puget Sound steelhead have suffered from widespread loss and degradation of freshwater habitat and degradation of nearshore marine habitat (NMFS 2016). The reduced quantity and quality of freshwater habitat that limits the viability of steelhead in Puget Sound streams is the primary factor that led to the listing of Puget Sound steelhead. Unless habitat is more effectively protected and restored, Puget Sound steelhead are very unlikely to recover (emphasis added). NMFS will need to determine that steelhead habitat condition is, and will likely continue to be, adequate to support a viable DPS before it can remove Puget Sound steelhead from the list of threatened species. Healthy freshwater and nearshore marine habitat conditions will be particularly important given the recent evidence of very low marine survival in the Salish Sea, which has led to recent periods of unprecedented low overall survival and productivity (Page 137). It is clear that the marine habitat conditions are critically important for Puget Sound steelhead. As discussed above, the high mortality rates that occur when steelhead smolts are migrating through Hood Canal to the ocean are a major difficulty. In addition, a very high number, about 50%, of out -migrating steelhead are being lost as they try to cross under or around the Hood Canal Floating Bridge. That makes it even more important that more young steelhead are not lost from disturbance and lack of prey on their migration out through the area proposed for the oyster farm. CHINOOK SALMON, PUGET SOUND EVOLUTIONARY SIGNIFICANT UNIT Federally Threatened Species, State Species of Greatest Conservation Need and a State Priority Species The 2020 State of Salmon in Watersheds Report, Washington State Recreation and Conservation Office, Governor's Salmon Recovery Office, Olympia, WA concluded: That wild Puget Sound Chinook salmon are "in crisis" despite being listed under the Endangered Species Act (ESA) for more than two decades. The number of natural -origin Chinook salmon returning to many Puget Sound 40 of 51 rivers has dropped to some of the lowest levels on record, affecting the entire Puget Sound ecosystem, as well as local economies and fishing opportunities. Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: Puget Sound Chinook Salmon Evolutionary Significant Unit (ESU) was listed as threatened on June 28, 2005. This ESU includes all wild (naturally spawned) populations of Chinook salmon from rivers and streams flowing into Puget Sound, including the Strait of Juan de Fuca from the Elwha River, eastward, including rivers and streams flowing into Hood Canal.... The general life history of anadromous Chinook salmon includes both freshwater and ocean phases of development. Incubation, hatching, and emergence occur in fresh water, followed by seaward migration to the ocean, which is preceded by the onset of smoltification. After several years at sea, maturation is initiated and adults return to freshwater habitats to spawn in their natal streams. Stream -type Chinook salmon spend extended periods in fresh water before smoltification, in contrast to the ocean -type that immigrates to the ocean as sub -yearling smolts. Puget Sound Salmon Recovery Plan, adopted by the National Marine Fisheries Service (NMFS) January 19, 2007, Submitted by the Shared Strategy Development Committee, Shared Strategy for Puget Sound, Seattle, WA, states: The majority of Puget Sound Chinook leave the freshwater environment during their first year, making extensive use of the protected estuary and nearshore habitats (emphasis added). Nearshore ecosystems provide areas for the young Chinook to forage and hide from predators. Juvenile salmon experience the highest growth rates of their lives while in the highly productive estuaries and nearshore waters. These estuarine habitats are ideal for juvenile salmon to undergo the physiological transition to saltwater, and to readjust to freshwater when they return to spawn as adults. Nearshore areas serve as the migratory pathway to ocean feeding areas. The vegetation, shade and insect production along river mouth deltas and protected shorelines help to provide food, cover and the regulation of 41 of 51 temperatures in shallow channels. Forage fish spawn in large aggregations along protected shorelines, thus generating a base of prey for the migrating salmon fry (emphasis added). Salmon often utilize "pocket estuaries" -small estuaries located at the mouths of streams and drainages, where freshwater input helps them to adjust to the change in salinity, insect production is high, and the shallow waters protect them from larger fish that may prey on them. As the juvenile salmon grow and adjust, they move out to more exposed shorelines such as eelgrass, kelp beds and rocky shorelines where they continue their migratory path to the ocean environment. As the Chinook salmon move through Hood Canal on their way to the Pacific Ocean, the condition of the habitat, including cover such as eelgrass, and the availability of food organisms is critical. There is already a great deal of impact in Hood Canal that needs to be analyzed in terms of cumulative impacts and no net loss for this species as well as the resident orca further up in Puget Sound that depend on them for food. There most certainly is a net loss of both Chinook salmon and resident orcas. The permit for this oyster farm should not be approved until a thorough cumulative impact analysis has been completed, especially due to the Chinook salmon and other T&E species being in crisis. 42 of 51 Salmon Abundance IN CRISIS NOT KEEPING PACE MAKING PROGRESS APPROACHING GOAL SNAKE RIVER PUGET SNAKE LOWER LOWER LOWER HOODCANAL SNAKE SPRING/SUMMER SOUND RIVERBASIN COLUMBIA RIVER COLUMBIA COLUMBIARIVER SUMMER RIVER FALL CHW-4 CHINOOK S1'EELHEAD ul1.;na. RIVER STEEIHEAD CHUM CHINOOK CpHp �� rr i -4 l LAKE 0zFT7E OPPERLOLtIN11A UPPER MIDDLL SOCKEVf RIVER SPRING LOLUMIUAMYli COLUMBIARIVER CHINOOK STEELHEAD STEELHLAO e we ►► SHwn F"M 2O" T0@02k TSOurID COWµi{IA Smite Rhwrlask%StMMa ldtr.Mod Opm PVGE STEE T SOUJ RIYE.i1. L-�20) S* 4Ilfz , P+^-p",'+..07`,• ClIUM' :.4N!!IrCoRY11DIL00MrCYE7C+h'roSkafn •krt rrrp.� R+ts' 3d.`9f sa'uay:n7 Prefytrss'�71i I Lacks complete data Data and analysis by Washington Department of Fish and Wildlife 7 2022 STATE OF SALMON IN WATERSHEDS EXECUTIVE SUMMARY I STATEOFSALMON.WA.00V 43 of 51 BULL TROUT Federally Threatened, State Candidate Species for Listing as State Endangered, Threatened or Sensitive Bull Trout, a listed threatened species, is found in the estuarine and marine waters of Puget Sound. Some bull trout are anadromous. According to the research publication "Behavior of Anadromous Bull Trout in the Puget Sound and Pacific Coast of Washington by Fred Goetz, et al., Estuarine Research Federation Conference, September 2003": ...bull trout are anadromous, inhabiting estuarine and nearshore marine waters for up to 5 months each year, possibly returning to these waters every year for up to 10 years. Bull trout are recognized as an apex predator in river and estuarine waters and can show a wide array of behaviors in their search for available prey, which can include juvenile salmon and forage fish such as surf smelt, sand lance and herring (emphasis added).... Months of estuary and nearshore use are predominantly March to July.... Fish were found from 1 in to 20 in depths, over all substrates, many near by to eelgrass areas (emphasis added). Protected areas appear to have more fish. Puget Sound Salmon Recovery Plan, adopted by the National Marine Fisheries Service (NMFS) January 19, 2007, Submitted by the Shared Strategy Development Committee, Shared Strategy for Puget Sound, Seattle, WA, states: Unlike chum and Chinook salmon, bull trout survive to spawn year after year. Since many populations of bull trout migrate from their natal tributary streams to larger water bodies such as rivers, lakes and saltwater, bull trout require two-way passage for repeat spawning as well (Page 56). While all bull trout are opportunistic eaters, feeding on insects, macrozooplankton, and crayfish, migratory bull trout are primarily "piscivorous"--they prey mostly on juvenile trout, salmon and other species of fish. Like other salmonids, the availability of food sources for newly hatched bull trout is particularly important. An adequate food base is critical to sustaining migratory bull trout in freshwater systems as well as saltwater forage areas (Page 57). 44 of 51 Although both resident and migratory forms of bull trout are present in the Coastal/Puget Sound bull trout population segment, it is the only known segment of bull trout in the United States that includes the anadromous life history form (spawns in freshwater, migrates to saltwater and returns to freshwater to spawn). Technically, Coastal/Puget Sound bull trout often return seasonally to freshwater as sub -adults, sometimes for several years, before returning to their natal tributary to spawn. These sub -adult bull trout move into marine waters and return to freshwater to take advantage of seasonal forage opportunities to feed on salmonid eggs, smolts or juveniles. Bull trout in the Coastal/Puget Sound population segment also move through the marine areas to gain access to independent streams to forage or take refuge from high flows. Bull trout target a variety of estuarine and near -shore marine forage fish such as sand lance, surf smelt and herring, and depend on the persistence of productive forage fish spawning beaches and intertidal habitats such as eelgrass beds and large woody debris (emphasis added). These populations can migrate extensively while in the marine waters of Puget Sound, the Strait of Juan de Fuca and the Pacific Ocean; but there is currently no evidence that they make long off -shore migrations similar to other salmon (Page 57). The availability of eelgrass and forage fish is impacted by commercial shellfish farming. See the discussion in this document on Pacific herring. Also see the diagram below that shows all of the shoreline areas that are bull trout foraging areas. The cumulative impact of adding even more commercial shellfish farming to Hood Canal has not been adequately addressed for bull trout or cumulative impacts and should not be approved. 45 of 51 O mpositary.library.noaa.gov Figure 2.13 Indicates where bull trout core areas overlap with the Puget Sound Chinook ESU. Hoh, Quinault, and Queefs core areas are located along the Pacific Coast of the Olympic Peninsula and are not included on this map. 46 of 51 IN SUMMARY In summary, there are an excessive number of listed threatened and endangered species and other priority species occurring in Squamish Harbor and Hood Canal. There is not an adequate cumulative impact analysis for this species. RCW 90.58.020 states: The legislature finds that the shorelines of the state are among the most valuable and fragile of its natural resources and there is great concern throughout the state relating to their utilization, protection, restoration and preservation ... This policy contemplates protecting against adverse effects to the public health, the land and its vegetation and wildlife, and the waters of the state and their aquatic life... There are numerous examples given above of the existing condition of shoreline ecological functions currently NOT being maintained. The no net loss standard is designed to halt the introduction of additional impacts to shoreline ecological functions. There IS a net loss of many of these species. The data already show a net loss in Hood Canal and adjacent areas of Puget Sound, many of them already under very intensive shellfish farming. Any introduction of another 2 acres of shellfish farming will cause further harm and does not meet no net loss. This proposal should be either denied or require more analysis based on the numerous impacts to the species listed above. The existing significant impacts to many of these species cannot be avoided, reduced or mitigated. 47 of 51 References Cited Bloxton, Thomas D., Jr. and Martin G. Raphael, May 2009. Breeding Ecology of the Marbled Murrelet in Washington State, Five Year Project Summary (2004-2008), USDA Forest Service, Pacific Northwest Research Station, Olympia, Washington Calfas, Jennifer, September 19, 2019. Bird Populations Plummet in North America, Science magazine as reported in "The Wall Street Journal" Dunagan, Chris, December 11, 2020. Sunflower Sea Stars, Kitsap Sun Eissinger, A.M., 2007. Great Blue Herons in Puget Sound. Puget Sound Nearshore Partnership Report No. 2007-06. Published by Seattle District, U.S. Army Corps of Engineers, Seattle, Washington. Derek Firenze, 7/13/2022. The mystery of the missing herons. Port Townsend Leader Fred Goetz, et al., September 2003. Behavior of Anadromous Bull Trout in the Puget Sound and Pacific Coast of Washington, Estuarine Research Federation Conference, September 2003 Governor's Salmon Recovery Office, Washington State Recreation and Conservation Office, 2020. The 2020 State of Salmon in Watersheds Report, Olympia, WA Hayes, G. and G. J. Wiles. 2013. Washington bat conservation plan. Washington Department of Fish and Wildlife, Olympia, Washington. 138+viii pp. Lance, M.M., and S.F. Pearson. 2021. Washington 2020 at -sea marbled murrelet population monitoring: Research Progress Report. Washington Department of Fish and Wildlife, Wildlife Science Division Lorenz, Theresa J., Martin G. Raphael and Thomas S. Bloxton, Jr., 2016. Marine Habitat Selection by Marbled Murrelets (Brachyi-airiphus marmoratus) During The Breeding Season, USDA, Forest Service, Pacific Northwest Research Station, Olympia, Washington 48 of 51 Jesse Major, August 5, 2016. Scientists consider starvation or illness in eastern Strait of Juan de Fuca bird die -off. Peninsula Daily News article Martin G. Raphael, Andrew J. Shirk, Gary A. Falxa, Scott F. Pearson, June 26, 2014. Habitat associations of marbled murrelets during the nesting season in nearshore waters along the Washington to California coast, Journal of Marine Systems McIver, W. R.; Baldwin, J.; Lance, M. M.; Pearson, S. F.; Strong, C.; Raphael, M. G.; Duarte, A.; Fitzgerald, K. 2023. Marbled Murrelet Effectiveness Monitoring, Northwest Forest Plan - 2022 Summary Report, Northwest Forest Plan Interagency Regional Monitoring Program. January 2023, final report. 25 p. Morse, Bob, Tom Aversa and Hal Opperman, 2003. Birds of the Puget Sound Region, R. W. Morse Company, Olympia, WA National Marine Fisheries Service (NMFS), January 19, 2007. Puget Sound Salmon Recovery Plan, adopted by the National Marine Fisheries Service (NMFS), Submitted by the Shared Strategy Development Committee, Shared Strategy for Puget Sound, Seattle, WA National Marine Fisheries Service (NMFS), 2019. ESA Recovery Plan for the Puget Sound Steelhead Distinct Population Segment (Oncorhynchus mykiss). National Marine Fisheries Service. Seattle, WA Navy, Department of, October 2019. Naval Special Operations Training in Western Washington State, Final Environmental Assessment NOAA, October 13, 2017. Rockfish Recovery Plan, Puget Sound, Executive Summary NOAA, no date given. Ecological Research on Rockfishes in Puget Sound Pearson, S. F. and M.M. Lance. 2020. Fall -spring 2019/2020 Marbled Murrelet At - Sea Densities for Four Strata Associated with U.S. Navy Facilities in Washington State: Annual Research Progress Report 2020. Washington Department of Fish and Wildlife, Wildlife Science Division, Olympia, WA Puget Sound Institute, Puget Sound Initiative, University of Washington, The Encyclopedia of Puget Sound, Bentho-Pelagic Fish 49 of 51 Sato, C. and G. J. Wiles. 2021. Periodic status review for the humpback whale in Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 29 + iii pp. SciTechDaily, Oregon State University, 1/2/21. Iconic Sunflower Sea Star Is Now Critically Endangered Mapes, Lynda V., originally published July 8, 2013 and Updated July 9, 2013. Harbor porpoises now a common sight in Puget Sound. Seattle Times. Palsson, Wayne A., Tien-Shui Tsou, Greg G. Bargmann, Raymond M. Buckley, Jim E. West, Mary Lou Mills, Yuk Wing Cheng, and Robert E. Pacunski, September 2009. The Biology and Assessment of Rockfishes in Puget Sound, Fish Management Division, Fish Program. Washington Department of Fish and Wildlife Steenberg, Paul E., 12/3/2021. Public comments, DEIS input, Proposed 25.5-acre geoduck farm in Burley Lagoon, WA. Washington Department of Fish and Wildlife, October of 2016. Executive summary for the Periodic Status Review for Threatened and Endangered Species for the Marbled Murrelet in Washington WDFW fact sheet on the brown rockfish WDFW fact sheet on the common loon WDFW fact sheet on the copper rockfish WDFW fact sheet on the gray whale WDFW fact sheet on the harbor porpoise WDFW fact sheet on the killer whale WDFW fact sheet on the Pacific cod WDFW fact sheet on the walleye pollock 50 of 51 WDFW fact sheet on the western grebe WDFW fact sheet on the western toad WDFW's Priority Habitat and Species Program. Priority Species black rockfish described under WDFW's Priority Habitat and Species Program. WDFW, August 2013. The Encyclopedia of Puget Sound, Keen's Myotis, Puget Sound Institute, University of Washington. Washington State Department of Natural Resources, 2/25/2014. Aquatic Lands Conservation Plan— Species Spotlight, Pacific Herring. 51 of 51