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Regular Agenda
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO: Board of County Commissioners
Philip Morley, County Administrator
FROM: AI Scalf, Director - Department of Community Develop
Stacie Hoskins, Planning Manager/Shoreline Administrato
Michelle McConnell, Associate Planne~ ~
DATE: April 25, 2011
SUBJECT: Continued Discussion: Finfish Aquaculture and Tlmeline For Preparation ofthe Draft
Jefferson County Response to Ecology on Changes to the Locally Approved Shoreline
Master Program (MLA08-475)
ATTACHED: 1) Revised Finfish Bibliography; 2) Draft letter to Ecology
STATEMENT OF ISSUE: During February and March of this year, the Board of County Commissioners
reviewed the DRAFT Jefferson County Response to Ecology on Changes to the LocaUy Approved SMP
('Draft County Response'). While the Board has provided direction on most of the 61 possible changes
to the Locally Approved SMP, additional discussion is needed on provisions for finfish/net pen
aquaculture. On March 21, 2011, the Board directed staff to collect and review additional scientific,
technical and policy guidance literature to assist the preparation of an alternative proposal for
management of finfish aquaculture use/development within the County's shoreline Jurisdiction. Staff
has collected over 70 documents to support continued Board discussion on the topic. A revised Finfish
Bibliography of those documents is submitted with this request.
Further, in February of this year, the County informed Ecology of its intent to submit a response by April
30, 2011 after completion of a public process. Because the finfish aquaculture issue has required
additional consideration, the public process has been delayed, and the County needs to inform Ecology
of its progress and anticipated future action.
ANALYSIS/STRATEGIC GOALS/PROS and CONS:
Ecology's approval is regarding the December 7, 2009 Locally Approved SMP, submitted to Ecology on
March 1, 2010 as Exhibit A of Jefferson County Resolution 77-09 (erroneously referenced in Ecoiogy
documents as 'Ordinance Number 77-09') as the proposed amendments to the Jefferson County
Comprehensive Plan and Jefferson County Code. This SMP Comprehensive Update (MLAOB-475) is
required by law and must be completed by December 2011.
In March 2010, the County submitted a LocaUy Approved ShoreUne Master Program (SMP) to the
Washington Department of Ecology (Ecology) for final review and approval, per RCW 90.58 and WAC
173-26. After a public review process, Ecology reviewed the County's proposed SMP update for
consistency with state statutory and rule requirements.
1
Regular Agenda
On January 26, 2011 Ecology determined that the County has met the procedural and policy
requirements of the Shoreline Management Act and the SMP Guidelines, pending some required
changes. A letter from Ecology's director with three attachments outlines their conditioned approval,
findings and conclusions, required and recommended changes. The County needs to consider the
required changes and respond as to whether to accept or propose alternatives to those changes as part
of the process for final adoption by the state and by local ordinance.
Staff reviewed the required and recommended changes and provided guidance to the Board on whether
to agree, further study, decline or propose alternative changes, Including numerous revisions proposed
for clarification to correct various errors In the dO,cument prior to final adoption. The Board discussed
the DCD Recommendation on February 22, February 28 and March 7, 2011 providing feedback to staff
on each item for the County's response to Ecology. The Board reviewed and discussed the Draft County
Response on March 14 and 21. Additional information has been gathered and the Board continued
discussion on the topic of finfish aquaculture on April 18 but further discussion Is needed.
In addition, the County needs to alert Ecology as to the status of meeting the April 30, 2011 deadline for
submittal of a response regarding the required and recommended changes to the LA-SMP.
FISCAL IMPACflcOST-BENEFIT ANALYSIS:
Grant funding for the SMP Update ended In June 2009. Department of Community Development staff
work is covered by the department's annual budget.
RECOMMENDATION:
Staff recommends the Board:
1. Discuss their review of, and provide staff with any questions about, the additional literature on
finfish aquaculture.
2. Take action to approve sending a letter to W A Department of Ecology about status of response
and public process.
lt/~{ It
Date
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Jefferson County Shoreline Moster Program Update
Science Considered for Finfish Aquaculture Policies & Regulations
CITATION
FF.OOl Weston, D. Science Applications International Corporation. December 1986.
Recommended Interim Guidelines for the Management of Salmon Net-Pen Culture in Puget
Sound. WA DeDartment of EcolollV. 54 DD.
FF.OO2 Aquaculture Siting Study. October 1986. Prepared by EDAW Inc. and CH2M/HiII for WA
DeDt. of EcolollV. 104 DD.
FF.OO3 Boyce, J. A. December 1988. WA Department of Ecology: Use Conflicts and Floating
AC!uaculture In Puget Sound. 43 DD.
FF.OO4 Washington Department of Fisheries. January 1990. Final programmatic environmental
impact statement: Fish culture in floating net pens. Prepared by Parametrlx. 161 pp.
[Volume 1 of 31
FF.OOS Washington Department of Fisheries. January 1990. Final programmatic environmental
impact statement: Fish culture In floating net pens - Response to Comments. Prepared by
Parametrix. 529 DD. [Volume 2 of 31
FF.OO6 Washington Department of Fisheries. January 1990. Final programmatic environmental
impact statement: Fish culture In floating net pens - Technical Appendices. Prepared by
Parametrix. 312 DD. [Volume 3 of 31
FF.OO7 Nash, C. E. (editor). 2001. NOAA Technical Memorandum NMFS-NWFSC-49: The net-pen
salmon farming Industry in the Pacific Northwest. U.S. Department of Commerce, National
Oceanic and Atmospheric Administration, National Marine Fisheries Service. 125 pp.
FF.OO8 Waknitz, F.H. et al. 2002. NOAA Technical Memorandum NMF5-NWFSC 53: Review of
Potential Impacts of Atlantic Salmon Culture on Puget Sound Chinook Salmon and Hood
Canal Summer-Run Chum Salmon Evolutionarllv Silmificant Units. 98 DD.
FF.Oog Nash, C.E., P.R. Burbridge, and J.K. Volkman. December 2005. NOAA Technical
Memorandum NMFS-NWFSC-71: Guidelines for Ecological Risk Assessment of Marine Fish
Aquaculture; Prepared at the NOAA Fisheries Service Manchester Research Station
International WorkshoD ADrllll- 14. 2005. 105 DD.
FF.OI0 US DeDartment of Commerce. Aquaculture Policy. Mav 2005. 2 pp.
FF.Oll US Department of Commerce. Aquaculture Policy - Draft for Public Comment. February
2011. 2 DD.
FF.OU National Oceanic and Atmospheric Administration Draft Aquaculture Policy - Draft for
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FF.Oll National Aquaculture Act of 1980. Act of September 26, 1980, Public Law 96-362, 94 Stat.
1198, 16 U.S.C. 2801, et seC!. 16 DD.
FF.014 Goldburg, R. J., M. S. Elliott, R. L. Naylor. 2001. Marine Aquaculture in the United States:
Environmental Impacts and Policy Options. Pew Oceans Commission, Arlington, Virginia. 42
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FF.OIS WA Invasive Species Council. 2008. Invaders at the Gate: invasive Species Strategic Plan.
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Revised 4-20-2011
Page 1 016
CITATION
FF.016 Ladenburg, C. and S. Sturges. May 1999. Potential Offshore Finfish Aquaculture in the State
of Washington; WA Dept. of Natural Resources Technical Report, Aquatic Resources
Division. 67 PP.
FF.017 Environmental Protection Agency: Compliance Guide for the Concentrated Aquatic Animal
Production Point Source Catel!:orv. March 1995. 292 pp.
FF.018 Food and Agriculture Organization of the United Nations (FAO): Code of Conduct for
ResDonslble Fisheries. 1995. 49 DD.
FF.019 Food and Agriculture Organization of the United Nations (FAO): Technical Guidelines for
Responsible Fisheries 5. Aquaculture Development. 1997; Reprinted 2004. 47 pp.
FF.020 Washington State Department of Health; Fish Facts for Healthy Nutrition; Wild vs. Farmed
Salmon IwebDage]. Last UDdated December 2010. 3 pp.
FF.021 WA Department of Fish & Wildlife. April 2008. Aquatic Farm Registration Form. 2 pp.
FF.022 Alvarez, D. 2011. Outline of '86 "Recommended Interim Guidelines for the Management of
Salmon Net Pen (aaual Culture". 7 DD.
FF.023 Amos, K. 2003. Disease Interactions In Wild and Atlantic Salmon [slideshow]; Pacific States
Marine Fisheries Council Conference. 59 DD.
FF.024 Amos, K.H. and Appleby, A. September 1999. Atlantic Salmon in Washington State: A fish
management perspective. Washington Department of Fish and Wildlife. 13 pp.
FF.025 Beamish, R. J., S. Jones, CEo Neville, F. Sweeting, G. Karreman, S. Saksida, and E. Gordon.
2006. Exceptional marine survival of pink salmon that entered the marine environment in
2003 suggests that farmed Atlantic salmon and Pacific salmon can coexist successfully In a
marine ecosystem on the Pacific coast of Canada. ICES Journal of Marine Science, Vol. 63.
PD. 1326 -1337.
FF.026 Beardslee, K. June 2007. Wild Fish Conservancy comment letter to WA Dept. of Ecology re:
Draft Renewal NPDES Permits, American Gold Seafoods Marine Net Pens. 17pp.
FF.027 Benbrook, C.M. February 2002. Antibiotic drug use in U.S. aquaculture. The Institute for
A!!rlcuiture and Trade Policv. 18 DO.
FF.02a Buschmann, A. H., V. A. Rlquelme, M. C. Hernandez-Gonzalez, D. Varela, J. E. Jimenez, L. A.
Henriquez, P. A. Vergara, R. GUlnez, L. Filun. 2006. A review of the Impacts of salmonid
farming on marine coastal ecosystems In the southeast Pacific. ICES Journal of Marine
Science. Vol. 63. PD. 1338 - 1345.
FF.029 Conners, B. M., M. Krkosek, J. Ford, and L. M. Dill. 2010. Coho salmon productivity In
relation to salmon lice from infected prey and salmon farms. Journal of Applied Ecology,
Vol. 47. PP. 1372 -1377.
FF.030 Gardner, J. and D. L. Peterson. January 2003. Making Sense of the Salmon Aquaculture
Debate - Executive Summary; Analysis of issues related to netcage salmon farming and wild
salmon in British Columbia; Pacific Fisheries Resource Conservation Council. 12 pp.
Revised 4-20-2011
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CITATION
FF.031 Gardner, J. and D. L Peterson. January 2003. Making Sense of the Salmon Aquaculture
Debate; Analysis of issues related to netcage salmon farming and wild salmon in British
Columbia' Pacific Fisheries Resource Conservation Council.
FF.032 Icicle Acquisition Subsidiary LLC, DBA American Gold Seafoods. June 2009. Fin Fish
Anuaculture ComDliance Procedures ['WDFW ODerations Permit']. 27 DO.
FF.033 Jefferson County Resolution No. 89-86. Emergency Moratorium on Filing and Processing
Substantial Development Permits for the Growth and Culture of Fish in the Marine Waters
of Jefferson Countv IRsh Farmsl. November 10 1986. 1 D.
FF.034 Kerwin, J. 2003. The Role ofthe Washington Department of Fish and Wildlife in Atlantic
Salmon Management [slideshow]; Pacific States Marine Fisheries Council Conference. 45
IDD.
FF.035 Krkosek, M., A. Morton, J. P. Volpe, and M. A. Lewis. 2009. Sea lice and salmon population
dynamics: effects of exposure time for migratory fish. Proceedings of the Royal Society,
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FF.036 Krkosek, M., J. S. Ford, A. Morton, S. Lele, M.A. Lewis. December 19, 2008. Response to
Comment on "Declining Wild Salmon Populations in Relation to Parasites from Farm
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FF.037 Krkosek, M., J. S. Ford, A. Morton, S. Lele, R.A. Myers, M. A. Lewis. December 14, 2007.
Declining Wild Salmon Populations In Relation to Parasites from Farm Salmon, Science, Vol.
318. Pp. 1772 -1775; Plus Science; Corrections - Erratum, Posted December 19, 2008. Pp. 1
2.
FF.038 Krkosek, M., M. A. Lewis, A. Morton, L. N. Frazer, and J. P. Volpe. October 17,2006.
Eplzootics of wild fish induced by farm fish. PNAS, Vol. 103, No. 42. Pp. 15506 -15510.
FF.039 Krkosek, M., M. A. Lewis, J. P. Volpe, and A. Morton. 2006. Fish Farms and Sea Lice
Infestations of Wild Juvenile Salmon in the Broughton Archipelago - A Rebuttal to Brooks
(2005).Reviews in Fisheries Science, Taylor & Francis Group, Vol. 14. 11 pp.
FF.04O LeVander, L. October 2007. Response to Comments for the 2007 Draft Marine Salmon Net
Pen NPDES Permits for American Gold Seafoods [8 puget Sound locations]. WA Department
of Ecology, Northwest Regional Office, Water Quality Section, Industrial Unit. 103 pp.
FF.041 McCreery, S. July 2002. Whatcom County Marine Resources Committee advisory letter to
Whatcom Countv Council, Natural Resources Committee. 4 DO.
FF.042 Naylor, R., K. Kindar, I. A. Fleming, R. Goldburg, S. Williams, J. Volpe, F. Whoriskey, J. Eagle,
D. Kelso, and M. Mangel. May 2005. Fugitive Salmon: Assessing the Risks of Escaped Fish
from Net-Pen Aquaculture. BioScience, American Institute of Biological Sciences, Vol. 55
No.5. pn. 427-437.
FF.043 Pitts, J. L. 2009. Aquaculture Issues [emall attachment]. 1 p.
FF.044 Pitts, J. L. 2009. Negative Net Pen In SMPlan (4) [email attachment]. 5 Pp.
FF.045 Pitts, J. L. 2009. Negative Net Pen In SMPlan [email attachment]. 4 pp.
FF.046 Pitts, J. L. 2009. Net Pen Historv in WA marine waters [email attachment'. 4 pp.
FF.047 Pitts, J. L. 2009. Stats Myths and Books on Aquaculture [emall attachment]. 1 p.
_4-ZlJ.ZOll
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CITATION
FF.048 Rensel, J. E. 2001. Salmon net pens In Puget Sound: Rules, performance criteria and
monitoring. An overview of Net pen permitting and monitoring in Washington State.
Global Aauaculture Advocate 411\ nn 66 -69.
FF.049 Rensel, J. E. November 2003. Water quality and sediment Impact management of finfish net
pens in Washington State; Pacific States Marine Fisheries Commission Conference
I'slideshowl. 34 DO.
FF.D5D Rensel, J. E., D. A. Kiefer, J. R. M. Forster, D. L. Woodruff, and N. R. Evans. 2007. Offshore
finfish mariculture in the Strait of Juan de Fuca. Bulletin of Fisheries Research and
DeveloDment Allencv No. 19. PD. 113 -129.
FF.DS1 Rensel, J. February 2009. Aquaculture Monitoring, modeling and performance standards for
net pens. Seriola and Cobia Aquaculture Dialogue (SCAD) 19-20 February 2009, Seattle, WA
slideshowl. 63 DO.
FF.OS2 Skagit County Resolutions 14302, 14698 and 15188 - Regarding Extension of [1987] Fish Net
Pen Moratorium. 1992/93. SOD.
FF.OS3 Silverman, H. 2002. Ever Wonder What's Being That Farmed Salmon Steak? Facts and
Footnotes. Ecotrust. 6 PP.
FF.OS4 Susewind, K. Upland Fin-Fish Hatching and Rearing General Permit: A National Pollutant
Discharge Elimination System (NPDES) and State Waste Discharge General Permit for
Discharges Associated with Upland Fin-Fish Hatching and Rearing Activities. WA
Denartment of EcolollV. Water Qualitv Proaram. 40 nn.
FF.D55 Volpe, J. March 21, 2001. Science Friction: the incredible story of Atlantic salmon in BC
Irslideshowl. 4700.
FF.DS6 Volpe, J.P. 2001. Super unnatural: Atlantic salmon in B.C. waters. David Suzuki Foundation.
37pp.
FF.OS7 Volpe, J.P., Anholt, B.R., Glickman, B.W. 2001. Competition among juvenile Atlantic salmon
(Salmo salar) and steelhead (Oncorhynchus mykiss): relevance to invasion potential In
British Columbia. Canadian Journal of Fisheries and Aquatic Science, v. 5S, p. 197-207.
FF.D58 Volpe, J.P., Taylor, E.B, Rimmer, D.W., and Glickman, B.W. June 2000. Evidence of natural
reproduction of aquaculture escaped Atlantic salmon in a coastal British Columbia river.
Conservation BlolollV: vol. 14 no. 3, o. 899903.
FF.OS9 Waknitz. F. W., R. N. Iwamoto, and M. S. Strom. 2003. Interactions of Atlantic Salmon in
the Pacific Northwest. IV. Impacts on the local ecosystems. Fisheries Research 62. Pp. 307-
328
FF.060 Washington Fish Growers Association. Fall 2002. Code of Conduct: Saltwater Salmon Net-
Pen ODerations. S PP.
FF.061 Whatcom County Shoreline Management Program; Title 23. August 8, 200S. 246 pp.
FF.062 Alvarez, D. April 11, 2011. Summary 1990 Final EIS; Finfish - Final Programmatic EIS-Jan.
1990 Table 1 Summarized bv DA. 4 DO.
FF.063 American Gold Seafoods, LLC. January 2010. NPDES Pollution Prevention Plan. 4 pp.
FF.D64 Bright, K. AprilS, 2011. State, Local, and Federal Regulatory Controls for Finfish Net Pen
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FF.067 Icicle Acquisition Subsidiary, LLC, DBA American Gold Seafoods. June 2009. Employee
GuIdance for Routine Handling Procedures to Minimize the Potential for Escapement. 6 pp.
FF.068 Icicle Acquisition Subsidiary, LLC, DBA American Gold Seafoods. June 2009. Fish Escape
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FF.069 Icicle Acquisition Subsidiary, LLC, DBA American Gold Seafoods. June 2009. Fish Escape
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FF.070 Kitsap County Shoreline Master Program - Aquaculture Practices [excerpted]; Code
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FF.071 Marine Aquaculture Task Force. January 2007. Sustainable Marine Aquaculture: Fulfilling
the Promise' Manae:lne: the Risks. 142 DO.
FF.072 MegaKelp [webpage]. 2011. Kelp Farming. 1 p.
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the risk and uncertalntv. Fisheries Research 62. PD. 339 - 347.
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Northwest: A Global Industry with Local Impacts. Environment 45:8. Pp. 18 - 39.
FF.076 Naylor, R., and M. Burke. 2005. Aquaculture and Ocean Resources: Raising Tigers of the
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Revised 4-20-2011.
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Revised 4-20-2011
Page 6 a/6
DRAFT
April 25, 2011
WA State Department of Ecology
Attn: Director's Office
PO Box 47600
Olympia, WA 98S04 - 6700
Also submitted via emall to
Iste461@ecv.wa.aov
SUBJECT:
Status of Pending Submittal - County Response on Required & Recommended Changes
Dear Mr. Sturdevant,
Since we last contacted you In February of this year, we continued efforts to complete our
Comprehensive Shoreline Master Program (SMP) Update. After reviewing the required and
recommended changes included with your January 26 approval letter, we worked with our Department
of Community Development staff to prepare a draft response regarding those changes. We conferred
with your staff on several items for additional gUidance and appreciate the continued support and good
rapport.
As a Board, we found agreement by informal consensus on most of those changes and are confident
you'll accept the anticipated submittal. However the Issue of finfish aquaculture has provided us an
opportunity for more In-depth discussions as we consider our response. Aquaculture plays an Important
role in our community and we would like to understand this issue thoroughly prior to submitting a
response.
We focused the last few weeks on expanding the range of scientific and technical information
considered as we delve into this multi-faceted topic. It has been a challenge given there has been little
state-wide policy or regulatory guidance on finfish and marine net pen operations since the 1980s and
'90s. State agency staff, industry representatives, online academic and peer-review sources, and
Interested citizens have all been providing Information as parts of the puzzle, and stlIllt seems the issue
Is one where strategic collaboration at the state level would prOVide consistent direction to us and the
many other jurisdictions currently engaged In SMP update efforts.
Because we anticipate making changes to the SMP locally approved by Jefferson County Resolution #n-
09, we Intend to aliow further public comment on the specific changes proposed and expect to hold a
public hearing as soon as possible. The additional round of public Involvement will take time to conduct
In a thorough manner. Therefore, we are writing to inform you that we wlIl not be submitting our
response to the Department by April 30, 2011. We will continue our dlIlgent work and deliver our
response as soon as our local process is complete. It Is our intent that even with this extended public
process we will still meet our statutory deadline of December 2011.
As has been true throughout this SMP Update, we will continue to coordinate with your staff for
guidance and to ensure consistency with statutory and administrative rule requirements.
We look forward to continued work with your agency to complete the final review and approval process.
Sincerely.
John Austin, Chair
C.C. Jeffree Stewart, Ecology Project Officer