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HomeMy WebLinkAboutM041513SDistrict No. 1 Commissioner: Phil Johnson District No. 2 Commissioner: David W. Sullivan District No. 3 Commissioner: John Austin County Administrator: Philip Morley Clerk of the Board: Erin Lundgren SPECIAL MEETING MINUTES Week of April 15, 2013 Chairman Austin called the meeting to order at 6:05 p.m. in the Superior Court Courtroom at the Jefferson County Courthouse, 1820 Jefferson Street, Port Townsend, Washington in the presence of Commissioner Phil Johnson and Commissioner David Sullivan. Staff present included County Administrator Philip Morleyk, Associate Planner Michelle McConnell and Planning Manager Stacie Hoskins. HEARING re: Revised response to Washington State Department of Ecology (DOE): In -Water Finfrsh Aquaculture required changes #13 -15, Shoreline Master Program (SMP) update (MLA08 -475): Associate Planner McConnell explained the basis for the hearing and stated that handouts and maps were provided so that everyone can be informed on what is being proposed. She commented that the Washington State Department of Ecology (DOE) has already provided tentative approval of the locally approved Shoreline Master Program (SMP), pending a handful of required and recommended changes. Together with some additional changes that staff identified, there were 63 changes that needed to be made. Of those, the Department of Community Development (DCD) managed to take care of all but 3 changes. These last changes involve finfish aquaculture and the DOE's stance that Jefferson County cannot ban all finfish aquaculture in the area. Associate Planner McConnell stated that staff has been working toward a provision that would allow this use and ensure adequate protection of resources. Their solution is to include geographic limitations along with specific performance standards that would be part of a conditional use permit process. Chairman Austin opened the hearing for public testimony. Michael Felber, Port Townsend: Submitted and reviewed his written testimony. (See permanent record). Tom Jay, Chimacum: Stated he is one of the hundreds of Jefferson County residents who are working to restore the salmon population, and stated they have been successful. Due to their efforts, they were able to bring Wild Summer Chum back to Chimacum Creek and enhanced the run in Salmon Creek to the point where both runs are self sustained again. They have also built habitat for Coho Salmon here in Jefferson County. Mr. Jay stated over 20,000 hours have been spent by those working in our County to restore the salmon population. He is against net pens for the same reason the previous speaker mentioned. In the long run, he stated that the fish pens were non - sustainable because they depend on fossil fuels and they depend on mining resources in the aquatic environment that we cannot afford to mine such as krill. Mr. Jay commented that in order to avoid dyeing their fish, fish pen farmers have been feeding their fish krill to give them a more sea -like taste and color. He believes the health of the environment is at stake. Salmon are the keynote species of the ecosystem here. If the salmon perish, the forest will perish because the salmon feed the forest. The whole ecosystem is designed around the return of this great nutrient resource. Mr. Jay stated to live within our means, we should live off our wild fish and have a terminal area fishery that we can productively harness, but not use net pens. Page 1 Commissioners Meeting Minutes of April 15, 2013 Diane Jones, Port Townsend: Stated she is against any fish net pens in Jefferson County and read aloud the highlights from her submitted written testimony. (See permanent record). Ms. Jones provided a letter from the Beckett Point Fisherman's Club. (See permanent record) David Woodruff, Port Townsend: Submitted and reviewed his written testimony. (See permanent record) Mr. Woodruff stated he watched a documentary called "Salmon Confidential" and strongly urged everyone to watch it as well. Jerry Johnson, Secretary of the Local Chapter of the Puget Sound Anglers (PSA): Stated that the PSA is communicating with the Department of Fish and Wildlife (DFW) Commissioners and staff. He explained that recreational fishing generates several billions of dollars for this state's economy. Washington has spent hundreds of millions in taxpayer dollars to protect and bring back the wild stock. Local tribes have recently sued the State of Washington Department of Natural Resources (DNR) for not correcting culverts that were incorrectly put in, preventing salmon from reaching estuaries to spawn. Mr. Johnson also mentioned he saw the video "Salmon Confidential" by Alexandra Morton. He visited the north end of Vancouver Island, British Columbia and witnessed firsthand net pen farming and talked to the divers who work the net pens every day. Mr. Johnson stated that Ms. Morton proved that as wild young smelt swim by the net pens, they are inundated with sea lice and their mortality rate increases. We cannot outlaw the net pens in Jefferson County, but the placement of the net pens is critical to keep them away from the migration routes of the smelts. These are smelts that come out of hatcheries that are under - funded, but smelts are also coming from natural rivers too. Mr. Johnson thanked the Board for taking his statement into consideration. O'Neill D. Louchard, Port Townsend: Is in agreement with previous public comments. She pointed out SNIP Article 9.6.B.5 which states "the public interest suffers no substantial detrimental effect." She believes there will be a very substantial effect on the health and well being of the ecosystem and people, by having less nutritional fish to eat. Ms. Louchard stated that the most damaging aspect of feed lots is the destruction of the natural communities and the collapse of the markets for them. This is one of the things that happen when people do not buy the wild fish. The new fish become proprietary and owned by a corporation and thus, dominate the market. She elaborated that when our food is owned, rather than being a public common where fisherman can go out and fish, this is a very dangerous direction to go in. She commented that we have already seen what happens when food is being owned by a corporate entity. Ms. Jones previously submitted her written testimony. (See permanent record) Al Latham, Chimacum: Is in agreement with previous public comments. He started off by thanking the Commissioners and other County staff for their efforts to counter the DOE mandate to allow saltwater net pens, under the SMP. Mr. Latham opposes the selection of the locations of the proposed net pen areas, as they're right in the migration quarters for the young salmon. He commented that it was ironic that DOE pushed for more extensive land use, water use and agricultural controls in the name of salmon and water quality, but on the other hand, is requiring the County to allow saltwater net pens that pose a threat to the salmon stocks they've worked so hard to protect. He also stated that millions of Federal, State and County taxpayer dollars and thousands of volunteer hours have been spent to protect and improve salmon habitat in the Chimacum Creek Watershed. The Endangered Species Act (ESA) reported that the Summer Chum salmon that have been reintroduced into Chimacum Creek are thriving. The whole stock of Summer Chum in the Hood Canal and in the Straits are well on their way to recovery and de- listing from the ESA. Mr. Latham added that net pens in Port Townsend Bay could Page 2 Commissioners Meeting Minutes of April 15, 2013 potentially have a very negative effect on the Chum, especially when it comes to out - migrating juvenile salmon. He stated that one site on Glen Cove is where salmon would travel as it is right up the way from Chimacum Creek. This could set back the timeline from de- listing the species from the ESA. He added that the DOE hammers farmers based on the potential to pollute, but is pressing the County to allow net pens that will have concentrated amounts of excess feed and salmon waste in the salmon migration path; creating a condition to potentially pollute. Mr. Latham believes the DOE should praise the County for trying to keep net pens out of our saltwater environment instead of forcing us to allow it. He stated that hopefully DOE will respect what the County has come up with and accept it, and allow the SMP process to conclude. He thanked the County again for standing tall on this issue. Doug Millholland. Port Townsend: Began by saying that his people have been catching salmon in these waters for five generations. He is upset that the County is being forced to take on this situation. He talked about the film that other public commentators have mentioned. It is shocking to him that the major runs on the Fraser River are collapsing because of the exposure of native stocks to the distribution of illnesses that are endemic to the net pens. The film talked about how it was impossible for the people who are bird dogging the approved process to access the data around morbidity on the fish pens. He believes that at the very least, the local public should have access to morbidity data and that it should be included in the SMP. Mr. Millholland explained that the arrival of the diseases in Canada have been hidden. He stated that the process of corporate domination of the various levels of government is so advanced, that it comes down to the independent and meritocratic power of local regulators and observers to honestly present what they are finding. He believes that when that begins to get crushed, by the power of multinational organizations, all of us are in tremendous trouble, as the salmon documentary film describes. Mr. Milholland believes with other previous commentators, that the protection of migratory paths has got to be critical. The specific distances mapped out in the SMP are inadequate. He has talked with local fisherman who have found Fraser River schools as they fish North of the Fraser where the water meets at the Salish Sea. He stated that the fish from the Fraser River appear to be quite ill. If that's the future for this area, he believes that it would be a tremendous blunder to allow it. Mr. Milholland urged the County to take a stand against fish pens and consider saying 'no' to the DOE, even if it means going to jail. He added that Brent Shirley stood his ground years ago when the sewer plant was being proposed and stated he wouldn't do it. George Yount, Port Townsend: Stated he is speaking on behalf of the Jefferson County Democrats who have adopted a resolution opposing the Atlantic salmon net pen operations in Jefferson County's waters. He submitted and reviewed his written testimony. (See permanent record). Ernest Sauerland, Port Townsend: Is in agreement with the previous public comments. He read the mission statement and goals of the of the DOE: "The Mission of the Department of Ecology is to protect, preserve and enhance Washington's environment and promote the wise management of our air, land and water for the benefit of current and future generations. " The DOE goals are: "Prevent pollution, clean up pollution, support sustainable communities and natural resources. " Mr. Sauerland stated that he has been to DOE meetings where they advise that they are creating jobs. He wants to know how the DOE has the authority to tell a community that is strictly against net pens, to make them have them. Does it have to go clear to the Governor? He believes the DOE is not following their mission statement. There are other methods of farming fish. In Massachusetts, they fish farm upland and it's very economical and it works. He stated that his septic system has to work better than the proposed fish pens do and that it is ridiculous. He believes there should be a way to see how the DOE has the power to make their decisions. Page 3 Commissioners Meeting Minutes of April 15, 2013 June Sinclair, Port Ludlow: Submitted and reviewed her written testimony. (See permanent record) Doug Campbell, Port Townsend: Opposes fish farms. He stated he lived in Kitsap County for 22 years. He remembers when there was a foreign -owned fish farm constructed at Manchester and South Kitsap County. He advised that one year the net pens were partially destroyed during a storm and thousands of farm fish escaped into Puget Sound. He also mentioned that he sailed up to parts of Vancouver Island where he experienced the smell of the fish farms, and that they stink. He stated he can smell a fish farm from three miles away. He believes that if there were to be a fish farm set up in the bay, foreign owned or American owned, when the wind is blowing right it will have a negative effect on tourism. Mr. Campbell thanked the Commissioners for their support. Linda Sutton. Port Townsend: Agrees with previous comments made by the public. She pointed out that this particular hearing was so different compared to the one she saw in Olympia regarding the same topic. She stated that in Olympia's hearing, massive amounts of people in the fish farm industry were pushing their thoughts and the general public was limited to two minutes a person. She stated she previously submitted her written testimony. (See permanent record) Ms. Sutton asked that the Commissioners exercise extreme precaution during this phase of the process. She noted that it should be added to the SMP the requirement of pen operators to conduct regular testing of the fish for certain viruses and the testing of toxic substances that are being used in the fish feed. She believes that British Columbia is covering up their findings regarding fish diseases. Ms. Sutton suggested that the testing for these diseases should be paid for by the fish farming operators to the State of Washington. She added that an independent laboratory should do the testing and make the results readily available to the public. Ms. Sutton mentioned that in Scotland and Norway they are using pesticides to successfully prevent sea lice from forming shells on fish and crabs. Gene Farr: Addressed the concern for net pens in regards to safety and health, but stated that civilization has been farming various animals and crops for years without a problem. He stated that the USDA, FDA, local Health Departments, EPA and DOE are all agencies that assure the environment isn't harmed as we do these things. He referenced a previous email he sent. Mr. Farr advised that back in 2000, the UN stated that about 25% of the fish eaten during those years were farmed fish. That number is now up to around 50 %. He wants to see accommodations made for this very important crop that's necessary for the world's food supply. He pointed out the need to do this smartly, with appropriate zoning and regulations. Mr. Farr commented on two benefits to fish pen farming; by farming the fish, we are not decimating the natural fisheries and the new industry in this area would provide much needed jobs. He wants everyone to consider the benefits of fish pen farming in a safe and healthy manner. Mike Regan, Port Hadlock: Started off by addressing some of Mr. Farr's statements regarding fanning not causing harmful effects. Mr. Regan believes that is not true. Corporate farms are poisoning us in many ways as do fish farms. He also commented on Mr. Farr's statement regarding new jobs being brought to the area. He believes that while some jobs may be created by fish pen farming, the harm to our native salmon will take away a lot of jobs. We already have jobs here in fishing and fish marketing he mentioned. Mr. Regan stated the amounts of possible jobs is negligible compared to the dangers and harmful effects fish pens may cause. He asked a question regarding the SMP marked `Policies' Article 2.13. He wants to strike out the section on mitigation asking "How can you mitigate the use of chemicals; etc, after the salmon have already been depleted ?" Mr. Regan would also like to take out the verbiage `known to be harmful' from that section of the SMP stating: if they are known to be harmful, they Page 4 Commissioners Meeting Minutes of April 15, 2013 should not be used at all. He doesn't believe the Commissioners will be thrown in jail for standing up for the rights of the community. He mentioned the Pit to Pier issue and the County is paying for standing up to the State for protecting the rights of the community and the environment. He urged the Board to pass a very strict measure that will end up, in effect, not allowing the use of fish pens. Gordon King, Port Townsend: He is in support of the SMP and stated it is long overdue. He explained that the long process of the SMP has led to the loss of ecological function with development along the shoreline. He stated there was inaccurate comments regarding the net pen industry. Mr. King addressed one such comment regarding the depletion of salmon in the Northwest was due to net pens. He said that there aren't many net pens in Oregon and California, yet they have major problems with salmon stocks. In reference to a comment previously made regarding the Fraser River run, Mr. King noted that in 2010 they had the largest return of fish to the Fraser River since 1913. He believes the salmon pen industry is very well regulated, particularly in the United States. He noted that wild fish in Puget Sound have more PCB's and dioxins than farmed fish due to fish farmers having the ability to choose where to get their fish feed from, and wild fish do not. Mr. King commented that the waters in the Puget Sound are polluted with PCB's and other negative chemicals in the water column. He indicated that a previous commentator spoke about IHN and ISA as being fish diseases. Mr. King elaborated that IHN is an endemic disease, it is not introduced by salmon and that ISA has never been properly identified in the Northwest. There has been some PCR traces which could be around he said, but it has not been demonstrated as being introduced by salmon net pens. He believes that if the SMP passed, which he would like to see, he would be extremely surprised if net pens ended up in Jefferson County, particularly because the community does not like or want them. Sidney Collins, Port Townsend: He believes those that propose net pen farms don't care about the community; fisher people, boaters, waters, ecology, tourist or any of our residents. He stated that the DOE is not our friend and acting more like the Department of Commerce. Mr. Collins elaborated that the DOE is a lap dog, not a watch dog. This is a repeating pattern in our states and our whole nation. He mentioned that when we regulate something, we are accepting it, and that is not acceptable. Regarding a previous comment made by someone who noted the smell of net pens, he expressed that net pens are a lot like filthy pig pens. Aqua feed lots are filthy, toxic and dangerous to our water and our salmon. Mr. Collins pointed out that in Pennsylvania, Republicans were against pig feed lots and initiated a Jurisdictional Dispute, challenging the State and Federal Governments, and most of them won. He added that we have a right to our sovereignty and a right to defend ourselves against bureaucracies that come down here and don't care about us. He would like to see the DOE be more like a Department of Ecology, and in his opinion, they are not. Mr. Collins stated that he would help break out the Commissioners if they went to jail for standing up against fish pens. He mentioned that when you have a septic tank, there has to be a drain field. He believes net pen farming in our area would cause our waters to be like a septic drain field for the pens. He wants to see pen fanners have insurance for any and all harm they might do to our salmon and our waters or anything here. If they have to insure, it is dangerous, impractical, toxic and harmful, Mr. Collins believes they won't do it. Joan Quackenbush, Port Townsend: Submitted and reviewed her written testimony. (See permanent record) Joel Kawahara, Quilcene: Submitted and reviewed his written testimony. (See permanent record) Page 5 Commissioners Meeting Minutes of April 15, 2013 Lorna Smith, Port Townsend: Is appalled by the position of the DOE and that DOE is forcing Jefferson County into this position. She stated that County staff is aware of her efforts on the State Environmental Policy Act and the SNIP for many years in a professional capacity. She emphasized that those laws are meant to protect our natural environment. She added that she has read enough about net pens to know that there are no ways to mitigate the impacts. Ms. Smith believes it is like a game when it comes to having conditional permits and that impacts can be mitigated. She believes you cannot mitigate impacts of net pens and the reason is that they are not self contained. Water flows in and out of them and the pathogens and the pollution flow in and out with them as well. She stated the British Columbia fisheries have been affected by the net pens. She commented on the film that was previously mentioned by other commentators pointing out Alexandra Morton's research. Ms. Smith mentioned that in 1990 the Sockeye run on the Fraser River was one of the biggest fish runs on the west coast. There was a nosedive decline coincidental to the establishment of fish pens in the nearby vicinity. She referenced Alexandra Morton's study that claimed there were a lot of fish entering those waters, but they died before they spawned. The study also stated these fish died of fish born Leukemia. Ms. Smith reiterated that you cannot mitigate for these kind of effects or necessarily know to head them off. She urged the Commissioners to go back to Olympia and meet with the Governor and the DOE and tell them they tried but the community won't accept it and we need to try another option. Darrell Smith. Port Townsend: He wanted to thank the Commissioners and the Jefferson County Administration for their efforts to mitigate a bad decision from DOE. He said it was similar to keeping unstable dynamite in your house. He stated he was a graduate student of Washington State University in the 1970's working in the fisheries and wildlife programs. Mr. Smith mentioned that back then, those programs had a strong interest in food science. There was worry about what may happen because they knew that organisms were a moving target that grew and evolved. He is concerned about the security of net pens and pointed out the power of the winds in this area during the winter months. While Mr. Smith was a graduate student, he worked on producing gear that would hold fish, just to have it blow up and broken down by flows and by unforeseen circumstances. He is concerned for the integrity of our natural fish and resources. He mentioned the hard work of those in the community who have been trying to fix mistakes from the past and work on damaged fish runs. Mr. Smith stated mitigation was very difficult and that most people working in wildlife and fisheries programs would believe that you cannot mitigate after a loss. It takes years. He brought up a previous comment made regarding farming and added that we have been farming for 20,000 years, but when it comes to fish pen farming, we have a very long way to go. He added that fish is a very delicate resource and it needs to be protected. Peter Guerrero, Port Townsend: Thanked the Commissioners for their efforts. He believes the risk to the salmon population is too great to allow for commercial enterprises to endanger these iconic species. The economic value of our native salmon populations far outweigh the economic benefits that would be derived from commercial operations. Mr. Guerrero submitted and reviewed his written testimony. (See permanent record) Sally Schumaker, Port Townsend: She stated she is a citizen watchdog and came to the hearing, not knowing much about the subject. She said she was quite impressed with the quality of the testimonies that were heard. She was informed that with DOE's requirements, it appeared there was not much hope regarding net pens. Ms. Schumaker admires those that came and spoke and it gives her hope that maybe the Commissioners could go to the State and say no. She mentioned she was just at the hearing as an observer and was very impressed. She reiterated that she hoped the Commissioners would have the courage to say no to DOE. Page 6 Commissioners Meeting Minutes of April 15, 2013 X Hearing no further testimony, the public hearing was closed. NOTICE OFADJOURNMENT: Chairman Austin moved to adjourn the meeting at 7:20 p.m. until the next regular meeting or special meeting as properly noticed. 1 SEAL:. tti o; ATTEST: f I C,7- _ Licht✓ ttiLdr.Q-J Erin Lundgren Clerk of the Board JEFFERSON COUNTY BOARD COMMISSIONERS Jo Austin, Chair Phil Johnson, Member David Sullivan, Member Page 7 U \1�\ 0 FIR U . yc u 7 i 16 HEARING RECORD r? JEFFERSON COUNTY GUEST LIST TITLE: Hearing re: Revised Response to Washington State Department of Ecology: In -Water Finfish Aquaculture Required Changes #13 -15; Shoreline Master Program (SMP) Update MLA08 -475 DATE and TIME: Monday, April 15, 2013 at 6:00 p.m. PLACE: Superior Court Courtroom, Jefferson County Courthouse NAME (Please Print) S STREET ADDRESS C CITY T Testimony? Of0,4EL �' Ojc7� P P T: D D'❑ ❑ 0 — C C�7' ❑ ❑ tone o 5 F FrT C Cam]' ❑ ❑ T ❑ ❑ ❑ C�' &;Q h Ao e- ❑ ❑N 1A El �E P� c#.v 5 CV4 ! !� L L❑ ❑ ❑ ❑ Cie %c( 17, 1�1�3 Z- V C V V V v v l��x JEFFERSON COUNTY GUEST LIST TITLE: Hearing re: Revised Response to Washington State Department of Ecology: In -Water Finfish Aquaculture Required Changes #13 -15; Shoreline Master Program (SMP) Update MLA08 -475 DATE and TIME: Monday, April 15, 2013 at 6:00 p.m. PLACE: Superior Court Courtroom, Jefferson County Courthouse NAME (Please Print) STREET ADDRESS Not Re uired CITY Not Required) Testimony? YES NO MAYBE /�¢�h[ v rry / El El j ❑ ❑ 2 ❑ ❑ Er V 1 2�O ❑ ❑ ❑ l- E ❑ ❑ ,j Zi,,S4 r E3- ❑ ❑ 3 LA r at. ❑ ❑ �v r�� 5�,,,. �`f� m�v Dr Cam❑ ❑ 141 #jh 1 ❑ ❑ R ❑❑❑ ❑❑❑ ❑ El ❑ El ❑ El El ❑❑❑ ❑❑❑ ❑❑❑ ❑❑❑ YV k JJ \,R. JEFFERSON COUNTY GUEST LIST TITLE: Hearing re: Revised Response to Washington State Department of Ecology: In -Water Finfish Aquaculture Required Changes #13 -15; Shoreline Master Program (SMP) Update MLA08 -475 DATE and TIME: Monday, April 15, 2013 at 6:00 p.m. PLACE: Superior Court Courtroom, Jefferson County Courthouse NAME (Please Print) STREET ADDRESS Not Required) CITY Not Re uired Testimony? YES No MAYBE <� ❑ ❑ ❑ ❑ ❑ 0 0 0 ❑ 1111 0 0 0 ❑ 1111 ❑ ❑ ❑ 0 0 0 ❑ ❑ ❑ ❑ ❑ ❑ 1100 0 0 0 ❑ ❑ ❑ ❑ 1111 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ 11 ❑ ❑ c 3 R JEFFERSON COUNTY GUEST LIST TITLE: Hearing re: Revised Response to Washington State Department of Ecology: In -Water Finfish Aquaculture Required Changes #13 -15; Shoreline Master Program (SMP) Update MLA08 -475 DATE and TIME: Monday. April 15, 2013 at 6:00 p.m. PLACE: Superior Court Courtroom, Jefferson County Courthouse NAME (Please Print) STREET ADDRESS Not Required) CITY Not Re uired Testimony? YES No MAYBE S L �uMak O ck� o �e , ej; (er o ; r� S zs� P �'o� 7oz ❑ ❑ ❑ ❑ ❑ l ❑ 1111❑ 1111❑ 1111❑ ❑ 1111 1 1 1 1 ❑ 1100 1111❑ 1111❑ ❑ 1111 1111❑ ❑❑❑ ❑❑❑ 11 11 ❑ 111111 1:11:10 ❑❑❑ PNI ;Yt Finfish aquaculture provisions My preference is that we don't allow any in water finfish aquaculture to locate in the county. I would like the county to continue to work with other counties and legislators to outlaw fish farms all together. Meanwhile until that happens I'd like to add a few extra conditions on fish farms that may attempt to locate here. 1.) Finfish net pens put in the water have a documented history of spreading pollutants containing antibiotics, other chemicals, dioxins, lice infestations, ISA, salmon alphavirus, piscine reovirus, etc.. They should fall under the federal pollution control act of 1972. NMF should be consulted for a biological opinion in relation to the Endangered Species Act for effects of these pollutants on listed salmon and steelhead whenever a finfish netpen is proposed for any location. If other finfish other than salmon are proposed for in water aquaculture net pens we would have to consider a host of other viruses endemic to those species as well. 2.) Where as double hulled oil tankers are required for better containing oil and since farmed atlantic salmon escape on a regular basis and present a threat to wild salmon then net pens should also be double walled. 3.) If a fish farm site is abandoned, the site should be restored to it's original pristine condition within a specified time. 4.) Night lighting should be night sky saver type to avoid light pollution Diane Jones P.O. Box 1938 Port Townsend, WA 360- 379 -9193 11� N lP I �Q�j April 15, 2013 TO: Jefferson County Commissioners HEARK }� Re: SMP - Comment Period on Draft Finfish Aquaculture Provisions The Board of Trustees, on behalf of the 156 members of the Beckett Point community, wishes to express concerns about locating any in -water finfish aquaculture in Jefferson County waters. We would like to reiterate our position, as stated in a letter of July 25, 2011, supporting the need for plant aquaculture. However, we do not support In -water finfish aquaculture. Realizing the potential problems associated with concentrated sources of antibiotics, processed feed, fish waste and non - native species, it is imperative our waters be protected. We are very concerned about water quality and the effect finfish farms could have on native Pacific salmon. We further request that finfish aquaculture be returned to "Uses and Activities Prohibited Outright" instead of "Requires Conditional Use Approvar until more is known. In conclusion, we support an outright ban on finfish aquaculture until these concerns are sufficiently addressed. Signed, K Ca�- President Dick Cable Beckett Point Board of Trustees dedicated to the propogatum, protection, anti enjgyment of our salmon resources for over 50 _years. Post Office Box 1657 Port Townsend, Washington 98368 HYtlyy,�� R, iN (( M DAve Woodruff From: "Dave Woodruff' <dwoodruff @cablespeed.com> Date: Monday, April 08, 2013 8:42 PM To: <jeffbocc @co.jefferson.wa.us> Cc: "Leader News" <news @PTLeader.com> Subject: Fish pens Honorable Jefferson County Commissioners: I am presenting this letter as written testimony for the 6 p.m public hearing of April 15, 2013 at the courthouse pertaining to the SMP and salmon net pens in Jefferson County. Please enter it into the official record. Thanks for your efforts in the matter of preventing salmon feed lot pens in Jefferson County marine waters. I fully understand the box into which the DOE has put you and your constituents. I understand your need to, for at least the time being, resolve the issue carefully with a conditional use permit system. I also continue to object to the net pens ever being placed in our county's waters. In spite of the reluctance of the DOE to appropriately consider the science, listen to public opinion or foresee the dangers to the large and important industry based on our native salmon, I am asking you to continue to work with our supportive legislative delegation, your commissioner colleagues statewide, and your concerned constituents to continue efforts to get a bill passed which would put the matter in the hands of the policy makers, and thusly the voters, in the counties where such pens are in future proposed or currently exist. Also, and very importantly, please be aware of the industry's next move. International interests have developed a genetically modified "super fish" version of Atlantic salmon which has been proposed for market. It will grow much faster and many times larger than currently used stock. These fish are intended to provide a market ready "crop" much quicker than currently possible. Many believe that these GMO fish, untested in the pens, will be a natural disaster waiting to happen. In my opinion they represent just one of many reasons for a "local option" in siting pens. Thank you. Dave Woodruff Port Townsend 98369 cc: The Leader w /request hereby for publication as a Letter to the Editor 4/12/2013 April 15, 2013 Jefferson County Board of Commissioners Dear Commissioners: Please add the attached documents to my testimony previously submitted for today's public hearing. Thank you. David E. Woodruff 1633 Water Street #8 Port Townsend WA 98368 Editor, The Leader Jefferson County is again targeted by fish farms! We have fought for a quarter century to keep them out of county marine waters. We had a longstanding moratorium against them, except for juvenile native salmon release pens for enhancement of sport and commercial fishing. Our Board of County Commissioners has proposed Shoreline Management Program language which would prohibit the fish feedlot farms, but the Department of Ecology wants changes which would permit them in spite of the fact that DOE recently approved Whatcom County's SNIP prohibiting them. We are spending hundreds of millions in federal and state funds to clean up Puget Sound, remove dams and generally improve, restore and protect habitat for our native salmon resource. That makes sense. But the farming of salmon, native or otherwise, is totally counterintuitive! The pens pollute, spread parasites which have extinguished native runs elsewhere, are subject to disease, stimulate algal suffocation in the pens and elsewhere and create bottom dead zones at their sites. They damage ecosystems elsewhere by overfishing foreign stocks to feed salmon and create a huge carbon footprint when harvesting and transporting the feed. The offspring of escaped Atlantics, which return to spawn multiple times, compete for habitat in native salmon bearing rivers. And, unless they're fed food containing questionable dyes and drugs, the meat of farmed salmon looks like the newsprint of this newspaper! The threat of grow -out salmon pens in Jefferson County represents an ethical, environmental and esthetic disaster for our future. They contribute little to the local economy and represent an unpredictable long term threat. Commercial, tribal and sports fishers, environmentalists, folks who want healthy, natural food sources and other interested parties should participate in BOCC written or oral public comment. Watch for announcements. Call, e -mail, write letters and show up to speak to the BOCC. Urge that the BOCC stands firm against fish pens. Dave Woodruff Port Townsend Editor, The Leader Port Townsend 10/12/12 The headline, "Net pen experts: industry unlikely here ", Leader, A 6, 10/10/12 is misleading. Would the industry expend time and money to come soft soap us if that was really true? I witnessed the industry suggest that wild fish are responsible for outbreaks of disease in farm pens. Like any organism, wild fish may naturally host endemic disease vectors to which they are immune and which may transfer to farmed fish. However, a reason diseases become epidemic is because farmed fish are from non- native stocks never intended to breed or develop natural immunities. When packed by the thousands in an unnatural environment, farmed fish can easily sicken and, as a huge reservoir of infection which can spread to other farmed or wild fish, must be destroyed. Destroying a crop of farmed fish is costly to the investors. But, what would be the cost of lost runs of native fish? We must continue efforts to convince the director of ecology, via legislation or governor's directive, that net pen farming should be banned from our public waters. Dave Woodruff 1633 Water #8 Port Townsend 360 - 437 -9138 Please confirm receipt. Thanks! PUBLIC SERVICE NOTICE: RE: SALMON NET PENS For over 20 years I have fought fish pens in Washington and B.C. waters via such groups as the Oak Bay Coalition here and the Marine Environmental Consortium regionally. As with most of us, I am grieved that the DOE director now has Jefferson County bound with a gun to our head.. But we are NOT gagged! Read the article and comments below and then consider contacting the governor and our legislators demanding the DOE director be required to stop this nonsense now! Americans have spent millions to restore and protect our waters for native fish, not for the profit of foreign investors! NO SALMON NET PENS IN JEFFERSON COUNTY!!! Dave Woodruff Public service paid for by Dave and Jeanette Woodruff, Port Townsend WA t For over 20 year. I have fought imb pen. in Wuhington and B.C. water, via inch group. as the Oak Bay Corinne here and the Marine Environmental Consortium regicmlly. As with most of o,, I am pieced that the DOE director now has Jeff o0 County boundwith a gun to om head. But we are NOT gagged! Ameticao. have spent mitico, to restore and protect our water, for manic fish, not for die profit of foreign imm.tom! NO SALMON NET FENS IN JEFFERSON COUWIYM -Uene Hbodfiy' on pagee aracfetided,ober penc�ern:tndahe Lio Bkc sort to wen belctished on page A6 of the October 10, 2012 issue of the Leads, and mmmron below, and then consider moracting the governor srd our legidatom demanding the DOE director be required to stop thu nonsense cowl. Comments posted to the same article on ptleedeccom on October 12, 2072 "Response to Hugh Mitchell's comments in the PT-eader, 10.12.12 Several of the statements vdmd by Hugh Mitchel in this piece concerning open water net pen salmon farming are inaccurate and ignore the scientific literature. While it is true that 'Every disease comes from the wild; it is not true that every disease is found at all locations world -wide. The intmduction of exotic pathogens can haw; disastrous af- fects on local, native populations, as was seen with the introduction of whiting disease (caused by the parasite Myxobdus cembralis) from Europe into front populations in the U.S. Now that Infectious Salmon Anemia vhus QSAVJ has been rejected to B.C,, we should be very concerned that this virus will move into WA state waters, as saloon mi- gration pathways lead salmon originating from Puget Sound along the coast of &C. an route to Alaska before they return to spawn. Statements of assurance that ISA is not in WA are indefensible, because without testing of hatchery, net pen, and wild storks, we have no way of knowing - and thus we should not be complacent. At present no federal in state agencies are testing for ISA in salmon from Washington waters. The assertion that wild stacks are the source of infection for net pen fish is also prob- lematic. While it is true that some local yrums, like infectious hemaopoielic necrosis virus (1HNV), whch caused major ]cases to the Pacific Northwest salmon statements industry in 2012, did originate in wild fish, open water net pons can amply the number of these pathogens far above what would occur naturally. The high densifies found in fish farms can lead W the shedding of huge amounts of pathogens into the seawater flowing through the pens, which can in Mn infect local fish, padiculadyjuvenBe salmon, during their ourenigration. I would be very interested in seeing the data that Mitchell based this statement upon:'The dissolution is tremendousjust a couple of meters from the pen the Wus partides were down tremendously' Another, perhaps even more serious issue, is that the conditions found in seawater net pen facdifies (crowding, stress, presence of multiple pathogens, frequent introduction of native hosts, and lack of selection for resistance due to all animals being harvested, rather than breeding those that are resistant) act mraclucive to the emergence of new, highly pathogenic viral strains that would not arise in a natural setting. Peer - reviewed, published research has documem ed this effect for ISAV (Nylund et ai. 2009 Christian- sen at al. 2011 Nylund et al. 2007), viral hemorrhagic septicemia virus (VHSVI (Eiher- Jersen 2004), and IHNV (Troyer and Kurath 2003). Finally, Mitchell's comment about no lice completely misses the point. 'He added that greater salinity in the region's ocean might decrease the risk of lice Inflections and that having some sea lice wasn't that dangerous. 'One or two doesn't matter. That used to be a sign of a fresh fish, when you had one or two sea ice on it,' Mitchel said. First, our'regionai ocean' does not have higher calories than those found !n B.C. Second, one or two sea lice on an adult salmon is not a big desk the problem is that open water net pens shed large quantities of sea lice onto juvenile sermon, which can impede their swimming strength and increase modality, as has been shown in the scientific litera- ture. And, as he corlecty states, an fine have been shown to be a vepipn for the trans- mission of several of the viral diseases mentioned above, which can increase disease transmission to native stacks.° Todd Sandell, MS., Ph.D. Disease Ecologist Wild Fish Conservancy 'Jefferson County Commissioners are right on with their concerns regarding the open pen salmon feedlot dus".. That concerns and marry others have been experienced whenever and wherever in the world open pan salmon feedlots are sited. Wild Pacific salmon, their ecosystems: satin dependent cctures and economies can if afford the known and unknown negative impacts of open pen salmon feedlots." James Wdoox "The fish farms may get diseases from wild fish, but they amplify than and keep them around so they can then intent the baby salmon. The life cycle of a salmon keeps this from happening in the wild with the adult salmon dying and taking the diseases with them before the new salmon are born. Fish farms keep the disease cyde gang. They aiw have been moving viruses around the planet and helping them mutate into much stronger forms, as with ISA virus, which came from Norway and has been found in Canada. A non -lethal form of ISA virus existed in the wild in Norway but was not a problem until salmon farms came on the scene and brought the perfect habitat (way M many of the same species in too tight a space) for it to mutate into a lethal form. Any biology student knows the problems associated with disease when you pack too many of the same species together like that, but Ecology and NOAA have forgotten biology in their quest to turn over our waters to corporations. Farmed salmon are a commodity. They are owned by the corporation that puts its farm in our waters. We pay the cost of their pollution and their harm of our environment. We wig lose all of the work and money that has been Wt into restoring wild salmon if we let salmon tarns in. Those farms don't provide as many jabs as they take away wind the decimation of the wild salmon runs. Look at what has happened to the communities around the salmon farms in Canada. Their wild runs are disappearing and their government actually fried to put a law on the books that would prosecute anyone who made disease outbreaks publd Ecology is trying to force the acceptance of salmon farms dove ourtlroats and I thank our County Commissioners for fighting valiantly to keep than from doing it We need to all step up to the plate and write to our representatives to put a moratorium on salmon farms in this State." Scott Marcot ondJoniaru Wood.Nj, Pit Tbvmmud, W9 PDN Editor Re: (PDN, pg A -1, October 10, 2012.) Fish pens are NOT funny, Mr Rust! The general consensus around Jefferson County is that they are anathema. Why? Fish pens are unnatural environments which raise non - native fish in unnatural ways using unnatural feed while adding unnatural coloring to an unnatural product. Concentrated diseases spread from fish pens endanger native runs and the wild caught fishing industry which creates many more sustainable jobs than the pens. Juvenile Atlantics, bred from escapees, have been found in nearby B.C. rivers. They represent unnatural competition for natives' nesting redds. International financiers profit at the expense of our marine environment. We have spent millions to protect and preserve our waters for native fish, not for the benefit of foreign investors. The negatives of the fish pen industry far outweigh any possible advantage. We Jefferson County folks believe in protecting our waters and our fish. The DOE is on the wrong track. Contact the governor and our legislators now. Dave Woodruff Port Townsend 1- 360- 437 -9138 To: Jefferson County Board of County Commissioners Dear Commissioners, The below letter to the editor which appeared in the March 23, 2011 edition of the Port Townsend and Jefferson County Leader newspaper is herewith submitted as my comment and testimony related to the announced July 11, 2011 public hearing pertaining to the matter of permitting net pens fish farms in any waters of Jefferson County. I request that this complete communication, including the cited letter, be made part of the body of spoken and written comments submitted to the Washington State Department of Ecology by the County as the public record of the hearing. My stance on March 23, 2011 was, and remains now, that net pen fish farms established to grow out mature non - native or native fish, particularly salmonids, for market purposes be permanently excluded from any waters of Jefferson County. Thank you. Sincerely, David E. Woodruff 1633 Water Street, Unit 8 Port Townsend WA 98368 Editor, The Leader Jefferson County is again targeted by fish farms! We have fought for a quarter century to keep them out of county marine waters. We had a longstanding moratorium against them, except for juvenile native salmon release pens for enhancement of sport and commercial fishing. Our Board of County Commissioners has proposed Shoreline Management Program language which would prohibit the fish feedlot farms, but the Department of Ecology wants changes which would permit them in spite of the fact that DOE recently approved Whatcom County's SMP prohibiting them. We are spending hundreds of millions in federal and state funds to clean up Puget Sound, remove dams and generally improve, restore and protect habitat for our native salmon resource. That makes sense. But the farming of salmon, native or otherwise, is totally counterintuitive! The pens pollute, spread parasites which have extinguished native runs elsewhere, are subject to disease, stimulate algal suffocation in the pens and elsewhere and create bottom dead zones at their sites. They damage ecosystems elsewhere by overfishing foreign stocks to feed salmon and create a huge carbon footprint when harvesting and transporting the feed. The offspring of escaped Atlantics, which return to spawn multiple times, compete for habitat in native salmon bearing rivers. And, unless they're fed food containing questionable dyes and drugs, the meat of farmed salmon looks like the newsprint of this newspaper! The threat of grow -out salmon pens in Jefferson County represents an ethical, environmental and esthetic disaster for our future. They contribute little to the local economy and represent an unpredictable long term threat. Commercial, tribal and sports fishers, environmentalists, folks who want healthy, natural food sources and other interested parties should participate in BOCC written or oral public comment. Watch for announcements. Call, e -mail, write letters and show up to speak to the BOCC. Urge that the BOCC stands firm against fish pens. Dave Woodruff Port Townsend George B. Yount, Chairman vll Jefferson County Democrats PO Box 85, Port Townsend WA 98368 April 15, 2013 PU Board of County Commissioners PO Box 1220 Port Townsend, WA 98368 Testimony on the Shoreline Master Program, Fin Fish Net Pen Aquaculture Commissioners, I am speaking on behalf of the Jefferson County Democrats who have adopted a resolution opposed to Atlantic salmon net pen operations in Jefferson County waters. Our opposition stems from the on going science that clearly demonstrates that Jefferson County, through its Shoreline Master Program, cannot guarantee "no net loss" to the ecological functions in our waters with the siting and operation of in water fin fish net pens. We take the responsibility of the stewardship of our shorelines of statewide significance very seriously. We are committed to the protection and restoration of our endangered native salmon species. If the native fish habitat were restored, there would be an abundance of fish and a return of our once thriving commercial salmon fishing and sports industry. This should be the thrust of our efforts rather than injecting net pens into our waters. Jefferson County's Shoreline Master Plan has been at least seven years in the making. It was crafted with massive citizen participation. Only after its completion did the Department of Ecology change the game. The good work of citizens, DCD staff, and our Board of County Commissioners is now being held hostage to net pen aquaculture. This has forced development along shorelines to remain in limbo. So, we are forced into a corner. We must allow net pens or DOE will not approve our SMP. This must be resolved as soon as practical. We applaud the Board of County Commissioners reluctance to allow net pens. We wish we could have a moratorium like British Columbia has recently has done in the northern Gulf Islands, or Alaska's out right ban. We encourage the Commissioners to continue to fight for a moratorium. However, we must have an up dated SMP, the Jefferson County Democrats urge you to adopt a clear set of conditional use conditions that gives maximum deference to native salmon species and imposes monetary consequences if there are damages to the ecosystem. If we are going to live by the concept of "no net loss ", then we mean no net loss. Respectfully Submitted, George B. unt, Chair n Jefferson County Democratic Party i V HEINZ RECORD 4C) J., -Pte .�c ;a6i. c 11 ALt rcLa 11 jt �- c. n, AJ�4 C4 Lal L -1 TAIQ- �- e �, Its ,114, ZA SJ X10 /"L/ IR4 7/1) C It April 15, 2013 "9 To: BoCC - SMP Comments, PO Box 1220, Port Townsend, WA 98368 or to jeffbocc @co.jefferson.wa.us. From: Joan Quackenbush 5062 Willamette Street Port Townsend, WA 98368 Re: Changes to our County Shoreline Master Plan (SMP) specifically regarding Net Pens Here in the Pacific Northwest, specifically the State of Washington, we clearly have the unique and enviable opportunity and ability as one place in the U.S. and World to brand ourselves with the highest quality fresh Wild Salmon. We can strive in this direction or muddy up our waters and loose our wild Salmon to disease, antibiotics, toxic feed and a myriad of multiple problems that have been proven to be the case in B.C. (see Sal monConfidential . ca ), Chili, and Norway. These problems are all associated with the use of Net Pens. I give much kudos to our County Commissioners in their attempt to ban the toxic use of Net Pens.. My understanding is because of past legislation, The Dept. of Ecology, State of WA., has given our Commissioners the ultimatum to force them to allow conditional use permits. I support these Commissioners and would like to know how I can support ending this old legislation. I am concerned about several areas of these conditional use Permits. Specifically, #15 on pg 6 of 15 states, " The County should prohibit in -water finfish aquaculture in waters of Jefferson County where there are habitat protection designations in place and/or water quality issues documents ". I would like it to show the word shall in lieu of should. Also, I am extremely concerned about the Enforcement Protocol for these changes. Who will do the testing, who bares the costs. I am concerned that even if the industry bares these costs, they have big money to make sure these tests say what they want them to say. They also have the ability to silence anyone they employment with the threat of dismissal. Is our County prepared to follow up test and are they prepared and able to Enforce these changes? So what is the Enforcement Mechanism? Jefferson County and even our State of Washington may not have the manpower and or monies available versus that of large Corporations. � / j� A-0 ESaq cry �-Vrw( tmx-,,D L, H, �i hod k /! CdWe -"� Ro�ic }rs w w' . NO-IlLb by No 1`�S in,- w a i �✓` 1 � C CW4-r%l a R ego�C"chy o ti -Le &,4,n, ti sJN,e swPP�y� N 6�e. �e.G,Q'1"� �'Jowihf LUC I .hP � -c' cak.(, 7-iK1e SmPoa r r Lr-ok6e� -- Crk . sc,:e,hce. de,We,LopiKy re r%4t%a pe,-m; t f 4bd- IA Vo .% �6s C- G: I's- pivypaA-,OV�,�- ; s r*j c IR IS-. ?'D Reap . P, afm.P4&I� e <Gy,`���y. und;sri Nlr:la/R�le r? 't April 15, 2013 Jefferson County Commissioners: I appreciate this opportunity to comment on the revisions to our Shoreline Master Plan that allow open cage finfish aquaculture (net pens) in Jefferson County. I am a member of the executive board of the Sierra Club's North Olympic Group and, while my comments today are submitted as an individual, l would note that the Sierra Club has raised many of the same concerns that I will address. I support the County Commissioners' original proposal to prohibit net pens in Jefferson County. The risks to native salmon populations are too great to allow commercial enterprises to endanger these iconic species and the economic value of our native salmon populations far outweigh the economic benefits that would be derived from commercial operations. The intent of the Shoreline Master Program is to add protections, not provide an opportunity for industry to degrade the diminishing aquatic resources that so many citizens are trying to restore. As you know The Puget Sound Partnership is currently working to implement policy changes at the local level to protect salmon habitat. Salmon recovery is guided by implementation of the Puget Sound Salmon Recovery Plan, adopted by the National Oceanic and Atmospheric Administration (NOAH) in January 2007. This recovery plan was a collaborative effort to protect and restore salmon runs across Puget Sound. The Puget Sound Partnership has now rehabilitated over 800 acres of salmon habitat. Allowing net pens in Jefferson County jeopardizes these efforts. It is well known that farmed salmon can transfer disease to wild stock and that escaped fish can reduce the fitness of wild stocks through interbreeding. Wild salmon are already under stress in Washington- -out of 435 wild stocks of salmon and steelhead studied, only 187 of them were classified as healthy. Farmed salmon will only further stress our native populations of salmon. Net pens pollute and degrade marine habitat. Because salmon are raised in open marine net -pens, organic and chemical wastes are not collected or treated. Organic wastes from uneaten feed and feces can accumulate on sediments and affect species within the immediate vicinity of net pens and species diversity is typically lower downstream from net pens. The introduction of antibiotics and pesticides into the environment will have additional harmful effects. The feed used to_produce farmed fish adversely affects the marine ecosystem. Salmon reared in captivity are carnivorous fish and farmed salmon are fed diets largely comprised of processed wild fish. In Washington, farmed fish dine on a mixture of anchovy, herring, wheat, soybeans and corn. A third of global fisheries landings are converted into fishmeal and fish oil annually (FAO 2002). The fish species that comprise most fishmeal include anchovies, sardines, and menhaden — species that are critical to a functional food chain that insures the health of species of high economic value, such as tuna, as well as the survival of countless bird species, including the endangered Pacific Brown Pelican. Fish farming poses an ethical and environmental dilemma as farming carnivorous animals results in a net loss of protein and the use of fishmeal and fish oil depletes the amount of protein available for human consumption. Because of these serious concerns I urge you to continue to work with the Governor to seek a moratorium on net pens pending study by a high level commission comprised of key stakeholders. And, although legislation failed to pass this legislative session, I urge you to continue to work with our legislators to enact provisions that would allow local governments to prohibit net pens. Sin erely, Pe errero Port Townsend Michael Felber • 5413 State Route 20 • Port Townsend, WA 98368 April 15, 2013 Jefferson County Commissioners Port Townsend,WA 98368 Dear Commissioners, In July of 2011,1 entered into our county record, extensive documentation of the correlation between open net pen fish farms and, infectious salmon anemia virus, sea lice and other parasites on salmon, and infectious hematopoietic necrosis virus (IHN virus) in British Columbia. Since then these viruses have been showing up in our local waters, as many of our local salmon migrate to sea via the Johnstone Straight, past British Columbian fish farms, and bring the diseases back with them. I am not a politician, so I don't know what you can do in view of the pressure you have received from the Department of Ecology to allow open net pen fish farms. I do know that the scientific evidence is clear that if we allow more fish farms, we can expect the decline and extinction of our wild salmon. This is something that the fish farm industry would see as eliminating its competition. With the recent removal of the Elwa River dams, and the extensive work that our county's residents have done to restore salmon streams, I consider it extremely counterproductive to allow fish farms in our waters. Since more than 200 species depend on the wild salmon for survival, most people view the fish farms as the vehicle of the death of our local ecology. I still have hope that you may find a way to keep the fish farm industry out of our county waters. Thank you, Michael Felber From: Newlan2dl @aol.com Sent: Wednesday, March 27, 2013 6:58 PM To: jeff bocc Subject: Comment on Finfish Aquaculture Pens 1. Only South PT Bay is exempt, but all of Port Townsend Bay has been open and unobstructed for recreational boating and fishing and other water sports. If pens are planned for anywhere near Rat Island or south of Boathaven, it will be an obstruction to those sports. 2. 1 see no mention of on ongoing monitoring system by a disinterested third party if this aquaculture project goes forward. This is imperative and should be specified with clarity as to how often and by whom to ensure disease and water toxicity is not present. WI- E! Shannon From: Phil Johnson Sent: Thursday, March 28, 2013 7:07 AM To: Julie Shannon Subject: FW: Salmon Pens From: Al Cairns Sent: Thursday, March 28, 2013 7:07:20 AM To: Phil Johnson Subject: RE: Salmon Pens Auto forwarded by a Rule Phil, I've been thinking a lot about the struggle you've had in advocating for our county's right to protect its natural resources, especially when the State says that we don't have that right to exercise. Would love to have lunch with you one of these days to get your feedback on an idea or two I have on how we could establish our rights. AI Cairns Jefferson County Dept. of Public Works Solid Waste Coordinator (360) 385 -9243 a cairn sra: co. i efferson.wa. us From: Phil Johnson Sent: Wednesday, March 27, 2013 3:00 PM To: Al Cairns Subject: RE: Salmon Pens AI - -- Thanks for the info --- I "ve already seen the documentary. It is excellent. Phil From: Al Cairns Sent: Wednesday, March 20, 2013 2:19 PM To: Phil Johnson Subject: FW: Salmon Pens Commissioner Johnson, The vendor that I have hired to produce a series of workshops on vermicomposting is also very much against net pen operations and we have talked about his concerns at some length. He sent the below e-mail to me and I thought you might find it useful in your own effort to protect our native salmon runs. Best regards, At Cairns Jefferson County Dept. of Public Works Solid Waste Coordinator (360) 385 -9243 acairns(a,co.iefferson.wa.us 1 From: TODD SPRATT [ mailto :infobugabayCawhidbey.com] Sent: Wednesday, March 20, 2013 1:31 PM To: Al Cairns Subject: Fwd: Salmon Pens This documentary should be watched. This film, produced mainly for British Columbia voters, is regrettably relevant to those of us here in Washington State. Even as we read this, proposals have been initiated to construct what might be the largest net pen operation on the West Coast just a few miles from Whidbey in the Strait of Juan de Fuca near Port Angeles. This film tells the back story, a behind - the - scenes peek at what may be the biggest environment - related government cover -up ever perpetrated on British Colombians (and by extension all citizens of the Pacific Northwest). As the May 14, 2013 BC election approaches, its producers intend the film to help citizens formulate their questions to candidates on the election trail - to tell them that the failure to fix salmon feedlot issues is important to voters and the health of the environment. The film also exposes the collusion between the farm -fish industry and politicians, to the continuing detriment of all of us. Here in Washington, please continue to resist the Dept. of Ecology's pressure to allow salmon net pens there and elsewhere, including in Island County waters. The risks are far too great to gamble. Just say NO to "Spamon "! http: / /www.salmonaresacred.org 2 i f Here are links to video recordings of a lecture presented by Dr. Lawrence M. Dill (BSc, MSc, PhD University of British Columbia) in Port Angeles last summer. Herein Mr. Dill discusses the farm fish industry in BC, right across the water. Link to presentation (two parts): Part 1: https,! vimeo.com /4790_3.851 Part 2: httE .,f,,.vimeo.com1479C�6547 Thanks to Greenbelt Consulting for this link and this perspective. Todd 5pratt drewslist@whidbey.com corn Cl BugaBay Company LLC info bugabay.com b u g a bay (cD_wh id bey. co m www.bugabay.com 360- 730 -1619 530 - 559 -5929 From: judithwalls @q.com ent: Thursday, March 28, 20136:27 PM To: jeffbocc Subject: net pens Greetings, I have lived in Jefferson County since the late 1970's, south of Port Townsend on Oak Bay. I strongly object to any net pens in this area because they are a community polluter and problematic. I remember when pens were here and the local divers told me the sea -bed below them was barren, plus at least twice the Navy had to retrieve pens which had broken loose in foul weather to keep shipping lanes safe. I never eat pen raised fish and consistently choose organic foods. For these reasons, I believe your first obligation is to your residents; both people and wildlife. Please protect MY rights to not have pens polluting my shellfish with antibiotics, concentrated wastes, industrial noise & vistas in front of my home. Protect our native fish runs from inferior Atlantic Salmon, virus risk and concentrations of sea lice. Further, net pen workers have made the news "abating" opportunistic marine life coming to their pens to feed. Even if I lived in upland areas - I would strongly object to an adjacent property owner towing in and parking a commercial pig pen. In short, the net pens historically moor in public waters and abuse the resourse. If the State demands that you just not say "no" - please so encumber the permitting process in this County that it will not be financially leasable for the dirty business to anchor here. Best regards, Judith Walls 0190 N Bay Way Port Ludlow WA 98365 ph: 360- 437 -2394 • `From: Sent: To: Subject: HEARING Forest Shomer [ziraat @olympus.net] Friday, March 29, 2013 1:24 PM jeffbocc re: land -based sockeye salmon production in BC Dear Board of Commissioners, Please be aware that in British Columbia there is now a producing LAID -BASED sockeye salmon farm: htW:/ NN;ww vancouversun com /life /World+ first+ land +based +faun +sockeye+ salmon+ ready +harvesd816li39 /story.html #i xzz2OxSsznVe I know that Dept. of Ecology is complicating your regulation of in -water salmon farming, so this could be useful in demonstrating that alternatives do exist, on land instead of in the sea. 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Find out... http: / /ww w. vancouversun.con-llife /World+ first +land+ based +farm +sockeye +salmon +ready... 3/29/2013 rage � vi I The two highest paid public servants in British Columbia —whose combined pay was more than $1.5 million in 2010 —work in a building in Victoria that doesn't even have a sign identifying the business. more » The Vancouver Sun Online now Top celebrity shots of the week... Entertainers and notable people caught by the camera at candid moments orjust flaunting it at special events- (4 F1 News Metro National World Politics Special Report s Ganes Education liealth Weather ° Traffic and Trangil Database U -Repor ° "todav's Paver Podeasts ° Enviromnent • Opinion • Staff Bloes • Community Bloes • Letters • Columnists • Editorials- Columns • On –Ed • Editorial Cartoon Business • BC rg • Enc�rav • Your Money • Morleaac Essentials • Small Business http : / /www.vancouversun.com/lifel World+ first +land+ based +farm +sockeye +salmon +ready... 3/29/2013 ]note » u 13 °C A few clouds Vancouver • Detaled Forecast F1 News Metro National World Politics Special Report s Ganes Education liealth Weather ° Traffic and Trangil Database U -Repor ° "todav's Paver Podeasts ° Enviromnent • Opinion • Staff Bloes • Community Bloes • Letters • Columnists • Editorials- Columns • On –Ed • Editorial Cartoon Business • BC rg • Enc�rav • Your Money • Morleaac Essentials • Small Business http : / /www.vancouversun.com/lifel World+ first +land+ based +farm +sockeye +salmon +ready... 3/29/2013 rage j va 1� • Economv • Commercial Real Estate • Resources • Technology Asia Pacific • Calculators • Real Estate • Keeping Track • Insurance • Watchlist Markets on PP Socir(s < Canuckss- Hockev Hockev Video Iliehliehts • Lions- Football • Whitecaps -Socce r • Baseball • Basketball • Galf • M M A, Boxing • Tennis • Racing • Winter Sports • 2010 Olympics Legacy • San Run • Ski Guide Entertainment • Movies • Television • TV Listings • Music • Books • Theatre • What's On Life 2013 Sun Run Fashion & Beauty Food Wine Parenting Relationships Diversions - Comics & Games In the Garden l leatth • Fitness • Empowered Health • Women • Men • I amily & Chld • Seniors Mental Health Sexual Health Technology Personal Tech Gamin Tech — Biz Internet Space Download Sun Apps Travel Ski Guide Trip Ideas Tools & Tips http : / /www.vancouversun.comllife /World+ first +land +based +farm +sockeye +salmon +ready... 3/29/2013 �r, ° Destination Guides ° I ravel Shots ° lops • Jobs • Itome • Post Jobs • Too Employers Driving • New • Cars of Bond • Kiiiii Aulos Classifieds • Sell • Research & Compare • News & Fyents ° RiR Videos Features Homes • New Home Developments • Al Home ° Westcoast Homes with Arran Henn • Out Of Town Properties • BoughtSold • Westcoast Homes & Design Ma a • Vancouver Sun TV • Renovative • Decorating • Classitieds ° Announcements • Dating ° Obituaries Job Listings Car Listings ° Real Estate For Sale%Rent Shopping ° Place an Ad ° F1verCity Don't miss' Mental Health Pensions Surrey Sun Run BC 203i Sun I V C hincsc NCws Video Paper Empowered Health Energy Challenge World's first land- based -farm sockeye salmon ready for harvest in B.C. http:// ww' vv. vancouversun .comllifelWorld +flrst +land+ based +farm +sockeye +salmon +ready... 3 /29/2013 r agc; ✓ yr r ✓ • Langley operation expects to ramp up to production of 500 kilograms of fish every week By Randy Shore, Vancouver SunMarch 27, 2013 Tweal o Comment 0 Story Fhoto> ( 15 ) Willowfield Fish Farm in Langley is producing the world's first commercially produced land -based farm sockeye. Photograph by: Jenelle Schneider, Vancouver Sun B.C. seafood firm Willowfield Enterprises will begin harvesting next week the world's first commercial supply of sockeye salmon raised on a land -based faun. The Langley fish farm expects to produce up to 500 kilograms of sockeye a week under the West Creek brand for wholesaler Albion Fisheries, according to company president Don Read. It will be sold at Choices Markets. Initially, the harvest will be considerably smaller. Sockeye take about three years to achieve a harvest weight of two to three kilograms. Fish coming to market next week are between 1.1 and 1.5 kilograms. "We have plans to double our capacity, but we want to take time to grow the market," said Read, who is taking a conservative approach to growing his business. "We have been fanning trout for 20 years, but we have only been profitable for three years." West Creek sockeye will cant' the Vancouver Aquarium's Ocean Wise sustainability certification. "Getting Ocean Wise certification (for West Creek trout) brought a lot of awareness and really helped our business," Read said. "It allowed us to raise our prices 20 per cent" Read and partner biologist Lam Albright experimented with sockeye for more than 15 years before developing a system to raise a commercially viable product. Willowfield's farm is based on a flow - through model, rather than recirculation common in land -based salmon farms. Water is drawn from a spring into above- ground sockeye tanks, then it flows into a series of in- ground trout ponds and finally into a holding pond before flowing into a local creek. "In the natural trout ponds, fish waste and ammonia is absorbed into the native plants," said Read. "So it's actually biofiltered." In that from the bottom of the trout ponds and the holding pond is dredged out and dried for use as fertilizer by a local farmer. `Our water has been tested by the Ministry of Environment and certified as non- polluting," Read said. http: / /www.vancouversun. comflife /World +first +land+ based +farm +sockeye +salmon +ready... 3/29/2013 While land -based salmon farming is generating headlines and optimism from sustainability certifiers and ocean -based farming opponents such as . David Suzuki, closed - containment fin fish aquaculture remains a niche business supplying only about three per cent of fart -grown fish. B.C. produces about 70,000 tonnes of Atlantic salmon each year from net pens in the ocean. The largest land -based Atlantic salmon farm in B.C. —run by the Namgis First Nation on northern Vancouver Island —is projected to produce up to 450 tonnes a year when it begins to harvest fish next year. Willowfield will produce about 25 tonnes a year of sockeye and trout combined this year, while Agassiz's Swift Aquaculture produces about 10 tonnes of coho a year. A new steelhead farm near Namurno is taking in 50,000 smelts this month and projects harvest of about 100 tonnes a year or 2,000 kilograms a week. Taste of BC Aquafatm will employ a recirculation system that recaptures more than 99 per cent of the water used by the system. Atkinson plans to release effluent from the farm to an on -site wetland and an aquaponic-growing operation "I'm absolutely confident of the technology for raising steelhead." said owner Steve Atkinson. Atkinson raised about half of the S1.2- million capital cost of his farm from the Department of Fisheries and Oceans' aquaculture innovation and market access program and B.C.'s agriculture innovation fund. rshored-vancouversun.com © Copyright (c) The Vancouver Sun • E -mail this Article • Print this Article • Share this Article • 71ithe the ogread ur d and etry.ran Location refreshed More on This Story B.C. fish -Farm foes fear beine `shouted dova" by new committee F-sh farm oroiect reiectedby Nova Scotia as threat to wild salmon Time to move fish farms onto I and '> Federal report sees it should be explored (with video) Vancouver's Urban Stream captures the circle of hfie in a shirmiu¢ container Follow "I lie Vancouver Sun on Twitter Follow The Vancouver Sun on Facebook Download the Sun's iphone app Download the Sun's Android sup Add The Vancouver Sun to your Goode Plus circles Story Tools • F -mail this Article • • Print this .Article Font: http: / /www.vancouversun.comllife /World +first +land+ based +farm +sockeye +salmon +ready... 3/29/2013 rage i or I:) i 0 Image: � k Prnious Next Willowfield Fish Farm in Langley is producing the world's first commercially produced land -based farm sockeye. 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All rights reserved. • Unauthorized distribution, transmission or republication strictly prohibited. http: / /www.vancouversun. comllife /World+ first +land+ based +farm +sockeye +salmon +ready... 3/29/2013 From: Kathy Pool [poolenge @gmail.coml Sent: Monday, April 01, 2013 10:56 AM To: jeffbocc Cc: Kathy Pool Subject: In -Water Finfish Aquaculture Dear Jefferson County Commissioners: As a commercial fisherman with 35 years experience and one who has monitored this issue both locally, regionally, and world -wide (including on -site visits), allowing any in -water finfish aquaculture, or any conditional activities be prohibited outright. Kathy Pool PO Box 1540 Port Townsend, WA 98368 360- 531 -3098 I categorically reject any language use allowances. I request that these lfj. I 42-. 0 From: Portia Mather - Hempler [revpmh7 @yahoo.com] Sent: Tuesday, April 02, 2013 10:53 AM To: jeffbocc Subject: Finfish aquaculture proposal I am writing in opposition to the proposed revision to finfish aquaculture policy in the waters surrounding Port Townsend, Discovery Bay, and the Strait of Juan de Fuca. Because we do not know what the negative effects of this type of aquaculture would be on native wild Pacific salmon and other fish and shell fish as well as the purity of our waters, I favor that finfish aquaculture be returned to the category of "uses and activities prohibited outright ". Thank you for registering my comment. Sincerely, Portia Mather Hempler 1210 Beckett Point Rd. Port Townsend, WA 98368 CC'. From: Dave Woodruff [doodruff @cablespeed.com] Sent: Monday, April 08, 2013 8:43 PM To: jeffbocc Cc: Subject: Leader News Fish pens HEARNG ggq aaa Honorable Jefferson County Commissioners: I am presenting this letter as written testimony for the 6 p.m public hearing of April 15 , 2013 at the courthouse pertaining to the SMP and salmon net pens in Jefferson County. Please enter it into the official record. Thanks for your efforts in the matter of preventing salmon feed lot pens in Jefferson County marine waters. fully understand the box into which the DOE has put you and your constituents. I understand your need to, for at least the time being, resolve the issue carefully with a conditional use permit system. I also continue to object to the net pens ever being placed in our county's waters. In spite of the reluctance of the DOE to appropriately consider the science, listen to public opinion or foresee the dangers to the large and important industry based on our native salmon, I am asking you to continue to work with our supportive legislative delegation, your commissioner colleagues statewide, and your concerned constituents to continue efforts to get a bill passed which would put the matter in the hands of the policy makers, and thusly the voters, in the counties where such pens are in future proposed or currently exist. Also, and very importantly, please be aware of the industry's next move. International interests have developed a genetically modified "super fish" version of Atlantic salmon which has been proposed for market. It will grow much faster and many times larger than currently used stock. These fish are intended to provide a market ready "crop" much quicker than currently possible. Many believe that these GMO fish, untested in the pens, will be a natural disaster waiting to happen. In my opinion they represent just one of many reasons for a "local option" in siting pens. Thank you. Dave Woodruff Port Townsend 98369 cc: The Leader w /request hereby for publication as a Letter to the Editor From: Deanna Pumplin [deepumplin @gmail.com] ..'. Sent: Wednesday, April 10, 2013 11:27 AM To: jeffbocc Subject: Fish Pens testimony for 4/15/13 hearing Public Comment regarding Fish Pens in Jefferson County From: Deanna Pumplin Port Townsend, WA I am very concerned about Fish Pens in Jefferson County. I understand that Jefferson County cannot ban Fish Pens outright. I assume that means it must provide some regulation of Fish Pens. This is a sad state of affairs, when a community cannot determine for itself, based on credible evidence, that a particular operation is detrimental to the health and welfare of that community of people and the natural environment upon which it is dependent. I see little difference between Fish Pens and any other industrial agricultural operation, such as those that increasingly dot the earth. Such industrial operations operate to the detriment of a community's quiet enjoyment of nature, to the detriment of the web of life. Fish Pens would be detrimental here in Jefferson County to clean water in which live aquatic creatures from the microscopic to mammals as large as whales. That water, the water that laps against the shores of Jefferson County, is already under stress from non -point run off from agricultural farms, leaking septic tanks, urban landscapes with their oil - leaking automobiles, backyard gardens using chemical inputs, backyard pet feces, and from pharmaceuticals and other compounds that survive sewage treatments. That water, the water that laps against the shores of Jefferson County and mingles with the salmon streams that are so lovingly and painstakingly being returned to health, will surely suffer a further decline if Fish Pens are allowed. The wild salmon will be at more risk. Our whole wild world is already at risk from large scale farming... whether on land or in the water. I support the BOCC in saying "NO" to Fish Pens. Someone must take a stand. How can there be a right to destroy the natural world? Please stand in defense of nature and the health of all living things. If you must provide for Fish Pen operations along the shores of Jefferson County, can you require a demonstration, through operations in other places, through very small scale test operations that the fecal matter will not overwhelm the ecosystem, that the fish will not escape, that the fish meet human nutritional needs and carry no detrimental pharmaceuticals? Can you require proposed Fish Pen operations to prove their sustainability and compatibility with the health and welfare of Jefferson County citizens and the wild world before beginning operations? Thank you for considering my comment. Deanna Pumplin 4/11/ CAC�._W /© « r Dr From: O'Neill Louchard loneill @olympus.net] Sent: Wednesday, April 10, 2013 9:10 AM To: jeffbocc Subject: Fwd: My Public Comment on Fish Pens -an addition at the beginning to ask that you enter into official record I am presenting this letter as written testimony for the 6 p.m public hearing of April 15 , 2013 at the courthouse pertaining to the SMP and salmon net pens in Jefferson County. Please enter it into the official record. THANK YOU. Public Comment regarding Fish Pens in Jefferson County From: ONeill D. Louchard Port Townsend, WA My primary objection to Fish Pens is that if there is contamination or an eventual die -off of wild stock, that there may be a move toward GMO fish, which will mean our food is owned by a corporation. • Our Food is Being Hijacked by Monopolizing Corporations truth -out. or /...1'14783-our-food-is-being-hijacked-by-monopolizing.. Feb 27, 2013 – Our Food Is Being Hijacked by Monopolizing Corporations .... Mark Karlin: In discussing corporate ownership of the milk product and ... Farmed Atlantic Salmon Versus Wild and... - Angler's Tonic www. anglersionic. cowl... /farmed- atlantic - salmon- versus -wild- and -su... Jan 24, 2013 – No fake coloration here — unlike farmed salmon, wild Alaska salmon ..... pen raising of salmon it is going to wipe out the wild salmon stocks. The most damaging aspect is that feed lots destroy the natural communities and collapse the markets for them and then the new fish as "proprietary" and owned by a Corporate, then dominate the market and our food is "owned." I Other objections: 1) Sewage in our water from the fish and the cost is born by the taxpayers. Seattle is an example. seattletimes.com - Search Results - Local Search search. nwsource. com/search ?source = ST &similarlo... 3, Atlantic Salmon Escape Into Sound From Pens, Local News ...escaped from a commercial fish farm are swimming free in Puget Sound this week . .... ... input of raw sewage into Puget Sound is bad and we need to be ... untreated sewage ... 2) GE Salmon have lower levels of nutrients compared to Farmed Salmon, which have fewer nutrients than wild Salmon and are also higher in PCBs, dioxins and fungicides, etc. More colorants. And most colorants are petrochemical based. Is there any nutritional difference between wild - caught and farm www whfoods com/QenpaQe phy ?tname= george &dbid =96 Jul 30, 2003 — eating healthy cooking healthy feeling great ... Farmed salmon, in addition, are given a salmon - colored dye in their feed, without which ... Farm- raised Fish Provide Less Usable Omega -3 Fats ... As with other toxins, it is thought that farm- raised salmon contain higher PBDE levels than wild due to the "salmon ... 1. Wild Salmon vs Farmed: The Real Story - eNature: Articles: Detail www.enature.com/artieles /detail. asp ?storvlD =508 Farmed salmon regularly escape and mix with wild populations.... just as the introduction of sportfish into western lakes and streams wiped out so many local 2. Farmed fish are less nutritious than wild stock and less healthy and require antibiotics, which are leading to superbugs. Antibiotic resistance - Wikipedia, the free encyclopedia en .wikipedia.or ,a/wiki/Antibiotic resistance The bacteria in the culture on the right are resistant to most of the antibiotics..... in animals that are used as human food, such as cattle, pigs, chickens, fish, etc.... Evidence for the transfer of so- called superbugs from animals to humans has 3. ... • Sea Lice From Fish Farms May Wipe Out Wild Salmon • news. nationalzeomraphic.com /news /2007/.../071213 - salmon- lice.htm... Dec 13, 2007 — Sea Lice From Fish Farms May Wipe Out Wild Salmon ... Wild vs. Farmed Salmon in National Geographic Magazine (July 2003) • Sea Trout ... Ocean Conservancy: Protecting the Future of Fish www.oceanconservancy.orp /our -work /aguaculture/ Decisions about the future of fish farming — including the role of genetically ... GE salmon have higher levels of a growth hormone that is known to cause cancer.... that escaped GE fish could breed with wild populations and wipe them out in • • From PCFFA: A PACIFIC RIM STRATEGY FOR WILD SALMON • www.pcffa.orp,1fn- may03.htm Everywhere market prices are being depressed by a glut offarmed salmon..... losses of wild fish from disease and parasites, and the escapes from these netpen ... This has nearly wiped out whole wild populations, such as what is occurring in ... "(1) Pollution: Salmon farms are major polluters. The pollution comes principally from four sources: a) fecal matter from the concentrated numbers of fish in each netpen (salmon netpen aquaculture amounts to a form of oceanic feedlots); b) anti - fungal agents used on the fish to contain such things as sea lice; c) uneaten food that settles beneath the nepens resulting in high concentrations of organic matter that often contains antibiotics and other medicines and artificial colorants contained in the fish feed; and, d) pesticides and anti - foulants used on the nets to retard algal growth. (2) Spread Of Disease And Parasites To Wild Fish: Salmon grown in netpen operations in open waters can and have spread disease and parasites to native wild salmon populations. This has nearly wiped out whole wild populations, such as what is occurring in the Broughton Peninsula in British Columbia. (3) Escape Of Farmed Fish Into The Wild: Salmon escape from netpens with considerable frequency. The danger they pose to native salmon populations are from: a) predation; b) competition for forage or habitat; and, c) displacing native fish in watersheds, including the destruction of the spawning redds of native salmon populations. The latter is now of great concern given that escaped Atlantic salmon have now successfully spawned and produced offspring in several British Columbia rivers. (4) Feed Conversion: Aquaculture proponents make a big deal about the need to increase world food production for a growing human population, and offer up aquaculture as a means for achieving increased food production. The fact is that we are currently taking three to four pounds of wild fish, such as anchovy, herring and sardines, that themselves are suitable human foods, to make one pound of edible salmon farm fish flesh. The wild fish caught to produce the feed for farmed salmon are also important forage for other commercially valuable fish, as well as forage for marine mammals and seabirds. Indeed, some of these wild fish, used only to make fish pellets, are themselves in demand as a food source in developed nations. Thus salmon farming, as currently practiced, results in a net loss of food for humans, not an increase. (5) Human Health: Farmed salmon, too, pose problems for human health. Unlike their natural counterparts, farmed salmon have much lower levels of omega -3 fatty acids and thus lack health benefits offered by wild salmon. The consumption of farmed salmon can also pose human health risks that are associated with the use of antibiotics in the growing of the fish, as well as antifungal agents and pesticides that may be taken up by the fish in the farm operations. Farmed fish have also been found to have 10 times the level of PCBs [polychlorinated biphenyls] of that found in wild salmon. Finally, the chemical colorants used to give farmed salmon their pink -red coloring can cause vision problems. (6) "Frankenfish" — A Future Problem ?: The current application by Aqua Bounty to the U.S. Food & Drug Administration (FDA) for approval of the use of transgenic Atlantic salmon in fish farm operations is also a problem looming close on the horizon. If problems with salmon farming are bad now, it's only going to get worse in the future when "Frankenfish" come alive. Given the push by the U.S. government, at the behest of biotech and large food processing companies, for the use of genetically engineered organisms in food production, FDA approval is likely to be granted, despite widespread concerns. But don't expect the National Marine Fisheries Service or the U.S. Fish & Wildlife Service to raise objections. Both NMFS and USFWS are busy pandering to aquaculture rather than looking out for natural fish populations or the public good. " I oppose the fish pens and hope you will do all you can to keep them from our waters. Thank you, O'Neill D. Louchard c,c% rN H-10-0 From: O'Neill Louchard [oneill @olympus.net] Sent: Wednesday, April 10, 2013 8:59 AM To: jeffbocc Subject: My Public Comment on Fish Pens Public Comment regarding Fish Pens in Jefferson County From: O'Neill D. Louchard Port Townsend, WA My primary objection to Fish Pens is that if there is contamination or an eventual die -off of wild stock, that there may be a move toward GMO fish, which will mean our food is owned by a corporation. • Our Food Is Being Hijacked by Monopolizing Corporations truth -out orgL.. 114783 -our food -is- being - hijacked -by- monopolizing... Feb 27, 2013 – Our Food Is Being Hijacked by Monopolizing Corporations .... Mark Karlin: In discussing corporate ownership of the milk product and ... Farined Atlantic Salmon Versus Wild and... - Angler's Tonic www. anglerstonic. com-- farmed- atlantic - salmon- versus- wild - and -su... Jan 24, 2013 — No fake coloration here — unlike farmed salmon, wild Alaska salmon ..... pen raising of salmon it is going to wipe out the wild salmon stocks. The most damaging aspect is that feed lots destroy the natural communities and collapse the markets for them and then the new fish as "proprietary" and owned by a Corporate, then dominate the market and our food is "owned." Other objections: 1) Sewage in our water from the fish and the cost is born by the taxpayers. Seattle is an example. seattletimes.com - Search Results - Local Search search.nwsource.com /search ?source= ST&similarto... 1 3, Atlantic Salmon Escape Into Sound From Pens, Local News ...escaped from a commercial fish farm are swimming free in Puget Sound this week . .... ... input of raw sewage into Puget Sound is bad and we need to be ... untreated sewage ... 2) GE Salmon have lower levels of nutrients compared to Farmed Salmon, which have fewer nutrients than wild Salmon and are also higher in PCBs, dioxins and fungicides, etc. More colorants. And most colorants are petrochemical based. Is there any nutritional difference between wild - caught and farm wii,w.whLood.y.com/izenpgge.php?tname—Qeor)ZC,&dbid--96 Jul 30, 2003 — eating healthy cooking healthy feeling great ... Farmed salmon, in addition, are given a salmon - colored dye in their feed, without which ... Farm - raised Fish Provide Less Usable Omega -3 Fats ... As with other toxins, it is thought that farm- raised salmon contain higher PBDE levels than wild due to the "salmon ... 1. Wild Salmon vs. Farmed: The Real Story - eNature: Articles: Detail www. enature. com/articles /detail. asp ?storylD =508 Farmed salmon regularly escape and mix with wild populations.... just as the introduction of sportfish into western lakes and streams wiped out so many local 2. Farmed fish are less nutritious than wild stock and less healthy and require antibiotics, which are leading to superbugs. Antibiotic resistance - Wikipedia, the free encyclopedia en .Wikipedia.orglwiki/Antibiotic resistance The bacteria in the culture on the right are resistant to most of the antibiotics..... in animals that are used as human food, such as cattle, pigs, chickens, fish, etc.... Evidence for the transfer of so- called superbugs from animals to humans has 3.... 4. 2 5. 6. Sea Lice From Fish Farms May Wipe Out Wild Salmon 7. news. nationa lgeographic.com /news/2007 /.. ✓071213- salmon- lice.htm... Dec 13, 2007 — Sea Lice From Fish Farms May Wipe Out Wild Salmon ... Wild vs. Farmed Salmon in National Geographic Magazine (July 2003) • Sea Trout ... Ocean Conservancy: Protecting the Future of Fish www. oceanconservan cy. org /our -work /aguaculI Decisions about the future of fish farming — including the role of genetically ... GE salmon have higher levels of a growth hormone that is known to cause cancer.... that escaped GE fish could breed with wild populations and wipe them out in 8. 9. 10. 11. 12.From PCFFA: A PACIFIC RIM STRATEGY FOR WILD SALMON 13. www.pcffa.or21fn- may03.h1m Everywhere market prices are being depressed by a glut of farmed salmon..... losses of wild fish from disease and parasites, and the escapes from these netpen ... This has nearly wiped out whole wild populations, such as what is occurring in ... "(1) Pollution: Salmon farms are major polluters. The pollution comes principally from four sources: a) fecal matter from the concentrated numbers of fish in each netpen (salmon netpen aquaculture amounts to a form of oceanic feedlots); b) anti - fungal agents used on the fish to contain such things as sea lice; c) uneaten food that settles beneath the nepens resulting in high concentrations of organic matter that often contains antibiotics and other medicines and artificial colorants contained in the fish feed; and, d) pesticides and anti - foulants used on the nets to retard algal growth. (2) Spread Of Disease And Parasites To Wild Fish: Salmon grown in netpen operations in open waters can and have spread disease and parasites to native wild salmon populations. This has nearly wiped out whole wild populations, such as what is occurring in the Broughton Peninsula in British Columbia. (3) Escape Of Farmed Fish Into The Wild: Salmon escape from netpens with considerable frequency. The danger they pose to native salmon populations are from: a) predation; b) competition for forage or habitat; and, c) displacing native fish in watersheds, including the destruction of the spawning redds of native salmon populations. The latter is now of great concern given that escaped Atlantic salmon have now successfully spawned and produced offspring in several British Columbia rivers. (4) Feed Conversion: Aquaculture proponents make a big deal about the need to increase world food production for a growing human population, and offer up aquaculture as a means for achieving increased food production. The fact is that we are currently taking three to four pounds of wild fish, such as anchovy, herring and sardines, that themselves are suitable human foods, to make one pound of edible salmon farm fish flesh. The wild fish caught to produce the feed for farmed salmon are also important forage for other commercially valuable fish, as well as forage for marine mammals and seabirds. Indeed, some of these wild fish, used only to make fish pellets, are themselves in demand as a food source in developed nations. Thus salmon farming, as currently practiced, results in a net loss of food for humans, not an increase. (5) Human Health: Farmed salmon, too, pose problems for human health. Unlike their natural counterparts, farmed salmon have much lower levels of omega -3 fatty acids and thus lack health benefits offered by wild salmon. The consumption of farmed salmon can also pose human health risks that are associated with the use of antibiotics in the growing of the fish, as well as antifungal agents and pesticides that may be taken up by the fish in the farm operations. Farmed fish have also been found to have 10 times the level of PCBs [polychlorinated biphenyls] of that found in wild salmon. Finally, the chemical colorants used to give farmed salmon their pink -red coloring can cause vision problems. (6) "Frankenfish" — A Future Problem ?: The current application by Aqua Bounty to the U.S. Food & Drug Administration (FDA) for approval of the use of transgenic Atlantic salmon in fish farm operations is also a problem looming close on the horizon. If problems with salmon farming are bad now, it's only going to get worse in the future when "Frankenfish" come alive. Given the push by the U.S. government, at the behest of biotech and large food processing companies, for the use of genetically engineered organisms in food production, FDA approval is likely to be granted, despite widespread concerns. But don't expect the National Marine Fisheries Service or the U.S. Fish & Wildlife Service to raise objections. Both NMFS and USFWS are busy pandering to aquaculture rather than looking out for natural fish populations or the public good. " I oppose the fish pens and hope you will do all you can to keep them from our waters. Thank you, O'Neill D. Louchard :C, From: Diane Jones [dianejns769 @gmail.coml �0', s Sent: Friday, April 12, 2013 3:21 PM To: jeffbocc Subject: finfish aquaculture provisions My preference is that we don't allow any in water finfish aquaculture to locate in the county. I would like the county to continue to work with other counties and legislators to outlaw fish farms all together. Meanwhile until that happens I d like to add a few extra conditions on fish farms that may attempt to locate here. 1.) There needs to be a biological opinion of any siting of a fish farm relative to it's impact on listed salmon and steelhead in the geographical area affected. 2.) Where as double hulled off tankers are required for better containing off and since farmed atlantic salmon escape on a regular basis and present a threat to wild salmon then net pens should also be double walled. 3.) If a fish farm site is abandoned, the site should be restored to it's original pristine condition within a specified time. 4.) Night lighting should be night sky saver type to avoid light pollution. Diane Jones P.O. Box 1938 Port Townsend, WA 360 - 379 -9193 10 5u � + (9- I3 From: Forest Shomer [ziraat @olympus.net] Sent: Sunday, April 14, 2013 1:51 PM To: jeffbocc Subject: closed- containment salmon farming #� HEARIN kyh g RD Dear BOCC, As you consider the state- required aquaculture regulations at your April 15 meeting, please first read this article which appeared this very Friday, about closed - containment, on -shore aquaponics getting established in Canada. http• / /www cbc calnews /technologylstorvl 2013 /04 /05 /hamilton- aguaponics.html Aquaponics is a system that combines aquaculture — raising of aquatic animals — and hydroponics raising plants in water. "It's an enclosed ecosystem, " Mastroianni said "When bash breathe, they exhale ammonia and that goes through a filter and breaks down into nutrients for the plants. " It is to be expected that people will be raising fish for food within containment more and more as native resources become more imperiled. Planning for the future of Jefferson County must include aquaponics done in a sustainable, environmentally - friendly way, without overburdening the sea itself and the areas around net -pens. This article appears to be part of the answer. Truly, Forest Shomer zi raat(cv o l v mpus. net Port Townsend WA Farming fish and veggies in the city: Hamilton pair launches aquaponics farm By Julia Chapman, CBC News Posted: Apr 12, 2013 9:25 AM ET Last Updated: Apr 14, 2013 12:32 PM ET 7[2 In a Stoney Creek neighbourhood among the auto shops and packaging plants is an unconventional farm raising little fish and baby lettuce plants. Behind a glass door beaded with condensation, the new business is taking a sustainable approach to farming fish and growing produce. Tim Alford, along with high school friend Al Mastroianni, operate A &M Aquaponics. It farms tilapia and uses the fish waste to fertilize the various plants. "There has never been a 12 -month organic procedure before in Canada," said Alford, describing the eco- friendly approach the company has taken with its urban farm. Aquaponics is a system that combines aquaculture — raising of aquatic animals — and hydroponics — raising plants in water. "It's an enclosed ecosystem," Mastroianni said. "When fish breathe, they exhale ammonia and that goes through a filter and breaks down into nutrients for the plants." How it works The two 25 -year -olds from Hamilton are taking a chance, dedicating their time and money to a unique business they strongly believe in. (Julia Chapman/CBQ and Mastroianni grow their greens under blue LED lights. In the system Mastroianni and Alford built, a school of fish live in a large tub. Water flows through a PVC pipe into a tank that's designed to pull the fish waste through to a filter. The water passes through a tub of bioballs, small plastic ball for bacteria to colonize on. The filtered water then moves through another pipe to feed and fertilize the plants. The system also keeps the water constantly clean for the fish. Drag this icon to your Windows taskbar for quicker access to CBC. http: / /www.cbc. ca/news /technology /story / 2013 /04 /05/hamilton- aquaponics.html 4/15/2013 At full capacity, Alford estimates they can produce 350 to 450 pounds of fish per week, as well as 200 to 300 heads of lettuce or other leafy greens per day. "With lights running 24/7, the plants can have what they need all the time," Mastroianni said. "They'll grow faster than being in a greenhouse or outside in a traditional farm." Growing market Alford and Mastroianni's business partnership started with a message on Facebook. "Al originally sent me a link for a farm [for sale] and the message said, 'Buy me this,"' said Alford. Mastroianni's interest in aquaponics spawned from the "one thing I took from my education" while in undergraduate economics classes at McMaster University. "In North America, we spend about 15 per cent of our income on food. Countries in Europe are spending upwards to 30 per cent and in Asia about 40 to 50 per cent," he said. "As their incomes catch up, our food prices will drive up." Economic benefits aside, Mastroianni has no doubt their operation will take off. His confidence comes from a former part-time job at Walmart. "Working in the produce department, people were looking for locally -grown stuff and we just didn't have it," Mastroianni said. "The market is there for it." Since he approached Alford to be his business partner, the farm has been a labour of love for both. Alford and Mastroianni are investors number one and two in A &M Aquaponics, along with a third anonymous investor. A &M to start sales in May The pair built the set -up from the ground up. Along with help from Mastroianni's father and brother, they constructed the floor -to- ceiling structure with tubs, tubes and filters with their own hands. "Tim helped," Mastroianni said with a laugh, their long friendship evident. The two aren't making any money yet — they just moved into their current space in December and turned on the system about two weeks ago. But A &M Aquaponics is set to start selling its harvest at several farmers' markets starting next month, including Ottawa Street, Ancaster and Dundas. Their stand will be filled with a variety of lettuces, spinach, kale and arugula to start, and tilapia will be available in the fall. Alford said everything they've accomplished will start sinking in once their first fish crop is ready to be sold, but Mastroianni is already amazed by what the pair has accomplished. "When I first started researching aquaponics, I thought I'd do it on a small scale just growing for myself in the basement," he said. `But the fact I can do this for a living is amazing." Drag this icon to your Windows taskbar for quicker access to CiBC. http: / /www.cbe.ca/news /technology /story / 2013 /04 /05/hamilton- aquaponics.html 4/15/2013 10-i:3 From: Annette Huenke [amh @olympus.net] Sent: Sunday, April 14, 2013 12:08 PM To: jeffbocc Subject: healthy fish Gentlemen: kA el I write to echo the concerns raised in Linda Sutton and O'Neill Louchard's letters. If you can't guarantee the safety of wild fish stocks, don't allow the pens. Thank you. Annette Huenke Port Townsend 'effbocc From: Linda Sutton [lindasutton.wa @gmail.com] Sent: Sunday, April 14, 2013 9:47 AM To; jeffbocc Subject: TESTIMONY 4 -15 -13 SNIP fish net pens hearing, Jefferson County Courthouse, 6pm In my testimony, I ask that any siting of fish net pens be at a great distance from the regular migratory routes of our native salmon to protect them from both European- sourced viruses as well as sea lice attacks on smolts as they leave the rivers. Also, I would ask that there be an advance agreement with all fish pen operators that fish from the pens would be tested on a regular basis (quarterly each year) for the presence of viruses that would include, but not be limited to, ISA (leukemia), salmon alphavirus (pancreatic), and piscine reovirus (heart attacks), AND for testing to detect the presence of toxic substances such as dioxins and PCB's commonly found in the fish feed given to net pen farmed fish. The testing fees for this should be required to be paid by the net pen operator to the State of WA (Dept. of Health) and the testing lab should be an independent lab not associated nor financially dependent on the industry. I would also request that the feed given to the farmed fish also be sampled without prior notice to the operators and tested for toxins. Results of these tests are to be made immediately available to the public in the media and online WITHOUT the burden of filing a freedom of information request. The justification for expanding the fin fish net pen business relates to expanding the food supply for the increasing human population as well as providing jobs in a job- starved economy. Expansion, however, directly endangers the wild salmon populations that Washington has spent so much money and effort re- establishing in recent years. And, the wild salmon are a key contributor to the economy of our entire region as well as for the tribes that also depend on them. There is no clearer example of the future for Washington State than that coming from our near neighbor, British Columbia. In the early 1990's, fish net pens were located directly on the migratory routes of the native salmon with total disregard of what effect they may have. A dramatic decline in the returning sockeye to Fraser River immediately followed in 1992. The inquiry by the Cohen Commission pointed directly at the net pen fish as the source of viral disease brought from European fish egg sources. See the new film, SalmonConfidential.ca, for details. In addition, the concentration of Atlantic Salmon in net pens became infested with sea lice possibly from passing native fish. In the wild, the large native salmon are not hurt by sea lice and, because they are out at sea, are not close enough to the smolts leaving the river to infect them. But, with net pens of farmed salmon incubating large populations of sea lice in the path of the smolts, the tiny fish are immediately attacked and die with the sea lice sucking their life away. Lastly, there is the question of the farmed fish themselves and the feed they are given. There is significant evidence in the literature that much, if not all, of the farmed fish have dioxins, PCBs, and other toxic substances contained in their feed. Our Department of Health acknowledges the presence of "high levels of PCBs and other contaminants in farmed salmon' in early studies. However, they allege that there now is a "consensus among scientists and regulators is that farmed salmon and wild salmon are safe foods' which, from my limited amount of research, shows there is NOT. The recent film, SalmonConfidential.ca, raises disturbing questions about the Canadian government's involvement in a serious cover -up and intimidation of scientists who have tried to report viruses in their fish. I would ask that the following research sources be added to the existing bibliography for our Shoreline Management Plan in the section pertaining to fish net pens. Thank you for giving me the opportunity to address the hearing. Lice From Fish Farms Killing Wild Salmon http: //news natio nalgeog raph ic. com /news /2006 /10/061002- sea -lice htmI Sea Lice From Fish Farms May Wipe Out Wild Salmon: http : / /news nationalgeographic com /news/2 00 7/1 2/071 21 3- salmon -lice html Sea Lice on farmed salmonids in Chile -- doctoral thesis by Sandra Bravo http : /Avvvw veths no /en/ Home/ News / News- stories/ Sea - lice -on- farmed - salmonids -in- Chile/ Offshore fish farming — The selling of common waters - -PCC Sound Consumer 2005; htti)://www.l)ccnaturalmarkets.com/sc/0504/scO5O4- fishfarming.html May 2012: "An outbreak of Infectious hematopoietic necrosis virus (IHNv) is currently occurring in farms and hatcheries on Vancouver Island and Washington state." go to: http: /Idei)twildsalmon org/ 2012 /05/26 /ihnv -in- hatcheries - and - farms/ WATCH FILM -- Salmon Confidential -- British Columbia offers a serious roadmap of where we are headed with the fish farms. http:/ /salmonconfidential.ca MORE at: htti)://www.salmonaresacred.orci Conditional use permit article in PON_ three -week public comment period; 4/15 public hearing hh>tti): / /www peninsuladailynews com /article/ 20130312/ news/ 303129988 /iefferson- county - drafting- net - Den- gLlidelines Van De Wege's bill... "The fish farm and Ecology (OUR STATE AGENCY) are going to fight hard against it" (NOTE -link to full video of hearing is at end of list under JeffCoDems newsletter) http / /www peninsuladailynews com /article /20130218 /NEWS /302189996/ van- de- weges- net -pen- bill - gets - hearing MORE from BC which has a very strong opposition organized: htti)://www.salmonfeedlotboycott.com BC Biologist Alex Morton - multiple youtubes: http: / /www.youtube.com /watch ?v= vGuiBrIyooO (3/10/13 viruses) htto: / /www.youtube.com /watch ?v= 3NKty6RBTcU (2/22/13 mutating viruses being released into BC waters) http: //www.youtube.com /watch?v= tl- zkOR59Os (2/24/13 infested- Dalrymple Atlantic Salmon Hatchery) Virus infestations: BC and Chile http: / /seattletimes .com /html /localnews/2018296338 virusladv27m.html Canadian Journal of Fisheries and Aquatic Sciences: Sea Lice Infection rates in juvenile pink and chum salmon (BC) highest close to salmon farms htto: / /vvww.nrcresearchpress. com /doi /abs/10.1139/f04- 016 #.UVn BUKRiBs this is an abstract/pdf of complete study is linked on website Scottish fish farmers use record amounts of highly toxic pesticides as sea lice become resistant. Use of organophosphates extremely threatening to crabs, prawns, lobsters. http://www,quardian.co.uk/envsronment/2012/sep/l 0 /scottish- fish - farmers - parasite - pesticide Here's the list of the chemicals they're using: http: //www.guardian.co.ukJnews/datablog/2012/sepi1 0/scoftish-fishing-farm-chemical s Coastal Conservation Association of WA legislative update 3, website /e -mail sent nothing about 1599 that I could see on their Relevant WA laws: Dept of Ecology: Shoreline Management htto: / /www.ecy.wa.ciov /programs /sea /sma /st guide/intro.html note under SMPS section: Local governments may modify (amend) master programs to reflect changing local circumstances, new information, or improved shoreline management approaches. There are two types of amendments: limited amendments and comprehensive amendments. All changes to master programs require public notice. Comprehensive amendments require more extensive public involvement. Master programs and any amendments are effective only after Ecology approval Within General Management Act: htti)://ar)i)s,leci,wa.gov/rcw/default.asox?cite=36.70A.480 Shorelines of the state (contains additional links) Sutton uploaded video of Gov Inslee response to fish pen question htto:llwww.youtube.com/watch?v=KPSKiHkzzaU Nash, C.E. (editor). 2001. The net -pen salmon farming industry in the Pacific Northwest. U.S. Dept. Commer., NOAA Tech. Memo. NMFS- NWFSC-49, 125 p. : http://www.nwfsc.noaa.,qov/publications/techmemos/tm49/tm49.htm Dioxins are noted by NOAA as being in ALL of the fish food for net -pen salmon, thus bringing into question the effect of the dioxin in the salmon on human health. Here's a link about dioxins from the World Health Organization: htti)://www.who.int/mediacentre/factsheets/fs225/en/ University of British Columbia Faculty of Law _ "Salmon Farming in British Columbia" lists the major players and the issues. States: "In salmon aquaculture net pens, however, (sea lice) have ideal incubation conditions, from which they can "jump off' and infect wild salmon as they migrate past the pens." Experience in Norway verifies this assertion. http: / /www.law.ubc. ca/ files /pdf /enlaw /salmonfarming04 20 09.pdf David Suzuki Foundation: The Risks of Open -Net Cage Salmon Farming — "hazards of open- netcage salmon farming far outweigh the much touted economic benefits" http: / /www.davidsuzuki.org /publications /down loads /Aguabrochu re. pelf Olympic Peninsula Environmental News -- BLOG (you can sign up to receive their updates and new postings too) http: /iolyol)en.net Resources, fact sheets, and some excellent scientific research papers are still available on this international website. Organization is no longer operating but continues to provide access. Research papers include: sea lice and pesticides used in Chile; a PCB study that says this: "Many people eat salmon regularly because of the health and nutritional benefits associated with the intake of omega -3 fatty acids present in salmon. However, results of a quantitative benefit -risk analysis for farmed and wild salmon presented by Form et al. (13) suggest that these benefits, primarily the possible prevention of sudden cardiac death, may be outweighed by health risks of consuming contaminated farmed salmon. This comprehensive analysis revealed that exposure to dioxins and dioxin -like compounds associated with even modest consumption of farmed salmon poses elevated cancer and noncancer health risks including neurodevelopmental, immune, and endocrine - disrupting effects that may, occur at lower concentrations" htti)://www.puresalmon.orci/iproblem.ht I "All along the Norwegian coastline genuine wild salmon stocks are declining or disappearing from more and more rivers " - -2012 analysis of Norwegian management practices by the Iceland -based North Atlantic Salmon Fund hftp: / /www nastworldwide com /latest- news /nasf- takes - the - fight -to- save -the- atla ntic -sa I mo n -to -n orwa v/ From Anne Mosness presented a program on genetically engineered salmon at QUIMPER GRANGE at 7:30 APRIL 1. This is the NEXT issue that will happen in fish farming if it is approved by the FDA: These articles provide arguments against GE salmon, need for labeling, impacts on wild fish and fisheries. More voices are needed, as transgenic salmon will likely be approved and may be produced in the US, and especially in the NW. Article in Cascade Weekly 3 -13 -2013 Tampering with our Future, Genetically engineered fish, the FDA and labeling GE/GMOs foods http://www.cascadiaweekly.com/currents/genetically engineered fish the fda and labeling ge gmo foods Radio program on AM930, 3-11 -2013: "Wild fish advocate Anne Mosness discusses efforts to ban genetically altered fish or at the very least force labeling of gmo's. htti)://www.kqmi.com/l)lay window. php ? audioTvpe= Episode &audioId= 6276344 Article in Common Ground, March 2013 "Frankenfish, Tampering with Pandora's box" http://www.soi)digitaledition.comlcommonground/#/22 Linda Sutton Cape George From: James C. Tracy pctesg2002 @yahoo.comj Sent: Monday, April 15, 2013 12:42 PM HEARING '=a14,> R To: jeffbocc Subject: Public Hearing Comment - Proposed Salmon Net Pen Regulations in LASMP Gentlemen - Please accept these comments into the record of proceedings for the "Special Meeting" to be held this evening regarding proposed changes to the Locally Approved Shoreline Master Program (LASMP) regarding the regulation of salmon net pens. As the Staff Report indicates, (the Washington State Department of ) "Ecology will not support the outright prohibition of a water- dependent use in shoreline jurisdiction, and concluded the County had not provided adequate scientific rationale for such a prohibition ". In response, Jefferson County now proposes to allow (in water) salmon net pens, subject to detailed criteria, in relatively limited /restricted shoreline environmental designations (SEDs) while continuing the prohibition of such uses in specifically identified geographic areas, including all of Hood Canal. According to the "Jefferson County Rationale" section of the proposed change to the LASMP, the prohibition of (in water) net pens is these identified areas "...would (also) apply to ensure protection of sensitive habitat areas and areas with degraded water quality." No scientific or technical foundation is presented to substantiate the treatment of all of Hood Canal as an area of "sensitive habitat" or "degraded water quality ". To the contrary, Hood Canal has long been clearly described as being composed of areas with distinct morphological and tidal characteristics with particular reference to "southern" and "northern" Hood Canal (north of the well identified sub - surface "sill' located south of Bangor). In fact, the recently completed EIS for the Bangor Explosive Handling Wharf (EHW -2) specifically identifies water quality characteristics in northern Hood Canal as " similar to the physical, chemical, and biological conditions of Puget Sound rather than southern Hood Canal'. (EHW -2 FEIS at 3.1.1.2 at page 3.1.9) Therefore, in light of specific recent scientific /technical evidence that "northern" Hood Canal does not generically present "sensitive habitat' or "degraded water quality ", the outright prohibition of (in water) salmon net pens should be stricken from any proposed changes to the LASMP. Rather, salmon net pens should be allowed in "northern" Hood Canal pursuant to the same criteria (acceptable to the Department of Ecology) that would be applicable to other areas of Puget Sound within the jurisdiction of the Jefferson County SMP. Sincerely, James C. Tracy, WSBA #15656 Land Use Counsel Hood Canal Sand & Gravel LLC ieffbocc Tr' From: Dave Woodruff [doodruff @cablespeed.com] Sent: Monday, April 15, 2013 2.57 PM To: Undisclosed- Recipient.; H l Subject: Salmon Confidential- the Documentary r • ; -• �,. 4, Almost a quarter century ago I, as a member of the regional Marine Environmental Consortium and the local Oak Bay Coalition, and other activists were concerned about salmon diseases attributable to the Atlantic salmon eggs being imported from Europe for the net pen industry. We spent much time, effort and money in an attempt to inform the public and the policy makers about the dangers to native salmon represented by the industry. We were limited in our success and both organizations are presently defunct. Now the wolf is at the door. This startling 70 minute documentary featuring the dedicated and timely work of Canadian Alexandra Morton, a former affiliate of the MEC, demonstrates with combined scientific research and civic activism that the threat that was real at the outset of the industry is even more real today. Three serious salmon diseases genetically linked to Atlantic salmon eggs seriously threaten the survival of native salmon runs in Pacific Northwest waters. The situation is critical! Please invest the time to view the film and forward it to others. Thanks! Dave Woodruff http: / /salmonconfidential.ca/ From: Ancestral Spirits Gallery [omnibus @olympus.net] Sent: Monday, April 15, 2013 5:47 PM To: jeffbocc Subject: fish pens Gentlemen: I have had some time today to digest more information surrounding control over the fish pens, and wish to thank you, Commissioners Johnson and Sullivan, for endorsing Kevin VanDeWege s bill. Apparently control is in the state's hands right now, but I greatly value your efforts on behalf of the commons. sincerely, Annette Huenke Port Townsend jeffbocc RD From: Deborah Pedersen [deborahgpedersen @yahoo.com] Sent: Monday, April 15, 2013 5:18 PM To: jeffbocc Subject: SMP comment Honorable Gentlemen: I am deeply concerned about the delay in implementing Jefferson County's Shorelines Master Program. I would be very happy to see a resolution of the issue of finfish netpen aquaculture that will allow Jefferson County to prohibit this activity, as Whatcom County has done. I believe a prohibition would be the best way to prevent danger to our extremely valuable and ecologically necessary native fish runs. I have learned quite a bit about the Department of Ecology's position on this issue. I see the DOE as behaving like a huge, ocean-going vessel that cannot be stopped or turned without a great deal of power and time. The DOE is also behaving like a Supreme Court relies on the precedents it has set during the last two decades; however, it seems to be a court to which we are prevented from making an appeal. This February, I heard members of the House Governmental Operations Committee express concern that consideration of HB 1599, which would have allowed our County to prohibit netpens, "should not become political." This sounds to me as if they wished to thwart the democratic process. Public concern about the dangers posed by open -water netpens is growing, as I believe it should. Ideally, our Governor will use his power to stop the vessel. If Governor Inslee were to impose a moratorium until science newer than that on which DOE relies can be evaluated, I would feel that our local waters were safer. Lacking legal authority to prohibit open -water netpens and absent a moratorium, we are left with only one way to implement our SMP, with all the other protections it provides: strict conditional use permit requirements. I appreciate the work you have done to bring the SMP so close to implementation and I hope you can craft a reasonably satisfactory solution to the protection of our native salmon. Deborah Pedersen 131 Rose Street Port Townsend, WA 98368 011 4. f ieffbocc From: PatG [patg @cablespeed.com] Sent: Monday, April 15, 2013 5:13 PM To: jeffbocc Subject: Comment Period Finfish Aquaculture Attachments: SMP Letter 041513.docx REARMv] RK"AYD Thank you for the opportunity to comment on this important issue. We are submitting this to you via email and also the signed letter delivered to the county courthouse today. Patti Sahlinger, Secretary Beckett Point Fishermens Club April 15, 2013 TO: Jefferson County Commissioners Re: SMP - Comment Period on Draft Finfish Aquaculture Provisions The Board of Trustees, on behalf of the 156 members of the Beckett Point community, wishes to express concerns about locating any in -water finfish aquaculture in Jefferson County waters. We would like to reiterate our position, as stated in a letter of July 25, 2011, supporting the need for plant aquaculture. However, we do not support in -water finfish aquaculture. Realizing the potential problems associated with concentrated sources of antibiotics, processed feed, fish waste and non - native species, it is imperative our waters be protected. We are very concerned about water quality and the effect finfish farms could have on native Pacific salmon. We further request that finfish aquaculture be returned to "Uses and Activities Prohibited Outright' instead of "Requires Conditional Use Approval" until more is known. In conclusion, we support an outright ban on finfish aquaculture until these concerns are sufficiently addressed. Signed, President Dick Cable Beckett Point Board of Trustees From: Kevin Bright [KevinB @IcicleSeafoods.com] Sent: Monday, April 15, 2013 5:01 PM To: jeffbocc Cc: jste461 @ecy.wa.gov, 'ZHiatt @GrahamDunn.com' Subject: American Gold Seafoods Comments draft Finfish Aquaculture provisions Attachments: Jeffco BOCC Comments April 15 2013.pdf From: Kevin and Kelley Bright [mailto:kjbright(@comcast.net) Sent: Monday, April 15, 2013 4:56 PM To: Kevin Bright Subject: American Gold Seafoods Comments draft Finfish Aquaculture provisions American Gold Seafoods comments on proposed leffco SMP provisions. Thank you. Kevin Bright From: Michelle McConnell [ mai Ito: mmcconnell@co.jefferson.wa.us] Sent: Wednesday, March 27, 2013 1:48 PM To: Michelle McConnell Subject: SMP: Comment period on draft Finfish Aquaculture provisions Greetings Interested Parties, Legal notice published today (link) opens a formal comment period on the Public Review Draft— Revised Response to Ecology: In -water Finfish Aquaculture Required Changes #13 -15. After lengthy consideration, the Board of County Commissioners proposes a limited allowance of this shoreline activity subject to a conditional use permit, with specific geographic limitations and performance standards to be met by any new proposal. A supplemental Summary & Maps of SED Allowance is also provided to help describe where the activity might be allowed to locate; this document is informational only and not proposed to be included as part of the SMP. Materials are available online at the State Review & Approval webpage or at the Department of Community Development office (621 Sheridan St., Port Townsend, WA 98368). Written comments may be submitted to: • jeffbocc @co.iefferson.wa.us; or to • BoCC— SMP Comments, PO Box 1220, Port Townsend, WA 98368 The comment period will close at the end of a public hearing on the matter, to be held on Monday, April 15, 2013, 6:00 pm, at the County Courthouse — Superior Court Room. Submittal of duplicate comments is not encouraged as it slows the staff process to collate and review public input. Thanks for your continued interest, Michelle Michelle McConnell, Associate Planner Long Range Planning Lead 1 Shoreline Master Program Update Project Manager Watershed Stewardship Resource Center Project Manager Jefferson County Department of Community Development MAIL 621 Sheridan St., Port Townsend, WA 98368 DIRECT 360.379.4484 1 MAIN 360.379.4450 1 FAX 360.379.4473 WEB www.co.*efferson.wa.us/commdevelopment OFFICE OPEN: Monday - Thursday 9:00 am - 4:30 pm MISSION: To preserve and enhance the quality of life in Jefferson County by promoting a vibrant economy, sound communities and a healthy environment. All e-mail sent to this address will be received by the Jefferson County e-mail system and maybe subject to Public Disclosure under Chapter 42.56 RCW and as such may be viewed by parties other than the intended recipient. ASAVE PAPER - Please do not print this e-mail unless absolutely necessary PO Box 669 Anaeortes, WA 98221 Phone: (360) 293 -9448 Fax: (360) 293 -0558 Commissioner John Austin, Chair Jefferson County Board of Commissioners 1820 Jefferson Street Port Townsend, WA 98368 April 15, 2013 RE: Public Comment on the Jefferson County "Draft- Revised Response to Ecology: In- water Finfish Aquaculture Required Changes #13 -15" and "Summary & Maps of SED Allowance." Dear Commissioner Austin and fellow Board Members: American Gold Seafoods ( "AGS ") would like to submit comments regarding the Jefferson County "Draft- Revised Response to Ecology: In -water Finfish Aquaculture Required Changes #13 -15 and Summary & Maps of SED Allowance." As you know our company, American Gold Seafoods is a Washington based marine aquaculture company that has been raising and producing fresh salmon from its' marine net pen sites in Puget Sound for over 30 years. For that reason, we are both very interested in the County's proposed draft aquaculture provisions, and believe we can offer specific knowledge and perspectives for the County's use in guiding this document. We continue to extend an invitation to meet with you to answer any further questions you may have about finfish aquaculture at your convenience. As you may know, American Gold Seafoods owns all of the commercial marine salmon net pens in Puget Sound, which produce approximately 15 million pounds of fresh salmon annually. Our company directly employs over 80 full time people, and another 240 people indirectly through the many support businesses and services we engage. Local businesses such as fish processors, contracted marine vessels, boat builders, net manufactures, marine equipment suppliers, hardware stores, packaging companies, marine repair shops, and trucking companies, all support our successful finfish aquaculture operation. Additionally, through the economic activities generated from our business, tax related revenues bring value to numerous local, state and federal entities. Our business is proud to be supporting local and sustainable jobs in the small communities we operate in, while at the same time producing fresh and wholesome Washington grown salmon for the domestic seafood market. Over the past several years, we have watched with interest as local county planning and development departments have begun the process of updating their SMP's. We very much appreciate the hard work that has been carried out by Jefferson County to get it to this point. As you are likely aware, the SMP update process requires the balance of allowing for consideration of future beneficial uses and developments in the shoreline area, while also ensuring there are appropriate protections for the ecological functions of the same shorelines. In the Shoreline Management Act ( "SMA "), the State of Washington recognizes the importance of creating a balanced approach towards future planning and land use regulations. The SMA states this in the General Policy Goals (WAC 173 -26 -179), "The unbridled use of shorelines ultimately could destroy their utility and value. The prohibition of all use of shorelines also could eliminate their human utility and value. Thus, the policy goals of the Act relate both to the utilizationand protection of the extremely valuable and vulnerable shoreline resources of the state." This clear policy direction demonstrates the SMA was crafted to allow both the thoughtful utilization of this valuable resource, while also protecting it from significant ecological degradation. The marine fin fish aquaculture industry is fundamentally reliant upon having access to clean water, and in the maintenance of a healthy marine ecosystem to produce a healthy seafood product. In other words, you can't grow healthy fish in a polluted environment. Additionally, it is impossible for the industry to grow fish in a regulatory environment that becomes polluted with redundant regulations, or ones based on obsolete or incorrect information. With over 30 years of experience growing fish in Puget Sound, we strongly believe that finfish aquaculture is a water dependent use that is being well regulated and carried out correctly. Additionally, there is a growing body of science that shows finfish aquaculture is being accomplished in Washington State without significant ecological impacts or risks. Our position is that finfish aquaculture in Washington can be a sustainable use that should be fostered in local SMP's, rather than being inhibited by duplicitous, purposefully confusing and obstructing regulations based on politics rather than science. Correctly regulated, the aquaculture industry in Washington can create local seafood products, local employment opportunities, generate state- wide economic activity and tax revenues, and sustain viable working waterfronts without adverse ecological impacts. The policy section (Article 8.2.A.1 and 3), of the Jefferson County draft SMP states that: Aquaculture is a preferred, water - dependent use of regional and statewide interest that is important to the long -term economic viability, cultural heritage and environmental health of Jefferson County. When properly managed, aquaculture can result in long -term ecological and economic benefits. The Washington Department of Ecology administers the SMA. Ecology's SMA guidelines require locally adopted SMP's to be both scientifically defensible and realistic regulations for the protection, and the uses, of the state's shorelines. Marine finfish aquaculture is by no means an uncontrolled use of the marine environment. It is actually highly regulated, and undergoes an extremely rigorous environmental permitting process for any new project proposals. There are more than sufficient local, state and federal regulations in place that are ensuring protection of the ecological functions of our state shorelines. Redundant, confusing or overreaching regulations written into local SMP's disingenuously impedes a water dependent use of statewide interest. American Gold respectfully suggests the following regulations in the draft Jefferson County Revised Response to Ecology: Required Changes 913 -15 be changed to bring them more in line with current state, and federal regulatory frameworks for these types of activities. The County's draft document however appears to rely on outdated information, incorrect information, and a general misunderstanding of the current regulatory structure for both private, and public finfish aquaculture operations in Washington State. It is our opinion that it is beyond making minor changes and corrections to the existing draft document as currently written and by the County to bring it into compliance with the intent of the State's SMA. Article 2 Definitions -I. 17 In -water finfish aquaculture. 1.17. In -water finfish aquaculture means the farming or culture of vertebrate or cartilaginous food fish for market sale when raised in facilities located waterward of the ordinary high water mark in freshwater or saltwater water bodies, in either open -flow or contained systems. This includes net pens, sea cages bag cages and similar floating/hanging containment structures and is intended to reflect the definition of 'marine finfish rearing facilities' (RCW 90.48.220), but does not include temporary restoration /enhancement facilities used expressly to improve populations of native stocks. Comment: Delete the section of last sentence, "but does not include temporary restoration, enhancement facilities used expressly to improve populations of native stocks. " State, Tribal and public and private finfish aquaculture facilities are all required to meet the same state and federal regulatory standards with regards to finfish aquaculture regulations. Exempting one segment of them by trying to redifine them as something else is not valid or scientifically defensible. A temporary restoration /enhancement fish rearing (finfish aquaculture) facility uses the same type of rearing units, fish feeds and animal husbandry techniques as a commercial net pen finfish facility. If an In -water net pen, sea cage, or similar floating/hanging containment structure that holds, raises, feeds and artificially propogates the fish in a man -made environmet is not considered "In -water finfish aquaculture," then what exactly is it? The County's definition is based on the false premise that there is something significanity different between temporarily raising a fish in a net pen and then releasing it for enhancement purposes, and the raising of a fish in a net pen and then harvesting it directly as a food fish. Article 8.2.A. Policies- #13. 13. The County should prefer in -water finfish aquaculture use and development that operates with fully - contained systems that treat effluent before discharge to local waters over open net pen systems. Comment: Delete entire number 13. The statement implies that there are fully- contained systems available that are comparable to "in water systems" and represent an alternative. This is not the case for In -water finfish aquaculture facilities, or for any other types of marine seafood facilities that produce harvestable amounts of biomass. There are upland shellfish hatcheries and upland fish hatcheries that can treat effluent before discharge to local waters, but neither "fully contained" type of production system can cultivate harvestable volumes of seafood necessary to make them economically viable as a food production system. The issue of contained floating systems and /or upland finfish aquaculture production systems, compared to in -water net pen aquaculture facilities was brought before the Washington State Pollution Control Hearings Board ( "PCHB "). The PCHB issued an Order of Partial Dismissal, concluding that upland alternatives and floating contained systems do not constitute currently available, known, and technologically reasonable treatment (AKART) for net pens. Currently, there are no technologically viable alternatives to in water net pen production facilities that are reliable or economically achievable. Stating a preference for something that is in all practicality, a non - existent alternative does not make sense. Article 8.2.C. Shoreline Environmental Regulations- #3 3. Natural: Aquaculture activities, except for geoduck aquaculture, may be allowed subject to policies and regulations of this Program. Geoduck aquaculture may be allowed with a conditional use permit (C(d)). Finfish aquaculture is prohibited except in -water finfish aquaculture may be allowed with a conditional use permit (C(d)) where the area within the County's jurisdiction extends seaward more than eight (8) miles from the OH WM, as measured perpendicularly from shore. Comment: Delete the last sentence of number 3. This sentence in Shoreline Environmental Regulation #3 is confusing, suspect and scientifically not justifiable. The proviso that finfish aquaculture is prohibited everywhere in the Natural designation, except in an area that meets some confusing and arbritrary geographical deliniation, likely resulting in allowing finfish aquaculture in an unrealistic sliver of water amounts essentially to a ban. This appears to be similar to a previous version of the SMP where the county proposed a few some areas for finfish aquaculture, such as in marinas, harbors and shallow bays, that would not be biologically, or environmentally suiteable for the health of the reared fish stocks or the commercial viability of the operators. The County's draft response to Ecology is to propose that In -water Finfish aquaculture be prohibited in the following Environmetal Designations; Priority Aquatic, Conservancy, Shoreline Residential. Additionally it proposes to prohibit finfish aquaculture in the following specific areas: B. Uses and Activities prohibited Outright 1. In -water finfish aquaculture use /development, including net pens as defined in Article 2, shall be prohibited in the following areas due to established habitat protection designations and or water quality issues: a. Protection Island Aquatic Reserve or within fifteen hundred feet j1,5001ofthe boundary,' b. Smith and Minor Islands Aquatic Reserve or within fifteen hundred feet (1,500') of the boundary; c. Discovery Bay, south of the boundary of the Protection Island Aquatic Reserve; d. South Port Townsend Bay Mooring Buoy Management Plan Area: and e. Hood Canal, south of the line extending from Tala Point to Foulweather Bluff, including Dabob and Tarboo Bays. In one (of the only two) Environmental Designations that the County is proposing to allow the consideration of a finfish aquaculture CUP applications (with the "discretionary" criteria) is in High Intensity Environmental designation areas. High Intensity areas are unlikely to have adequated water quality or environmental parameters to allow for commercially raised fish to survive in, and they are likely to have significant other user conflicts, such as commercial or recreational navigation. Both will likely result in no permits ever being issued for net pens in the High Intensity Environmental designation. Again, the County proposes to allow the use, but then indirectly denies it by restricting the possible locations to environmentally marginal areas. Directly or indirectly, the defacto prohibition by the County is in conflict with the Shoreline Management Act which requires allowance for water- dependent uses to be included in the SMP. The term "allowance" as used in the SMA implies that an area set aside for consideration of that allowed use would actually be appropriate, tolerable and satisfactory for the intended use. Allowing for a use in areas that can not actually support the intended use is just another way of prohibiting it. The other Environmental Designation area that allows an "X * /C(d)," process to occur is in the Natural designation. As stated above, the special definitions of that area that are given in Article 8.2.C.3 are both confusing and arbritrary. This too, is likely to result in no new proposals for a finfish aquaculture project from ever occuring in these Natural designated areas. There are likely very few areas of water that would meet the County's definition, ( "where the area within the County's jurisdiction extends seaward more than eight (8) miles from the OHWM, as measured perpendicularly form shore "), and that would be appropriate for a floating finfish aquaculture facility. Add to this the other provisions in the County's draft response to Ecology, such as the limit of "one facility per square nautical mile," and you are talking about a very area that there is an allowance for this use. Again, the County intends the applicant "to fit a camel through the eye of a needle" with the over - reaching and unsupported conditions it is proposing that will restrict reasonable consideration of a water - dependent use. The appropriate locations of a new aquaculture proposal should be based on site specific information provided by the applicant, and vetted throughout the entire environmental permitting process. The County should be willing to allow the Conditional Use process to honestly and fairly go forward, and use the information and expertise of scientists and environmental consulting firms to figure out if the proposal represents the potential for significant ecological harm, or that just maybe, an area can sustain a proposed and preferred water dependent use. Writing confusing, and arbitrarily based restrictions for a CUP permit over vast areas of public waters, and then prohibiting the use outright in the majority of the other areas, is just a round about way of banning net pens in the County. The appropriate location of a facility should be left to site specific evaluations, environmental assessments, computer modeling analysis and then vetted through the entire permit process by the numerous resource agencies involved. The existing in -water finfish aquaculture permit process is designed to help ensure that a facility is located in the proper area and that it can be operated with minimal impact to the surrounding environment. There are a multitude of regulatory monitoring, reporting and operational conditions that restrict the types of activities that can be carried out at these facilities. Additionally, there are distinct impact limitations designed to keep the facility in balance with the surrounding environment and corrective requirements if they become out of balance. If a facility doesn't meet the requirements, it has to alter the operations or it will cease to exist. Properly located, permitted and managed, an aquaculture facility can create long term local economic opportunities, local jobs, locally grown food sources, and support nearby marine related businesses in rural communities. D. Regulations- General 5.v. struetHrpy 6m4 99goeiWe Comment: There is no ecological basis for a blanket height restriction of six (6) feet above the surface of the water. The height limit of 6' appears to be an arbitrary number with no meaningful basis other than to be an impracticably low number that is overly burdensome to the normal operation of many types of floating aquaculture facilities. As an example, a modern marine net pen walkway is typically about three (3) feet above the water's surface to begin with. This leaves only three (3) more feet for the additional "associated equipment" such as feeding machinery, hand railings for employee safety, or any typical support equipment for the aquaculture operation and its' employees. The county does not place a 6' height restriction on any of its' recreational or commercial boat marinas, or on any other types of water dependent uses, so why is it placing this limitation on floating/hanging aquaculture? If visual impacts are a concern, those are site specific and should be addressed on a case by case basis during the initial SEPA process and during the SSD /CUP application process. The County already has the ability to require a visual analysis be prepared by the applicant, (D. Regulations- 6), that would identify, address and allow for the mitigation of any potential visual impacts or use conflicts. A blanket, and arbitrary height restriction of 6' for all floating /hanging aquaculture is overly restrictive and unfairly applied with regard to other similar water dependent uses. We suggest removing the entire Regulation #5.v., as potential visual impacts are addressed in Regulation 46. This is a more appropriate means of identifying the site specific visual impacts and developing measures necessary to address any concerns. E. Regulations — Finfish 1. The culture of finfish, including net pens as defined in Article 2, maybe allowed with a discretionary conditional use approval (C(d)) subject to the policies and regulations of this Program. The following standards and criteria apply for all in -water finfish aquaculture use /development, per the recommendations of the 1986 Interim Guidelines (Weston /SAIL), the 1986 Aquacuiture Siting Study (EDAW Inc.), the 1988 Use Conflict Study (Boyce), and the 1990 Final Programmatic Environmental impact Statement - Preferred Alternative (Parametrix). In the event there is a conflict between these requirements the more restrictive shall prevail. Upon availability of any other subsequently state - approved guidance, the more protective requirements shall prevail. Comment: Delete E. Regulations #1 above. Replace with the following: In evaluating conditional use proposals for in -water finfish aquaculture use /development the County will consider how the proposed activity is currently regulated by the state and federal agencies with jurisdiction over in -water finfish aquaculture. The County will use the most recent re u�y information from these agencies to ensure that the provisions of this Program are being met and that the proposal meets all required state and federal water quality and aquaculture compliance standards. The County is proposing to evaluate conditional use proposals for new in -water finfish projects using documents and information from a report written to the Department of Ecology nearly 30 years ago. The 1986 Interim Guidelines were just that, interim, temporary, short-term recommendations based on the currently available information at that time. The cover letter attached to the 1986 Interim Guidelines by the Department of Ecology even states, "The guidelines are not designed to be adopted state regulations." The temporary recommendations were based on a very incomplete record, with rudimentary amounts of information about a new type of aquaculture that was just beginning to evolve. Prior to 1980, the idea of a private company cultivating finfish in a floating marine net pen structure was a completely foreign concept to most people, and especially to county planning departments. During the 1980's when applications for new marine net pen facilities began to show up, very few local governments had any idea of how this activity fit into their existing land use regulations. The 1986 Interim Guidelines were very quickly put together to provide some assistance to counties at the time. They were temporary guidelines until Ecology, and the other regulatory agencies could gain more knowledge and scientific information about the potential impacts these facilities may have, and then develop appropriate monitoring requirements and regulations to address the issues. Ecology formed a scientific advisory committee to develop new sediment management standards for the marine net pen industry; developed a new net pen NPDES permit system; created performance based monitoring standards; set discharge limitations; added reporting requirements; and developed other environmental regulations that govern this industry's activities. The NPDES issued to the net pen operators was extensively litigated in front of the Pollution Control Hearings Board ( "PCHB "). Every environmental concern brought forward by the appellants was heard by the PCHB and the majority of these issues were dismissed and the permits upheld. Ecology has added additional new monitoring and reporting requirements to these permits since they were issued over 15 years ago. The NPDES permits that are issued and administered by the Department of Ecology are the most relevant and currently available "state - approved guidance documents' and are based on the proper rules and regulations that the County should be relying upon for addressing any environmental concerns. Since the 1986 Interim Guidelines were written, the net pen industry has changed dramatically. New technological advances, new aquaculture equipment and constant research into improved aquatic farming methods and environmental monitoring have all greatly reduced the potential for environmental impacts. Over the past 27 years, there has also been a significant amount of new scientific research performed on the various aspects of net pen farming around the world, and very specific, peer reviewed risk assessments with regard to the Washington net pen industry in Puget Sound. Those biological assessments were performed by the federal agencies charged with protecting the marine environment, endangered species and the fisheries of the United States. They point to the fact that current existing regulations mitigate the potential risks of finfish aquaculure and that a properly regulated and managed net pen industry poses little risk to the ecological functions of Puget Sound. The current body of knowledge about in- water finfish aquaculture has expanded significantly and shaped the current regulatory structures, the best management practices, and the environmental monitoring that now govern how the industry operates. The 1986 Interim Guidelines are obsolete, and holding a rapidly evolving industry to guidelines written 30 years ago negates the new scientific knowledge, and the regulatory structures that have developed since that time. There are sites in Puget Sound that have been operating for well over 30 years now that have continually passed every benthic impact monitoring test performed. The NPDES permits require performance based monitoring of the sediments around fish pens that test for organic waste build up, and for other environmental impacts. If a site cannot meet the performance based monitoring standards set forth by the discharge permits, then the facility is required to reduce the standing biomass. Any new net pen applicant would look very closely at the tidal current velocities, and the depth and substrate characteristics of the potential site to ensure that the facility can be operated sustainably, in balance with the natural environment, and remain in compliance with these performance standards. The siting of a new net pen facility requires the environmental review and approval by numerous agencies that will look at the potential site specific impacts, and then determine whether the physical characteristics of the project area, the proposed facility size, and the regulatory monitoring are in place to ensure that no significant ecological impacts occur. The County's proposed response to Ecology and the exhaustive reiteration of existing regulations is both embarrassing and disconcerting, as the County tries to regulate the regulations. The following material describes the current environmental review process and the permits required for any new marine finfish aquaculture proposal in Washington State. It is outlined to show the multiple environmental regulatory safeguards that are already in place to ensure the proper siting and the proper operation of floating finfish aquaculture operations: Shoreline Substantial Development Permit / Conditional Use Permit (Local Counties /Cities) The local county or city in which a new net -pen facility plans to operate is responsible for issuing a Shoreline Substantial Development Permit (SSDP) under the Shoreline Management Act. The SSDP allows for the construction and operation of the net -pen facility and any associated structures. The local jurisdiction also issues a Conditional Use Permit, which allows site - specific issues to be mitigated and minimized through the placement of specific conditions on the issuance of the SSDP /CUP. For example, conditions on a SSDP /CUP may address lighting or noise limitations to ensure compatibility with nearby upland uses. The Department of Ecology ( "Ecology ") performs the final review of all types of shoreline permits issued by the local agency to ensure any environmental concerns are adequately addressed. State Environmental Policy Act (SEPA) review and determination. A proposed new net pen aquaculture facility requires a SEPA threshold determination and, if necessary, a full environmental analysis to evaluate impacts and identify required mitigation. Joint Aquatic Resource Permit Application (Various Agencies) A new finfish aquaculture facility is required to submit a Joint Aquatic Resources Permit Application (DARPA) to all agencies involved in the permit process related to the use of state or federal waters. This process facilitates agency coordination in addressing the overall potential impacts of a proposed development project. The JARPA creates a public process, numerous agency notifications and a thorough permit review process by state, local and federal agencies, Tribal resource agencies, and interested groups and citizens. U.S. Army Corps of Engineers Section 10 Permit (Various Agencies) Any federal permit approval requires an Endangered Species Act (ESA) review and Section 7 consultation with the National Marine Fisheries Service (NMFS), the U.S. Fish and Wildlife Service (USFWS) and Tribal governments with respect to any potential impacts on endangered species in the project area. A Biological Assessment/ Biological Evaluation (BABE) of the proposed project must be performed by an approved consulting firm with expertise in the fisheries, aquatic biology and/or habitat conservation fields. The BABE analyzes the project with a specific focus on the potential impacts of the project on ESA listed species in the area. The applicably expert agency (USFWS and NMFS) reviews and approves the BABE. The federal Coastal Zone Management Act requires that all projects in the coastal zone be certified by the Department of Ecology before a federal agency such as the Corps of Engineers grants its permits. This certification ensures that federally- permitted projects are consistent with the state Coastal Zone Management Program, which has federal approval. This applies to all shoreline activities in or affecting Washington's 15 coastal counties. Washington Department of Fish and Wildlife Aquatic Farm Permit and Registration (WDFW) • Registration is required with WDFW for each individual aquatic farm location and the type of species being reared within the State. The registration requires annual renewal and quarterly reports on the production from the facility. Aauaculture Finfish Permit (WDFW) ■ WDFW has the authority to approve, deny or condition the type of aquaculture finfish species being reared in a facility. WDFW considers the specific facility location, the type of species reared, the rearing methods, potential biological risks, best available science and the best available technology in rendering its decision. The WDFW permit requires the development of a facility operations plan that addresses Best Management Practices (BMP's), Best Available Technologies (BAT' s), and the development of Fish Escape Prevention Plans, Fish Escape Reporting Procedures and Accidental Fish Escape Recapture Plans. Fish Transport Permit (WDFW) WDFW is responsible for enforcing the fish health laws and disease control regulations within the State. Private finfish aquaculture facilities are subject to the same laws and regulations that state, and Tribal finfish enhancement hatcheries are subject to. Any findings of regulated pathogens must be reported to fish health authorities with WDFW. WDFW requires annual facility disease health certifications. Periodic health screenings of captive brood stock and smolts screen for regulated pathogens. There are very strict Washington State disease control regulations and requirements for the importation or interstate transport of live finfish and/or gametes. Additionally, the importation or interstate transfer of live finfish falls under the jurisdiction of the US Fish and Wildlife Service. Testing, certification and disease free status of the fish stocks is carried out by a Title 50 Certified Fish Health Veterinarian. National Pollutant Discharge Elimination System ( NPDES) Permit (Ecology) The Dept. of Ecology is responsible for issuing and regulating the NPDES Waste Discharge Permit under the authority of the federal Clean Water Act and Washington State equivalent An NPDES permit is required for each individual net -pen site. • The NPDES Permit sets limits on the allowable discharges from a finfish aquaculture operation in State waters and prohibits discharge of unauthorized chemicals. • The NPDES Permit requires a sampling plan with specific permit requirements be developed, including a monitoring cycle to be carried out by a third party consultant. All sediment monitoring reports are submitted to Ecology and the Dept. of Natural Resources. • Sediment monitoring of benthic impacts are carried out around a 100' perimeter from the farm sites. Impact limits are set for the organic enrichment of sediments to distinct threshold values. Mandatory mitigation and monitoring is required if sediment standards exceed the limits. Monitoring is required of any stations that exceeded the threshold limits until they return to the reference levels. • The NPDES Permit calls for the mandatory reporting of approved chemical use, reporting incidence of sea lice infestations, reporting of emergency disease occurrences and the reporting of accidental fish escapes. • The NPDES Permit requires the development and use of Best Management Practices and Best Available Technology to minimize pollution. • The NPDES permit requires the development and use of site- specific Pollution Prevention Plans, Accidental Fish Escape Prevention Plans, Fish Escape Reporting Procedures and Accidental Fish Escape Recovery Plans in coordination with WDFW. Aquatic Use Permit Application and Aquatic Lands Lease (WDNR) The State owns most aquatic lands, including tidelands, harbor areas and the sub -tidal lands of navigable waters. An Aquatic Lands Lease is required for a finfish net pen facility. Aquatic Lands Leases are issued and regulated by the Washington Dept. of Natural Resources. Aquatic Lands Leases have strict guidelines, rules and allowable use activities on the facility operations within the lease area. Leases are written to protect State resources, including ecological resources. Any vacated lease sites must have all physical improvements completely removed from them and require any contaminants be removed from them. Quarterly lease payments are based on a flat annual rate (regardless of production) plus an additional royalty amount based on the production from the facility. U.S. Coast Guard Private Aids to Navigation ( PATON) Permit • Floating structures permanently moored in the navigable waters of the U.S. must obtain a PATON permit to operate navigational lights. US Food and Drug Agenev Aquaculture facilities must comply with the rules and regulation pertaining to the production of food fish for human consumption. Only USFDA approved disease control chemicals are allowed to be used. Periodic random inspections of aquaculture products are carried out by the USFDA. Fish processing plants are inspected by USFDA and must meet current regulations. A Hazards Analysis and Critical Control Points (HACCP) plan and strict record keeping are required to be licensed to process fish products. 10 The County appears to have gone to great lengths to disallow an allowed use by writing over 12 pages of policy and regulations that pertain to Aquaculture into their proposed response draft SNIP to Ecology. It is unfortunate to think that this process has gone on for over two years, and to then read the County's proposed responses to Ecology and suggested provisions to the aquaculture section of the SMP. Jefferson County is blessed with the beauty and the natural resources that the marine shore lands and marine waters provide to all of the citizens of Washington State. Aquaculture represents a sustainable way to utilize this renewable resource when properly sited and regulated. In -water floating aquaculture may be a contentious issue for reasons beyond the scope of this letter, but one thing is for certain, it is by no means under regulated. The finfish aquaculture industry in Washington State continues to demonstrate that it can be practiced in a way that minimizes environmental impacts, while also creating opportunities for new jobs, increasing the domestic seafood supply and supporting working waterfront communities. As stated before, the SMA requires locally adopted SMP's to not only protect the shoreline environment, but to also encourage water dependent uses in that shoreline environment. Those uses include the economic, recreational and restoration activities that can create positive opportunities for every citizen of Washington State. Thank you for your consideration of our comments. Sincerely, Kevin Bright- Environmental Permit Coordinator American Gold Seafoods Cc: Ms. Michelle McConnel -DCD; Mr. Jeffree Stewart -WDOE; Mr. Zach Hiatt- Graham & Dunn LLP 11 PO Box 669 Anaeortes, WA 98221 Phone: (360) 293 -9448 Fax: (360) Commissioner John Austin, Chair April 15, 2013 Jefferson County Board of Commissioners 1820 Jefferson Street Port Townsend, WA 98368 RE: Public Comment on the Jefferson County "Draft- Revised Response to Ecology: In- water Finfish Aquaculture Required Changes #13 -15" and "Summary & Maps of SED Allowance." Dear Commissioner Austin and fellow Board Members: American Gold Seafoods ( "AGS ") would like to submit comments regarding the Jefferson County "Draft- Revised Response to Ecology: In -water Finfish Aquaculture Required Changes #13 -15 and Summary & Maps of SED Allowance." As you know our company, American Gold Seafoods is a Washington based marine aquaculture company that has been raising.and producing fresh salmon from its' marine net pen sites in Puget Sound for over 30 years_ For that reason, we are both very interested in the County's proposed draft aquaculture provisions, and believe we can offer specific knowledge and perspectives for the County's use in guiding this document. We continue to extend an invitation to meet with you to answer any further questions you may have about finfish aquaculture at your convenience. _ As you may know, American Gold Seafoods owns all of the commercial marine salmon net pens in Puget Sound, which produce approximately 15 million pounds of fresh salmon annually. Our company directly employs over 80 full time people, and another 240 people indirectly through the many support businesses and services we engage. Local businesses such as fish processors, contracted marine vessels, boat builders, net manufactures, marine equipment suppliers, hardware stores, packaging companies, marine repair shops, and trucking companies, all support our successful finfish aquaculture operation. Additionally, through the economic activities generated from our business, tax related revenues bring value to numerous local, state and federal entities. Our business is proud to be supporting local and sustainable jobs in the small communities we operate in, while at the same time producing fresh and wholesome Washington grown salmon for the domestic seafood market. Over the past several years, we have watched with interest as local county pladning and development departments have begun the process of updating their SMP's. We very much appreciate the hard work that has been carried out by Jefferson County to get it to this point. As you are likely aware, the SMP update process requires the balance of allowing for consideration of future beneficial uses and developments, in the, shoreline areawhile also ensuring there are appropriate protections for the ecological functions of the same shorelines. In the Shoreline Management Act ( "SMA "), the State of Washington recognizes the importance of creating a balanced approach towards future planning and land use regulations. The SMA states this in the General Policy Goals (WAC 173 -26 -179), "The unbridled use of shorelines ultimately could destroy their utility and value. The prohibition of all use of shorelines also could eliminate their human utility and value. Thus, the policy goals of the Act relate both to the utilizationand protection of the extremely valuable and vulnerable shoreline resources of the state. " This clear policy direction demonstrates the SMA was crafted to allow both the thoughtful utilization of this valuable resource, while also protecting it from significant ecological degradation. The marine fin fish aquaculture industry is fundamentally reliant upon having access to clean water, and in the maintenance of a healthy marine ecosystem to produce a healthy seafood product. In other words, you can't grow healthy fish in a polluted environment. Additionally, it is impossible for the ,industry to grow fish in a regulatory environment that becomes polluted with redundant regulations, or ones based on obsolete or incorrect information. With over 30 years of experience growing fish in Puget Sound, we strongly believe that finfish aquaculture is a water dependent use that is being well regulated and carried out correctly. Additionally, there is a growing body of science that shows finfish aquaculture is being accomplished in Washington State without significant ecological impacts or risks. Our position is that finfish aquaculture in Washington can be a sustainable use that should be fostered in local SMP's, rather than being inhibited by duplicitous, purposefully confusing and obstructing regulations based on politics rather than science. Correctly regulated, the aquaculture industry in Washington can create local seafood products, local employment opportunities, generate state- wide economic activity and tax revenues, and sustain viable working waterfronts without adverse ecological impacts. The policy section (Article 8.2.A.1 and 3), of the Jefferson County draft SMP states that: Aquaculture is a preferred, water - dependent use of regional and statewide interest that is important to the long -term economic viability, cultural heritage and environmental health of Jefferson County. When properly managed, aquaculture can result in long -term ecological and economic beneftts. The Washington Department of Ecology administers the SMA. Ecology's SMA guidelines require locally adopted SMP's to be both scientifically defensible and realistic regulations for the protection, and the uses, of the state's shorelines. Marine finfish aquaculture is by no means an uncontrolled use of the marine environment. It is actually highly regulated, and undergoes an extremely rigorous environmental permitting process for any new project proposals. There are more than sufficient local, state and federal regulations in place that are ensuring protection of the ecological functions of our state shorelines. Redundant, confusing or overreaching regulations written into local SMP's disingenuously impedes a water dependent use of statewide interest. American Gold respectfully suggests the following regulations in the draft Jefferson County Revised Response to Ecology: Required Changes #13 -15 be changed to bring them more in line with current state, and federal regulatory frameworks for these types of activities. The County's draft document however appears to rely on outdated information, incorrect information, and a general misunderstanding of the current regulatory structure for both private, and public finfish aquaculture operations in Washington State. It is our opinion that it is beyond making minor changes and corrections to the existing draft document as currently written and by the County to bring it into compliance with the intent of the State's SMA. 2 Article 2 Definitions -I. 17 In -water finfish aquaculture. 1.17, In -water finfish aquaculture means the farming or culture of vertebrate or cartilaginous food fish for market sale when raised in facilities located waterward of the ordinary high water mark in fresiiv, a ±e or saltwater water bodies, in either open -flow or contained systems. This includes net pens, sea cage_, bag cages and similar floating /hanging containment structures and is intended to reflect the definition if'marire finfish rearing facilities' (RCW 90.48.220), but does not include temporary restoration enhancement faclities used expressly to improve populations of native stocks. Comment: Delete the section of last sentence, "but does not include temporary restoration, enhancement facilities used expressly to improve populations of native stocks. " State, Tribal and public and private finfish aquaculture facilities are all required to meet the same state and federal regulatory standards with regards to finfish aquaculture regulations. Exempting one segment of them by trying to redifine them as something else is not valid or scientifically defensible. A temporary restoration/enhancement fish rearing (finfish aquaculture) facility uses the same type of rearing units, fish feeds and animal husbandry techniques as a commercial net pen finfish facility. If an In -water net pen, sea cage, or similar floatingd=ging containment structure that holds, raises, feeds and artificially propogates the fish in a man-made environmet is not considered "In -water finfish aquaculture," then what exactly is it? The County's definition is based on the false premise that there is something significanity different between temporarily raising a fish in a net pen and then releasing it for enhancement purposes, and the raising of a fish in a net pen and then harvesting it directly as a food fish. Article 8.2.A. Policies- #13. 13. The County should prefer in -water finfish aquaculture use and development that operates with fuI!v- contained systems that treat effluent before discharge to local waters over open net ire_,; systems. Comment: Delete entire number 13. The statement implies that there are fully- contained systems available that are comparable to "in water systems" and represent an alternative. This is not the case for In -water finfish aquaculture facilities, or for any other types of marine seafood facilities that produce harvestable amounts of biomass. There are upland shellfish hatcheries and upland fish hatcheries that can treat effluent before discharge to local waters, but neither "fully contained" type of production system can cultivate harvestable volumes of seafood necessary to make them economically viable as a food production system. The issue of contained floating systems and/or upland finfish aquaculture production systems, compared to in -water net pen aquaculture facilities was brought before the Washington State Pollution Control Hearings Board ( "PCHB "). The PCHB issued an Order of Partial Dismissal, concluding that upland alternatives and floating contained systems do not constitute currently available, known, and technologically reasonable treatment (AKART) for net pens. Currently, there are no technologically viable alternatives to in water net pen production facilities that are reliable or economically achievable. Stating a preference for something that is in all practicality, a non - existent alternative does not make sense. Article 8.2.C. Shoreline Environmental Regulations- #3 3. Natural: Aquaculture activities, except for geoduck aquaculture, may be allowed subject to policies and regulations of this Program. Geoduck aquaculture may be allowed with a conditional use permit (C(d)). Finfish aquaculture is prohibited, . except in-water finfish aquaculture may be allowed with a condi ^ai use permit IQcl)) where the area within the Count's jurisdiction extends seaward more than e g' _: miles from the OFiWNi, as measureaperpencicu _ arygom snore. Comment: Delete the last sentence of number 3. This sentence in Shoreline Environmental Regulation 93 is confusing, suspect and scientifically not justifiable. The proviso that finfish aquaculture is prohibited everywhere in the Natural designation, except in an area that meets some confusing and arbritrary geographical deliniation, likely resulting in allowing finfish aquaculture in an unrealistic sliver of water amounts essentially to a ban. This appears to be similar to a previous version of the SMP where the county proposed a few some areas for finfish aquaculture, such as in marinas, harbors and shallow bays, that would not be biologically, or environmentally suiteable for the health of the reared fish stocks or the commercial viability of the operators. The County's draft response to Ecology is to propose that In -water Finfish aquaculture be prohibited in the following Environmetal Designations; Priority Aquatic, Conservancy, Shoreline Residential. Additionally it proposes to prohibit finfish aquaculture in the following specific areas: B. Uses and Activities Prohibited uutngnt 1. In -water finfish aquaculture use /development, including net pens as defined in Article 2, sha!i prohibited in the followine areas due to established habitat protection designations and /or aate) w =.c*,- a. Protection Island Aquatic Reserve or within fifteen hundred feet 1 So0') of the bourda b. Smith and Minor Islands Aquatic Reserve or within fifteen hundred feet 11 SOOT of + ? i3 n,dat c. Discovery Bay, south of the boundary of the Protection Island Aquatic Reserve' r' South Port Townsend Bav Mooring Buov_Management Plan Area; and e. Hood Canal, south of the line extending from Tala Point to foul^ ✓eather Bluff iucimg: a5cy_and Tarboo Bays. In one (of the only two) Environmental Designations that the County is proposing to allow the consideration of a finfish aquaculture CUP applications (with the "discretionary" criteria) is in High Intensity Environmental designation areas. High Intensity areas are unlikely to have adequated water quality or environmental parameters to allow for commercially raised fish to survive in, and they are likely to have significant other user conflicts, such as commercial or recreational navigation. Both will likely result in no permits ever being issued for net pens in the High Intensity Environmental designation. Again, the County proposes to allow the use, but then indirectly denies it by restricting the possible locations to environmentally marginal areas. Directly or indirectly, the defacto prohibition by the County is in conflict with the Shoreline Management Act which requires allowance for water - dependent uses to be included in the SMP. The term "allowance" as used in the SMA implies that an area set aside for consideration of that allowed use would actually be appropriate, tolerable and satisfactory for the intended use. Allowing for a use in areas that can not actually support the intended use is just another way of prohibiting it. 4 The other Environmental Designation area that allows an "X * /C(d)," process to occur is in the Natural designation. As stated above, the special definitions of that area that are given in Article 8.2.C.3 are both confusing and arbritrary. This too, is likely to result in no new proposals for a finfish aquaculture project from ever occuring in these Natural designated areas. There are likely very few areas of water that would meet the County's definition, ( "where the area within the County's jurisdiction extends seaward more than eight (8) miles from the OHWM, as measured perpendicularly form shore "), and that would be appropriate for a floating finfish aquaculture facility. Addto this the other provisioncin the: County's draft response to Ecology, such as the limit of "one facility per square nautical mile," and you are talking about a very area that there is an allowance for this use. Again, the County intends the applicant "to fit a camel through the eye of a needle" with the over - reaching and unsupported conditions it is proposing that will restrict reasonable consideration of a water - dependent use. The appropriate locations of a new aquaculture proposal should be based on site specific information provided by the applicant, and vetted throughout the entire environmental permitting process. The County should be willing to allow the Conditional Use process to honestly and fairly go forward, and use the information and-expertise of scientists and environmental consulting firms to figure out if the proposal represents the potential for significant ecological harm, or that just maybe, an area can sustain a proposed and preferred water dependent use. Writing confusing, and arbitrarily based restrictions for a CUP permit over vast areas of public waters, and then prohibiting the use outright in the majority of the other areas, is just around about way of banning net pens in the County. The appropriate location of a facility should be left to site specific evaluations, environmental assessments, computer modeling analysis and then vetted through the entire permit process by the numerous resource agencies involved. The existing in -water finfish aquaculture permit process is-designed to help ensure that a facility is located in the proper area and that it can be operated with minimal impact to the surrounding environment. There are a multitude of regulatory monitoring, reporting and operational conditions that restrict the types of activities that can be carried out at these facilities. Additionally, there are distinct impact limitations designed to keep the facility in balance with the surrounding environment and corrective requirements if they become out of balance. If a facility doesn't meet the requirements, it has to alter the operations or it will cease to exist. Properly located, permitted and managed, an aquaculture facility can create long tern local economic opportunities, local jobs, locally grown food sources, and support nearby marine related businesses in rural communities. D. Regulations- Comment: There is no-ecological basis for a blanket height restriction of six (6) feet above the surface of the water. The height limit of 6' appears to be an arbitrary number with no meaningful basis other than to be an impracticably low number that is overly burdensome to th8 normal operation of many types of floating aquaculture facilities. As an example, a modem marine net pen walkway is typically about three (3) feet above the water's surface to begin with. This leaves only three (3) more feet for the additional "associated equipment" such as feeding machinery, hand railings for employee safety, or any typical support equipment for the aquaculture operation and its' employees. The county does not place a 6' height restriction on any of its' recreational or commercial boat marinas, or on any other types of water dependent uses, so why is it placing this limitation on floating/hanging aquaculture? If visual impacts are a concern, those are site specific and should be addressed on a case by case basis during the initial SEPA process and during the SSD /CUP application process. The County already has the ability to require a visual analysis be prepared by the applicant, (D. Regulations- 6), that would identify, address and allow for the mitigation of any potential visual impacts or use conflicts. A blanket, and arbitrary height restriction of 6' for all floating/hanging aquaculture is overly restrictive and unfairly applied with regard to other similar water dependent uses. We suggest removing the entire Regulation #5.v., as potential visual impacts are addressed in Regulation #6. This is a more appropriate means of identifying the site specific visual impacts and developing measures necessary to address any concerns. E. Reeaiations – tin-, 1. The culture of finfish incu pens as defined m Article 2. may be allowed with a aiscreuonar° conditional use approval (C(d)) subject to the polices and regulations of this Program The folio,,._. standards and criteria apply for all in -water fmnsn ac uacwture use7aeveiopment, per , - mmendations of the _7986 Interim (irk +eston /SAKI, the 1W Arugcult,jre SiNnn Ztr,4 •'r ^�tiar t e 1966, Use r,on5a uay � b �c> -;_ °C -f Frogro Imo. "— io r� .,entaf imps -_ r remen[ -Pre erred Atternotive (Parametrix; ,gin t!'.e, event there is-a co M: lct between these requirements the more restrictive snail prevail. upan avaiiaimt) of any other_subsequentiy state- approved guidances the more protective requirements ✓ ts shall prap_ Comment: Delete E. Regulations 41 above. Replace with the following: In evaluating conditional use proposals for in -water finfish aquaculture use /development the County will consider how the proposed activity is currently regulated by the state and federal agencies with jurisdiction over in -water fnfash aquaculture. The County will use the most recent regulatory information from these agencies to ensure that the provisions of this Program are being met and that the proposal meets all required state and federal water quality and aquaculture compliance 'ante standards. The County is proposing to evaluate conditional use proposals for new in -water finfish projects using documents and information from a report written to the Department of Ecology nearly 30 years ago. The 1986 Interim Guidelines were just that, interim, temporary, short-term recommendations based on the currently available information at that time. The cover letter attached to the 1986 Interim Guidelines by the Department of Ecology even states,. "Tke guidelines are not designed to be adopted state regulations. " The temporary recommendations were based on a very incomplete record, with rudimentary amounts of information about a new type of aquaculture that was just beginning to evolve. Prior to 1980, the idea of a private company cultivating finfish in a floating marine net pen structure was a completely foreign concept to most people, and especially to county planning departments. During the 1980's when applications for new marine net pen facilities began to show up, very few local governments had any idea of how this activity fit into their existing land use regulations. The 1986 Interim Guidelines were very quickly put together to provide some assistance to counties at the time. They were temporary guidelines until Ecology, and the other regulatory agencies could gain more knowledge and scientific information about the potential impacts these facilities may have, and then develop appropriate monitoring requirements and regulations to address the issues. Ecology formed a scientific advisory committee to develop new sediment management standards for the marine net pen industry; developed a new net pen NPDES permit system; created performance based monitoring standards; set discharge limitations; added reporting requirements; and developed other environmental regulations that govern this industry's activities. The NPDES issued to the net pen operators was extensively litigated in front of the Pollution Control Hearings Board ( "PCHB "). Every environmental concern brought forward by the appellants was heard by the PCHB and the majority of these issues were dismissed and the permits upheld. Ecology has added additional new monitoring and reporting requirements to these permits since they were issued over 15 years ago. The NPDES permits that are issued and administered by the Department of Ecology are the most relevant and currently available "state - approved guidance documents" and are based on the proper rules and regulations that the County should be relying upon for addressing any environmental concerns. Since the 1986 Interim Guidelines were written, the net pen industry has changed dramatically. New technological advances, new aquaculture equipment and constant research into improved aquatic farming methods and environmental monitoring have all greatly reduced the potential for environmental impacts. Over the past 27 years, there has also been a significant amount of new scientific research performed on the various aspects of net pen farming around the world, and very specific, peer reviewed risk assessments with regard to the Washington net pen industry in Puget Sound. Those biological assessments were performed by the federal agencies charged with protecting the marine environment, endangered species and the fisheries of the United States. They point to the fact that current existing regulations mitigate the potential risks of finfish aquaculure and that a properly regulated and managed net pen industry poses little risk to the ecological functions of Puget Sound. The current body of knowledge about in- water finfish aquaculture has expanded significantly and shaped the current regulatory structures, the best management practices, and the environmental monitoring that now govern how the industry operates. The 1986 Interim Guidelines are obsolete, and holding a rapidly evolving industry to guidelines written 30 years ago negates the new scientific knowledge, and the regulatory structures that have developed since that time. There are sites in Puget Sound that have been operating for well over 30 years now that have continually passed every benthic impact monitoring test performed. The NPDES permits require performance based monitoring of the sedimefAs around fish pens that test for organic waste build up, and for other environmental impacts. If a site cannot meet the performance based monitoring standards set forth by the discharge permits, then the facility is required to reduce the standing biomass. Any new net pen applicant would look very closely at the tidal current velocities, and the depth and substrate characteristics of the potential site to ensure that the facility can be operated sustainably, in balance with the natural environment, and remain in compliance with these performance standards. The siting of a new net pen facility requires the environmental review and approval by numerous agencies that will look at the potential site specific impacts, and then determine whether the physical characteristics of the project area, the proposed facility size, and the regulatory monitoring are in place to ensure that no significant ecological impacts occur. The County's proposed response to Ecology and the exhaustive reiteration of existing regulations is both embarrassing and disconcerting, as the County tries to regulate the regulations. The following material describes the current environmental review process and the permits required for any new marine finfish aquaculture proposal in Washington State. It is outlined to show the multiple environmental regulatory safeguards that are already in place to ensure the proper siting and the proper operation of floating finfish aquaculture operations: 7 Shoreline Substantial Development Permit / Conditional Use Permit (Local Counties /Cities) The local county or city in which a new net -pen facility plans to operate is responsible for issuing a Shoreline Substantial Development Permit (SSDP) under the Shoreline ManagementAct. The SSDP allows for the construction and operation of the net -pen facility and any associated structures. The local jurisdiction also issues a Conditional Use Permit, which allows site - specific issues to be mitigated and minimized through the placement of specific conditions on the issuance of the SSDP /CUP. For example, conditions on a SSDP /CUP may address lighting or noise limitations to ensure compatibility with nearby upland uses. The Department of Ecology ( "Ecology ") performs the final review of all types of shoreline permits issued by the local agency to ensure any environmental concerns are adequately addressed. State Environmental Policy Act (SEPA) review and determination. A proposed new net pen aquaculture facility requires a SEPA threshold determination and, if necessary, a full environmental analysis to evaluate impacts and identify required mitigation. Joint Aquatic Resource Permit Application (Various Agencies) A new finfish aquaculture facility is required to submit a Joint Aquatic Resources Permit Application ( JARPA) to all agencies involved in the permit process related to the use of state or federal waters. This process facilitates agency coordination in addressing the overall potential impacts of a proposed development project. The JARPA creates a public process, numerous agency notifications and a thorough permit review process by state, local and federal agencies, Tribal resource agencies, and interested groups and citizens. U.S. Army Corps of Engineers Section 10 Permit (Various Agencies) • Any federal permit approval requires an Endangered Species Act (ESA) review and Section 7 consultation with the National Marine Fisheries Service (NMFS), the U.S. Fish and Wildlife Service (USFWS) and Tribal governments with respect to any potential impacts on endangered species in the project area. • A Biological Assessment/ Biological Evaluation ( BA/BE) of the proposed project must be performed by an approved consulting firm with expertise in the fisheries, aquatic biology and/or habitat conservation fields. The BABE analyzes the project with a specific focus on the potential impacts of the project on ESA listed species in the area. The applicably expert agency (USFWS and NMFS) reviews and approves the BABE. • The federal Coastal Zone Management Act requires that all projects in the coastal zone be certified by the Department of Ecology before a federal agency such as the Corps of Engineers grants its permits. This certification ensures that federally- permitted projects are consistent with the state Coastal Zone Management Program, which has federal approval. This applies to all shoreline activities in or affecting Washington's 15 coastal counties. Washington Der>artment of Fish and Wildlife Aquatic Farm Permit and Registration (WDFW) ` • Registration is required with WDFW for each individual aquatic farm location and the type of species being reared within the State. The registration requires annual renewal and quarterly reports on the production from the facility. Aquaculture Finfish Permit (WDFW) WDFW has the authority to approve, deny or condition the type of aquaculture finfish species being reared in a facility. WDFW considers the specific facility location, the type of species reared, the rearing, methods, potential biological risks, best available science and the best available technology in rendering its decision. The WDFW permit requires the development of a facility operations plan that addresses Best Management Practices (BMP's), Best Available Technologies (BAT'S), and the development of Fish Escape Prevention Plans, Fish Escape Reporting Procedures and Accidental Fish Escape Recapture Plans. Fish Transport Permit (WDFW) WDFW is responsible for enforcing the fish health laws and disease control regulations within the State. Private finfish aquaculture facilities are subject to the same laws and regulations that. state, and Tribal finfish enhancement hatcheries are subject to. Any findings of regulated pathogens must be reported to fish health authorities with WDFW. WDFW requires annual facility disease health certifications. Periodic health screenings of captive brood stock and smolts screen for regulated pathogens. There are very strict Washington State disease control regulations and requirements for the importation or interstate transport of live finfish and/or gametes. Additionally, the importation or interstate transfer of live finfish falls under the jurisdiction of the US Fish and Wildlife Service., Testing, certification and disease free status of the fish stocks,is carried out by a Title 50 Certified Fish Health Veterinarian. National Pollutant Discharge Elimination System ( NPDES) Permit (Ecology) The Dept. of Ecology is responsible for issuing and regulating the NPDES Waste Discharge Permit under the authority of the federal Clean Water Act and Washington State equivalent. An NPDES permit is required for each individual- net -pen site; • The NPDES Permit sets limits, on the allowable discharges from a finfish aquaculture operation in State waters and prohibits discharge of unauthorized chemicals. The NPDES Permit requires a sampling plan with specific permit requirements be developed, including a monitoring cycle to be carried out by a third party consultant. All sediment monitoring reports are submitted to Ecology and the Dept. of Natural Resources. Sediment monitoring of benthic impacts are carried out around a 100' perimeter from the farm sites. Impact limits are set for the organic enrichment of sediments to distinct threshold values. Mandatory mitigation and monitoring is required if sediment standards exceed the limits. Monitoring is required of any stations that exceeded the threshold limits until they return to the reference levels. The NPDES Permit calls for the mandatory reporting of approved chemical use, reporting incidence of sea lice- infestations, reporting of emergency disease occurrences and the reporting of accidental fish escapes. The NPDES Permit requires the development and use of Best Management Practices and Best Available Technology to minimize pollution. The NPDES permit requires the development and use of site- specific Pollution Prevention Plans, Accidental Fish Escape Prevention Plans, Fish Escape Reporting Procedures and Accidental Fish Escape Recovery Plans in coordination with WDFW. Aquatic Use Permit Application and Aquatic Lands Lease (WDNR) The State owns most aquatic lands, including tidelands, harbor areas and the sub -tidal lands of navigable waters. An Aquatic Lands Lease is required for a fmfish net pen facility. Aquatic Lands Leases are issued and regulated by the Washington Dept. of Natural Resources. Aquatic Lands Leases have strict guidelines, rules and allowable use activities on the facility operations within the lease area. Leases are written to protect State resources, including ecological resources. Any vacated lease sites must have all physical improvements completely removed from them and require any contaminants be removed from them. Quarterly lease payments are based on a flat annual rate (regardless of production) plus an additional royalty amount based on the production from the facility. U.S. Coast Guard Private Aids to Navigation ( PATON) Permit ■ Floating structures permanently moored in the navigable waters of the U.S. must obtain a PATON permit to operate navigational lights. US Food and Drug Agency Aquaculture facilities must comply with the rules and regulation pertaining to the production of food fish for human consumption. Only USFDA approved disease control chemicals are allowed to be used. Periodic random inspections of aquaculture products are carried out by the USFDA. Fish processing plants are inspected by USFDA and must meet current regulations. A Hazards Analysis and Critical Control Points (HACCP) plan and strict record keeping are required to be licensed to process fish products. ID, The County appears to have gone to great lengths to disallow an allowed use by writing over 12 pages of policy and regulations that pertain to Aquaculture into their proposed response draft SMP to Ecology. It is unfortunate to think that this process has gone on for over two years, and to then read the County's proposed responses to Ecology and suggested provisions to the aquaculture section of the SMP. Jefferson County is blessed with the beauty and the natural resources that the marine shore lands and marine waters provide to all of the citizens of Washington State. Aquaculture represents a sustainable way to utilize this renewable resource when properly sited and regulated. In -water floating aquaculture may be a contentious issue for reasons beyond the scope of this letter, but one thing is for certain, it is by no means under regulated. The finfish aquaculture industry in Washington State continues to demonstrate that it can be practiced in a way that minimizes environmental impacts, while also creating opportunities for new jobs, increasing the domestic Seafood supply and supporting working waterfront communities. As stated before, the SMA requires locally adopted SMP's to not only protect the shoreline environment, but to also encourage water dependent uses in that shoreline environment. Those uses include the economic, recreational and restoration activities that can create positive opportunities for every citizen of Washington State. Thank you for your consideration of our comments. Sincerely, n � Kevin Bright- Environmental Permit Coordinator American Gold Seafoods Cc: Ms. Michelle McConnel -DCD; Mr. Jeffiee Stewart -WDOE; Mr. Zach Hiatt- Graham & Dunn LLP 11 c9n, N'V3S ,\CN effbocc IN C From: john.dentler @gmail.com on behalf of John Dentler Udentler @troutlodge.comj Sent: Monday, April 15, 2013 6:55 PM To: jeffbocc Cc: Jeffree Stewart Subject: Comments on Proposed Shoreline Master Program -- Finfish Aquaculture Attachments: Jefferson County Commissioners April 2013 SMP Comments.pdf; Attachment A.NOAA TM NMFS- NWFSC- 53.pdf; Attachment B.NOAA TM NMFS - NWFSC- 49.pdf; Attachment C.NOAA Letter to Ecology.pdf; Attachment D.Ecology Letter to Clallam Co..pdf; Attachment E.Dickhoff.Escapes &Genetics.pdf; Attachment F.Rensel. Monitoring &Tools.pdf Dear Commissioners, Attached are comments submitted by Troutlodge on the proposed Jefferson County Shoreline Master Program as it relates to finfish aquaculture. Thanks for your consideration of our comments. Sincerely, John Dentler John Dentler Director, Gov. Relations Troutlodge, Inc. Managing Partner, Troutlodge Sablefish LLC 8920 Franklin Avenue Gig Harbor, WA 98335 USA Google Voice 253 - 293 -5662 identlerna troutlodae.com www.troutiodge.com wwwAroutlodcle.cl/ A OWN � MARINE FARMS DRAFT April 11, 2013 The Honorable Phil Johnson, Jefferson County Commissioner, District 1 PO Box 1220 Port Townsend, WA 98368 The Honorable David Sullivan, Commissioner District 2 Jefferson County Commissioner PO Box 1220 Port Townsend, WA 98368 The Honorable John Austin, Jefferson County Commissioner, District 3 PO Box 1220 Port Townsend, WA 98368 RE: Comments on Shoreline Master Program Amendments Related to Finfish Aquaculture in Jefferson County Dear Commissioners: I am writing you on behalf of Troutlodge, Inc., Troutlodge Marine Farms and Troutlodge Sablefish LLC in relation to Jefferson County's efforts to draft a new Shoreline Master Program and in particular provisions regarding to finfish aquaculture. We thank you for the opportunity to provide comments on the latest revisions to the Jefferson County SMP as it relates generally to "in -water finfish aquaculture and to a more limited extent upland finfish aquaculture. We Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS support the County's goal to protect the shoreline environment, wild populations of fish and shellfish and the need for sound productive waters and shorelines. We believe the rearing of finfish, including in -water finfish production and upland finfish production, can be accomplished in a manner that is responsible and can enhance and protect the shoreline environment. We incorporate by reference our prior comments on the Jefferson County Shoreline Master Program where the intent was to completely prohibit all in -water finfish production. As noted, we clearly understand that that the County's prior intent was to effect an outright prohibition on all in -water finfish aquaculture. Although the County now includes a new policy suggestive that the County understands the importance local food production both on land and in the water -- including aquaculture, (see. Policy 8.1.A.8) -- the County now proposes many prohibitions by area as well as other burdensome and duplicative requirements for in -water finfish aquaculture which, when taken together, will likely result in the de -facto prohibition on in -water finfish aquaculture that the Department of Ecology and the Shoreline Management Act otherwise prohibits the County from effecting. We believe that this latest effort is also unlawful. We believe the record does not support many of the County's restrictions, requirements and prohibitions on finfish aquaculture by manner, methods, and area. We should note that opponents of fish culture in Canada were given ample opportunity to present their case at the Cohen Commission of Inquiry into the Decline of the Sockeye Salmon in the Fraser River. After three years, $26 million expended, after the testimony of dozens of expert witnesses, Judge Bruce Cohen stated in his final Cohen Commission report "Data presented during this Inquiry did not show that salmon farms were having a significant negative impact on Fraser River sockeye." (Final Report, Volume 3, p. 24, Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS column 2). We similarly are unaware of any data or evidence that would support a conclusion that finfish aquaculture, including net pens, is detrimental to native fish populations in Washington in Washington State, Puget Sound, the Strait of San Juan de Fuca or in the Waters of Jefferson County. The County appears to have an agenda to punish and burden commercial aquaculture operators who produce finfish for food but there appears to be no rational basis for doing so. The County's antipathy for finfish aquaculture appears evident in the County's definition of "In water finfish aquaculture" which is focused on operations that produce finfish for market sale while expressly excluding any finfish rearing which may result in "enhancement" that may improve native stocks and thus recreational fisheries.' We believe this definition and subsequent provisions limiting finfish aquaculture is irrational, arbitrary, is unsupported in the record, fails to comply with the Shoreline Management Act and implementing regulations, the Administrative Procedures Act and is unlawful. If in -water finfish production is in need of the panoply of limitations, prohibitions, limitations, and requirements set out in the proposed SMP, then these provisions should apply to any in -water finfish production, including those that may serve "enhancement" or other purposes. In short, it appears that the County's intention is to make in -water finfish aquaculture as difficult as possible and thus effect an outright ban on aquaculture through restrictions by location and manner. Troutlodge now turns to more detailed aspects of the benefits of finfish aquaculture and the regulations. 1. The County's SMP Policies and Regulations on Finfish Aquaculture including in -water finfish aquaculture will foreclose opportunities to sustainably produce healthy finfish products. Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS Fish and fish products, including those products resulting from aquaculture production, represent a healthy and wholesome food product. Many studies show that fish and fish products high in omega -3 fatty acids, which are found in high levels in salmon and black cod (sablefish)2, are vitally important for human health, including fetal development, brain development, maternal health, heart and circulatory health and many other facets of health.3 Aquaculture is the world's fastest - growing source of animal protein, according to a report published here by FAO.4 Further, aquaculture products now supply approximately one -half of all fish and fish products consumed world- wide.5 While it would be wonderful if the average consumer could afford wild fish on a regular basis, the fact is that consumers of modest means may be unable to regularly purchase wild - produced fish and fish products. We believe that the County's proposed Shoreline Master Program policies and regulations on finfish aquaculture are, in practice, a prohibition on all future finfish aquaculture in Jefferson County. The SMP, unless changed, will have an incremental negative effect on human health due to the fact that opportunities to raise healthy finfish products will be foreclosed and those products will become less available especially to consumers of modest means. 2. The County's current position on aquaculture would likely continue to drive aquaculture production offshore and exacerbate the U.S. trade deficit in seafood products. The US seafood trade deficit is, unfortunately, growing at an alarming rate. Currently, the Department of Commerce estimates that 84 percent of the seafood consumed in the U.S. is imported.6 This is due, in our opinion, to many factors, but ultimately is the culmination of production costs differences, largely labor, and regulatory burdens that make it impractical to produce seafood in the U.S. Further curtailment of the aquaculture sector through Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA � MARINE FARMS impediments such as that proposed by Jefferson County will likely drive more aquaculture production offshore. Importantly, many other countries do not implement or enforce equivalent health, safety and environmental controls as in the U.S. The adoption of policies that force aquaculture offshore and serve to increase the U.S. Trade deficit in seafood products should be thoroughly considered prior to final adoption of the proposed SMP provisions. (Figure 1, Trade deficit in US Dollars -- Billions) (Source: littp: / /www.nmfs. noaa. gov/ fishwatch /trade_and_aquaculture.htm) $16 IWl Exports 14 N Imports $12 10 $8 $6 54 $2 F'��I +I�)<►l+ Iii' �i�+ It# ��If���7iZl h��Iik�" ��I�TF��I�3riFI '}I� }:��I�Ik�"��3 [�] Before moving to substantive matters I'd like to tell you a bit about Troutlodge. 3. Troutlodge has a successful history in Washington where we provide jobs, support the tax base and provide healthy fish and fish products for anglers and consumers. Troutlodge has been in the trout egg production and sales business for over 65 years. We annually produce and sell nearly 500 million live salmon eggs to Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS nearly 60 countries on 5 continents. For this reason, our welfare and that of our employees is dependent on the ability to export disease -free trout eggs around the world. In addition, we produce catchable trout which are produced for the Washington Department of Fish and Wildlife (WDFW) for its trout fishery program and, through Troutlodge Sablefish, we produce black cod (sablefish) in Jefferson County and sell the resulting fry to companies that, in turn, raise them in Puget Sound and Canada. We employ 60 workers in Washington where we operate 9 facilities (Enumclaw, Winchester, Tacoma, Soap Lake 1 and 2, Orting, Rochester, Hoodsport, Brinnon), as well as facilities in Oregon, Idaho, Florida and Hawaii as well as facilities in the Isle of Man and Chile. We lease space at the Washington Department of Fish and Wildlife Point Whitney Shellfish laboratory where we produce black cod and oysters seed. The Point Whitney Shellfish Laboratory appears to be in a Conservancy Environment designation under the proposed SMP. We do not operate any net - pens; however, our business and employees depend on well- managed, environmentally sustainable, and vibrant net -pen farms throughout Puget Sound. Troutlodge and other companies involved in the culture of salmon, trout or marine species like black cod take many measures to maintain and operate facilities so as to prevent the introduction or spread of pathogens in our facilities. All Troutlodge facilities implement advanced biosecurity measures to prevent the introduction of diseases into our facilities. For example, visitors and employees must disinfect their shoes and hands before entering our facilities. Visitors who have been to other fish hatcheries within the past 24 hours may not enter our hatcheries. Equipment and vehicles must be disinfected prior to Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS entering our facilities, etc. Many other measures are also implemented with the goal of preventing the introduction of diseases into any of our facilities. All Troutlodge egg exports must be produced at facilities that have received Animal Health Certification from an independent veterinarian approved by the Animal Plant Health Inspection Service (APHIS), a unit of the U.S. Department of Agriculture. Further, the pathogen testing protocols must meet the requirements of APHIS. All of our fish health samples and analyses but be carried out independently rather than through our own program. Our Fish Health Surveillance and Monitoring Plan meet all the requirements of the World Organization for Animal Health (htty: / /www.oie.int/ ) and require twice annual comprehensive sampling and disease evaluation and analysis. Under the APHIS testing protocol fish tissue samples are collected by an independent veterinarian and sent to the Washington Animal Disease Diagnostic Laboratory (WADDL) at Washington State University. This protocol has been followed for many years to assess pathogens on our trout populations. We are informed by WADDL that, had the ISA Virus been present in our trout populations, the WADDL pathogen testing protocol would have detected its presence. In fact, the WADDL has never detected the presence of any viruses in our trout populations. Our black cod are similarly sampled and tested for diseases in accordance with APHIS guidelines by WADDL. We will now turn to the revised sections of the Jefferson County Shoreline Master Program. 4. The definition and use tables presented in Article 4.3 are confusing and appear inconsistent. The proposed definition 1.17 would define in -water finfish aquaculture as the rearing of fish "farming or culture of vertebrate or [fish] ...for market sale Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS when raised in facilities located waterward of the ordinary high watermark in freshwater or saltwater water bodies, in either open -flow or contained systems." In the use designation criteria, it appears that in -water finfish aquaculture would be either permitted in environmental designations denoted as "Aquatic" and either prohibited or permitted via a conditional use permit in "Conservancy" areas. Further, in -water finfish aquaculture appears to be permitted only when the adjacent upland shoreline environmental designation allows finfish aquaculture. This may be inadvertent but these two requirements would appear to effectively prohibit in -water finfish aquaculture in most locations. We are not clear how these provisions would work when taken together and believe that more clarification and change is required. For example, while in -water finfish aquaculture (including net pens) would be permitted in areas with the environmental designation of "Natural," upland finfish production would be prohibited in such areas. On the other hand, upland finfish production would be prohibited in areas with the environmental designation of "Natural" but permitted as a conditional use in areas with the environmental designation of "Conservancy ". This approach seems inconsistent. We are unaware of any sound basis or rationale for this allowing one use in one area but not the other. Based on the environmental designation maps, it appears that in -water finfish aquaculture would be available only in four small limited areas. Further, insofar as we can ascertain, there is no rational basis for the limitation on in -water net pens to those areas only where there is eight (8) miles of seawater jurisdiction. We recommend that both upland finfish and in -water finfish aquaculture be permitted as conditional uses in both the "Natural" and "Conservancy" environmental designations. Moreover, there is no reason finfish aquaculture Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS should be prohibited in areas with the residential or high intensity residential designation so long as significant adverse impacts are properly addressed. 5. Policy Provisions a. The County's proposed Policy Number 12 is duplicative, unduly burdensome, irrational, and should be revised. The Policy change proposed by the County states: 12. Finfish aquaculture that uses or releases herbicides, pesticides, antibiotics, fertilizers, pharmaceuticals,non- indigenous species, parasites, viruses, genetically modified organisms, e-r feed, or other materials known to be harmful into surrounding waters should not be allowed unless significant impacts to surrounding habitat and conflicts with adjacent uses are effectively mitigated. We support responsible aquaculture and support the spirit of this policy. However, we believe this policy makes several unwarranted assumptions, is duplicative and unnecessary and unduly, burdensome. We make note of the following: • Aquaculture operations, including finfish operations, generally must obtain and abide by requirements of National Pollution Discharge Elimination System ( "NPDES ") permits. These NPDES permits are issued under the Clean Water Act and the Washington Water Pollution Control Act. The NPDES permits limit the nature and concentration of discharges to State waters and provide for the protection of water quality and take into consideration impacts to the environment and other uses. We know of nothing in the record to support additional policies to curtail or further regulate finfish aquaculture. Where properly managed, the regulated Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS release of these items are not significant or harmful. See, e.g., Attachment C, pp. 1 -3. • Where viruses affect finfish in Net -pen culture as well as upland culture, the source of viruses is wild fish adjacent to the operation. We do not believe the internal assumption as to viruses has support in the scientific literature and would appreciate knowing the basis for any such conclusion. See Attachments A, B, C and E. We recommend the policy be rewritten as follows: Where aquaculture developments or uses would result in the release of harmful substances into the environment that would result in significant adverse impacts to the environment or to existing uses and those impacts are not regulated or managed through Federal, state or other permit requirements, then such uses and developments should be allowed only if such impacts or conflicts are minimized or mitigated. phaFffiaeeutieals,Fi - 'd s spe£+es sites, 4dFttseg e flfiii is with adia eftt uses rage effeftlyeiy Il'lltlgr'ltP(i, b. The County's proposed Policy Number 13 is unsupported and should be eliminated. Policy Number 13 provides: The County should prefer in -water finfish aquaculture use and development that operates with fully- contained systems that Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS treat effluent before discharge to local waters over open net pen systems. This policy continues to underscore the County's continued antipathy towards net pen aquaculture operations. We believe this antipathy is unwarranted and unsupported as such operations are highly regulated and well- studied. See Attachments A through E. Moreover, we are unaware of any commercially viable "fully- contained" aquaculture systems. Troutlodge, like many commercial aquaculture operations includes various recirculation technologies in its operations. However, these recirculation systems are utilized only on the beginning life stages or for small brood stock holding tanks where water demand is less problematic and the technology is economically viable. Many recirculation systems (closed containment) purport to be commercially viable but they are supported by capital infusion from government and non- profit grants, not the revenue of the operation. The only closed recirculation system that was commercially operated in the Pacific Northwest, the Hutterite- run recirculation systems that raised coho salmon in Montana recently closed after less than two years of operation. They realized they were losing money and would never make a profit. While many lauded the opening of this farm, there was little press coverage of its closure.'. We have attached numerous documents prepared by Ecology, the National Oceanic and Atmospheric Administration and others demonstrating that net pen operations are highly regulated and there is no basis for prohibiting them or at this junction disfavoring them. See Attachments A - E. In summary, Policy Number 13 is unsupported by scientific literature or other rational basis. For that reason, we recommend striking Policy 13 in its entirety or redrafting the provision as follows: Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS The County should prefer in -water finfish aquaculture use and development that __ntained systeFns } systeffis is designed, located and operated under best available practices and which address significant adverse impacts to the environment. c. The County's proposed Policy Number 14 is vague and unhelpful. Policy 14 provides: The County should allow in -water finfish aquaculture in the open waters of the Strait of Juan de Fuca only when the area seaward of the shore extends a considerable distance, and when consistent with other provisions of this Program. The aim of Policy 14 is unclear and is so vague as to provide little guidance to applicants or decision - makers. Presumably, the intent is to require net pen aquaculture operations in Puget Sound to be located distant from the shoreline. However, we believe the intent of Policy 14 should be clarified so that interested persons can easily understand the policy objective. In summary, we believe Policy 14 should be eliminated or revised and clarified. d. The County's proposed Policy Number 15 is vague and unhelpful. Policy 15 provides: The County should prohibit in -water finfish aquaculture in waters of Jefferson County where there are habitat protection designations in place and /or water quality issues documented. Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS The intent of this policy appears to be to protect water quality and designated critical habitat. The County presumes that in -water finish aquaculture is detrimental to water quality and fish habitat; however, as far as we know there is no support in the record for the presumption. As pointed out elsewhere and has been underscored by the Department of Ecology in materials supplied to the County, in water finfish aquaculture is highly regulated through the requirements and conditions of NPDES Permits -- which requires consideration and protection of water quality criteria. Moreover, siting, development and operation of in water finfish aquaculture will require federal permits which, in turn, requires federal consultation by the National Marine Fisheries Service and /or the U.S. Fish and Wildlife Service, under Section 7 of the Endangered Species Act (ESA): Each Federal agency shall, in consultation with and with the assistance of the Secretary insure that any action authorized, funded, or carried out by such agency (hereinafter in this section referred to as an "agency action ") is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat 16 U.S.C. 1536(a)(2). Moreover, state permits, such as Hydraulic Project Approval will be required which. in turn, will require consideration of impacts to Habitat of Special Significance. These permit requirements will also trigger the requirements for environmental impact analysis under the State Environmental Policy Act (SEPA) or the National Environmental Policy Act (NEPA). Rather than adopt a policy of prohibition, the County would be better served by waiting for actual facts and scientific analysis as to likely effects of any proposed in -water finfish production on protected habitat or water quality. Doing so will likely Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&dtroutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS result in increased employment in the County, greater availability of healthy seafood products which is important for consumers of modest means and which has been shown to have significant health benefits (cardio- vascular, cognitive health, fetal development, etc.) In short, Policy 15 could unnecessarily worsen the economic health of the County and human health generally. For these reason Policy 15 should be revised as follows: In considering applications for in -water finfish aquaculture in waters of Jefferson County consideration should be given to the protection of water quality and any designated critical habitat under the Endangered Species Act or habitat of special significance under state law and where water quality or designated critical habitat is not adequately addressed by Federal or State permitting requirements, measures should be adopted to minimize or mitigate significant _ 6. Uses and Activities Prohibited Outright a. The County's "Uses Prohibited Outright" is unsupported by facts, is irrational and should be eliminated as other statues and laws allow the County to consider and address identified significant adverse impacts on habitat and water quality. Part B.1. of the proposed regulations would prohibit outright any "in -water finfish aquaculture use /development, including net pens" in four areas$ in which the County asserts is "due to established habitat protection designations and /or water quality issues." As noted in our comments to Policy 15, we are unaware of any rational basis or justification as to why mere designation of habitat or water quality issues, Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS should result in all net pen aquaculture being banned in the four areas noted. As noted in comments to the proposed Policy 15, NEPA, SEPA, the ESA, hydraulic project approval and many other federal, state and local permitting requirements provide ample opportunities to consider whether and to what degree a proposed net pen operation might impact habitat or water quality. The County and other agencies can then act on actual facts and data to prevent, minimize or mitigate any significant adverse environmental impact, including impacts to water quality or habitat. Finfish aquaculture is a water dependent use and should be fostered wherever possible. 7. Shoreline Environment Regulations a. Provision C.1 which would prohibit entirely finfish aquaculture in "Priority Aquatic" Environments should be eliminated. The proposed SMP appears to allow aquaculture activities in upland environments except where the species raised has fins: Priority Aquatic: Aquaculture activities may be allowed subject to the use and development regulations of the adjacent upland shoreline environment, except finfish aquaculture is prohibited. As far as we can ascertain, the record does not support allowing aquaculture generally in "Priority Aquatic" designated areas but on the other hand, prohibiting aquaculture solely on the basis that the cultured organism has fins. We believe this prohibition does not follow the County's recognition "of the importance of local food production, both on land and in water areas, when properly managed to control pollution and prevent environmental damage." We believe the proposed measure is unwarranted and unsupported in the record and should be eliminated. Specifically, we request that the additional text "except finfish aquaculture is prohibited" be stricken. Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS b. Provision C.2 should be clarified. Regulation C.2 provides: Aquatic: Aquaculture activities may be allowed subject to the use and development regulations of the adjacent upland shoreline environment. It is not clear if the activities referred to are to take place in the upland area of the shoreline or merely that any aquaculture activity, even though it is not in the upland shoreline area must somehow meet the use and development regulations of the adjacent upland shoreline environment. To the extent that this in the intent of the provision, then we believe it should be stricken. Aquaculture should be subject to those use and development regulations of the applicable area in which it is located, rather than being subject to rules and use restrictions of an adjacent zone. c. Paragraph C.3 should be revised. Paragraph C.3 now provides as follows: Natural: Aquaculture activities, except for geoduck aquaculture, may be allowed subject to policies and regulations of this Program. Geoduck aquaculture may be allowed with a conditional use permit(C(d)). Finfish aquaculture is prohibited except in -water finfish aquaculture may be allowed with a conditional use permit(C(d)) where the area within the County's jurisdiction extends seaward more than eight (8) miles from the OHWM, as measured perpendicularly from shore. We believe the prohibition of finfish aquaculture is unwarranted and is unsupported in the record. We are unaware of any facts and scientific Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS literature that support this outright prohibition on finfish aquaculture in natural areas. The fact that the County may authorize geoduck production with a conditional use permit demonstrates that this water dependent use can, with conditions attached to address significant impacts be carried out in a responsible manner. Similarly, finfish aquaculture, when subject to a conditional use permit, can address identified significant adverse impact. Aquaculture is a water - dependent use that should be fostered. Finfish aquaculture should not be prohibited outright. Moreover, the limitation of in- water finfish aquaculture to areas in which county jurisdiction extends eight (8) miles is warranted and unsupported in the record. d. Paragraph CA should be revised. Paragraph CA provides as follows: Conservancy: Aquaculture activities, except for geoduck aquaculture, may be allowed subject to policies and regulations of this Program. Geoduck and upland finfish aquaculture may be allowed with a conditional use permit(C(d)). In -water finfish aquaculture is prohibited. While we are gratified to see that upland finfish production is allowed in Conservancy areas, subject to a conditional use permit, we believe that there is no basis for the outright banning of in -water finfish production. We believe that such activities, subject to a conditional use permit, would accomplish the County's goal of protecting the environment but at the same time fostering local production of crops on land and in the water. There appears to be no evidence in the record to support linking in -water finfish production as a use incompatible with the conservancy shoreline areas. The blanket prohibition of Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS in -water finfish aquaculture in areas designated with the conservancy environment should be eliminated. e. Paragraph C.5 should be revised. The proposed regulation provides: Shoreline Residential: Aquaculture activities, except for geoduck aquaculture, may be allowed subject to policies and regulations of this Program. Geoduck aquaculture may be allowed with a conditional use permit(C(d)). Finfish aquaculture is prohibited. Similar to our comments above, we believe there is no basis in the record for allowing geoduck production but prohibiting altogether finfish aquaculture in the shoreline residential environment. We believe that such activity should be permitted, subject to a conditional use permit. Such permitting would allow in the County to consider finfish aquaculture in those instances in which significant adverse impacts can be adequately addressed. The SEPA, NEPA and shoreline permitting process provides ample opportunity to identify and address significant adverse impacts for this water - dependent use. In those cases where significant adverse impacts cannot be adequately addressed, then the County may deny the permit and the operation. 8. General Regulations. Troutlodge incorporates by reference its prior comments. We believe many of the requirements and conditions are irrational, not supported by the scientific literature, or the record generally. However, we wish to make particular note regarding several of the regulations: a. Missing References Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS We cannot locate some of the referenced clarifications. For example, Regulation D.2 refers to proposed clarification 21; however, we failed to find clarification 21 in the document on finfish aquaculture. We thus do not have proper notice of the proposed change and cannot evaluate or comment on the provision. Similarly we could not locate proposed change #13 referenced in this part. b. Provision D.5.iv and v should be reconsidered as a matter of necessity and safety Current section D.S.v. and vi. provide: iv. Overwater work shelters and sleeping quarters accessory to aquaculture use /development shall be prohibited. v. Floating /hanging aquaculture structures and associated equipment shall not exceed six (6)feet in height above the water's surface. The Administrator may approve hoists and similar structures greater than six (6)feet in height when there is a clear demonstration of need. The six foot height limit shall not apply to vessels. Work on in -water finfish aquaculture operations requires workers to find safe harbor from inclement weather and rest when working long hours. The prohibition on sleeping quarters is illogical and would result in inhumane and unsafe working conditions and for that reason it should be eliminated. Further, the prohibition on structures (except for vessels) greater than six (6) feet is not supported by data or literature. Moreover, there seems to be little logic in allowing vessels to be involved in aquaculture when they may be greater than six (6) feet in height but not equipment or necessary structures. We understand the desire for minimizing significant effects on views and vistas Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS wherever practicable, however, we believe the above provisions are unsupported, arbitrary and unlawful. c. Provision D.5.viii should be stricken The revisions to Regulation D.5.viii reads as follows: viii. Aquaculture uses and developments, except finfish aquaculture, shall be located at least six hundred (600)feet from any National Wildlife Refuge, seal and sea lion haulouts, seabird nesting colonies, or other areas identified as critical feeding or migration areas for birds and mammals. finfish facilities, including net pens, shall be located 1,500 feet or more from such areas. The County may approve lesser distances based upon written documentation that US Fish and Wildlife Service (USFWS), Washington Department of Fish and Wildlife (WDFW) and affected tribes support the proposed location. The record, the scientific literature, and logic does not support the prohibition. The regulation presumes that all types of finfish operations would be detrimental to fish and wildlife of all kinds within the prescriptive areas set out and that such impacts cannot be mitigated in any manner. We do not believe this is supported by the scientific literature. We recommend that the County use actual facts, data, and analysis related to individual proposals to determine whether to approve permits for finfish or any other type of aquaculture and if so, what conditions should be adopted. For that reason alone, the provision should be stricken. Moreover, the Shoreline Management Act does not authorize local government including Jefferson County to delegate its decision making capacity under the SMA to any other state, federal, local or tribal agency. This provision purports Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS to delegate the decision as to distances from wildlife refuges, haul -outs or nesting areas to other agencies or entities and the County is barred by law from doing so. For that reason, the provision is void. State v. Summers, 60 Wash.2d 702, 708, 375 P.2d 143 (1962), see also, In re Puget Sound Pilots Assn, 63 Wn.2d 142, 146 n.3, 385 P.2d 711 (1963). 9. E. Regulations -- Finfish. a. Provision E.1 regarding Finfish Regulations should be revised. Provision E.1. states as follows: 1. The culture of finfish, including net pens as defined in Article 2, may be allowed with a discretionary conditional use approval(C(d)) subject to the policies and regulations of this Program. The following standards and criteria apply for all in -water finfish aquaculture use /development, per the recommendations of the 1986 Interim Guidelines (Weston /SAIC),the 1986 Aquaculture Siting Study (EDAW Inc.), the 1988Use Conflict Study (Boyce), and the 1990 Final Programmatic Environmental Impact Statement - Preferred Alternative (Parametrix). In the event there is a conflict between these requirements, the more restrictive shall prevail. Upon availability of any other subsequently state - approved guidance, the more protective requirements shall prevail. This provision relies on studies that are many decades old, are out of date or obsolete or which will be obsolete. Thus the County's SMP would be inappropriately be governed not by the best available science but by archaic if not incorrect information. Moreover, the SMP could be contrary to other legitimate and superseding regulatory authority. See Attachment D, p.5. Since 2 007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS Updated material is readily available to the County. See, e.g., Attachments A and B. Moreover, the documents do not provide criteria and standards but as noted are guidance only. For that reason the regulation fails to provide certainty other than to reflect the County's continued antipathy towards finfish aquaculture. Furthermore, constraining the County to the most restrictive material or requirements, even if the requirement is incorrect is irrational, arbitrary and unlawful. For that reasons the provision should be stricken or amended as follows: 1. The culture of finfish, including net pens as defined in Article 2, may be allowed with a discretionary conditional use approval(C(d)) subject to the policies and regulations of this Program, the policies of the Shoreline Management Act and shoreline rules adopted by the Department of Ecology. Conditional use permits should be supported by the best available science and should wherever practicable avoid minimize or mitigate significant adverse impacts. The fell tFSe/develeirif?ent, peF the Feee endatiens of the 1986 l�= teFiffi Guidelines r (EDAW r r and the 1999 nFefe ed ???tCTTT'aLTO r (r aFaffirtF� x) • in the ei }r',e,,i- .� }t,`L PrP 14 r'1 f'(11"1 „If't _PtS�kIPPI'1 these s, the stFietive shall pFevail. Upeff b. Provision E.2. and the subsequent paragraph should be renumbered and substantially amended Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS Regulation E.2. addresses documentation requirements that applicants would be required to provide to the County. Generally, this information includes a site plan an operational plan and information on insurance that may be required by Washington DNR or other agencies. However, the next paragraph is also denoted as Regulation E.2.2 which is confusing. We recommend renumbering the next paragraph as E.2.3 and other paragraphs accordingly. Moreover, reference to the 1986 guidelines in what is currently denoted as E.2. pertaining to "Bottom Sediments and Benthos" should be amended as follows: The depth of water below the bottom of any in -water finfish aquaculture facility shall meet the minimum required by the 1986 Interim Guidelines(i.e. 20 - 60 feet at MLLW), as based on facility production capacity (Class I, II or III) and the mean current velocity at the site, measured as noted in the Guidelines or by more current data /methodology.. or updated guidelines." c. Provision E.3. should be amended Provision E.3.a provides as follows: All in -water finfish aquaculture facilities shall be designed, located and operated to avoid adverse impacts to water temperature, dissolved oxygen and nutrient levels, and other water quality parameters. Facilities must comply with National Pollutant Discharge Elimination Standards(NPDES) requirements. All food production systems, whether terrestrial (beef, poultry, swine, dairy, cereal crops, orchards, etc.), marine or aquatic, including commercial and recreational fishing (e.g., by- catch, seabird and marine mammal interaction), will result in some impacts to the environment. Presumably, of interest here is the avoidance, mitigation or minimization of significant adverse impacts. Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS Moreover, the NPDES Permitting requirement is aimed at addressing adverse impacts to water quality criteria. For that reason, the foregoing provision should be amended as follows: All in -water finfish aquaculture facilities shall FnHs comply with National Pollutant Discharge Elimination Standards(NPDES) requirements and where practicable be designed, located and operated to avoid, mitigate or minimize any additional significant adverse impacts to water quality criteria. wateF te , d. Provision E.4 should be amended or stricken. Regulation E.4.a is denoted "Phytoplankton" but addresses nutrients and other requirements. The regulation would limit production to 1 million pounds per square nautical mile. Although Troutlodge does not operate net pens, we understand that this requirement would make any in -water finfish net pen operation economically unviable. As noted elsewhere Ecology already regulates water quality through NPDES permits and corresponding water and sediment quality criteria, standards and regulations. There is nothing in the record to suggest that these regulations are not satisfactory and nothing in the record to support more stringent regulations. For these reasons, we urge the County to eliminate this D.2.4.a in its entirety. e. Provision E.6 should be amended or stricken. Regulation E.6.a denoted "Food Fish and Shellfish" states that "[a]II in -water finfish aquaculture facilities shall be located to avoid adverse impacts to habitats of special significance (as defined in Article 2) and populations of food Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS fish and shellfish as follows, as determined on a case -by -case basis. Aquaculture is a water dependent use and must be fostered by the SMP. Any production of food products whether on land or in the water will result in some impacts to the environment including fish and wildlife. While significant adverse impacts may be minimized, mitigated or avoided, avoiding all impacts is simply infeasible. For that reason we recommend that the first the sentence should be amended to read as follows:" ... in -water finfish aquaculture facilities shall be located to avoid, minimize or mitigate significant adverse impacts ..." Regulations E.6.a and b address threatened and endangered species and would require the siting of in -water finfish aquaculture to be located prescribed distances from certain areas intended to protect threatened or endangered species. As noted elsewhere, in -water finfish aquaculture invariably require federal permits which, in turn, requires federal agencies to consult with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service to ensure that the proposed actions does not jeopardize species listed under the Endangered Species Act or destroy habitat listed as critical under the ESA. We believe there is no basis in the record to support the prescriptive minimum distances set out in Regulation E.6.a. Rather, we believe the SEPA, NEPA, the shoreline conditional use permit process as well as the federal ESA provide the bases to take into consideration specific impacts to habitat and listed species that would result from any specific proposal and to condition such proposals accordingly. For that reason, we recommend provision E.6.a and b be stricken. Moreover, E.6.b refers to the County's subsequent adoption of "buffer zones ". The establishment of additional zoning requirements (buffer zones) must be adopted in accordance with the procedures of the SMA. f. Section E.8 should be clarified, amended and some parts stricken Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS Section E.8 entitled "Genetic Issues" under part (a) appears to require that where native species are used for in -water finfish aquaculture that "stocks with the greatest genetic similarity to local stocks" be used. However, this provision is unclear. Would the rearing of native stocks require genetic similarity where that is a requirement of "state and federal" agencies or is this requirement a free - standing requirement of the County SMP regardless of any other state or federal requirement? Genetic selection is an important agriculture (and aquaculture) tool. Prohibiting the U.S. aquaculture industry from utilizing genetic selection (which implies that the genetics of the cultured population will diverge from the native wild stock) to increase growth rate, food conversion efficiency, meat quality and other characteristics in essence requires a larger impact and environmental footprint and puts the U.S. aquaculture producers at a competitive disadvantage. For this reason, we believe the provision be eliminated or clarified. More specifically, provision E.2.8.b states: When there is an increased risk of interbreeding or establishment of naturalized populations of the cultured species that would [sic] in conflict with native stocks, only sterile or mono - sexual fish shall be allowed. This subparagraph begs the question of determining "when there is an increased risk" What if the risk is infinitesimally small? moderate? significant? Moreover, while there may be risk of interbreeding, the issue of importance is whether the interbreeding would represent a significant risk to the native population. This in turn will depend on the risk of an inadvertent release of culture organisms, how large the release might be, and how soon a plan for Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&dtroutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS recovering the released organisms can be implemented and how effective it is. To the extent that a stock has been selected for rearing in pens and tanks, they are typically unable to survive in the wild. See Attachment E. In short, Atlantic salmon are not good colonizers here in the Pacific Northwest.9 Further, the companies involved in net -pen aquaculture have taken extensive efforts to eliminate or minimize the escape or loss of salmon, and steelhead from their net -pens. Finally, under current law, net pen operations must have plans in place for preventing escapements and an emergency plan for recovering escaped fish should an escape occur. We know of nothing in the record to support the supposition that monosexual fish would provide any benefits and we know of no support over and above current state requirements governing species allowed, escapement plans, etc. We believe the subparagraphs E.8.b should be stricken or modified as follows: When there is a significant risk of a cultured non - native species escaping and establishing natural populations in the wild that would be likely to adversely affect native species or ecosystems then only sterile populations of such species may be cultured. Where there is a significant risk of an escapement of a cultured native species and such escapement is anticipated to interbreed with and cause a significant threat to the native population such as to jeopardize the continued existence or survival of the species, then eenfloet with native steeks, only sterile or mono - sexual fish shall be allowed." Subparagraph E.8.c currently provides: Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS All in -water finfish aquaculture facilities shall locate a minimum distance from river mouths where wild fish could be most vulnerable to genetic degradation, as determined on a case -by -case basis or by State guidance. This subparagraph includes several suppositions -- that are not supported by the record -- and we believe the measure is void for vagueness because there is no definition of "minimum distance ". The first supposition is that in -water finfish aquaculture facilities are, in fact, detrimental to the wild fish genetics and populations. Second, the provision presupposes that this "genetic degradation" by some unknown route or factor is magnified where in -water finfish facilities are within some "minimum distance" (proximal to ?) to river mouths. We are unaware of any scientific data or analysis in the record that would support this provision. Moreover, as noted elsewhere, after three years of analysis and many millions of dollars, Judge Bruce Cohen stated in his final Cohen Commission report "Data presented during this Inquiry did not show that salmon farms were having a significant negative impact on Fraser River sockeye." (Final Report, Cohen Commission of Inquiry into the Decline of the Sockeye Salmon in the Fraser River 2013, Volume 3, p. 24, column 2). In view of the fact there is not sufficient data to support this provision, it should be stricken. g. Paragraph E.10 should be clarified, amended and some parts stricken Section E.10 states: a. All in -water finfish aquaculture facilities shall locate a minimum of 1,500 feet from habitats of special significance for marine mammals and seabirds. Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS b. Only non - lethal techniques(e.g. anti - predator netting)shall be allowed to prevent predation by birds and /or mammals on the cultured stocks. We are unaware of anything in the record to support a prescriptive buffer of 1,500 feet from habitats for marine mammals or seabirds. We believe it is better practice to utilize the SEPA and NEPA process for this purpose and to seek the comment and recommendations of appropriate state and federal agencies on this issue. There may be instances where lesser or more distance may be justified between in -water net pen facilities and special habitat that protects marine mammals and seabirds. We also note that federal statutes such as the Marine Mammal Protection Act, Endangered Species Act, Migratory Bird Treaty Act and many other provisions prohibit, for example, harm or harassment to marine mammals, many birds, and other organisms. Moreover, federal and state regulation requires predator nets to be installed for seabirds and marine mammal predation and we support such efforts. However, there may be instances in which special federal and state permits may be granted to "harass" or "harm" problematic marine mammals. In summary, because there is a lack of support in the record to support prescriptive requirements set out in this provision as drafted, we believe it should be stricken. h. Paragraph E.11 should be clarified, amended and some parts stricken Paragraph E.11. entitled "Visual Quality" states: a. All in -water finfish facilities shall conduct a Visual Impact Assessment to evaluate and document the following siting and design variables in order to minimize visual impacts to adjacent and surrounding uses;" Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA T MARINE FARMS We understand the importance of shoreline viewscapes and this is a good start; however, the remainder of the subparagraphs (i) through (viii) include a number of prescriptive requirements that appear arbitrary and unsupported in the record. These prescriptive requirements include but are not limited to prohibiting structure to no more than 10 vertical feet, locating 2000 feet offshore where near "higher density residential development" occurs; limiting "overall size and surface area coverage so as not to 10% of the normal cone of vision "; limiting facilities to no more than " 2 acres of surface coverage and no more than one operation per square nautical mile; as well as other prescriptions. We believe these prescriptive requirements are unsupported in the record. We believe that the section should be stricken and rewritten in its entirety as follows: E.11.a Visual Quality: All in -water finfish facilities shall conduct a Visual Impact Assessment to identify significant adverse impacts to shoreline views and vistas, both individually and cumulatively, including any required upland development on which the facility depends. Where practicable, the applicant shall through utilization of materials, design, color, location, and other means, avoid, minimize and mitigate significant adverse impacts to shoreline views and vistas. i. Section E.14 should be stricken or amended. Section E.14.b relating to "Recreation" provides: All in -water finfish aquaculture facilities shall be located a minimum of 1,000 feet from any recreational shellfish beach, public tidelands, public access facilities(e.g. docks or boat ramps) or other areas of extensive or established recreational use. Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA T MARINE FARMS We know of nothing in the record to support this prescriptive requirement. The provision presumes without evidence that any in -water finfish facility would represent a health threat or conflict with recreational uses. However, we know of no data or evidence in the record which would support the supposition. We believe the better practice would be to await the results of any SEPA or NEPA analysis and utilize the rigorous environmental review process that would likely be required to determine what conditions should be required to avoid significant adverse impacts to recreational uses. For that reason, we believe section E.14.b should be stricken in its entirety or rewritten as follows: All proposed in -water finfish aquaculture facilities shall be located to avoid, minimize or mitigate significant adverse impacts to recreational shellfish beach, public tidelands, public access facilities(e.g. docks or boat ramps) or other areas of extensive or established recreational use. a. Section E.15 should be stricken. Section E.15 entitled "Noise" and specifically, subparagraph(a) states: All in -water finfish aquaculture facilities shall be designed, located and operated to: ii. Require mufflers and enclosures on all motorized fish farm equipment. We believe there is nothing in the record to require mufflers as well as enclosures on all motorize fish farm equipment. We have no problem with a requirement of meeting all applicable state and federal standards for noise and otherwise addressing significant noise impacts through appropriate conditions; however, requiring both a muffler and an enclosure on farm equipment no Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA T MARINE FARMS matter what kind of equipment is involved and no matter what little amount of noise may be generated is unsupported as well as arbitrary and capricious and is, therefore, unlawful. For that reason, the provision should be stricken. b. Paragraph E.16 should be amended. Section E.16 addresses "Odor" and would require among other things that a. All in -water finfish aquaculture facilities shall be designed, located and operated to: iii. Maximize the distance between the facility and nearby residential use /development, downwind location preferred, to minimize impacts resulting from foul odors. (Emphasis added). We have no argument with the intent of addressing odors that may emanate from in -water finfish production; however, we are unaware that this is a problem. Nonetheless, as drafted, the provision could be used to completely prohibit siting a facility because of how the term "maximize" is used without any qualification and by failing to reference the "impacts" of interest to "significant impacts." We believe the provision should be redrafted as follows: a. All in -water finfish aquaculture facilities shall be designed, located and operated to: Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA T MARINE FARMS adverse impacts to downwind residential or other uses caused by foul odors that are anticipated to be created by the facility. 10. Conclusions It appears that the County's position on finfish aquaculture and in -water finfish aquaculture in particular continues to be based on misconceptions and antipathy. In closing we would like to make a few points: a. Native Sablefish and Steelhead may be reared in net -pens. We urge the County to keep in mind that native species, such as steelhead and black cod (sablefish) can, have been, and are currently being grown in net pens in Puget Sound. Moreover, black cod are immune to a number of viruses native to Pacific fishes (hence the apparent native immunity to the viruses) that are typically lethal to Atlantic salmon (e.g. Infectious Hematopoietic Necrosis and Viral Hemorrhagic Septicemia),10 A significant number of family wage jobs are available should the County wish to adopt reasonable regulations and work with fish producers. We do not imply that rearing Atlantic salmon net -pens is flawed but simply that aquaculture is very diverse. b. The ISA Virus has not been found in salmon populations in the Pacific Northwest To the extent that the County's proposed ban on net -pens is based on the supposition that the infectious salmon anemia virus was introduced into the Pacific Northwest via imported salmon eggs by the operators of net pens we emphasize that the Canadian or U.S. authorities have been unable to confirm, through cell culture, the actual presence of the ISA virus in wild salmon or trout populations. Further we understand that initial announcements about the Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marin&a•troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 92406 USA A OWN � MARINE FARMS detection of the disease ignored the key scientist's report noting that the tests did not confirm the presence of the virus in the fish tested nor in the area tested. The U.S. Fish and Wildlife Service, Code of Federal Regulations, Title 50, requires health certification for salmonids imported as live fish, fertilized eggs and gametes, as well as uneviscerated dead fish, prior to entry to the United States. This testing protocol involves cell culture on cell lines that are sensitive to the ISA virus. Further, Washington requires additional measures such as quarantine and testing with the more sensitive cell line to detect ISA virus on a case -by -case basis. In short, the ISA virus has neither been diagnosed nor confirmed to be present in BC.11 Experts in this field note that over 36,000 salmonids from 51 watersheds were tested during July 2010 to June 2011 in Washington utilizing tests that would have demonstrated the presence of the North American genotype of the ISA virus. Further, given the virulent nature of the European strain of the ISA virus, it is near certain that exceedingly high and otherwise unexplained net -pen mortality of Atlantic salmon reared in Puget Sound and Canada would have been observed. Such mortality events are entirely lacking, strongly suggesting that the ISA virus is not and has not been present in the Pacific Northwest. c. The scientific record does not support the SMP proposed by Jefferson County After three years, $26 million, the testimony of dozens of expert witnesses, and exhaustive review, Judge Bruce Cohen stated in his final Cohen Commission report "Data presented during this Inquiry did not show that salmon farms were having a significant negative impact on Fraser River sockeye." (Final Report, Cohen Commission of Inquiry into the Decline of the Sockeye Salmon in the Since 2007 marine.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A OWN � MARINE FARMS Fraser River 2013, Volume 3, p. 24, column 2). We believe the County should take a more careful and circumspect view of finfish aquaculture and carefully evaluate any shoreline applications for new finfish operations. We urge the County to reconsider its proposed amendments to the Shoreline Master Program as they relate to finfish aquaculture and in -water finfish aquaculture. We believe that the County's proposed action will harm seafood consumers, forego significant economic development that could result from sustainable aquaculture, further erode the jobs and tax base of the County and adversely and unnecessarily harm the County's economy. In closing, we extend an invitation to you and your staff to visit any of our aquaculture facilities. For reasons of biosecurity, we typically only entertain a maximum of three visitors at any one time. While a visit to our facility may not change your views or opinions we would sincerely appreciate the opportunity to meet with you and attempt to answer your questions. Best regards, ZIn Dentler Director, Government Relations Troutlodge Cc: Michelle McConnell, Assoc. Planner, Jefferson County Jeffree Stewart, Ecology Laura Hoberect, NMFS Since 2007 mar! ne.troutiodge.com T +1 (253) 759 -4217 F +1 (253) 759 -0825 E marine( «troutlodge.com 3518 6th Ave, Suite 201, Tacoma, WA 98406 USA A111111"t OWN � MARINE FARMS 1 1.17. In -water finfish aquaculture means the farming or culture of vertebrate or cartilaginous food fish for market sale when raised in facilities located waterward of the ordinary high watermark in freshwater or saltwater water bodies, in either open -flow or contained systems. This includes net pens, sea cages, bag cages and similar floating /hanging containment structures and is intended to reflect the definition of 'marine finfish rearing facilities'(RCW 90.48.220), but does not include temporary restoration /enhancement facilities used expressly to improve populations of native stocks. z http://fn.cfs.purdue.edu/fish4health/HealthBenefits/omega3.pd 3 http: / /www.umm.edu /altmed /articles /omega- 3- 000316.htm 4 http: / /www.fao.org/ news /story /en /item /94232 /icode/ 5 http: / /www.noaanews. noaa. gov/ stories20ll /20110711_aquaculture.htm1; 6 http: / /www.noaanews.noaa. gov/ stories20ll /20110711_aquaculture.html See http://saImonfarmscience.com/ 2013 /02 /21 /hutterite- salmon- farm - fails/ 8 a. Protection Island Aquatic Reserve or within fifteen hundred feet(1,500') of the boundary; b. Smith and Minor Islands Aquatic Reserve or within fifteen hundred feet(1,500') of the boundary; c. Discovery Bay, south of the boundary of the Protection Island Aquatic Reserve; d. South Port Townsend Bay Mooring Buoy Management Plan Area; and e. Hood Canal, south of the line extending from Tala Point to Foul weather Bluff, including Dabob and Tarboo Bays) 9 http: / /www.aquaticnuisance.org /fact- sheets /atlantic - salmon. ( "Unsuccessful attempts were made in the early 20th Century by Canadian and United States federal agencies to introduce Atlantic salmon to Pacific waters. According to the Washington Department of Fish and Wildlife, the release of Atlantic salmon smolts, for the purpose of establishing runs in Washington, occurred in 1951, 1980, and 1981. These releases failed to establish Atlantic salmon in Washington State. 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W tg Lu a OX pnoC 1 • m 1 l R tu ra IL _ UJ 7 . _v 06 Lu C6 fn AAA ?. •• 7 . _v w fr-c Z a_ pp 3 l l i 3:# 1 w l N U (u CT N (u PEI �mq N O N -0U m U) 2 >L Z U) CU CU LL (a Z � O 2 N n' V) U N c/ F- a) 0-1 cu 0 Z N L a) U U N v) cn N a) cn IL cn O Z cu N cu cu Q 70 a) cu U W < L a) V �mq N O N -0U m U) 2 >L Z U) CU CU LL (a Z � O 2 N n' V) U N c/ F- a) 0-1 cu 0 Z N L a) U U N v) cn N a) cn IL cn O Z cu N cu cu Q I- N a) =3 X N 0 O N E O U N E O 0) � N U O m co Q N U N c C M O ^ E U 4-0 (6 O LO -0 N Q _CU r 70 N �� a > p Q r r N OU 70 cn U �2 E O N E O 4_ 7C3 o 0) C/) D w C O (u nj U o =3 =3 O N — (u > 0 W 7C3 U C- N 7C3 o N N O O rn N =3 N o O U N U) CU O c N m > cn O s N (� — o U) U o) O N = E U O_ cn o (L) L � o is J Nmf O O � � V i E N o � O _ Q N a� O N _ U_ CD_ 70 o O � N u� o m`UQ�� I- N U (u CT N (u PEI �mq N O N -0U m U) 2 >L Z U) CU CU LL (a Z � O 2 N n' V) U N c/ F- a) 0-1 cu 0 Z N L a) U U N v) cn N a) cn IL cn O Z cu N cu cu Q 70 a) cu U W < L a) V �mq N O N -0U m U) 2 >L Z U) CU CU LL (a Z � O 2 N n' V) U N c/ F- a) 0-1 cu 0 Z N L a) U U N v) cn N a) cn IL cn O Z cu N cu cu Q .. N a) =3 X N 0 O N E O U N E O 0) � N U O m co Q N U N c C M O ^ E U 4-0 (6 O LO -0 N Q _CU r 70 N �� a > p Q r r N OU 70 cn U �2 E O N E O 4_ 7C3 o 0) C/) D w C O (u nj U o =3 =3 O N — (u > 0 W 7C3 U C- N 7C3 o N N O O rn N =3 N o O U N U) CU O c N m > cn O s N (� — o U) U o) O N = E U O_ cn o (L) L � o is J Nmf O O � � V i E N o � O _ Q N a� O N _ U_ CD_ 70 o O � N u� o m`UQ�� .. Attachment D sraT� o� N Q ��y l859 �oY STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Box 47600 Olympia, WA 98504 -7600 360 - 407 -6000 711 for Washington Relay Service o Persons with a speech disability can call 877 -833 -6341 January 31, 2013 Cathy Lear Clallam County Community Development 223 East 4 #h Street Port Angeles, Washineo# 98362 y _. __-_-_Dear ar: - -- The following comments ar6 responsive to Clallam County's November 2012 Shoreline Master - -- - Program Final Draft, the proposed update to the 1992 Clallam County SMP. We recognize - extensive revisions have been made to the earlier version fiom last February. Most notably, perhaps, are revisions to the Environment Designation system, and also the parsing out safety and habitat protection in the buffer zone provisions. Ecology's comments.will address these briefly. We will make suggestions about residential development provisions and about public access. We will also include a number of comments about the acluaculture use definitions, policies, and regulations in Chapter 3, 5, and 7. As we are doing additional work to clarify guidance on Channel Migration Zones, our comments in this area will be limited. Introductory overview Clallam County and their consultants have done commendable work to strike a balance between the need to protect ecological functions and to allow continuing development and use of Clallam County's extensive shoreline areas. We especially appreciate the'degree to which the County has asked for, listened to, and incorporated appropriate suggestions from the public, Tribal governments, and the various resource agencies such as WDFW and WDNR. The Program Overview and introduction to the SMP in Chapter I is concise, helpful, and on point as an orientation for citizens. These pages clearly describe the purposes and.background of shoreline management in both practical and legal terms. Pictorial and schematic information combined with the text communicates well the significance of shoreline regulation. In Chapter 1.6, a Helpful addition at the front end (or elsewhere as appropriate) should explain to readers the distinction between "uses" and "development." These simple words are also fundamental terms as applied per RCW 90.58, and development of an SMP requires parsing them correctly, and not conflating as if they were the same. Both uses and development are regulated by SMP provisions, while each is distinct. Based on conversations we have had with the City of Forks, Chapter 1.8 appears to be a place for adding language that describes the linkage between County and City shoreline regulations, once agrecihents have been made final on how that works and limitations as appropriate. Ocean Management We have previously talked about adding a "placeholder" to the Applicability section at the front of the document. Pursuant to WAC 173 -26 -(360) , a brief statement should be added to ensure everyone understands that Clallara County shoreline jurisdiction extends waterward from the OHWM to the three mile limit in the Pacific Ocean, recognizing that shoreline jurisdiction overlaps ,vith other state and federal management systems. This marine aquatic jurisdiction needs explicit annotation. It is not obvious based on ownership of shoreland areas by the federal government of the Olympic National Park, and by Makah and Quileute Tribal Reservations. Clallam County has no permitting authority on the landward side of OHWM because of these. However the County does have authority waterward to the state limit, despite the overlapping management overlay of the Olympic Coast Marine Sanctuary and the fact underwater state lands are held by Washington Department of Natural Resources. If Marine Spatial Planning efforts proceed as intended at the statewide level, subsequent updates of your Master Program may find useful applications for addressing various large scale proposals in the ocean environment at some point in the future, Aquaculture Provisions in Chapters 3, 5, and 7 The following comments relating to the draft aquacuiture provisions were compiled and summarized by Cedar Bouta after consultation with Lori LeVander, Perry Lund, and myself More detailed comments will be attached, and we are available if the County would like to discuss any or all of these comments. 1. Overall, the SMP contains some good policies and regulations. More simplification would help avoid conflicts with existing state and federal regulations. 2. Definitions a. Definitions related to aquaculture are overly complex and in some cases don't mect statute or SMP Guidelines. b. There needs to be more work ensuring the finfish aquaculture - related definitions are clear and applied consistently throughout the SMP. 3. The proposed SMP language does not comply with WAC 173 -26- 241 (3) (b). More wort: is needed to cross- reference the draft SMP with the WAC provisions regarding commercial geoduck aquaculture. 4. Net pen SMP language pulls from the 1986 interim siting guidelines, We appreciate that they are cross - referencing with that document, which is still a useful reference. However, there are newer best management practices, PCHB rulings, sediment monitoring data, and other sources of data and information that also need to be considered. 5. We believe some of the current SMP language is contrary to current state and federal laws, and would amount to a de -fact ban on net pens. We believe such a ban is not warranted based on current science or 25+ }Tears of operational data from finfish net pen facilities operating in waters of Washington State. 6. Only the legislature can define what development is or make exemptions. Some of the wording in Section 3.2.3 Regulations (#4 and 5) appear to create new exemptions from permit requirements, which is an authority reserved to the Legislature by statute. We note the language in Regulation #S on page 3- 6-could appropriately be moved up to a more introductory position among the policy provisions. As we discussed during the January 15, 2013 Advisory Committee meeting at Port Angeles, many of the proposed SMP aquaculture provisions are reiterative to regulations or guidance from different state and federal agencies. We noted that, while including these provisions in the County's SMP may be allowable, there are reasons to proceed with caution in doing so. The Department'of Community Development becomes responsible for evaluating large amounts of technical information, and, making permit decisions for actions which are addressed elsewhere. Technical capacity and workload implications should be considered along with RCW and WAC requirements. 0 Regulating Authorities for Net Pen Aquaculture The following state and federal agencies have regulatory authority over the marine salmon net pen industry in )Vashington State: • Washington State Department of Fish and Wildlife (WDFW) — Management and regulatory authority over commercial aquaculture for disease control and escapement. Department of Agriculture — Jointly develops regulations for commercial aquaculture with WDFW. • Department of Ecology — Regulates the discharges from net pens by issuing NPDES permits containing operational conditions to protect water quality and sediment standards. • Department of Natural Resources -- Leases aquatic lands to net pen operators. • Washington State Counties — Issue Shoreline Permits to net pens to operate in State waters. • Treaty Tribes of Washington State -- Tribes co- manage natural resources in Washington and have input into aquaculture disease control regulations developed by WDFW. • National Marine Fisheries Service (NMFS) — NMFS administers Endangered Species Act (ESA) for anadromous salmonids. • Army Corp of Engineers — The Corp requires net pens to have a "Section 404" navigation permit. Local and state agency coordination on aquaculture There may in fact be some value in having local oversight of the regulatory reviews done by other agencies. Some Advisory Committee members certainly expressed strong interest in doing so. At the same time, we should be careful about exactly how SMP.provisions are worded. Regulation #5 on page 3 -3 is an example where non - native fish populations are "discouraged" except in upland systems. The County can decide to express a preference, but should have a rationale for doing so. Native and non - native species would have similar impacts in the water, so why the preference for one over the other? We should ensure that the SMP does not constrain the County to adhere to references which later become out -of -date, nor ones that prove contrary to other legitimate regulatory authorities. An 5 example is Regulation #10 on page 3 -6, that would make 1986 technical guidance- which may change as the science advances- into enforceable regulation the County is responsible for. #10(i) is a single line that says most of what is useful and necessary if the surrounding provisions are dropped. The wording in 9100) and (m)(for using regional broodstock) are both contrary to current recommendations by WDFW.'These provisions would require amending the SMP to remove, and are plainly inadvisable. Shoreline master program policies and regulations do need to correlate land use regulation onshore with decisions about offshore location of water - dependent uses such as net pens. This appears to be addressed to some degree by Regulation #7 on page 3 -6. Residential Development provisions Ecology encourages locating residential development in areas where homeowners will be relatively safe, and which avoid taxpayer expenditures for rescue and cleanup operations. The need for shoreline stabilization and structures such as levees should be avoided. Guidelines at WAC 173 -26 -241 for residential uses state that: Master programs shall include standards for the creation of new residential lots through land division that accomplish the following: (i) Plats and subdivisions must be designed, configured and developed in a manner that assures that no net loss of ecological functions results from the plat or subdivision at full build -out of all lots. (ii) Prevent the need for new shoreline stabilization or flood hazard reduction measures that would cause significant impacts to other properties or public improvements or a net loss of shoreline ecological functions. Residential development, including appurtenant structures and uses, should be sufficiently set back from steep slopes and shorelines vulnerable to erosion so that structural improvements, including bluff walls and other stabilization structures, are not required to protect such structures and uses. (See RCW 90.58.100(6).) M There is a need to be clear in the SMP about the Iocation of primary residential structures, particularly for the safety of residents from such hazards as landslides and flooding. Houses and other structures need to be located far enough back from the edges of bluffs and outside areas where streams and rivers are shown prone to meander over time. The proposed language in Chapter 3.8 appears to address these concerns to some degree. The policies and regulations appear to be correctly aligned. Some of the assumptions therein may need further scrutiny, such as allowing for new residential Iots with fi•ontage of 150 feet, and the premise (Section 3.8.3 #7, page 3 -21) that a 75 year lifespan is the basis for "life of a structure." Further evaluation of cumulative impacts should help to clarify if those assumptions are realistic, and whether their implementation would result in no net loss of ecological functions. Some uncertainty must be noted about Regulation #3 in Section 3.8.3. The language here includes "beach -- access structures" as "water- dependent and water --- related structures." A similar concern is noted about Section 3.8.5 where "accessory uses" and "appurtenant structures" seem rather vague and unclear about what is included, and also how the terms relate to one another. Structures and uses appear to be conflated here. And related provisions in Section 3.13 need to be clarified as to how many similar or related structures would be allowed on a single lot. This also relates to provisions in Section 4.2.3 of Chapter 4. As written, the definition for "appurtenant" structure would default to that in the WAC because a specific definition is not found in Chapter 7. We do not consider beach access structures to qualify as water- dependent. We believe appurtenant structures should be carefully enumerated and described as to what fits that category. If they are not spelled out, proposals for rather large and significantly impactful structures may be argued for as falling under those provisions. In Chapter 3, Section 3.18, the policy provisions appear generally sound, in keeping with Guidelines requirements in terms of avoiding unnecessary armoring and removal of existing impairments where appropriate and possible. There is one regulation that did not seem to make sense, #3 in Section 3.18.3, which appears to say the owner of an existing bulkhead could come in once and year and add ten percent more fill to the existing structure as maintenance. Buffers and vegetation conservation The provisions for establishing buffers and protecting the ecological functions of shoreline vegetation appear thoughtful and carefully designed. There may need to be some additional explanatory text about the relationships between safety and habitat buffers, as the system proposed is fairly complex. 7 We have concerns about the basis for identifying a safety buffer from the Ordinary high Water Mark to a set distance landward in Channel Migration Zone areas. The nature of rivers and streams, some more than others, such as the Bogachiel or the Hoh, is to move far and fast under certain conditions. In Figure 4.2 on page 4 -12, a set figure of 150 feet from OHWM is identified as being outside the Channel Migration Zone, and we think this deserves further discussion and evaluation. Public Access As was noted during the Advisory Committee meeting January, the policies and regulations.. about Public Access in Chapter 4, Section 4.6 , while they are fine as far as they go, seem remarkably scant and less than comprehensive, considering that public access is among the fundamental policy elements of the Shoreline Management Act. Per the Guidelines, "The master program should seek to increase the amount and diversity of public access to the state's shorelines consistent with the natural shoreline character, property rights, public rights under the Public Trust Doctrine, and public safety." The present version addresses public access for larger scale developments, provides criteria for assessment of feasibility, and talks about what must. be demonstrated to avoid providing public access. It says that existing public access on County owned rights of way "shall not be diminished..," The present language does not require any kind of alternate contribution requirement in cases where public access is not provided. More significantly, it does not say anything specific about public access requirements associated with new residential subdivisions, nor anywhere else. The Guidelines call for each local government to " establish policies and regulations that protect. and enhance both physical and visual public access." Previous Advisory Group conversations have addressed this subject in general terms, with recognition there are vast areas of waterfront in Clallain County which are in public ownership. It has been indicated that public access planning at the Countywide level would preclude the need for requiring individual public access in residential areas. That approach is an option, but we have yet to see the requisite planning instrument to effect it. Absent that countywide plan, the same requirements as indicated in Section 4.6.3 should also apply to residential subdivisions with more than four lots. We would like to have some further conversation with the citizens and the County about the long tern needs for public access, to what extent those have been adequately addressed, and where could improvements be made the SMP could support with appropriate language. F. Conclusion In addition to these comments, further work has and will be done by Ecology regarding Channel Migration Zone delineation and hazard avoidance evaluation. Detailed remarks about the aquaculture provisions are available in addition to what is summarized in this letter. The comments here are the ones we had time to make before the deadline, and further collaborative review will doubtless be appropriate. As noted earlier, generally we view Clallam County's work in development of an updated Shoreline Master Program to be exemplary, and look forward to working through the remaining details towards local and statewide adoption, collaboratively. Sincerely, i Jeffi•ee Stewart Shoreline Specialist Washington Department of Ecology 360- 407 -6521 Cc: Paula Ehlers, Peter Skowlund, Perry Lund, Cedar Bouta, Patricia Olson New multiunit residential development, including the subdivision of land for more than four parcels, should provide community and /or public access in conformance to the local government's public access planning and this chapter. Attachment C o'a yf n UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration s�o �°' NATIONAL MARINE FISHERIES SERVICE "Ares of � Northwest Fisheries Science Center 2725 Montlake Blvd. East Seattle WA 98112 January 13, 2012 Brian Lyrm Coastal /Shorelands Section Manager Shorelands and Environmental Assistance Program Washington State Department of Ecology PO Box 47600 Olympia, WA 98504 -7600 Dear Mr. Lynn, Thank you for your email dated November 22, 2011, requesting current scientific information about finfish net pen aquaculture. We understand that this request is made in response to Jefferson County's findings on net pen aquaculture drafted as part of their Shoreline Master Program (SMP) update. NOAA supports the development of sustainable marine aquaculture within the context of our multiple stewardship missions and broader social and economic goals. As with any activity, there are risks associated with marine aquaculture. However, with existing regulations, proper farm management practices, appropriate siting, and consistent monitoring, these risks are manageable, as is documented by the 40 year track record of net pen facilities operating in Washington State. NOAA has published two scientific technical memorandums analyzing the effects of net pen Atlantic salmon farming in the Pacific Northwest (Nash 2001, Waknitz 2002). Together, these documents assess the risks associated with salmon farming, identify best management practices to minimize risks, and find no harm to ESA- listed salmonids from the operations of existing farms. The Jefferson County analysis acknowledges these documents, but also comments that they are dated and newer literature should be considered. NOAA agrees that newer literature must be considered, but maintains that the science in the technical memorandums is still valid. NOAA is in the process of producing an updated and expanded review of the environmental effects of marine finfish aquaculture that should be ready for the public this summer. In addition, computer models to aid aquaculture siting have been developed and are being used to understand single farm and cumulative impacts to marine areas due to fish farming. Nothing in the newer literature negates the findings in the two older NOAA documents. In fact, new technologies and practices have actually reduced many of the risks identified. Furthermore, new frameworks are available for integrated management of cultured and wild fish populations (cf K. Lorenzen et al. 2012, Biological Reviews). ® Printed on Recycled Paper �,o ArMasPNFq� r �a e� p9glMEHi OE C�� We offer the following in response to the risks called out in the Jefferson County analysis: Biodeposits — food and feces Technological advances in both feeds and feeding practices have minimized these risks. New feeds are well assimilated by fish leading to a reduction in waste production. Farms utilize underwater cameras to monitor feeding behavior of fish. This allows managers to reduce feeding rates as fish are satiated, reducing the amount of excess feed that can reach the benthos. Since feed costs can amount to over half the cost to raise fish in captivity, there is strong financial incentive for companies to insure that feed is not wasted. Farins pay a third party to conduct video surveys and collect benthic samples to demonstrate that sites do not have any net increase in bio- deposits under cage lease areas. All sediment monitoring reports are submitted to Washington State Departments of Ecology (Ecology) and Natural Resources. 2. Chemical Use - pesticides, pharmaceuticals, etc For the most part, antibiotics are no longer used by Atlantic salmon farmers in Washington State. Instead, fish are vaccinated for specific diseases that are known to cause problems. If salmon farmers wanted to use antibiotics they have to be prescribed on a case by case basis by a veterinarian and are only approved to treat an identified condition. Antibiotics are not used prophylactically with fish in the US. Disease - bacteria, viruses Monitoring of fish health and vaccinations reduce risk of disease. In addition, better husbandry, diets and selectively bred fish, reduce the susceptibility of farmed fish to diseases. Treatment has already been discussed. National Pollutant Discharge Elimination System ( NPDES) permits issued by Ecology call for the mandatory reporting of approved chemical use and reporting of emergency disease occurrences. 4. Parasites - sea lice We don't generally find sea lice in Puget Sound because of its relatively low salinity (salinity disrupts sea lice reproduction). If sea lice became an issue then treatment could be authorized by a veterinarian using either a mix of freshwater and hydrogen peroxide, or a commercial product such as Slice. Other parasites are treated with freshwater baths sometimes with hydrogen peroxide added or another FDA approved method. NPDES permits issued by Ecology call for the mandatory reporting of approved chemical use and reporting incidence of sea lice infestations. 5. Escapement - GMOs, breed /compete with natives No GM fish are approved to be grown in the US. The current petition before the FDA to allow GMO fish to be sold in the US does not include a request to grow them here. The request is to grow them in closed land -based systems in Panama, and import the fillets. There is no request to raise GMO fish in the US and it is unlikely that one will be made for salmon in net -pens. There is no evidence of escaped Atlantic salmon breeding or outcompeting native Pacific salmon (Waknitz 2002) in the Pacific Northwest. Atlantic salmon are a different species and cannot hybridize in nature with Pacific salmon. Genetic impact models for native fish escaping in to the wild have been developed and can be used to determine the potential impacts and risk of these escapes. Should they become necessary, management strategies to reduce the risk of escape of native fish can be developed. Finally, Aquaculture Finfish permits issued by the Washington State Department of Fish and Wildlife and NPDES permits issued by Ecology require the development of Employee Fish Escape Prevention Plans, Fish Escape Reporting Procedures and Accidental Fish Escape Rapid Recapture Plans. 6. Impacts to Puget Sound — low dissolved oxygen, shellfish beds, forage fish, kelp & eelgrass, mammals, ongoing restoration efforts Existing regulations, proper siting, and ongoing monitoring minimizes ecological risk of farms. The effectiveness of this three pronged approach is demonstrated by findings showing that there are no effects to these marine resources by existing farms. The amount of oxygen removed, and nutrients added to the water by a salmon farm are very small. Typically it is not possible to detect a change in any of these variables farther than 100 meters from the net -pens. 7. Conflicts with adjacent shoreline uses such as aesthetics, lighting, glare, noise, and odor. NOAA concurs that such risks are present and are site specific. Appropriate mitigation measures could be developed on a case by case basis. The ongoing debate in the scientific literature about the effect of net pen aquaculture can cause confusion about these issues, particularly when problems in other geographic locations are extrapolated to Washington State. To assist in interpretation of the literature, we offer to meet with interested County Commissioners and answer questions about the science surrounding net pen aquaculture. We would also recommend a regional working group to assist in reviewing and updating guidelines for sustainable marine net pen aquaculture and would offer our participation in such a group. In order to document existing regulations, this group should consist of appropriate staff from State agencies with regulatory authority over net pen aquaculture, specifically Department of Ecology, Department of Natural Resources, and Department of Fish and Wildlife. Finally when the upcoming publication about marine cage culture and the environment is finished we would be happy to provide you with a copy. This publication offers a comprehensive review of water quality, benthic sediment, marine life, contaminant, and management issues associated with net pen aquaculture. It is expected to be released in the next 6 -8 months and will be valuable for use in establishing regional guidelines. We also would welcome your agency's involvement with impact and siting models as they evolve. NMFS is one of the lead agencies in Puget Sound involved in protecting, improving, and restoring marine species, habitats, and ecosystems. We look forward to continued coordination with the Department of Ecology and Jefferson County in support of the timely and successful implementation of the LA -SMP. Sincerely, z�Z� ter± Walt Dickhoff Director Resource Enhancement & Utilization Northwest Fisheries Science Center Michael Rust Science Coordinator Office of Aquaculture NOAA Fisheries Literature Cited Lorenzen, K., M.C.M. Beveridge, and M. Mangel. 2012. Cultured fish: integrative biology and management of domestication and interactions with wild fish. Biol. Rev. Early View 5 Jan 2012. Nash, C.E. (editor). 2001. The net -pen salmon farming Industry in the Pacific Northwest. U.S. Dept. Commer., NOAA Tech. Memo. NMFS - NWFSC -49, 125 p. Waknitz, F.W., T.J. Tynan, C.E. Nash, R.N. Iwamoto, and L.G. Rutter. 2002. Review of potential impacts of Atlantic salmon culture on Puget Sound Chinook salmon and Hood Canal summer -run chum salmon evolutionarily significant units. U.S. Dept. Commer., NOAA Tech. Memo. NMFS - NWFSC -53, 83 p. Attachment B NOAA Technical Memorandum NWS- NWFSC -49 The Net -pen Salmon Farming Industry in the Pacific Northwest September 2001 U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration National Marine Fisheries Service NOAA Technical Memorandum NMFS Series The Northwest Fisheries Science Center of the Na- tional Marine Fisheries Service, NOAA, uses the NOAA Technical Memorandum NMFS series to issue informal scientific and technical publications when complete formal review and editorial processing are not appropriate or feasible due to time constraints. Documents published in this series may be referenced in the scientific and technical literature. The NMFS - NWFSC Technical Memorandum series of the Northwest Fisheries Science Center continues the NMFS -F /NWC series established in 1970 by the Northwest & Alaska Fisheries Science Center, which has since been split into the Northwest Fisheries Science Center and the Alaska Fisheries Science Center. The NMFS -AFSC Technical Memorandum series is now being used by the Alaska Fisheries Science Center. Reference throughout this document to trade names does not imply endorsement by the National Marine Fisheries Service, NOAA. This document should be cited as follows: Nash, C.E. (editor). 2001. The net -pen salmon farming Industry in the Pacific Northwest. U.S. Dept. Commer., NOAA Tech. Memo. NMFS - NWFSC -49, 125 p. NOAA Technical Memorandum NMFS- NWFSC -49 The Net -pen Salmon Farming Industry in the Pacific Northwest Edited by Colin Nash From contributions by Kenneth M. Brooks (consultant) *, William T. Fairgrieve, Robert N. Iwamoto, Conrad V.W. Mahnken, Colin E. Nash, Michael B. Rust, Mark S. Strom, and F. William Waknitz Northwest Fisheries Science Center Resource Enhancement and Utilization Technologies Division 2725 Montlake Boulevard East Seattle, Washington 98112 *Aquatic Environmental Sciences 644 Old Eaglemount Road Port Townsend, Washington 98368 September 2001 U.S. DEPARTMENT OF COMMERCE Donald L. Evans, Secretary National Oceanic and Atmospheric Administration Scott B. Gudes, Acting Administrator National Marine Fisheries Service William T. Hogarth, Acting Assistant Administrator for Fisheries Most NOAA Technical Memorandums NMFS -NWFSC are available on -line at the Northwest Fisheries Science Center web site (http: / /www.nwfsc.noaa.gov) Copies are also available from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 phone orders (1- 800 -553 -6847) e -mail orders (orders @ntis.fedworld.gov) it Acknowledgements Thirty -five copies of this document in draft were circulated globally in April and May, 2001 for review and comment. The authors acknowledge the added contributions of the following individuals: Hans Ackefors (University of Stockholm, Sweden) Kevin H. Amos (Washington Department of Fish and Wildlife) Andrew Appleby (Washington Department of Fish and Wildlife) Faye M. Dong (University of Washington, Seattle, Washington) John Forster (Forster Consulting Inc., Port Angeles, Washington) Peter Granger (Washington Fish Growers Association, Bellingham, Washington) James P. McVey (National Sea Grant Program, NOAA, Washington D.C.) John E. Rensel ( Rensel Associates Aquatic Science Consultants, Arlington, Washington) Andrew J.L. Thomson (Fisheries and Oceans, Nanaimo, B.C. Canada) iii Acronyms of Organizations and Common Terms ACE US Army Corps of Engineers ADF &G Alaska Department of Fish and Game ALL Aquatic Lands Lease APHA American Public Health Association BC British Columbia (Canada) BCSAR British Columbia Salmon Aquaculture Review BCSGA British Columbia Salmon Growers Association (Canada) BMP Best Management Practice CFOI Census of Fatal Occupational Injuries CFR Code of Federal Regulations (Food and Drug Administration) COP Code of Practice DOC United States Department of Commerce DOI United States Department of the Interior DFO Department of Fisheries and Oceans (Canada) EAO Environmental Assessment Office (Canada BC) EEZ Extended Economic Zone EPA United States Environmental Protection Agency ESA Endangered Species Act 1974 ESU Evolutionarily Significant Unit EU European Union FAO Food and Agriculture Organization (United Nations) FDA United States Food and Drug Administration FPC Fish Passage Control (Oregon) HACCP Hazard Analysis Critical Control Point HGMP Hatchery and Genetic Management Plan HIE Highlands and Islands Enterprises (Scotland) EPA Hydraulic Project Approval GDP Gross Domestic Product GDU Genetic Diversity Unit GESAMP Joint Group of Experts on Scientific Aspects of Marine Environmental Protection (United Nations) GLP Good Laboratory Practice GM Genetically Modified GMO Genetically Modified Organism ICOR Interagency Committee for Outdoor Recreation (Washington State) INAD Investigational New Animal Drug JSA Joint Sub - Committee on Aquaculture MLLW Mean Low Low Water NADP National Aquaculture Development Plan NBSGA New Brunswick Salmon Growers Association (Canada) NMFS National Marine Fisheries Service (NOAA) NOAA National Oceanographic and Atmospheric Administration NPAFC North Pacific Anadromous Fish Commission u NPDES National Pollution Discharge Elimination System Permit NRC Natural Resources Consultants NSGCP National Sea Grant College Program (NOAA) NSSP National Shellfish Sanitation Program NWFSC Northwest Fisheries Science Center NWIFC Northwest Indian Fisheries Commission OAR Office of Oceanic and Atmospheric Research (NOAA) ODFW Oregon Department of Fish and Wildlife ODIN Official Documentation and Infonnation from Norway OSU Oregon State University PCHB Pollution Control Hearings Board (Washington State) PNP Private Non - Profit (Aquaculture Organizations, Alaska) PNWFHPC Pacific Northwest Fish Health Protection Committee PSMFC Pacific States Marine Fisheries Commission PSEP Puget Sound Estuary Protocols PSGA Puget Sound Gillnetters Association PSWQAT Puget Sound Water Quality Action Team RCW Regulatory Code of Washington REUT Resource Enhancement and Utilization Technologies Division (Northwest Fisheries Science Center) SCAN Scientific Committee on Animal Nutrition (European Union) SEPA (Washington) State Environmental Policy Act SEPA Scottish Environmental Protection Agency SIC Standard Industrial Classification (Index) SMA (Washington) Shoreline Management Act SOAEFD Scottish Office, Agriculture Environment and Fisheries Department SSFA Shetland Salmon Farmers Association (Scotland) USCG United States Coast Guard USDA United States Department of Agriculture USFWS United States Fish and Wildlife Service USOFR United States Office of Federal Regulations WAC (State of) Washington Administrative Code WDA State of Washington Department of Agriculture WDF State of Washington Department of Fisheries (before 1991) WDFW State of Washington Department of Fish and Wildlife WDL State of Washington Department of Licensing WDNR State of Washington Department of Natural Resources WDOE State of Washington Department of Ecology WFGA Washington Fish Growers Association WHO World Health Organization (United Nations) WMP (BC Canada) Waste Management Policy WRAC Western Regional Aquaculture Center WSGP Washington Sea Grant Program vi Abbreviations of Technical Terms and Symbols AET Apparent effects threshold AVS Acid volatile sulfides BHA Butylated hydroxyanisol BHT Butylated hydroxytoluene BOD Biological oxygen demand DIN Dissolved inorganic nitrogen Eh Redox potential ER -L, ER -M Effects range low and medium FCR Feed conversion ratio H' Shannon - Wiener diversity index if Pielou's evenness index MPN Most probable number NIS Non- indigenous species NIZ Neutral impact zone NOEC No observed effect concentration NOEL No observed effect level ORP Oxidation - reduction potential PCBs Polychlorinated biphenols PCA Principal components analysis PEC Predicted environmental concentration PEL Probable effects level PNEC Predicted no- effect concentration RPD Reduction- oxidation potential discontinuity S- Total sediment sulfides SAC Sediment assimilative capacity SIZ Sediment impact zone TEL Threshold effects level TOC Total organic carbon TVS Total volatile solids vii Abbreviations of Diseases and Pathogens BKD Bacterial kidney disease BSE Bovine spongiform encephalitis CS Ceratomyxa CWD Coldwater disease EIBS Erythrocytic inclusion body syndrome ERM Enteric redmouth disease FC Fecal coliform FC -MPN Fecal coliform most probable number FUR Furunculosis ICH Ichthyopthirius IHN Infectious hematopoietic necrosis IPN Infectious pancreatic necrosis MC Whirling disease PKD Proliferative kidney disease VHS Viral hemorrhagic septicemia viii EXECUTIVE SUMMARY The US Government advocates a strong policy for national aquaculture development. The Department of Commerce (DOC) has set specific 25 -year goals to offset the annual $7 billion imbalance in seafood trade, and to double employment and the export value of goods and services. The policy is reflected in strategies proposed by the National Oceanic and Atmospheric Administration (NOAA) and its three line agencies responsible for certain aquaculture- related activities. With its broad mandate for stewardship of the nation's marine and coastal living resources, NOAA recommends that aquaculture development and environmental protection proceed hand in hand to meet public needs. Thus, in keeping with the Government's firm commitment to the United Nations Food and Agriculture Organization's (FAO) Code of Conduct for Responsible Fisheries, the line agencies of NOAA are encouraging the fisheries and aquaculture sectors to develop national Codes of Conduct, and their sub - sectors to develop and abide by Best Management Practices (BMPs). The National Aquaculture Act of 1980 recognized that the principal responsibility for national development lay with the private sector. Therefore, to increase overall effectiveness of federal research, transfer, and assistance programs for the private sector, the Act created the Joint Subcommittee for Aquaculture (JSA). JSA published a National Aquaculture Plan in 1983, which has been recently updated. A review of all the current government policy statements and the National Aquaculture Development Plan 2000 reveals considerable verbal (but not financial) encouragement for private initiatives. The Plan recognizes that aquaculture is not a unique industry with unique hazards. Its systems and practices, and its products, parallel those of many other industries and human activities. Apart from the single and pandemic caveat of protection for the environment there are no directives which promote one aquaculture system or practice over another, elevate one genera or species above another, or forward or forbid the use of any specific technology. In summary, there is no political attempt to rate or rank a sub - sector, or to advance or suppress any specific activity because of any known risk. The sub- sector of salmon fanning in saltwater is a minor part of the national aquaculture industry, but it is a valuable economic asset contributing 11% to the total value of all aquaculture products. Only 45 commercial farms produce salmonids in marine net -pens directly for food, which is just 1% of all production facilities registered in the country, and <6% of all facilities in marine and coastal waters. Another 244 federal, state, or tribal facilities in the freshwater environment produce anadromous Pacific and Atlantic salmon for restoration of the commercial fisheries, recreational fisheries, or conservation, and another 362 freshwater facilities produce salmonids for both food fish and recreational fisheries. Because of its particular niche in marine and coastal waters, American net -pen technology has resulted in considerable growth of secondary producers in the aquaculture industry, and contributes a disproportionate share to the export of national goods and services. Despite the economic success of net -pen salmon farming in the USA, this review of scientific and other literature reveals that there are many perceived and real issues with this industry which concern the American public. These areas of risk and uncertainty occur in many facets of the industry - from the effects of salmon farming on the environment, to competition with ix other economies for the same resources, and the human health and safety of farming or consuming farm products. However, based on the evidence available in the existing literature and in ongoing research, it is apparent that the degrees of risk vary considerably from issue to issue. Risk and Uncertainty in the Pacific Northwest Industry A. Issues which carry the most risk After a review of the available scientific literature, the following three issues of net -pen salmon farming in the Pacific Northwest appear to carry the most risk. All potentially impact the environment. 1. The impact of bio- deposits (fish feces and uneaten feed) from farm operations on the environment beneath the net -pens. Bio- deposits from salmon farms settle onto sediments near the net -pens and can have definite effects on their chemistry together with their benthic and infaunal biota. Firstly, with regard to the chemistry, changes can be anticipated in total volatile solids and sulfur chemistry in the sediments in the immediate vicinity of operational net -pens, together with decreased redox potential. Sedimentation rates remain fairly constant irrespective of farm size, which currently is about 1,500 mt, and a typical total volatile solids (TVS) loading is 32.9 g/m2 -day for the perimeter of such a farm near peak production. This value is reasonably close to a theoretical average of 25.7 g TVS /1n2 -day calculated for an entire 18 -month production cycle. Reduced accumulation of volatile organic material under farms can extend to distances of 145 to 205 in from the net -pen perimeter during peak production. The magnitude of the change in any of these parameters is correlated with the degree of flushing in and around each farm site. Secondly, with regard to the benthic biota, the accumulation of bio- deposits can enrich benthic communities but the actual affects depend on the hydrodynamics of each particular site. At poorly circulated sites these accumulations can exceed the aerobic assimilative capacity of sediments, leading to reduced oxygen tension and significant changes in the benthic community. Under extreme conditions sediments can become anoxic and depauperate. However, under any circumstances these effects are ephemeral and conditions have returned to normal within a period of weeks to years during fallow periods in all cases studied. Thirdly, with regard to the infaunal communities, the accumulation of organic wastes in the sediments can change their abundance and diversity. But prolonged case studies reveal significant differences between poorly- flushed and well- flushed sites. At poorly- flushed sites benthic effects are highly dependent on farm management practices. Very high salmon production levels and other activities, such as cleaning nets in -situ, result in significant changes in both abundance and diversity of infauna to distances as great as 30 m from the net - pen's perimeter. At reduced production levels, and in the absence of in -situ net cleaning, the impacts are restricted to as little 15 in, or less, downstream from the net -pens. At well- flushed sites the abundance and diversity of infaunal organisms is positively correlated with total X organic carbon, suggesting that the farm stimulates the infaunal community throughout the area. 2. The impact on benthic communities by the accumulation of heavy metals in the sediments below the net -pens. Both copper, from marine anti - fouling compounds used on net -pens, and zinc, from fish feeds, can be toxic in their ionic forms to marine organisms. Levels of copper are elevated around some net -pen farms which use government- approved anti - fouling paints on structures or, more likely, treat their nets with approved commercial compounds containing copper. The detected additions of copper in the water following the installation of newly- treated nets are biologically insignificant, except to organisms which settle on the nets. Zinc is an essential trace element for salmon nutrition, and it is added to feeds as part of the mineral supplement. Sediment concentrations of zinc are typically increased near salmon farms and the concentrations at a few farms in British Columbia have exceeded Washington State's sediment quality criteria (270 ig zinc /g dry sediment). The degree of risk is dependent on several factors. Firstly, the concentration of sulfide in the sediment is important, as typically elevated concentrations near salmon farms reduce the bio- availability of both copper and zinc thus making the observed concentrations non - toxic. Long -term studies have demonstrated that the metal concentrations return to background during the period of chemical remediation, and there is no evidence of a long -term buildup of these metals under salmon farms. Secondly, the formulation of the feed is relevant, as the majority of feed manufacturers now use reduced amounts of a more bio- available proteinated form of zinc, or a methionine analog. Monitoring of zinc continues to determine the efficacy of this change in reducing even the temporary accumulation of zinc in sediments under salmon farms. Finally, management practices play a role, as the potential rate of accumulation of copper in sediments can be significantly reduced by washing the nets at upland facilities and properly disposing of the waste in an approved landfill. 3. The impact on non - target organisms by the use of therapeutic compounds (both pharmaceuticals and pesticides) at net -pen farms. In European salmon farms therapeutic compounds are used for the control of sea lice, both for the health of the fish and to reduce their potential as vectors. The commonly used compounds are all non - specific within the Class Crustacea, and several are broad - spectrum biocides with potential to affect many phyla adversely. The degree of risk is greatly reduced by government regulation for the use of specific therapeutic compounds following extensive research in vitro and in situ on their effects on marine organisms. Case studies show that some of these compounds can be detected in sediments close to the perimeter of net -pen farms, but the levels resulting from their authorized use do not show significant widespread adverse affects on either pelagic or benthic resources. In the Pacific Northwest the use of pharmaceuticals to control sea lice has not been practiced in Washington State for over 15 years because they have not presented significant xi problems to growers, but some sea lice control agents have been used infrequently in British Columbia. Note: One more issue might be included in this first category, although the degree of risk is uncertain as there is little scientific information available. This is the impact on human health through consumption of feed -borne organic toxicants. Farmed fish are exposed to dioxins through feed ingredients, and dioxins are found in virtually all feedstuffs of animal origin, especially those containing fish meal and oils. Dioxins can be accumulated and transferred up the food chain. But the degree of risk is uncertain, as the impact of dioxin and dioxin -like compounds on human health is a recent discovery. Currently the Codex Alimentarius Commission is making efforts to reduce the risk by specifying stringent quality control of the ingredients for all animal feeds, and the potential for substituting plant proteins and oils for fish meal and fish oil in salmon diets. Although observation of the Codex by the 165 member countries is voluntary, the USA is an active signatory (see the section on Managing Risk and Uncertainty, which follows). B. Issues which carry a low risk Puget Sound is a stressed ecosystem and one continuously being degraded by further human intervention. For the last 25 years it has been an area of intense annual population growth (1.5 %) and is now home to 4 million people, with 1.4 million more projected by 2020. It is an area noted for recreational sailing and fishing, and there has been a corresponding growth in the number of support facilities for these water -borne activities. Salmon net -pen farming is another intervention competing for space and water -use, albeit minute by comparison. There are only 10 salmon net -pen farms active on sites in Puget Sound and unlike marinas, which deplete oxygen levels and elevate water temperatures, they are porous structures. Nonetheless, there are a number of facets of the net -pen salmon industry in Puget Sound which appear to carry a low risk. The majority of these eight issues concern the environment in the immediate vicinity of the farms themselves. 4. The physiological effect of low dissolved oxygen levels on other biota in the water column. Fish stocked intensively in contained areas are known to have a high oxygen demand. Decades of monitoring in Washington State have found a maximum oxygen reduction of 2 mg/L in water passing through salmon net -pens where large biomasses of fish were being fed. In most cases the reduction in dissolved oxygen has been < 0.5 mg/L. Salmon are more sensitive than most other species to depressed oxygen levels and 6.0 mg /L is considered a minimum concentration for optimum health. Therefore, if there was a localized effect associated with net -pen culture, the farmed salmon would be the first organisms affected. At coastal (oceanic) sites, farmed salmon are infrequently subjected to low dissolved oxygen concentrations when oxygen deficient up- welled water naturally intrudes into the growing area. However, these are oceanographic events which have nothing to do with the culture of fish or shellfish. In even the most poorly flushed farm in Puget Sound the culture facility does not consume quantities of oxygen sufficient to affect other organisms. xii 5. The toxic effect of hydrogen sulfide and ammonia from the bio- deposits below a net -pen farm on other biota in the water column. The accumulation of any highly- organic sediment produces ammonia and hydrogen sulfide once the oxygen is depleted. These gases most frequently cycle between oxidized and reduced states within superficial sediment layers where they modify the infaunal community. They are infrequently released into the water column. Although there is evidence from in situ studies that total sulfide concentrations in surface sediments in areas of high organic loading can exceed 20,000 iM, there is little soluble hydrogen sulfide in the water column even under poorly flushed sites. Less than 1.9% of the gases at the sediment -water interface are sulfide, and this can be reduced to 0.05% at a distance 3 in above the sediment. The majority of these gases are methane and carbon dioxide. In a well -sited farm concentrations of hydrogen sulfide gas rising through the water column are rapidly reduced by oxidation, diffusion, and mechanical mixing. For these reasons it is unlikely that toxic conditions caused by hydrogen sulfide will ever occur unless there were extremely large emissions at the sediment -water interface in shallow water. 6. The toxic effect of algal blooms enhanced by the dissolved inorganic wastes in the water column around net -pen farms. Enhancement of a harmful algal bloom by the inorganic nutrients discharged from salmon farms in Puget Sound is feasible but highly unlikely to occur in the Pacific Northwest. First, apart from the summer months, the natural atmospheric and geographical parameters of the region reduce light availability for photosynthesis, and the waters are vertically well mixed which reduces the time phytoplankton spend in the euphotic zone. Second, the physical characteristics of locations permitted for salmon farming are not conducive to the accumulation of nutrients, even when the water body is nutrient limited. Decades of monitoring have shown minimal increases in inorganic nutrient concentrations downstream from even the few sites having restricted water exchange. Small increases observed at 6 in downstream during slack tide have been statistically insignificant at a distance of 30 in downstream. Nutrient - limited embayments in Washington State have been identified and salmon aquaculture activities in these locations are discouraged and carefully managed when allowed. 7. Changes in the epifaunal community caused by the accumulation of organic wastes in sediments below net -pen farms. The effects on a wide variety of epifaunal communities have been studied in detail and the results are well - documented. One case study, with long -term (up to 10 years) monitoring, reveals significant numbers of fish, shrimp and other megafauna inhabiting the site, which appears to function as an artificial reef. Other salmon farms in close proximity all share the same characteristics, even attracting larger predators to the enhanced epifaunal communities. xiii 8. The proliferation of human pathogens in the aquatic environment. Wild salmonids carry genera of marine bacteria, such as Vibrio, Acinetobacter, and Aeromonas, some species of which are pathogenic to humans. The concern is that fish feces and waste feed might enhance populations of these pathogens. There is no evidence in the literature, or in the epidemiological records of Washington State, of any documented case in which the handling or consumption of farmed salmon has led to infectious disease in consumers or farm workers. There are many differences in the physical and chemical composition of salmon farm waste compared with human sewage discharge, and the former does not disperse over large areas but remains localized where it is metabolized by naturally - occurring marine bacteria and invertebrates. There is no credible evidence supporting a hypothesis that salmon farming increases the risk of infectious disease in humans or wild populations of animals. 9. The proliferation of fish and shellfish pathogens in the aquatic environment. Public health concerns for the safety of fish and shellfish in the vicinity of discharges of industrial and residential waste are real, and vigilance is maintained by stringent regulations and monitoring programs. The accumulation of wastes from net -pen farms is perceived as another source of human and environmental pathogens. However, there is little evidence substantiating this hypothesis. Viruses pathogenic to fish have no documented effect on human beings because they are taxa- specific. Fecal coliform bacteria are unlikely to persist in net -pen sediments rich in total organic carbon as they are specific to warm- blooded animals. Sources of fecal coliformn bacteria near salmon farms are more likely to be mammals (such as seals and sea - lions) or birds. In situ monitoring at some well - flushed net -pen farms revealed slightly more fecal coliform bacteria in water and shellfish tissues at stations closest to the farm perimeter. The sources of observed bacteria were not determined. However, all water and shellfish tissues examined were consistently of high quality and met all bacteriological requirements imposed by the National Shellfish Sanitation Program. 10. The increased incidences of disease among wild fish. Maintaining animal or plant populations in intensive concentrations can be conducive to an outbreak of disease. The specific diseases and their prevalence in Atlantic salmon stocks cultured in net -pens in Puget Sound are not shown to be any different than those of the more numerous cultured stocks of Pacific salmon in hatcheries, which in turn are not known to have a high risk for infecting wild salmonids. All Pacific and Atlantic salmon stocks currently cultured in Washington are inspected annually for bacterial and viral pathogens, and the movement of fish from place to place is regulated by permit. 11. The displacement of wild salmon in the marketplace by farmed salmonids. Salmon farmers and traditional Pacific salmon fishennen sell the same generic product, and therefore compete in the marketplace. Regulations specific to Washington State require farmed fish to be identified for the consumer. In terms of supply, salmon production by the net -pen salmon industry in the USA has been a counterbalance to the declining commercial xiv and tribal landings of Pacific salmon to meet increasing consumer demands for seafood. But in terms of demand there are distinct differences in the species produced by the two industries, and there are also differences in products available to consumers. Farmed fish are sold mostly as whole dressed fish and fresh fillets, while the typical disposition of the total annual wild catch (not by species) of the five Pacific species is whole fish, fresh and frozen, and canned products. In terms of price and availability, Atlantic salmon has an all -year round advantage and therefore a competitive edge over Pacific salmon harvested in the commercial fisheries. They are also relatively cheap to produce for the market. Per harvested fish, the cost to the private producer of farmed Atlantic salmon is currently about $1 per pound, head on, gutted weight. However, irrespective of its origin, production of salmon in Washington has little or no measurable effect on prices determined by global supply and demand, or reducing the large importation of farmed salmon from Norway and Chile. C. Issues which carry very little or no risk Despite the fact that two of the issues in this final category have many sub -sets, all three issues are deemed to carry very little or no risk. Two are specific to the environment of the Pacific Northwest, and the third concerns human health and safety in general. 12. The escape of Atlantic salmon - a non - native species. Since a reporting regulation was imposed in 1996, the records show that some 600,000 fanned salmon escaped between 1996 and 1999. These were mostly fish between 0.5 - 1.5 kg in weight. Only 2,500 of these particular escapees were subsequently accounted for. In addition, between 1951 and 1991 the State made 27 releases of 76,000 smolts of Atlantic salmon of various sizes into the Puget Sound Basin in attempts to establish this prized species on the west coast. Many escapees were taken immediately by recreational fishermen angling close to the net -pen farms, and a few others were taken at random by commercial fishermen in Puget Sound and beyond. A few fish (which may have originated in either Washington or British Columbia) have been recovered as far away as the Alaskan Peninsula. However, the numbers recovered have always been small and the rest remain unaccounted for, and it is assumed that the domesticated existence and docile behavior of farm fish makes them easy victims of predators, especially the large populations of marine mammals which now exist throughout the Pacific Northwest. The following list summarizes the sub - issues of concern regarding escaped Atlantic salmon in Puget Sound which appear to carry little or no risk. (i) Hybridization with other salmonids There is no evidence of adverse genetic impacts associated with escaped Atlantic salmon on the west coast of North America as they do not have congeneric wild individuals with which to interact. Hybrids between Atlantic salmon and the Pacific salmonid species can be produced in vitro, but with difficulty. Hybrids between Atlantic salmon and brown trout, another non - native species, are more easily produced in vitro, and occur readily in nature. xv Atlantic salmon x Pacific salmonid hybrids are not observed in nature, whether for introduced Atlantic salmon in North America, or for introduced North American salmonids to Europe and the other continents. By comparison, successful hybridization between some North American salmonids is regularly recorded. (ii) Colonization of salmonid habitat Atlantic salmon are unlikely to colonize salmon habitat in the Pacific Northwest. Accidents occur, and farm fish of various sizes occasionally escape in large numbers. About 1 million Atlantic salmon have escaped from net -pen farms in Puget Sound and British Columbia since 1990. Only a few were accounted for in recreational and commercial fisheries. In addition to escapes, deliberate releases of Atlantic salmon to establish local self - sustaining populations have been made in the Pacific Northwest since the beginning of the century, with the last release in 1991. Although routine monitoring programs occasionally find naturally- produced juveniles, naturally- produced adults have yet to be observed. (iii) Competition with native species for forage Like all salmonids Atlantic salmon are high on the food chain. But few prey items of any sort have been found in the stomach contents of escaped Atlantic salmon which have been recaptured. As survival in the wild is extremely low for escaped farm fish, it is assumed that their domestic upbringing makes them poor at foraging successfully for themselves. Therefore, the few natural prey items any escaped fish might consume is negligible, especially when compared with the competitive food requirements of the juvenile Pacific salmon deliberately released into Puget Sound and its tributaries from hatcheries. (iv) Predation on indigenous species All salmonids are predators. However, all analyses of the stomachs of recovered farm Atlantic salmon, and of the few naturally- produced juveniles caught in the wild, have failed to show evidence of preying on native salmonid species. This is not the case of other introduced non - native species which are known to be voracious predators of juvenile Pacific salmonids. Some of these non - native predators have been deliberately and /or accidentally introduced and are now managed for sustained natural reproduction to enhance recreational fisheries and for their contribution to sport fishing revenues. (v) Vectors for the introduction of exotic pathogens Provided no new stocks or eggs of Atlantic salmon are introduced into the region, farm Atlantic salmon cannot be a vector for the introduction of an exotic pathogen into Washington State. The extensive movement of aquatic animals and plants globally is known to carry the risk of introducing exotic diseases but movement of fish into and within Pacific Northwest states is now well - regulated with the requirement for disease -free certification. No Atlantic salmon stocks have been transferred into the State of Washington since 1991. 13. The impact of antibiotic- resistant bacteria on native salmonids. Drugs are used in all hatcheries and rearing facilities, and over -use of drugs is known to increase the resistance of many bacteria. Therefore there is the potential for development of antibiotic - resistant bacteria in net -pen salmon farms or Atlantic salmon smolt hatcheries xvi which could in time impact native salmonids. All drugs used in fish culture in the USA are scientifically safe and efficacious, and approved by the FDA. Drug resistance has been commonly observed in public fish hatcheries in Washington State for over 40 years and no resulting adverse impacts on wild salmonids have been reported. 14. Impacts on human health and safety. The consumption of salmon farm products and /or working in and around the vicinity of net - pen salmon farms are perceived by some people to be concerns of human health and safety. The following list summarizes these sub - issues of concern regarding human health and safety which appear to carry little or no risk, either directly or indirectly. (i) Heavy metal contamination of farm products The three main sources of heavy -metal contamination found in coastal waters where fish and shellfish are farmed include industrial and municipal waste discharge, anti - fouling paints, and various organic pesticides, herbicides, and hydrocarbons. Problems with industrial and municipal waste discharges have long been recognized, and exposure to toxic chemicals from these sources are minimized by licensing fanning areas away from sources of contamination. The hazards of heavy metal contamination, principally methyl mercury and tributyl -tin, are currently addressed by regulatory controls. As intensive fanning relies on high quality formulated diets, the ingredients are regularly monitored to avoid possible contamination of feed with methyl mercury; and the use of tributyl -tin, once a common biocide used in anti- fouling bottom paints and for treating net -pens structures, is totally banned in North America. (ii) Rendered animal products in animal feeds The use of rendered animal proteins, once common in formulated feeds for many species of fish as well as other farm animals, has been curtailed by public concern over possible amplification of bovine spongiform encephalopathy (BSE), or'mad cow disease'. Although not specifically prohibited by regulation, rules designed to prevent cross - contamination of feeds and feed ingredients at time of manufacture have effectively eliminated the use of these ingredients from salmon feeds. There are no scientific studies on the potential for BSE transmission to humans through discharge of BSE prions into the aquatic environment, but based on studies of the discharges from rendering plants to aquifers used for drinking water, the possibility of infection by this route is remote. (iii) Genetically modified (GM) ingredients in fish feeds Although safety concerns regarding the use of GM ingredients in animal feeds have not been substantiated scientifically, most feed suppliers continue to offer only GM -free feeds. The use of GM oilseeds and grains in animal and human foods has gained considerable public attention in North America because of uncertainties regarding their effects on human health and the environment. (iv) Other ingredients and additives in animal feeds The use of pigments, hormones, antioxidants, and vitamin /mineral supplements in animal feeds is strictly controlled by FDA regulations. Although growth hormones are given commonly to other farm animals, such as poultry and cattle, their use in food fish is xvii prohibited. Additives such as pigments, antioxidants, and other nutritional supplements have been proven safe and their use in fish feeds is permitted by FDA regulation. (v) Residual medicines and drugs in farmed products Antibiotic residues in any farmed animals, including fish, is of concern to consumers because they might induce allergic reactions, have toxic effects, or simply increase antibiotic resistance in human pathogens. All drugs used in aquatic species farmed in the USA have been proven safe and efficacious, and are undetectable at the time of harvest when withdrawal times prescribed by the FDA are followed. At present only two antibiotics are registered and sold for use in the USA as feed additives for disease control in farmed fish. The use of parasiticides and vaccines is similarly restricted by FDA regulation. There could be a risk to consumers if these chemical compounds and vaccines were misused or administered by untrained workers. (vi) Biological hazards in farm products Potential biological hazards include parasites, bacterial and viral infections, or naturally produced toxins. To date there have been no reported cases of any fish parasites or pathogenic organism from farmed fish causing disease in humans. Most hazards have been eliminated by strict adherence to BMPs on the farm and at harvest, and /or by HACCP regulations during processing. (vii) Transgenic farm fish The perceived hazards of transgenic farms products, such as human allergies or unnatural competitors in the ecosystem, are hypothetical issues for net -pen salmon farming in Puget Sound. There is no evidence in the literature that transgenic fish have been raised or are being raised in the Pacific Northwest, and there are no plans to raise them. (viii) Workers' safety Compared with commercial fishing, which is identified as one of the most hazardous of occupations, net -pen salmon farms provide a safe working environment. Some fatalities and injuries in the national aquaculture industry from physical accidents have been reported but not specifically among net -pen salmon farmers. (ix) Public safety and navigational hazards There is no evidence that floating net -pen structures in Puget Sound are a hazard to the safe navigation of Washington's large and diverse boating communities. Firstly, permits from the US Coast Guard and Army Corps of Engineers are required for each farm to ensure that it complies with navigation and water safety regulations. Secondly, the complexes are small in total area. The ten active sites, which range in size from 2 - 24 acres, occupy only 131 acres of navigable surface waters from the State. The actual surface areas of the net -pen structures themselves occupy only 21.2 acres in total, with each complex ranging from 0.48 - 3.9 acres. By comparison the State has 77 aquatic land sites leased for commercial shellfish production, with a total area of 81,500 acres. xviii (x) The impact on nearby property values In the competition for coastal sites between the salmon farming industry (requiring access and good quality water conditions), and residential real estate (requiring access and industry-free views) there is no evidence that the sight and presence of net -pen operations has impacted the values of coastal properties in Puget Sound. Managing Risk and Uncertainty A. The environment There is considerable evidence available in the scientific literature to evaluate any potential risk of net -pen salmon farming on the environment of the Pacific Northwest. Most issues have been studied in great detail for some 20 years, and in many similar environments in different parts of the world. The results are well documented, and a common denominator is that the potential for environmental impact depends primarily on the site of each individual farm. The most important rule in the management of risk is therefore the careful selection of the site. Responsible permitting of each site is also playing an important management role. The National Pollution Discharge Elimination System (NPDES) permit has been effective in regulating the degree of allowable effect, but its impact must now be supplemented with the strict adherence by site operators to a well- defined set of industry BMPs which are based on good scientific information. These BMPs can be specific to a particular farm, or they can be overarching for the entire industry. Scientific evidence in the literature indicates that the potential changes in the sediments below operating net -pen farms bear the most risk for the environment. Continuous monitoring of the sediments under and around farm sites for many years has produced an extensive database of chemical and biological information, and specific parameters are now being used to predict the environmental effects. Key parameters include, inter alia, sediment grain size, total volatile solids or total organic carbon, redox potential, free sulfide concentrations and ultimately invertebrate community assessment. Modeling programs are also beginning to provide insight into the environmental response to farm waste, but these are not yet adequate to make reasonable quantitative predictions. Long -term monitoring of the sediments has also revealed that chemical and biological recovery of the substrate under and around farm sites occurs naturally without human intervention or mitigation. In situ data show that physicochemical recovery can occur within weeks or months at some sites, and within two or three years at others. Biological remediation of the sediments follows after a period of chemical remediation, and the speed of recovery depends on the seasonal recruitment of new infauna. B. Human health and safety Net -pen salmon farming is a relatively new global industry, but one which is very highly regulated in the USA. Atlantic salmon cannot be farmed in the Pacific Northwest or along the xix Northeastern Atlantic coast under any conditions which might pose a hazard to human health by exposure to environmental contaminants, pathogens, or infectious disease organisms. Farm salmon cannot be treated with any chemo- therapeutic compounds not approved by the US Food and Drug Administration (FDA). The health and safety of the farm workers are protected similarly by labor and industrial regulations. The United Nations Food and Agriculture Organization (FAO) in 1995 formally adopted a Code of Conduct for Responsible Aquaculture, which was followed in 1997 by a detailed document called Responsible Aquaculture at the Production Level. These documents detailed areas of concern regarding the responsible, safe, and effective use of feeds and feed additives, chemicals and chemotherapeutants, and other aquaculture practices which might reduce health and safety risks to humans. Food safety issues associated with farmed aquatic organisms have been subsequently evaluated by the World Health Organization in a working committee of the Codex Alimentarius Commission. The USA, which has agreed to abide by the intentions of all these international codes, has also developed national guidelines regulating the safety of all seafood, including farmed products. These are administered by the FDA. The literature reveals that the net -pen salmon farming industry in the Pacific Northwest is integrating all these safety assurance and quality control measures at all levels of the farm -to- table food - safety continuum. It has been applying Hazard Analysis and Critical Control Point (HACCP) methods wherever possible since their inception, and is in the final stages of publishing its own BMP. C. Farm escapes Accidents have occurred enabling farmed salmon to escape. Such incidents are likely to continue following some unique meteorological event or human error. The possible negative consequences of such events have been limited in part by implementation of pre - prepared recovery plans, some of which have included deregulating catch limits for public fishing on escaped farm fish, and by programs to monitor the background populations of fish in nearby watersheds. These responses will continue to be effective management practices to minimize impact, together with further advances in the technology. Improvements in the design and engineering of net -pens and their anchorages, and the use of new net materials, are continuing to reduce the incidents of loss following structural failure or damage from large predators. xx TABLE OF CONTENTS TABLEOF CONTENTS ....................................................................... ..............................1 FOREWORD................................................................................... ............................... 3 1. GENERAL DEVELOPMENT OF AQUACULTURE IN THE USA .......................... 5 1.1 Federal Leadership for the National Aquaculture Industry ..... ............................... 5 1.2 The National Salmon Aquaculture Sector .............................. ............................... 6 2. SALMON AQUACULTURE IN THE STATE OF WASHINGTON ......................... 9 2.1 Salmon Production for Restoration and Conservation ............ ............................... 9 2.2 Salmon Production for Food ................................................ ............................... 11 2.3 Interactions of Farming with Commercial and Recreational Fishing ................... 12 2.4 Interactions of Farming with Recreational Activities in Puget Sound .................. 16 2.5 Economic Benefits of Salmon Farming to the State ............. ............................... 17 2.5.1 The contribution of salmon farming to seafood production ............................ 17 2.5.2 The impact on employment and wages ........................... ............................... 18 2.5.3 The impact on coastal property values ............................ ............................... 19 2.6 The Regulatory Structure for Commercial Enterprises ......... ............................... 20 2.7 The Regulatory Structure for Public and Tribal Hatcheries .. ............................... 23 3. POTENTIAL ISSUES FOR HUMAN HEALTH AND SAFETY ............................. 25 3.1 General Food Safety ............................................................ ............................... 25 3.2 Chemicals and Chemical Contamination .............................. ............................... 26 3.2.1 Heavy metals ................................................................. ............................... 26 3.2.2 Manufactured feeds ........................................................ ............................... 27 3.2.3 Chernotherapeutants ....................................................... ............................... 31 3.3 Biological Safety ................................................................. ............................... 33 3.4 Quality and Safety of the Products ........................................ ............................... 34 3.5 Worker Safety ..................................................................... ............................... 35 4. SALMON FARMING AND THE ENVIRONMENT ................ ............................... 36 4.1 The Effects of Organic Wastes from Net -pen Salmon Farms .............................. 36 4.1.1 Waste feed ..................................................................... ............................... 36 4.1.2 Fish feces ....................................................................... ............................... 37 4.1.3 Fish carcasses as wastes ................................................. ............................... 38 4.1.4 Bio- fouling organisms as wastes .................................... ............................... 38 4.1.5 Measurement of organic wastes ..................................... ............................... 39 4.2 Dissolved Inorganic Wastes ................................................. ............................... 41 4.2.1 Dissolved nitrogen and phosphorus ................................ ............................... 41 4.2.2 Heavy metal accumulation in sediments ......................... ............................... 42 4.3 Pathogenic Organisms in the Vicinity of Net -pen Salmon Farms ......................... 45 4.3.1 Fecal coliform bacteria ................................................... ............................... 45 4.3.2 Farm wastes ................................................................... ............................... 46 4.4 The Effects of Therapeutic Compounds ............................... ............................... 47 4.5 Farm Sediments ................................................................... ............................... 51 4.5.1 Monitoring environmental effects on sediments ............. ............................... 51 4.5.2 Biological changes in the water column and sediments .. ............................... 53 4.5.3 Hydrogen sulfide gas production in sediments ............... ............................... 55 1 4.5.4 Dissolved oxygen ........................................................... ............................... 56 4.5.5 Changes in the local fish community .............................. ............................... 56 4.5.6 Physicochemical changes in the sediment near salmon farms ........................ 57 4.5.7 Biological effects ........................................................... ............................... 57 4.5.8 Case histories describing benthic responses to salmon farming ....................... 59 4.6. Recovery and Remediation of Sediments ............................ ............................... 60 4.6.1 Chemical remediation .................................................... ............................... 60 4.6.2 Biological remediation ................................................... ............................... 61 4.6.3 The assimilative capacity of the local environment ........ ............................... 65 4.7 Managing the Environmental Effects Associated with Salmon Farms ................. 65 4.7.1 Monitoring experiences .................................................. ............................... 65 4.7.2 Management by modeling salmon farm wastes .............. ............................... 68 4.7.3 Risk management through NPDES permit standards ...... ............................... 69 4.7.4 Risk management practices in British Columbia ............ ............................... 72 5. ATLANTIC SALMON and the LOCAL ECOSYSTEMS ......... ............................... 74 5.1 General Issues of Artificial Propagation of Salmonids .......... ............................... 74 5.2 Genetic Interactions of Artificially- Propagated Pacific and Atlantic Salmon........ 75 5.2.1 Hybridization ................................................................... .............................75 5.2.2 Genetic dilution and alteration of the wild salmonid gene pool ...................... 77 5.2.3 Colonization by Atlantic salmon .................................... ............................... 78 5.2.4 Interactions of wild salmon and transgenic fish .............. ............................... 79 5.3 Epidemics and the Transmission of Waterborne Disease ...... ............................... 80 5.3.1 The origin and disease status of Atlantic salmon stocks in Puget Sound ........ 80 5.3.2 Disease of salmonids ...................................................... ............................... 80 5.3.3 Infectious disease therapy .............................................. ............................... 83 5.3.4 Disease interactions between wild and propagated salmonids ........................ 84 5.3.5 The scale of artificial propagation .................................. ............................... 85 5.3.6 Disease control policies in Washington and the USA ..... ............................... 86 5.4 Potential Ecological Impacts of Atlantic Salmon in the Pacific Northwest ........... 87 5.4.1 Social interactions between Pacific and Atlantic salmon ............................... 87 5.4.2 Predation by Atlantic salmon ......................................... ............................... 88 5.5 Potential Impacts of Propagated Pacific Salmon ................... ............................... 88 5.6 Adverse Impacts of Non - indigenous Fish Introductions ....... ............................... 91 5.7 A Perspective of Salmon Culture in Northwest Waters ........ ............................... 94 5.8 NMFS Biological Status Reviews of West Coast Pacific Salmon Stocks ............. 96 6. POST SCRIPT .......................................................................... ............................... 97 7. REFERENCES ......................................................................... ............................... 98 2 FOREWORD Many government regulators are now encouraging all intensive food production industries, including capture fisheries, to adopt and observe protocols and methodologies to make their activities more compatible with the environment. The majority of these industries are responsive to this challenge and are beginning to comply through self - developed codes of practice and best management practices. A code of practice (COP) describes a set of general practices and standards to guide human conduct in a specific endeavor in order to maintain conformity and consistency. COPs are voluntary in principle but invariably the overarching organization, such as the Federation of European Aquaculture Producers (FEAP), makes them obligatory in universal interest (FEAP 2000). Best management practices (BMP), on the other hand, describe a specific (and often detailed) set of protocols, practices, or procedures to manage and carry out specific operations in a responsible manner, with respect to the social and ecological environment, based on the best available scientific information and an assessment of risk. BMPs are voluntary in principle but invariably the overarching organization makes them mandatory in the interest of the specific industry. Each element in any code of practice is based on the best scientific information available or the most practical experiences. Consequently a code of practice is not a finite entity in itself but a never- ending dynamic process ready to incorporate each relevant scientific discovery and each new technical experience. In 1997 the Environmental Assessment Office of British Columbia (EAO) published the British Columbia Salmon Aquaculture Review (BCSAR). A section of this comprehensive document (EAO 1997) discussed key environmental issues based on reviews of over 750 scientific and technical papers, and many pertinent government documents. This background information greatly assisted the British Columbia Salmon Farmers Association (BCSFA) to develop its individual code of practice in 1999 (BCSFA 1999), and the New Brunswick Salmon Growers Association will complete its code in 2001 (N. Halse, NBSGA, personal communication). The same efforts have been made in other countries, and in 2000 the Shetland Salmon Farmers Association of Scotland produced its code of best practices (SSFA 2000). Government and salmon farmers in the US on both the west and east coasts have not moved as quickly as those in Canada, or indeed as those in Norway, Scotland, and Ireland. This is because most of the sub - sectors of American aquaculture are very small, unlike those of US agriculture, and individual farmer's associations do not have the capacity or scientific information on which to develop appropriate codes. Consequently, research staff of the Northwest Fisheries Science Center ( NWFSC) has prepared this scientific review to help salmon fanners in the Pacific Northwest codify their industry. Research by scientists of the NWFSC first instigated the industry of net -pen salmon farming in saltwater in North America at the Manchester Research Station in the early 1970s. Subsequently salmon have been farmed extensively in the Pacific Northwest in 3 the protected waters of the Georgia Straits and Puget Sound. Therefore it is fitting that the NWFSC is guiding the local industry to be compatible with its ecological surroundings. This document is the result of the efforts of the Resource Enhancement and Utilization Technologies Division (RELIT) of the NWFSC. It is not a comprehensive review of the literature on net -pen salmon farming from its historical beginning, like the BCSAR, and it is not trying to update the BCSAR with citations to information after 1996. The document is intended to stand in its own right and fulfil a set of three objectives: • First, from the perspective of the US and local stakeholders it annotates the best scientific information regarding local issues arising from or affecting development of net -pen salmon farming in the Pacific Northwest. • Second, together with other literature reviews, it completes an information base for all stakeholders to make a qualified and quantified analysis and assessment of any risks associated with salmon farming in the area. • Third, together with these risk assessment studies, it will assist salmon farmers to develop an appropriate COP for their industries, and in particular the salmon farm and hatchery managers in the Pacific Northwest, to develop a set of BMPs for their specific activity. 0 1. GENERAL DEVELOPMENT OF AQUACULTURE IN THE USA The first chapter initially summarizes the national leadership for development and growth of the aquaculture sector by a range of government policies and legislation spread over half a century. It explains government direction was first to mitigate for displaced wildlife resources but now its objectives are to reduce imbalances in seafood trade, enhance commercial fisheries, and assist conservation of endangered species. It notes that national development has been guided for twenty years by the National Aquaculture Act of 1980, and a National Aquaculture Development Plan which has been continually under review and updated. The second part of the chapter summarizes the national salmon aquaculture sector. It provides current data for the two key pillars of the sector, specifically production for enhancement of commercial and recreational salmon fisheries, and production of food -fish for domestic and export markets. It explains briefly the different commercial end - products of salmon aquaculture, and the contribution to the national economy made by the industry's producers of good and services. 1.1 Federal Leadership for the National Aquaculture Industry Modern aquaculture is not new technology to the USA. Early attempts to culture fish and shellfish in North America date back to the 1850s and 1860s, and it was the intensity of the early pioneers to raise fish to enhance the indigenous fisheries which persuaded the US Government to create the US Fish Commission in 1871. The Commission, in time, became the Bureau of Commercial Fisheries and subsequently the National Marine Fisheries Service (NMFS). Early development of aquaculture in the US was continuously expanded by legislation. Predominantly it was federal legislation to compensate for salmon fisheries affected by federal water projects in the Columbia River Basin. The Federal Power Act of 1920 and the Fish and Wildlife Coordination Act of 1934 were responsible for over $400 million spent on salmon hatcheries and fish passages constructed at that time, and in 1938 the Mitchell Act authorized appropriation of federal tax revenues annually to restore and enhance the salmon resources of the Columbia Basin as a whole. As a result, a substantial technical and scientific research and information base was established in the country on almost every aspect of the biology and culture of Pacific salmon. This knowledge and experience was a significant factor in the farming of both North American and European salmonids some 30 years later. Encouraging development of aquaculture in the US was again the government's policy behind the National Aquaculture Act of 1980. Recognizing the growing diversity of modern aquaculture, and multi- agency responsibilities, the 1980 Act established a coordinating group, the Joint Subcommittee on Aquaculture (JSA) which continues in existence today. The JSA has been responsible for developing and updating the National Aquaculture Development Plan (NADP 2000), which identifies the relative roles of the Department of Agriculture (USDA), the Department of Commerce (DOC), and the Department of the Interior (DOI). Within DOC, the National Oceanic and Atmospheric Administration (NOAA) has a strong statutory base for the promotion and regulation of marine - related aquaculture. Historically this has been achieved through NMFS programs and the National Sea Grant College Program (NSGCP) in the Office of Oceanic and Atmospheric Research (OAR). In 1999 the Secretary of Commerce signed an Aquaculture Policy for DOC identifying seven specific objectives. Among quantified targets for the aquaculture sector to achieve by the year 2025, the policy strongly emphasized technological development and growth in harmony with the environment. The same message is evident in the NOAA policy on aquaculture, signed in 1998. The underlying goal is for development through environmentally sound production practices. Particularly noted is the use of aquaculture technologies for the enhancement of threatened populations but also avoiding negative impacts on any wild stocks. The policies of both DOC and NOAA are very evident in the draft National Marine Aquaculture Act of 1999 for further development of aquaculture into the exclusive economic zone (EEZ). In conclusion, the federal government continues to encourage sector development through applicable legislation, funding programs, and agency policies. It has set 25 -year targets for increased domestic production to help offset the large annual trade deficit in seafood, and to double employment and exports of goods and services. In addition, it wants new technologies for increased diversification of the industry, and for enhancement of wild stocks. Finally, it demands economic development with the necessary safeguards for the environment to be enforced through total compliance with industrial codes for responsible aquaculture. NADP 2000 is not detailed regarding different aquaculture products or production technologies. Irrespective of any sub - sector, the Plan repeats the challenge for better knowledge about possible interactions between aquaculture and the natural environment to minimize, (i) the potential for habitat degradation, (ii) transmission of diseases, (iii) potential genetic dilution of wild stocks through interbreeding with cultivated strains, (iv) introduction of non - indigenous species into natural waters, and (v) discharges of wastes, toxins, and excess nutrients QSA 1999). 1.2 The National Salmon Aquaculture Sector The Census of Aquaculture recently published by USDA (USDA 1999) reports the value of salmon produced and sold for food or food /sport in 1998 was $104 million, or about 11% of the total value of national aquaculture products. The Census notes that 244 farms produced salmon for restoration or conservation purposes. It defines these farms as mostly non - commercial operations, such as federal, state, or tribal facilities (which were mostly hatcheries), academic, and private research facilities with products valued above $1,000 in the year of the Census. Within this total, the Census records that 238 farms produced 2.4 billion fish (288 million lb or some 130,000 mt), and 47 farms produced 71 million salmon eggs or seed for distribution. Another 362 farms produced trout for 31 restoration or conservation, of which 360 farms produced 177 million fish (32 million lb or 1,450 mt), and 72 farms produced 163 million eggs or seed for distribution. In addition the Census notes that 47 farms in the country produced salmon commercially, of which 45 raised food -size fish. This number is about 1% of all the aquaculture farms recorded in the country. It is assumed that almost all these salmon farms are saltwater farms. The Census records that there are only 815 of the 4,028 recorded aquaculture facilities and /or farms in the country which operate with or within saltwater, and the majority raise mollusks or tropical fish. The word 'farm' in the literature can be confusing, as the definition adopted by the Census is specific to its own use. Typically, farm' applies to a physical complex for production but this, in turn, can refer to a complex on a single registered site, or a number of complexes operated by a single business which owns or leases a number of registered sites close together. Using its definition of a commercial or non - commercial place from which $1,000 of products were sold, the Census shows that the majority of salmon farms operate in the States of Alaska (19), Maine (12), and Washington (9). But Alaska prohibits private farming of all fish species, and therefore the number refers to salmon hatcheries operated by private non - profit corporations (PNPs) which rear to release and subsequently harvest — an aquaculture practice known as 'ocean ranching.' The word 'farm' can in fact be applied to any location where primary production of aquatic animals and plants takes place. There are five primary producers in the salmon aquaculture sub - sector in the USA, and their end products are: (i) certified disease -free eggs from a freshwater hatchery, (ii) pre - smolted juveniles from a freshwater nursery farm, (iii) smolted juveniles from a saltwater nursery farm, (iv) marketable fish from the saltwater grow -out farm, and (v) marketable products after processing. Active in these areas are both non - commercial and commercial enterprises. The non- commercial enterprises are all the federal, state, and tribal organizations that own and operate only hatcheries and other licensed rearing facilities to produce pre - smolts and smolts for release to enhance commercial and recreational fisheries. Commercial enterprises are private companies which invariably own or have controlling interests in at least four end - products, and possibly all five. The Western Regional Aquaculture Center (WRAC) noted that the State of Washington Department of Fisheries and Wildlife (WDFW) had close to 1,000 aquaculture licenses on file in 1995, of which 74 were for salmon and 187 for trout production (WRAC 1999). These numbers included both active and non - active licenses, as licenses are not required to be updated annually. There are many secondary producers in the industry throughout the country. Their manufactured end products include, for example, (i) hardware, such as craned vehicles, service boats, floating cages, net -pens, feed silos, egg incubators, hatchery tanks, raceway tanks, pumps, pipes, etc., (ii) formulated feeds, (iii) technical apparatus and laboratory equipment, (iv) veterinary medicines and drugs, and (v) a variety of expert services. Again, many commercial enterprises active in primary production are active in secondary 7 production, particularly with ownership or controlling interest of subsidiaries in fish nutrition and health. Within the last 2 years several large companies in Europe and North America have spread their business risk throughout the global salmon industry by consolidating their hold on substantial lengths of the value chain. Secondary producers are very important to the national economy. In a recent aquaculture policy statement, DOC recognized that the annual value of US exports of goods and services was $500 million, and set a goal of $2.5 billion by the year 2025 (DOC 1999). 2. SALMON AQUACULTURE IN THE STATE OF WASHINGTON The second chapter is predominantly regional in scope and deals mostly with the pros and cons of salmon aquaculture in the State of Washington. The first section provides quantified data regarding aquaculture for restoration and conservation of salmon fisheries, and some economic costs and benefits. The second section provides data regarding the physical extent of the commercial salmon farming industry for food production, making comparisons with other parts of the US and overseas. The third section describes some of the interactions of the salmon farming industry in Puget Sound with commercial and recreational fishing activities, in particular with other fish populations and in the marketplace. The fourth section deals with economic benefits to the State, particularly at the regional and local levels. These include the contribution to seafood production, the impact on employment and wages, and the impact on coastal property values. The two final sections concern the current regulatory structure for commercial enterprises raising food fish in the State of Washington, and the regulatory structure for public and tribal hatcheries raising juvenile salmon for commercial and recreational fisheries. 2.1 Salmon Production for Restoration and Conservation The State of Washington has one of the largest artificial production systems for salmonids in the world. Its hatcheries program operates 24 complexes (groups of hatcheries) with more than 90 rearing facilities (WDFW 2000). These include production hatcheries, net -pens, acclimation sites, and rearing ponds, as well as several remote egg - incubator locations and small -scale cooperative rearing programs with community and educational groups. Washington hatcheries produce approximately 75% of all coho and chinook salmon, and 88% of all steelhead trout harvested statewide. Trout hatcheries produce over 90% of the statewide harvest. Approximately 700,000 adult salmonids of several species return to hatcheries each year, and more than 300 million eggs are collected from them for future generations. All fish raised in State hatcheries are released into the open waters of Washington. In 1995 some 201 million salmon, 8.5 million steelhead, and 22.6 million trout and warm -water fish were released. In addition, there are 12 federal and 17 tribal rearing facilities which produce another 50 million salmonids for release (WDNR 2000a). Between 1951 and 1991 WDFW also made 27 releases of Atlantic salmon in attempts to establish the species in State waters. A total of 76,031 parr and smolts were released varying in size between 0.25g and 450g (Amos and Appleby 1999). Until 1979 the origin of the stocks was Gasp6 River in Canada, most of which came through broodstocks held in Oregon. From 1980 the stocks were a mix of origins, including Gasp6 River, the Penobscot and St. John's Rivers (Maine), together with some landlocked stocks from Grand Lakes (Maine). 9 The State of Oregon, which shares the Columbia Basin with the States of Washington and Idaho, currently operates 34 hatcheries and 15 other rearing facilities. Annually these facilities release about 43 million Pacific salmon, 5.7 million steelhead, and 8.3 million trout. In the last decade about 80% of all trout, and 70% of all steelhead and coho harvested in Oregon were propagated artificially (ODFW 2000). More recently, net -pen complexes have been used for conditioning and releasing salmon in areas around the mouth of the Columbia River to create local commercial and recreational fisheries. The Clatsop County Economic Development project near Astoria released about 3.5 million coho, and 1.1 million chinook in 2000 (OSU 2000), and expected a return of 5,000 spring chinook from its previous releases. Using 1990s data for the production, release, and survival of Pacific salmon from Columbia Basin hatcheries, where the juveniles may be retained for up to 18 months, Radtke (2000) calculated that the hatchery cost per harvested coho salmon was $58.89, with an economic value per harvested fish (7 lb. at $1.00 /lb.) of $76.07. For spring/summer chinook (12 lb. at $1.50 /lb.) the costs per harvested fish were $404.55 and $109.36, respectively, and for fall chinook (15 lb. at $1.25 /lb.) they were $35.00 and $114.5, respectively. For steelhead (9 lb. at $0.60/lb.) the costs were $292.86 and $74.8, respectively. He also estimated the (fixed plus variable) cost per smolt from hatcheries in Oregon into the Columbia Basin for salmon (all species) to be between $7.20 -7.42 per lb of smolt. Current estimates by WDFW (K. Amos, WDFW, personal communication) put the cost at between $3 -4 per lb. of smolt. This is because outside the Basin hatcheries generally retain many stocks for a month or less, primarily chum salmon, which results in a lower cost per smolt. Puget Sound has a large number of artificial propagation facilities releasing juvenile salmonids into its freshwater basin every year. Based on historical data over 30 -40 years, a total of 30 facilities together released about 29 million coho every year (NMFS 1995). Some 43 facilities released 65 million chum (NMFS 1997a), and 69 rearing facilities released about 44 million chinook (NMFS 1998). There are also 10 facilities which release some 1.5 million- winter steelhead and 400,000 summer steelhead, mostly smolts, (NMFS 1996). Collectively, these facilities now release about 50 million juvenile salmon (equivalent to some 300 mt of fish) into the Puget Sound Basin on an annual basis. The reductions in number of fish released are due in part to changes in hatchery strategies to lessen the potential adverse impacts on wild salmonids. Forster (1995), in his evaluation of cost trends in farmed salmon, reported the current (1994/95) production cost of an Atlantic salmon smolt (100 g in weight, or 3.5 oz) in Chile, Norway, and Canada was between $0.75 -1.25 each, which included $0.5 -0.15 for the eyed egg, and $0.12 -0.20 for the feed. Prices asked by smolt producers, however, might be $1.50 -4.00, depending on the size at sale, with $2.00 being the average for a 100g fish. Grez (Salmones Camanchaca S.A. Chile, personal communication) reported that fixed and variable production costs for rainbow trout and coho salmon smolts in Chile in 1996 were $0.21 -0.26, and a little more for Atlantic salmon depending on the source and cost of eggs. Rainbow trout and coho salmon smolts were sold for $0.55 -0.65 each, and Atlantic salmon smolts for about $1.00. 10 In his report to the State of Alaska Department of Commerce and Economic Development, Forster (1995) estimated that the cost to the private producer of farmed Atlantic salmon was $1.14 -2.03 per pound, head on, gutted weight. Based on advances in technology and increased faun efficiencies, he projected that production costs for the year 2000 would be between $0.73 -1.19 per pound, head -on, gutted weight. His current estimate is that it is about $1.00 (J. Forster, Forster Consulting, personal communication). 2.2 Salmon Production for Food A production site for salmon farming invariably consists of a complex of on -shore buildings and tanks, and offshore floating cages or net -pens. Floating cages are usually associated with the freshwater nurseries for smolt production, and net -pens are associated with grow -out and production of marketable fish in marine waters. The 1998 Census of Aquaculture (USDA 1999) defines cages as structures 'normally used in larger, open bodies of water such as lakes or rivers,' while net -pens are 'enclosures usually placed in protected bays or inlets used to produce fish.' Weston (1986), in his study of the environmental effects of floating mariculture in Puget Sound, recorded nine sites where Pacific coho and /or Atlantic salmon were raised commercially in net -pen facilities. Another permit had been granted, and others were pending. There were also three more sites for non - commercial culture, which is for research or to enhance fisheries. In addition there were five major and eight minor net - pen facilities used by tribes or sportsmen's clubs for delayed release of coho and chinook salmon. By 1990 there were 13 commercial sites, each limited to a total surface area of less than 2 acres, or 8,100 m2 (WDF 1990). In response to the listing of Puget Sound chinook salmon as threatened under ESA, Chinook salmon releases from minor -net -pen sites have been reduced or terminated (NWIFC 2000). In its summary of the status of aquaculture for 1997, WRAC (1999) reported that net -pen salmon farming in the Pacific Northwest only occurred in Washington. Earlier in the 1990s net -pen rearing of salmon had been practiced in Oregon, California, and Idaho but had since ceased. Atlantic salmon dominated production (99 %) in Washington, with the remainder being coho, chinook, and steelhead trout. All salmon production sites in Washington, whether on or off land, are licensed appropriately. Sites are owned outright or leased (tenured). Companies may own and /or lease several sites, and consequently some sites are continuously active; others are developed but not always in use, and a few may be inactive and undeveloped. WRAC (1999) reported six companies with leases to sites in Washington in 1997. These included Domsea Farms Inc. (5 sites), Global Aqua US Inc. (3 sites), Moore -Clark Co. (USA) Inc. (3 sites and a hatchery), Scan Am (3 sites), Sea Farm Washington (3 sites), and British Petroleum (1 site). In the last five years there has been considerable restructuring in the salmon aquaculture industry worldwide with some companies consolidating their position through merger and /or purchase of smaller companies. Consequently, the global industry is now dominated by a few international companies, although individual farms may still operate 11 under the name of the registered leaseholder. In Washington four different companies now hold the leases to 12 licensed net -pen production sites. These are: • Cypress Island Inc., which has three leases by Cypress Island outside Anacortes and one lease in Skagit Bay; and (once under Northwest Farms) three leases in Rich Passage, one in Port Angeles harbor (formed by combining two previous leases), and one by Hartstene Island currently not in use. • Sunpoint Systems, which has one lease in Rich Passage. • Jamestown S'Klallum Tribe, which has one lease in Discovery Bay but not in use. • Ocean Spar Technologies, a sea -cage manufacturing company which has one lease by Whiskey Creek near Port Angeles for research and development trials, but not in use. In the State of Washington, statistics provided by WDNR (2001) indicate there are 166.67 acres currently leased by companies for commercial salmon net -pens, and a further 38.67 acres currently leased by the State, tribes, and private enterprises for net - pens used for the delayed release of Pacific salmon, and 0.39 acres for herring net -pens. All these sites have a different limit for the water surface area leased (for anchorages and navigational protection) and the internal surface area for the net -pens in production. The 10 commercial sites currently operational in Puget Sound have a total of 131 acres under lease from the State (ranging from 2 -24 acres in size), with 21.5 acres permitted for the internal pen structures (range 21,000 - 170,000 sq. ft) (K. Bright, WFGA, personal communication). This area is little more than the larger marinas located on State -owned aquatic lands, any of which can be 15 -20 acres in size. The number of commercial net -pen farms in Washington is small by comparison with that on the east coast (Maine) and other countries. Maine has 42 permitted sites for salmon, and two for steelhead, of which six are currently idle (J. McGonagle, Maine Aquaculture Association, personal communication). Producers in Maine, of which there are 14 companies, are in the process of moving to single -year -class cultivation over the next two years. This should result in about one -third of the sites lying fallow each year. In eastern Canada the industry is largely confined to New Brunswick. In New Brunswick there are about 60 farming companies, each with one or more permitted sites. There are also a few sites in Nova Scotia and Newfoundland. In western Canada there are 122 registered net -pen sites in British Columbia (BC), of which 104 are active (BCSFA 1999). The Highlands and Islands Enterprise (HIE) of Scotland recorded 440 growing sites registered in 1997 with the Agriculture, Environment and Fisheries Department of the Scottish Office (SOAEFD). Of these, 128 were fully stocked all year round, 202 were in rotation, and 100 were classified as inactive (HIE 1999). 2.3 Interactions of Farming with Commercial and Recreational Fishing In a commentary on regional fisheries, the Marine Advisory Services of the Washington Sea Grant Program (WSGP 2001) stated that commercial fishing was a significant industry in Washington State, with nearly 3 billion lb. of fish and shellfish harvested annually, with a wholesale value over $1.6 billion. However, the report also added that commercial fisheries around the world were collapsing and efforts in fisheries science 12 were turning more to conservation of resources and finding ways to harvest fish stocks in a sustainable manner. The commercial fisheries of Puget Sound reflect these global trends. WDFW (1994) reported that commercial salmon harvest levels in the State of Washington had declined from a peak of over 10 million fish in 1985 to about 7 million fish in 1993, with most of these fish produced in hatcheries. Similarly recreational salmon fishing levels had declined from a peak of 1,100,000 fish in 1979 to just over 600,000 fish in 1993. More recent data by Didier (1998) put preliminary estimates of commercial salmon catch in the State in 1998 as only 1,618,300 fish, together withl41,604 fish in the subsistence catch by the tribes; and the sport salmon (recreational) harvest in 1997 was down to 451,425 fish. Data for the 2000 landings and prices of salmon in Washington provided by Pacific Fishing (2001) gave figures of 1,475,315 fish (5,342 mt) that landed in the State, with a value of $8.5 million. Both landings and prices were considerably above those for 1999. Much of the decline in the commercial harvest can be attributed to the shift from a terminal harvest to a high catch - per -unit effort in the offshore fishery. Eriksson and Eriksson (1993) described the parallel of the Swedish salmon fisheries in the Baltic Sea in their study of wild and hatchery propagated stocks over the 40 -year post -war period. They concluded that wild fish were unable to cope with the present exploitation rates, and without the effective compensatory program, a reduction in stock -size of the magnitude shown by wild salmon in the Baltic would decrease the catch - per -unit effort to such a degree that there would be no economic incentive for a commercial salmon fishery. In addition to fluctuating changes in ocean conditions, declines in the commercial harvest can also be attributed to the increased interest in recreational fishing in Puget Sound, and competitive pressure on the habitat. Drinkwin and Ransom (1999) projected another 1.4 million people would settle in the Puget Sound Basin by 2020, which would further degrade the already- stressed ecosystem. Their indicators included continued declines in bottom -fish populations, restrictions on shellfish harvesting, and rapid loss of freshwater, estuarine, and near -shore habitats. All these indicators are impacted by the increase in aquatic recreational activities, particularly recreational boating (see Section 2.4). The decline in some fisheries populations in Puget Sound has reached significantly low levels. For example, in 1999 chinook salmon in Puget Sound and summer chum salmon in Hood Canal were listed as threatened by NMFS under the federal Endangered Species Act of 1973 (ESA). However, not all aquatic species are in decline. In its current report on the health of Puget Sound, PSWQAT (2000) noted that the waters of the Sound were still home to over 220 species of fish, 26 different kinds of marine mammals, 100 species of sea birds, and thousands of species of marine invertebrates. Some species were migratory, while others remained in the Sound all year round. Some populations, such as harbor seals and California sea lions, were increasing rapidly. The trends in the counts of harbor seals indicated some 12,000 now living in the Puget Sound region, or double the number recorded in 1985. They attribute these increasing numbers to protection under the Marine Mammal Act of 1972, variable abundance of food resources, such as Pacific herring and Pacific hake, decreasing levels of contamination in the water, and tolerant 13 interaction with human interventions. As major fish predators in Puget Sound they must be contributing to the decline of some fisheries. In a study on the impacts of California sea lions and Pacific harbor seals on salmonids in the west coast States, NMFS (1997b) estimated that the total bio -mass consumption by these pinnipeds along the coasts (a minimum of about 217,400 mt) amounted to almost half of the commercial harvest of the three States. There is no evidence in the literature that the presence of 10 operational net -pen salmon farms in Puget Sound has contributed to the decline of the fisheries populations. In fact Henriksson (1991), in his study on the effects of fish farming on natural fish communities in the Baltic Sea, described an overall recruitment by small fish around farms compared with reference areas, followed by the increased abundance of certain fish species such as, inter alia, perch, roach, white bream, and bleak. However, Crutchfield (1989) noted that fishermen opposed the growing salmon net -pen industry for encroachment on fishing grounds or transfer /over- wintering lay -up areas. He believed this was a legitimate complaint at the time but suggested it could be rectified easily by restricting net -pen farms in such sites, although this would add another site burden to farmers. There is little evidence in the literature that deliberate releases or escapes of fanned fish from operational net -pen sites have resulted in the sustained natural production of a population providing a new commercial resource in Puget Sound. Rensel et al. (1988), in a 5 -year tagging study with farmed coho salmon, showed that the annual estimated recovery (estimated catch plus escapement) averaged 17.1 %, which was similar to recovery rates of coho salmon released from other facilities at about the same time. They estimated approximately only 0.2% of the released coho salmon survived to enter streams in the general vicinity of the net -pens. They concluded that the Puget Sound commercial net fishery benefited most from the program. In Washington, in addition to the 27 releases of Atlantic salmon made by WDFW between 1951 and 1991, records by WDFW (Amos and Appleby 1999) indicated a total of 613,639 Atlantic salmon escaped from farms between 1996 and 1999. There had been escapes also in previous years (1990- 1995), evidenced by the fact that fish were taken in the commercial and recreational catches, but at that time reporting was not a regulatory requirement. However, a sustained natural population has not been established. Similarly attempts to establish Atlantic salmon in the waters of British Columbia were made between 1905 and 1935. These have also been supplemented with reported escapes of 286,885 farm Atlantic salmon between 1988 and 2000 (McKinnell et al. 1997, and A. Thomson, DFO, personal communication) but again no sustained natural production has been recorded. A total of 9,096 were recovered up to 1995, mostly in the area where the abundance of salmon farms was the highest. Wing et al. (1998) report that 89 Atlantic salmon which had escaped from marine aquaculture facilities in British Columbia and Washington were caught in Alaska fisheries between 1990 and 1995. New data by Thomson (DFO, personal communication) puts the number at 556 by 2001. 14 Losses of fish from net -pens are not always due to escapes. Moring (1989), in his documentation of unexplained losses of chinook salmon from small (5.5 m3) experimental saltwater cages with intact netting were on average 8 -38% for individual locations, and 2.5 -46.5% for individual cages. He attributed the losses to rapid decomposition of carcasses, scavenging by birds, mammals, and fishes, and to a lesser extent escapes. Actual unaccounted -for losses from commercial net -pens are currently in the order of f2 -5% (P. Granger, WFGA, personal communication). This is primarily because unexplained losses are few. In practice, fish arrive from hatcheries inventoried, and further inventories are taken each time they are moved for grading or changing nets. The accuracy of the inventory depends on how the fish are being handled. Escapes have also occurred from net -pen salmon farms in Norway, Chile, and Tasmania. In Norway, Gausen and Moen (1990) reported that escaped fish entered Norwegian rivers in great numbers, but most ( >20 %) were found only in rivers having farms situated closer than 20 kin from the outlet. Lura and Saegrov (1991) documented the successful spawning of fanned female Atlantic salmon in Norwegian rivers, where it is a native species, and Lura et al. (1993) recorded some differences in spawning behavior between a single farmed fish and wild fish. For example, the redd of the female farmed fish had more pockets (nine versus an average of two) but fewer eggs (459 compared with an average 707). Jonsson et al. (1991) described differences in life history and migratory behavior between wild and hatchery - reared Atlantic salmon. In the sea, wild salmon survived twice as well as hatchery fish, ascended the rivers earlier, and were injured less during spawning. Hatchery- reared fish, on the other hand, stayed for a shorter period in the rivers, and a larger proportion returned to sea without spawning. Crutchfield (1989) reported that fishermen opposed the net -pen industry for adverse effects of farmed fish on market prices. He recognized that this was a complex point, but thought competition between farm and wild fish would broaden as farm salmon could be found year -round and wild salmon in relatively narrow windows — normally four months of the year, but much less in Washington where trollers and gill - netters were restricted. He concluded that farmed salmon would either moderate price increases or actually cut real -price increases for domestic wild salmon. However, he added that imports were much greater than the supplies of equal - quality troll- caught chinook and coho. Again, his conclusions proved to be correct, as evidenced by the imports of Atlantic salmon in 2000 which totaled over 130,000 mt with a value of $741 million (USDA 2001), mostly from Chile and Canada. From his economic and futuristic survey of the industry, Crutchfield (1989) indicated that 79% of wholesalers and distributors felt that fresh farmed Atlantic salmon were a direct substitute for fresh Pacific fish, and that 26% felt that farmed Atlantic salmon competed directly with frozen Pacific salmon. He said that exports of US wild salmon to Europe, which was about 10 -15% by value of total production, would feel the impact of farmed salmon most severely. European smoked fish processors had all gone over to Atlantic salmon. However, he concluded that all the conjecture was insignificant as the output of farmed salmon in Washington in the long -term had little or no measurable effect on prices determined by worldwide supply and demand. 15 2.4 Interactions of Farming with Recreational Activities in Puget Sound The State of Washington Department of Licensing (WDL) reported that the number of registered recreational boats in the State was about 250,000 (WDL 1997). This was double the number of boats registered in 1984. A more recent statistic (PSWQAT 2001) stated that people living in Puget Sound own more than 165,000 power boats, 21,500 sailboats, 43,500 canoes and kayaks, and numerous other watercraft. This had necessitated the installation of 43 new pump -out stations in the Puget Sound Basin since 1994, with the construction of 15 more on line. Goodwin and Farrel (199 1) published a directory of marinas and moorage facilities in the State in 1991, and listed 379. Kitsap County had 26 facilities and 2,968 wet moorage slips. The 20 facilities in Kitsap County which completed the survey data offered a total of more than 4 miles of dock and guest -dock space to recreational boats. The State's Interagency Committee for Outdoor Recreation (ICOR) made a comprehensive field inventory of motorized boat launches in the State in 1997 and identified 984 such sites (ICOR 2000). The typical marina or yacht club in Puget Sound leases between 2 -20 acres of aquatic lands from the State (WDNR 2001). More importantly, these facilities displace areas which have probably been near -shore habitat for juvenile fish. Based upon past studies of marinas for the State's Department of Fisheries, Cardwell et al. (1980) considered reduced dissolved oxygen (DO) and increased water temperature the greatest potential threat to aquatic life in Puget Sound marinas. Although coliforin contamination of shellfish, the leaching of antifouling paints, and the introduction of hydrocarbons via the exhausts of outboard motors posed potential or real threats, they stated this could all be controlled if marinas were well managed and had sufficient flushing to prevent large temperature and DO changes. Although they recognized that the statistical relationship between flushing and changes in these parameters measured in the study was weak, they judged that a minimum flushing rate of 30% was adequate for the purpose. This value was based on a 1.82 m tidal range computed for a 24 -hr period. If the marina was in an estuary where tidal ranges never attained 1.82 m, then the minimum overall flushing rate was about 15 %. Subsequently, Cardwell and Koons (1981) documented several water quality perturbations within marinas and moorage facilities. Pollutant inputs included runoff from parking lots and storm drains, hydrocarbons from outboard motor exhaust, heavy metals from antifouling paints, and biocides such as creosote and pentachlorphenol in wood piling and docks. Indirect effects resulted from nocturnal diminutions in dissolved oxygen due to respiration of phytoplankton blooms and diurnal elevations in water temperature due to solar radiation. In an earlier study on the effects of hydrocarbons on marine organisms consumed by humans, Clark et al. (1974) exposed mussels and oysters to a diluted effluent from a two - cycle outboard motor in a running seawater system. The organisms displayed physiological stress, degeneration of gill tissue, and uptake of paraffin hydrocarbons from the effluent. Mussels showed an immediate response to the pollutant as well as a 16 significant delayed mortality after removal. The oysters were less affected as they had the capability of closing for longer periods of time. Milliken and Lee (1990) carried out a comprehensive review of literature on recreational boating and pollution dating back over 40 years. They focused on four of the principal pollution problems associated with recreational boating, namely sewage, engine pollution, anti- fouling paints, and plastics debris. Regarding boat sewage, they found that, although the volume of wastewater discharged from recreational boats was small, the organic matter in the wastewater were concentrated, and consequently the biological oxygen demand (BOD) was much higher than that of raw municipal sewage or treated municipal sewage. Furthermore, the concentrations built up around the marinas as they were usually sheltered and poorly flushed. They also found that there was both a positive and negative correlation between the density of boats and fecal coliforin concentrations in the water, but that background fecal coliform levels from overland storm -water runoff exceeded that caused by boats. WDFW (1997a) reported that anglers took 1.5 million trips to Puget Sound and the coast in 1996 to catch 'food fish' — the State - designated category for salmon, sturgeon, carp, and most marine fish. Departmental statistics in the 1996 -1997 Annual Report (WDFW 1997b) indicate that 358,954 fishing licenses for food fish were sold in 1996, together with 596,898 licenses for game fish (primarily freshwater species), and 89,393 licenses for steelhead. Zook (1999) estimated that recreational angling for non - native game fish contributed about $735 million annually to the State's economy. 2.5 Economic Benefits of Salmon Farming to the State Dicks et al. (1996), in a study on the economy -wide impacts of US aquaculture, concluded that, in 1992, the aquatic farming industry generated approximately $5.6 billion in gross domestic product (GDP) and over 181,000 jobs. Production activities accounted for about 8% of the income and 16,500 jobs, while upstream activities, such as equipment, supplies, feed, seed, fertilizer, labor, and financing, accounted for about 23% of the income and 40,500 jobs. Downstream activities, such as transport, storage, processing, manufacture, distribution, and sale of products, etc., accounted for 69% of the income and approximately 125,000 jobs. Stokes (1988) concluded there were many economic net gains statewide from salmon farming in the State of Washington. In a study of 64 benefit -cost and sensitivity analyses for ratios of gross economic gains (household income) to potential losses (adverse property consequences), and reflecting a wide combination of data, the ratios all exceeded unity. Average results for all calculations and results calculated under assumptions favorable to the industry indicated substantial net economic gains. The study had three tasks, regional input- output analysis, state fiscal analysis, and property value analysis. 2.5.1 The contribution of salmon farming to seafood production In its annual summary of national fisheries statistics, DOC estimated commercial aquaculture production in 1997 of 314,657 mt (693.7 million lb) with a value of $886 17 million (DOC 1998). Total exports of edible fishery products were 915,000 mt (2.0 billion lb) valued at $2.7 billion. The total imports of edible fishery products were 1.5 million mt (3.3 billion lb) valued at $7.8 billion. With regard to salmon, the DOC fisheries statistics estimated exports of fresh and frozen salmon in 1997 were 86,157 mt (189.9 million lb) valued at $307.5 million. Canned salmon exports were 37,023 mt (81.6 million lb) valued at $135.4 million. Imports of fresh and frozen salmon in 1997 were 73,847 mt (162.6 million lb) valued at $344.4 million, and imports of canned salmon were 557 mt (28.8 million lb) valued at $4.8 million. In an early review of the economics and future of salmon farming in the Pacific Northwest, Crutchfield (1989) concluded that a fully developed salmon industry in Puget Sound would make a positive contribution to the economies of the region but would do little to reduce the imbalance of international trade or even the trade in seafood. He estimated that salmon imports were less than one -tenth of one percent of the $150 million international trade deficit, and a salmon farming industry would have little or no impact. USDA more recently reported (USDA 2001) that Atlantic salmon imports in 2000 reached 289 million lb (131,000 mt), as shipments increased in all three main categories (fresh whole fish, frozen whole fish, and fresh and frozen fillets). Imports of fillets remained the fastest growing category and made up over 50% of imports. The majority of imports came from Chile (filleted products) and Canada (fresh fish), with Chile taking over as top supplier with shipments rising by 51 %. The value of Atlantic salmon imports in 2000 was $741 million, and the market continues to expand. In a comparative review of 1999, Northern Aquaculture (2000) reported that actual production of salmon in Washington in 1999 was 5,500 mt, with a value C$38 million (just below US$30 at that time). Production was about the same as in 1998. In Maine production of Atlantic salmon was 12,100 mt (down 8 %) with a value of C$111 million. In Canada BC production was 47,000 mt of Atlantic and Pacific salmon (chinook and coho). This figure was up 19% over 1998. The value was C$347, of which 86% was for Atlantic salmon. In New Brunswick production of Atlantic salmon and steelhead was about 27,000 mt, with a value of about C$140 million. The Washington Fish Growers Association FGA (WFGA) reported that total production in Washington in 1999 was 14 million lb. dressed weight (6,545 mt) of Atlantic salmon (99 %) and steelhead (1 %). The total value was about $30 million. About 95% of the farmed products were sold on the national markets as whole dressed fish, and 5 % were exported as fresh fillets (P. Granger, WFGA, personal communication). 2.5.2 The impact on employment and wages Crutchfield (1989) predicted that a fully developed net -pen salmon industry in Puget Sound would be useful in contributing to employment in the area but would not be a significant factor. His prediction has proved to be very accurate. Some earlier estimates regarding employment in the industry were rather optimistic. Inveen (1987) suggested primary employment in a typical net -pen operation in Puget In Sound was 8 -10 persons with an average annual wage of $19,000 (range $14,500- 30,000). Capital investment required was about $750,000 -1 million, with annual operating expenses of $1.4 million (feed 30 %, labor 14 %, smolts 12 %, other 44 %). Assuming eight more jobs in secondary activities, the total contribution to employment by 10 farms would be 160 -200 jobs. This was similar to employment profiles in Norway. Stokes (1988) in a report to WDFW estimated that the State economy would gain $38 -48 million in output, $11 -21 million in household income, and 257 -303 jobs from the existence of five Atlantic salmon farms in the State, with typical production figures of 1 million lb /annum and $5 million revenue. The average impact on the ( Kitsap) County for one operational site would be $5.8 -6.8 million in output, $1.1 -2.1 million in household income, and 40 -51 jobs. For the state of the industry in 1999, with 10 operational sites, WFGA reported current employment in the local industry of 65 full -time positions, 5 part-time positions, and approximately 200 more employed indirectly down the line (P. Granger, WFGA, personal communication). By comparison, Young et al. (1998) reported 1,000 full and part-time employees in the net -pen salmon industry in Maine, with 38 operational sites, which equated to about 750 full -time jobs. In addition, about 500 full -time jobs in Maine were directly dependent on contracted employment with salmon fauns, such as trucking, diving, health management, and other services. Indirect impacts of employment induced in the local communities by salmon farms represented another 1,000 jobs. BCSFA (2000) reported that the salmon farming industry in Canada employed 3,400 people, mostly on the BC coast. In 1999 the BC salmon industry produced 47,000 mt of salmon valued at C$347 million. Estimated wages for a direct employee in the industry in Washington were up to about $45,000, and for an indirect employee about $35,000 (P. Granger, WFGA, personal communication). These wages continued to be above average for the collective agriculture sector (which includes forestry and fishing) in Kitsap County, which accommodates most of the net -pen sites. Kitsap County (2000b) reported that the annual average wage (1994) for this sector was $16,268. This was higher than the statewide average of $13,767 primarily, it noted, because of a small number of highly paid workers in aquaculture and fishing. However, about 70% of jobs in the collective agriculture sector were in agricultural services industries, with the largest industries being lawn and garden services, and non - livestock veterinarian services. 2.5.3 The impact on coastal property values In a study of Puget Sound waters for coastal sites for net -pen fish farms, Weston (1986) provided interim tidal velocity and water quality guidelines to minimize their impact. Only 19 areas were identified as acceptable, relevant to specific farm capacity and the proximity of special habitats. Five more areas, in Puget Sound Basin and beyond, were acceptable without limitation. Parameters relevant to the existence of shoreline industries or private properties, or any anticipated real estate developments, were not included in Weston's early guidelines, 19 although the Basin was in the middle of major population growth and property development. In its period summary on the health of Puget Sound, PWSWQAT (2000) noted the Sound was currently home to almost exactly 4 million people, or double the population of the 1960s. Annual growth was about 50,000 people (1.5 %) and the population was expected to reach 5 million people by the year 2020. The majority of preferred net -pen farm sites identified by Weston (1986) were located in waters around Kitsap County and Mason County. In the last 25 years (1970 -1995) the population of Kitsap County, in the middle of the Sound, has increased 116.8 %, compared with 59.1% across the State. Much of this was due to the immigration of 47,104 persons between 1980 and 1995 (Kitsap County 2000a). Property development was a priority and principal activity, as the collective finance, insurance, and real estate employment sector showed an increase in employment by 255% (1970- 1995), of which real estate garnered one -third of the jobs (Kitsap County 2000b). Alpine Appraisers (1988) undertook a comparative study of visual and market effects of net -pen fish farms on property values around Puget Sound. They concluded that floating net -pens had no effect on upland property values in the area studied (Mason County and Kitsap County), and that they had `minimal', if any, visual impact at distances over 2,400 lineal feet. Stokes (1988), in a statistical analysis of 335 property listings and assessed value in water -front areas throughout Puget Sound in the vicinity of net -pen complexes, determined the average front footage price of $409 had a standard deviation of $290, half of which could be accounted for by general location (County), land type (high -low bank), and improvements (water, sewer, etc.). The remaining, or 'residual' price variation, was presumed to result, at least in part, from variations in visual aesthetic quality. Parsons (1991) studied the effect of coastal - land -use restrictions on housing prices in the State of Maryland. He found that housing prices in the critical area with water frontage increased by 46 -62% due to restrictions, compared with 14 -27% without water frontage, 13 -21% for those just outside the area, and 4 -11% for those three miles away. The direct beneficiaries of coastal - land -use restrictions were the current owners of housing in the community, while the losers were owners of undeveloped or restricted land, renters, and future owners. Garrod and Willis (1992) studied the effect of selected countryside characteristics on house prices in a rural area of England covering 4,800 km2. They found that many variables (such as within 1 km proximity to woodland, river or canal, or rural settlement) had a positive influence on house prices of 7 -10 %, 4 -9 %, 8 -12 %, respectively. Furthermore, the characteristics of an open water view or gradient slope had no observable effect; and being close to wetlands or having woodland or urban views had the effect of reducing house prices. 2.6 The Regulatory Structure for Commercial Enterprises The policies and regulations (and their enforcement) for aquaculture introductions in the State of Washington and the Province of British Columbia were reviewed and summarized in detail by Elston (1997) in his study of pathways and management of 20 marine non - indigenous species (NIS) into the shared waters of British Columbia and Washington. Aquaculture had been identified as one of six pathways for NIS introductions for the study, and in his final report to the Puget Sound Water Quality Authority, the US Environmental Protection Agency, and the Department of Fisheries and Oceans Canada, he stated that the adequacy of information available to assess the relative risks of introductions through aquaculture was good. This was because for more than a decade Washington and British Columbia had in place state /provincial (and federal) procedures specific to aquaculture. He noted that intentional introduction of aquaculture species was then far more restricted than in the past. He stated that technology could assist further in reducing the risk from exotic species introductions by, for example, culturing only strains of sterile organisms. Elston concluded that the risk from aquaculture introductions from aquaculture was well - defined, the industry was highly regulated, and active processes were underway for continuous review of aquaculture activities as they involved NIS. Traditionally the policy of the State of Washington has been supportive of aquaculture. The State was one of the first to recognize that aquaculture was a form of agriculture and enacted legislation in 1985 which designated the Department of Agriculture as the lead agency, with WDF responsible for disease control and prevention regulations. The current policy of the State fosters the commercial and recreational use of the aquatic environment for production of food, fiber, income, and public enjoyment from state - owned aquatic lands, and identifies aquaculture among legitimate uses. In its policy implementation manual for the use of the State's aquatic resources (WDNR 2000b) aquaculture is specifically designated as an aquatic land use of statewide value. WDNR generally encourages this use, and it takes precedence over other water - dependent uses which have only local interest values. While commenting on the possible environmental impact on aquaculture by surrounding activities, and vice versa in a discussion on net - pens and floating rafts, the manual states again that aquaculture remains a favored use of state -owned aquatic lands. WDNR (1999) recently published a technical report on the potential offshore finfish aquaculture in the State. Amos and Appleby (1999) summarized the roles and responsibilities of the regulatory authorities in the State of Washington with regard to the management of salmon farming in State waters, and particularly Atlantic salmon farming. Their summary forms the basis of the following annotations of the regulatory structure for commercial enterprises producing either Pacific or Atlantic salmon. (i) WDFW has management and regulatory authority over all free - ranging fish in the State. The authority of WDFW over commercial fish culture in State waters is restricted to disease control and protection of wildlife in general. • The Finfish Import and Transfer Permit (WAC 220 -77 -030) assures that diseases, pests, and predators are not introduced or transferred. In addition, under a legal settlement, WDFW is required to kill and conduct biological examination of any Atlantic salmon encountered by agency staff. 21 • Hydraulic Project Approval (RCW 75.20.100, WAC 220 -120), or HPA, assures that all construction projects ensure protection of wildlife and habitats. However, the authority of WDFW to require HPAs of aquaculture workers at their sites is not clear. WDFW, in association with the State of Washington Department of Ecology (WDOE) and Department of Natural Resources (WDNR), provides guidance to state and local agencies siting farms to avoid adverse impacts on the environment. In association with the State Department of Agriculture (WDA), it develops disease control regulations with regard to human health and safety. (ii) WDOE has regulatory authority over discharges of pollutants into State waters for the protection, preservation, and enhancement of the environment. • The National Pollution Discharge Elimination System Permit (40 Regulation CFR, Part 122.21), or NPDES, assures compliance with state and federal water quality laws. • The Water Discharge Permit (RCW 90.48) assures that discharges and wastes do not adversely affect water quality and standards. Under the Clean Water Act and the Water Pollution Control Act, WDOE can take regulatory action against net -pen operators who allow Atlantic salmon to escape. This follows the determination by the Pollution Control Hearings Board (PCHB) that Atlantic salmon are 'pollutants.' The PCHB also adjudicates appeals over permits issued by WDOE. In association with WDFW and WDNR, WDOE provides guidance to state and local agencies on siting farms to avoid adverse impacts on the environment. (iii) WDNR has regulatory authority over state -owned aquatic lands, including all bedlands of Puget Sound, navigable rivers, lakes, and other waters. The authority also extends over lands covered and exposed by the tide, and most shores of navigable lakes and other fresh waters. • The Aquatic Lands Lease (RCW 79.90 - 79.96), or ALL, assures the specification of all uses of the land and the proposed facilities. WDNR, in association with WDFW and WDOE, provides guidance to state and local agencies on siting farms to avoid adverse impacts on the environment. (iv) WDA is responsible for assuring the safety of the State's food supply, providing protection from diseases and pests, and facilitating movement of agriculture products in domestic and international markets. With WDFW it jointly develops disease control regulations with regard to human health and safety. (v) Local counties in the State of Washington act as lead agencies for applying the environmental policies of the State, and the management of their respective county shorelines. The State Environmental Policy Act (RCW 43.21C, WAC 197 -11), or SEPA, assures consideration of social and environmental impacts of proposed actions. 22 • The Shoreline Management Act (RCW 90.58), or SMA, assures appropriate and orderly development of state shorelines, management of their uses, and preservation of their natural character. (vi) A number of federal agencies [NMFS, the US Army Corps of Engineers (ACE), US Fish and Wildlife Service ( USFWS), US Coast Guard (USCG), and the Environmental Protection Agency (EPA)], together with respective State agencies, have management and regulatory authority over the use of all waters by the public. • The Section 10 Permit assures protection of public interest, including navigation, water safety, and water quality. (vii) NMFS administers the ESA for anadromous salmonids. It may require commercial salmon farmers to obtain permits to take fish for their use due to the impact on listed species. Jointly in collaboration with USFWS and WDNR, NMFS permits the use of predator control methods (non- lethal) for birds and mammals in accordance with permit restrictions. (viii) The US Food and Drug Administration (FDA) is responsible for the protection of consumers by enforcing the Federal Food, Drug, and Cosmetic Act, and several related public health laws. It is also responsible for the safety of feed and drugs for pets and farm animals. Salmon farmers are restricted to the use and conditions of veterinary medicines, drugs, growth enhancers, and other chemical supplements licensed by FDA. (ix) The Treaty Tribes of the State of Washington co- manage fisheries resources in the State with WDFW and thus have input into disease control regulations (see (i), above). 2.7 The Regulatory Structure for Public and Tribal Hatcheries Public and tribal hatcheries producing Pacific salmon (and other fish) in the State of Washington must conform to the same general regulations regarding commercial hatcheries and farms. These regulations, as described, are all concerned with protection of the environment, or the health and safety of other plants and animals, including human consumers. However, since 1994, when a number of Pacific salmonid species in the region were listed for protection under ESA, there are some differences in regulations for public and tribal hatcheries. The production of listed fish in public and tribal hatcheries is now restricted to recovery purposes only, and not for subsequent commercial or recreational harvest. Certain sections of the ESA pertain to the necessary taking of listed fish for public and tribal hatchery operations, and also for research. For example, in Section 7 of the Act, hatcheries in ESUs where there are single listed stocks are permitted a directed take of fish for recovery operations, and an incidental take in ESUs with mixed - stocks. In an attempt to avoid further layering of regulations the NMFS is proposing to adopt a new approach. Through the so- called 4(d) Rules, public and tribal authorities (and the private sector) can develop their own conservation strategies to be approved by NMFS. 23 After approval of a specific conservation program, any activities appropriately implemented will automatically be in compliance with the ESA and will not require individual permitting. As part of this approach the NIVIFS has been working with management agencies in the region to develop Hatchery and Genetic Management Plans (HGMPs). The HGMP procedure provides a thorough description of each hatchery operation, including the facilities used, methods employed to propagate and release fish, and measures of performance. There are also sections dealing with the status of listed stocks which may be affected by the plan, anticipated listed-fish 'take' levels, and a description of measures to minimize risk to listed fish. However, once completed, accepted, and followed, hatchery managers are assured that their activities are all in compliance with ESA and no further permitting is required. 24 3. POTENTIAL ISSUES FOR HUMAN HEALTH AND SAFETY The third chapter is specific to the potential issues for human health and safety from net -pen salmon farming in the Pacific Northwest region. It is sub - divided into five parts. After a brief introduction to global and national responsibilities for food safety, the second part deals with the chemicals and chemical contaminants in materials used in farm production operations. Possible sources include metallic paints, feed ingredients, and chemo - therapeutants. The third part concerns the transmission of diseases, and the common pathogenic diseases are reviewed. The fourth part deals with the processing and quality of farm products, specifically the proximate composition of farm fish, and differences between farm and wild salmon species. The final part concerns worker safety. 3.1 General Food Safety In 1995 the members of the United Nations Food and Agriculture Organization (FAO) formally adopted a Code of Conduct for Responsible Fisheries. The Code, which was then published (FAO 1995), advocated safe and high quality fisheries products. Article 9 of the Code, which was specific to aquaculture, was then broken out and detailed in a subsidiary document called, Aquaculture Development (FAO 1997). The section on Responsible Aquaculture at the Production Level called for the global aquaculture industry to make safe and effective use of feeds, feed additives, chemo - therapeutants, and other chemicals, and to promote the use of aquaculture practices and methods which reduced the hazards. As a signatory of the FAO Code, the US has ensured that its national aquaculture industry will abide by all the intentions contained in Article 9. The terminology used in this Chapter is adopted from the World Health Organization (WHO) report on Food safety issues associated with products from aquaculture (WHO 1999). The terms'hazard and'risk' have specific definitions. A'hazard is a biological, chemical, or physical agent in food, or a condition of food, with the potential to cause harm. A'risk' is an estimate of the probability and severity in exposed populations of the adverse health effects resulting from a hazard(s) in food. The greatest risk to human health from seafood occurs from post - harvest contamination and loss of product quality. However, this section confines its review to the risks to human health from hazards which might be incurred in the pre - harvest production of farm salmon raised in marine net -pens. When appropriate, it compares the risk with products from wild harvests, other forms of aquaculture, and agriculture. Potential hazards to food safety by the consumption of farm salmon raised in net -pens, or by human contact with farm operations, may include: • Toxic chemicals and chemical compounds which have been accumulated by the fish from their aquatic environment, or from their food, or as residues from veterinary medicines. 25 Pathogenic organisms in the fish, such as parasites, viruses, and bacterial pathogens, which may also be harmful to humans. The overall risks of feed -borne human illnesses from cooked seafood (wild and cultured) are low compared with risks from other animal products. Otwell (1989) pointed out that the estimated risk of disease from consuming a 4 —oz serving of cooked seafood was 1 in 5 million servings, but for chicken it was 1 in 25,000 servings. However, unlike other meat products, seafood is often eaten raw or lightly cooked, and the estimated risk rises to 1 in 250 servings for the consumption of uncooked shellfish. The risk from consumption of uncooked fish is also higher than for cooked fish. Primary responsibility for regulating all seafood safety, including farm products, rests with the FDA. The FDA performs its functions by adopting BMPs, approving hazard analysis and critical control points (HACCP) plans, and promulgating regulations. Enforcement is primarily through inspection of handling and processing plants to ensure compliance with BMPs, HACCAP plans, and regulations. The FDA also approves and regulates the use of drugs and additives used in all domestic and farm animal feeds, which includes feeds used by the aquaculture industry. 3.2 Chemicals and Chemical Contamination Toxic chemicals and chemical compounds are accumulated by fish and shellfish from their aquatic environment and from their food. Chemical contaminants which are potentially hazardous to humans through seafood consumption, including farmed salmon, are heavy metals, feed -borne toxicants, and chemo- therapeutics. Human illnesses resulting from chemicals in the environment are more commonly associated with long -term exposure. Jensen and Greenlees (1997) found that illness associated with a single meal was rare. Moreover, areas of chemical contamination tended to be concentrated in space and sometimes in time. For the most part, sensible precautions and local regulations have ensured that fish farm facilities have been situated where risks of chemical contamination were minimized. Sites have always been far from industries associated with environmental pollutants and the out -fall of human sewage treatment plants. 3.2.1 Heavy metals Metal ions enter fish by absorption through the gills or from food. The latter is more common. In general, fish regulate the concentrations of metal compounds in muscle tissue within tight limits. Consequently, concentrations of inorganic metals do not exceed regulatory limits even when the fish are harvested from environments with high metal concentrations. The exception to this rule is tin, in the organic form of tributyl -tin, and mercury in its organic form of methyl - mercury, which a number of sources (Cappon 1983, Jensen and Greenlees 1997, WHO 1999) indicate can be accumulated through the food chain. 26 Tributyl -tin was commonly used as a biocide in anti - fouling paints on recreational boats (Milliken and Lee 1990) in the marine environment. Subsequently it was used on net -pen structures. However, due to its rapid leaching, tributyl -tin and its breakdown products were found in the water, sediment, and in organisms where there are concentrations of recreational boats. Later it was demonstrated that salmon in treated pens could accumulate tin in their tissues. The use of tributyl -tin was consequently restricted in Europe and North America, and WHO set a limit of 3.2 µg /kg body weight for tin in humans (WHO 1999). Based on this figure, and levels of tin found in fish reared in cages treated with tributyl -tin, a daily consumption of 150 g of salmon by a 70 kg person would be necessary to exceed this level. At least 13 States in the US have enacted their own legislation on the use of tributyl -tin, in addition to that of the EPA. Methyl - mercury bio- accumulates in the food chain, and is of particular concern for long - lived predatory fish. Farmed salmon live on a diet of prepared pelleted feeds, and are usually harvested before 3 years of age so there is less opportunity for methyl - mercury to accumulate. There are no records of farmed salmon accumulating methyl- mercury. However, there are examples of methyl - mercury accumulation in wild salmon. Cappon (1983) recorded mercury levels of 0.3 -0.8 mg/kg in wild salmon from the Great Lakes, which is just below the maximum permissible limit of 1.0 mg /kg. 3.2.2 Manufactured feeds The risks to human health from feed -borne toxins have long been known, and feed manufacturing standards, including the composition and labeling of fish feeds, are strictly regulated by the FDA. However, the ingredients for the compounding of animal feeds still come from a variety of suppliers, and some risks still remain. Of particular concern for human health are certain animal byproducts, oilseed meals, grains and byproducts, honnones, pigments, antioxidants, and most recently some organic compounds called 'dioxins.' (i) Animal byproducts Rendered animal protein ingredients, including various meat and bone meals, poultry byproducts, blood, and marine processing wastes have been used for decades to replace some fish meal in the diets of salmonids. However, the dietary inclusion levels for most of these products have been limited because of concerns of poor digestibility, nutritional value, palatability, and variable product quality. Efforts to avoid excessive phosphorous levels in hatchery effluents have also limited the use of some of animal byproduct meals, which may include relatively high levels of indigestible phosphorous from bone. The use of rendered animal byproducts in animal feeds has been severely constrained since 1997 by new standards imposed by FDA in the Code of Federal Regulations (CFR) Title 21. Regulation 21 CFR, Part 589.2000 prevents the inclusion of certain mammalian proteins in feeds for cattle and other ruminant animals. This is intended to prevent the establishment or amplification of bovine spongiform encephalopathy (BSE) in the US by prohibiting the feeding of protein from ruminants (such as cattle, sheep, goats, deer, elk, buffalo, and antelope) to ruminants. Exempt from the ban is mammalian protein derived 27 from pure pork or horses slaughtered as single- species facilities, inspected meat products, blood and blood products, gelatin, and milk products. Feeding of mammalian proteins to fish is not prohibited by the regulation. However, the final regulation requires feed manufacturers who handle both prohibited mammalian protein and non - prohibited mammalian /non - mammalian protein to follow strict measures to prevent cross contamination of feeds which may be fed to ruminants, label finished feeds appropriately, and maintain records of ingredient purchases and disposition of the finished feeds. Customer concerns and changes in market availability of many of these byproducts (e.g., meat and bone meal) have effectively eliminated these ingredients from salmonid feeds. The use of exempt products, including blood meal and byproducts of fish and poultry processing, still continues, although levels of dietary inclusion may be constrained by price and availability. Studies regarding the potential for BSE transmission to humans through discharge of BSE prions into the aquatic environment via uneaten fish feed and feces have not been reported in the scientific literature. However, risks from a rendering plant disposing of cull cattle carcasses in the catchment area of a chalk aquifer used for drinking water have been examined by Gale et al. (1998). They calculated that the risk to consumers who drank the water was remote, and an individual consuming two liters daily for 45 million years would have a 50 % chance of any infection. (ii) Oilseed meals, grains, and byproducts Fish meal in salmon feeds may be partially replaced by soybean, cottonseed, and canola meals. The dietary inclusion level is governed by available content of essential amino acids, palatability, and whether compounds toxic to the fish or anti- nutritional factors are present. Dabrowski et al. (1989) and Sanz et al. (1994) found that soybean meal products could replace a high percentage (25 -40 %) of dietary fish meal without affecting growth of rainbow trout. However, dietary levels of some soy products were limited by the presence of compounds which induced intestinal enteritis in Atlantic salmon (Baeverfjord and Krogdahl 1996) and rainbow trout (Refstie et al. 2000). Salmon feeds may also include low levels ( <10 %) of wheat and wheat byproducts, such as wheat middlings, as binding agents and sources of dietary energy. In recent years, oilseeds and grains have been modified by genetic engineering to produce crops with increased yield and decreased reliance on herbicides and pesticides. Few published data are available regarding their safety and nutritional value as animal feed ingredients. Research by Hammond et al. (1996) has shown, however, that the feeding value (nutritional value) of soybeans to rats, chickens, catfish, and dairy cattle is not affected by genetic modifications which impart tolerance to mid-season application of the herbicide, glyphosate. The use of genetically modified (GM) oilseeds and grains in animal and human foods has gained considerable attention in the US and the European Union because of uncertainties regarding their effects on human health and the environment. Of concern are modifications that introduce previously unknown allergens in food products, or affect native plants through cross - pollination. The FDA is unaware at the present time of scientific data indicating that foods developed through genetic modifications differ as a class in quality, safety, or any other attribute from those developed by convention breeding techniques. In recognition of the importance of issues surrounding the safety of bio- engineered foods, the Codex Alimentarius Commission (established by WHO and FAO) in March 2000 appointed the Codex Ad -hoc Intergovernmental Task Force on Foods Derived from Biotechnology. Its mandate is to study the safety of such foods, their effects on the conservation and sustainable use of biological diversity, and also their effects on human health. Safety concerns over the use of genetically modified ingredients in animal feeds have not been substantiated scientifically. However, consumer demand for GM -free fish in the marketplace has resulted in some feed companies producing and offering for sale only GM -free feeds. Suppliers are required to present documentation that all ingredients are free from any genetically modified organism (GMO). (iii) Growth hormones Exposure to steroids incorporated into the diet has been shown experimentally to affect sexual development, growth, and feed efficiency of several salmonids. Piferreri and Donaldson (1989) found experimental feeding of low doses of 1743 - methyltestosterone to coho fry increased the proportion of males, whereas the estrogenic steroid 1743 - estradiol increased the proportion of phenotypic females. Baker et al. (1988) developed a technique for producing phenotypic male chinook salmon from mono -sex female -eyed eggs and fry by immersion in a solution of 1743 - methyltestosterone and water. Human food safety and environmental issues associated with the use of 1743 - methyltestosterone for sex control in fish have been reviewed by Green and Teichert- Coddington (2000). Ostrowski and Garling (1986) found that dietary 17- 13- methyltestosterone enhanced growth of fingerling rainbow trout without affecting feed utilization. In contrast, Yu et al. (1979) showed that low doses of androgenic steroids improved both growth and feed conversion of juvenile coho salmon. Some synthetic steroids have been approved by the FDA for use in the US to increase growth, feed efficiency, and milk production in cattle. However, the use of hormones has not been cleared for food fish. (iv) Pigments The characteristic red color of salmonid flesh from the deposition of dietary carotenoids is an important factor in determining product quality and consumer acceptance. In the wild, salmonids consume prey organisms containing small quantities of astaxanthin and other carotenoids which are deposited in the skin and muscle. Formulated feeds used in salmonid aquaculture are usually supplemented with astaxanthin, although a related carotenoid, canthaxanthin, is sometimes used. Astaxanthin is an approved color additive in the feed of salmonids (Regulation 21 CFR, Part 73.35 [USOFR 1995c]). The maximum permitted level of astaxanthin is 80 mg /kg (72 g /mt) of finished feed. The FDA requires that the presence of the color additive in the feed, or fish which have been colored with the feed additive, or any product which contains artificially colored salmon 29 as an ingredient, is declared on the label or ingredient list. However, this information is unlikely to pass to the consumer when the product is displayed out of its packaging. (v) Antioxidants Oxidation of lipids in feed ingredients can cause a reduction in their nutritional value and may produce compounds toxic to fish. Hung et al. (1981) found that feeds and /or ingredients containing high levels of unsaturated fatty acids, such as fish meal and fish oil, treated with synthetic antioxidants prevent nutrient loss and formation of toxic peroxide compounds. Synthetic antioxidants, such as BHA (butylated hydroxyanisol), BHT (butylated hydroxytoluene), and ethoxyquin (1,2- dihydro -6- ethoxy- 2,2,4- timethylquinoline) are commonly used in animal feeds. Maximum levels permitted in the finished feed by the FDA is 0.2% of the fat content for BHA and BHT, and 150 mg /kg for ethoxyquin. (vi) Organic toxicants Organic compounds, such as polychlorinated biphenyls (PCBs), dibenzofurans, organic pesticides, and halogenated aromatic hydrocarbons, etc., have all been found in wild salmon from polluted areas, such as the Great Lakes (Cleland et al. 1987, Cleland et al. 1989, Daly et al. 1989, Seegal 1999) and the Baltic Sea (Svensson et al. 1991). Recently, media reports on the presence of 'dioxins' in farmed salmon have gained considerable attention, particularly among consumers in the United Kingdom and other EU countries. Dioxin exposure is of concern because of potential effects on the immune and endocrine functions and reproduction, as well as the development of malignant tumors (SCAN 2000). The term dioxins describes three classes of toxic chemical compounds widely distributed and persistent in the environment. They tend to dissolve in lipids and thus can be accumulated in the food chain. The groups are polychlorodibenzo -p- dioxins (PCDDs), polychlorodibenzofurans (PCDFs), and dioxin -like or co- planar biphenyls (PCBs). PCDDs and PCDFs are by- products of certain industrial processes, such as high - temperature waste incineration, and /or those involving organic chlorine treatments (bleaching paper during manufacture, synthesis of herbicides). PCBs were used mainly in electrical equipment beginning in the early 1930s until their manufacture and use was stopped in almost all industrialized countries by the late 1980s. Of the 210 possible PCDF and PCDD congeners, 17 are considered toxic. Twelve of the 209 members of the PCB family show dioxin -like toxicity. The overall toxicity of a dioxin - contaminated materials or food is an additive function of both the quantity of each congener present and its toxicity, relative to the most toxic compound 2,3,7,8 -TCDD (Seveso- dioxin), expressed as total toxic equivalents (TEQ). WHO has proposed a tolerable daily intake (TDI) for humans of 1 -4 pg WHO- TEQ /kg body weight (Van Leeuwen and Younes 2000), with the ultimate goal to reduce human intake levels below 1 pg TEQ/kg body weight per day. More than 90% of human dioxin exposure is derived from food, with food of animal origin as the predominant (ca. 90 %) source. Consequently, recent efforts to reduce human dietary exposure to dioxin and PCBs has focused on evaluating the contribution of various feed ingredients given to 30 farmed animals, including fish, and the contamination of human food products of animal origin (SCAN 2000). Data collected by the SCAN (2000) on basic feed ingredients (roughages, grains and cereals, vegetable oils, animal fat and other rendered by- products, fish meal and fish oil, as well as binders and trace element premixes) indicated that virtually all are contaminated with dioxin to varying degrees. Feedstuffs originating from plants generally contain low levels of dioxins (0.1 -0.2 ng WHO - TEQ /kg dry matter), while fish meal and oil, particularly those originating from European sources are highly contaminated (fish meal 1.2 ng WHO - TEQ /kg dry matter, fish oil 4.8 ng WHO- TEQ /kg dry matter). European fish meals and oils are about 8 -fold lower in total dioxin content than those produced from species caught in the coastal areas of less - industrialized regions of the world (Peru, Chile). Because of the high percentage of fish meal and oil in the diets of farmed carnivorous fish, such as salmon, the impact of using less contaminated feed materials of fish origin on whole diet dioxin burden is considerable. According to SCAN estimates, a typical diet for carnivorous fish containing 50% fish meal and 25% fish oil originating from Europe might contain 1.82 ng WHO- TEQ /kg dry matter, compared with 0.25 ng WHO - TEQ /kg dry matter if fish products from the south Pacific were used. Further reductions may be realized by partially replacing fish meal and oil with plant products, such as soybean meal and vegetable oils. Little is known about transfer of dioxins from feed to fish. However, based on limited data on transfer rates for PCBs in fish, and assuming similar behavior of ortho and non - ortho cholorobiphenyls, SCAN estimated at least 60% of the total dioxin + PCB TEQ in fish feed is likely to be transferred to fish. At present, the level of dioxin contamination in farmed salmon has not been rigorously evaluated, and transfer rates to humans have not been determined. However, it is likely that guidelines for tolerable limits for dioxin in all human food products or animal origin will soon emerge. While the potential for feed -borne hazards from organic compounds exists in farmed salmon, Jensen and Greenlees (1997) note that this public health issue is largely avoided in aquaculture by application of best management practices (BMPs) for site selection, and regulations for formulation and manufacture of feeds. 3.2.3 Chemotherapeutants Toxic chemicals and chemical compounds may residualize in fish following protracted use of approved veterinary medicines. Aquaculture, like terrestrial animal agriculture, relies upon good husbandry and proper use of drugs and chemicals to combat infectious disease pathogens. Of the chemotherapeutants approved for use in aquaculture, certain antibiotics and parasiticides are used in salmon net -pen farming. (i) Antibiotics Antibiotic residues in farmed seafood products are possible hazards to consumers in that they might induce allergic reactions, have toxic effects, or modify the human gut flora. They might also increase resistance in aquatic bacteria to antibiotics, which in turn, might be transferred to human pathogens. 31 All drugs approved by the FDA must be shown to be safe and efficacious. Studies required to meet these requirements typically consist of field (clinical) and laboratory (non - clinical) trials (USOFR 1995a). Clinical studies are conducted under an investigational new animal drug (INAD) exemption issued by FDA under the same conditions expected under the proposed use of the drug. Laboratory studies under strictly controlled conditions in accordance with good laboratory practices (GLP) are specified under the Regulation 21 CFR, Part 58 (USOFR 1995b). Laboratory studies conducted for the approval of a new animal drug for use in US aquaculture have been reviewed in detail by Greenlees (1997). The FDA permits certain antibiotics to be added at sub - therapeutic levels to the feeds of poultry, swine, and cattle as growth promoters. It does not pen-nit the use of antibiotics as growth promoters for fish. In contrast with the results obtained with higher vertebrates, Wagner (1954), Sniezko and Wood (1954), and Sniezko (1957) reported that sulfonamide, tetracycline, and other antibiotics added to the diets of several salmonid species (brook trout, brown trout, and rainbow trout) had no stimulatory effect on growth. At the present time three antibiotics are registered in the US as feed additives for disease control under Regulation 21 CFR, Parts 558.450, 558.575, and 558.582. Respectively, these are oxytetracyline (terramycin), sulfadimethoxine plus ormetoprim (RRomet -30), and sulfamerazine, although sulfamerazine is no longer marketed. For sahmonids, oxytetracyline (terramycin) has a 21 -day withdrawal period before harvest, and RRomet- 30 has a 42 -day withdrawal period. Stoffregen et al. (1996) stated that levels in flesh tissues were undetectable if these withdrawal times were followed. Fong and Brooks (1989) determined that the tolerance levels of salmon for each of these antibiotics were 0.1 ppm. (ii) Parasiticides JSA reviewed the use of chemical compounds and vaccines in aquaculture and published their findings in a guidebook (JSA 1994). Seafood producers operating by the JSA guidelines introduce no hazards from residual drugs. The risk is the misuse of chemical compounds and vaccines by untrained workers. Formalin is the only parasiticide approved at present for farm salmon operations (JSA 1994). It is applied topically, and Fong and Brooks (1989) were unable to detect it in salmon flesh after treatment, concluding that it was not a hazard to consumers. Other substances with putative activity, including acetic acid, garlic, hydrogen peroxide, onion, and sodium chloride, are currently classified by FDA as 'unapproved drugs of low regulatory priority.' The FDA is unlikely to object to use of these substances if the following conditions are met: (a) the drugs are used for the prescribed indications, including species and life stage where specified, (b) they are used at the prescribed dosages, and (c) are used according to good management practices. Also, (d) the product is of an appropriate grade for use in food animals, and (e) an adverse effect on the environment is unlikely. However, the use of such substances under these conditions is not approval or affirmation of their safety and efficacy, and the FDA may take a different position on their use in the future based on further information. 32 3.3 Biological Safety Potential biological hazards to human health from the consumption or contact with contaminated farm products include parasites, bacterial infections, viral infections, or naturally produced toxins. The majority of human pathogens associated with aquaculture products are to be found at freshwater farms, farms in tropical countries, and among shellfish operations. Specific hazards to human health which might be associated with net -pen farming of salmon are anisakiasis, diphylobothriasis, rickettsialosis, vibriosis, aeromonasis, salmonellasis, and plesiomonasis. To date there have been no reported cases of any of these hazards being associated with farmed salmon, and WHO (1999) states that the risk of contracting these illnesses from farmed fish is considered to be low. (i) Aniskiasis Anisakiasis is caused by larval ascaridiod nematode parasites which normally infect marine mammals as the definitive host, and an invertebrate as the primary host. Marine fish are secondary hosts, and are infected when they consume infected fish or invertebrates. Roderick and Cheng (1989) indicated that the parasite inhabits the viscera of live fish but relocated to the musculature upon death. They concluded that the parasite is not likely to be a problem in farmed fish, as the viscera are removed quickly after harvest. The parasite is killed by proper cooking or proper freezing, and only infrequently infects humans. Human infection of this and other parasites primarily occurs when wild fishery products are consumed raw, as in Japanese maguro (tuna) or sake (salmon) sashimi, or after only mild processing, such as cold smoking. Studies by Angot and Brasseur (1993), Bristow and Berland (1991), and Deardorff and Kent (1989) have indicated that farmed salmon do not have nematodes. Consequently the European Union (EU) exempts farmed salmon from a directive (91/493/EEC) which requires that all (wild) Atlantic and Pacific salmon to be processed with minimal cooking (i.e. cold smoking <60 °C) must be frozen prior to sale. This is to protect the consumer from anisakiasis and other parasites. The reason that farmed salmon are apparently free of nematodes is that they are fed with manufactured feeds. If farmed salmon were fed with fresh trash fish, WHO (1999) believes that the potential for aniskiasis from farmed salmon would exist. (ii) Diphylobothriasis Diphylobothriasis is caused by the broad fish tapeworm, Diphyllobothrium Tatum. While the majority of human infections of this parasite come from freshwater fish, Roderick and Cheng (1989) described cases caused by the consumption of uncooked wild salmon. They assumed that the salmon contracted the tapeworm in freshwater and carried the parasite throughout the marine phase before capture. Diphylobothriasis is common found among Eskimos of Alaska and Canada and inhabitants of Finland, all of whom consume large quantities of wild caught salmon. There have been no reports of this tapeworm associated with farmed salmon. 33 (iii) Rickettsialosis Rickettsialosis, or 'salmon poisoning,' is caused by a digenean troglotrematid and is primarily a problem for dogs, which have eaten uncooked wild salmon entrails. Rodrick and Cheng (1989) described reports of this parasite in humans but rarely with serious disease consequences. There have been no reports of this parasite associated with farmed salmon. (iv) Vibriosis and other bacterial diseases Vibriosis, aeromonasis, salmonellasis and plesiomonasis are caused by bacterial infections of Vibrio spp., Aeromonas spp. Salmonella spp. and Plesiomonas spp., respectively. All of these bacteria are a part of the normal aquatic flora, except for Salmonella spp. which are associated with human and animal wastes. The greatest potential for contamination of wild or farmed fish occurs post - harvest when the muscle, which is sterile in healthy living fish, is exposed to external contamination. The practice of delivering net -pen reared salmon alive to the processing plant, where strict BMPs and HACCP practices are followed, significantly reduces the risk to public health from bacteria and parasites. Wild caught salmon, which are landed headed and gutted, have a slightly higher risk of contamination en route to the processing plant. Ward (1989) noted that all these bacteria were killed by thorough cooking, and concluded that the greater risk for the consumer was uncooked or undercooked fish, or if the product was incorrectly handled and processed after harvest. 3.4 Quality and Safety of the Products The public perception of seafood has traditionally been one of high quality, with a range of products all beneficial to individual health. However, there are subtle differences between species, and many of the positive healthy qualities can be destroyed or contaminated by poor post - harvest handling and processing. The proximate composition of farmed salmon (percent protein, lipid, ash and water) is generally similar to wild salmon, except that the lipid and fatty acid composition can differ. In general, wild salmon have a higher concentration of n -3 fatty acids as a percent of total fat, while farmed salmon have a higher level of total fat. Sargent (1995) found there was a similar overall level of n -3 fatty acids as a percentage of the total fillet, which was important for human health. The fatty acid composition of farmed fish reflects the fatty acid of the lipid source in the feed. Many authors (Nettleton 1990, Haard 1992, Nettleton and Exler 1992) have experimented with an array of variables and all report that it is possible to control the fatty acid composition of farmed fish. Many food nutritionists have worked on the various sensory measures of farmed salmon, such as taste, texture, and color of the final product. Haard (1992) reported that farmed salmon, in general, were milder in flavor, softer in texture, and paler in color than their wild counterparts. Sylvia et al. (1995) and Wessells and Holland (1998) noted that consumers were able to detect differences between wild and cultured salmon, with preferences related to regional experience with each product. The greatest determinant of product quality for salmon from either source was freshness. Consistency in quality and 34 quantity, consistent price, and year -round availability were all considered by consumers to be advantages of farmed salmon. 3.5 Worker Safety According to the Bureau of Labor Statistics Census of Fatal Occupational Injuries (CFOs) commercial fishing was the single most deadly occupation in the US between 1992 and 1996 (CFOI 1999). This is likely to still be the case. Drudi (1998) concluded that fishers face a risk of death 20 -30 times higher than all other occupations. Between 1992 and 1996 inclusive, 380 fishermen fatalities were recorded in the USA. During the same period the occupation classified as 'Animal aquaculture' (SIC 0273) had eight fatalities, and 'Fish hatcheries and preserves' (SIC 092 1) had five fatalities (D. Drudi, personal communication, 2000). It was not possible to isolate salmon fishers and salmon farmers from within these numbers. Fish farm workers face chemical hazards from mishandling drugs and chemicals used in aquaculture. Guidelines for the use and safe handling of chemical compounds and vaccines in the aquaculture industry in the US have been published by JSA (JSA 1994), and many of these guidelines are being reflected by the CON and BMPs being prepared by individual industries for the protection of their workers. 35 4. SALMON FARMING AND THE ENVIRONMENT The fourth chapter reviews current information on the effects of the many activities associated with salmon aquaculture on the environment. Where possible the review attempts to deal with these effects in quantitative terms, and the measures which are currently used to reduce them. The chapter has seven identified sub -sets. The first sub - section reviews the potential effects of the organic wastes emanating from net -pen salmon farming. The origins of such effects are uneaten or waste feed, feces from the fish, and bio- fouling organisms on the structures. The second sub - section reviews the inorganic wastes, specifically nitrogen and phosphorus, and heavy metals. The third sub- section deals with the pathogenic organisms, which might be in the vicinity of fish farms, and the risks to human health from wastes, which might contain such pathogens. The next sub - section deals with the therapeutic compounds which might be used to control parasites and diseases. The fifth sub - section reviews the biological and chemical changes in the sediments and in the water column both beneath the farm and downstream. Where possible, quantitative information is provided and then applied collectively in terms of an operating farm with reference points. The sixth sub - section reviews information on the chemical and biological recovery of sediments under salmon farms. The final sub - section reviews alternatives being used for management of all these environmental effects. These include monitoring experiences with a number of indicators and models, followed by a review of other government policies and methodologies. 4.1 The Effects of Organic Wastes from Net -pen Salmon Farms 4.1.1 Waste feed Early diets for farmed Atlantic salmon contained 45 -50 % protein, 16 -22% lipids, and 17% carbohydrates. Technology now permits the production of high- energy salmon diets containing about 30 -35% lipids and 40% protein, and the minimum level of digestible carbohydrate (about 10 %) necessary to bind the pellets. These high- energy diets more closely resemble the composition of the natural prey of salmon. More recent salmon feeds were reported by Einen at al. (1995) and Rosenthal et al. (1995) to contain 7% nitrogen and 1% phosphorus. Mann (EWOS Canada Ltd., personal communication) estimates that current salmon diets contain 38 -39 % crude protein, 6.5% nitrogen, and 1% phosphorus. Lipid content in current high - energy diets is 33 -35 %, of which half is fish oils and half plant oils, such as flax and linseed oils, high in omega -3 fatty acids. The amount of waste feed depends on feeding efficiency, which is principally influenced by feed composition, feeding methodology, water currents at the site, and net -pen configuration. Beveridge et al. (1991) stated that up to 30% of feed was lost. Rosenthal et al. (1995) noted higher losses (up to 35 %) for wet feeds, which might contain greater than 30% moisture, than dry feeds. Weston (1986) suggested that less than 5% of dry feed was lost at Puget Sound salmon farms. This is consistent with research by Gowen 36 and Bradbury (1987), who reported losses were least (1 -5 %) with dry feeds, which contained less than 10% moisture. Findlay and Watling (1994) reported maximum feed loss rates of 5 -11 %, with an average feed wastage of <5 %. Dry and semi -moist feeds are now used exclusively in the Pacific Northwest and current feed loss rates are estimated between 3 -5 % (J. Mann, EWOS Canada Ltd., personal communication). The amount of feed loss is also dependent on feeding methods and strategies. Cross (1990) reported that feed wastage at a commercial salmon farm in Sooke Inlet, British Columbia (BC) was 3.6% delivered by hand and 8.8% delivered by automatic feeders. This was probably due to the abrasion of feed pellets in some automatic feeders, which can result in the disintegration of 4 -5% of the pellets. Other automated feeding systems, with short delivery distances and operated by compressed air valves, may disintegrate <0.5% of the pellets (J. Mann, EWOS Canada Ltd., personal communication). New technologies, such as feedback cones and underwater video or acoustical devices described by Mayer and McLean (1995), are now commonly used to monitor feeding behavior in efforts to minimize losses of uneaten feed from net -pens. Sutherland et al. (2000) conducted a study at a salmon farm in the Broughton Archipelago, Canada BC, to quantify suspended particulates during peak feeding times and to make point -in -time estimates of organic loading. Based on stable carbon isotope analysis, they concluded that very little feed was not consumed by the fish at the farm under study. In a series of video reports to the BC Ministry of Environment documenting the environmental conditions on the perimeter of several salmon farms in the Province, Brooks (2000a —f) recorded no observable wasted feed pellets. The results of this review are reasonably consistent and indicate that, as at this time, 5% or less of the dry feed delivered to cultured salmon in net -pens is lost to the environment. The low proportion has been due to the combination of improved feedback technologies and the practice of quickly feeding the fish to satiation once or twice each day (mean feeding). Improvements in feed delivery systems to minimize pellet disintegration will probably reduce losses further well below 5 %, a figure much less than the 20 -30% numbers used in many aquaculture models (see Section 4.7.2). 4.1.2 Fish feces Weston (1986) estimated that 25 -33% of feed consumed by the fish was ejected as feces. Modern diets are approximately 87 -88% digestible Q. Mann, EWOS Canada Ltd., personal communication). The remaining ash consists primarily of calcium and inorganic phosphate, and represents 8.0 -8.5% of the feed. This implies approximately 12.5% of the weight of ingested feed will be ejected in feces. Subtracting 87.7% for digested protein and 8.25% for ash, this leaves about 4% of the feed ingested to be ejected as labile organic material in the feces. If 5% of the feed is uneaten (Findlay and Watling 1994) and feces contribute organic matter equivalent to 4% of the feed weight, then approximately 8.8% of the labile organic carbon delivered in feed is discharged from the net -pen structure in particulate form, contributing to the BOD of the sediments. 37 Feed conversion ratios (FCRs) of farmed fish are frequently quoted in literature, but have not been adequately defined. They are typically measured as the ratio of the dry weight of feed provided to the wet weight of salmon produced. They are considered an essential metric by the aquaculture industry for assessing producer program efficiency. The FCR is affected by genetic and environmental factors. The quality and composition of the feed, to include palatability and nutrient balance, is also important together with fish health and feeding methodologies. In short, the FCR integrates all aspects of the culture operation into one simple metric. Two types of FCR are typically defined by industry: • The economic feed conversion ratio (EFCR) is defined as the amount of feed supplied to a farm divided by the round dressed weight of fish produced for market. This metric is easy to calculate and is useful in determining the economic efficiency of a farm. The biological feed conversion ration (BFCR). This metric is biologically and environmentally more meaningful but more difficult to determine. It is equal to the feed actually consumed by the fish (feed provided less the uneaten portion) divided by the total fish biomass produced on the farm, including escapes and mortalities. Robinson (Stolt Sea Farm, personal communication) noted that the head -on processed weights must be corrected for the approximate 16% loss of fish weight during starvation, bleeding and removal of offal. Enell and Ackefors (1992) reported that marine FCRs in Norway declined from 2.25 in 1974 to an average of 1.2 -1.3 in 1992. The authors calculated that improvement resulted in a 23% decrease in nitrogen and a 50% decrease in phosphorous loading associated with farm operations. Rosenthal et al. (1995) estimated FCRs for Atlantic salmon to be 1.2, while Levings (1997) estimated an even lower FCR of 1.17 for operations in BC. FCRs have probably advanced to a point where significant additional improvement will be difficult. 4.1.3 Fish carcasses as wastes Winsby et al. (1996) reviewed and analyzed the mortality of fish at BC net -pen salmon farms in 1994. Their data suggested approximately 2,000 mt of salmon died at farms that year, or approximately 9% of the total production of 22,000 mt. They concluded that most of the salmon carcasses were removed to approved compost disposal locations. No inappropriate disposal of salmon carcasses has been documented in the literature. Losses of fish on net -pen salmon farms are restricted to individual fish, which may have been attacked and killed by a predator, and numbers of fish which died as a consequence of an algal bloom or disease epidemic. BMPs of net -pen salmon farms require physical removal of any carcasses on a daily basis, and therefore they do not contribute to any biological loading on the environment. 4.1.4 Bio- fouling organisms as wastes Biological fouling is a significant factor in coastal environments and large masses of mussels, barnacles, ascidians, and bryozoans can weigh down nets and restrict water flow through a net -pen complex. Heavily fouled nets can also compromise the structural integrity of the complex. Weston (1986) concluded that bio- fouling organisms on net -pens, and the debris which was released by net cleaning, were not significant sources of organic input to sediments beneath salmon farms. Winsby et al. (1996) discussed the mechanics of removing fouling organisms from nets associated with salmon fauns. There is no literature quantitatively describing the mass of bio- fouling which builds up on nets and floating structures of salmon farms, or other similar marine structures. Brooks (1994a) defined a neutral impact zone (NIZ) as that distance from the perimeter of a salmon farm at which there was neither an apparent increase nor decrease in the abundance and diversity of the benthic infaunal community when compared with a local control site. In annual observations at a poorly flushed farm site, he noted that the NIZ was influenced by several factors, including, for example, deposits of debris following the pressure - washing of nets in situ. He observed a 30 -cm deep layer of mussel debris in sediments from the perimeter of the farm stretching a distance of 6 m downstream. The downstream location of the NIZ increased from 12 m in 1993 to approximately 22 m in 1994, after in situ cleaning. He concluded that it was not possible to establish a cause and effect relationship but the presence of the mussel shells undoubtedly had an effect on the benthos. 4.1.5 Measurement of organic wastes Brown et al. (1987) compared the areal extent of benthic impacts associated with organic wastes from fish farms in Sweden with that from sewage treatment plant and pulp mill effluents. They found reducing (anaerobic) sediments covering 0.6 km2 around a poorly flushed (mean current velocity = 3.7 cm /sec) salmon farm located in shallow water (20 m below NILLW). Significant changes in the benthic community were observed within 15 m of the perimeter of the farm. In comparison, they cite Stanley et al. (1980) in noting that a pulp mill in Loch Eil, Scotland had created reducing conditions in sediments extending over an area of 5 km2. Pearson (1986) observed reducing sediments covering 23 km2 associated with a sewage disposal site at Garroch Head, Firth of Clyde, Scotland. The impact associated with this single sewage discharge covered an area 38 times as large as that impacted by the salmon farm. Ellis (1996) suggested that waste feed and feces from salmon farms in BC were equivalent to the human sewage from a city of 500,000 people, and Folke et al. (1994) compared the waste from 100 mt of salmon with a human settlement of 850 to 3,200 persons. Ackefors and Enell (1990) criticized the assumptions upon which such comparisons were made. Their argument was based on differences in the form of nitrogen released from sewage treatment plants and fish farms and differences in the ratio of carbon, nitrogen and phosphorus discharged from the two activities. Taylor et al. (1998) found that organic enrichment adjacent to the Macaulay and Clover Point outfalls in the city of Victoria BC, was similar to that expected at a productive salmon farm. Adverse effects on benthic infauna associated with organic enrichment by 39 sewage treatment plants were generally restricted to distances less than 100 m from the diffusers. They also found significantly elevated levels of 1,4- dichlorobenzene, polycyclic aromatic hydrocarbons and mercury within 100 -400 m of the same two outfalls. These concentrations exceed Washington State Sediment Quality Standards. Sediment toxicity associated with these outfalls was limited to adverse effects on growth and development in laboratory bioassays. The authors concluded that the magnitude and extent of the observed effects ( <400 m from the outfalls) indicated little cause for concern for human health. The effects at these outfalls extend four times further from the source than is allowed at salmon farms complying with the BC Draft Waste Management Policy. Salmon farm wastes do not contain toxic levels of metals and industrial hydrocarbons associated with sewage treatment plants, and there are no reasonable sources of these common contaminants on farms other than the minor exhaust from boats. Ackefors and Enell (1994) estimated the total organic output from salmon farms on the order of 2.5 mt wet weight per metric tonne of fish produced. Gowen et al. (1991) cited three studies assessing the flux of carbon through salmon net -pens. In all three cases the harvested fish retained 21 -23% of the carbon in feed and it was estimated that 75 -80 % of the carbon was lost to the environment mostly in a dissolved form as CO2. Merican and Phillips (1985) estimated that 35.6% of the carbon, 21.8% of the nitrogen, and 65.9% of the phosphorus were lost to the environment in solid form. Other estimates of the total suspended solids output from intensive net -cage culture of fish by Kadowaki et al. (1980), Warrer- Hansen (1982), Enell and Lof (1983), and Merican and Phillips (1985) range from 5 -50 g suspended solids /m2 -day. All these publications are more than 15 years old and therefore these values do not reflect recent improvements in fish feed and feeding technologies. Gowen and Bradbury (1987) estimated organic waste sedimentation rates of 27.4 g /m2- day under Irish salmon farms, and an average of 8.2 g /m2 -day immediately adjacent to the perimeter of the net -pen. Gowen et al. (1988) measured average rates of 82.2 g dry weight/m2 -day on the perimeter of a net -pen in Washington, and Cross (1990) estimated an average overall sedimentation rate of 42.7 g TVS /m2 -day with a maximum of 94.5 g total volatile solids (TVS) /m2 -day at seven salmon farms in BC. More recent work by Findlay and Watling (1994) in Maine measured sedimentation rates on the perimeter of salmon farms at between 1.0 -1.6 g carbon/m2 -day, and Hargrave (1994) summarized sedimentation rates from less than one to over 100 g carbon/2 m -day from salmon cage operations described by a number of authors. Brooks, using his published data from many original sources (Brooks 2000a —f), derived a theoretical estimate of contemporary TVS loading near fish farms. Given a feed with 11% moisture content and FCR of 1.2, the feed provided (1.2 kg x 89 % dry matter) or 1.07 kg dry feed /kg of fish produced. This: [(1.07 kg dry wt. feed/kg salmon produced) x 8.8% labile organic waste /dry weight] was in turn equal to 0.094 kg of labile volatile solids /wet weight kg of fish produced. Thus he estimated that a salmon farm producing 1,500 mt of salmon during a 16 to 20- month production cycle would discharge 141 mt of organic waste on a dry weight basis. M Furthermore, assuming a fish density of 10 kg/m3 in cages 15 m deep and a grow -out cycle of 18 months, the annual sediment load on average would be: (10 k-g fish/m3 x 15 m deed x 0.094 kg LYS /kg fish) (548 days) which is equal to 25.7 g TVS /m2 -day. The load would, in reality, be lower at the beginning of the grow -out cycle and increase towards maximum biomass. Brooks (2000e) analyzed sediments collected in canisters deployed 5 m above the bottom at varying distances from two farms in BC and at reference stations. The mean loading of volatile solids on the perimeter of these farms was 39.2 g TVS /m2 -day. The mean deposition of volatile material at the control stations was 6.3 g TVS /m2 -day and the contribution by the farm was approximately 32.9 g TVS /m2 -day. These studies were completed near peak salmon biomass and the observed values would therefore be greater than the theoretical average of 25.7 g TVS /m2 -day calculated above. Nonetheless, these observed and theoretical values are reasonably close. In summary, sedimentation rates on the perimeter of salmon net -pens have remained fairly constant in the range 15.1 -100 g TVS /m2 -day despite the typical increase in farm size from 200 -300 mt in the 1980s and early 1990s to the 1,500 mt of recent years. A recent study by Brooks (2000e) found a TVS loading of 32.9 g/m2 -day on the perimeter of a salmon farm at peak production. This value is reasonably close to a theoretical average of 25.7 g TVS /m2 -day calculated for an entire 18 -month production cycle. 4.2 Dissolved Inorganic Wastes 4.2.1 Dissolved nitrogen and phosphorus Salmon excrete 75 -90% of their ammonia and ammonium waste across gill epithelia (Gormican 1989) or in concentrated urea (Persson 1988, and Gowen et al. 1991). Brett and Zala (1975) reported a constant urea excretion rate by sockeye salmon of 2.2 mg N /kg per hour. Nitrogen and phosphorus are also dissolved from waste feed and feces during and after descent to bottom sediments. All these dissolved forms of nitrogen are readily available for uptake by phytoplankton. Silvert (1994a) suggested that 66 -85% of phosphorus in feed is lost in a dissolved form to the environment at salmon farms. Winsby et al. (1996) reported significant variation in observable increases in soluble nitrogen and phosphorus levels in the water column at salmon farms. Johnsen and Wandsvik (199 1) and Johnsen et al. (1993) estimated that 20.5 -30.0 g of nitrogen and 6.7 g of phosphorus are released per kilogram of Atlantic salmon produced when fed modern high- energy diets containing 30% lipid. Levings (1997) used these estimates to conclude that 844 mt of nitrogen and 188.6 mt of phosphorus are released to marine environments in BC each year by salmon farms. These values do not include nitrogen and phosphorus associated with uneaten feed. Statistically significant increases in soluble nutrients at salmon farms have infrequently been observed in Puget Sound (Rensel 1989, and Brooks 1994x, 1994b, 1995a, and 1995b). Aquatic Lands Leases (ALLs) for salmon farms in Washington State have required monitoring of NO3, NO2, and total ammonia (NH3 + NH4) in water samples 41 taken within one hour of slack tide at stations located 30 m up- current, and 6 m and 30 m downstream at all permitted farms at a depth equal to one -half the depth of the containment nets. In general, the variability between replicate samples taken at the 6 m downstream station was as great, or greater, than any observed increase in nitrogen between upstream and downstream stations. No significant increases in nitrogen were observed at any of the 30 m downstream stations. The highest observed level of toxic unionized ammonia (NH3) was 0.0004 mg -L -1. This is lower (by a factor of 87.5) than the EPA chronic exposure (4 -day) concentration limit of 0.035 mg -L -1 at pH = 8 and T = 15 °C when sensitive salmonid species are present. Rensel (1989) studied dissolved nitrogen production at two poorly flushed farms in Washington. He compared dissolved nitrogen and unionized ammonia concentrations within the salmon pens with upstream and downstream levels during early ebb tides. Upstream dissolved nitrogen levels of 0.0003 mg -L -1 were increased to 0.0023 mg -L -1 at the center of the net -pen complex, but decreased to background levels at downstream stations. He also observed maximum unionized ammonia levels equivalent to 6% of the EPA criteria in the center of these net -pen complexes during slack tide. Weston (1986) reported ambient levels of dissolved inorganic nitrogen (DIN) in Puget Sound at 0.3 to 1.9 mg -L -1, indicating high variability. The greatest increase in DIN reported by Brooks (1991, 1992, 1993a, 1994a, and 1995a) was 5.29 µmoles -L -1 (0.09 mg -L -1), or 8% of the mean value reported by Weston (1986). The literature indicates that the concentration of dissolved inorganic nitrogen added to marine water at salmon farms is very low on the perimeter of net -pen farms, and essentially immeasurable at distances greater than 9 m from the farm perimeter. 4.2.2 Heavy metal accumulation in sediments (i) Zinc Zinc is an essential metal important for insulin structure and function and as a co- factor of carbonic anhydrase. Historically it has been added to salmon feeds in trace amounts equal to 30 to 100 mg-kg-1 of feed (see Chow and Schell 1978, and Anderson 1998). Long et al. (1995) provide an effects range -low (ER -L) of 150 µg zinc /g dry sediment weight, an effects range - moderate (ER -M) of 410 µg /g and an overall apparent effects threshold (AET) of 260 µg /g. The Washington State sediment quality criterion for zinc is 270 µg Zn/g dry sediment (WAC 1991). Other available benchmarks include the (TEL + PEL) /2 or 197.5 µg Zn/g dry sediment. Information on the development of the threshold effects level (TEL) and the probable effects level (PEL) can be found in MacDonald (1994). The published sediment benchmarks (in µg Zn /g dry sediment) are summarized below. It should be noted that only the WA State AET is a statutory criterion. Contaminant NOAA AET TEL + PEL /2 WA State AET Zinc 260.0 197.5 270.0 42 Brooks (2000b) summarized 193 analyses for zinc in sediments collected near 27 salmon farms in BC. Nineteen samples from eight farms exceeded the AET of 260 µg Zn /g dry sediment. All of the high zinc samples also contained significantly elevated sediment sulfide and TVS concentrations. There was a statistically significant correlation between zinc and both TVS and total sediment sulfides (S -). In response to the observed high sediment zinc concentration as some farms, fish feed manufacturing companies in BC have reduced the amount of zinc in feed to the minimum necessary to maintain salmon health. They have also changed the form of zinc from zinc sulfate to a methionine analog, which is more bio- available. Di Toro et al. (1992) described the relationship between sediment acid volatile sulfides, metal concentrations, and toxicity to infauna. Acid volatile sulfides (AVS) is a reactive pool of solid -phase sulfide that is available to bind metals and render them biologically unavailable and non -toxic to biota. The AVS method is useful in predicting when sediments with elevated metal concentrations are potentially toxic. Metal toxicity is considered additive, and each must be added to obtain a sum of toxic units. This methodology has been validated for copper and zinc (EPA 1994). None of the zinc concentrations observed by Brooks (2000a) was toxic, as they were all associated with sediments containing high concentrations of sulfide. Furthermore, Brooks (2000a) reported that initially high sediment concentrations of zinc under one salmon farm declined to background during a post production fallow period. At the peak of production at the studied farm, sediment zinc concentrations were elevated to 200 µg/g on the perimeter. They declined exponentially and reached a background concentration of ca. 25 µg /g at a distance of between 30 -75 m from the net -pen perimeter on the downstream transect. Sediment -zinc concentrations were well correlated with TVS throughout the study (r = 0.76). Sediment -zinc declined during chemical remediation and was at background concentrations after six months of fallow. He hypothesized that zinc was bound by sulfides in the sediments. Sediment sulfides decrease with decreasing biological oxygen demand during chemical remediation. When the sediments become aerobic, the sulfide is oxidized back to sulfate releasing the zinc, which is diluted in the overlying water column. This hypothesis is consistent with chemical theory and with evidence collected earlier by Brooks (2000b). Given that these hypotheses stand the test of further scrutiny, no biological effects should be anticipated from the observed concentrations of sediment zinc under salmon farms. (ii) Copper Levels of copper may be elevated in the environment around net -pen farms, which use preventative treatments for bio- fouling. Several anti - fouling paints and solutions are approved for use in the marine environment, and are therefore used on salmon farms. Anti - predator nets and fish containment nets are increasingly treated with a copper anti- fouling solution to inhibit the settlement of organisms and bio- fouling. The practice benefits the environment by reducing carbon inputs to the benthos. However, if cleaning is accomplished in situ the displaced organisms can exacerbate organic loading to the 43 benthos under the farm. BMPs should require that nets first be removed and then washed by hand or machine on a barge or at an upland facility. Copper is a micronutrient. At moderately low levels the cupric ion is toxic to marine organisms — particularly the larval stages of invertebrates. Until 1995 the EPA marine chronic water quality criterion for copper was 2.5 µg-L_' (EPA, 1986). Based on new information that level is now being increased to 3.1 µg-L-' dissolved copper (EPA, 1995). Lewis and Metaxas (1991) examined copper concentrations immediately adjacent to newly installed copper - treated nets at net -pen salmon farms in BC. They measured ambient copper concentrations of 0.38 µg-L_' in July and 0.37 µg-L-' in August. The concentration inside the pen was 0.54 pg -L -1 in July after a freshly treated net was installed, and 0.54 pg -L -1 one month later in August. The small addition of copper in the water from the treated net (0.16 to 0.17 µg-L-) was not biologically significant except to organisms which tried to settle on the net. Peterson et al. (199 1) compared copper levels in muscle and liver tissue from chinook salmon grown in pens treated with ®Americoat 675, a copper based antifoulant, with those in a pen with untreated nets. No statistically significant differences in the copper levels in like -size fish from these two fauns were observed, suggesting that the copper released from the treated nets was not significantly concentrated by Chinook salmon. Brooks (2000d) conducted in vitro studies on the leaching of copper from ®Flexgard XI, the most commonly used antifouling product on the west coast of North America. Initial losses of 155 µg Cu /cm2 -day declined exponentially during the period of the study. Brooks (2000d) used the data to develop a spreadsheet model that predicts copper concentration in the water as a function of the maximum current speeds observed at a site, and the net -pen configuration and orientation of the complex to the currents. His model predicted that containment nets treated with ®Flexgard XI would not exceed the US EPA copper water quality criteria when fewer than 24 cages were installed in two rows oriented parallel to currents flowing with a maximum speed greater than 20 cm /sec. The model predicted that unless the configuration of net -pens or their orientation with the currents was changed, the use of ®Flexgard XI treated nets would result in exceeding the chronic water quality copper criterion at a small percentage of existing farms. The author noted that assumptions used in his model were conservative, and probably predicted higher copper concentrations than would actually be observed in the field. The model has not been yet been tested in the field but it clearly demonstrated the need to manage the use of antifouling products. Brooks (2000d) compared sediment copper concentrations at salmon farms in BC using ®Flexgard XI treated nets with those at fauns using untreated nets and reference stations. Farmers in BC typically treat their nets at the beginning of each production period and treat them again only after the fish are harvested. The mean concentration of copper in the sediments of 117 farm stations using treated nets was 48.24 + 27.00 µg Cu /g. This level was not significantly different than the mean concentration of 12.01 + 2.77 .. measured at the reference stations, or mean concentration of 26.3 observed at farms not using copper treated nets (ANOVA F = 0.73; p = 0.49). Brooks (2000d) found a great deal of variability in sediment copper concentrations at farms using copper treated nets. The concentration of copper in 2 of these 117 samples collected at 14 farms using copper treated nets exceeded the NOAA ER -M of 270 µg Cu /g dry sediment, and the State of Washington sediment quality criterion of 390 µg Cu /g. Thirteen of the samples (11 %) exceeded the mean of the TEL and PEL used as a regulatory benchmark in BC. All samples exceeding the lower benchmark were collected at 5 of the 14 farms using copper- treated nets. Discussion with the producers revealed that these farms washed their nets in barges during fallow periods. The fouling debris cleaned from the nets was not retained but washed over the side. Consequently, the concentrations observed at 5 of the 14 farms were not directly associated with the copper treatment itself but some ancillary activity, like net washing. Other anecdotal information revealed also that the copper — latex paint was abraded from the nets during washing and that significant quantities of the latex chips (with copper imbedded) were then washed over the side of the barge with the fouling organisms. The copper bound in the latex would then leach out over time. Brooks (2000d) concluded that all copper - treated nets should be removed after harvesting the fish, and washed and retreated at upland stations. Furthermore, all debris should be buried at an approved landfill site. 4.3 Pathogenic Organisms in the Vicinity of Net -pen Salmon Farms 4.3.1 Fecal coliform bacteria The National Shellfish Sanitation Program (NSSP) certifies commercial shellfish beds in the US and their harvest is governed by some very specific regulations (NSSP 1997); for example, harvesting shellfish is forbidden within one mile of any out -fall from a sewage treatment plant. This is because of public health concerns associated with toxicants (heavy metals, PCBs, polycyclic aromatic hydrocarbons, etc.) released in industrial and residential waste, and because many human pathogens (including viruses and bacteria) are associated with treated human sewage. Shellfish sanitation is not adversely affected by nutrients (carbon, nitrogen or phosphorus). Viruses are generally taxa- specific, and viruses pathogenic to fish, such as infectious pancreatic necrosis (IPN), viral hemorrhagic septicemia (VHS), and infectious hematopoietic necrosis (11-IN) have no documented effect on human beings. However, fecal coliform (FC) bacteria persist in sediments high in total organic carbon (TOC) for varying periods. These bacteria are specific to warm - blooded animals (mammals and birds) and are not a normal part of the microflora found in fish intestines. However, mammals and birds are strongly attracted to fish farms increasing the potential for increased fecal coliform levels in the sediments near salmon farms. There is no potential for an increase in fecal coliform bacteria associated with cultured fish. NSSP defines water quality standards for shellfish growing areas and has a methodology for assessing and classifying shellfish harvest grounds. Approved growing areas must have a most probable number or geometric mean (FC MPN) of <14 FC /100 ml, with not MR more than 10% of the samples exceeding an MPN of 43/100 ml in a 5 -tube decimal dilution test (APHA, 1992). Brooks (2000x) analyzed 33 water samples from the vicinity of an operating salmon farm during every quarter of the year. The MPN for all stations was less than the NSSP requirements for an Approved Shellfish Harvest Classification (14 FC /100 ml), and all stations met NSSP requirements. He also examined shellfish tissues for FC bacteria. NSSP has established an allowable upper limit of 230 FC /100 g of tissue for product entering interstate (or international) commerce. Average clam tissue levels at the closest station located 200 m from the farm were 130 FC /100 g tissue. At 500 m the average level dropped to 50 FC /100 g, and at the reference station it was 20 FC /100 g. All of the shellfish samples tested met the NSSP requirement for shellfish tissues in commerce. In summary, he observed slightly more FC bacteria in water and shellfish tissues at stations closest to the farm perimeter. The sources of observed bacteria were not determined, but potential sources include farm workers themselves and, more probably, the birds and mammals which congregate around salmon farms. Water and shellfish tissues were consistently of high quality and met all bacteriological requirements imposed by NSSP. 4.3.2 Farm wastes Ellis (1996) postulated that waste feed and feces might enhance populations of a variety of ubiquitous marine bacteria pathogenic to humans. There is no direct evidence in the scientific literature that salmon farm wastes enhance pathogenic marine bacteria. In an extensive review of the epidemiological records for shellfish in the waters of Washington State spanning 20 years, Brooks (1993 unpubl. data, Aquatic Environmental Sciences, Port Townsend, WA 98368) did not find one documented case of Vibrio vulnificus- induced disease. This, he concluded, was because thennophilic bacteria, like V. vulnificus, required a high water temperatures in addition to a rich source of organic material to thrive. Elevated ambient water temperatures would likely be a requirement of most bacteria that are pathogenic to homoeothermal humans. Bacteria which flourish in warm - blooded animals are unlikely to proliferate in cold Pacific Northwest waters under salmon farms. Also, as salmon are poikilotherms, FC and other disease - causing bacteria which flourish in warm - blooded animals would not likely multiply in the gut of salmon, whose intestinal flora is determined primarily by ambient bacterial concentrations. He concluded there was no basis for assuming the feces of caged salmon would contain more than ambient concentrations of those bacteria pathogenic to humans. In another comparison of microbial levels in the tissues of farmed and wild salmon, Calderwood et al. (1988) examined the kidney, liver, spleen, heart, and muscle tissues for the presence of viruses and 16 bacterial species, including several later hypothesized as risks by Ellis (1996). They compared 68 adult wild steelhead trout at Robertson Creek and 50 wild adult coho from Chehalis, Washington with cultured Chinook salmon from Sechelt and Sooke Basin in British Columbia. Their results were as follows: (a) V. vulnificus, a potentially serious human pathogen in immune - compromised individuals, was not detected in the cultured fish. However, 44% of wild fish returning to Chehalis were positive for this bacterium. Other vibrio species, including the potential M human pathogen, V. parahaemolyticus, were not found in the farmed salmon, but were found with a prevalence of 9 and 44% in the wild fish. (b) Acinetobacter calcoaceticus var. anitratus, which is a common bacterium found in water and soil, and has been associated with pneumonia, meningitis, and septicemia in humans, was observed with an average prevalence of 14% in cultured fish, and five times higher (76 %) in wild fish. (c) Aeromonas hydrophila was observed in over half of the wild fish from both Robertson Creek and Chehalis. Both A. hydrophila and A. salmonicida are common fish pathogens (Roberts 1978) but neither was isolated from tissues of cultured Chinook salmon. This early work by Caldewood et al. (1988) suggests that wild fish are far more likely to be a source of disease - causing bacteria than farmed fish. Their data do not support any hypothesis that environmental conditions on farms with healthy Chinook salmon are enhancing populations of pathogenic bacteria. Furthermore, in their search for human diseases epidemiologists most frequently examine the population having the greatest exposure to the suspected etiologic agent. On salmon farms, the populations most exposed to the fish are the farm workers and processors. If farms are a significant source of human pathogens, then farm workers and fish processors should show some history of such diseases. There are no epidemiological records, which show evidence of any infectious outbreaks of disease. Collectively, an understanding of productive environments and fish and human physiology, and the lack of supporting epidemiological evidence, show that salmon farms in the Pacific Northwest are unlikely to increase any risk to human health from marine bacteria. Because of differences in its physical and chemical composition fish farm wastes do not disperse over large areas. They remain localized where they are metabolized by naturally occurring marine bacteria and opportunistic invertebrates. There is no evidence that salmon farms create conditions leading to a proliferation of pathogenic bacteria. Furthermore, from a perspective of human health there appears to be no basis for suggesting fish farm wastes are comparable with human sewage from either large cites or even small towns. 4.4 The Effects of Therapeutic Compounds The majority of therapeutic compounds used at salmon farms are for the control of sea lice. Sea lice, particularly Caligus elongatus, Lepeophtheirus salmonis, and Ergasilus labracis, have caused extensive losses of fish, particularly at farms in the northeastern Atlantic. They have not presented significant problems to producers in the Pacific Northwest, and salmon produced in Washington have not been treated for lice for the last 15 years (A. Mogster, Northwest Seafarms, personal communication). Both ivermectin and emamectin have been used infrequently to control sea lice in BC. Costello (1993) and Roth et al. (1993) describe the physical, chemical, and biological methods used to control sea lice on fish farms in other areas. Current practices rely 47 primarily on the administration of chemo- therapeutic compounds in food or as a bath. The following treatments have been authorized for use. (i) Ivermectin Ivermectin (22, 23- dihydroavermectin B 1) has been used widely in agriculture for many years to control parasites, and was reported by Smith et al. (1993), and Johnson and Margolis (1993) to be effective in controlling sea lice on caged salmon. It is administered as a coating on feed at a rate of 0.025 mg ivermectin /kg of fish at 10 °C twice per week for 4 weeks. The dose is increased by 10% for every 1 °C decrease in ambient temperature. In Scotland the maximum number of weekly treatments is three per year (SEPA 2000). Ivermectin is a broad - spectrum biocide which has low water solubility and a moderately high affinity for binding to particles. The compound is reported by SEPA (1998a) to concentrate in Mytilus edulis by a relatively low factor of 752. Grant and Briggs (1998a) stated that it did not appear to accumulate or concentrate in the food chain. Dissolved concentrations of ivermectin are lethal to a number of marine organisms, ranging from a 96 hr LC50 of 0.022 µg ivennectin/L for Mysidopsis bahia (Davies et al. 1997) to >10,000 pg/L for nematodes (Grant and Briggs 1998b). Most of the 96 hr LC 50 values are less than 1000 pg/L. Collier and Pinn (1998) and Grant and Briggs (1998b) have shown that crustaceans and polychaetes are more susceptible to ivermectin than mollusks. Annual studies in Scotland by ERT Ltd. did not detect ivermectin in the water column (detection limit = 0.5 µg/L) at a Scottish farm undergoing treatment (ERT 1997, and ERT 1998). Burridge and Haya (1993) found that ivermectin- coated waste feed affected non - target species, such as the shrimp (Crangon septemspinosa) at concentrations of 8.5 µg ivermectin /g food. Ivermectin toxicity was demonstrated in laboratory sediments at concentrations ranging from a 10 day LC50 of 23 µg ivermectin /kg dry sediment for Arenicola marina by Thain et al. (1997), and to 180 µg /kg for Asterias rubens by Davies et al. (1998). Black et al. (1997) documented significant mortality of polychaetes at ivermectin accumulations >81 µg ivermectin /m2. This is equivalent to a concentration of approximately 25 µg /kg if the ivennectin is mixed into the top 2 -cm of sediments having a density of 1.6 g/cm3. Of particular interest was the adverse effect on the organic carbon tolerant opportunist C. capitata, whose abundance was significantly reduced at ivermectin concentrations above the calculated value of 25 µg /kg. The paper by Black et al. (1997) did not discuss the increased chemical and biological remediation times that might result from a significant reduction in the abundance of C. capitata. The fate of ivermectin not absorbed by Atlantic salmon appears to be sedimentation followed by slow degradation. Collier and Pinn (1998) noted that the breakdown of ivermectin in marine sediments was dependent on light and temperature. Davies et al. (1998) determined a half -life of ivermectin in marine sediments to be >100 days under the tested conditions. ERT (1997 and 1998) detected ivermectin at concentrations ranging from 5 -11 µg /kg (wet sediment weight) in only 3 of 54 sediment samples at a farm undergoing treatment. Ivermictin was also detected in sediment traps deployed on the perimeter of farms undergoing treatment at 42 g /kg. Ivermectin was detected in 2 of 108 mussel samples at concentrations of 5 and <5 µg /kg collected from caged mussels deployed around farms undergoing treatment. The active ingredient was not detected in wild shrimp (Nephrops norvegicus) collected in the vicinity of the treated farm. According to a report by the Canadian Department of Fisheries and Ocean (DFO), ivermectin (with a detection limit of 1 to 2 µg/kg) was not found in American lobsters (Homarus americanus) around salmon farms (DFO 1996); however, the same document noted detection of ivermectin in sediments at distances up to 50 m from a farm in the Bay of Fundy where the compound was used. Concentrations varied between 13.7 and 17.3 µg /kg dry sediment at distances <10 m from the farm perimeter. Traces (between 2 and 6 µg /g) of ivermectin were detected at distances up to 100 m from the farm. These results suggest that ivennectin is most likely to be detected in sediments and not in the water column. DFO has set a predicted no- effect sediment concentration (PNEC) of 1.8 µg ivermectin /kg dry sediment. Empirical evidence has demonstrated sediment concentrations exceeding this value to 50 m from the perimeter of one farm, but not beyond. In general, significant sediment concentrations of ivermectin have not been observed at distances beyond 10 -20 m. The half -life of sedimented ivermectin is approximately three months (DFO 1996). Permission to use ivermectin on farms in Scotland has been withdrawn by the Scottish Environmental Protection Agency (SEPA). (ii) Emamectin benzoate SEPA reviewed the proposed use in Scotland of the pharmaceutical emamectin benzoate under the proprietary name RSlice (SEPA 1999a). Emamectin has low water solubility and is expected to accumulate in sediments. However, based on laboratory bioassays SEPA stated that emamectin was about ten times less toxic than ivermectin, at least for the genus Crangon. However, SEPA noted that the PNEC level of 0.763 µg emamectin /kg wet sediment was lower than the PNEC of 1.8 µg ivermectin /kg proposed by DFO (DFO 1996). Field studies failed to detect emamectin in water, and maximum observed sediment concentrations were just above the level of quantification (1.0 µg /kg wet weight). The sediment half -life of emamectin was 175 days. No adverse effects on infaunal communities were observed following treatment with emamectin benzoate. SEPA used the deposition model (DEPOMOD) to suggest that the ratio of the predicted environmental concentration (PEC) to the PNEC was low, and there was little risk that treatment would pose a threat to sediment - dwelling organisms, even in the worst -case scenario tested. Currently RSlice is in use in Chile, Ireland, and Norway, and has been approved in Scotland by SEPA in January 2000 (SEPA 2000) but to -date no permits have been issued. (iii) Calicide Calicide (teflubenzuron) has been licensed by SEPA for the control of sea lice in Scotland (SEPA 2000), and is being licensed in Canada, Chile, Ireland, and Norway. This therapeutic compound is administered as a 2 -g /kg coating on feed. It is a chitinase .. inhibitor effective against juvenile sea lice on salmon at a dose of 10 mg/kg-day-1 for seven consecutive days. It has reduced effectiveness after lice become adults and stop molting. SEPA (1999b) noted that calicide had a long half -life of 115 days in sediments, and could be detected at distances up to 1,000 m downstream from farms being treated. However, no adverse effects were detected in benthic communities (including crustaceans) and SEPA concluded that any residual teflubenzuron was not bio- available. Calicide inhibits the production of chitinase and therefore is not toxic to phyla other than the Crustacea. For teflubenzuron, SEPA (1999b) permitted an allowable sea -water quality standard of 6.0 ng/L for the annual average, and a maximum allowable concentration of 30 ng /L. In Scotland there is an 'allowable effects area' of 100 m from salmon farms. A sediment quality standard of 2.0 µg calicide /kg dry sediment in a 5 -cm deep core has been established outside this area. Sediment concentrations at all distances within 25 m of a treated farm must be maintained at less than 10 mg calicide /kg dry sediment (5 cm core). Calicide is approved only for interrupting the life cycle of sea lice. It is not approved for treating adult lice infestations. Its use is based on computer - modeling of specific sites and it is not approved for general use. Predicted sediment and water column concentrations of the active ingredient must be lower than the water and sediment quality standards described above. (iv) Cypermethrin ®Cypermethrin (dichlorvos) is a pesticide being used in investigative programs, and under some form of temporary registration in Canada, Ireland, Norway, UK, and US. It is administered in a 5 µg/L bath for 60 minutes within a confined and covered area. Dichlorvos is toxic to crustaceans, with a LCso of 0.006 µg/L and a no- observed - effect concentration (NOEL) of 0.003 µg/L for Mysidopsis Bahia. It is adsorbed by sediments where it degrades with a half -life of 35 days in high TVS sediments and 80 days in low TVS environments. It has a 10 -day NOEC of 1000 µg /kg in Arenicola, and 64 µg /kg in amphipods of the genus Corophium. Concentrations greater than about 10 ng /L are acutely toxic to some crustaceans, and modeling suggests that this value can be exceeded in the immediate vicinity of pens being treated with this product. SEPA (1998b) concluded that toxic effects to non - target species could occur within a few hundred meters of a treated farm and that these effects might last for several hours. High mortality of shrimp and lobsters has been observed when they are exposed to a bath of dichlorvos, but the effect has not been observed outside net -pens. Field trials have observed peak water concentrations of 187 ng/L 25 m downstream from salmon net -pens following removal of the tarpaulin covers. Based on an absence of demonstrated deleterious effects on non - target animals, SEPA (1998b) recommended authorization of ®Excis (containing dichlorvos) for a 2 -year period initially. Individual permits are issued by SEPA. Modeling must predict that the 50 proposed treatment will not result in exceeding a 3 -hr environmental quality standard of 16 ng/L in the dispersing plume following removal of the covers. Post - treatment monitoring is required. (v) Azanzethiphos Azamethiphos (or ®Salmosan) is a pesticide administered in a bath at 0.1 mg/L. The active ingredient degrades with a half -life of approximately 11 days at neutral pH. Larval lobsters were the most sensitive organism tested with a 96 hr -LC,o of 0.52 µg/L and a no- observed- effect level (NOEL) of 0.156 µg/L,. A toxicity threshold to lobster larvae was estimated by SEPA (1997) at 0.078 µg/L. Azamethiphos is very water- soluble and is not expected to accumulate in sediments. Compared with dichlorvos, azamethiphos is considered more toxic to crustaceans. SEPA (1997) restricted its use in aquatic environments where modeling predicted that: • 3 h after treatment the mean residual concentrations in the dispersion zone will not exceed 160 ng/L. • 24 h after treatment the mean residual concentrations in the receiving water will nowhere exceed 80 ng/L. • 3 days after treatment the residual concentrations in the receiving water will nowhere exceed 5 ng/L. Post - application monitoring was required by SEPA to ensure compliance. The control of sea lice is important to the health of farmed salmon and to reduce the potential for salmon farms to act as vectors for the infestation of wild stocks of salmon and sea trout. A review of the available treatments suggests that great care must be exercised in the use of these therapeutic compounds. They are all non - specific, at least within the Class Crustacea, and several are broad - spectrum biocides with potential to affect many phyla adversely. However, field studies have not found significant widespread adverse effects to either pelagic or benthic resources associated with the authorized use of these pharmaceuticals or pesticides. 4.5 Farm Sediments 4.5.1 Monitoring environmental effects on sediments Infaunal community analysis, as demonstrated by Pearson and Rosenberg (1978), Mahnken (1993), and Brooks (2000a), is ultimately the most direct and sensitive methodology for assessing the biological response to organic loading from salmon farming. However, benthic communities are not stable, as shown by Mills (1969) and Eagle (1975), and their structure is influenced by many natural processes unrelated to human influence. These processes include seasonal factors (Crisp 1964, Arntz and Rumohr 1982, and Brooks 2000a) and physicochemical factors (Striplin Environmental Associates 1996). Skalski and McKenzie (1982) pointed out that this variability typically requires large numbers of samples to achieve reasonable test powers. The international Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) noted that the taxonomy required in support of infaunal analysis was expensive and time consuming (GESAMP 1996). This cost, when 51 coupled with high internal variability, detracted from infaunal analysis as a routine method for evaluating environmental effects as part of regulatory programs. Therefore physicochemical endpoints, including TVS, TOC, redox potential (Eh) and total sediment sulfides (S -) were being used increasingly as rapid and inexpensive surrogates for assessing biological response. GESAMP (1996) concluded that the visually determined depth of the reduction- oxidation discontinuity was of low value because it was semi - quantitative. They did not consider emerging physicochemical endpoints, such as sulfide analysis using ion specific probes (Wildish, et al. 1999), or TVS (Hargrave et al. 1995, Brooks 2000e and 2000f). Brooks (2000c and 2000e) discussed the relative merits of TVS, TOC, S -, and Eh for evaluating the environmental response to salmon farms. He noted that organic carbon, whether measured as TOC or TVS, had only a moderate correlation with biological effects, particularly infauna. He hypothesized that sediment carbon comes in many forms including woody debris, which is refractory to microbial catabolism resulting in low BOD. Drift macroalgae and eelgrass form an intermediate class of sediment carbon broken down within a few months to one year. Fish feces on the other hand was very labile and created high BOD, more frequently leading to anaerobic conditions than woody debris or macroalgae. Therefore 15% TVS may not exceed the assimilative capacity of the sediment if it was in the form of woody debris, whereas 15% TVS associated with salmon farm waste in the same sediment would be more likely to create anaerobic conditions with significant biological effects. It was recognized that when finely divided woody debris exceeded the assimilative capacity the effect could last for centuries as the wood deteriorated very slowly. Salmon farm waste, on the other hand, because it was catabolized very quickly had rather ephemeral effects lasting from months to two or three years in extreme cases. Redox potential (Eh) was identified by GESAMP (1996) and Wildish et al. (1999) as a valuable endpoint for evaluating sediment chemistry near salmon farms because it is rapid, low cost, and permits extensive spatial surveys. Brooks (2000f) found low sediment redox (20.68 + 22.29 mV) and low sulfide concentrations (29.83 + 11.59 µmoles) in the same samples from reference stations located in areas with greater than 80 -90% silts and clays comprising the sediment grain size distribution. He noted low Eh and high sulfide concentrations in sediments were not always well correlated, and that low Eh could be the result of physical processes, especially in fine- grained sediments. This limited its usefulness in evaluating the effects of carbon input from salmon farms. Wang and Chapman (1999) described the response of laboratory bioassay test animals to sediment sulfides. However, despite attempts by Brown et al. (1987), Henderson and Ross (1995), and Hargrave et al. (1997), the literature does not provide a good quantitative description of the response of natural infaunal communities to sediment sulfide concentrations or redox potential. In summary, benthic infaunal and epifaunal analysis appears to be the most sensitive indicator of environmental health in sediments around salmon farms. However, benthic communities are not stable across environments and depend on the physical environment, 52 including water depths, current speeds, sediment grain size distribution, and the availability of organic carbon (Striplin Environmental Associates 1996). In addition benthic communities vary by season, as influenced by food input and water temperature, etc. (Arntz and Rumohr 1982). 4.5.2 Biological changes in the water column and sediments The environmental changes associated with salmon farms are superimposed on natural changes. These potential effects have been examined in numerous studies during the last two decades. Despite significant site - specific variability there is a consistent thread binding this literature. (i) Water column changes Possible changes in the water column associated with the intensive culture of fish could be associated with intoxication due to hydrogen sulfide and ammonia production in underlying sediments, decreases in dissolved oxygen associated with salmon respiration and /or the oxidation of sedimented waste, and eutrophication associated with nitrogen released across gill epithelia and in urine and feces. The magnitude and consequences of environmental changes associated with these factors is dependent on environmental parameters such as water depth, current speeds, background nutrient availability, salinity, rainfall, wind, etc., which in aggregate constitute the local environment. (ii) Nitrogen and phosphorous loading to the water cohimn Marine environments along the west coast of North America are especially productive because cold, upwelling, nutrient rich water replaces surface waters driven offshore by prevailing northwesterly winds. In addition, the relatively high geographic latitude of BC and Washington results in reduced light penetration in water compared with more southerly latitudes. Lastly, moisture laden onshore winds create significant cloud cover throughout much of the year. These factors combine to limit light availability significantly in most temperate marine environments, except during summer months. Furthermore, it should be noted that in most marine environments, nitrogen is the limiting nutrient and not phosphorus. The remainder of this review will focus on nitrogen inputs. In the Pacific Northwest, wind -driven vertical- mixing drives a significant proportion of the phytoplankton crop below the compensation depth where cell respiration equals photosynthesis and where they no longer multiply. Where water freely circulates, flood tides replenish nutrients from water upwelling offshore. When coupled with the atmospheric and geographical factors that reduce light availability, the result is that primary productivity in the Pacific Northwest is generally light limited, not nutrient limited. This is especially true during winter months. In other words, there is insufficient light to use the nutrients already available in the water column. Adding more nutrients in a light limited system does not increase plant growth. There are sheltered, poorly flushed, shallow embayments where salinity and temperature induced stratification results in a stable water column that allows phytoplankton to remain above the compensation depth. When these conditions occur in the spring or summer, significant blooms can occur following several days or weeks of clear sunny 53 weather. These blooms eventually wane because winds increase vertical mixing; cloud cover reduces the available light; or nutrients are depleted in the surface water. In this last situation, nutrient input from a salmon farm could further stimulate plant growth, exacerbating the problem. In addition, shallow bays having significant freshwater input and minimal flushing, are not considered good sites for net -pen grow -out operations. However, they might be deemed appropriate as smolt introduction sites. The last point to consider in this general discussion is that nitrogenous compounds are released from fish farms into currents that generally average greater than 4 to 12 cm-sec-1 and acoustic Doppler current meter studies at British Columbia salmon farms have revealed net transport speeds of 1.0 to 5.0 cm-sec-1. At temperatures of 10 -15 °C, it takes one to two days for an algal cell to divide, even if all of its photosynthetic needs are met (Brooks 2000g). An algal bloom may result in cell densities increasing from a few thousand cells per ml to perhaps a million. That requires eight or nine cell generations, which requires a minimum of 8 -16 days. In open bodies of water, moving with a net speed of even 2 cm-sec-1, a phytoplankton population would move 14 km from the location at which nutrients were added during creation of a bloom. Recall that the barely significant increases in nitrogen observed 6 in downstream from farms in Puget Sound were generally not detectable at 30 m downstream. Therefore it appears reasonable to conclude that, within a single algal cell division (one to two days), the water passing through the farm would have traveled at least 1.7 km. It is difficult to conclude that the nutrient additions from the farm, generally undetectable at 30 in downstream would have any effect at all on primary production even if the water body was nutrient limited. Pease (1977), Rensel (1988 and 1989), and Parametrix Inc., ( Parametrix 1990) documented small increases in dissolved nitrogen within and on the perimeter of salmon farms. However, all of these authors agreed that the quantity of dissolved nitrogen added by even several farms would have no measurable effect on phytoplankton production. Gowen et al. (1988) studied a Scottish loch with very restricted water exchange to the open sea and a large salmon farm. The authors concluded that the farm had no measurable effect on phytoplankton density. Weston (1986) conducted a quantitative assessment of the effects of five hypothetical farms located in a small embayment with poor flushing. His analysis suggested that the nitrogen added by five fauns could not be expected to adversely affect the phytoplankton abundance in the embayment. He did address the issue of nutrient sensitive embayments and recommended that these areas should be identified and carefully managed. Banse et al. (1990), Parsons et al. (1990), Pridmore and Rutherford (1992), Taylor (1993), and Taylor and Horner (1994) all examined phytoplankton production and blooms of noxious phytoplankton in the Pacific Northwest. They concluded that nitrogen levels and phytoplankton production at salmon farms were determined by ambient conditions. Furthermore, they found that salmon farms had little or no effect on ambient levels of either nutrients or phytoplankton density. 54 The literature is consistent with the previous general discussion and strongly supports a thesis that, with the exception of a few shallow, very poorly flushed embayments, the potential for net -pen enhancement of phytoplankton populations is remote, or non- existent. Based on similar arguments and ten years of monitoring dissolved nutrients at salmon farms, Washington State eliminated any requirement for water column monitoring in compliance with NPDES permits issued to all salmon farms in 1996. 4.5.3 Hydrogen sulfide gas production in sediments When the assimilative capacity of the benthos is exceeded, oxygen is depleted and sulfur - reducing bacteria continue to degrade organic carbon. During the process either ammonia or hydrogen sulfide gas may be produced. These gases, particularly the latter, are highly toxic and can significantly compromise infauna. They are not unique to fish farms and other sources of anthropogenic carbon, and are frequently found in natural environments where organic debris (leaves, macroalgae, eel - grass, etc.) accumulates. Hydrogen sulfide is the cause of the 'rotten egg' smell emitted from many pristine estuarine sediments at levels >2 µg/L (EPA 1986). Hargrave et al. (1997) examined a suite of physicochemical parameters under 11 salmon farms and 11 reference stations located >50 in from net -pens in the Western Isles region of the Bay of Fundy on the east coast of Canada. Sediment concentrations of hydrogen sulfide were found to be significantly different (P = 0.00001) under net -pens when compared with reference sediments. Total sulfide concentrations in surface sediments at all cage sites were >180 µM while values at all but one reference location were <200 µM. They noted sulfide concentrations >2000 µM were indicative of high organic loading under some net -pens and were generally associated with negative Eh potentials. Ammonia and hydrogen sulfide are lighter than water and when significant quantities of these gases accumulate in sediments, they can escape and rise to the surface (out - gassing). As the bubbles rise the soluble H2S is dissolved in the water column. Samuelsen et al. (1988) analyzed gas released from sediments underlying poorly flushed salmon farms. They found that 98% of the gas was CH4 and CO2. Less than 1.9% of the gas at the sediment -water interface was sulfide (S -). Furthermore they found that, after rising 3 in in the water column, the S- was reduced to 0.05% of the total gas. The resulting concentration would be 1.54 x 10 -6 g S_ ml x 1.025 g/ml) or 25.5 µg S /L seawater (25 ppb). Water quality standards are based on the undissociated sulfide (H2S) which is ca. 10% of S- at pH = 8.4. Applying this factor predicts an undissociated H2S level of 2.55 in the 0.5 cm diameter column through which the gas bubble passes. This is approximately equal to the 2 µg/L, chronic water quality criteria established by the EPA (1986) for freshwater and marine environments. In reality oxidation, diffusion, and mechanical mixing significantly reduce concentrations further by a factor of 100 or more. Samuelsen et al. (1988) found that the fraction of the less soluble CH4 did not appreciably change during transit of the bubbles through the water column. The low concentration of H2S in the bubbles at the sediment -water interface, and the low water concentrations predicted during ascent, suggests that very large gas emissions would be required before sufficient H2S could be dissolved in the water column to create toxic conditions. 55 4.5.4 Dissolved oxygen Weston (1986) reviewed the effects of salmon culture on ambient dissolved oxygen levels and concluded that farms could decrease these levels by 0.3 ppm. Brooks (1991, 1992, 1993a, 1994a, 1994b, 1995a, and 1995b) observed decreases of as much as 2 ppm in water passing through a large, poorly flushed farin in Puget Sound. Significant reductions in dissolved oxygen (DO) were not observed by Brooks (1994a and 1994b) at farms in well - flushed passages. In no case were DO levels within 6 m of the downstream farm perimeter depressed below 6 ppm, a minimum level for optimum culture of salmonids. Winsby et al. (1996) reported a range of results from the literature. However, his discussion in general suggested that depressed oxygen levels are associated with the water column immediately overlying anaerobic sediments. Cross (1993) concluded that salmon farms in BC have minimal effects on ambient DO levels. Depressed oxygen levels (3 to 6 ppm) are infrequently encountered at salmon farms along the Pacific coast. These depressions result from the upwelling of cold, nutrient rich but oxygen deficient water to the surface. Conditions favoring depressed DO are most frequently encountered in the Pacific Northwest during the summer and fall when northwest trade winds increase oceanic upwelling. Deep fjords, like Hood Canal in Washington State, can also experience depressed concentrations of DO when winds bring anoxic water to the surface from deep stagnant pools. Feeding is suspended and compressors used to increase DO when these naturally occurring masses of water with low DO levels flow into salmon farms. This phenomenon is imposed on the farm, not caused by the farm. However, the frequency of occurrence of these oxygen deficient water masses should be assessed in siting a farm. In addition, it could be considered good management on the part of operators to measure DO in bottom water under their farms in an attempt to predict periods of depressed surface oxygen. In summary, based on the literature it appears that net -pens create only minor depressions in surface water DO concentrations. When sediments under a farm become anaerobic the overlying water to a depth of perhaps a meter may experience some reduction in DO. This is most likely to occur under farms with very poor circulation ( <3 to 5 cm-sec-1 maximum current speeds). 4.5.5 Changes in the local fish community Salmon farms are known to function as fish aggregating devices. The structures attract numerous fish species, which frequently take up residence between the containment and predator nets. There are no published reports as yet which document this community of aquatic animals, and its abundance. Brooks (1994b and 1995b), at a well- flushed net -pen site in Washington identified pile perch (Rhacochilus vacca), shiner perch (Cymatogaster aggregata), herring (Clupea pallasi), lingcod (Ophiodon elongatus), bay pipefish (Syngnathus leptorhynchus) and several species of sole (Pleuronichthys spp.) all in abundance. At another site nearby, located over a sandy bottom, sea cucumbers (Parastichopus californicus) and geoducks (Panopea abrupta) had proliferated. All of these populations are closely associated with the farm (within 30 m). It should be added that one of these facilities is located in shallow water (15 -18 m M LW) and fast currents 56 (115 cm-sec-1). The second facility is located in a moderately well flushed environment with maximum currents of 30 cm-sec-1 and water depths of 22 -30 m MLLW. 4.5.6 Physicochemical changes in the sediment near salmon farms The chemical and biological effects associated with fish farms have been documented and reviewed by Pease (1977), Braaten et al. (1983), Earll et al. (1984), Ervik et al. (1985), Ackefors (1986), Weston (1986), Aure et al. (1988), Rosenthal et al. (1988 and 1995), Weston and Gowen (1988), Hansen et al. (1990), Parametrix (1990), Gowen et al. (1991), Johannessen et al. 1994, Winsby (1996), Mazzola et al. (1999) and Morri sey et al. (2000). It is possible to model rates of organic loading from net -pen operations described by Weston and Gowen (1988), Findlay (1992), Einen et al. (1995), Silvert and Sowles (1996), and Ervik et al. (1997). The fate and transport of those wastes is a far more complex problem. However, the effects of farm wastes on the benthos in a variety of environments have been well documented. Brooks (1992, 1993a, 1994a, 1994b, 1995a, and 1995b) studied sediment chemistry (redox, TOC, nitrogen, and sediment grain size) and benthic infaunal response at two farms which represented two very different environments in Puget Sound, Washington. In terms of negative environmental effects associated with intensive net -pen fish culture, organic loading to the sediments is most significant. Goyette and Brooks (1999) observed statistically significant changes in the composition of the benthic infaunal community in Sooke Basin, BC associated with small natural changes in sediment organic carbon content of <1% change across the 500 -m study area. In general, the literature suggests a lack of appreciation of the sensitivity of the benthos to small additions of organic carbon, particularly labile forms like fish feces. Hargrave et al. (1995) documented sediment total sulfide concentrations under salmon fauns in the Bay of Fundy that were <6,600 µmoles S -. In contrast, Brooks (2000c and 2000f) observed significantly higher sediment sulfide concentrations ( <16,000 µmoles) on the perimeter of salmon farms in Canada BC, and Wildish (1999) reported sediment concentrations up to 36,000 µmoles S- in Bay of Fundy sediments under operating farms. 4.5.7 Biological effects The biological response of infauna to the sediment physicochemical changes occurring as a result of organic loading from salmon farms has been assessed by Hargrave (1994), Henderson and Ross (1995), and Hargrave et al. (1997). The toxicity of sulfide to infauna is documented for a few species (Bagarinao 1993; Wang and Chapman 1999), but despite the efforts of Henderson and Ross (1995), quantitative relationships between infauna and physicochemical endpoints (S -, Eh, TVS) remain elusive. Brooks (2000a) observed a significant enhancement in infauna during the early stages of production and at the end of the fallow period. However, at the peak biomass there was a significant reduction in the number of invertebrates observed at downstream stations located between 20 m and about 70 m from the farm perimeter. Near -field invertebrate numbers were supplemented by allochthonous input from the fouling community on farm nets. In addition, a significant portion of the invertebrate community associated with near -field sediments during periods of high organic fann input were the TOC tolerant species C. capitata and Ophryotrocha cf. vivipara. 57 Species richness, the number of species observed in biological samples, is frequently a more sensitive indicator of environmental stress than abundance. Brooks (2000a) observed significant reductions ( <2.0 standard deviations below the mean) in the number of taxa within 45 m of the farm during peak production. It did not appear that significant effects extended beyond 75 m during this production period. Biological remediation began as soon as harvest was initiated in April of 1997 and was essentially complete within four months of fallow. A slight enhancement in taxa richness was evident five months following the completion of harvest. Polychaete abundance was enhanced as sediment organic carbon built up at the beginning of the production cycle. Abundance declined within 80 m of the farm perimeter during peak biomass when farm waste exceeded the assimilative capacity of the sediments, which became anaerobic. Polychaete abundance began increasing again during the winter of 1996 -1997, approximately six months after harvest began. Polychaetes proliferated with the improving benthic conditions and exceeded reference abundance during the last 6 months of the study. The enhanced area extended from the farm perimeter to a distance of at least 75 m during the October 1997 evaluation. Brooks (2000a) found that crustaceans were adversely affected at near -field stations earlier (and therefore possibly in association with smaller increases in sediment organic carbon) than polychaetes. A steady increase in the number of crustacean taxa was observed as soon as the fish biomass began decreasing during harvest. The salmon farm had little effect on the overall abundance of crustaceans. In part that was because the benthos in the immediate vicinity of the farm was supplemented by allochthonous input from the net -pens, such as the amphipods Metacaprella kennerlyi and .Lassa falcata. Arthropods were supplemented by mobile crustaceans, such as the megalope of Cancer magister which were very abundant in the vicinity of the farm during June 1996. Brooks (2000a) found that mollusks were an abundant and diverse part of the infaunal invertebrate community in reference sediments from the study area. Statistically significant decreases in the numbers of mollusks were not observed in this study. However, the number of molluskan taxa was significantly reduced at all farm stations during the production cycle. An increase in the number of molluskan taxa was evident at the end of the study, but the number of taxa observed within 50 -75 m from the net -pen perimeter had not recovered to reference conditions. Brooks (200 1) has determined the biological response to varying concentrations of sediment TVS, sulfides, and Eh as a function of farm production, overlying currents, and sediment grain size distribution. Preliminary results indicated that reference sulfide concentrations were generally low (10 -100 µmoles) but could be as high as 250 -300 µmoles. Reductions in the number of taxa from >20 species to 12 -14 species, with significantly increased abundance and biomass of infauna, were noted with sulfide concentrations in the range of 300 -2,000 µmoles. Sediments containing >2000 micromoles S- had a reduced infaunal community dominated by C. capitata, and those containing greater than 6,000 µmoles were generally sparse. His findings were consistent with the reports of Wildish (1999), Poole et al. (1978), and Pearson and Rosenberg (1978), which are tabulated below. Endpoint Classification Reference Microbial Nonnal Oxic Hy oxic Anoxic Poole et al. 1978 Macrofaunal Normal Transitory Polluted Grossly polluted Pearson and Rosenberg 1978 Sulfides <300 300 -1300 1300 -6000 >6000 Wildish et al. 1999 4.5.8. Case histories describing benthic responses to salmon farming. Brooks (1991a, 1992, 1993a, 1994a, and 1995a) evaluated a salmon farm located in a poorly circulated bay with maximum current speeds of less than 8 to 10 cm -sec. This farm is situated in deep water (30 -33 m MLLW) over fine- grained substrates containing 820 -50% silt and clay mixed with sand. The farm has produced as much as 863 mt of Atlantic salmon in one year. TOC remained constant near the baseline mean of 1.067% at all stations until 1990 when production increased. By 1990, TOC at the periphery of the farm increased to 2.48% and remained within a range of 1.85 to 2.95 from 1990 until 1995 while significant quantities of salmon were being produced. This level of TOC in sediments containing less than 50% fines (silt and clay) resulted in a significant change in the benthic community. Reductions in the infaunal community were generally restricted to distances less than 22 m, and in 1992 and 1993 a normal benthic community was observed at distances as close as 6 m from the farm perimeter. The biomass of salmon on site during the period immediately preceding the survey was significantly greater in 1995 (453,229 kg) than in previous years (134,577 kg in 1994). The effects of this were seen in the increased TOC at all far -field stations. Sediment organic carbon was very sensitive to farm operations and highly correlated with management practices. The number of infaunal species was determined at the same stations used to measure TOC. The results indicated a reasonably homogeneous benthic community over the 60 m sampling transect during the baseline survey. Infaunal diversity decreased at stations less than 6 m from the perimeter of the farm very shortly after operations began in 1989. Species diversity was variable at stations >15 m from the perimeter of the farm following start -up. In general infaunal diversity exceeded baseline values at stations >30 m in all years except 1989, which was probably due to a 1,250 m3 oil spill in the harbor several months prior to the survey. In years following that accident, infaunal diversity at all stations greater than 15 m from the farm perimeter were elevated above the 1987 baseline value. However, the 15 m station suffered a significant decline in species during 1995 when production peaked. Total invertebrate abundance was more sensitive than diversity to organic carbon input. Except for the year of the oil spill, and 1995 when production peaked, infaunal abundance was generally equal to or greater than baseline values at all stations greater than or equal to 30 m from the perimeter of the farm. There was a consistent amplification of abundance at the 60 m station in all years. Benthic impacts were restricted to 15 m and less, except when production peaked. This reinforces the diversity 59 data and demonstrates that both abundance and diversity were sensitive to organic carbon input. Over the history of this farm the distance at which adverse effects on benthic community were observed varied between 6 m and 30 m downstream from the farm perimeter. These effects were dependent on the biomass of fish being raised and the resulting sediment concentrations of organic carbon. Sediment organic carbon was reduced to less than baseline values between 30 -60 m downstream where there was a significant increase in the number of species (average of 106 species per station) and their abundance (9,367 animals per station, which was over twice the baseline average of 4,552). No cause and effect relationship between this amplification and the reduced TOC at stations 30 m and 60 m was investigated. Brooks hypothesized that the increased infaunal biomass was consuming the missing TOC. In contrast, Brooks (1994b and 1995b) documented sediment chemistry and infauna downstream from a salmon farm located in a well - flushed passage with maximum current speeds in excess of 125 cm-sec-1. The water was shallow (15 -18 m MLLW) and the bottom consists of large gravel, cobble and rock mixed with small amounts of sand, silt, clay and broken shell. The site was used for final grow -out as part of a complex, which produced approximately 3,000 mt of Atlantic salmon per year. Monitoring results demonstrated the positive environmental effects associated with this farm, which had been operating continuously for more than 10 years in the same location. A total of 3,953 infaunal organisms distributed in 116 species were observed at the 60 m control station in 1994. The abundance and diversity of benthic infauna was enhanced at all stations closer to the farm with a maximum of 7,350 animals distributed in 173 species observed at the 30 m station. On the periphery of the farm 4,207 animals were observed, distributed in 142 species. Annelids dominated the infaunal community and the annelids C. capitata (16 %) and Prionospio steenstrupi (17 %) were abundant in the immediate vicinity of the farm. However, arthropods and surprisingly mollusks (Mysella tumida andMacoma spp.) were well represented in these samples. The abundance and diversity of infaunal organisms was positively correlated with sediment TOC, suggesting that organic carbon was limiting the infaunal community throughout the area. Significant numbers of fish, shrimp and other megafauna were observed during each annual survey at this site, which appeared to function as an artificial reef. Three salmon farms located in close proximity all shared the same characteristics. They appeared to attract megafaunal predators and to enhance the infaunal and epifaunal communities. 4.6. Recovery and Remediation of Sediments Chemical and biological recovery of sediments under salmon farms has been documented by, inter alia, Ritz et al. (1989), Anderson (1992), Mahnken (1993), Brooks (1993b), Brooks (2000a), Lu and Wu (1998), Karakassis et al. (1999) and Crema et al. (2000). 4.6.1 Chemical remediation Brooks (2000a) defined chemical remediation as the reduction of accumulated organic carbon with a concomitant decrease in hydrogen sulfide and an increase in sediment oxygen concentrations under and adjacent to salmon farms to a level at which aerobic organisms can recruit into the area. At the farm being studied sediment concentrations of o volatile solids declined rapidly as soon as harvest was started in June of 1996 and they were close to control values when the harvest was completed in April of 1997. By the end of the 10 -month harvest, significant differences ((x = 0.05) in TVS were not observed between the mean for all reference area data and farm stations located at 5, 10, and 15 in from the net -pen perimeter. Chemical remediation resulted in increased levels of oxygen in sediment pore water and decreased levels of H2S and /or ammonia. H2S was evaluated organoleptically. High levels of sediment H2S were evident to 20 in during peak production. Moderate levels of H2S were observed as far as 37 m on the downstream transect. H2S was detectable at low levels to distances less than 50 in from the net -pen perimeter at the peak of production. It was moderately well correlated with other physicochemical parameters (r = 0.68 to 0.69). 4.6.2 Biological remediation Biological remediation was defined by Brooks (2000a) as the restructuring of the infaunal community to include those taxa representing at least 1% of the total invertebrate abundance observed at a local reference station. Recruitment of rare species (those representing <1% of the reference area abundance) into the remediation area is not considered necessary for biological remediation to be considered complete. Brooks (2000a) observed the beginning of biological remediation during the harvest period. Biological remediation appeared to be nearly complete 5 months following harvest. Several infaunal series are apparent in his data. These were initially identified using principal components analysis. The results are presented in Figure 1. Farm inputs (fish biomass and 30 -day feeding rate) associated in Group I were positively correlated with several sediment physicochemical variables including percent fines, total volatile solids and the presence of hydrogen sulfide. There was also a significant and positive correlation between the opportunistic polychaetes C. capitata and O. vivipara, and farm inputs. Species identified in Group 11 were not strongly negatively correlated with farm inputs. However these species all shared at least one of two characteristics. Larval shrimp (LSxRAT), and crab megalope larvae (BRACAMEG) are mobile organisms which live on top of the sediments, enabling them to avoid the anaerobic conditions associated with high organic loading. The amphipods, .Lassa falcata (JASFAL) and Metacaprella kennerlyi (METKEN), and barnacles in the Class Cirripedia (CIRRI), were found in great abundance on the farm structure. Their presence on anaerobic sediments containing high amounts of volatile solids probably represented an ephemeral benthic community derived from the net -pen structure. 61 0.8 0.6 0.4 0.2 N 0 0.0 U CU LL -0.2 -0.4 -0.6 Factor Loadings, Factor 1 vs. Factor 2 Rotation: Varimax normalized Extraction: Principal components -0.8 L -0.4 -0.2 0.0 0.2 0.4 Factor 1 0.6 0.8 1.0 Figure 1. Output from a Varimax normalized principal components analysis of the dominant infauna, farm inputs, and sediment physicochemical parameters. (From Brooks 2000a). Key for Group II organisms LSHRIW - Larval shrimp BRACHMEG - crab megalope larvae JASFAL - the amphipod .Jassa falcata METKEN - the amphipod Metacaprella kennerlyi CIRRI — barnacles in the Class Cirripedia 62 ARSE. Group IV DI ANCE NUCTEN MYTLM 0 : PIELOU.:_.. NIQ_UMB LESQUASH:ANNON _.. _ PHYRD_r. .. .0. _.. _.. : .0 _.. _._0 0 0 : MARGALFF MIROCUL 0. MALDS' RPD O DIVERS O0.... ITSP LEITPUG COOSUB.O_ _. _... '.. ._. PECTGR HFEF :.0.... ... _.._ Group II LUCANN ETLONR AA JRRSP OD09 0 V17GAS' AMbkj NG _... _.. __.. IRRI 0 .... _._ _. _. Ci,70_. _ ... .... _... MAN ,... 0. NDROWh L�YLSF 0 NEvA DATE 000 0 SFAL PHYLMAC :0 D_ 0 EU ISP oL SF 0 .... _.. .. _..: _.. _.. .... CHIMES _._ .... _._ .... _... L. _... _. _. PHYLCIT L MEDS°. _.PHLSP .. _... _... o0 0 LSHRIMP : 0 �P FINES Group I TVS Group III 0 HzSOPHVIV CAPCAPO 0 0 1000 FEED 100. -0.8 L -0.4 -0.2 0.0 0.2 0.4 Factor 1 0.6 0.8 1.0 Figure 1. Output from a Varimax normalized principal components analysis of the dominant infauna, farm inputs, and sediment physicochemical parameters. (From Brooks 2000a). Key for Group II organisms LSHRIW - Larval shrimp BRACHMEG - crab megalope larvae JASFAL - the amphipod .Jassa falcata METKEN - the amphipod Metacaprella kennerlyi CIRRI — barnacles in the Class Cirripedia 62 Group III organisms were early colonizers following chemical remediation. Organisms in this group demonstrated a range of tolerance to sedimented organic carbon. Chemical remediation occurred very quickly at this site and the order of recruitment into the area was more likely a function of when the various taxa spawned than of sediment TVS concentrations. Finally, the organisms in Group IV were strongly negatively correlated with farm inputs. These organisms were least tolerant of sedimented carbon, or recruited late in the year. It is also worthy of note that Shannon's diversity index, Margalef s index, and infauna- diversity were more negatively correlated with farm inputs than any of the individual taxa. These data suggested at least three invertebrate series, as follows: Concentrations of organic carbon High Medium Low Ca itella ca itata Nematoda Le idonotus s uamatus O hr otrocha vivi ara Mediomastus s . Coo erella subdia Nana Eteone lon a S llis elon ata Lumbrineris sp. Notocirrus californiensis Other measures of biological integrity (Shannon's diversity index and Margalef s index) were also evaluated. Striplin Environmental Associates (1996) found that Shannon's index varied between 1.09 and 1.53 at Puget Sound reference stations where the percent fines (silt and clay) was less than 20% and water depths were <45 m. Brooks (2000a) found relatively high values of Shannon's index (2.6 + 0.4) at the reference station. These values suggest that the undisturbed infaunal community was diverse and evenly distributed. Low values of Shannon's index suggest a community dominated by a few species. This condition was evident to 50 in and possibly as far as 100 in from the perimeter of the net -pens on the down current transect during the peak of the production period. Shannon's index increased steadily following the initiation of harvest and an enhancement of the invertebrate community was suggested by this index at the end of the 5 -month fallow period. Anderson (1992) aggregated the taxa identified in three replicate Ponar grab (0.05 m2) samples at each station at fallow fauns in Canada BC, and found H' values varying from 0.108 to 1.465. The lowest values were found at stations with high TOC loading dominated by C. capitata, Nephtys cornuta, and the gastropod Mitrella gouldi. The higher values were generally associated with undisturbed reference stations. He used principal components analysis (PCA) to observe that factors fallow time, biomass, percent fines, total taxa richness and Shannon's index (H') were positively correlated with each other and negatively correlated with TVS, coarse sand, gravel, and sulfide. He concluded that high values of TVS and sulfide were indicative of unhealthy ecological conditions. Anderson (1992) observed recovery times that varied between several months at sites with low initial impact to an estimate of two years for severely impacted sites during which physical, chemical and microbial processes acted on sediments to make them hospitable to macrofaunal colonization. This refractory period was referred to as chemical remediation by Brooks (2000a). Once macrofaunal colonization began Anderson (1992) observed an increased rate of recovery. 63 In Washington State Brooks (1993b) found recovering sediments dominated by N. cornuta, Glycera, and Lumbrineris, with few C. capitata in the vicinity of a fallow salmon farm in Port Townsend Bay, Washington. He hypothesized that, following cessation of production in October 1992, an initial period of chemical remediation was followed by a proliferation of opportunistic C. capitata. As the organic load was dispersed and catabolized by microbes, and the oxidation - reduction potential increased, predatory polychaetes in the genera Nephtys, Glycera, and Lumbrineris flourished by preying on the large standing crop of smaller prey species. Mahnken (1993) studied the succession of invertebrates at a depositional environment in Clam Bay, Puget Sound, for two years during a fallow period at a salmon farm and observed two distinct 'stanzas' of biological recovery. The first was a three month period of rapid recovery in abundance and species diversity followed by a 3 -25 -month period when community recovery proceeded more slowly. Species which were numerically dominant in samples from the reference station showed rapid colonization. Rare species were slow to recruit to the area. He identified four successional series including: • A pre- successional series comprised of species tolerant of sediments having high TOC. • A pioneering group of early colonizers containing several species of organic- tolerant opportunists. • An intermediate group of colonizers associated with reduced numbers of deposit feeding opportunists. • A group of late colonizers consisting of a group of more conservative and persistent species. A fifth group of rare species identified at the reference station were still absent from the farm sediments at the end of the 20.5 month study. Mahnken (1993) observed that succession was most clearly defined in the Order Polychaeta. At the Clam Bay site biological recovery was initiated by C. capitata and followed in successive series characterized in turn by Armandia brevis, Phyllodoce maculata, Pectinaria granulata, Platynereis bicanaliculata, and finally by more generalist species like Leitoscoloplos pugettensis. He concluded that the sequence was best described as a response to changing organic content in the sediments, resulting from biogenic reworking by changing guilds of benthic organisms. Brooks (2000a) conducted an exhaustive study of a salmon farm in BC during production and fallow periods over a period of two years. This was the first study documenting the relationship between salmon farm biomass, fish feed inputs, and the physicochemical and biological response of the benthos. The study design focused on quarterly samples collected on the downstream transect from the net -pen perimeter to a distance of 75 m, and at a local reference station located approximately 1,200 in from the faun. A maximum Atlantic salmon biomass of 1,199 mt was raised at the farm under study. His data clearly depicted the accumulation of volatile organic material under the farm and out to distances of ca. 40 in from the net -pen perimeter during the peak of production. The physicochemical data (TVS, TOC, hydrogen sulfide, zinc, and depth of the reduction - oxidation potential (RPD) discontinuity) were well correlated and internally consistent. .� Organic carbon accumulations (TOC or TVS) were sensitive indicators of biological effects. The regression approach taken in the experimental design allowed for the three - dimensional mapping of these parameters describing the spatial (as a function of distance from the net -pen perimeter on the downstream transect) and temporal (as a function of both season and production cycle) trends in the data. In all of these cases chemical and biological recovery of the benthos occurred within weeks or months at some sites, and within two to three years at others. These benthic recoveries have occurred naturally with no need for intervention or mitigation. 4.6.3 The assimilative capacity of the local environment Brooks (2000a) provided a methodology for estimating the assimilative capacity of sediments adjacent to salmon farms. The upper 90th percentile TVS observed at the local reference station was 3.4 %. In Figure 2 this value is represented by the boundary between dark green and light blue. Based on the assumption that the 90th percentile TVS observed at the reference station represents the sediment assimilative capacity (SAC), this analysis suggested that a maximum salmon biomass of ca. 170 mt could be raised at this site without exceeding the SAC on the perimeter of the farm. That is 14% of the actual farm production. A similar methodology could be applied to other physicochemical benchmarks including sediment sulfides or Eh. 4.7 Managing the Environmental Effects Associated with Salmon Farms 4.7.1 Monitoring experiences From 1987 until 1996 the Washington State DNR required monitoring of sediment chemistry (carbon, nitrogen, redox and sediment grain size), water chemistry (dissolved oxygen, pH, nitrate, nitrite, total ammonia and unionized ammonia), and the benthic community (quantitative infaunal surveys and qualitative scuba surveys) as a condition in ALLs for salmon farms. That monitoring experience provided an extensive database upon which to evaluate the effectiveness of each measured parameter in predicting environmental effects. Several lessons were learned from those studies, as follows: (a) Sediment grain size and water depth were primary factors determining the structure of an undisturbed infaunal community. (b) Absent any anthropogenic inputs, i.e., in reference areas, the TOC content of undisturbed sediments was significantly correlated with the proportion fines (silt and clay) contained in superficial sediments ( <2 cm depth). Depositional areas associated with slow current speeds and gyres accumulate both fine sediments and particulate organic materials at higher rates than high - energy areas. (c) The redox potential and health of the infaunal community associated with a particular sediment grain size distribution appears well correlated with the level of TOC in the sediments (Striplin Environmental Associates 1996, Goyette and Brooks 1999). This is evident in Figure 3, which depicts the relationship between infaunal abundance, diversity, redox potential, and percent TOC. Note that the significant depressions in infaunal diversity and abundance observed at distances of zero and 6 m from the perimeter of the net -pens was associated with TOC levels averaging 2.8% and an RPD .. P 0) 0 c 0 0 ca E 0 CO 1080000 1020000 960000 900000 840000 780000 720000 660000 600000 540000 480000 420000 360000 300000 240000 180000 120000 60000 0 z =0. 021- 0* x+ 5. 859e- 8* y+ 225e- 6* x *x- 6.028e- 10 *x *y- 1.415e- 14 *y *y Upper 90th percentile TOC at the local reference station Sediment TVS (Proportion dry weight) 0.011 I I - 0.016 - - -------- ,-------- ,-------- -------- -- -- 0.021 0.026 Maximum salmon biomass not exceeding 0.031 the upper 90th percentile TOC observed 0.036 at the local reference station at a distance ® 0.041 of 30 meters from the netpen perimeter. 0.046 Q 0.051 a056 /Approximate salmon biomass not exceeding the sediment's assimilative capacity. 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Distance from netpen perimeter in meters Figure 2. Surface contour plot describing the relationship between salmon biomass (kg), distance from the farm perimeter on the downcurrent transect in meters, and TOC expressed as a proportion of dry sediment weight. Me that was very close to the sediment surface. These sediments smelled strongly of hydrogen sulfide. Beyond 6 m the TOC declined rapidly to 1.8% and the depth of the RPD increased to approximately 1.0 cm. Conditions remained constant to 24 m from the farm perimeter where TOC slowly declined to background levels of ca. 1.25 %. Infaunal samples were not collected at all TOC stations during this study. However, sediments were depauperate from the perimeter of the farm to 6 m downstream. The abundance and diversity of infauna slowly increased between 6 and 30 m downstream but remained depressed to a distance of 30 rn from the net -pen perimeter. A normal community was observed in samples collected 60 m downstream from the perimeter of this farm. 700 L p 500 CU c ° 400 U C CO 300 Q c 200 7 C 100 v Diversity O Abundance 12/95 TOC _ -12/95 RPD -00 ♦ A A -[� 1 1 1 Y l X A 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N M I-* LO (0 1-- M M O - N M q-* LO 0 ti M M O N Distance from farm perimeter (feet) 5.00 E 0 4.00 -Oa Co 3.00 0 CO U U 2.00 a 21 O CO 1.00 b KM IM Figure 3. Relationship between percent total organic carbon, depth of the reduction - oxidation potential discontinuity (cm), Washington State TOC triggers, and abundance and diversity of infaunal organisms at a major salmon farm located in a deep (33 m MLLW) bay where maximum currents speeds were less than 10 cm-sec-1. 67 Based on these monitoring reports, it appears that TOC can be used as a screening tool to evaluate benthic health indirectly. This is not unlike the use of bioassays as a screening tool in evaluating the effects of toxic industrial and municipal effluents in fine - grained sediments. The use of TOC (or TVS) as a screening tool has the advantage of being fast. Analyses can be completed in a few days, whereas infaunal community analysis takes months. In addition, the lower cost of TOC /TVS analysis allows more frequent monitoring. When combined, these factors allow TOC /TVS to be used as a real -time parameter useful to farm managers. Sediment total sulfides and oxidation - reduction potential measured with ion specific probes immediately following sample collection are emerging as more biologically relevant physicochemical endpoints in ongoing studies in BC. The results of these studies will be available in May 2001. (d) Invertebrate community analysis has been a traditional and direct way of evaluating the effects of organic loading (see Pearson and Rosenberg 1978, Lunz and Kendall 1982, Weston 1990, Brooks 1993 and 1993b, Henderson and Ross 1995, Brooks 1994a, 1994b, 1995a, and 1995b). In Washington State invertebrate infaunal community analysis is used as a primary endpoint for evaluating benthic sediment quality (WAC 173 -204 -320). (e) Salmon farms located in well - flushed ( >50 to 100 cm -sec ) environments frequently increase both the abundance and taxa richness of infaunal communities, even at high levels of salmon production (Brooks 1994b and 1995b). (f) Salmon farms located in poorly flushed ( <10 cm -sec ) environments can result in the deposition of significant amounts of carbon to the benthos — even when located in water as deep as 30 in MLLW. Adverse effects are generally restricted to an area within 15 -22 m from the perimeter of farms located in these poorly circulated environments. Increases in both the level of TOC and the distance at which adverse effects are observed are sensitive to farm management practices (Brooks 1994a). However, in these poorly flushed environments the negative effects can be managed so that they remain within 33- 100 in of the farm perimeter, even during intensive production of fish. (g) Indicator invertebrate taxa have been identified at several of the farms studied in the ALL Program of DNR. These indicator taxa and groups of taxa appear temporally consistent but are specific to different environments (Brooks 1995a and 1995b). Other authors (Weston 1990, Tsutsumi et al. 1991, Mahnken 1993, and Henderson and Ross 1995) have identified similar suites of indicator species in response to organic loading. 4.7.2 Management by modeling salmon farm wastes There is significant interest in modeling salmon farm waste as a management tool for regulatory agencies. Some of these models are qualitative (Sowles et al. 1994) and others attempt to quantify the dispersal and accumulation of particulate organic matter in sediments (Fox 1990, Gowen et al. 1994, and Silvert 1994b). It appears that the more basic the model inputs, the more room there is for error. Silvert (1994a) used a simple carbon budget to model salmon farm waste and concluded that 40% of the feed was not consumed by the fish. There is no evidence in the literature substantiating feed loss rates this high. None of these models has been tested to compare predictions with observed carbon deposition rates or sediment physicochemical responses to salmon farm waste. .: Findlay and Watling (1994) modeled sediment organic carbon decay rates and developed nonlinear regression equations relating oxygen delivery (mmoles /m2 -hr) and maximum oxidizable organic matter (grams carbon/m2 -day) to sediments as a function of current speed (cm /sec). They concluded that the maximum carbon flux not exceeding the assimilative capacity of the sediment is highly dependent on the minimum 2 -hour average bottom current speed. Silvert and Sowles (1996) developed several algorithms considered useful in modeling the environmental response to salmon farming. They concluded that models exist which can help to assess impacts and make reasonable management decisions, but this is not substantiated in the existing literature. These models provide some insight into the environmental response to salmon farm waste. However, they are not adequate for making reasonable quantitative predictions regarding the degree or spatial extent of salmon farm waste. 4.7.3 Risk management through NPDES permit standards In 1996 Washington State developed sediment management standards for marine net - pens (WAC 173 -204). The Washington State rule is based on the following assumptions: (a) Salmon farming provides significant benefit to the State and its people. (b) The negative benthic effects associated with net -pen operations in poorly flushed environments will remediate naturally following cessation of operation or initiation of a fallow period. (c) The spatial extent of these effects can be managed. The sediment rule for net - pens authorizes a sediment impact zone (SIZ) extending 33 in from the perimeter of the farm structure. This distance was chosen because it corresponds to the SIZ provided for other industrial discharges. From a biological point of view, it would seem more appropriate to develop site specific SIZs which reflect the biological productivity of the site's benthos and the presence of adjacent valuable resources. In that context, SIZ widths could extend considerably further from the perimeter of a farm, perhaps to a distance of 100 m or more. (d) TOC can be used as a screening tool in evaluating the health of the benthos. TOC 'triggers' have been defined as a function of the proportion of silt and clay in the sediment matrix. TOC triggers used to screen sediments for adverse biological effects at salmon farms in Washington State are tabulated below. If sediments located 33 m from the perimeter of the net -pen structures at salmon farms exceed these trigger values, then an evaluation of the health of the infaunal community is required. Proportion ( %) silt -clay in the sediments TOC trigger ( %) 0-20 0.5 20-50 1.7 50-80 3.2 80-100 2.6 69 (e) Biennial monitoring of sediment TOC is required at seven stations at each permitted farm. Four of these stations are located at a distance of 30 m from the perimeter on each side of the farm. Three replicate sediment samples are collected at each station. No further monitoring is required if sediment TOC is not statistically elevated (t -test) above the TOC trigger corresponding to the observed percent fines at each 30 m station. If the measured TOC is significantly higher than the corresponding trigger, then repeat sampling is required in the summer of the next year together with the collection of five benthic infaunal samples at each station failing the TOC trigger, and at a suitable control. Benthic infaunal analysis is required for any station at which elevated TOC is observed during the second round of sampling. (f) Each farm is required to manage its production such that there are no significant negative effects on benthic resources beyond the boundary of this 33 -m SIZ. WAC 173 -204 states that biological resources in sediments are considered adversely impacted if the mean numbers of crustaceans, mollusks or polychaetes in the test sediment at the boundary of the SIZ are reduced to significantly less than 50% of the number of animals belonging to the same taxa living in an undisturbed reference sediment. Evaluation is based on a one tailed t -test at a = 0.05 for five replicate 0.1 m2 samples. It should be pointed out that populations of benthic organisms are frequently found in patchy distributions with many animals of the same species confined in groups separated from each other. Infauna are seldom found regularly distributed in sediments. For that reason, if three samples were collected from the same general area, the individual samples would likely contain very different numbers of any one of these taxa. The reason that the rule relies on a 50% reduction in the number of any taxa is not that it is acceptable to kill 50% of the crustaceans, mollusks, or polychaetes outside the boundary of the sediment impact zone, but to acknowledge that the collection of a reasonable number of random samples may produce two means which vary by as much as 50 %, even though the sediments are not impacted at all, or share the same level of impact. (g) Benthic conditions at each of the four orthogonal 30 m SIZ stations must be photographically documented every two years and whenever sediment samples cannot be collected and analyzed in conformance with the requirements stipulated in the Puget Sound estuary protocols (PSEP 1986). (h) Well- managed salmon farms recognize the benefits of vaccination and BMPs in controlling disease. While not examined in this review, records of antibiotic use in Washington indicated a sharp decline at permitted farms between 1992 and 1996. Similarly, Kontali (1996) reported that the use of vaccines in Norway had resulted in reductions in the use of antibiotics from a high of 592 mg /kg salmon produced in 1987 to 5, 9 and 3 mg /kg in 1994, 1995, and 1996, respectively. Based on the current low use, Washington regulations (WAC 173 - 204 -412) do not require routine monitoring for bacterial resistance at marine net -pet sites. All farms are required to maintain an operational log that specifies the date and nature of application of all disease control chemicals used. In addition, farms are required annually to report the amount of each therapeutic used on each farm. Based on the absence of adverse effects observed during 10 years of monitoring the water column adjacent to salmon farms in Washington State, the WDOE eliminated all 70 requirements for nutrient and dissolved oxygen monitoring in the water column from the NPDES permits. This approach by the State of Washington regulatory agencies is appealing for several reasons: • It recognizes the value of net -pen culture while requiring that any negative impacts be restricted to the immediate vicinity of the farm • It invokes a realistically achievable performance standard that can (must) be met through proper management practices • It is a relatively inexpensive approach as long as TOC levels at the boundary of the SIZ remain below trigger levels. This provides a real incentive to maintain carbon levels below specified triggers • The immediate endpoint (TOC) can be measured quickly and is useful as a real time management tool • The performance standard encourages future siting in environments that either have fine grained sediments that support high TOC levels, or in high current areas where TOC will not accumulate On the other hand there have been some problems in implementing the State's NPDES permit system. For example, sediment samples collected from coarse bottoms cannot be analyzed for TOC because the matrix must be ground to a fine consistency. Sediments from erosion environments are generally composed of coarse gravel and cobble. Opponents of aquaculture have argued that the WDOE biological performance standard defined in WAC 173 - 204 -320 (3)(c) is inappropriate because it allows for up to a 50% reduction in the abundance of arthropods, mollusks, or annelids, and because it does not include some measure of species richness (PCHB Nos. 96 -257 through 96 -268). This criterion applies to all discharges in the State of Washington and not just to salmon farms. Application of the criterion requires analysis of these major taxa in five 0.1 m2 infaunal samples. A one - tailed t -test is then applied with a = 0.05. Alpha is the probability of finding an effect when it does not exist (the probability of making a Type I error or of rejecting the null hypothesis when it should not be rejected). That means that approximately 1 in 20 tests will indicate a statistically significant difference in the means of the populations when in fact the populations are identical. Brooks (2001, unpubl. data, Aquatic Environmental Sciences, Port Townsend, WA 98368) has tested this hypothesis using a Monte Carlo approach for analyzing benthic data from reference sites at two farms located in Puget Sound. He found that the null hypothesis was in fact rejected in 22% of the analyses on samples collected from the same reference station. Obviously, absent the allowable error of 50% incorporated in the WDOE rule, the criterion would be too conservative. The consequences to the permittee of failing the benthic biological criteria are significant, requiring reductions in the number of fish raised, or the amount of food provided, or actually fallowing the farm for a period. That is a significant penalty when there is a half 71 chance that failure is simply a matter of chance with a = 0.05. There are at least three ways to address this issue: (a) The value of a could be decreased to 1% or 0.5 %. When a = 0.1 %, there is only a one in 100 probability of obtaining a false positive (Type I error). That would require a larger difference between the mean number of animals in any of the taxa observed at the reference site and the SIZ boundary — in other words it would not provide any more protection for the environment, (b) The DOE has defined an allowable error term of 50 %, (c) The number of endpoints at each station could in increased by evaluating both the abundance and the number of species observed in each of the major taxa. This would provide six endpoints (abundance and richness of arthropods, mollusks and annelids) for evaluation. By requiring failure of two of these endpoints before considering the station failed, the probability of a false positive would be decreased to 0.05 x 0.05 = 0.0025. 4.7.4 Risk management practices in British Columbia Following the exhaustive review of the scientific literature by EAO (EAO 1997), the Provincial Government of Canada BC has been developing a performance -based waste management policy (WMP) to insure that adverse benthic effects associated with salmon farming are managed. The following are essential elements likely to emerge. (a) Only single year - classes of fish will be grown at BC salmon farms. The purpose of this restriction, as practiced also in Norway and Chile since the mid- 1990s, is to reduce the potential for disease transfer between year- classes and to provide for a fallow period between production cycles sufficient to insure that sediments chemically remediate to within 30 in of the farm perimeter prior to restocking. (b) Prior to restocking a new year - class, the farm must remain fallow until the level of volatile residue in sediments at a distance of 33 in from the net -pen complex perimeter returns to baseline or local reference station values. The length of fallow is not specified, but farm management must certify to the Ministry of Environment that this condition has been met before restocking fish. (c) At no time will adverse benthic effects be allowed at distances >100 in from the perimeter of the net -pens. This performance standard will be evaluated annually during the months of August through November. This distance is under review and will likely be set by the BC Government during 2001. (d) Based on the problems encountered with the analysis of TOC in Washington State, BC is using TVS as a primary screening tool. TVS (as a percent of dry sediment weight) must not statistically exceed (one- tailed t -test, a = 0.05, N = 3) the upper 90th percentile value observed at a local reference station. Samples are collected for this analysis at a distance of either 30 m (for the pre - stocking certification) or 100 in (for the annual monitoring) from the midpoint on each of the sides of the net -pen's perimeter. These points are referred to as the 'inner' and 'outer' sediment impact zones (ISIZ and OSIZ). If no local reference station is available, then farm samples will be compared against TVS triggers which represent the upper 90th percentile of historical TVS levels observed at reference stations throughout BC. (e) Hargrave et al. (1997) examined the biological and physicochemical attributes at 11 salmon farm and 11 reference stations in the Western Isles region of the Bay of Fundy on the east coast of Canada. They found that organic carbon, sediment sulfides, 72 and redox potential were effective endpoints for evaluating the benthic effects associated with salmon farming. The results of this study have been incorporated in the WMP by requiring quantitative evaluation of sediments for total sulfides (S -) and oxidation - reduction potential (ORP). Protocols developed by Hargrave et al. (1995) were adopted for these analyses. Specific performance standards for sulfides and Eh will be developed pending the outcome of a series of focused studies designed to determine the biological response to varying concentrations of these endpoints. Stations failing the screening tests will probably be evaluated against the biologically - based performance standard which states that, 'Adverse Sediment Biological Effects will be evaluated by comparing abundance and diversity (number of species) in the Class Crustacea, Class Polychaeta and the Phylum Mollusca at farm sample stations de fined in the performance standards with the abundance and diversity of the same taxa found at a local reference station. This test will establish six endpoints for evaluation (abundance and diversity in each of three major taxa). These differences shall be evaluated using a one - tailed Nest with a probability of observing an effect when one does not exist of five percent (a 0.05). Because one in twenty of these tests are expected to produce a false positive (indicates an adverse effect when one does not exist), this performance standard defines adverse biological effects when two or more of the six endpoints are statistically decreased compared to levels observed at a local reference station. This procedure will still result in one false positive in 400 tests. This biological standard will be determined by comparing the three major taxa, observed in five 0.1 m2 grab samples at each farm station with the abundance and diversity of these taxes observed at a local reference station sharing similar depth and sediment grain size characteristics. This may require more than one local reference station per farm. Identification of all taxa in this evaluation will be to the level of species, or the lowest practical level. Ammann et al. (1997) used the results from 28 previous studies to examine the Taxonomic Sufficiency of various levels of biological organization to determine adverse impacts in aquatic environments. They found that for 89% of the experiments evaluated, phyla counts were as sensitive as any of the metrics evaluated. Community metrics (Shannon- Weiner's, Simpson's, and Brillouin's diversity and evenness and richness) were never found to be more sensitive than count data. Amman et al. (1997), and the citations included therein, support British Columbia's choice of major taxa (Phylum Molluska, Class Crustacea and Class Polychaeta) as appropriate metrics in developing their regulatory policy. The identification of organisms to species will allow for future analysis using a variety of additional metrics. Farms with stations failing the Sediment Biological Effects Standard will be required to develop a remediation plan that brings the farm back into compliance.' The BC Provincial Government has stated a desire to establish a final performance based salmon farm management program in the fall of 2001. In addition, the DFO, which has the responsibility to enforce the Fisheries Act is participating at the technical level in developing the BC program. 73 5. ATLANTIC SALMON AND THE LOCAL ECOSYSTEMS The fifth chapter is very specific to the pros and cons of salmon species in the local ecosystem of the Northwest (Puget Sound). It has seven identified subsets. The first subsection reviews the issue of the introduction of Atlantic salmon into the Pacific ecosystem and the potential interactions. Specific sections review possible hybridization between Atlantic and Pacific salmon, the genetic dilution and alteration of the gene pool, the colonization of the aquatic environment by Atlantic salmon, and finally the interactions of wild salmon and genetically altered transgenics. The second subsection concerns epidemics and transmission of waterborne disease, and reviews the potential for cultured Atlantic salmon, an exotic species, to introduce new diseases into the local ecosystem. There are nine specific items, from the diseases which might be involved, to potential interactions, and current policies for disease control. The third subsection concerns the potential ecological impacts in the Pacific Northwest, specifically the interaction with Pacific salmon and predation. The following sections review the effects of artificial propagation practices in the region in general, the impacts of the introduction of non - indigenous species, and a comparison of escapes or releases of propagated Atlantic and Pacific salmon. The last section examines the NMFS Biological Status Reviews of west coast Pacific salmon stocks. 5.1 General Issues of Artificial Propagation of Salmonids Ellis (1996) and Alverson and Ruggerone (1997) comment that the artificial propagation of salmon and trout in the Pacific Northwest had come under increasing scrutiny in recent years. This was due to the recognition that hatchery cultured salmon and trout may have the potential to adversely impact natural populations. Although the weight of attention has been focused on the extremely large complex of federal, state, tribal, and cooperative hatcheries in Alaska and the western States, concerns about the potential adverse impacts of private trout and salmon culture in Washington have also been expressed. Concerns about genetic interactions, the transmission of disease, and ecological interactions are most commonly voiced. The secondary source for this unpublished study is Gross (1997), who stated that Atlantic salmon had the potential for hybridization with Pacific salmon. Quinn (1997) stated that it was possible that the 369,000 Atlantic salmon which escaped into Puget Sound in 1997 would produce 10 million healthy smolts in local rivers. The Alaska Department of Fish and Game (ADF &G) has expressed concern that escaped Atlantic salmon from west coast salmon farms will compete with wild salmon and spread diseases and parasites for which Pacific salmon have little resistance (ADF &G 1999). For example, a letter sent to Alaska Senator Stevens (April 25, 1997), by a constituent, read, in part, 'The continued introduction ofAtlantic salmon to the marine habitat of British Columbia and Washington State will inevitably have negative biological impacts. These will include displacement, hybridization, and the introduction of alien.... disease.' (Gilbertsen 1997). 74 5.2 Genetic Interactions of Artificially - Propagated Pacific and Atlantic Salmon A major concern with artificial propagation in general and farming of Pacific salmonids and Atlantic salmon in particular are the potential genetic effects of inadvertent escapees on the native salmonids. For the salmon farming industry in BC, where both Pacific and Atlantic salmon are extensively farmed, the BCSAR study listed four major areas of concern (EAO 1997): • Hybridization between Atlantic and Pacific salmon • Genetic dilution and alteration of the wild salmonid gene pool • Colonization by Atlantic salmon • Interactions between wild salmon and genetically altered transgenics These concerns are both geographically and species specific. For the Puget Sound, the primary concern is with Atlantic salmon, as Pacific salmon, with rare exception, are not cultured by private enterprises. 5.2.1 Hybridization No genetic interactions between Atlantic and wild Pacific salmon have been reported in the Pacific Northwest. Similarly, under controlled and protected laboratory conditions where survival of hybrid offspring should be optimized, viable hybrids between Atlantic and Pacific salmonid species are difficult to produce. Refstie and Gjedrem (1975), Sutterlin et al. (1977), and Blanc and Chevassus (1979, 1982) found that crosses between Atlantic salmon and rainbow trout failed to produce any viable progeny. A similar lack of vitality was observed in pairings of Atlantic salmon and coho salmon ( Chevassus 1979) and Atlantic salmon and pink salmon (Loginova and Krasnoperova 1982). Gray et al. (1993) attempted to produce diploid and triploid hybrids by crossing Atlantic salmon with chum and coho salmon, and rainbow trout. All embryos died in early developmental stages, leading to the conclusion that hybridization of Atlantic salmon with Pacific salmon species was unlikely to happen. The secondary source of these two unpublished BC studies by Alverson and Ruggerone (1997) have provided more data regarding the relative genetic compatibility between Atlantic and Pacific salmon (R. Devlin, DFO Canada, reported in Alverson and Ruggerone 1997). In the first, using a small number of eggs, Atlantic salmon produced no viable hybrids with coho, chum, chinook, sockeye salmon, and rainbow trout. In the same experiment, each species of Pacific salmon readily produced hybrids with between two and five other Pacific salmon species, and confirmed previous observations in this genus by, inter alia, Foerster (1935), and Seeb et al. (1988). These results were cited as evidence of 'rampant hybridization potential' in hearings before the Washington State PCHB (96- 257 -266, and 97 -110, 1998). However, the Board found the statement not supported by the study, and there was no reasonable potential for hybridization between escaped Atlantic salmon and native Pacific salmon in Puget Sound based on current knowledge and behavior (PCHB 1998). In the second study using a much larger number of eggs, viable hybrids to hatch involving rainbow and steelhead trout, coho, chum, chinook, and pink salmon were produced. Approximately 6.1% of the steelhead x Atlantic salmon, and 0.01% of the 75 pink salmon x Atlantic salmon hybrids survived to the hatching stage. The inter - specific crosses between Oncorhynchus species produced hybrids with survivals to hatch ranging from 10 -90% in 15 of the 42 crosses. Despite these high survivals to hatch among the Pacific salmon hybrids, compared with the fractional survival to hatch observed between an Atlantic salmon x pink salmon cross, no concerns over the introduction of hatchery stocks of Pacific salmonids into natural habitats were addressed to the PCHB. The 'successful' Atlantic x steelhead hybrids were carefully controlled experiments in vitro, and actual Atlantic /steelhead hybridization would probably not happen under natural conditions in Washington State. The Atlantic salmon stocks used in Washington have finished spawning by the end of November (W. Waknitz, NMFS, unpublished data), and wild steelhead in western Washington spawn between mid -March and mid -June (Freymond and Foley 1985). Therefore, there is virtually no opportunity for Atlantic salmon to spawn with local wild, native steelhead outside the laboratory. While viable hybrids between Atlantic salmon and the Pacific salmonid species have been difficult to produce in the laboratory and do not occur under natural conditions, hybrids between Atlantic salmon and a sympatric species, the brown trout are relatively successful. Viable Atlantic salmon x brown trout hybrids have been produced in the laboratory by, inter alia, Suzuki and Fukuda (1971), Refstie and Gjedrem (1975), Blanc and Chevassus (1982), and Gray et al. (1993). Successful hybridization under natural conditions has been reported for Europe where brown trout are native, and also in North America where the brown trout has been introduced (Verspoor and Hammar 1991). The frequency of natural hybridization in Europe and North America ranges from 0.1 to 13.2% of juveniles in river systems (Jordan and Verspoor 1993) and appears to be increasing relative to pre - aquaculture levels (Hindar et al. 1998). McGowan and Davidson (1992) cite the breakdown in pre - reproductive isolating mechanisms (abundance of mature Atlantic parr) as the principal mechanism for natural hybridization. Hindar et al. (1998) reported that although a disproportionate number of hybrids were the product of matings involving Atlantic salmon females, there was no evidence that escaped farmed Atlantic salmon females produced more hybrids than wild females. Youngson et al. (1993), on the other hand, had previously reported that escaped female in western and northern Scotland rivers hybridized with brown trout more frequently. Wilkins et al. (1993) found that male hybrids were fertile and when back - crossed with female Atlantic salmon produced about 1% diploid progeny. Galbreath and Thorgaard (1995) reported that back - crosses between male diploid, male triploid, and female diploid Atlantic salmon x brown trout hybrids and both parental species produced either non - viable or sterile progeny. No natural hybrids between Atlantic salmon and Pacific salmonids have been reported in Europe. This is despite the fact that introduced rainbow /steelhead trout, brook trout, coho salmon, and pink salmon have all established naturalized populations within the native range of Atlantic salmon throughout the European continent (MacCrimmon and Campbell 1969, MacCrimmon 1971, Berg 1977, and Lever 1996). Similarly, no hybrids between Atlantic salmon and brown trout, rainbow trout or brook trout have been 76 reported in South America or New Zealand, even though all four of these species are not native to those locations (MacCrimmon 1971, Lever 1996). The propensity of Atlantic salmon to produce successful hybrids with brown trout and not with the Pacific salmonids may be related to the phylogenetic distances that exist between the two groups. Neave (1958) postulated that the putative ancestors of the Salmo group migrated to the Pacific 600,000 to 1,000,000 years ago, were subsequently isolated by land bridges, and evolved to the ancestral Oncorhynchid form. The ancestral Oncorhynchid form subsequently developed to form the separate Oncorhynchus species (Simon 1963). McKay et al. (1996), based on DNA sequence analysis of growth hormone type -2 and mitochondrial NADH dehydrogenase subunit 3 gene, estimated that, at a minimum, the major divergence between the genus Salmo and the genus Oncorhynchus occurred 18 million years ago, while speciation within the genus Oncorhynchus began about 10 million years ago. Benfey et al. (1989) also noted that the evolutionary differences between the Pacific and Atlantic salmonids were reflected by immunologically detectable forms of vitellogenin. Attesting to their phylogenetic similarity, interspecific hybrids within the Oncorhynchids are relatively successful. Foerster (1935) was among the first to report successful hybrids between controlled mating of sockeye, chum, pink and chinook salmon. Since then, limited occurrences of natural hybrids have been reported among anadromous salmonids. Bartley et al. (1990) reported on natural hybridization between chinook and coho salmon in a northern California river, and Rosenfield (1998) reported a natural pink x chinook hybrid from the St. Mary's River in Michigan. On the other hand, hybridization between introduced rainbow trout and native cutthroat trout appears to be almost ubiquitous throughout the interior part of western North America, and has been enormously detrimental to the latter species according to Gresswell (1988) and Behnke (1992). 5.2.2 Genetic dilution and alteration of the wild salmonid gene pool Adverse genetic and ecological effects due to releases or escapes of artificially - propagated Atlantic salmon from public hatcheries and private net -pens on wild Atlantic salmon populations in Norway, Scotland, Ireland, and the Canadian Maritimes have been reported. For wild Atlantic salmon these include a reduction in their genetic adaptability and capacity to evolve as a result of interbreeding with artificially - propagated fish, and direct competition for food and space (Einum and Fleming 1997, Gross 1998). Such adverse effects only happened in those locations because both the cultured and wild fish were Atlantic salmon. Escaped Atlantic salmon on the west coast of North America do not have congeneric wild individuals with which to interact. In the Pacific Northwest region, the release of hatchery Pacific salmon has the greater potential to produce impacts on native Pacific salmon which are analogous to those found between cultured and wild Atlantic salmon in Europe and eastern North America. Adverse genetic and /or ecological interactions on local wild salmon populations from artificially- propagated Pacific salmon have been well documented by Weitkamp et al. (1995), Busby et al. (1996), Hard et al. (1996), EAO (1997), Gustafson et al. (1997), 77 Johnson et al. (1997), Myers et al. (1998), and Johnson et al. (1999). No detrimental effects related to Atlantic salmon have been reported in western North America. Compared with the evidence in the literature of genetic alterations of Pacific salmonid populations as a consequence of salmonid enhancement and supplementation programs in the Pacific Northwest, there is little or no evidence in the literature of adverse impacts associated with escaped Atlantic salmon in the region. 5.2.3 Colonization by Atlantic salmon In the past century there have been numerous attempts in the US and elsewhere to establish Atlantic salmon outside their native range. These attempts involve at least 34 different States, including Washington, Oregon, and California. None of these efforts was successful. MacCrimmon and Gots (1979) subsequently reported that no reproduction by Atlantic salmon was observed in the waters of these States, and twenty years later this was reconfirmed by Dill and Cordone (1997) and Alverson and Ruggerone (1997). It also appears difficult to reintroduce Atlantic salmon to their native rivers. In the last 100 years, Atlantic salmon populations in New England have declined precipitously, despite the large -scale introduction of locally derived hatchery fish (Moring et al. 1995). The Penobscot strain of Atlantic salmon (which is used in net -pen farms in Puget Sound) is now under consideration for listing under the US Endangered Species Act 1974 (USDODUSDOC 1995). Between 1905 and 1934 the government of BC released 7.5 million juvenile Atlantic salmon into local waters, primarily on the east coast of Vancouver Island and the lower Fraser River in Canada (MacCrimmon and Gotts 1979; Alverson and Ruggerone 1997). These releases were not successful in establishing Atlantic salmon populations in the Province, although some natural reproduction may have occurred according to Carl et al. (1959). Emery (1985) noted that even in historic Atlantic salmon habitat, such as the lower Great Lakes, attempts to re- establish Atlantic salmon populations have not been successful, although Brown (1975) had earlier stated that introduced Pacific salmonids had succeeded in establishing self - reproducing populations in that area. Lever (1996) noted that, worldwide, no self - sustaining populations of anadromous Atlantic salmon have been established outside the natural range of this species, although a landlocked population appears to have become established in the mountains of New Zealand. Reproduction by Atlantic salmon was also observed subsequent to introduction in Chile and Australia, but these transfers also failed to create self - sustaining populations. The failure of early introductions of Atlantic salmon to produce self - sustaining populations could have been due to the rather primitive hatchery methods used in the early 1900s. However, the same primitive methods that failed to establish Atlantic salmon anywhere in North America proved to be remarkably successful in establishing European brown trout, brook trout, and rainbow trout almost everywhere in the earliest days of fish culture, usually on the first attempt. With these particular salmonids, the success or failure of introduction appears to be associated with attributes inherent to the species, not from the hatchery methods employed. Atlantic salmon are virtually the only non - native salmonid not successfully introduced to Washington, with the exception of Arctic char and Masu salmon (Wydoski and Whitney 1979). The initial transfer of Atlantic salmon to Washington occurred in 1904, according to MacCrimmon and Gots (1979), and Coleman and Rasch (1981) noted that attempts to introduce runs of this species continued until about 1980. Occasional releases of Atlantic salmon into high mountain lakes have since been made. Sea -run and landlocked strains were used, but neither life - history form succeeded in establishing self - perpetuating populations. Attempts to establish Atlantic salmon in Canada BC took place during this period, with similar results, although successful spawning may have occurred in the Cowichan River, Canada as specimens thought to have resulted from the planting of Atlantic salmon were taken until May 1926, according to Dymond (1932), Carl et al. (1959), and Hart (1973). The DFO has been carrying out a long term monitoring study on the catches and sightings of individuals and to see is self - sustaining populations are becoming established but without results (Thomson and Candy 1998). Recently Volpe et al. (2000) reported that Atlantic salmon had successfully produced offspring in BC. Several Atlantic salmon farmers in Washington rear juveniles in the Chehalis River basin prior to transfer to seawater in Puget Sound. Since the mid -1980s escaped Atlantic salmon smolts have been captured in traps designed to monitor the outmigration of juvenile Pacific salmon (Seiler et al. 1995). However, as of 1998, no returning adult Atlantic salmon have been encountered at adult salmon traps on several tributaries of the Chehalis River system, or been caught in tribal gillnet fisheries, which capture about 10% of all upstream migrants in the main stem of the Chehalis River (D. Seiler, WDFW, personal communication). The risk of anadromous Atlantic salmon establishing self - perpetuating populations anywhere outside of their home range is extremely remote, given that substantial and repeated efforts over the last hundred years have not produced a successful self - reproducing population anywhere in the world. In the Pacific Northwest Atlantic salmon introductions also have not succeeded in producing self - sustaining populations, even though a few naturally produced juveniles may have been observed from time to time, according to Dill and Cordone (1997). 5.2.4 Interactions of wild salmon and transgenic fish As with other agricultural sectors, there is considerable interest within the fish farming sector to improve growth or survival of fish or shellfish through genomic manipulations. In recent years the role of transgenics (descendants of genetically engineered parents whereby introduced DNA has been incorporated and inherited) in traditional farming has been a controversial topic. The potential exists that transgenic fish, should they escape from fish farms, may reproduce successfully with wild or other transgenic fish and produce offspring which may eventually adapt to their local environments. This is a topic which will receive 79 considerable debate in the years to come. There is no evidence in the literature that transgenic fish have been raised or are currently being raised in Puget Sound waters, and there are no plans to raise them in the future. 5.3 Epidemics and the Transmission of Waterborne Disease 5.3.1 The origin and disease status of Atlantic salmon stocks in Puget Sound In 1971 scientists from the NMFS Northwest Fisheries Science Center began testing the feasibility of rearing New England stocks of Atlantic salmon in seawater net -pens in Puget Sound to provide 3.5 million eyed eggs annually for restoring depleted runs in southern New England (Mighell 1981, Harrell et al. 1984). Between 1971 and 1983 NMFS received eggs from many North American stocks, including the Grand Cascapedia River in Quebec (via Oregon State), and the Penobscot, Union, St. John, and Connecticut rivers in the USA. All Atlantic salmon eggs sent to the NMFS Manchester Research Station were examined according to the code of federal regulations (Regulation 50 CFR) and certified by federal pathologists to be free of bacterial and viral pathogens prior to transfer from New England to Washington. However, few eggs were ever sent back to New England due to the reluctance of east coast fisheries managers to accept eggs from Atlantic salmon which had been grown in waters inhabited by Pacific salmon. A panel of New England state and federal fisheries officials met at Newton Corner, Massachusetts in March, 1984 and determined that raising Atlantic salmon in Puget Sound had rendered the eggs unfit for transfer back to the east coast because the risk of introducing Pacific salmon diseases to New England Atlantic salmon populations was too great. As a result of this decision, millions of Atlantic salmon eggs originally meant for New England restoration programs were available for distribution to salmon farmers in Washington. These eggs proved to be a boon to the local industry as, by this time, it was clear from work in Norway and Scotland, that Atlantic salmon were superior to Pacific salmon in all aspects of culture, including survival to hatching, growth rate in fresh and sea water, and, contrary to east coast opinion, resistance to infectious diseases (Mighell 1981, Waknitz 1981). 5.3.2 Disease of salmonids Freshwater salmonid diseases observed in Pacific salmon hatcheries in the Pacific Northwest include furunculosis, bacterial gill disease, bacterial kidney disease, botulism, enteric redmouth disease, cold water disease, columnaris, infectious hematopoietic necrosis, infectious pancreatic necrosis, viral hemorrhagic septicemia, erythrocytic inclusion body syndrome, and a large number of parasitic infections, such as gyrodactylus, nanophyetus, costia, trichodina, ceratomyxosis, proliferative kidney disease, whirling disease, and ichthyophonis. All these diseases are described in works by, inter alia, Wood (1979), Leitritz and (1980), Foott and Walker (1992), and Kent and Poppe (1998). :1 The frequency of occurrence of these pathogens in hatcheries appears to vary geographically. For example, between 1988 and 1992, a greater percentage of hatcheries in Alaska tested positive for infectious hematopoietic necrosis, viral hemorrhagic septicemia, furunculosis, and ceratomyxosis than hatcheries located elsewhere in the western States, whereas the same hatcheries in Alaska tested positive at the lowest rate for several other salmonid pathogens (PNWFHPC 1993) (Table 1). In the Pacific Northwest, hatchery diseases associated with freshwater organism can also occur in natural sea water environments after salmon are released from hatcheries or transferred to net -pens for further rearing. Some pathogens, such as V. anguillarum and various parasites, are unique to the marine environment and are normally encountered by wild and hatchery- reared salmonids only after they leave rivers for the sea (Wood 1979, Harrell et al. 1985 and 1986, Kent and Poppe 1998). Salmonid diseases observed in salmon and trout reared in public and private net -pens in sea water in the Pacific Northwest include; vibriosis, furunculosis, bacterial kidney disease, enteric redmouth disease, myxobacterial disease, infectious hematopoietic necrosis, infectious pancreatic necrosis, viral hemorrhagic septicemia, erythrocytic inclusion body syndrome, rosette agent, and a large number of parasitic infections. Kent and Poppe (1998) listed and described infections currently observed in salmonids in marine waters. Like other animals, salmon can carry pathogen organisms without themselves being infected. For example, numerous bacterial species were observed in tissues of chinook salmon which had returned from the ocean to a hatchery in the lower Columbia River Basin, although the fish displayed no clinical signs of disease. Some bacteria observed were Listeria sp., Aeromonas hydrophila, Enterobacter agglomerans, E. cloacae, Staphylococcus aureus, Pseudomonas sp., Pasteurella sp., V. parahaemolyticus, V extorquens, V. fluvialis, Hafnia alvei, and Serratia liquefaciens (Sauter et al. 1987). Several of these organisms found in hatchery salmon are known to be infectious for humans but it does not infer they pose any risk. al Table 1. Facilities ( %) testing positive for various salmonid pathogens (July 1988 -June 1993). (Data from PNWFHPC 1993) State or Agency IHN IPN VHS EIBS BKD FUR ERM CWD PKD MC CS ICH AK 47.3 0.0 1.2 0.0 75.2 42.5 10.9 27.5 NS NS 50.0 0.0 CA 24.2 0.0 0.0 0.0 31.2 2.2 23.0 19.4 27.9 12.0 12.8 56.3 ID 20.2 8.7 0.0 15.5 48.4 1.8 12.3 23.6 4.3 15.6 20.4 20.7 T 0.0 1 0.0 0.0 1 0.0 5.6 1 2.5 0.8 4.2 1 7.7 0.0 0.0 0.0 OR 18.1 0.3 0.0 24.6 53.1 35.9 17.8 84.8 0.0 2.9 33.3 26.2 A 11.5 0.7 0.1 34.2 52.6 20.1 17.0 60.3 3.5 0.0 11.9 24.4 SFWS 37.5 1.0 0.0 27.2 84.9 23.7 20.0 34.9 0.0 0.6 30.6 24.0 IFC 2.9 0.0 0.6 NS 51.5 14.0 18.1 39.9 56.3 0.0 0.0 15.0 verage 20.2 1.3 0.2 14.5 50.3 17.8 15.0 36.8 12.5 4.4 18.8 20.8 NS = Not surveyed Key: (a) Viral Diseases IHN Infectious hematopoietic necrosis IPN Infectious pancreatic necrosis VHS Viral hemorrhagic septicemia EMS Erythrocytic inclusion body syndrome (b) Bacterial Diseases BKD Bacterial kidney disease FUR Furunculosis ERM Enteric redmouth disease CWD Coldwater disease (c) Parasites PKD Proliferative kidney disease MC Whirling disease CS Ceratomyxa ICH Ichthyopthirius 5.3.3 Infectious disease therapy Fish diseases and subsequent antibiotic therapy have been normal occurrences at state, federal, and tribal Pacific salmon hatcheries since the 1940s (WDF 1950, PNWFHPC 1993). For example, an examination of the disease histories of Puget Sound area Pacific salmon hatcheries (data from 45 hatcheries) during the 1980s showed that on average each hatchery commonly experienced disease outbreaks from about 4 different pathogenic organisms during this period, frequently on an annual basis ( PNWFHPC 1988a —d). Cumulatively, salmon hatcheries in the Pacific Northwest (Alaska, Washington, Oregon, and Idaho), including those located in Puget Sound, experience hundreds of disease outbreaks every year, according to Wood (1979) and PNWFHPC (1988a —d). For example, Michak and Rodgers (1989) reported that, between 1983 and 1986, the WDFW Cowlitz Hatchery experienced Costia sp. infections on 11 different occasions, bacterial hemorrhagic septicemia 4 times, cold water disease 9 times, bacterial kidney disease 8 times, and furunculosis once. Disease outbreaks have been observed in hatchery salmon reared in saltwater in Washington since the first attempts at seawater rearing in the 1950s (WDF 1954, PNWFHPC 1998). However, the occurrence of fish diseases and their treatment with chemotherapeutics at public hatcheries has not been show to have deleterious effects on wild salmonids. Diseases in public trout and salmon hatcheries (Table 1) are normally treated with a variety of antibiotics and chemical baths including, inter alia, oxytetracycline, ®Romet- 30, formalin, iodophores (Wood 1979; PNWFHPC 1988a —d, 1998). Drug therapy in federal, state, and tribal hatcheries in Washington State is conducted in line with FDA guidelines (K. Amos, WDFW, personal communication). Antibiotic - resistant strains of bacterial fish pathogens have been observed in Pacific salmon hatcheries in the Pacific Northwest for over 40 years (WDF 1954, Wood 1979, PNWFHPC 1993), but no adverse impacts on wild salmonids have been reported as a result of drug use or the occasional development of antibiotic- resistant bacteria. Schnick (1992) reported that only three therapeutants (formalin, oxytetracycline, and ®Romet -30) and one anesthetic (MS -222) were currently approved by the federal government for use with food fish in public and private artificial propagation facilities. However, the use of antibiotics in the US is far more restrictive than in other countries. For example, Weston (1996) stated that 26 different antibacterials were approved for use in Japan. This compares currently with three in Canada, according to EAO (1997) and two in the US ( Schnick 1992). Given that Pacific salmon hatcheries rear thousands of metric tons of fish each year, the amount of antibiotics used to treat bacterial salmon diseases is not insignificant, amounting to hundreds of tons of medicated feed each year. Michak et al. (1990) stated that WDF hatcheries located in the Columbia River Basin used about 200 mt of feed containing antibiotics. Since WDF (now WDFW) hatcheries in the Columbia River Basin represented only about 25% of the number of all salmon and trout hatcheries (albeit many of the largest facilities are in the Columbia River Basin) in Washington State at that time (Myers et al. 1998), it is reasonable to estimate that the total amount of medicated feed used by the public hatchery system in the State was about 450 mt in 1990. However, no adverse impacts to wild salmonids have been reported as a result. Actual or estimated annual amounts of medicated feed used in private fish culture of Atlantic salmon in seawater and rainbow trout in freshwater are not available at this time for the USA. However, the amount of drugs used elsewhere in salmon farming has greatly declined, mostly as a result of improved husbandry practices, including development of effective vaccines. EAO (1997) noted that salmon farmers in Norway used 48.7 mt of antibacterial drugs in 1987, and the figure had fallen to 6 mt by 1993. In 1998 it was only 679 kg (Intrafish 2000). During the same ten year period, the production of salmon increased from 50,000 mt to 400,000 mt, and the quality of product was considerably improved (ODIN 2001). A similar pattern of reduced drug use has occurred in BC. With few salmon farms in Washington the annual use of antibiotics in the net -pen farms will be minimal. 5.3.4 Disease interactions between wild and propagated salmonids Documented examples of pathogen transmission between wild and artificially- propagated fish are not common, yet have been known to occur (Brackett 1991). For example, the planting of infected Atlantic salmon smolts from Norwegian federal salmon hatcheries into rivers in Norway was responsible for the introduction of the freshwater parasite Gyrodactylus salaris, which caused the extirpation of Atlantic salmon in many river systems (Johnsen and Jensen 1986, 1988). The salmonid viral pathogen IHN (infectious hematopoietic necrosis) was introduced to Japan from a shipment of infected sockeye salmon eggs from a hatchery in Alaska and subsequently caused epizootic mortality in Japanese chum salmon and in two species of landlocked salmon which occur only in Japan (McDaniel et al. 1994). In these two cases, the indigenous salmonids in Norway and Japan were exposed to novel pathogens to which they had little or no immunity. In Washington the pathogens found in cultured salmonids are identical to those known to occur in wild salmon (Amos and Appleby 1999). PSGA (2000) and Carrel (1998) assert that local Atlantic salmon stocks are more likely to carry pathogens than hatchery stocks of Pacific salmon, but this is not supported the scientific literature. Salmonids, including Atlantic salmon, can only carry diseases to which they have been exposed. The New England Atlantic salmon stocks used by Washington growers were certified by federal pathologists to be pathogen -free prior to shipment from east coast hatcheries between 1980 and 1986, inclusive, and have been reared exclusively in the Pacific Northwest for many generations. Their diseases, if any, would be no different than the diseases found in nearby Pacific salmon hatcheries. In addition, Washington regulations require that all broodstocks of hatchery salmon, including Atlantic salmon broodstocks, are examined for pathogens each year (WAC 220 -77; RCW 75.58). Non - indigenous salmon diseases transmitted into the Pacific Northwest by North American stocks of Atlantic salmon have not been reported. Pacific salmonids do not seem to be put to any increased risk of pathogen transmission when exposed to water in which Atlantic salmon have been reared. For example, Rocky Ford Creek near Ephrata, in eastern Washington, is considered one of the premier trout streams in the State but its entire flow consists of effluent from an Atlantic salmon hatchery (J. Parsons, Troutlodge Inc., personal communication). There are no reports of diseased trout in this stream in either the scientific literature or in 'gray' literature. There is no evidence to suggest that hatchery - reared Atlantic salmon have introduced or spread non - indigenous pathogens to native fishes in Washington. With Pacific salmon, Griffiths (1983) observed that outbreaks of serious contagious diseases were normally associated with the intensive culture of fish in a hatchery environment. There are no recorded observations to suggest this would be any different for artificially- propagated Atlantic salmon or rainbow trout. 5.3.5 The scale of artificial propagation Based solely on the enormous number of hatchery- reared salmonids released into rivers and lakes in the Pacific Northwest, the potential for transmission of disease to wild stocks from hatchery - reared Pacific salmon and trout greatly exceeds that of accidentally - escaped farmed Atlantic salmon and rainbow trout in Washington State. This is because escaped Atlantic salmon and rainbow trout constitute an insignificant percentage of all artificially- propagated salmon which end up in natural waters in the area. However, the millions of Pacific salmon which enter the marine waters of Washington each year have not been shown to impose adverse impacts on wild salmonids. Carrel (1998) described escaped Atlantic salmon as 'smart bombs, delivering disease right into the bedrooms of wild salmon' in the Pacific Northwest, but this is not supported in the scientific literature. Because Atlantic salmon are propagated in only a few facilities in the Pacific Northwest, compared with the several hundred federal, state, tribal, and cooperative hatcheries rearing Pacific salmon and trout, the primary difference in the disease incidence between artificially- propagated Atlantic and Pacific salmon is one of scale. Mahnken et al. (1998) reported that, since 1980, the number of Pacific salmon released from west coast hatcheries was about two billion fish annually. This number is 4 or 5 orders of magnitude larger than the number of Atlantic salmon which may have escaped from net - pens since 1980 (Table 2). Table 2. Number (in millions) of salmon released or escaped by species and location along the west coast of North America, 1980 -1995 (Data from NRC 1995 and 1996; Thomson and McKinell 1993 -1997; Mahnken et al. 1998; Thomson and Candy 1998). State or Region Atlantic Sockeye Chum Steelhead Pink Coho Chinook Alaska 0 978 3,885 2 8,610 193 98 Canada BC —0.4 3,930 2,870 17 533 300 721 Pacific Northwest —0.6 52 1,081 359 21 726 4,320 Total —1.0 4,960 7,836 377 91164 2,219 5,139 Total ( %) 0.0003 1 16.7 1 26.4 1 1.2 1 30.9 1 7.5 1 17.3 Comparing only the number of Pacific salmon released from salt -water net -pens, then the magnitude and geographic distribution of these artificially- propagated Pacific salmon is still much greater than the number and magnitude of Atlantic salmon reared in farms. :11 For example, NRC (1995, 1996) reported that coho salmon were released annually from 18 different marine net -pen sites, chinook salmon from 13 different sites, and chum salmon from 10 different sites in Puget Sound between Olympia and Bellingham. The annual release from these marine sites between 1980 and 1992 averaged about 10 million fish. These fish had sometimes been exposed to various salmonid pathogens while in seawater, including bacterial kidney disease, vibriosis, and furunculosis. Infections in these fish were often treated with antibiotics prior to their release (PNWFBPC 1988a —d), yet no adverse impacts on wild salmonids have been reported as a result. 5.3.6 Disease control policies in Washington and the USA In Washington all public and private growers of salmon, including Atlantic salmon hatchery operators, are required to adhere to strict disease control polices which regulate all phases of fish culture, from egg take to harvest and /or release (NWIFC/WDFW 1991; NWIFC/WDFW1998). Each year at spawning time, adult salmon at public and private hatcheries must be sampled for viral, bacterial, and parasitic organisms. If any of several reportable organisms are detected in fish at a hatchery, or have been detected within the past five years, transfer of eggs or fish from that facility is prohibited. The movement of fish and eggs across state or international borders is regulated by the USFWS under Title 50 of the CFR, which has stipulations and controls in accord with State regulations (Regulation 50 CFR, Part 16.13). For the case in point, all Atlantic salmon stocks distributed to local growers by NMFS were federally certified by federal pathologists before transfer from New England, and have been annually certified since then under Washington guidelines and procedures. Most of the cumulative body of information pertaining to salmon farming developed in the last several decades has already been integrated into the regulatory processes of Washington State. This scientific information has been incorporated into State regulations relating to farm fish escapes, antibiotic residues in sediments, accumulation of organic wastes on the seabed, importation of non - native and non -local species, and disease management. These and other important regulations and documents pertaining to private salmon farming include: • Final programmatic EIS for fish culture in floating net -pens (WDF 1990) • Recommended interim guidelines for the management of salmon net -pen culture in Puget Sound (WDOE 1986) • Environmental effects of floating mariculture in Puget Sound (Weston 1986) • Environment fate and effects of aquacultural antibacterials in Puget Sound (Weston et al. 1994) • Disease control policies of Washington (NWIFC/WDF 1991) • Disease control policies of the United States (USFWS 1984) • Fish health manual of the Washington Department of Fish and Wildlife (WDFW 1996) :. 5.4 Potential Ecological Impacts of Atlantic Salmon in the Pacific Northwest In areas where Atlantic salmon are indigenous, such as Scandinavia, Great Britain, and eastern North America, adverse genetic and ecological impacts for natural populations of Atlantic salmon have been reported by, inter alia, Gibson 1977; Gross 1998; Hearn and Kynard 1986; Jones and Stanfield 1993; Beall et al. 1989; Heggberget et al. 1993, following programmed releases or escapes of artificially- propagated Atlantic salmon from public hatcheries and private net -pens. The impacts included reduction in genetic adaptation and capacity to evolve in wild Atlantic salmon resulting from interbreeding with artificially- propagated Atlantic salmon, and competition for food and space between wild and hatchery stocks of Atlantic salmon. These adverse effects occurred because both the artificially - propagated and wild salmonid species were Atlantic salmon. Escaped Atlantic salmon on the Pacific coast of North America do not have congeneric wild individuals with which to interact. In the Pacific Northwest region it is the introduction of hatchery stocks of Pacific salmon which have the potential to produce impacts on native Pacific salmon comparable to those found between propagated and wild Atlantic salmon in Europe and eastern North America. Adverse genetic and /or ecological interactions on local wild salmon populations resulting from plants of artificially- propagated Pacific salmonids have been well documented in the Pacific Northwest in papers by Nickelson et al. (1986), Behnke (1992), Kostow (1995), Campton and Johnston (1985), WDFW et al. (1993), and Leider et al. (1997). A series of papers by Thomson and McKinnell (1993, 1994, 1995, 1996, and 1997), Thomson and Candy (1998), and Amos and Appleby (1999) have reported no detrimental effects in the region which can be related to deliberate or accidental Atlantic salmon introductions. 5.4.1 Social interactions between Pacific and Atlantic salmon Gibson (198 1) reported that, from laboratory studies in New England, introduced Pacific steelhead juveniles were more aggressive than Atlantic salmon. In turn Atlantic salmon fry appeared to be more aggressive than coho salmon fry when introduced into open pools, although it was recognized that open pools are not the preferred habitat of coho salmon fry. Beall et al. (1989) in a similar experiment reported that the survival of Atlantic salmon was reduced in the presence of older coho salmon fry. In trials of inter - specific combative behavior in New England, Hearn and Kynard (1986) observed that rainbow trout juveniles initiated three to four times more aggressive encounters than did Atlantic salmon, and concluded that it would take very large numbers of Atlantic salmon juveniles to displace or even disrupt native species. Jones and Stanfield (1993), in a study conducted in a Lake Ontario tributary once inhabited by Atlantic salmon, reported that their attempts to reintroduce hatchery strains of Atlantic salmon were significantly impaired in the presence of naturalized Pacific salmon juveniles, compared with reintroduction in stream sections where Pacific salmon juveniles had been removed. 5.4.2 Predation by Atlantic salmon In a study on farined fish in Canada BC by Black et al. (1992) stomach analyses revealed that <1% of farmed salmon in net -pens (in this case coho and chinook salmon) contained the remains of fish. Since 1992 scientists of the Canadian federal government have examined the stomach contents of escaped Atlantic salmon recovered in the open waters of BC. Fish remains of any sort were rarely observed, and no confirmed salmonid remains were reported (see Thomson and McKinnell 1993, 1994, 1995, 1996, 1997; Thomson and Candy 1998). This confirms earlier work by Tynan (1981) who examined the stomachs of 93 coho salmon captured after release from a net -pen near Squaxin Island, in South Puget Sound, and reported that only three stomachs contained fish remains, which were identified as smelt. At the NMFS Manchester Research Station in Puget Sound many species of forage fish have been observed seeking refuge from predators in net -pens containing large Atlantic salmon. Among the species observed are known prey of salmonids, such as herring, smelt, candlefish, shiner perch, and tube snouts. These prey species enter the net -pens voluntarily and then grow too large to exit. A report by Alverson and Ruggerone (1997) noted that many thousands of these small fish had been observed in Atlantic salmon net - pens, and had to be removed by hand. Buckley (1999) showed that cannibalism and predation on other salmonids by chinook salmon when feeding was uncommon in Puget Sound waters. It is difficult to imagine that escaped Atlantic salmon, conditioned to a diet of artificial feed pellets and trained to be fed by humans, could have greater predation impacts on juvenile native salmonids than the low impact observed with free - swimming Puget Sound Chinook salmon. In the Cowichan River in Canada BC, non - native brown trout became established soon after its first introduction in 1932. Idyll (1942) observed that native salmon and trout, and their eggs, were a significant dietary component of newly - established Cowichan River brown trout, and were the primary food item of large brown trout. Recent evaluations by Wightman et al. (1998) of steelhead populations on the east coast of Vancouver Island showed that the Cowichan River was one of only two rivers (out of 27 evaluated) with a relatively healthy steelhead population. Therefore the successful colonization of the Cowichan River by a highly piscivorous species such as the brown trout has apparently had no adverse impact on steelhead abundance for more than 60 years, whereas concurrent attempts to establish Atlantic salmon in the Cowichan River basin were failures. 5.5 Potential Impacts of Propagated Pacific Salmon Adverse genetic and ecological effects from artificially- propagated Pacific salmon have been documented by, inter alia, Weitkamp et al. (1995), Busby et al. (1996), Hard et al. (1996), Gustafson et al. (1997), Johnson et al. (1997), Myers et al. (1998), and Johnson et al. (1999) in a number of coast -wide status reviews of Pacific salmonids. These status reviews were conducted by NMFS in fulfillment of their responsibilities under ESA. The reviews contained information from the scientific literature which documented known adverse ecological impacts sometimes associated with the artificial propagation and release of Pacific salmon. In recent years, west coast management agencies have eliminated many of the policies which contributed to these adverse effects. However, examining some of the known adverse impacts of Pacific salmon hatchery programs which have not been observed to be a result of Atlantic salmon hatchery programs on the west coast offers an effective demonstration that the ecological and genetic risks associated with Atlantic salmon farming are small in the waters of Puget Sound. The following paragraphs provide a brief review by species of adverse effects of artificial propagation which occurred under the old Pacific salmon hatchery policies. (i) Steelhead trout Hatchery stocks of steelhead have been widely distributed. Few native steelhead stocks exist in the contiguous US which have not had some influence from hatchery operations. For example, Busby et al. (1996) cite the summer steelhead program at the Nimbus Hatchery in Central Valley, California was established with fish from a distant coastal tributary hatchery which was itself earlier established with Lower Columbia River summer steelhead. Howell et al. (1985) reported that over 90% of the 'wild' steelhead spawning in the Cowlitz River originated in a hatchery, and some of these fish exhibited genetic characteristics of Puget Sound steelhead due to previous transfers of Puget Sound stock to the Cowlitz Hatchery. Chilcote (1997) reported that, since 1980, the percentage of non - native stray hatchery steelhead (from upper Columbia River and Snake River hatcheries) spawning in the Deschutes River had increased to over 70% of the run, while the percentage of native, wild steelhead spawning in the Deschutes River decreased to less than 15 %. Phelps et al. (1997) postulated that introductions of non - native steelhead stocks in Washington, primarily Chambers Creek winter steelhead and Wells and Skamania summer steelhead, may have changed the genetic characteristics of some populations sufficiently so that the original genetic relationships between stocks may have been obscured. Finally, Leider et al. (1987) concluded that the genetic fitness of the wild Kalama River population had been compromised by maladaptive gene flow from excess hatchery escapement. By comparison, no documented adverse effects on steelhead have been reported to result from escapes of Atlantic salmon in Washington or elsewhere. (ii) Chinook salmon About 2 billion hatchery chinook salmon have been released into Puget Sound since 1953, with the stock from the Green River Hatchery being the dominant stock as far back as 1907. Concerns that this strategy may erode genetic diversity was raised by Myers et al. (1998). As recently as 1995, 20 hatcheries and 10 marine net -pen sites throughout Puget Sound regularly released Green River -stock chinook salmon. Busack and Marshall (1995) reported that the extensive use of this stock had an undoubted impact on among - stock diversity within the South Puget Sound, Hood Canal, and Snohomish summer /fall genetic diversity unit (GDU), and may also have impacted GDUs elsewhere in Puget Sound and the Strait of Juan de Fuca. Rogue River chinook salmon were recently released on the Oregon side of the Lower Columbia River to produce a south - migrating stock to avoid interception in commercial fisheries in Canada BC and Southeast Alaska. However, chinook salmon exhibiting Rogue River fall chinook salmon genetic markers were subsequently observed by Marshall (1997) in several lower Columbia River tributaries, and were estimated to comprise about 13% of the Lower Columbia River naturally- produced chinook salmon sampled in 1995. Marshall et al. (1995) had earlier stated that most of the naturally - spawning spring chinook salmon in Lower Columbia River tributaries were hatchery strays. Adverse impacts resulting from the introduction of artificially- propagated fish into native populations of chinook salmon were identified as a primary concern by the NMFS Biological Review Team during the recent review of the status of west coast chinook salmon populations (Myers et al. 1998). There is no documented evidence of adverse effects on chinook salmon resulting from escaped Atlantic salmon in Washington or elsewhere. (iii) Chum salmon Johnson et al. (1997) reported that five hatchery stocks and several wild populations of chum salmon outside the Hood Canal, but which received eggs from Hood Canal hatcheries for several years, exhibited genetic frequencies more similar to those in Hood Canal hatchery populations than to populations in nearby streams not receiving Hood Canal hatchery stocks. Their analyses of gene frequency patterns were consistent with the hypothesis that egg transfers between hatcheries and out - plantings of Hood Canal stock fry had genetically influenced the receiving populations. According to Phelps et al. (1995) such transfers were terminated because of the potential jeopardy to wild gene pools through interbreeding. However, there is no documented evidence of adverse effects on chum salmon resulting from escaped Atlantic salmon in Washington or elsewhere. (iv) Coho salmon Weitkamp et al. (1995) noted that the NMFS Biological Review Team was unable to identify any remaining natural populations of coho salmon in the lower Columbia River below Bonneville Dam, due in large part to persistent and extensive hatchery programs. A recent survey by NRC (1999) of coho salmon spawning habitat in the lower Columbia River estimated that about 97% of recovered spawned -out carcasses originated from hatchery releases. Hatchery fish were observed in high percentages in streams up to 45 miles from the nearest hatchery. In many streams, wild, native coho salmon were not observed at all. In an earlier similar survey by NRC (1997) in Hood Canal, over 50% of all spawning coho in streams within a 10 -mile radius of a net -pen release site were fish released from the net -pen as juveniles 18 months earlier. Kostow (1995) stated that hatchery programs in Oregon may have contributed to the decline of wild coho salmon by supporting harvest rates in mixed -stock fisheries which were excessive for sustained wild fish production, and by reducing the fitness of wild populations through interbreeding of hatchery and wild fish. Furthermore, they may have reduced survival of wild coho salmon juveniles in Oregon through increased competition 90 for food in streams and estuaries, through attraction of predators during mass migrations, and through initiation of disease problems. Weitkamp et al. (1995) also reported that artificial propagation of coho salmon had appeared to have substantial impact on native coho salmon populations to the point where it was difficult for the NMFS Review Team to identify self - sustaining native stocks in Puget Sound, as over half the returning spawners originated in hatcheries. Spawn- timing had been advanced by selective breeding so that most hatcheries met their quotas for eggs by early November, and fish arriving at the hatchery with the later run (which would be coincidental with the spawn -time of the wild or native fish) were not propagated. As a result of such practices, according to Flagg et al. (1995), segments of hatchery coho salmon populations which historically returned as late as January through March have disappeared from many river systems, resulting in a significant loss of life history diversity. Again, for comparison, there is no documented evidence of adverse effects on coho salmon resulting from escaped Atlantic salmon. (v) Trouts Long -term introductions of rainbow trout into western streams originally inhabited only by cutthroat trout have resulted in widespread extinctions of native cutthroat trout through introgressive hybridization, according to Leary et al. (1995). They noted that hybridization between introduced brook trout and bull trout is widespread in the western USA, and usually produces sterile hybrids. Behnke (1992) noted that introduced brown trout had commonly replaced interior subspecies of cutthroat trout in large streams throughout the same region, and introduced brook trout were the most common trout to be found in many small streams. The situation regarding attempts to establish Atlantic salmon populations in the West is much different. In summary, MacCrimmon and Gots (1979) described frequent attempts and failures to introduce Atlantic salmon to the western States, many of which occurred in the same river systems and at the same time as the introductions noted above. Since then no recent introductions, accidental or not, have succeeded and, most importantly, no known adverse impacts on indigenous species by Atlantic salmon have been reported in the literature. 5.6 Adverse Impacts of Non - indigenous Fish Introductions As many as 50 species of non - native fish are successfully established in the western US (Table 3). The Atlantic salmon is not one of those listed. Some adverse impacts associated with the establishment of these species are discussed below. None of these negative impacts has been associated with the artificial propagation of Atlantic salmon in the Pacific Northwest. 91 Table 3. Status of non - native fish introductions in the Pacific Northwest vis -a -vis their behavior relative to Pacific salmonids (Data after Behnke 1992, Lever 1996, ODFW 1999, WDFW 1999, Dill and Cordone 1997) Non - Native Species Naturalized in Washington Naturalized in Oregon Naturalized in California Predator Competitor Hybridize Atlantic salmon Non-native rainbow X X X X X X Non-native cutthroat X X X X X X ahotan cutthroat X X estslope cutthroat X X X X Brown trout X X X X X X Brook trout X X X X X X Lake trout X X X X X American shad X X X X Threadfin shad X Lake whitefish X Arctic grayfing X X Grass pickerel X X orthern pike X X X Striped bass X X X White bass X Common carp X X X X Grass carp X X Tench X X Brown bullhead X X X X X Black bullhead X X X X X Yellow bullhead X X X X X Flathead catfish X X X X Blue catfish X X X Channel catfish X X X X X White catfish X X X X Largemouth bass X X X X X Smallmouth bass X X X X X Wannouth bass X X X X X Rock bass X X X Redeye bass X orthem spotted bass X Alabama spotted bass X Black crappie X X X X X White crappie X X X X X Green sunfish X X X X X Blue gill X X X X X Pumpkinseed X X X X X edear sunfish X i scale logperch X Yellow perch X X X X X alleve X X X X X 92 ODFW /NMFS (1998) documented that many introduced non - native species were harmful to native salmon. For example, walleye, bass, perch, sunfish, brown trout, and brook trout, among others, are all now well - established in Northwest waters and are well - known predators and /or competitors of native salmon and trout. Beamesderfer and Nigro (1988) and Beamesderfer and Ward (1994) estimated that walleye and smallmouth bass introduced into the John Day Reservoir of the Columbia River consumed an average of 400,000 and 230,000 juvenile salmonids, respectively, each year. Daily et al. (1999 in prep.) reported that juvenile salmonids from seven ESUs currently listed as threatened or endangered under ESA must migrate through the John Day Reservoir; and in some coastal lakes in Oregon the summer rearing of coho salmon fry no longer occurred due to predation by introduced largemouth bass. Seiler (WDFW, personal communication) has observed that introduced bass eat out - migrating salmon, including juvenile chinook salmon, as they pass through the Lake Washington Ship Canal in Seattle, WA. There is no documented literature which shows that Atlantic salmon in western states prey on juvenile native salmonids. In 1997 and 1999, in response to the escape of some net -pen Atlantic salmon, WDFW suspended fishing regulations concerning size and bag limits for these fish. Licensed anglers fishing in open management zones were permitted to keep all Atlantic salmon they could catch, of whatever size (WDFW 1997c, 1999). Suspension of fishing regulations for an introduced, non - native species in waters inhabited by native salmonids at some period of their life cycle is an appropriate management which WDFW has used before. For example, freshwater angling regulations for non - native brook trout in Washington were recently relaxed to increase harvest of this species, and regulations for non - native shad, perch, crappie, and carp have long -since been dismissed entirely. Catch limits and close seasons for non - native salmonids in Washington (such as brown trout, golden trout, lake trout, landlocked Atlantic salmon, California- strain rainbow trout, and grayling) have given these species many of the same protections given to native salmonids. Furthermore, several non - native species known to prey on salmonid juveniles (such as smallmouth and largemouth bass, walleye, and channel catfish) are currently managed for sustained natural reproduction through regulations which limit the take of large individuals which have the greatest reproductive potential (WDFW 2001). From a review of the literature, Atlantic salmon have far less potential for adverse impacts than all the non - native species noted above. Therefore, to decrease unnecessary adverse impacts on listed native salmonids by non - indigenous fish, it would not be an inconsistent strategy for states in the Pacific Northwest to suspend regulations for the harvest of all non - indigenous fish by licensed anglers. 93 5.7 A Perspective of Salmon Culture in Northwest Waters Most of the concerns for the negative impacts of Atlantic salmon on native salmon in the Pacific Northwest are hypothetical. They are associated with the belief that artificially - propagated fish are bigger, stronger, and more vigorous that wild fish. Although this opinion has been generally disproved in a multitude of studies, many studies and reviews, among them WDFW et al. (1993) and the NMFS Status Reviews, have shown that adverse impacts from hatchery stocks of Pacific salmon are likely to occur if and when hatchery fish comprise a large portion of the total population. Therefore, it is instructive to compare the numbers of artificially- propagated Pacific salmon released each with the number of Atlantic salmon estimated to escape each year to give a perspective as to where and when the greatest risks actually occur, and to what degree, keeping in mind recent changes in hatcheries strategies in the Pacific Northwest which will likely reduce the impact of hatchery fish on wild fish. Mahnken et al. (1998) reported that several billion Pacific salmon were released from freshwater hatcheries and marine net -pens in North America each year (see Table 2). Although Washington, Oregon, Idaho, and California had more salmon hatcheries, the total number of fish released in the contiguous States of the Pacific Northwest was dwarfed by the vast number of hatchery salmon released in Alaska each year. McNair (1997, 1998, and 1999) documented the annual release of about 1.4 billion hatchery salmon into natural rearing areas since 1996. Pacific salmon have been released from hatcheries with the understanding that they must compete for food and habitat in common with native wild salmon to survive. Until recently the capacity of the ocean pastures were thought to be limitless. Recent investigations by Heard (1998), Cooney and Broduer (1998), and Beamish et al. (2000) show that food availability in the ocean fluctuated over time and might be limiting salmon abundance. Bisbal and McConnah (1998) proposed fishery managers planning to release vast numbers of fish from hatcheries should take these fluctuations into account. Compared with the great numbers of Pacific salmonids released each year into the marine ecosystems, there is no evidence in the literature that the few Atlantic salmon which escape pose any competitive threat to native Pacific salmon for forage or habitat. The majority of Atlantic salmon escapes have occurred in Puget Sound. However, the number of escapees is extremely low compared with the number of Pacific salmon deliberately introduced into the ecosystem. NRC (1995, 1996) documented that the total number of cultured chinook. coho, and chum salmon released into Puget Sound tributaries by various fisheries agencies between 1980 and 1992 exceeded 2.2 billion in number. Although data are not yet available through the year 2000, it is predictably over 3 billion. For comparative purposes, if the total number of Atlantic salmon which escaped into Puget Sound since 1980 was represented on a histogram by a bar one inch high, the total number of Pacific salmon released into Puget Sound and its river basins since 1980 would be a bar about 250 feet high. Comparison with the 13.5 billion hatchery fish released into Alaskan waters since 1990, using annual data published by ADF &G between 1991 and 2000, is even more dramatic, and would require a bar almost one quarter of a mile high. The adverse ecological and genetic interactions associated with abundant releases of hatchery - reared Pacific salmon are well- documented and present a more serious risk for native salmonids. There is no evidence in the literature which associates adverse impacts with the escape of Atlantic salmon in the Pacific Northwest, or that they even pose a serious threat. NRC (1995) reported that over 240 million small, non - migratory, hatchery coho salmon were released into Puget Sound tributaries between 1980 and 1992, which averaged about 18 million annually. FPC (1999) since reported that the number of unsmolted coho salmon was reduced by over half, due to the previously mentioned changes in hatchery strategies. Nonetheless, these artificially - propagated fish have to survive by competing for natural food and rearing space with native salmon for about 18 months. Using typical wild coho salmon life history data (ODFW 1982), such as egg -to- fingerling survival levels of 10% and a fecundity of 4000 eggs per female, it would take every year about 92,000 mature, successful Atlantic salmon spawners (1:1 female:male ratio) to produce enough fry to equal the numbers of artificially- propagated non - migrant coho salmon planted in Puget Sound rivers every year. Applying the same calculations on a more local scale, FPC (1999) reported that about 7,500,000 coho salmon fry of hatchery origin were planted in the Green River between 1993 and 1996. To produce an equal number of Atlantic salmon juveniles, it would be necessary for over 9,000 mature Atlantic salmon adults to escape and spawn successfully in the Green River each year. However, Thomson and Candy (1998) recaptured fewer than 20 mature Atlantic salmon in all Washington rivers systems during 1997, although some were not surveyed completely. BMPs for net -pen salmon fan-fling continue to stress the importance of preventing escapes (BCSFA 1999), but any potential adverse impacts associated with escaped Atlantic salmon cannot begin to approach the potential impacts of fish released from Pacific salmon hatchery programs, even when recent changes in hatchery strategies are considered Volpe et al. (2000) recovered less than 100 naturally- spawned juvenile Atlantic salmon during counts of salmon juveniles in the Tsitika River in Canada BC. Noakes (1999) noted more than 10,000 juvenile Pacific salmonids were observed in this river in the same survey. The juvenile Atlantic salmon made up approximately 1% of the juvenile salmonids in the river and presented no competition to native salmonids for food or rearing space. No naturally - produced Atlantic salmon have been observed in Washington rivers to -date, although surveys have not been as vigorous as those in Canada. The success of a hatchery or net -pen facility, as well as the degree to which hatchery fish potentially impact wild fish, is largely determined by how well fish survive in the wild after release. Some hatchery programs are very successful at producing fish for harvest. Johnson et al. (1997) noted that hatcheries in Alaska, through extremely successful early - rearing strategies, produced prodigious numbers of adult chum and pink salmon, two '. species which normally have juvenile to adult survival rates of <0.5 %. The Hidden Falls Hatchery in Southeast Alaska has consistently experienced survivals of 3 —8% with chum salmon (Bachen 1994), resulting in this single facility producing more than 22% of all the chum salmon, wild and hatchery, caught in the fisheries of southeast Alaska (Johnson et al. 1997). McNair (1998) reported that 93.6% of all pink salmon caught in Prince William Sound in 1997 were artificially propagated, and that for all salmon harvested in common property fisheries throughout Alaska that year, 22% of the coho salmon, 30% of the pink salmon, and 65% of the chum salmon originated in hatcheries. Overall, she reported that hatcheries contributed 26% of all salmon harvested in Alaska in 1997. In 2000, McNair (2001) reported that 34% of the total salmon catch in Alaska was produced in Alaskan hatcheries. Additional contributions to Alaska's commercial harvest from hatcheries in British Columbia, Washington, Oregon, and Idaho were not include in this analysis. In Washington, WDFW (2000) estimated that hatcheries provide about 75% of all coho and chinook salmon harvested, as well as 88% of all steelhead harvested. As west coast hatcheries put enough artificially- propagated salmon into the natural environments to produce a significant proportion of the harvest in Alaska, and the overwhelming proportion of fish harvested in Washington, it is not possible that the relatively inconsequential competition for natural resources from present levels of escaped Atlantic salmon could even be evaluated. Given that it is necessary for millions of hatchery Pacific salmon to compete successfully with wild salmon in natural environments to survive and contribute to the economies of Alaska and Washington, expressions of concern by ADF &G (1999) regarding competition for food from relatively small numbers of escaped Atlantic salmon appear misdirected. A review of the literature reveals that the potential for artificially - propagated Pacific salmon released from public hatcheries to pose adverse impacts with wild Pacific salmon through competition for food is far greater than the potential for competition posed by escaped Atlantic salmon. 5.8 NMFS Biological Status Reviews of West Coast Pacific Salmon Stocks Since 1991 14 Biological Status Reviews have been published by NMFS as part of the its federal obligation under ESA. These Reviews are individual scientific studies of the current status of all anadromous salmonid populations on the west coast of the USA. These are generally regarded as the most complete scientific reviews of their kind ever published. They form the basis for NMFS actions concerning ESA listing determinations, as well as the scientific basis for NMFS testimony for litigation and courtroom challenges to proposed and implemented listings under ESA. In these Reviews, experienced federal scientists have identified many factors which have adverse effects on the Pacific salmonids of the west coast. The potential biological impacts of cultured salmon have continuously been identified as a primary factor (see Hard et al. 1992, and Waples 1991). Atlantic salmon farms have not been identified as the cause of adverse effects in any of the 14 Reviews conducted to -date, which cover 58 separate ESUs for Pacific salmon species, or factors in the decline of west coast populations of chinook salmon or steelhead (NMFS 1996, 1998). 96 6. POST SCRIPT In 1996 a group of organizations brought suit before the PCHB in the State of Washington against WDOE, WDFW, and salmon farmers in the State. The suit (PCHB Nos. 96 -257 through 96 -268) challenged the issuance of NPDES permits to the salmon farmers. The basis of the suit by the appellants was a series of allegations regarding conflict with other resources and unacceptable environmental risks associated with the culture of Atlantic salmon, the effects of waste on the water column and benthos, and damage to other resources, including fish and shellfish. Following months of testimony by experts, on May 27, 1997 the PCHB denied partial summary judgement to the appellants because of a genuine issue of material fact as to whether escaped Atlantic salmon 'shall cause or tend to cause pollution' under State law, and whether they constitute 'a man -made change to the biological integrity of State water' under federal law (PCHB 1997). The PCHB found that, 'the Permittees' facilities do not create unresolved conflicts with alternative uses of Puget Sound resources as contemplated by RCW 43.32C. 030(2)(e). The existence of commercial salmon farms as permitted uses does not preclude other beneficial uses in Puget Sound, such as shellfish harvesting, commercial or sport fishing, navigation or recreational boating. Likewise, the existence of the salmon farms does not operate to the exclusion of available resources, such as native salmon runs, sediment and water quality, or marine mammals. In short, salmon farming in Puget Sound does not present the citizens of the State of Washington with an "either /or " choice with respect to other beneficial uses and important resources.' The Board issued its Final Order on the matter on November 30, 1998 (PCHB 1998) and found: 'no evidence that Permittees' facilities have impacts that effectively exclude other beneficial uses of available resources of Puget Sound. The escapement of Atlantic salmon from Permittees' facilities absent large regular releases in the fixture does not pose an unacceptable risk to native Pacific salmon in terms of competition, predation, disease transmission, hybridization or colonization.' This decision by the PCHB was not substantially different from that of the authors of the British Columbia Salmon Aquaculture Review (EAO 1997) which concluded that salmon aquaculture, as currently practiced in BC, did not pose unacceptable risks to the environment. The PCHB finding in favor of the `performance standard' on which the NPDES permit system in Washington State is based also supports the decision by the BC government to work towards similar standards. Organic and inorganic loading of the benthos, the transport, fate and biological effects of pharmaceuticals, and dissolved nutrient effects on phytoplankton are important public concerns which have long been recognized and studied. 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Final Findings of Fact, Conclusions of Law and Order, PCHB No. 96 -257 et seq., NPDES Permit Appeals, November 30, 1998, 46 p. Weston, D.P. 1986. The environmental effects of floating mariculture in Puget Sound. Univ. Washington School of Oceanography Report 87(16), 148 p. 124 Winsby, M., B. Sander, D. Archibald, M. Daykin, P. Nix, F.J.R. Taylor, and D. Munday. 1996. The environmental effects of salmon netcage culture in British Columbia. Prepared for the Ministry of Environment, Lands and Parks, Environmental Protection Department, Industrial Waste/Hazardous Contaminants Branch, 1106 -1175 Douglas Street, Victoria, BC, 214 p. 125 Attachment A NOAH Technical Memorandum NMFS - NWFSC -53 GPN °AM °SFq° Review of Potential Impacts o 90 z of Atlantic Salmon Culture P F4gNENTOF° on Puget Sound Chinook Salmon and Hood Canal Summer -Run Chum Salmon Evolutionarily Significant Units June 2002 U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration National Marine Fisheries Service NOAA Technical Memorandum NMFS Series The Northwest Fisheries Science Center of the Na- tional Marine Fisheries Service, NOAA, uses the NOAA Technical Memorandum NMFS series to issue informal scientific and technical publications when complete formal review and editorial processing are not appropriate or feasible due to time constraints. Documents published in this series may be referenced in the scientific and technical literature. The NMFS -NWFSC Technical Memorandum series of the Northwest Fisheries Science Center continues the NMFS -F/NWC series established in 1970 by the Northwest & Alaska Fisheries Science Center, which has since been split into the Northwest Fisheries Science Center and the Alaska Fisheries Science Center. The NMFS -AFSC Technical Memorandum series is now being used by the Alaska Fisheries Science Center. Reference throughout this document to trade names does not imply endorsement by the National Marine Fisheries Service, NOAA. This document should be cited as follows: Waknitz, F.W., T.J. Tynan, C.E. Nash, R.N. Iwamoto, and L.G. Rutter. 2002. Review of potential impacts of Atlantic salmon culture on Puget Sound chinook salmon and Hood Canal summer -run chum salmon evolutionarily significant units. U.S. Dept. Commer., NOAA Tech. Memo. NMFS - NWFSC -53, 83 p. NOAH Technical Memorandum NMFS - NWFSC -53 �0Ep1Y OF Review of Potential Impacts of Atlantic Salmon Culture oIrATr of/ on Puget Sound Chinook Salmon and Hood Canal Summer -Run Chum Salmon Evolutionarily Significant Units F. William Waknitz', Tim J. Tynan', Colin E. Nash 2, Robert N. Warn oto2, and Larry G. Rutter' Northwest Fisheries Science Center Conservation Biology Division 2725 Montlake Boulevard East Seattle, Washington 98112 2 Northwest Fisheries Science Center Resource Enhancement and Utilization Technologies Division 2725 Montlake Boulevard East Seattle, Washington 98112 3 NMFS Northwest Regional Office Sustainable Fisheries Division 510 Desmond Drive Southwest Lacey, Washington 98503 June 2002 U.S. DEPARTMENT OF COMMERCE Donald L. Evans, Secretary National Oceanic and Atmospheric Administration Vice Admiral Conrad C. Lautenbacher, Jr. USN (Ret), Administrator National Marine Fisheries Service William T. Hogarth, Administrator for Fisheries 11 Most NOAA Technical Memorandums NMFS -NWFSC are available on -line at the Northwest Fisheries Science Center web site (http: / /www.nwfse.noaa.gov) Copies are also available from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 phone orders (1- 800 -553 -6847) e -mail orders (orders (a7jlntis.fedworld.gov) iii TABLE OF CONTENTS LITOF TABLES ........................................................................... ............................... ............................vii EXECUTIVESUMMARY .......................................................................................... ............................... ix ACKNOWLEDGMENTS............................................................................................ ............................... xi INTRODUCTION.......................................................................................................... ..............................1 Intentof Present Document ........................................................................................ ..............................1 Concerns Regarding Salmon Farming in Puget Sound ............................................. ............................... 3 Scopeof Literature Review ....................................................................................... ............................... 3 Previous Investigations of Salmon Farming in the Pacific Northwest ...................... ............................... 4 ORIGIN OF ATLANTIC SALMON STOCKS IN PUGET SOUND ........................... ............................... 7 POTENTIAL GENETIC IMPACTS OF ATLANTIC SALMON CULTURE IN THE PUGET SOUND CHINOOK AND HOOD CANAL SUMMER -RUN CHUM SALMON ESUS ........... ............................... 9 Potential Genetic Interactions of Artificially Propagated Pacific and Atlantic Salmon ........................... 9 Hybridization between Atlantic and Pacific Salmon ................................................. ............................... 9 Potential Genetic Compatibility ............................................................................ ............................... 9 Potential Contribution from Precocious Male Atlantic Salmon ............................ .............................12 Hybridization between Atlantic Salmon and Brown Trout ................................... .............................13 Hybridization among Pacific Salmon .................................................................... .............................14 Genetic Dilution and Alteration of the Wild Salmon Gene Pool .............................. .............................14 Potential Impact of Transgenic Atlantic Salmon ....................................................... .............................15 POTENTIAL FOR COLONIZATION OF PUGET SOUND CHINOOK AND HOOD CANAL SUMMER -RUN CHUM SALMON ESUs BY ATLANTIC SALMON ...................... .............................17 Success of Atlantic Salmon Introductions Worldwide .............................................. .............................17 Success of Atlantic Salmon Introductions in the United States ................................. .............................17 Success of Atlantic Salmon Introductions in the Pacific Northwest ......................... .............................17 Possible Reasons for the Failure of Atlantic Salmon Introductions ........................ ............................... 20 PrimitiveHatchery Methods ................................................................................. .............................20 Pristine Habitats and Healthy Pacific Salmon Populations ................................. ............................... 20 Incompatible Biological Characteristics of Introduced Atlantic Salmon ............ ............................... 20 POTENTIAL FOR DISEASE TRANSMISSION OR ADVERSE DISEASE IMPACTS BETWEEN ATLANTIC SALMON AND PACIFIC SALMON IN WASHINGTON ..................... .............................23 Diseases of Salmon and Trout in Hatcheries ............................................................. .............................23 DiseaseTherapy ...................................................................................................... ............................... 25 Concerns Regarding Treatment of Diseases in Salmon Rearing Facilities ......... ............................... 25 Chemotherapeutants Registered for Use in the United States ............................... .............................26 Amount of Antibiotics Used in Fish Culture Facilities ....................................... ............................... 26 Disease Interactions between Hatchery and Wild Salmon and Trout ...................... ............................... 27 Transmissions of Disease from Hatchery to Wild Salmon ................................. ............................... 27 Diseases of Atlantic Salmon in the Pacific Northwest ........................................ ............................... 28 Potential for Disease Transmission from Atlantic Salmon to Pacific Salmon .... ............................... 28 The Scale of Artificial Propagation of Salmon in the Pacific Northwest and Disease Transmission Potential............................................................................................................... ............................... 28 Disease Control Policies in Washington and the United States .......................... ............................... 29 POTENTIAL ECOLOGICAL IMPACTS OF ATLANTIC SALMON IN THE PACIFIC NORTHWEST............................................................................................................. ............................... 31 Impacts of Cultured Atlantic Salmon on Wild Atlantic Salmon ............................. ............................... 31 Impacts of Cultured Pacific Salmon on Wild Pacific Salmon ................................. ............................... 31 Ecological Interactions between Atlantic Salmon and Pacific Salmon ................... ............................... 32 IV BehavioralInteractions ....................................................................................... ............................... 32 Predationby Atlantic Salmon ............................................................................. ............................... 32 Predation by Introduced Brown Trout ................................................................. ............................... 33 Ecological Interactions between Cultured Pacific Salmon and Wild Pacific Salmon ............................ 34 ChinookSalmon .................................................................................................... .............................34 ChumSalmon ........................................................................................................ .............................35 SteelheadTrout ................................................................................................... ............................... 35 CohoSalmon ......................................................................................................... .............................35 PacificTrout ........................................................................................................ ............................... 36 ADVERSE IMPACTS OF NONINDIGENOUS FISH INTRODUCTIONS .............. ............................... 39 MANAGEMENT OF NONINDIGENOUS FISH IN WASHINGTON ...................... ............................... 41 SCALE OF ARTIFICIAL PROPAGATION OF PACIFIC SALMON IN THE PACIFIC 52 NORTHWEST............................................................................................................. ............................... 43 Number of Artificially Propagated Pacific Salmon Released Each Year ................ ............................... 43 Survival of Artificially Propagated Pacific Salmon ................................................ ............................... 43 Comparison of Numbers of Artificially Propagated Atlantic Salmon and Pacific Salmon in the Pacific Northwest................................................................................................................ ............................... 44 POTENTIAL IMPACT OF SUCCESSFULLY REPRODUCING ATLANTIC SALMON IN PUGET Scale and Impacts of Marinas in Puget Sound ........................................................ ............................... SOUND........................................................................................................................ ............................... 47 Number of Naturally Produced Juvenile Atlantic Salmon that Would Approximate Impacts from Environmental Impacts of Marinas ..................................................................... ............................... Pacific Salmon Hatchery Programs in Puget Sound ................................................ ............................... 47 Number of Naturally Produced Juvenile Atlantic Salmon that Would Approximate Impacts from REGULATORY STRUCTURE FOR COMMERCIAL AQUACULTURE ENTERPRISES IN Pacific Salmon Hatchery Programs in the Green River .......................................... ............................... 47 Number of Juvenile Atlantic Salmon Observed in the Pacific Northwest ............... ............................... 48 OTHER EVALUATIONS OF POTENTIAL RISKS FROM CULTURED ATLANTIC SALMON IN Stateof Washington Agencies ............................................................................ ............................... PUGET SOUND CHINOOK SALMON AND HOOD CANAL SUMMER -RUN CHUM SALMON FederalAgencies ................................................................................................. ............................... ESUs............................................................................................................................ ............................... 49 Washington State Pollution Control Hearings Board .............................................. ............................... 49 Washington Department of Fish and Wildlife Atlantic Salmon Management Perspective .................... 50 NMFS Biological Status Reviews of West Coast Pacific Salmon Stocks ............... ............................... 50 POTENTIAL IMPACTS OF SALMON FARMS IN PUGET SOUND ON ESSENTIAL FISH HABITAT.................................................................................................................... ............................... 51 WaterColumn Impacts ............................................................................................ ............................... 51 Comparison to Benthic Impacts of Other Activities in the Pacific Northwest ........ ............................... 52 SewageTreatment Plants .................................................................................... ............................... 52 FishProcessing Plants ......................................................................................... ............................... 52 SCALE AND IMPACTS OF SIMILAR ACTIVITIES IN PUGET SOUND ............. ............................... 55 Scale of Salmon Farms and Other Aquaculture ...................................................... ............................... 55 SalmonFanns ...................................................................................................... ............................... 55 OvsterFarms ....................................................................................................... ............................... 56 Scale and Impacts of Marinas in Puget Sound ........................................................ ............................... 56 Scaleof Marina Development ............................................................................. ............................... 56 Environmental Impacts of Marinas ..................................................................... ............................... 56 ESSENTIAL FISH HABITAT AND THE MAGNUSON- STEVENS ACT ................ .............................59 REGULATORY STRUCTURE FOR COMMERCIAL AQUACULTURE ENTERPRISES IN WASHINGTONAND PUGET SOUND .................................................................... ............................... 61 Agencies Regulating Salmon Farming in Washington ............................................ ............................... 62 Stateof Washington Agencies ............................................................................ ............................... 62 FederalAgencies ................................................................................................. ............................... 64 The Regulatory Structure for Public and Tribal Hatcheries in Washington ............ ............................... 64 CONCLUSIONS REGARDING POTENTIAL IMPACTS OF ATLANTIC SALMON CULTURE IN PUGETSOUND ............................................................................................................ .............................6i CITATIONS................................................................................................................ ............................... 67 i Vll LIST OF TABLES Table 1. Percent survival to hatch from various Atlantic salmon x Pacific salmon crosses, or interspecific Pacific salmon x Pacific salmon crosses, using a small number of eggs (less than 500) ...................11 Table 2. Percent survival to hatch from various Atlantic salmon x Pacific salmon crosses, using a large number of eggs (more than 2, 000) ........................................................................ .............................11 Table 3. Number of juvenile Atlantic salmon observed in British Columbia freshwater areas, 1996- 2001 ............................................................................................................. .............................19 Table 4. Facilities (% in state or agency) testing positive for various salmonid diseases (July 1988 -June 1993) . ................................................................................................................................................. 24 Table 5. Number (in millions) of salmon released or escaped by species and location along the West Coast of North America, 1980 - 1995 ................................................................... ............................... 30 Table 6. Status of non - native fish introductions in the Pacific Northwest and their behavior relative to Pacificsalmonids ................................................................................................... .............................40 �G lx EXECUTIVE SUMMARY This document examines the potential of Atlantic salmon farming in Puget Sound to impose adverse impacts on the Puget Sound chinook salmon (Oncorhynchus tshawytscha) and Hood Canal summer -run chum salmon (O. keta) evolutionarily significant units (ESUs), both of which were listed as "threatened" under the federal Endangered Species Act (ESA) by the National Marine Fisheries Service (NMFS) in March 1999. The threatened status of these populations requires that all activities that may harm the fish or their critical habitat be limited such that they do not appreciably reduce the likelihood for recovery of the ESUs in the wild. Many of the activities that may lead to the take of listed salmon in Puget Sound, including the artificial propagation of salmonids in hatcheries and marine enclosures, will have effects that are incidental to otherwise lawful activities. Among such activities is the private culture of Atlantic salmon. This document presents the best scientific and commercial information available to evaluate the possible effects of salmon farming on listed chinook and summer -run chum salmon populations, and will provide the scientific basis for federal regulatory agency direction for the appropriate management of the industry in Puget Sound. Much of the available scientific information pertaining to salmon aquaculture was produced by NMFS in furtherance of its national mandate to advocate environmentally sustainable aquaculture through research, technology development, financial assistance, and regulatory programs. Locally, Washington State policies also recognize aquaculture as a legitimate and beneficial use of its coastal waters. By reason of NMFS' concomitant responsibilities to conserve Pacific salmon species, especially those listed under the ESA, the agency has also collected, analyzed, and published a significant amount of scientific information relevant to the specific issue of Atlantic salmon impacts on federally listed Pacific salmon. After conducting several scientific reviews of Washington's Atlantic salmon farming industry, including the present one, NMFS concluded that the operations can be managed to minimize risks to local salmon populations. In particular, NMFS found that Washington State regulation of the industry provides adequate protection to stocks of Pacific salmon listed under the ESA. Nonetheless, there are legitimate issues associated with hatchery- reared salmon and trout that end up in natural ecosystems, either by deliberate release or by escape from the rearing facility. Concerns regarding the artificial propagation of salmon and trout in the Pacific Northwest have been expressed numerous times in recent years, focused primarily on Pacific salmon hatcheries. However, concerns about the potential adverse impacts of private trout and Atlantic salmon culture in Washington have been expressed as well. Uncertainty about genetic and ecological interactions and the transmission of disease among Atlantic and Pacific salmon are the most commonly voiced concerns. It should be understood that this review does not intend to evaluate potential risks associated with Atlantic salmon farming anywhere in the world except Puget Sound, Washington. Also, social issues related to salmon farming in Puget Sound are not discussed. Much of the material presented here has been taken from previous NMFS evaluations of the risks of Atlantic salmon in Pacific coast states or from NMFS' ESA - related status reviews of West Coast salmonids. x The conclusions regarding the potential impacts of Atlantic salmon culture on the Puget Sound chinook salmon and Hood Canal summer -run chum salmon ESUs are based on three important assumptions. The first assumption is that the salmon farming industry in Puget Sound remains approximately the same size as currently or in the recent past. A significant expansion of the industry may increase risks and would require a reconsideration of some of the potential impacts discussed in this review. The second assumption is that salmon farms in Puget Sound continue to rear only Atlantic salmon. Should the local industry shift production to coho or chinook salmon or to steelhead (O. mykiss), the risks for hybridization, dilution of the gene pool, colonization, and competition for natural resources with wild salmonids will be greater than they are now with Atlantic salmon culture. Third, these conclusions assume that Atlantic salmon farmers in Washington continue to use only stocks presently in culture and that no new Atlantic salmon stocks are brought into the State. Based on these assumptions, this review arrives at the following risk assessment conclusions: It finds no risk for one parameter, low risk for several parameters, little risk for other parameters, and no parameters for which the potential impacts from Atlantic salmon farms in Puget Sound are considered to be serious or even moderate. The review finds no risk of adverse genetic interaction from transgenic salmon because there are currently no transgenic salmon being commercially cultured in Washington and there are no plans to do. For several parameters, the risks associated with escaped Atlantic salmon are low, in particular: • The expectation that Atlantic salmon will increase current disease incidence in wild and hatchery salmon is low. The risk that escaped Atlantic salmon will compete with wild salmon for food or habitat is low, considering their well -known inability to succeed away from their historic range. The risk that salmon farms will adversely impact Essential Fish Habitat is low, especially when compared to other commonly accepted activities that also occur in nearshore marine environments. For other parameters, there appears to be little risk associated with escaped Atlantic salmon, in particular: • There is little risk that escaped Atlantic salmon will hybridize with Pacific salmon. • There is little risk that Atlantic salmon will colonize habitats in the Puget Sound chinook salmon and Hood Canal summer -run chum salmon ESUs. • There is little risk that escaped Atlantic salmon will prey on Pacific salmon. • There is little risk that existing stocks of Atlantic salmon will be a vector for the introduction of an exotic pathogen into Washington State. • There is little risk that the development of antibiotic - resistant bacteria in net -pen salmon farms or Atlantic salmon freshwater hatcheries will impact native salmonids, as similar antibiotic resistance often observed in Pacific salmon hatcheries has not been shown to have a negative impact on wild salmon. X1 ACKNOWLEDGMENTS The authors thank the following individuals, who kindly provided information and assistance that was essential to the completion of this document: Donald Noakes and Andrew Thomson of the Department of Fisheries and Oceans Canada; Peter Granger and Kevin Bright of the Washington Fish Growers Association; Robert Kope and Lee Harrell of NMFS; Jim Parsons of Troutlodge, Inc.; Andy Appleby and Dave Seiler of the Washington Department of Fish and Wildlife; and Tim Wheeler of the Port of Seattle. The authors also give special thanks to the individuals who provided critical comments on draft versions of this document: Kevin Amos, Tom Good, Jeff Hard, Peter Kareiva, and Conrad Mahnken of NMFS; Reginald Reisenbichler of the U.S. Geological Survey; Donald Noakes, Trevor Evelyn, and Andrew Thomson of the Department of Fisheries and Oceans Canada; Mart Gross, University of Toronto; Ian Fleming, Oregon State University; Kenneth Brooks, Aquatic Environmental Sciences, Inc.; and Donald Campton, U.S. Fish and Wildlife Service. The conclusions and recommendations in this document are those of the authors and do not necessarily reflect the opinions of the reviewers. INTRODUCTION In response to the depleted status of naturally produced chinook salmon (Oncorhynchus tshawytscha) and certain summer -run chum salmon (O. keta) in the Puget Sound region of Washington State, the National Marine Fisheries Service (NMFS) listed the populations as "threatened" under the U.S. Endangered Species Act (ESA) of 1973 in March 1999. The populations or evolutionarily significant units (ESUs) (Waples 1991) listed for protection under the provisions of the Act were the Puget Sound chinook salmon ESU and the Hood Canal summer -run chum salmon ESU. Subsequent to these listings, NMFS designated critical habitat necessary for the recovery of the populations to healthy levels. The Puget Sound chinook salmon ESU's critical habitat generally includes all freshwater areas accessible to anadromous salmon in the Puget Sound region, as well as the marine waters of Puget Sound. Critical habitat for the Hood Canal summer -run chum salmon ESU is encompassed within the area designated for chinook salmon. Intent of Present Document The ESA - listing status of these populations as threatened requires that all activities that may harm the fish or their critical habitat be limited such that they do not appreciably reduce the likelihood for the survival and recovery of the ESUs in the wild. In particular, Section 9 of the ESA and federal regulations pursuant to Section 4(d) of the ESA prohibit the direct or incidental "take" of endangered and threatened salmon species, respectively, without special exemption from NMFS. "Take" is defined as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to engage in any such conduct. "Harass" is defined as intentional or negligent actions that create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior patterns which include, but are not limited to, breeding, feeding, or sheltering. "Harm" is defined to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns, including breeding, feeding, or sheltering. The majority of activities that may lead to the take of listed salmon in Puget Sound will have effects that are incidental in nature. Incidental takes are defined as takes that are incidental to, and not the purpose of, carrying out an otherwise lawful activity. NMFS evaluation and authorization for incidental takes of listed salmon may be provided through several avenues under the ESA. Section 7 of the ESA provides for the authorization of incidental takes associated with federal or federally funded actions through the completion of a consultation with NMFS to evaluate the effects of a proposed action. Successful completion of the consultation would lead to a determination by NMFS that the federal action does not jeopardize the continued existence of a listed population, or destroy or adversely modify its critical habitat. Non - federal entities may apply for permits from NMFS to incidentally take ESA - listed species under Section 10(a)(1)(B) of the ESA. A Section 10(a)(1)(B) permit shall be issued to a non - federal entity if NMFS finds: 1. The taking will be incidental. 2 2. The applicant will, to the maximum extent practicable, minimize and mitigate the impacts of such taking. 3. The applicant will ensure that adequate funding for a species "Conservation Plan," required for submittal with the take application, will be provided. 4. The taking will not appreciably reduce the likelihood of the survival and recovery of the species in the wild. 5. Any other measures that the Secretary of Commerce may require as being necessary or appropriate will be met. Completed Section 7 consultations and Section 10 permits generally include measures, terms, and conditions required to limit or further minimize the incidental takes that may occur through the proposed action requiring authorization. An additional means by which takes of recently listed threatened species, including Puget Sound chinook salmon and Hood Canal summer -run chum salmon, may be evaluated and authorized by NMFS is through the ESA Section 4(d) Rule issued for these species (50 Code of Federal Regulations 223.203 — 65 Federal Register 42422, July 10, 2000). Under the Rule, ESA Section 9 take prohibitions do not apply to actions that are in compliance with criteria specified in the Rule that insure consistency with ESA requirements, and that avoid or minimize the risk of take of listed threatened salmon. NMFS has identified 13 programs or subsets of activities in the Rule that are conducted in a way that contribute to conserving the listed ESUs, and where NMFS determines that added protection through federal regulation is not necessary or advisable for conservation of the ESU. Included in the 13 programs or "limits" is a category that limits application of take prohibitions to activity associated with salmonid artificial propagation programs, provided that such activity complies with certain criteria specified under the 4(d) Rule limit (50 CFR 223.203(b)(5)(i)). Among the activities in the Puget Sound region that are now subject to federal prohibitions on the take of listed salmon and the need for NMFS evaluation and authorization of listed fish effects is the private Atlantic salmon (Salmo salar) aquaculture industry. The purpose of this review is to gather the best scientific and commercial information available to evaluate and determine the likely effects of Atlantic salmon aquaculture in the region on the survival and recovery of the listed chinook and summer -run chum salmon populations. It will also serve to indicate appropriate measures recommended by the NMFS Northwest Fisheries Science Center for minimizing risks of Atlantic salmon aquaculture to the listed salmon populations. This document will therefore provide the scientific basis for federal regulatory agency direction for the appropriate management of the industry in Puget Sound for listed salmon protection purposes. However, it is mainly intended to serve as the key resource for subsequent NMFS evaluation under the ESA of the specific, private Atlantic salmon aquaculture operations in the Puget Sound region for effects on listed fish. These site - specific NMFS evaluations will determine whether individual operations may be authorized for takes through the ESA Section 7 or Section 10 permit processes, or for limits on listed fish take prohibitions under the new ESA Section 4(d) Rule for the listed chinook and summer -run chum salmon populations. Concerns Regarding Salmon Farming in Puget Sound The artificial propagation of salmon and trout in the Pacific Northwest has come under increasing scrutiny in recent years. This is due to the recognition that hatchery- cultured salmon and trout have the potential to adversely impact natural populations (Busack and Currens 1995, ODFW 2000). Although the greater weight of attention has been focused on the large complex of federal, state, tribal, and cooperative Pacific salmon hatcheries in western states, concerns about the potential adverse impacts of private trout and Atlantic salmon culture in Washington have been expressed by some scientists and fisheries managers, as well as by some advocacy groups and the popular media (print and internet). Uncertainty about genetic and ecological interactions and the transmission of disease among Atlantic and Pacific salmon are most commonly voiced. In testimony before the Washington State Pollution Control Hearings Board (PCHB 1997a), it was stated that Atlantic salmon had the potential for hybridization with Pacific salmon, based on a recent unpublished Canadian laboratory study, and that it was not impossible that the 369,000 Atlantic salmon which escaped into Puget Sound in 1997 would produce 10 million healthy smolts in local rivers (PCHB 1997b). The Marine Environmental Consortium, a coalition of Northwest environmental advocacy groups, considers escaped Atlantic salmon a serious threat to endangered species in Puget Sound, according to its spokesperson, Barbara Stenson (Le 1999). Assertions such as University of Victoria student John Volpe's that "native stocks will have to move aside to make room for a new exotic" have appeared in the popular press (Marsh 1999). Dale Kelly, executive director of the Alaska Troller's Association, declared that the impacts of escaped Atlantic salmon on Pacific salmon were frightening (Dobbyn 2001). Tom Geiger, outreach director of the Washington Environmental Council, said Atlantic salmon compete for food and shelter with native fish that are already struggling for survival (Morente 2001). The Alaska Department of Fish and Game has expressed concern that escaped Atlantic salmon from salmon farms in Washington State and British Columbia, Canada, will compete with wild salmon and spread diseases and parasites for which Pacific salmon have little resistance (ADF &G 1999). A letter a constituent sent to U.S. Senator Ted Stevens of Alaska read in part, "The continued introduction of Atlantic salmon to the marine habitat of British Columbia and Washington State will inevitably have negative biological impacts. These will include displacement, hybridization, and the introduction of alien... disease" (Gilbertsen 1997). Scope of Literature Review This paper reviews the potential risks from escapes of Atlantic salmon into the Puget Sound chinook salmon ESU and the Hood Canal summer -run chum salmon ESU, both of which are listed as threatened under the ESA. These hypothetical risks include the potential for escaped Atlantic salmon to interbreed with, displace, compete with, or prey upon listed Puget Sound chinook salmon or Hood Canal summer -run chum salmon. It is imperative to understand that this review pertains to potential impacts in just these two ESUs and is not intended to be an evaluation of potential biological risks associated with Atlantic salmon farming anywhere in the world except Puget Sound, Washington. Since regulatory and management policies, ecological factors, and biological and geophysical parameters are not uniform worldwide, potential adverse 11 biological impacts of artificially propagated Atlantic salmon on Pacific salmon in Puget Sound may not be the same as Atlantic salmon impacts observed in other parts of the world, especially in locations where Atlantic salmon are native. Social issues related to salmon farming in Puget Sound, such as the decline in consumer price of wild Pacific salmon due to free market competition from farmed salmon, are not addressed, as they do not pertain to potential risks for ESA - listed salmonids. Specific sections of this paper review the literature concerning risks of hybridization between Atlantic and Pacific salmon, the colonization of aquatic environments by Atlantic salmon, and interactions of wild salmon and genetically altered transgenic salmon. A section concerning occurrence and transmission of waterborne salmon disease reviews the risk that cultured Atlantic salmon will introduce diseases into Puget Sound ecosystems. Information regarding genetic consequences and disease incidences associated with artificially propagated Pacific salmon are presented to provide a perspective against which to evaluate the potential adverse impacts of farmed Atlantic salmon for these same elements. The potential for adverse ecological impacts of escaped Atlantic salmon in the Pacific Northwest, specifically, competition for food and space, and predation, are then reviewed. That is followed by a summary, for comparative purposes, of known adverse ecological impacts associated with artificial propagation of Pacific salmon in the Pacific Northwest. For additional perspective, a review of impacts of other nonindigenous fish species in the Pacific Northwest is given, followed by a comparison of the number of artificially propagated Atlantic and Pacific salmon found in natural environments (by escape or release) on the West Coast of North America. Reviews of previous evaluations of the potential adverse impacts of escaped Atlantic salmon in Puget Sound are then presented. These include the findings of the PCHB and a perspective on escaped Atlantic salmon from the Washington Department of Fish and Wildlife (WDFW). In addition, a brief review of the potential impact of salmon farms on Essential Fish Habitat (EFH) is provided. The volume of solid waste discharged from salmon farms onto EFH and the amount of solid waste discharged from fish processing plants onto EFH are presented to provide a comparison of the amount of nearshore wastes produced by two different methods of fish production. The scale of marina development in Puget Sound is examined for comparison to an activity which uses similar nearshore habitat and also has the potential for environmental impacts on salmon EFH. Pertinent excerpts from the Artificial Propagation of Fish and Shellfish section of the EFH Provision of the Magnuson- Steven Fisheries Conservation and Management Act are presented. Finally, a list of managing agencies and specific regulations pertaining to private and public aquaculture in Puget Sound is presented to show current government oversight of salmon farming. Previous Investigations of Salmon Farming in the Pacific Northwest Much of the material presented here has been taken from previous NMFS evaluations of the risks of Atlantic salmon in Pacific coast states or from NMFS' ESA - related status reviews of West Coast salmonids. These evaluations include: The Net -Pen Salmon Farming Industry in the Pacific Northwest, by the Resource Enhancement and Utilization Technologies Division of the Northwest Fisheries Science Center (Nash 2001), and oral and written testimony (oral by Conrad Mahnken, written by William Waknitz, both of the Northwest Fisheries Science Center's Manchester Research Station) before the Washington State Senate on September 16, 1999. In addition, material from recent salmon farming reviews by the PCHB and WDFW is included in the present review. 7 ORIGIN OF ATLANTIC SALMON STOCKS IN PUGET SOUND Beginning in 1971, scientists from the NMFS Northwest Fisheries Science Center tested the feasibility of rearing New England stocks of Atlantic salmon in seawater net -pens in Puget Sound to provide 3.5 million eyed eggs annually for restoring depleted runs in southern New England as part of a cooperative effort between the U. S. Fish and Wildlife Service (USFWS) and NMFS (Mighell 1981, Harrell et al. 1984). Between 1971 and 1983, NMFS received eggs from many North American stocks, including the Grand Cascapedia River in Quebec (via Oregon State), and the Penobscot, Union, St. John, and Connecticut rivers in the United States. Prior to the transfer of eggs from New England to Washington, all Atlantic salmon eggs sent to the NMFS Manchester Research Station were examined according to the Code of Federal Regulations (50 CFR) and certified by federal pathologists to be free of bacterial and viral pathogens. However, few eggs were ever sent back to New England due to the reluctance of East Coast fisheries managers to accept eggs from Atlantic salmon which had been grown in waters inhabited by Pacific salmon and thereby exposed to indigenous Puget Sound salmon diseases. A panel of New England state and federal fisheries officials meeting at Newton Corner, Massachusetts, in March 1984 determined that the risk of introducing Pacific salmon diseases to New England Atlantic salmon populations due to raising Atlantic salmon in the proximity of Pacific salmon in Puget Sound was great and had rendered the eggs unfit for transfer back to the East Coast. As a result of this decision, millions of Atlantic salmon eggs originally meant for New England restoration programs were available for distribution to salmon farmers in Washington. These eggs proved to be a boon to the local industry as, by this time, it was clear that Atlantic salmon grown in Puget Sound salmon farms were superior to the coho salmon (O. kisutch) originally used by local salmon farmers in all aspects of culture, including survival to hatch, growth rate in freshwater and seawater enclosures, size at harvest, and contrary to East Coast opinion, resistance to infectious diseases (Mighell 1981, Waknitz 1981, Amos and Appleby 1999). In Washington now about 67.5 total hectares (ha) are leased by companies for commercial salmon net -pens, although not all the leased area is being used (WDNR 2001). The leased area extends to the perimeter of the anchoring system, so the actual area covered by floating structures is much less. The 10 commercial sites currently operational in Puget Sound have a total of 53 ha under lease from the State (ranging in size from 0.8 to 9.7 ha per site), with a total of 8.7 ha permitted for internal pen structures for all Puget Sound salmon farms combined (range 1,951 m2 to 15,793m2) (K. Bright). ' K. Bright, Washington Fish Growers Association, 10420 173rd Ave. SW, Rochester, WA 98579. Pers. commun., February 12, 2001. E POTENTIAL GENETIC IMPACTS OF ATLANTIC SALMON CULTURE IN THE PUGET SOUND CHINOOK AND HOOD CANAL SUMMER -RUN CHUM SALMON ESUs Potential Genetic Interactions of Artificially Propagated Pacific and Atlantic Salmon A major concern with artificial propagation of salmonids in hatcheries, which includes the farming of Pacific salmonids and Atlantic salmon, is the potential genetic effects of released fish (hatcheries) and inadvertent escapees (farming) on native salmonids. For the salmon farming industry in British Columbia, where both Pacific and Atlantic salmon are extensively farmed, a recent study listed three major areas of concern (EAO 1997): • Hybridization between Atlantic and Pacific salmon • Genetic dilution and alteration of the wild salmonid gene pool • Interactions between wild salmon and genetically altered transgenic salmon These concerns are both geographically and species specific. For private aquaculture in Puget Sound net -pens, the concerns expressed by citizen groups and agencies have been primarily associated with farmed Atlantic salmon, as Pacific salmon, with rare exception, are not cultured by private enterprises. Hybridization between Atlantic and Pacific Salmon Potential Genetic Compatibility No genetic compatibility between Atlantic salmon (genus Salmo) and wild Pacific salmon (genus Oncorhynchus) has been reported in the Pacific Northwest or elsewhere. Similarly, under controlled and protected laboratory conditions, where survival of hybrid offspring should be optimized, genetically viable hybrids between Atlantic and Pacific salmonid species have been impossible to produce. Refstie and Gjedrem (1975), Sutterlin et al. (1977), and Blanc and Chevassus (1979, 1982) found that crosses between Atlantic salmon and rainbow trout (O. mykiss) failed to produce any viable progeny. A similar lack of survival was observed in attempted hybridization of Atlantic salmon and coho salmon ( Chevassus 1979) and Atlantic salmon and pink salmon (O. gorbuscha) (Loginova and Krasnoperova 1982). Gray et al. (1993) attempted to produce diploid and triploid hybrids by crossing Atlantic salmon with chum and coho salmon and rainbow trout. All embryos died in early developmental stages, leading to the conclusion that hybridization of Atlantic salmon with Pacific salmon species was unlikely to happen. Recently, two pilot studies from British Columbia have provided more data regarding the lack of genetic compatibility between Atlantic and Pacific salmon (R. Devlin, Department of Fisheries and Oceans Canada, reported in Alverson and Ruggerone 1997). In the first study using a small number of eggs, crosses with Atlantic salmon produced a few hybrids with pink 10 salmon, but no hybrids with coho, chum, chinook, sockeye salmon (O. nerka), and rainbow trout (Table 1). In the same experiment, by contrast, the interspecific crosses between Oncorhynchus species produced hybrids with survivals to hatch ranging from 10 to 90% in 15 of the 42 crosses, with each species of Pacific salmon readily producing hybrids with between 2 and 5 other Pacific salmon species, confirming previous observations of this genus (Foerster 1935, Seeb et al. 1988). It should be noted that because of dissimilar spawning times between Atlantic salmon (fall spawning) and steelhead (spring spawning) (O. mykiss), this particular cross was performed using cryopreserved Atlantic salmon sperm. In the second study using a larger number of eggs, and involving crosses between Atlantic salmon and rainbow and steelhead trout, coho, chum, chinook, and pink salmon, a few hybrids were also produced (Table 2). It should be noted that because of dissimilar spawning times between Atlantic salmon (fall spawning) and cutthroat trout (winter spawning) (O. clarki), this particular cross was performed using cryopreserved Atlantic salmon sperm. Approximately 6.1% of the steelhead x Atlantic salmon, and 0.02% of the pink salmon x Atlantic salmon hybrids survived to the hatching stage. Surviving progeny exhibited deformities such as curvature of the spine and none of the survivors showed any signs of maturity after four years (Noakes et al. 2000). The results pertaining to survival to the hatching stage were presented as evidence of hybridization potential between Atlantic salmon and Pacific salmon in hearings before the PCHB (PCHB 96 -257 -266, and 97 -110, 1998). However, the PCHB found that evidence of hybridization was not supported by this study, and there was no reasonable potential for hybridization between escaped Atlantic salmon and native Pacific salmon in Puget Sound based on current knowledge and behavior (PCHB 1998). No concerns about these studies' evidence of hybridization potential resulting from the introduction of hatchery stocks of Pacific salmonids into natural habitats were addressed to the PCHB or voiced in the popular press, despite the readily produced hybrids in Pacific salmon compared to the low percentage of survival to hatch observed between the Atlantic salmon x pink salmon cross (Table 1). The few Atlantic x steelhead hybrids produced resulted from experiments conducted in vitro, and actual Atlantic /steelhead hybridization would probably not happen under natural conditions (no cryopreservation) in Washington State. The Atlantic salmon stocks used in Washington begin spawning in early October and have finished spawning by the end of November (Waknitz unpubl. data). Wild steelhead in western Washington spawn from March through June (Freymond and Foley 1985). Therefore, there is virtually no opportunity for Atlantic salmon to spawn with native steelhead outside the laboratory. Atlantic salmon x Pacific salmon hybrids have not been observed in other regions of North or South America or New Zealand. In eastern North America, non - native rainbow trout have been successfully introduced into 12 states or provinces within the natural range of Atlantic salmon (MacCrimmon 1971). No naturally produced hybrids have been reported in the 30 to 100 years subsequent to this occurrence, even though many adult Atlantic salmon are examined at weirs and traps sometime during their upstream migration (NMFS/USFWS 1999). Similarly, no hybrids between Atlantic salmon and brown trout (Salmo trutta), rainbow trout or brook trout (Salvelinus fontinalis) have been reported in South America or New Zealand, where all four of these species are not native to those locations (MacCrimmon 1971, Lever 1996). 11 Table 1. Percent survival to hatch from various Atlantic salmon x Pacific salmon crosses, or interspecific Pacific salmon x Pacific salmon crosses, using a small number of eggs (less than 500). (Data from EAO 1997.) Intraspecific crosses (nonhybrids) are in bold. Female: Male: Atlantic Sockeye Churn Pink Coho Chinook Rainbow trout Atlantic 64.1 0.0 0.0 0.0 0.0 0.0 0.0 Sockeye 0.0 88.4 90.9 16.9 0.0 0.-1 0.0 Chum 0.0 61.9 94.9 85.7 0.0 0.0 0.0 Pink 5.5 77.7 54.2 83.9 14.9 93.2 15.8 Coho 0.0 82.9 0.0 1.5 73.3 0.0 0.7 Chinook 0.0 4 3. 2 3 5. 3 64.3 52.3 94.3 10.6 Rainbow trout 0.0 0.0 0.0 0.0 0.0 0.0 54.6 Table 2. Percent survival to hatch from various Atlantic salmon x Pacific salmon crosses, using a large number of eggs (more than 2,000). (Data from EAO 1997.) Crosses not attempted are represented by a blank cell. Female: Atlantic Sockeye Chum Steelhead Pink Coho Chinook Cutthroat Rainbow Male: Trout Atlantic 0.012 0.12 6.07 0.018 0.00 0.012 0.00 0.098 Sockeye 0.00 Chum 0.014 Steelhead 0.0012 Pink 0.36 Coho 0.014 Chinook 0.023 Cutthroat 0.00 Rainbow 0.0017 12 No natural hybrids between Atlantic salmon and Pacific salmonids have been reported in Europe, despite the fact that introduced rainbow /steelhead trout, brook trout, coho salmon, and pink salmon have all established naturalized populations to some degree within the native range of Atlantic salmon on the European continent (MacCrimmon and Campbell 1969, MacCrimmon 1971, Berg 1977, Lever 1996). Potential Contribution from Precocious Male Atlantic Salmon It has been suggested that spawning escaped Atlantic salmon may produce precocious male Atlantic salmon which will attempt to breed with Pacific salmon. It was hypothesized that, while not actually capable of producing hybrids, these precocious males might produce genetic disturbances by interfering with wild salmonid breeding behavior, and by beating Pacific salmon males to the eggs in the redd, produce nonviable eggs that would reduce the number of juvenile salmonids available for recruitment in depressed populations (Group Participants 2001). Although it is possible that this could happen in some locations, the risk of this scenario occurring in Puget Sound tributaries is low for a number of reasons. First, salmon farmers in Puget Sound use Atlantic salmon derived from stocks provided to them by NMFS in the mid- 1980s, primarily Penobscot River and Grand Cascapedia River strains. The Penobscot River hatchery strain is known to have a remarkably low incidence of early maturity, either after 1 or 2 years in freshwater (precocious male parr), or at 2 or 3 years of age (1 year at sea), known as grilse (Ritter et al. 1986). Since age at maturity is a genetically inherited trait which can then be influenced by changes in environmental conditions (Randle et al. 1986), the Penobscot River Atlantic salmon strain now used in Puget Sound salmon farms begins with an especially low potential for adverse impacts from precocious males, assuming that naturally spawned juvenile male Atlantic salmon ever become numerous in Puget Sound tributaries. Second, smoltification and early male maturity are mutually exclusive events (Thorpe 1986), and precocious parr Atlantic salmon do not survive transfer to full strength seawater (Waknitz unpubl. data), due primarily to the fact that they have invested their metabolic resources in producing gametes instead of acquiring the ability to osmoregulate in seawater. Therefore, precocious parr are directly selected against in Puget Sound domesticated Atlantic salmon populations every generation at the time of transfer to seawater, where they are eliminated from that particular brood. Third, protocols common to salmon farming also directly, if inadvertently, select against the production of precocious male Atlantic salmon in local salmon farms. To reduce freshwater rearing costs, local salmon farmers cull juveniles which do not smolt at 1 year of age. This serves to select against early maturity because 1- year -old smolts are known to produce fewer precocious parr and grilse than 2- year -old smolts (Ritter et al. 1986). Furthermore, Atlantic salmon that mature as grilse after only 1 year in seawater are not retained for broodstock by growers in Puget Sound because fish that never grow to a large size are not as profitable as those that do. Grilse are known to produce more precocious parr than older Atlantic salmon (Ritter et al. 1986). 13 Fourth, it may not be a cause for concern that low population abundance in some Pacific salmon stocks might create conditions favorable to hybridization by male Atlantic salmon parr, if any are ever produced in Puget Sound tributaries. In a study of wild Atlantic salmon and brown trout in Newfoundland, McGowan and Davidson (1992) found that it was unlikely that a disparity in species abundance was a principal cause of interspecific hybridization by Atlantic salmon. Therefore, the unusually low incidence of early maturity in the Atlantic salmon strain from the Penobscot River, which Ritter et al. (1986) noted as "striking" compared to the much higher incidences of early maturity observed in nearby Canadian populations in Quebec and New Brunswick, has been further reduced by generations of directed selection by Puget Sound salmon farmers against this particular life - history type. Similarly, no precocious parr were observed in several generations of the Grand Cascapedia River population held at the NMFS Manchester Research Station between 1971 and 1983 prior to this stock being made available to the public (Mighell 1981, Waknitz unpubl. data). Hybridization between Atlantic Salmon and Brown Trout While viable hybrids between Atlantic salmon and the Pacific salmonid species are difficult to produce in the laboratory and have not been observed in natural environments, hybrids between Atlantic salmon and a congeneric species, the brown trout, are relatively successful. Viable Atlantic salmon x brown trout hybrids in the laboratory have been reported by Suzuki and Fukuda (1971), Refstie and Gjedrem (1975), and Blanc and Chevassus (1982). Successful hybridization under natural conditions has been reported in many European countries where brown trout are native, and also in North America where the brown trout has been introduced (Verspoor and Hammar 1991). The frequency of natural Atlantic salmon x brown trout hybrids in Europe and North America ranges from 0.1 to 13.2% of juveniles in river systems (Jordan and Verspoor 1993) and appears to be increasing relative to pre - aquaculture levels in Europe (Hindar et al. 1998). McGowan and Davidson (1992) cite the breakdown in pre- reproductive isolating mechanisms in Newfoundland (abundance of mature Atlantic salmon parr) as the principal mechanism for such natural hybridization between wild brown trout and wild Atlantic salmon. Hindar et al. (1998) reported that although a disproportionate number of hybrids were the product of pairings involving Atlantic salmon females, there was no evidence that escaped farmed Atlantic salmon females produced more hybrids than wild females. Youngson et al. (1993), on the other hand, had previously reported that escaped females in western and northern Scotland rivers hybridized with brown trout more frequently. Wilkins et al. (1993) found that male hybrids were fertile, and when back - crossed with female Atlantic salmon, produced about 1% diploid progeny. Galbreath and Thorgaard (1995) reported that back - crosses between male diploid, male triploid, and female diploid Atlantic salmon x brown trout hybrids and both parental species produced either nonviable or sterile progeny. Brown trout have established naturalized populations in many locations in the Columbia River basin (Wydoski and Whitney 1979, WDFW 2002) and in about a dozen rivers and lakes on Vancouver Island (Idyll 1942, Lever 1996, Wightman et al. 1998, BC. com 2001). Brown trout in the mid - Columbia River region above Bonneville Dam and below Grand Coulee Dam are so large they are commonly mistaken for adult Chinook salmon (Shangle 2001). However, no 14 reports of hybridization between introduced brown trout and native Pacific salmon in these areas were found in this literature review, despite the fact that many of these brown trout populations have been naturalized in these locations for over half a century, during which time local native and hatchery populations of salmonids have been subject to frequent observations. No scientific or media reports expressing apprehension about brown trout x Pacific salmon hybrids were found in the process of this review, suggesting that hybrids resulting from escaped Atlantic salmon are viewed as a threat to wild Pacific salmon in the Pacific Northwest, while the same hypothetical threats that could also be associated with brown trout have either been accepted or not recognized. The propensity of Atlantic salmon to produce successful hybrids with brown trout and not with Pacific salmonids may be related to the phylogenetic distance between the two groups. Neave (195 8) postulated that the putative ancestors of the Salmo group migrated to the Pacific 600,000 to 1,000,000 years ago, were subsequently isolated by land bridges, and evolved to the ancestral Oncorhynchid form. The ancestral form subsequently developed to form the separate Oncorhynchus species (Simon 1963). McKay et al. (1996), based on DNA sequence analysis of growth hormone type -2 and mitochondrial NADH dehydrogenase subunit 3 gene, estimated that, at a minimum, the major divergence between the genus Salmo and the genus Oncorhynchus occurred 18 million years ago, while speciation within the genus Oncorhynchus began about 10 million years ago. Hybridization among Pacific Salmon Attesting to their phylogenetic similarity, interspecific hybrids within the Oncorhynchids are relatively successful, as noted above. Foerster (1935) was among the first to report successful hybrids between controlled matings of sockeye, chum, pink and chinook salmon. Two -year -old chum salmon x pink salmon hybrids released from a hatchery in Puget Sound returned at a higher rate than pure pink salmon (Simon and Noble 1968). However, as Simon and Noble (1968) observed: "The fact that hybrids can be produced artificially is of little consequence to natural circumstances unless: (a) fertility of the hybrids is evident, and; (b) the same crosses occur in nature." These requirements were met in crosses of chum and pink salmon in British Columbia, where natural hybrids have been observed (Hunter 1949). On the whole, however, reports of natural hybrids among anadromous salmonids have been limited. Bartley et al. (1990) reported on natural hybridization between Chinook and coho salmon in a northern California river, and Rosenfield (1998) reported a natural pink x chinook salmon hybrid from the St. Mary's River in Michigan. The situation for non - anadromous salmonids is very different. Hybridization between introduced rainbow trout and native cutthroat trout appears to be almost ubiquitous throughout the interior part of western North America, and has been enormously detrimental to the latter species (Gresswell 1988, Behnke 1992). Genetic Dilution and Alteration of the Wild Salmon Gene Pool Adverse genetic and ecological effects on wild Atlantic salmon populations due to releases or escapes of artificially propagated Atlantic salmon from public hatcheries and private net -pens have been reported in Norway, Scotland, Ireland, and the Canadian Maritime Provinces. 15 For wild, native Atlantic salmon, these include a reduction in their genetic diversity and capacity to evolve, a result of dilution of genetic diversity by interbreeding with artificially propagated fish, and direct competition for food and space (Einum and Fleming 1997, Gross 1998). Such adverse effects happened in Europe and eastern North America because both the cultured and wild fish were Atlantic salmon. However, Atlantic salmon escaping into the Puget Sound and Hood Canal ESUs for chinook and summer -run chum salmon will not have conspecific or congeneric wild individuals with which to interact. In the Pacific Northwest region, releases of artificially propagated Pacific salmon, not the escape of Atlantic salmon, have been shown to produce impacts on native Pacific salmon that are analogous to those found between artificially propagated and wild Atlantic salmon in Europe and eastern North America. Adverse genetic and ecological interactions on local wild Pacific salmon populations from artificially propagated Pacific salmon have been well - documented by Weitkamp et al. (1995), Busby et al. (1996), Hard et al. (1996), EAO (1997), Gustafson et al. (1997), Johnson et al. (1997, 1999), and Myers et al. (1998x) in reviews of this large body of literature. Over the last 100 years, no detrimental genetic effects related to escaped or planted Atlantic salmon have been reported in Puget Sound or western North America. Potential Impact of Transgenic Atlantic Salmon As with other agricultural sectors, there is considerable interest within the fish farming and fish enhancement sectors to improve growth or survival of fish or shellfish through genomic or chromosomal manipulations. For example, triploid (treated to produce 3 instead of 2 chromosome copies) California - strain rainbow trout were planted in about 75 lakes in Washington this year to provide anglers with opportunities for large fish (WDFW 2002). The use of triploids in fish farming is considered to be a low risk endeavor in Washington, and has been suggested as one of the means to avoid genetic interactions, remote as they are, between Atlantic salmon and native salmonids (PCHB 1998). However, in recent years the role of transgenics (descendants of genetically engineered parents whereby introduced DNA has been incorporated and inherited) in traditional farming has been a controversial topic. The potential risk is thought to be that transgenic fish, should they escape from fish farms, may reproduce successfully with wild or other transgenic fish and produce offspring that may eventually adapt to their local environments. This is a topic that will receive considerable debate in the years to come. There is no evidence in the literature that transgenic fish have been raised or are currently being raised in Puget Sound waters, and at present there are no plans to raise them in the future (P. Granger). The formally adopted position of the Washington Fish Growers Association is as follows: "Transgenic fish (as defined by actual transfer of genes from one species to another species) are not used in commercial production in Washington State today and should not be used here or elsewhere in the future unless they are proven healthy and nutritious, safe for human P. Granger, Washington Fish Growers Association, 10420 173rd Ave. SW, Rochester, WA 98579. Pers. commun., February 12, 2001. 16 consumption and of minimal risk to the environment. This would mean approval by appropriate state and federal agencies" (D. Swecker3). s D. Swecker, Washington Fish Growers Association, 10420 173rd Ave. SW, Rochester, WA 98579. Pers. commun., March 4, 2002. 17 POTENTIAL FOR COLONIZATION OF PUGET SOUND CHINOOK AND HOOD CANAL SUMMER -RUN CHUM SALMON ESUs BY ATLANTIC SALMON Success of Atlantic Salmon Introductions Worldwide Worldwide, there have been several hundred attempts to establish Atlantic salmon outside their native range, and with two exceptions in barren habitat, these have inevitably failed (MacCrimmon and Gots 1979, Lever 1996). On the other hand, there are many reports regarding other non - native species that eventually became established after first experiencing numerous failures, especially introductions involving plants and invertebrates (Williamson 1996). However, most Atlantic salmon introductions have been well- matched to habitat (northern and mountainous states or southern provinces) with optimal environmental conditions for the salmon, have included large numbers over many years, and still have failed. Thus, it is the total number of failed introductions over the last century that is the basis of the risk assessment presented below. Success of Atlantic Salmon Introductions in the United States In the past century, there have been numerous attempts in the United States and elsewhere to establish Atlantic salmon outside their native range. At least 170 attempts occurred in 34 different states where Atlantic salmon were not native, including Washington, Oregon, and California (MacCrimmon and Gots 1979). None of these efforts was successful. No reproduction by Atlantic salmon was verified after introductions in the waters of these states (MacCrimmon and Gots 1979, Alverson and Ruggerone 1997, Dill and Cordone 1997). Success of Atlantic Salmon Introductions in the Pacific Northwest The initial transfer of Atlantic salmon to Washington occurred in 1904 (MacCrimmon and Gots 1979). Attempts to introduce this species, as well as plantings for recreational purposes, continued until about 1991 (Coleman and Rasch 1981, Amos and Appleby 1999). Occasional releases of Atlantic salmon into high mountain lakes in Washington have since been made. Sea -run and landlocked strains (originally from NMFS) were used, but neither life - history form succeeded in establishing self - perpetuating populations. Several Atlantic salmon farmers in Washington rear juveniles in the Chehalis River basin prior to transfer to seawater in Puget Sound. Since the mid- 1980s, escaped Atlantic salmon smolts have been captured in traps designed to monitor the out - migration of juvenile Pacific salmon (Seiler et al. 1995). However, as of 1998, no returning adult Atlantic salmon have been encountered at adult salmon traps on several tributaries of the Chehalis River system, or been caught in tribal gill -net fisheries, which capture about 10% of all upstream migrating adults in I: the main stem of the Chehalis River (D. Seiler4). If 20 adult Atlantic salmon were returning to the Chehalis River in a given year, a 10% level of sampling would give an 88% percent chance of observing at least one Atlantic salmon if it returned at the same time as the tribal fisheries in the summer through early fall (R. Kopec). Therefore, the probability of not capturing an adult Atlantic salmon if they were numerous enough to have a hypothetical negative impact in the Chehalis River is small. Between 1905 and 1934, the government of British Columbia released 7.5 million juvenile Atlantic salmon into local waters, primarily on the east coast of Vancouver Island and the lower Fraser River (MacCrimmon and Gots 1979, Alverson and Ruggerone 1997). These releases were not successful in establishing Atlantic salmon populations in the province (Carl et al. 1959, Hart 1973), although some natural reproduction may have occurred in the Cowichan River, as specimens thought to have resulted from the planting of Atlantic salmon were taken until May 1926 (Dymond 1932). The Department of Fisheries and Oceans Canada (DFO Canada) currently is carrying out a long term monitoring study, known as the Atlantic Salmon Watch, examining catches and sightings of Atlantic salmon to determine if self - sustaining populations are becoming established (Thomson and Candy 1998). Recently Volpe et al. (2000) reported that feral Atlantic salmon had successfully produced offspring in British Columbia. Locations in British Columbia where juvenile Atlantic salmon of both naturally produced (feral) and hatchery (escapees) origin have been captured are presented in Table 3. In addition to the total failure of fisheries managers to establish populations of anadromous Atlantic salmon outside their native range, it appears that it is extremely difficult to reintroduce Atlantic salmon to their native rivers in North America. In the last 100 years, Atlantic salmon populations in New England have declined precipitously, despite widespread introductions of locally derived hatchery fish, primarily from the Penobscot River (Moring et al. 1995), a stock now used in net -pen farms in Puget Sound. Due to continued declines in abundance, Atlantic salmon in Maine have recently been listed as an endangered species under the ESA ( USDOI and USDOC 2000). Emery (1985) and Crawford (2001) noted that in historic Atlantic salmon habitat in Lake Ontario, attempts to reestablish Atlantic salmon populations have not been successful. However, introduced Pacific salmonids have succeeded in establishing self - reproducing populations throughout the Great Lakes (Brown 1975), although it appears that many populations of introduced salmon and trout in the Great Lakes would face an immediate risk of local extinction without continued supplemental stocking (Crawford 2001). USFWS (1982) reported that Pacific salmon and trout, as well as brown trout from Europe, were prevalent in Canadian and United States tributaries of Lake Ontario, a system where Atlantic salmon were once a common species. Coho salmon were observed spawning in 48 different streams, kokanee (sockeye salmon life - history form) in 4 streams, chinook salmon in 52 streams, rainbow trout /steelhead in 62 streams, and brown trout in 25 streams. Atlantic salmon were not observed in any tributary of Lake Ontario in this 1982 study, having been extirpated from the Lake Ontario system by 1904. Lever (1996) reported that, worldwide, no self - sustaining populations of anadromous Atlantic salmon have been established outside the natural range of this species, although 4 D. Seiler, WDFW, 600 Capitol Way N, Olympia, WA 98501. Pers. comrmm., September 1, 1999. 'R. Kope, NMFS, 2725 Montlake Blvd. E, Seattle, WA 98112. Pers. commun., October 16, 2001. 19 Table I Number of juvenile Atlantic salmon observed in British Columbia freshwater areas, 1996 -2001. Suspected naturally produced juveniles in bold. (Data from A. Thomson, DFO Canada, Pacific Biological Station, Nanaimo, BC V9R 5K6. Pers. commun., April 16, 2001.) It is possible that the three fish observed in the Adam R. in 1999 could have been brown trout (D. Noakes, DFO Canada, Pacific Biological Station, Nanaimo, BC V9R 5K6. Pers. commun., February 2, 2002). River or lake 1996 1997 1998 1999 2000 2001 Adam R. 3 Amor de Cosmos R. 113 8 Carnation Creek 1 3 1 Georgie Lake 41 21 86 30 Keogh R. 1 2 Lois Lake 13 Pye R. 1 Stamp R. 3 Tsitika R. 24 2 3 20 landlocked populations appear to have become established in the Southern Hemisphere in Argentina and in the mountains of New Zealand. Reproduction by Atlantic salmon was observed subsequent to introductions in Chile and Australia, but these transfers failed to create self - sustaining populations. Possible Reasons for the Failure of Atlantic Salmon Introductions Primitive Hatchery Methods The failure of early introductions of Atlantic salmon to produce self - sustaining populations could have been due to the rather primitive hatchery methods used in the early 1900s (Volpe 2001). However, the same primitive methods that failed to establish Atlantic salmon anywhere in North America proved to be remarkably successful in establishing European brown trout, brook trout, and rainbow trout almost everywhere in the earliest days of fish culture, often on the first attempt (Lever 1996, Dill and Cordone 1997). With these particular salmonids, the success or failure of introduction appears to be associated with attributes inherent to each species, not with the hatchery methods employed. Pristine Habitats and Healthy Pacific Salmon Populations It has also been suggested (by University of Victoria student John Volpe) that the earlier attempts to establish Atlantic salmon in the Pacific Northwest failed because salmonid habitats had not yet been damaged and local salmonid populations were abundant, thereby preventing Atlantic salmon from finding an available niche to colonize (Glavin 2001). However, brown trout, brook trout, California- strain rainbow trout, lake trout (Salvelinus namaychus), and several dozen non - salmonid species all successfully colonized habitats throughout Washington and the rest of North America during this early period (Wydoski and Whitney 1979), indicating that the limited availability of suitable niches and the presence of abundant salmon populations were not exclusionary factors for colonization by non - native fish, including Atlantic salmon, early in the 20th century. Moreover, attempts to establish Atlantic salmon populations in the Pacific Northwest were conducted under a variety of climatic conditions, variations of which have been show to dramatically influence the ocean survival of Pacific salmon (Beamish and Bouillon 1993, Beamish et al. 1997, Noakes et al. 2000). Climatic conditions during the early part of the 20th century were favorable for salmon survival as evidenced by high abundance of salmon in the Pacific Ocean during this period (Beamish et al. 1997, Noakes et al. 2000). Most of the introductions of Atlantic salmon into the Pacific Northwest occurred concurrent with this episode of favorable ocean conditions, but colonization failed to take place. Incompatible Biological Characteristics of Introduced Atlantic Salmon The failure of Atlantic salmon to colonize new habitat has also been attributed to other factors, including the inability to navigate in new environments, and to introductions that were made in small batches of less than several hundred thousands of individuals (Lever 1996, Dill and Cordone 1997). Atlantic salmon may also have "prohibitively stringent reproductive 21 requirements, including very particular stream substrate qualities" (Crawford 2001). The experience in Washington and elsewhere in the world suggests that the failure of Atlantic salmon to establish populations after introductions is linked to incompatible biological characteristics of Atlantic salmon and not with the availability of suitable habitat or absence of potential competitors or predators. In California, attempts to establish Atlantic salmon populations have been discontinued because the expectation of successful introductions is "so remote that it does not warrant the effort or expense of an attempt" (Dill and Cordone 1997). In a review of the ecological and genetic effects of salmonid introductions in North America, Krueger and May (199 1) observed that, with the notable exception of pink salmon inadvertently introduced into the Great Lakes, successful introductions from the accidental release or escape of salmonids has rarely occurred, unlike the frequent success observed with some intentionally introduced salmonid species such as chinook and coho salmon, and rainbow, brook, and brown trout. As noted above, the success of introduced salmonids in the Great Lakes may be due for the most part to the relatively large numbers of artificially propagated salmonids introduced into the Great Lakes each year. For example, between 1966 and 1998, 4 million Atlantic salmon, 336 million chinook salmon, 81 million brown trout, 148 million coho salmon, and 174 million rainbow trout have been planted in all the Great Lakes combined (Crawford 2001). Atlantic salmon may have failed to succeed in the Great Lakes because of the low numbers of artificially propagated Atlantic salmon introduced compared to the much larger number of artificially propagated Pacific salmon and trout juveniles present in the Great Lakes (M. Gross6). In addition, competitive interactions with coho and chinook salmon and rainbow and brown trout may limit the successful restoration of Atlantic salmon to Lake Ontario (Crawford 2001). Atlantic salmon are virtually the only non - native salmonid not successfully introduced to Washington, with the exception of Arctic char (Salvelinus alpinus) and Masu salmon (Oncorhynchus masou) (Wydoski and Whitney 1979). Even so, Barbara Stenson, spokesperson of the Marine Environmental Consortium, views escaped Atlantic salmon colonizing habitats throughout the Puget Sound Basin at great detriment to Pacific salmon as an inevitable outcome of salmon farming (Le 1999). The risk of anadromous Atlantic salmon establishing self - perpetuating populations anywhere outside their home range has been shown to be extremely remote, given that substantial and repeated efforts over the last 100 years have not produced a successful self - reproducing anadromous population anywhere in the world. In Oregon, the hatchery- supported fishery for Atlantic salmon in Hosmer Lake represents the only successful fishery produced in approximately eight lakes stocked with this species (Dill and Cordone 1997). In the Pacific Northwest, there have been no reports of self - sustaining populations resulting from deliberate or accidental Atlantic salmon introductions, compared to the plethora of other non - native species which have readily established themselves in the region. 6 M. Gross, University of Toronto, 25 Harbord St., Suite 503, Toronto, ON M5S 3G5. Pers. commun., February 24, 2002. 23 POTENTIAL FOR DISEASE TRANSMISSION OR ADVERSE DISEASE IMPACTS BETWEEN ATLANTIC SALMON AND PACIFIC SALMON IN WASHINGTON The occurrence and treatment of diseases is an unavoidable consequence of animal husbandry. This is no less true for aquatic husbandry, public and private, than for terrestrial farming. This section will discuss salmon diseases commonly observed in the Pacific Northwest and whether net -pen rearing of Atlantic salmon has a potential for adverse disease impacts comparable to disease risks associated with the artificial propagation of Pacific salmon in public hatcheries, which in turn appears to have a low risk for federally protected Pacific salmon in Puget Sound and Hood Canal. Diseases of Salmon and Trout in Hatcheries Freshwater salmonid diseases observed in Pacific salmon hatcheries in the Pacific Northwest include furunculosis, bacterial gill disease, bacterial kidney disease, botulism, enteric redmouth disease, cold water disease, columnaris, infectious hematopoietic necrosis, infectious pancreatic necrosis, viral hemorrhagic septicemia, erythrocytic inclusion body syndrome, and a number of parasitic infections, such as gyrodactylus, nanophyetus, costia, trichodina, ceratomyxosis, proliferative kidney disease, whirling disease, and ichthyophonis. These diseases are described in manuals by Wood (1979), Leitritz and Lewis (1980), Foott and Walker (1992), and Kent and Poppe (1998). The frequency of occurrence of these pathogens in hatcheries appears to vary geographically. For example, between 1988 and 1993, a greater percentage of Alaska hatcheries tested positive for infectious hematopoietic necrosis, viral hemorrhagic septicemia, furunculosis, and ceratomyxosis than hatcheries located in other western states, whereas hatcheries in Alaska tested positive at the lowest rate for several other salmonid pathogens (PNWFHPC 1993) (Table 4). In the Pacific Northwest, hatchery diseases associated with the freshwater phase of salmon culture can also occur in natural seawater environments after salmon are released from hatcheries or transferred to net -pens for further rearing. Other pathogens, such as Vibrio anguillarum and various parasites, are unique to the marine environment and are normally encountered by wild and hatchery- reared salmonids only after they leave rivers for the sea (Wood 1979, Harrell et al. 1985, 1986, Kent and Poppe 1998). Salmonid diseases observed in salmon and trout reared in public and private net -pens in seawater in the Pacific Northwest include; vibriosis, furunculosis, bacterial kidney disease, enteric redmouth disease, myxobacterial disease, infectious hematopoietic necrosis, infectious pancreatic necrosis, viral hemorrhagic septicemia, erythrocytic inclusion body syndrome, rosette agent, and a number of parasitic infections (Kent and Poppe 1998). 24 Table 4. Facilities (% in state or agency) testing positive for various salmonid diseases (July 1988 -June 1993). (Data from PNWFHPC 1993.) State or IHN IPN VHS EIBS BKD FUR ERM CWD PKD MC CS ICH AK 473 0.0 1.2 0.0 75.2 42.5 10.9 27.5 NSa NSa 50.0 0.0 CA 24.2 0.0 0.0 0.0 31.2 2.2 23.0 19.4 27.9 12.0 12.8 563 ID 20.2 8.7 0.0 15.5 48.4 1.8 12.3 23.6 4.3 15.6 20.4 20.7 MT 0.0 0.0 0.0 0.0 5.6 2.5 0.8 4.2 7.7 0.0 0.0 0.0 OR 18.1 03 0.0 24.6 53.1 35.9 17.8 84.8 0.0 2.9 333 26.2 WA 11.5 0.7 0.1 34.2 52.6 20.1 17.0 60.3 3.5 0.0 11.9 24.4 USFWS 37.5 1.0 0.0 27.2 84.9 23.7 20.0 34.9 0.0 0.6 30.6 24.0 NWIFCb 2.9 0.0 0.6 NSa 51.5 14.0 18.1 39.9 563 0.0 0.0 15.0 Averaize 20.2 13 0.2 14.5 503 17.8 15.0 36.8 12.5 4.4 18.8 20.8 'NS = Not surveyed bNorthwest Indian Fisheries Commission Key: Viral Diseases IHN Infectious hematopoietic necrosis IPN Infectious pancreatic necrosis VHS Viral hemorrhagic septicemia EIBS Erythrocytic inclusion body syndrome Bacterial Diseases BKD Bacterial kidney disease FUR Furunculosis ERM Enteric redmouth disease CWD Coldwater disease Parasites PKD Proliferative kidney disease MC Whirling disease CS Ceratomvxa ICH Ichthyopthirius 25 Salmon, like other animals, can carry pathogenic organisms without themselves being infected. For example, numerous bacterial species were observed in tissues of chinook salmon which had returned from the ocean to a hatchery in the lower Columbia River Basin, although the fish displayed no clinical signs of disease. Some of the bacteria observed were Listeria sp., Aeromonas hydrophila, Enterobacter agglomerans, Enterobacter cloacae, Staphylococcus aureus, Pseudomonas sp., Pasteurella sp., Vibrio parahaemolyticus, V. extorquens, V. fluvialis, Hafnia alvei, and Serratia liquefaciens (Sauter et al. 1987). Several of these organisms are known to be infectious to humans. However, the fact that such bacteria were found in hatchery salmon does not mean they posed a risk to humans, as the bacteria were present only at background levels. Disease Therapy Fish diseases and subsequent antibiotic therapy have been normal occurrences at state, federal, and tribal Pacific salmon hatcheries since the 1940s (WDF 1950, 1953, PNWFHPC 1993). An examination of the disease histories of Puget Sound area Pacific salmon and trout hatcheries (data from 45 hatcheries) during the 1980s showed that, on average, each hatchery experienced disease outbreaks from about 4 different pathogenic organisms during this period, frequently on an annual basis ( PNWFHPC 1988a -d). Cumulatively, salmon hatcheries in the Pacific Northwest (Alaska, Washington, Oregon, and Idaho), including those located in Puget Sound, experience hundreds of disease outbreaks every year (Wood 1979, PNWFHPC 1988a -d). It is not uncommon for a hatchery to experience different diseases in a relatively short period. For example, Michak and Rodgers (1989) reported that between 1983 and 1986 the WDFW Cowlitz Hatchery experienced Costia sp. infections on 11 different occasions, bacterial hemorrhagic septicemia 4 times, cold water disease 9 times, bacterial kidney disease 8 times, and furunculosis 1 time. Disease outbreaks have been observed in hatchery salmon reared in saltwater in Washington since the first attempts at seawater rearing in the 1950s (WDF 1954, PNWFHPC 1998). Concerns Regarding Treatment of Diseases in Salmon Rearing Facilities Alexandra Morton (1997), director of Raincoast Research, Peter Knutson, commissioner of the Puget Sound Gillnetters Association, Arthur Whitely, board member of the Marine Environmental Consortium (Carrel 1998), and others (Meloy 2000) have recently expressed concerns that the use of chemotherapeutics in fish culture will have negative impacts on wild salmonids and their environment. However, the occurrence of fish diseases at public hatcheries or private salmon farms and their treatment with chemotherapeutics have not been shown to have deleterious effects on wild salmonids or their habitat. For example, it is a recommended procedure to bath freshly spawned eggs in an iodophor solution at state, tribal, federal, and private hatcheries in the Pacific Northwest (ADF &G 1983, IHOT 1995 -1998, NWIFC/WDFW 1998). However, this procedure has not been shown to be harmful to wild salmonids in the Pacific Northwest. In a study at several Atlantic salmon net -pen farms in Puget Sound, it was found that the use of antibacterial compounds in fish food had no inhibitory effect on important 26 sediment biogeochemical processes such as bacterial densities, oxygen and ammonia fluxes, or interstitial ammonium and sulfate levels (Weston et al. 1994). Chemotherapeutants Registered for Use in the United States Diseases in public and private trout and salmon hatcheries in western states are normally treated with a variety of antibiotics and chemical baths, including oxytetracycline, Romet -308, formalin, iodophores and several others (Wood 1979; PNWFHPC 1988a -d, IHOT1995 -1998, PNWFHPC 1998). Drug therapy in federal, state, and tribal hatcheries in Washington, Oregon, Idaho, California, and Alaska is conducted in accordance with U.S. Food and Drug Administration (FDA) guidelines (Nash 2001, K. Amos'). As a result of drug therapy, antibiotic - resistant strains of bacterial fish pathogens have been observed in Pacific salmon hatcheries in the Pacific Northwest for over 40 years (WDF 1954, Wood 1979, PNWFHPC 1993). Only three therapeutants (formalin, oxytetracycline, and Romet -309) and one anesthetic (MS -222) are currently approved by the federal government for use with food fish in public and private artificial propagation facilities for salmon, trout, and catfish (Schnick 1992). However, the use of antibiotics in the United States is far more restrictive than in some countries. For example, Weston (1996) observed that 26 different antibacterial preparations were approved for use in Japan. This compares currently with 3 in Canada (EAO 1997) and 2 in the United States (Schnick 1992). Amount of Antibiotics Used in Fish Culture Facilities Given that Pacific salmon hatcheries rear thousands of metric tons (t) of fish each year, the amount of antibiotics used to treat bacterial salmon diseases in hatcheries is not inconsequential, sometimes amounting to hundreds of tons of medicated feed each year. Michak et al. (1990) stated that the Washington Department of Fisheries (WDF, now WDFW) hatcheries located in the Columbia River Basin used about 200 t of feed containing antibiotics. Since WDF hatcheries in the Columbia River Basin represented only about 25% of the number of all salmon and trout hatcheries (albeit many of the largest facilities are in the Columbia River Basin) in Washington State at that time (Myers et al. 1998a), it is reasonable to estimate that the total amount of medicated feed used by the public hatchery system in the State was about 450 t in 1990. Actual or estimated annual amounts of medicated feed used in private fish culture of Atlantic salmon in seawater and rainbow trout in freshwater are not available at this time for the United States or Puget Sound. However, the amount of drugs used elsewhere in salmon farming has declined greatly, mostly as a result of improved husbandry practices, including development of effective vaccines for common fish diseases. EAO (1997) noted that salmon farmers in Norway used a total of 48.7 t of antibacterial drugs in 1987, and the figure had fallen to 6 t by 1993. In 1998 it was only 0.7 t (Intrafish 2000). To put the amount of antibiotics currently used in Norway into perspective, it took about two level teaspoons (approximately 7 g) of antibiotic to 7 K. Amos, WDFW, 600 Capitol Way N, Olympia, WA 98501. Pers. common., May 30, 2001. 27 produce a metric ton of farmed salmon in Norway in 1996 (Noakes et al. 2000). Less than that is required today. During the same 12 -year period, the production of salmon in Norway increased from 50,000 t to 400,000 t and the quality of product was considerably improved (ODIN 2001). A similar pattern of reduced drug use has occurred in British Columbia (EAO 1997). Although the amount of antibiotics used in Puget Sound Atlantic salmon farms has not been summarized, with just a few salmon farms in Puget Sound, the annual use of antibiotics in the net -pen farms would be relatively small compared to the amount used in other countries. Disease Interactions between Hatchery and Wild Salmon and Trout Transmissions of Disease from Hatchery to Wild Salmon Documented examples of disease transmission between wild and artificially propagated fish are not common, yet have been known to occur (Brackett 1991). For example, the planting of infected Atlantic salmon smolts from two Norwegian federal salmon hatcheries into rivers in Norway was responsible for the introduction of the freshwater parasite Gyrodactylus salaris, which caused the extirpation of Atlantic salmon in many river systems (Johnsen and Jensen 1986, 1988). The viral disease infectious hematopoietic necrosis, ubiquitous in Alaska, British Columbia, and Washington sockeye salmon populations (Meyer et al. 1983), was introduced to Japan from a shipment of infected sockeye salmon eggs from a hatchery in Alaska and subsequently caused epizootic mortality in Japanese chum salmon and in two species of landlocked salmon which occur only in Japan (McDaniel et al. 1994). In these two cases, the indigenous salmonids in Norway and Japan were exposed to novel pathogens to which they had little or no immunity. In Washington, where no new stocks of Atlantic salmon have been introduced since 1991, the pathogens found in cultured salmonids are the same as those known to occur in wild salmon (Amos and Appleby 1999). Recently, significantly higher infestation rates by the copepod parasite Lepeophtherius salmonis was found on wild salmonids in Irish bays containing L. salmonis- infected farmed salmon than in bays where infected farmed salmon were not present (Tully et al. 1999). It appears that salmon farms in Ireland acted as a biomagnifier for this particular organism. Sea lice have also been observed on salmon from farms in British Columbia (Kent and Poppe 1998). However, L. salmonis has not been reported to be a significant problem in marine net -pens in Puget Sound (K. Amos). For example, since 1969, rainbow and cutthroat trout, and coho, chum, chinook, sockeye, pink, and Atlantic salmon have been grown in government and private net -pens in Clam Bay, Washington. L. salmonis, although commonly observed on captive fish in the net -pens, has not been a serious problem at the NMFS Manchester Research Station (L. Harrell ), despite the fact that the fish in the pens experienced a high rearing density (number of fish per unit space) relative to densities experienced by free - swimming fish. High rearing density is thought to be primarily responsible for the greater incidences of fish diseases observed in hatchery salmon versus wild salmon (Wood 1979, Leitritz and Lewis 1980, Foott and Walker 1992, Kent and Poppe 1998). 'K. Amos, NMFS, 510 Desmond Dr. SW, Lacey, WA 98503. Pers. commun., March 27, 2002. 9 L. Harrell, NMFS, P.O. Box 130, Manchester, WA 98353. Pers. commun., March 27, 2002. Diseases of Atlantic Salmon in the Pacific Northwest Alexandra Morton, director of Raincoast Research (PSGA 2000), and Peter Knutson, commissioner of the Puget Sound Gillnetters Association (Carrel 1998), asserted that Atlantic salmon in the Pacific Northwest are more likely to carry diseases than hatchery stocks of Pacific salmon, but these statements were not accompanied by a review of the scientific literature. Salmonids, including Atlantic salmon, can only carry diseases to which they have been exposed. The New England Atlantic salmon stocks used by Washington growers were certified by federal pathologists to be disease -free prior to shipment from East Coast hatcheries between 1980 and 1986 and have been reared exclusively in the Pacific Northwest for many generations. Their diseases, if any, would be no different than the diseases found in nearby Pacific salmon hatcheries. In addition, Washington regulations require that all broodstocks of hatchery salmon, including Atlantic salmon broodstocks, must be examined for pathogens each year (Washington Administrative Code 220 -77; Revised Code of Washington 75.58). Nonindigenous salmon diseases transmitted into the Pacific Northwest by the North American hatchery stocks of Atlantic salmon used in Washington have never been observed in the yearly sampling of these stocks since the mid- 1970s. Potential for Disease Transmission from Atlantic Salmon to Pacific Salmon Pacific salmonids do not appear to be put to any increase in disease incidence when continually exposed to water in which Atlantic salmon have been reared. For example, Rocky Ford Creek, near Ephrata in eastern Washington, is considered to be one of the premier trout streams in the State (Northwest Fishing Holes 2001), yet the entire flow in this stream consists of effluent from an Atlantic salmon hatchery and smolt production facility (J. Parsons10). There are no reports of diseased trout in this stream in either the scientific literature or in the many media reports on the fine fishing in this stream. There is no evidence that hatchery- reared Atlantic salmon have introduced or spread nonindigenous diseases to native fishes in Washington (Amos and Appleby 1999). By law, privately owned Atlantic salmon populations in Washington are examined for diseases every year (WAC 220 -77 -030), and no exotic pathogens have been reported. With Pacific salmonids, Griffiths (1983) observed that outbreaks of serious contagious diseases were normally associated with the intensive culture of fish in a hatchery environment. Documentation of disease introductions in North America from the stocking or escape of artificially propagated salmonids has been uncommon (Krueger and May 1991). The Scale of Artificial Propagation of Salmon in the Pacific Northwest and Disease Transmission Potential Based solely on the enormous number of hatchery- reared salmonids released into rivers and lakes in the Pacific Northwest, the potential for transmission of disease to wild stocks from hatchery- reared Pacific salmon and trout would be greater than that of accidentally escaped farmed Atlantic salmon and rainbow trout in Washington State, although this statement is not 10 J Parsons, Troutlodge, Inc., P.O. Box 1290, Sumner, WA 98390. Pers. commun., March 12, 1999. 29 meant to suggest that the risk from Pacific salmon hatcheries is severe or even moderate. However, escaped farmed Atlantic salmon and rainbow trout constitute a miniscule percentage of all artificially propagated salmon which end up in natural waters in the area. Furthennore, hatchery Pacific salmon occupying the marine waters of Washington each year have not been shown to impose adverse disease impacts on wild salmonids. Peter Knutson (Carrel 1998) described escaped Atlantic salmon as "smart bombs, delivering disease right into the bedrooms of wild salmon" in the Pacific Northwest, but this declaration has not been supported by the scientific literature. Mahnken et al. (1998) reported that since 1980 the number of Pacific salmon released from several hundred federal, state, tribal, and cooperative hatcheries on the West Coast was about 2 billion fish annually, which is about 30,000 to 40,000 times more than the number of Atlantic salmon that may have escaped from net -pens since 1980 (Table 5). On a smaller scale, the number of Pacific salmon released from saltwater net -pens in Puget Sound is much greater than the number of Atlantic salmon that escape from salmon farms. For example, NRC (1995, 1996) reported that coho salmon were released annually from 18 different marine net -pen sites, chinook salmon from 13 different sites, and chum salmon from 10 different sites in Puget Sound between Olympia and Bellingham. The number of fish released from these marine sites averaged about 10 million annually between 1980 and 1992. Currently, however, only about half that number are being released, due to dramatic changes in hatchery practices meant to protect wild salmonids in Puget Sound and Hood Canal (NWIFC 2001, WDFW 2000). These hatchery fish had sometimes been exposed to various salmonid pathogens before transfer to or while in seawater, including bacterial kidney disease, vibriosis, and furunculosis. Infections in these fish were often treated with antibiotics (PNWFHPC 1988a -d). Adverse disease impacts on wild salmonids were not reported during the rearing period or after they were released, nor were any media reports seen expressing concern that these fish may have been treated with antibiotics sometime prior to release into public waters. Disease Control Policies in Washington and the United States In Washington all public and private growers of salmon, including Atlantic salmon hatchery operators, are required to adhere to strict disease control polices that regulate all phases of fish culture, from egg take to harvest and release (NWIFC/WDF 1991, NWIFC/WDFW 1998). Each year at spawning time, adult salmon at public and private hatcheries must be sampled for viral, bacterial, and parasitic organisms. If any of several reportable organisms are detected in fish at a hatchery or have been detected within the past five years, transfer of eggs or fish from that facility is prohibited, thereby significantly reducing the risk of diseases transfer from one location to another. The movement of fish and eggs across state or international borders is regulated by the USFWS under Title 50 of the CFR, which has stipulations and controls in accord with state regulations (50 CFR 16.13). For the case in point, all Atlantic salmon stocks distributed to local growers by NMFS were certified by federal pathologists before transfer from New England, and have been annually certified since then under Washington guidelines and procedures. 30 Table 5. Number (in millions) of salmon released or escaped by species and location along the West Coast of North America, 1980 -1995. (Data from Amos and Appleby 1999, Mahnken et al. 1998, Thomson and McKinnell 1993, 1994, 1995, 1996, 1997, Thomson and Candy 1998.) State or region Atlantic Sockeye Chum Steelhead Pink Coho Chinook Alaska 0.0 978 3,885 2 8,610 193 98 BC, Canada —0.4 3,930 2,870 17 533 300 721 Pacific Northwest —0.6 52 1,081 359 21 1,726 4,320 Total No. —1.0 4,960 71836 377 9,164 2,219 5,139 Total % 0.0003 16.7 26.4 1.2 30.9 7.5 17.3 31 POTENTIAL ECOLOGICAL IMPACTS OF ATLANTIC SALMON IN THE PACIFIC NORTHWEST Impacts of Cultured Atlantic Salmon on Wild Atlantic Salmon In areas where Atlantic salmon are indigenous, such as Scandinavia, Great Britain, and eastern North America, adverse genetic and ecological impacts for natural populations of Atlantic salmon have been reported following programmed releases or unintentional escapes of artificially propagated Atlantic salmon from public hatcheries and private net -pens (Hearn and Kynard 1986, Beall et al. 1989, Jones and Stanfield 1993, Heggberget et al. 1993, Gross 1998). The impacts included reductions in the genetic diversity and capacity to evolve in wild Atlantic salmon, introduction of genetic maladaptations as a result of interbreeding with artificially propagated Atlantic salmon, and competition for food and space between wild and hatchery stocks of Atlantic salmon. These particular adverse effects occurred because the artificially propagated and wild salmonid species were both Atlantic salmon. Escaped Atlantic salmon on the Pacific coast of North America do not have conspecific or congeneric wild individuals with which to interact. However, adverse ecological effects may still occur between different species. For example, introductions of hatchery coho salmon juveniles in western Washington appear to have had a negative impact on the abundance of wild cutthroat trout in some streams (Johnson et al. 1999). Actual negative ecological consequences for Pacific salmon and trout related to the deliberate or unintentional introduction of Atlantic salmon into their habitats have not been reported. In the Pacific Northwest region, introductions and transfers of hatchery stocks of Pacific salmon, rather than escapes of Atlantic salmon, have much greater potential to produce impacts on native Pacific salmon analogous to those found between propagated and wild Atlantic salmon in Europe and eastern North America. Impacts of Cultured Pacific Salmon on Wild Pacific Salmon Many adverse genetic and ecological interactions on local wild salmon populations resulting from plants of artificially propagated Pacific salmonids have been documented in the Pacific Northwest (Campton and Johnston 1985, Nicholson et al. 1986, Leider et al. 1987, Behnke 1992, WDF et al. 1993, Kostow 1995). These adverse impacts in part include introgressive hybridization, competition for food and rearing space, decreased effective population size, decreased reproductive success, and reductions in intraspecific diversity. Recently, significant changes in management strategies by resource agencies have been initiated to reduce or eliminate adverse impacts from traditional hatchery programs, such as stock transfer guidelines used by WDFW for the last decade (WDF 1991a). No reports of detrimental impacts in the Puget Sound or Hood Canal ESUs related to deliberate or accidental Atlantic salmon introductions have been found. 32 Ecological Interactions between Atlantic Salmon and Pacific Salmon Behavioral Interactions Gibson (1981) reported that in laboratory studies in New England, introduced Pacific steelhead juveniles were more aggressive than Atlantic salmon. In turn, Atlantic salmon fry appeared to be more aggressive than coho salmon fry when introduced into open pools, although it was recognized that open pools are not the preferred habitat of coho salmon fry. In a similar experiment, Beall et al. (1989) reported that the survival of Atlantic salmon was reduced in the presence of older coho salmon fry. In trials of interspecific combative behavior in a small river in New England, Hearn and Kynard (1986) observed that rainbow trout juveniles initiated three to four times more aggressive encounters than did Atlantic salmon, and concluded that it would take very large numbers of Atlantic salmon juveniles to displace or even disrupt rainbow trout. Jones and Stanfield (1993), in a study conducted in a Lake Ontario tributary once inhabited by Atlantic salmon, reported that their attempts to reintroduce hatchery strains of Atlantic salmon were significantly impaired in the presence of naturalized Pacific salmon juveniles, compared with reintroduction in stream sections where Pacific salmon juveniles had been removed. Volpe et al. (2001) observed that in an artificial environment, territory was successfully defended by the initial resident, whether that was an Atlantic salmon or a steelhead, which had been reared to achieve a standardized size prior to the study. It was speculated that the potentially greater size -at -age of naturally produced Atlantic salmon (Volpe et al. 2000) might give them a greater advantage. Predation by Atlantic Salmon In a study on farmed fish in British Columbia by Black et al. (1992), stomach analyses revealed that less than 1% of farmed salmon in net -pens (in this case coho and chinook salmon) contained the remains of fish. Since 1992 Canadian government scientists have examined the stomach contents of escaped Atlantic salmon recovered in the open waters of British Columbia as part of the Atlantic Salmon Watch Program in the province. Fish remains of any sort were rarely observed, and to date, the remains of just a few Pacific salmon (chum salmon) have been observed, in this case, in the stomach of a hatchery Atlantic salmon juvenile in Carnation Creek, British Columbia (Thomson and McKinnell 1993, 1994, 1995, 1996, 1997, Thomson and Candy 1998; A. Thomson"). That only a few juvenile salmonids have been observed in the stomachs of escaped Atlantic salmon (over 1,000 stomachs examined in British Columbia and Alaska) indicates that these fish have a very low propensity to prey on juvenile salmonids, compared to Pacific salmon. For example, Fresh (1997) compiled information showing that about 50% of chum salmon juveniles are consumed by various predators, including other salmon, during their short period of migration from freshwater to marine environments. In the Chignik Lakes of Alaska, Ruggerone and Rodgers (1992) observed that juvenile coho salmon ate almost 60% of the sockeye salmon fry population. Fresh (1997) indicated that 33 fish species, 13 bird species, and 16 marine mammal species are predators of juvenile and adult Pacific salmon. Tynan (1981) " A. Thomson, DFO Canada, Pacific Biological Station, Nanaimo, BC V9R 5K6. Pers. commim., December 27, 2001. 33 examined the stomachs of 93 coho salmon post - smolts captured after release from a net -pen near Squaxin Island, in South Puget Sound, and reported that only 3 stomachs contained fish remains, which were identified as smelt (Hypomesus pretiosus). At the NMFS Manchester Research Station in Puget Sound, many species of forage fish have been observed seeking refuge from predators in net -pens containing adult Atlantic salmon. Among the species observed are known prey of salmonids, such as herring (Clupeapallasi), smelt, sand lance (Ammodytes hexapterus), shiner perch (Cymatogaster aggregata), and tube snouts (Aulorhynchus flavidus). These prey species voluntarily enter the net -pens through the mesh and then grow too large to exit. Alverson and Ruggerone (1997) noted that many thousands of these small fish had been observed in Atlantic salmon net -pens, and eventually had to be removed by hand. Buckley (1999) observed that cannibalism and predation by chinook salmon on other salmonids was uncommon in Puget Sound waters. It is difficult to imagine that escaped Atlantic salmon, conditioned to a diet of artificial feed pellets and trained to be fed by humans, could have greater predation impacts on juvenile native salmonids than the impacts observed with free - swimming Puget Sound chinook and coho salmon. Predation by Introduced Brown Trout In the Cowichan River in British Columbia, non - native brown trout became established soon after the first introduction in 1932. Idyll (1942) observed that native salmon, trout, and their eggs, were a significant dietary component of young Cowichan River brown trout, and were the primary food item of large brown trout, as they were found to be elsewhere (Krueger and May 1991). Recent evaluations by Wightman et al. (1998) of steelhead populations on the east coast of Vancouver Island showed that the Cowichan River was one of only two rivers (out of 27 evaluated) with a relatively healthy steelhead population. Therefore, the successful colonization of the Cowichan River by a highly piscivorous species such as the brown trout has apparently had little or no adverse impact on steelhead abundance for more than 60 years, whereas attempts to establish Atlantic salmon in the Cowichan River Basin were failures. No media reports deploring the establishment of predatory brown trout in the Cowichan River were found in this review. On the contrary, the fact that large brown trout established in the Cowichan River compete with and prey on native salmon and trout was described, simply, as "browns will be browns" (Marsh 2000). Self- sustaining populations of predacious brown trout do not appear to be a cause for concern for citizens in the Pacific Northwest. However, the presence of a small number of Atlantic salmon juveniles in Vancouver Island streams has been viewed with alarm. These concerns can be summarized by statements such as John Volpe's that "steelhead will likely suffer most" from the presence of Atlantic salmon in these streams (Marsh 1999); Barbara Stenson's that "the possibility of farmed salmon interbreeding with Pacific salmon has been confirmed in laboratory tests" (1998); and that of Jim Fulton, executive director of the David Suzuki Foundation, that successful Atlantic salmon reproduction will be "the wave of death" for native salmon stocks (Howard 1999). 34 Ecological Interactions between Cultured Pacific Salmon and Wild Pacific Salmon Adverse genetic and ecological effects from artificially propagated Pacific salmon have been documented by Weitkamp et al. (1995), Busby et al. (1996), Hard et al. (1996), Gustafson et al. (1997), Johnson et al. (1997, 1999), and Myers et al. (1998a) in coast -wide status reviews of Pacific salmonids conducted by NMFS in fulfillment of its responsibilities under ESA. The reviews contained information from the scientific literature that documented known adverse ecological impacts sometimes associated with the artificial propagation and release of Pacific salmon on the West Coast. In recent years, however, concerned management agencies have eliminated or modified many of the policies that contributed to these adverse effects. Nevertheless, examining known adverse impacts of Pacific salmon hatchery programs offers an effective demonstration that, by comparison, the ecological and genetic risks associated with Atlantic salmon farming are very small for federally listed chinook and summer -run chum salmon, as well as for other species, in Puget Sound and Hood Canal. The following paragraphs provide a brief review, by species, of adverse effects of artificial propagation that occurred before some of the Pacific salmon hatchery strategies that contributed to these effects were modified or eliminated. Chinook Salmon About 1.77 billion hatchery chinook salmon have been released into Puget Sound and its tributaries between 1953 and 1993, which is about 84 million per year, with the stock from the Green River Hatchery being the dominant stock as far back as 1907 (Myers et al. 1998a). Concerns that this strategy may have eroded genetic diversity were raised by Myers et al. (1998a). As recently as 1995, 20 hatcheries and 10 marine net -pen sites throughout Puget Sound regularly released Green River -stock chinook salmon, although most marine releases of chinook salmon in Puget Sound have been terminated (NWIFC 2001). Busack and Marshall (1995) reported that the extensive use of this stock had an undoubted impact on among -stock diversity within WDFW's South Puget Sound, Hood Canal, and Snohomish summer /fall chinook salmon genetic diversity unit (GDU), and may also have impacted GDUs elsewhere in Puget Sound and the Strait of Juan de Fuca. A GDU is defined as: "a group of genetically similar stocks that is genetically distinct from other such groups. The stocks typically exhibit similar life histories and occupy ecologically, geographically, and geologically similar habitats. A GDU may consist of a single stock" (Busack and Marshall 1995). Generally, GDUs delineate stocks at a finer scale than the NMFS criteria for ESUs. For example, the single NMFS ESU for Puget Sound chinook salmon includes 6 WDFW GDUs (Busack and Marshall 1995). Rogue River chinook salmon have recently been released on the Oregon side of the Lower Columbia River to produce a south - migrating stock to avoid interception in commercial fisheries in British Columbia and southeast Alaska. Consequently, chinook salmon exhibiting Rogue River fall chinook salmon genetic markers were subsequently observed in about 13% of naturally produced chinook salmon juveniles in several lower Columbia River tributaries (Marshall 1997). In addition, most of the naturally spawning spring chinook salmon in Lower Columbia River tributaries were already hatchery strays (Marshall et al. 1995). Adverse impacts 35 resulting from the introduction of artificially propagated fish into native populations of chinook salmon were identified as a primary concern by the NMFS Biological Review Team(BRT) for ESA Status Review during the recent review of the status of West Coast chinook salmon populations (Myers et al. 1998x). There is no evidence of similar adverse effects on chinook salmon resulting from escaped Atlantic salmon in Washington or elsewhere within the original and naturalized (introduced) range of chinook salmon. Chum Salmon Johnson et al. (1997) reported that five hatchery stocks and several wild populations of chum salmon outside Hood Canal that were enhanced with eggs from Hood Canal hatcheries for several years subsequently exhibited genetic profiles more similar to those in Hood Canal hatchery populations than to populations in nearby streams that did not receive Hood Canal hatchery stock. Analyses of genetic profiles were consistent with the hypothesis that egg transfers between hatcheries and out - plantings of Hood Canal stock fry had genetically influenced the receiving populations. As a result, such transfers were terminated because of the potential jeopardy to wild gene pools through interbreeding (Phelps et al. 1995). Steelhead Trout Hatchery stocks of steelhead have been widely distributed. Few native steelhead stocks exist in the contiguous United States that have not had some influence from hatchery operations. For example, the summer steelhead program at the Nimbus Hatchery in Central Valley, California, was established with fish from a distant coastal tributary hatchery, which was itself earlier established with Lower Columbia River summer steelhead (Busby et al. 1996). Howell et al. (1985) reported that over 90% of the "wild" steelhead spawning in the Cowlitz River originated in a hatchery, and some of these fish exhibited genetic characteristics (chromosome number) of Puget Sound steelhead due to previous transfers of Puget Sound stock to the Cowlitz Hatchery. Chilcote (1997) reported that since 1980 the percentage of non - native hatchery steelhead (from upper Columbia River and Snake River hatcheries) spawning in the Deschutes River had increased to over 70% of the run, while the percentage of native, wild steelhead spawning in the Deschutes River decreased to less than 15 %. Phelps et al. (1997) postulated that introductions of non - native steelhead stocks in Washington, primarily Chambers Creek winter steelhead and Wells and Skamania summer steelhead, may have changed the genetic characteristics of some Puget Sound and eastern Washington steelhead populations sufficiently so that the original genetic relationships between stocks may have been obscured. Leider et al. (1987) concluded that the genetic fitness of the wild Kalama River population had been compromised by maladaptive gene flow from excess hatchery escapement. By comparison, no adverse effects on steelhead have been reported as a result of escapes of Atlantic salmon in Washington or elsewhere within the original and naturalized (introduced) range of steelhead. Coho Salmon Weitkamp et al. (1995) noted that it was extremely difficult for the NMFS BRT for ESA Status Review to identify any remaining natural populations of coho salmon in the Lower 36 Columbia River below Bonneville Dam, due in large part to persistent and extensive hatchery programs. A recent survey by NRC (1999) of coho salmon spawning habitat in the Lower Columbia River estimated that about 97% of recovered spawned -out carcasses originated from hatchery releases. Hatchery fish were observed in high percentages in streams up to 45 miles from the nearest hatchery. In many streams, wild coho salmon were not observed at all. In an earlier survey in Hood Canal, over 50% of all spawning coho salmon in streams within a 10 -mile radius of a net -pen release site were fish originally released from the net -pen as juveniles 18 months earlier (NRC 1997). Kostow (1995) stated that hatchery programs in Oregon may have contributed to the decline of wild coho salmon by supporting harvest rates in mixed -stock fisheries that were excessive for sustained wild fish production, and by reducing the fitness of wild populations through interbreeding between hatchery and wild fish. Furthermore, hatchery fish may have reduced survival of wild coho salmon juveniles in Oregon through increased competition for food in streams and estuaries, attraction of predators during mass migrations, and initiation of disease problems. Weitkamp et al. (1995) also reported that artificial propagation of coho salmon appeared to have had substantial impact on native coho salmon populations to the point where it was difficult for the NMFS BRT for ESA Status Review to identify self - sustaining native stocks in Puget Sound, as over half the returning spawners originated in hatcheries. Spawn timing had been advanced by selective breeding to allow hatcheries to meet their quotas for eggs by early November. Fish arriving at the hatchery with the later part of the run (which would be coincidental with the spawn time of the majority of wild or native fish) were not propagated. As a result of such practices, segments of hatchery coho salmon populations which historically returned as late as January through March have disappeared from many river systems, resulting in a significant loss of life - history diversity (Flagg et al. 1995). Regarding speculation that small pockets of self - sustaining wild coho salmon populations that have had no hatchery influence might remain in any tributary in Washington State, WDF (1991b) stated: "To assume there are, given the record, would seem to be a most notable defiance of the odds." There is no documented evidence of similar adverse effects on coho salmon resulting from escaped Atlantic salmon. Pacific Trout Long -term introductions of rainbow trout into western streams originally inhabited only by cutthroat trout have resulted in widespread extinction of native cutthroat trout through introgressive hybridization (Leary et al. 1995). Most of the rainbow trout released into Pacific Northwest lakes are derived from California strains, which have a different number of chromosomes than the rainbow trout native to many Puget Sound watersheds (Busby et al. 1996). Genetic analysis has shown the California- strain rainbow trout to be dramatically different than local strains (Busby et al. 1996). Hybridization between introduced brook trout and native bull trout (Salvelinus confluentus) is widespread in the western United States and usually produces sterile hybrids (Behnke 1992). Behnke (1992) noted that introduced brown trout had commonly replaced interior subspecies of cutthroat trout in large streams throughout 37 the same region, and introduced brook trout were the most common trout to be found in some small streams. The situation regarding attempts to establish Atlantic salmon populations west of the Mississippi River is much different. In summary, MacCrimmon and Gots (1979) described frequent attempts (all failures) to introduce Atlantic salmon to western states, many of which occurred in the same river systems and at the same time as the successful trout introductions noted above. Since MacCrimmon and Gots (1979), no recent introductions, accidental or not, have succeeded and, most importantly, no known adverse impacts on Puget Sound trout by Atlantic salmon have been reported in the literature. 39 ADVERSE IMPACTS OF NONINDIGENOUS FISH INTRODUCTIONS In contrast to the situation with Atlantic salmon, as many as 50 species of non - native fish are successfully established in the western United States (Table 6). Some adverse impacts associated with the establishment of these species are discussed below. ODFW/NMFS (1998) documented that many introduced non - native species were harmful to native salmon. For example, walleye (Stizostedion vitreum), bass, perch (Perca flavescens), sunfish (Lepomis sp.), brown trout, and brook trout, among others, are well-known predators or competitors of native salmon and trout and all have now been successfully established in Northwest waters. Beamesderfer and Nigro (1988) and Beamesderfer and Ward (1994) estimated that walleye and smallmouth bass (Micropterus dolomieu) introduced into the Columbia River consumed an average of 400,000 and 230,000 juvenile salmonids, respectively, each year in the John Day Reservoir. Daily et al. (1999) reported that juvenile salmonids from 7 ESUs currently listed as threatened or endangered under ESA must migrate through the John Day Reservoir. In some coastal lakes in Oregon, the summer rearing of coho salmon fry no longer occurs due to predation by introduced largemouth bass (Micropterus salmoides) (Daily et al. 1999). Tabor et al. (2000) observed that introduced largemouth and smallmouth bass eat out - migrating salmon, including juvenile chinook salmon, as they pass through the Lake Washington Ship Canal in Seattle, Washington. From April through July, juvenile chinook salmon constituted about 50% of the stomach contents of smallmouth bass in the Ship Canal. As many as 100,000 juvenile chinook salmon, some of which are hatchery fish, may be consumed in the Ship Canal during the 90 day out - migration period, which may pose a significant threat to juvenile chinook salmon migrating from the Lake Washington system (City of Bellevue 2002). By comparison, there is no documented literature which shows that escaped Atlantic salmon are a significant predator of juvenile native salmonids in the Pacific Northwest. Of the over 1,000 feral Atlantic salmon examined to date in Alaska and British Columbia, only one was found to have consumed a Pacific salmon juvenile (see Predation by Atlantic Salmon subsection above). .e Table 6. Status of non - native fish introductions in the Pacific Northwest and their behavior relative to Pacific salmonids. (Data after Behnke 1992, Lever 1996, Daily et al. 1999, WDFW 1999, Wydoski and Whitney 1979, Dill and Cordone 1997.) Naturalized in Naturalized in Naturalized in Non - native species Washington Oregon California Predator Competitor Hybridize Atlantic salmon Non - native rainbow X X X X X X Non - native cutthroat X X X X X X Lahotan cutthroat X X Westslope cutthroat X X X X Brown trout X X X X X X Brook trout X X X X X X Lake trout X X X X X American shad X X X X Threadfin shad X Lake whitefish X Arctic grayling X X Grass pickerel X X Northern pike X X X Striped bass X X X White bass X Common carp X X X X Grass carp X X Tench X X Brown bullhead X X X X X Black bullhead X X X X X Yellow bullhead X X X X X Flathead catfish X X X X Blue catfish X X X Channel catfish X X X X X White catfish X X X X Largemouth bass X X X X X Smallmouth bass X X X X X Wannouth bass X X X X X Rock bass X X X Redeye bass X Northern spotted bass X Alabama spotted bass X Black crappie X X X X X White crappie X X X X X Green sunfish X X X X X Bluegill X X X X X Pumpkinseed X X X X X Redear sunfish X Bigscale logperch X Yellow perch X X X X X Walleye X X X X X 41 MANAGEMENT OF NONINDIGENOUS FISH IN WASHINGTON In 1997 and 1999, in response to the escape of a large number of net -pen Atlantic salmon, WDFW suspended fishing regulations concerning size and bag limits for these fish. Licensed anglers fishing in open management zones were permitted to keep all the Atlantic salmon they could catch, of whatever size (WDFW 1997, 1999, 2002). The suspension of fishing regulations for an introduced, non - native species in waters inhabited by native salmonids is a management strategy that has been used before in Washington. For example, freshwater angling regulations for non - native brook trout were recently relaxed to increase harvest of this species, and regulations for non - native shad (Alosa sapidissima), perch, crappie (Pomoxis nigromaculatus), bluegill (Lepomis macrochirus), and carp (Cyprinus carpio) have long since been dismissed entirely. Harvest policies of this type would likely reduce, but not eliminate, known impacts of non - native species on listed salmonids in the two Puget Sound ESUs that are the subject of this review. However, regulations currently applied to some non - native species (see next paragraph), such as those that encourage their sustained natural reproduction, may not reduce but actually increase the impacts of non - native species on listed salmonids. Catch limits and closed seasons for non - native salmonids (such as brown trout, lake trout, landlocked Atlantic salmon, California- strain rainbow trout, and grayling) in watersheds within the Puget Sound and Hood Canal ESUs for chinook salmon and summer -run chum have given these species many of the same statutory protections given to native salmonids. Several non- native warm -water species known to prey on salmonid juveniles in Washington (such as smallmouth and largemouth bass, walleye, and channel catfish [Ictalurus punctatus]) are currently managed for sustained natural reproduction through regulations that limit the take of large individuals, which have the greatest reproductive potential (WDFW 2002). Although walleye and channel catfish are found primarily in the Columbia River, largemouth and smallmouth bass populations in dozens of Puget Sound area tributary systems are regulated to insure their continued survival. As shown in this review, Atlantic salmon have far less potential for adverse impacts on Puget Sound chinook salmon and Hood Canal summer -run chum salmon than the non - native species noted here. Extending management policies currently applied to escaped Atlantic salmon (no catch or size limits) to all non - native fish in Puget Sound would be the most effective method to decrease adverse impacts by nonindigenous fish on listed native Puget Sound salmonids. However, this is probably not feasible due to the tremendous economic and social value of non - native game fish species in local sport fisheries. Zook (1998) estimated that recreational angling for non - native game fish, including California- strain rainbow trout, contributed about $735 million annually to the economy in Washington State. 43 SCALE OF ARTIFICIAL PROPAGATION OF PACIFIC SALMON IN THE PACIFIC NORTHWEST Virtually all opinions about the negative biological impacts of escaped Atlantic salmon on native salmon in the Pacific Northwest are hypothetical, and have not been observed or documented in this region. They appear to be strongly associated with the belief that artificially propagated salmon, including Atlantic salmon, are bigger, stronger, and more vigorous than wild Pacific salmon. Although this opinion has been generally disproved, many studies and reviews, among them WDF et al. (1993) and NMFS' ESA - related status reviews (Weitkamp et al. 1995, Busby et al. 1996, Hard et al. 1996, Gustafson et al. 1997, Johnson et al. 1997, 1999, Myers et al. 1998a), have shown that adverse impacts from hatchery stocks of Pacific salmon can occur if and when hatchery fish comprise a significant portion of the total population. Therefore, it will be instructive to compare the numbers of artificially propagated Pacific salmon released each year to the number of Atlantic salmon estimated to escape each year. Such comparison will provide a perspective for evaluating which species or types of culture actually present the greatest risks to wild Pacific salmon, keeping in mind that recent changes in hatcheries strategies in the Pacific Northwest have been initiated to reduce or eliminate impacts sometimes associated with releases of artificially propagated Pacific salmon. Number of Artificially Propagated Pacific Salmon Released Each Year Mahnken et al. (1998) reported that several billion Pacific salmon were released from freshwater hatcheries and marine net -pens in North America each year, with most of these fish (about 1.4 billion per year) released from hatcheries in Alaska (McNair 1997, 1998, 1999) (see Table 5), although Washington, Oregon, Idaho, and California have more salmon hatcheries. Pacific salmon are released from hatcheries with the understanding that to survive, they must compete for food and habitat in common with native wild salmon. Until recently the capacity of the ocean pastures were thought to be limitless. However, recent investigations by Heard (1998), Cooney and Brodeur (1998), and Beamish et al. (2000), among others, show that food availability in the ocean fluctuates over time and might be limiting salmon abundance. Bisbal and McConnaha (1998) proposed that fishery managers planning to release large numbers of fish from hatcheries should take these fluctuations into account. Given the enormous numbers of Pacific salmonids released each year into Pacific Ocean ecosystems, including Puget Sound, the relatively few domesticated Atlantic salmon that escape could never pose a corresponding competitive threat to native Pacific salmon for forage or habitat. Survival of Artificially Propagated Pacific Salmon The success of a hatchery or net -pen facility, which in large part determines the degree to which hatchery fish potentially impact wild fish, is largely influenced by how well fish survive in MA the wild after release. Some hatchery programs are very successful at producing fish. Johnson et al. (1997) noted that hatcheries in Alaska, through extremely efficient early rearing strategies, produced prodigious numbers of adult chum and pink salmon, two species which normally have juvenile to adult survival rates of less than 0.5 %. The Hidden Falls Hatchery in southeast Alaska has frequently experienced survivals of 3 -8% with chum salmon (Bachen 1994), resulting in this single facility producing more than 22% of all the chum salmon, wild and hatchery, caught in the fisheries of southeast Alaska (Johnson et al. 1997). McNair (1998) reported that 93.6% of all pink salmon caught in Prince William Sound in 1997 were artificially propagated, and that for all salmon harvested in common property fisheries throughout Alaska that year, 22% of the coho salmon, 30% of the pink salmon, and 65% of the chum salmon originated in hatcheries. Overall, hatcheries contributed 26% of all salmon harvested in Alaska in 1997 (McNair 1998). This percentage increased to 34% in 2000 (McNair 2001). In Washington, WDFW (2000) estimated that hatcheries provide about 75% of all coho and chinook salmon harvested, as well as 88% of all steelhead harvested. Since West Coast hatcheries put enough artificially propagated salmon into the natural environments to produce a significant proportion of the harvest in Alaska and the overwhelming proportion of the harvest in Washington, including all ESUs in Puget Sound and Hood Canal, it is not possible that the competition for natural resources from present levels of escaped Atlantic salmon could be noticeable. Therefore, expressions of concern regarding competition for food from relatively small numbers of escaped Atlantic salmon (Carrel 1998, ADF &G 1999, 2002, PSGA 2000, Suzuki 2001) appear to be focused on the wrong species. The potential for adverse impacts on wild Pacific salmon through competition for natural resources is clearly greater from the enormous number of hatchery Pacific salmon in natural environments than from the relatively small number of domesticated Atlantic salmon that occasionally escape. Comparison of Numbers of Artificially Propagated Atlantic Salmon and Pacific Salmon in the Pacific Northwest The majority of Atlantic salmon escapes in Washington have occurred in Puget Sound. However, the number of escaped fish is extremely low compared with the number of Pacific salmon intentionally introduced into the Puget Sound and Hood Canal ESUs for chinook and summer -run chum salmon. The total number of hatchery chinook, coho, and chum salmon released into Puget Sound tributaries by various fisheries agencies between 1980 and 1992 exceeded 2.2 billion fish (NRC 1995, 1996). Although data are not yet available through the year 2001, it is predictably over 3 billion by now. For illustrative purposes, if all the Atlantic salmon which have escaped into Puget Sound since 1980 (assume 1 million) were represented on a bar graph by a bar about 3 cm high, the total number of Pacific salmon released into Puget Sound and its river basins since 1980 would be depicted on the same graph by a bar about 76 in high. Comparison with the 13.5 billion hatchery fish released into Alaskan waters since 1990 (McKean 1991, McNair 1995, 1996, 1997, 1998, 1999, 2000, 2001, Holland and McKean 1992, McNair and Holland 1993, 1994) is even more dramatic, and would require a bar almost 400 m high. The adverse ecological and genetic interactions sometimes associated with abundant releases of hatchery- reared Pacific salmon are well - documented and clearly present a greater risk for native salmonids in Puget Sound and Hood Canal than escaped Atlantic salmon, although this Ci is not meant to imply that the risk from hatchery stocks of Pacific salmon is severe under present, modified hatchery policies. However, no evidence in the literature pertaining to Atlantic salmon introductions was found that suggests that current levels of production would pose a manifest threat to the Puget Sound chinook salmon ESU or the Hood Canal summer -run chum salmon ESU. 47 POTENTIAL IMPACT OF SUCCESSFULLY REPRODUCING ATLANTIC SALMON IN PUGET SOUND Number of Naturally Produced Juvenile Atlantic Salmon that Would Approximate Impacts from Pacific Salmon Hatchery Programs in Puget Sound It would take a very large number of successfully spawning, escaped Atlantic salmon to produce enough progeny to approach the number of hatchery Pacific salmon juveniles introduced into streams in the Puget Sound ESU. For example, NRC (1995, 1996) reported that about 18 million pre -smolt coho salmon were released into Puget Sound tributaries each year between 1980 and 1992. Since then, the number of unsimolted coho salmon has been reduced by over half, due to changes in hatchery strategies (FPC 1999). Nonetheless, to survive in freshwater habitats, artificially propagated salmon fry planted into local rivers compete with native salmon for food and rearing space for up to 18 months. Using typical wild coho salmon life - history data (ODFW 1982), such as egg to smolt survival levels of 10% and a fecundity of 4,000 eggs per female, it would take about 46,000 mature, successful Atlantic salmon spawners (1:1 female:male ratio) to produce enough fry to equal the numbers of artificially propagated nonmigrant hatchery coho salmon planted in Puget Sound rivers every year. However, the likelihood of such an outcome is remote, given the well- documented negligible ability of introduced Atlantic salmon to prosper in habitats outside their native range. Number of Naturally Produced Juvenile Atlantic Salmon that Would Approximate Impacts from Pacific Salmon Hatchery Programs in the Green River On a more local scale, FPC (1999) reported that about 7,500,000 hatchery coho salmon fry were planted in the Green River between 1993 and 1996. To produce an equal number of Atlantic salmon juveniles, it would be necessary for over 9,000 mature Atlantic salmon adults to escape and spawn successfully in the Green River each year. However, Thomson and Candy (1998) reported fewer than 20 mature Atlantic salmon in all Washington river systems during 1997, although few streams were surveyed completely. As Puget Sound region stocks of farmed Atlantic salmon continue to be domesticated, there is little chance they will suddenly outperform native salmon in their natal streams. Best management practices for net -pen salmon farming continue to stress the importance of preventing escapes (BCSFA 1999), but any potential adverse impacts associated with escaped Atlantic salmon cannot begin to approach the potential impacts of fish released from Pacific salmon hatchery programs, even when recent beneficial changes in hatchery strategies are considered. 48 Number of Juvenile Atlantic Salmon Observed in the Pacific Northwest Fewer than 25 naturally spawned juvenile Atlantic salmon were recovered during counts of salmon juveniles in the Tsitika River in British Columbia in 1998 (A. Thomson 12). Although scale analysis confirmed that these fish were the progeny of naturally spawning adult Atlantic salmon (Volpe et al. 2000), it is not known whether these were first, second, or greater generation wild Atlantic salmon. During the same Tsitika River survey, Noakes (1999) noted that more than 10,000 juvenile Pacific salmonids were observed in the river. Therefore, the juvenile Atlantic salmon made up less than 1% of the juvenile salmonids in the river in 1998. Since 1998, 5 more juvenile Atlantic salmon have been observed in the Tsitika River (A. Thomson 12). Over 90% of all naturally produced Atlantic salmon juveniles discovered to date were found in 1998 and 1999. Interestingly, naturally produced Atlantic salmon juveniles were never observed in the same streams in which juvenile Atlantic salmon hatchery escapees were found (Table 3). It is possible that Atlantic salmon have been successfully spawning in the Pacific Northwest for the past 20 years and that this behavior has just recently been observed. Conversely, Atlantic salmon could be periodically introduced into local environments every so often via escaping adults without successfully colonizing new habitat, although naturally produced offspring may have been occasionally produced. In any event, no naturally produced Atlantic salmon have been observed in Washington rivers to date, although surveys specifically designed to find juvenile Atlantic salmon have not been conducted here, unlike the situation in British Columbia. 11 A. Thomson, DFO Canada, Pacific Biological Station, Nanaimo, BC V9R 5K6. Pers. commun., April 16, 2001. EE OTHER EVALUATIONS OF POTENTIAL RISKS FROM CULTURED ATLANTIC SALMON IN PUGET SOUND CHINOOK SALMON AND HOOD CANAL SUMMER -RUN CHUM SALMON ESUs Washington State Pollution Control Hearings Board In 1996, a consortium of organizations brought suit before the PCHB against the Washington State Department of Ecology (WDOE), WDFW, and Atlantic salmon farmers in Puget Sound. The suit (PCHB Nos. 96 -257 through 96 -268) challenged the issuance of National Pollutant Discharge Elimination System (NPDES) permits to the salmon farmers. The basis of the suit by the appellants was a series of allegations regarding conflict with other resources and perceived unacceptable environmental risks associated with the culture of Atlantic salmon, the effects of waste on the water column and benthic environment, and damage to other resources, including fish and shellfish. Following months of testimony by experts, on May 27, 1997, the PCHB denied partial summary judgment to the appellants because of a genuine issue of material fact as to whether escaped Atlantic salmon "shall cause or tend to cause pollution" under State law, and whether they constitute "a manmade change to the biological integrity of State water" under federal law (PCHB 1997b). The PCHB found that, "the Permittees' facilities do not create unresolved conflicts with alternative uses of Puget Sound resources as contemplated by RCW 43.32C.030(2)(e). The existence of commercial salmon farms as permitted does not preclude other beneficial uses in Puget Sound, such as shellfish harvesting, commercial or sport fishing, navigation, or recreational boating. Likewise, the existence of the salmon farms does not operate to the exclusion of available resources, such as native salmon runs, sediment and water quality, or marine mammals. In short, salmon farming in Puget Sound does not present the citizens of the State of Washington with an `either /or' choice with respect to other beneficial uses and important resources." The Board issued its Final Order on the matter on November 30, 1998, (PCHB 1998) and found: "no evidence that Permittees' facilities have impacts that effectively exclude other beneficial uses of available resources of Puget Sound. The escapement of Atlantic salmon from Permittees' facilities absent large regular releases in the future does not pose an unacceptable risk to native Pacific salmon in terms of competition, predation, disease transmission, hybridization, or colonization." This decision by the PCHB was not substantially different from that of the authors of the British Columbia Salmon Aquaculture Review (EAO 1997), who concluded that salmon aquaculture as currently practiced in British Columbia did not pose unacceptable risks to the environment. 50 Washington Department of Fish and Wildlife Atlantic Salmon Management Perspective Some fishery managers have expressed concerns that escaped Atlantic salmon may impact native fish stocks through "competition, predation, disease transfer, hybridization, and colonization" (summarized by Amos and Appleby 1999). In a review of the potential for adverse impacts on Pacific salmon from farmed Atlantic salmon, WDFW found there was no evidence that Atlantic salmon competed well against native species, or that they would prey on native species. Furthermore, WDFW recognized that diseases of Atlantic salmon in Puget Sound were the same as diseases of Pacific salmon, that the risk of Atlantic salmon hybridizing with native salmonids was low, and that colonization was an unlikely event (Amos and Appleby 1999). NMFS Biological Status Reviews of West Coast Pacific Salmon Stocks Since 1991 NMFS has published 15 biological status reviews as part of its obligation under ESA. These reviews are individual scientific compilations of the current status of all anadromous salmonid populations on the West Coast of the United States, excluding Alaska. These are generally regarded as the most complete scientific reviews of Pacific salmon abundance ever published. They form the basis for NMFS actions concerning ESA listing determinations, as well as the scientific basis for NMFS testimony for litigation and courtroom challenges to proposed and implemented listings under ESA. In these reviews, teams of experienced Pacific salmon scientists, known as the NMFS BRTs for ESA Status Reviews, have identified many factors that have adverse effects on salmonids of the West Coast (Weitkamp et al. 1995, Busby et al. 1996, Hard et al. 1996, Gustafson et al. 1997, Johnson et al. 1997, 1999, Myers et al. 1998a). The potential biological impacts of artificially propagated Pacific salmon have consistently been identified as one of several primary factors impacting wild salmonids (Hard et al. 1992, Waples 1991). However, Atlantic salmon farms have not been identified as causing adverse effects on Pacific salmon in any of the status reviews conducted to date, which cover 55 separate ESUs for Pacific salmon species, nor have Atlantic salmon been suggested as a factor for decline of Puget Sound chinook salmon or Hood Canal summer -run chum salmon (NMFS 1996, 1998). 51 POTENTIAL IMPACTS OF SALMON FARMS IN PUGET SOUND ON ESSENTIAL FISH HABITAT In addition to concerns about adverse impacts to native salmonids resulting from escapes of Atlantic salmon, conjecture has been raised that organic input to the EFH and over -water structures associated with salmon farming will have a significant negative effect on nearshore estuarine and marine habitats used by juvenile salmon in the Puget Sound chinook salmon ESU (Eglick 1990, McMather 1990). (There are no commercial salmon farms in the Hood Canal summer -run chum salmon ESU.) Apprehension about potential water column impacts, such as reduced dissolved oxygen (DO) levels and the stimulation of phytoplankton blooms, are most commonly expressed, as well as concerns about accumulation of organic and inorganic material and chemotherapeutants in the sediments under and in the vicinity of the salmon farms. These issues have been extensively evaluated over the last 15 years in Puget Sound and elsewhere. Therefore, only a brief review of the pertinent findings will be presented here. Water Column Impacts Dissolved nitrogen added to the water column by salmon farms is essentially not measurable more than 9 m away from the perimeter of the farm. Correspondingly, there was no measurable effect on phytoplankton production near salmon farms, even in countries with substantial development of salmon farms (Pease 1977, Weston 1986, Rensel 1988, Parametrix 1990). Salmon farms in Puget Sound had little to no effect on levels of DO in the water column immediately adjacent to the farms (Weston 1986, Brooks 1995). Clam Bay, Washington, location of the NMFS Manchester Research Station since 1969, and also the location of one of the largest salmon farms in the world since 1972, may be used as an example of the type of effects on EFH water quality that can be expected from a well- sited, large fish farm. In 1979 the U. S. Environmental Protection Agency (EPA) Region X Water Quality Laboratory was constructed on the shore of Clam Bay next to the NMFS Manchester Research Station. During most of the 1980s, this laboratory used oyster larvae bioassays to determine the level of pollution in water samples taken from other areas in the Pacific Northwest. The EPA laboratory used water pumped from Clam Bay as the clean, control baseline water against which oyster larvae survival in polluted water was compared. The laboratory drew the control water less than 200 m from the salmon farm. If the salmon farm had adversely effected the ambient water quality, the EPA investigations would have been severely compromised. However, there are no reports that they were compromised. During the same period, a study investigating the best places in Puget Sound for mussel culture found that Clam Bay was a poor site for mussel culture as the waters there were "clear, deep blue," and that "large blooms of phytoplankton to support fast growth are rarely found" (Skidmore and Chew 1985). The NMFS Manchester Research Station was involved in a plethora of important scientific studies with salmon during this period, all of which required the use of high quality seawater. Concurrent with the EPA and NMFS work and the mussel study, the commercial salmon farm in Clam Bay reared about 3 million fish per year. Claims that salmon farms will adversely affect EFH by polluting the water or stimulating blooms of phytoplankton have not been verified by numerous 52 scientific investigations conducted in Clam Bay during a period of intense salmon farming. It should be noted that the salmon farm site in Clam Bay does not meet current Washington State siting criteria, which require specific depths and tidal flows for salmon farm location (WDOE 1986). Because the salmon farm was in existence before siting criteria were developed, it was allowed to remain at its present site. However, the Clam Bay situation can be used to demonstrate that the salmon farm siting criteria used in Puget Sound since 1986 adequately protects the environment occupied by ESA - listed chinook and summer -run chum salmon. Comparison to Benthic Impacts of Other Activities in the Pacific Northwest Sewage Treatment Plants Since the area beneath salmon farms is organically enriched by uneaten fish food and by fish feces, salmon farms have often been likened to sewage treatment plants (McMather 1990, Ellis 1996). However, this simile is not accurate, at least for salmon farms in Puget Sound, for several reasons. First, the organically enriched area beneath a salmon farm (Weston 1986, Mahnken 1993, Brooks 2000) is far less extensive than the area impacted by a sewage treatment plant (Brown et al. 1987, Taylor et al. 1998). Second, waste from a salmon farm does not contain the metals and industrial hydrocarbons associated with sewage wastes. Third, the time required for biological remediation at a fish farm site ranges from about five months to several years ( Mahnken 1993, Brooks 2000), whereas the period for full remediation at a sewage outfall can easily be at least 10 years (Rosenberg 1976, Pearson and Rosenberg 1978, Shillabeer and Tapp 1989). And finally, demersal fish bearing tumors and lesions have not been observed nearby or associated with salmon farms in Puget Sound, unlike the situation near sewage treatment plants and other contaminated areas of Puget Sound, where diseased and cancerous fish are commonly observed (Myers et al. 1998b). Fish Processing Plants It has been estimated that salmon farms in Puget Sound produce about 0.7 kg of solid waste for each kg of fish produced (Weston 1986). At current levels of production, about 7300 t (P. Granger), all Puget Sound salmon farms produce a cumulative total of about 5000 t of solid organic waste per year. By comparison, seafood processing plants discharge substantially more organic material onto the benthos. For example, individual seafood processing plants at numerous locations, mostly in Alaska, discharge 20,000 to 30,000 t of organic material per year into nearshore waters (NMFS 2001a). The waste pile atone plant was estimated to be 200 min diameter and 7 m deep, and at another location, the waste pile covered 4.5 ha to a depth of 1 m (NMFS 2001a). The negative effects on the environment from large waste piles such as these would certainly be enormous compared to impacts associated with the relatively small amount of solid waste produced by Puget Sound salmon farms. However, NMFS (2001a) found that the discharges from seafood processing plants in Alaska "appear to be localized and would not be expected to adversely affect threatened or endangered species under NMFS jurisdiction." 53 Similarly, the markedly smaller organic discharges from Puget Sound salmon farms do not seem likely to adversely affect threatened salmonids in Puget Sound. °4 55 SCALE AND IMPACTS OF SIMILAR ACTIVITIES IN PUGET SOUND Scale of Salmon Farms and Other Aquaculture Salmon Farms In 1986 there were 9 sites in Puget Sound where coho salmon or Atlantic salmon were raised commercially in net -pen facilities (Weston 1986). In addition, at that time there were 5 major and 8 minor noncommercial net -pen facilities used by WDFW, tribes, or sportsmen's clubs for delayed release of coho and chinook salmon. By 1990 there were 13 commercial sites, each limited to a total surface area of less than 0.8 ha (WDF 1990a). WRAC (1999) reported 6 companies with leases to sites in Washington in 1997. These included Domsea Farms Inc. (5 sites), Global Aqua USA Inc. (3 sites), Moore -Clark Co. (USA) Inc. (3 sites and a hatchery), Scan Am Farms (3 sites), Sea Farm Washington (3 sites), and British Petroleum (1 site). In the last five years, there has been considerable restructuring in the salmon aquaculture industry worldwide, with some companies consolidating their position through merger or purchase of smaller companies. Consequently, much of the global industry is now dominated by a few international companies, although individual farms may still operate under the name of the registered leaseholder. In Washington 4 different companies now hold the leases to 12 licensed net -pen production sites, of which 9 licensed sites are in production. These are: • Cypress Island Inc., which has 3 leases by Cypress Island outside Anacortes and 1 lease in Skagit Bay, and under Northwest Farms, 3 leases in Rich Passage, 1 in Port Angeles Harbor (formed by combining 2 previous leases), and 1 by Hartstene Island currently not in use. • Sunpoint Systems, which has 1 lease in Rich Passage. • Jamestown S'Klallum Tribe, which has 1 lease in Discovery Bay, but not in use. • Ocean Spar Technologies, a sea -cage manufacturing company, which has 1 lease by Whiskey Creek near Port Angeles for research and development trials, but not in use. In the State of Washington, statistics provided by the Washington State Department of Natural Resources (WDNR 200 1) indicate there are 67.5 ha currently leased by companies for commercial salmon net -pens, a further 15.7 ha currently leased by the State, tribes, and private enterprises for net -pens used for the delayed release of native salmon, and 0.2 ha for herring net - pens. All these sites have a different limit for the water surface area leased (for anchorage and navigational protection) and the internal surface area for the net -pens in production. The 9 commercial sites currently operational in Puget Sound have a total of 53 ha under lease from the State (ranging from 0.8 to 9.7 ha in size), with a total of 8.7 ha permitted for internal pen structures for all Puget Sound salmon farms combined (range 1,951 m2 to 15,793 m2) (K. Bright 1). 56 Oyster Farms By comparison, other activities in Washington, such as other types of aquaculture and marinas, use habitats similar to those used by salmon farms in Puget Sound, but require substantially more space. For example, 585 ha of State -owned aquatic lands are leased for oyster farming, primarily in Willapa Bay (WDNR 2001). Scale and Impacts of Marinas in Puget Sound Scale of Marina Development The surface area of Puget Sound covered by salmon farms is insignificant compared to the surface area covered by marinas. The total surface area actually covered by floating structures for all salmon farms in Puget Sound combined, about 8.7 ha of State -owned aquatic lands (WDNR 2001), is much less than the total surface area occupied by several of the larger marinas located on State -owned aquatic lands. All the above -water structures at salmon farms in Puget Sound would fit several times over inside each of several large Seattle -area marinas such as the Elliott Bay Marina, Shilshole Bay Marina, or Fisherman's Terminal (Port of Seattle 2001, Serdar and Cubbage 1996). The Shilshole Bay Marina alone covers 32.1 ha between the shoreline and breakwater, with about 3 ha of this area covered by over -water structures such as floats and vessels (T. Wheeler 13). In addition, marinas are much more numerous than salmon farms in Puget Sound. Goodwin and Farrel (1991) published a directory of marinas and moorage facilities in the State and listed 379 facilities, about 150 of which were located in the marine waters of Puget Sound. Kitsap County, where most of the salmon farms in Puget Sound are located, had 26 facilities and more than 2,900 wet moorage slips. The 20 facilities in Kitsap County that completed the survey data offered a total of more than 6.4 km of float space to moor commercial and recreational boats. Because most marinas are adjacent to the shore and required some dredging to accommodate vessels, marinas have probably eliminated some areas which previously had been important nearshore habitat for juvenile chinook and summer -run chum salmon in Puget Sound, primarily eel grass beds (Healey 1991). By contrast, sites permitted for salmon farms are restricted to deeper waters to minimize impacts on benthic communities (WDOE 1986). Many marinas are protected by breakwaters which may inhibit free flow of water and may impede passage of nearshore migrating juvenile chinook and summer -run chum salmon, whereas free - flowing water is essential at a salmon farm. Environmental Impacts of Marinas Based upon past studies of marinas for WDF, Cardwell et al. (1980) considered reduced DO and increased water temperature the greatest potential threat to aquatic organisms in Puget Sound marinas. Potential threats such as fecal coliforim bacterial contamination of shellfish, the leaching of antifouling paints, and the introduction of hydrocarbons via the exhausts of outboard motors were also identified (PSWQAT 2001, Cardwell et al. 1980). Subsequently, Cardwell and Koons (198 1) documented several water quality perturbations within marinas and moorage " T. Wheeler, Port of Seattle, P.O. Box 1209, Seattle, WA 98111. Pers. commun., November 6, 2001. 57 facilities in Puget Sound. Pollutant inputs included runoff from parking lots and storm drains, hydrocarbons from outboard motor exhaust, heavy metals from antifouling paints, and biocides such as creosote and pentachlorophenol in wood piling and docks. Indirect effects resulted from nocturnal reductions in DO due to respiration from blooms of phytoplankton and diurnal elevations in water temperature due to solar radiation. By contrast, salmon farms sited under current WDOE guidelines only slightly reduce DO, do not increase water temperature (Brooks 2000), and cold - blooded animals such as salmon do not produce fecal coliform bacteria (Geldreich and Clarke 1966). Although some salmon farms in Puget Sound use tarred nets similar to those used by commercial salmon fishermen, use of chemical antifoulants is restricted to the same compounds used on the hulls of the commercial and recreational salmon fleets. Most, if not all salmon farms in Puget Sound are constructed of either plastic or metal, while concrete and wood, sometimes treated, is the material of choice in most marinas. Since floating wooden structures associated with marinas cover much more surface acreage than salmon farms in Puget Sound, marinas would therefore constitute the primary source of wood preservation chemicals entering the marine environments of Puget Sound from floating structures. An examination of sediments in and near a marina in Port Townsend, Washington, found that concentrations of copper, lead, zinc, butylated tins, polyaromatic hydrocarbons, and total organic carbon were elevated compared to sediments outside the marina. The zone of influence from the marina was observed to extend for a distance of about 150 m from the entrance (Crecelius et al. 1990), a somewhat greater distance than the zone of impact typically observed at Puget Sound fish farms (Capone et al. 1994). In a similar study, also conducted in Port Townsend, concentration of metals in sediments under an Atlantic salmon farm were similar to those found at a control site at Point Wilson in the Strait of Juan de Fuca. However, for selenium, beryllium, silver, arsenic, lead, copper, and zinc, the concentrations of metals under the salmon pens were less than those found near a local marina (same marina as above) in Port Townsend (Johnson 1988). Another study in Puget Sound found that several marinas violated Washington State water temperature and oxygen concentrations standards, primarily due to poor flushing (Cardwell et al. 1980). Unlike marinas, which may introduce elevated levels of toxic chemicals to the environment, the primary impact from salmon farms consists of organic enrichment and, in some cases, short-term inputs of antibiotic residues, which also may occur at public fish- culture facilities. Since marinas occupy at least 100 times the total nearshore acreage of salmon farms in Puget Sound, they clearly are a greater source of pollutants introduced to EFH. However, although marinas are a significantly greater source of toxic chemicals than Atlantic salmon farms in Puget Sound, Crecelius et al. (1990) concluded that if the toxic input from all marinas in Puget Sound were similar to the marina in Port Townsend mentioned above, the total environmental impact would be very small: the annual influx of metals and other contaminants from marinas would be less than a 1% addition to the total input to the main Puget Sound Basin from other sources. Since the total inputs of chemical pollution to Puget Sound from salmon farms are much less than inputs from marinas, it is unlikely that the environmental impacts of salmon farms are equal to or greater than the small overall impacts noted for marinas. 59 ESSENTIAL FISH HABITAT AND THE MAGNUSON- STEVENS ACT The potential impacts of public and private fish and shellfish on EFH have been addressed in Section 3.2.3, Appendix A, of the Essential Fish Habitat Provision of the amended Magnuson- Stevens Fishery Conservation and Management Act (Public Law 94 -265). It is the responsibility of NMFS and the eight regional Fishery Management Councils, under authority of the Secretary of Commerce, to: describe and identify EFH in each fishery management plan, minimize to the extent practicable the adverse effects of fishing on EFH, and identify other potentially deleterious actions to encourage the conservation and enhancement of EFH. The potential adverse impacts to EFH on the West Coast can be found on the Pacific States Marine Fisheries Commission's Web site at: www.psmfc.org /efh.html. Primary recommendations in Section 3.2.3, Appendix A, to minimize adverse fish culture impacts include following established guidelines and policies regarding disease prevention and the use of chemotherapeutics, and the use of stocks in hatcheries and salmon farms that will have little or no impact on native salmon. The farming of Atlantic salmon in Puget Sound currently adheres to the EFH guidelines. 61 REGULATORY STRUCTURE FOR COMMERCIAL AQUACULTURE ENTERPRISES IN WASHINGTON AND PUGET SOUND Most of the extensive body of scientific information pertaining to salmon farming published in the last several decades has already been integrated into the regulatory processes of Washington State. This information has been incorporated into State regulations relating to farm fish escapes, antibiotic residues in sediments, accumulation of organic wastes on the seabed, importation of non - native and non -local species, and disease management. These and other important regulations and documents pertaining to private salmon farming include: • Final programmatic Environmental Impact Statement for fish culture in floating net -pens (WDF 1990b) • Recommended interim guidelines for the management of salmon net -pen culture in Puget Sound (WDOE 1986) • Environmental effects of floating mariculture in Puget Sound (Weston 1986) • Environment fate and effects of aquacultural antibacterials in Puget Sound (Weston et al. 1994) • Disease control policies of Washington (NWIFC/WDF 1991) • Disease control policies of the United States (USFWS 1984) • Fish health manual of the WDFW (1996) • Marine finfish aquaculture escape prevention reporting and recapture plan (WAC 220 -76- 100 to WAC 220 -76 -160) The policies and regulations (and their enforcement) for aquaculture introductions in Washington State and British Columbia were reviewed and summarized in detail by Elston (1997) in a study of pathways and management of marine nonindigenous species into the shared waters of British Columbia and Washington. Shellfish and finfish aquaculture had been identified as one of six potential pathways for nonindigenous species introductions for the study, and in his final report to the Puget Sound Water Quality Authority, the EPA, and the DFO Canada, he stated that the adequacy of information available to assess the relative risks of introductions through aquaculture was good, because for more than a decade, Washington State and British Columbia have had in place state /provincial and federal procedures specific to aquaculture. He noted that intentional introduction of fish and shellfish species was now far more restricted than in the past, and that technology could assist further in reducing the risk from exotic species introductions by, for example, culturing only strains of sterile organisms. Elston (1997) concluded that the risk of introductions from aquaculture was well - defined, the industry was highly regulated, and active processes were underway for continuous review of aquaculture activities as they involved nonindigenous species. 62 Agencies Regulating Salmon Farming in Washington State of Washington Agencies Traditionally, the policy of the State of Washington has been supportive of aquaculture. The State was one of the first to recognize that aquaculture was a form of agriculture and enacted legislation in 1985 that designated the Washington State Department of Agriculture (WSDA) as the lead agency, with WDF (now WDFW) responsible for regulations pertaining to disease control and prevention. Recently, Second Substitute House Bill 1499 gives WDFW the authority to require all fish farms in Washington to prevent, report, and recapture escaped fish. The current policy of the State fosters the commercial and recreational use of the aquatic environment for production of food, fiber, income, and public enjoyment from State -owned aquatic lands, and identifies aquaculture among legitimate uses. In its policy implementation manual for the use of the State's aquatic resources (WDNR 2000), shellfish and finfish aquaculture is specifically designated as an aquatic land use of State -wide value. The WDNR generally encourages this use and it takes precedence over other water - dependent uses that have only local interest values. While commenting on the possible environmental impact on aquaculture by surrounding activities and vice versa in a discussion on net -pens and floating rafts, the manual states again that aquaculture remains a favored use of State -owned aquatic lands. WDNR (1999) recently published a technical report on the potential for offshore finfish aquaculture in the State. Amos and Appleby (1999) summarized the roles and responsibilities of the regulatory authorities in the State of Washington with regard to the management of salmon farming in State waters, and particularly Atlantic salmon farming. Their summary forms the basis of the following overview of the regulatory structure for commercial farms producing either Pacific or Atlantic salmon. Washington Department of Fish and Wildlife WDFW has management and regulatory authority over all free - ranging fish in the State. The authority of WDFW over commercial fish culture in State waters is restricted to disease control, prevention of escapes, and protection of wildlife in general. Within this authority: • The Fin Fish Import and Transfer Permit (WAC 220 -77 -030) assures that diseases, pests, and predators are not introduced or transferred. In addition, under a legal settlement, WDFW is required to kill and conduct biological examination of any Atlantic salmon encountered by agency staff. • Regulation of Marine Fin Fish Aquaculture (WAC 220 -76 -110 to WAC 220 -76 -160) gives WDFW authority over fish that have escaped from a salmon farm. • Hydraulic Project Approval (RCW 75.20.100, WAC 220 -120), or HPA, assures that all construction projects ensure protection of wildlife and habitats. However, the authority of WDFW to require HPAs of aquaculture workers at their sites is not clear. 63 Washington State Department of Ecology WDFW, in association with WDOE and WDNR, provides guidance to State and local agencies siting farms to avoid adverse impacts on the environment. In association with WSDA, it develops disease control regulations with regard to human health and safety. WDOE has regulatory authority over discharges of pollutants into State waters for the protection, preservation, and enhancement of the environment. Within this authority: • The National Pollution Discharge Elimination System Permit (40 CFR 122.21), or NPDES, assures compliance with state and federal water quality laws. • The Water Discharge Permit (RCW 90.48) assures that discharges and wastes do not adversely affect water quality and standards. Under the Clean Water Act and the Water Pollution Control Act, WDOE can take regulatory action against net -pen operators who allow Atlantic salmon to escape. This follows the determination by the PCHB that escaped Atlantic salmon are "pollutants," primarily because they escaped from a point source (PCHB 1998), the fish themselves constituted biological material, and are a species not native to Puget Sound. The PCHB also adjudicates appeals over permits issued by WDOE. In association with WDFW and WDNR, WDOE provides guidance to State and local agencies on siting farms to avoid adverse impacts on the environment. Washington State Department of Natural Resources WDNR has regulatory authority over State -owned aquatic lands, including all bedlands of Puget Sound, navigable rivers, lakes, and other waters. The authority also extends over lands covered and exposed by the tide, and most shores of navigable lakes and other fresh waters. Within this authority, the Aquatic Lands Lease (RCW 79.90- 79.96), or ALL, assures that all uses of the land and the proposed facilities are as specified. WDNR, in association with WDFW and WDOE, provides guidance to State and local agencies on siting farms to avoid adverse impacts on the environment. Washington State Department of Agriculture WSDA is responsible for assuring the safety of the State's food supply, providing protection from diseases and pests, and facilitating movement of agriculture products in domestic and international markets. With WDFW it jointly develops disease control regulations with regard to human health and safety. Local counties in Washington State act as lead agencies for applying the environmental policies of the State and the management of their respective county shorelines. Among relevant authorities: • The State Environmental Policy Act (RCW 43.21C, WAC 197 -11), or SEPA, assures consideration of social and environmental impacts of proposed actions. • The Shoreline Management Act (RCW 90.58), or SMA, assures appropriate and orderly development of State shorelines, management of their uses, and preservation of their natural character. 64 Federal Agencies A number of federal agencies (NMFS, U.S. Army Corps of Engineers, USFWS, U.S. Coast Guard, and EPA), together with respective State agencies (WDFW, WDOE, WDNR, WSDA), have management and regulatory authority over the use of all waters by the public. NMFS administers the ESA for anadromous salmonids, including authorizing Section 10 Exception Permits, which assures protection of public interests, including navigation, water safety, and water quality. In collaboration with USFWS and WDNR, NMFS permits the use of predator control methods (nonlethal) for birds and mammals in accordance with permit restrictions. The FDA is responsible for the protection of consumers by enforcing the Federal Food, Drug, and Cosmetic Act, and several related public health laws. It is also responsible for the safety of feed and drugs for pets and farm animals. Salmon and trout farmers are restricted to the use and conditions of veterinary medicines, drugs, growth enhancers, and other chemical supplements licensed by the FDA. The Treaty Tribes of the State of Washington co- manage fisheries resources in the State with WDFW and have input into finfish culture regulations in common with WDFW. The Regulatory Structure for Public and Tribal Hatcheries in Washington Public and tribal hatcheries producing Pacific salmon (and other fish) in Washington State must conform to the same general directives that regulate commercial hatcheries and farms (see WDFW subsection above). These regulations, as described, are concerned with protection of the environment or the health and safety of other plants and animals, including human consumers. However, since 1994 when a number of Pacific salmonid species in the region were listed for protection under the ESA, there have been some differences in regulations for public and tribal hatcheries that rear federally listed salmonids. Generally, the production of listed salmon populations in public and tribal hatcheries is now restricted to recovery purposes only, and not to provide fish for subsequent commercial or recreational harvest. As part of this approach, NMFS (2001b) has been working with management agencies in the region to develop Hatchery and Genetic Management Plans. The HGMP procedure provides a thorough description of each hatchery operation, including the facilities used, methods employed to propagate and release fish, and measures of performance. There are also sections dealing with the status of listed stocks that may be affected by the plan, anticipated listed -fish "take" levels, and a description of measures to minimize risk to listed fish. However, once the HGMP is completed, accepted, and followed, hatchery managers are assured that their activities are all in compliance with ESA and no further permitting is required. M CONCLUSIONS REGARDING POTENTIAL IMPACTS OF ATLANTIC SALMON CULTURE IN PUGET SOUND These conclusions regarding the potential impacts of Atlantic salmon culture on the Puget Sound chinook salmon and Hood Canal summer -run chum salmon ESUs are based on three important assumptions. The first assumption is that the salmon farming industry in Puget Sound remains approximately the same size as currently or in the recent past. A significant expansion of the industry may increase risks and would require a reconsideration of some of the potential impacts discussed in this review. The second assumption is that salmon farms in Puget Sound continue to rear only Atlantic salmon. Should the local industry shift production to coho or chinook salmon or to steelhead, the risks for hybridization, dilution of the gene pool, colonization, and competition for natural resources with wild salmonids will be greater than they are now with Atlantic salmon culture. Third, these conclusions assume that Atlantic salmon farmers in Washington continue to use only stocks presently in culture and that no new Atlantic salmon stocks are brought into the State. Based on these assumptions, this review draws the following risk assessment conclusions: It finds no risk for one parameter, low risk for several parameters, little risk for other parameters, and no parameters for which the potential impacts from Atlantic salmon farms in Puget Sound are considered to be serious or even moderate. In particular: 1. There is little risk that Atlantic salmon which escape from net -pen farms will hybridize with Pacific salmon or dilute the native gene pool. Atlantic salmon x Pacific salmon hybrids are not observed in nature, whether for introduced Atlantic salmon in western North America or for North American salmonids introduced to Europe and the other continents. By comparison, successful interspecific and intraspecific hybridization between North American salmonids has been regularly recorded. 2. At present, there is no risk of adverse genetic interaction between transgenic farm fish and wild salmon in Puget Sound, as there are no transgenic salmon being commercially cultured in Washington and no plans to raise them here in the future. 3. There is little risk that Atlantic salmon will colonize habitats in the Puget Sound chinook salmon and Hood Canal summer -run chum salmon ESUs. Atlantic salmon of various sizes occasionally escape into the waters of Puget Sound. Deliberate releases of Atlantic salmon have failed to establish local self - sustaining populations anywhere in the Northern Hemisphere outside their native range. Monitoring programs in British Columbia find naturally produced juveniles from time to time, but naturally produced adults have not been observed. 4. There is a low risk that the presence of salmon farms will increase the incidences of disease among wild fish. The specific diseases and their prevalence in Atlantic salmon stocks cultured in net -pens in Puget Sound are no different than those of the more numerous cultured stocks of Pacific salmon in hatcheries, which in turn have not been shown to have a high risk for infecting wild salmonids. All Pacific and Atlantic salmon stocks currently cultured in Washington are inspected annually for bacterial and viral pathogens, and the movement of fish from place to place is regulated by permit. I 5. There is little risk that existing stocks of Atlantic salmon will be a vector for the introduction of an exotic pathogen into Washington State. Movements of fish into and within Pacific Northwest states are well - regulated, including the requirement for disease -free certification. No Atlantic salmon stocks have been transferred into Washington State since 1991 6. There is little risk that the development of antibiotic- resistant bacteria in net -pen salmon farms or Atlantic salmon freshwater hatcheries will impact native salmonids. All drugs used in Atlantic and Pacific salmon hatcheries are safe and efficacious and approved by the FDA. Drug resistant bacteria have been commonly observed in fish culture facilities in Washington State for over 40 years and no resulting adverse impacts on wild salmonids have been reported. 7. There is little risk that escaped Atlantic salmon or their progeny will become an introduced non - native species that will be a predator of indigenous species. Analyses of the stomachs of recovered farm Atlantic salmon and of the few naturally produced juveniles caught in the wild have shown that only a few juvenile Pacific salmon have been eaten by Atlantic salmon. Other introduced non - native species are credited with consuming hundreds of thousands of juvenile salmon in, for example, one reservoir of the Columbia River. These non - native predators have been deliberately or accidentally introduced and are now managed for sustained natural reproduction to enhance recreational fisheries and contribute to sport fishing revenues. 8. The risk that escaped Atlantic salmon or their progeny will compete with native salmonids for natural forage is low. Few prey items of any sort have been found in the stomach contents of escaped Atlantic salmon of any size. The few natural prey items any escaped fish might consume is negligible compared with the food requirements of the tens of millions of hatchery- reared juvenile Pacific salmon released each year into Puget Sound and its tributaries. 9. The risk of adverse impact to EFH is low because the salmon farming industry is well - regulated at local, state, and federal levels. 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NMFS - NWFSC -44, 275 p. NTIS PB2001- 105562. 43 Methot, R.D. 2000. Technical description of the stock synthesis assessment program. U.S. Dept. Commer., NOAATech. Memo. NMFS - NWFSC -43, 46 p. NTIS PB2001- 105560. Most NOAA Technical Memorandums NMFS -NWFSC are available on -line at the Northwest Fisheries Science Center web site (http: / /www.nwfsc.noaa.gov). NOAA Technical Memorandum NMFS - NWFSC -49 The Net -pen Salmon Farming Industry in the Pacific Northwest September 2001 U.S. DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration National Marine Fisheries Service NOAA Technical Memorandum NMFS Series The Northwest Fisheries Science Center of the Na- tional Marine Fisheries Service, NOAA, uses the NOAA Technical Memorandum NMFS series to issue informal scientific and technical publications when complete formal review and editorial processing are not appropriate or feasible due to time constraints. Documents published in this series may be referenced in the scientific and technical literature. The NMFS -NWFSC Technical Memorandum series of the Northwest Fisheries Science Center continues the NMFS -F/NWC series established in 1970 by the Northwest & Alaska Fisheries Science Center, which has since been split into the Northwest Fisheries Science Center and the Alaska Fisheries Science Center. The NMFS -AFSC Technical Memorandum series is now being used by the Alaska Fisheries Science Center. Reference throughout this document to trade names does not imply endorsement by the National Marine Fisheries Service, NOAA. This document should be cited as follows: Nash, C.E. (editor). 2001. The net -pen salmon farming Industry in the Pacific Northwest. U.S. Dept. Commer., NOAA Tech. Memo. NMFS - NWFSC -49, 125 p. NOAA Technical Memorandum NMFS - NWFSC -49 The Net -pen Salmon Farming Industry in the Pacific Northwest Edited by Colin Nash From contributions by Kenneth M. Brooks (consultant) *, William T. Fairgrieve, Robert N. Iwamoto, Conrad V.W. Mahnken, Colin E. Nash, Michael B. Rust, Mark S. Strom, and F. William Waknitz Northwest Fisheries Science Center Resource Enhancement and Utilization Technologies Division 2725 Montlake Boulevard East Seattle, Washington 98112 *Aquatic Environmental Sciences 644 Old Eaglemount Road Port Townsend, Washington 98368 September 2001 U.S. DEPARTMENT OF COMMERCE Donald L. Evans, Secretary National Oceanic and Atmospheric Administration Scott B. Gudes, Acting Administrator National Marine Fisheries Service William T. Hogarth, Acting Assistant Administrator for Fisheries Most NOAA Technical Memorandums NMFS -NWFSC are available on -line at the Northwest Fisheries Science Center web site (http: / /www.nwfsc.noaa.gov) Copies are also available from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 phone orders (1-800-553-6847) e -mail orders (orders @ntis.fedworld.gov) Acknowledgements Thirty-five copies of this document in draft were circulated globally in April and May, 2001 for review and comment. The authors acknowledge the added contributions of the following individuals: Hans Ackefors (University of Stockholm, Sweden) Kevin H. Amos (Washington Department of Fish and Wildlife) Andrew Appleby (Washington Department of Fish and Wildlife) Faye M. Dong (University of Washington, Seattle, Washington) John Forster (Forster Consulting Inc., Port Angeles, Washington) Peter Granger (Washington Fish Growers Association, Bellingham, Washington) James P. McVey (National Sea Grant Program, NOAA, Washington D.C.) John E. Rensel ( Rensel Associates Aquatic Science Consultants, Arlington, Washington) Andrew J.L. Thomson (Fisheries and Oceans, Nanaimo, B.C. Canada) iii Acronyms of Organizations and Common Terms ACE US Army Corps of Engineers ADF &G Alaska Department of Fish and Game ALL Aquatic Lands Lease APHA American Public Health Association BC British Columbia (Canada) BCSAR British Columbia Salmon Aquaculture Review BCSGA British Columbia Salmon Growers Association (Canada) BMP Best Management Practice CFOI Census of Fatal Occupational Injuries CFR Code of Federal Regulations (Food and Drug Administration) COP Code of Practice DOC United States Department of Commerce DOI United States Department of the Interior DFO Department of Fisheries and Oceans (Canada) EAO Environmental Assessment Office (Canada BC) EEZ Extended Economic Zone EPA United States Environmental Protection Agency ESA Endangered Species Act 1974 ESU Evolutionarily Significant Unit EU European Union FAO Food and Agriculture Organization (United Nations) FDA United States Food and Drug Administration FPC Fish Passage Control (Oregon) HACCP Hazard Analysis Critical Control Point HGMP Hatchery and Genetic Management Plan HIE Highlands and Islands Enterprises (Scotland) HPA Hydraulic Project Approval GDP Gross Domestic Product GDU Genetic Diversity Unit GESAMP Joint Group of Experts on Scientific Aspects of Marine Environmental Protection (United Nations) GLP Good Laboratory Practice GM Genetically Modified GMO Genetically Modified Organism ICOR Interagency Committee for Outdoor Recreation (Washington State) INAD Investigational New Animal Drug JSA Joint Sub - Committee on Aquaculture MLLW Mean Low Low Water NADP National Aquaculture Development Plan NBSGA New Brunswick Salmon Growers Association (Canada) NMFS National Marine Fisheries Service (NOAA) NOAA National Oceanographic and Atmospheric Administration NPAFC North Pacific Anadromous Fish Commission NPDES National Pollution Discharge Elimination System Permit NRC Natural Resources Consultants NSGCP National Sea Grant College Program (NOAA) NSSP National Shellfish Sanitation Program NWFSC Northwest Fisheries Science Center NWIFC Northwest Indian Fisheries Commission OAR Office of Oceanic and Atmospheric Research (NOAA) ODFW Oregon Department of Fish and Wildlife ODIN Official Documentation and Information from Norway OSU Oregon State University PCHB Pollution Control Hearings Board (Washington State) PNP Private Non - Profit (Aquaculture Organizations, Alaska) PNWFHPC Pacific Northwest Fish Health Protection Committee PSMFC Pacific States Marine Fisheries Commission PSEP Puget Sound Estuary Protocols PSGA Puget Sound Gillnetters Association PSWQAT Puget Sound Water Quality Action Team RCW Regulatory Code of Washington REUT Resource Enhancement and Utilization Technologies Division (Northwest Fisheries Science Center) SCAN Scientific Committee on Animal Nutrition (European Union) SEPA (Washington) State Environmental Policy Act SEPA Scottish Environmental Protection Agency SIC Standard Industrial Classification (Index) SMA (Washington) Shoreline Management Act SOAEFD Scottish Office, Agriculture Environment and Fisheries Department SSFA Shetland Salmon Farmers Association (Scotland) USCG United States Coast Guard USDA United States Department of Agriculture USFWS United States Fish and Wildlife Service USOFR United States Office of Federal Regulations WAC (State ol) Washington Administrative Code WDA State of Washington Department of Agriculture WDF State of Washington Department of Fisheries (before 199 1) WDFW State of Washington Department of Fish and Wildlife WDL State of Washington Department of Licensing WDNR State of Washington Department of Natural Resources WDOE State of Washington Department of Ecology WFGA Washington Fish Growers Association WHO World Health Organization (United Nations) WMP (BC Canada) Waste Management Policy WRAC Western Regional Aquaculture Center WSGP Washington Sea Grant Program kv Abbreviations of Technical Terms and Symbols AFT Apparent effects threshold AVS Acid volatile sulfides BHA Butylated hydroxyanisol BHT Butylated hydroxytoluene BOD Biological oxygen demand DIN Dissolved inorganic nitrogen Eh Redox potential ER -L, ER -M Effects range low and medium FCR Feed conversion ratio IT Shannon - Wiener diversity index J' Pielou's evenness index MPN Most probable number NIS Non - indigenous species NIZ Neutral impact zone NOEC No observed effect concentration NOEL No observed effect level ORP Oxidation- reduction potential PCBs Polychlorinated biphenols PCA Principal components analysis PEC Predicted environmental concentration PEL Probable effects level PNEC Predicted no- effect concentration RPD Reduction- oxidation potential discontinuity S- Total sediment sulfides SAC Sediment assimilative capacity SIZ Sediment impact zone TEL Threshold effects level TOC Total organic carbon TVS Total volatile solids vii Abbreviations of Diseases and Pathogens BKD Bacterial kidney disease BSE Bovine spongiform encephalitis CS Ceratomyxa CWD Coldwater disease EIBS Erythrocytic inclusion body syndrome ERM Enteric redmouth disease FC Fecal coliform FC -MPN Fecal coliform most probable number FUR Furunculosis ICH Ichthyopthirius IHN Infectious hematopoietic necrosis IPN Infectious pancreatic necrosis MC Whirling disease PKD Proliferative kidney disease VHS Viral hemorrhagic septicemia Viii EXECUTIVE SUMMARY The US Government advocates a strong policy for national aquaculture development. The Department of Commerce (DOC) has set specific 25 -year goals to offset the annual $7 billion imbalance in seafood trade, and to double employment and the export value of goods and services. The policy is reflected in strategies proposed by the National Oceanic and Atmospheric Administration (NOAA) and its three line agencies responsible for certain aquaculture - related activities. With its broad mandate for stewardship of the nation's marine and coastal living resources, NOAA recommends that aquaculture development and environmental protection proceed hand in hand to meet public needs. Thus, in keeping with the Government's firm commitment to the United Nations Food and Agriculture Organization's (FAO) Code of Conduct for Responsible Fisheries, the line agencies of NOAA are encouraging the fisheries and aquaculture sectors to develop national Codes of Conduct, and their sub - sectors to develop and abide by Best Management Practices (BMPs). The National Aquaculture Act of 1980 recognized that the principal responsibility for national development lay with the private sector. Therefore, to increase overall effectiveness of federal research, transfer, and assistance programs for the private sector, the Act created the Joint Subcommittee for Aquaculture (JSA). JSA published a National Aquaculture Plan in 1983, which has been recently updated. A review of all the current government policy statements and the National Aquaculture Development Plan 2000 reveals considerable verbal (but not financial) encouragement for private initiatives. The Plan recognizes that aquaculture is not a unique industry with unique hazards. Its systems and practices, and its products, parallel those of many other industries and human activities. Apart from the single and pandemic caveat of protection for the environment there are no directives which promote one aquaculture system or practice over another, elevate one genera or species above another, or forward or forbid the use of any specific technology. in summary, there is no political attempt to rate or rank a sub - sector, or to advance or suppress any specific activity because of any known risk. The sub - sector of salmon farming in saltwater is a minor part of the national aquaculture industry, but it is a valuable economic asset contributing 11% to the total value of all aquaculture products. Only 45 commercial farms produce salmonids in marine net -pens directly for food, which is just 1% of all production facilities registered in the country, and <6% of all facilities in marine and coastal waters. Another 244 federal, state, or tribal facilities in the freshwater environment produce anadromous Pacific and Atlantic salmon for restoration of the commercial fisheries, recreational fisheries, or conservation, and another 362 freshwater facilities produce salmonids for both food fish and recreational fisheries. Because of its particular niche in marine and coastal waters, American net -pen technology has resulted in considerable growth of secondary producers in the aquaculture industry, and contributes a disproportionate share to the export of national goods and services. Despite the economic success of net -pen salmon farming in the USA, this review of scientific and other literature reveals that there are many perceived and real issues with this industry which concern the American public. These areas of risk and uncertainty occur in many facets of the industry - from the effects of salmon farming on the environment, to competition with ix other economies for the same resources, and the human health and safety of farming or consuming farm products. However, based on the evidence available in the existing literature and in ongoing research, it is apparent that the degrees of risk vary considerably from issue to issue. Risk and Uncertainty in the Pacific Northwest Industry A. Issues which carry the most risk After a review of the available scientific literature, the following three issues of net -pen salmon farming in the Pacific Northwest appear to carry the most risk. All potentially impact the environment. 1. The impact of bio- deposits (fish feces and uneaten feed) from farm operations on the environment beneath the net -pens. Bio- deposits from salmon farms settle onto sediments near the net -pens and can have definite effects on their chemistry together with their benthic and infaunal biota. Firstly, with regard to the chemistry, changes can be anticipated in total volatile solids and sulfur chemistry in the sediments in the immediate vicinity of operational net -pens, together with decreased redox potential. Sedimentation rates remain fairly constant irrespective of farm size, which currently is about 1,500 mt, and a typical total volatile solids (TVS)loading is 32.9 g /m2 -day for the perimeter of such a farm near peak production. This value is reasonably close to a theoretical average of 25.7 g TVS /mZ -day calculated for an entire 18 -month production cycle. Reduced accumulation of volatile organic material under farms can extend to distances of 145 to 205 in from the net -pen perimeter during peak production. The magnitude of the change in any of these parameters is correlated with the degree of flushing in and around each farm site. Secondly, with regard to the benthic biota, the accumulation of bio- deposits can enrich benthic communities but the actual affects depend on the hydrodynamics of each particular site. At poorly circulated sites these accumulations can exceed the aerobic assimilative capacity of sediments, leading to reduced oxygen tension and significant changes in the benthic community. Under extreme conditions sediments can become anoxic and depauperate. However, under any circumstances these effects are ephemeral and conditions have returned to normal within a period of weeks to years during fallow periods in all cases studied. Thirdly, with regard to the infaunal communities, the accumulation of organic wastes in the sediments can change their abundance and diversity. But prolonged case studies reveal significant differences between poorly- flushed and well- flushed sites. At poorly- flushed sites benthic effects are highly dependent on farm management practices. Very high salmon production levels and other activities, such as cleaning nets in -situ, result in significant changes in both abundance and diversity of infauna to distances as great as 30 in from the net- pen's perimeter. At reduced production levels, and in the absence of in -situ net cleaning, the impacts are restricted to as little 15 m, or less, downstream from the net -pens. At well- flushed sites the abundance and diversity of infaunal organisms is positively correlated with total X organic carbon, suggesting that the farm stimulates the infaunal community throughout the area. 2. The impact on benthic communities by the accumulation of heavy metals in the sediments below the net -pens. Both copper, from marine anti - fouling compounds used on net -pens, and zinc, from fish feeds, can be toxic in their ionic forms to marine organisms. Levels of copper are elevated around some net -pen farms which use government- approved anti - fouling paints on structures or, more likely, treat their nets with approved commercial compounds containing copper. The detected additions of copper in the water following the installation of newly - treated nets are biologically insignificant, except to organisms which settle on the nets. Zinc is an essential trace element for salmon nutrition, and it is added to feeds as part of the mineral supplement. Sediment concentrations of zinc are typically increased near salmon farms and the concentrations at a few farms in British Columbia have exceeded Washington State's sediment quality criteria (270 ig zinc /g dry sediment). The degree of risk is dependent on several factors. Firstly, the concentration of sulfide in the sediment is important, as typically elevated concentrations near salmon farms reduce the bio- availability of both copper and zinc thus making the observed concentrations non - toxic. Long -term studies have demonstrated that the metal concentrations return to background during the period of chemical remediation, and there is no evidence of a long -term buildup of these metals under salmon farms. Secondly, the formulation of the feed is relevant, as the majority of feed manufacturers now use reduced amounts of a more bio- available proteinated form of zinc, or a methionine analog. Monitoring of zinc continues to determine the efficacy of this change in reducing even the temporary accumulation of zinc in sediments under salmon farms. Finally, management practices play a role, as the potential rate of accumulation of copper in sediments can be significantly reduced by washing the nets at upland facilities and properly disposing of the waste in an approved landfill. 3. The impact on non- target organisms by the use of therapeutic compounds (both pharmaceuticals and pesticides) at net -pen farms. In European salmon farms therapeutic compounds are used for the control of sea lice, both for the health of the fish and to reduce their potential as vectors. The commonly used compounds are all non - specific within the Class Crustacea, and several are broad - spectrum biocides with potential to affect many phyla adversely. The degree of risk is greatly reduced by government regulation for the use of specific therapeutic compounds following extensive research in vitro and in situ on their effects on marine organisms. Case studies show that some of these compounds can be detected in sediments close to the perimeter of net -pen farms, but the levels resulting from their authorized use do not show significant widespread adverse affects on either pelagic or benthic resources. In the Pacific Northwest the use of pharmaceuticals to control sea lice has not been practiced in Washington State for over 15 years because they have not presented significant xi problems to growers, but some sea lice control agents have been used infrequently in British Columbia. Note: One more issue might be included in this first category, although the degree of risk is uncertain as there is little scientific information available. This is the impact on human health through consumption of feed -borne organic toxicants. Farmed fish are exposed to dioxins through feed ingredients, and dioxins are found in virtually all feedstuffs of animal origin, especially those containing fish meal and oils. Dioxins can be accumulated and transferred up the food chain. But the degree of risk is uncertain, as the impact of dioxin and dioxin -like compounds on human health is a recent discovery. Currently the Codex Alimentarius Commission is making efforts to reduce the risk by specifying stringent quality control of the ingredients for all animal feeds, and the potential for substituting plant proteins and oils for fish meal and fish oil in salmon diets. Although observation of the Codex by the 165 member countries is voluntary, the USA is an active signatory (see the section on Managing Risk and Uncertainty, which follows). B. Issues which carry a low risk Puget Sound is a stressed ecosystem and one continuously being degraded by further human intervention. For the last 25 years it has been an area of intense annual population growth (1.5 %) and is now home to 4 million people, with 1.4 million more projected by 2020. It is an area noted for recreational sailing and fishing, and there has been a corresponding growth in the number of support facilities for these water -borne activities. Salmon net -pen farming is another intervention competing for space and water -use, albeit minute by comparison. There are only 10 salmon net -pen farms active on sites in Puget Sound and unlike marinas, which deplete oxygen levels and elevate water temperatures, they are porous structures. Nonetheless, there are a number of facets of the net -pen salmon industry in Puget Sound which appear to carry a low risk. The majority of these eight issues concern the environment in the immediate vicinity of the farms themselves. 4. The physiological effect of low dissolved oxygen levels on other biota in the water column. Fish stocked intensively in contained areas are known to have a high oxygen demand. Decades of monitoring in Washington State have found a maximum oxygen reduction of 2 mg/L in water passing through salmon net -pens where large biomasses of fish were being fed. In most cases the reduction in dissolved oxygen has been < 0.5 mg/L. Salmon are more sensitive than most other species to depressed oxygen levels and 6.0 mg/L is considered a minimum concentration for optimum health. Therefore, if there was a localized effect associated with net -pen culture, the farmed salmon would be the first organisms affected. At coastal (oceanic) sites, farmed salmon are infrequently subjected to low dissolved oxygen concentrations when oxygen deficient up- welled water naturally intrudes into the growing area. However, these are oceanographic events which have nothing to do with the culture of fish or shellfish. In even the most poorly flushed farm in Puget Sound the culture facility does not consume quantities of oxygen sufficient to affect other organisms. xii 5. The toxic effect of hydrogen sulfide and ammonia from the bio- deposits below a net -pen farm on other biota in the water column. The accumulation of any highly- organic sediment produces ammonia and hydrogen sulfide once the oxygen is depleted. These gases most frequently cycle between oxidized and reduced states within superficial sediment layers where they modify the infaunal community. They are infrequently released into the water column. Although there is evidence from in situ studies that total sulfide concentrations in surface sediments in areas of high organic loading can exceed 20,000 iM, there is little soluble hydrogen sulfide in the water column even under poorly flushed sites. Less than 1.9% of the gases at the sediment -water interface are sulfide, and this can be reduced to 0.05% at a distance 3 m above the sediment. The majority of these gases are methane and carbon dioxide. In a well -sited farm concentrations of hydrogen sulfide gas rising through the water column are rapidly reduced by oxidation, diffusion, and mechanical mixing. For these reasons it is unlikely that toxic conditions caused by hydrogen sulfide will ever occur unless there were extremely large emissions at the sediment -water interface in shallow water. 6. The toxic effect of algal blooms enhanced by the dissolved inorganic wastes in the water column around net -pen farms. Enhancement of a harmful algal bloom by the inorganic nutrients discharged from salmon farms in Puget Sound is feasible but highly unlikely to occur in the Pacific Northwest. First, apart from the summer months, the natural atmospheric and geographical parameters of the region reduce light availability for photosynthesis, and the waters are vertically well mixed which reduces the time phytoplankton spend in the euphotic zone. Second, the physical characteristics of locations permitted for salmon farming are not conducive to the accumulation of nutrients, even when the water body is nutrient limited. Decades of monitoring have shown minimal increases in inorganic nutrient concentrations downstream from even the few sites having restricted water exchange. Small increases observed at 6 m downstream during slack tide have been statistically insignificant at a distance of 30 m downstream. Nutrient - limited embayments in Washington State have been identified and salmon aquaculture activities in these locations are discouraged and carefully managed when allowed. 7. Changes in the epifaunal community caused by the accumulation of organic wastes in sediments below net -pen farms. The effects on a wide variety of epifaunal communities have been studied in detail and the results are well- documented. One case study, with long -term (up to 10 years) monitoring, reveals significant numbers of fish, shrimp and other megafauna inhabiting the site, which appears to function as an artificial reef. Other salmon farms in close proximity all share the same characteristics, even attracting larger predators to the enhanced epifaunal communities. xiii 8. The proliferation of human pathogens in the aquatic environment Wild salmonids carry genera of marine bacteria, such as Vibrio, Acinetobacter, and Aeromonas, some species of which are pathogenic to humans. The concern is that fish feces and waste feed might enhance populations of these pathogens. There is no evidence in the literature, or in the epidemiological records of Washington State, of any documented case in which the handling or consumption of farmed salmon has led to infectious disease in consumers or farm workers. There are many differences in the physical and chemical composition of salmon farm waste compared with human sewage discharge, and the former does not disperse over large areas but remains localized where it is metabolized by naturally - occurring marine bacteria and invertebrates. There is no credible evidence supporting a hypothesis that salmon farming increases the risk of infectious disease in humans or wild populations of animals. 9. The proliferation of fish and shellfish pathogens in the aquatic environment. Public health concerns for the safety of fish and shellfish in the vicinity of discharges of industrial and residential waste are real, and vigilance is maintained by stringent regulations and monitoring programs. The accumulation of wastes from net -pen farms is perceived as another source of human and environmental pathogens. However, there is little evidence substantiating this hypothesis. Viruses pathogenic to fish have no documented effect on human beings because they are taxa - specific. Fecal coliform bacteria are unlikely to persist in net -pen sediments rich in total organic carbon as they are specific to warm - blooded animals. Sources of fecal coliform bacteria near salmon farms are more likely to be mammals (such as seals and sea - lions) or birds. In situ monitoring at some well- flushed net -pen farms revealed slightly more fecal coliform bacteria in water and shellfish tissues at stations closest to the farm perimeter. The sources of observed bacteria were not determined. However, all water and shellfish tissues examined were consistently of high quality and met all bacteriological requirements imposed by the National Shellfish Sanitation Program. 10. The increased incidences of disease among wild fish. Maintaining animal or plant populations in intensive concentrations can be conducive to an outbreak of disease. The specific diseases and their prevalence in Atlantic salmon stocks cultured in net -pens in Puget Sound are not shown to be any different than those of the more numerous cultured stocks of Pacific salmon in hatcheries, which in turn are not known to have a high risk for infecting wild salmonids. All Pacific and Atlantic salmon stocks currently cultured in Washington are inspected annually for bacterial and viral pathogens, and the movement of fish from place to place is regulated by permit. 11. The displacement of wild salmon in the marketplace by farmed salmonids. Salmon farmers and traditional Pacific salmon fishermen sell the same generic product, and therefore compete in the marketplace. Regulations specific to Washington State require farmed fish to be identified for the consumer. In terms of supply, salmon production by the net -pen salmon industry in the USA has been a counterbalance to the declining commercial xiv and tribal landings of Pacific salmon to meet increasing consumer demands for seafood. But in terms of demand there are distinct differences in the species produced by the two industries, and there are also differences in products available to consumers. Farmed fish are sold mostly as whole dressed fish and fresh fillets, while the typical disposition of the total annual wild catch (not by species) of the five Pacific species is whole fish, fresh and frozen, and canned products. In terms of price and availability, Atlantic salmon has an all -year round advantage and therefore a competitive edge over Pacific salmon harvested in the commercial fisheries. They are also relatively cheap to produce for the market. Per harvested fish, the cost to the private producer of farmed Atlantic salmon is currently about $1 per pound, head on, gutted weight. However, irrespective of its origin, production of salmon in Washington has little or no measurable effect on prices determined by global supply and demand, or reducing the large importation of farmed salmon from Norway and Chile. C. Issues which carry very little or no risk Despite the fact that two of the issues in this final category have many sub -sets, all three issues are deemed to carry very little or no risk. Two are specific to the environment of the Pacific Northwest, and the third concerns human health and safety in general. 12. The escape of Atlantic salmon - a non - native species. Since a reporting regulation was imposed in 1996, the records show that some 600,000 farmed salmon escaped between 1996 and 1999. These were mostly fish between 0.5 - 1.5 kg in weight. Only 2,500 of these particular escapees were subsequently accounted for. In addition, between 1951 and 1991 the State made 27 releases of 76,000 smolts of Atlantic salmon of various sizes into the Puget Sound Basin in attempts to establish this prized species on the west coast. Many escapees were taken immediately by recreational fishermen angling close to the net -pen farms, and a few others were taken at random by commercial fishermen in Puget Sound and beyond. A few fish (which may have originated in either Washington or British Columbia) have been recovered as far away as the Alaskan Peninsula. However, the numbers recovered have always been small and the rest remain unaccounted for, and it is assumed that the domesticated existence and docile behavior of farm fish makes them easy victims of predators, especially the large populations of marine mammals which now exist throughout the Pacific Northwest. The following list summarizes the sub - issues of concern regarding escaped Atlantic salmon in Puget Sound which appear to carry little or no risk. (i) Hybridization with other salmonids There is no evidence of adverse genetic impacts associated with escaped Atlantic salmon on the west coast of North America as they do not have congeneric wild individuals with which to interact. Hybrids between Atlantic salmon and the Pacific salmonid species can be produced in vitro, but with difficulty. Hybrids between Atlantic salmon and brown trout, another non - native species, are more easily produced in vitro, and occur readily in nature. xv Atlantic salmon x Pacific salmonid hybrids are not observed in nature, whether for introduced Atlantic salmon in North America, or for introduced North American salmonids to Europe and the other continents. By comparison, successful hybridization between some North American salmonids is regularly recorded. (ii) Colonization of salmonid habitat Atlantic salmon are unlikely to colonize salmon habitat in the Pacific Northwest. Accidents occur, and farm fish of various sizes occasionally escape in large numbers. About 1 million Atlantic salmon have escaped from net -pen farms in Puget Sound and British Columbia since 1990. Only a few were accounted for in recreational and commercial fisheries. In addition to escapes, deliberate releases of Atlantic salmon to establish local self- sustaining populations have been made in the Pacific Northwest since the beginning of the century, with the last release in 1991. Although routine monitoring programs occasionally find naturally - produced juveniles, naturally - produced adults have yet to be observed. (iii) Competition with native species for forage Like all salmonids Atlantic salmon are high on the food chain. But few prey items of any sort have been found in the stomach contents of escaped Atlantic salmon which have been recaptured. As survival in the wild is extremely low for escaped farm fish, it is assumed that their domestic upbringing makes them poor at foraging successfully for themselves. Therefore, the few natural prey items any escaped fish might consume is negligible, especially when compared with the competitive food requirements of the juvenile Pacific salmon deliberately released into Puget Sound and its tributaries from hatcheries. (iv) Predation on indigenous species All salmonids are predators. However, all analyses of the stomachs of recovered farm Atlantic salmon, and of the few naturally - produced juveniles caught in the wild, have failed to show evidence of preying on native salmonid species. This is not the case of other introduced non - native species which are known to be voracious predators of juvenile Pacific salmonids. Some of these non - native predators have been deliberately and /or accidentally introduced and are now managed for sustained natural reproduction to enhance recreational fisheries and for their contribution to sport fishing revenues. (v) Vectors for the introduction of exotic pathogens Provided no new stocks or eggs of Atlantic salmon are introduced into the region, farm Atlantic salmon cannot be a vector for the introduction of an exotic pathogen into Washington State. The extensive movement of aquatic animals and plants globally is known to carry the risk of introducing exotic diseases but movement of fish into and within Pacific Northwest states is now well - regulated with the requirement for disease -free certification. No Atlantic salmon stocks have been transferred into the State of Washington since 1991. 13. The impact of antibiotic - resistant bacteria on native salmonids. Drugs are used in all hatcheries and rearing facilities, and over -use of drugs is known to increase the resistance of many bacteria. Therefore there is the potential for development of antibiotic- resistant bacteria in net -pen salmon farms or Atlantic salmon smolt hatcheries xvi which could in time impact native salmonids. All drags used in fish culture in the USA are scientifically safe and efficacious, and approved by the FDA. Drug resistance has been commonly observed in public fish hatcheries in Washington State for over 40 years and no resulting adverse impacts on wild salmonids have been reported. 14. Impacts on human health and safety. The consumption of salmon farm products and /or working in and around the vicinity of net - pen salmon farms are perceived by some people to be concerns of human health and safety. The following list summarizes these sub - issues of concern regarding human health and safety which appear to carry little or no risk, either directly or indirectly. (i) Heavy metal contamination of farm products The three main sources of heavy -metal contamination found in coastal waters where fish and shellfish are farmed include industrial and municipal waste discharge, anti - fouling paints, and various organic pesticides, herbicides, and hydrocarbons. Problems with industrial and municipal waste discharges have long been recognized, and exposure to toxic chemicals from these sources are minimized by licensing farming areas away from sources of contamination. The hazards of heavy metal contamination, principally methyl mercury and tributyl -tin, are currently addressed by regulatory controls. As intensive farming relies on high quality formulated diets, the ingredients are regularly monitored to avoid possible contamination of feed with methyl mercury; and the use of tributyl -tin, once a common biocide used in anti- fouling bottom paints and for treating net -pens structures, is totally banned in North America. (ii) Rendered animal products in animal feeds The use of rendered animal proteins, once common in formulated feeds for many species of fish as well as other farm animals, has been curtailed by public concern over possible amplification of bovine spongiform encephalopathy (BSE), or'mad cow disease'. Although not specifically prohibited by regulation, rules designed to prevent cross - contamination of feeds and feed ingredients at time of manufacture have effectively eliminated the use of these ingredients from salmon feeds. There are no scientific studies on the potential for BSE transmission to humans through discharge of BSE prions into the aquatic environment, but based on studies of the discharges from rendering plants to aquifers used for drinking water, the possibility of infection by this route is remote. (iii) Genetically modified (GM) ingredients in fish feeds Although safety concerns regarding the use of GM ingredients in animal feeds have not been substantiated scientifically, most feed suppliers continue to offer only GM -free feeds. The use of GM oilseeds and grains in animal and human foods has gained considerable public attention in North America because of uncertainties regarding their effects on human health and the environment. (iv) Other ingredients and additives in animal feeds The use of pigments, hormones, antioxidants, and vitamin /mineral supplements in animal feeds is strictly controlled by FDA regulations. Although growth hormones are given commonly to other farm animals, such as poultry and cattle, their use in food fish is xvii prohibited. Additives such as pigments, antioxidants, and other nutritional supplements have been proven safe and their use in fish feeds is permitted by FDA regulation. (v) Residual medicines and drugs in farmed products Antibiotic residues in any farmed animals, including fish, is of concern to consumers because they might induce allergic reactions, have toxic effects, or simply increase antibiotic resistance in human pathogens. All drugs used in aquatic species farmed in the USA have been proven safe and efficacious, and are undetectable at the time of harvest when withdrawal times prescribed by the FDA are followed. At present only two antibiotics are registered and sold for use in the USA as feed additives for disease control in farmed fish. The use of parasiticides and vaccines is similarly restricted by FDA regulation. There could be a risk to consumers if these chemical compounds and vaccines were misused or administered by untrained workers. (vi) Biological hazards in farm products Potential biological hazards include parasites, bacterial and viral infections, or naturally produced toxins. To date there have been no reported cases of any fish parasites or pathogenic organism from farmed fish causing disease in humans. Most hazards have been eliminated by strict adherence to BMPs on the farm and at harvest, and /or by HACCP regulations during processing. (vii) Transgenic farm fish The perceived hazards of transgenic farms products, such as human allergies or unnatural competitors in the ecosystem, are hypothetical issues for net -pen salmon farming in Puget Sound. There is no evidence in the literature that transgenic fish have been raised or are being raised in the Pacific Northwest, and there are no plans to raise them, (viii) Workers' safety Compared with commercial fishing, which is identified as one of the most hazardous of occupations, net -pen salmon farms provide a safe working environment. Some fatalities and injuries in the national aquaculture industry from physical accidents have been reported but not specifically among net -pen salmon farmers. (ix) Public safety and navigational hazards There is no evidence that floating net -pen structures in Puget Sound are a hazard to the safe navigation of Washington's large and diverse boating communities. Firstly, permits from the US Coast Guard and Army Corps of Engineers are required for each farm to ensure that it complies with navigation and water safety regulations, Secondly, the complexes are small in total area. The ten active sites, which range in size from 2 - 24 acres, occupy only 131 acres of navigable surface waters from the State. The actual surface areas of the net -pen structures themselves occupy only 21.2 acres in total, with each complex ranging from 0.48 - 3.9 acres. By comparison the State has 77 aquatic land sites leased for commercial shellfish production, with a total area of 81,500 acres. xviii (x) The impact on nearby property values In the competition for coastal sites between the salmon farming industry (requiring access and good quality water conditions), and residential real estate (requiring access and industry-free views) there is no evidence that the sight and presence of net -pen operations has impacted the values of coastal properties in Puget Sound. Managing Risk and Uncertainty A. The environment There is considerable evidence available in the scientific literature to evaluate any potential risk of net -pen salmon farming on the environment of the Pacific Northwest. Most issues have been studied in great detail for some 20 years, and in many similar environments in different parts of the world. The results are well documented, and a common denominator is that the potential for environmental impact depends primarily on the site of each individual farm. The most important rule in the management of risk is therefore the careful selection of the site. Responsible permitting of each site is also playing an important management role. The National Pollution Discharge Elimination System (NPDES) permit has been effective in regulating the degree of allowable effect, but its impact must now be supplemented with the strict adherence by site operators to a well - defined set of industry BMPs which are based on good scientific information. These BMPs can be specific to a particular farm, or they can be overarching for the entire industry. Scientific evidence in the literature indicates that the potential changes in the sediments below operating net -pen farms bear the most risk for the environment. Continuous monitoring of the sediments under and around farm sites for many years has produced an extensive database of chemical and biological information, and specific parameters are now being used to predict the environmental effects. Key parameters include, inter alia, sediment grain size, total volatile solids or total organic carbon, redox potential, free sulfide concentrations and ultimately invertebrate community assessment. Modeling programs are also beginning to provide insight into the environmental response to farm waste, but these are not yet adequate to make reasonable quantitative predictions. Long -term monitoring of the sediments has also revealed that chemical and biological recovery of the substrate under and around farm sites occurs naturally without human intervention or mitigation. In situ data show that physicochemical recovery can occur within weeks or months at some sites, and within two or three years at others. Biological remediation of the sediments follows after a period of chemical remediation, and the speed of recovery depends on the seasonal recruitment of new infauna. B. Human health and safety Net -pen salmon farming is a relatively new global industry, but one which is very highly regulated in the USA. Atlantic salmon cannot be farmed in the Pacific Northwest or along the xix Northeastern Atlantic coast under any conditions which might pose a hazard to human health by exposure to environmental contaminants, pathogens, or infectious disease organisms. Farm salmon cannot be treated with any chemo- therapeutic compounds not approved by the US Food and Drug Administration (FDA). The health and safety of the farm workers are protected similarly by labor and industrial regulations. The United Nations Food and Agriculture Organization (FAO) in 1995 formally adopted a Code of Conduct for Responsible Aquaculture, which was followed in 1997 by a detailed document called Responsible Aquaculture at the Production Level. These documents detailed areas of concern regarding the responsible, safe, and effective use of feeds and feed additives, chemicals and chemotherapeutants, and other aquaculture practices which might reduce health and safety risks to humans. Food safety issues associated with farmed aquatic organisms have been subsequently evaluated by the World Health Organization in a working committee of the Codex Alimentarius Commission. The USA, which has agreed to abide by the intentions of all these international codes, has also developed national guidelines regulating the safety of all seafood, including farmed products. These are administered by the FDA. The literature reveals that the net -pen salmon farming industry in the Pacific Northwest is integrating all these safety assurance and quality control measures at all levels of the farm -to- table food - safety continuum. It has been applying Hazard Analysis and Critical Control Point (HACCP) methods wherever possible since their inception, and is in the final stages of publishing its own BMP. C. Farm escapes Accidents have occurred enabling farmed salmon to escape. Such incidents are likely to continue following some unique meteorological event or human error. The possible negative consequences of such events have been limited in part by implementation of pre - prepared recovery plans, some of which have included deregulating catch limits for public fishing on escaped farm fish, and by programs to monitor the background populations of fish in nearby watersheds. These responses will continue to be effective management practices to minimize impact, together with further advances in the technology. Improvements in the design and engineering of net -pens and their anchorages, and the use of new net materials, are continuing to reduce the incidents of loss following structural failure or damage from large predators. xx TABLE OF CONTENTS TABLE OF CONTENTS FOREWORD................................................................................... ............................... 3 1. GENERAL DEVELOPMENT OF AQUACULTURE IN THE USA .......................... 5 1.1 Federal Leadership for the National Aquaculture Industry ..... ............................... 5 1.2 The National Salmon Aquaculture Sector ............................... ..............................6 2. SALMON AQUACULTURE IN THE STATE OF WASHINGTON ......................... 9 2.1 Salmon Production for Restoration and Conservation ............. ..............................9 2.2 Salmon Production for Food ................................................ ............................... 11 2.3 Interactions of Farming with Commercial and Recreational Fishing ................... 12 2.4 Interactions of Farming with Recreational Activities in Puget Sound .................. 16 2.5 Economic Benefits of Salmon Farming to the State ............. ............................... 17 2.5.1 The contribution of salmon farming to seafood production ............................ 17 2.5.2 The impact on employment and wages ........................... ............................... 18 2.5.3 The impact on coastal property values ............................ ............................... 19 2.6 The Regulatory Structure for Commercial Enterprises ........... .............................20 2.7 The Regulatory Structure for Public and Tribal Hatcheries .... .............................23 3. POTENTIAL ISSUES FOR HUMAN HEALTH AND SAFETY .............................25 3.1 General Food Safety .............................................................. .............................25 3.2 Chemicals and Chemical Contamination ................................ .............................26 3.2.1 Heavy metals ................................................................... .............................26 3.2.2 Manufactured feeds .......................................................... .............................27 3.2.3 Chemotherapeutants ......................................................... .............................31 3.3 Biological Safety ................................................................... .............................33 3.4 Quality and Safety of the Products ........................................ ............................... 34 3.5 Worker Safety ..................................................................... ............................... 35 4. SALMON FARMING AND THE ENVIRONMENT ................ ............................... 36 4.1 The Effects of Organic Wastes from Net -pen Salmon Farms .............................. 36 4.1.1 Waste feed ....................................................................... .............................36 4.1.2 Fish feces ......................................................................... .............................37 4.1.3 Fish carcasses as wastes ................................................... .............................38 4.1.4 Bio- fouling organisms as wastes .................................... ............................... 38 4.1.5 Measurement of organic wastes ..................................... ............................... 39 4.2 Dissolved Inorganic Wastes ................................................... .............................41 4.2.1 Dissolved nitrogen and phosphorus .................................. .............................41 4.2.2 Heavy metal accumulation in sediments ........................... .............................42 4.3 Pathogenic Organisms in the Vicinity of Net -pen Salmon Farms ......................... 45 4.3.1 Fecal coliform bacteria ..................................................... .............................45 4.3.2 Farm wastes ..................................................................... .............................46 4.4 The Effects of Therapeutic Compounds ............................... ............................... 47 4.5 Farm Sediments ................................................................... ............................... 51 4.5.1 Monitoring environmental effects on sediments ............. ............................... 51 4.5.2 Biological changes in the water column and sediments .. ............................... 53 4.5.3 Hydrogen sulfide gas production in sediments ............... ............................... 55 4.5.4 Dissolved oxygen ........................................................... ............................... 56 4.5.5 Changes in the local fish community .............................. ............................... 56 4.5.6 Physicochemical changes in the sediment near salmon farms ........................ 57 4.5.7 Biological effects ........................................................... ............................... 57 4.5.8 Case histories describing benthic responses to salmon farming ....................... 59 4.6. Recovery and Remediation of Sediments ............................ ............................... 60 4.6.1 Chemical remediation ...................................................... .............................60 4.6.2 Biological remediation ..................................................... .............................61 4.6.3 The assimilative capacity of the local environment ........ ............................... 65 4.7 Managing the Environmental Effects Associated with Salmon Farms ................. 65 4.7.1 Monitoring experiences .................................................. ............................... 65 4.7.2 Management by modeling salmon farm wastes .............. ............................... 68 4.7.3 Risk management through NPDES permit standards ...... ............................... 69 4.7.4 Risk management practices in British Columbia ............ ............................... 72 5. ATLANTIC SALMON and the LOCAL ECOSYSTEMS ......... ............................... 74 5.1 General Issues of Artificial Propagation of Salmonids .......... ............................... 74 5.2 Genetic Interactions of Artificially- Propagated Pacific and Atlantic Salmon........ 75 5.2.1 Hybridization ................................................................... .............................75 5.2.2 Genetic dilution and alteration of the wild salmonid gene pool ......................77 5.2.3 Colonization by Atlantic salmon ...................................... .............................78 5.2.4 Interactions of wild salmon and transgenic fish ................ .............................79 5.3 Epidemics and the Transmission of Waterborne Disease ........ .............................80 5.3.1 The origin and disease status of Atlantic salmon stocks in Puget Sound........ 80 5.3.2 Disease of salmonids ...................................................... ............................... 80 5.3.3 Infectious disease therapy .............................................. ............................... 83 5.3.4 Disease interactions between wild and propagated salmonids ........................ 84 5.3.5 The scale of artificial propagation .................................... .............................85 5.3.6 Disease control policies in Washington and the USA ..... ............................... 86 5.4 Potential Ecological Impacts of Atlantic Salmon in the Pacific Northwest........... 87 5.4.1 Social interactions between Pacific and Atlantic salmon ............................... 87 5.4.2 Predation by Atlantic salmon ......................................... ............................... 88 5.5 Potential Impacts of Propagated Pacific Salmon ................... ............................... 88 5.6 Adverse Impacts of Non- indigenous Fish Introductions ....... ............................... 91 5.7 A Perspective of Salmon Culture in Northwest Waters ........ ............................... 94 5.8 NMFS Biological Status Reviews of West Coast Pacific Salmon Stocks .............96 6. POST SCRIPT ............................................................................ .............................97 7. REFERENCES ......................................................................... ............................... 98 FOREWORD Many government regulators are now encouraging all intensive food production industries, including capture fisheries, to adopt and observe protocols and methodologies to make their activities more compatible with the environment. The majority of these industries are responsive to this challenge and are beginning to comply through self - developed codes of practice and best management practices. A code of practice (COP) describes a set of general practices and standards to guide human conduct in a specific endeavor in order to maintain conformity and consistency. COPs are voluntary in principle but invariably the overarching organization, such as the Federation of European Aquaculture Producers (FEAP), makes them obligatory in universal interest (FEAP 2000). Best management practices (BMP), on the other hand, describe a specific (and often detailed) set of protocols, practices, or procedures to manage and carry out specific operations in a responsible manner, with respect to the social and ecological environment, based on the best available scientific information and an assessment of risk. BMPs are voluntary in principle but invariably the overarching organization makes them mandatory in the interest of the specific industry. Each element in any code of practice is based on the best scientific information available or the most practical experiences. Consequently a code of practice is not a finite entity in itself but a never - ending dynamic process ready to incorporate each relevant scientific discovery and each new technical experience. In 1997 the Environmental Assessment Office of British Columbia (EAO) published the British Columbia Salmon Aquaculture Review ( BCSAR). A section of this comprehensive document (EAO 1997) discussed key environmental issues based on reviews of over 750 scientific and technical papers, and many pertinent government documents. This background information greatly assisted the British Columbia Salmon Farmers Association (BCSFA) to develop its individual code of practice in 1999 (BCSFA 1999), and the New Brunswick Salmon Growers Association will complete its code in 2001 (N. Halse, NBSGA, personal communication). The same efforts have been made in other countries, and in 2000 the Shetland Salmon Farmers Association of Scotland produced its code of best practices (SSFA 2000). Government and salmon farmers in the US on both the west and east coasts have not moved as quickly as those in Canada, or indeed as those in Norway, Scotland, and Ireland. This is because most of the sub - sectors of American aquaculture are very small, unlike those of US agriculture, and individual farmer's associations do not have the capacity or scientific information on which to develop appropriate codes. Consequently, research staff of the Northwest Fisheries Science Center ( NWFSC) has prepared this scientific review to help salmon farmers in the Pacific Northwest codify their industry. Research by scientists of the NWFSC first instigated the industry of net -pen salmon farming in saltwater in North America at the Manchester Research Station in the early 1970s. Subsequently salmon have been farmed extensively in the Pacific Northwest in the protected waters of the Georgia Straits and Puget Sound. Therefore it is fitting that the NWFSC is guiding the local industry to be compatible with its ecological surroundings. This document is the result of the efforts of the Resource Enhancement and Utilization Technologies Division (REUT) of the NWFSC. It is not a comprehensive review of the literature on net -pen salmon farming from its historical beginning, like the BCSAR, and it is not trying to update the BCSAR with citations to information after 1996. The document is intended to stand in its own right and fulfil a set of three objectives: • First, from the perspective of the US and local stakeholders it annotates the best scientific information regarding local issues arising from or affecting development of net -pen salmon farming in the Pacific Northwest. • Second, together with other literature reviews, it completes an information base for all stakeholders to make a qualified and quantified analysis and assessment of any risks associated with salmon farming in the area. • Third, together with these risk assessment studies, it will assist salmon farmers to develop an appropriate COP for their industries, and in particular the salmon farm and hatchery managers in the Pacific Northwest, to develop a set of BMPs for their specific activity. 4 1. GENERAL DEVELOPMENT OF AQUACULTURE IN THE USA The first chapter initially summarizes the national leadership for development and growth of the aquaculture sector by a range of government policies and legislation spread over half a century. It explains government direction was first to mitigate for displaced wildlife resources but now its objectives are to reduce imbalances in seafood trade, enhance commercial fisheries, and assist conservation of endangered species. It notes that national development has been guided for twenty years by the National Aquaculture Act of 1980, and a National Aquaculture Development Plan which has been continually under review and updated. The second part of the chapter summarizes the national salmon aquaculture sector. It provides current data for the two key pillars of the sector, specifically production for enhancement of commercial and recreational salmon fisheries, and production of food -fish for domestic and export markets. It explains briefly the different commercial end - products of salmon aquaculture, and the contribution to the national economy made by the industry's producers of good and services. 1.1 Federal Leadership for the National Aquaculture Industry Modern aquaculture is not new technology to the USA. Early attempts to culture fish and shellfish in North America date back to the 1850s and 1860s, and it was the intensity of the early pioneers to raise fish to enhance the indigenous fisheries which persuaded the US Government to create the US Fish Commission in 1871. The Commission, in time, became the Bureau of Commercial Fisheries and subsequently the National Marine Fisheries Service (NMFS). Early development of aquaculture in the US was continuously expanded by legislation. Predominantly it was federal legislation to compensate for salmon fisheries affected by federal water projects in the Columbia River Basin. The Federal Power Act of 1920 and the Fish and Wildlife Coordination Act of 1934 were responsible for over $400 million spent on salmon hatcheries and fish passages constructed at that time, and in 1938 the Mitchell Act authorized appropriation of federal tax revenues annually to restore and enhance the salmon resources of the Columbia Basin as a whole. As a result, a substantial technical and scientific research and information base was established in the country on almost every aspect of the biology and culture of Pacific salmon. This knowledge and experience was a significant factor in the farming of both North American and European salmonids some 30 years later. Encouraging development of aquaculture in the US was again the government's policy behind the National Aquaculture Act of 1980. Recognizing the growing diversity of modern aquaculture, and multi- agency responsibilities, the 1980 Act established a coordinating group, the Joint Subcommittee on Aquaculture (JSA) which continues in existence today. The JSA has been responsible for developing and updating the National Aquaculture Development Plan (NADP 2000), which identifies the relative roles of the Department of Agriculture (USDA), the Department of Commerce (DOC), and the Department of the Interior (DOI). Within DOC, the National Oceanic and Atmospheric Administration (NOAA) has a strong statutory base for the promotion and regulation of marine - related aquaculture. Historically this has been achieved through NMFS programs and the National Sea Grant College Program (NSGCP) in the Office of Oceanic and Atmospheric Research (OAR). In 1999 the Secretary of Commerce signed an Aquaculture Policy for DOC identifying seven specific objectives. Among quantified targets for the aquaculture sector to achieve by the year 2025, the policy strongly emphasized technological development and growth in harmony with the environment. The same message is evident in the NOAA policy on aquaculture, signed in 1998. The underlying goal is for development through environmentally sound production practices. Particularly noted is the use of aquaculture technologies for the enhancement of threatened populations but also avoiding negative impacts on any wild stocks. The policies of both DOC and NOAA are very evident in the draft National Marine Aquaculture Act of 1999 for further development of aquaculture into the exclusive economic zone (EEZ). In conclusion, the federal government continues to encourage sector development through applicable legislation, funding programs, and agency policies. It has set 25 -year targets for increased domestic production to help offset the large annual trade deficit in seafood, and to double employment and exports of goods and services. In addition, it wants new technologies for increased diversification of the industry, and for enhancement of wild stocks. Finally, it demands economic development with the necessary safeguards for the environment to be enforced through total compliance with industrial codes for responsible aquaculture. NADP 2000 is not detailed regarding different aquaculture products or production technologies. Irrespective of any sub - sector, the Plan repeats the challenge for better knowledge about possible interactions between aquaculture and the natural environment to minimize, (i) the potential for habitat degradation, (ii) transmission of diseases, (iii) potential genetic dilution of wild stocks through interbreeding with cultivated strains, (iv) introduction of non - indigenous species into natural waters, and (v) discharges of wastes, toxins, and excess nutrients (JSA 1999). 1.2 The National Salmon Aquaculture Sector The Census of Aquaculture recently published by USDA (USDA 1999) reports the value of salmon produced and sold for food or food/sport in 1998 was $104 million, or about 11% of the total value of national aquaculture products. The Census notes that 244 farms produced salmon for restoration or conservation purposes. It defines these farms as mostly non - commercial operations, such as federal, state, or tribal facilities (which were mostly hatcheries), academic, and private research facilities with products valued above $1,000 in the year of the Census. Within this total, the Census records that 238 farms produced 2.4 billion fish (288 million lb or some 130,000 mt), and 47 farms produced 71 million salmon eggs or seed for distribution. Another 362 farms produced trout for restoration or conservation, of which 360 farms produced 177 million fish (32 million lb or 1,450 mt), and 72 farms produced 163 million eggs or seed for distribution. In addition the Census notes that 47 farms in the country produced salmon commercially, of which 45 raised food -size fish. This number is about 1% of all the aquaculture farms recorded in the country. It is assumed that almost all these salmon farms are saltwater farms. The Census records that there are only 815 of the 4,028 recorded aquaculture facilities and/or farms in the country which operate with or within saltwater, and the majority raise mollusks or tropical fish. The word 'farm' in the literature can be confusing, as the definition adopted by the Census is specific to its own use. Typically, farm' applies to a physical complex for production but this, in turn, can refer to a complex on a single registered site, or a number of complexes operated by a single business which owns or leases a number of registered sites close together. Using its definition of a commercial or non - commercial place from which $1,000 of products were sold, the Census shows that the majority of salmon farms operate in the States of Alaska (19), Maine (12), and Washington (9). But Alaska prohibits private farming of all fish species, and therefore the number refers to salmon hatcheries operated by private non - profit corporations (PNPs) which rear to release and subsequently harvest — an aquaculture practice known as 'ocean ranching.' The word 'farm' can in fact be applied to any location where primary production of aquatic animals and plants takes place. There are five primary producers in the salmon aquaculture sub - sector in the USA, and their end products are: (i) certified disease -free eggs from a freshwater hatchery, (ii) pre - smolted juveniles from a freshwater nursery farm, (iii) smolted juveniles from a saltwater nursery farm, (iv) marketable fish from the saltwater grow -out farm, and (v) marketable products after processing. Active in these areas are both non - commercial and commercial enterprises. The non- commercial enterprises are all the federal, state, and tribal organizations that own and operate only hatcheries and other licensed rearing facilities to produce pre - smolts and smolts for release to enhance commercial and recreational fisheries. Commercial enterprises are private companies which invariably own or have controlling interests in at least four end - products, and possibly all five. The Western Regional Aquaculture Center (WRAC) noted that the State of Washington Department of Fisheries and Wildlife (WDFW) had close to 1,000 aquaculture licenses on file in 1995, of which 74 were for salmon and 187 for trout production (WRAC 1999). These numbers included both active and non - active licenses, as licenses are not required to be updated annually. There are many secondary producers in the industry throughout the country. Their manufactured end products include, for example, (i) hardware, such as craned vehicles, service boats, floating cages, net -pens, feed silos, egg incubators, hatchery tanks, raceway tanks, pumps, pipes, etc., (ii) formulated feeds, (iii) technical apparatus and laboratory equipment, (iv) veterinary medicines and drugs, and (v) a variety of expert services. Again, many commercial enterprises active in primary production are active in secondary production, particularly with ownership or controlling interest of subsidiaries in fish nutrition and health. Within the last 2 years several large companies in Europe and North America have spread their business risk throughout the global salmon industry by consolidating their hold on substantial lengths of the value chain. Secondary producers are very important to the national economy. In a recent aquaculture policy statement, DOC recognized that the annual value of US exports of goods and services was $500 million, and set a goal of $2.5 billion by the year 2025 (DOC 1999). 2. SALMON AQUACULTURE IN THE STATE OF WASHINGTON The second chapter is predominantly regional in scope and deals mostly with the pros and cons of salmon aquaculture in the State of Washington. The first section provides quantified data regarding aquaculture for restoration and conservation of salmon fisheries, and some economic costs and benefits. The second section provides data regarding the physical extent of the commercial salmon farming industry for food production, making comparisons with other parts of the US and overseas. The third section describes some of the interactions of the salmon farming industry in Puget Sound with commercial and recreational fishing activities, in particular with other fish populations and in the marketplace. The fourth section deals with economic benefits to the State, particularly at the regional and local levels. These include the contribution to seafood production, the impact on employment and wages, and the impact on coastal property values. The two final sections concern the current regulatory structure for commercial enterprises raising food fish in the State of Washington, and the regulatory structure for public and tribal hatcheries raising juvenile salmon for commercial and recreational fisheries. 2.1 Salmon Production for Restoration and Conservation The State of Washington has one of the largest artificial production systems for salmonids in the world. Its hatcheries program operates 24 complexes (groups of hatcheries) with more than 90 rearing facilities (WDFW 2000). These include production hatcheries, net -pens, acclimation sites, and rearing ponds, as well as several remote egg - incubator locations and small -scale cooperative rearing programs with community and educational groups. Washington hatcheries produce approximately 75% of all coho and chinook salmon, and 88% of all steelhead trout harvested statewide. Trout hatcheries produce over 90% of the statewide harvest. Approximately 700,000 adult salmonids of several species return to hatcheries each year, and more than 300 million eggs are collected from them for future generations. All fish raised in State hatcheries are released into the open waters of Washington. In 1995 some 201 million salmon, 8.5 million steelhead, and 22.6 million trout and warm -water fish were released. In addition, there are 12 federal and 17 tribal rearing facilities which produce another 50 million salmonids for release (WDNR 2000a). Between 1951 and 1991 WDFW also made 27 releases of Atlantic salmon in attempts to establish the species in State waters. A total of 76,031 parr and smolts were released varying in size between 0.25g and 450g (Amos and Appleby 1999). Until 1979 the origin of the stocks was Gaspd River in Canada, most of which came through broodstocks held in Oregon. From 1980 the stocks were a mix of origins, including Gaspd River, the Penobscot and St. John's Rivers (Maine), together with some landlocked stocks from Grand Lakes (Maine). The State of Oregon, which shares the Columbia Basin with the States of Washington and Idaho, currently operates 34 hatcheries and 15 other rearing facilities. Annually these facilities release about 43 million Pacific salmon, 5.7 million steelhead, and 8.3 million trout. In the last decade about 80% of all trout, and 70% of all steelhead and coho harvested in Oregon were propagated artificially (ODFW 2000). More recently, net -pen complexes have been used for conditioning and releasing salmon in areas around the mouth of the Columbia River to create local commercial and recreational fisheries. The Clatsop County Economic Development project near Astoria released about 3.5 million coho, and 1.1 million chinook in 2000 (OSU 2000), and expected a return of 5,000 spring chinook from its previous releases. Using 1990s data for the production, release, and survival of Pacific salmon from Columbia Basin hatcheries, where the juveniles may be retained for up to 18 months, Radtke (2000) calculated that the hatchery cost per harvested coho salmon was $58.89, with an economic value per harvested fish (7 lb. at $1.00 /lb.) of $76.07. For spring/summer chinook (12 lb. at $1.50 /lb.) the costs per harvested fish were $404.55 and $109.36, respectively, and for fall chinook (15 lb. at $1.25 /lb.) they were $35.00 and $114.5, respectively. For steelhead (9 lb. at $0.60 /lb.) the costs were $292.86 and $74.8, respectively. He also estimated the (fixed plus variable) cost per smolt from hatcheries in Oregon into the Columbia Basin for salmon (all species) to be between $7.20 -7.42 per lb of smolt. Current estimates by WDFW (K. Amos, WDFW, personal communication) put the cost at between $3-4 per lb, of smolt. This is because outside the Basin hatcheries generally retain many stocks for a month or less, primarily chum salmon, which results in a lower cost per smolt. Puget Sound has a large number of artificial propagation facilities releasing juvenile salmonids into its freshwater basin every year. Based on historical data over 30-40 years, a total of 30 facilities together released about 29 million coho every year (NMFS 1995). Some 43 facilities released 65 million chum (NMFS 1997a), and 69 rearing facilities released about 44 million chinook (NMFS 1998). There are also 10 facilities which release some 1.5 million- winter steelhead and 400,000 summer steelhead, mostly smolts, (NMFS 1996). Collectively, these facilities now release about 50 million juvenile salmon (equivalent to some 300 mt of fish) into the Puget Sound Basin on an annual basis. The reductions in number of fish released are due in part to changes in hatchery strategies to lessen the potential adverse impacts on wild salmonids. Forster (1995), in his evaluation of cost trends in farmed salmon, reported the current (1994/95) production cost of an Atlantic salmon smolt (100 g in weight, or 3.5 oz) in Chile, Norway, and Canada was between $0.75 -1.25 each, which included $0.5 -0.15 for the eyed egg, and $0.12 -0.20 for the feed. Prices asked by smolt producers, however, might be $1.50 -4.00, depending on the size at sale, with $2.00 being the average for a 1008 fish. Grez (Salmones Camanchaca S.A. Chile, personal communication) reported that fixed and variable production costs for rainbow trout and coho salmon smolts in Chile in 1996 were $0.21 -0.26, and a little more for Atlantic salmon depending on the source and cost of eggs. Rainbow trout and coho salmon smolts were sold for $0.55 -0.65 each, and Atlantic salmon smolts for about $1.00. 10 In his report to the State of Alaska Department of Commerce and Economic Development, Forster (1995) estimated that the cost to the private producer of farmed Atlantic salmon was $1.14 -2.03 per pound, head on, gutted weight. Based on advances in technology and increased farm efficiencies, he projected that production costs for the year 2000 would be between $0.73 -1.19 per pound, head -on, gutted weight. His current estimate is that it is about $1.00 (J. Forster, Forster Consulting, personal communication). 2.2 Salmon Production for Food A production site for salmon farming invariably consists of a complex of on -shore buildings and tanks, and offshore floating cages or net -pens. Floating cages are usually associated with the freshwater nurseries for smolt production, and net -pens are associated with grow -out and production of marketable fish in marine waters. The 1998 Census of Aquaculture (USDA 1999) defines cages as structures 'normally used in larger, open bodies of water such as lakes or rivers,' while net -pens are 'enclosures usually placed in protected bays or inlets used to produce fish.' Weston (1986), in his study of the environmental effects of floating mariculture in Puget Sound, recorded nine sites where Pacific coho and /or Atlantic salmon were raised commercially in net -pen facilities. Another permit had been granted, and others were pending. There were also three more sites for non - commercial culture, which is for research or to enhance fisheries. In addition there were five major and eight minor net - pen facilities used by tribes or sportsmen's clubs for delayed release of coho and chinook salmon. By 1990 there were 13 commercial sites, each limited to a total surface area of less than 2 acres, or 8,100 mZ (WDF 1990). In response to the listing of Puget Sound chinook salmon as threatened under ESA, chinook salmon releases from minor - net -pen sites have been reduced or terminated (NWIFC 2000). In its summary of the status of aquaculture for 1997, WRAC (1999) reported that net -pen salmon farthing in the Pacific Northwest only occurred in Washington. Earlier in the 1990s net -pen rearing of salmon had been practiced in Oregon, California, and Idaho but had since ceased. Atlantic salmon dominated production (99 %) in Washington, with the remainder being coho, chinook, and steelhead trout. All salmon production sites in Washington, whether on or off land, are licensed appropriately. Sites are owned outright or leased (tenured). Companies may own and /or lease several sites, and consequently some sites are continuously active; others are developed but not always in use, and a few may be inactive and undeveloped. WRAC (1999) reported six companies with leases to sites in Washington in 1997. These included Domsea Farms Inc. (5 sites), Global Aqua US Inc. (3 sites), Moore -Clark Co. (USA) Inc. (3 sites and a hatchery), Scan Am (3 sites), Sea Farm Washington (3 sites), and British Petroleum (1 site). In the last five years there has been considerable restructuring in the salmon aquaculture industry worldwide with some companies consolidating their position through merger and/or purchase of smaller companies. Consequently, the global industry is now dominated by a few international companies, although individual farms may still operate under the name of the registered leaseholder. In Washington four different companies now hold the leases to 12 licensed net -pen production sites. These are: • Cypress Island Inc., which has three leases by Cypress Island outside Anacortes and one lease in Skagit Bay; and (once under Northwest Farms) three leases in Rich Passage, one in Port Angeles harbor (formed by combining two previous leases), and one by Hartstene Island currently not in use. • Sunpoint Systems, which has one lease in Rich Passage. • Jamestown S'Klallum Tribe, which has one lease in Discovery Bay but not in use. • Ocean Spar Technologies, a sea -cage manufacturing company which has one lease by Whiskey Creek near Port Angeles for research and development trials, but not in use. In the State of Washington, statistics provided by WDNR (2001) indicate there are 166.67 acres currently leased by companies for commercial salmon net -pens, and a further 38.67 acres currently leased by the State, tribes, and private enterprises for net - pens used for the delayed release of Pacific salmon, and 0.39 acres for herring net -pens. All these sites have adifferent limit for the water surface area leased (for anchorages and navigational protection) and the internal surface area for the net -pens in production. The 10 commercial sites currently operational in Puget Sound have a total of 131 acres under lease from the State (ranging from 2 -24 acres in size), with 21.5 acres permitted for the internal pen structures (range 21,000- 170,000 sq. ft) (K. Bright, WFGA, personal communication). This area is little more than the larger marinas located on State -owned aquatic lands, any of which can be 15 -20 acres in size. The number of commercial net -pen farms in Washington is small by comparison with that on the east coast (Maine) and other countries. Maine has 42 permitted sites for salmon, and two for steelhead, of which six are currently idle (J. McGonagle, Maine Aquaculture Association, personal communication). Producers in Maine, of which there are 14 companies, are in the process of moving to single - year -class cultivation over the next two years. This should result in about one -third of the sites lying fallow each year. In eastern Canada the industry is largely confined to New Brunswick. In New Brunswick there are about 60 farming companies, each with one or more permitted sites. There are also a few sites in Nova Scotia and Newfoundland. In western Canada there are 122 registered net -pen sites in British Columbia (BC), of which 104 are active (BCSFA 1999). The Highlands and Islands Enterprise (HIE) of Scotland recorded 440 growing sites registered in 1997 with the Agriculture, Environment and Fisheries Department of the Scottish Office (SOAEFD). Of these, 128 were fully stocked all year round, 202 were in rotation, and 100 were classified as inactive (HIE 1999). 2.3 Interactions of Farming with Commercial and Recreational Fishing In a commentary on regional fisheries, the Marine Advisory Services of the Washington Sea Grant Program (WSGP 2001) stated that commercial fishing was a significant industry in Washington State, with nearly 3 billion lb. of fish and shellfish harvested annually, with a wholesale value over $1.6 billion. However, the report also added that commercial fisheries around the world were collapsing and efforts in fisheries science 12 were turning more to conservation of resources and finding ways to harvest fish stocks in a sustainable manner. The commercial fisheries of Puget Sound reflect these global trends. WDFW (1994) reported that commercial salmon harvest levels in the State of Washington had declined from a peak of over 10 million fish in 1985 to about 7 million fish in 1993, with most of these fish produced in hatcheries. Similarly recreational salmon fishing levels had declined from a peak of 1,100,000 fish in 1979 to just over 600,000 fish in 1993. More recent data by Didier (1998) put preliminary estimates of commercial salmon catch in the State in 1998 as only 1,618,300 fish, together with141,604 fish in the subsistence catch by the tribes; and the sport salmon (recreational) harvest in 1997 was down to 451,425 fish. Data for the 2000 landings and prices of salmon in Washington provided by Pacific Fishing (2001) gave figures of 1,475,315 fish (5,342 mt) that landed in the State, with a value of $8.5 million. Both landings and prices were considerably above those for 1999. Much of the decline in the commercial harvest can be attributed to the shift from a terminal harvest to a high catch - per -unit effort in the offshore fishery. Eriksson and Eriksson (1993) described the parallel of the Swedish salmon fisheries in the Baltic Sea in their study of wild and hatchery propagated stocks over the 40 -year post -war period. They concluded that wild fish were unable to cope with the present exploitation rates, and without the effective compensatory program, a reduction in stock -size of the magnitude shown by wild salmon in the Baltic would decrease the catch - per -unit effort to such a degree that there would be no economic incentive for a commercial salmon fishery. In addition to fluctuating changes in ocean conditions, declines in the commercial harvest can also be attributed to the increased interest in recreational fishing in Puget Sound, and competitive pressure on the habitat. Drinkwin and Ransom (1999) projected another 1.4 million people would settle in the Puget Sound Basin by 2020, which would further degrade the already- stressed ecosystem. Their indicators included continued declines in bottom -fish populations, restrictions on shellfish harvesting, and rapid loss of freshwater, estuarine, and near -shore habitats. All these indicators are impacted by the increase in aquatic recreational activities, particularly recreational boating (see Section 2.4). The decline in some fisheries populations in Puget Sound has reached significantly low levels. For example, in 1999 chinook salmon in Puget Sound and summer chum salmon in Hood Canal were listed as threatened by NMFS under the federal Endangered Species Act of 1973 (ESA). However, not all aquatic species are in decline. In its current report on the health of Puget Sound, PS WQAT (2000) noted that the waters of the Sound were still home to over 220 species of fish, 26 different kinds of marine mammals, 100 species of sea birds, and thousands of species of marine invertebrates. Some species were migratory, while others remained in the Sound all year round. Some populations, such as harbor seals and California sea lions, were increasing rapidly. The trends in the counts of harbor seals indicated some 12,000 now living in the Puget Sound region, or double the number recorded in 1985. They attribute these increasing numbers to protection under the Marine Mammal Act of 1972, variable abundance of food resources, such as Pacific herring and Pacific hake, decreasing levels of contamination in the water, and tolerant 13 interaction with human interventions. As major fish predators in Puget Sound they must be contributing to the decline of some fisheries. In a study on the impacts of California sea lions and Pacific harbor seals on salmonids in the west coast States, NMFS (1997b) estimated that the total bio -mass consumption by these pinnipeds along the coasts (a minimum of about 217,400 mt) amounted to almost half of the commercial harvest of the three States. There is no evidence in the literature that the presence of 10 operational net -pen salmon farms in Puget Sound has contributed to the decline of the fisheries populations. In fact Henriksson (1991), in his study on the effects of fish farming on natural fish communities in the Baltic Sea, described an overall recruitment by small fish around farms compared with reference areas, followed by the increased abundance of certain fish species such as, inter alia, perch, roach, white bream, and bleak. However, Crutchfield (1989) noted that fishermen opposed the growing salmon net -pen industry for encroachment on fishing grounds or transfer /over - wintering lay -up areas. He believed this was a legitimate complaint at the time but suggested it could be rectified easily by restricting net -pen farms in such sites, although this would add another site burden to farmers. There is little evidence in the literature that deliberate releases or escapes of farmed fish from operational net -pen sites have resulted in the sustained natural production of a population providing a new commercial resource in Puget Sound. Rensel et al. (1988), in a 5 -year tagging study with farmed coho salmon, showed that the annual estimated recovery (estimated catch plus escapement) averaged 17.1 %, which was similar to recovery rates of coho salmon released from other facilities at about the same time. They estimated approximately only 0.2% of the released coho salmon survived to enter streams in the general vicinity of the net -pens. They concluded that the Puget Sound commercial net fishery benefited most from the program. In Washington, in addition to the 27 releases of Atlantic salmon made by WDFW between 1951 and 1991, records by WDFW (Amos and Appleby 1999) indicated a total of 613,639 Atlantic salmon escaped from farms between 1996 and 1999. There had been escapes also in previous years (1990- 1995), evidenced by the fact that fish were taken in the commercial and recreational catches, but at that time reporting was not a regulatory requirement. However, a sustained natural population has not been established. Similarly attempts to establish Atlantic salmon in the waters of British Columbia were made between 1905 and 1935. These have also been supplemented with reported escapes of 286,885 farm Atlantic salmon between 1988 and 2000 (McKinnell et al. 1997, and A. Thomson, DFO, personal communication) but again no sustained natural production has been recorded. A total of 9,096 were recovered up to 1995, mostly in the area where the abundance of salmon farms was the highest. Wing et al. (1998) report that 89 Atlantic salmon which had escaped from marine aquaculture facilities in British Columbia and Washington were caught in Alaska fisheries between 1990 and 1995. New data by Thomson (DFO, personal communication) puts the number at 556 by 2001. 14 Losses of fish from net -pens are not always due to escapes. Moring (1989), in his documentation of unexplained losses of chinook salmon from small (5.5 m') experimental saltwater cages with intact netting were on average 8 -38% for individual locations, and 2.5 -46.5% for individual cages. He attributed the losses to rapid decomposition of carcasses, scavenging by birds, mammals, and fishes, and to a lesser extent escapes. Actual unaccounted -for losses from commercial net -pens are currently in the order of f2 -5% (P. Granger, WFGA, personal communication). This is primarily because unexplained losses are few. In practice, fish arrive from hatcheries inventoried, and further inventories are taken each time they are moved for grading or changing nets. The accuracy of the inventory depends on how the fish are being handled. Escapes have also occurred from net -pen salmon farms in Norway, Chile, and Tasmania. In Norway, Gausen and Moen (1990) reported that escaped fish entered Norwegian rivers in great numbers, but most ( >20 %) were found only in rivers having farms situated closer than 20 km from the outlet. Lura and Saegrov (1991) documented the successful spawning of farmed female Atlantic salmon in Norwegian rivers, where it is a native species, and Lura et al. (1993) recorded some differences in spawning behavior between a single farmed fish and wild fish. For example, the redd of the female farmed fish had more pockets (nine versus an average of two) but fewer eggs (459 compared with an average 707). Jonsson et al. (1991) described differences in life history and migratory behavior between wild and hatchery- reared Atlantic salmon. In the sea, wild salmon survived twice as well as hatchery fish, ascended the rivers earlier, and were injured less during spawning. Hatchery- reared fish, on the other hand, stayed for a shorter period in the rivers, and a larger proportion returned to sea without spawning. Crutchfield (1989) reported that fishermen opposed the net -pen industry for adverse effects of farmed fish on market prices. He recognized that this was a complex point, but thought competition between farm and wild fish would broaden as farm salmon could be found year -round and wild salmon in relatively narrow windows — normally four months of the year, but much less in Washington where trollers and gill - netters were restricted. He concluded that farmed salmon would either moderate price increases or actually cut real -price increases for domestic wild salmon. However, he added that imports were much greater than the supplies of equal - quality troll - caught chinook and coho. Again, his conclusions proved to be correct, as evidenced by the imports of Atlantic salmon in 2000 which totaled over 130,000 mt with a value of $741 million (USDA 2001), mostly from Chile and Canada. From his economic and futuristic survey of the industry, Crutchfield (1989) indicated that 79% of wholesalers and distributors felt that fresh farmed Atlantic salmon were a direct substitute for fresh Pacific fish, and that 26% felt that farmed Atlantic salmon competed directly with frozen Pacific salmon. He said that exports of US wild salmon to Europe, which was about 10-15% by value of total production, would feel the impact of farmed salmon most severely. European smoked fish processors had all gone over to Atlantic salmon. However, he concluded that all the conjecture was insignificant as the output of farmed salmon in Washington in the long -term had little or no measurable effect on prices determined by worldwide supply and demand. 15 2.4 Interactions of Farming with Recreational Activities in Puget Sound The State of Washington Department of Licensing (WDL) reported that the number of registered recreational boats in the State was about 250,000 (WDL 1997). This was double the number of boats registered in 1984. A more recent statistic (PSWQAT 200 1) stated that people living in Puget Sound own more than 165,000 power boats, 21,500 sailboats, 43,500 canoes and kayaks, and numerous other watercraft. This had necessitated the installation of 43 new pump -out stations in the Puget Sound Basin since 1994, with the construction of 15 more on line. Goodwin and Farrel (1991) published a directory of marinas and moorage facilities in the State in 1991, and listed 379. Kitsap County had 26 facilities and 2,968 wet moorage slips. The 20 facilities in Kitsap County which completed the survey data offered a total of more than 4 miles of dock and guest -dock space to recreational boats. The State's Interagency Committee for Outdoor Recreation (ICOR) made a comprehensive field inventory of motorized boat launches in the State in 1997 and identified 984 such sites (ICOR 2000). The typical marina or yacht club in Puget Sound leases between 2 -20 acres of aquatic lands from the State (WDNR 2001). More importantly, these facilities displace areas which have probably been near -shore habitat for juvenile fish. Based upon past studies of marinas for the State's Department of Fisheries, Cardwell et al. (1980) considered reduced dissolved oxygen (DO) and increased water temperature the greatest potential threat to aquatic life in Puget Sound marinas. Although coliform contamination of shellfish, the leaching of antifouling paints, and the introduction of hydrocarbons via the exhausts of outboard motors posed potential or real threats, they stated this could all be controlled if marinas were well managed and had sufficient flushing to prevent large temperature and DO changes. Although they recognized that the statistical relationship between flushing and changes in these parameters measured in the study was weak, they judged that a minimum flushing rate of 30% was adequate for the purpose. This value was based on a 1.82 in tidal range computed for a 24 -hr period. If the marina was in an estuary where tidal ranges never attained 1.82 m, then the minimum overall flushing rate was about 15 %. Subsequently, Cardwell and Koons (1981) documented several water quality perturbations within marinas and moorage facilities. Pollutant inputs included runoff from parking lots and storm drains, hydrocarbons from outboard motor exhaust, heavy metals from antifouling paints, and biocides such as creosote and pentachlorphenol in wood piling and docks. Indirect effects resulted from nocturnal diminutions in dissolved oxygen due to respiration of phytoplankton blooms and diurnal elevations in water temperature due to solar radiation. In an earlier study on the effects of hydrocarbons on marine organisms consumed by humans, Clark et al. (1974) exposed mussels and oysters to a diluted effluent from a two - cycle outboard motor in a running seawater system. The organisms displayed physiological stress, degeneration of gill tissue, and uptake of paraffin hydrocarbons from the effluent. Mussels showed an immediate response to the pollutant as well as a 16 significant delayed mortality after removal. The oysters were less affected as they had the capability of closing for longer periods of time. Milliken and Lee (1990) carried out a comprehensive review of literature on recreational boating and pollution dating back over 40 years. They focused on four of the principal pollution problems associated with recreational boating, namely sewage, engine pollution, anti - fouling paints, and plastics debris. Regarding boat sewage, they found that, although the volume of wastewater discharged from recreational boats was small, the organic matter in the wastewater were concentrated, and consequently the biological oxygen demand (BOD) was much higher than that of raw municipal sewage or treated municipal sewage. Furthermore, the concentrations built up around the marinas as they were usually sheltered and poorly flushed. They also found that there was both a positive and negative correlation between the density of boats and fecal coliform concentrations in the water, but that background fecal coliform levels from overland storm -water runoff exceeded that caused by boats. WDFW (1997a) reported that anglers took 1.5 million trips to Puget Sound and the coast in 1996 to catch 'food fish'— the State - designated category for salmon, sturgeon, carp, and most marine fish. Departmental statistics in the 1996 -1997 Annual Report (WDFW 1997b) indicate that 358,954 fishing licenses for food fish were sold in 1996, together with 596,898 licenses for game fish (primarily freshwater species), and 89,393 licenses for steelhead. Zook (1999) estimated that recreational angling for non- native game fish contributed about $735 million annually to the State's economy. 2.5 Economic Benefits of Salmon Farming to the State Dicks et al. (1996), in a study on the economy -wide impacts of US aquaculture, concluded that, in 1992, the aquatic farming industry generated approximately $5.6 billion in gross domestic product (GDP) and over 181,000 jobs. Production activities accounted for about 8% of the income and 16,500 jobs, while upstream activities, such as equipment, supplies, feed, seed, fertilizer, labor, and financing, accounted for about 23% of the income and 40,500 jobs. Downstream activities, such as transport, storage, processing, manufacture, distribution, and sale of products, etc., accounted for 69% of the income and approximately 125,000 jobs. Stokes (1988) concluded there were many economic net gains statewide from salmon farming in the State of Washington. In a study of 64 benefit -cost and sensitivity analyses for ratios of gross economic gains (household income) to potential losses (adverse property consequences), and reflecting a wide combination of data, the ratios all exceeded unity. Average results for all calculations and results calculated under assumptions favorable to the industry indicated substantial net economic gains. The study had three tasks, regional input- output analysis, state fiscal analysis, and property value analysis. 2.5.1 The contribution of salmon farming to seafood production In its annual summary of national fisheries statistics, DOC estimated commercial aquaculture production in 1997 of 314,657 mt (693.7 million lb) with a value of $886 17 million (DOC 1998). Total exports of edible fishery products were 915,000 mt (2.0 billion lb) valued at $2.7 billion. The total imports of edible fishery products were 1.5 million mt (3.3 billion lb) valued at $7.8 billion. With regard to salmon, the DOC fisheries statistics estimated exports of fresh and frozen salmon in 1997 were 86,157 mt (189.9 million lb) valued at $307.5 million. Canned salmon exports were 37,023 mt (81.6 million lb) valued at $135.4 million. Imports of fresh and frozen salmon in 1997 were 73,847 mt (162.6 million lb) valued at $344.4 million, and imports of canned salmon were 557 mt (28.8 million lb) valued at $4.8 million. In an early review of the economics and future of salmon farming in the Pacific Northwest, Crutchfield (1989) concluded that a fully developed salmon industry in Puget Sound would make a positive contribution to the economies of the region but would do little to reduce the imbalance of international trade or even the trade in seafood. He estimated that salmon imports were less than one -tenth of one percent of the $150 million international trade deficit, and a salmon farming industry would have little or no impact. USDA more recently reported (USDA 2001) that Atlantic salmon imports in 2000 reached 289 million lb (131,000 mt), as shipments increased in all three main categories (fresh whole fish, frozen whole fish, and fresh and frozen fillets). imports of fillets remained the fastest growing category and made up over 50% of imports. The majority of imports came from Chile (filleted products) and Canada (fresh fish), with Chile taking over as top supplier with shipments rising by 51 %. The value of Atlantic salmon imports in 2000 was $741 million, and the market continues to expand. In a comparative review of 1999, Northern Aquaculture (2000) reported that actual production of salmon in Washington in 1999 was 5,500 mt, with a value C$38 million (just below US$30 at that time). Production was about the same as in 1998. In Maine production of Atlantic salmon was 12,100 mt (down 8 %) with a value of C$111 million. In Canada BC production was 47,000 mt of Atlantic and Pacific salmon (chinook and coho). This figure was up 19% over 1998. The value was C$347, of which 86% was for Atlantic salmon. In New Brunswick production of Atlantic salmon and steelhead was about 27,000 mt, with a value of about C$140 million. The Washington Fish Growers Association FGA (WFGA) reported that total production in Washington in 1999 was 14 million lb. dressed weight (6,545 mt) of Atlantic salmon (99 %) and steelhead (1 %). The total value was about $30 million. About 95% of the farmed products were sold on the national markets as whole dressed fish, and 5% were exported as fresh fillets (P. Granger, WFGA, personal communication). 2.5.2 The impact on employment and wages Crutchfield (1989) predicted that a fully developed net -pen salmon industry in Puget Sound would be useful in contributing to employment in the area but would not be a significant factor. His prediction has proved to be very accurate. Some earlier estimates regarding employment in the industry were rather optimistic. Inveen (1987) suggested primary employment in a typical net -pen operation in Puget 18 Sound was 8 -10 persons with an average annual wage of $19,000 (range $14,500- 30,000). Capital investment required was about $750,000 -1 million, with annual operating expenses of $1.4 million (feed 30 %, labor 14 %, smolts 12 %, other 44 %). Assuming eight more jobs in secondary activities, the total contribution to employment by 10 farms would be 160 -200 jobs. This was similar to employment profiles in Norway. Stokes (1988) in a report to WDFW estimated that the State economy would gain $38-48 million in output, $11 -21 million in household income, and 257 -303 jobs from the existence of five Atlantic salmon farms in the State, with typical production figures of 1 million lb /annum and $5 million revenue. The average impact on the (Kitsap) County for one operational site would be $5.8 -6.8 million in output, $1.1 -2.1 million in household income, and 40-51 jobs. For the state of the industry in 1999, with 10 operational sites, WFGA reported current employment in the local industry of 65 full -time positions, 5 part -time positions, and approximately 200 more employed indirectly down the line (P. Granger, WFGA, personal communication). By comparison, Young et al. (1998) reported 1,000 full and part-time employees in the net -pen salmon industry in Maine, with 38 operational sites, which equated to about 750 full -time jobs. In addition, about 500 full -time jobs in Maine were directly dependent on contracted employment with salmon farms, such as trucking, diving, health management, and other services. Indirect impacts of employment induced in the local communities by salmon farms represented another 1,000 jobs. BCSFA (2000) reported that the salmon farming industry in Canada employed 3,400 people, mostly on the BC coast. In 1999 the BC salmon industry produced 47,000 mt of salmon valued at C$347 million. Estimated wages for a direct employee in the industry in Washington were up to about $45,000, and for an indirect employee about $35,000 (P. Granger, WFGA, personal communication). These wages continued to be above average for the collective agriculture sector (which includes forestry and fishing) in Kitsap, County, which accommodates most of the net -pen sites. Kitsap County (2000b) reported that the annual average wage (1994) for this sector was $16,268. This was higher than the statewide average of $13,767 primarily, it noted, because of a small number of highly paid workers in aquaculture and fishing. However, about 70% of jobs in the collective agriculture sector were in agricultural services industries, with the largest industries being lawn and garden services, and non - livestock veterinarian services. 2.5.3 The impact on coastal property values In a study of Puget Sound waters for coastal sites for net -pen fish farms, Weston (1986) provided interim tidal velocity and water quality guidelines to minimize their impact. Only 19 areas were identified as acceptable, relevant to specific farm capacity and the proximity of special habitats. Five more areas, in Puget Sound Basin and beyond, were acceptable without limitation. Parameters relevant to the existence of shoreline industries or private properties, or any anticipated real estate developments, were not included in Weston's early guidelines, 19 although the Basin was in the middle of major population growth and property development. In its period summary on the health of Puget Sound, PWSWQAT (2000) noted the Sound was currently home to almost exactly 4 million people, or double the population of the 1960s. Annual growth was about 50,000 people (1.5 %) and the population was expected to reach 5 million people by the year 2020. The majority of preferred net -pen farm sites identified by Weston (1986) were located in waters around Kitsap County and Mason County. In the last 25 years (1970 -1995) the population of Kitsap County, in the middle of the Sound, has increased 116.8 %, compared with 59.1% across the State. Much of this was due to the immigration of 47,104 persons between 1980 and 1995 (Kitsap County 2000a). Property development was a priority and principal activity, as the collective finance, insurance, and real estate employment sector showed an increase in employment by 255% (1970 - 1995), of which real estate garnered one -third of the jobs (Kitsap County 2000b). Alpine Appraisers (1988) undertook a comparative study of visual and market effects of net -pen fish farms on property values around Puget Sound. They concluded that floating net -pens had no effect on upland property values in the area studied (Mason County and Kitsap County), and that they had `minimal', if any, visual impact at distances over 2,400 lineal feet. Stokes (1988), in a statistical analysis of 335 property listings and assessed value in water -front areas throughout Puget Sound in the vicinity of net -pen complexes, determined the average front footage price of $409 had a standard deviation of $290, half of which could be accounted for by general location (County), land type (high -low bank), and improvements (water, sewer, etc.). The remaining, or 'residual' price variation, was presumed to result, at least in part, from variations in visual aesthetic quality. Parsons (199 1) studied the effect of coastal- land -use restrictions on housing prices in the State of Maryland. He found that housing prices in the critical area with water frontage increased by 46 -62% due to restrictions, compared with 14 -27% without water frontage, 13 -21% for those just outside the area, and 4-11% for those three miles away. The direct beneficiaries of coastal- land -use restrictions were the current owners of housing in the community, while the losers were owners of undeveloped or restricted land, renters, and future owners. Garrod and Willis (1992) studied the effect of selected countryside characteristics on house prices in a rural area of England covering 4,800 km2. They found that many variables (such as within 1 km proximity to woodland, river or canal, or rural settlement) had a positive influence on house prices of 7 -10 %, 4-9 %, 8 -12 %, respectively. Furthermore, the characteristics of an open water view or gradient slope had no observable effect; and being close to wetlands or having woodland or urban views had the effect of reducing house prices. 2.6 The Regulatory Structure for Commercial Enterprises The policies and regulations (and their enforcement) for aquaculture introductions in the State of Washington and the Province of British Columbia were reviewed and summarized in detail by Elston (1997) in his study of pathways and management of 20 marine non - indigenous species (NIS) into the shared waters of British Columbia and Washington. Aquaculture had been identified as one of six pathways for NIS introductions for the study, and in his final report to the Puget Sound Water Quality Authority, the US Environmental Protection Agency, and the Department of Fisheries and Oceans Canada, he stated that the adequacy of information available to assess the relative risks of introductions through aquaculture was good. This was because for more than a decade Washington and British Columbia had in place state /provincial (and federal) procedures specific to aquaculture. He noted that intentional introduction of aquaculture species was then far more restricted than in the past. He stated that technology could assist further in reducing the risk from exotic species introductions by, for example, culturing only strains of sterile organisms. Elston concluded that the risk from aquaculture introductions from aquaculture was well - defined, the industry was highly regulated, and active processes were underway for continuous review of aquaculture activities as they involved NIS. Traditionally the policy of the State of Washington has been supportive of aquaculture. The State was one of the first to recognize that aquaculture was a form of agriculture and enacted legislation in 1985 which designated the Department of Agriculture as the lead agency, with WDF responsible for disease control and prevention regulations. The current policy of the State fosters the commercial and recreational use of the aquatic environment for production of food, fiber, income, and public enjoyment from state - owned aquatic lands, and identifies aquaculture among legitimate uses. In its policy implementation manual for the use of the State's aquatic resources (WDNR 2000b) aquaculture is specifically designated as an aquatic land use of statewide value. WDNR generally encourages this use, and it takes precedence over other water - dependent uses which have only local interest values. While commenting on the possible environmental impact on aquaculture by surrounding activities, and vice versa in a discussion on net - pens and floating rafts, the manual states again that aquaculture remains a favored use of state -owned aquatic lands. WDNR (1999) recently published a technical report on the potential offshore finfish aquaculture in the State. Amos and Appleby (1999) summarized the roles and responsibilities of the regulatory authorities in the State of Washington with regard to the management of salmon farming in State waters, and particularly Atlantic salmon farming. Their summary forms the basis of the following annotations of the regulatory structure for commercial enterprises producing either Pacific or Atlantic salmon. (i) WDFW has management and regulatory authority over all free - ranging fish in the State. The authority of WDFW over commercial fish culture in State waters is restricted to disease control and protection of wildlife in general. • The Finfish Import and Transfer Permit (WAC 220 -77 -030) assures that diseases, pests, and predators are not introduced or transferred. In addition, under a legal settlement, WDFW is required to kill and conduct biological examination of any Atlantic salmon encountered by agency staff. 21 • Hydraulic Project Approval (RCW 75.20.100, WAC 220 -120), or HPA, assures that all construction projects ensure protection of wildlife and habitats. However, the authority of WDFW to require HPAs of aquaculture workers at their sites is not clear. WDFW, in association with the State of Washington Department of Ecology (WDOE) and Department of Natural Resources (WDNR), provides guidance to state and local agencies siting farms to avoid adverse impacts on the environment. in association with the State Department of Agriculture (WDA), it develops disease control regulations with regard to human health and safety. (ii) WDOE has regulatory authority over discharges of pollutants into State waters for the protection, preservation, and enhancement of the environment. • The National Pollution Discharge Elimination System Permit (40 Regulation CFR, Part 122.21), or NPDES, assures compliance with state and federal water quality laws. • The Water Discharge Permit (RCW 90.48) assures that discharges and wastes do not adversely affect water quality and standards. Under the Clean Water Act and the Water Pollution Control Act, WDOE can take regulatory action against net -pen operators who allow Atlantic salmon to escape. This follows the determination by the Pollution Control Hearings Board (PCHB) that Atlantic salmon are 'pollutants.' The PCHB also adjudicates appeals over permits issued by WDOE. In association with WDFW and WDNR, WDOE provides guidance to state and local agencies on siting farms to avoid adverse impacts on the environment. (iii) WDNR has regulatory authority over state -owned aquatic lands, including all bedlands of Puget Sound, navigable rivers, lakes, and other waters. The authority also extends over lands covered and exposed by the tide, and most shores of navigable lakes and other fresh waters. • The Aquatic Lands Lease (RCW 79.90- 79.96), or ALL, assures the specification of all uses of the land and the proposed facilities. WDNR, in association with WDFW and WDOE, provides guidance to state and local agencies on siting farms to avoid adverse impacts on the environment. (iv) WDA is responsible for assuring the safety of the State's food supply, providing protection from diseases and pests, and facilitating movement of agriculture products in domestic and international markets. With WDFW it jointly develops disease control regulations with regard to human health and safety. (v) Local counties in the State of Washington act as lead agencies for applying the environmental policies of the State, and the management of their respective county shorelines. • The State Environmental Policy Act (RCW 43.21C, WAC 197 -11), or SEPA, assures consideration of social and environmental impacts of proposed actions. 22 • The Shoreline Management Act (RCW 90.58), or SMA, assures appropriate and orderly development of state shorelines, management of their uses, and preservation of their natural character. (vi) A number of federal agencies [NMFS, the US Army Corps of Engineers (ACE), US Fish and Wildlife Service ( USFWS), US Coast Guard (USCG), and the Environmental Protection Agency (EPA)], together with respective State agencies, have management and regulatory authority over the use of all waters by the public. • The Section 10 Permit assures protection of public interest, including navigation, water safety, and water quality. (vii) NMFS administers the ESA for anadromous salmonids. It may require commercial salmon farmers to obtain permits to take fish for their use due to the impact on listed species. Jointly in collaboration with USFWS and WDNR, NMFS permits the use of predator control methods (non - lethal) for birds and mammals in accordance with permit restrictions. (viii) The US Food and Drug Administration (FDA) is responsible for the protection of consumers by enforcing the Federal Food, Drug, and Cosmetic Act, and several related public health laws. It is also responsible for the safety of feed and drugs for pets and farm animals. Salmon farmers are restricted to the use and conditions of veterinary medicines, drugs, growth enhancers, and other chemical supplements licensed by FDA. (ix) The Treaty Tribes of the State of Washington co- manage fisheries resources in the State with WDFW and thus have input into disease control regulations (see (i), above). 2.7 The Regulatory Structure for Public and Tribal Hatcheries Public and tribal hatcheries producing Pacific salmon (and other fish) in the State of Washington must conform to the same general regulations regarding commercial hatcheries and farms. These regulations, as described, are all concerned with protection of the environment, or the health and safety of other plants and animals, including human consumers. However, since 1994, when a number of Pacific salmonid species in the region were listed for protection under ESA, there are some differences in regulations for public and tribal hatcheries. The production of listed fish in public and tribal hatcheries is now restricted to recovery purposes only, and not for subsequent commercial or recreational harvest. Certain sections of the ESA pertain to the necessary taking of listed fish for public and tribal hatchery operations, and also for research. For example, in Section 7 of the Act, hatcheries in ESUs where there are single listed stocks are permitted a directed take of fish for recovery operations, and an incidental take in ESUs with mixed - stocks. In an attempt to avoid further layering of regulations the NMFS is proposing to adopt a new approach. Through the so- called 4(d) Rules, public and tribal authorities (and the private sector) can develop their own conservation strategies to be approved by NMFS. 23 After approval of a specific conservation program, any activities appropriately implemented will automatically be in compliance with the ESA and will not require individual permitting. As part of this approach the NMFS has been working with management agencies in the region to develop Hatchery and Genetic Management Plans (HGMPs). The HGMP procedure provides a thorough description of each hatchery operation, including the facilities used, methods employed to propagate and release fish, and measures of performance. There are also sections dealing with the status of listed stocks which may be affected by the plan, anticipated listed -fish 'take' levels, and a description of measures to minimize risk to listed fish. However, once completed, accepted, and followed, hatchery managers are assured that their activities are all in compliance with ESA and no further permitting is required. 24 3. POTENTIAL ISSUES FOR HUMAN HEALTH AND SAFETY The third chapter is specific to the potential issues for human health and safety from net -pen salmon farming in the Pacific Northwest region. It is sub - divided into five parts. After a brief introduction to global and national responsibilities for food safety, the second part deals with the chemicals and chemical contaminants in materials used in farm production operations. Possible sources include metallic paints, feed ingredients, and chemo - therapeutants. The third part concerns the transmission of diseases, and the common pathogenic diseases are reviewed. The fourth part deals with the processing and quality of farm products, specifically the proximate composition of farm fish, and differences between farm and wild salmon species. The final part concerns worker safety. 3.1 General Food Safety In 1995 the members of the United Nations Food and Agriculture Organization (FAO) formally adopted a Code of Conduct for Responsible Fisheries. The Code, which was then published (FAO 1995), advocated safe and high quality fisheries products. Article 9 of the Code, which was specific to aquaculture, was then broken out and detailed in a subsidiary document called, Aquaculture Development (FAO 1997). The section on Responsible Aquaculture at the Production Level called for the global aquaculture industry to make safe and effective use of feeds, feed additives, chemo - therapeutants, and other chemicals, and to promote the use of aquaculture practices and methods which reduced the hazards. As a signatory of the FAO Code, the US has ensured that its national aquaculture industry will abide by all the intentions contained in Article 9. The terminology used in this Chapter is adopted from the World Health Organization (WHO) report on Food safety issues associated with products from aquaculture (WHO 1999). The terms'hazard and 'risk'have specific definitions. A'hazard is a biological, chemical, or physical agent in food, or a condition of food, with the potential to cause harm. A'risk' is an estimate of the probability and severity in exposed populations of the adverse health effects resulting from a hazard(s) in food. The greatest risk to human health from seafood occurs from post - harvest contamination and loss of product quality. However, this section confines its review to the risks to human health from hazards which might be incurred in the pre- harvest production of farm salmon raised in marine net -pens. When appropriate, it compares the risk with products from wild harvests, other forms of aquaculture, and agriculture. Potential hazards to food safety by the consumption of farm salmon raised in net -pens, or by human contact with farm operations, may include: • Toxic chemicals and chemical compounds which have been accumulated by the fish from their aquatic environment, or from their food, or as residues from veterinary medicines. 25 • Pathogenic organisms in the fish, such as parasites, viruses, and bacterial pathogens, which may also be harmful to humans. The overall risks of feed -borne human illnesses from cooked seafood (wild and cultured) are low compared with risks from other animal products. Otwell (1989) pointed out that the estimated risk of disease from consuming a 4—oz serving of cooked seafood was 1 in 5 million servings, but for chicken it was 1 in 25,000 servings. However, unlike other meat products, seafood is often eaten raw or lightly cooked, and the estimated risk rises to 1 in 250 servings for the consumption of uncooked shellfish. The risk from consumption of uncooked fish is also higher than for cooked fish. Primary responsibility for regulating all seafood safety, including farm products, rests with the FDA. The FDA performs its functions by adopting BMPs, approving hazard analysis and critical control points (HACCP) plans, and promulgating regulations. Enforcement is primarily through inspection of handling and processing plants to ensure compliance with BMPs, HACCAP plans, and regulations. The FDA also approves and regulates the use of drugs and additives used in all domestic and farm animal feeds, which includes feeds used by the aquaculture industry. 3.2 Chemicals and Chemical Contamination Toxic chemicals and chemical compounds are accumulated by fish and shellfish from their aquatic environment and from their food. Chemical contaminants which are potentially hazardous to humans through seafood consumption, including farmed salmon, are heavy metals, feed -borne toxicants, and chemo- therapeutics. Human illnesses resulting from chemicals in the environment are more commonly associated with long -term exposure. Jensen and Greenlees (1997) found that illness associated with a single meal was rare. Moreover, areas of chemical contamination tended to be concentrated in space and sometimes in time. For the most part, sensible precautions and local regulations have ensured that fish farm facilities have been situated where risks of chemical contamination were minimized. Sites have always been far from industries associated with environmental pollutants and the out -fall of human sewage treatment plants. 3.2.1 Heavy metals Metal ions enter fish by absorption through the gills or from food. The latter is more common. In general, fish regulate the concentrations of metal compounds in muscle tissue within tight limits. Consequently, concentrations of inorganic metals do not exceed regulatory limits even when the fish are harvested from environments with high metal concentrations. The exception to this rule is tin, in the organic form of tributyl -tin, and mercury in its organic form of methyl- mercury, which a number of sources (Cappon 1983, Jensen and Greenlees 1997, WHO 1999) indicate can be accumulated through the food chain. 26 Tributyl -tin was commonly used as a biocide in anti - fouling paints on recreational boats (Milliken and Lee 1990) in the marine environment. Subsequently it was used on net -pen structures. However, due to its rapid leaching, tributyl -tin and its breakdown products were found in the water, sediment, and in organisms where there are concentrations of recreational boats. Later it was demonstrated that salmon in treated pens could accumulate tin in their tissues. The use of tributyl -tin was consequently restricted in Europe and North America, and WHO set a limit of 3.2 µg/kg body weight for tin in humans (WHO 1999). Based on this figure, and levels of tin found in fish reared in cages treated with tributyl -tin, a daily consumption of 150 g of salmon by a 70 kg person would be necessary to exceed this level. At least 13 States in the US have enacted their own legislation on the use of tributyl -tin, in addition to that of the EPA. Methyl- mercury bio- accumulates in the food chain, and is of particular concern for long - lived predatory fish. Farmed salmon live on a diet of prepared pelleted feeds, and are usually harvested before 3 years of age so there is less opportunity for methyl - mercury to accumulate. There are no records of farmed salmon accumulating methyl- mercury. However, there are examples of methyl- mercury accumulation in wild salmon. Cappon (1983) recorded mercury levels of 0.3 -0.8 mg /kg in wild salmon from the Great Lakes, which is just below the maximum permissible limit of 1.0 mg/kg. 3.2.2 Manufactured feeds The risks to human health from feed -borne toxins have long been known, and feed manufacturing standards, including the composition and labeling of fish feeds, are strictly regulated by the FDA. However, the ingredients for the compounding of animal feeds still come from a variety of suppliers, and some risks still remain. Of particular concern for human health are certain animal byproducts, oilseed meals, grains and byproducts, hormones, pigments, antioxidants, and most recently some organic compounds called 'dioxins.' (i) Animal byproducts Rendered animal protein ingredients, including various meat and bone meals, poultry byproducts, blood, and marine processing wastes have been used for decades to replace some fish meal in the diets of salmonids. However, the dietary inclusion levels for most of these products have been limited because of concerns of poor digestibility, nutritional value, palatability, and variable product quality. Efforts to avoid excessive phosphorous levels in hatchery effluents have also limited the use of some of animal byproduct meals, which may include relatively high levels of indigestible phosphorous from bone. The use of rendered animal byproducts in animal feeds has been severely constrained since 1997 by new standards imposed by FDA in the Code of Federal Regulations (CFR) Title 21. Regulation 21 CFR, Part 589.2000 prevents the inclusion of certain mammalian proteins in feeds for cattle and other ruminant animals. This is intended to prevent the establishment or amplification of bovine spongiform encephalopathy (BSE) in the US by prohibiting the feeding of protein from ruminants (such as cattle, sheep, goats, deer, elk, buffalo, and antelope) to ruminants. Exempt from the ban is mammalian protein derived 27 from pure pork or horses slaughtered as single- species facilities, inspected meat products, blood and blood products, gelatin, and milk products. Feeding of mammalian proteins to fish is not prohibited by the regulation. However, the final regulation requires feed manufacturers who handle both prohibited mammalian protein and non - prohibited mammalian /non - mammalian protein to follow strict measures to prevent cross contamination of feeds which may be fed to ruminants, label finished feeds appropriately, and maintain records of ingredient purchases and disposition of the finished feeds. Customer concerns and changes in market availability of many of these byproducts (e.g., meat and bone meal) have effectively eliminated these ingredients from salmonid feeds. The use of exempt products, including blood meal and byproducts of fish and poultry processing, still continues, although levels of dietary inclusion may be constrained by price and availability. Studies regarding the potential for BSE transmission to humans through discharge of BSE prions into the aquatic environment via uneaten fish feed and feces have not been reported in the scientific literature. However, risks from a rendering plant disposing of cull cattle carcasses in the catchment area of a chalk aquifer used for drinking water have been examined by Gale et al. (1998). They calculated that the risk to consumers who drank the water was remote, and an individual consuming two liters daily for 45 million years would have a 50% chance of any infection. (ii) Oilseed meals, grains, and byproducts Fish meal in salmon feeds may be partially replaced by soybean, cottonseed, and canola meals. The dietary inclusion level is governed by available content of essential amino acids, palatability, and whether compounds toxic to the fish or anti - nutritional factors are present. Dabrowski et al. (1989) and Sanz et al. (1994) found that soybean meal products could replace a high percentage (25 -40 %) of dietary fish meal without affecting growth of rainbow trout. However, dietary levels of some soy products were limited by the presence of compounds which induced intestinal enteritis in Atlantic salmon (Baeverfjord and Krogdahl 1996) and rainbow trout (Refstie et al. 2000). Salmon feeds may also include low levels ( <10 %) of wheat and wheat byproducts, such as wheat middlings, as binding agents and sources of dietary energy. In recent years, oilseeds and grains have been modified by genetic engineering to produce crops with increased yield and decreased reliance on herbicides and pesticides. Few published data are available regarding their safety and nutritional value as animal feed ingredients. Research by Hammond et al. (1996) has shown, however, that the feeding value (nutritional value) of soybeans to rats, chickens, catfish, and dairy cattle is not affected by genetic modifications which impart tolerance to mid- season application of the herbicide, glyphosate. The use of genetically modified (GM) oilseeds and grains in animal and human foods has gained considerable attention in the US and the European Union because of uncertainties regarding their effects on human health and the environment. Of concern are modifications that introduce previously unknown allergens in food products, or affect 28 native plants through cross - pollination. The FDA is unaware at the present time of scientific data indicating that foods developed through genetic modifications differ as a class in quality, safety, or any other attribute from those developed by convention breeding techniques. In recognition of the importance of issues surrounding the safety of bio- engineered foods, the Codex Alimentarius Commission (established by WHO and FAO) in March 2000 appointed the Codex Ad -hoc Intergovernmental Task Force on Foods Derived from Biotechnology. Its mandate is to study the safety of such foods, their effects on the conservation and sustainable use of biological diversity, and also their effects on human health. Safety concerns over the use of genetically modified ingredients in animal feeds have not been substantiated scientifically. However, consumer demand for GM -free fish in the marketplace has resulted in some feed companies producing and offering for sale only GM -free feeds. Suppliers are required to present documentation that all ingredients are free from any genetically modified organism (GMO). (iii) Growth hormones Exposure to steroids incorporated into the diet has been shown experimentally to affect sexual development, growth, and feed efficiency of several salmonids. Piferreri and Donaldson (1989) found experimental feeding of low doses of 1743- methyltestosterone to coho fry increased the proportion of males, whereas the estrogenic steroid 17- B- estradiol increased the proportion of phenotypic females. Baker et al. (1988) developed a technique for producing phenotypic male chinook salmon from mono -sex female -eyed eggs and fry by immersion in a solution of 17 -B- methyltestosterone and water. Human food safety and environmental issues associated with the use of 17 -f3- methyltestosterone for sex control in fish have been reviewed by Green and Teichert- Coddington (2000). Ostrowski and Garling (1986) found that dietary 17 -6- methyltestosterone enhanced growth of fingerling rainbow trout without affecting feed utilization. In contrast, Yu et al. (1979) showed that low doses of androgenic steroids improved both growth and feed conversion ofjuvenile coho salmon. Some synthetic steroids have been approved by the FDA for use in the US to increase growth, feed efficiency, and milk production in cattle. However, the use of hormones has not been cleared for food fish. (iv) Pigments The characteristic red color of salmonid flesh from the deposition of dietary carotenoids is an important factor in determining product quality and consumer acceptance. In the wild, salmonids consume prey organisms containing small quantities of astaxanthin and other carotenoids which are deposited in the skin and muscle. Formulated feeds used in salmonid aquaculture are usually supplemented with astaxanthin, although a related carotenoid, canthaxanthin, is sometimes used. Astaxanthin is an approved color additive in the feed of salmonids (Regulation 21 CFR, Part 73.35 [USOFR 1995c]). The maximum permitted level of astaxanthin is 80 mg /kg (72 g /mt) of finished feed. The FDA requires that the presence of the color additive in the feed, or fish which have been colored with the feed additive, or any product which contains artificially colored salmon Wt as an ingredient, is declared on the label or ingredient list. However, this information is unlikely to pass to the consumer when the product is displayed out of its packaging. (v) Antioxidants Oxidation of lipids in feed ingredients can cause a reduction in their nutritional value and may produce compounds toxic to fish. Hung et al. (1981) found that feeds and /or ingredients containing high levels of unsaturated fatty acids, such as fish meal and fish oil, treated with synthetic antioxidants prevent nutrient loss and formation of toxic peroxide compounds. Synthetic antioxidants, such as BHA (butylated hydroxyanisol), BHT (butylated hydroxytoluene), and ethoxyquin (1,2- dihydro -6- ethoxy- 2,2,4- timethylquinoline) are commonly used in animal feeds. Maximum levels permitted in the finished feed by the FDA is 0.2% of the fat content for BHA and BHT, and 150 mg /kg for ethoxyquin. (vi) Organic toxicants Organic compounds, such as polychlorinated biphenyls (PCBs), dibenzofurans, organic pesticides, and halogenated aromatic hydrocarbons, etc., have all been found in wild salmon from polluted areas, such as the Great Lakes (Cleland et al. 1987, Cleland et al. 1989, Daly et al. 1989, Seegal 1999) and the Baltic Sea (Svensson et al. 1991). Recently, media reports on the presence of'dioxins' in farmed salmon have gained considerable attention, particularly among consumers in the United Kingdom and other EU countries. Dioxin exposure is of concern because of potential effects on the immune and endocrine functions and reproduction, as well as the development of malignant tumors (SCAN 2000). The term dioxins describes three classes of toxic chemical compounds widely distributed and persistent in the environment. They tend to dissolve in lipids and thus can be accumulated in the food chain. The groups are polychlorodibenzo -p- dioxins (PCDDs), polychlorodibenzofurans (PCDFs), and dioxin -like or co- planar biphenyls (PCBs). PCDDs and PCDFs are by- products of certain industrial processes, such as high - temperature waste incineration, and /or those involving organic chlorine treatments (bleaching paper during manufacture, synthesis of herbicides). PCBs were used mainly in electrical equipment beginning in the early 1930s until their manufacture and use was stopped in almost all industrialized countries by the late 1980s. Of the 210 possible PCDF and PCDD congeners, 17 are considered toxic. Twelve of the 209 members of the PCB family show dioxin -like toxicity. The overall toxicity of a dioxin- contaminated materials or food is an additive function of both the quantity of each congener present and its toxicity, relative to the most toxic compound 2,3,7,8 -TODD (Seveso- dioxin), expressed as total toxic equivalents (TEQ). WHO has proposed a tolerable daily intake (TDI) for humans of 1-4 pg WHO- TEQ /kg body weight (Van Leeuwen and Younes 2000), with the ultimate goal to reduce human intake levels below 1 pg TEQ/kg body weight per day. More than 90% of human dioxin exposure is derived from food, with food of animal origin as the predominant (ca. 90 %) source. Consequently, recent efforts to reduce human dietary exposure to dioxin and PCBs has focused on evaluating the contribution of various feed ingredients given to 30 farmed animals, including fish, and the contamination of human food products of animal origin (SCAN 2000). Data collected by the SCAN (2000) on basic feed ingredients (roughages, grains and cereals, vegetable oils, animal fat and other rendered by- products, fish meal and fish oil, as well as binders and trace element premixes) indicated that virtually all are contaminated with dioxin to varying degrees. Feedstuffs originating from plants generally contain low levels of dioxins (0.1 -0.2 ng WHO- TEQ/kg dry matter), while fish meal and oil, particularly those originating from European sources are highly contaminated (fish meal 1.2 ng WHO- TEQ/kg dry matter, fish oil 4.8 ng WHO- TEQ/kg dry matter). European fish meals and oils are about 8 -fold lower in total dioxin content than those produced from species caught in the coastal areas of less- industrialized regions of the world (Peru, Chile). Because of the high percentage of fish meal and oil in the diets of farmed carnivorous fish, such as salmon, the impact of using less contaminated feed materials of fish origin on whole diet dioxin burden is considerable. According to SCAN estimates, a typical diet for carnivorous fish containing 50% fish meal and 25% fish oil originating from Europe might contain 1.82 ng WHO- TEQ/kg dry matter, compared with 0.25 ng WHO - TEQ /kg dry matter if fish products from the south Pacific were used. Further reductions may be realized by partially replacing fish meal and oil with plant products, such as soybean meal and vegetable oils. Little is known about transfer of dioxins from feed to fish. However, based on limited data on transfer rates for PCBs in fish, and assuming similar behavior of ortho and non - ortho cholorobiphenyls, SCAN estimated at least 60% of the total dioxin + PCB TEQ in fish feed is likely to be transferred to fish. At present, the level of dioxin contamination in farmed salmon has not been rigorously evaluated, and transfer rates to humans have not been determined. However, it is likely that guidelines for tolerable limits for dioxin in all human food products or animal origin will soon emerge. While the potential for feed -borne hazards from organic compounds exists in farmed salmon, Jensen and Greenlees (1997) note that this public health issue is largely avoided in aquaculture by application of best management practices (BMPs) for site selection, and regulations for formulation and manufacture of feeds. 3.2.3 Chemotherapeutants Toxic chemicals and chemical compounds may residualize in fish following protracted use of approved veterinary medicines. Aquaculture, like terrestrial animal agriculture, relies upon good husbandry and proper use of drugs and chemicals to combat infectious disease pathogens. Of the chemotherapeutants approved for use in aquaculture, certain antibiotics and parasiticides are used in salmon net -pen farming. (i) Antibiotics Antibiotic residues in farmed seafood products are possible hazards to consumers in that they might induce allergic reactions, have toxic effects, or modify the human gut flora. They might also increase resistance in aquatic bacteria to antibiotics, which in turn, might be transferred to human pathogens. 31 All drugs approved by the FDA must be shown to be safe and efficacious. Studies required to meet these requirements typically consist of field (clinical) and laboratory (non - clinical) trials (USOFR 1995a). Clinical studies are conducted under an investigational new animal drug (INAD) exemption issued by FDA under the same conditions expected under the proposed use of the drug. Laboratory studies under strictly controlled conditions in accordance with good laboratory practices (GLP) are specified under the Regulation 21 CFR, Part 58 (USOFR 1995b). Laboratory studies conducted for the approval of a new animal drug for use in US aquaculture have been reviewed in detail by Greenlees (1997). The FDA permits certain antibiotics to be added at sub - therapeutic levels to the feeds of poultry, swine, and cattle as growth promoters. It does not permit the use of antibiotics as growth promoters for fish. In contrast with the results obtained with higher vertebrates, Wagner (1954), Sniezko and Wood (1954), and Sniezko (1957) reported that sulfonamide, tetracycline, and other antibiotics added to the diets of several salmonid species (brook trout, brown trout, and rainbow trout) had no stimulatory effect on growth At the present time three antibiotics are registered in the US as feed additives for disease control under Regulation 21 CFR, Parts 558.450, 558.575, and 558.582. Respectively, these are oxytetracyline (terramycin), sulfadimethoxine plus ormetoprim ( ®Romet -30), and sulfamerazine, although sulfamerazine is no longer marketed. For salmonids, oxytetracyline (terramycin) has a 21 -day withdrawal period before harvest, and ®Romet- 30 has a 42 -day withdrawal period. Stoffregen et al. (1996) stated that levels in flesh tissues were undetectable if these withdrawal times were followed. Fong and Brooks (1989) determined that the tolerance levels of salmon for each of these antibiotics were 0.1 ppm. (ii) Parasiticides JSA reviewed the use of chemical compounds and vaccines in aquaculture and published their findings in a guidebook (JSA 1994). Seafood producers operating by the JSA guidelines introduce no hazards from residual drugs. The risk is the misuse of chemical compounds and vaccines by untrained workers. Formalin is the only parasiticide approved at present for farm salmon operations (JSA 1994). It is applied topically, and Fong and Brooks (1989) were unable to detect it in salmon flesh after treatment, concluding that it was not a hazard to consumers. Other substances with putative activity, including acetic acid, garlic, hydrogen peroxide, onion, and sodium chloride, are currently classified by FDA as 'unapproved drugs of low regulatory priority.' The FDA is unlikely to object to use of these substances if the following conditions are met: (a) the drugs are used for the prescribed indications, including species and life stage where specified, (b) they are used at the prescribed dosages, and (c) are used according to good management practices. Also, (d) the product is of an appropriate grade for use in food animals, and (e) an adverse effect on the environment is unlikely. However, the use of such substances under these conditions is not approval or affirmation of their safety and efficacy, and the FDA may take a different position on their use in the future based on further information. 32 3.3 Biological Safety Potential biological hazards to human health from the consumption or contact with contaminated farm products include parasites, bacterial infections, viral infections, or naturally produced toxins. The majority of human pathogens associated with aquaculture products are to be found at freshwater farms, farms in tropical countries, and among shellfish operations. Specific hazards to human health which might be associated with net -pen farming of salmon are anisakiasis, diphylobothriasis, rickettsialosis, vibriosis, aeromonasis, salmonellasis, and plesiomonasis. To date there have been no reported cases of any of these hazards being associated with farmed salmon, and WHO (1999) states that the risk of contracting these illnesses from farmed fish is considered to be low. (i) Aniskiasis Anisakiasis is caused by larval ascaridiod nematode parasites which normally infect marine mammals as the definitive host, and an invertebrate as the primary host. Marine fish are secondary hosts, and are infected when they consume infected fish or invertebrates. Roderick and Cheng (1989) indicated that the parasite inhabits the viscera of live fish but relocated to the musculature upon death. They concluded that the parasite is not likely to be a problem in farmed fish, as the viscera are removed quickly after harvest. The parasite is killed by proper cooking or proper freezing, and only infrequently infects humans. Human infection of this and other parasites primarily occurs when wild fishery products are consumed raw, as in Japanese maguro (tuna) or sake (salmon) sashimi, or after only mild processing, such as cold smoking. Studies by Angot and Brasseur (1993), Bristow and Berland (1991), and Deardorff and Kent (1989) have indicated that farmed salmon do not have nematodes. Consequently the European Union (EU) exempts farmed salmon from a directive (91/493/EEC) which requires that all (wild) Atlantic and Pacific salmon to be processed with minimal cooking (i.e. cold smoking <60 °C) must be frozen prior to sale. This is to protect the consumer from anisakiasis and other parasites. The reason that farmed salmon are apparently free of nematodes is that they are fed with manufactured feeds. If fanned salmon were fed with fresh trash fish, WHO (1999) believes that the potential for aniskiasis from farmed salmon would exist. (ii) Diphylobothriasis Diphylobothriasis is caused by the broad fish tapeworm, Diphyllobothrium latum. While the majority of human infections of this parasite come from freshwater fish, Roderick and Cheng (1989) described cases caused by the consumption of uncooked wild salmon. They assumed that the salmon contracted the tapeworm in freshwater and carried the parasite throughout the marine phase before capture. Diphylobothriasis is common found among Eskimos of Alaska and Canada and inhabitants of Finland, all of whom consume large quantities of wild caught salmon. There have been no reports of this tapeworm associated with farmed salmon. 33 (iii) Rickettsialosis Rickettsialosis, or 'salmon poisoning,' is caused by a digenean troglotrematid and is primarily a problem for dogs, which have eaten uncooked wild salmon entrails. Rodrick and Cheng (1989) described reports of this parasite in humans but rarely with serious disease consequences. There have been no reports of this parasite associated with farmed salmon. (iv) Vibriosis and other bacterial diseases Vibriosis, aeromonasis, salmonellasis and plesiomonasis are caused by bacterial infections of Vibrio spp., Aeromonas spp. Salmonella spp. and Plesiomonas spp., respectively. All of these bacteria are a part of the normal aquatic flora, except for Salmonella spp. which are associated with human and animal wastes. The greatest potential for contamination of wild or farmed fish occurs post- harvest when the muscle, which is sterile in healthy living fish, is exposed to external contamination. The practice of delivering net -pen reared salmon alive to the processing plant, where strict BMPs and HACCP practices are followed, significantly reduces the risk to public health from bacteria and parasites. Wild caught salmon, which are landed headed and gutted, have a slightly higher risk of contamination en route to the processing plant. Ward (1989) noted that all these bacteria were killed by thorough cooking, and concluded that the greater risk for the consumer was uncooked or undercooked fish, or if the product was incorrectly handled and processed after harvest. 3.4 Quality and Safety of the Products The public perception of seafood has traditionally been one of high quality, with a range of products all beneficial to individual health. However, there are subtle differences between species, and many of the positive healthy qualities can be destroyed or contaminated by poor post- harvest handling and processing. The proximate composition of farmed salmon (percent protein, lipid, ash and water) is generally similar to wild salmon, except that the lipid and fatty acid composition can differ. In general, wild salmon have a higher concentration of n -3 fatty acids as a percent of total fat, while farmed salmon have a higher level of total fat. Sargent (1995) found there was a similar overall level of n -3 fatty acids as a percentage of the total fillet, which was important for human health. The fatty acid composition of farmed fish reflects the fatty acid of the lipid source in the feed. Many authors (Nettleton 1990, Haard 1992, Nettleton and Exler 1992) have experimented with an array of variables and all report that it is possible to control the fatty acid composition of farmed fish. Many food nutritionists have worked on the various sensory measures of farmed salmon, such as taste, texture, and color of the final product. Haard (1992) reported that farmed salmon, in general, were milder in flavor, softer in texture, and paler in color than their wild counterparts. Sylvia et al. (1995) and Wessell sand Holland (1998) noted that consumers were able to detect differences between wild and cultured salmon, with preferences related to regional experience with each product. The greatest determinant of product quality for salmon from either source was freshness. Consistency in quality and 34 quantity, consistent price, and year -round availability were all considered by consumers to be advantages of farmed salmon. 3.5 Worker Safety According to the Bureau of Labor Statistics Census of Fatal Occupational Injuries (CFOI) commercial fishing was the single most deadly occupation in the US between 1992 and 1996 (CFOI 1999). This is likely to still be the case. Drudi (1998) concluded that fishers face a risk of death 20 -30 times higher than all other occupations. Between 1992 and 1996 inclusive, 380 fishermen fatalities were recorded in the USA. During the same period the occupation classified as Animal aquaculture' (SIC 0273) had eight fatalities, and 'Fish hatcheries and preserves' (SIC 0921) had five fatalities (D. Drudi, personal communication, 2000). It was not possible to isolate salmon fishers and salmon farmers from within these numbers. Fish farm workers face chemical hazards from mishandling drugs and chemicals used in aquaculture. Guidelines for the use and safe handling of chemical compounds and vaccines in the aquaculture industry in the US have been published by JSA (JSA 1994), and many of these guidelines are being reflected by the COPs and BMPs being prepared by individual industries for the protection of their workers. 35 4. SALMON FARMING AND THE ENVIRONMENT The fourth chapter reviews current information on the effects of the many activities associated with salmon aquaculture on the environment. Where possible the review attempts to deal with these effects in quantitative terms, and the measures which are currently used to reduce them. The chapter has seven identified sub -sets. The first sub - section reviews the potential effects of the organic wastes emanating from net -pen salmon farming. The origins of such effects are uneaten or waste feed, feces from the fish, and bio- fouling organisms on the structures. The second sub - section reviews the inorganic wastes, specifically nitrogen and phosphorus, and heavy metals. The third sub- section deals with the pathogenic organisms, which might be in the vicinity of fish farms, and the risks to human health from wastes, which might contain such pathogens. The next sub - section deals with the therapeutic compounds which might be used to control parasites and diseases. The fifth sub - section reviews the biological and chemical changes in the sediments and in the water column both beneath the farm and downstream. Where possible, quantitative information is provided and then applied collectively in terms of an operating farm with reference points. The sixth sub - section reviews information on the chemical and biological recovery of sediments under salmon farms. The final sub - section reviews alternatives being used for management of all these environmental effects. These include monitoring experiences with a number of indicators and models, followed by a review of other government policies and methodologies. 4.1 The Effects of Organic Wastes from Net -pen Salmon Farms 4.1.1 Waste feed Early diets for farmed Atlantic salmon contained 45 -50% protein, 16-22% lipids, and 17% carbohydrates. Technology now permits the production of high - energy salmon diets containing about 30-35% lipids and 40% protein, and the minimum level of digestible carbohydrate (about 10 %) necessary to bind the pellets. These high - energy diets more closely resemble the composition of the natural prey of salmon. More recent salmon feeds were reported by Einen at al. (1995) and Rosenthal et al. (1995) to contain 7% nitrogen and 1% phosphorus. Mann (EWOS Canada Ltd., personal communication) estimates that current salmon diets contain 38 -39% crude protein, 6.5% nitrogen, and 1% phosphorus. Lipid content in current high- energy diets is 33 -35 %, of which half is fish oils and half plant oils, such as flax and linseed oils, high in omega -3 fatty acids. The amount of waste feed depends on feeding efficiency, which is principally influenced by feed composition, feeding methodology, water currents at the site, and net -pen configuration. Beveridge et al. (1991) stated that up to 30% of feed was lost. Rosenthal et al. (1995) noted higher losses (up to 35 %) for wet feeds, which might contain greater than 30% moisture, than dry feeds. Weston (1986) suggested that less than 5% of dry feed was lost at Puget Sound salmon farms. This is consistent with research by Gowen W and Bradbury (1987), who reported losses were least (1 -5 %) with dry feeds, which contained less than 10% moisture. Findlay and Watling (1994) reported maximum feed loss rates of 5 -11 %, with an average feed wastage of <5 %. Dry and semi -moist feeds are now used exclusively in the Pacific Northwest and current feed loss rates are estimated between 3 -5 %(J. Mann, EWOS Canada Ltd., personal communication). The amount of feed loss is also dependent on feeding methods and strategies. Cross (1990) reported that feed wastage at a commercial salmon farm in Sooke Inlet, British Columbia (BC) was 3.6% delivered by hand and 8.8% delivered by automatic feeders. This was probably due to the abrasion of feed pellets in some automatic feeders, which can result in the disintegration of 4-5% of the pellets. Other automated feeding systems, with short delivery distances and operated by compressed air valves, may disintegrate <0.5% of the pellets (J. Mann, EWOS Canada Ltd., personal communication). New technologies, such as feedback cones and underwater video or acoustical devices described by Mayer and McLean (1995), are now commonly used to monitor feeding behavior in efforts to minimize losses of uneaten feed from net -pens. Sutherland et al. (2000) conducted a study at a salmon farm in the Broughton Archipelago, Canada BC, to quantify suspended particulates during peak feeding times and to make point -in -time estimates of organic loading. Based on stable carbon isotope analysis, they concluded that very little feed was not consumed by the fish at the farm under study. In a series of video reports to the BC Ministry of Environment documenting the environmental conditions on the perimeter of several salmon farms in the Province, Brooks (2000a -0 recorded no observable wasted feed pellets. The results of this review are reasonably consistent and indicate that, as at this time, 5% or less of the dry feed delivered to cultured salmon in net -pens is lost to the environment. The low proportion has been due to the combination of improved feedback technologies and the practice of quickly feeding the fish to satiation once or twice each day (mean feeding). Improvements in feed delivery systems to minimize pellet disintegration will probably reduce losses further well below 5 %, a figure much less than the 20 -30% numbers used in many aquaculture models (see Section 4.7.2). 4.1.2 Fish feces Weston (1986) estimated that 25 -33% of feed consumed by the fish was ejected as feces. Modern diets are approximately 87 -88% digestible (J. Mann, EWOS Canada Ltd., personal communication). The remaining ash consists primarily of calcium and inorganic phosphate, and represents 8.0 -8.5% of the feed. This implies approximately 12.5% of the weight of ingested feed will be ejected in feces. Subtracting 87.7% for digested protein and 8.25% for ash, this leaves about 4% of the feed ingested to be ejected as labile organic material in the feces. If 5% of the feed is uneaten (Findlay and Watling 1994) and feces contribute organic matter equivalent to 4% of the feed weight, then approximately 8.8% of the labile organic carbon delivered in feed is discharged from the net -pen structure in particulate form, contributing to the BOD of the sediments. 37 Feed conversion ratios (FCRs) of farmed fish are frequently quoted in literature, but have not been adequately defined. They are typically measured as the ratio of the dry weight of feed provided to the wet weight of salmon produced. They are considered an essential metric by the aquaculture industry for assessing producer program efficiency. The FCR is affected by genetic and environmental factors. The quality and composition of the feed, to include palatability and nutrient balance, is also important together with fish health and feeding methodologies. In short, the FCR integrates all aspects of the culture operation into one simple metric. Two types of FCR are typically defined by industry: • The economic feed conversion ratio (EFCR) is defined as the amount of feed supplied to a farm divided by the round dressed weight of fish produced for market. This metric is easy to calculate and is useful in determining the economic efficiency of a farm. • The biological feed conversion ration (BFCR). This metric is biologically and environmentally more meaningful but more difficult to determine. It is equal to the feed actually consumed by the fish (feed provided less the uneaten portion) divided by the total fish biomass produced on the farm, including escapes and mortalities. Robinson (Stolt Sea Farm, personal communication) noted that the head -on processed weights must be corrected for the approximate 16% loss of fish weight during starvation, bleeding and removal of offal. Enell and Ackefors (1992) reported that marine FCRs in Norway declined from 2.25 in 1974 to an average of 1.2 -1.3 in 1992. The authors calculated that improvement resulted in a 23% decrease in nitrogen and a 50% decrease in phosphorous loading associated with farm operations. Rosenthal et al. (1995) estimated FCRs for Atlantic salmon to be 1.2, while Levings (1997) estimated an even lower FCR of 1.17 for operations in BC. FCRs have probably advanced to a point where significant additional improvement will be difficult. 4.1.3 Fish carcasses as wastes Winsby et al. (1996) reviewed and analyzed the mortality of fish at BC net -pen salmon farms in 1994. Their data suggested approximately 2,000 mt of salmon died at farms that year, or approximately 9% of the total production of 22,000 mt. They concluded that most of the salmon carcasses were removed to approved compost disposal locations. No inappropriate disposal of salmon carcasses has been documented in the literature. Losses of fish on net -pen salmon farms are restricted to individual fish, which may have been attacked and killed by a predator, and numbers of fish which died as a consequence of an algal bloom or disease epidemic. BMPs of net -pen salmon farms require physical removal of any carcasses on a daily basis, and therefore they do not contribute to any biological loading on the environment. 4.1.4 Bio- fouling organisms as wastes Biological fouling is a significant factor in coastal environments and large masses of mussels, barnacles, ascidians, and bryozoans can weigh down nets and restrict water flow W through a net -pen complex. Heavily fouled nets can also compromise the structural integrity of the complex. Weston (1986) concluded that bio- fouling organisms on net -pens, and the debris which was released by net cleaning, were not significant sources of organic input to sediments beneath salmon farms. Winsby et al. (1996) discussed the mechanics of removing fouling organisms from nets associated with salmon farms. There is no literature quantitatively describing the mass of bio- fouling which builds up on nets and floating structures of salmon farms, or other similar marine structures. Brooks (1994a) defined a neutral impact zone (NIZ) as that distance from the perimeter of a salmon farm at which there was neither an apparent increase nor decrease in the abundance and diversity of the benthic infninal community when compared with a local control site. In annual observations at a poorly flushed farm site, he noted that the NIZ was influenced by several factors, including, for example, deposits of debris following the pressure- washing of nets in situ. He observed a 30 -cm deep layer of mussel debris in sediments from the perimeter of the farm stretching a distance of 6 in downstream. The downstream location of the NIZ increased from 12 in in 1993 to approximately 22 in in 1994, after in situ cleaning. He concluded that it was not possible to establish a cause and effect relationship but the presence of the mussel shells undoubtedly had an effect on the benthos. 4.1.5 Measurement of organic wastes Brown et al. (1987) compared the areal extent of benthic impacts associated with organic wastes from fish farms in Sweden with that from sewage treatment plant and pulp mill effluents. They found reducing (anaerobic) sediments covering 0.6 km' around a poorly flushed (mean current velocity = 3.7 cm /sec) salmon farm located in shallow water (20 in below MLLW). Significant changes in the benthic community were observed within 15 in of the perimeter of the farm. In comparison, they cite Stanley et al. (1980) in noting that a pulp mill in Loch Eil, Scotland had created reducing conditions in sediments extending over an area of 5 km'. Pearson (1986) observed reducing sediments covering 23 kmz associated with a sewage disposal site at Garroch Head, Firth of Clyde, Scotland. The impact associated with this single sewage discharge covered an area 38 times as large as that impacted by the salmon farm. Ellis (1996) suggested that waste feed and feces from salmon farms in BC were equivalent to the human sewage from a city of 500,000 people, and Folke et al. (1994) compared the waste from 100 mt of salmon with a human settlement of 850 to 3,200 persons. Ackefors and Enell (1990) criticized the assumptions upon which such comparisons were made. Their argument was based on differences in the form of nitrogen released from sewage treatment plants and fish farms and differences in the ratio of carbon, nitrogen and phosphorus discharged from the two activities. Taylor et al. (1998) found that organic enrichment adjacent to the Macaulay and Clover Point outfalls in the city of Victoria BC, was similar to that expected at a productive salmon farm. Adverse effects on benthic infauna associated with organic enrichment by 39 sewage treatment plants were generally restricted to distances less than 100 in from the diffusers. They also found significantly elevated levels of 1,4- dichlorobenzene, polycyclic aromatic hydrocarbons and mercury within 100 -400 in of the same two outfalls. These concentrations exceed Washington State Sediment Quality Standards. Sediment toxicity associated with these outfalls was limited to adverse effects on growth and development in laboratory bioassays. The authors concluded that the magnitude and extent of the observed effects ( <400 in from the outfalls) indicated little cause for concern for human health. The effects at these outfalls extend four times further from the source than is allowed at salmon farms complying with the BC Draft Waste Management Policy. Salmon farm wastes do not contain toxic levels of metals and industrial hydrocarbons associated with sewage treatment plants, and there are no reasonable sources of these common contaminants on farms other than the minor exhaust from boats. Ackefors and Enell (1994) estimated the total organic output from salmon farms on the order of 2.5 mt wet weight per metric tonne of fish produced. Gowen et al. (1991) cited three studies assessing the flux of carbon through salmon net -pens. In all three cases the harvested fish retained 21 -23% of the carbon in feed and it was estimated that 75 -80 % of the carbon was lost to the environment mostly in a dissolved form as CO2. Merican and Phillips (1985) estimated that 35.6% of the carbon, 21.8% of the nitrogen, and 65.91/c of the phosphorus were lost to the environment in solid form. Other estimates of the total suspended solids output from intensive net -cage culture of fish by Kadowaki et al. (1980), Warrer- Hansen (1982), Enell and Lof (1983), and Merican and Phillips (1985) range from 5 -50 g suspended solids /m2 -day. All these publications are more than 15 years old and therefore these values do not reflect recent improvements in fish feed and feeding technologies. Gowen and Bradbury (1987) estimated organic waste sedimentation rates of 27.4 g /m2- day under Irish salmon farms, and an average of 8.2 g /m2 -day immediately adjacent to the perimeter of the net -pen. Gowen et al. (1988) measured average rates of 82.2 g dry weight/m2 -day on the perimeter of net -pen in Washington, and Cross (1990) estimated an average overall sedimentation rate of 42.7 g TVS /m2 -day with a maximum of 94.5 g total volatile solids (TVS) /m2 -day at seven salmon farms in BC. More recent work by Findlay and Watling (1994) in Maine measured sedimentation rates on the perimeter of salmon farms at between 1.0 -1.6 g carbon /m2 -day, and Hargrave (1994) summarized sedimentation rates from less than one to over 100 g carbon /m2 -day from salmon cage operations described by a number of authors. Brooks, using his published data from many original sources (Brooks 2000a —f), derived a theoretical estimate of contemporary TVS loading near fish farms. Given a feed with 11% moisture content and FCR of 1.2, the feed provided (1.2 kg x 89 % dry matter) or 1.07 kg dry feed/kg of fish produced. This: — [(1.07 kg dry wt. feed/kg salmon produced) x 8.8% labile organic waste /dry weight] — was in turn equal to 0.094 kg of labile volatile solids /wet weight kg of fish produced. Thus he estimated that a salmon farm producing 1,500 mt of salmon during a 16 to 20- month production cycle would discharge 141 mt of organic waste on a dry weight basis. 40 Furthermore, assuming a fish density of 10 kg/m3 in cages 15 in deep and a grow -out cycle of 18 months, the annual sediment load on average would be: (10 kg ftshlm3 x 15 m deep x 0.094 kg TVS /kg fish ) (548 days) which is equal to 25.7 g TVS /m2 -day. The load would, in reality, be lower at the beginning of the grow -out cycle and increase towards maximum biomass. Brooks (2000e) analyzed sediments collected in canisters deployed 5 in above the bottom at varying distances from two farms in BC and at reference stations. The mean loading of volatile solids on the perimeter of these farms was 39.2 g TVS /m2 -day. The mean deposition of volatile material at the control stations was 6.3 g TVS /m2 -day and the contribution by the farm was approximately 32.9 g TVS /m2 -day. These studies were completed near peak salmon biomass and the observed values would therefore be greater than the theoretical average of 25.7 g TVS /m2 -day calculated above. Nonetheless, these observed and theoretical values are reasonably close. In summary, sedimentation rates on the perimeter of salmon net -pens have remained fairly constant in the range 15.1 -100 g TVS /m2 -day despite the typical increase in farm size from 200 -300 mt in the 1980s and early 1990s to the 1,500 mt of recent years. A recent study by Brooks (2000e) found a TVS loading of 32.9 g /m2 -day on the perimeter of a salmon farm at peak production. This value is reasonably close to a theoretical average of 25.7 g TVS /m2 -day calculated for an entire 18 -month production cycle. 4.2 Dissolved Inorganic Wastes 4.2.1 Dissolved nitrogen and phosphorus Salmon excrete 75 -90% of their ammonia and ammonium waste across gill epithelia (Gormican 1989) or in concentrated urea (Persson 1988, and Gowen et al. 1991). Brett and Zala (1975) reported a constant urea excretion rate by sockeye salmon of 2.2 mg N/kg per hour. Nitrogen and phosphorus are also dissolved from waste feed and feces during and after descent to bottom sediments. All these dissolved forms of nitrogen are readily available for uptake by phytoplankton. Silvert (1994a) suggested that 66-85% of phosphorus in feed is lost in a dissolved form to the environment at salmon farms. Winsby et al. (1996) reported significant variation in observable increases in soluble nitrogen and phosphorus levels in the water column at salmon farms. Johnsen and Wandsvik (1991) and Johnsen et al. (1993) estimated that 20.5 -30.0 g of nitrogen and 6.7 g of phosphorus are released per kilogram of Atlantic salmon produced when fed modern high- energy diets containing 30% lipid. Levings (1997) used these estimates to conclude that 844 mt of nitrogen and 188.6 mt of phosphorus are released to marine environments in BC each year by salmon farms. These values do not include nitrogen and phosphorus associated with uneaten feed. Statistically significant increases in soluble nutrients at salmon farms have infrequently been observed in Puget Sound (Rensel 1989, and Brooks 1994a, 1994b, 1995a, and 1995b). Aquatic Lands Leases (ALLs) for salmon farms in Washington State have required monitoring of NO3, NO2, and total ammonia (NH3 + NH4) in water samples 41 taken within one hour of slack tide at stations located 30 in up- current, and 6 in and 30 in downstream at all permitted farms at a depth equal to one -half the depth of the containment nets. In general, the variability between replicate samples taken at the 6 in downstream station was as great, or greater, than any observed increase in nitrogen between upstream and downstream stations. No significant increases in nitrogen were observed at any of the 30 in downstream stations. The highest observed level of toxic unionized ammonia (NH3) was 0.0004 mg -L "'. This is lower (by a factor of 87.5) than the EPA chronic exposure (4 -day) concentration limit of 0.035 mg-L"' at pH = 8 and T = 15 °C when sensitive salmonid species are present. Rensel (1989) studied dissolved nitrogen production at two poorly flushed farms in Washington. He compared dissolved nitrogen and unionized ammonia concentrations within the salmon pens with upstream and downstream levels during early ebb tides. Upstream dissolved nitrogen levels of 0.0003 mg -L -1 were increased to 0.0023 mg -L-1 al the center of the net -pen complex, but decreased to background levels at downstream stations. He also observed maximum unionized ammonia levels equivalent to 6% of the EPA criteria in the center of these net -pen complexes during slack tide. Weston (1986) reported ambient levels of dissolved inorganic nitrogen (DIN) in Puget Sound at 0.3 to 1.9 mg -L-1, indicating high variability. The greatest increase in DIN reported by Brooks (1991, 1992, 1993a, 1994a, and 1995a) was 5.29 µmoles -L "i (0.09 mg-L-1), or 8% of the mean value reported by Weston (1986). The literature indicates that the concentration of dissolved inorganic nitrogen added to marine water at salmon farms is very low on the perimeter of net -pen farms, and essentially immeasurable at distances greater than 9 in from the farm perimeter. 4.2.2 Heavy metal accumulation in sediments (i) Zinc Zinc is an essential metal important for insulin structure and function and as a co- factor of carbonic anhydrase. Historically it has been added to salmon feeds in trace amounts equal to 30 to 100 mg -kg "' of feed (see Chow and Schell 1978, and Anderson 1998). Long et al. (1995) provide an effects range -low (ER -L) of 150 pg zinc /g dry sediment weight, an effects range- moderate (ER -M) of 410 µg /g and an overall apparent effects threshold (AET) of 260 pg /g. The Washington State sediment quality criterion for zinc is 270 µg Zn /g dry sediment (WAC 1991). Other available benchmarks include the (TEL + PEL) /2 or 197.5 µg Zh/g dry sediment. Information on the development of the threshold effects level (TEL) and the probable effects level (PEL) can be found in MacDonald (1994). The published sediment benchmarks (in Ng Zn /g dry sediment) are summarized below. It should be noted that only the WA State AET is a statutory criterion. Contaminant I NOAA AET I (TEL + PEL )/2 WA State AET Zinc 260.0 197.5 270.0 42 Brooks (2000b) summarized 193 analyses for zinc in sediments collected near 27 salmon farms in BC. Nineteen samples from eight farms exceeded the AFT of 260 µg Zn/g dry sediment. All of the high zinc samples also contained significantly elevated sediment sulfide and TVS concentrations. There was a statistically significant correlation between zinc and both TVS and total sediment sulfides (S -). In response to the observed high sediment zinc concentration as some farms, fish feed manufacturing companies in BC have reduced the amount of zinc in feed to the minimum necessary to maintain salmon health. They have also changed the form of zinc from zinc sulfate to a methionine analog, which is more bio- available. Di Toro et al. (1992) described the relationship between sediment acid volatile sulfides, metal concentrations, and toxicity to infauna. Acid volatile sulfides (AVS) is a reactive pool of solid -phase sulfide that is available to bind metals and render them biologically unavailable and non -toxic to biota. The AVS method is useful in predicting when sediments with elevated metal concentrations are potentially toxic. Metal toxicity is considered additive, and each must be added to obtain a sum of toxic units. This methodology has been validated for copper and zinc (EPA 1994). None of the zinc concentrations observed by Brooks (2000a) was toxic, as they were all associated with sediments containing high concentrations of sulfide. Furthermore, Brooks (2000a) reported that initially high sediment concentrations of zinc under one salmon farm declined to background during a post production fallow period. At the peak of production at the studied farm, sediment zinc concentrations were elevated to 200 µg /g on the perimeter. They declined exponentially and reached a background concentration of ca. 25 µg /g at a distance of between 30-75 m from the net -pen perimeter on the downstream transect. Sediment -zinc concentrations were well correlated with TVS throughout the study (r = 0.76). Sediment -zinc declined during chemical remediation and was at background concentrations after six months of fallow. He hypothesized that zinc was bound by sulfides in the sediments. Sediment sulfides decrease with decreasing biological oxygen demand during chemical remediation. When the sediments become aerobic, the sulfide is oxidized back to sulfate releasing the zinc, which is diluted in the overlying water column. This hypothesis is consistent with chemical theory and with evidence collected earlier by Brooks (2000b). Given that these hypotheses stand the test of further scrutiny, no biological effects should be anticipated from the observed concentrations of sediment zinc under salmon farms. (ii) Copper Levels of copper may be elevated in the environment around net -pen farms, which use preventative treatments for bio- fouling. Several anti - fouling paints and solutions are approved for use in the marine environment, and are therefore used on salmon farms. Anti - predator nets and fish containment nets are increasingly treated with a copper anti- fouling solution to inhibit the settlement of organisms and bio - fouling. The practice benefits the environment by reducing carbon inputs to the benthos. However, if cleaning is accomplished in situ the displaced organisms can exacerbate organic loading to the 43 benthos under the farm. BMPs should require that nets first be removed and then washed by hand or machine on a barge or at an upland facility. Copper is a micronutrient. At moderately low levels the cupric ion is toxic to marine organisms — particularly the larval stages of invertebrates. Until 1995 the EPA marine chronic water quality criterion for copper was 2.5 µg -L -1 (EPA, 1986). Based on new information that level is now being increased to 3.1 gg -L -' dissolved copper (EPA, 1995). Lewis and Metaxas (199 1) examined copper concentrations immediately adjacent to newly installed copper - treated nets at net -pen salmon farms in BC. They measured ambient copper concentrations of 0.38 µg -L-1 in July and 0.37 µg -L -1 in August. The concentration inside the Fen was 0.54 µg -L-' in July after a freshly treated net was installed, and 0.54 gg -L- one month later in August. The small addition of copper in the water from the treated net (0.16 to 0.17 µg -L-') was not biologically significant except to organisms which tried to settle on the net. Peterson et al. (1991) compared copper levels in muscle and liver tissue from chinook salmon grown in pens treated with ®Americoat 675, a copper based antifoulant, with those in a pen with untreated nets. No statistically significant differences in the copper levels in like -size fish from these two farms were observed, suggesting that the copper released from the treated nets was not significantly concentrated by chinook salmon. Brooks (2000d) conducted in vitro studies on the leaching of copper from ®Flexgard Xl, the most commonly used antifouling product on the west coast of North America. Initial losses of 155 µg Cu/cm 2 -day declined exponentially during the period of the study. Brooks (2000d) used the data to develop a spreadsheet model that predicts copper concentration in the water as a function of the maximum current speeds observed at a site, and the net -pen configuration and orientation of the complex to the currents. His model predicted that containment nets treated with ®Flexgard XI would not exceed the US EPA copper water quality criteria when fewer than 24 cages were installed in two rows oriented parallel to currents flowing with a maximum speed greater than 20 cm /sec. The model predicted that unless the configuration of net -pens or their orientation with the currents was changed, the use of ®Flexgard XI treated nets would result in exceeding the chronic water quality copper criterion at a small percentage of existing farms. The author noted that assumptions used in his model were conservative, and probably predicted higher copper concentrations than would actually be observed in the field. The model has not been yet been tested in the field but it clearly demonstrated the need to manage the use of antifouling products. Brooks (2000d) compared sediment copper concentrations at salmon farms in BC using ®Flexgard XI treated nets with those at farms using untreated nets and reference stations. Farmers in BC typically treat their nets at the beginning of each production period and treat them again only after the fish are harvested. The mean concentration of copper in the sediments of 117 Farm stations using treated nets was 48.24 ± 27.00 µg Cu /g. This level was not significantly different than the mean concentration of 12.01 ± 2.77 44 measured at the reference stations, or mean concentration of 26.3 observed at farms not using copper treated nets (ANOVA F = 0.73; p = 0.49). Brooks (2000d) found a great deal of variability in sediment copper concentrations at farms using copper treated nets. The concentration of copper in 2 of these 117 samples collected at 14 farms using copper treated nets exceeded the NOAA ER -M of 270 µg Cu/g dry sediment, and the State of Washington sediment quality criterion of 390 µg Cu/g. Thirteen of the samples (11 %) exceeded the mean of the TEL and PEL used as a regulatory benchmark in BC. All samples exceeding the lower benchmark were collected at 5 of the 14 farms using copper - treated nets. Discussion with the producers revealed that these farms washed their nets in barges during fallow periods. The fouling debris cleaned from the nets was not retained but washed over the side. Consequently, the concentrations observed at 5 of the 14 farms were not directly associated with the copper treatment itself but some ancillary activity, like net washing. Other anecdotal information revealed also that the copper — latex paint was abraded from the nets during washing and that significant quantities of the latex chips (with copper imbedded) were then washed over the side of the barge with the fouling organisms. The copper bound in the latex would then leach out over time. Brooks (2000d) concluded that all copper - treated nets should be removed after harvesting the fish, and washed and retreated at upland stations. Furthermore, all debris should be buried at an approved landfill site. 4.3 Pathogenic Organisms in the Vicinity of Net -pen Salmon Farms 4.3.1 Fecal coliform bacteria The National Shellfish Sanitation Program (NSSP) certifies commercial shellfish beds in the US and their harvest is governed by some very specific regulations (NSSP 1997); for example, harvesting shellfish is forbidden within one mile of any out -fall from a sewage treatment plant. This is because of public health concerns associated with toxicants (heavy metals, PCBs, polycyclic aromatic hydrocarbons, etc.) released in industrial and residential waste, and because many human pathogens (including viruses and bacteria) are associated with treated human sewage. Shellfish sanitation is not adversely affected by nutrients (carbon, nitrogen or phosphorus). Viruses are generally taxa - specific, and viruses pathogenic to fish, such as infectious pancreatic necrosis (IPN), viral hemorrhagic septicemia (VHS), and infectious hematopoietic necrosis (IHN) have no documented effect on human beings. However, fecal coliform (FC) bacteria persist in sediments high in total organic carbon (TOC) for varying periods. These bacteria are specific to warm - blooded animals (mammals and birds) and are not a normal part of the microflora found in fish intestines. However, mammals and birds are strongly attracted to fish farms increasing the potential for increased fecal coliform levels in the sediments near salmon farms. There is no potential for an increase in fecal coliform bacteria associated with cultured fish. NSSP defines water quality standards for shellfish growing areas and has a methodology for assessing and classifying shellfish harvest grounds. Approved growing areas must have a most probable number or geometric mean (FC MPN) of <14 FC /100 ml, with not 45 more than 10% of the samples exceeding an MPN of 43/100 ml in a 5 -tube decimal dilution test (APHA, 1992). Brooks (2000a) analyzed 33 water samples from the vicinity of an operating salmon farm during every quarter of the year. The MPN for all stations was less than the NSSP requirements for an Approved Shelfsh Harvest Classification (14 FC /100 ml), and all stations met NSSP requirements. He also examined shellfish tissues for FC bacteria. NSSP has established an allowable upper limit of 230 FC /100 g of tissue for product entering interstate (or international) commerce. Average clam tissue levels at the closest station located 200 in from the farm were 130 FC /100 g tissue. At 500 in the average level dropped to 50 FC /100 g, and at the reference station it was 20 FC /100 g. All of the shellfish samples tested met the NSSP requirement for shellfish tissues in commerce. In summary, he observed slightly more FC bacteria in water and shellfish tissues at stations closest to the farm perimeter. The sources of observed bacteria were not determined, but potential sources include farm workers themselves and, more probably, the birds and mammals which congregate around salmon farms. Water and shellfish tissues were consistently of high quality and met all bacteriological requirements imposed by NSSP. 4.3.2 Farm wastes Ellis (1996) postulated that waste feed and feces might enhance populations of a variety of ubiquitous marine bacteria pathogenic to humans. There is no direct evidence in the scientific literature that salmon farm wastes enhance pathogenic marine bacteria. In an extensive review of the epidemiological records for shellfish in the waters of Washington State spanning 20 years, Brooks (1993 unpubl. data, Aquatic Environmental Sciences, Port Townsend, WA 98368) did not find one documented case of Vibrio vulnifrcus- induced disease. This, he concluded, was because thermophilic bacteria, like V. vulnificus, required a high water temperatures in addition to a rich source of organic material to thrive. Elevated ambient water temperatures would likely be a requirement of most bacteria that are pathogenic to homoeothermal humans. Bacteria which flourish in warm- blooded animals are unlikely to proliferate in cold Pacific Northwest waters under salmon farms. Also, as salmon are poikilotherms, FC and other disease- causing bacteria which flourish in warm - blooded animals would not likely multiply in the gut of salmon, whose intestinal flora is determined primarily by ambient bacterial concentrations. He concluded there was no basis for assuming the feces of caged salmon would contain more than ambient concentrations of those bacteria pathogenic to humans. In another comparison of microbial levels in the tissues of farmed and wild salmon, Calderwood et al. (1988) examined the kidney, liver, spleen, heart, and muscle tissues for the presence of viruses and 16 bacterial species, including several later hypothesized as risks by Ellis (1996). They compared 68 adult wild steelhead trout at Robertson Creek and 50 wild adult echo from Chehalis, Washington with cultured chinook salmon from Sechelt and Sooke Basin in British Columbia. Their results were as follows: (a) V. vulnificus, a potentially serious human pathogen in immune - compromised individuals, was not detected in the cultured fish. However, 44% of wild fish returning to Chehalis were positive for this bacterium. Other vibrio species, including the potential we human pathogen, V. parahaemolyticus, were not found in the fanned salmon, but were found with a prevalence of 9 and 44% in the wild fish. (b) Acinetobacter calcoaceticus var. anitratus, which is a common bacterium found in water and soil, and has been associated with pneumonia, meningitis, and septicemia in humans, was observed with an average prevalence of 14% in cultured fish, and five times higher (76 %) in wild fish. (c) Aeromonas hydrophila was observed in over half of the wild fish from both Robertson Creek and Chehalis. Both A. hydrophila and A. salmonicida are common fish pathogens (Roberts 1978) but neither was isolated from tissues of cultured chinook salmon. This early work by Caldewood et al. (1988) suggests that wild fish are far more likely to be a source of disease- causing bacteria than farmed fish. Their data do not support any hypothesis that environmental conditions on fauns with healthy chinook salmon are enhancing populations of pathogenic bacteria. Furthermore, in their search for human diseases epidemiologists most frequently examine the population having the greatest exposure to the suspected etiologic agent. On salmon farms, the populations most exposed to the fish are the farm workers and processors. If farms are a significant source of human pathogens, then farm workers and fish processors should show some history of such diseases. There are no epidemiological records, which show evidence of any infectious outbreaks of disease. Collectively, an understanding of productive environments and fish and human physiology, and the lack of supporting epidemiological evidence, show that salmon farms in the Pacific Northwest are unlikely to increase any risk to human health from marine bacteria. Because of differences in its physical and chemical composition fish farm wastes do not disperse over large areas. They remain localized where they are metabolized by naturally occurring marine bacteria and opportunistic invertebrates. There is no evidence that salmon farms create conditions leading to a proliferation of pathogenic bacteria. Furthermore, from a perspective of human health there appears to be no basis for suggesting fish farm wastes are comparable with human sewage from either large cites or even small towns. 4.4 The Effects of Therapeutic Compounds The majority of therapeutic compounds used at salmon farms are for the control of sea lice. Sea lice, particularly Caligus elongatus, Lepeophtheirus salmonis, and Ergasilus labracis, have caused extensive losses of fish, particularly at farms in the northeastern Atlantic. They have not presented significant problems to producers in the Pacific Northwest, and salmon produced in Washington have not been treated for lice for the last 15 years (A. Mogster, Northwest Seafarms, personal communication). Both ivermectin and emamectin have been used infrequently to control sea lice in BC. Costello (1993) and Roth et al. (1993) describe the physical, chemical, and biological methods used to control sea lice on fish farms in other areas. Current practices rely 47 primarily on the administration of chemo- therapeutic compounds in food or as a bath. The following treatments have been authorized for use. (i) Ivermectin Ivermectin (22, 23- dihydroavermectin B1) has been used widely in agriculture for many years to control parasites, and was reported by Smith et al. (1993), and Johnson and Margolis (1993) to be effective in controlling sea lice on caged salmon. It is administered as a coating on feed at a rate of 0.025 mg ivermectin/kg of fish at 10 °C twice per week for 4 weeks. The dose is increased by 10% for every IT decrease in ambient temperature. In Scotland the maximum number of weekly treatments is three per year (SEPA 2000). Ivermectin is a broad - spectrum biocide which has low water solubility and a moderately high affinity for binding to particles. The compound is reported by SEPA (1998a) to concentrate in Mytilus edulis by a relatively low factor of 752. Grant and Briggs (1998a) stated that it did not appear to accumulate or concentrate in the food chain. Dissolved concentrations of ivermectin are lethal to a number of marine organisms, ranging from a 96 hr LC50 of 0.022 pg ivermectin /L for Mysidopsis bahia (Davies et al. 1997) to >10,000 µg/L for nematodes (Grant and Briggs 1998b). Most of the 96 hr LC5o values are less than 1000 ltg/L. Collier and Pinn (1998) and Grant and Briggs (1998b) have shown that crustaceans and polychaetes are more susceptible to ivermectin than mollusks. Annual studies in Scotland by ERT Ltd. did not detect ivermectin in the water column (detection limit = 0.5 µg/L) at a Scottish farm undergoing treatment (ERT 1997, and ERT 1998). Burridge and Haya (1993) found that ivermectin- coated waste feed affected non - target species, such as the shrimp (Crangon septemspinosa) at concentrations of 8.5 µg ivermectin /g food. Ivermectin toxicity was demonstrated in laboratory sediments at concentrations ranging from a 10 day LC50 of 23 µg ivermectin/kg dry sediment for Arenicola marina by Thain et al. (1997), and to 180 µg /kg for Asterias rubens by Davies et al. (1998). Black et al. (1997) documented significant mortality of polychaetes at ivermectin accumulations >81 µg ivermectin /m 2. This is equivalent to a concentration of approximately 25 pg/kg if the ivermectin is mixed into the top 2 -cm of sediments having a density of 1.6 g /cm3. Of particular interest was the adverse effect on the organic carbon tolerant opportunist C. capitata, whose abundance was significantly reduced at ivermectin concentrations above the calculated value of 25 µg/kg. The paper by Black et al. (1997) did not discuss the increased chemical and biological remediation times that might result from a significant reduction in the abundance of C. capitata. The fate of ivermectin not absorbed by Atlantic salmon appears to be sedimentation followed by slow degradation. Collier and Pinn (1998) noted that the breakdown of ivermectin in marine sediments was dependent on light and temperature. Davies et al. (1998) determined a half -life of ivermectin in marine sediments to be >100 days under the tested conditions. M ERT (1997 and 1998) detected ivermectin at concentrations ranging from 5 -11 µg/kg (wet sediment weight) in only 3 of 54 sediment samples at a farm undergoing treatment. Ivermictin was also detected in sediment traps deployed on the perimeter of farms undergoing treatment at 42 g/kg. Ivermectin was detected in 2 of 108 mussel samples at concentrations of 5 and <5 pg/kg collected from caged mussels deployed around farms undergoing treatment. The active ingredient was not detected in wild shrimp (Nephrops norvegicus) collected in the vicinity of the treated farm. According to a report by the Canadian Department of Fisheries and Ocean (DFO), ivermectin (with a detection limit of 1 to 2 µg/kg) was not found in American lobsters (Homarus arnericanus) around salmon farms (DFO 1996); however, the same document noted detection of ivermectin in sediments at distances up to 50 in from a farm in the Bay of Fundy where the compound was used. Concentrations varied between 13.7 and 17.3 µg/kg dry sediment at distances <10 in from the farm perimeter. Traces (between 2 and 6 µg /g) of ivermectin were detected at distances up to 100 in from the farm. These results suggest that ivermectin is most likely to be detected in sediments and not in the water column. DFO has set a predicted no -effect sediment concentration (PNEC) of 1.8 gg ivermectin/kg dry sediment. Empirical evidence has demonstrated sediment concentrations exceeding this value to 50 in from the perimeter of one farm, but not beyond. In general, significant sediment concentrations of ivermectin have not been observed at distances beyond 10 -20 m. The half -life of sedimented ivermectin is approximately three months (DFO 1996). Permission to use ivermectin on farms in Scotland has been withdrawn by the Scottish Environmental Protection Agency (SEPA). (ii) Emamectin benzoate SEPA reviewed the proposed use in Scotland of the pharmaceutical emamectin benzoate under the proprietary name ®Slice (SEPA 1999a). Emamectin has low water solubility and is expected to accumulate in sediments. However, based on laboratory bioassays SEPA stated that emamectin was about ten times less toxic than ivermectin, at least for the genus Crangon. However, SEPA noted that the PNEC level of 0.763 µg emamectin/kg wet sediment was lower than the PNEC of 1.8 µg ivermectin/kg proposed by DFO (DFO 1996). Field studies failed to detect emamectin in water, and maximum observed sediment concentrations were just above the level of quantification (1.0 gg/kg wet weight). The sediment half -life of emamectin was 175 days. No adverse effects on infaunal communities were observed following treatment with emamectin benzoate. SEPA used the deposition model (DEPOMOD) to suggest that the ratio of the predicted environmental concentration (PEC) to the PNEC was low, and there was little risk that treatment would pose a threat to sediment - dwelling organisms, even in the worst -case scenario tested. Currently ®Slice is in use in Chile, Ireland, and Norway, and has been approved in Scotland by SEPA in January 2000 (SEPA 2000) but to -date no permits have been issued. (iii) Calicide Calicide (teflubenzuron) has been licensed by SEPA for the control of sea lice in Scotland (SEPA 2000), and is being licensed in Canada, Chile, Ireland, and Norway. This therapeutic compound is administered as a 2 -g/kg coating on feed. It is a chitinase 49 inhibitor effective against juvenile sea lice on salmon at a dose of 10 mg/kg -day' for seven consecutive days. It has reduced effectiveness after lice become adults and stop molting. SEPA (1999b) noted that calicide had a long half -life of 115 days in sediments, and could be detected at distances up to 1,000 in downstream from farms being treated. However, no adverse effects were detected in benthic communities (including crustaceans) and SEPA concluded that any residual teflubenzuron was not bio- available. Calicide inhibits the production of chitinase and therefore is not toxic to phyla other than the Crustacea. For teflubenzuron, SEPA (1999b) permitted an allowable sea -water quality standard of 6.0 ng/L for the annual average, and a maximum allowable concentration of 30 ng/L. In Scotland there is an 'allowable effects area' of 100 in from salmon farms. A sediment quality standard of 2.0 pg calicide/kg dry sediment in a 5 -cm deep core has been established outside this area. Sediment concentrations at all distances within 25 in of a treated farm must be maintained at less than 10 mg calicide/kg dry sediment (5 cm core). Calicide is approved only for interrupting the life cycle of sea lice. It is not approved for treating adult lice infestations. Its use is based on computer- modeling of specific sites and it is not approved for general use. Predicted sediment and water column concentrations of the active ingredient must be lower than the water and sediment quality standards described above. (iv) Cypermethrin ®Cypermethrin (dichlorvos) is a pesticide being used in investigative programs, and under some form of temporary registration in Canada, Ireland, Norway, UK, and US. It is administered in a 5 µg/L bath for 60 minutes within a confined and covered area. Dichlorvos is toxic to crustaceans, with a LCso of 0.006 µg /L and a no- observed - effect concentration (NOEL) of 0.003 µg /L for Wysidopsis bahia. It is adsorbed by sediments where it degrades with a half -life of 35 days in high TVS sediments and 80 days in low TVS environments. It has a 10 -day NOEC of 1000 pg/kg in Arenicola, and 64 µg/kg in amphipods of the genus Corophium. Concentrations greater than about 10 ng/L, are acutely toxic to some crustaceans, and modeling suggests that this value can be exceeded in the immediate vicinity of pens being treated with this product. SEPA (1998b) concluded that toxic effects to non- target species could occur within a few hundred meters of a treated farm and that these effects might last for several hours. High mortality of shrimp and lobsters has been observed when they are exposed to a bath of dichlorvos, but the effect has not been observed outside net -pens. Field trials have observed peak water concentrations of 187 ng/L 25 m downstream from salmon net -pens following removal of the tarpaulin covers. Based on an absence of demonstrated deleterious effects on non - target animals, SEPA (1998b) recommended authorization of®Excis (containing dichlorvos) for a 2 -year period initially. Individual permits are issued by SEPA. Modeling must predict that the 50 proposed treatment will not result in exceeding a 3 -hr environmental quality standard of 16 ng/L in the dispersing plume following removal of the covers. Post- treatment monitoring is required. (v) Azamethiphos Azamethiphos (or ®Salmosan) is a pesticide administered in a bath at 0.1 mg/L. The active ingredient degrades with a half -life of approximately 11 days at neutral pH. Larval lobsters were the most sensitive organism tested with a 96 hr -LC50 of 0.52 µg/L and a no- observed- effect level (NOEL) of 0.156 µg /L. A toxicity threshold to lobster larvae was estimated by SEPA (1997) at 0.078 µg /L. Azamethiphos is very water- soluble and is not expected to accumulate in sediments. Compared with dichlorvos, azamethiphos is considered more toxic to crustaceans. SEPA (1997) restricted its use in aquatic environments where modeling predicted that: • 3 h after treatment the mean residual concentrations in the dispersion zone will not exceed 160 ng/L. • 24 h after treatment the mean residual concentrations in the receiving water will nowhere exceed 80 ng /L. • 3 days after treatment the residual concentrations in the receiving water will nowhere exceed 5 ng /L. Post - application monitoring was required by SEPA to ensure compliance. The control of sea lice is important to the health of farmed salmon and to reduce the potential for salmon farms to act as vectors for the infestation of wild stocks of salmon and sea trout. A review of the available treatments suggests that great care must be exercised in the use of these therapeutic compounds. They are all non - specific, at least within the Class Crustacea, and several are broad - spectrum biocides with potential to affect many phyla adversely. However, field studies have not found significant widespread adverse effects to either pelagic or benthic resources associated with the authorized use of these pharmaceuticals or pesticides. 4.5 Farm Sediments 4.5.1 Monitoring environmental effects on sediments Infaunal community analysis, as demonstrated by Pearson and Rosenberg (1978), Mahnken (1993), and Brooks (2000a), is ultimately the most direct and sensitive methodology for assessing the biological response to organic loading from salmon farming. However, benthic communities are not stable, as shown by Mills (1969) and Eagle (1975), and their structure is influenced by many natural processes unrelated to human influence. These processes include seasonal factors (Crisp 1964, Arntz and Rumohr 1982, and Brooks 2000a) and physicochemical factors (Striplin Environmental Associates 1996). Skalski and McKenzie (1982) pointed out that this variability typically requires large numbers of samples to achieve reasonable test powers. The international Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) noted that the taxonomy required in support of infaunal analysis was expensive and time consuming (GESAMP 1996). This cost, when 51 coupled with high internal variability, detracted from infaunal analysis as a routine method for evaluating environmental effects as part of regulatory programs. Therefore physicochemical endpoints, including TVS, TOC, redox potential (Eh) and total sediment sulfides (S -) were being used increasingly as rapid and inexpensive surrogates for assessing biological response. GESAMP (1996) concluded that the visually determined depth of the reduction- oxidation discontinuity was of low value because it was semi - quantitative. They did not consider emerging physicochemical endpoints, such as sulfide analysis using ion specific probes (Wildish, et al. 1999), or TVS (Hargrave et al. 1995, Brooks 2000e and 20000. Brooks (2000c and 2000e) discussed the relative merits of TVS, TOC, S -, and Eh for evaluating the environmental response to salmon farms. He noted that organic carbon, whether measured as TOC or TVS, had only a moderate correlation with biological effects, particularly infauna. He hypothesized that sediment carbon comes in many forms including woody debris, which is refractory to microbial catabolism resulting in low BOD. Drift macroalgae and eelgrass form an intermediate class of sediment carbon broken down within a few months to one year. Fish feces on the other hand was very labile and created high BOD, more frequently leading to anaerobic conditions than woody debris or macroalgae. Therefore 15% TVS may not exceed the assimilative capacity of the sediment if it was in the form of woody debris, whereas 15% TVS associated with salmon farm waste in the same sediment would be more likely to create anaerobic conditions with significant biological effects. It was recognized that when finely divided woody debris exceeded the assimilative capacity the effect could last for centuries as the wood deteriorated very slowly. Salmon farm waste, on the other hand, because it was catabolized very quickly had rather ephemeral effects lasting from months to two or three years in extreme cases. Redox potential (Eh) was identified by GESAMP (1996) and Wildish et al. (1999) as a valuable endpoint for evaluating sediment chemistry near salmon farms because it is rapid, low cost, and permits extensive spatial surveys. Brooks (20000 found low sediment redox (20.68 + 22.29 mV) and low sulfide concentrations (29.83 + 11.59 µmoles) in the same samples from reference stations located in areas with greater than 80-90% silts and clays comprising the sediment grain size distribution. He noted low Eh and high sulfide concentrations in sediments were not always well correlated, and that low Eh could be the result of physical processes, especially in fine- grained sediments. This limited its usefulness in evaluating the effects of carbon input from salmon farms. Wang and Chapman (1999) described the response of laboratory bioassay test animals to sediment sulfides. However, despite attempts by Brown et al. (1987), Henderson and Ross (1995), and Hargrave et al. (1997), the literature does not provide a good quantitative description of the response of natural infaunal communities to sediment sulfide concentrations or redox potential. In summary, benthic infaunal and epifaunal analysis appears to be the most sensitive indicator of environmental health in sediments around salmon farms. However, benthic communities are not stable across environments and depend on the physical environment, 52 including water depths, current speeds, sediment grain size distribution, and the availability of organic carbon (Striplin Environmental Associates 1996). In addition benthic communities vary by season, as influenced by food input and water temperature, etc. (Arntz and Rumohr 1982). 4.5.2 Biological changes in the water column and sediments The environmental changes associated with salmon farms are superimposed on natural changes. These potential effects have been examined in numerous studies during the last two decades. Despite significant site - specific variability there is a consistent thread binding this literature. (i) Water column changes Possible changes in the water column associated with the intensive culture of fish could be associated with intoxication due to hydrogen sulfide and ammonia production in underlying sediments, decreases in dissolved oxygen associated with salmon respiration and /or the oxidation of sedimented waste, and eutrophication associated with nitrogen released across gill epithelia and in urine and feces. The magnitude and consequences of environmental changes associated with these factors is dependent on environmental parameters such as water depth, current speeds, background nutrient availability, salinity, rainfall, wind, etc., which in aggregate constitute the local environment. (ii) Nitrogen and phosphorous loading to the water column Marine environments along the west coast of North America are especially productive because cold, upwelling, nutrient rich water replaces surface waters driven offshore by prevailing northwesterly winds. In addition, the relatively high geographic latitude of BC and Washington results in reduced light penetration in water compared with more southerly latitudes. Lastly, moisture laden onshore winds create significant cloud cover throughout much of the year. These factors combine to limit light availability significantly in most temperate marine environments, except during summer months. Furthermore, it should be noted that in most marine environments, nitrogen is the limiting nutrient and not phosphorus. The remainder of this review wilt focus on nitrogen inputs. In the Pacific Northwest, wind - driven vertical- mixing drives a significant proportion of the phytoplankton crop below the compensation depth where cell respiration equals photosynthesis and where they no longer multiply. Where water freely circulates, flood tides replenish nutrients from water upwelling offshore. When coupled with the atmospheric and geographical factors that reduce light availability, the result is that primary productivity in the Pacific Northwest is generally light limited, not nutrient limited. This is especially true during winter months. In other words, there is insufficient light to use the nutrients already available in the water column. Adding more nutrients in a light limited system does not increase plant growth. There are sheltered, poorly flushed, shallow embayments where salinity and temperature induced stratification results in a stable water column that allows phytoplankton to remain above the compensation depth. When these conditions occur in the spring or summer, significant blooms can occur following several days or weeks of clear sunny 53 weather. These blooms eventually wane because winds increase vertical mixing; cloud cover reduces the available light; or nutrients are depleted in the surface water, In this last situation, nutrient input from a salmon farm could further stimulate plant growth, exacerbating the problem. In addition, shallow bays having significant freshwater input and minimal flushing, are not considered good sites for net -pen grow -out operations. However, they might be deemed appropriate as smolt introduction sites. The last point to consider in this general discussion is that nitrogenous compounds are released from fish farms into currents that generally average greater than 4 to 12 cm-sec-1 and acoustic Doppler current meter studies at British Columbia salmon farms have revealed net transport speeds of 1.0 to 5.0 cm -sec'. At temperatures of 10 -15 °C, it takes one to two days for an algal cell to divide, even if all of its photosynthetic needs are met (Brooks 2000g). An algal bloom may result in cell densities increasing from a few thousand cells per ml to perhaps a million. That requires eight or nine cell generations, which requires a minimum of 8 -16 days. In open bodies of water, moving with a net speed of even 2 cm-sec'], a phytoplankton population would move 14 km from the location at which nutrients were added during creation of a bloom. Recall that the barely significant increases in nitrogen observed 6 in downstream from farms in Puget Sound were generally not detectable at 30 in downstream. Therefore it appears reasonable to conclude that, within a single algal cell division (one to two days), the water passing through the farm would have traveled at least 1.7 km. It is difficult to conclude that the nutrient additions from the farm, generally undetectable at 30 in downstream would have any effect at all on primary production even if the water body was nutrient limited. Pease (1977), Rensel (1988 and 1989), and Parametrix Inc., ( Parametrix 1990) documented small increases in dissolved nitrogen within and on the perimeter of salmon farms. However, all of these authors agreed that the quantity of dissolved nitrogen added by even several farms would have no measurable effect on phytoplankton production. Gowen et al. (1988) studied a Scottish loch with very restricted water exchange to the open sea and a large salmon farm. The authors concluded that the farm had no measurable effect on phytoplankton density. Weston (1986) conducted a quantitative assessment of the effects of five hypothetical farms located in a small embayment with poor flushing. His analysis suggested that the nitrogen added by five farms could not be expected to adversely affect the phytoplankton abundance in the embayment. He did address the issue of nutrient sensitive embayments and recommended that these areas should be identified and carefully managed. Banse et al. (1990), Parsons et al. (1990), Pridmore and Rutherford (1992), Taylor (1993), and Taylor and Horner (1994) all examined phytoplankton production and blooms of noxious phytoplankton in the Pacific Northwest. They concluded that nitrogen levels and phytoplankton production at salmon farms were determined by ambient conditions. Furthermore, they found that salmon farms had little or no effect on ambient levels of either nutrients or phytoplankton density. 54 The literature is consistent with the previous general discussion and strongly supports a thesis that, with the exception of a few shallow, very poorly flushed embayments, the potential for net -pen enhancement of phytoplankton populations is remote, or non- existent. Based on similar arguments and ten years of monitoring dissolved nutrients at salmon farms, Washington State eliminated any requirement for water column monitoring in compliance with NPDES permits issued to all salmon farms in 1996. 4.5.3 Hydrogen sulfide gas production in sediments When the assimilative capacity of the benthos is exceeded, oxygen is depleted and sulfur - reducing bacteria continue to degrade organic carbon. During the process either ammonia or hydrogen sulfide gas may be produced. These gases, particularly the latter, are highly toxic and can significantly compromise infauna. They are not unique to fish farms and other sources of anthropogenic carbon, and are frequently found in natural environments where organic debris (leaves, macroalgae, eel- grass, etc.) accumulates. Hydrogen sulfide is the cause of the 'rotten egg' smell emitted from many pristine estuarine sediments at levels >2 µg/l, (EPA 1986). Hargrave et al. (1997) examined a suite of physicochemical parameters under 11 salmon farms and 1 I reference stations located >50 in from net -pens in the Western Isles region of the Bay of Fundy on the east coast of Canada. Sediment concentrations of hydrogen sulfide were found to be significantly different (P = 0.00001) under net -pens when compared with reference sediments. Total sulfide concentrations in surface sediments at all cage sites were >180 µM while values at all but one reference location were <200 µM. They noted sulfide concentrations >2000 µM were indicative of high organic loading under some net -pens and were generally associated with negative Eh potentials. Ammonia and hydrogen sulfide are lighter than water and when significant quantities of these gases accumulate in sediments, they can escape and rise to the surface (out - gassing). As the bubbles rise the soluble H2S is dissolved in the water column. Samuelsen et al. (1988) analyzed gas released from sediments underlying poorly flushed salmon farms. They found that 98% of the gas was CH4 and CO2. Less than 1.9% of the gas at the sediment -water interface was sulfide (S -). Furthermore they found that, after rising 3 in in the water column, the S was reduced to 0.05% of the total gas. The resulting concentration would be 1.54 x 10-6 g S- /(58.9 ml x 1.025 g /ml) or 25.5 µg S_ seawater (25 ppb). Water quality standards are based on the undissociated sulfide (H2S) which is ca. 10% of S at pH = 8.4. Applying this factor predicts an undissociated H2S level of 2.55 in the 0.5 cm diameter column through which the gas bubble passes. This is approximately equal to the 2 µg/L chronic water quality criteria established by the EPA (1986) for freshwater and marine environments. In reality oxidation, diffusion, and mechanical mixing significantly reduce concentrations further by a factor of 100 or more. Samuelsen et al. (1988) found that the fraction of the less soluble C144 did not appreciably change during transit of the bubbles through the water column. The low concentration of H2S in the bubbles at the sediment -water interface, and the low water concentrations predicted during ascent, suggests that very large gas emissions would be required before sufficient H2S could be dissolved in the water column to create toxic conditions. 55 4.5.4 Dissolved oxygen Weston (1986) reviewed the effects of salmon culture on ambient dissolved oxygen levels and concluded that farms could decrease these levels by 0.3 ppm. Brooks (1991, 1992, 1993a, 1994a, 1994b, 1995a, and 1995b) observed decreases of as much as 2 ppm in water passing through a large, poorly flushed farm in Puget Sound. Significant reductions in dissolved oxygen (DO) were not observed by Brooks (1994a and 1994b) at farms in well - flushed passages. In no case were DO levels within 6 m of the downstream farm perimeter depressed below 6 ppm, a minimum level for optimum culture of salmonids. Winsby et al. (1996) reported a range of results from the literature. However, his discussion in general suggested that depressed oxygen levels are associated with the water column immediately overlying anaerobic sediments. Cross (1993) concluded that salmon farms in BC have minimal effects on ambient DO levels. Depressed oxygen levels (3 to 6 ppm) are infrequently encountered at salmon farms along the Pacific coast. These depressions result from the upwelling of cold, nutrient rich but oxygen deficient water to the surface. Conditions favoring depressed DO are most frequently encountered in the Pacific Northwest during the summer and fall when northwest trade winds increase oceanic upwelling. Deep fjords, like Hood Canal in Washington State, can also experience depressed concentrations of DO when winds bring anoxic water to the surface from deep stagnant pools. Feeding is suspended and compressors used to increase DO when these naturally occurring masses of water with low DO levels flow into salmon farms. This phenomenon is imposed on the farm, not caused by the farm. However, the frequency of occurrence of these oxygen deficient water masses should be assessed in siting a farm. In addition, it could be considered good management on the part of operators to measure DO in bottom water under their farms in an attempt to predict periods of depressed surface oxygen. In summary, based on the literature it appears that net -pens create only minor depressions in surface water DO concentrations. When sediments under a farm become anaerobic the overlying water to a depth of perhaps a meter may experience some reduction in DO. This is most likely to occur under farms with very poor circulation ( <3 to 5 cm-sec-1 maximum current speeds). 4.5.5 Changes in the local fish community Salmon farms are known to function as fish aggregating devices. The structures attract numerous fish species, which frequently take up residence between the containment and predator nets. There are no published reports as yet which document this community of aquatic animals, and its abundance. Brooks (1994b and 1995b), at a well- flushed net -pen site in Washington identified pile perch (Rhacochilus vacca), shiner perch (Cymatogaster aggregata), herring (Clupea pallasi), lingcod (Ophiodon elongatus), bay pipefish (Syngnathus leptorhynchus) and several species of sole (Pleuronichthys spp.) all in abundance. At another site nearby, located over a sandy bottom, sea cucumbers (Parastichopus californicus) and geoducks (Panopea abrupta) had proliferated. All of these populations are closely associated with the farm (within 30 m). It should be added that one of these facilities is located in shallow water (15 -18 in MLLW) and fast currents 56 (115 cm-sec-1). The second facility is located in a moderately well flushed environment with maximum currents of 30 cm-sec' and water depths of 22 -30 in MLLW. 4.5.6 Physicochemical changes in the sediment near salmon farms The chemical and biological effects associated with fish farms have been documented and reviewed by Pease (1977), Braaten et al. (1983), Earll et al. (1984), Ervik et al. (1985), Ackefors (1986), Weston (1986), Aure et al. (1988), Rosenthal et al. (1988 and 1995), Weston and Gowen (1988), Hansen et al. (1990), Parametrix (1990), Gowen et al. (1991), Johannessen et al. 1994, Winsby (1996), Mazzola et al. (1999) and Morrisey et al. (2000). It is possible to model rates of organic loading from net -pen operations described by Weston and Gowen (1988), Findlay (1992), Einen et al. (1995), Silvert and Sowles (1996), and Ervik et al. (1997). The fate and transport of those wastes is a far more complex problem. However, the effects of farm wastes on the benthos in a variety of environments have been well documented. Brooks (1992, 1993a, 1994a, 1994b, 1995a, and 1995b) studied sediment chemistry (redox, TOC, nitrogen, and sediment grain size) and benthic infaunal response at two farms which represented two very different environments in Puget Sound, Washington. In terms of negative environmental effects associated with intensive net -pen fish culture, organic loading to the sediments is most significant. Goyette and Brooks (1999) observed statistically significant changes in the composition of the benthic infaunal community in Sooke Basin, BC associated with small natural changes in sediment organic carbon content of <1% change across the 500 -m study area. In general, the literature suggests a lack of appreciation of the sensitivity of the benthos to small additions of organic carbon, particularly labile forms like fish feces. Hargrave et al. (1995) documented sediment total sulfide concentrations under salmon farms in the Bay of Fundy that were <6,600 µmoles S -. In contrast, Brooks (2000c and 20000 observed significantly higher sediment sulfide concentrations ( <16,000 µmoles) on the perimeter of salmon farms in Canada BC, and Wildish (1999) reported sediment concentrations up to 36,000 µmoles S- in Bay of Fundy sediments under operating farms. 4.5.7 Biological effects The biological response of infauna to the sediment physicochemical changes occurring as a result of organic loading from salmon farms has been assessed by Hargrave (1994), Henderson and Ross (1995), and Hargrave et al. (1997). The toxicity of sulfide to infauna is documented for a few species (Bagarinao 1993; Wang and Chapman 1999), but despite the efforts of Henderson and Ross (1995), quantitative relationships between infauna and physicochemical endpoints (S -, Eh, TVS) remain elusive. Brooks (2000a) observed a significant enhancement in infauna during the early stages of production and at the end of the fallow period. However, at the peak biomass there was a significant reduction in the number of invertebrates observed at downstream stations located between 20 m and about 70 m from the farm perimeter. Near -field invertebrate numbers were supplemented by allochthonous input from the fouling community on farm nets. In addition, a significant portion of the invertebrate community associated with near -field sediments during periods of high organic farm input were the TOC tolerant species C. capitata and Ophryotrocha cf. vivipara. 57 Species richness, the number of species observed in biological samples, is frequently a more sensitive indicator of environmental stress than abundance. Brooks (2000a) observed significant reductions (<2.0 standard deviations below the mean) in the number of taxa within 45 in of the farm during peak production. It did not appear that significant effects extended beyond 75 in during this production period. Biological remediation began as soon as harvest was initiated in April of 1997 and was essentially complete within four months of fallow. A slight enhancement in taxa richness was evident five months following the completion of harvest. Polychaete abundance was enhanced as sediment organic carbon built up at the beginning of the production cycle. Abundance declined within 80 in of the farm perimeter during peak biomass when farm waste exceeded the assimilative capacity of the sediments, which became anaerobic. Polychaete abundance began increasing again during the winter of 1996 -1997, approximately six months after harvest began. Polychaetes proliferated with the improving benthic conditions and exceeded reference abundance during the last 6 months of the study. The enhanced area extended from the farm perimeter to a distance of at least 75 in during the October 1997 evaluation. Brooks (2000a) found that crustaceans were adversely affected at near -field stations earlier (and therefore possibly in association with smaller increases in sediment organic carbon) than polychaetes. A steady increase in the number of crustacean taxa was observed as soon as the fish biomass began decreasing during harvest. The salmon farm had little effect on the overall abundance of crustaceans. In part that was because the benthos in the immediate vicinity of the farm was supplemented by allochthonous input from the net -pens, such as the amphipods Metacaprella kennerlyi and Jassa falcata. Arthropods were supplemented by mobile crustaceans, such as the megalope of Cancer magister which were very abundant in the vicinity of the farm during June 1996. Brooks (2000a) found that mollusks were an abundant and diverse part of the infaunal invertebrate community in reference sediments from the study area. Statistically significant decreases in the numbers of mollusks were not observed in this study. However, the number of molluskan taxa was significantly reduced at all farm stations during the production cycle. An increase in the number of molluskan taxa was evident at the end of the study, but the number of taxa observed within 50-75 in from the net -pen perimeter had not recovered to reference conditions. Brooks (2001) has determined the biological response to varying concentrations of sediment TVS, sulfides, and Eh as a function of farm production, overlying currents, and sediment grain size distribution. Preliminary results indicated that reference sulfide concentrations were generally low (10 -100 µmoles) but could be as high as 250 -300 µmoles. Reductions in the number of taxa from >20 species to 12 -14 species, with significantly increased abundance and biomass of infauna, were noted with sulfide concentrations in the range of 300 -2,000 µmoles. Sediments containing >2000 micromoles S- had a reduced infaunal community dominated by C. capitata, and those containing greater than 6,000 µmoles were generally sparse. His findings were consistent 58 with the reports of Wildish (1999), Poole et al. (1978), and Pearson and Rosenberg (1978), which are tabulated below. Endpoint Classification Reference Microbial Normal Oxic Hypoxic Anoxic Poole et al. 1978 Macrofaunal Normal Transitory Polluted Grossly polluted Pearson and Rosenberg 1978 Sulfides <300 300 -1300 1300 6000 >6000 Wildish et al. 1999 4.5.8. Case histories describing benthic responses to salmon farming. Brooks (1991a, 1992, 1993a, 1994a, and 1995a) evaluated a salmon farm located in a poorly circulated bay with maximum current speeds of less than 8 to 10 cm -sec. This farm is situated in deep water (30 -33 in MLLW) over fine- grained substrates containing 820 -50% silt and clay mixed with sand. The farm has produced as much as 863 mt of Atlantic salmon in one year. TOC remained constant near the baseline mean of 1.067% at all stations until 1990 when production increased. By 1990, TOC at the periphery of the farm increased to 2.48% and remained within a range of 1.85 to 2.95 from 1990 until 1995 while significant quantities of salmon were being produced. This level of TOC in sediments containing less than 50% fines (silt and clay) resulted in a significant change in the benthic community. Reductions in the infaunal community were generally restricted to distances less than 22 m, and in 1992 and 1993 a normal benthic community was observed at distances as close as 6 in from the farm perimeter. The biomass of salmon on site during the period immediately preceding the survey was significantly greater in 1995 (453,229 kg) than in previous years (134,577 kg in 1994). The effects of this were seen in the increased TOC at all far -field stations. Sediment organic carbon was very sensitive to farm operations and highly correlated with management practices. The number of infaunal species was determined at the same stations used to measure TOC. The results indicated a reasonably homogeneous benthic community over the 60 in sampling transect during the baseline survey. infaunal diversity decreased at stations less than 6 m from the perimeter of the farm very shortly after operations began in 1989. Species diversity was variable at stations >15 in from the perimeter of the farm following start -up. In general infaunal diversity exceeded baseline values at stations >30 m in all years except 1989, which was probably due to a 1,250 m3 oil spill in the harbor several months prior to the survey. In years following that accident, infaunal diversity at all stations greater than 15 in from the farm perimeter were elevated above the 1987 baseline value. However, the 15 in station suffered a significant decline in species during 1995 when production peaked. Total invertebrate abundance was more sensitive than diversity to organic carbon input. Except for the year of the oil spill, and 1995 when production peaked, infaunal abundance was generally equal to or greater than baseline values at all stations greater than or equal to 30 in from the perimeter of the farm. There was a consistent amplification of abundance at the 60 m station in all years. Benthic impacts were restricted to 15 in and less, except when production peaked. This reinforces the diversity 59 data and demonstrates that both abundance and diversity were sensitive to organic carbon input. Over the history of this farm the distance at which adverse effects on benthic community were observed varied between 6 in and 30 in downstream from the farm perimeter. These effects were dependent on the biomass of fish being raised and the resulting sediment concentrations of organic carbon. Sediment organic carbon was reduced to less than baseline values between 30 -60 in downstream where there was a significant increase in the number of species (average of 106 species per station) and their abundance (9,367 animals per station, which was over twice the baseline average of 4,552). No cause and effect relationship between this amplification and the reduced TOC at stations 30 in and 60 in was investigated. Brooks hypothesized that the increased infaunal biomass was consuming the missing TOC. In contrast, Brooks (1994b and 1995b) documented sediment chemistry and infauna downstream from a salmon farm located in a well - flushed passage with maximum current speeds in excess of 125 cm -sec'. The water was shallow (15 -18 in MLLw) and the bottom consists of large gravel, cobble and rock mixed with small amounts of sand, silt, clay and broken shell. The site was used for final grow -out as part of a complex, which produced approximately 3,000 mt of Atlantic salmon per year, Monitoring results demonstrated the positive environmental effects associated with this farm, which had been operating continuously for more than 10 years in the same location. A total of 3,953 infaunal organisms distributed in 116 species were observed at the 60 in control station in 1994. The abundance and diversity of benthic infauna was enhanced at all stations closer to the farm with a maximum of 7,350 animals distributed in 173 species observed at the 30 m station. On the periphery of the farm 4,207 animals were observed, distributed in 142 species. Annelids dominated the infaunal community and the annelids C. capitata (16 %) and Prionospio steenstrupi (17 %) were abundant in the immediate vicinity of the farm. However, arthropods and surprisingly mollusks (Mysella tumida and Macoma spp.) were well represented in these samples. The abundance and diversity of infaunal organisms was positively correlated with sediment TOC, suggesting that organic carbon was limiting the infaunal community throughout the area. Significant numbers of fish, shrimp and other megafauna were observed during each annual survey at this site, which appeared to function as an artificial reef. Three salmon farms located in close proximity all shared the same characteristics. They appeared to attract megafaunal predators and to enhance the infaunal and epifaunal communities. 4.6. Recovery and Remediation of Sediments Chemical and biological recovery of sediments under salmon farms has been documented by, inter alia, Ritz et al. (1989), Anderson (1992), Mahnken (1993), Brooks (I 993b), Brooks (2000a), Lu and Wu (1998), Karakassis et al. (1999) and Crema et al. (2000). 4.6.1 Chemical remediation Brooks (2000a) defined chemical remediation as the reduction of accumulated organic carbon with a concomitant decrease in hydrogen sulfide and an increase in sediment oxygen concentrations under and adjacent to salmon farms to a level at which aerobic organisms can recruit into the area. At the farm being studied sediment concentrations of .1 volatile solids declined rapidly as soon as harvest was started in June of 1996 and they were close to control values when the harvest was completed in April of 1997. By the end of the 10 -month harvest, significant differences (a = 0.05) in TVS were not observed between the mean for all reference area data and farm stations located at 5, 10, and 15 in from the net -pen perimeter. Chemical remediation resulted in increased levels of oxygen in sediment pore water and decreased levels of H2S and /or ammonia. H2S was evaluated organoleptically. High levels of sediment HZS were evident to 20 in during peak production. Moderate levels of H2S were observed as far as 37 in on the downstream transect. H2S was detectable at low levels to distances less than 50 in from the net -pen perimeter at the peak of production. It was moderately well correlated with other physicochemical parameters (r = 0.68 to 0.69). 4.6.2 Biological remediation Biological remediation was defined by Brooks (2000a) as the restructuring of the infaunal community to include those taxa representing at least 1% of the total invertebrate abundance observed at a local reference station. Recruitment of rare species (those representing <1% of the reference area abundance) into the remediation area is not considered necessary for biological remediation to be considered complete. Brooks (2000a) observed the beginning of biological remediation during the harvest period. Biological remediation appeared to be nearly complete 5 months following harvest. Several infaunal series are apparent in his data. These were initially identified using principal components analysis. The results are presented in Figure 1. Farm inputs (fish biomass and 30 -day feeding rate) associated in Group I were positively correlated with several sediment physicochemical variables including percent fines, total volatile solids and the presence of hydrogen sulfide. There was also a significant and positive correlation between the opportunistic polychaetes C. capitata and O. vivipara, and farm inputs. Species identified in Group II were not strongly negatively correlated with farm inputs. However these species all shared at least one of two characteristics. Larval shrimp (LSHRImp), and crab megalope larvae (BRACHMEG) are mobile organisms which live on top of the sediments, enabling them to avoid the anaerobic conditions associated with high organic loading. The amphipods, Jassa falcata (IASFAL) and Metacaprella kennerlyi (METKEN), and barnacles in the Class Cirripedia (CIRRI), were found in great abundance on the farm structure. Their presence on anaerobic sediments containing high amounts of volatile solids probably represented an ephemeral benthic community derived from the net -pen structure. 61 0.8 0.6 0.4 0.2 N O 0.0 U fO LL -0.2 -0.4 -0.6 Factor Loadings, Factor 1 vs. Factor 2 Rotation: Varimax normalized Extraction: Principal components -0.8 ` -0.4 -0.2 0.0 0.2 0.4 0.6 0.8 1,0 Factor 1 Figure 1. Output from a Varimax normalized principal components analysis of the dominant infauna, farm inputs, and sediment physicochemical parameters. (From Brooks 2000a). Key for Group II organisms LSHRIMP - Larval shrimp BRACHMEG -crab megalope larvae IASFAL - the amphipod Jassa falcata METKEN - the amphipod Metacaprella kennerlyi CIRRI - barnacles in the Class Cirripedia 62 Group III organisms were early colonizers following chemical remediation. Organisms in this group demonstrated a range of tolerance to sedimented organic carbon. Chemical remediation occurred very quickly at this site and the order of recruitment into the area was more likely a function of when the various taxa spawned than of sediment TVS concentrations. Finally, the organisms in Group IV were strongly negatively correlated with farm inputs. These organisms were least tolerant of sedimented carbon, or recruited late in the year. It is also worthy of note that Shannon's diversity index, Margalef s index, and infauna- diversity were more negatively correlated with farm inputs than any of the individual taxa. These data suggested at least three invertebrate series, as follows: Concentrations of organic carbon High Medium Low Ca itella ca itata Nematoda Le idonotus s uamatus Ophryotrocha vivi ara Mediomastus s . Coo erella subdia Nana Eteone lon a S llis elon ata Lumbrineris s . Notocirrus californiensis Other measures of biological integrity (Shannon's diversity index and Margalefs index) were also evaluated. Striplin Environmental Associates (1996) found that Shannon's index varied between 1.09 and 1.53 at Puget Sound reference stations where the percent fines (silt and clay) was less than 20% and water depths were <45 m. Brooks (2000a) found relatively high values of Shannon's index (2.6 + 0.4) at the reference station. These values suggest that the undisturbed infaunal community was diverse and evenly distributed. Low values of Shannon's index suggest a community dominated by a few species. This condition was evident to 50 in and possibly as far as 100 in from the perimeter of the net -pens on the down current transect during the peak of the production period. Shannon's index increased steadily following the initiation of harvest and an enhancement of the invertebrate community was suggested by this index at the end of the 5 -month fallow period. Anderson (1992) aggregated the taxa identified in three replicate Ponar grab (0.05 mZ) samples at each station at fallow farms in Canada BC, and found H' values varying from 0.108 to 1.465. The lowest values were found at stations with high TOC loading dominated by C. capitata, Nephtys cornuta, and the gastropod Mitrella gouldi. The higher values were generally associated with undisturbed reference stations. He used principal components analysis (PCA) to observe that factors fallow time, biomass, percent fines, total taxa richness and Shannon's index (H') were positively correlated with each other and negatively correlated with TVS, coarse sand, gravel, and sulfide. He concluded that high values of TVS and sulfide were indicative of unhealthy ecological conditions. Anderson (1992) observed recovery times that varied between several months at sites with low initial impact to an estimate of two years for severely impacted sites during which physical, chemical and microbial processes acted on sediments to make them hospitable to macrofaunal colonization. This refractory period was referred to as chemical remediation by Brooks (2000a). Once macrofaunal colonization began Anderson (1992) observed an increased rate of recovery. M In Washington State Brooks (1993b) found recovering sediments dominated by N. comuta, Glycera, and Lumbrineris, with few C. capitata in the vicinity of a fallow salmon farm in Port Townsend Bay, Washington. He hypothesized that, following cessation of production in October 1992, an initial period of chemical remediation was followed by a proliferation of opportunistic C. capitata. As the organic load was dispersed and catabolized by microbes, and the oxidation - reduction potential increased, predatory polychaetes in the genera Nephtys, Glycera, and Lurnbrineris flourished by preying on the large standing crop of smaller prey species. Mahnken (1993) studied the succession of invertebrates at a depositional environment in Clam Bay, Puget Sound, for two years during a fallow period at a salmon farm and observed two distinct 'stanzas' of biological recovery. The first was a three month period of rapid recovery in abundance and species diversity followed by a 3 -25 -month period when community recovery proceeded more slowly. Species which were numerically dominant in samples from the reference station showed rapid colonization. Rare species were slow to recruit to the area. He identified four successional series including: • A pre - successional series comprised of species tolerant of sediments having high TOC. • A pioneering group of early colonizers containing several species of organic - tolerant opportunists. • An intermediate group of colonizers associated with reduced numbers of deposit feeding opportunists. • A group of late colonizers consisting of a group of more conservative and persistent species. A fifth group of rare species identified at the reference station were still absent from the farm sediments at the end of the 20.5 month study. Mahnken (1993) observed that succession was most clearly defined in the Order Polychaeta. At the Clam Bay site biological recovery was initiated by C. capitata and followed in successive series characterized in turn by Armandia brevis, Phyllodoce maculata, Pectinaria granulata, Plarynereis bicanaliculata, and finally by more generalist species like Leitoscoloplos pugettensis. He concluded that the sequence was best described as a response to changing organic content in the sediments, resulting from biogenic reworking by changing guilds of benthic organisms. Brooks (2000a) conducted an exhaustive study of a salmon farm in BC during production and fallow periods over a period of two years. This was the first study documenting the relationship between salmon farm biomass, fish feed inputs, and the physicochemical and biological response of the benthos. The study design focused on quarterly samples collected on the downstream transect from the net -pen perimeter to a distance of 75 m, and at a local reference station located approximately 1,200 in from the farm. A maximum Atlantic salmon biomass of 1,199 rat was raised at the farm under study. His data clearly depicted the accumulation of volatile organic material under the farm and out to distances of ca. 40 m from the net -pen perimeter during the peak of production. The physicochemical data (TVS, TOC, hydrogen sulfide, zinc, and depth of the reduction - oxidation potential (RPD) discontinuity) were well correlated and internally consistent. 64 Organic carbon accumulations (TOC or TVS) were sensitive indicators of biological effects. The regression approach taken in the experimental design allowed for the three - dimensional mapping of these parameters describing the spatial (as a function of distance from the net -pen perimeter on the downstream transect) and temporal (as a function of both season and production cycle) trends in the data. In all of these cases chemical and biological recovery of the benthos occurred within weeks or months at some sites, and within two to three years at others. These benthic recoveries have occurred naturally with no need for intervention or mitigation. 4.6.3 The assimilative capacity of the local environment Brooks (2000x) provided a methodology for estimating the assimilative capacity of sediments adjacent to salmon farms. The upper 90th percentile TVS observed at the local reference station was 3.4 %. In Figure 2 this value is represented by the boundary between dark green and light blue. Based on the assumption that the 90th percentile TVS observed at the reference station represents the sediment assimilative capacity (SAC), this analysis suggested that a maximum salmon biomass of ca. 170 mt could be raised at this site without exceeding the SAC on the perimeter of the farm. That is 14% of the actual farm production. A similar methodology could be applied to other physicochemical benchmarks including sediment sulfides or Eh. 4.7 Managing the Environmental Effects Associated with Salmon Farms 4.7.1 Monitoring experiences From 1987 until 1996 the Washington State DNR required monitoring of sediment chemistry (carbon, nitrogen, redox and sediment grain size), water chemistry (dissolved oxygen, pH, nitrate, nitrite, total ammonia and unionized ammonia), and the benthic community (quantitative infaunal surveys and qualitative scuba surveys) as a condition in ALLs for salmon farms. That monitoring experience provided an extensive database upon which to evaluate the effectiveness of each measured parameter in predicting environmental effects. Several lessons were learned from those studies, as follows: (a) Sediment grain size and water depth were primary factors determining the structure of an undisturbed infaunal community. (b) Absent any anthropogenic inputs, i.e., in reference areas, the TOC content of undisturbed sediments was significantly correlated with the proportion fines (silt and clay) contained in superficial sediments ( <2 cm depth). Depositional areas associated with slow current speeds and gyres accumulate both fine sediments and particulate organic materials at higher rates than high - energy areas. (c) The redox potential and health of the infaunal community associated with a particular sediment grain size distribution appears well correlated with the level of TOC in the sediments (Striplin Environmental Associates 1996, Goyette and Brooks 1999). This is evident in Figure 3, which depicts the relationship between infaunal abundance, diversity, redox potential, and percent TOC. Note that the significant depressions in infaunal diversity and abundance observed at distances of zero and 6 m from the perimeter of the net -pens was associated with TOC levels averaging 2.8% and an RPD 65 z =0. 021- 0" x+ 5. 859e- 8' y+ 2. 25e- 6' x "x- 6.028e- 10'x'y- 1.415e- 14'y'y Figure 2. Surface contour plot describing the relationship between salmon biomass (kg), distance from the farm perimeter on the downcurrent transect in meters, and TOC expressed as a proportion of dry sediment weight. .. 1063600 _, .. 1020000 Upper On percentile TOC at the local reference station Sediment TVS (Proportion dry weight) N E 040000 ., 0014 7@]000 720000 0021 - - - -- -_ 0._0026 660000 ,-,. _m. ` -.... _- Maximum salmon biomass not exceeding ED 0031 ._ � 600000 `�F: "' -- the upper 901n percentile TOC observed FM 0038 E540000 'q`p' -- at the local reference station at a distance Mg -: 0044 480000 -- - of 30 meters from the netpen perimeter. 0 046 Ell 0 051 `S !. ._ 420000 ®.. _. ®x..0056 360000 ®. 2 E CO 300000 240000 Approximate salmon biomass not exceetlng - 180000 the sediment's assimilative capacity. 0 0 10 20 30 40 50 60 70 00 90 100 110 120 130 140 150 160 170 180 190 200 Distance from netpen perimeter in meters Figure 2. Surface contour plot describing the relationship between salmon biomass (kg), distance from the farm perimeter on the downcurrent transect in meters, and TOC expressed as a proportion of dry sediment weight. .. that was very close to the sediment surface. These sediments smelled strongly of hydrogen sulfide. Beyond 6 m the TOC declined rapidly to 1.8% and the depth of the RPD increased to approximately 1.0 cm. Conditions remained constant to 24 m from the farm perimeter where TOC slowly declined to background levels of ca. 1.25 %. Infaunal samples were not collected at all TOC stations during this study. However, sediments were depauperate from the perimeter of the farm to 6 m downstream. The abundance and diversity of infauna slowly increased between 6 and 30 m downstream but remained depressed to a distance of 30 m from the net -pen perimeter. A normal community was observed in samples collected 60 m downstream from the perimeter of this farm. 700 600 0 500 a c @ ° 400 m U C '0 300 a 200 w C �111111 13 O O O O O O O O O O O O O O O O O O O O O CO W O N MIt N 0 n W rn 0 Distance from farm perimeter (feet) [MIS' 5.00 u 0 CL 4.00 ° CO 0 3.00 0 II @ 2.00 o� @ 1.00 F M Figure 3. Relationship between percent total organic carbon, depth of the reduction - oxidation potential discontinuity (cm), Washington State TOC triggers, and abundance and diversity of infaunal organisms at a major salmon farm located in a deep (33 m MLLw) bay where maximum currents speeds were less than 10 cm-sec'. 67 Based on these monitoring reports, it appears that TOC can be used as a screening tool to evaluate benthic health indirectly. This is not unlike the use of bioassays as a screening tool in evaluating the effects of toxic industrial and municipal effluents in fine- grained sediments. The use of TOC (or TVS) as a screening tool has the advantage of being fast. Analyses can be completed in a few days, whereas infaunal community analysis takes months. In addition, the lower cost of TOC /TVS analysis allows more frequent monitoring. When combined, these factors allow TOUTVS to be used as a real -time parameter useful to farm managers. Sediment total sulfides and oxidation - reduction potential measured with ion specific probes immediately following sample collection are emerging as more biologically relevant physicochemical endpoints in ongoing studies in BC. The results of these studies will be available in May 2001. (d) Invertebrate community analysis has been a traditional and direct way of evaluating the effects of organic loading (see Pearson and Rosenberg 1978, Lunz and Kendall 1982, Weston 1990, Brooks 1993 and 1993b, Henderson and Ross 1995, Brooks 1994a, 19946, 1995a, and 1995b). In Washington State invertebrate infaunal community analysis is used as a primary endpoint for evaluating benthic sediment quality (WAC 173- 204 -320). (e) Salmon farms located in well- flushed ( >50 to 100 cm- sec's) environments frequently increase both the abundance and taxa richness of infaunal communities, even at high levels of salmon production (Brooks 1994b and 1995b). (f) Salmon farms located in poorly flushed ( <10 cm-sec") environments can result in the deposition of significant amounts of carbon to the benthos — even when located in water as deep as 30 in MLLW. Adverse effects are generally restricted to an area within 15 -22 m from the perimeter of farms located in these poorly circulated environments. Increases in both the level of TOC and the distance at which adverse effects are observed are sensitive to farm management practices (Brooks 1994a). However, in these poorly flushed environments the negative effects can be managed so that they remain within 33- 100 in of the farm perimeter, even during intensive production of fish. (g) Indicator invertebrate taxa have been identified at several of the farms studied in the ALL Program of DNR. These indicator taxa and groups of taxa appear temporally consistent but are specific to different environments (Brooks 1995a and 1995b). Other authors (Weston 1990, Tsutsumi et al. 1991, Mahnken 1993, and Henderson and Ross 1995) have identified similar suites of indicator species in response to organic loading. 4.7.2 Management by modeling salmon farm wastes There is significant interest in modeling salmon farm waste as a management tool for regulatory agencies. Some of these models are qualitative (Sowles et al. 1994) and others attempt to quantify the dispersal and accumulation of particulate organic matter in sediments (Fox 1990, Gowen et al. 1994, and Silvert 1994b). It appears that the more basic the model inputs, the more room there is for error. Silvert (1994a) used a simple carbon budget to model salmon farm waste and concluded that 40% of the feed was not consumed by the fish. There is no evidence in the literature substantiating feed loss rates this high. None of these models has been tested to compare predictions with observed carbon deposition rates or sediment physicochemical responses to salmon farm waste. TM Findlay and Watling (1994) modeled sediment organic carbon decay rates and developed nonlinear regression equations relating oxygen delivery (mmoles /mZ -hr) and maximum oxidizable organic matter (grams carbon /m- -day) to sediments as a function of current speed (cm /sec). They concluded that the maximum carbon flux not exceeding the assimilative capacity of the sediment is highly dependent on the minimum 2 -hour average bottom current speed. Silvert and Sowles (1996) developed several algorithms considered useful in modeling the environmental response to salmon farming. They concluded that models exist which can help to assess impacts and make reasonable management decisions, but this is not substantiated in the existing literature. These models provide some insight into the environmental response to salmon farm waste. However, they are not adequate for making reasonable quantitative predictions regarding the degree or spatial extent of salmon farm waste. 4.7.3 Risk management through NPDES permit standards In 1996 Washington State developed sediment management standards for marine net - pens (WAC 173 -204). The Washington State rule is based on the following assumptions: (a) Salmon farming provides significant benefit to the State and its people. (b) The negative benthic effects associated with net -pen operations in poorly flushed environments will remediate naturally following cessation of operation or initiation of a fallow period. (c) The spatial extent of these effects can be managed. The sediment rule for net - pens authorizes a sediment impact zone (S1Z) extending 33 in from the perimeter of the farm structure. This distance was chosen because it corresponds to the SiZ provided for other industrial discharges. From a biological point of view, it would seem more appropriate to develop site specific SIZs which reflect the biological productivity of the site's benthos and the presence of adjacent valuable resources. In that context, SIZ widths could extend considerably further from the perimeter of a farm, perhaps to a distance of 100 in or more. (d) TOC can be used as a screening tool in evaluating the health of the benthos. TOC 'triggers' have been defined as a function of the proportion of silt and clay in the sediment matrix. TOC triggers used to screen sediments for adverse biological effects at salmon farms in Washington State are tabulated below. If sediments located 33 in from the perimeter of the net -pen structures at salmon farms exceed these trigger values, then an evaluation of the health of the infaunal community is required. Proportion ( %) silt -clay in the sediments TOC trigger ( %) 0-20 0.5 20-50 1.7 50-80 3.2 80— 100 2.6 o (e) Biennial monitoring of sediment TOC is required at seven stations at each permitted farm. Four of these stations are located at a distance of 30 in from the perimeter on each side of the farm. Three replicate sediment samples are collected at each station. No further monitoring is required if sediment TOC is not statistically elevated (t -test) above the TOC trigger corresponding to the observed percent fines at each 30 in station. If the measured TOC is significantly higher than the corresponding trigger, then repeat sampling is required in the summer of the next year together with the collection of five benthic infaunal samples at each station failing the TOC trigger, and at a suitable control. Benthic infaunal analysis is required for any station at which elevated TOC is observed during the second round of sampling. (t) Each farm is required to manage its production such that there are no significant negative effects on benthic resources beyond the boundary of this 33 -m SIZ. WAC 173 -204 states that biological resources in sediments are considered adversely impacted if the mean numbers of crustaceans, mollusks or polychaetes in the test sediment at the boundary of the SIZ are reduced to significantly less than 50% of the number of animals belonging to the same taxa living in an undisturbed reference sediment. Evaluation is based on a one tailed t -test at a = 0.05 for five replicate 0.1 mZ samples. It should be pointed out that populations of benthic organisms are frequently found in patchy distributions with many animals of the same species confined in groups separated from each other. Infauna are seldom found regularly distributed in sediments. For that reason, if three samples were collected from the same general area, the individual samples would likely contain very different numbers of any one of these taxa. The reason that the rule relies on a 50% reduction in the number of any taxa is not that it is acceptable to kill 50% of the crustaceans, mollusks, or polychaetes outside the boundary of the sediment impact zone, but to acknowledge that the collection of a reasonable number of random samples may produce two means which vary by as much as 50 %, even though the sediments are not impacted at all, or share the same level of impact. (g) Benthic conditions at each of the four orthogonal 30 in SIZ stations must be photographically documented every two years and whenever sediment samples cannot be collected and analyzed in conformance with the requirements stipulated in the Puget Sound estuary protocols (PSEP 1986). (h) Well- managed salmon farms recognize the benefits of vaccination and BMPs in controlling disease. While not examined in this review, records of antibiotic use in Washington indicated a sharp decline at permitted farms between 1992 and 1996. Similarly, Kontali (1996) reported that the use of vaccines in Norway had resulted in reductions in the use of antibiotics from a high of 592 mg/kg salmon produced in 1987 to 5, 9 and 3 mg /kg in 1994, 1995, and 1996, respectively. Based on the current low use, Washington regulations (WAC 173- 204 -412) do not require routine monitoring for bacterial resistance at marine net -pet sites. All farms are required to maintain an operational log that specifies the date and nature of application of all disease control chemicals used. In addition, farms are required annually to report the amount of each therapeutic used on each farm. Based on the absence of adverse effects observed during 10 years of monitoring the water column adjacent to salmon farms in Washington State, the WDOE eliminated all W11 requirements for nutrient and dissolved oxygen monitoring in the water column from the NPDES permits. This approach by the State of Washington regulatory agencies is appealing for several reasons: • It recognizes the value of net -pen culture while requiring that any negative impacts be restricted to the immediate vicinity of the farm • It invokes a realistically achievable performance standard that can (must) be met through proper management practices • It is a relatively inexpensive approach as long as TOC levels at the boundary of the SIZ remain below trigger levels. This provides a real incentive to maintain carbon levels below specified triggers • The immediate endpoint (TOC) can be measured quickly and is useful as a real time management tool • The performance standard encourages future siting in environments that either have fine grained sediments that support high TOC levels, or in high current areas where TOC will not accumulate On the other hand there have been some problems in implementing the State's NPDES permit system. For example, sediment samples collected from coarse bottoms cannot be analyzed for TOC because the matrix must be ground to a fine consistency. Sediments from erosion environments are generally composed of coarse gravel and cobble. Opponents of aquaculture have argued that the WDOE biological performance standard defined in WAC 173- 204 -320 (3)(c) is inappropriate because it allows for up to a 50% reduction in the abundance of arthropods, mollusks, or annelids, and because it does not include some measure of species richness (PCHB Nos. 96 -257 through 96 -268). This criterion applies to all discharges in the State of Washington and not just to salmon farms. Application of the criterion requires analysis of these major taxa in five 0.1 mZ infaunal samples. A one - tailed t -test is then applied with a = 0.05. Alpha is the probability of finding an effect when it does not exist (the probability of making a Type I error or of rejecting the null hypothesis when it should not be rejected). That means that approximately 1 in 20 tests will indicate a statistically significant difference in the means of the populations when in fact the populations are identical. Brooks (2001, unpubl. data, Aquatic Environmental Sciences, Port Townsend, WA 98368) has tested this hypothesis using a Monte Carlo approach for analyzing benthic data from reference sites at two farms located in Puget Sound. He found that the null hypothesis was in fact rejected in 22% of the analyses on samples collected from the same reference station. Obviously, absent the allowable error of 50% incorporated in the WDOE rule, the criterion would be too conservative. The consequences to the permittee of failing the benthic biological criteria are significant, requiring reductions in the number of fish raised, or the amount of food provided, or actually fallowing the farm for a period. That is a significant penalty when there is a half 71 chance that failure is simply a matter of chance with a = 0.05. There are at least three ways to address this issue: (a) The value of a could be decreased to l% or 0.5 %. When a = 0.1 %, there is only a one in 100 probability of obtaining a false positive (Type I error). That would require a larger difference between the mean number of animals in any of the taxa observed at the reference site and the SIZ boundary — in other words it would not provide any more protection for the environment, (b) The DOE has defined an allowable error term of 50 %, (c) The number of endpoints at each station could in increased by evaluating both the abundance and the number of species observed in each of the major taxa. This would provide six endpoints (abundance and richness of arthropods, mollusks and annelids) for evaluation. By requiring failure of two of these endpoints before considering the station failed, the probability of a false positive would be decreased to 0.05 x 0.05 = 0.0025. 4.7.4 Risk management practices in British Columbia Following the exhaustive review of the scientific literature by EAO (EAO 1997), the Provincial Government of Canada BC has been developing a performance -based waste management policy (WMP) to insure that adverse benthic effects associated with salmon farming are managed. The following are essential elements likely to emerge. (a) Only single year - classes of fish will be grown at BC salmon farms. The purpose of this restriction, as practiced also in Norway and Chile since the mid- 1990s, is to reduce the potential for disease transfer between year - classes and to provide for a fallow period between production cycles sufficient to insure that sediments chemically remediate to within 30 m of the farm perimeter prior to restocking. (b) Prior to restocking a new year - class, the farm must remain fallow until the level of volatile residue in sediments at a distance of 33 in from the net -pen complex perimeter returns to baseline or local reference station values. The length of fallow is not specified, but farm management must certify to the Ministry of Environment that this condition has been met before restocking fish. (c) At no time will adverse benthic effects be allowed at distances >100 in from the perimeter of the net -pens. This performance standard will be evaluated annually during the months of August through November. This distance is under review and will likely be set by the BC Government during 2001. (d) Based on the problems encountered with the analysis of TOC in Washington State, BC is using TVS as a primary screening tool. TVS (as a percent of dry sediment weight) must not statistically exceed (one- tailed t -test, a = 0.05, N = 3) the upper 90th percentile value observed at a local reference station. Samples are collected for this analysis at a distance of either 30 in (for the pre- stocking certification) or 100 in (for the annual monitoring) from the midpoint on each of the sides of the net -pen's perimeter. These points are referred to as the 'inner' and 'outer' sediment impact zones (IS1Z and OSIZ). If no local reference station is available, then farm samples will be compared against TVS triggers which represent the upper 90th percentile of historical TVS levels observed at reference stations throughout BC. (e) Hargrave et al. (1997) examined the biological and physicochemical attributes at 11 salmon farm and I 1 reference stations in the Western Isles region of the Bay of Fundy on the east coast of Canada. They found that organic carbon, sediment sulfides, 72 and redox potential were effective endpoints for evaluating the benthic effects associated with salmon farming. The results of this study have been incorporated in the WMP by requiring quantitative evaluation of sediments for total sulfides (S -) and oxidation - reduction potential (ORP). Protocols developed by Hargrave et al. (1995) were adopted for these analyses. Specific performance standards for sulfides and Eh will be developed pending the outcome of a series of focused studies designed to determine the biological response to varying concentrations of these endpoints. Stations failing the screening tests will probably be evaluated against the biologically - based performance standard which states that, Adverse Sediment Biological Effects will be evaluated by comparing abundance and diversity (number of species) in the Class Crustacea, Class Polychaeta and the Phylum Mollusca at farm sample stations defined in the performance standards with the abundance and diversity of the same taxa found at a local reference station. This test will establish six endpoints for evaluation (abundance and diversity in each of three major taxa). These differences shall be evaluated using a one- tailed t -test with a probability of observing an effect when one does not exist of five percent (a = 0.05). Because one in twenty of these tests are expected to produce a false positive (indicates an adverse effect when one does not exist), this performance standard defines adverse biological effects when two or more of the six endpoints are statistically decreased compared to levels observed at a local reference station. This procedure will still result in one false positive in 400 tests. This biological standard will be determined by comparing the three major taxa, observed in five 0.1 mz grab samples at each farm station with the abundance and diversity of these taxa observed at a local reference station sharing similar depth and sediment grain size characteristics. This may require more than one local reference station per farm. Identification of all taxa in this evaluation will be to the level of species, or the lowest practical level. Ammann et al. (1997) used the results from 28 previous studies to examine the Taxonomic Sufficiency of various levels of biological organization to determine adverse impacts in aquatic environments. They found that for 89% of the experiments evaluated, phyla counts were as sensitive as any of the metrics evaluated. Community metrics (Shannon- Weiner's, Simpson's, and Brillouin's diversity and evenness and richness) were never found to be more sensitive than count data. Amman et al. (1997), and the citations included therein, support British Columbia's choice of major taxi (Phylum Molluska, Class Crustacea and Class Polychaeta) as appropriate metrics in developing their regulatory policy. The identification of organisms to species will allow for future analysis using a variety of additional metrics. Farms with stations failing the Sediment Biological Effects Standard will be required to develop a remediation plan that brings the farm back into compliance.' The BC Provincial Government has stated a desire to establish a final performance based salmon farm management program in the fall of 2001. In addition, the DFO, which has the responsibility to enforce the Fisheries Act is participating at the technical level in developing the BC program. 73 5. ATLANTIC SALMON AND THE LOCAL ECOSYSTEMS The fifth chapter is very specific to the pros and cons of salmon species in the local ecosystem of the Northwest (Puget Sound). It has seven identified subsets. The first subsection reviews the issue of the introduction of Atlantic salmon into the Pacific ecosystem and the potential interactions. Specific sections review possible hybridization between Atlantic and Pacific salmon, the genetic dilution and alteration of the gene pool, the colonization of the aquatic environment by Atlantic salmon, and finally the interactions of wild salmon and genetically altered transgenics. The second subsection concerns epidemics and transmission of waterborne disease, and reviews the potential for cultured Atlantic salmon, an exotic species, to introduce new diseases into the local ecosystem. There are nine specific items, from the diseases which might be involved, to potential interactions, and current policies for disease control. The third subsection concerns the potential ecological impacts in the Pacific Northwest, specifically the interaction with Pacific salmon and predation. The following sections review the effects of artificial propagation practices in the region in general, the impacts of the introduction of non - indigenous species, and a comparison of escapes or releases of propagated Atlantic and Pacific salmon. The last section examines the NMFS Biological Status Reviews of west coast Pacific salmon stocks. 5.1 General Issues of Artificial Propagation of Salmonids Ellis (1996) and Alverson and Ruggerone (1997) comment that the artificial propagation of salmon and trout in the Pacific Northwest had come under increasing scrutiny in recent years. This was due to the recognition that hatchery cultured salmon and trout may have the potential to adversely impact natural populations. Although the weight of attention has been focused on the extremely large complex of federal, state, tribal, and cooperative hatcheries in Alaska and the western States, concerns about the potential adverse impacts of private trout and salmon culture in Washington have also been expressed. Concerns about genetic interactions, the transmission of disease, and ecological interactions are most commonly voiced. The secondary source for this unpublished study is Gross (1997), who stated that Atlantic salmon had the potential for hybridization with Pacific salmon. Quinn (1997) stated that it was possible that the 369,000 Atlantic salmon which escaped into Puget Sound in 1997 would produce 10 million healthy smolts in local rivers. The Alaska Department of Fish and Game (ADF &G) has expressed concern that escaped Atlantic salmon from west coast salmon farms will compete with wild salmon and spread diseases and parasites for which Pacific salmon have little resistance (ADF &G 1999). For example, a letter sent to Alaska Senator Stevens (April 25, 1997), by a constituent, read, in part, 'The continued introduction of Atlantic salmon to the marine habitat of British Columbia and Washington State will inevitably have negative biological impacts. These will include displacement, hybridization, and the introduction of alien.... disease.' (Gilbertsen 1997). 74 5.2 Genetic Interactions of Artificially- Propagated Pacific and Atlantic Salmon A major concern with artificial propagation in general and farming of Pacific salmonids and Atlantic salmon in particular are the potential genetic effects of inadvertent escapees on the native salmonids. For the salmon farming industry in BC, where both Pacific and Atlantic salmon are extensively farmed, the BCSAR study listed four major areas of concern (EAO 1997): • Hybridization between Atlantic and Pacific salmon • Genetic dilution and alteration of the wild salmonid gene pool • Colonization by Atlantic salmon • Interactions between wild salmon and genetically altered transgenics These concerns are both geographically and species specific. For the Puget Sound, the primary concern is with Atlantic salmon, as Pacific salmon, with rare exception, are not cultured by private enterprises. 5.2.1 Hybridization No genetic interactions between Atlantic and wild Pacific salmon have been reported in the Pacific Northwest. Similarly, under controlled and protected laboratory conditions where survival of hybrid offspring should be optimized, viable hybrids between Atlantic and Pacific salmonid species are difficult to produce. Refstie and Gjedrem (1975), Sutterlin et al. (1977), and Blanc and Chevassus (1979, 1982) found that crosses between Atlantic salmon and rainbow trout failed to produce any viable progeny. A similar lack of vitality was observed in pairings of Atlantic salmon and coho salmon ( Chevassus 1979) and Atlantic salmon and pink salmon (Loginova and Krasnoperova 1982). Gray et al. (1993), attempted to produce diploid and triploid hybrids by crossing Atlantic salmon with chum and coho salmon, and rainbow trout. All embryos died in early developmental stages, leading to the conclusion that hybridization of Atlantic salmon with Pacific salmon species was unlikely to happen. The secondary source of these two unpublished BC studies by Alverson and Ruggerone (1997) have provided more data regarding the relative genetic compatibility between Atlantic and Pacific salmon (R. Devlin, DFO Canada, reported in Alverson and Ruggerone 1997). In the first, using a small number of eggs, Atlantic salmon produced no viable hybrids with coho, chum, chinook, sockeye salmon, and rainbow trout. In the same experiment, each species of Pacific salmon readily produced hybrids with between two and five other Pacific salmon species, and confirmed previous observations in this genus by, inter alia, Foerster (1935), and Seeb et al. (1988). These results were cited as evidence of 'rampant hybridization potential' in hearings before the Washington State PCHB (96- 257 -266, and 97 -110, 1998). However, the Board found the statement not supported by the study, and there was no reasonable potential for hybridization between escaped Atlantic salmon and native Pacific salmon in Puget Sound based on current knowledge and behavior (PCHB 1998). In the second study using a much larger number of eggs, viable hybrids to hatch involving rainbow and steelhead trout, coho, chum, chinook, and pink salmon were produced. Approximately 6.1% of the steelhead x Atlantic salmon, and 0.01% of the 75 pink salmon x Atlantic salmon hybrids survived to the hatching stage. The inter - specific crosses between Oncorhynchus species produced hybrids with survivals to hatch ranging from 10 -90% in 15 of the 42 crosses. Despite these high survivals to hatch among the Pacific salmon hybrids, compared with the fractional survival to hatch observed between an Atlantic salmon x pink salmon cross, no concerns over the introduction of hatchery stocks of Pacific salmonids into natural habitats were addressed to the PCHB. The 'successful' Atlantic x steelhead hybrids were carefully controlled experiments in vitro, and actual Atlantic /steelhead hybridization would probably not happen under natural conditions in Washington State. The Atlantic salmon stocks used in Washington have finished spawning by the end of November (W. Waknitz, NMFS, unpublished data), and wild steelhead in western Washington spawn between mid -March and mid -June (Freymond and Foley 1985). Therefore, there is virtually no opportunity for Atlantic salmon to spawn with local wild, native steelhead outside the laboratory. While viable hybrids between Atlantic salmon and the Pacific salmonid species have been difficult to produce in the laboratory and do not occur under natural conditions, hybrids between Atlantic salmon and a sympatric species, the brown trout are relatively successful. Viable Atlantic salmon x brown trout hybrids have been produced in the laboratory by, inter alia, Suzuki and Fukuda (1971), Refstie and Gjedrem (1975), Blanc and Chevassus (1982), and Gray et al. (1993). Successful hybridization under natural conditions has been reported for Europe where brown trout are native, and also in North America where the brown trout has been introduced (Verspoor and Hammar 1991). The frequency of natural hybridization in Europe and North America ranges from 0.1 to 13.2% of juveniles in river systems (Jordan and Verspoor 1993) and appears to be increasing relative to pre - aquaculture levels ( Hindar et al. 1998). McGowan and Davidson (1992) cite the breakdown in pre - reproductive isolating mechanisms (abundance of mature Atlantic parr) as the principal mechanism for natural hybridization. Hindar et al. (1998) reported that although a disproportionate number of hybrids were the product of matings involving Atlantic salmon females, there was no evidence that escaped farmed Atlantic salmon females produced more hybrids than wild females. Youngson et al. (1993), on the other hand, had previously reported that escaped female in western and northern Scotland rivers hybridized with brown trout more frequently. Wilkins et al. (1993) found that male hybrids were fertile and when back - crossed with female Atlantic salmon produced about 1% diploid progeny. Galbreath and Thorgaard (1995) reported that back - crosses between male diploid, male triploid, and female diploid Atlantic salmon x brown trout hybrids and both parental species produced either non - viable or sterile progeny. No natural hybrids between Atlantic salmon and Pacific salmonids have been reported in Europe. This is despite the fact that introduced rainbow /steelhead trout, brook trout, coho salmon, and pink salmon have all established naturalized populations within the native range of Atlantic salmon throughout the European continent (MacCrimmon and Campbell 1969, MacCrimmon 1971, Berg 1977, and Lever 1996). Similarly, no hybrids between Atlantic salmon and brown trout, rainbow trout or brook trout have been 76 reported in South America or New Zealand, even though all four of these species are not native to those locations (MacCrimmon 1971, Lever 1996). The propensity of Atlantic salmon to produce successful hybrids with brown trout and not with the Pacific salmonids may be related to the phylogenetic distances that exist between the two groups. Neave (1958) postulated that the putative ancestors of the Salmo group migrated to the Pacific 600,000 to 1,000,000 years ago, were subsequently isolated by land bridges, and evolved to the ancestral Oncorhynchid form. The ancestral Oncorhynchid form subsequently developed to form the separate Oncorhynchus species (Simon 1963). McKay et al. (1996), based on DNA sequence analysis of growth hormone type -2 and mitochondrial NADH dehydrogenase subunit 3 gene, estimated that, at a minimum, the major divergence between the genus Salmo and the genus Oncorhynchus occurred 18 million years ago, while speciation within the genus Oncorhynchus began about 10 million years ago. Benfey et al. (1989) also noted that the evolutionary differences between the Pacific and Atlantic salmonids were reflected by immunologically detectable forms of vitellogenin. Attesting to their phylogenetic similarity, interspecific hybrids within the Oncorhynchids are relatively successful. Foerster (193 5) was among the first to report successful hybrids between controlled mating of sockeye, chum, pink and chinook salmon. Since then, limited occurrences of natural hybrids have been reported among anadromous salmonids. Bartley et al. (1990) reported on natural hybridization between chinook and coho salmon in a northern California river, and Rosenfield (1998) reported a natural pink x chinook hybrid from the St. Mary's River in Michigan. On the other hand, hybridization between introduced rainbow trout and native cutthroat trout appears to be almost ubiquitous throughout the interior part of western North America, and has been enormously detrimental to the latter species according to Gresswell (1988) and Behnke (1992). 5.2.2 Genetic dilution and alteration of the wild salmonid gene pool Adverse genetic and ecological effects due to releases or escapes of artificially - propagated Atlantic salmon from public hatcheries and private net -pens on wild Atlantic salmon populations in Norway, Scotland, Ireland, and the Canadian Maritimes have been reported. For wild Atlantic salmon these include a reduction in their genetic adaptability and capacity to evolve as a result of interbreeding with artificially- propagated fish, and direct competition for food and space (Einum and Fleming 1997, Gross 1998). Such adverse effects only happened in those locations because both the cultured and wild fish were Atlantic salmon. Escaped Atlantic salmon on the west coast of North America do not have congeneric wild individuals with which to interact. In the Pacific Northwest region, the release of hatchery Pacific salmon has the greater potential to produce impacts on native Pacific salmon which are analogous to those found between cultured and wild Atlantic salmon in Europe and eastern North America. Adverse genetic and /or ecological interactions on local wild salmon populations from artificially - propagated Pacific salmon have been well documented by Weitkamp et al. (1995), Busby et al. (1996), Hard et al. (1996), EAO (1997), Gustafson et al. (1997), 77 Johnson et al. (1997), Myers et al. (1998), and Johnson et al. (1999). No detrimental effects related to Atlantic salmon have been reported in western North America. Compared with the evidence in the literature of genetic alterations of Pacific salmonid populations as a consequence of salmonid enhancement and supplementation programs in the Pacific Northwest, there is little or no evidence in the literature of adverse impacts associated with escaped Atlantic salmon in the region. 5.2.3 Colonization by Atlantic salmon In the past century there have been numerous attempts in the US and elsewhere to establish Atlantic salmon outside their native range. These attempts involve at least 34 different States, including Washington, Oregon, and California. None of these efforts was successful. MacCrimmon and Gets (1979) subsequently reported that no reproduction by Atlantic salmon was observed in the waters of these States, and twenty years later this was reconfirmed by Dill and Cordone (1997) and Alverson and Ruggerone (1997). It also appears difficult to reintroduce Atlantic salmon to their native rivers. In the last 100 years, Atlantic salmon populations in New England have declined precipitously, despite the large -scale introduction of locally derived hatchery fish (Moring et al. 1995). The Penobscot strain of Atlantic salmon (which is used in net -pen farms in Puget Sound) is now under consideration for listing under the US Endangered Species Act 1974 (USDOI/USDOC 1995). Between 1905 and 1934 the government of BC released 7.5 million juvenile Atlantic salmon into local waters, primarily on the east coast of Vancouver Island and the lower Fraser River in Canada (MacCrimmon and Gotts 1979; Alverson and Ruggerone 1997). These releases were not successful in establishing Atlantic salmon populations in the Province, although some natural reproduction may have occurred according to Carl et al. (1959). Emery (1985) noted that even in historic Atlantic salmon habitat, such as the lower Great Lakes, attempts to re- establish Atlantic salmon populations have not been successful, although Brown (1975) had earlier stated that introduced Pacific salmonids had succeeded in establishing self - reproducing populations in that area. Lever (1996) noted that, worldwide, no self - sustaining populations of anadromous Atlantic salmon have been established outside the natural range of this species, although a landlocked population appears to have become established in the mountains of New Zealand. Reproduction by Atlantic salmon was also observed subsequent to introduction in Chile and Australia, but these transfers also failed to create self - sustaining populations The failure of early introductions of Atlantic salmon to produce self - sustaining populations could have been due to the rather primitive hatchery methods used in the early 1900s. However, the same primitive methods that failed to establish Atlantic salmon anywhere in North America proved to be remarkably successful in establishing European brown trout, brook trout, and rainbow trout almost everywhere in the earliest days of fish culture, usually on the first attempt. With these particular salmonids, the 78 success or failure of introduction appears to be associated with attributes inherent to the species, not from the hatchery methods employed. Atlantic salmon are virtually the only non - native salmonid not successfully introduced to Washington, with the exception of Arctic char and Masu salmon (Wydoski and Whitney 1979). The initial transfer of Atlantic salmon to Washington occurred in 1904, according to MacCrimmon and Gots (1979), and Coleman and Rasch (1981) noted that attempts to introduce runs of this species continued until about 1980. Occasional releases of Atlantic salmon into high mountain lakes have since been made. Sea -run and landlocked strains were used, but neither life- history form succeeded in establishing self - perpetuating populations. Attempts to establish Atlantic salmon in Canada BC took place during this period, with similar results, although successful spawning may have occurred in the Cowichan River, Canada as specimens thought to have resulted from the planting of Atlantic salmon were taken until May 1926, according to Dymond (1932), Carl et al. (1959), and Hart (1973). The DFO has been carrying out a long term monitoring study on the catches and sightings of individuals and to see is self - sustaining populations are becoming established but without results (Thomson and Candy 1998). Recently Volpe et al. (2000) reported that Atlantic salmon had successfully produced offspring in BC. Several Atlantic salmon fanners in Washington rearjuveniles in the Chehalis River basin prior to transfer to seawater in Puget Sound. Since the mid -1980s escaped Atlantic salmon smolts have been captured in traps designed to monitor the outmigration of juvenile Pacific salmon (Seiler et al. 1995). However, as of 1998, no returning adult Atlantic salmon have been encountered at adult salmon traps on several tributaries of the Chehalis River system, or been caught in tribal gillnet fisheries, which capture about 10% of all upstream migrants in the main stem of the Chehalis River (D. Seiler, WDFW, personal communication). The risk of anadromous Atlantic salmon establishing self - perpetuating populations anywhere outside of their home range is extremely remote, given that substantial and repeated efforts over the last hundred years have not produced a successful self - reproducing population anywhere in the world. In the Pacific Northwest Atlantic salmon introductions also have not succeeded in producing self - sustaining populations, even though a few naturally produced juveniles may have been observed from time to time, according to Dill and Cordone (1997). 5.2.4 Interactions of wild salmon and transgenic fish As with other agricultural sectors, there is considerable interest within the fish farming sector to improve growth or survival of fish or shellfish through genomic manipulations. In recent years the role of transgenics (descendants of genetically engineered parents whereby introduced DNA has been incorporated and inherited) in traditional farming has been a controversial topic. The potential exists that transgenic fish, should they escape from fish farms, may reproduce successfully with wild or other transgenic fish and produce offspring which may eventually adapt to their local environments. This is a topic which will receive 79 considerable debate in the years to come. There is no evidence in the literature that transgenic fish have been raised or are currently being raised in Puget Sound waters, and there are no plans to raise them in the future. 5.3 Epidemics and the Transmission of Waterborne Disease 5.3.1 The origin and disease status of Atlantic salmon stocks in Puget Sound In 1971 scientists from the NMFS Northwest Fisheries Science Center began testing the feasibility of rearing New England stocks of Atlantic salmon in seawater net -pens in Puget Sound to provide 3.5 million eyed eggs annually for restoring depleted runs in southern New England (Mighell 1981, Harrell et al. 1984). Between 1971 and 1983 NMFS received eggs from many North American stocks, including the Grand Cascapedia River in Quebec (via Oregon State), and the Penobscot, Union, St. John, and Connecticut rivers in the USA. All Atlantic salmon eggs sent to the NMFS Manchester Research Station were examined according to the code of federal regulations (Regulation 50 CFR) and certified by federal pathologists to be free of bacterial and viral pathogens prior to transfer from New England to Washington. However, few eggs were ever sent back to New England due to the reluctance of east coast fisheries managers to accept eggs from Atlantic salmon which had been grown in waters inhabited by Pacific salmon. A panel of New England state and federal fisheries officials met at Newton Corner, Massachusetts in March, 1984 and determined that raising Atlantic salmon in Puget Sound had rendered the eggs unfit for transfer back to the east coast because the risk of introducing Pacific salmon diseases to New England Atlantic salmon populations was too great. As a result of this decision, millions of Atlantic salmon eggs originally meant for New England restoration programs were available for distribution to salmon farmers in Washington. These eggs proved to be a boon to the local industry as, by this time, it was clear from work in Norway and Scotland, that Atlantic salmon were superior to Pacific salmon in all aspects of culture, including survival to hatching, growth rate in fresh and sea water, and, contrary to east coast opinion, resistance to infectious diseases (Mighell 1981, Waknitz 1981). 5.3.2 Disease of salmonids Freshwater salmonid diseases observed in Pacific salmon hatcheries in the Pacific Northwest include furunculosis, bacterial gill disease, bacterial kidney disease, botulism, enteric redmouth disease, cold water disease, columnaris, infectious hematopoietic necrosis, infectious pancreatic necrosis, viral hemorrhagic septicemia, erythrocytic inclusion body syndrome, and a large number of parasitic infections, such as gyrodactylus, nanophyetus, costia, trichodina, ceratomyxosis, proliferative kidney disease, whirling disease, and ichthyophonis. All these diseases are described in works by, inter alia, Wood (1979), Leitritz and (1980), Foott and Walker (1992), and Kent and Poppe (1998). lE The frequency of occurrence of these pathogens in hatcheries appears to vary geographically. For example, between 1988 and 1992, a greater percentage of hatcheries in Alaska tested positive for infectious hematopoietic necrosis, viral hemorrhagic septicemia, furunculosis, and ceratomyxosis than hatcheries located elsewhere in the western States, whereas the same hatcheries in Alaska tested positive at the lowest rate for several other salmonid pathogens (PNWFHPC 1993) (Table 1). In the Pacific Northwest, hatchery diseases associated with freshwater organism can also occur in natural sea water environments after salmon are released from hatcheries or transferred to net -pens for further rearing. Some pathogens, such as V. anguillarum and various parasites, are unique to the marine environment and are normally encountered by wild and hatchery- reared salmonids only after they leave rivers for the sea (Wood 1979, Harrell et al. 1985 and 1986, Kent and Poppe 1998). Salmonid diseases observed in salmon and trout reared in public and private net -pens in sea water in the Pacific Northwest include; vibriosis, furunculosis, bacterial kidney disease, enteric redmouth disease, myxobacterial disease, infectious hematopoietic necrosis, infectious pancreatic necrosis, viral hemorrhagic septicemia, erythrocytic inclusion body syndrome, rosette agent, and a large number of parasitic infections. Kent and Poppe (1998) listed and described infections currently observed in salmonids in marine waters. Like other animals, salmon can carry pathogen organisms without themselves being infected. For example, numerous bacterial species were observed in tissues of chinook salmon which had returned from the ocean to a hatchery in the lower Columbia River Basin, although the fish displayed no clinical signs of disease. Some bacteria observed were Listeria sp., Aeromonas hydrophila, Enterobacter agglomerans, E. cloacae, Staphylococcus aureus, Pseudomonas sp., Pasteurella sp., V. parahaemolyticus, V. extorquens, V Jluvialis, Hafnia alvei, and Serratia liquefaciens (Sauter et al. 1987). Several of these organisms found in hatchery salmon are known to be infectious for humans but it does not infer they pose any risk. 81 Table 1. Facilities ( %) testing positive for various salmonid pathogens (July 1988 -June 1993). (Data from PNWFHPC 1993) State or Agency IHN IPN VHS FIBS BKD FUR ERM CWD PKD, MC I CS ICH K 47.3 0.0 1.2 0.0 75.2 42.5 10.9 27.5 NS NS 50.0 0.0 CA 24.2 0.0 0,0 0.0 31.2 2.2 23.0 19.4 27.9 12.0 12.8 56.3 D 20.2 &.7 0.0 15.5 48.4 1.8 12.3 23.6 4.3 15.6 20.4 20.7 T 0.0 0.0 0.0 0.0 5.6 2.5 0.8 4.2 7.7 0.0 0.0 0.0 OR 18.1 0.3 0.0 24.6 53.1 35.9 17.8 84.8 0.0 2.9 33.3 26.2 WA 11.5 0.7 0.1 34.2 52.6 20.1 17.0 60.3 3.5 0.0 11.9 24.4 USFWS 37.5 1.0 0.0 27.2 84.9 23.7 20.0 34.9 1 0.0 1 0.6 30.6 24.0 WIFC 2.9 0.0 0.6 NS 51.5 14.0 18.1 39.9 56.3 0.0 0,0 15.0 Average 20.2 1.3 1 0.2 1 14.5 1 50.3 17.8 15.0 36.8 12.5 4.4 18.8 20.8 NS = Not surveyed Key: (a) Viral Diseases IHN Infectious hematopoietic necrosis IPN Infectious pancreatic necrosis VHS Viral hemorrhagic septicemia EIBS Erythrocytic inclusion body syndrome (b) Bacterial Diseases BKD Bacterial kidney disease FUR Furunculosis ERM Enteric redmouth disease CWD Coldwater disease (c) Parasites PKD Proliferative kidney disease MC Whirling disease CS Ceratomyxa ICH Ichthyopthirius M 5.3.3 Infectious disease therapy Fish diseases and subsequent antibiotic therapy have been normal occurrences at state, federal, and tribal Pacific salmon hatcheries since the 1940s (WDF 1950, PNWFHPC 1993). For example, an examination of the disease histories of Puget Sound area Pacific salmon hatcheries (data from 45 hatcheries) during the 1980s showed that on average each hatchery commonly experienced disease outbreaks from about 4 different pathogenic organisms during this period, frequently on an annual basis ( PNWFHPC 1988a —d). Cumulatively, salmon hatcheries in the Pacific Northwest (Alaska, Washington, Oregon, and Idaho), including those located in Puget Sound, experience hundreds of disease outbreaks every year, according to Wood (1979) and PNWFHPC (I 988a—d). For example, Michak and Rodgers (1989) reported that, between 1983 and 1986, the WDFW Cowlitz Hatchery experienced Costia sp. infections on I 1 different occasions, bacterial hemorrhagic septicemia 4 times, cold water disease 9 times, bacterial kidney disease 8 times, and furunculosis once. Disease outbreaks have been observed in hatchery salmon reared in saltwater in Washington since the first attempts at seawater rearing in the 1950s (WDF 1954, PNWFHPC 1998). However, the occurrence offish diseases and their treatment with chemotherapeutics at public hatcheries has not been show to have deleterious effects on wild salmonids. Diseases in public trout and salmon hatcheries (Table 1) are normally treated with a variety of antibiotics and chemical baths including, inter alia, oxytetracycline, ®Romet- 30, formalin, iodophores (Wood 1979; PNWFHPC 1988a —d, 1998). Drug therapy in federal, state, and tribal hatcheries in Washington State is conducted in line with FDA guidelines (K. Amos, WDFW, personal communication). Antibiotic - resistant strains of bacterial fish pathogens have been observed in Pacific salmon hatcheries in the Pacific Northwest for over 40 years (WDF 1954, Wood 1979, PNWFHPC 1993), but no adverse impacts on wild salmonids have been reported as a result of drug use or the occasional development of antibiotic - resistant bacteria. Schnick (1992) reported that only three therapeutants (formalin, oxytetracyc line, and (ERomet -30) and one anesthetic (MS -222) were currently approved by the federal government for use with food fish in public and private artificial propagation facilities. However, the use of antibiotics in the US is far more restrictive than in other countries. For example, Weston (1996) stated that 26 different antibacterials were approved for use in Japan. This compares currently with three in Canada, according to EAO (1997) and two in the US ( Schnick 1992). Given that Pacific salmon hatcheries rear thousands of metric tons of fish each year, the amount of antibiotics used to treat bacterial salmon diseases is not insignificant, amounting to hundreds of tons of medicated feed each year. Michak et al. (1990) stated that WDF hatcheries located in the Columbia River Basin used about 200 mt of feed containing antibiotics. Since WDF (now WDFW) hatcheries in the Columbia River Basin represented only about 25% of the number of all salmon and trout hatcheries (albeit many of the largest facilities are in the Columbia River Basin) in Washington State at that 83 time (Myers et al. 1998), it is reasonable to estimate that the total amount of medicated feed used by the public hatchery system in the State was about 450 mt in 1990. However, no adverse impacts to wild salmonids have been reported as a result. Actual or estimated annual amounts of medicated feed used in private fish culture of Atlantic salmon in seawater and rainbow trout in freshwater are not available at this time for the USA. However, the amount of drugs used elsewhere in salmon farming has greatly declined, mostly as a result of improved husbandry practices, including development of effective vaccines. EAO (1997) noted that salmon farmers in Norway used 48.7 mt of antibacterial drugs in 1987, and the figure had fallen to 6 mt by 1993. In 1998 it was only 679 kg (Intrafish 2000). During the same ten year period, the production of salmon increased from 50,000 mt to 400,000 mt, and the quality of product was considerably improved (ODIN 2001). A similar pattern of reduced drug use has occurred in BC. With few salmon farms in Washington the annual use of antibiotics in the net -pen farms will be minimal. 5.3.4 Disease interactions between wild and propagated salmonids Documented examples of pathogen transmission between wild and artificially- propagated fish are not common, yet have been known to occur (Brackett 1991). For example, the planting of infected Atlantic salmon smolts from Norwegian federal salmon hatcheries into rivers in Norway was responsible for the introduction of the freshwater parasite Gyrodactylus salaris, which caused the extirpation of Atlantic salmon in many river systems (Johnsen and Jensen 1986, 1988). The salmonid viral pathogen I14N (infectious hematopoietic necrosis) was introduced to Japan from a shipment of infected sockeye salmon eggs from a hatchery in Alaska and subsequently caused epizootic mortality in Japanese chum salmon and in two species of landlocked salmon which occur only in Japan (McDaniel et al. 1994). In these two cases, the indigenous salmonids in Norway and Japan were exposed to novel pathogens to which they had little or no immunity. In Washington the pathogens found in cultured salmonids are identical to those known to occur in wild salmon (Amos and Appleby 1999). PSGA (2000) and Carrel (1998) assert that local Atlantic salmon stocks are more likely to carry pathogens than hatchery stocks of Pacific salmon, but this is not supported the scientific literature. Salmonids, including Atlantic salmon, can only carry diseases to which they have been exposed. The New England Atlantic salmon stocks used by Washington growers were certified by federal pathologists to be pathogen -free prior to shipment from east coast hatcheries between 1980 and 1986, inclusive, and have been reared exclusively in the Pacific Northwest for many generations. Their diseases, if any, would be no different than the diseases found in nearby Pacific salmon hatcheries. In addition, Washington regulations require that all broodstocks of hatchery salmon, including Atlantic salmon broodstocks, are examined for pathogens each year (WAC 220 -77; RCW 75.58). Non - indigenous salmon diseases transmitted into the Pacific Northwest by North American stocks of Atlantic salmon have not been reported. Pacific salmonids do not seem to be put to any increased risk of pathogen transmission when exposed to water in which Atlantic salmon have been reared. For example, Rocky 84 Ford Creek near Ephrata, in eastern Washington, is considered one of the premier trout streams in the State but its entire flow consists of effluent from an Atlantic salmon hatchery (J. Parsons, Troutlodge Inc., personal communication). There are no reports of diseased trout in this stream in either the scientific literature or in 'gray' literature. There is no evidence to suggest that hatchery- reared Atlantic salmon have introduced or spread non - indigenous pathogens to native fishes in Washington. With Pacific salmon, Griffiths (1983) observed that outbreaks of serious contagious diseases were normally associated with the intensive culture of fish in a hatchery environment. There are no recorded observations to suggest this would be any different for artificially- propagated Atlantic salmon or rainbow trout. 5.3.5 The scale of artificial propagation Based solely on the enormous number of hatchery- reared salmonids released into rivers and lakes in the Pacific Northwest, the potential for transmission of disease to wild stocks from hatchery- reared Pacific salmon and trout greatly exceeds that of accidentally - escaped farmed Atlantic salmon and rainbow trout in Washington State. This is because escaped Atlantic salmon and rainbow trout constitute an insignificant percentage of all artificially- propagated salmon which end up in natural waters in the area. However, the millions of Pacific salmon which enter the marine waters of Washington each year have not been shown to impose adverse impacts on wild salmonids. Carrel (1998) described escaped Atlantic salmon as'smart bombs, delivering disease right into the bedrooms of wild salmon' in the Pacific Northwest, but this is not supported in the scientific literature. Because Atlantic salmon are propagated in only a few facilities in the Pacific Northwest, compared with the several hundred federal, state, tribal, and cooperative hatcheries rearing Pacific salmon and trout, the primary difference in the disease incidence between artificially- propagated Atlantic and Pacific salmon is one of scale. Mahnken et al. (1998) reported that, since 1980, the number of Pacific salmon released from west coast hatcheries was about two billion fish annually. This number is 4 or 5 orders of magnitude larger than the number of Atlantic salmon which may have escaped from net - pens since 1980 (Table 2). Table 2. Number (in millions) of salmon released or escaped by species and location along the west coast of North America, 1980 -1995 (Data from NRC 1995 and 1996; Thomson and McKinell 1993 -1997; Mahnken et al. 1998; Thomson and Candy 1998). State or Region Atlantic Sockeye Chum Steelhead Pink Coho I Chinook Alaska 0 978 3,885 2 8,610 193 98 Canada BC —0.4 3,930 2,870 17 533 300 721 Pacific Northwest —0.6 52 1,081 359 21 726 4,320 Total —1.0 4,960 7,836 377 9,164 2,219 5,139 Total ( %) 0.0003 16.7 26.4 1.2 30.9 7.5 17.3 Comparing only the number of Pacific salmon released from salt -water net -pens, then the magnitude and geographic distribution of these artificially- propagated Pacific salmon is still much greater than the number and magnitude of Atlantic salmon reared in farms. 85 For example, NRC (1995, 1996) reported that coho salmon were released annually from 18 different marine net -pen sites, Chinook salmon from 13 different sites, and chum salmon from 10 different sites in Puget Sound between Olympia and Bellingham. The annual release from these marine sites between 1980 and 1992 averaged about 10 million fish. These fish had sometimes been exposed to various salmonid pathogens while in seawater, including bacterial kidney disease, vibriosis, and furunculosis. Infections in these fish were often treated with antibiotics prior to their release (PNWFHPC 1988a -d), yet no adverse impacts on wild salmonids have been reported as a result. 5.3.6 Disease control policies in Washington and the USA In Washington all public and private growers of salmon, including Atlantic salmon hatchery operators, are required to adhere to strict disease control polices which regulate all phases of fish culture, from egg take to harvest and /or release (NWIFC /WDFW 1991; NWIFC /WDFW1998). Each year at spawning time, adult salmon at public and private hatcheries must be sampled for viral, bacterial, and parasitic organisms. If any of several reportable organisms are detected in fish at a hatchery, or have been detected within the past five years, transfer of eggs or fish from that facility is prohibited. The movement of fish and eggs across state or international borders is regulated by the USFWS under Title 50 of the CFR, which has stipulations and controls in accord with State regulations (Regulation 50 CFR, Part 16.13). For the case in point, all Atlantic salmon stocks distributed to local growers by NMFS were federally certified by federal pathologists before transfer from New England, and have been annually certified since then under Washington guidelines and procedures. Most of the cumulative body of information pertaining to salmon farming developed in the last several decades has already been integrated into the regulatory processes of Washington State. This scientific information has been incorporated into State regulations relating to farm fish escapes, antibiotic residues in sediments, accumulation of organic wastes on the seabed, importation of non - native and non -local species, and disease management. These and other important regulations and documents pertaining to private salmon farming include: • Final programmatic EIS for fish culture in floating net -pens (WDF 1990) • Recommended interim guidelines for the management of salmon net -pen culture in Puget Sound (WDOE 1986) • Environmental effects of floating mariculture in Puget Sound (Weston 1986) • Environment fate and effects of aquacultural antibacterials in Puget Sound (Weston et al. 1994) • Disease control policies of Washington (NWIFC /WDF 1991) • Disease control policies of the United States ( USFWS 1984) • Fish health manual of the Washington Department of Fish and Wildlife (WDFW 1996) M 5.4 Potential Ecological Impacts of Atlantic Salmon in the Pacific Northwest In areas where Atlantic salmon are indigenous, such as Scandinavia, Great Britain, and eastern North America, adverse genetic and ecological impacts for natural populations of Atlantic salmon have been reported by, inter alia, Gibson 1977; Gross 1998; Hearn and Kynard 1986; Jones and Stanfield 1993; Beall et al. 1989; Heggberget et al. 1993, following programmed releases or escapes of artificially- propagated Atlantic salmon from public hatcheries and private net -pens. The impacts included reduction in genetic adaptation and capacity to evolve in wild Atlantic salmon resulting from interbreeding with artificially- propagated Atlantic salmon, and competition for food and space between wild and hatchery stocks of Atlantic salmon. These adverse effects occurred because both the artificially- propagated and wild salmonid species were Atlantic salmon. Escaped Atlantic salmon on the Pacific coast of North America do not have congeneric wild individuals with which to interact. In the Pacific Northwest region it is the introduction of hatchery stocks of Pacific salmon which have the potential to produce impacts on native Pacific salmon comparable to those found between propagated and wild Atlantic salmon in Europe and eastern North America. Adverse genetic and/or ecological interactions on local wild salmon populations resulting from plants of artificially- propagated Pacific salmonids have been well documented in the Pacific Northwest in papers by Nickelson et al. (1986), Behnke (1992), Koslow (1995), Campton and Johnston (1985), WDFW et al. (1993), and Leider et al. (1997). A series of papers by Thomson and McKinnell (1993, 1994, 1995, 1996, and 1997), Thomson and Candy (1998), and Amos and Appleby (1999) have reported no detrimental effects in the region which can be related to deliberate or accidental Atlantic salmon introductions. 5.4.1 Social interactions between Pacific and Atlantic salmon Gibson (198 1) reported that, from laboratory studies in New England, introduced Pacific steelhead juveniles were more aggressive than Atlantic salmon. In turn Atlantic salmon fry appeared to be more aggressive than coho salmon fry when introduced into open pools, although it was recognized that open pools are not the preferred habitat of coho salmon fry. Beall et al. (1989) in a similar experiment reported that the survival of Atlantic salmon was reduced in the presence of older coho salmon fry. In trials of inter - specific combative behavior in New England, Hearn and Kynard (1986) observed that rainbow troutjuveniles initiated three to four times more aggressive encounters than did Atlantic salmon, and concluded that it would take very large numbers of Atlantic salmon juveniles to displace or even disrupt native species. Jones and Stanfield (1993), in a study conducted in a Lake Ontario tributary once inhabited by Atlantic salmon, reported that their attempts to reintroduce hatchery strains of Atlantic salmon were significantly impaired in the presence of naturalized Pacific salmon juveniles, compared with reintroduction in stream sections where Pacific salmon juveniles had been removed. 87 5.4.2 Predation by Atlantic salmon In a study on farmed fish in Canada BC by Black et al. (1992) stomach analyses revealed that <I% of farmed salmon in net -pens (in this case coho and chinook salmon) contained the remains of fish. Since 1992 scientists of the Canadian federal government have examined the stomach contents of escaped Atlantic salmon recovered in the open waters of BC. Fish remains of any sort were rarely observed, and no confirmed salmonid remains were reported (see Thomson and McKinnell 1993, 1994, 1995, 1996, 1997; Thomson and Candy 1998). This confirms earlier work by Tynan (1981) who examined the stomachs of 93 coho salmon captured after release from a net -pen near Squaxin Island, in South Puget Sound, and reported that only three stomachs contained fish remains, which were identified as smelt. At the NMFS Manchester Research Station in Puget Sound many species of forage fish have been observed seeking refuge from predators in net -pens containing large Atlantic salmon. Among the species observed are known prey of salmonids, such as herring, smelt, candlefish, shiner perch, and tube snouts. These prey species enter the net -pens voluntarily and then grow too large to exit. A report by Alverson and Ruggerone (1997) noted that many thousands of these small fish had been observed in Atlantic salmon net - pens, and had to be removed by hand. Buckley (1999) showed that cannibalism and predation on other salmonids by chinook salmon when feeding was uncommon in Puget Sound waters. It is difficult to imagine that escaped Atlantic salmon, conditioned to a diet of artificial feed pellets and trained to be fed by humans, could have greater predation impacts on juvenile native salmonids than the low impact observed with free - swimming Puget Sound chinook salmon. In the Cowichan River in Canada BC, non - native brown trout became established soon after its first introduction in 1932. Idyll (1942) observed that native salmon and trout, and their eggs, were a significant dietary component of newly- established Cowichan River brown trout, and were the primary food item of large brown trout. Recent evaluations by Wighmtan et al. (1998) of steelhead populations on the cast coast of Vancouver Island showed that the Cowichan River was one of only two rivers (out of 27 evaluated) with a relatively healthy steelhead population. Therefore the successful colonization of the Cowichan River by a highly piscivorous species such as the brown trout has apparently had no adverse impact on steelhead abundance for more than 60 years, whereas concurrent attempts to establish Atlantic salmon in the Cowichan River basin were failures. 5.5 Potential Impacts of Propagated Pacific Salmon Adverse genetic and ecological effects from artificially- propagated Pacific salmon have been documented by, inter alia, Weitkamp et al. (1995), Busby et al. (1996). Hard et al. (1996), Gustafson et al. (1997), Johnson et al. (1997), Myers et al. (1998), and Johnson et al. (1999) in a number of coast -wide status reviews of Pacific salmonids. These status reviews were conducted by NMFS in fulfillment of their responsibilities under ESA. The reviews contained information from the scientific literature which documented known 88 adverse ecological impacts sometimes associated with the artificial propagation and release of Pacific salmon. In recent years, west coast management agencies have eliminated many of the policies which contributed to these adverse effects. However, examining some of the known adverse impacts of Pacific salmon hatchery programs which have not been observed to be a result of Atlantic salmon hatchery programs on the west coast offers an effective demonstration that the ecological and genetic risks associated with Atlantic salmon farming are small in the waters of Puget Sound. The following paragraphs provide a brief review by species of adverse effects of artificial propagation which occurred under the old Pacific salmon hatchery policies. (i) Steelhead trout Hatchery stocks of steelhead have been widely distributed. Few native steelhead stocks exist in the contiguous US which have not had some influence from hatchery operations. For example, Busby et al. (1996) cite the summer steelhead program at the Nimbus Hatchery in Central Valley, California was established with fish from a distant coastal tributary hatchery which was itself earlier established with Lower Columbia River summer steelhead. Howell et al. (1985) reported that over 90% ofthe'wild' steelhead spawning in the Cowlitz River originated in a hatchery, and some of these fish exhibited genetic characteristics of Puget Sound steelhead due to previous transfers of Puget Sound stock to the Cowlitz Hatchery. Chilcote (1997) reported that, since 1980, the percentage of non - native stray hatchery steelhead (from upper Columbia River and Snake River hatcheries) spawning in the Deschutes River had increased to over 70% of the run, while the percentage of native, wild steelhead spawning in the Deschutes River decreased to less than 15 %. Phelps et al. (1997) postulated that introductions of non - native steelhead stocks in Washington, primarily Chambers Creek winter steelhead and Wells and Skamania summer steelhead, may have changed the genetic characteristics of some populations sufficiently so that the original genetic relationships between stocks may have been obscured. Finally, Leider et al. (1987) concluded that the genetic fitness of the wild Kalama River population had been compromised by maladaptive gene flow from excess hatchery escapement. By comparison, no documented adverse effects on steelhead have been reported to result from escapes of Atlantic salmon in Washington or elsewhere. (ii) Chinook salmon About 2 billion hatchery chinook salmon have been released into Puget Sound since 1953, with the stock from the Green River Hatchery being the dominant stock as far back as 1907. Concerns that this strategy may erode genetic diversity was raised by Myers et al. (1998). As recently as 1995, 20 hatcheries and 10 marine net -pen sites throughout Puget Sound regularly released Green River -stock chinook salmon. Busack and Marshall (1995) reported that the extensive use of this stock had an undoubted impact on among - stock diversity within the South Puget Sound, Hood Canal, and Snohomish summer /fall genetic diversity unit (GDU), and may also have impacted GDUs elsewhere in Puget Sound and the Strait of Juan de Fuca. W Rogue River chinook salmon were recently released on the Oregon side of the Lower Columbia River to produce a south - migrating stock to avoid interception in commercial fisheries in Canada BC and Southeast Alaska. However, chinook salmon exhibiting Rogue River fall chinook salmon genetic markers were subsequently observed by Marshall (1997) in several lower Columbia River tributaries, and were estimated to comprise about 13% of the Lower Columbia River naturally- produced chinook salmon sampled in 1995. Marshall et al. (1995) had earlier stated that most of the naturally - spawning spring chinook salmon in Lower Columbia River tributaries were hatchery strays. Adverse impacts resulting from the introduction of artificially - propagated fish into native populations of chinook salmon were identified as a primary concern by the NMFS Biological Review Team during the recent review of the status of west coast chinook salmon populations (Myers et al. 1998). There is no documented evidence of adverse effects on chinook salmon resulting from escaped Atlantic salmon in Washington or elsewhere. (iii) Chum salmon Johnson et al. (1997) reported that five hatchery stocks and several wild populations of chum salmon outside the Hood Canal, but which received eggs from Hood Canal hatcheries for several years, exhibited genetic frequencies more similar to those in Hood Canal hatchery populations than to populations in nearby streams not receiving Hood Canal hatchery stocks. Their analyses of gene frequency patterns were consistent with the hypothesis that egg transfers between hatcheries and out - plantings of Hood Canal stock fry had genetically influenced the receiving populations. According to Phelps et al. (1995) such transfers were terminated because of the potential jeopardy to wild gene pools through interbreeding. However, there is no documented evidence of adverse effects on chum salmon resulting from escaped Atlantic salmon in Washington or elsewhere. (iv) Coho salmon Weitkamp et al. (1995) noted that the NMFS Biological Review Team was unable to identify any remaining natural populations of coho salmon in the lower Columbia River below Bonneville Dam, due in large part to persistent and extensive hatchery programs. A recent survey by NRC (1999) of coho salmon spawning habitat in the lower Columbia River estimated that about 97% of recovered spawned -out carcasses originated from hatchery releases. Hatchery fish were observed in high percentages in streams up to 45 miles from the nearest hatchery. In many streams, wild, native coho salmon were not observed at all. In an earlier similar survey by NRC (1997) in Hood Canal, over 50% of all spawning coho in streams within a 10 -mile radius of a net -pen release site were fish released from the net -pen as juveniles 18 months earlier. Kostow (1995) stated that hatchery programs in Oregon may have contributed to the decline of wild coho salmon by supporting harvest rates in mixed -stock fisheries which were excessive for sustained wild fish production, and by reducing the fitness of wild populations through interbreeding of hatchery and wild fish. Furthermore, they may have reduced survival of wild coho salmon juveniles in Oregon through increased competition E for food in streams and estuaries, through attraction of predators during mass migrations, and through initiation of disease problems. Weitkamp et al. (1995) also reported that artificial propagation of coho salmon had appeared to have substantial impact on native coho salmon populations to the point where it was difficult for the NMFS Review Team to identify self - sustaining native stocks in Puget Sound, as over half the returning spawners originated in hatcheries. Spawn- timing had been advanced by selective breeding so that most hatcheries met their quotas for eggs by early November, and fish arriving at the hatchery with the later run (which would be coincidental with the spawn -time of the wild or native fish) were not propagated. As a result of such practices, according to Flagg et al. (1995), segments of hatchery coho salmon populations which historically returned as late as January through March have disappeared from many river systems, resulting in a significant loss of life history diversity. Again, for comparison, there is no documented evidence of adverse effects on coho salmon resulting from escaped Atlantic salmon. (v) Trouts Long -term introductions of rainbow trout into western streams originally inhabited only by cutthroat trout have resulted in widespread extinctions of native cutthroat trout through introgressive hybridization, according to Leary et al. (1995). They noted that hybridization between introduced brook trout and bull trout is widespread in the western USA, and usually produces sterile hybrids. Behnke (1992) noted that introduced brown trout had commonly replaced interior subspecies of cutthroat trout in large streams throughout the same region, and introduced brook trout were the most common trout to be found in many small streams. The situation regarding attempts to establish Atlantic salmon populations in the West is much different. In summary, MacCrimmon and Gots (1979) described frequent attempts and failures to introduce Atlantic salmon to the western States, many of which occurred in the same river systems and at the same time as the introductions noted above. Since then no recent introductions, accidental or not, have succeeded and, most importantly, no known adverse impacts on indigenous species by Atlantic salmon have been reported in the literature. 5.6 Adverse Impacts of Non - indigenous Fish Introductions As many as 50 species of non - native fish are successfully established in the western US (Table 3). The Atlantic salmon is not one of those listed. Some adverse impacts associated with the establishment of these species are discussed below. None of these negative impacts has been associated with the artificial propagation of Atlantic salmon in the Pacific Northwest. 91 Table 3. Status of non - native fish introductions in the Pacific Northwest vis -a -vis their behavior relative to Pacific salmonids (Data after Behnke 1992, Lever 1996, ODFW 1999, WDFW 1999, Dill and Cordone 1997) Non - Native Species Naturalized in Wasbington Naturalized in Oregon Naturalized in California Predator Competitor Hybridize Atlantic salmon Non-native rainbow X X X X X X Non-native cutthroat X X X X X X ahotan cutthroat X X Westslo e cutthroat X X X X Brown trout X X X X X X Brook trout X X X X X X Lake trout X X X X X American shad X X X X hreadfin shad X Lake wbitefish X Arctic grayling X X Grass pickerel X X Northern pike X X X Striped bass X X X White bass X Common carp X X X X Grass carp X X Tench X X Brown bullhead X X X X X Black bullhead X X X X X Yellow bullhead X X X X X Flathead catfish X X X X Blue catfish X X X Channel catfish X X X X X White catfish X X X X Largemouth bass X X X X X Smallmouth bass X X X X X Warmouth bass X X X X X Rock bass X X X Redeye bass X Northern spotted bass X Alabama spotted bass X Black crappie X X X X X White crappie X X X X X Green sunfish X X X X X Blue gill X X X X X Pumpkinseed X X X X X edear sunfish X i scale to erch X Yellow erch X X X X X Walle e I X I X X X X 92 ODFW/NMFS (1998) documented that many introduced non - native species were harmful to native salmon. For example, walleye, bass, perch, sunfish, brown trout, and brook trout, among others, are all now well - established in Northwest waters and are well - known predators and /or competitors of native salmon and trout. Beamesderfer and Nigro (1988) and Beamesderfer and Ward (1994) estimated that walleye and smallmouth bass introduced into the John Day Reservoir of the Columbia River consumed an average of 400,000 and 230,000 juvenile salmonids, respectively, each year. Daily et al. (1999 in prep.) reported that juvenile salmonids from seven ESUs currently listed as threatened or endangered under ESA must migrate through the John Day Reservoir; and in some coastal lakes in Oregon the summer rearing of coho salmon fry no longer occurred due to predation by introduced largemouth bass. Seiler (WDFW, personal communication) has observed that introduced bass eat out- migrating salmon, including juvenile chinook salmon, as they pass through the Lake Washington Ship Canal in Seattle, WA. There is no documented literature which shows that Atlantic salmon in western states prey on juvenile native salmonids. In 1997 and 1999, in response to the escape of some net -pen Atlantic salmon, WDFW suspended fishing regulations concerning size and bag limits for these fish. Licensed anglers fishing in open management zones were permitted to keep all Atlantic salmon they could catch, of whatever size (WDFW 1997c, 1999). Suspension of fishing regulations for an introduced, non - native species in waters inhabited by native salmonids at some period of their life cycle is an appropriate management which WDFW has used before. For example, freshwater angling regulations for non - native brook trout in Washington were recently relaxed to increase harvest of this species, and regulations for non - native shad, perch, crappie, and carp have long -since been dismissed entirely. Catch limits and close seasons for non - native salmonids in Washington (such as brown trout, golden trout, lake trout, landlocked Atlantic salmon, California- strain rainbow trout, and grayling) have given these species many of the same protections given to native salmonids. Furthermore, several non - native species known to prey on salmonid juveniles (such as smallmouth and largemouth bass, walleye, and channel catfish) are currently managed for sustained natural reproduction through regulations which limit the take of large individuals which have the greatest reproductive potential (WDFW 2001). From a review of the literature, Atlantic salmon have far less potential for adverse impacts than all the non - native species noted above. Therefore, to decrease unnecessary adverse impacts on listed native salmonids by non - indigenous fish, it would not be an inconsistent strategy for states in the Pacific Northwest to suspend regulations for the harvest of all non - indigenous fish by licensed anglers. 93 5.7 A Perspective of Salmon Culture in Northwest Waters Most of the concerns for the negative impacts of Atlantic salmon on native salmon in the Pacific Northwest are hypothetical. They are associated with the belief that artificially - propagated fish are bigger, stronger, and more vigorous that wild fish. Although this opinion has been generally disproved in a multitude of studies, many studies and reviews, among them WDFW et al. (1993) and the NMFS Status Reviews, have shown that adverse impacts from hatchery stocks of Pacific salmon are likely to occur if and when hatchery fish comprise a large portion of the total population. Therefore, it is instructive to compare the numbers of artificially- propagated Pacific salmon released each with the number of Atlantic salmon estimated to escape each year to give a perspective as to where and when the greatest risks actually occur, and to what degree, keeping in mind recent changes in hatcheries strategies in the Pacific Northwest which will likely reduce the impact of hatchery fish on wild fish. Mahnken et al. (1998) reported that several billion Pacific salmon were released from freshwater hatcheries and marine net -pens in North America each year (see Table 2). Although Washington, Oregon, Idaho, and California had more salmon hatcheries, the total number of fish released in the contiguous States of the Pacific Northwest was dwarfed by the vast number of hatchery salmon released in Alaska each year. McNair (1997, 1998, and 1999) documented the annual release of about 1.4 billion hatchery salmon into natural rearing areas since 1996. Pacific salmon have been released from hatcheries with the understanding that they must compete for food and habitat in common with native wild salmon to survive. Until recently the capacity of the ocean pastures were thought to be limitless. Recent investigations by Heard (1998), Cooney and Broduer (1998), and Beamish et al. (2000) show that food availability in the ocean fluctuated over time and might be limiting salmon abundance. Bisbal and McConnah (1998) proposed fishery managers planning to release vast numbers of fish from hatcheries should take these fluctuations into account. Compared with the great numbers of Pacific salmonids released each year into the marine ecosystems, there is no evidence in the literature that the few Atlantic salmon which escape pose any competitive threat to native Pacific salmon for forage or habitat. The majority of Atlantic salmon escapes have occurred in Puget Sound. However, the number of escapees is extremely low compared with the number of Pacific salmon deliberately introduced into the ecosystem. NRC (1995, 1996) documented that the total number of cultured chinook. coho, and chum salmon released into Puget Sound tributaries by various fisheries agencies between 1980 and 1992 exceeded 2.2 billion in number. Although data are not yet available through the year 2000, it is predictably over 3 billion. For comparative purposes, if the total number of Atlantic salmon which escaped into Puget Sound since 1980 was represented on a histogram by a bar one inch high, the total number of Pacific salmon released into Puget Sound and its river basins since 1980 would be a bar about 250 feet high. Comparison with the 13.5 billion hatchery fish released into Alaskan waters since 1990, using annual data published by 94 ADF &G between 1991 and 2000, is even more dramatic, and would require a bar almost one quarter of a mile high. The adverse ecological and genetic interactions associated with abundant releases of hatchery- reared Pacific salmon are well- documented and present a more serious risk for native salmonids. There is no evidence in the literature which associates adverse impacts with the escape of Atlantic salmon in the Pacific Northwest, or that they even pose a serious threat. NRC (1995) reported that over 240 million small, non- migratory, hatchery coho salmon were released into Puget Sound tributaries between 1980 and 1992, which averaged about 18 million annually. FPC (1999) since reported that the number of unsmolted coho salmon was reduced by over half, due to the previously mentioned changes in hatchery strategies. Nonetheless, these artificially- propagated fish have to survive by competing for natural food and rearing space with native salmon for about 18 months. Using typical wild coho salmon life history data (ODFW 1982), such as egg -to- fingerling survival levels of 10% and a fecundity of 4000 eggs per female, it would take every year about 92,000 mature, successful Atlantic salmon spawners (1:1 female:male ratio) to produce enough fry to equal the numbers of artificially- propagated non - migrant coho salmon planted in Puget Sound rivers every year. Applying the same calculations on a more local scale, FPC (1999) reported that about 7,500,000 coho salmon fry of hatchery origin were planted in the Green River between 1993 and 1996. To produce an equal number of Atlantic salmon juveniles, it would be necessary for over 9,000 mature Atlantic salmon adults to escape and spawn successfully in the Green River each year. However, Thomson and Candy (1998) recaptured fewer than 20 mature Atlantic salmon in all Washington rivers systems during 1997, although some were not surveyed completely. BMPs for net -pen salmon farming continue to stress the importance of preventing escapes (BCSFA 1999), but any potential adverse impacts associated with escaped Atlantic salmon cannot begin to approach the potential impacts of fish released from Pacific salmon hatchery programs, even when recent changes in hatchery strategies are considered Volpe et al. (2000) recovered less than 100 naturally- spawned juvenile Atlantic salmon during counts of salmon juveniles in the Tsitika River in Canada BC. Noakes (1999) noted more than 10,000 juvenile Pacific salmonids were observed in this river in the same survey. The juvenile Atlantic salmon made up approximately 1% of the juvenile salmonids in the river and presented no competition to native salmonids for food or rearing space. No naturally- produced Atlantic salmon have been observed in Washington rivers to -date, although surveys have not been as vigorous as those in Canada. The success of a hatchery or net -pen facility, as well as the degree to which hatchery fish potentially impact wild fish, is largely determined by how well fish survive in the wild after release. Some hatchery programs are very successful at producing fish for harvest. Johnson et al. (1997) noted that hatcheries in Alaska, through extremely successful early - rearing strategies, produced prodigious numbers of adult chum and pink salmon, two 95 species which normally have juvenile to adult survival rates of <0.5 %. The Hidden Falls Hatchery in Southeast Alaska has consistently experienced survivals of 3 —8% with chum salmon (Bachen 1994), resulting in this single facility producing more than 22% of all the chum salmon, wild and hatchery, caught in the fisheries of southeast Alaska (Johnson et al. 1997). McNair (1998) reported that 93.6% of all pink salmon caught in Prince William Sound in 1997 were artificially propagated, and that for all salmon harvested in common property fisheries throughout Alaska that year, 22% of the coho salmon, 30% of the pink salmon, and 65% of the chum salmon originated in hatcheries. Overall, she reported that hatcheries contributed 26% of all salmon harvested in Alaska in 1997. In 2000, McNair (200 1) reported that 34% of the total salmon catch in Alaska was produced in Alaskan hatcheries. Additional contributions to Alaska's commercial harvest from hatcheries in British Columbia, Washington, Oregon, and Idaho were not include in this analysis. In Washington, WDFW (2000) estimated that hatcheries provide about 75% of all coho and chinook salmon harvested, as well as 88% of all steelhead harvested. As west coast hatcheries put enough artificially- propagated salmon into the natural environments to produce a significant proportion of the harvest in Alaska, and the overwhelming proportion of fish harvested in Washington, it is not possible that the relatively inconsequential competition for natural resources from present levels of escaped Atlantic salmon could even be evaluated. Given that it is necessary for millions of hatchery Pacific salmon to compete successfully with wild salmon in natural environments to survive and contribute to the economies of Alaska and Washington, expressions of concern by ADF &G (1999) regarding competition for food from relatively small numbers of escaped Atlantic salmon appear misdirected. A review of the literature reveals that the potential for artificially - propagated Pacific salmon released from public hatcheries to pose adverse impacts with wild Pacific salmon through competition for food is far greater than the potential for competition posed by escaped Atlantic salmon. 5.8 NMFS Biological Status Reviews of West Coast Pacific Salmon Stocks Since 1991 14 Biological Status Reviews have been published by NMFS as part of the its federal obligation under ESA. These Reviews are individual scientific studies of the current status of all anadromous salmonid populations on the west coast of the USA. These are generally regarded as the most complete scientific reviews of their kind ever published. They form the basis for NMFS actions concerning ESA listing determinations, as well as the scientific basis for NMFS testimony for litigation and courtroom challenges to proposed and implemented listings under ESA. In these Reviews, experienced federal scientists have identified many factors which have adverse effects on the Pacific salmonids of the west coast. The potential biological impacts of cultured salmon have continuously been identified as a primary factor (see Hard et al. 1992, and Waples 1991). Atlantic salmon farms have not been identified as the cause of adverse effects in any of the 14 Reviews conducted to -date, which cover 58 separate ESUs for Pacific salmon species, or factors in the decline of west coast populations of chinook salmon or steelhead (NMFS 1996, 1998). Mt 6. POST SCRIPT In 1996 a group of organizations brought suit before the PCHB in the State of Washington against WDOE, WDFW, and salmon farmers in the State. The suit (PCHB Nos. 96 -257 through 96 -268) challenged the issuance of NPDES permits to the salmon farmers. The basis of the suit by the appellants was a series of allegations regarding conflict with other resources and unacceptable environmental risks associated with the culture of Atlantic salmon, the effects of waste on the water column and benthos, and damage to other resources, including fish and shellfish. Following months of testimony by experts, on May 27, 1997 the PCHB denied partial summary judgement to the appellants because of a genuine issue of material fact as to whether escaped Atlantic salmon 'shall cause or tend to cause pollution' under State law, and whether they constitute 'a man -made change to the biological integrity of State water' under federal law (PCHB 1997). The PCHB found that, 'the Permittees' facilities do not create unresolved conflicts with alternative uses of Puget Sound resources as contemplated by RCW 43.32C. 030(2) (e). The existence of commercial salmon farms as permitted uses does not preclude other beneficial uses in Puget Sound, such as shellfish harvesting, commercial or sport fishing, navigation or recreational boating. Likewise, the existence of the salmon farms does not operate to the exclusion of available resources, such as native salmon runs, sediment and water quality, or marine mammals. In short, salmon farming in Puget Sound does not present the citizens of the State of Washington with an "either /or" choice with respect to other beneficial uses and important resources.' The Board issued its Final Order on the matter on November 30, 1998 (PCHB 1998) and found: 'no evidence that Permittees' facilities have impacts that effectively exclude other beneficial uses of available resources of Puget Sound. The escapement of Atlantic salmon from Permittees' facilities absent large regular releases in the future does not pose an unacceptable risk to native Pacific salmon in terms of competition, predation, disease transmission, hybridization or colonization.' This decision by the PCHB was not substantially different from that of the authors of the British Columbia Salmon Aquaculture Review (EAO 1997) which concluded that salmon aquaculture, as currently practiced in BC, did not pose unacceptable risks to the environment. The PCHB finding in favor of the `performance standard' on which the NPDES permit system in Washington State is based also supports the decision by the BC government to work towards similar standards. Organic and inorganic loading of the benthos, the transport, fate and biological effects of pharmaceuticals, and dissolved nutrient effects on phytoplankton are important public concerns which have long been recognized and studied. 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W. 1981. Broodstock programs at Manchester Fisheries Laboratory, p.31 -33. In T. Nosho (ed.), Salmonid Broodstock Maturation. Washington Sea Grant Publication WSG —WO 86-1. Waples, R.S. 1991. Pacific salmon, Oncorhynchus spp, and the definition of "species" under the Endangered Species Act. Mar. Fish. Rev. 53(3):11 -22. WDOE (Washington Department of Ecology). 1986. Recommended interim guidelines for the management of salmon net -pen culture in Puget Sound. Department of Ecology, Olympia, WA. WDF (Washington Department of Fisheries). 1950, Annual Report for 1949. Seattle, WA. WDF (Washington Department of Fisheries). 1953. Annual Report for 1951. Seattle, WA. WDF (Washington Department of Fisheries). 1954. Annual Report for 1953. Seattle, WA. WDF (Washington Department of Fisheries). 1990. Final programmatic environmental impact statement for fish culture in floating net -pens. Washington Department of Fisheries, Olympia, WA, 161 p. WDFW (Washington Department of Fish and Wildlife). 1993. Atlantic salmon: a fish management perspective. Internet document www:wa.gov /wdfw /fish /atlantic /toc.htm. WDFW (Washington Department of Fish and Wildlife). 1996. Fish health manual. Fish Health Division, Washington Department of Fish and Wildlife, Olympia, WA, 69 p. WDFW (Washington Department of Fish and Wildlife). 1997c. Escaped Atlantic salmon provide fishing opportunity. WDFW News Release, July 21, 1997. Internet document http://www:wa.gov/wdfw/do/ju]97/atlantic.htm. WDFW (Washington Department of Fish and Wildlife). 1999, Atlantic salmon escape. WDFW News Release, June 15, 1999. Internet document www:wa .gov /wdfw /do /jun99 /junI599a.htm. WDFW (Washington State Department of Fish and Wildlife). 2000, WDFW Hatcheries program: statistics. Internet document http: / /www.wa.gov.wdfw /hat /hat - stat.htm. WDFW (Washington Department of Fish and Wildlife). 2001. Fishing and shell - fishing rules. Internet document www:wa .gov /wdfw /fish/regs /fishregs.htm. 123 WDF /WDW/W WTIT (Washington Department of Fisheries /Washington Department of Wildlife/Westem Washington Treaty Indian Tribes). 1993. Washington State salmon and steelhead stock inventory, 1992. Washington Department of Fish and Wildlife 212 p. (Available from Washington Department of Fish and Wildlife, P.O. Box 43151, Olympia, WA 98504). Weitkamp, L., T.C. Wainwright, G.J. Bryant, G.B. Milner, D.J. Teel, R.G. Kope, and R.S. Waples. 1995. Status review ofcoho salmon from Washington, Oregon, and California. NOAA Tech. Memo. NMFS — NWFSC -24, 258 p. Weston, D.P. 1986. The environmental effects of floating mariculture in Puget Sound. Univ. Washington School of Oceanography Report 87(16), 148 p. Weston, D.P. 1996. Environmental considerations in the use of antibacterial drugs in aquaculture. In D.P. Baird, M. Beveridge, L, Kelly, and J. Muir (eds.), Aquaculture and Water Resource Management. Blackwell Science Publications, Oxford. Weston, D.P., D,G. Capone, R.P. Herwig, and J.T. Staley. 1994. The environmental fate and effects of aquacultural antibacterials in Puget Sound. NOAA Grant Publication No. NA26FDO109 -01, 19 p. Wightman, 1.C., B.R. Ward, R.A. Ptolemy, and F.N. Axford. 1998. A recovery plan for east coast Vancouver Island steelhead trout. Ministry of Environment, Lands and Parks, Nanaimo, BC., 132 p. Wilkins, N.P., H.P. Courtney, and A. Curatolo. 1993. Recombinant genotypes, in back - crosses of male Atlantic salmon x brown trout hybrids to female Atlantic salmon. J. Fish Biol. 43(3):393 -399. Wood, J.W. 1979. Diseases of Pacific salmon, their prevention and treatment (Third edition). Washington Department of Fisheries, Hatchery Division Report, Olympia, 82 p. Wydoski, R.S., and R.R. Whitney. 1979. Inland fishes of Washington. Univ, Washington Press, Seattle, WA, 220 p. Youngson, A.F., J.H. Webb, C.E. Thompson, and D. Knox. 1993. Spawning of escaped farmed Atlantic salmon (Salmo salar): hybridization of females with brown trout (Salmo trutta). Can. J. Fish. Aquat. Sci. 50(9):1986 -1990. Post Script FAG (Environmental Assessment Office, Canada BC). 1997. British Columbia salmon aquaculture review. Environmental Assessment Office, Government of British Columbia, 836 Yates Street, Victoria, BC V8V 1X4. Parametrix. 1990. Final programmatic environmental impact statement fish culture in floating net -pens. Prepared by Parametrix Inc., for Washington State Department of Fisheries, 115 General Administration Building, Olympia, WA 98504, 161 p. PCHB (Pollution Control Hearing Board of Washington). 1997. First Order on Summary Judgement, PCHB No. 96-257 et seq., NPDES Permit Appeals, May 29, 1997, 22 p. PCHB (Pollution Control Hearing Board of Washington). 1998. Final Findings of Fact, Conclusions of Law and Order, PCHB No. 96-257 et seq., NPDES Permit Appeals, November 30, 1998, 46 p. Weston, D.P. 1986. The environmental effects of floating mariculture in Puget Sound, Univ. Washington School of Oceanography Report 87(16), 148 p. 124 Winsby, M., B. Sander, D. Archibald, M. Daykin, P. Nix, F.J.R. Taylor, and D. Munday. 1996. The environmental effects of salmon netcage culture in British Columbia. Prepared for the Ministry of Environment, Lands and Parks, Environmental Protection Department, Industrial Waste /Hazardous Contaminants Branch, 1106 -1175 Douglas Street, Victoria, BC, 214 p. 125 o Pt,tMi OCO4* w UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration a Br NATIONAL MARINE FISHERIES SERVICE r +hs of � Northwest Fisheries Science Center 2725 Montlake Blvd. East Seattle WA 98112 January 13, 2012 Brian Lynn Coastal /Shorelands Section Manager Shorelands and Environmental Assistance Program Washington State Department of Ecology PO Box 47600 Olympia, WA 98504 -7600 Dear Mr. Lynn, Thank you for your email dated November 22, 2011, requesting current scientific information about frnfish net pen aquaculture. We understand that this request is made in response to Jefferson County's findings on net pen aquaculture drafted as part of their Shoreline Master Program (SMP) update. NOAA supports the development of sustainable marine aquaculture within the context of our multiple stewardship missions and broader social and economic goals. As with any activity, there are risks associated with marine aquaculture. However, with existing regulations, proper farm management practices, appropriate siting, and consistent monitoring, these risks are manageable, as is documented by the 40 year track record of net pen facilities operating in Washington State. NOAA has published two scientific technical memorandums analyzing the effects of net pen Atlantic salmon farming in the Pacific Northwest (Nash 2001, Waknitz 2002). Together, these documents assess the risks associated with salmon farming, identify best management practices to minimize risks, and find no harm to ESA - listed salmonids from the operations of existing farms. The Jefferson County analysis acknowledges these documents, but also comments that they are dated and newer literature should be considered. NOAA agrees that newer literature must be considered, but maintains that the science in the technical memorandums is still valid. NOAA is in the process of producing an updated and expanded review of the environmental effects of marine finfish aquaculture that should be ready for the public this summer. In addition, computer models to aid aquaculture siting have been developed and are being used to understand single farm and cumulative impacts to marine areas due to fish farming. Nothing in the newer literature negates the findings in the two older NOAH documents. In fact, new technologies and practices have actually reduced many of the risks identified. Furthermore, new frameworks are available for integrated management of cultured and wild fish populations (ef K. Lorenzen et al. 2012, Biological Reviews). ® Printed on Recycled Paper QUO We offer the following in response to the risks called out in the Jefferson County analysis: 1. Biodeposits — food and feces Technological advances in both feeds and feeding practices have minimized these risks. New feeds are well assimilated by fish leading to a reduction in waste production. Farms utilize underwater cameras to monitor feeding behavior of fish, This allows managers to reduce feeding rates as fish are satiated, reducing the amount of excess feed that can reach the benthos. Since feed costs can amount to over half the cost to raise fish in captivity, there is strong financial incentive for companies to insure that feed is not wasted. Farms pay a third party to conduct video surveys and collect benthic samples to demonstrate that sites do not have any net increase in bio- deposits under cage lease areas. All sediment monitoring reports are submitted to Washington State Departments of Ecology (Ecology) and Natural Resources, 2. Chemical Use - pesticides, pharmaceuticals, etc For the most part, antibiotics are no longer used by Atlantic salmon farmers in Washington State. Instead, fish are vaccinated for specific diseases that are known to cause problems. If salmon farmers wanted to use antibiotics they have to be prescribed on a case by case basis by a veterinarian and are only approved to treat an identified condition. Antibiotics are not used prophylactically with fish in the US. 3. Disease - bacteria, viruses Monitoring of fish health and vaccinations reduce risk of disease. In addition, better husbandry, diets and selectively bred fish, reduce the susceptibility of farmed fish to diseases. Treatment has already been discussed. National Pollutant Discharge Elimination System ( NPDES) permits issued by Ecology call for the mandatory reporting of approved chemical use and reporting of emergency disease occurrences. 4. Parasites - sea lice We don't generally find sea lice in Puget Sound because of its relatively low salinity (salinity disrupts sea lice reproduction). If sea lice became an issue then treatment could be authorized by a veterinarian using either a mix of freshwater and hydrogen peroxide, or a commercial product such as Slice. Other parasites are treated with freshwater baths sometimes with hydrogen peroxide added or another FDA approved method. NPDES permits issued by Ecology call for the mandatory reporting of approved chemical use and reporting incidence of sea lice infestations. 5. Escapement - GMOs, breed /compete with natives No GM fish are approved to be grown in the US. The current petition before the FDA to allow GMO fish to be sold in the US does not include a request to grow them here. The request is to grow them in closed land -based systems in Panama, and import the fillets. There is no request to raise GMO fish in the US and it is unlikely that one will be made for salmon in net -pens. There is no evidence of escaped Atlantic salmon breeding or outcompeting native Pacific salmon (Waknitz 2002) in the Pacific Northwest. Atlantic salmon are a different species and cannot hybridize in nature with Pacific salmon. Genetic impact models for native fish escaping in to the wild have been developed and can be used to determine the potential impacts and risk of these escapes. Should they become necessary, management strategies to reduce the risk of escape of native fish can be developed. Finally, Aquaculture Finfish permits issued by the Washington State Department of Fish and Wildlife and NPDES permits issued by Ecology require the development of Employee Fish Escape Prevention Plans, Fish Escape Reporting Procedures and Accidental Fish Escape Rapid Recapture Plans. 6. Impacts to Puget Sound — low dissolved oxygen, shellfish beds, forage fish, kelp & eelgrass, mammals, ongoing restoration efforts Existing regulations, proper siting, and ongoing monitoring minimizes ecological risk of farms. The effectiveness of this three pronged approach is demonstrated by findings showing that there are no effects to these marine resources by existing farms. The amount of oxygen removed, and nutrients added to the water by a salmon farm are very small. Typically it is not possible to detect a change in any of these variables farther than 100 meters from the net -pens. 7. Conflicts with adjacent shoreline uses such as aesthetics, lighting, glare, noise, and odor. NOAA concurs that such risks are present and are site specific. Appropriate mitigation measures could be developed on a case by case basis. The ongoing debate in the scientific literature about the effect of net pen aquaculture can cause confusion about these issues, particularly when problems in other geographic locations are extrapolated to Washington State. To assist in interpretation of the literature, we offer to meet with interested County Commissioners and answer questions about the science surrounding net pen aquaculture. We would also recommend a regional working group to assist in reviewing and updating guidelines for sustainable marine net pen aquaculture and would offer our participation in such a group. In order to document existing regulations, this group should consist of appropriate staff from State agencies with regulatory authority over net pen aquaculture, specifically Department of Ecology, Department of Natural Resources, and Department of Fish and Wildlife. Finally when the upcoming publication about marine cage culture and the environment is finished we would be happy to provide you with a copy. This publication offers a comprehensive review of water quality, benthic sediment, marine life, contaminant, and management issues associated with net pen aquaculture. It is expected to be released in the next 6 -8 months and will be valuable for use in establishing regional guidelines. We also would welcome your agency's involvement with impact and siting models as they evolve. NMFS is one of the lead agencies in Puget Sound involved in protecting, improving, and restoring marine species, habitats, and ecosystems. We look forward to continued coordination with the Department of Ecology and Jefferson County in support of the timely and successful implementation of the LA -SMP. Sincerely, Walt Dickhoff Director Resource Enhancement & Utilization Northwest Fisheries Science Center `) ^� Michael Rust Science Coordinator Office of Aquaculture NOAA Fisheries Literature Cited Lorenzen, K., M.C.M. Beveridge, and M. Mangel. 2012. Cultured fish: integrative biology and management of domestication and interactions with wild fish. Biol. Rev. Early View 5 Jan 2012. Nash, C.E. (editor). 2001. The net -pen salmon farming Industry in the Pacific Northwest. U.S. Dept. Commer., NOAA Tech. Memo. NMFS - NWFSC -49, 125 p. Waknitz, F.W., T.J. Tynan, C.E. Nash, R.N. Iwamoto, and L.G. Rutter. 2002. Review of potential impacts of Atlantic salmon culture on Puget Sound Chinook salmon and Hood Canal summer -run chum salmon evolutionarily significant units. U.S. Dept. Commer., NOAA Tech, Memo. NMFS- NWFSC -53, 83 p. a STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Box 47600- Olympia, WA 98504 -7600 360- 407 -6000 - 711 for Washington Relay Service ^ Persons with a speech disability can call 877- 833 -6341 January 31, 2013 Cathy Lear Clallam County Community Development 223 East 4!h Street Port Angeles, Washington 98362 The following comments are responsive to Clallam County's November 2012 Shoreline Master -- — Program Final Draft, the proposed update to the 1992 Clallam County SMP. We recognize — extensive revisions have been made to the earlier version fiom last February. Most notably, perhaps, are revisions to the Environment Designation system, and al90 the parsing out safety and habitat protection in the buffer zone provisions. Ecology's comments.will address these briefly. We will make suggestions about residential development provisions and about public access. We will also include a number of comments about the aquaculture use definitions, policies, and regulations in Chapter 3, 5, and 7. As we are doing additional work to clarify guidance on Channel Migration Zones, our comments in this area will be lfmited. Introductory overview Clallam County and their consultants have done commendable work to strike a balance between the need to protect ecological functions and to allow continuing development and use of Ciallani County's extensive shoreline areas. We. especially appreciate the degree to which the County has asked for, listened to, and incorporated appropriate suggestions fi-om the public, Tribal governments, and the various resource agencies such as WDFW and WDNR. The Program Overview and introduction to the SMP in Chapter 1 is concise, helpful, and on point as an orientation for citizens. These pages clearly describe the purposes and background of shoreline management in both practical and legal terms. Pictorial and schematic information combined with the text communicates well the significance of shoreline regulation. W7_° a9 In Chapter 1.6, a helpful addition at the fiont end (or elsewhere as appropriate) should explain to readers the distinction between "uses" and "development." These simple words are also fundamental terms as applied per RC W 90.5 S, and development of an SMP requires parsing them correctly, and not conflating as if they were the same. Both uses and development are regulated by SMP provisions, while each is distinct. Based on conversations we have had with the City of Forks, Chapter 1.8 appears to be a place for adding language that describes the linkage between County and City shoreline regulations, once agreements have been made final on how that works and limitations as appropriate. Ocean Management We have previously talked about adding a "placeholder" to the Applicability section at the front of the document. Pursuant to WAC 173 -26 -(360) , a brief statement should be added to ensure everyone understands that Clallain County shoreline jurisdiction extends waterward from the OHWM to the three mile limit in the Pacific Ocean, recognizing that shoreline jurisdiction overlaps with other state and federal management systems. This marine aquatic jurisdiction needs explicit annotation. It is not obvious based on ownership of shoreland areas by the federal government of the Olympic National Park, and by Makah and Quileute Tribal Reservations. Clallam County has no permitting authority on the landward side of OHWM because of these. However the County does have authority waterward to the state limit, despite the overlapping management overlay of the Olympic Coast Marine Sanctuary and the fact underwater state lands are held by Washington Department of Natural Resources. If Marine Spatial Planning efforts proceed as intended at the statewide level, subsequent updates of your Master Program may find useful applications for addressing various large scale proposals in the ocean environment at some point in the future. Aquaculture Provisions in Chapters 3, 5, and 7 The following comments relating to the draft aquaculture provisions were compiled and summarized by Cedar Bouta after consultation with Lori LeVander, Perry Lund, and myself, More detailed comments will be attached, and we are available if the County would like to discuss any or all of these comments. 1. Overall, the SMP contains some good policies and regulations. More simplification would help avoid conflicts with existing state and federal regulations. 2. Definitions a. Definitions related to aquaculture are overly complex and in some cases don't meet statute or SMP Guidelines. b. There needs to be more work ensuring the finfish aquaculture- related definitions are clear and applied consistently throughout the SMP. 3. The proposed SMP language does not comply with WAC 173 -26- 241 (3) (b). More work is needed to cross - reference the draft SMP with the WAC provisions regarding commercial geoduck aquaculture. 4. Net pen SMP language pulls from the 1986 interim siting guidelines. We appreciate that they are cross - referencing with that document, which is still a useful reference. However, there are newer best management practices, PCHB rulings, sediment monitoring data, and other sources of data and information that also need to be considered. 5. We believe some of the current SMP language is contrary to current state and federal laws, and would amount to a de -fact ban on net pens. We believe such a ban is not warranted based on current science or 25+ years of operational data from finfish net pen facilities operating in waters of Washington State, 6. Only the legislature can define what development is or make exemptions. Some of the wording in Section 3.2.3 Regulations (94 and 5) appear to create new exemptions from permit requirements, which is an authority reserved to the Legislature by statute. We note the language in Regulation #8 on page 3 -6 could appropriately be moved up to a more introductory position among the policy provisions. As we discussed during the January 15, 2013 Advisory Committee meeting at Port Angeles, many of the proposed SMP aquaculture provisions are reiterative to regulations or guidance from different state and federal agencies. We noted that, while including these provisions in the County's SMP may be allowable, there are reasons to proceed with caution in doing so. The Department of Community Development becomes responsible for evaluating large amounts of technical information, and, making permit decisions for actions which are addressed elsewhere. Technical capacity and workload implications should be considered along with RCW and WAC requirements. Regulating Authorities for Net Pen Aquaculture The following state and federal agencies have regulatory authority over the marine salmon net pen industry in Washington State: • Washington State Department of Fish and Wildlife (WDFW) — Management and regulatory authority over commercial aquaculture for disease control and escapement. • Department of Agriculture — Jointly develops regulations for commercial aquaculture with WDFW. • Department of Ecology — Regulates the discharges from net pens by issuing NPDES permits containing operational conditions to protect water quality and sediment standards. • Department of Natural Resources — Leases aquatic lands to net pen operators. • Washington State Counties — Issue Shoreline Permits to net pens to operate in State waters. • Treaty Tribes of Washington State — Tribes co- manage natural resources in Washington and have input into aquaculture disease control regulations developed by WDFW. • National Marine Fisheries Service (NMFS) — NMFS administers Endangered Species Act (ESA) for anadromous salmonids. • Army Corp of Engineers — The Corp requires net pens to have a "Section 404" navigation permit. Local and state agency coordination on aquaculture There may in fact be some value in having local oversight of the regulatory reviews done by other agencies. Some Advisory Committee members certainly expressed strong interest in doing so. At the same time, we should be careful about exactly how SMP.provisions are worded. Regulation #5 on page 3 -3 is an example where non - native fish populations are "discouraged" except in upland systems. The County can decide to express a preference, but should have a rationale for doing so. Native and non - native species would have similar impacts in the water, so why the preference for one over the other? We should ensure that the SMP does not constrain the County to adhere to references which later become out -of -date, nor ones that prove contrary to other legitimate regulatory authorities. An example is Regulation #10 on page 3 -6, that would make 1986 technical guidance- which may change as the science advances- into enforceable regulation the County is responsible for. #10(i) is a single line that says most of what is useful and necessary if the surrounding provisions are dropped. The wording in #100) and (m)(for using regional broodstock) are both contrary to current reconnnendations by WDFW.'These provisions would require amending the SMP to remove, and are plainly inadvisable. Shoreline master program policies and regulations do need to correlate land use regulation onshore with decisions about offshore location of water - dependent uses such as net pens. This appears to be addressed to some degree by Regulation #7 on page 3 -6. Residential Development provisions Ecology encourages locating residential development in areas where homeowners will be relatively safe, and which avoid taxpayer expenditures for rescue and cleanup operations. The need for shoreline stabilization and structures such as levees should be avoided. Guidelines at WAC 173 -26 -241 for residential uses state that: Master programs shall include standards for the creation of new residential lots through land division that accomplish the following: (i) Plats and subdivisions must be designed, configured and developed in a manner that assures that no net loss of ecological functions results fiom the plat or subdivision at full build -out of all lots. (ii) Prevent the need for new shoreline stabilization or flood hazard reduction measures that would cause significant impacts to other properties or public improvements or a net loss of shoreline ecological functions. Residential development, including appurtenant structures and uses, should be sufficiently set back from steep slopes and shorelines vulnerable to erosion so that structural improvements, including bluff walls and other stabilization structures, are not required to protect such structures and uses. (See RCW 90.58.100(6).) There is a need to be clear in the SNIP about the location of primary residential structures, particularly for the safety of residents from such hazards as landslides and flooding. Houses and other structures need to be located far enough back from the edges of bluffs and outside areas where streams and rivers are shown prone to meander over time. The proposed language in Chapter 3.8 appears to address these concerns to some degree. The policies and regulations appear to be correctly aligned. Some of the assumptions therein may need further scrutiny, such as allowing for new residential lots with frontage of 150 feet, and the premise (Section 3.8.3 #7, page 3 -21) that a 75 year lifespan is the basis for "life of a structure." Further evaluation of cumulative impacts should help to clarify if those assumptions are realistic, and whether their implementation would result in no net loss of ecological functions. Some uncertainty must be noted about Regulation #3 in Section 3.8.3. The language here includes "beach — access structures" as "water - dependent and water — related structures." A similar concern is noted about Section 3.8.5 where "accessory uses" and "appurtenant structures" seem rather vague and unclear about what is included, and also how the terns relate to one another. Structures and uses appear to be conflated here. And related provisions in Section 3.13 need to be clarified as to how many similar or related structures would be allowed on a single lot. This also relates to provisions in Section 4.23 of Chapter 4. As written, the definition for "appurtenant' structure would default to that in the WAC because a specific definition is not found in Chapter 7. We do not consider beach access structures to qualify as water - dependent. We believe appurtenant structures should be carefully enumerated and described as to what fits that category. If they are not spelled out, proposals for rather large and significantly impactful structures may be argued for as falling under those provisions. In Chapter 3, Section 3.18, the policy provisions appear generally sound, in keeping with Guidelines requirements in terms of avoiding unnecessary armoring and removal of existing impairments where appropriate and possible. There is one regulation that did not seem to make sense, #3 in Section 3.18.3, which appears to say the owner of an existing bulkhead could come in once and year and add ten percent more fill to the existing structure as maintenance. Buffers and vegetation conservation The provisions for establishing buffers and protecting the ecological functions of shoreline vegetation appear thoughtful and carefully designed. There may need to be some additional explanatory text about the relationships between safety and habitat buffers, as the system proposed is fairly complex. We have concerns about the basis for identifying a safety buffer from the Ordinary high Water Mark to a set distance landward in Channel Migration Zone areas. The nature of rivers and streams, some more than others, such as the Bogachiel or the Hoh, is to move far and fast under certain conditions. In Figure 4.2 on page 4 -12, a set figure of 150 feet from OH WM is identified as being outside the Channel Migration Zone, and we think this deserves further discussion and evaluation. Public Access As was noted during the Advisory Committee meeting January, the policies and regulations, about Public Access in Chapter 4, Section 4.6 , while they are fine as far as they go, seem remarkably scant and less than comprehensive, considering that public access is among the fundamental policy elements of the Shoreline Management Act. Per the Guidelines, "The master program should seek to increase the amount and diversity of public access to the state's shorelines consistent with the natural shoreline character, property rights, public rights under the Public Trust Doctrine, and public safety." The present version addresses public access for larger scale developments, provides criteria for assessment of feasibility, and talks about what must, be demonstrated to avoid providing public access. It says that existing public access on County owned rights of way "shall not be diminished..." The present language does not require any kind of alternate contribution requirement in cases where public access is not provided. More significantly, it does not say anything specific about public access requirements associated with new residential subdivisions, nor anywhere else. The Guidelines call for each local government to " establish policies and regulations that protect-and enhance both physical and visual public access." Previous Advisory Group conversations have addressed this subject in general terms, with recognition there are vast areas of waterfront in Clallarn County which are in public ownership. It has been indicated that public access planning at the Countywide level would preclude the need for requiring individual public access in residential areas. That approach is an option, but we have yet to see the requisite planning instrument to effect it. Absent that countywide plan, the same requirements as indicated in Section 4.6.3 should also apply to residential subdivisions with more than four lots. We would like to have some further conversation with the citizens and the County about the long term needs for public access, to what extent those have been adequately addressed, and where could improvements be made the SMP could support with appropriate language. Conclusion In addition to these comments, further work has and will be done by Ecology regarding Channel Migration Zone delineation and hazard avoidance evaluation. Detailed remarks about the aquaculture provisions are available in addition to what is summarized in this letter. The comments here are the ones we had time to make before the deadline, and further collaborative review will doubtless be appropriate. As noted earlier, generally we view Clallam County's work in development of an updated Shoreline Master Program to be exemplary, and look forward to working through the remaining details towards local and statewide adoption, collaboratively. 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H Q r'1 Aauanba d;uawed LL v O ryo E 0 co N U Q O cn 0 0 Q 0 ui c 0 U a) U O a) .5 E () N a U) C () �L O L U- C: 0 cn c U Q co 0) O C a) U 0 TZ O 70 O O 0 a m c c a a) Q tB U) D C O N .O LL w c� U U a) c tf a) o U 4Z-3 c m a) U a) U) U Q) U) .0 c N LL V c•-n O a) C O Z Z • • '` O 0 O i as O o L � U Q O a) 0 t to Q 0 L ® -L-f � ® V U) > L D Z) O a) Q cn 0 0 Q 0 ui c 0 U a) U O a) .5 E () N a U) C () �L O L U- C: 0 cn c U Q co 0) O C a) U 0 TZ O 70 O O 0 a m c c a a) Q tB U) D C O N .O LL w c� U U a) c tf a) o U 4Z-3 c m a) U a) U) U Q) U) .0 c N LL V c•-n O a) C O Z Z • • '` O O o O as O O L � U Q O a) O O U t to Q T� 1 To: Michelle McConnell, Jefferson County From: Jeffree Stewart, Ecology (SECOND VERSION) Date: April 15, 2013 Subject: In -water Finfish Aquaculture /Revised Response to Ecology We have completed a staff -level review of Jefferson County's Public Review Draft, Revised Response to Ecology: In -water Finfish Aquaculture, dated 3- 27 -13. While not a final formal response from the agency, the following comments are offered to indicate some Ecology perspective on what is being considered by the public and by the County Commissioners. We continue to appreciate the careful and deliberate efforts being made by Jefferson County to identify areas where water - dependent uses, including in -water finfish facilities, could possibly be sited safely. Any such project approval would depend on careful site - specific review against Conditional use criteria and considering statewide policy for protection of ecological resources, plus additional criteria the County establishes in its Shoreline Master Program (SMP). Per WAC 173- 26- 241(3)(b)(C), aquaculture "should not be permitted in areas where it would result in a net loss of ecological functions, adversely impact eelgrass and macroalgae, or significantly conflict with navigation and other water - dependent uses." We recognize Jefferson County has worked with diligence and focus to discern where in -water aquaculture operations could be allowed and where they should be excluded for sound reasons. We note that in the Guidelines, aquaculture is not given preference over other water - dependent uses. While both uses involve food production, for purposes of an SMP, we think mixing definitions and requirements of agriculture and aquaculture makes for difficult understanding. Some of the notations in the matrix for upland facilities relative to the Aquatic Designation are hard to fathom. We encourage the County in having SMP requirements clearly laid out, as easy to follow as possible. We recognize that large portions of Jefferson County's Revised Response is based on existing requirements from various other local, state, and federal codes. Provided the other statutory policies of RCW 90.58 are also upheld, the County may adopt such detailed and stringent standards where appropriate. As we have discussed on past occasions, the County should recognize the down sides of using standards copied from other sources. Of particular concern in the present public review document is that several pages worth of text taken mostly from the 1986 Interim Siting Guidelines are proposed to become regulations in the SMP. The Interim Siting Guidelines document is a perfectly good reference source. Much of its content, while many years old, remains useful and appropriate. Over time, however, based on new scientific knowledge or technology innovation, some of those referenced standards will change. We therefore do not recommend such a large block of text being made into regulation. More advisable for the SMP is referring to selected sections as a guidance document for project review. Some provisions in the 1986 document have already become out -of -date with current practice based on science. The need for formal amendments to an SMP should be carefully considered before adoption. Once adopted into a SMP, formal amendment procedures will be necessary to make necessary changes to any provision. As you know, this can be a time - consuming process. We must avoid contradictions with other codes, and making unnecessary or redundant requirements, for legal reasons and because these would drive up costs for applicants and also make more work for County and also Ecology planning staff who have to review the proposals. We encourage local governments to parse out what areas of regulation are not already covered by the federal and state agencies, adding what is unspecified elsewhere, but determined locally necessary, to the SMP. The general direction Jefferson County is taking with these proposed revisions appears rational and carefully considered. We appreciate the extensive efforts the County has made to ensure we get this chapter to address the required changes which ensures protection of the ecological resources while honoring the water - dependent use policies of RCW 90.58. We look forward to discussing further any particular suggestions and /or concerns, along with public comments both written and from testimony at the April 15, 2013 Hearing. As noted in earlier correspondence, Ecology is ready to conclude this lengthy dialogue about in -water finfish aquaculture provisions, and we look forward to completion, approving an updated SMP for Jefferson County. CC: Gordon White, Brian Lynn, Peter Skowlund, Paula Ehlers, Perry Lund, Cedar Bouta C CSI" April 14, 2013 To: Department of Community Development 621 Sheridan St. Port Townsend, WA 98368 Attn: Michelle McConnell, SMP Update Project Manager From: Margo DeVries Subject: Public Comment: Finfish Aquaculture Provisions Ultimately, beyond the years of exchange filled with differences of opinion; with consistent observation and representation of community perspective and preference; the absolute answer for Jefferson County is produced in this comprehensive, currently draft, formal response to Ecology: In -water Finfish Aquaculture Required Changes #13 — 15, as offered by this Board of Jefferson County Commissioners. This excellent document unwaveringly sets -out to protect our most sensitive environment, and comply with current legislation to the satisfaction of our state. This outcome is a compromise of the highest order; which will hopefully be recognized and accepted for its diligence and reconciliation over what is most important to county, state and the public. Respectfully, Margo DeVries