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Site Plan - BDN LLC Geoduck Farm
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County's Exhibit 4 - Page 028
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To: Pamela Sanguinetti, U.S. Army Corps of Engineers
cc: Robert Smith, Plauché & Carr LLP
Brad Nelson, BDN
From: Grant Novak, Confluence Environmental Company
Date: September 13, 2016
Re: Addendum to Biological Evaluation of BDN LLC Smersh Geoduck Aquaculture Project
(NWS‐2013‐1268)
This document is intended to amend the Biological Evaluation (“BE”) provided by Marine Surveys and
Assessments, Inc., dated October 28, 2013. At the request of the Corps, Confluence has performed
additional eelgrass surveys to confirm the location of native eelgrass (Zostera marina) at the
Smersh/Nelson site. This Addendum updates the BE through updating the location of native eelgrass
on the site, revising the location of proposed geoduck planting consistent with the location of the
eelgrass bed and Corps’ eelgrass buffer requirements, and provides additional analysis regarding the
potential for indirect effects to threatened or endangered species listed under the Endangered Species
Act (ESA) due to potential impacts to eelgrass from geoduck culture and harvest activities. This
Addendum is intended to supplement the original analysis in the BE and any descriptions or analysis
not modified herein should be considered to still be valid and accurate.
A. REVISIONS TO PROJECT DESCRIPTION
Based upon the updated eelgrass survey, BDN has revised its proposed planted area as shown on Figure
1. The revised planted area will consist of approximately 5.15 acres, generally between approximately
+2 ft. MLLW and a 5‐meter (16.4‐ft) buffer of the dense Z. marina bed edge, located between
approximately ‐1 MLLW and ‐2 MLLW.1,2 There are also a couple of minor modifications to BDN’s
proposed operations as compared to what is described in the BE. BDN employees working at the
Smersh parcel will park at public parking areas on Madrona Vista and use property owned by James
1 On a July 21, 2016 site visit, the Corps requested clarification as to whether area netting would be used. As noted
in the original BE, “Area netting over the tubes may be installed to prevent tube dislocation during severe weather”
(BE, pg. 5) and “Once [mesh] caps have been removed, area netting will be put down to contain tubes, as the
growing geoducks will begin to push these out of the sand” (BE, pg. 6). BDN anticipates that area nets may be used
for a maximum of four years to protect geoducks from predators and to provide additional protection against tube
dislodgement.
2 The tidal elevations described herein are approximate. The planted area, location of the eelgrass bed, and extent of
the eelgrass buffer are all described by GPS coordinates that have been provided to the Corps.
Appellant
Exhibit 45 page 1106
Apr 03 2019
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Smersh located across the street from the project site as a staging area.3 Further, while BDN may use a
skiff in the manner described in Section 4.b.(1) of the BE (pg. 6), most site inspections will be conducted
by walking the beds at low tide.
B. ADDITIONAL EELGRASS SURVEYS
Confluence performed several additional eelgrass surveys on the Smersh parcel. On September 4, 2015,
Confluence used a towed video system with integrated Global Positioning System (GPS) to collect
information about native eelgrass presence/absence. The towed video data were collected in transects
running perpendicular to the beach and spaced about every 45 feet. In addition, a transect that ran
parallel to the shoreline was collected along the anticipated eelgrass bed edge and landward of the
edge. The video system electronically recorded latitude and longitude to aid in the mapping of native
eelgrass locations. A differential GPS (dGPS) with sub‐meter accuracy was used to collect positions at
one second intervals during the towed video surveys. To aid mapping, a proprietary program created by
Confluence was used when reviewing the video to characterize the presence/absence of eelgrass. The
entirety of the field‐collected video data was reviewed in the office on a high definition monitor to
ensure that habitat variables were accurately characterized. Tabular data describing the vegetative
cover, substrate material, relief, and complexity were then joined, using a time stamp, to the dGPS
positions thereby allowing the high quality characterization of video in the office to be linked to the
dGPS positions and video data collected in the field.
During the September 29, 2015 survey, the edge of native eelgrass was confirmed using snorkel‐based
surveys and a dGPS unit at the Smersh site. Two biologists snorkeled the landward native eelgrass
boundary using a floating dGPS unit to precisely collect location data. The biologists divided the area
into two eelgrass zones: patchy vs. continuous. These zones were mapped according to the following
criteria: (1) Patchy = individual shoots or small patches of native eelgrass (typical of shoots migrating
from the main eelgrass bed), (2) Continuous = the main native eelgrass bed with few locations where
eelgrass was absent (typical of a fringe eelgrass bed). The landward edge of the patchy eelgrass zone
was considered to be the upper (or landward) extent of native eelgrass habitat. Underwater video,
using a GoPro HERO4 camera, was collected during the snorkel‐based surveys. The results from the
September 2015 eelgrass surveys are depicted in Figure 2.
Pursuant to the Corps’ request, Confluence conducted another eelgrass survey on the Smersh parcel on
July 20, 2016 to reconfirm the extent of the eelgrass bed surveyed in 2015. A surveyor walked the Z.
marina bed edge, recording the location using a GPS unit with decimeter accuracy. The location of the
marina bed edge was substantially similar to that mapped by Confluence in 2015 and is depicted in
Figure 1.
3 Depending on the source of geoduck seed, the size of planted seed may be 4-5 mm as opposed to the 10-15 mm
seed described in the BE.
Appellant
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C. ADDITIONAL ANALYSIS REGARDING EFFECTS TO EELGRASS
Effects to eelgrass have the potential to result in changes to ecosystem functions provided by eelgrass
beds at the Smersh/Nelson site and, thereby, to ESA‐listed species that may benefit from those
services.
1. Location of Eelgrass Beds
Both native eelgrass (Z. marina) and non‐native dwarf eelgrass (Zostera japonica) are present at the
proposed Smersh/Nelson geoduck culture site. Z. marina is abundant at subtidal and lower intertidal
elevations, while Z. japonica is very sparsely distributed at higher intertidal elevations. A bed of dense,
robust Z. marina is located seaward of the extreme low tide elevation (approximately ‐2 ft. mean lower
low water [MLLW]) (Figure 1). Landward of this dense bed edge the beach is substantially composed of
bare sand with occasional patches of sparse Z. japonica. No Z. marina is present landward of
approximately ‐2’ MLLW. Planting of geoducks is planned between approximately +2 ft. MLLW and a 5‐
meter (16.4‐ft) buffer of the dense Z. marina bed edge (Figure 1).
2. Effects to Native Eelgrass from Planting and Maintenance Activities
As mentioned above, the project will incorporate a 5‐meter buffer from the identified Z. marina
eelgrass bed, consistent with the Corps’ conservation measure included in the Programmatic Biological
Assessment concerning Shellfish Activities in Washington State Inland Marine Waters (“PBA”). The
Biological Opinions submitted by the National Marine Fisheries Service (“NMFS”) and U.S. Fish &
Wildlife Service both confirm that the buffer will adequately protect eelgrass for new shellfish farms.
For example, NMFS found that new farms “will be required to follow the 16‐foot buffer requirements
from native eelgrass, this is not expected to diminish eelgrass density or function of existing eelgrass.”
NMFS, Endangered Species Act (ESA) Section 7(a)(2) Biological Programmatic Opinion and Magnuson‐
Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation: Washington
State Commercial Shellfish Aquaculture and Restoration Programmatic (2016), at pg. 72.
3. Impacts to Non‐Native Eelgrass (Z. japonica)
The project may result in the removal of Z. japonica located in the planted area or adverse effects to Z.
japonica from project operations. However, Z. japonica is not a threatened or protected species. To the
contrary, the Washington State Noxious Weed Control Board (NWCB) has classified Z. japonica as a
Class C noxious weed (WAC 16‐750‐015). Aquatic plants on the noxious weed list are considered “to be
highly destructive, competitive, or difficult to control . . .” (WAC 16‐750‐001). In adopting the listing,
the NWCB justified the regulation partially based on concerns that Z. japonica can increase the
deposition of silt and detritus. Protecting Z. japonica would be contrary to the State’s designation of the
Appellant
Exhibit 45 page 1108
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plant as a Class C noxious weed. Therefore, impacts to Z. japonica existing on the site is considered to
be a less than significant impact.4
4 This amends statements made in the original BE that “Z. japonica will not be removed from the site during
planting. Instead, planting will occur through these patches” (BE, pg. 5) and “Still, any activities that reduce harm to
Z. japonica, such as planting around the patches, would maintain additional valuable habitat at this site” (BE, pg.
15). While the initial BE notes that Z. japonica creates three-dimensional habitat and complexity as compared to
mudflats (pg. 15), as noted above, geoduck aquaculture provides similar three-dimensional complexity through the
introduction of tubes and canopy nets. Further, BDN’s operations west of the project site have documented that
BDN’s proposed geoduck aquaculture can coexist with Z. japonica.
Appellant
Exhibit 45 page 1109
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www.confenv.com page 5 of 7 Figure 1. Proposed Geoduck Planting Plan and July 2016 Eelgrass Density ZonesAppellant Exhibit 45 page 1110Log Item 1 Page 97 of 204
www.confenv.com page 6 of 7 Figure 2. Proposed Geoduck Planting Plan and September 2015 Eelgrass Density ZonesAppellant Exhibit 45 page 1111Log Item 1 Page 98 of 204
146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
BDN Inc.
SMERSH FARM CUMULATIVE IMPACTS REPORT
FINAL REPORT
Prepared for:
Brad Nelson, BDN Inc.
June 2018
Apr 03 2019
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146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
BDN Inc.
SMERSH FARM CUMULATIVE IMPACTS REPORT
FINAL REPORT
Prepared for:
BDN Inc.
3011 S. Chandler St.
Tacoma, WA 98409
Attn: Brad Nelson
Authored by:
Confluence Environmental Company
June, 2018
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BDN Inc. - SMERSH FARM CUMULATIVE IMPACTS REPORT
June 2018 Page i
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................................................... 1
2.0 PROJECT DESCRIPTION .................................................................................................................................... 1
3.0 EFFECTS ANALYSIS ........................................................................................................................................... 2
3.1 Biological Impacts ..................................................................................................................................... 2
3.1.1 Water Quality ............................................................................................................................ 2
3.1.1.1 Filtration .................................................................................................................................... 3
3.1.1.2 Turbidity During Harvest ........................................................................................................... 3
3.1.2 Habitat Functions ...................................................................................................................... 3
3.1.2.1 Sediment Character/Quality ...................................................................................................... 4
3.1.2.2 Sediment Supply and Delivery .................................................................................................. 4
3.1.2.3 Submerged Aquatic Vegetation ................................................................................................ 4
3.2 Impacts to Navigation ............................................................................................................................... 5
3.3 Impacts to Aesthetics ............................................................................................................................... 5
3.4 Impacts to Public Access .......................................................................................................................... 5
4.0 CONCLUSION ...................................................................................................................................................... 6
5.0 REFERENCES ...................................................................................................................................................... 1
TABLES
Table 1. Possible impacts due to the proposed project. ................................................................................................. 6
FIGURES
Figure 1. Project area and vicinity. ................................................................................................................................. 1
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BDM – Smersh Geoduck Farm Cumulative Impacts Report
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1.0 INTRODUCTION
BDN, Inc. has leased parcel 721031007 (Smersh parcel) on Shine Road, west of the Hood Canal
Bridge, and is proposing to operate a geoduck farm at the site (Figure 1). A conditional use
permit is required by Jefferson County and, as part of the permit application, a cumulative
impacts assessment has been requested by the County pursuant to Jefferson County Code (JCC)
18.25.440 and JCC 18.25.590.
This report provides an assessment of cumulative impacts that may result from the proposed
project. Cumulative environmental effects can be defined as environmental effects caused by
the combined results of past, current, and future activities. This assessment incorporates the
following factors in an assessment and summation of potential cumulative impacts: current
ecological functions, human factors influencing shoreline processes, foreseeable future shoreline
development, beneficial effects of regulatory programs, and conservation measures.
Figure 1. Project area and vicinity.
2.0 PROJECT DESCRIPTION
BDN, Inc proposes to plant up to 5.15 acres of geoducks at the site between +2 feet and
approximately ‐2 feet relative to mean lower low water (MLLW). The lower boundary of
planting will be determined based on the location of the eelgrass bed below approximately ‐2
feet MLLW (Confluence 2016). Log Item 1
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To protect juvenile geoduck until they can burrow deep enough to avoid predators, PVC tubes
4” in diameter by 10” long would be placed into the sandy substrate. Tubes would be placed at
an approximate density of 1 tube per square foot with 3” to 5” of the tube exposed above the
substrate. Area netting may be placed over the tubes to prevent them from becoming dislodged
during severe weather. Tubes would be removed after 18‐24 months once the geoduck have
reached a sufficient size and depth to avoid predation.
Routine maintenance of the proposed geoduck aquaculture area ensures that gear is preserved
on‐site, and would begin once gear has been installed. Maintenance would occur monthly, and
also immediately following large storm events. Maintenance activities may include monitoring
shellfish weight and health, picking up unnatural debris, ensuring that predator netting is
suitably anchored to the substrate, and ensuring that PVC tubes are not becoming dislodged
from the substrate. Maintenance would typically be done by a two‐person crew over a 4‐hour
period.
Geoduck will be harvested 5‐7 years after planting. Netting may remain on the site until harvest
to protect the crop from theft and/or predation.
3.0 EFFECTS ANALYSIS
Potential effects to fish and wildlife habitat, boat navigation, aesthetics, and public access/use
are considered in this assessment. Biological impacts and visual impacts have been assessed in
detail in separate reports (Confluence 2018a, Confluence 2018b). Summaries of the findings of
those assessments are included below in addition to evaluations of effects to boat navigation
and public access.
3.1 Biological Impacts
Biological impacts are discussed below as a function of potential effects to water quality (i.e.
filtration by shellfish, turbidity during harvest) and physical habitat functions (i.e. sediment
quality, sediment supply and delivery, submerged aquatic vegetation). Additional detail on
each of these elements is provided in Confluence 2018a.
3.1.1 Water Quality
Potential effects to water quality and fish and wildlife species or their habitat are different
during the growing and harvest phases of geoduck aquaculture. During the growth phase,
geoducks filter phytoplankton and other particles from the water column. During harvest,
sediment is re‐suspended into the water column. These two aspects are addressed in further
detail below.
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3.1.1.1 Filtration
The depth at which photosynthetic submerged aquatic vegetation (SAV) can grow is limited by
the depth at which light penetrates through the water column. Shellfish aquaculture can result
in a beneficial reduction in turbidity, and increase in light penetration, due to removal of
phytoplankton and particulate organic matter through filtration. Improvements to water clarity
and light penetration can improve habitat conditions through the growth of SAV.
Shellfish aquaculture or the presence of a naturally dense bivalve community may provide
some control of human nutrient loading to water bodies. Bivalves remove phytoplankton and
suspended sediment from the water column through filtration, which can have a net benefit to
water quality. When shellfish are harvested, sequestered nutrients are permanently removed
from the system which benefits areas with high nutrient loading, such as Hood Canal.
Shellfish aquaculture infrastructure also provide microhabitats for communities of nitrifying
microbes. Through filtration, sequestration, and hosting of nitrifying microbes commercial
shellfish aquaculture can be considered a net benefit to water quality ecosystem functions.
3.1.1.2 Turbidity During Harvest
Geoducks can be harvested when the tide is out or by divers when the tide is in, both methods
use a water jet to loosen the sediment around the geoduck which causes a temporary increase in
suspended sediment and turbidity. A geoduck harvest event is limited geographically and
temporally compared to natural storm events which increase suspended sediment and turbidity
to comparable levels.
Exposure to high levels of suspended sediment can stress fish and result in reduced survival
and growth but studies have shown that fish are likely to avoid localized, elevated turbidity
events such as a geoduck harvest.
Both the timing and intensity of activities are below the natural disturbance regime of typical
Puget Sound storm events and mobile species are able to avoid the harvest area. Thus, harvest
is not anticipated to result in negative impacts to ecological functions.
3.1.2 Habitat Functions
In‐water activities have the potential to alter sediment character/quality, sediment supply and
delivery, or distribution of submerged aquatic vegetation. Changes to these elements could
result in either negative or beneficial alteration of habitat in the vicinity of the project. The
potential effects to each of these elements from geoduck culture and harvest is discussed further
below.
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3.1.2.1 Sediment Character/Quality
Sediment along the north shore of Squamish Harbor is primarily sandy in the lower elevations
with gravel and cobble on the upper intertidal beach. No sediment contaminants are known in
the proposed project area and the surrounding land use is low density residential and not
industrial, as is typically associated with sediment contamination. The proposed project will
not be using any chemicals that may cause sediment contamination. The proposed project
would not change existing sediment character or quality.
3.1.2.2 Sediment Supply and Delivery
The beach slopes gradually and has exposure to wind generated waves from the south, where
winter storms typically come from in Puget Sound. East of the project area there is a high
eroding bluff that supplies sediment to the beach. Net shore‐drift of sediment is to the west,
from the eroding bluff toward the proposed project site. Shoreline armoring is prevalent along
the north shore of Squamish Harbor, which may generally limit sediment supply in the area.
The two types of potential disturbances associated with shellfish aquaculture that could affect
sediment supply and delivery include the use of tubes and netting that slow the transport of
sediments, and sediment re‐suspension due to harvest activities.
A small accumulation of sediment may collect in the proposed geoduck tubes and is expected to
rapidly redistribute through wave and current action after one or two tidal cycles following the
removal of nets and tubes.
During a geoduck harvest, the overlying sediments are loosened around the clam by a low‐
pressure water hose. Although this activity results in minor, localized changes in elevation and
sediment grain size, both quickly return to baseline conditions within one month after harvest.
In summary, geoduck harvest and the presence of culture tubes and/or cover nets do not lead to
significant impacts to sediment transport or bathymetry. Minor changes in elevation may
persist for up to 1 month, but these effects are insignificant compared to the natural sediment
dynamics along the shoreline associated with the project area.
3.1.2.3 Submerged Aquatic Vegetation
A dense bed of eelgrass (Zostera marina) extends from approximately ‐3 ft MLLW, waterward of
the project area to an unknown depth. A narrow band of sparse, patchy eelgrass is landward of
the dense bed between approximately ‐2 and ‐3 feet MLLW. Several sparse patches of non‐
native dwarf eelgrass (Zostera japonica) were observed distributed throughout the proposed
project area.
Macroalgae beds are not found in or near the project area. Green algae (Ulva spp) were present
at a very low density, attached to a small number of hard objects such as derelict clam shells.
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Macroalgae density is anticipated to increase in the project area due to geoduck farming as the
PVC tubes and cover netting provide solid substrate required by macroalgae for attachment
and growth.
Because the project will be located outside of a 16‐foot protective buffer from native eelgrass, no
negative effects are anticipated to occur to eelgrass due to the proposed project and there may
be an ecological lift from the potential increase in other macroalgal species on the tubes and
netting.
3.2 Impacts to Navigation
Geoducks are grown in sediment and infrastructure (netting and tubes) that has very low relief
(less than 5 inches). This would not result in any impacts to boat navigation.
3.3 Impacts to Aesthetics
A visual impacts assessment was completed as part of this project and indicates that visual
impacts due to the project would be very low (Confluence 2018b). The proposed geoduck
planting area covers less than 5 percent of the cone of vision when viewed from nearby
residences. The project is 500 feet wide along the nearly 2‐mile‐long northern shoreline of
Squamish Harbor.
The Smersh site is located on a heavily altered shoreline in a medium‐density, residential
neighborhood. The shoreline has been altered by rip rap hardening, there is a concrete boat
ramp and gravel parking lot on the adjacent public property, riparian trees have been removed
from a number of the adjacent properties to increase private views, and the paved roadway is
adjacent to the shoreline for approximately 1 mile next to the Smersh parcel.
Tides low enough to expose the planting area follow a seasonal pattern in the Puget Sound
region. Larger‐magnitude summer low tides occur during daylight hours, while winter low
tides occur at night. Therefore, geoduck tubes and netting are more visible in summer, and
minimal in winter. Also, geoduck tubes and nets have very low relief and natural macroalgae
colonizes equipment rapidly, quickly resulting in natural color and texture.
Given the site is visible only a small portion of the time, the site is not visible from heavily
traveled routes, the surroundings are heavily altered by local residential development, and the
geoduck tubes and netting will quickly take on a natural color due to colonization by aquatic
flora and fauna, there would be only very low impacts to aesthetics.
3.4 Impacts to Public Access
There will be no impacts to beach access as part of this project as the project is located on
private tidelands that are not currently accessible by the public.
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4.0 CONCLUSION
Based on communication with Jefferson County no other like actions are present or proposed in
the area that will cumulatively increase impacts to the area (Bausher 2018). As presented above,
the proposed project would have minimal negative impact on the local shoreline and some
beneficial impacts. Past and current use of the area is residential and any impacts to the
shoreline are incorporated into existing background conditions. Thus, the cumulative impact of
the project on the local ecosystem would range from none to minor as summarized in Table 1.
Table 1. Cumulative Impact Determinations.
Impact Category Cumulative Impact
Determination Rationale for Impact Determination
Biological (Water Quality and
Habitat Functions)
None Filtration by geoducks may improve water quality in the
vicinity of the proposed project area.
Turbidity will be temporarily increased during harvest,
but this will not negatively impact habitat because
effects are similar to monthly storm events.
Sediment character and quality will not change as part
of the proposed project.
Sediment supply and delivery may be temporarily
impacted by accumulating sediment during the
proposed project and releasing sediment during
harvest.
Submerged aquatic vegetation may be beneficially
impacted during the proposed project by increasing the
locations where algae can establish.
Navigation None The proposed project has very low relief (e.g., 0.25
feet).
Aesthetics Minor The proposed project will be visible for only short
duration during very low tides.
Maintenance will occur monthly to ensure farm is tidy
and tubes have not become dislodged.
While not in use, equipment will be stored off-site.
Public Access None Proposed project is located on private tidelands with no
public access.
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5.0 REFERENCES
Confluence (Confluence Environmental Company). 2016. BDN Eelgrass Delineation –
Final Report. October 31, 2016.
Confluence. 2018a. Smersh Farm Habitat Management Plan and No Net Loss Report. June, 2018.
Confluence. 2018b. Smersh Farm Visual Assessment. June, 2018.
Bausher, A. 2018. Personal communication between Anna Bausher, Jefferson County –
Development Review Division, and Grant Novak, Confluence Environmental. June, 14, 2018
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146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
To: Anna Bausher, Jefferson County Department of Community Development
cc: Rick Mraz, Washington State Department of Ecology; Brad Nelson, BDN Inc.
From: Grant Novak, Confluence Environmental Company
Date: July 9, 2018
Re: BDN Inc. - Proposed Smersh Geoduck Farm: 2018 Zostera marina bed edge re-verification
This memo summarizes the findings of surveys conducted by Confluence Environmental Company
(Confluence) to re‐verify the location of the landward edge of the native eelgrass (Zostera marina)
bed on Jefferson County parcel 721031007 (Smersh parcel). The bed edge was previously surveyed in
2016 by Confluence. Representatives of the U.S. Corps of Engineers (Matthew Bennett, Pamela
Sanguinetti, and Deborah Schaeffer) visited the Smersh parcel on July 21, 2016 to confirm the
findings of the 2016 eelgrass delineation. The Corps was in agreement with the methods and agreed
that the boundaries of the dense and patchy eelgrass beds were appropriately mapped at that time.
Because more than one year has lapsed since the previous survey was completed, the Washington
State Department of Ecology and Jefferson County have requested that the bed edge be re‐verified to
ensure the proposed geoduck aquaculture project will be sighted at least 16 feet from native eelgrass
so as to reduce the potential for negative impacts to protected resources.
A biologist knowledgeable in Pacific Northwest seagrass identification and survey methods visited
the Smersh parcel during low tide on June 28th between 11:00 am and 1:00 pm. During the time of the
survey, water elevations ranged from ‐0.3 feet to ‐1.6 feet relative to mean lower low water (MLLW).
The surveyor crisscrossed the entirety of the parcel while scanning the substrate to the left and right
in an effort to locate and identify any submerged aquatic vegetation at the site, with a specific focus
on locating native eelgrass.
As with previous surveys, very small, sparse patches of non‐native Japanese eelgrass
(Zostera japonica) were found widely distributed between approximately +2 feet and ‐1 foot MLLW.
No native eelgrass was found above ‐1 foot MLLW. A dense bed of native eelgrass with a patchy
margin was observed below approximately ‐1 to ‐2 feet MLLW. The location of the landward edge of
the native eelgrass bed was accurately recorded using a differential GPS with sub‐meter accuracy.
The 2018 bed edge closely matches the 2016 bed edge in some areas but the patchy margin has
receded waterward in many areas (Figure 1). Nowhere has the bed expanded landward of the 2016
margin. Thus, the geoduck planting area proposed in 2016, and permitted by the Corps in 2017, will
not be altered in the application for a Jefferson County conditional use permit.
Apr 03 2019
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www.confenv.com page 2 of 2
Figure 1. Comparison of 2016 and 2018 Native Eelgrass Bed Edge.
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146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
Smersh Farm Habitat Management Plan and
No Net Loss Report - 2018
FINAL REPORT
Prepared for:
BDN, LLC
June 2018
Apr 03 2019
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146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
Smersh Farm Habitat Management Plan and
No Net Loss Report - 2018
FINAL REPORT
Prepared for:
BDN, LLC
Attn: Brad Nelson
Prepared by:
Grant Novak
Confluence Environmental Company
June 2018
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TABLE OF CONTENTS
1.0 INTRODUCTION .............................................................................................................................................. 1
2.0 PROJECT DESCRIPTION................................................................................................................................ 1
2.1 Planting and Grow-Out .................................................................................................................................... 2
2.2 Maintenance .................................................................................................................................................... 4
2.2.1 Site Inspection ........................................................................................................................................ 4
2.2.2 Cap Removal .......................................................................................................................................... 4
2.2.3 Tube and Net Removal ........................................................................................................................... 4
2.3 Harvesting ........................................................................................................................................................ 5
2.4 Habitat Management Plan ............................................................................................................................... 5
2.4.1 Maintenance, Repair, and Operation ...................................................................................................... 5
2.4.2 Species-Specific Activities ...................................................................................................................... 7
2.4.3 Farm Plan Record-Keeping Log ............................................................................................................. 7
3.0 EFFECTS ANALYSIS ...................................................................................................................................... 8
3.1 Noise................................................................................................................................................................ 9
3.1.1 Existing Conditions ................................................................................................................................. 9
3.1.1.1 Airborne Noise ........................................................................................................................................ 9
3.1.1.2 Underwater Noise ................................................................................................................................... 9
3.1.2 Effects of Noise ....................................................................................................................................... 9
3.1.2.1 Effects of Airborne Noise ........................................................................................................................ 9
3.1.2.2 Effects of Underwater Noise ................................................................................................................. 11
3.1.3 Summary of Noise Effects .................................................................................................................... 12
3.2 Water Quality ................................................................................................................................................. 12
3.2.1 Existing Conditions ............................................................................................................................... 12
3.2.2 Effects to Water Quality ........................................................................................................................ 13
3.2.3 Filtration Effects .................................................................................................................................... 13
3.2.4 Harvest Effects ...................................................................................................................................... 14
3.2.5 Summary of Effects to Water Quality .................................................................................................... 16
3.3 Sediment Quality ........................................................................................................................................... 16
3.3.1 Existing Sediment Conditions ............................................................................................................... 16
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3.3.2 Effects to Sediment Quality ................................................................................................................... 17
3.4 Sediment Transport and Bathymetry ............................................................................................................. 18
3.4.1 Existing Conditions ............................................................................................................................... 18
3.4.2 Effects to Sediment Transport and Bathymetry .................................................................................... 18
3.4.3 Addition of Gear .................................................................................................................................... 18
3.4.4 Harvest Activities .................................................................................................................................. 19
3.4.5 Summary of Effects to Sediment Tranport and Bathymetry .................................................................. 19
3.5 Migration, Access, and Refugia ..................................................................................................................... 19
3.5.1 Existing Conditions ............................................................................................................................... 19
3.5.2 Effects to Migration, Access, and Refugia ............................................................................................ 20
3.6 Forage Fish .................................................................................................................................................... 20
3.6.1 Existing Conditions ............................................................................................................................... 20
3.6.2 Effects to Forage Fish ........................................................................................................................... 21
3.6.3 Spawning Habitat Overlap .................................................................................................................... 21
3.6.4 Sediment Mobilization ........................................................................................................................... 21
3.6.5 Summary of Effects to Forage Fish ...................................................................................................... 21
3.7 Benthic Infauna and Epifauna ........................................................................................................................ 22
3.7.1 Existing Conditions ............................................................................................................................... 22
3.7.2 Effects to Benthic Infauna and Epifauna ............................................................................................... 22
3.7.3 Culture Tube Placement Effects ........................................................................................................... 22
3.7.4 Predator Exclusion Netting Effects ....................................................................................................... 22
3.7.5 Harvest Effects ...................................................................................................................................... 23
3.7.6 Summary of Effects to Benthic Infauna and Epifauna ........................................................................... 24
3.8 Aquatic Vegetation ......................................................................................................................................... 24
3.8.1 Existing Conditions ............................................................................................................................... 24
3.8.2 Effects to Aquatic Vegetation ................................................................................................................ 24
3.9 Summary of Potential Effects......................................................................................................................... 25
4.0 REFERENCES ............................................................................................................................................... 27
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TABLES
Table 1. Underwater Noise Thresholds by Functional Hearing Group ......................................................................... 11
Table 2. Clearance Rate Calculations for Pacific Oyster, Manila Clam, and Geoduck ................................................ 14
Table 3. Summary of Potential Effects from Geoduck Aquaculture ............................................................................. 25
FIGURES
Figure 1. Smersh Parcel and Vicinity. ............................................................................................................................ 1
Figure 2. Proposed Geoduck Planting Area and Distances from High Water ................................................................ 2
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1.0 INTRODUCTION
BDN, Inc., (BDN) has leased parcel 721031007 (Smersh parcel) on Shine Road, in Squamish Harbor,
west of the Hood Canal Bridge and is proposing to operate a geoduck farm at the site (Figure 1). A
conditional use permit is required by Jefferson County and, as part of the permit application, a
habitat management plan and no net loss report are required (JCC 18.25.440).
The standard of “No Net Loss” of ecological functions was established by Washington State in the
Shoreline Management Act of 1971 and is implemented through a framework outlined in Jefferson
County’s Shoreline Master Program. This document presents an assessment of the proposed
aquaculture activities and demonstrates how geoduck aquaculture at the Smersh parcel will be
managed to achieve no net loss of ecological functions.
2.0 PROJECT DESCRIPTION
The project, if approved with current design, will consist of the following elements as described
below. Potential impacts described herein are based on this current design.
BDN proposes to plant up to 5.15 acres of geoducks at the site between +2 feet and
approximately ‐2 feet relative to mean lower low water (MLLW) (Figure 2). The lower boundary of
planting has been determined based on the location of the eelgrass bed below
approximately ‐2 feet MLLW (Confluence 2016, Confluence 2018). To protect juvenile geoduck
Figure 1. Smersh Parcel and Vicinity
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until they can burrow deep enough to avoid predators, PVC tubes 4 inches in diameter by 10
inches long will be placed into the sandy substrate. Tubes will be placed at an approximate density
of 1 tube per square foot with approximately 4 inches of the tube exposed above the substrate. All
tubes will be labeled with BDN contact information, including telephone number and email
address. Area netting may be placed over the tubes to prevent them from becoming dislodged
during severe weather and to reduce predation and theft.
Tubes will be removed after 18 to 24 months once the geoduck have reached a sufficient size and
depth to avoid predation. Geoduck will be harvested 5 to 7 years after planting. Netting may
remain on the site until harvest to protect the crop from predation and theft.
2.1 Planting and Grow-Out
Locations for geoduck clam aquaculture do not typically require much, if any, site preparation
prior to planting because they are located in sandflats or mudflats that do not have large substrate
materials. Substrate composition in the proposed culture area is primarily sand. Excessive
amounts of macroalgae (i.e., Ulva) will be hand‐raked away from the planting area, but left on‐site.
Successive tides will redistribute algae across the site. Non‐native dwarf eelgrass (Zostera japonica),
which is very sparsely distributed throughout the proposed planting area (Confluence 2016,
Confluence 2018), will not be removed during planting. Native eelgrass (Zostera marina) will not
be disturbed and all geoduck planting will occur outside of the 16‐foot buffer from eelgrass bed as
Figure 2. Proposed Geoduck Planting Area and Distances from High Water
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delineated by Confluence Environmental Company (Confluence) in July 2016 and reverified in
2017. Site preparation, if any, would occur at the same time as culture tube installation.
Geoduck seed are highly vulnerable to predation because of their small size and the shallow depth
at which they reside in the substrate when small. There will be no active predator removal from
the site. Predator control would be achieved through exclusion by planting geoduck seed into PVC
culture tubes, covering the tube with a mesh cap secured with a UV‐resistant rubber band, and
covering the bed with predator netting. PVC culture tubes are 4 inches in diameter and 10 inches
in length. Culture tubes will be positioned approximately 12 inches apart on center. Tubes would
be pushed into the substrate manually. PVC tubes typically extend approximately 4 inches.
Predator netting will be laid over the PVC tubes and secured to the substrate using rebar stakes to
further reduce predation and theft. Predator netting has the added advantage of securing the PVC
tubes so that they do not wash away in the event of high wind and large waves.
After the culture tubes are removed, predator exclusion netting may be placed over the bed.
Predator exclusion nets will be placed directly on the sediment surface during this phase and
secured every 8 to 10 feet along the perimeter with U‐shaped rebar stakes. PVC tubes and predator
exclusion netting will be stored at an upland location when not in use.
Planting of seed will occur within the intertidal zone between approximately ‐2 feet and +2 feet
relative to MLLW, and may occur at any time of the year when growing conditions and tides are
suitable. Four juvenile geoduck will be planted in each tube. This will provide an initial density of
4 geoduck/square foot within the planting area. Planting will be completed by 12 to 25 workers on
the beach for approximately 5‐hour shifts. These workers will plant 8,000 to 10,000 geoduck per
shift by hand. With 12 to 25 workers, it will take 4 to 8 days to fully plant the beach. Planting will
begin in late spring and continue through mid‐fall as tides allow. At the end of every shift, any
leftover materials (e.g., PVC tubes, mesh caps, area nets) will be loaded onto the work skiff and
taken back to the staging area.
Routine maintenance of the proposed geoduck aquaculture area ensures that gear is preserved on‐
site, and will begin once gear has been installed. Maintenance will occur on a monthly basis, and
immediately following large storm events. Maintenance activities include monitoring shellfish
weight and health, picking up unnatural debris (if any), ensuring that predator netting is suitably
anchored to the substrate, ensuring that PVC tubes are not becoming dislodged from the substrate,
and any other general maintenance activity required. Crews must walk over the culture beds and
immediately adjacent areas to perform almost all activities that occur on the beds. This would
typically be done by a 2‐person crew over a 4‐hour period.
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2.2 Maintenance
2.2.1 Site Inspection
Regular site inspections will be made during low tides to ensure that tubes and netting have not
become dislodged and drifted onto the beach. All debris will be removed from the beach to
prevent it from entering the water. These regular inspections will continue until all tubes and
netting have been removed from the beach. Inspections will typically be made with 2 to 4 workers
and staged from the 24‐foot work skiff. Inspections will include monitoring for build‐up of drift
macroalgae. Ulva can unexpectedly inundate a given farm, covering tubes entirely and choking
out all sea‐life below, including juvenile geoduck clams. Drift algae is typically heaviest in late
spring to mid‐summer months. If a given farm area becomes heavily infested with the drift algae,
the algae can be picked up and moved to the top of the farm area where it can be distributed on
the upper beach portion that is not used for farming.
2.2.2 Cap Removal
As soon as 6 to 12 months after planting, the mesh caps and rubber bands may be removed from
the tubes by hand. Prior to removal, caps will be inspected for herring spawn. If any herring
spawn is found, no caps will be removed until eggs have hatched. Once caps have been removed,
area netting will be laid over the tubes to stabilize them and keep them in the substrate, as the
growing geoducks will begin to push these out of the sand. Area netting will be secured with 24‐
inch rebar stakes placed vertically into the substrate as well as rebar stakes laid horizontally along
the netting. This method will ensure that netting cannot float free and become a safety or
navigation hazard.
2.2.3 Tube and Net Removal
The tubes will be removed when the geoducks have reached a depth sufficient to avoid predators.
The depth to which the geoducks can burrow is typically substrate driven, and they tend to
burrow more quickly in sandy substrates versus those substrates containing a mixture of shell or
gravel. In sandier substrates, the geoducks may burrow to the desired protective depth of 18 to 24
inches in 18 months, whereas in substrates with more gravel, it may take as much as 24 months to
accomplish this. In either case, tube removal should be completed within 24 months of planting.
All gear installed on a particular beach must be removed during the lowest tides of the year. When
a particular beach is ready for gear removal, workers will come to the beach by boat and remove
all area nets to expose the tubes for removal by hand. Prior to removal, tubes and nets will be
inspected for herring spawn. If any herring spawn is found, no tubes will be removed until eggs
have hatched. After the area nets have been unstaked and removed to the work boat, workers will
remove and place the tubes (and caps if they haven’t already been removed) in large bags that will
be stored on the work boat until all the gear is removed from the site.
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Tube and net removal will be done from winter to early summer to avoid Ulva buildup, as the
weight of accumulated Ulva can add thousands of pounds to nets. A crew of 10 workers will be
used to remove approximately 5,000 tubes per day.
2.3 Harvesting
Geoduck clams will be harvested using either dry or wet (i.e., diving) harvest methods. Both
methods employ low‐pressure seawater that is pumped into the substrate through a 1‐ to 2‐inch‐
diameter, hand‐operated hose with a 0.5‐ to 0.6‐inch‐diameter PVC “stinger.” The stinger is
inserted into the sediment directly adjacent to a visible geoduck siphon. The pressure at the nozzle
is approximately equivalent to a garden hose (e.g., 40 pounds per square inch and 20 gallons per
minute). This method allows for the extraction of geoducks without the removal of large quantities
of overlying sediments. Pumps for the hoses would be run by small, boat‐based, internal
combustion engines located adjacent to the harvest site. Water intake lines on the pumps would be
fitted with screens that meet National Marine Fisheries Service (NMFS) screening criteria to
prevent fish entrainment.
Harvesting, either dry or wet, would be accomplished by 2‐ to 4‐person teams. Dry harvesting
would occur during a minus tide series (typically lasting 4 to 6 hours), and wet harvesting would
occur during a high tide series. The duration of harvest may exceed 4 to 6 hours a day if extended
high tide periods during the winter are coupled with the appropriate low tidal cycle to allow dive
harvest during daylight hours and beach harvest during the evening. Under most conditions, dry
and wet harvesting would not occur in the same day.
2.4 Habitat Management Plan
Avoidance, conservation, and minimization measures that would be adopted at the proposed
geoduck farm are consistent with those outlined in relevant shellfish culture conservation
measures adopted by the U.S. Army Corps of Engineers (Corps) in their programmatic
consultation with the NMFS (2016a) and USFWS (2016) on Nationwide Permit 48 for shellfish
farming in the State of Washington. Avoidance of potential effects, where possible, is the priority.
The avoidance, conservation, and minimization measures at the proposed geoduck farm include
the following and are described in more detail in Sections 2.4.1, 2.4.2, and 2.4.3:
Maintenance, Repair, and Work
Species‐Specific Activities
Farm Plan Record‐Keeping Log
2.4.1 Maintenance, Repair, and Operation
1. Damage to aquatic vegetation and substrates from boats or barges will be minimized/
avoided through the following practices:
Measures shall be implemented to prevent anchors, chains, and ropes from dragging
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Boats and barges shall be moored and operated in deeper water and away from
aquatic vegetation to prevent potential impacts from propeller scour or anchors. If
boats need to come into the project area for personnel or gear access, then vessels
shall not ground in native eelgrass or attached kelp beds.
Intertidal areas shall not be used to store materials such as tools, bags, marker stakes,
rebar, or nets. Materials that are not in use or immediately needed shall be removed
to an off‐site storage area and the site kept clean of litter.
All excess or unsecured materials and trash shall be removed from the beach prior to
the next incoming tide.
Moving large substrate materials (e.g., logs, rocks) during aquaculture operations
shall be avoided to the extent feasible. Where the relocation of such features is
necessary, they shall be relocated no farther than another section of the nearby
beach.
There shall be no modification of substrate in an effort to improve conditions for
geoduck clam aquaculture.
2. Operators of vehicles or machinery will reduce contamination from vehicles and
equipment through the following practices:
Pump intakes (e.g., geoduck harvest) that use seawater shall be screened in
accordance with NMFS and Washington Department of Fish and Wildlife (WDFW)
criteria to protect fish life.
Unsuitable material (e.g., trash, debris, asphalt, or tires) shall not be discharged or
used as fill (e.g., used to secure nets, create berms, or provide nurseries).
All vessels operated within 150 feet of any stream, waterbody, or wetland shall be
inspected daily for fluid leaks before leaving the staging area. Repair any leaks
detected in the staging area before resuming operation.
3. At least once a month and directly following storm events, beaches in the project vicinity
shall be patrolled by crews who will retrieve aquaculture debris (e.g., predator exclusion
nets, tubes) that escape from the project area. Within the project vicinity, locations shall be
identified where debris tends to accumulate due to wave, current, or wind action, and after
weather events these locations shall be patrolled by crews who will remove and dispose of
debris appropriately.
4. The grower shall not use tidelands waterward from the line of mean higher high water
(MHHW) for the storage of aquaculture gear. All aquaculture gear shall be stored and
sorted at an upland facility and transported to the project area at the time of deployment.
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5. The grower shall ensure that predator exclusion nets are secured to prevent them from
escaping from the project area.
6. Employees shall be trained in meeting environmental objectives.
2.4.2 Species-Specific Activities
1. A Pacific herring spawn survey shall be conducted prior to undertaking the activities listed
below if any of these activities occur outside the Tidal Reference Area 13 in‐water work
window, which is April 15 through January 14 (Washington Administrative Code [WAC]
220‐110‐271). Activities requiring a spawn survey include: (1) culture tube placement, (2)
geoduck harvesting, (3) predator exclusion net placement or removal, and (4) culture tube
removal. Vegetation, substrate, and aquaculture materials (e.g., nets, tubes) shall be
inspected for Pacific herring spawn. If herring spawn is present, these activities are
prohibited in the areas where spawning has occurred until the eggs have hatched and
spawn is no longer present (typically 2 weeks). Records shall be maintained, including the
date and time of surveys; the area, materials, and equipment surveyed; results from the
survey; etc. The record of Pacific herring spawn surveys shall be made available to the
Corps, NMFS, and U.S. Fish and Wildlife Service (USFWS), upon request.
2. Shellfish culturing shall not be placed above the tidal elevation of +7 feet MLLW if the area
is documented as surf smelt spawning habitat by WDFW (note the project will be confined
below +2 feet MLLW).
3. Shellfish culturing shall not be placed above the tidal elevation of +5 feet MLLW if the area
is documented as Pacific sand lance spawning habitat by WDFW (note the project will be
confined below +2 ft MLLW).
2.4.3 Farm Plan Record-Keeping Log
Logs will be kept to record the timing, personnel, and findings of the following surveys and/or
cleanup activities.
1. Pacific herring spawn surveys: The grower shall maintain a record with the following
information and the record shall be made available upon request to the Corps, NMFS, and
USFWS: date of survey, location of area patrolled, surveyor name, and whether herring
spawn was observed in the project area.
2. Spills or cleanups conducted on the beach: The grower shall maintain a record with the
following information and the record shall be made available upon request to the Corps,
NMFS, and USFWS: date of patrol, location of areas patrolled, description of the type and
amount of retrieved debris, and other pertinent information.
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3.0 EFFECTS ANALYSIS
The “no net loss” standard contained in WAC 173‐26‐186 requires that the impacts of shoreline use
and/or development (e.g., geoduck aquaculture) be identified and mitigated such that there are no
resulting adverse impacts to ecological functions or processes. The Washington State Department
of Ecology (Ecology) defines no net loss as meaning that no significant adverse impacts to
preexisting ecological function shall occur as a result of proposed shoreline development. Jefferson
County further defines no net loss as “the maintenance of the aggregate total of the county
shoreline ecological functions over time.” Ecological function is defined by the County as “the
work performed or role played by the physical, chemical, and biological processes that contribute
to the maintenance of the aquatic and terrestrial environments that constitute the shoreline’s
natural ecosystem” (JCC 18.25.100(5)(a)).
In the following analysis, habitat and species indicators serve as a proxy for ecological function.
By avoiding impacts to species and the habitats upon which they rely, impacts to ecological
functions will be avoided as well.
The following specific factors are assessed in the following analysis of effects:
Noise
Water quality
Sediment quality
Sediment transport and bathymetry
Migration, access, and refugia
Forage fish
Benthic infauna and epifauna
Aquatic vegetation
Macroplastics, microplastics, and toxicity
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3.1 Noise
Changes in noise can result behavioral disturbance or, if loud enough, injury. The following
section describes existing noise conditions and expected effects of the proposed action.
3.1.1 Existing Conditions
Existing sources and levels of airborne as well as underwater noise are described in this section.
3.1.1.1 Airborne Noise
The uplands neighboring the proposed Smersh geoduck farm are rural residential, and they are
zoned as shoreline residential under the current Shoreline Master Plan for Jefferson County. There
are numerous single‐family residential houses in the Shine neighborhood which is bordered on the
north side by the heavily trafficked Sstate Route (SR) 104. Between 6,000 and 22,000 vehicles pass
the Shine neighborhood each day on SR 104 (15,000 average annual daily trips) traveling at 60
miles per hour (WSDOT 2017). Existing noise in the area includes that which is typically found
associated with water‐dependent activities (e.g., boat use), residential uses (e.g., vehicle use, lawn
mowers, beach walking), and vehicular traffic. Using the standard that 10 percent of the average
annual daily traffic represents hourly average traffic (WSDOT 2018) leads to 1,500 vehicles per
hour passing near the Shine neighborhood on SR 104. At 60 mph the sound from vehicle traffic is
approximately 75 dBA at 50 feet (WSDOT 2018). This sound level attenuates to approximately 45
dBA at 800 feet which is approximately the halfway point between the Smersh parcel and SR 104.
The estimated noise level based on population density is approximately 40 to 45 dBA (FTA 2006).
3.1.1.2 Underwater Noise
Measurements of ambient underwater noise were recorded at the Hood Canal Bridge in 2004.
Median background peak sound pressure was between 118.2 and 137.5 dBPEAK re 1 μPa and
median root mean squared (RMS) levels were 115 and 135 dBRMS re 1 μPa (Battelle 2005).
3.1.2 Effects of Noise
Noise‐generating elements of the proposed project are consistent with existing use of the
surroundings (small boat use and walking on the beach). Both airborne and underwater noise
would be generated from the proposed project when boats are used to access the project site and
during the operation of pumps for harvest on a 5‐ to 7‐year cycle. The potential to affect fish and
wildlife in relation to noise is described below.
3.1.2.1 Effects of Airborne Noise
The proposed project does not include the use of heavy equipment. Access to the site would occur
about once a month, and more frequently during limited periods for activities such as planting or
harvesting. Access would be via the upland parcels or via boat. The outboard motors typically
used on boats used for aquaculture typically create a noise level of about 60 dBA at 50 feet (Berger
et al. 2010). However, once at the site, the engine would be turned off until employees are ready to
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leave. Small diesel‐ or gas‐powered water pumps with hoses would be used to harvest the
geoducks for several days every 5 to 7 years. While noise levels of the water pumps have not been
directly measured, they are considerably quieter than the outboards, referenced above, that
produce a sound level of 60 dBA at 50 feet. Based on an ambient noise level of approximately
40 dBA to 45 dBA, terrestrial noise associated with the proposed project is expected to attenuate to
ambient conditions 199 to 285 feet from the pumps. The landward margin of the geoduck planting
area is approximately 160 feet from the ordinary high water line, leading to the conclusion that
nearby residents will be exposed to only slight increases in noise if they approach within close
proximity to the shoreline near the project site.
Noise associated with aquaculture operations during planting, maintenance, and harvesting
activities could, if loud enough, result in temporary displacement of birds and/or masking of
communication among foraging birds. Strachan et al. (1995 as cited in USFWS 2009) observed that
marbled murrelets around heavy boat traffic do not appear to be adversely affected by the ambient
noise of urban areas. Other waterbirds have shown behavioral changes in response to noise, but
not to the extent that would cause population‐level effects as long as distances of approximately
164 feet to 328 feet are maintained from nesting habitats (Carney and Sydeman 1999, Borgmann
2010).
Because bald eagles are a state sensitive species in Washington, and protected under the federal
Bald and Golden Eagle Protection Act, there is an emphasis on ensuring that shoreline activities, in
general, do not disturb eagles. WDFW studied the response of nesting bald eagles for a 2‐year
period (1993‐1994) in relation to recreational pedestrian activity and wildstock geoduck harvest
activities within eight territories in Puget Sound (Watson et al. 1995). Eagles flushed in response to
4 percent of 890 potential disturbances, and only 1 of 34 responses was a result of geoduck harvest
activities. Effects to eagle foraging from geoduck harvest activity was considered statistically
insignificant at the frequency tested1, and eagles tended to forage evenly throughout the day with
or without a harvest vessel present. Similar effects are anticipated due to the proposed project.
The threshold for masking marbled murrelet communication is an in‐air noise level of 29 dB
sensation level (SL) or 29 dB above ambient noise level (Teachout 2013). This threshold was
informed by two critical hearing demands: (1) communication between conspecifics (at‐sea or in
terrestrial habitat), and (2) detection of the presence of corvid predators in terrestrial habitat. It is
unlikely that the noise generated by the proposed geoduck aquaculture operation would result in
masking marbled murrelet communication because the use of water pumps during a wet harvest
(the loudest noise source proposed for the project) is expected to increase noise levels by 15 dBA to
20 dBA above ambient noise levels (assuming 60 dBA produced by the water pump and 40 to 45
dBA ambient noise).
1 Frequency of geoduck harvest activities tested by Watson et al. (1995) included two weekday bouts when harvest boats were
present, followed by two weekend control days when boats were absent, for a total of 296 observational bouts and 1,896 hours.
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Considering the distances from nesting sites from the proposed project area, negative effects
associated with increased human presence are not anticipated at this site. Even if some short‐term
avoidance behavior is observed, there is nothing to indicate that this reaction would impact the
overall foraging ability of birds present in the project area. Therefore, it is unlikely that such
temporary displacement from foraging activities in the limited project area would result in
reduced foraging success, nesting success, or fitness of overwintering birds. This concurs with the
conclusions reached by USFWS (2016), that determined exposures and effects of aquaculture‐
related noise to marbled murrelets are insignificant.
3.1.2.2 Effects of Underwater Noise
Underwater noise would also be generated from the motors on boats used to transport gear and
personnel to the project area and the small engines used for the water pumps during a geoduck
harvest. Underwater noise thresholds for fish, cetaceans, pinnipeds, and marbled murrelets are
presented in Table 1.
Table 1 Underwater Noise Thresholds by Functional Hearing Group
Functional Hearing Group Underwater Noise Thresholds
Behavioral Disruption Threshold Injury Threshold
Fish > 2 grams
Fish < 2 grams
Fish all sizes
150 dB RMS
187 dB Cumulative SEL
183 dB Cumulative SEL
Peak 206 dB
Marbled Murrelet 150 dB RMS* 208 dB SEL (barotrauma)
202 dB SEL (injury)
Low-Frequency (LF)
Cetaceans 120 dB RMS** LE,LF,24h:199 dB Cumulative SEL
(non-impulsive sound source)
Mid-Frequency (MF)
Cetaceans 120 dB RMS** LE,MF,24h: 198 dB Cumulative SEL
(non-impulsive sound source)
High-Frequency (HF)
Cetaceans 120 dB RMS** LE,HF,24h: 173 dB Cumulative SEL
(non-impulsive sound source)
Phocid Pinnipeds (PW)
(Underwater) 120 dB RMS** LE,PW,24h: 201 dB Cumulative SEL
(non-impulsive sound source)
Otariid Pinnipeds (OW)
(Underwater) 120 dB RMS** LE,OW,24h: 219 dB Cumulative SEL
(non-impulsive sound source)
1 dB re 1 μPa2 -sec = sound exposure level (SEL)
RMS = root-mean-square; this is the square root of the mean square of a single pile driving impulse pressure event
*USFWS considers this to be a guideline, not a threshold
** NMFS’s interim sound threshold for behavioral effects
Source: NMFS 2016b, Teachout 2013
To estimate underwater noise that might result from geoduck aquaculture, we reviewed Table 3.73
of Wyatt (2008) to find a close approximation of the underwater noise generated from boats that
would be used for the proposed project. In order to estimate the worst‐case scenario for
underwater noise, the parameters used for this analysis were the 21‐ft Boston Whaler vessel with a
250 horsepower Johnson 2‐cycle outboard motor operating at full speed and producing sound
measured at 147.2 dB RMS re 1μPa at 1 meter. Following Equation 1, underwater sound of this
level attenuates to the disturbance sound level for marine mammals 213 feet from the boat. Sound Log Item 1
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levels produced by the boat do not reach injury levels for any marine mammal group. Nor do
sound levels reach disturbance or injury levels for murrelets and fish.
Equation 1 R1 (in meters) = R2 (in meters)*10((V‐120)/15)
R1 = 1m*10(147.2 dB‐120 dB)/15)
R1 = 65 m (213 ft)
Where:
R1 = range in meters of the sound pressure level; R2 = distance from the sources of the initial
measurement; V = transmission loss; and dB = decibels
3.1.3 Summary of Noise Effects
According to NMFS’s 2009 assessment of potential impacts to endangered species due to geoduck
aquaculture activities, “A very low level of vessel operations will be associated with the
aquaculture activities (small and larger work boats and barges). Vessels would remain relatively
immobile until work is complete, with minimal sound and insignificant potential for disturbance.”
There is no evidence that increases in either airborne or underwater noise from the use of boat
motors or water pumps associated with the rearing and harvest of geoducks would result in
negative effects to fish and wildlife species. Noise resulting from aquaculture operations
throughout Washington State was reviewed with respect to potential effects to Endangered
Species Act (ESA‐listed fish, marine mammals, and marbled murrelets (NMFS 2009, USFWS 2009,
NMFS 2011). These reviews found that noise levels did not exceed disturbance thresholds that
would affect foraging, migration, reproduction, or fitness for any of the ESA‐listed species in Puget
Sound. The proposed shellfish aquaculture operation in Squamish Harbor would not significantly
alter noise above existing background conditions. Therefore, harvest operations are not anticipated
to increase underwater noise to a level that will result in a loss of ecological functions
3.2 Water Quality
This section describes existing water quality conditions and the expected effects of the proposed
project.
3.2.1 Existing Conditions
Water quality effects are a function of water circulation (or flushing rate and transportation) and
inputs into the system. Due to its proximity to the entrance to Hood Canal, Squamish Harbor
flushes quickly compared to southern Hood Canal. No waters near the project area are listed on
the Federal Clean Water Act Section 303(d) list (Ecology 2018), indicating that upland sources of
pollution are low and circulation maintains good water quality parameters.
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3.2.2 Effects to Water Quality
Potential effects to water quality and fish and wildlife species or their habitat are different for the
various phases of potential aquaculture activities. The following discussion is broken down into
(1) filtration effects and (2) harvest effects.
3.2.3 Filtration Effects
Per Thom et al. (2008), Pacific Northwest estuaries are light limited, which reduces the depth at
which eelgrass and other light‐dependent species (e.g., macroalgae/kelp) can be successful.
Shellfish aquaculture can result in a beneficial reduction in turbidity due to removal of
phytoplankton and particulate organic matter through filtration (Peterson and Heck 2001, Newell
and Koch 2004, Cranford et al. 2011). By consuming phytoplankton and particulate organic matter,
shellfish decrease turbidity, thereby increasing the amount of light reaching the sediment surface
that is available for photosynthesis (Dame et al. 1984, Koch and Beer 1996, Newell 2004, Newell
and Koch 2004). Improvements to water clarity and light penetration can improve habitat
conditions that promote the growth of submerged aquatic vegetation (SAV) and other aquatic
vegetation.
A large body of literature indicates that shellfish aquaculture, or the presence of a dense bivalve
community, may provide some control of human nutrient loading to water bodies (Newell 2004,
Shumway et al. 2003, Newell et al. 2005, Burkholder and Shumway 2011, Kellogg et al. 2013, Banas
and Cheng 2015, Bricker et al. 2015). Bivalves remove more nutrients from the water column than
they input as biodeposits, which can have a net benefit to water quality. As bivalves filter organic
matter from the water column, they assimilate nitrogen and phosphorus into their shells and
tissue. When shellfish are harvested, the sequestered nutrients are permanently removed from the
system. According to Newell (2004), this process of bioextraction is one of the only methods
available that removes nutrients after they have entered an aquatic system, which can then make
that system more resilient to nutrient loading and, ultimately, decreases in dissolved oxygen.
High nutrient loading, and resulting decreases in dissolved oxygen, are a known problem in Hood
Canal. Similarly, bivalve filter‐feeding also serves an important role in improving water quality
conditions through benthic‐pelagic coupling, which is when biodeposits become incorporated into
surficial sediments, and microbially mediated processes facilitate nitrification‐denitrification
coupling to permanently remove sediment‐associated nitrogen as nitrogen gas.
The amount of benefit to water quality is dependent on species‐specific filtration rates. A recent
effort to calculate filtering capacity within south Puget Sound (Ferriss 2015) compiled clearance
rates for Pacific oyster, Manila clam, and geoduck (Table 2). According to Banas and Cheng (2015),
a modeling study that used the data compiled by Ferriss (2015), the potential for local control by
shellfish was shown to be possible in areas with reduced circulation such as Henderson, Eld,
Totten, Hammersley, and upper Case inlets, and Oakland Bay. While Banas and Cheng’s study
focused on southern Puget Sound, Hood Canal exhibits similar circulation patterns and clearance
rates when compared to southern Puget sound. Therefore, shellfish filtration could have a positive
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influence on local water quality parameters, even if small compared to the inputs into the system
from residential development, municipal wastewater, agriculture, or other non‐point sources.
Table 2 Clearance Rate Calculations for Pacific Oyster, Manila Clam, and Geoduck
Species Indiv. Wwet (g) L hr-1 indiv-1 L hr-1 Wwet-1 Source
Pacific oyster 11.52 3 0.260 Kobayashi et al. 1997, Ruesink et al. 2006
Manila clam 18.19 1 0.060 Ruesink et al. 2006, Solidoro et al. 2003
Geoduck 980 3 0.003 Davis 2010
Source: Ferriss 2015, Banas and Cheng 2015
An example of the potential benefits offered by shellfish filtration and nutrient sequestration is
provided by Kellogg et al. (2013), who partially quantified the removal of nutrients from the water
column at a subtidal oyster reef restoration site compared to an adjacent control site in the
Choptank River within Chesapeake Bay, Maryland. The authors indicated that denitrification rates
at the oyster reef in August were “among the highest ever recorded for an aquatic system.” In
addition, a significant portion (47% and 48%) of the available nitrogen and phosphorus were
sequestered in the shells of live oysters and mussels. An ancillary benefit of the shellfish reef
structure, which is also true for shellfish aquaculture, was that the structure and faunal
composition provided ample microhabitats for communities of nitrifying microbes. One of the
conclusions by Kellogg et al. (2013) was that oyster reef restoration could be considered a “safety
net” to reduce additional downstream impacts to water quality. Because geoduck aquaculture
provides many of the same benefits, with the added benefit of the total removal of
anthropogenically derived nutrients at harvest, commercial shellfish aquaculture can be
considered a net benefit to water quality ecosystem functions.
3.2.4 Harvest Effects
During harvest, suspended sediment and turbidity can be increased for a short period near the
harvest activity. Harvest events are limited in space (about 0.1 acre per day), duration (4 to 6 hours
per day), and occurs infrequently (once every 5 to 7 years) compared to the entire culture cycle.
The intensity and duration of turbid conditions are related to the concentration of suspended
sediment, suspended sediment grain size, water temperature, currents, and tidal flow conditions
at the site (NMFS 2009). Golder (2016) modeled sediment movement and suspension of sediment
(primarily sand) disturbed during a geoduck harvest in Case Inlet. Sediment particles were shown
to settle back to the bed rapidly and only a minor fraction was transported a distance of about 300
feet. This result is consistent with total suspended solids (TSS) collected by Short and Walton
(1992) during a geoduck harvest in the Nisqually Reach, where it was noted that most sediment
was deposited within 3 feet of the harvest hole, and only “small quantities of material” were
transported beyond 150 feet from the harvest zone. TSS measured by Short and Walton (1992) at
the harvesting location ranged from 4 to 21 mg/L. While a visible harvest plume persisted for
approximately 30 minutes after harvest and extended approximately 330 feet down current, almost
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all TSS measurements within 131 feet of the harvest were shown to be within 1 mg/L of
background TSS.
New research from Fisheries and Oceans Canada, Pacific Biological Station in British Columbia,
Canada, has shown similar or lower effects from wet geoduck harvest events. A 2‐year research
program in both intertidal and subtidal habitats reported that the measurable sediment plume
generated during a geoduck harvest event was generally limited to within approximately 16 feet of
the harvest plot, and TSS levels were similar to those reported during typical storm conditions (Liu
et al. 2015). In addition, a harvest event did not result in significant changes to sediment grain size
down‐current.
Cornwell et al. (in review) evaluated the nutrients released from a typical commercial geoduck
harvest using low‐pressure water hoses. The study found that: (1) the amount of nutrients released
into the water column during harvesting is low, (2) the moderate concentrations of nitrogen and
phosphorus found in sediments and released during harvest make a relatively small contribution
to overall nutrient discharges into Puget Sound, and (3) localized effects are likely to be negligible.
A typical geoduck harvest event is limited in space (about 0.1 acre for 1 day), duration (4 to 6
hours), and occurs infrequently with respect to the entire culture cycle (i.e., 5‐ to 7‐year grow‐out
period prior to harvest). In comparison, a typical storm event in Puget Sound occurs once per
month and transports material over thousands of kilometers. Therefore, both the timing and
intensity of activities are well below the natural disturbance regime of a typical Puget Sound
habitat and harvest is not anticipated to result in loss of ecological functions.
Exposure to high levels of suspended sediment can cause behavioral stress in fish (e.g., gill
flaring), sublethal effects (e.g., gill damage, increased susceptibility to disease), or reduced survival
and growth. Newcombe and MacDonald (1991) suggested that a good indicator of suspended
sediment effects is the product of sediment concentration and duration of exposure. Fisher et al.
(2008) evaluated whether the TSS generated during a harvest event could result in significant
effects to fish using the suspended sediment risk assessment model developed by Newcombe and
Jensen (1996). The results indicate that fish are likely to exhibit avoidance responses to the
localized TSS levels generated during a harvest event. Because there is no confinement of the
harvest area (i.e., the site is located along an open shoreline) there is no mechanism to entrap fish
and expose them to increased suspended sediments for a significant amount of time.
Published literature that addresses suspended sediment effects to juvenile and larval estuarine
fishes also report limited effects at the concentrations generated during a geoduck harvest event.
Juvenile Chinook salmon have been observed to increase their rates of foraging in relation to
increased turbidity (18‐150 nephelometric turbidity units [NTUs]), which was attributed to the
increase in cover provided by turbid waters (Gregory and Northcote 1993, Gregory 1994). The
maximum concentration of turbidity that juvenile Chinook salmon experienced before reduced
foraging was observed was 150 NTUs for individuals that were 2 to 3 inches in fork length
(Gregory 1994). Studies have also reported increased feeding incidence and intensity for larval
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Pacific herring at TSS concentrations ranging from 500 mg/L to 1,000 mg/L (Boehlert and Morgan
1985). Boehlert and Morgan (1985) attributed the enhanced feeding to improved “visual contrast of
prey items on the small perceptive scale used by the larvae.” Finally, Griffin et al. (2012) noted that
TSS levels of 400 mg/L did not result in adverse effects for Pacific herring larvae for exposure times
of 16 hours. All of the TSS and turbidity levels noted in these examples are either within or
significantly higher than levels measured during a geoduck harvest, indicating that a harvest
would be unlikely to raise TSS to a level or duration that would have negative effects on salmon
and forage fishes. Also, environmental effects of geoduck harvests have been shown to be similar
to, or less than, the effects of periodic natural storms. Therefore, harvest activities are unlikely to
have a negative effect on fish.
3.2.5 Summary of Effects to Water Quality
Bivalves can improve water quality and mitigate anthropogenic sources of nitrogen in coastal
systems through filtration of nitrogen by absorbing phytoplankton in the water column (Newell
2004, Lindahl et al. 2005, Zhou et al. 2006). Conversely, a harvest event can potentially impact
water quality. Although a harvest event may increase suspended sediment for short periods of
time (one to two tidal cycles), it is typically confined to a small area (from 3 feet to 150 feet from
the harvest area) and occurs infrequently (every 5 to 7 years).
Fish would be expected to either avoid the sediment plume generated during a geoduck harvest or
use the plume as a foraging opportunity. Suspended sediment and turbidity levels measured
during geoduck harvest events were within or lower than the range in which juvenile Chinook
salmon and Pacific herring larvae were observed to successfully forage (Boehlert and Morgan
1985, Gregory 1994). Overall, effects from suspended sediments are considered insignificant and
habitat may potentially be improved in local areas if shellfish improve water quality conditions.
No net loss of ecological function is anticipated due to water quality impacts from geoduck
aquaculture.
3.3 Sediment Quality
This section describes existing sediment quality conditions and the expected effects of the
proposed action.
3.3.1 Existing Sediment Conditions
No sediment quality studies have been completed for the specific project site but the lack of
historic industrial development in Hood Canal indicates that sediment is unlikely to contain
deleterious substances regulated by the state. Substrate at the Smersh site consists mainly of
well‐sorted, clean sand.
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3.3.2 Effects to Sediment Quality
Bivalve filter feeding serves an important role through benthic‐pelagic coupling, which is the
consumption of nutrients (via filtration of phytoplankton) and creation of biodeposits (feces and
pseudofeces). Nitrogen and phosphorus that are not digested are excreted as soluble ammonia and
biodeposits in the form of feces. When these biodeposits become incorporated into aerobic,
surficial sediments, microbially mediated processes facilitate nitrification‐denitrification coupling
to permanently remove sediment‐associated nitrogen as nitrogen gas (Newell 2004, Kellogg et al.
2013).
The biodeposits created through bivalve filter feeding contribute to organic materials in the
sediment surface, as described above. Studies have identified changes in geochemical
characteristics associated with the sediment under predator exclusion netting when used in Manila
clam (or other hard clam) aquaculture operations, but the majority of literature indicates that these
changes do not represent negative impacts to the surrounding environment. According to Bendell‐
Young (2006) and Bendell et al. (2010), there may be statistically significant changes in the organic
content of sediments under Manila clam netting. However, other studies indicated that small,
detectable changes under netting do not appear to be significant in terms of overall impacts to
sediment quality (Spencer et al. 1997, Munroe and McKinley 2007). Further, many authors report
that effects from the use of predator exclusion nets are short‐term and do not persist following net
removal (Simenstad and Fresh 1995, Spencer et al. 1998). Based on a review of 35 peer‐reviewed
articles, Munroe et al. (2015) concluded that, “predator netting is an effective environmentally
acceptable means of farming clam crops.”
Effects from the use of predator exclusion netting in geoduck clam aquaculture may be similar to
Manila clam (or other hard clam) aquaculture, but the nets associated with geoduck clam
aquaculture may be present for a portion of the 7‐year culture cycle. This is compared to a nearly
constant presence of nets for Manila clam farming. Therefore, predator exclusion netting used for
geoduck aquaculture is unlikely to result in significant changes to sediment quality.
A study conducted for the Washington Sea Grant Geoduck Aquaculture Research Program
assessed the influence of geoduck aquaculture on sediment nutrient regeneration (Cornwell et al.
in review). During the culture period of the study, porewater nutrient concentrations of nitrogen
and soluble reactive phosphorus were higher at culture sites than at reference sites. The release of
nitrogen and phosphorus species during harvest resulted in a minor increase in nutrient
concentration of water surrounding the geoduck harvest, suggesting that the liquefication of
sediments does not release a large percentage of the accumulated nutrients in the porewater. The
authors concluded that when extrapolated to all Puget Sound cultivated geoduck harvest on a
daily basis, the harvest release of nutrients represents an inconsequential fraction of anthropogenic
inputs into Puget Sound, leading to the conclusion that geoduck harvest is unlikely to reduce
ecological function due to sediment or water quality effects.
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3.4 Sediment Transport and Bathymetry
This section describes existing sediment transport and bathymetry conditions and the expected
effects of the proposed action.
3.4.1 Existing Conditions
Sediment along the north shore of Squamish Harbor is primarily sandy in the lower elevations
with gravel and cobble on the upper intertidal beach. The beach slopes gradually and has a
relatively high exposure to waves, winds, and currents during storm events. East of the project
area there is a high bluff composed of various layers of glacial sediment. The bluff is characterized
by massive erosion that threatens several structures on the top of the bluffs (ESA Adolphson et al.
2008). The shoreline is classified as unstable recent landslide (Ecology 1978). Net shore‐drift is to
the west as indicated by sediment accumulations on the east side of obstacles and the westward
prograding spit at the mouth of Shine Creek ESA Adolphson et al. 2008). In the nearshore,
eelgrass beds are patchy in the intertidal zone and continuous below MLLW. Shoreline armoring is
prevalent along the north shore of Squamish Harbor, with about 26 percent of this reach armored
(Jefferson County 2008). A boat ramp extends onto the beach next to the project parcel, with a
parking lot located on fill. The effect of the armoring and boat ramp are unclear, but are likely
having at least a minor effect on sediment erosion and input.
3.4.2 Effects to Sediment Transport and Bathymetry
No dredging or placement of fill is proposed as part of the project. The two types of potential
disturbances associated with shellfish aquaculture that could affect sediment transport and
bathymetry include: (1) addition of gear that slows the transport of sediments, and (2) pulse
disturbances due to effects of harvest activities (Dumbauld et al. 2009). These potential
disturbances are described below.
3.4.3 Addition of Gear
Predator exclusion netting and culture tubes used in geoduck clam aquaculture can slow currents
near the substrate, resulting in accumulation of sediment under the nets. Golder (2011) estimated
the potential accumulation of sediment within the tubes from an existing geoduck aquaculture
operation in south Puget Sound. Based on a visual inspection, an average height of 2.5 ±0.5 inches
of sediment accumulation was reported within the 4 inches of tube that was exposed above the
sediment bed. This equates to a volume of approximately 31.4±6.3 cubic inches per tube. Golder
(2011) then calculated net accumulation over a 1‐acre area to be approximately 29.3 cubic yards
(cy) of sediment. This minor amount of net accumulation is expected to rapidly redistribute
through wave and current action after 1 or 2 tidal cycles (or a few days with typical wave
conditions) following the removal of nets and tubes.
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3.4.4 Harvest Activities
During a geoduck harvest, the overlying sediments are loosened around the clam by adding water
through a 0.5‐inch‐ to 0.6‐inch‐diameter hose. Although this activity results in minor, localized
changes in elevation and sediment grain size, both quickly return to baseline conditions post‐
harvest. At Samish Bay, Horwith (2009) reported that minor post‐harvest elevation drop was not
evident within 1 month of a harvest. Post‐harvest resettling of sediments occurs as water content
decreases, leading to an increase in shear strength and resistance to erosion. In laboratory
experiments with fine‐grained marine sediment, resistance to resuspension was shown to double
approximately every 12 hours (Southard et al. 1971 as cited in Short and Walton 1992). Therefore,
the sediment redeposited during a harvest event will tend to regain its original shear strength
within 1 or 2 days after harvest.
3.4.5 Summary of Effects to Sediment Tranport and Bathymetry
In summary, geoduck harvest or the presence of culture tubes and/or predator exclusion nets does
not lead to significant negative effects to sediment transport or bathymetry. Minor changes in
elevation may persist for up to 1 month, but these effects are considered to be short‐term with no
lasting changes to the surrounding sediment structure. The changes associated with geoduck
aquaculture operations are insignificant compared to the dynamic nature of sediment distribution
potential (e.g., storms, littoral drift, etc.) along the shoreline associated with the project area. No
loss of ecological function is anticipated due to changes in sediment transport or bathymetry.
3.5 Migration, Access, and Refugia
This section describes existing migration, access, predation, and refugia conditions and the
expected effects of the proposed project.
3.5.1 Existing Conditions
Shine Creek, approximately 1.5 miles to the west supports chum and coho salmon and cutthroat
and steelhead trout spawning. The Shine Creek estuary is likely rearing habitat for natal and non‐
natal juvenile pink, chum, coho, and Chinook salmon (ESA Adolphson et al. 2008). A small stream
enters Squamish Harbor near the project site (>150 feet to the north) and is presumed cutthroat
trout habitat (Correa 2003). This small stream does not support salmon because access to upstream
habitat is hindered by (1) the very small size of the stream, and (2) the steep gradient where the
stream flows through shoreline armoring (i.e., boulder riprap). Sand lance spawning has been
documented along the beach to the west of the project and herring are known to spawn in the
eelgrass beds offshore (Penttila 2000, Long et al. 2003).
The project site is a sandy, gravelly beach with no man‐made structures. Juvenile salmonids and
other fish may use the intertidal area, when inundated, for migration, access, and refugia.
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3.5.2 Effects to Migration, Access, and Refugia
Predator netting and PVC tubes are the only material planned for use in aquatic areas for this
project. PVC tubes extend only 3 to 5 inches above the substrate surface. Predator netting, when
laid over PVC tubes, will add only an inch or less to the height of the tubes. When predator
netting is used on the beach it will add only an inch or less to the height of the substrate. No other
equipment is planned for use in the project and no excavation or alteration of the beach is planned.
Neither tubes nor netting will block migration or access to habitat in the project area.
The planting area is over 150 feet from the mouth of the nearby stream. All species of Puget Sound
salmon are well documented utilizing estuarine and nearshore habitat in their migrations from
their natal freshwater watersheds to the ocean and back (Duffy et al. 2010). Salmon are known to
feed in habitat similar to that found in the project area, ingesting amphipods, copepods, larval fish,
and terrestrial insects (Fresh et al. 2006). Depending on the tidal cycle, fish can easily swim over,
around, or through PVC tubes or predator netting, if necessary. Many researchers have reported
that aquaculture gear is similar (or superior) to adjacent eelgrass habitat in terms of the diversity
and abundance of benthic fauna and fish (Meyer and Townsend 2000, DeAlteris et al. 2004, Pinnix
et al. 2005, Powers et al. 2007).
Sand lance spawn in sandy substrate in the upper intertidal zone between MHHW and +5 feet
(MLLW) (Pentilla 2007). Because project planting, grow‐out, and harvest will not extend above +2
feet elevation, access to sand lance spawning habitat will not be reduced.
As long as the gear is properly maintained, geoduck culture tubes and predator exclusion nets in
the intertidal area are not expected to affect migration, access, or refugia pathways for fish that
utilize shallow water. The presence of aquaculture gear may even serve as additional foraging
habitat or cover from predators. No loss of ecological function is expected to occur due to effects to
migration, access, and refugia.
3.6 Forage Fish
This section describes existing forage fish conditions and the expected effects of the proposed
project.
3.6.1 Existing Conditions
Sand lance spawning has been documented along the beach to the west of the project and herring
are known to spawn in the eelgrass beds offshore (Penttila 2000; Long et al. 2003). Sand lance
spawn in sandy substrate in the upper intertidal zone between MHHW and +5 feet (MLLW)
(Pentilla 2007) and typically select substrate with a diameter between 0.2 and 0.4 millimeters. In
the project area, the substrate found in the elevation range sand lance typically spawn is primarily
gravel, which is sub‐optimal for sand lance spawning. A dense eelgrass bed is found in the
subtidal zone at least 16 feet from the proposed planting area.
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3.6.2 Effects to Forage Fish
There are two potential effects to forage fish from the proposed geoduck aquaculture operation,
including: (1) spawning habitat could be overlapped, and (2) forage fish spawning areas could
receive suspended sediments during a harvest event. The potential for these effects to be
significant to forage fish or their habitat in the project area are discussed below.
3.6.3 Spawning Habitat Overlap
The proposed culture activities are not located at shoreline elevations where sand lance spawn.
Culture will be confined to the intertidal and subtidal zone below +3 MLLW, while the forage fish
spawn elevation begins at +5 MLLW. Therefore, the proposed project is not expected to impact
spawning habitat of these forage fish species. When the site is accessed by boat, boats would not be
beached above +5 ft MLLW. Boats will be moored or grounded in areas waterward of +5 ft MLLW.
Foot traffic for routine maintenance and beach surveys for debris will use consistent paths and will
not occur where potential forage fish spawning habitat may exist.
In some cases, aquaculture gear can provide a new substrate for herring spawn attachment in an
otherwise unstructured environment. Growers will be trained by a WDFW‐certified biologist to
recognize herring spawn. If herring spawn is observed within the geoduck farm, then those areas
will be avoided until the eggs have hatched. This conservation measure has been adopted by the
Corps as part of the ESA consultation process with the Services on the Programmatic Consultation
for Shellfish Activities in Washington State Inland Marine Waters (NMFS 2016a, USFWS 2016).
Therefore, the proposed project will not result in a loss of ecological function due to the project
overlapping forage fish spawning habitat.
3.6.4 Sediment Mobilization
If forage fish do spawn near the project area, there is a low potential for adversely impacting
spawning beds with sediment mobilized during harvest. Fines make up a small percentage of the
farm substrate, and sands (because they are denser) drop out of the sediment plume within a few
meters (Short and Walton 1992, Golder 2011). Therefore, there will be no loss of ecological function
due to effects to forage fish spawning habitat resulting from sediment mobilization.
3.6.5 Summary of Effects to Forage Fish
Because the project does not overlap sand lance spawning habitat, and because farming activity
will halt if herring spawn are observed within the project area, no loss of ecological function is
anticipated due to negative effects to forage fish spawning. Additionally, because sediments
mobilized during geoduck harvest settle out of the water column within a few feet of harvest
activity, no net loss of ecological function is anticipated due to mobilized sediment.
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3.7 Benthic Infauna and Epifauna
This section describes existing benthic infauna and epifauna conditions and the expected effects of
the proposed action.
3.7.1 Existing Conditions
Observations of epifauna in the proposed project area were consistent with Puget Sound sandflat
habitats (Dethier 1990, Dethier and Schoch 2005). Species observed at the project site include
various amphipods, various isopods, various polychaete worms, sand sole, English sole, various
sculpins, various shrimp, Dungeness crab, red rock crab, and various hermit crabs,
3.7.2 Effects to Benthic Infauna and Epifauna
Geoduck aquaculture may affect the benthic faunal community, including community changes
during: (1) culture tube placement, (2) use of predator exclusion nets, and (3) harvesting. The
effects of each action, the relative recovery period, and potential effects to benthic fauna are
discussed below.
3.7.3 Culture Tube Placement Effects
Placement of culture tubes is not expected to significantly affect benthic epifauna. Once the tubes
are placed, they are rapidly encrusted with epibiota that create a reef‐type structure and a biogenic
source for associated food organisms of juvenile salmonids (Cheney 2009, VanBlaricom et al. 2013).
Specific studies evaluating the use of geoduck farms by salmonids and other fish are ongoing.
However, based on shellfish aquaculture studies in similar sandflat habitats, the effects from a
tube field are likely beneficial to salmonids because of the additional food resources available
(Cheney 2009, NMFS 2011, NMFS 2016b, USFWS 2016). In fact, NMFS (2016b) concluded that
increased densities of benthic infauna at intertidal geoduck clam aquaculture sites may persist
even after removing the protective PVC tubes and netting. For example, at one aquaculture site in
southern Puget Sound, ENVIRON 2008 (as cited in NMFS 2016b) found the average number of
infaunal benthic organisms per sediment core from an unprotected seeded area was greater than
the density of infaunal benthic organisms found in a reference area located outside of the
aquaculture site. Thuesen and Brown (2011, as cited in NMFS 2016b) observed an increase in
biodiversity of benthic fauna in an intertidal geoduck farm using PVC tubes and predator nets,
and species richness was significantly higher compared to a control site and compared to a
geoduck farm without tubes and netting. Data from the Pacific Shellfish Institute (Cheney 2009)
documented up to a 30 percent increase of harpacticoid copepods (e.g., typical salmonid prey
items) on mesh tubes and nets at an existing geoduck aquaculture plot in Spencer Cove on
Harstine Island.
3.7.4 Predator Exclusion Netting Effects
Based on a review of the pertinent literature, Powers et al. (2007) noted that protective netting
placed over hard clam aquaculture sites supported elevated densities of mobile invertebrates and
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juvenile fishes similar to natural seagrass habitats. A 5‐year study of Manila clam culture in the
River Exe indicated that increased sedimentation under the netting resulted in increased benthic
productivity, although the infauna shifted from an assemblage dominated by predatory
polychaetes (before netting) to deposit feeders (after netting) that could exploit the increased
sedimentation and organic content (Spencer et al. 1996, 1997, 1998). Even in studies that have
shown minor changes to the benthic communities, the effects persisted as long as the nets were in
place and reverted to baseline conditions (or near baseline conditions) shortly after net removal or
harvest (Simenstad and Fresh 1995, Spencer et al. 1998, Munroe and McKinley 2007).
Potential effects to the benthic community from the introduction of PVC tubes with predator
exclusion nets was studied by McDonald et al. (2015). Effects on the benthic community from the
presence of geoduck aquaculture gear were found to be short‐term, with a short recovery period.
Similarly, as discussed above, the presence of shellfish aquaculture gear may increase benthic
invertebrate prey resources compared to what may be present without shellfish culture. Therefore,
presence of geoduck gear leads to an insignificant, or potentially beneficial, effect to benthic
infauna and epifauna.
3.7.5 Harvest Effects
Shellfish harvest disrupts the sediment and results in the loss of some benthic fauna (Hall and
Harding 1997, Ferns et al. 2000), although that does not mean that the loss is a significant impact to
that resource. The recovery rate of infauna varies in response to the timing and magnitude of the
disturbance as well as the location of the site to populations of organisms and the mobility of
organisms affected (Dernie et al. 2003). Intertidal habitats are exposed to a wide range of natural
disturbance regimes that are dominated by physical processes such as tides, storm‐generated
waves, inter‐annual variation in climate, and nearshore sediment transport. It is generally
assumed that benthos found in more dynamic sand and gravel habitats will recover more quickly
following physical disturbance than those found in less energetic muddy habitats based on the
adaptive strategies of the respective assemblages found in these environments (Kaiser et al. 1998,
Ferns et al. 2000). Microcosm studies appear to support this hypothesis (Dernie et al. 2003). In
general, benthic infauna recovered very quickly (weeks to months) in terms of both diversity and
abundance from small‐scale disturbances, especially within clean sand communities.
Price (2011) and VanBlaricom et al. (2015) reported that potential effects to benthic invertebrates
from a geoduck harvest event are within the natural disturbance regime. This work compared the
benthic community within harvested and non‐harvested plots and found that effects to benthic
infauna during geoduck harvest are similar to effects resulting from wind and wave energy due to
natural storms. Detectable disturbances quickly become indistinguishable from control plots
(VanBlaricom et al. 2015). Recovery of the benthic infauna is relatively rapid after a geoduck
harvest event because infauna are still preserved in roughly the same location, leading to rapid
recolonization (Price 2011). In addition, because a harvest cycle occurs every 5 to 7 years, there
would unlikely be compounded effects due to repeated harvesting of the same area (Liu et al.
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2015). The main conclusion from VanBlaricom et al. (2015) was that communities in Puget Sound
are well adapted to accommodate various types of disturbance. Because the frequency of
disturbance from geoduck harvest occurs at a much lower rate than storm events, infaunal and
epifaunal populations are unlikely to experience long‐term negative effects. Based on this
evaluation, it was determined that there were no long‐term measurable effects to resident
populations of invertebrates from geoduck harvest, and the intensity of potential effects was
equivalent to natural disturbances.
3.7.6 Summary of Effects to Benthic Infauna and Epifauna
Overall, the research indicates that the benthic infaunal and epifaunal community is not affected or
returns to baseline, or near baseline conditions, once the gear is removed or harvest is complete
(VanBlaricom et al. 2013, Price 2011, McDonald et al. 2015, Liu 2015, VanBlaricom et al. 2015).
Small benthic invertebrates produce more than one generation per year and thus have rapid
recolonization rates. Intertidal species have adapted to habitat changes. Chronic low‐intensity or
sporadic medium‐intensity intertidal substrate disturbances are within the range of “behavioral or
ecological adaptability” (Jamieson et al. 2001). Therefore, no net loss in ecological function is
anticipated due to impacts to benthic infauna and epifauna.
3.8 Aquatic Vegetation
This section describes existing submerged aquatic vegetation (SAV) conditions and the expected
effects of the proposed action.
3.8.1 Existing Conditions
A dense bed of eelgrass extends from approximately ‐3 ft MLLW, waterward of the project area to
an unknown depth. A narrow band of sparse, patchy eelgrass is adjacent to the dense native
eelgrass bed between approximately ‐2 and ‐3 feet MLLW. No native eelgrass was identified
landward of the upper edge of the patchy eelgrass bed. Several very sparse patches of non‐native
dwarf eelgrass (Zostera japonica) were observed distributed throughout the project area.
Macroalgae beds are not found in or near the project area. Typical of sand‐ and silt‐dominated
habitats in Puget Sound, ulvoids were present at a very low density (<2% surface coverage)
throughout the mid‐ and low‐intertidal zone (approximately +2 to ‐2 feet MLLW) attached to hard
objects such as derelict clam shells.
3.8.2 Effects to Aquatic Vegetation
Macroalgae density is anticipated to increase in the project area due to geoduck farming as the
PVC tubes and predator netting provide solid substrate required by macroalgae for attachment
and growth.
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Because the project will be located outside of a 16‐foot protective buffer from native eelgrass, no
negative effects are anticipated to occur to eelgrass due to the proposed project. No net loss in
ecological function will occur due to impacts to aquatic vegetation.
3.9 Summary of Potential Effects
Although shellfish aquaculture can result in short‐term, localized changes, overall there is a
potential net gain, or at worst, insignificant effect, as demonstrated above. Table 3 is a summary of
potential direct effects for each parameter discussed above.
Table 3 Summary of Potential Effects from Geoduck Aquaculture
Parameter Potential Effect Duration Level of Effect
Noise
Airborne Noise: minor increase
above background when boats or
pump motors are in use
Underwater Noise: minor
increase above background
when boats motors are in use
Airborne Noise: during transit
(boat motor) and during harvest
(pump)
Underwater Noise: during transit
Airborne Noise:
insignificant
Underwater Noise:
insignificant
Water Quality
Filtration: increased water clarity
locally by reducing plankton
blooms and nutrients
Harvest: increased suspended
sediments and nutrients
Fish Behavior: avoidance or
increased foraging
Filtration: during grow-out
Harvest: during harvest and for
about 1-2 tidal cycles
Fish Behavior: during harvest
Filtration: beneficial
(albeit small)
Harvest:
insignificant
Fish Behavior:
insignificant to
beneficial
Sediment Quality
Sediment quality: increased
density of geoducks can result in
increased organic content,
especially with nets in place.
Sediment quality: when nets are
in place (maximum of 2.5 years)
and very minor during grow-out
(5-7 years); not likely to be
significant with good circulation
Sediment quality:
insignificant
Sediment
Transport and
Bathymetry
Tubes and nets: minor accretion
of sediments within the tube
area/under nets
Harvesting: changes to elevation
and grain size
Tubes and nets: 2 years of grow-
out cycle; baseline conditions
within 1-2 tidal cycles
Harvesting: 1-4 months
Tubes and nets:
insignificant
Harvesting:
insignificant
Migration,
Access, and
Refugia
Tubes: the vertical relief (4-5
inches) is different than sandflat
habitat
Tubes: when tubes are present
(2 years)
Tubes:
insignificant
Forage Fish
Spawning: potential overlap with
forage fish spawning habitat;
largely avoided with spatial
separation and conservation
measures
Sediment mobilization: sediment
migrates to spawning beds;
unlikely with wave energy
Larvae ingestion: forage fish
larvae ingested by geoduck filter
feeding; unlikely based on size
Spawning: planting, maintenance,
and harvest
Sediment mobilization: harvest
Larvae ingestion: grow-out (5-7
years)
Spawning:
insignificant
Sediment
mobilization:
insignificant
Larvae ingestion:
insignificant
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Parameter Potential Effect Duration Level of Effect
Benthic Infauna
and Epifauna
Benthic fauna: potential increase
of prey, but also short-term
change of community structure
Benthic fauna: 2-3 years with
nets and harvest; baseline
conditions within several months;
6 months post-harvest
Benthic fauna:
insignificant
Aquatic
Vegetation
Eelgrass and Attached Kelp:
none present in project area
Macroalgae: drift macroalgae
would be disturbed, but not taken
out of the system
Eelgrass and attached kelp: not
applicable
Macroalgae: planting,
maintenance, and harvest
activities
Eelgrass and
attached kelp: not
applicable
Macroalgae:
insignificant
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Threshold Shifts. U.S. Dept. of Commer., NOAA. NOAA Technical Memorandum NMFS‐OPR‐
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Powers, M.J., C.H. Peterson, H.C. Summerson, and S.P. Powers. 2007. Macroalgal growth on
bivalve aquaculture netting enhances nursery habitat for mobile invertebrates and juvenile
fishes. Mar. Ecol. Prog. Ser. 339: 109‐122.
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146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
Smersh Farm Visual Assessment‐ 2018
FINAL REPORT
Prepared for:
BDN, Inc.
May, 2018
Apr 03 2019
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146 N Canal St, Suite 111 Seattle, WA 98103 www.confenv.com
Smersh Farm Visual Assessment‐ 2018
FINAL REPORT
Prepared for:
BDN, Inc.
Attn: Brad Nelson
Prepared by:
Grant Novak
Confluence Environmental Company
May, 2018
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TABLE OF CONTENTS
1.0 INTRODUCTION .............................................................................................................................................. 1
2.0 VISUAL IMPACT ASSESSMENT METHOD .................................................................................................... 2
2.1 Overview .......................................................................................................................................................... 2
2.2 Inventory .......................................................................................................................................................... 3
2.3 Analysis ........................................................................................................................................................... 4
3.0 FINDINGS ......................................................................................................................................................... 5
3.1 Scenic Quality .................................................................................................................................................. 5
3.1.1 Environmental Condition ......................................................................................................................... 5
3.1.2 Spatial Definition ..................................................................................................................................... 5
3.1.3 Adjacent Scenery .................................................................................................................................... 6
3.2 Sensitivity Level ............................................................................................................................................... 6
3.2.1 Number of Viewers ................................................................................................................................. 6
3.2.1 View Duration.......................................................................................................................................... 6
3.3 Visibility ............................................................................................................................................................ 8
3.3.1 View Obstruction ..................................................................................................................................... 8
3.3.2 Distance Offshore/Observer Position ...................................................................................................... 9
3.3.3 Viewshed Coverage ................................................................................................................................ 9
3.4 Extent of Probable Visual Impact ..................................................................................................................... 9
4.0 REFERENCES ............................................................................................................................................... 10
FIGURES
Figure 1. Smersh Parcel and Vicinity. ................................................................................................................... 1
Figure 2. Proposed Geoduck Planting Area and Distances from High Water ....................................................... 2
Figure 3.Visual Assessment Inventory Categories ................................................................................................ 4
Figure 4. Proportion of month the upper margin (Chart A) and lower margin (Chart B) of the geoduck planting
will be visible based on NOAA tide data from Jan 1, 2012 to Dec 31, 2017. .......................................... 7
Figure 5. Proportion of Month Tidal Elevation Range is Within Farm Boundary ................................................... 8
Figure 6. Visual Impact Classifications .................................................................................................................. 9
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1.0 INTRODUCTION
BDN, Inc. has leased parcel 721031007 (Smersh parcel) on Shine Road west of the Hood Canal
Bridge and is proposing to operate a geoduck farm at the site (Figure 1). A conditional use permit
is requried by Jefferson County and, as part of the permit application, a visual assessment has been
requested by the County pusrsuant to Jefferson County code 18.25.440(4)(f). The following
document presents an assessment of the potential effects to nearby uses and aesthetic qualities of
the shoreline that might occur due to geoduck aquaculture operations on the Smersh parcel.
BDN, Inc proposes to plant up to 5.15 acres of geoducks at the site between +2 feet and
approximately ‐2 feet relative to mean lower low water (MLLW) (Figure 2). The lower boundary of
planting has been determined based on the location of the eelgrass bed below approximately ‐2
feet MLLW (Confluence 2016). Geoduck will be planted outside of a 16 foot horizontal buffer from
the eelgrass bed (Figure 2). To protect juvenile geoduck until they can burrow deep enough to
avoid predators, PVC tubes 4” in diameter by 10” long will be placed into the sandy substrate.
Tubes will be placed at an approximate density of 1 tube per square foot with 3” to 5” of the tube
exposed above the substrate. All tubes will be labelled with BDN, LLC’s contact information,
including telephone number, and email address. Area netting may be placed over the tubes to
prevent them from becoming dislodged during severe weather.
Figure 1. Smersh Parcel and Vicinity.
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Tubes will be removed after 18‐24 months once the geoduck have reached a sufficient size and
depth to avoid predation. Geoduck will be harvested 5‐7 years after planting. Netting may remain
on the site until harvest to protect the crop from theft and/or predation.
2.0 VISUAL IMPACT ASSESSMENT METHOD
2.1 Overview
This visual assessment follows protocols and methods outlined in the Department of Ecology’s
Aquaculture Siting Study (Ecology 1986) developed by the State of Washington to assess visual
effects that might be experienced due to aquaculture activities. In Ecology’s study, they
incorporated and expanded upon visual assessment techniques identified by the U.S. Forest
Service (USFS) and U.S. Bureau of Land Management (BLM) and refined the applicable techniques
to focus on assessments of aquaculture. The result is the Visual Assessment Workbook which
provides an analytical process for evaluating visual impacts of aquaculture.
The USFS identified nine assumptions related to visual quality that were adopted by Ecology in
their analytical process to assess visual impacts of aquaculture:
Figure 2. Proposed Geoduck Planting Area and Distances from High Water
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1. People have certain scenic expectations
2. View duration is critical;
3. Number of viewers is critical;
4. Diversity increases scenic value;
5. Retention of distinctive character is desirable;
6. Each setting varies in capacity to absorb visual alteration;
7. Landmarks/focal points receive critical scrutiny;
8. Viewing angle is critical; and
9. Viewing distance is critical.
The BLM identified three principles related to visual quality that were adopted by Ecology in their
analytical process to assess visual impacts of aquaculture:
1. Landscape character is primarily determined by the four basic visual elements of form,
line, color, and texture. Although all four elements are present in every landscape, they
exert varying degrees of influence.
2. The stronger the influence exerted by these elements, the more interesting the landscape.
3. The more visual variety in a landscape, the more aesthetically pleasing the landscape.
Variety without harmony, however, is unattractive, particularly in terms of alterations
(cultural modifications) that are made without care.
The principles and assumptions outlined by the USFS and BLM were incorporated by Ecology into
a visual assessment method that inventories the surrounding landscape to quantify visual
characteristics of the landscape and the proposed aquaculture operations, and incorporates the
landscape inventory scores within an analysis matrix to arrive at an overall visual impact score.
2.2 Inventory
The Ecology defined inventory of visual characteristics includes three categories: scenic quality,
sensitivity level, and visibility. Scenic quality incorporates individual rating scores of
environmental condition, spatial definition, and adjacent scenery to determine a high, moderate,
or low scenic quality rating. Site sensitivity level is an accounting of the number of potential
viewers and their potential view duration of the project area (i.e., Smersh geoduck farm). The
visibility category identifies key observation points and evaluates the visibility of the aquaculture
site based on obstructions, distance from viewer, and the amount of the viewers cone of vision
taken up by the aquaculture activity (Figure 3).
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2.3 Analysis
In the analysis step, the scores from the inventory of scenic quality, sensitivity level, and visibility
are incorporated into an overall score to determine the severity of the probable visual impact. The
four classifications of visual impact are:
1. Class I (Severe Visual Impact) – Any permanently visible aquaculture facility will likely
have a severe visual impact that cannot be mitigated for. This category is applicable only in
wilderness areas.
2. Class II (High Visual Impact) – Areas where permanently visible aquaculture facilities will
likely be visually obtrusive.
3. Class III (Moderate Visual Impact) – Areas where permanently visible aquaculture facilities
will be visually evident.
4. Class IV (Low Visual Impact) – Areas where existing visual disruptions dominate or areas
with low sensitivity/visibility.
Figure 3.Visual Assessment Inventory Categories
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3.0 FINDINGS
A site visit was made to the Shine neighborhood and surrounding locale on April 18, 2018 during a
daylight low tide to inventory the scenic quality, sensitivity level, and visibility of the area within
the viewshed of the proposed Smersh geoduck farm. A hard copy of the visual assessment
workbook was consulted during the site visit and notes and scores were cataloged in the
workbook (Appendix A) for incorporation into this assessment.
3.1 Scenic Quality
Scenic quality is a combination of environmental condition, spatial definition, and adjacent
scenery. Each of these elements is described in more detail below.
Summary Category Rating: Moderate scenic quality – Areas with a combination of some
outstanding features and some that are fairly common.
3.1.1 Environmental Condition
Environmental condition is the capacity of the landscape to accept human alteration without
losing its natural visual character.
3.1.1.1 Environmental Condition Rating
Individual Element Rating: Moderate
Environmental condition was rated as Moderate based on distinctive landscape character, the
nearby public park and public use area, and areas with visible evidence of human activity, but not
at a dominating level. The Smersh site is located on a heavily altered shoreline in a medium‐
density, residential neighborhood. The shoreline has been altered by rip rap hardening, there is a
concrete boat ramp and gravel parking lot in the adjacent public property, riparian trees have been
removed from a number of the adjacent properties to increase private views, and the paved
roadway is adjacent to the shoreline for approximately 1 mile to the west of the Smersh parcel.
3.1.2 Spatial Definition
Spatial definition is the degree of spatial enclosure and volume created by the flat plane of the
water body and the surrounding landforms.
3.1.2.1 Spatial Definition Rating
Individual Element Rating: Moderate
Spatial dfinition was rated as moderate based on the shoreline form with concave embayments ½
mile to 2 miles across. Squamish Harbor is approximately 2 miles across at the Smersh site and
Hood Canal is approximately 3 miles across at the Smersh site.
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3.1.3 Adjacent Scenery
Adjacent scenery refers to the adjacent shoreline edge, landform, and vegetation which define the
embayment. Influence, detail, and clarity diminish with distance. In general, impact of this
variable increases as the degree of enclosure increases, or as the embayment size or the distance to
the opposite shoreline decreases.
3.1.3.1 Adjacent Scenery Rating
Individual Element Rating: Low
Adjacent scenery was rated as low based on the lack of variety in form, line, color, and texture.
Trees obscure views from neighboring residences, clear cutting is visible in the managed forests to
the west, managed forests are visible on all adjacent shorelines, and most shorelines being greater
than 1 mile from viewpoints.
3.2 Sensitivity Level
Sensitivity level refers to the number of potential viewers, adjacent travel routes, use areas, or the
amount of existing residential development.
Summary Category Rating: Low – few adjacent travel routes and medium‐density residential
development. Further, because geoducks will be located in the intertidal zone, they will be
underwater for the majority of the time and the duration when they are visible will be short. This
rating is described in more detail below.
3.2.1 Number of Viewers
Individual Element Rating: Low
This element was rated as low because the potential number of viewers of the Smersh Site is low.
At low tide, the upper margin of the geoduck planting at +2 feet elevation is visible from only 12
residences while the lower margin of the geoduck planting at ‐2 feet elevation is visible from only
20 residences (See Appendix B – Photos 11 and 12). The site is not visible from the heavily‐
travelled state route 104 and, while it may be visible from Shine road during some tidal stages,
Shine road is a neighborhood access route and not heavily travelled. The neighboring park is little
more than a boat ramp and gravel parking lot. The boat ramp is only useable during high tide,
when the geoduck tubes would be submerged, so there is little opportunity for visitors to see
aquaculture activities.
3.2.1 View Duration
Individual Element Rating: Low
It is important to note that tides low enough to expose the planting area follow a seasonal pattern
in the Puget Sound region. Larger‐magnitude summer low tides occur during daylight hours,
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while winter low tides occur at night. Therefore, geoduck tubes and netting are more visible in
summer, and minimal in winter.
While the presence of medium‐density residential development may lead to a moderate score for
the Sensitivity Level category, aquaculture equipment and activities are only visible during
daylight low tides for a small percentage of each month. Figure 4 illustrates that the upper margins
of the geoduck planting area are visible a maximum of 16% of any single month (Chart A) and the
entire planted area is visible a maximum of only 2% of a month (Chart B) (NOAA 2018).
A. B.
Figure 4. Proportion of month the upper margin (Chart A) and lower margin (Chart B) of the
geoduck planting will be visible based on NOAA tide data from Jan 1, 2012 to Dec 31, 2017.
Figure 5 presents the tidal range in Hood Canal throughout the year overlaid by the farm
boundary. It should be noted that, while geoduck will be planted between +2 feet and ‐2 feet
elevation, the geoduck tubes may extend up to 4 inches (0.3 feet) above the sediment so the farm
boundary has been shown between ‐1.7 feet and +2.3 feet to represent the tidal elevation of the
geoduck tubes. As can be seen in Figure 5, tidal elevation seldom goes as low as the upper farm
boundary and even more rarely goes as low as the lower farm boundary, further illustrating that
the aquaculture activities will be exposed only a minor portion of a month.
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3.3 Visibility
Visibility is a combination of the following elements, which are discussed in more detail below:
view obstruction, distance offshore/observer position, and viewshed coverage.
Summary Category Rating: Low
Visibility is rated low due to obstructed views from vegetation and landform as well as large
distances between geoduck planting area and potential viewers. Also, geoduck tubes and nets
have very low relief and natural macroalgae colonizes equipment rapidly leading to natural color
and texture (See Appendix B – Photos for examples).
3.3.1 View Obstruction
View obstruction is related to the degree of obstruction in viewing the farm by vegetation,
landform, or man‐made objects.
3.3.1.1 View Obstruction Rating
Individual Element Rating: Moderate – Partially obstructed view
15 to 20 homes have unobstructed view of the proposed geoduck planting area. During the site
visit, nearby trees were in the leaf‐off condition. The estimate of 15‐20 homes with unobstructed
views will be reduced during the summer when trees have a cover of leaves that are likely to more
fully block views.
Figure 5. Proportion of Month Tidal Elevation Range is Within Farm Boundary
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3.3.2 Distance Offshore/Observer Position
Visibility is critically related to the distance the farm is located from observation points and the
height of key observation points above sea level.
3.3.2.1 Distance Offshore/Observer Position Rating
Individual Element Rating: Low – Areas with little visibility
This element is rated low because distance from most potential viewers (i.e. visible residences and
Shine road) to aquaculture is greater than 1500 feet and between 20 feet and 50 feet above sea level.
3.3.3 Viewshed Coverage
Viewshed coverage is related to the percentage of the normal cone of vision occupied by the
proposed aquaculture facility.
3.3.3.1 Viewshed Coverage Rating
Individual Element Rating: Low
The proposed geoduck planting area covers less than 5% of the cone of vision when viewed from
nearby residences. The project is only 500 feet wide along the nearly 2‐mile‐long northern
shoreline of Squamish Harbor.
3.4 Extent of Probable Visual Impact
Scores from the inventory of scenic quality, sensitivity level, and visibility are incorporated into an
overall score to determine the severity of the probable visual impact.
Scenic Quality Summary Category Rating: Moderate
Sensitivity Level Summary Category Rating: Moderate
Visibility Summary Category Rating: Low
Figure 6. Visual Impact Classifications Log Item 1
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Using the matrix provided in the Visual Assessment Workbook to determine the extent of visual
impact of the project site leads to a Class IV Low Visual Impact. Because the site is visible only a
small portion of the time, the site is not visible from heavily traveled routes, the surroundings are
heavily altered by local residential, and the geoduck tubes and netting will quickly take on a
natural color due to colonization by aquatic flora and fauna (see photos 13‐16 in Appendix B).
Based on the resultant Class IV Low Visual Impact rating, the project should require no mitigation
measures to reduce visual effects.
4.0 REFERENCES
Confluence Environmental Company. 2016. BDN Eelgrass Bed Delineation – 2016 – Final Report.
October 31, 2016.
Ecology (WA State Department of Ecology). 1986. Aquaculture siting study. Prepared by EDAW
Inc. and CH2M/Hill for State of Washington Department of Ecology, Olympia.
National Oceanographic and Atmospheric Administration. 2018. Tides and Currents Website –
Tide Predictions at Gage 99445088 at Lofall, WA from 1/1/2012 to 12/31/2017.
https://tidesandcurrents.noaa.gov/noaatidepredictions.html?id=9445088&legacy=1
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Appendix A
Visual Assessment Workbook
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Appendix B
Photos
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SMERSH FARM VISUAL ASSESSMENT – 2018 Appendix B: Photos May 2018 Page 1 Photo Index - Numbers correspond to the photos numbers in the following appendix. Arrows indicate the viewing direction of the photo. Log Item 1 Page 181 of 204
Smersh Farm Visual Assessment – Appendix B: Photos
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Photo 1 — View of proposed geoduck planting area from neighboring public boat ramp. Orange
boundary is approximate location of proposed geoduck.
Photo 2 — View of proposed geoduck planting area from western property boundary looking
east.
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Photo 3 — View of proposed geoduck planting area looking east from neighboring public boat
ramp.
Photo 4 — View from residential driveway approximately 1000 feet north of proposed geoduck
planting area.
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Photo 5 — View from residential driveway approximately 500 feet north of proposed geoduck
planting area.
Photo 6 — View from Shine Road approximately 400 feet northeast of proposed geoduck
planting area. Note boat that is also visible in phots 1-3.
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Photo 7 — View from approximately 1500 feet east of proposed geoduck planting area from
Shine Road looking in direction of farm. This view is typical of most residences in the area. The
high bluff blocks views of the proposed aquaculture. This photo was taken at low tide but no
exposed beach is visible.
Photo 8 — View from approximately 1500 feet east of proposed geoduck planting area from
Shine Road looking in direction of farm. This view is typical of most residences in the area. The
high bluff blocks views of the proposed aquaculture. This photo was taken at low tide but no
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Photo 9 — View of active geoduck farm from Shine Road. Looking to east during low tide.
Photo 10 — View of active geoduck farm from Shine Road. Looking to west during low tide.
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Smersh Farm Visual Assessment – Appendix B: Photos May 2018 Page 7 Photo 11 — Houses with line-of-sight visibility to center of proposed aquaculture (approximately +1 feet MLLW). Orange circles indicate residences that may be able to see the farm when tides are low enough. Photo taken at 12:10pm on April 18, 2018. Tidal elevation approximately -0.35 feet MLLW. Photo 12 — Houses with line-of-sight visibility to lower margin of proposed aquaculture (approximately -2 feet MLLW). Orange circles indicate residences that may be able to see the farm when tides are low enough. Photo taken at 12:12pm on April 18, 2018. Tidal elevation approximately -0.34 feet MLLW. Log Item 1 Page 187 of 204
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Photo 13 — Example of geoduck tubes colonized by natural flora and fauna within months of
installation. Note scoters diving to feed on attached organisms.
Photo 14 — Example of geoduck tubes in early stages of floral and faunal colonization within
two months of installation.
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Photo 15 — Example of predator netting over geoducks. Note natural coloration and texture.
Photo 16 — Example of geoduck tubes covered with predator netting. Note colonization by
macroalgae (Ulvaria spp.) and natural coloration.
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Exhibit 54 page 1342
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