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Home My WebLink About066 Email - ShowalterDonna Frostholm From: Marilyn Showalter <marilyn.showalter@gmail.com> Sent: Monday, September 13, 2021 7:55 PM To: Donna Frostholm LOG ITEi Cc: Sue Corbett; Janet # Subject: Section C pp1-40 (of 111 pages) 0a Attachments: C SECTION C pp 1-40 - Smersh mgs jlw-sdc.pdf 9s--L,0f 7 Follow Up Flag: Follow up Flag Status: Flagged CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Donna: This is the first of three emails. Please confirm receipt. Thanks --Marilyn Marilyn Showalter 1596 Shine Rd Port Ludlow, WA 98365 (360) 259-1700 (cell) marilyn.showalter@gmail.com I LUG ITEM # cl oF1L7 Donna Frostholm From: Marilyn Showalter <marilyn.showalter@gmail.com> Sent: Monday, September 13, 2021 7:56 PM To: Donna Frostholm LOG ITEM Sue Corbett; Janet Subject: Section C pp 41-84 (of 111 pages) # , Attachments: C SECTION C pp 41-84 Smersh mgs jlw-sdc.pdf Pa 0# , , ..y Follow Up Flag: Follow up �( , I Flag Status: Flagged CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Donna: This is the second of three emails. Please confirm receipt. Thanks --Marilyn Marilyn Showalter 1596 Shine Rd Port Ludlow, WA 98365 (360) 259-1700 (cell) i-narilyn.shovvalter@gmail.com 1 LOG 1T Eli Page ; --.fll L, L Donna Frostholm From: Marilyn Showalter <marilyn.showalter@gmail.com> ��/'�'�ty Sent: Monday, September 13, 2021 7:58 PM M To: Donna Frostholm Cc: Sue Corbett; Janet pG e Subject: Section C pp 85-111 (of 111 pages)�" Attachments: C SECTION C pp 85-111 Smersh mgs jlw-sdc.pdf Follow Up Flag: Follow up Flag Status: Flagged CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Donna: This is the third of three emails. Please confirm receipt. Thanks --Marilyn Marilyn Showalter 1596 Shine Rd Port Ludlow, WA 98365 (360) 259-1700 (cell) marilyn.showatter@gmail.com 1 LOG ITEM # 'age �� % SECTION C MARINE ENVIRONMENT LOG ITEM Page 0 A geoduck farm would degrade the ecology that supports threatened and endangered species, and would contribute to ocean acidification and plastics pollution. This section is organized in the following subsections. It is important to remember, though, that all of these creatures live in an ecological web, dependent on each other. So, for example, when densely planted geoducks ingest forage -fish eggs, that alters the availability of forage fish for threatened and endangered (T&E) salmon and Marbled Murrelets. Looking at the food chain from the other direction: Transient Orcas eat seals, the seals eat forage fish, and BDN geoducks east forage -fish eggs. There's no free lunch. Subsection Page C-1: T&E Birds 2 C-2: T&E Mammal 19 C-3: T&E Echinoderms and Reptiles/Amphibians 33 C-4: T&E Mollusks 40 C-5: T&E Marine Fish 45 C-6: T&E Salmon and Trout 52 C-7: Forage Fish 61 C-8: Native Eelgrass 69 C-9: Carbon Release 85 C-10: Plastics Pollution 99 C pagel LOG IT ENI; J}w THREATENED, ENDANGERED AND CANDIDATE SPECIES Estuaries such as Squamish Harbor, the location of the proposed Smersh 5.15 acre commercial geoduck farm are some of the most important, diverse and imperiled ecosystems in the world. Millions of public dollars are being spent to restore Puget Sound habitat that is so important for dwindling numbers of forage fish, salmon, orcas, gray and humpback whales, marbled murrelets, common loons, western grebes, sunflower sea stars and numerous other species. Herring, sand lance and surf smelt populations continue to decline, yet are critical in the food chain for many other imperiled species. Eelgrass is also critical as habitat and the foundation for the food chain for so many of these species and their offspring. It is important to remember that all of these creatures live in an ecological web, dependent on each other. So, for example, when densely planted geoducks ingest forage - fish eggs, that alters the availability of forage fish for endangered salmon and Marbled Murrelets. Looking at the food chain from the other direction: Transient Orcas eat seals, the seals eat forage fish, and BDN geoducks east forage -fish eggs. There's no free lunch. It is my observation after decades of working in natural resource management and taking part in planning or supervising thousands of projects that I have not seen projects that have anywhere near the number of threatened, endangered and candidate species for listing as in the Smersh proposed commercial geoduck farm (Jan Wold, personal experience, whose last job before retirement was as the leader of a one million -acre National Forest). For this reason alone this proposal should be rejected. If not, then an Environmental Impact Statement (EIS) should be prepared. C page2 jlw THREATENED, ENDANGERED AND CANDIDATE BIRDS ITcm PlerA Research published in Science magazine as reported in "The Wall Street Journal" by Jennifer Calfas, September 19, 2019 found that: North America's overall bird population has dropped 29% since 1970, with about 3 billion fewer birds now than nearly 50 years ago.... Described as unprecedented by researchers and scientists, the findings display a new and unexpected assessment of the bird population across the continent. The research also is a grim indicator of the overall health of the environment and reflects what may be occurring in other less closely observed animals, said Ken Rosenberg, a bird conservation scientist at the Cornell Lab of Ornithology who was the study's lead author. MARBLED MURRELET State Endangered and Federally Threatened Species Marbled murrelets (Brachyramphus marmoratus) are a small seabird that is listed as a federally threatened species. The species has been recently up -listed to endangered by the State of Washington. Marbled murrelets have been documented in the northern portions of Hood Canal and Squamish Harbor by the U. S. Forest Service, Washington State Department of Fish and Wildlife and by local residents. Marbled murrelets are in Squamish Harbor because of the forage fish they eat and feed to their one annual nestling and because of the proximity to old -growth forest nesting habitat, especially in Olympic National Park. They usually lay a single egg in a very large tree on a flat spot on a very large limb. We should not further endanger their existence due to habitat loss, noise, disruption and loss of critical food chain organisms, such as forage fish, by permitting this commercial shellfish farm in this critical nearshore location and designated shoreline of statewide significance. Additional commercial shellfish farms should not be approved in the northern portions of Hood Canal until after an Environmental Impact Statement and a thorough cumulative effects analysis ensures that no further degradation of the habitat, food source, and safety of the endangered marbled murrelet will occur. One neighbor has observed marbled murrelets feeding directly over Smersh's tidelands: C page3 jlw LOG ME-M P a+ge_ W of _! r 7 The executive summary of the "Washington Department of Fish and Game for the Periodic Status Review for Threatened and Endangered Species for the Marbled Murrelet in Washington (2016)," published in October of 2016 states that: The marbled murrelet (Brachyramphus marmoratus) is a small seabird that inhabits near shore marine environment in western North America. The distribution of murrelets in Washington includes the southern Salish Sea and the outer coast. The species was listed as threatened under the U.S. Endangered Species Act in 1992 in Washington, Oregon and California and... was subsequently listed by the Washington Fish and Wildlife Commission as threatened in 1993.... Marbled murrelets forage in the marine environment and may fly up to 55 miles inland where they nest and rear a single young on large tree limbs in mature and old conifer forests. Murrelets prey primarily on a variety of forage fishes, and sometimes on larger zooplankton. They exhibit strong site fidelity to nesting areas, appear to nest in alternate years, on average, and have a naturally low reproductive rate. ... At -sea population monitoring from 2001 to 2015 indicated a 4.4% decline in the murrelet population annually, which represents a 44% reduction since 2001. The 2015 population estimate for Washington is about 7,500 birds. Sustained low juvenile recruitment has been identified as a main cause of the decline, ... A 20% nest success rate in Washington for the period 2004-2008 was C page4 LOG ITEM jlW j e Page��pf attributed to nestling starvation or adults abandoning eggs before completing incubation, suggesting low prey availability. Human marine activities appear to influence murrelet abundance and distribution in the Salish Sea. Declines in populations of forage fish species such as herring and anchovy subsequently resulted in an increased use of lower trophic level, less calorie -rich food sources (invertebrates). Ultimately, these changes to the marine food web may have influenced reproductive output.... The magnitude of the population decline indicates that the status of the marbled murrelet in Washington has become more imperiled since state listing in 1993. Without solutions that can effectively address these concerns in the short-term, it is likely the marbled murrelet could become functionally extirpated in Washington within the next several decades. Therefore, our recommendation is to list the Marbled Murrelet as a state endangered species in Washington. A Marbled murrelet research paper titled, 'Breeding Ecology of the Marbled Murrelet in Washington State, Five Year Project Summary (2004-2008)," May 2009, by Thomas D. Bloxton, Jr. and Martin G. Raphael, USDA Forest Service, Pacific Northwest Research Station, Olympia, Washington stated: ...only one nest was apparently successful in each year from 2004- 2006, and in 2008, and none of the five nests monitored in 2007 were successful. The majority of nest failures appear to be related to nestling starvation (emphasis added) or adults abandoning eggs prior to completion of the incubation period (or eggs failing to hatch after 40+ days). The low observed rate of confirmed nest initiation in all years (2004 [3 of 27 adults], 2005 [8/40], 2006 [2/40], 2007 [5/32], & 2008 [2/18]) and high rate of nest failure (80%) is possibly due to low prey availability at sea. (emphasis added) Lance, M.M., and S.F. Pearson. 2021. Washington 2020 at -sea marbled murrelet population monitoring: Research Progress Report. Washington Department of Fish and Wildlife, Wildlife Science Division, found that: The population estimate for Puget Sound and the Strait of Juan de Fuca in 2020 (Zone 1) was 3,143 birds (95% confidence interval = 2,030 — 4,585 birds) with a - 4.96% (95% CI = -7.01 to-2.86%) average annual rate of decline for the 2001- 2020 period, assuming a constant rate of decline. (See figure 5, photo number MM.j.2020, below, for a diagram showing the decline of marbled murrelets each year in Puget Sound and the Straight of Juan de Fuca). This research shows the largest annual percentage drops in marbled murrelet numbers in Washington are in Hood Canal. Dire as the situation is in Puget Sound, it is the very worst in Hood Canal. C page5 jlw Habitat associations of marbled murrelets during the nesting season in nearshore waters along the Washington to California coast, Martin G. Raphael, Andrew J. Shirk, Gary A. Falxa, Scott F. Pearson, Journal of Marine Systems, June 26, 2014, states: Whereas nesting habitat is essential to murrelet conservation, managers cannot ignore foraging habitat nor the availability of certain forage species, not simply because murrelets require prey but also because prey availability can affect murrelet nesting success (emphasis added) (Barbaree, 2011; Barbaree et al., 2014; Becker et al., 2007; Norris et al., 2007) and seabird survival (Sandvik et al., 2005)... Murrelet numbers have seriously decreased over the past decades and continue to decline in our study area, especially in the waters of Washington State (Miller et al., 2012)... Despite this relatively weak spatial relationship, marine factors, and especially decrease in forage species, may play an important role in explaining the apparent population decline (emphasis added), but this relationship is not evident in an analysis with such strong spatial factors. Indeed, for example, a number of smelt species, which as a group are important murrelet prey (Burkett, 1995), are themselves ESA listed within the murrelet's range. ...Murrelet abundance was greater in waters associated with sandy shores... The marbled murrelet is a pursuit diver that preys primarily upon small schooling fishes including sand lance (Ammodytes hexapterus), anchovy (family Engraulidae), herring (Clupea pallasii), and juvenile rockfish (Sebastes spp.) (emphasis added) during spring and summer (Burkett, 1995; Nelson, 1997). We did not have information on the spatial and temporal distributions of these forage fishes that we could include in our models. (emphasis added) This research emphasizes the importance for sand lance, herring and juvenile rockfish for marbled murrelets. The number of these forage fish are dropping and some are threatened, endangered or candidates themselves. Smersh is in the middle of a herring spawning area and next to or possibly in a sand lance spawning area as well as a rearing area for forage fish. Continuing disturbance year after year on 5.15 acres of this critical nearshore habitat for forage fish, marbled murrelets and so many other species is ill advised. C page6 j lw The research article, "Marine Habitat Selection by Marbled Murrelets (Brachyramphus marmoratus) During The Breeding Season, by Theresa J. Lorenz, Martin G. Raphael and Thomas S. Bloxton, Jr., USDA, Forest Service, Pacific Northwest Research Station, Olympia, Washington," states: In particular, marine areas in close proximity to old -growth nesting habitat appear important for murrelets during the breeding season and should be priorities for protection... the conservation of marbled murrelets may hinge on protecting not only nesting habitat --the focus of conservation efforts to date --but also on foraging habitat. Sand lance (Ammod tes hexgpterus) are considered an important prey of breeding marbled murrelets ... They are associated with fine gravel or sandy - bottomed coastal waters ... Given the marine habitat selection we observed in this study, we suggest that marine areas that should be prioritized for protection are those in closest proximity to large tracts of nesting habitat, with low human footprint, and near sand or gravel beaches. Herring and sand lance are the primary foods for the endangered marbled murrelet. The proposed BDN/Smersh commercial geoduck farm are listed by the State of Washington as herring and sand lance spawning areas. Marbled murrelets have been observed and photographed feeding directly during breeding season in the 5.15-acre area proposed for the BDN/Smersh commercial geoduck farm. The photograph attached below, labeled Murrelet.j.2017, shows data on marbled murrelets spotted in Squamish Harbor and close by in Hood Canal in 2017 and 2018. This information came from the research in Evaluating he Potential Influence of the Hood Canal Bridge On Piscivorous Bird and Mammal Densi , Jessica J. Stocking and Scott R. Pearson, et. al., November 2019, WDFW. A Peninsula Daily News article on August 5, 2016 features a story describing how scientists investigating the death of 400 rhinoceros auklets who breed on Protection Island (in Puget Sound about 20 miles northwest of the 5.15 acre proposed Smersh geoduck farm) were likely starved because the size of the sand lance and herring they eat had become too small to satisfy their dietary requirements. Shellfish are touted as being important for cleaning the water of Puget Sound, but the extreme numbers found in shellfish farms may in fact be cleaning the water of the very organisms that serve as the base of the food chain for forage fish, marbled murrelets and other threatened and endangered species. Details on this conflict with forage fish their prey, including the marbled murrelet are given in our section on forage fish, herring and C page7 ;iW LOG iTEN! Pale 4�fl— sand lance. Research is provided documenting how shellfish are removing from the water the very organisms needed to feed forage fish and all of the imperiled species depending on them. Smersh is planning on adding 243,000 PVC tubes each planted with two to four geoducks "cleaning" the water. That could result in nearly one million geoducks "cleaning" the water of the organisms that would normally be the base of the natural food chain in Squamish Harbor. This commercial geoduck farm should not be approved by Jefferson County due to the expected impact on this highly endangered marbled murrelet by commercial geoduck farming. At a minimum, an Environmental Impact Statement and thorough cumulative effects analysis need to be undertaken by the proponent to determine these impacts. In the case of marbled murrelets any impact will likely be permanent as their numbers are dropping so rapidly. C pageg 2020 Marbled Mwmlet Monitoring Report Washington Department of Fish and Wildlife jiW 1❑ Figure 5. Washington marbled murrelet population density trend for 2001-2020 will] 95% confidence band far Zone I (Puget Sound and Strait Of Juan dU Fuca), The trend is for a linear trend in the tog of density. We excluded 2000 from this analysis because distances to. birds Werc not recorded and fewer replicates were conducted in that yeah for Zone: 2 and for T..onc I Stratum 1. E 3 1 (Photo MM j.2020) Marbled murrelet A • • r Year LOG ITE;V C page9 j,W LOG 1TEN, #r Pug,e l �04 Fall -Spring 2019/2020 Marbled Murrelet Monitoring at Navy Facilities Table 3. Estimates of average annual rate of marbled murrelet population change based on at -sea abundance surveys in four strata in the Puget Sound region. Confidence limits are for the estimates of percent annual change. The P-value is based on a 2-tailed test for whether the annual rate of change is less than zero, significant values (p < 0.05) are shaded in gray. Region (Stratum) Period of Analysis 2012-2020 2012-2020 Annual Rate of Change (/) -13.5 -13.7 95% Conf. Limits Lower Upper Adjusted R2 P- value Puget Sound (all strata) Admiralty Inlet (S2) -20.7 -5.6 0.692 0.534 0.007 -23.5 -2.7 0.024 Hood Canal (S3) 2012-2020 -17.2 -29.1 -3.2 0.527 0.025 Whidbey Basin (S4) 2012-2020 -11.2 -20.3 -1.2 0.478 0.035 Central Puget Sound (S5) 2012-2020 -14.9 -31.5 5.7 0.248 0.119 Pearson, S. F. and M.M. Lance. 2020. Fall -spring 2019/2020 Marbled Murrelet At -Sea Densities for Four Strata Associated with U.S. Navy Facilities in Washington State: Annual Research Progress Report 2020. Washington Department of Fish and Wildlife, Wildlife Science Division, Olympia, WA. July provides Table 3, above, showing the decline of marbled murrelets being the most severe in Hood Canal from 2012 through 2020, with a -17.2% rate of change. There were lesser drops in all other sampled locations such as Central Puget Sound and Admiralty Inlet among others (photo MM2.j.2020). C pagel0 jIw 2018 • r .at ., a KM �.A vedld.MY>Q1� 1 LSHJ yWf1y Figure 6. Relative density of marbled murrelet (Brachyramphus marmoratus) in line transect surveys of Hood Canal bridge, WA during steelhead outmigration 2017-2018 (n=14visits/year). Points represent observations. 6,4 T,py�� Marbled Murrelet Photo: Murrelet.j.2017 9' C pagell jIW LOG P" WESTERN GREBE � � PGs 04 -]!- State Candidate Species The western grebe is a state candidate for listing as endangered, threatened or sensitive. This species is commonly seen feeding in Hood Canal and Squamish Harbor. The WDFW information sheet for the western grebe notes that the population is low and the trend suggests it is declining. According to the book, Birds of the Puget Sound Region, by Bob Morse, Tom Aversa and Hal Opperman, 2003, the western grebe feeds mostly on fish obtained by diving. The forage fish in Squamish Harbor are discussed in the section on forage fish. Smersh is located in a herring spawning area and near a sand lance spawning area. The WDFW fact sheet on the western grebe states: Up to 20-25% of the world's population of western grebes overwinters in Washington. Fish can comprise over 80% of the diet and Pacific herring (Clupea pallasii) can make up more than 50% of their winter diet (emphasis added). The simultaneous declines of wintering western grebe populations and forage fish stocks like the Cherry Point herring, around which western grebe concentrations historically gathered, suggest that changes in food resources have played a role in the decline of wintering populations of this species in Washington. Jan Wold, who has lived on Shine Road about 1/4 mile west of the proposed Smersh commercial geoduck farm for eight years has observed flocks of western grebes in the past feeding in Squamish Harbor. Carolyn Eagan has lived adjacent to Squamish Harbor on Margaret Street, directly west of Shine Road, part and full time for the last 25 years. Carolyn is located about a mile west of the proposed Smersh geoduck farm. Carolyn used to see huge flocks of western grebes but the numbers are down lately and has not seen them this year. CLARK'S GREBE State Candidate Species According to the book, The Birds of the Puget Sound Region, by Bob Morse, Tom Aversa and Hal Opperman, R. W. Morse Company, Olympia Washington, 2004, page 39, Clark's Grebe is a rare winter visitor in this Region. C page12 j 1w COMMON LOON State Sensitive Species � Common loons are frequently seen feeding year round in this portion of Hood Canal and in Squamish Harbor (Jan Wold, personal observation). The numbers of common loon are dropping in part due to a lack of quiet undisturbed lakes necessary for their breeding, nesting and raising young. There are at least three dozen lakes within ten miles of Squamish Harbor and this proposed Smersh commercial geoduck farm. Jan Wold observe eight common loons close together on August 26, 2016. Some of these common loons appeared to be smaller and less well marked. Some of these were likely recently fledged and feeding as a group on Squamish Harbor about 1/4 mile west of the Smersh proposed commercial shellfish farm. It would appear likely that one or more pairs of this state sensitive species had managed to nest successfully in the vicinity and Squamish Harbor was one of the first marine locations for the new fledglings to feed. It would make this area of Squamish Harbor especially important for this struggling species and their offspring. According to the WDFW common loon fact sheet: It's overall range has contracted northward. Due to life history and a small population in Washington it is highly vulnerable to impacts (emphasis added) .... Common loons feed mainly on fish, typically of a size between 0.35 to 2.45 ounces. Saltwater prey include eels, menhaden, herring, haddock, whiting, pipefish, shiner perch, sand lance, gobies, blennies, Irish lords, gurnards, sculpins, flounder, sole, and skates. They also occasionally take amphibians, crayfish, small crabs and dragonflies.... ....common loons do not begin breeding until at least 6 years of age. There are herring and sand lance spawning at and near Smersh and rocksole spawn about a mile south west of Smersh. The noise and other disturbance at a geoduck farm, the impact on eelgrass, the reductions in the base of the food chain and the reductions in forage fish would all be expected to negatively impact the common loons in Squamish Harbor. C page13 j1W LOG ITEM, k, PILEATED WOODPECKER page �Z-0 of j L7 State Candidate Species Pileated woodpeckers are the largest woodpeckers in North America. Timber harvesting and loss of habitat already have this species stressed in the Squamish Harbor area. Thousands of acres of timber have been cut during the last five years leaving large clear cuts that have removed areas to feed and nest for this species. They typically feed in areas with trees and sometimes on fruit such as apples (Jan Wold personal observation). There are many old apple trees along Shine Road. According to the WDFW fact sheet on pileated woodpeckers they: ....eat wood -boring insects and insects that nest in trees. Including long -horned beetles and especially carpenter ants. They eat some fruit and nuts. According to all about birds.org: they can also be found in younger forests that have scattered, large, dead trees or a ready supply of decaying, downed wood. Throughout their range, Pileated Woodpeckers can also be found in suburban areas with large trees and patches of woodland. They can be observed from time to time at suet feeders 1/4 mile west of Smersh. A male and a female were observed feeding together at the same location this spring. There are several pileated nest or roost holes in trees and snags 1/4 mile west of Smersh. In a couple of previous years an adult female has landed at suet feeders with a newly fledged offspring 1/4 mile west of Smersh (Jan Wold, personal observation). Smersh is proposing to not only have the noise and activity of a commercial geoduck farm on the tidelands but also have roads and parking lots in or next to riparian buffers on Bones Creek and have areas of PVC tubes and equipment being moved in and out and left in piles not far away. Smersh has not analyzed whether or not there will be impacts to the pileated woodpeckers that are feeding and nesting here. An EIS would review the possible impacts to the species of birds nearby. C pageM j1W P �- OREGON VESPER SPARROW #�17 State Candidate Species The Oregon vesper sparrow is experiencing range -wide population declines and range contractions and many local extirpations. The Washington Department of Fish and Wildlife (WDFW) believe that it has recently become extinct in the Dungeness area. The WDFW is recommending that it be classified as an endangered species in Washington in its May 2020 analysis. The WDFW Status Report for the Oregon Vesper Sparrow, prepared by Bob Altman, Derek W. Stinson, and Gerald E. Hayes, February 2021, describes: Oregon Vesper Sparrow breeding habitats in Washington include herbaceous - dominated, open upland landscapes such as prairie and savannahs, pastures.... Historical accounts suggest it was locally uncommon to abundant in the disjunct distribution of grassland and savannah habitat in western Washington. It has experienced range -wide population declines and range contractions, and many local extirpations. In Washington, this includes 20th century extirpations from Vashon Island of the north Puget lowlands, and the Dungeness area of the Olympic Peninsula; and extirpation from San Juan Island appears likely. Although this species if likely no longer occurring in this area, and EIS would give a thorough analysis of this and other species prior to approving any commercial shellfish operations, including in the areas above Shine Road. VAUX'S SWIFT State Candidate Species Vaux's Swift has apparently been observed at Hamma Hamma, about 25 miles south southwest of the Smersh proposed geoduck farm. Carolyn Eagan has lived adjacent to Squamish Harbor on Margaret Street, directly west of Shine Road, part and full time for the last 25 years. Carolyn is located about a mile west of the proposed Smersh geoduck farm. Carolyn has observed a couple of swifts during these years. C page15 5 According to the WDFW fact sheet: Vaux's swifts spend most of their day in the air foraging for flying insects, which they pursue and capture in their beak. Foraging occurs over forests, grasslands, and aquatic habitats (Bull and Beckwith 1993). After nestlings hatch, adults collect boluses of insects in their mouths that are brought to the nest for feeding the young. Vaux's swifts are present in Washington as spring and autumn migrants and as summer residents. Migration occurs from late April to late May and again from mid -August to late September. During the breeding season, the species is mainly associated with old -growth and mature forests in western Washington.... Nests are often placed in hollow trees used by roosting pileated woodpeckers (Dryocopus pileatus), with swifts entering these trees through woodpecker holes. Without these excavations, Vaux's swifts would have no access to many hollow tree chambers (Bull and Collins 1993, Sterling and Paton 1996). This species may or may not be using the Squamish Harbor area. There are large trees and snags with pileated holes in them between Squamish Harbor and State Highway 104. There are also large trees in some areas across and above State Highway as well as west of Squamish Harbor. An EIS would provide a thorough analysis of this and other species prior to approving any commercial shellfish operations, including in the areas above Shine Road. OTHER IMPORTANT BIRD SPECIES IN SQUAMISH HARBOR THAT ARE NOT PRESENTLY THREATENED, ENDANGERED OR CANDIDATE SPECIES 1010IK A large heron rookery containing a number of heron nests is located on the west edge of Squamish Harbor next to Squamish Creek, approximately one and a half miles west of the Smersh proposed commercial geoduck farm. Tube covered tidelands with higher turbidity from planting and harvesting make these areas in the Smersh tidelands normally used by the nesting herons from this rookery unavailable or less useable for catching fish for themselves and their nestlings. These same shorelines, including Smersh, are used for feeding by the heron offspring once they have fledged. The impact of reduced water quality, disturbance, noise, release of micro plastics, release of carbon and acidification of the water all can impact their food chain and their ability to feed and have successful offspring. See the forage fish section for additional information. C page16 jlw OSPREY LOG ITUp P, Iqq—Zo3—�� There are a number of ospreys that hunt in Squamish Harbor daily during the spring and summer months (Jan Wold, personal observation). They are feeding on fish from Squamish Harbor as they build or repair nests in the spring, lay and sit on eggs, feed offspring and eventually instruct their offspring on fishing in Squamish Harbor once the offspring fledge. The osprey are often seen flying with fish heading north across Shine Road. They are no doubt heading to nests in the nearby area. BALD EAGLE There is an active bald eagle nest a half mile east of the proposed Smersh commercial geoduck farm (See photo below, labeled EagleNest.j.6/6/19). The hunting and fishing areas used daily by the eagles as well as when they are feeding their nestlings include the area proposed for the Smersh geoduck farm. These shorelines, including Smersh, are also some of the first areas used by the newly fledged eagles for feeding. The eagles also use larger trees along the shoreline for perching, fishing and searching for food that washes up along the tidelands. The Bald and Golden Eagle Protection Act of 1940 (16 USC. 668-668c), as amended, prohibits the take of bald eagles, including their parts, nests, or eggs. The act defines "take" as "pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb." The U.S. Fish and Wildlife Service, who is responsible for carrying out provisions of this Act, define "disturb" to include a "decrease in its productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior, or nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior." This proposed geoduck farm will create disturbance and noise, especially during planting and harvesting. The eagles do hunt this area daily. One would expect the amount of available food from the tidelands to also decrease with another 5.15 acres continually disturbed. Fish are the main food for eagles in this area. C page17 LOG, ITE.- Pc4g Z �� MAMMALS 7 KILLER WHALE (SOUTHERN RESIDENT AND TRANSIENTS) Both are State Endangered Species and the Southern Residents are also a Federal Endangered Species According to the WDFW species sheet: Three populations of killer whales, known as the southern residents, transients, and offshores, regularly occur in Washington. The southern residents are listed as federal endangered species, but all three populations are state endangered species. Southern Resident Killer Whales (SRKW) did occur in Hood Canal in the past. Although SRKW have not been in Hood Canal recently, they are included in our report for this commercial geoduck farm due to the extreme importance of chinook salmon (Federal Threatened Species and State Candidate Species) as the main food source in keeping SRKW from becoming extinct. Any impacts of commercial geoduck farms on chinook salmon can then impact Southern Resident Orcas. Chinook salmon do travel through the Smersh tidelands. In particular, the out bound chinook salmon feed, hide from predators, and swim through the Smersh tideland area on the way to the Hood Canal bridge and eventually the Pacific Ocean. Very large percentages of these juvenile chinook salmon are lost due to heavy predation at the Hood Canal bridge impeding their movement out of Hood Canal. This makes it even more critical for this federally threatened species that it not be impacted by a commercial geoduck farm in this critical location. Transient killer whales do hunt in this area of Hood Canal, feeding heavily on harbor porpoises and seals, which in turn feed on a number of fish species. The Transient Killer Whales have been in Hood Canal several times during this summer. See the attached Orca Network sightings of Transient Killer Whales on 8/10/2021 that include a sighting in Squamish Harbor (See photos Orca3.j.8/10/21and Orca6.j.8/10/21 at the end of this subsection). C pagel9 jlw A Seattle Times article titled "Baby orca seen in Hood Canal with whale family", originally published May 2, 2018 and updated May 13, 2019, stated that in40,Ord-iUff f jVj in Mason County: _LL ] There's a baby orca whale hanging out in Hood Canal. PC-4ge. �7 117 A whale -watching group, Puget Sound Express, says on Monday it saw a healthy newborn calf with the whale pod known as the T65As. The family of six is led by a mother whale, the leader of the pod who has had five orca calves since she was born in 1986. The transient orcas hunt for harbor seals and sea lions for food. The whale -watchers say some of the younger orcas were seen leading hunts. An article in the Seattle Times, "Hood Canal orcas lingering, feasting", published May 29, 2005, reported: Six orcas that have spent the past four months feeding on seals in Hood Canal are defying conventional opinion about killer whales that don't belong to a territorial group. Other small transient groups typically move on to a new area after two weeks or less, said Steve Jeffries, a state Department of Fish and Wildlife biologist. "This event is unprecedented," Jeffries said. "This length of stay by transients has never been documented anywhere in the world." Officials say the orcas are among some 170 transient whales that range from California to Southeast Alaska. And while resident orca pods in Puget Sound eat fish, the transients generally dine on marine mammals. Each whale is thought to eat about one seal per day. They have been in the canal since late January, and may be taking their toll on a seal population once estimated at about 1,200. Harbor seals in the area have begun behaving differently as a result, Jeffries said. "You used to see them in the deeper open water — not now," he said. The six orcas, ranging in age from about 5 years to more than 20 years, include two older females, their two daughters and the daughters 'two offspring. They normally move south during incoming tides and north on outgoing tides, between Dabob and Quilcene bays in the north and Belfair to the south. Another group of 11 transient orcas spent nearly two months in Hood Canal in 2003. C page20 j1W LOG 9T.E,4 HUMPBACK WHALE State Endangered Species, Mexico Population Federally Threatened, Central America Population Federally Endangered Humpback whales do occur in Hood Canal. One was spotted as recently as March 21, 2021. An article by Christopher Dunagan, "Humpback shows up in Hood Canal, then disappears", dated January 31, 2012, reported sightings of a humpback whale in Hood Canal on January 30, 2012 just north of the Great Bend of Hood Canal toward the eastern shore. The article further reported: A humpback whale made a rare appearance in Hood Canal's Dabob Bay at the end of last week ... about 40 feet long. That would make it a fairly young humpback. According to Sato, C. and G. J. Wiles. 2021. Periodic status review for the humpback whale in Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 29 + iii pp.: The humpback whale is a large baleen whale found in nearly all of the world's oceans that forages on zooplankton and small fish primarily in continental shelf waters. The species undertakes long distance migrations between winter breeding grounds in tropical and subtropical waters and summer feeding grounds in high - latitude waters. Humpback whales have been listed as a state endangered species in Washington since 1981. In 2016 the National Marine Fisheries Service revised the federal Endangered Species Act listing for the humpback whale to identify 14 Distinct Population Segments (DPSs) worldwide, three of which visit Washington's waters. These include (1) the Mexico DPS, which comprises 27.9% of humpback whales present in the state and is federally threatened, (2) the Central America DPS, which contributes the fewest animals (8.7%) among Washington's humpbacks and is federally endangered, and (3) the Hawaii DPS, which comprises 63.5% of the humpbacks visiting Washington and is not federally listed. Humpback whales in the North Pacific remain vulnerable to a number of threats, including entanglement in fishing gear and marine debris, ship strikes, human - generated marine sound, the effects of climate change... Foraging and diet. Humpback whales are filter feeders but are unique among baleen whales for their ability to exploit a wide range of prey, including euphausiids (krill), crab, squid, and schooling fish (Witteveen et al. 2005, 2008, C page2l jlw L 0 G ITr1'� # k Ng Ford 2014). Fish eaten in the northeastern Pacific include juvenile walleye pollock (Gadus chalcogrammus), Pacific herring (Clupea pallasii), Pacific sand lance (Ammodytes personatus ... [emphasis added; also see our subsection on forage fish] Washington Salish Sea sightings have been concentrated in the Strait of Juan de Fuca and near the San Juan Islands, but are also reported throughout Puget Sound, including Hood Canal and as far south as Olympia... Entanglement in fishing gear and marine debris. A growing concern to whale populations is the level of threat posed by entanglement in active drifting or stationary fishing gear (such as gillnets and vertical lines used to mark trap/pot fisheries) or in discarded netting and other marine debris... Death, injury, or eventual starvation may result when entangled animals fail to free themselves of gear or debris. Risk of entanglement varies with species, the amount of spatial overlap with various fisheries, and the type of gear used in those fisheries. Humpback whales are especially vulnerable to entanglement because of their frequent use of shallower waters, combined with their large knobby pectoral fins and large flukes that make them prone to snagging lines and nets (Saez et al. 2013). Entanglements are the most commonly identified cause of death and injury among humpback whales along California, Oregon, and Washington... Vessel strikes. Whales swimming or resting near the ocean surface can be vulnerable to injury or death from collisions with large and small vessels, especially in areas of frequent vessel traffic such as the U.S. west coast. Collisions can involve either blunt force trauma or propeller strikes. Disturbance from sound and vessels. Marine mammals in all oceans are exposed to increasing levels of underwater sound from vessels, seismic surveys, sonar, marine construction, and other human -related sources (Nowacek et al. 2007, 2015). Marine ambient noise levels at frequencies below 500 Hz, which overlap with the low -frequency calls of baleen whales, have increased by at least 20 dB (re 1 µPa) since pre -industrial conditions (Hildebrand 2009, Andrew et al. 2011, Redfern et al. 2017). Baleen whales rely on their acoustic sensory system for communicating with other individuals, sometimes at distances of hundreds of kilometers. Significant levels of anthropogenic sound can therefore interfere with communication by masking vocalizations (Erbe et al. 2016). C page22 L0'Gf JlW 7�T, i Intense sound can also cause changes in surface, foraging, and vocal behavior, displace animals from occupied areas, and produce temporary or permanent hearing damage and physiological stress... Climate change. The effects of global climate change will likely become one of the greatest threats to many species of marine mammals in the coming decades because of its alteration of marine ecosystems and food webs through changes in ocean temperatures, currents, stratification, and nutrient cycling, and by causing higher sea levels and increased occurrence of unusual and extreme ocean conditions such as strong El Nino events (e.g., Doney et al. 2012) and marine heatwaves.. . The most recent size estimates place the Central America DPS at 783 whales and the Mexico DPS at 2,806 whales, and together, they comprise 36.6 percent of the humpback whales that visit the state's waters. Throughout their range, humpback whales face a number of known or potential threats such as entanglement in fishing gear and marine debris, ship strikes, human -generated marine sound, and climate change. These are most likely to adversely impact the Mexico and particularly the Central America DPSs because of their smaller sizes and heightened conservation status. See our subsection on the release of carbon caused by disturbance of the substrate and its impact on acidification of sea water and on global warming. Normally entanglements would not be associated with a geoduck farm that does not use cover nets. However, due to the capsizing of boats by BDN and loss of ropes and other debris, the entanglement issue has been included here. See the Section D Bad Track Record, item 5b. GRAY WHALE State Sensitive Species and Western North Pacific Stock is Federally Endangered According to the WDFW gray whale information sheet: Gray whales in the North Pacific are divided into two genetically -distinct populations (or stocks) known as the Eastern North Pacific and Western North Pacific stocks. The Western North Pacific stock is listed as federal endangered. Individuals from both stocks occur in Washington and are state listed as "sensitive" species. C page23 LOG IT .Ivi j1W ? Pge_ .a# f r 7 Gray whales face a number of known or potential threats, such as entanglement in fishing gear and marine debris, ship strikes, human -generated marine sound, and climate change. ...their sensitivity (to climate change) will most likely be driven by potential alterations in prey abundance. A combination of increasing ocean acidity, increasing ocean temperatures, and other changing oceanographic patterns could lead to declines in the small benthic invertebrates that gray whales feed on (mainly amphipods, clams, and krill), as well as disrupt the timing and distribution of prey. (emphasis added) Gray whales undertake the longest migration of any mammal, sometimes traveling more than 12,400 miles round-trip annually in coastal waters. Cascadia Research Collective's article, Dramatic Rescue Frees Whale in Hood dated November 21, 1994, stated: A gray whale entangled in net, ropes, and an anchor for almost a week in Hood Canal was successfully freed by biologists at 1:20 PM on Sunday, 21 November 1994. The whale had become entangled in a tribal gillnet near Hoodsport, in the southern part of Hood Canal, on Monday, 14 November. Shortly after the whale became entangled, the net was cut as close as possible to the thrashing whale by fisher people who feared for the safety of their boats and gear. The whale then slowly swam into deeper water trailing over 100 feet of net and line including an anchor of more than 130 lbs. Additional debris, including several crab pots also became attached to the gear as the whale swam. On Thursday, 17 November... found the whale, now about 15 miles north of where it had become entangled. The whale was in distress and was only able to swim slowly forward and appeared to struggle to surface to breath (sic.). On Sunday, biologists working from four boats relocated the whale in Dabob Bay, in northern Hood Canal ... they were able to cut all the visible major lines wrapped around the whale. Other boats, grappled the pieces of net and anchor trailing the whale. Final success was achieved when the whale, in a burst of energy and apparently sensing the change, done for the bottom. Though this almost swamped one of the boats, it broke the final pieces of net that still held the whale to the rest of the gear. The whale was followed for about an hour after being freed. It appeared healthy and was now diving normally. C page24 j1W A Kitsap Sun article, "Gray Whale Dies in Hood Canal", written by Christopher Dunagan, January 3, 2007 reported: ITEM !�4-ofla Quilcene A gray whale has died in Central Hood Canal, and researchers are seeking help to find the carcass, which washed up briefly on a beach near Quilcene. The first reported sighting of a live gray whale was near Seabeck on Dec. 18, according to records by Orca Network, which keeps track of whale sightings. On Dec. 22, the animal was seen swimming near Alderbrook Inn at the south end of Hood Canal. On Sunday, boaters spotted the carcass of the animal floating in the middle of Hood Canal east of Triton Cove, where it appeared to be drifting northward. The whale apparently washed up on a beach on the Toandos Peninsula, directly across from Bangor... After entering Hood Canal all of these whales must travel past the Squamish Harbor area. PACIFIC HARBOR PORPOISE State Candidate Species According to the WDFW Species Fact Sheet: Very limited information is available regarding the sensitivity of the Pacific harbor porpoise to climate change, particularly for Washington populations. Their overall sensitivity is likely to be influenced by prey availability (e.g., small forage fish like herring, zooplankton). Porpoises prefer areas with high prey density; thus, any changes in prey density, which could be prompted by climate factors like increasing ocean temperature or declines in pH could limit prey availability for porpoises. The diet of the harbor porpoise is primarily schooling fish, such as herring and mackerel, but can also include squid and octopus. (emphasis added) C page25 jlw An article in the Seattle Times, "Harbor porpoises now a common sight in Puget Sound", was originally published July 8, 2013 and Updated July 9, 2013 reported: Phocoena phocoena is a distinct species unique to Puget Sound's inside waters. They live out their lives near ours, foraging herring, smelt and sand lance in shallow nearshore waters, usually less than 500 feet deep. Living 15 to 20 years, females produce a calf each year for most of those years. The photograph attached below, labeled Hporpoise.WDFW.2017, shows data on Harbor porpoise sightings in Squamish Harbor and close by in Hood Canal in 2017 and 2018. This information came from the research in Evaluating the Potential Influence of the Hood Canal Bridge On Piscivorous Bird and Mammal Density, Jessica J. Sgtocking and Scott R. Pearson, et. al., November 2019, WDFW. Porpoises are almost always visible in Squamish Harbor and Hood Canal next to Squamish Harbor. They are often seen feeding adjacent to Shine Road (personal observation, Jan Wold). They can be impacted by a commercial geoduck farm due to their dependence on herring, smelt and sand lance and sensitivity to noise (emphasis added). These forage fish species which spawn in Squamish Harbor can be impacted by a geoduck farm as documented in other sections of this public comment. The Smersh property is in a herring spawning area. OLYMPIC MARMOT State candidate species for Threatened and Endangered A marmot, most likely an Olympic marmot, was recorded on 7/7/20 at Huckleberry Hill Lane, Port Ludlow, WA on a security camera. The picture was available on the social media site Nextdoor (see photo below, labeled Marmot.j.7/7/20) This location is about 3/4 mile northwest of portions of the Smersh proposed commercial geoduck farm, storage and parking areas. This species is not shown on the list of threatened and endangered species on the Smersh application or in the SEPA documents. It is a state candidate species for Threatened and Endangered status. It is the only endemic mammal in Washington state and was designated as the official endemic mammal of Washington in 2009. C page26 10:58 9 4 Nextdoor jlw 0 nextdoor.com Marmot j.7/7/20 LOG ITEM P49,G _of11. C page27 j lw NVI o r�� State Endangered and Federal Candidate for Listing The WDFW fact sheet states: 1-0"G ITEM 7 Ninety fishers were reintroduced to the Olympic Peninsula from 2008 to 2010 as the first step in fisher recovery in Washington, and surveys conducted from 2013 to 2016 indicated that reintroduced fishers have been successfully reproducing and are widely distributed on the Olympic Peninsula. Since 2008, the Washington Department of Fish and Wildlife (WDFW) and its partners have successfully relocated 260 fishers from British Columbia and Alberta to the National Park and National Forest lands of the Olympic Peninsula and the Cascade Mountain Range in Washington. This species is identified as a Species of Greatest Conservation Need (SGCN) under the State Wildlife Action Plan (SWAP). Lewis, J. C. 2017. Periodic status review for the Fisher in Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 13+ iv pp. reports in the mapping in this 2017 report that a fisher was killed on the road approximately 1.5 miles NE of this proposed commercial geoduck farm and was even closer to the proposed storage areas for this farm. The fisher has not even been mentioned in the Smersh application SEPA document even though this State Endangered species has been recorded less than one and a half miles from this proposed geoduck farm. At a minimum, an EIS is needed for this project. Jefferson County needs to be certain all of these many Threatened and Endangered species in the area have been thoroughly reviewed before any decision to approve this project is considered. KEEN'S MYOTIS BAT State Candidate Species According to Hayes, G. and G. J. Wiles. 2013. Washington bat conservation plan. Washington Department of Fish and Wildlife, Olympia, Washington. 138+viii pp.: C page28 j1W PC4 7 Keen's myotis has one of the smallest distributions of any North American bat, occurring in coastal areas from southeast Alaska to the Olympic Peninsula, Puget Sound, and Mt. Rainier in Washington (Buries and Nagorsen 2003, Boland et al. 2009b, WDFW WSDM database; Appendix A). In Washington, it has been recorded in San Juan, Clallam, Jefferson, Mason, and Pierce counties (van Zyll de Jong and Nagorsen 1994; E. Myers, pers. comm.; WDFW WSDM database). Riparian and estuarine habitats near mature conifer forests are important foraging sites on Vancouver Island (Burles and Nagorsen 2003). There are mature conifer forests above State Highway 104, including in the vicinity of Bones Creek. TO W N SEN D' S BIG -EARED BAT State Candidate Species According to Hayes, G. and G. J. Wiles. 2013. Washington bat conservation plan. Washington Department of Fish and Wildlife, Olympia, Washington. 138+viii pp. (pages 55-80): Townsend's big -eared bat occurs from southern British Columbia southward through most of the western U.S. to central Mexico (Kunz and Martin 1982, NatureServe 2009; Appendix A). Isolated populations also exist in the Ozarks and Appalachians. Documented records exist for most counties in Washington, but are lacking for the southern Columbia Basin and the Blue Mountains (WDFW WSDM database). Townsend's big -eared bats use night roosts as resting places during foraging and for social interaction. Night roosting occurs in caves, mines, buildings, culverts, and bridges (Dalquest 1947, Perkins 1990a, Perlmeter 1996, Pierson et al. 1999, Adam and Hayes 2000, Fursman and Aluzas 2005). Dropped insect parts, such as moth wings, can be used to identify night roosts. In the West, this species forages in closed -canopy forests, canopy gaps, forest edges, riparian corridors, and shrub -steppe (Dobkin et al. 1995, WBWG 2005, Gruver and Keinath 2006). This species occupies elevations from sea level to 3,200 m (Nagorsen and Brigham 1993, Pierson et al. 1999), but occurs mainly at low- to mid - elevation C page29 j1W o facebook.com EiWW-=_ - MYEMAI L.CON STANTCONTACT.COM Aug 11, 2021 WS Report: Bigg's KWs & humpbacks around the Salish Sea 4)0 87 1 Comment 6 Shares 6 Like Q Comment p,> Share Oldest W W AN Lee Nicole Strawderman 13h ca Orca Network August 10 at 824 AM Q Tuesday, August 10th: 08:04 - Three orcas spotted hunting just now mid span Hood Canal Bridge south side. Almost under bridge so couldn't get a good count but looked like two females, possibly a male. Actively hunting. -Tammy Shelton Y PLEASE KEEP COMMENTS to current sightings, photos & video UPDATES ONLY. (Please NO: Tags; "Following"; "Updates?"; or watercraft behavior comments (for that see (1). Y SEE #BeWhaleWise info & link in 1st comment. (laws/guidelines, educational... See More Orca3 . j .8/ 10/21 photo LOG ITSM 117 C page30 jIW LOG ITEM Pag,9�-�Lof � facebook.com r✓' '~ 1 au Page I Nora Sh... hood Canal, humpback w... G transient orcas, [MV] TACOMA Master reports 3-4 Orca frolicking in various directions just off of Tyee Shoal. [Tyee Shoal just south-southeast of Wing Point, Bainbridge] r PLEASE KEEP COMMENTS to current sightings, photos & video UPDATES ONLY. (Please NO: Tags; "Following"; "Updates?"; or watercraft behavior comments (for that see ").... See More SnA RIE i- f Want wwworcanetworkorg 0083 29 Comments 4 Shares 0!) Like Q Comment (�> Share View 19 more comments Oldest Philip Mackey -Moseley We just saw a pod off of Bridgehaven Community Club which is just south of the hood canal bridge. They followed the current west, into the bay in front of Shine. 2d 00 5 Orca6.j.8/10/21 photo C page3l jlw 2017 Utimcmodd0nsity L11)1.09 = 1.22 CI23.n1 M J2-57 $8.8.0 �a1.12.6 12.0.02.5 MOd Cunel Bridge L( iG ITEM #- f Page of / l 7 w 0 1 2 4 Km I i 1 i I wver.a NWFW J.8b04q, FW Figure 8. Relative density of harbor porpoise (Phocoena phocoena) in line transect surveys of Hood Canal bridge during steelhead outmigration 2017-201 S (n=14 visits/year). Points represent observations. Hporpoise.WDFW.2017 C page32 j1W !-0: ECHINODERM Page SUNFLOWER SEA STAR �117 Certified as Critically Endangered by International Union for Conservation of Nature The sunflower sea star (Pycnopodia helianthoides) has been pushed to the edge of extinction by sea star wasting disease. Its range used to extend from Alaska into Mexico, but it has apparently now disappeared from Oregon, California and Mexico. Scattered populations can still be found in Hood Canal, at least in 2020. They are the second largest sea star in the world and can have an arm span of over three feet. According to a newspaper article written by Chris Dunagan in the Kitsap Sun on December 11, 2020, ecologists say the sea stars are a key component of the complex marine food web. One important function is to prey upon sea urchins that consume a massive amount of vegetation such as kelp. The sea stars help keep the kelp beds productive. Kelp is also declining in Hood Canal. The listing of the sunflower sea star by the International Union for Conservation of Nature announced a 90-percent reduction in the overall population of sunflower sea stars. There are much reduced numbers in Puget Sound, Canada and Alaska. The entire coastline of western Washington is apparently now devoid of sunflower sea stars and it is only found in Puget Sound (including Hood Canal) and areas to the north. After intensive surveys there have been no signs of the population recovering. According to the Dunagan article, Taylor Frierson of the Washington Department of Fish and Wildlife stated for a news release that: The speed and scale of this widespread sea star die -off was absolutely perplexing ...and that the sunflower sea star has a ...fundamental role in the nearshore ecosystem. The Dunagan article further states that in a captive -breeding program at Friday Harbor Labs, the first of its kind: After learning to feed and care for the animals, the challenge was to get the sea stars to spawn and then to help the free-swimming offspring survive and eventually settle down, according to senior research scientist Jason Hodin...'To me, this is the most radical transformation of any metamorphosis in the living world,' Jason said. `The larvae feed on micro algae, and they look nothing like adults. Then, at the ends of their larval period, they have to find their way to appropriate habitat and transform their bodies into a form that can live on the sea floor.' (emphasis added) C page33 jIW LiDG iT 1 e ZZ An article in SciTechDaily titled Iconic Sunflower Sea Star Is Now Critically Endangered, by Oregon State University, 1/2/21 states: ...your chances of finding one [sunflower sea star] now are next to nothing in most of the contiguous United States - this listing is one step above extinction ... Sunflower sea stars are a key predator of purple sea urchins and the sea star decline has helped fuel an explosion in the urchin population in many regions. An over abundance of urchins is linked to a decline in kelp forests already facing pressure from marine heat wave events, making the future uncertain for ecosystems that provide habitat for thousands of marine animals and help support coastal economies... In this same article, study co-author Sara Hamilton, a Ph. D. candidate in the Oregon State University College of Science states: We need to think creatively about how to keep our ocean healthy. While drawing down carbon emissions is the most pressing need, rebuilding key predator populations, like the sunflower sea star, can be an important piece of the puzzle too. As covered in other sections of our analysis of the Smersh proposed geoduck farm, we cover the increases in carbon released into Hood Canal by disturbance of the nearshore substrate from activities such as inserting and removing PVC tubes and the disturbance of the top three feet of tideland and redistribution of this substrate when the geoducks are harvested. We also discuss concern that geoducks may filter the water of the very organisms the larval stage of the sunflower sea star need to feed on to prosper. We provide research articles covering this issue. There has apparently been no review of the impact of the large number of commercial shellfish farms in Puget Sound or Hood Canal on sunflower sea stars, its habitat and the species it feeds upon. The sunflower sea star larvae feed on micro algae which may be the same members of the food chain the up to a million geoducks at the Smersh commercial farm will the "cleaning" from the water column. Any impacts to this critically endangered sea star species need to be studied along with cumulative impacts prior to any county approval of this commercial geoduck farm permit. Either an EIS needs to be prepared to understand these impacts or this project needs to be denied outright. C page34 j1W ITEM REPTILES AND AMPHIBIANS G►g@(� WESTERN TOAD State Candidate Species A toad was discovered in Bridgehaven on the south side of Suquamish Harbor, along the west edge of Hood Canal about two miles southwest of the Smersh proposed commercial geoduck farm, storage and parking areas (see photo: WToadl.j.8/11/21 at the end of this subsection). This toad appears to be a western toad and is located in the known range of the western toad. A neighbor on the social media site, Nextdoor, shared the photograph. See the distribution map from the Washington Herp Atlas, Hadlock, L. A. and McAllister, K. R., 2005, updated October 2011, located at the end of this section (see photo: WToad3.j.8/11/21). According to the WDFW species sheet, This species is identified as a Species of Greatest Conservation Need (SGCN) under the State Wildlife Action Plan (SWAP) and is also identified as a Priority Species under WDFW's Priority Habitat and Species Program. The WDFW species sheet states: Conservation Threats and Actions Needed Fish and wildlife habitat loss or degradation • Threat: Transportation and service corridors — roads and railroads. • Action Needed: Avoid road building near breeding sites. • Threat: Road mortality when moving to and from breeding sites. Newly metamorphosed toads disperse en masse and gather in piles. When this happens on roads, thousands of toads can be killed by a single vehicle. Adults are also killed as they move to and from breeding sites. • Action Needed: 1. Identify and map known crossings; 2. Avoid road building near breeding sites; 3. When possible, close roads to vehicles during dispersal periods (e.g., ATV use on gated dirt roads); 4. Create passage structures to circumvent roads. • Threat: Loss of upland habitat through the development on shorelines and around water bodies used for breeding. • Action Needed: Protect known pockets of abundance and breeding areas. • Threat: Habitat alteration and degradation. • Action Needed: Protect known pockets of abundance and breeding areas.... C page35 I _00 tits. JlW f PCB 117 WDFW participated in the Washington Wildlife Habitat Connectivity Working Group, formed in 2007, whose mission was to promote the long-term viability of wildlife populations in Washington State through a science -based, collaborative approach that identified opportunities and priorities to conserve and restore habitat connectivity. This working group initiated the Washington Connected Landscapes Project, which provided a systematic approach with multiple components and a sustained effort to support the group's mission. They produced a statewide analysis, published in 2010....Assessing the current condition of wildlife habitat connectivity in the state was an important step for connectivity conservation. Animals move across landscapes to find food and other resources, migrate between seasonal habitats, find mates, and shift to new habitats in response to environmental changes. The ability to successfully move between habitats is essential for the long-term survival of many wildlife species, from large, migratory species such as elk and mule deer, to smaller animals like white-tailed jackrabbits, greater sage -grouse, and western toads. Focal wildlife species were selected using criteria designed to favor species with geographic ranges, habitat associations, and vulnerabilities to human -created barriers that made them representative of the habitat connectivity needs of many terrestrial species at a statewide scale. Western toads were selected as a focal species because they were a good representative of habitat connectivity needs of wildlife with similar life history needs in the three forest vegetation classes (Rocky Mountain, Vancouverian, and Subalpine Forests). In addition, the toads `broad coverage across the landscape, reliance on connectivity between populations, and in particular, their association with wetlands and aquatic systems led to inclusion in the statewide analysis. Bones Creek, on a smaller scale, does provide one of the few safe travel ways under State Highway 104, about 1 /4 mile above the Smersh property to the north. The State of Washington spent $1.4 million to replace an impassable culvert with a large concrete arch that allows for the passage of fish and wildlife through this connected habitat from the shoreline of Hood Canal at the Smersh property, north up under Highway 104 and to Teal Lake, about 2.5 miles to the north (see maps in our Section B Bones Creek). Most of this area is forested, with some recent clearcuts. See the photograph of the culvert under State Highway 104 at the end of this section, below, labeled Culvert.j.6/5/20. C page36 j1W PC4ge -�f1 All of the Smersh operations are not far from, or within in the 150-foot buffers of Bones Creek and Hood Canal. Analysis needs to be undertaken to determine if the western toad is located in the immediate area. Smersh is proposing to add a parking lot in or next to the Bones Creek (F, fish stream) 150-foot critical area buffer. Smersh and/or the neighboring owner has already widened the road to this proposed parking lot, added gravel and possibly added a new culvert in the last couple of years. This was done apparently without the benefit of any permits. This previous road construction and upgrading is inside the Bones Creek 150-foot critical area buffer. All vehicles entering and leaving the Smersh proposed parking lot for this commercial business will be traveling inside of this fish stream buffer. See our Section B Bones Creek for more history on this and other situations regarding Bones Creek. C page37 jlW Photo WT-oad3.j.8/11/21: 96 of 250 ' o w&w.wa,gov Distribution Map Western Toad -Known Distribution Sped*$ Qbsewatione 4� 2006 - 2016 e• ■ ■ • A � - - iAj A PFW to 2006 �� ~gyx�A K A' ti.- rxav • n■■ ■� .� r w ■ -ArL jAA A � � {!!�it TWA ORAIIt %�� ■ ■ .. / AJ)Alli 1NRMAN `� r y■0 � .�■ FFAHK Law WO A cotin�rt aonnN --.tiwr.L�wk� w +F 9CAmrt� ■ rxi,s,a ■ . . 1` AA" ■ C page38 Photo: WToadl.j.8/11/21 C page39 jlw Photo: Culvert.j.6/5/20 C page40 jlw MOLLUSKS PINTO ABALONE Washington State Endangered Species, Federal Species of Concern Pinto abalone (also called northern abalone) do occur in Hood Canal. According to the Puget Sound Restoration Fund Pinto Abalone Recovery Plan, March 2014: The pinto abalone is the only abalone species found in Washington waters. This native species has cultural and ecological significance, grazing rock surfaces and maintaining the health of rocky reef habitat and kelp beds. Population declines have been precipitous; the Washington Department of Fish & Wildlife (WDFW) documented a —98% decline from 1992 to 2017, leading WDFW to formally list pinto abalone as a State endangered species in 2019. Adult pinto abalone feed primarily on drift macroalgae, such as Nereocystis luetkeana (bull kelp), and juveniles feed predominantly on microalgae and diatoms (page 10). ...they typically occur in shallow subtidal areas... (page 11) Adult pinto abalone may be experiencing intrinsic and extrinsic conditions that affect reproductive success. Factors such as reproductive senescence and changing ocean chemistry (including ocean acidification) may be factors contributing to reduced spawning activity, reduced gamete production and poor gamete condition... (emphasis added) (page 12). ...larval development of pinto abalone was affected by ocean acidification conditions (emphasis added) (page 15). ...elevated sedimentation and levels of pollutants may be affecting reproduction, settlement and juvenile survival (page 15). According to the Proposed Rule Making on pinto abalone, the Washington Department of Fish and Wildlife analysis of pinto abalone stated: that they may still occur in Hood Canal, at least in 2003 as follows: Pinto abalone observations were reported in two northern Hood Canal locations in 2003 by REEF surveyors. These reports are considered unconfirmed because the surveyors were classified as "novice level"; these data were not used to describe the geographic extent of the species. C page4l J1W� p A pinto abalone shell was found washed up on the Squamish Harbor shoreline about a half mile east of the proposed Smersh commercial geoduck farm on June 7, 2020 (Marilyn Showalter and Marcia Swendiman, personal communication). Their three pictures of the pinto abalone shell are below, labeled Abalonel.m.6/7/20, Abalone2.m.6/7/20 and Abalone3.m.6/7/20. An EIS should be required to review the closest locations of pinto abalone and provide an analysis of any possible impacts, if there are any, from geoduck farming. Photo Abalonel.m.6/7/20 C page42 ;lW Photo: Abalone2.m.6/7/20 LOG ITUM Page C page43 jlw Photo: Abalone3.m.6/7/20. LOG ITEM I r7 C page44 jlw OLYMPIA OYSTER -�7 Washington State Candidate Species for Threatened, Endangered or Sensitive The Olympia oyster is Washington's only native oyster. It is also included in WDFW's Priority Habitats and Species (PHS) List, a catalog of habitats and species considered a priority for conservation and management. According to the WDFW the stressors for this species is further habitat alterations, water pollution, invasive predators and alternative uses for habitat such as aquaculture The WDFW has selected 19 Priority Sites for Olympia oyster restoration, three of which are in Hood Canal. (emphasis added) According to the WDFW website, August 2021: Olympia oysters are likely to be sensitive to a number of climate factors, including declines in salinity, oxygen and pH....increases in extent and time of hypoxic conditions could limit oyster growth. Predicted declines in ocean pH in Washington are also likely to lead to decreases in growth, weight, and metamorphic success of oyster larvae, which could also trigger increased mortality at larger life stages. The effects of acidification on oyster larvae could be more severe if low pH conditions are coupled with decreases in phytoplankton food availability. (emphasis added) These are the very conditions that are to be expected from a geoduck farm. Both competition for food availability and the acidification of Hood Canal (both discussed in depth in other sections of our input) are made considerably worse by a commercial geoduck farm. The Army Corps of Engineers draft cumulative effects analysis that was started over five years ago determined that 19% of Hood Canal tidelands were covered with commercial shellfish permits. We cannot afford to add any more geoduck farms until these impacts are better understood. This geoduck farm should not be approved or at a minimum an EIS should be prepared to be certain of these impacts on Olympia oysters. C page45 r-00 11T MARINE FISH WALLEYE POLLOCK (SOUTH PUGET SOUND) State Candidate Species for listing in Washington as Endangered, Threatened or Sensitive According to the WDFW species sheet: In Puget Sound, walleye pollock can grow up to 3 feet (91.4 centimeters) in length and live up to 10 years.... Walleye pollock are likely to be sensitive to increases in sea surface temperature, particularly since Puget Sound is the southern limit of their range. Cooler waters support higher levels of pollock recruitment and larval survival because cooler waters promote increased production of primary prey species for pollock (e.g., copepods, euphausiids, other zooplankton). See the discussion regarding the food chain organisms being removed from the water by geoducks in our public comments in the Marine Environment section that discusses forage fish. The prey species needed by walleye pollock are the very same species the geoducks "clean" from the water. The Smersh geoduck farm will add to this impact on this species. PACIFIC COD (SOUTH AND CENTRAL PUGET SOUND) State Candidate Species for listing in Washington as Endangered, Threatened or Sensitive According to The Encyclopedia of Puget Sowed Puget Sound Initiative, University of Washington, Bentho-Pelagic Fish: Pacific cod occupy different habitats throughout their life cycle. Eggs are typically found in demersal habitats followed by a transition to the pelagic zone as larvae and small juveniles, settling to intertidal or subtidal sand or eelgrass habitats as large juveniles and moving to deep water as adults (reviewed by Gustafson et al. 2000). Juvenile cod feed on crustaceans such as shrimp, mysids and amphipods; the diet of adults is though to reflect the relative availability of prey with some preference for walleye pollock in large (>70 cm) adults (Gustafson et al. 2000). Pacific cod are preyed upon by a variety of predators including pelagic fishes, sea birds, whales, halibut, shark and other Pacific Cod. (emphasis added) C page46 This species is quite dependent on sand and eelgrass habitats that will be impacted by a commercial geoduck farm. Refer to the section on eelgrass in our public comments for more information. PACIFIC HERRING State Candidate Species for Listing in Washington as Endangered, Threatened or Sensitive and Federal Species of Concern The Washington Department of Natural Resources, Aquatic Lands Conservation Plan Species Spotlight, Pacific Herring, discusses: Importance in the ecosystem food web: Herring are a foundation food source in the food web because they are secondary consumers —eating smaller plant -eating animals. Recently emerged herring and juveniles feed on plankton. Adults feed primarily on planktonic crustaceans, such as copepods and other zooplankton. Approximately 50 to 70 percent of adult herring from Puget Sound are estimated as an important prey item each year for numerous marine animals, such as seabirds, marine mammals, and other fishes. Herring stock strength is directly linked to the health and status of many such predators, including those protected by state and/or federal laws, such as the Endangered Species Act (ESA). Herring deposit transparent, adhesive eggs on intertidal and shallow subtidal eelgrass and marine algae. Eggs may be deposited anywhere between the upper limits of high tide to a depth of 40 feet. Eggs hatch in about 14 days, producing slender, transparent larvae. At this stage, they are at the mercy of currents and subject to heavy predation by larger organisms. At about three months of age and 11/2 inches long, herring metamorphose into their adult form and coloration. (emphasis added) See the extensive discussion regarding the food chain organisms being removed from the water by geoducks in our subsection on forage fish. The prey species needed by Pacific herring are the very some of the very same species the geoducks "clean" from the water. Our forage fish section also describes a large Pacific herring spawning area that includes the Smersh proposed geoduck farm and large areas to both the east and west of the proposed geoduck farm. Herring are one of the most important species in the food chain for many other marine species. C page47 LOO ATENI #_ 61) Page- `— ROCKFISH All of the following Rockfish do occur in Hood Canal or have in the recent past and are all State Candidate Species for listing in Washington as Endangered, Threatened or Sensitive according to the WDFW. The Biology and Assessment of Rockfishes in Puget Sound By Wayne A. Palsson, Tien- Shui Tsou, Greg G. Bargmann, Raymond M. Buckley, Jim E. West, Mary Lou Mills, Yuk Wing Cheng, and Robert E. Pacunski, Fish Management Division, Fish Program. Washington Department of Fish and Wildlife, September 2009 states: Rockfishes in Puget Sound are a diverse group that form mixed species assemblages and require species- specific habitats at different life -stages. Rockfish have evolved to complex life strategies adapted for long survival, slow growth, late age -at -maturity, low natural mortality rates, and high habitat fidelity... Population structure is highly dependent upon the evolutionary and ecological patterns of each species.... Rockfishes feed on a wide variety of prey, including plankton, crustaceans, and fishes. Rockfishes are prey for a variety of predators including lingcod and other marine fishes, marine mammals, and marine birds. ... larval and juvenile stages of some rockfishes make use of open water and nearshore habitats as they grow. Nearshore vegetated habitats are particularly important for common species of rockfish and serve as nursery areas for juveniles and later provide connecting pathways for movement to adult habitats. (emphasis added) Among the potential stressors, fishery removals, derelict gear, hypoxia, and food web interactions are the highest relative risks to rockfish in Puget Sound. Chemical contamination is a moderate risk manifested by undetermined reproductive dysfunction associated with exposure to endocrine disrupting compounds, loading of larvae with persistent organics via maternal transfer, exposure of pelagic larvae to toxics via contaminated prey, and exposure of long- lived adults to toxics like polychlorinated biphenyl compounds that accumulate over the life of the fish. Most prey studies conducted in Puget Sound and adjacent waters have focused on the diets of copper and quillback rockfishes and have found that shrimps, fishes, and crabs constitute the main components of their diets (Table 3.3). Rockfish size and location may be important factors in the types of prey selected. Murie (1995) studied rockfish diets in Saanich Inlet in the southwestern Strait of Georgia and found that copper rockfish mostly consume, by mass, Pacific herring (Clupea pallasii) (emphasis added), coonstriped shrimp (Pandalus danae), kelp perch C page48 �-`°�°`� 'fir R7 '► �,1 (Brachyistius frenatus), pile perch (Rhacochilus vacca), and squat lobster (Munida quadraspina). The diet of copper rockfish depends upon fish size. Copper rockfish smaller than 20 cm in length feed upon demersal crustaceans or pelagic fishes (on a mass basis), while larger copper rockfish principally feed upon pelagic fishes. These feeding patterns are consistent for copper rockfish diets in Puget Sound, except surfperches and other fish are the principal fishes eaten with few or no herring found in the stomach contents. In South Sound, Hueckel and Buckley (1987) found surfperches, pandalid shrimp, greenlings, other fishes, and crabs are the most important prey items. (Copper rockfish in The Biology and Assessment of Rockfishes in Puget Sound September 2009 3-6) South Sound eat pandalid shrimp, surfperches, and sculpins (Patten 1973). They also eat crabs and other fishes including Pacific herring, spiny dogfish (Squalus acanthias), eel -like fishes, and Pacific sand lance (Ammodytes hexapterus) (Washington et al. 1978). Juvenile copper rockfish from the Nisqually area of South Sound primarily feed upon crangonid and pandalid shrimps followed by fishes in importance (Fresh et al. 1978). Crabs are the second -most important prey item after fishes in the San Juan Islands (Moulton 1977). Miller et al. (1978) found that juvenile copper rockfish eat amphipods, fishes, and mysids as the three most important prey items. Quillback rockfishes consume similar prey items compared to copper rockfish except that demersal crabs and shrimps are usually the most important or highest mass items (Table 3.3). In the most detailed study of quillback rockfish food habitats (Murie 1995) found that the majority of quillback rockfish of any size feed upon pelagic fishes and pelagic and demersal crustaceans, such as squat lobster, euphausids, and coonstriped shrimp on a mass basis. The most important pelagic fish is Pacific herring, but prey items vary by the size of rockfish. Small quillback rockfish less than 20 cm in length feed primarily on demersal crustaceans and pelagic fish, and to a lesser extent, pelagic crustaceans. In contrast, most of the food mass consumed by larger quillback rockfish (greater than 20 cm) consists of pelagic fishes. Studies from central Puget Sound also found that small and medium-sized quillback rockfishes primarily consume demersal crustaceans, including pandalid and hippolytid shrimp, amphipods, crabs, but also consume euphausids as an important prey category (Washington et al. 1978, Heuckel 1980). Large quillback rockfishes consume crabs, shrimp, fishes, and amphipods as their principal prey items, showing that fishes are important in larger rockfish diets, but there is still a high degree of dependence upon benthic invertebrates Moulton (1977) examined stomachs from juvenile quillback rockfish from the San Juan Islands and found that crabs, fish, and shrimp are the most important constituents of their diets. (emphasis added) C page49 � .. : - "AV #_�� n pCA •-Q � There is some seasonality to the feeding patterns of copper and quillback rockfishes. Copper rockfish feed throughout the year, but quillback rockfish tended to have fuller stomachs during the spring and summer than during the winter and fall (Murie 1995). Both copper and quillback rockfishes feed on pelagic fishes during all seasons but pelagic fishes are more prevalent in rockfish diets during the winter. Demersal crustaceans are more important on a mass basis for copper rockfish during the spring and summer. Murie (1995) found daily variation in the feeding patterns of copper and quillback rockfishes. Copper rockfish have higher percentages of full stomachs after sunrise and sunset indicating crepuscular feeding activities. In contrast, quillback rockfish feed at mid -day. Moulton (1977) found a similar crepuscular pattern in daily feeding patterns for copper rockfish, but found that quillback rockfish in the San Juan Islands are also crepuscular feeders, not mid -day feeders. Limited food habit data for other rockfishes only allow for a general description and categorization of their feeding ecology. Brown rockfish in South Sound depend upon fish and demersal crustaceans, including crabs, pandalid and other shrimps, and isopods (Washington et al. 1978, Hueckel and Buckley 1987). One tiger rockfish sampled from the San Juan Islands only had crabs in its stomach, and one yelloweye rockfish had pandalid shrimp and nematodes (Miller et al. 1978). In South Sound, yelloweye rockfish feed on fishes, especially walleye pollock (Theragra chalcogramma), cottids, poachers, and Pacific cod (Gadus macrocephalus) (Washington et al. 1978). As expected, black rockfish feed upon pelagic prey including fishes such as Pacific sand lance, Pacific herring, and sculpins, hyperiid amphipods, euphausids, chaetognaths, gelatinous zooplankton, shrimps, and crabs. Yellowtail rockfish, which often co -inhabits pelagic schools with black rockfish, feed upon fishes, shrimp, chaetoghanths, and euphausids, similar to black rockfish, but their diets also include mysids, crab larvae, calanoid copepods, and polychaetes (Moulton 1977, Miller et al. 1978, Washington et al. 1978). The diet of Puget Sound rockfish consists of small prey items such as calanoid copepods, crab larvae, chaetognaths, hyperiid amphipods and siphonophores (Moulton 1977, Miller et al. 1978). Rockfishes of all sizes are an important food resource for a variety of predators in Puget Sound. They are prevalent in the diets of lingcod, other marine fishes, marine birds, and marine mammals. Marine mammals.- Rockfishes are consumed in varying but low amounts by marine mammals including harbor seals (Phoca vitulina), California sea lions (Zalophus californianus), and orca (Orcinus orca) in Puget Sound. There are two types of killer whales (Orca) that inhabit Puget Sound, the "resident" whales that spend their entire lives in the Sound and "transient whales C page50 LOG ITEM PGgell that move in and out of the Sound. The transient whales primarily consume marine mammals, while the resident whales feed on fish (Wiles 2004). Limited studies of the diet of resident killer whales found that during the spring, summer, and fall 22 species of fish are consumed. However, approximately 96% of the diet during these times consist of chinook salmon (Wiles 2004). There has been one instance of a yelloweye rockfish being consumed by a killer whale (Wiles 2004). Rockfish can exhibit avoidance and other behaviors to stimuli. Rockfish exhibit strong depth and geographic movements in response to hypoxic waters, apparently avoiding waters with dissolved oxygen concentrations of less than 2 mg/L (Palsson et al., 2008). Rockfish, however, may also avoid warm, stratified water greater than 11 o C, remaining below the thermocline but above the oxycline when hypoxic conditions are not too severe. Rockfishes exhibit startle and alarm responses when exposed to sounds from an air gun (Pearson et al. 1992). Rockfish exhibit alarm responses at 180 dB referenced at 1 uPa, and startle responses occur at 200 to 205 dB referenced at 1 uPa, and that more subtle behaviors are evident at 161 dB. In addition to their behavioral response to hypoxia, mass mortality events have killed approximately a quarter of all copper rockfish present at a marine reserve in Hood Canal. The mortality event occurred when dissolved oxygen concentrations were likely below 1 mg/L (Palsson et al. 2008), and smaller rockfish were affected more than larger rockfish. A recent study of climate change by the University of Washington concluded that profound changes have occurred in the Puget Sound environment over the past century and that the next several decades will see even more changes (Snover et al. 2005). Projected changes that could impact rockfishes include increases in water temperature and flooding, accelerated rates of sea level rise, loss of nearshore habitat, changes in plankton, and increased likelihood of algae blooms and low levels of dissolved oxygen. (emphasis added) See also our subsection on the need to evaluate release of carbon during geoduck harvesting and its impact on the condition of Hood Canal. Loss of nearshore habitat as occurs with a commercial geoduck farm is listed above as a potential impact to rockfishes. BLACK ROCKFISH C page5l LOG ITF,,oM y, This species is identified as a Priority Species under WDFW's Priority Habitat and Species Prag gm. Also according to WDFS Black rockfish can grow up to 69 cm (27.6 in) in length, and 5 kg (11 lbs) in weight. Maximum age is 50 years old. Ecological Research on Rockfishes in Puget Sound, NOAA, no date given, states: Relative Importance of Pelagic, Kelp Forest and Eelgrass Habitats to Rockfish ... In the Puget Sound, bull kelp (Nereocystis luetkeana) and eelgrass (Zostera marina) are important biogenic habitats providing shelter for various valued specie. As such, they are the focus of restoration efforts, (emphasis added) See our subsection on Native Eelgrass on the impacts of geoduck farming on eelgrass. BOCACCIO ROCKFISH Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: ....rockfish habitat utilization in Puget Sound indicate that nearshore vegetated habitats are particularly important for some species and serve as nursery areas for juveniles (Palsson et al., 2009) (79 FR 68042). Juvenile bocaccio settle to shallow, algae -covered rocky areas or to eelgrass and sand ... (emphasis added) The following rockfish occur in Hood Canal. See the descriptions of some of their prey items and other information in the main discussion above, under the Rockfish heading. BROWN ROCKFISH COPPER ROCKFISH CANARY ROCKFISH GREENSTRIPED ROCKFISH QUILLBACK ROCKFISH REDSTRIPE ROCKFISH YELLOWEYE ROCKFISH YELLOWTAIL ROCKFISH C page52 lw SALMON AND TROUT �c4go j~ �0 1 l 7 INTRODUCTION Hood Canal contains populations of federally threatened, (subject of federal register notices, but have not yet been added to the state candidate list) Puget Sound steelhead (Oncorhynchus mykiss), federally threatened, state candidate for listing as endangered, threatened or sensitive Puget Sound Chinook salmon (O. tsha , scha), federally threatened, state candidate for listing as endangered, threatened or sensitive Hood Canal Summer -run Chum salmon (O. keta), and federally threatened, state candidate for listing as endangered, threatened or sensitive Bull trout (Salvelinus confluentus). Coho, fall chum and pink salmon also occur in Hood Canal but are not federally listed at this time. Shellfish aquaculture adversely affects marine life, including Chinook salmon which are essential to Southern Resident Killer Whale (Orca) survival (See our discussion of this species in the subsection on mammals). The 2017 Army Corps Draft Cumulative Effects Analysis' is a frank assessment of what the science shows will likely happen if industrial scale aquaculture is allowed to continue, much less expand. The Corps concluded: Given the magnitude of the impacts in acreage, the importance of eelgrass to the marine ecosystem, and the scale of the aquaculture impacts relative to other stressors, the impacts are considered significant [Page 103]. The conclusion therefore is that significant cumulative effects to surf smelt and sand lance spawning habitat would occur due to the proposed action [shellfish aquaculture permitting] [Page 112]. The proposed action [shellfish aquaculture permitting] is inconsistent with State requirements under the SMA to protect forage fish spawning habitat [Page 111]. (emphasis added) ' This is a document included in the record of the U.S. District Court for Western Washington, Coalition to Protect Puget Sound Habitat et al v U.S. Army Corps of Engineers et al. The court's order of October 10, 2019 is included in Log Item 39, pp 215-238/561 C page53 j1W PC4��f-� These determinations make clear that aquaculture is impacting these threatened and endangered salmon and trout as well as the eelgrass and forage fish that are important for their survival. See our sections on eelgrass and forage fish in the Marine section of our public comments for more detailed information, Programmatic Biological Assessment, Shellfish Activities in Washington State Inland Marine Waters, U.S. Army Corps of Engineers Regulatory Program, Seattle District, October 2015, states: 8.1.3. Effect Determination. The proposed action [shellfish aquaculture permitting] may affect, likely to adversely affect Puget Sound Chinook salmon and Puget Sound Chinook salmon designated critical habitat. [Page 106] 8.3.3. Effect Determination The proposed action may affect, likely to adversely affect Hood Canal summer chum salmon and Hood Canal summer chum salmon designated critical habitat. [Page 109] 8.6.3. Effect Determination The proposed action may affect, likely to adversely affect bull trout and bull trout designated critical habitat. [Page 112] 9.2.... As discussed in the PBA and summarized above, the activities authorized under the proposed action would affect EFH (Essential Fish Habitat). While these effects would be minimized by the implementation of the many Conservation Measures, the proposed action would result in adverse effects to EFH for groundfish, coastal pelagic, and Pacific salmon species. [Page 126] STEELHEAD, PUGET SOUND DISTINCT POPULATION SEGMENT Federal Threatened Species Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: The winter -run steelhead is the predominant run in Puget Sound, in part because there are relatively few basins in the Puget Sound DPS with the flow and watershed characteristics necessary to establish the summer -run life history (National Marine Fisheries Service, 2016c). All summer -run stocks are depressed and concentrated in northern and central Puget Sound and Hood Canal..... NMFS (2016a) indicated the principal factor for decline for Puget Sound steelhead is the present or threatened destruction, modification, or curtailment of its habitat or range. Within Puget Sound, these threats may include barriers to fish passage, C page54 jtW # LOG I7'SM a 1, J _0 2/7 adverse effects on water quality, loss of wetland and riparian habitats, and other urban development activities contributing to the loss and degradation of steelhead habitats (National Marine Fisheries Service, 2016a, 2016c). NMFS (National Marine Fisheries Service). 2019. ESA Recovery Plan for the Puget Sound Steelhead Distinct Population Segment (Oncorhynchus mykiss). National Marine Fisheries Service. Seattle, WA, states: Unlike salmon species, steelhead are iteroparous, capable of repeat spawning in successive years, and they have a resident life -history form (Rainbow trout) that is capable of producing anadromous offspring and interbreeding with anadromous life forms. Adult steelhead also have a leaping ability that exceeds salmon, which allows them to migrate far into the headwater reaches of watersheds. Adult Puget Sound steelhead commonly return from the ocean after two to three years to spawning and rearing habitats in independent tributaries that flow into Puget Sound, Hood Canal, and the Strait of Juan de Fuca. The recovery team identified 10 primary pressures associated with the listing decision for Puget Sound steelhead and subsequent affirmations of the listing. These "pressures" are human activities and natural events that cause or contribute to the species 'decline in viability. The 10 primary pressures are: ....juvenile mortality in estuary and marine waters of Puget Sound; and climate change. High mortality of juvenile Puget Sound steelhead during their migration through the marine environment of Puget Sound remains a primary factor limiting the species 'survival and recovery. Puget Sound steelhead early marine mortality is generally defined as mortality that occurs as steelhead smolts (juveniles) enter the marine environment and die during a short outmigration window though the Sound before entering the Pacific Ocean. Steelhead spend a few days to a few weeks migrating through Puget Sound, and the mortality rates during this short period of their life cycle are critically high. Puget Sound steelhead marine survival rates are lower than for populations from other nearby regions, including for coastal Washington and Columbia River populations. The high mortality rates currently observed in steelhead smolts migrating through Puget Sound towards the ocean represent a major bottleneck to the productivity and abundance of steelhead on a regional basis. These high mortality rates are unsustainable over the long term, since they are seriously impairing the VSP components of steelhead (especially productivity), and thus the recovery of the Puget Sound steelhead DPS. Puget Sound steelhead have suffered from widespread loss and degradation of freshwater habitat and degradation of nearshore marine habitat (NMFS 2016). The reduced quantity and quality of freshwater habitat that limits the viability of C page55 LOG 1TENI `` age af��7 steelhead in Puget Sound streams is the primary factor that led to the listing of 1 Puget Sound steelhead. Unless habitat is more effectively protected and restored, Puget Sound steelhead are very unlikely to recover. NMFS will need to determine that steelhead habitat condition is, and will likely continue to be, adequate to support a viable DPS before it can remove Puget Sound steelhead from the list of threatened species. Healthy freshwater and nearshore marine habitat conditions will be particularly important given the recent evidence of very low marine survival in the Salish Sea, which has led to recent periods of unprecedented low overall survival and productivity. [Page 137] It is clear that the nearshore marine habitat conditions are very important for Puget Sound steelhead. A very high number of outmigrating steelhead are being lost as they try to cross under or around the Hood Canal Floating Bridge. That makes it even more important that even more young steelhead are not lost due to lack of cover due to loss of eelgrass and lack of prey on their migration through Squamish Harbor and out Hood Canal. See our sections on eelgrass and forage fish in the Marine Section of our public comments. CHINOOK SALMON, PUGET SOUND EVOLUTIONARY SIGNIFICANT UNIT State Candidate, Federal Threatened Species Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: Puget Sound Chinook Salmon Evolutionary Significant Unit (ESU) was listed as threatened on June 28, 2005. This ESU includes all wild (naturally spawned) populations of Chinook salmon from rivers and streams flowing into Puget Sound, including the Strait of Juan de Fuca from the Elwha River, eastward, including rivers and streams flowing into Hood Canal.... The general life history of anadromous Chinook salmon includes both freshwater and ocean phases of development. Incubation, hatching, and emergence occur in fresh water, followed by seaward migration to the ocean, which is preceded by the onset of smoltif cation. After several years at sea, maturation is initiated and adults return to freshwater habitats to spawn in their natal streams. Stream -type Chinook salmon spend extended periods in fresh water before smoltification, in contrast to the ocean -type that immigrates to the ocean as sub -yearling smolts. Puget Sound Salmon Recovery Plan, adopted by the National Marine Fisheries Service (NMFS) January 19, 2007, Submitted by the Shared Strategy Development Committee, Shared Strategy for Puget Sound, Seattle, WA, states: C page56 jIW LOG ITEM # ; Of..1L. The majority of Puget ma'J Sound Chinook leave the freshwater environment during Y g g their first year, making extensive use of the protected estuary and nearshore habitats (emphasis added). Nearshore ecosystems provide areas for the young Chinook to forage and hide from predators. Juvenile salmon experience the highest growth rates of their lives while in the highly productive estuaries and nearshore waters. These estuarine habitats are ideal for juvenile salmon to undergo the physiological transition to saltwater, and to readjust to freshwater when they return to spawn as adults. Nearshore areas serve as the migratory pathway to ocean feeding areas. The vegetation, shade and insect production along river mouth deltas and protected shorelines help to provide food, cover and the regulation of temperatures in shallow channels. Forage fish spawn in large aggregations along protected shorelines, thus generating a base of prey for the migrating salmon fry. Salmon often utilize "pocket estuaries" -small estuaries located at the mouths of streams and drainages, where freshwater input helps them to adjust to the change in salinity, insect production is high, and the shallow waters protect them from larger fish that may prey on them. As the juvenile salmon grow and adjust, they move out to more exposed shorelines such as eelgrass, kelp beds and rocky shorelines where they continue their migratory path to the ocean environment. Dissolved oxygen levels are at historic low levels in the marine waters of Hood Canal [Page 310] (emphasis added) HOOD CANAL SUMMER -RUN CHUM SALMON State Candidate Species, Federal Threatened Species Naval Special Operations Training in Western Washington State, Final Environmental Assessment, Department of the Navy, October 2019 states: Hood Canal Summer Run Chum Salmon Evolutionary Significant Unit - The Hood Canal summer -run ESU chum salmon was listed as threatened in June 2005 (70 FR 37160). The listing includes all naturally spawned populations of summer -run chum salmon in Hood Canal and its tributaries, as well as populations in Olympic Peninsula rivers between Hood Canal and Dungeness Bay, Washington.... The Hood Canal summer -run chum C page57 LOG ITEM JlW _ 41,4, population is composed of nine extant runs that include the Big Quilcene River, Little Quilcene River, Dosewallips River, Duckabush River, Hamma Hamma River, Lilliwaup Creek, Union River, Big Beef Creek, and Tahuya River populations. Chum salmon are second only to Chinook in dependence upon estuaries. (West Coast Salmon Biological Review Team et al., 2003). Chum salmon usually spawn in the lowest reaches of streams, and juveniles move out into the estuaries almost immediately after emerging from their spawning gravel. Ocean migration of juveniles is correlated with increasing water temperature and plankton blooms. This means survival and growth of juveniles depends less on river habitat conditions and more on favorable estuarine and ocean conditions. ... juveniles are found at depths less than 40 meters.... After spending between one and five years in the ocean, chum salmon mature and return to their home freshwater stream to spawn. Critical habitat was designated for the Hood Canal summer -run chum salmon ESU in February 2000 and re -designated September 2005 (70 FR 52630). Designated critical habitat includes nearshore marine areas (including areas adjacent to islands) of Hood Canal .... (emphasis added) The Puget Sound Salmon Recovery Plan, adopted by the National Marine Fisheries Service (NMFS) January 19, 2007, Submitted by the Shared Strategy Development Committee, Shared Strategy for Puget Sound, Seattle, WA, states: Chum salmon spend more of their life history in marine waters than any other Pacific salmonid species. Juvenile chum migrate to saltwater almost immediately after emerging from gravel, thus their continued survival depends substantially on estuarine conditions (unlike other salmonid species that depend extensively on fresh- water habitat). Also unlike other salmon species, chum salmon form schools, a characteristic that is presumed to help them reduce predation. [Page 51] Estuarine residency is the most critical phase in the life history of chum. They remain close to the surface, rearing in shallow eelgrass beds, tidal creeks, sloughs or other productive estuarine areas for several weeks between January and July. (emphasis added) [Page 52] C page58 jlw i_C� % .j �;" E- ,e, . ,I�s BULL TROUT page Z 4 1 1j7 State Candidate, Federal Threatened Bull Trout, a listed threatened species, are found in the estuarine and marine waters of Puget Sound. Some bull trout are anadromous. According to the research publication Behavior of Anadromous Bull Trout in the Puget Sound and Pacific Coast of Washington by Fred Goetz, et al., Estuarine Research Federation Conference September 2003: ...bull trout are anadromous, inhabiting estuarine and nearshore marine waters for up to 5 months each year, possibly returning to these waters every year for up to 10 years. Bull trout are recognized as an apex predator in river and estuarine waters and can show a wide array of behaviors in their search for available prey, which can include juvenile salmon and forage fish such as surf smelt, sand lance and herring ...Months of estuary and nearshore use are predominantly March to July. ...Fish were found from 1 in to 20 in depths, over all substrates, many near by to eelgrass areas . Protected areas appear to have more fish. (emphasis added) Puget Sound Salmon Recovery Plan, adopted by the National Marine Fisheries Service (NMFS) January 19, 2007, Submitted by the Shared Strategy Development Committee, Shared Strategy for Puget Sound, Seattle, WA, states: Unlike chum and Chinook salmon, bull trout survive to spawn year after year. Since many populations of bull trout migrate from their natal tributary streams to larger water bodies such as rivers, lakes and saltwater, bull trout require two-way passage for repeat spawning as well (Page 56). While all bull trout are opportunistic eaters, feeding on insects, macrozooplankton, and crayfish, migratory bull trout are primarily "piscivorous"- -they prey mostly on juvenile trout, salmon and other species of fish. Like other salmonids, the availability of food sources for newly hatched bull trout is particularly important. An adequate food base is critical to sustaining migratory bull trout in freshwater systems as well as saltwater forage areas (Page 57). Although both resident and migratory forms of bull trout are present in the Coastal/ Puget Sound bull trout population segment, it is the only known segment of bull trout in the United States that includes the anadromous life history form (spawns in freshwater, migrates to saltwater and returns to freshwater to spawn). Technically, Coastal/Puget Sound bull trout are "amphidromus"--unlike strict anadromy, amphidromus individuals often return seasonally to freshwater as sub - adults, sometimes for several years, before returning to their natal tributary to C page59 f (DO ITEM j1W �- P,- CA f spawn. These sub -adult bull trout move into marine waters and return to freshwater to take advantage of seasonal forage opportunities to feed on salmonid eggs, smolts or juveniles. Bull trout in the Coastal/Puget Sound population segment also move through the marine areas to gain access to independent streams to forage or take refuge from high flows. Bull trout target a variety of estuarine and near- shore marine forage fish such as sandlance, surf smelt and herring, and depend on the persistence of productive forage fish spawning beaches and intertidal habitats such as eelgrass beds and large woody debris These populations can migrate extensively while in the marine waters of Puget Sound, the Strait of Juan de Fuca and the Pacific Ocean; but there is currently no evidence that they make long off- shore migrations similar to other salmon. (emphasis added) [Page57] The need for eelgrass and forage fish will be impacted if these species are impacted by commercial geoduck farming. See the sections on eelgrass and forage fish in the Marine Section of our comments. See also the photograph below, labeled BullTroutForageArea j.8/19/21 that clearly shows all of the shoreline areas of Squamish Harbor is a bull trout foraging area. C page60 j1W Q repository.librarynoaa gov p _ E1S11.I. ACK F _ A- aNaslar Snr:li .. , , - SHh 61i„+ r M 1811�..F-.� :6F•R Sx Acit au+r dr Furrr. S71tcn a;eis+l Euv>!n1 1 `.i s;l'ailnrrtlsli . �XYKUfn l:; it .1 -L ;}lesr u MORSE Bull Trout kaWlm uvaw,w••saa Figure 2.13 Indicates where bull trout core areas overlap with the Puget Sound Chinoolt ESU. Hoh, Quinault, and Queets core areas ar located along the Pacific Coast of the Olympic Peninsula and are not included on this map. BullTroufforageArea j.8/19/21 UG ITEM a" C page6l �,w I �-Y G FORAGE FISHr"� Squamish Harbor is a designated herring and sand lance spawning site. Forage fish are of utmost importance to the marine environment in Squamish Harbor and Hood Canal. All Hood Canal is a shoreline of statewide significance up to the ordinary high water mark and associated shorelands, including the Smersh proposed site.' The Smersh application in Log Item 39, page 287/ 561 acknowledges: Nearly the entire action area is considered potential forage fish habitat; sand lance spawning has been documented near the western side of the planting area. Pacific herring breeding area has been identified along the seaward extent of the project area. Forage Fish Spawning Map - Washington State This map displays sand lance, smelt, herring spawning areas, herring pre -spawner holding areas, and the forage fish spawning survey beaches In Washington State. DigitalGlobe, GeoEye, Microsoft, USDA FSA, CNES/Airbus DS I These data were collected by WDFW staff with contributlons from the North Olympic Salmon Coalition and the Friends of the San Juans. I County of Kltsap, Esrl, HERE Pale blue lines = herring. Orange = sand lance. Pale green = smelt. Actual spawning areas may be broader. ' New Chapter 5: Determining Shoreline Jurisdiction {wa.gov , p 34 C page62 jlw Dead sand lance on BDN's geoduck site in Squamish Harbor,''/: mile west of Smersh site. Photo by Sue Corbett, June 24, 2017 LOG # PcA� Forage fish play a vital role in the oceanic ecosystem. Pacific herring, surf smelt and sand lance provide sustenance to larger fish, including many that are threatened and endangered as well as those with significant commercial value, seabirds, and marine mammals. According to an article titled These Little Fish Play aBig Role in Puget Sound's Health —and Washington's Economy by Andy Hobbs in the Bellingham Herald, dated August 31, 2016: Forage fish play a critical role in the food chain. Their health directly affects the health of salmon —and ultimately the overall economic health of Washington. The U. S. Department of Commerce reported that the annual Puget Sound salmon harvest alone contributes nearly $1 billion to the state's economy. C page63 �C. C. ITFhel j1W Shore Friendly Kitsap News and Information, The Puget Sound Food Web states: Until recently, Pacific Herring, Surf Smelt, and Sand Lance have been largely understudied and much of their habits are still unknown. Without prior data, it makes it difficult to determine how and why their populations are suffering. Right now, it is crucial to make sure their known spawning grounds are protected so that their populations have a chance to remain sustainable for the rest of the marine food web. WDFWWDFW Forage Fish EcoloU in Washington State, EcoloU in Washington State, undated document, https://wdfw.wa.gov/fishing/management/marine-beach-spawning, states: Surf smelt and Pacific sand lance are important food for marine mammals, birds, and fishes, including Pacific salmon. The Washington Department of Fish and Wildlife protects these fish species and their spawning habitat by limiting human activities under the terms of a permit (called the Hydraulic Project Approval (HPA) on beaches where spawning has been documented. Extensive surveys have sampled many of the beaches in Puget Sound. However, despite good information on the distribution of spawning beaches our understanding of the ecology and protection needs for these species is very limited. Washington State Law (RCW 77.55) requires people planning hydraulic projects in or near state waters to get Hydraulic Project Approval (HPA) from the Washington Department of Fish and Wildlife (WDFW). This includes most marine and fresh waters. An HPA ensures that construction is done in a manner that protects fish and their aquatic habitats. Geoduck harvesting is exempt from having to acquire an HPA even though during harvest with a hydraulic hose, acres of marine tidelands are liquified down to a depth of about three feet. HERRING From Puget Sound Institute, University of Washington, April 11, 2019; For most herring, the spawning period begins in January and lasts through April. Single events can bring so many fish into the intertidal and shallow, subtidal nearshore that the sea seems to bubble and the milt of the males turns large patches of water a vibrant, irradiated blue. The milt will fertilize the millions of eggs females have deposited on eelgrass or algae, or tree branches, or other marine debris. (emphasis added) C page64 Left alone, the eggs hatch ten to fourteen days later, filling the water with tiny herring larvae, each less than half -an -inch long. These larval fish drift from the spawning areas to mix in Puget Sound, developing for a few months until they look more like adults Therefore, eelgrass, algae, or marine debris should not be removed from marine tidelands. Daniel E. Penttila, Salish Sea Biologist, in A Review of EtTects on Forage Fishes, Zooplankton and Marine Vegetation from Three Geoduck/Clam Farm Proposals in Henderson Inlet and One Proposal in Eld Inlet. Thurston County, WA, presented at the Shoreline Hearing Board 2013 (testimony under oath) shared: EFFECTS OF THE PROPOSAL ON MARINE VEGETATION Aside from their regulatory -protected function when serving as herring spawning grounds, marine algae beds should be considered as habitats deserving of no -net - loss protections and thus not disturbed by human activities within the marine photic zone, including aquaculture farm areas. Routine clearing of marine algae beds from farm plots should be considered a major disturbance. SURF SMELT Specific concerns: Siltation of adjacent spawning beaches by the cumulative effects of production - scale shellfish harvest activities. Spawning habitat may overlap with clam -farming zone activities, both harvest and anti -predator netting..... Ingestion and mortality of planktonic yolk sac larvae arising from adjacent spawning beaches throughout the spawning season. Over -arching concern for the lack of forage fish -focused research pertaining to shellfish-aquaculture effects amidst continuous farm expansion. C page65 j1W LOG FEV PFg� 7Qf 117 PACIFIC SAND LANCE Sand Lance habits: Sand Lance spawning occurs November through February in Puget Sound. Spawning activity occurs at irregular intervals.... Spawning habitat context similar to that of the surf smelt; fine-grained beaches in the upper intertidal zone. Spawn incubation period is about one month. Sand lance burrow diurnally in bottom sediment for refuge. Sand lance feed upon a variety of planktonic animals. Specific Effects: Spawning habitat vulnerabilities are similar to those for surf smelt spawning habitat. Spawning habitat similarly denoted as "marine habitat of special concern," with similar regulatory protective language in the Hydraulic Code Rules, GMA, SMA and EFH rules. (P-118) Similar effects from larval ingestion mortalities by artificially -dense cultured shellfish.... NOTE: Should proposed geoduck/clam farm operations be dependent on a determination of presence/absence of forage fish spawn on -site, beach sediment sampling protocols specifically designed to detect surf smelt and sand lance eggs dispersed in beach substrates would be available for application on -site by suitably trained ("certified") samplers. It cannot be assumed that either incubation surf smelt or sand lance eggs will simply be visible upon beach surfaces to determine recent spawning at a site. C page66 j1W & 73- Consumption Of Zooplankton By Suspension -Feeding Bivalves Consumption of zooplankton has only recently been recognized as a common feeding strategy of bivalves of all types, formerly considered to feed only on phytoplankton. The aquaculture industry for years has stated that the high densities of shellfish that have been added to the shorelines are "cleaning the water". The unnaturally high densities of shellfish that you would find at a geoduck farm are not "cleaning the water", but are actually clearing the water column of fish eggs, larvae and crab Zoes. This is particularly harmful when the shellfish are growing in high ecological value forage fish spawning habitat such as Squamish Harbor. Daniel E. Penttila, Salish Sea Biologist, in A Review of Effects on Forage Fishes, Zooplankton and Marine Vegetation from Three Geoduck/Clam Farm Proposals in Henderson Inlet and One Proposal in Eld Inlet Thurston County, WA, presented at the Shoreline Hearing Board 2013 (testimony under oath) shared: Thumbnail sketches of a number of recent journal references on this subject (emphasis added): Lehane, Clare, Davenport, John (2002). Ingestion of mesozooplankton by three species of bivalve: Mytilus edulis, Cerastoderma edule and Aequepecten opercularis. J. Mar. Biol. Ass. UK 82, 615-619. Cites previous report of 6 mm amphipod being consumed by mussel. All bivalve species were found to have ingested zooplankton. [P-86] Wong, Wai Hing, Levinton, Jeffrey S. (2006).The trophic linkage between zooplankton and benthic suspension feeders: direct evidence from analyses of bivalve fecal pellets. Marine Biology (New York waters) 148: 799-805. Mussel species fed on zooplankton, found in both stomachs and "pseudo feces" expelled uneaten, but also dead. Larger animals ate larger plankton. [P-87] Troost, Karen, Kamermans, Pauline, Wolff, Wim J. (2008). Larviphagy in native bivalves and an introduced oyster. Journal of Sea Research (Dutch waters) 60 157- 163. Using blue mussel, cockles and Pacific oysters, all consumed zooplankton in bivalve larvae. [P-88] C page67 jlw Lonsdale, Darcy J., Cerrato, Robert M., Holland, Robert, Mass, Allision, Holt, Lee, Schaffner, Rebbeca A., Pan, Jeronimo, Caron, David. (2009). Influence of suspension -feeding bivalves on the pelagic food webs of shallow, coastal embayments. Aquatic Biology (New York waters). Vol. 6: 263-279. Using soft shell clams, quahogs and ribbed mussels, all were found to ingest zooplanktonic copepod eggs, and bivalves were considered competitors with zooplankton for phytoplanktonic food supplies. [P-89] Troost, Karin, Stamhuis, Elize J. van Duren, Luca A., Wolff, Wim J. (2008). Feeding current characteristics of three morphologically different bivalve suspension feeders, Crassostrea gigas [Pacific oyster], Mytilus edulis [blue mussel], and Cerastoderma edule [cockle], in relation to food competition. Marine Biology (Dutch waters). Describes lab set-ups for feeding rates data suitable for geoduck studies. Cites numerous zooplankton-consumption papers. Filtration rates were considered to increase with shellfish body size. 156:355-372. (P-91). Peharda, Melita, Ezgeta-Balic, Davenport, John, Bojanic, Natalia, Vidjak, Olja, Nincevic-Gladan, Zivana. (2012) Differential ingestion of zooplankton by four species of bivalves (Mollusca) in the Mail Ston Bay, Croatia. Marine Biology. (Adriatic waters). Zooplankton ingestion was found in oysters, mussels and ark - clams. Ingestion rates go up with specimen size. Ingestion can affect zooplankton community structure. Bivalves compete with zooplankton for phytoplankton food. 011-1866-5. (P-90) Jones and Stokes NWP48 Consultation Memorandum dated January 10, 2008, to Corrie Veenstra, USACE (P-25) Consumption Of Zooplankton By Suspension -Feeding Bivalves -From the published scientific literature, it is clear that all bivalve species tested were found to consume zooplankton of a wide variety of forms, during feeding/respiration activities.(P-86, 87, 88, 89, 90, 91) -While published data on the diet of Salish Sea geoducks seems to be lacking, it can only be assumed, at present, that they will readily consume zooplankton as well. Given the concerns raised, in the absence of data, to assume that they do not would be unwise. -Published data also suggest that zooplankton filtration rates and prey sizes can increase with increasing body size of the filtering animals. (P-87, 90, 91) Thus it C page68 LOG 11'6�Vi j1W -4)4-- P`"9P- 1,5,-Of .11 % should be assumed that geoducks, reported to be among the largest clams in the region, may be capable of ingesting significant amounts and relatively large sizes of organisms from the nearshore zooplankton community. •Geoducks would seem to be amenable to lab observations of filtration rates and the behavior of potential zooplankton prey items in their presence using methodologies outlined in the literature, to answer pressing questions of the effects of enhanced densities of cultured geoducks to the nearshore zooplankton/ichthyoplankton communities in their vicinity. (P-91) The USFWS NWP48 Consultation document includes the following statement: -"Since it is plausible that geoducks will compete for prey resources (particularly in sheltered bays and coves and when they are planted in high densities) and dominate as a consumer of the local food web, and then you must assume that juvenile salmonids and forage fish will have less to eat which will lower their growth and survival [emphasis added] ... I think it would be prudent to alleviate this uncertainty prior to the Corps allowing more widespread geoduck culture given the tenuous condition of salmonids and bull trout populations in Puget Sound." (P-25) Dan Penttila has pointed out in reports and testimony at a Pierce County Geoduck EIS Hearing, held March 2011 that: The adverse impacts of shellfish aquaculture on forage fish need to be examined in an EIS and that specific studies be conducted to learn more about shellfish ingesting fish eggs and larvae prior to further expansion. C page69 j1W EELGRASS Introduction The eelgrass surveys conducted for the Smersh proposed commercial geoduck farm and the active BDN commercial geoduck farm are located in the same shoreline of statewide significance, approximately 1/2 mile apart in Squamish Harbor. The eelgrass surveys completed on both properties demonstrate that native eelgrass is receding and is negatively impacted by geoduck farming. Eelgrass surveys taken in 2016 and again in 2018 at the Smersh proposed geoduck farm site show that native eelgrass is receding during the time period between 2016 and 2018. This concerning reduction in native eelgrass was occurring even prior to the beginning of any farming activity at the Smersh commercial geoduck farm. The data and photographs of the active BDN commercial geoduck farm very clearly demonstrate the negative impact of an active commercial geoduck farm on native eelgrass. Before discussing the biology and importance of eelgrass in Squamish Harbor and Hood Canal it is important to have an understanding of the specific eelgrass situation at the site of the proposed Smersh commercial geoduck farm. It is also important to be aware of, and learn from, the eelgrass situation 1/2 mile west of Smersh at the BDN active commercial geoduck farm. Eelgrass Situation at Smersh Proposed Geoduck Farm and at BDN Active Geoduck Farm Confluence Environmental Company, a consultant working for Smersh and BDN, sent a letter to Anna Bausher at the Jefferson County Department of Community Development on July 9, 2018 (See the photo of Log Item 39, Page 97 of 561, shown below) stating the following: No native eelgrass was found above -1 foot MLLW. A dense bed of native eelgrass with a patchy margin was observed below approximately A 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. (emphasis added) C page70 L(7) TE: 77-- The Smersh native eelgrass has been receding between the 2016 and 2018 eelgrass surveys that were completed in the very same location during each of the two sampling years. In other words, the native eelgrass beds are declining, specifically at the Smersh site, even before active farming, as reported by Smersh. The consultant explains that "the patchy margin has receded waterward in many areas". One thing they failed to mention is that the southwest and the southeast corner sections of the proposed farm also show the dense beds of native eelgrass receding. The photograph provided below is labeled "Figure 1" by Smersh (our photo label is "Eelgrass log98of561"). It was provided in the Smersh application to JeffersonCounty. It shows the comparison of the 2016 and 2018 native eelgrass bed edge (log item 39, page 98 of 561). BDN active commercial geoduck farm negative impact on eelgrass The eelgrass is apparently also receding, perhaps even more markedly, at the BDN 3.58- acre active commercial geoduck farm located approximately 1/2 mile west of the Smersh site. The map/diagram that was provided to the WA Department of Ecology by BDN shows the three sections of his active 3.58-acre commercial geoduck farm. This will be referred to as the BDN farm. This farm was originally comprised of three separate geoduck farms or permitted areas that were later combined by the Army Corps of Engineers into one geoduck farm permit. Even after being combined, each section of the farm had different permit requirements from the Army Corps. The photograph of this map/diagram is provided below, labeled `BDNdiagram.j". As labeled on the BDN map/diagram, the western portion of the BDN farm is labeled "Former Mocean Shellfish Site," the middle and smaller of the three is labeled `BDN Site" and the eastern, largest section of the BDN farm is labeled "Former Washington Shellfish Site." The "Former Washington Shellfish Site" was originally operated by Doug McCrae prior to BDN obtaining it. The central unit in the BDN map/diagram, the `BDN Site" shows that patchy and or thick eelgrass beds are growing up to about the +1 ft tide level. The `BDN Site" area below a +1 ft tide has not been disturbed by recent shellfish farming. The Army Corps did not allow BDN to plant below about the + 1 ft tide level at this site. On either side of the center `BDN Site" the map/diagram does not show eelgrass above the buffers. It does appear to show both patchy and or thick eelgrass growing in the buffers for the east and west sections of the farm. The map/diagram also shows both patchy or thick eelgrass up all sides of the west "Former Mocean Shellfish Site" and both patchy and or thick eelgrass up all sides of the eastern "Former Washington Shellfish Site." This patchy and C page7l j1W or thick eelgrass appears to grow well up to about a +1 ft tide level everywhere in the immediate area EXCEPT in the east and west parts of the BDN farm. There is more documentation in our Section D Bad Track Record, item # 3 BDN's disregard for native eelgrass. Pam Sanguinetti from the Army Corps of Engineers visited the site on July 1, 2015. She observed extensive native eelgrass in BDN's central proposed `BDN Site", resulting in cancellation of his applications (two of which, both in Squamish Harbor, have not yet been revived). The following communications from the Corps to BDN are drawn from the Corps 'files on BDN. July 31, 2015 email from the Corps: This email is to follow-up on our site visit on July 1, 2015. The purpose of the site visit was to confirm the eelgrass delineations provided by Marine Surveys and Assessments (MSA) NWS-2013-1147 (Tjemsland lease), NWS- 2013-1222 (BDN), NWS-2013-1223 (Garten lease), NWS-2013-1268 (Smersh), and also for NWS-2010 (BDN - formerly WA Shellfish). We observed extensive native eelgrass within the areas proposed for cultivation (emphasis added). I recommend you withdraw your applications at this time until you can provide the requested revisions. See the analysis of this situation in our Section D Bad Track Record, Item 3. It is apparent from the BDN eelgrass mapping, diagrams and track record that the eelgrass is doing somewhat better adjacent to and below all of the three farmed sections of the BDN farm than in the farm itself. Even without a determination of cause it is quite apparent even from BDN's own mapping that their active commercial BDN geoduck farming operation is having a substantial negative impact on native eelgrass. (emphasis added) See the photographs "EelgrassHarvest.s.6/26/21" showing harvesting in or near eelgrass and`BelgrassHarvestDamage.s.6/26/21" showing the damage to the eelgrass around the hole where the geoduck was extracted as well as the change in the substrate. In any event, permits should not be approved for Smersh or any other commercial shellfish farm that proposes activities that could damage native eelgrass beds. No permits should be approved until a determination is made as to the cause of the decline of native eelgrass in Squamish Harbor, a shoreline of statewide significance with numerous threatened and endangered species and forage fish spawning and rearing. C page72 G testco.jeffersonma.us j1W CONFLUENCE J��]Mny Q72Q71 EN V I RONMEN IAI. CUM VANY JEFFERSON OOUMY OLD To: Anna Baushep, Jefferson County Department of Communliy Development 1 cc: Rick Mpaz, Washington Slate Department of Ecology; Brad Nelson, BDN Inc. 1_ ) G, From: Grant Novak, Confluence Environmental Company � i Date: July 9, 2018 Nap Re: BDN Inc. - Proposed Smepsh Geoduck Farm: 2018 Zosfera marina bed edge re-verlllcatlon 1 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 (Zosfera 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 Sanaetsh parcel during low tide on June 281h between 11.00 dui and 1:00 Nut. Dutiug the lime of ll le 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 (Zosterajaponica) 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. Log Item 39 146 N Canal St, Suile 111 • Seallle, WA 99103 • www.conlenv.com Page 97 of 561 C page73 j1W Photo: Eelgrass, Log Iterm 39 p 98/561 j i Smareh Parcel ^P— 2018 Landward Zostera marina Exlenl qA ? Proposed Oeoduck Planting Area MFUUi 2015 Landward Zoelara marina Eyler Elevation Contour (MLLW) .; : 2016 Patchy Zostera marine Zone 201a aunr,r. 2u1ala . -na duns t`1 S. Zou,a rrrar,na Surer 120161 Figure 1. Comparison of 2016 and 2016 Native Eelgrass Bed Edge. LOG ITSM, PC of �7 N A 0 15 150 275 am Feel m Molals 0 10 20 30 40 Log Item 39 Page 98 of 561 C page74 j1W BDNdiagram j L, 71 P-ge Approximate Parcel Comers (Decimal Degrees) NW: 47 86832,-122,67512 NE: 47.86830,-122.67319 SW: 47, 86680,-122,67502 SE: 47.86673.-122.67337 Approximate Planting Area Corners (Decimal Degrees) NW:47.86795:-1,22:67510 NE: 47.86793-12267325 SW: 47-86683,-122.67502 SE: 47 86676,-122 67337 Approximate Planting & Pm)ed Area: 3.57 acres Proposed Planting Area: Former Mocean: .65 acre BDN: .28 acre Former WA Shellfish: 2.64 acre Adjacent Parcel Elevation Contour IV) Parcel Boundary Existing Planting Area - Proposed Planting Area Eelgrass Buffer Patchy Eelgrass Bed Dense Eelgrass Bed 0 20 40 80 120 160 200 1 Feel ;+ CORPS REFERE110E: PARCEL IDs/Owners: PROPOSED PROJECT. NWS-2012-1099, MYS-2012 121(1 821334079: BON, LLC, 3011 S Chandler St, Tacoma, WA 98409 New and existing geoduck 1 NWS-2013-1223 821334011: BDN, LLC, 3011 S Chandler St, Tacoma, WA 98409 on private tidelands. APPLICANT. BDN LLG 821334073: BDN LLC 3011 S Chandler St Ta me. WA 98409 SITE ADDRESS: ADJACENT PROPERTY OWNERS (East to West): Tidal datum: R MLLW 601-641 Shine Road 821334007: James Weitiramp, 11965 SW 119TH Ave-, Tigard, OR 97223 Scale t 1000 Port Ludlow, WA 98365 821334012: Walter Simkus, PO Box 26, Goldendale, WA 98620 Coordinate System: In: Squamish Harbor 821334072: Steve Dittmar, 30 Walney Lane, Port Ludlow, WA 98365 WA Stalo Plane North !1 Nc r Pnrt 1 , 01— 821334078: Arnold Tjemsland, 354 W Maple St, Sequim, WA 98382 C page75 j1W Page There are large areas of native eelgrass in Squamish Harbor in areas that are not being impacted by human activity. There are thick continuous native eelgrass beds below the proposed Smersh geoduck planting site. Eelgrass supports commercially important fish species and wading birds. The Puget Sound Seagrass Monitoring Report, Monitoring Year 2016 - 2017, dated 03/11/2019, Bart Christiaen, Lisa Ferrier, Pete Dowty, Jeff Gaeckle and Helen Berry, DNR Nearshore Habitat Program Aquatic Resources Division states: Page 12; Eelgrass provides similar ecosystem services as other seagrass species. In particular, it offers spawning grounds for Pacific herring (Clupea harengus ap llasi), out- migrating corridors for juvenile salmon (Oncorh, n� sip.) (Phillips 1984, Simenstad 1994), and important feeding and foraging habitats for waterbirds such as the black brant (Branta bernicla) (Wilson and Atkinson 1995) and great blue heron (Ardea herodias) (Butler 1995).... As with other seagrass species, eelgrass responds quickly to anthropogenic stressors. Other Washington State agencies also recognize the value of seagrass beds as an aquatic resource. The Washington State Department of Fish and Wildlife designated eelgrass beds as habitats of special concern (WAC 220-110-250) under its statutory authority over construction projects in state waters (RCW 77.55.021). Similarly, the Washington State Department of Ecology designated eelgrass areas as critical habitat (WAC 173-26-221) under its statutory authority to implement the state's Shoreline Management Act (RCW 90.58). The 2017 Army Corps of Engineers Draft CIA found: The action (shellfish aquaculture permitting) does threaten a violation of State requirements under the Shoreline Management Act to achieve no net loss of eelgrass and Federal requirements to protect eelgrass imposed under the ESA for aquaculture activities. The proposed action is not consistent with either of these requirements. (Page 101) Eelgrass supports commercially important fish species. Eelgrass is very important habitat for forage fish. Without eelgrass the forage fish would not thrive and be available as food for salmon and other critical species. C page76 j1W LC,G IT., " � _ page �tfZL �0 /117 According to an article titled These Little Fish Play a Big Role in PugetSound's Health —and Washington's Economy by Andy Hobbs in the Bellingham Herald, dated August 31, 2016: Forage fish play a critical role in the food chain. Their health directly affects the health of salmon —and ultimately the overall economic health of Washington. The U. S. Department of Commerce reported that the annual Puget Sound salmon harvest alone contributes nearly $1 billion to the state's economy. SHORELINES HEARINGS BOARD DECISION, SHB No. 13-106c The Shorelines Hearings Board Decision, SHB No. 13-106c, Findings of Fact, Conclusions of Law, and Order (SHB), dated January 22, 2014, involved a challenge to Pierce County's approval of a Shoreline Substantial Development Permit issued to Respondents Darrell de Tienne and Chelsea Farms, LLC for a 5-acre commercial geoduck farm on private tidelands in Henderson Bay, a portion of Carr Inlet located in Pierce County. This Chelsea Farms proposed 5-acre commercial geoduck farm is about 30 miles south of the Smersh proposed 5.15-acre commercial geoduck farm on private tidelands in Squamish Harbor. The Shorelines Hearings Board Decision, SHB No. 13-106c, Findings of Fact, Conclusions of Law, and Order (SHB), dated January 22, 2014, states: (Page 9). Eelgrass serves essential functions in the developmental life history of fish and shellfish. WAC 220-110-250. It provides refuge sites and shelter from predators for fish and invertebrates, and for other small organisms. Eelgrass is a source of food for many marine animals and birds, and is habitat for red algae and other marine plants. It also provides physical stabilization of the nearshore area. Seagrasses baffle wave and tidal energy, protecting subtidal sediments and shorelines from erosion and can alter local and regional hydrography. Seagrasses such as eelgrass are the only rooted organisms in the near -shore region and they serve as the foundation for thousands of vertebrate and invertebrate species that use it for shelter, foraging, spawning habitat, and nurseries.... C page77 jlw LOG ITEM page4:0 I l 7 The Board has repeatedly acknowledged the vital role of eelgrass to the health of Puget Sound and noted its "significant decline" over time, finding: Damage to eelgrass can affect whole populations of fish, including threatened salmon, waterfowl, shellfish, and other animals. Eelgrass also serves to physically stabilize the state's shorelines by concentrating in nearshore areas where these animals live, feed and spawn. There has been a marked decline in eelgrass and other sea grasses world-wide, which can be classified as a global crisis. This decline has accelerated in developed countries such as the United States. Due to the site -specific nature of the functions and values of eelgrass, protection of eelgrass beds is preferable to replacement of beds because the surrounding environment loses the functions and values that the destroyed eelgrass beds provide, and replacement efforts are not always successful, and can take a long time. When seagrasses are damaged, restoration is expensive and uncertain. Many of the lost ecological services cannot be adequately restored, and the cumulative effects from loss of seagrasses such as eelgrass can degrade seagrasses biomes on both local and regional scales. Documented success of restoration by replanting is rare. (Page 10). The Board has thus recognized the need to protect eelgrass because doing so "safeguards species richness, biodiversity, ecosystem structure, and many ecological processes." Both eelgrass and macroalgae provide major ecological benefits as habitat for out -migrating juvenile salmon and for forage fish, including herring, to spawn (emphasis added). Herring are one of three major shore -spawning forage fish species in Puget Sound; they are a key species in the marine food web and therefore a good "indicator species" for gauging the relative health of the Sound. Herring spawn cling to vegetation, including eelgrass.... Eelgrass and macroalgae serve vital ecological roles in addition to providing spawning habitat. This includes carbon-fixing/sequestration, the production of organic matter and detritus (the basis of the food chain), and the provision of physical habitat for use by adult marine species and as a refuge and nursery area for juvenile life stages. Eelgrass is particularly susceptible to disturbances. This can include both direct disturbances like trampling, plus effects from indirect disturbances (e.g., sedimentation and related turbidity) that decrease light availability (emphasis added). Pentilla Testimony (Page 18) ....sediment will travel laterally along the shore and therefore over the eelgrass, where it will begin to settle out. Meanders Testimony. There has been C page78 j1W no analysis of the effects of this sediment deposition on the eelgrass in this area, only a recognition of the potential problem. The Shorelines Hearings Board Decision, SHB No. 13-106c to Deny a Permit, With an Emphasis on Eelgrass, for a Proposed de Tienne Chelsea Farms, LLC Geoduck Farm and a Comparison With the Smersh Proposed Geoduck Farm Permit Application The Shorelines Hearings Board Decision, SHB No. 13-106c, Findings of Fact, Conclusions of Law, and Order (SHB), dated January 22, 2014, involved a challenge to Pierce County's approval of a Shoreline Substantial Development Permit issued to Respondents Darrell de Tienne and Chelsea Farms, LLC for a 5-acre commercial geoduck farm on private tidelands in Henderson Bay, a portion of Carr Inlet located in Pierce County. This Chelsea Farms proposed 5-acre commercial geoduck farm is about 30 miles south of the Smersh proposed 5.15-acre commercial geoduck farm on private tidelands in Squamish Harbor. Chelsea Farms (Chelsea) was proposing to use a longer planting/harvesting cycle of 10 years compared to the Smersh planting and harvesting cycle of seven years. Chelsea was also at deeper tidal levels and was proposing to place PVC tubes at 15-18 inch intervals. Smersh proposed 12-inch intervals between PVC tubes. Chelsea was in an area designated as a shoreline of statewide significance for areas lying waterward of the extreme low tide. Just like Chelsea, Smersh is also a shoreline of statewide significance for areas lying waterward of the extreme low tide. However, Smersh is located in Hood Canal which is also designated a shoreline of statewide significance from the extreme low tide up to the ordinary high water mark and associated shorelands. There are high winds at both Chelsea and Smersh. Both contain eelgrass at the farm site. Both have recreational use, but Smersh shares a boundary with Hicks County Park and boat launch which sports a large amount of public use, including recreational shellfish harvesting at low tides (see our thorough analysis of the recreation at Hicks Park in the Recreation section of our public input). C page79 j1W Smersh has a fish stream (F stream) on the property. Chelsea did not. Smersh is located completely within a herring spawning area and very close to a sand lance spawning area. Chelsea was not. Smersh is used by the federally threatened Hood Canal summer -run chum salmon, including migrating adult and juvenile fish. The Smersh tidelands provide feeding and cover for these juvenile fish as well. Chelsea does not. Smersh is used by the endangered marbled murrelet for feeding and catching forage fish for their single nestling. Chelsea does not. Smersh has numerous other threatened, endangered and candidate species that are listed and discussed in the threatened and endangered species section of this public comment. The Shorelines Hearings Board Decision, SHB No. 13-106c states: (Page 8)... potential impacts from the proposed Farm fell into identifiable subject areas including impacts from marine debris and how farm operations may affect the benthic environment, forage fish, and other species ... this case presents some unique aspects that include the presence of eelgrass at the Farm Site, the proximity of known herring spawning locations to the Farm Site, the specialized recreational use of the area for windsurfing, and the Farm Site's location on a shoreline of statewide significance. These areas of distinction serve as the main focus of the Board's analysis and, ultimately, it decision to deny the Permit in this case. Both Chelsea and Smersh have had eelgrass surveys. The eelgrass at the Chelsea Site presented a degraded condition. The eelgrass beds at the Smersh site are receding, as documented by Smersh eelgrass surveys from 2016 and 2018, described above. The Shorelines Hearings Board continues on page 12: The eelgrass underlying the Farm Site was heavily damaged —including removal of eelgrass—during past commercial geoduck operations conducted onsite. In 2001, Mr. De Tienne entered into a lease with Doug McCrae of Washington Shellfish, Inc. to plant and harvest geoduck on the Farm Site. Mr. McCrae also leased three additional nearby parcels, and he began farming all four parcels without shoreline permits. Shoddy and illegal practices led to an enforcement action by the County against Washington Shellfish and Mr. De Tienne as the property owner. The County issued a cease and desist order that halted the operations in 2003.... (Page 12 and 13)....the Applicants rely on eelgrass surveys performed after the eelgrass beds had been damaged by the previous operations....Notably, the first survey just two years after farming at the Site, in 2004—....found eelgrass to be in a highly degraded condition:.... C page80 j1W Pc'�Qe of In addition to the condition of the individual plants, if taken as a whole the are p � a looked like a "warzone." All plants were either partially or wholly dislodged from the substrate with the roots and rhizomes exposed. (Page 13) The latest survey in 2012 confirmed that the eelgrass continues to be found in a degraded state.... It is curious that the same Doug McCrae was apparently the operator of the BDN active geoduck farm prior to BDN purchasing it. The Shorelines Hearings Board continues on page 28: Most testimony regarding herring was directed at the need to protect eelgrass as potential spawning habitat....The nearest documented herring spawning habitat from the (Chelsea) Farm Site is 0.3 miles to the northwest, or roughly 1,5000 feet away, on the other side of Henderson Bay (emphasis added). The Smersh proposed commercial geoduck farm is located completely within a documented herring spawning area. In addition, the documented herring spawning area covering Smersh then continues on both sides of Smersh to the west and east for a total of about a continuous 1.5 miles of herring spawning area on the nearshore area bordering Shine Road. Additionally, the Smersh site is located a very short distance directly east of a sand lance spawning area. The Shorelines Hearing Board continues on Page 29: The Board finds that, because the Permit fails to adequately protect eelgrass, it also fails to adequately protect herring, which depend on eelgrass for spawning habitat. (Page 34) Because of these vital ecological roles served by eelgrass for benthic species, forage fish, and salmon, the Board finds that adverse impacts to eelgrass at this Site are also likely to adversely affect the ability of these other dependent species to utilize or benefit from eelgrass habitat. The Board thus finds on this basis that the Coalition has also met its burden to show inadequate protection for those species in addition to herring that are dependent on eelgrass—including juvenile salmon, forage fish, and other benthic organisms. (Page 52-53) The fact that the Farm Site here will be operated in a high-energy subtidal environment, bordering a continuous eelgrass bed that provides spawning habitat for nearby herring, and habitat and refuge for other forage fish, juvenile salmon, and various aquatic organisms —makes this Site one without the C page8l jlw LOCI 5 .S pu prerequisite qualities for prioritizing it as an appropriate aquaculture site under PCC 20.24.020(A)(10).... These site -specific factors also elevate the importance of other statewide interests over any preference given to aquaculture for this Site. The recognition of aquaculture as a preferred use that is of statewide interest is premised on its proper design and management preventing damage to the environment. Given the lack of protection for eelgrass and related ecosystem values at this Site, the Board concludes that the Farm proposed is not consistent (sic.) the SMA's requirement that the interest of all people be paramount in the management of this shoreline of statewide significance. RCW 90.58.020. In particular, the potential for impacts to eelgrass and other dependent aquatic resources make this proposal one that does not "recognize and protect the state-wide interest over the local interest," does not "result in long term over short term benefit," and does not adequately "protect the resources and ecology of the shoreline." RCW 90.58.020(1), (3), (4). Further, because the Farm may negatively impact the public's use of the area for windsurfing and other recreational uses, it does not "increase recreational opportunities for the public in the shoreline." RCW 90.58.020(5). Balancing these considerations as mandated by the SMA weighs in favor of denying the Permit for this shoreline of statewide significance. C page82 •�.:.:: T 7',: .,b �� , �' �� " 6 �` �-' � ..i ��.i� f.�-�, G'V-'mac.: � . jlw EelgrassHarvestDamage. s.6/26/21 jol LOG ITEM C page84 mgsPr 117 The Carbon -Release Effects of Hydraulic Harvesting Need Evaluation A recent study revealed the alarming news that trawlers dredging the ocean floor release as much carbon as global air travel —due to disruption of sediment that acts as a carbon sink. This prompts the question: What is the effect of hydraulic geoduck harvesting —which liquifies and redistributes sediment to three feet deep —on carbon release? Trawler Study In its March 17, 2021 article, Trawling for Fish May Unleash as Much Carbon as Air Travel, Study Says - The New York Timesinytimes.com), the New York Times reports: The team had not planned to calculate the amount of emissions released by trawling until an outside reviewer for Nature required it, Dr. Sala said. So his team hired an additional researcher and got to work. "I could not believe it," he recalled, describing the video call when his colleagues revealed the number of emissions. "Immediately I went to Google and checked the global emissions by sector and by country, and said, `Wow, this is larger than Germany's."' The carbon released from the sea floor leads to more acidified water, threatening marine life, and reduces the oceans' capacity to absorb atmospheric carbon dioxide. The study cited in the NYT article found that carbon contained in the first meter of substrate --exactly what is disrupted when harvesting geoducks--is "more than twice that of terrestrial soils." Atwood, et. al, "Global Patterns in Marine Sediment Carbon Stocks," p.1 (Note: to view study, copy and paste -in link below, or use NYT link). https://www.frontiersin.org/articles/I 0.33 89/fmars.2020.00165/full#f6 In its introduction, the Atwood study observes: Marine sediments are one of the most expansive and critical carbon (C) reservoirs on the planet; hence, they are key for regulating climate change. Although less than 1% of the gross production on Earth ends up on the seafloor (Hedges and Keil, 1995; Burdige, 2007), organic C buried in the sediments of the ocean can remain there for 1000s to millions of years if left undisturbed (McLeod et al., 2011; Estes et al.. 2019). However, advances in human exploitation of the ocean C page85 LOG ITEV mgs � r• have made the once semi -permanent C stocks in marine sediments` Rff erahle to ' remineralization, a process that will likely exacerbate future climate change. To help develop more refined C budgets and to better inform management of human activities on the seafloor, we quantified the distribution of organic C stocks in global marine sediments and identified critical C storage hotspots. Large-scale degradation of marine habitats has sparked concern that without protection, marine sediments may become a large source of carbon dioxide (CO2) (Pendleton et A. 2012; Lovelock et A, 2017). When disturbed, marine sediments can become mixed and resuspended, exposing them to oxygen and heterotrophic metabolism that can remineralize the C to CO2 (Bianchi et al., 2016). Climate change, coastal development, and advancements in technology that have expanded fishing (e.g., deep-sea bottom -trawling), mining, and oil and gas exploration and drilling in the ocean (Davies et al., 2007; Cordes et al., 2016), pose a potential threat to marine C stocks that could lead to their significant loss and remineralization. To help mitigate abatable threats to C, many have argued that the protection of C hotspots should be considered when developing spatial management plans, including Marine Protected Areas (MPAs) (Howard et al., 2017; Roberts et al., 2017). Hydraulic Harvesting If dredging incidentally disturbs the surface of the ocean floor, hydraulic geoduck harvesting deliberately liquifies a full three feet of sediment and then redistributes the sediment into marine waters, or into the air if harvesting on the beach. This harvesting goes on day after day, month after month, in nearly every square foot of many contiguous acres. Several questions need to be answered: • What is the carbon stock in the specific location? • What is the effect of hydraulic harvesting on carbon release, and what factors, e.g., temperature, season, affect the magnitude? • How much carbon will be released over the life of the permit? • Where does the carbon go, immediately and ultimately? Into the water? The air? C page86 mgs What is the effect on the immediate vicinity —to acidification, for example? This consideration is urgently important in Hood Canal. "The most extreme conditions, at levels known to be stressful to shell -building organisms, were in deep waters of Whidbey Basin and Hood Canal." New repast details ocean acidification in greater Puget Sound - Washington State Department of Ecology • What is the related effect on marine life, e.g. eelgrass, feeder fish, shell formation? What is the total acreage authorized (or applied for) for geoduck farming in Puget Sound? • What is the carbon stock in all ongoing and proposed geoduck farms? • What is the cumulative effect of all, or of any given number, of farms? What is the effect on the atmosphere and contribution to global climate change? This may be a novel issue, but it's an exceedingly important one, and it should be included in any analysis of effects and cumulative effects when considering applications for commercial geoduck permits. Without this analysis, the permits should be denied. LO ITEM' PCAgE C page87 LOG ITEM, New York Times, March 17, 2021 F',,�_ t/ htti2s://www, nytimes. com/2021103/17/cl imate/cl imate-change-oceans. htm i Trawlingfor Fish May Unleash as Much Carbon as Air Travel, Study Says The report also found that strategically conserving some marine areas would not only safeguard imperiled species but sequester vast amounts planet -warming carbon dioxide, too. A trawler on Georges Bank, between Massachusetts atul Nova Scotia. A new study found that bottom trawling accounts for as much carbon emissions as global aviation. Credit... Jeffrey Rotman/Alamy C pagegg LOG ITE v: New York Times, March 17, 2021 1- � F` https://www_ nytimes, com/2021/03/17/clit-nate/clirnate-chancle-oceans. html 1)7 By Catrin Einhorn March 17, 2021 For the first time, scientists have calculated how much planet -warming carbon dioxide is released into the ocean by bottom trawling, the practice of dragging enormous nets along the ocean floor to catch shrimp, whiting, cod and other fish. The answer: As much as global aviation releases into the air. While preliminary, that was one of the most surprising findings of a groundbreaking new study published on Wednesday in the jotirnal Nature. The study offers what is essentially a peer -reviewed, interactive road map for how nations can confront the interconnected crises of climate change and wildlife collapse at sea. It follows similar recent research focused on protecting lancl, all with a goal of informing a global agreement on biodiversity to be negotiated this autumn in Kunming, China. Protecting strategic zones of the world's oceans from fishing, drilling and mining would not only safeguard imperiled species and sequester vast amounts of carbon, the researchers found, it would also increase overall fish catch, providing more healthy protein to people. "It's a triple win," said Enric Sala, a marine biologist who directs National Geographic's Pristine Seas project. Dr. Sala led the study's team of 26 biologists, climate scientists and economists. How much and what parts of the ocean to protect depends on how much value is assigned to each of the three possible benefits: biodiversity, fishing and carbon storage. In order to maximize fish catch alone, the study found, nations would need to set aside 28 percent of the ocean for conservation. That's because no -fishing zones serve as nurseries, replenishing fish and crustacean populations which then disperse beyond the protected areas. For example, this year a study concluded that a 35 percent reduction in the fishing grounds for the California spiny lobster resulted in a 225 percent overall increase in catch after six years. "The worst enemy of fishing and food security is overfishing," Dr. Sala said. C page89 LOG ITEM frontiers in Marine Science W ORIGINAL RESEARCH outilished. 25 Mouth 2020 or I0.3389i"hnars.2020,00i6c 9 Global Patterns in Marine Sediment Carbon Stocks Trisha B. Atwood'*, Andrew Witt', Juan Mayorga2.3, Edd Hammill' and Enric Sala2 Department of Watershed Sciences and Ecology Center, Utah State University, Logan, UT, United States, 2 National Geographic Society, Washington, DC, United States, 3 Bren School of Environmental Science 8 Management and Marine Science Institute, University of California, Santa Barbara, Santa Barbara, CA, United States To develop more accurate global carbon (C) budgets and to better inform management of human activities in the ocean, we need high -resolution estimates of marine C stocks. Here we quantify global marine sedimentary C stocks at a 1-km resolution, and find that marine sediments store — 3117 (3006-3209) Pg C in the top 1 m (more than twice that of terrestrial soils). Sediments in abyss/basin zones account for 75% of the global marine sediment C stock, and 52% of that stock is within the 200-mile Exclusive Economic Zones of countries. Currently, only —2% of sediment C stocks are located in highly to fully protected areas that prevent the disturbance of the seafloor. Our results show that marine sediments represent a large and globally important C sink. However, the lack of protection for marine C stocks makes them highly vulnerable to human OPEN ACCESS disturbances that can lead to their remineralization to CO2, further aggravating climate Edited by. change impacts. Selvaraj Kandasamy, Xiamen University, China Keywords: blue carbon, sail carbon, carbon storage, climate mitigation, carbon cycle, SOC Reviewed by: Andrew Dale, INTRODUCTION GEOMAR Helmholtz Center for Ocean Research Kiel, Germany Marine sediments are one of the most expansive and critical carbon (C) reservoirs on the planet; Tim Rixen, Leftiz Centre for Tropical Marine hence, they are key for regulating climate change. Although less than 1% of the gross production Research (LG), Germany on Earth ends up on the seafloor (Hedges and Keil, 1995; Burdige, 2007), organic C buried in the *Correspondence: sediments of the ocean can remain there for 1000s to millions of years if left undisturbed (McLeod Trisha e. Atwood ct al„ 2011; Estes et at., 20 t 9). However, advances in human exploitation of the ocean have made the trisha.atwood(Wusu.edu once semi -permanent C stocks in marine sediments vulnerable to remineralization, a process that will likely exacerbate future climate change. To help develop more refined C budgets and to better Specialty section: inform management of human activities on the seafloor, we quantified the distribution of organic This article was submitted to C stocks in global marine sediments and identified critical C storage hotspots. Marine Bidgeochemistry, Large-scale degradation of marine habitats has sparked concern that without protection, marine a section ofthejournal sediments may become a large source of carbon dioxide (CO2) (Pendleton et al., 2012; Lovelock Frontiers in Marine Science et al„ 2017). When disturbed, marine sediments can become mixed and resuspended, exposing Received. 24 November2019 them to oxygen and heterotrophic metabolism that can remineralize the C to COz (Bianchi Accepted: 02 March 2020 Published: 25 March 2020 et al., 2016). Climate change, coastal development, and advancements in technology that have expanded fishing (e.g., deep-sea bottom -trawling), mining, and oil and gas exploration and drilling Citation: Atwood TB, Witt A, Mayorga J, in the ocean (Davies et at., 2007; Cordes et al., 2016), pose a potential threat to marine C Hammill E and Sala E (2020) Global stocks that could lead to their significant loss and remineralization. To help mitigate abatable Patterns in Marine Sediment Carbon threats to C, many have argued that the protection of C hotspots should be considered when Stocks. Front. Mar. Sci. 7:165. developing spatial management plans, including Marine Protected Areas (MPAs) (Howard et al., doi: 10.33891fmars.2020.00165 20 t 7; Roherts eL al., 2017). �ront��r��j;�err_e i ww��•�.Iron�_iersin,org 1 Me,i't:ii 2020 i •volume 7 i A�tide � 65 LOG Atwood G_ al. Despite recent advancements in our understanding of the distribution of C stocks in vegetated coastal ecosystems such as mangroves (Atwood et al., 2017; Hamilton and Friess, 2018; Sanderman et al., 2018), seagrasses (Kennedy et al., 2010; Fourqurean et al., 2012), and salt marshes (Macreadie et al., 2017; Osland et at., 2018), as well as the carbon content in global surface (<5 cm) marine sediments (Seiter et al., 2004; Lee et al., 2019) we still lack robust, spatially explicit estimates of global marine sediment C stocks. Without this knowledge, the protection of marine habitats for their climate mitigation potential will likely be overlooked in ocean conservation efforts. Furthermore, seminal reports such as those by the International Panel on Climate Change (IPCC, 2013), which help guide societies response to climate change, are still using non -spatially explicit estimates of global marine sediment C stocks that are calculated by multiplying the average C density of marine sediments by their global extent (Emerson MId FiPdl'Ps, 1988)- Such an approach limits our ability to understand and modify biogeochemical processes and the human driving forces that influence local and global marine sediment C inventories. Fortunately, the collection and dissemination of the chemical compositions of 10s of 1000s of marine sediment cores through programs like the Ocean Drilling Program have now made it possible to map global sediment C stocks at a high spatial resolution. Here, we used C data from 11,578 sediment cores collected from the global ocean (Figure 1) to model and map the distribution of marine sediment organic C stocks down to a 1 m depth at a 1-km2 resolution. In addition to our fine -scale C estimates, we also quantified the amount of C stored within 200- mile Exclusive Economic Zones (EEZs), across oceanic provinces (continental shelf, continental slope, abyssal/basin plains, hadal zone, and subtidal coastal zones not included in the continental shelf), and within current MPAs. MATERIALS AND METHODS C Mapping We used Google Scholar, Web of Science, Pangea, personal datasets, and published reports to generate the most extensive dataset to date on ocean sediment C stocks. Studies included Yy , r� .•• : + ,lam• .7� FIGURE 1 Sediment core locations. Black dots represent the locations where sediment cores for marine sedimentary carbon were collected. Carbor. Slocks contained latitude and longitude of the sample location, percent organic C content of the sediment, loss on ignition (LOI) or percent organic matter (OM), and maximum core depth. This search resulted in C data for 15,004 cores. However, 3,426 cores were removed from the data set because they occurred in supratidal sites that lacked predictor variables for our Random Forest model (see below). In some cases, the original data was presented as an average across multiple sites; in these cases, GPS coordinates of the middle point were used. In cases where a single GPS point was provided for multiple cores, we jittered the longitude of each core in a random direction by 0.001 m. This offset allowed us to make each C sample spatially explicit. Studies reporting LOI were converted to percent C using Eq. 1 for cores collected from salt marsh (Howard et al., 2014) and Eq. 2 for cores collected from seagrass (Fourqurean el al., 2012; Howard et al., 2014). Salt marsh : %C = 0.4 * LOI + 0.0025*1,0I2 (1) Seagrass : %C = 0.43*LOI — 0.33 (2) We standardized soil C stocks down to 1 m in the sediment. This standardization allowed for direct comparisons with terrestrial soils (Scharlemann el al., 2014; Kochy el al., 2015), and allows for comparisons across marine systems as 1 m is commonly used in marine sediment C studies, especially studies in vegetated coastal ecosystems (Fourqurean et al., 2012; Duarte el al., 2013; Atwood et al., 2017; Macreadie et al., 2017). Additionally, studies have suggested that the top 1 m of sediment is the most sensitive to disturbances (Pendleton et al., 2012; Atwood et al., 2017). Studies containing depth profiles greater than (i.e., reported composite stocks for depths greater than 1 m) or less than 1 m were standardized to 1 m by taking the average C stock per centimeter and multiplying it by 100. For studies that did not provide a direct measure of C stock, we calculated it using Eq. 3. C stocks are generally reported in Mg ha-1, however, we converted all stocks to Mg km-2 for modeling and mapping. We used the pedotransfer function in Eq. 4 (R2 = 0.65, n = 6,172; Figure 2), to estimate dry bulk density in studies that did not report one. C stocks (Mg ha-1) = 10, 000 * soil depth (m) *dry bulk density (g cm-3) * (%OC/100) (3) drybulk density = 0.861*%C-0.399 (4) Random Forest Regression models were implemented to predict global marine sediment C stocks between 80' N and ^-58' S. The southern bound of our data was limited by the spatial coverage of our predictor variables. Marine areas that lacked predictor variables, such as supratidal sites, were not included in the model. Random Forest Regressions were based on the compiled C data and 12 predictor variables; mean annual temperature of nearest land point, mean annual precipitation of nearest land point, maximum annual temperature of nearest Fronlier�r.��jy�g�en;;e � ww�id.fron•b,reir.ory PAaicn 20201 1 �,olume r I Aricle icy AD,vood e; al, Pr• a 0 0 U 0 o� m c any (D 88 Y N 7 O � o Z' o 0 r 00 ❑ 0 0 �cp�oo 0 ❑ 0 0 0 10 20 30 40 50 60 Percent Carbon FIGURE 2 Pedotransfer function to estimate dry bulk density based on carbon content (RZ = 0.65, n = 6,172). Dry bulk density = 0.861 '%C-0-399. land point, minimum annual temperature of nearest land point, ocean mean annual sea surface temperatures, ocean chlorophyll a concentration, elevation and bathymetry, sea surface height anomaly, sea surface salinity, distance from land, and distance from rivers (Table 1). These variables were chosen because they are known or hypothesized to influence the delivery and breakdown of C in marine systems. Carbon stocks down to 1 m in the sediment were modeled at a 1 kmz resolution using a bootstrapped (500 iterations) Random Forest regression from the `randomForest' package in R 3.3.3. Model performance was assessed using cross - validation, where 30% of the data were withheld in each model refitting. TABLE 1 I Data sources for the predictor variables used in the Random Forest analysis. Data layer Source Ocean Chlorophyll a https://neo.sci.gsfc.nasa.gov Elevation https:Hasterweb.jpl, nasa.gov Bathymetry https://visibleearth.nasa.gov/images/73963/ bathymetry Mean Annual Precip. https://www.worldclim.org/bioclim Sea Surface Height Anomoly https://sos.noaa.gov/datasets/sea-surface- height-anomaly/ Sea Surface Salinity https:Hpodaac.jpl.nasa.gov Distance From Land Euclidean distance calculation Distance From Rivers Euclidean distance calculation Min. Annual Temp, https://www.worldclim.org/bioclim Max Annual Temp. https://www.worldclim.org/bioclim Mean Annual Temp. https://www.worldclim,org/bioclim Ocean Mean Annual Temp. https:gpodaac.ipl.nasa.gov Marine Carbon Stocks Random Forest models are a popular and relatively new machine learning tool that can be used for digital soil mapping. Briefly, Random Forest models are an ensemble technique that allows for both classification and regression by developing multiple decision trees (i.e., bagging). Each tree is trained from a random bootstrap sample, where a subset of the data points are used to train (i.e., grow) the tree and the remaining data points are used to validate the tree. In our study, 30% of the data was used to validate our model. A more thorough explanation of Random Forest models can be found in Breirnan (2001). Random Forest models provide several advantages over other techniques: they allow for the modeling of high dimensional non -linear relationships, they require few defined parameters, they reduce experimental noise and enhance accuracy by aggregating predictions, and one can measure the variable importance of predictor variables (Breirnan, 2001; Sanderman eL al., 2018). Random Forest Models assess the importance of specific predictor variables by randomly permuting the out -of - bag observations and then passing the modified out -of -bag data down the tree to get new predictions. It then measures the importance of each variable by taking the difference between the misclassification rate for the modified and original out -of -bag data and dividing it by the standard error. One disadvantage of using Random Forest models is that they do not estimate spatially -explicit uncertainty, rather they quantify model uncertainty as a whole. Previous investigations have demonstrated that sources of uncertainty in C stock are present across multiple scales in soil/sediment measurements. We therefore estimated error in C stocks at the core level using parametric bootstraps, and then propagated that error up to the pixel- and global -level. Parametric bootstrapping was done by comparing the measured C stocks from collected sediment cores to the predicted C stock values generated from the Random Forest model. The difference between the measured and predicted C stock values for each core are indicative of the error associated with the measurement and calculation of C stocks, while accounting for the influence of environmental parameters, as well as the model performance. Plots of the measured versus predicted data reveal that across the range of C stocks measured, the residuals are relatively evenly spread, but that the variation increases slightly as C stock increases (Figure 3). Therefore, we converted the residual difference between the measured and predicted data to a proportion of the measured value, and used these residuals to generate a normal distribution. This technique is similar to Monte Carlo simulations used in previous studies to propagate error in soil C stocks (Goidts et al., 2009). Proportional residuals were not bound between 0 and 1 as the difference between measured and predicted values could be greater or less than the measured value. We found that the proportional residuals form a normal distribution with a mean of—0.0032 and a standard deviation of 0.017. From the distribution of proportional residuals, we estimated error in C stock by generating bootstrapped confidence limits around C stock estimates. We used 1000 iterations to produce bootstrapped confidence limits. For each iteration, we took the predicted C stock value for each collected sediment core, and Frontierer�Jj 8nr_e 1 ,,ro,hw .Iron-.iersin,org March 20?0 1 Volume 7 1 Article 65 LOG ITEM AIWtu7t: a; d. 0 o O ° a ✓ o � 0 E 0 f Y o 0 7 ° ° m O ° °: N 7 O B P O U) ° too Eo a N ° Y o ` g e ° 0 Cb ° oo e 0 OO '6 ° 0 a ° % t6 0 o o 0 6 U %o o ° ° vooi ° a 0 a m 0a 0 0 50000 100000 150000 200000 250000 300000 350000 Carbon stock predicted (Mg km2) FIGURE 3 1 Predicted carbon (C) stock data versus measured C stock. Each data point represents the C stock data from one core. Measured C stocks were calculated from the data reported in the original source study, while predicted C stocks were obtained from the Random Forest model. The dashed line represents the 1 :1 line where measured data equals predicted data. PGA then added a proportion of that predicted value based on a sample from the normal distribution of proportional residuals (a value that could be positive or negative). This process is analogous to the Monte Carlo simulations used in previous attempts to quantify error (C,oidts et al., 2009). From the 1000 iterations of predicted value plus error sample generated for �1 1-7 M,cn!ie Cam -or. Stocks each individual core, we identified the 0.025 and 0.975 quantiles to produce upper and lower 95% confidence limits for the predicted value of each core. This process meant that for each core used in the analysis, we had a measured value, and an upper and lower confidence limit. Finally, Random Forest models were then run using the upper and lower confidence limits for each collected sediment core value to produce confidence intervals for each pixel, which was then propagated up to the global C stock. We used Harris aiiLl Wliiteway (2009) geomorphic units to calculate the amount of C stored in sediments located in the continental shelf, continental slope, abyss/basin, and hadal zones (Figure 4). We combined abyss and basin zones because they were not spatially explicit in the original data set. We estimated the amount of C stored in EEZs, the high seas, all MPAs, highly protected MPAs, and ocean depths > 1000 m (deep-sea) using spatial statistics. EEZ locations were obtained from the marine regions database managed by the Flanders Marine Institute`. MPA locations and protection levels were identified using the MPAtlas database (Marine Conservation institute, 2019). Ocean depths were calculated from the bathymetry predictor variable used in the Random Forest analysis'. RESULTS Our Random Forest Regression model explained 76% of the variance in C stocks estimated from sediment cores (Rz = 0.76, RMSE 7306 Mg km2). Ocean chlorophyll a concentrations, elevation and bathymetry, mean annual precipitation of nearest land point, and sea surface height, respectively, were the most important variables explaining marine sediment C stocks (Figure 5). 1 http://marineregions,org 'h ttps://visiblecarth.nasa.gov T•r _J Ocean Provinces �- •� ,- Fladal Continental slope , Continental shelf Q Abyss/Basin FIGURE 4 Global distribution of ocean provinces. Data from I lai r:s anU ?^/hitcav�y.i2009i. oritii;rtPAke93er`e 1 `v.frgniiergn.nrq 4 P11-0( n 20- O 1 Volk irm r Article TrHl �t� Atwood e; cal Marine Carbon Stocks Ocean chi a 0 ElevatioN6athymetry 0 Mean annual precip. of nearat land 0 Sea surface height anomaly 0 Sea surface saiinty o Distance to land 0 Distance to river 0 Min annual temp of nearest land 0 Max annual temp. of nearest land 0 Mean annual tempof nearest land a Sea surface temp. 0 5 10 15 20 %lncMSE FIGURE 51 Variable importance plot for predictor variables used in the Random Forest analysis expressed as the percent increase in mean squared error (% IncMSE). The higher the values of %incMSE, the more important that variable is in the Random Forest model. We found that the global ocean stores 3117 Pg of C in the top 1 m (Figure 6A), with a 3006 to 3209 Pg C range across all pixels. Error spatially varied across ocean sediments with larger uncertainty occurring in areas that had low data densities and/or higher variability in known C stocks. Areas with the highest uncertainty included the continental shelf, with parts of the Caribbean, the North Sea, the Mediterranean, and coastal Indonesia and Malaysia having the highest variability in C stocks (Figure 6B). Carbon stocks spatially varied across oceanic depths and across regions. Nearly four -times as much C is stored in deep- sea sediments (water depths > 1000 m) compared to sediments underlying shallow seas (Table 2). Within the oceanic provinces, abyssal/basins store the most C (2240-2395 Pg C), followed by the continental shelf (490-523 Pg C), the continental slope (218- 233 Pg), other non -shelf coastal habitats (30-31.4 Pg) and the hadal zone (28-29.6 Pg). The amount of C stored in EEZs and the high seas were similar, with 1606 (218-233, 95% CI) Pg C stored in EEZs and 1512 (1480-1580) Pg C stored in the high seas. As of 2019, 118 (114-122) Pg C in the top 1 m of sediments is stored in MPAs, of which only 57 (54-58) Pg C is stored in highly protected MPAs (Figures 6A,C and Table 2). DISCUSSION We estimate that the ocean is currently storing ^-3117 (3006- 3209) Pg C in the top 1 m of sediments, with most (75%) of this C stored in abyssal/basin zones. This estimate makes the A low eeeo r y reoe B C s ot tiYfa aw a •'� FIGURE 61 Global marine sediment carbon (C) stocks and marine protected areas. (A) Average distribution of global marine sediment C stocks. Stocks represent the amount of C stored in the top 1 m of sediment. (B) Uncertainty in C stocks as express by the difference between the upper and lower 95% Cl. (C) Locations of marine protected areas. Areas circled in red are implemented fully to highly protected marine areas where only light extractive activities are allowed, and other impacts are minimized to the extent possible. Data on marine protected areas are from http://mpatlas.org/map/mpas/ (Marine Conservation Institute, 2019). MPAtlas. Seattle, WA, United States. www.mpatias.org [Accessed 19/02/20191. ocean the largest pool of sediment/soil C stocks in the world, with 2.3 times greater C stocks than the top 1 m of terrestrial soils (KSchy et al., 2015). Because our estimate does not include supratidal areas, our C stock estimate is likely conservative as it omits some supratidal marshes and mangroves, which are known to store large amounts of sediment C (Atwood et al., 2017; Macreadie et al., 20t7; Osland et aL, 2018). Past studies have estimated that marine surface sediments store between 87 Pg C (top 5 cm; Lee et al., 2019) and 147 Pg C (top 30 cm; Emerson and Hedges, 1988); if we extrapolate their results to a 1 m depth (assuming an equal distribution of C with depth), our estimate is ^-1.8 times to 6 times greater, respectively, than these previous calculations. Emerson and Hedges' (1988) estimate was not spatially explicit and relied on average %C and bulk density estimates for the open ocean and continental margin sediments. Frontiertr-ik tm-.e I wA,,,v,lrorriersin.org 5 Maich 2020 1 Volume 7 1 Article 165 Akw)od et ai. x Marine Carboy Stocks R TABLE 21 Global extent, average (95% confidence intervals) carbon (C) stocks in the top 1 m, and proportion of the global marine sediment C stock in the top 1 m for different oceanic provinces, marine jurisdictions [Exclusive Economic Zones (EEZ)], ocean depths, marine protected areas (MPAs), including implemented highly and fully protected areas, and total marine sedimentary C stock for the global ocean. Area km2 C stock (Mg km2) Total sediment C stocks (Pg) Global proportion # of cores Oceanic Provinces Continental Shelf 14,250,873 35, 646 (34, 384-36, 700) 508 (490-523) 16% 5450 Other Coastal 4,894,100 6, 334 (6, 130-6, 416) 31 (30-31.4) 1 % 856 Continental Slope 19,693,306 11, 476 (11, 070-11, 831) 226 (218-233) 7% 2261 Abyss/Basin 306,595,886 7, 577 (7, 306-7, 802) 2323 (2240-2392) 75% 2981 Hadal 3,437,928 8,435 (8, 144-8, 610) 29 (28-29.6) 1 % 30 Jurisdictions EEZs 167,345,228 9, 597 (9, 119-9, 734) 1606 (1526-1629) 52% 9610 High Seas 181,526,865 8, 329 (8, 153-8, 704) 1512 (1480-1580) 49% 1968 Ocean depth Shallow sea (<1000 m) 31.687,886 20, 355 (19, 566-20, 891) 645 (620-662) 21 % 7692 Deep-sea (> 1000 m) 317,184,207 7, 794 (7, 522-8, 030) 2472 (2386-2547) 79% 3886 MPAs All MPAs 18,164,927 6,496 (6, 276-6, 716) 118 (114-122) 4% 835 Highly protected MPAs 8,498,959 6, 707 (6, 354-6, 824) 57 (54-58) 2% 236 Total C stocks Global marine sediments 348,872,093 8,935 (8, 616-9, 198) 3117 (3006-3209) 11,578 Global terrestrial soil 125.800,000 1325 The number of cores indicates the sample size for each category. Terrestrial soil stocks and land area estimates are from K6chy et al'. (2015) The more recent estimate from Lee et al. (2019), used 5623 sediment cores collected from the global ocean before 2004, and k-nearest neighbors algorithms to estimate C content in marine sediments at a 5 x 5-arcmin resolution. They then calculated C stocks in the top 5 cm by using a global average for bulk density. Our study improves upon these past estimates of marine sediment C stocks by using spatially explicit estimates of bulk density, and by including 1000s of additional cores, many of which were collected from the carbon -rich sediments of coastal vegetated habitats (Atwood et al., 2017; Macreadie et A, 2017; Osland et al., 2018; Serrano et al., 2019). Sediment C hotspots (i.e., large C stocks per unit area) generally occurred along continental shelves. Some of the largest C hotspots were observed off the coasts of Namibia, Peru, Baja California, and in the Caribbean Sea, the Baltic Sea, and the Indo-Pacific (Figure 4). Variable importance plots identified ocean chlorophyll a, depth, mean annual precipitation, of nearest land, distance to land, and distance to rivers as some of the most important variables influencing C stock distributions. These results suggest that the large supply of organic -rich sediments from land runoff and river discharge (Bauer et al., 2013; Regnier et al., 2013; Bianchi et al., 2018) and the production of large phytoplankton blooms in upwelling areas are important drivers in the supply of C to continental shelf marine sediments. Over the past two centuries, human -driven land -use change, river modification, and climate change have led to significant impacts on the spatial and temporal fluxes of C from land, rivers, and pelagic environments to marine sediments (Bauer et al., 2013; Regnier et al., 2013). As a result, human activities will likely play a large role in reshaping the spatial distribution of future C hotspots. Deep-sea sediments (ocean depths > 1000 m) generally had low C stocks per unit area owing to low C concentrations (<l%) in the sediment (Lee et al., 2019). However, because of their extensive geographic areal coverage, deep-sea sediments accounted for ^-80% of the total marine sediment C stock. Although our C stock assessment was standardized to a 1 m depth to help compare C stocks across systems, the C composing deep- sea stocks represent the accumulation of C over much longer timescales than those in shallow coastal zones. Sedimentation rates in the deep-sea are two to three orders of magnitude slower than coastal sediments (McLeod et al., 201 l; Estes et al., 2019). Thus, C stocks down to 1 m depth in coastal sediments represent accumulation over 100 to 1000s of years, while a depth of 1 m in deep-sea sediments represent accumulation over 100s of 1000s to millions of years. For anthropogenic disturbances (e.g., deep-sea mining or trawling) to enhance C remineralization in marine sediments, the organic C in the sediment must be physically and chemically available to be broken down by heterotrophic communities, and physicochemical conditions in the sediments must be or become conducive to heterotrophic metabolism (Hedges and Neil, 1995; Burdige, 2007; Hendriks et al., 2008). In general, organic -rich coastal sediments along the continental shelf that experience high sedimentation rates and rapid oxygen depletion with depth are hypothesized to be the most sensitive to disturbances. Disturbances that physically disrupt these organic - rich coastal sediments can enhance oxygen exposure and mix fresh C pools with degraded ones, priming microbial activity, and the breakdown of C (Bianchi, 2011; Lovelock et al., 2017; Macreadie et al., 2019). Conversely, recent estimates have suggested that a large portion of deep-sea sediment C Frontiertr141fLg,!Aence I ewtiw.fron.iersin.org WICK 2020 1 Volume 7 1 Article -65 • . .. . • . LOG ITEPW At,,v:,,,d e. ;,i. �r• occurs in oxygenated sediments, but that physical and chemical protections make that C inaccessible to heterotrophic metabolism (Keil and Hedges, 1993; Hedges and Keil, 1995; Estes et al., 2019). As a result, deep-sea sediment C along the continental slope, abyssal/basin, and hadal zones may be more resistant to disturbances than coastal continental shelf sediments. Even if deep-sea organic C is remineralized, it is unlikely to influence atmospheric COZ concentrations over the near future because deep-sea C cycling works on millennial time -scales. However, organic C availability and the release of metabolic COz in sediment porewater from its degradation are major drivers of calcium carbonate dissolution in marine sediments (Ernerson and Archer, 1990; Archer, 1991; Archer and Maier -Reimer, 1994; Jahnke et al., 1994). As calcium carbonate is a major buffer, alterations to calcium carbonate preservation in marine sediments could lead to complex and hard to predict ocean acidification feedbacks, as well as effects on benthic calcifiers (Sulpis et al., 2018). The sheer volume of C stored in marine sediments underscores the importance of safeguarding, as the remineralization of even a small fraction of these C stocks could greatly exacerbate climate change. Currently, ^-4% (^-118 Pg C) of marine sediment C stocks occur in MPAs, and only ^2% (57 Pg C) occur in highly protected MPAs where commercial extraction is prohibited, and recreational and subsistence extraction is minimal (i.e., no -take reserves). Although the expansion of MPAs will not reduce the effects of all disturbances on marine C stocks, they can help alleviate impacts from abatable threats like trawling and mining, as long as those activities are not displaced to areas with higher C stocks. However, most MPAs are established within country boundaries, with only ^-1% of the high seas receiving protection from current MPAs (.1v[arine Conservation Institute, 2019). The large amount of C stocks residing outside EEZs (48%), is, therefore, concerning because there is currently little governance over the expanding human activities (e.g., deep-sea mining and bottom -trawling) that could lead to the disturbance and remineralization of sediment C stored in high seas benthic habitats (Ardron et al., 2013). C Model Error and Uncertainty Several factors may contribute to potential errors and uncertainty in our C model predictions. Error estimates showed that continental shelf sediments had the highest uncertainty in C stocks. This uncertainty is, at least in part, likely the result of high variability in the C content of continental shelf sediments, which can range from relic sands that have C contents of < 1% (Sei(er et al., 2004) to organic -rich sediments in vegetated coastal habitats with C contents > 15% (Donato et al., 2011). In addition, the marine sediment C data used to build and test our models is subject to a variety of errors. First, studies used a variety of analytical methods for estimating percent C in sediments that include both quantitative (wet oxidation and dry combustion) and semi -quantitative (LOI) measures. Each of these methods, as well as the labs and equipment performing these analyses, vary in their sensitivity and error. Second, maximum core depth varied across studies, with 84% of Mann: ;arbor, Stocks the cores used in this study requiring standardization to 1 m. We chose a standardized depth of 1 m to comply with IPCC protocols and common practice in the literature for sediment/soil C budgets. Our extrapolations assume a uniform distribution of C to 1 m. However, many studies have shown that C concentrations in sediments show a non -linear decline in C to a depth of ^-30 cm and then remain relatively constant to —1 m (Sanders et al., 2016; Serrano et al., 2016). Third, 69% of cores used in our study did not have a bulk density measurement and required the use of a pedotransfer functions to estimate one. Furthermore, various coring devices were used by the different studies to extract sediments. Some coring devices cause severe disturbance to surface sediments, which can cause sediment loss from the surface. Other devices can cause compaction during core penetration, which can affect bulk density measurements. Bulk density estimates and non -standardization of core depth are often two of the largest sources of uncertainty in large- scale sediment/soil C models (K6chy et al., 2015; Sanderman A al., 2018). Overall, only ^-10% of our data provided all the necessary information to calculate C stocks down to 1 m, which highlights the large disconnect between the current methods used by studies examining C in marine sediments, and protocols set out by the IPCC for carbon budgets. Fourth, the global distribution of our sediment C data was not uniform, with fewer collections occurring in the southern hemisphere and a large data gap in the Southern Ocean. If the studies that collected the cores used in our model were globally or regionally biased toward more organic -rich or organic -poor sediments, then such biases would propagate through the C model predictions. Although we cannot discount that such sampling bias exists, our study provides the most robust collation of global marine sediment cores. Thus, our study represents our most up-to-date knowledge on C stocks in global marine sediments based on the cores collected to date. In addition to errors and uncertainty in the C data, our model uses 12 predictor variables (see section "Materials and Methods") to estimate local C stocks at a 1- km resolution. Most of these predictor variables are themselves based on modeled data and are subject to their own error and uncertainty. Finally, some benthic habitats in the ocean are composed of hard substrates with little or no sediment or soil accumulation. However, a high resolution, global map of substrate characteristics has yet to be completed. In areas with extensive coverage of hard substrate and no or limited sediment or soil accumulation, our results will overestimate sediment C stocks. CONCLUSION Our study shows that marine sediments, particularly nearshore sediments, are a large and important global C sink. Currently, only a small portion of marine sediment C is safeguarded from activities that could lead to the disturbance of ocean sediments and the remineralization of these stocks. These results suggest that as nations strive to protect more of the ocean, the design of new MPAs should consider the inclusion of C storage as a conservation objective (Howard el al., 2017; Fronk r r,jalrgty yrerr_.e ;�;wUtfrcn_iersin.oig 7 iVaOh 262E l Volume hrOde 165 r� TEM r� l� Atwood et al. Dinerstein et al„ 2019). Not only can the protection of marine C stocks help mitigate climate change, but C-financing mechanisms can also be used to help support the economic costs of implementing and maintaining an MPA (Howard et A, 2017). This study provides a quantitative, high -resolution assessment of the C stored in marine sediments that not only enhances our understanding of the ocean C budget, but also helps identify major priority areas for conservation. DATA AVAILABILITY STATEMENT The sediment carbon data is available at https://figshare.com/ articles/marine_soil_carbon/9941816. The R code for calculating uncertainty and GeoTiff files of the carbon maps are available at https://figshare.com/articles/Global_marine_Sedimentary_ carbon_stock/J1956356. REFERENCES Archer, D. (1991). Modeling the calcite lysocline. J. Geophys. Res. 96, 17037-17050. doi: 10.1029/91 j c01812 Archer, D„ and Maier -Reimer, E. (1994). Effect of deep-sea sedimentary calcite preservation on atmospheric CO 2 concentration. 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Centers of organic carbon burial and oxidation at the land -ocean interface. Org. Geochem. 115, 138-155, doi: 10.1016/j.orggeochem.2017.09.008 Bianchi, T. S., Schreiner, K. M., Smith, R. W., Burdige, D. J., Woodard, S., and Conley, D. J. (2016). Redox effects on organic matter storage in coastal sediments during the Holocene: a biomarker/proxy perspective. Annu. Rev. Earth Planet. Sci. 44, 295-319. doi: 10.1 146/annurev- earth- 060614- 105417 Breiman, L. (2001). Random forests. Mach. Learn. 45, 5-32. Burdige, D. J. (2007). Preservation of organic matter in marine sediments: controls, mechanisms, and an imbalance in sediment organic carbon budgets? Chem. Rev. 107, 467-485. doi: 10.1021/cr050347q Cordes, E. E., Jones, D. 0. B., Schlacher, T. A., Amon, D. J., Bernardino, A. F., Brooke, S., et al. (2016). Environmental impacts of the deep -water oil and gas industry: a review, to guide management strategies. Front. Environ. Sci. 4:58. doi: 10.3 389/fen vs.2016.00058 Davies, A. J., Roberts, J. M., and Hall-Spenccr, J. (2007). Preserving deep-sea natural heritage: emerging issues in offshore conservation and management. Biol. Conserv. 138, 299-312. doi: 10.1016/j,biocon.2007.05.011 Dinerstein, E., Vynne, C., Sala, E., Joshi, A. R., Fernando, S., Lovejoy, T. E., et al. (2019). A global deal for nature: guiding principles, milestones, and targets. Sci. Adv. 5:eaaw2869. doi: 10. 1 126/sciadv.aaw2869 Donato, D. C., Kauffman, J. B., Murdiyarso, D., Kurnianto, S., Stidham, M., and Kanninen, M. (2011). Mangroves among the most carbon -rich forests in the tropics. Nat. Geosci. 4, 293-297. doi: 10.1038/ngeol123 Duarte, C. M., Losada, I, J„ Hendriks, I. E., Mazarrasa, I., and Marba, N. (2013). The role of coastal plant communities for climate change mitigation and adaptation. Nat. Clim. Chang. 3, 961-968. doi: 10.1038/nclimatel970 AUTHOR CONTRIBUTIONS Nlarr.e Carbon Stocks TA and ES designed the study. TA, AW, and EH collected the data. AW, JM, and EH analyzed the data. TA, AW, JM, EH, and ES wrote the manuscript. FUNDING This study was funded by the National Geographic Society. ACKNOWLEDGMENTS We would like to thank Tom Bianchi and Boris Worm for comments on an early draft of the manuscript. Emerson, S., and Hedges, J. I. (1988). Processes controlling the organic carbon content of open ocean sediments, Palaeogeogr. Palaeoclimatol. Palaeoecol 3, 621-634.doi: 10.1029/PA003i005p00621 Emerson, S. R., and Archer, D. (1990). Calcium carbonate preservation in the ocean. Philos. Trans. R. Soc. Ser. A Math. Phys. Sci. 331, 29-40, doi: 10.1098/ rs ta.1990.0054 Estes, E. R., Pockalny, R., D'Hondt, S., Inagaki, F., Morono, Y., Murray, R. W., et al. (2019). Persistent organic matter in oxic subseafloor sediment. Nat. Geosci. 12, 126-131.doi: 10.1038/s41561-018-0291-5 Fourqurean, J. W., Duarte, C. M., Kennedy, H., Marba, N., Holmer, M., Mateo, M. A., et al. (2012). Seagrass ecosystems as a globally significant carbon stock. Nat. Geosci. 5, 505-509. doi: 10.1038/ngeol477 Goidts, E., Van Wesemael, B., and Crucifix, M. (2009). Magnitude and sources of uncertainties in soil organic carbon (SOC) stock assessments at various scales. Eur. J. Soil Sci. 60, 723-739, doi: 10.1111/j.1365-2389.2009. 01157.x Hamilton, S. E., and Friess, D. A. (2018). Global carbon stocks and potential emissions due to mangrove deforestation from 2000 to 2012. Nat. Clim, Chang. 8, 240-244. doi: 10.1038/s41558-018-0090-4 Harris, P. T., and Whiteway, T. (2009). High seas marine protected areas: benthic environmental conservation priorities from a GIS analysis of global ocean biophysical data. Ocean Coast. Manag. 52, 22-38. doi: 10.1016/j.ocecoaman. 2008.09.009 Hedges, J. I., and Keil, R. G. (1995). Sedimentary organic matter preservation: an assessment and speculative synthesis. Mar. Chem. 49, 81-115. doi: 10.1016/ 0304-4203(95)00008-F Hendriks, I., Sintes, T., Bouma, T., and Duarte, C. (2008). Experimental assessment and modeling evaluation of the effects of the seagrass Posidonia oceanica on flow and particle trapping. Mar. Ecol. Prog. Ser. 356, 163-173. doi: 10.3354/ meps07316 Howard, J., Hoyt, S., Isensee, K., Pidgeon, E., and Telszewski, M. (eds). (2014). Coastal Blue Carbon: Methods for Assessing Carbon Stocks and Emission Factors in Mangroves, Tidal Salt Marshes, and Seagrass Meadows. Arlington, VA: Conservation International, Intergovernmental Oceanographic Commission of UNESCO, International Union for Conservation of Nature. Howard, J„ McLeod, E., Thomas, S., Eastwood, E., Fox, M., Wenzel, L., et al, (2017), The potential to integrate blue carbon into MPA design and management. Aquat. Conserv. Mar. Freshw. Ecosyst. 27, 100-115. doi: 10.1002/agc.2809 IPCC (2013). Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, eds T. F. Stocker, D. Qin, G.-K Plattner, M. Tignor, S. K. Allen, J, Boschung, et al. (Cambridge: Cambridge University Press), 1535, doi: 10.1017/CB 09781107415324 Jahnke, R. A., Craven, D. B., and Gaillard, J. F. (1994). The influence of organic matter diagenesis on CaCO3 dissolution at the deep-sea floor, Geochim. Cosmochim. Acta 58, 2799-2809- doi: 10.1016/0016-7037(94)90115-5 Frontier. �y joence I w,Anufrcntiersin.org 8 Much 2Q?0 I volume 7 I Article :85 G � J tr Atwood e: it. Keil, R. G., and Hedges, J. I. (1993). Sorption of organic matter to mineral surfaces and the preservation oforganic matter in coastal marine sediments. Chem, Geol. 107,385-388. doi: 10.1016/0009-2541(93)90215-5 Kennedy, H., Bcggins, J., Duarte, C. M., Fourqurean, J. W., Holmcr, M., Marb$, N., et al. (2010). Seagrass sediments as a global carbon sink: isotopic constraints. Global Biogeochem. Cycles 24:GB4026. doi: 10.1029/2010GB003848 K6chy, M., Hiederer, R, and Freibauer, A. (2015). Global distribution of soil organic carbon - Part 1: masses and frequency distributions of SOC stocks for the tropics, permafrost regions, wetlands, and the world. Soil 1, 351-365. doi: 10.5194/soil-1- 351- 2015 Lee, T. R., Wood, W. T., and Phrampus, B. J. (2019). A machine learning (kNN) approach to predicting global seafloor total organic carbon. Global Biogeochem. Cycles 33, 37-46. doi: 10.1029/2018GB005992 Lovelock, C. E., Atwood, T. B., Baldock, J., Duarte, C. M., Hickey, S., Lavery, P. S., et al. (2017). Assessing the risk of carbon dioxide emissions from blue carbon ecosystems. Front. Ecol. Environ. 15, 257-265. doi: 10.1002/fee.1491 Macreadie, I., 011ivier, Q. R., Kelleway, J. J„ Serrano, 0., Carnell, P. E., Ewers Lewis, C. J., et al. (2017). Carbon sequestration by Australian tidal marshes. Sci. Rep. 7:44071. doi: 10.1038/srep44071 Macreadie, P. L, Atwood, T. B., Seymour, J. R., Fontes, M. L. S., Sanderman, J., Nielsen, D. A., et al. (2019). Vulnerability of seagrass blue carbon to microbial attack following exposure to warming and oxygen. Sci. Total Environ. 686, 264-275. doi: 10.1016/j.scitotenv.2019.05.462 Marine Conservation Institute (2019). Available online at: www.mpatias.org (accessed February 19,2019). McLeod, E., Chmura, G. L., Bouillon, S., Salm, R., Bjork, M., Duarte, C. M., et al. (2011). A blueprint for blue carbon: toward an improved understanding of the role of vegetated coastal habitats in sequestering CO2. Front. Ecol. Environ. 9, 552-560. doi: 10.1890/110004 Osland, M. J., Gabler, C. A., Grace, J. B., Day, R. H., McCoy, M. L., McLeod, J. L., et al. (2018). Climate and plant controls on soil organic matter in coastal wetlands. Glob. Chang. Biol. 24, 5361-5379, doi: 10.1111/gcb.14376 Pendleton, L., Donato, D. C., Murray, B. C., Crooks, S., Jenkins, W. A., Sifleet, S., et al. (2012). Estimating global "blue carbon" emissions from conversion and degradation of vegetated coastal ecosystems. PLoS One 7:e43542. doi: 10.1371/ jou rnal,po n e.0043542 Regnier, P., Friedlingstein, P., Ciais, P., Mackenzie, F. T., Gruber, N., Janssens, I. A., et al. (2013). Anthropogenic perturbation of the carbon fluxes from land to ocean. Nat. Geosci. 6, 597-607. doi: 10. 1038/ngeo 1830 Marine Carbon Stocks Roberts, C. M., O'Leary, B. C., McCauley, D. J., Cury, P. M., Duarte, C M., Lubchenco, J., et al. (2017), Marine reserves can mitigate and promote adaptation to climate change. Proc, Natl. Acad, Sci. U.S.A. 114, 6167-6175. doi: 10.1073/pnas.1701262114 Sanderman, J., Hengl, T., Fiske, G., Solvik, K., Adame, M. F., Benson, L., et al. (2018). A global map of mangrove forest soil carbon at 30 m spatial resolution. Environ, Res. Lett. 13:055002. doi: 10.1088/1748-9326/aabelc Sanders, C. J., Maher, D. T„ Tait, D, R., Williams, D., Holloway, C., Sippo, J. Z., et al. (2016). Are global mangrove carbon stocks driven by rainfall? J. Geophys. Res. Biogeosci. 121, 2600-2609. doi: 10.1002/2016JG00 3510 Scharlemann, J. P. W., Tanner, E. V. J., Hiederer, R., and Kapos, V. (2014). Global soil carbon: understanding and managing the largest terrestrial carbon pool. Carbon Manag. 5, 81-91. doi: 10.4155/cmt.13.77 Seiter, K., Hensen, C., Schroter, J., and Zabel, M. (2004). Organic carbon content in surface sediments - defining regional provinces, Deep Sea Res. Part I Oceanogr. Res. Pap. 51, 2001-2026. doi: 10, 10 16/j.dsr.2004.06.014 Serrano, 0., Lovelock, C. E., Atwood, T. B., Macreadie, P. L, Canto, R., Phinn, S., et al. (2019). Australian vegetated coastal ecosystems as global hotspots for climate change mitigation. Nat. Commun. 10, 1-10. doi: 10.1038/s41467-019- 12176-8 Serrano, 0., Ruhon, R., Lavery, P. S., Kendrick, G. A„ Hickey, S., and Masque, P. (2016), Impact of mooring activities on carbon stocks in seagrass meadows. Sci. Rep. 6:23193. doi: 10.1038/srep23193 Sulpis, 0., Boudreau, B. P., Mucci, A., Jenkins, C., Trossman, D. S., Arbic, B. K., et al, (2018). Current CaCO3 dissolution at the seafloor caused by anthropogcnic CO2. Proc. Natl. Acad. Sci. U.S.A. 115, 11700-11705. doi: 10. 1073/pnas.1804250115 Conflict of Interest: The authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest. Copyright © 2020 Atwood, Witt, Mayorga, Hammill and Sala. This is an open -access article distributed under the terms of the Creative Commons Attribution License (CC BY), The use, distribution or reproduction in otherforums is permitted, provided the original author(s) and the copyright owner(s) are credited and that the original publication in this journal is cited, in accordance with accepted academicpractice. No use, distribution or reproduction ispermitted which does not comply with these terms. Frontiertr-,4&4gence I wwmfrom,ersimoig .S Plaicl1 2020 I Volume 7 1 Art,de. 165 Plastics Pollution Page BDN-Smersh seeks authorization to insert 43,560 PVC tubes/acre on 5.15 acres, or 224,334 inserted tubes. That is 35.4 miles of tubes, and 61 TONS of plastic. (Each tube and band weighs 8.7 ounces.) Plastics pollution of our waters is a world-wide scourge. Microplastics have invaded the food chain of marine life and humans. For the most part, plastic in our seas is the result of inadvertent, or at least unauthorized, actions. But geoduck farmers want government permission to deliberately place plastic tubes into the substrate. These tubes trap wildlife, escape in high winds, and are ground by the substrate into tiny microparticles that enter the food chain. Later the substrate, along with any microplastic it holds, is liquified and redistributed into marine waters. There is a wholly insufficient analysis (let alone cumulative analysis) of both the macro and micro effects of the PVC tubes at this site. Plastics pollution is at once a serious navigational hazard (see Section A Hicks Park), an aesthetic blight (see Section E Aesthetics), and a biological threat: At the macro level: What is the effect of 5.1 acres, packed with these tubes protruding seven inches, on tidal flow? On returning salmonids and on young exiting salmonids? How does this density of protruding tubes affect the feeding habits of diving birds, in particular the Marbled Murrelet? At the micro level: What is the particular quality of the substrate at the site, e.g. coarseness, hardness? What is the chemistry of PVC and any additional coating? What is the grinding effect of substrate, the tides, and the winds on the degradation of the PVC tubes? What is the distributional effect of the substrate, the tides, and the winds on microparticles? What is the distributional effect of hydraulic harvesting on microparticles? What metals (e.g. cadmium) or chemicals are "desorbed" from PVC into the water over time? What quantity? At the micro level: what is the effect of microplastics on the food chain? s C page99 mgs #.. Pugsj�L_a' 1 r The application barely touches these and other questions for this particular site. In addition, any reliance the application places on more general studies in federal Nationwide Permit 48 approvals with respect to plastics should be disregarded. These permits, including BDN-Smersh's, were invalidated by the U.S. District Court for Western Washington, on the grounds the US Army Corps of Engineers had failed adequately to analyze the effects, including cumulative effects, of some 900 shellfish permits in Washington, and had abdicated its responsibilities under the Clean Water Act and the National Environmental Policy Act.I Regarding plastics, Judge Lasnik said: The Corps' analysis with regards to plastic debris discharged into the marine environment is even more problematic. The Corps acknowledges the many public comments raising concerns about the introduction of plastics into the marine food web, but relies on the fact that "[d]ivision engineers can impose regional conditions to address the use of plastics" in response to these concerns. NWP003402. The Seattle District, for its part, declined to quantify the impact of plastics, instead noting that "it would not be a practicable solution to regionally condition NWP 48 to not allow the use of PVC and HDPE gear as there are no current practicable alternatives to use of the materials." COE 127559. The CWA requires the Corps to make minimal adverse effect findings before issuing a general permit. If, as appears to be the case with regards to the discharge of plastics from the permitted operations, the Corps is unable to make such a finding, a general permit cannot issue. The Corps has essentially acknowledged that it needs to individually evaluate the impacts of a particular operation, including the species grown, the cultivation techniques/gear used, and the specific location, before it can determine the extent of the impacts the operation will have.2 (emphasis added) In short, there simply isn't available an adequate analysis of the effects, especially the cumulative effects, of the 61 tons of plastic proposed for this site, in combination with many thousands of tons of plastic in use at many hundreds of shellfish farms in Hood Canal and Puget Sound' 1 Log Item 39, pp 215-138/561 z Ibid, p 234/561 'A 2014 estimate based on 2010 information no doubt underestimates the cumulative load of PVC tubes now, but: "The best current estimate according to the Shellfish Aquaculture Regulatory Commission, as of June 1, 2010, suggests there are currently 364 acres of active geoduck farms in Puget Sound. This represents nearly 3 thousand miles, 12 million pounds or 6 thousand tons of PVC in Puget Sound from geoduck aquaculture. If one assumes that at any given time only one-third of all geoduck farms have PVC tubes installed in the tidelands, then this would yield about 1 thousand miles, 4 million pounds or 2 thousand tons of PVC." (emphasis added) Item 8, "Scientific Evidence that Industrial Shellfish Aquaculture," Coalition to Protect Puget Sound Habitat, attached at the end of this subsection. C page100 LOG ITEAi.,' mgs Pi:i�j Y e &f J f'�— & -117 s C page101 mgs LOG ITEM Paw IC��_0_1 l 7 WHO calls for more research into microplastics and -a crackdown on plastic pollution Plastic accumulation in food may be underestimated (phys.ore) A comparison of microplastics in farmed and wild shellfish near Vancouver Island and potential implications for contaminant transfer to humans Murrspace.ca) iwiI;10I+]_0 L•Il�i] r.a IDUA-1111.1 plastic-food-chain.ipg {768x434) {wp.com] s C page102 &I!: •-' r:� „ ,+' P.O. Box 233 h ° ALITION t` Burley, WA 98322 (4—��To Protect Puget Sound -r^--- toalitiontoprotectpugetsound.org Page ,r� rl 7 Scientific Evidence that Industrial Shellfish Aquaculture "is Poisoning Our Shorelines" Section I - Aquaculture Gear and Toxic Plastic Pollution Summary of Recent Science Since the late 1990's, Washington State has allowed unlimited toxic, polluting plastics authorized in over 50,000 shoreline acres for geoduck, oysters and clams. PVC tubes, High Density Polyethylene (HDPE) canopy nets, HDPE oyster bags, HDPE zipties, HDPE oyster purses, HDPE mesh tubes and Polypropylene blue oyster ropes are routinely used. Carbon Black, the same additive used for tires, is added to the HDPE to absorb sunlight radiation. Shellfish industry plastic aquaculture gear has been scientifically examined and is a major threat to our marine life as documented in the studies cited below. 2018 "Abundance and Distribution of Microplastics within Surface Sediments of Key Shellfish Growing Regions of Canada. Bendell et al., PLOS One, May 23, 2018. Associated news article: "Alarmingly High Amounts of Plastic Microbeads Found in BC Shellfish Farming Areas" "Researcher says better standards needed for shellfish industry." "We found (shellfish industry) microbeads in the smallest bits of sediment and in a concentration equal to the amounts of silt and organic matter," Leah Bendell, Professor of Marine Ecology and Ecotoxicology at Simon Fraser University (SFU), said in the statement. Study states: "..the industry also makes extensive use of High Density Polyethylene (HDPE), in the form of netting, oyster bags, trays, cages and fences (e.g., vexar) [:= r ]. Each year, 3-4 tonnes of debris, comprised primarily of these plastic materials is recovered from the intertidal regions of Baynes Sound [38]. Sites where the greatest number of microfragments and microfibers were found also coincide with regions of extensive shellfish aquaculture equipment." Link: PLOS Journal Study: htt ://iournals. los.org/plosone/article?id=1 0. 1371 /journal. 12one.0196005 C page103 }}T P.O. Box 233 q�p ALITION LOG i + Ek. Burley, WA 98322 To Protect Puget Sound /„ coal itio nto protectp u g etsou n d.org PC4 is 117 Link: New Article: Abundance and Distribution of Microplastics - Bendell Article: 'Alarmingly high' amount of plastic microbeads found in B.C. shellfish farming areas: http://www.cbc.ca/news/canada/british-columbia/shelifish-rricroplastics-bc- a uaculture-1.4675672 2. 2018 "Macro and Micro Plastics Sorb and Desorb Metals and Act As A Point Source of Trace Metals To Coastal Ecosystems." Bendell et al., PLOS One published February 14, 2018. Associated news article: "Heavy Metals: The New Toxic Danger Posed by Ocean Plastic Trash." "For example, PVC, the most commonly found plastic, had high levels of lead and copper attached to its surface. The comparison of the new and debris plastic also showed how some of the chemicals used in plastic production may release overtime — including cadmium, which is used to make plastic rigid and resistant to UV light. The researchers found that new PVC releases zinc and cadmium. " The study found: "Field samples of PVC, HDPE and LDPE had significantly greater amounts of acid extracted copper and HDPE, LDPE and PUR significantly greater amounts of acid extracted zinc. PVC and LDPE had significantly greater amounts of acid extracted cadmium and PVC tended to have greater levels of acid extracted lead, significantly so for HDPE... Plastic debris will affect metals within coastal ecosystems by; 1) providing a sorption site (copper and lead), notably for PVC; 2) desorption from the plastic i.e., the "inherent" load (cadmium and zinc) and 3) serving as a point source of acute trace metal exposure to coastal ecosystems. All three mechanisms will put coastal ecosystems at risk to the toxic effects of these metals." Link: PLOS Journal Study: httpJ/iournals.,org/olosone/article?id=10.1371 /Iournal.pone. 0191759 Link: Macro and Micro Plastics. Bendel Article: https://www.newsdeenly.com/oceans/articles/2018/04/03/heavy-metal-the-new- toxic-danger-posed-bv-ocean-plastic-trash 2 C page104 P.O. Box 233 rw Tr N LOG IT 4 Burley, WA 98322 ALA 1 1�und L� ff -:! coalstionto rotect u etsound.or To Protect Puget Sound � p p g g Page 3. 2016 Microplastic Ingestion by Wild and Cultured Manila Clams from Baynes Sound, BC. Katie Davidson, Sarah Dudas. Arch Environ Contam Toxicol (2016) 71:147-156. Aquaculture Gear Microplastics: "The most commonly observed fibers in our study were colourless (36 followed by dark gray (26 %); in contrast with Desforges et al. (2014), blue, red, and purple fibers were considerably lower in abundance. Of the gray fibers recorded, 87 % were from farmed clams. It is possible the source of these dark gray fibers is the black anti -predator netting (APN) located directly above the clams, although without spectroscopic analysis (e.g., FT-IR) this cannot be verified. It has been suggested that clams might have highest concentrations of blue fibers due to the widespread use of blue polypropylene rope used on oyster farms located near clam farms throughout Baynes Sound." Link: Microplastic Ingestion by Wild and Cultured Manilla Clams htto://users.neo.re-gisteredsite.com/3/7/5/12218573/assets/2016 Davidson Duda s _Microplastic Ingestion by Wild and Cultured Manila_Clams.pdf 2017 KCTS 9 Interview with Dudas: "How Much Plastic Do You Want In Your Oysters and Clams?" "Others note that the world consumes hundreds of millions of tons of plastic annually -- like food packaging and straws. Dudas said that, while she is finding that farmed shellfish don't contain any more plastic than non -farmed shellfish, she has no doubt that nets and ropes from shellfish aquaculture sites also shed fibers into the ocean." Link: Dudas KCTS 9 Story: https:Ilkcts9.orplprograms/earthfix-localstories/how-much-plastic-do-yvu-want- in- our-o sters-and-clams 4. 2014 "Rapidly Increasing Plastic Pollution from Aquaculture Threatens Marine Life". Moore, Charles. 27 Tulane Env Law Journal 205 "CONCLUSION: Unmonitored and unregulated aquaculture activities around the world are poisoning and choking the marine environment with their lost and derelict plastic gear.... At the present time, it does not C page105 !-/'+ l'T'� P.O. Box 233 1 ALITION I Burley, WA 98322 7o Protect Puget Sound �� .. coal itiontoprotectpugetsou n d.o rg Pups / appear possible to introduce any conventional plastic into the marine environment without harmful consequences." Link: Charles Moore Tulane Environmental Law Journal: http://users.neo.registeredsite.com/3/7/5/12218573/assets/2014 CharlesMoore Tulane Plastic Pollution Threatens Marine Life.pdf 5. 2015 Bivalve Aquaculture Associated Plastic Pollution in South Puget Sound. Charles Moore, Renowned Marine Plastic Expert, Washington State Shorelines Hearings Board Presentation. Mr. Moore tested the PVC, HDPE and Polypropylene blue oyster rope gear used by Taylor Shellfish which are the standard plastics used by the aquaculture industry throughout the world. At the hearing, under oath, he stated: "The plastic gear used on the 11-acre site and the gear and parts of gear that leave the site are a significant adverse impact. No baseline is available to determine current levels of aquaculture debris in the subject inlets or South Sound aquaculture sites. The mitigation of beach cleanups is only a very partial solution to the impact problem and ignores microplastic pollution." Link: Charles Moore Presentation: htts://www.dro box.com/shl totz2w4im36bia/AAAxd5GSV7mnZ mvCLZ- aTEha?dl=0&0rey_i_ew=(17)+Charles+Moore+Al-qalita+Power+point. pdf 6. 2013. Long -Term Field Measurement of Sorption of Organic Contaminants to Five Types of Plastic Pellets: Implications for Plastic Marine Debris. Chelsea M. Rochman, Eunha Hoh, Brian T. Hentschel and Shawn Kaye. Environ. Sci. Technol. 2013, 47, 1646-1654. "The ingestion of plastic debris by marine animals, including invertebrates, fishes, sea turtles, seabirds, and whales, raises concerns that plastic is another mechanism for such chemicals to enter food webs. This mixture of hazardous monomers, plastic additives, and sorbed pollutants, may impose a multiple stressor to marine organisms upon ingestion." "Our data suggest that for PAHs and PCBs, PET and PVC reach equilibrium in the marine environment much faster than HDPE, LDPE, and PP. Most importantly, concentrations of PAHs and PCBs sorbed to HDPE, LDPE, and PP were consistently much greater than concentrations sorbed to PET and PVC. These data imply that products made from HDPE, LDPE, 4 C page106 ' ITEM Y' P.O. Box 233 r� OALITION # �� r �j, - Burley, WA 98322 7o Protect Puget Sound" coal itio ntoprotectp u getsound.o rg117 and PP pose a greater risk than products made from PET and PVC of concentrating these hazardous chemicals onto fragmented plastic debris ingested by marine animals. (See attached Rochman et. al study). Study News Link: htt s:/Avww.ucdavis.edu/news) lastics-and-chemicals-the -absorb- ose-double- threat-marine-life 7. 2015 Confluence Shellfish Industry Report Documents Birds Foraging on Harmful HDPE Plastic Oyster Bags - "Foraging in Shellfish Beds — in the photos note least sandpipers on oyster bags, dunlins on oyster bags, and godwits around and on oyster bags." Link: Confluence Report htt s://www.dro box.com/shl totz2w4'j36bia/AAAxd5GSV7mnZ mvCLZ- aTEha?d1=0& review= 18 +Confluence+Re ort%2C+Bird+Interactions+with+Sh ellfish+A uaculture+Gear+and+D erations. df 8. 2014 Calculation of Per Acre Plastic Pollution From Geoduck Aquaculture. Note: This calculation does not include the tons of plastics from oyster and clam aquaculture "The geoduck aquaculture industry embeds approximately 8 miles of PVC pipe per acre in pristine intertidal habitat areas of Puget Sound, mostly in South Sound. Based on the approximate weight per acre calculations provided by the geoduck industry, 4 inch schedule 10 PVC tubes, the smallest size used, weigh about 32,000 pounds, or 16 tons per acre of PVC. The best current estimate according to the Shellfish Aquaculture Regulatory Commission, as of June 1, 2010, suggests there are currently 364 acres of active geoduck farms in Puget Sound. This represents nearly 3 thousand miles, 12 million pounds or 6 thousand tons of PVC in Puget Sound from geoduck aquaculture. If one assumes that at any given time only one-third of all geoduck farms have PVC tubes installed in the tidelands, then this would yield about 1 thousand miles, 4 million pounds or 2 thousand tons of PVC." Link: Calculation of Geoduck Plastic Pollution: Link httr)://www.caseinlet.oEg/uploads/PVC.pdf 5 C page107 P.O. Box 233 ALITI ON µy; t�iv; ITC c- ?� y Burley, WA 98322 To Protect Puget Sound .' coalitiontoprotectpugetsound.org P y 7 9. Number of Geoduck Aquaculture Acres and Aquaculture Plastic Pollution According to industry figures, there are approximately 500 acres of geoduck aquaculture in Puget Sound. If the shellfish industry standard practice of 40,000 PVC or HDPE mesh tubes are inserted in the tidelands per acre, over 20 million pieces of polluting plastics will be "poisoning our shorelines." If the industry standard practice of using HDPE net caps and HDPE zipties are added to those PVC tubes, over 20 million-40 million more polluting plastics will be "poisoning our shorelines." 10. Carbon Black Shellfish -UV Stabilizer According to the September 28, 2016 email from Joth Davis, Taylor Shellfish biologist:: "Norplex manufactures shellfish cages that are used in the industry along with mesh tubes used for geoduck aquaculture and other netting products used by shellfish growers." "Mr Sanford reported that Norplex adds 6% "small carbon black" to the HDPE during the manufacturing process..." Carbon Black "is on the Right to Know Hazardous Substance List because it is cited by OSHA, ACGIH, NIOSH and IARC (NJ Department of Health Right To Know Hazardous Substance Fact Sheet). Fact Sheet Link: https:flni.gov/health/eoh/rtkweb/documents/fs/0342.pdf Section II -Shellfish Industry Use of Pesticides The shellfish industry has been spraying pesticides in Willapa Bay and Grays Harbor for over 50 years to eradicate both non-native Zostera japonica eelgrass and Spartina as well as native aquatic vegetation/eelgrass and native burrowing shrimp. The shellfish industry accidently brought in both Zostera japonica and Spartina with their non-native oysters. In addition, citizens in Puget Sound have reported to the Coalition and state agencies that shellfish industry growers have applied pesticides to shorelines where they have aquaculture sites. For more information on this issue, read the true story Toxic Pearl. Toxic Pearl Website: liltp l/www.koxlcT)earl.cony 2014. Major Pesticides Are More Toxic to Human Cells Than Their Declared Active Principles Mesnage, Defarge, de Vendomois, Seralini. 2014. BioMed Research International. 0 C page108 1J_),9 , P.O. Box 233 ALI T I O N t Burley, WA 98322 To Protect Puget Sound coal itio ntoprotectpu getsou n d.o rg "Glyphosate, isoproturon, fluroxpyr, pirimicarb, imidacloprid, acetamiprid, tebuconazole, epoxiconazole and prochloraz constitute, respectively, the active principles of 3 major herbicides, 3 insecticides, and 3 fungicides." "Most importantly, 8 formulations out of 9 were up to one thousand more toxic than their active principles. Our results challenge the relevance of the acceptable daily intake for pesticides because this norm is calculated from the toxicity of the active principle along. Chronic tests on pesticides may not reflect relevant environmental exposures if only one ingredient of these mixtures is tested alone." Page 1 Study Link: https://www.ncbi-nim.nih.gov/pmc/articles]PMC39G5660/ Section III -Mussel Cage Scientific Analysis -Per Mussel Cage Leader Maradel Gale, Bainbridge Island. "Every other year since 2011 at more than 70 sites around Puget Sound, mussels are set out in cages for three months over the winter and then analyzed to determine the contaminants in their bodies. Like other bivalves (clams, oysters, geoducks), mussels are filter feeders, which means they in - filter whatever is in the water around them. The most abundant contaminants. measured were PAHs, PCB's, PBDE's and DDT's (see technical names below). The first two organic contaminants were found in mussels from every site. The amount of contamination varied and was higher at more urban sites, as measured by land use classifications and by the percent of impervious surface in the upland watersheds adjacent to the nearshore where the mussels were placed. Additionally, heavy metals (zinc, arsenic, cadmium, copper and mercury) were found in mussels from all of the study sites; lead was found in mussels from most sites, but not all. Issues with microplastics and persistent organic pollutants are closely interrelated. This is because the organic pollutants are hydrophobic and adsorb onto the microplastics, which are the same size as zooplankton and thus are in -filtered by the bivalves, where the organic pollutants desorb in the gut of the animal." PAH-Polycyclic aromatic hydrocarbon PCB -Polychlorinated biphenyl PBDE-Polybrominted diphenyl ethers DDT-Dichlorodiphenyltrichloroethane C page109 LOG iTFNA P.O. Box 233 �OALITION Burley, WA 98322 To Protect Puget Sound ��? ,�. coal itiontoprotectp u getso u nd.org Psge / / 4- _0' / (7 Section IV -Lack of Testing of Toxins in Washington State Shellfish By the Washington State Department of Health Email from the Washington Department of Health From: Toy, Mark C (DOH) <Mark.Tov cr doh.wa.grav> Date: Tue, Feb 12, 2019 at 12:09 PM Subject: Shellfish question Dear Stella — You asked Can you tell me if the DOHroutinely tests commercial and recreational shellfish for pesticides and heavy metals? Anyway, that question got bounced to me so I will take a stab at it and am cc:'ing everyone else you e-mailed so they have a future reference. The short answer is no, except for geoducks which are tested for arsenic routinely because that is a requirement for export to China (htt s://www.doh.wa. ov/Communit andEnvironment/Shellfish/CommercialShellfi_ sh/Export/ExporttoChina) . DOH did a comprehensive survey of toxics in shellfish in the 90's (see attached report) and found generally low (or below limits of detection) concentrations of 105 contaminants (see page 8 for list) except for Eagle Harbor (Prohibited area). NOAA implements Mussel Watch nationally (https://en.wikipedia.orcl/wiki/Mussel Watch Program), and WDFW implements this in Washington State. Here is a good local presentation on the Mussel Watch program, which tests (ideally on a biennial basis) for a variety of contaminants (including organochlorine pesticides) https:/Isoundwaterstewards.org/web/wt)- co ntent/u P1 oad s/2014/09/M usselWatch Program -presentation- Wh id bey Isla nd Rea ch Watchers-9-8-2014 . Pdf DOH does environmental site assessments where we have concerns about legacy pollution, particularly in areas where we are considering an initial classification. There are three site assessments done in Pierce County for shellfish and sediments: https://www.doh.wa.gov/DataandStatisticaIRppgrts/EnvironmentalHe alth/SiteAssessments#Pierce On this website you will find other assessments in Oakland Bay, Port Gamble, Irondale, and Port Angeles Harbor (to name a few). Hopefully this satisfactorily answers your question. Let me know if you have any additional questions or concerns. C page110 _i ALITION To Pralecl Puget Sound Mark Toy Environmental Engineer Office of Environmental Health & Safety Environmental Public Health Division Washington State Department of Health P.O. Box 233 Burley, WA 98322 coalitiontoprotectpugetsound.org (l7 Summary Our Question -Would you eat food raised in toxic PVC, HDPE or Rubber Tires? Should our native species be subjected to these toxic plastics and pesticides when their populations are dramatically declining in favor of shellfish exports? Tell your local, state and Federal officials that these polluting plastics and pesticides should not be allowed in Washington State marine waters! Compiled by the Coalition To Protect Puget Sound March 2019 2 C page111