HomeMy WebLinkAbout083 Response to CommentsFrom: Ken Sheppard <KSheppard@sksp.com>
Sent: Monday, April 11, 2022 5:44 PM
To: Donna Frostholm; Philip Hunsucker
Cc: Brad Nelson
Subject: RE: MLA19-00036 BDN
Attachments: Response Smersh Dittmar - MLA19-00036 BDN.pdf; Dungeness Crab Research
Guide.pdf; Comment Matrix. - MLA 19-00036 BDN.pdf
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Hello Donna –
Here are additional materials connected with our comment response:
1) A table showing the topics addressed by each commenter. As you can see, all but a few were
covered by Marilyn Showalter’s comment, so I have not submitted separate responses for those
other comments on such topics . Of course, it there is an issue in one or more of those
comments that you feel I have not addressed, please let me know.
2) Response to Steve Dittmar comment, particularly his claims about area crab population.
Portions of this comment were not addressed by Ms. Showalter, so I am submitting a separate
response.
3) I note that the Department of Ecology submitted a comment about the possible requirement of
an updated eelgrass study because “more than three years have elapsed.” I don’t understand
the three year time period to be any kind of regulatory requirement. Because there has been no
aquaculture activity on the proposed site since the last study, we do not think such a new study
is necessary, especially with the permit requiring BDN to stay 16’ away from any native eelgrass.
A study can be done, however, if required. It is very expensive, and cannot be done until later in
the year when eelgrass is actively growing, so we would like to be able to avoid the time and
expense of a third verification of the project area if at all possible.
4) The Ecology comment also mentions erosion and stormwater runoff. I did not respond
specifically to that because we have previously submitted an stormwater packet that addresses
this. Again, let me know if there is something else that you require on this.
Please indicate if there is anything else we need to provide to you at present. We want to be as
cooperative and responsive as possible.
Ken
Apr 11 2022
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Kenneth A. Sheppard
Ketter, Sheppard & Jackson, LLP
50 116th Ave. S.E., Suite 201
Bellevue, WA, 98004
(206) 382-2600
Fax: (206) 223 3929
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BDN Response – Dittmar (Smersh) – Page 1
RESPONSE OF BDN, LLC TO THE COMMENT OF STEVE DITTMAR
BDN LLC Geoduck Farm MLA19-00036 BDN
April 8, 2022
BDN, LLC responds to Mr. Dittmar’s comments as follows:
1) “Unnatural Concentrations of Geoducks in one small Squamish Harbor”. Mr. Dittmar’s calculations of
the numbers of geoduck anticipated on the proposed project per acre is not correct. While the permit
requests the ability to plant in tubes spaced “approximately” one per square foot apart, BDN’s
experience in actual planting on its existing tracts turns out to be more in the order of 20,000 tubes per
acre, taking into account project areas that are too shallow or otherwise unsuitable. So the survival rate,
with three seed per tube, would be more on the order of 40-60,000 geoducks per acre. Only about 3.5
acres of the Smersh tract is actually plantable within the allowed 5.15 acre area, so the realistic potential
number of geoducks would theoretically be more in the order of 140,000 to 210,000 total, not 400,000.
That 3.5 planted acres will not contain mature geoducks at all times – portions will always be vacant or
newly planted with seed or very small geoducks. Moreover, geoducks are dormant during large parts of
the year, and are not filtering when the tides are out every day. So the “unnatural load” on the water
column is actually much, much less than Mr. Dittmar contends. Regardless of the filtration rates of
geoducks on the project, Mr. Dittmar presents absolutely no evidence that such filtration would actually
be harmful to anything, and ignores the evidence that such filtration actually improves water quality.
But the more important issue is what Mr. Dittmar then attempts to extrapolate from his inaccurate
figures – “the degradation of our crab population here in the harbor.” He bases this on his personal
observation that the Dungeness crab population has declined in the less than ten years he has owned his
property. He opines, without any proof, that the geoducks on the existing BDN farm must of course be
consuming crab larvae and directly causing this decline. He provides no evidence or proof of this.
What is the actual evidence on this issue? The same assertion that geoducks consumed larvae was made
in the Washington Shorelines Hearings Board case of Coalition To Protect Puget Sound Habitat And Case
Inlet Shoreline Association, Petitioners v. Pierce County And Longbranch Shellfish, LLC, SHB No. 11-019
July 13, 2012. The Board, after careful consideration of the scientific evidence supporting each claim,
held that:
“Petitioners’ experts raise questions about the ingestion of forage fish larvae by geoducks. They testified
that there is insufficient data on this question but that it could hypothetically happen. Penttila Testimony;
Daley Testimony. [The farmer’s] expert was able to rebut these concerns regarding predation of
zooplankton by geoducks. The filtration rate of geoducks is relatively low compared to other bivalves.
There is no access to seawater more than a few centimeters above the tip of the siphon, and therefore
there is limited access by the geoducks to the water column. During the winter months, when forage fish
spawn and feed, geoducks are relatively dormant and do not compete with forage fish or salmon for food
resources. Davis Testimony; Ex. L14. An earlier study suggests that geoducks feed exclusively on
phytoplankton and not zooplankton. Ex. L9V at 97. There is no evidence that farmed geoduck will cause
adverse impacts to forage fish or salmon by depleting food resources.”
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BDN Response – Dittmar (Smersh) – Page 2
So the actual science is that geoducks do not consume fish or crab larvae, and do not compete with other
juvenile wildlife for food resources.
There is no doubt that the Dungeness crab population in Puget Sound, and in south Puget Sound in
particular, is declining. But why? That question is being intensively studied on several fronts. The
Washington Department of Fish and Wildlife examines the issue at https://wdfw.medium.com/wdfw-
works-to-manage-and-restore-dungeness-crab-in-washington-waters-4e507e00a813 . Possible causes
being reviewed are “the effects of changing ocean conditions – which may include warming surface
waters, ocean acidification, pollutant levels, and hypoxia.” Clam population or effects are not
mentioned.
This issue has also been studied since 2018 by the Pacific Northwest Crab Research Group, a collaborative
collection of partners from tribal, state and federal governments, as well as The Universities of
Washington and Oregon. Attached is the 2020-2025 Pacific Northwest Dungeness Crab Research Guide.
It mentions a number of theories being studied as the possible cause of the decline, including various
diseases, loss from handling injury by crab fishermen, and biotoxins (domoic acid in particular.) the only
mention of clams anywhere in any of these materials is the proposition that invasive European Green
Crabs may be outcompeting Dungeness for the clams that both species feed on (i.e that too few clams,
not too many, may be a problem for Dungeness crabs.)
Mr. Dittmar’s unsupported and inaccurate allegations and conclusions are irresponsible in the extreme.
2) Tube Escapement It’s a bit hard to tell from his description exactly where Mr. Dittmar’s 2015 dives
took place, but it appears they were mostly along the deep-water edge of the properties owned or leased
by BDN, and perhaps 200-300’ further to the west. The submerged tubes Mr. Dittmar describes seeing
and photographing appear to have been almost exclusively in water south of BDN’s properties at depths
of 6.5 to 16.5 feet below MLLW – in other words, they could not have been seen by BDN beach patrols,
and were beyond the depth that BDN divers typically worked in. It would appear that Mr. Dittmar did
not see large numbers of deep-water dislodged tubes west of the BDN properties, or rest assured he
would have pointed this out.
The “Brad Nelson Message to the Squamish Bay Community”, previously submitted, describes this
situation and BDN’s response:
“On a normal beach maintenance day in July of 2015, I saw my neighbor Steve come down to the
beach in a dive suit and snorkel gear. I thought that’s pretty cool, I didn’t know he liked to
snorkel. When he was finished, he walked right past me. I asked him if he had seen anything
interesting, but he did not reply. Maybe he didn’t hear me.
A few days later, I received a notice from the Army Corp, including pictures, informing me that
there were dislodged tubes in deeper water below the low tide line. I had no idea that tubes
would go down there, and this was the first time I became aware of this. In all my previous
experience I thought that dislodged tubes had been washed into shallower water and down the
beach to the west. In order to behave responsibly, we immediately began deeper water diving
tube recovery surveys and did locate and recover quite a few dislodged tubes. Since that time
we schedule no less than 4 annual deeper water dive missions to recover such tubes, even
though the Army Corp only requested one per year.”
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BDN Response – Dittmar (Smersh) – Page 3
Photos submitted by Marilyn Showalter in her recent submissions show the BDN vessel conducting
just such a dive mission a few weeks ago.
The point being that once it became apparent to BDN that some tubes were escaping to deeper
water, it has established a program to effectively address that issue, in excess of the response
required by the Corps, and has been doing so effectively on its current tract. That same system can
be a condition of the permit on this new tract, and will also effectively address that issue here.
3) Plastics Pollution Like some other commenters, Mr. Dittmar contends that “PVC material does
decompose and faster than previously thought and breaks off little bits that get ingested by the
critters” This is simply not the case with the marine grade PVC used by BDN.
There are numerous studies and cases that establish that the rigid marine grade PVC plastic tubes to
be used by BDN will not have any adverse ecological impacts. The Shorelines Hearings Board has on
multiple occasions affirmed the use of plastics in shellfish aquaculture operations. Coalition to
Protect Puget Sound Habitat v. Pierce County, SHB No. 11-019 (July 13, 2012); Coalition to Protect
Puget Sound Habitat v. Thurston County, SHB No. 13-006c (October 11, 2013); and Coalition to
Protect Puget Sound Habitat v. Pierce County, SHB No. 14-024 (May 15, 2015). The Board rejected
the claim that the PVC tubes to be used here degrade into microplastics, SHB No. 11-019 (FF 9); SHB
No. 13-006c (FF 41-42 and COL 16); SHB No. 14-024 (FF 44-47 and COL 13, 20), release chemicals,
SHB No. 110-019 (FF 11), cause significant marine debris, SHB No. 11-019 (FF 10 and COL 6, 14); SHB
No. 13-006c (FF 36-39 and COL 16); SHB No. 14-024 (FF 39-43, 47 and COL 13, 20), or threaten fish
and wildlife, SHB No. 13-006c (FF 40 and COL 42); SHB No. 14-024 (FF 26, 27 and COL 17).
The Washington Department of Ecology, during its review of a proposed City of Bainbridge Island
Ordinance regulating the use of plastics in aquaculture, specifically found that: "The marine grade
plastics currently used [in aquaculture] are specifically designed to resist breaking down in the harsh
marine environment. Without evidence of an impact related to marine grade plastics this
prohibition is not supported by current science, data, or other technical information." Department
of Ecology informal response to Bainbridge Island Aquaculture SMP amendment, Ordinance 2016-6,
2016.
Laboratory test results of sediment samples taken from within active geoduck tube fields
demonstrated the absence of microplastics. Coalition To Protect Puget Sound Habitat And Case Inlet
Shoreline Association, Petitioners v. Pierce County And Longbranch Shellfish, LLC, SHB No. 11-019
July 13, 2012. Baker Testimony; Ex. L5, Appendix B. Additional expert testimony described the
absence of plastic in the stomach contents of 235 fish captured near active geoduck tube fields.
VanBlaricom Testimony.
There is simply no evidence that the marine grade PVC used by BDN leaches microplastics into the
environment, no matter how hard Mr. Dittmar and other commenters attempt to weaponize this
incorrect contention.
4) The need for baseline scientific data to assess the cumulative impacts. The Corps asked that this
issue be addressed in its review of Mr. Dittmars comment submitted to it in connection with BDN’s
individual Corps license application. That data is provided in great detail in the “Smersh Farm
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BDN Response – Dittmar (Smersh) – Page 4
Habitat Management Plan and No Net Loss Report” referenced above and in the eelgrass surveys of
the site, all of which are included in the BDN application.
The “Proposed Smersh Geoduck Farm: 2018 Zostera marina bed edge re-verification, July 9, 2018
and the Biological Evaluation Addendum dated October 15, 2020 show baseline data for eelgrass.
The Habitat Management Plan and No Net Loss Report shows baseline data for Noise ( Page 9)
Water Quality (Page 10), Sediment Quality and Transport (Pages 17-19), Fish (Pages 19-22),
Waterfowl (Page 24) Aquatic Vegetation (Page 22) and Plastics (Page 27.)
Thus, every baseline element in the vicinity of the project has been established.
CONCLUSION
Unlike some forms of aquaculture, geoduck farming does not introduce non-native species into the
environment, and does not pollute or degrade the surrounding waters with introduced feed or
chemicals. In fact, research has shown that farmed geoducks do not damage the surrounding water
quality or environment, and may actually improve water quality and biodiversity in the areas where
they are grown. Ecological Effects of the Harvest Phase of Geoduck (Panopea Generosa Gould, 1850)
Aquaculture on Infaunal Communities In Southern Puget Sound, Washington, VanBlaricom et al.,
Journal of Shellfish Research, Vol. 34, No. 1, 171–187, 2015. This is one reason why the proposed
use by BDN of the property for a geoduck farm is not only allowed but is preferred under
Washington law (See WAC 173-26-241(3)(b)(i)(A).) Consistent with those regulations, The minimal
visual and noise impact of the project is far outweighed by its positive economic and environmental
impact.
BDN, LLC
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BDN Response – Dittmar (Smersh) – Page 5
Extensive Cumulative Impact Studies have been done on this project, for use both in the
pending Jefferson County SEPA determination and, as appropriate, in this proceeding. They are
attached. These studies find that “ the proposed project would have minimal negative impact
on the local shoreline and some beneficial impacts.” (Smersh Farm Cumulative Impacts Report,
September 2020, Page 9.) The problem from Mr. Wenman’s standpoint seems to be that they
do not reach the conclusions he desires, and since he has nothing to counter their on-the-
ground, project specific studies and observations, he ignores them. The project is fully
complaint with the provisions of SEPA via its submittals to Jefferson County, and with NEPA via
its submittals here.
“Credible scientific evidence in the record supports the conclusion that geoduck aquaculture
generally and, as proposed to be operated at this site specifically, is not a significant concern
for long-term risk to the plants, animals, and physical characteristics of the shoreline. On the
contrary, the evidence demonstrates that effects of the proposal would be highly localized and
short in duration. Studies and articles offered in opposition to the application do not
controvert the findings of the site-specific evaluations in evidence and the findings of the
Washington Sea Grant research program. No substantial evidence was offered in support of
alleged impacts to recreational values and community use of the shoreline. The Farm would
not interfere with navigation, existing public recreational facilities, or community use of the
tidelands via boats, kayaks, or other means. The Farm would not obstruct views, would be
completely submerged for the vast majority of daylight hours, and would be required to
comply with numerous conditions to minimize and mitigate aesthetic impacts. The record
contains no evidence demonstrating that the Farm would result in cumulative impacts.”
Thus, the fact that the proposed project in a shoreline of statewide significance does not
disqualify it unless it is shown to have “impacts that risk harm to habitat, loss of community
use, or a significant degradation of views or aesthetic impacts.” Even in such cases, a
cumulative impacts analyses can be used to evaluate these impacts.
That is exactly what has been done here – a cumulative impacts analysis of a project of
statewide and national interest demonstrates that the proposed project will have no adverse
impact on the “shoreline of statewide significance” in which it will be located.
5) Baseline Analysis. The Corps has inquired as to “[t]he need for baseline scientific data to
assess the cumulative impacts of the proposed project. That data is provided in great detail in
the “Smersh Farm Habitat Management Plan and No Net Loss Report” referenced above and in
the eelgrass surveys of the site, all of which are included in the BDN application.
The “Proposed Smersh Geoduck Farm: 2018 Zostera marina bed edge re-verification, July 9,
2018 and the Biological Evaluation Addendum dated October 15, 2020 show baseline data for
eelgrass. The Habitat Management Plan and No Net Loss Report shows baseline data for Noise
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BDN Response – Dittmar (Smersh) – Page 6
( Page 9) Water Quality (Page 10), Sediment Quality and Transport (Pages 17-19), Fish (Pages
19-22), Waterfowl (Page 24) Aquatic Vegetation (Page 22) and Plastics (Page 27.)
Thus, every baseline element in the vicinity of the project has been established.
CONCLUSION
Mr. Wenman’s comment is primarily a survey of all of the laws and regulations he contends
apply to the project. All of these laws and regulations taken together do establish the
overriding concern of legislators and regulators that a shoreline activity must not have a
substantial net negative effect on the environment, either individually or cumulatively.
The problem with Mr. Wenman’s comment is that he then assumes that the proposed project
must by its very nature violate those standards, without presenting any proof the this is so. His
approach seems to be “well, this sure looks ugly to me, and it could be having some negative
effects, so we must therefore assume it is damaging the environment.” In fact, the proposed
project will on the whole have positive environmental effects, Ecological Effects of the Harvest
Phase of Geoduck (Panopea Generosa Gould, 1850) Aquaculture on Infaunal Communities In
Southern Puget Sound, Washington, VanBlaricom et al., Journal of Shellfish Research, Vol. 34,
No. 1, 171–187, 2015, which is one reason why it is a preferred statewide activity under WAC
173-26-241(3)(b)(i)(A).)
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1
2020-2025 Pacific Northwest Dungeness Crab Research Guide
Report Leads: Emily Buckner (Puget Sound Restoration Fund) and Angela Cruz (Washington Sea Grant)
Contributing Editors: Julie Barber (Swinomish Indian Tribal Community, SITC); Katelyn Bosley (Washington
Department of Fish and Wildlife, WDFW); Rich Childers (WDFW); Claire Cook (SITC); Sarah Grossman (SITC); Neil
Harrington (Jamestown S'Klallam Tribe, JST); Matt Nelson (SITC); Emma Saas (Suquamish Tribe) and Elizabeth Tobin
(JST)
Background & Need for Research
Dungeness crab (Metacarcinus magister) are decapod crustaceans that inhabit coastal and estuarine
waters ranging from the Pribilof Islands, AK to Baja, Mexico (Hart 1984, Jensen & Armstrong 1987).
Throughout its range, Dungeness crab serve as the backbone to many West Coast communities who rely
on the species due to their cultural, ecological, and economic importance. For example, the Dungeness
crab fishery is one of the highest valued and heaviest exploited along the West Coast. In Washington
alone, the non-tribal commercial harvest of this species brings in an annual ex-vessel value around $70m
USD (Puget Sound and coastal fisheries combined; WDFW unpub. data, 2021) and an average of 220,434
recreational licenses are sold per year (Puget Sound Partnership Vital Signs); this supports many local
communities and a global seafood industry. Despite its importance for both tribal and non-tribal
communities of the eastern Pacific Coast, many questions regarding how Dungeness crab populations
vary and interact with the ecosystem remain unanswered. These significant gaps in our understanding
have become particularly evident as harvest in some historically productive areas has declined1, raising
questions regarding the status of M. magister populations and the sustainability of harvest. In addition
to questions of sustainability, it is unclear how vulnerable the species and fishery are to changing
climate and ocean conditions (Froehlich et al. 2017). Given these concerns, there is a need for an
immediate and coordinated response to fill essential data gaps to better inform the management of this
species.
Dungeness Crab Biology & Ecology
Dungeness crab have multiple developmental stages which occupy distinct habitats throughout their
lifecycle (Lough 1975, Methot 1989). Beginning as planktonic larvae, newly hatched Dungeness crab are
1 Prior to 2015, total Dungeness crab harvest in the southern portion of Puget Sound (Crab Regions 6
and 7) averaged 364,000 lbs. (~165,000 kg) annually (WDFW, unpub. data, 2021). By 2018, harvest
dropped below 45,000 lbs. (~20,400 kg) prompting closure of the fisheries in those regions. Since that
time, crab populations in Regions 6 and 7 have not recovered. The crab fishery has remained closed in
Region 7 and only a very limited fishery has been permitted in Region 6 (WDFW, unpub. data, 2021).
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released into the water column, where they progress through five zoeal and one megalopal stage over a
period of four months (ranging from 115 days in California to 154 days in Alaska) before transitioning to
benthic habitats as juveniles (Rasmuson 2013). Larval Dungeness crab are strong swimmers, occupying
surface waters during the early evening/night and at depth during daylight hours (Jamieson & Phillips
1993). Juvenile crab (instars) preferentially settle in structurally complex intertidal and shallow subtidal
habitats (McMillan et al. 1995, Galloway & Shanks 2017). Young-of-the-year juvenile instars rear in these
protective habitats for six to 12 months, before migrating to deeper habitats (Dinnel et al. 1987,
Armstrong et al. 1989). Dungeness crab reach sexual maturity around two years of age (up to five years
for slower growing populations). Females carry between 1.5 and 2.5 million eggs, which hatch between
December and June (as reviewed in Rasmuson 2013).
Adult and juvenile Dungeness crab are opportunistic feeders in both estuarine and subtidal habitats,
feeding on bivalves, fishes, shrimp, and other crabs (Stevens et al. 1982, Lawton & Elner 1985, Jensen &
Asplen 1998). Juvenile crab are often eaten by demersal fishes like flounder, sole, and sculpin
(Armstrong et al. 1995, 2003), as well as shore crabs and the introduced European green crab (Carcinus
maenas) (McDonald et al. 2001). Dungeness crab often travel great distances to feed, balancing food
resource availability against predation risks (Holsman et al. 2006). Adult Dungeness crab have few
predators, but are known to be eaten by lingcod, cabezon, wolf eels, octopuses, and sea otters (Reilly
1983, Garshelis et al. 1986). In addition to predation, other threats to the species include hypoxia (low
oxygen content) (Bernatis et al. 2007, McGaw 2008, Chan et al. 2019), ocean warming and acidification
(McConnaughey et al. 1995, Sulkin et al. 1996, Bednaršek et al. 2020), sedimentation particularly due to
dredging (Chang & Levings 1978, Armstrong et al. 1987), and vulnerability of larvae to disease,
pesticides, and other pollutants (e.g., metals) (Buchanan et al. 1970, Armstrong, Buchanan, & Caldwell
1976, Armstrong, Buchanan, Mallon, et al. 1976, Fisher & Nelson 1977, Caldwell et al. 1978, Martin et
al. 1981).
Photo caption: Dungeness crab at several life stages (left to right): megalopal (two different cohorts shown),
juvenile instar, and adult. All photos taken in Puget Sound, WA by the Swinomish Indian Tribal Community.
Although the biology and ecology of Dungeness crab is relatively well-understood compared to other
marine invertebrates, fundamental gaps still exist, notably in crab populations within inland waters,
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such as the Salish Sea. There is currently a lack of information regarding the spatial and temporal
distribution of larvae and juvenile settlement, adult migration patterns, genetic population structure,
and environmental influences on vulnerable life history stages. Given the unprecedented changes
happening to our global environment, it is more important than ever to better understand the biology
and ecology of this iconic species. This critical need for research and the collective interest in pursuing
collaborative research to address data gaps prompted the formation of the Pacific Northwest Crab
Research Group with the goal of pursuing a collaborative approach to generate and share information
needed to learn more about the marine environment and ensure a sustainable future for Dungeness
crab and the communities that rely on them.
Who We Are
The Pacific Northwest Crab Research Group (PCRG), formed in 2018, is a consortium of scientific
research partners, resource managers, and community members looking to address critical research
gaps in our knowledge of Dungeness crab. Working with the mission to promote and support sustainable
Dungeness crab populations in the Pacific Northwest, the aim of PCRG is to bring together scientists and
stakeholders from different disciplines and specialties relevant to Dungeness crab to: define and
prioritize research questions; identify how PCRG can best tailor its research to inform resource
managers; and share research results from PCRG activities. As a collective network, the goals of PCRG
are to pursue collaborative research to:
1. Monitor crab populations and develop tools to forecast crab abundance;
2. Better understand and sustain the ecological role of crab; and
3. Produce information addressing multiple critical data gaps for Dungeness crab.
The group works to implement these goals by developing collaborative projects and by facilitating
information and knowledge sharing between members. Projects are funded by a combination of
avenues including grants solicited by PCRG as a group and individual project components led by PCRG
member teams.
Prioritizing Research
The purpose of this research guide is to document the current research topics/questions identified and
prioritized by PCRG regarding Dungeness crab biology and management. Together, management
priorities and research questions highlighting knowledge gaps act to direct the research pursued by the
group (Fig. 1). Below we identify the top 10 research questions prioritized by PCRG members and discuss
how to move towards information-driven action.
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Figure 1. Schematic indicating how PCRG
research is determined. Management
priorities identify research topics and
knowledge gaps, from which research
questions can be developed to
inform/direct PCRG research efforts. The
knowledge derived from those strategic
research efforts ultimately integrate into
management and can be used to
influence new manager priorities.
Management Priorities
The PCRG is not a management entity, and as such, has no decision-making authority over Dungeness
crab fisheries. However, PCRG plays a role in supporting fishery managers by providing baseline data
that is critical for making informed decisions about the resource. Therefore, in order to pursue research
that is the most relevant for informing management, the needs of fishery managers must be considered
in the research prioritization and planning phase. During the winter 2020 workshop, PCRG members
(including several Washington crab co-managers) identified PCRG’s major management topics, as they
relate to the Dungeness crab fishery. Through this process, the following six priority management topics
were identified: Population Assessment; Spatial and Temporal Management; Adaptive Management;
Habitat Conservation and Mitigation; Diseases, Pests, and Pollution; and Fishery Impacts. Participants
then ranked these topics in order of relevance and priority for managers and fishery sustainability (Fig.
2). These focal management topics are discussed in detail below.
Note that because of the Washington-specific expertise of group members who participated in PCRG
workshops, these topics were primarily determined based on Washington fishery issues, and are
described with that geographic focus, though these issues can likely be extrapolated to other regions.
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Figure 2. Management topics by order of importance, as determined by PCRG Winter 2020 Workshop
participants. It is important to note that lower ranking topics are not lacking in importance. Indeed,
there are so many gaps in the literature that research focusing on any of these topics can be used to
improve management of the fishery. The higher ranking topics represent the most pressing topics in
light of the lack of current information and management structures.
Population Assessment
Population assessments, or stock assessments, are a tool used to estimate the abundance of a given
biological population. These assessments are generally based on an integrated modeling framework
which incorporates several data sources to provide an estimate of a species biomass in a given area
including fishery harvest data, population structure and life history parameters (i.e., growth rates,
sexual maturity, recruitment success, mortality rate; NMFS 2001). Because of their reliance on a wide
range of data, these types of assessments are often found to be the most reliable means to estimate the
status of fisheries stocks (Branch et al. 2011). Stock assessment outputs not only provide information on
stock productivity, they are also important when developing sustainable fishery management practices
designed to maximize yield while minimizing the risk of overfishing (NMFS 2001).
Despite its high commercial value, no formal stock assessment exists for Dungeness crab in Washington
state. Though the fishing rates are well tracked and recorded, this species’ absolute population
abundance remains unknown. Currently, the only population abundance information for Dungeness
crab comes from fishery landings data and some annual pre- and post-harvest population surveys
conducted specifically to assess the availability of legal-sized males. The overall dearth of high-quality
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and complete life history and abundance data, which are required to construct an accurate population
model that encompasses all life history stages, remains the primary challenge in producing a reliable
Dungeness crab stock assessment.
The population assessment management topic was ranked as the most important by PCRG members
for ensuring the sustainability of the Dungeness crab fishery. Thus, research focused on acquiring data
needed to create a population assessment model should be prioritized (see research gaps highlighted
under Population Status, Structure and Dynamics).
Spatial & Temporal Management
Spatial and temporal management refers to the scale in which fishery management practices are
applied. Spatial management units are typically defined by geographical and/or political boundaries
which are often misaligned with the true spatial structure of the harvested resource (Berger et al. 2020).
Within a spatial management unit, the applied management procedures typically assume a closed
homogeneous population, ignoring heterogeneity in population vital rates and connectivity among
adjacent management units (Kerr et al. 2017). In recent years, fishery management practices have
evolved to accommodate the need for more refined spatial management through the development of
tools to identify complex population structure (e.g., genomics and tagging) and population assessment
models that account for stock heterogeneity (Cadrin 2020, Bosley et al. 2021). However, for the
Dungeness crab fishery, the temporal and spatial resolution of the data needed to apply these advanced
techniques are lacking, therefore the ability to align spatial management practices with true biological
population structure remains limited.
Dungeness crab management in Washington’s inland waters is spatially and temporally complex, with
many small discrete spatial management units and a protracted fishing season. Fisheries are generally
timed to avoid vulnerable life stages of the species to preserve the stock (e.g., closed fishing during the
molting period for Dungeness crab). Since the 1940’s the ‘3-S’ management scheme has largely proven
effective in maintaining sustainable harvest on the U.S west coast, where harvest is managed (1) with a
minimum size limit, (2) by only allowing males to be harvested and (3) by setting seasons to protect soft-
shelled crab (Richerson et al. 2020). As climate change becomes a more prominent threat to the
Dungeness crab fishery, managers are concerned about the resiliency of the ‘3-S’ management scheme
under changing ocean conditions. Warming waters may impact molting patterns and growth trajectories
which could impede the current management scheme and potentially reduce protection to vulnerable
life stages. Therefore, it is essential to have a thorough understanding of Dungeness crab life history and
how population vital rates are expected to change across space and through time. High quality
population data is needed at spatial and temporal scales that allow managers to assess effectiveness of
the current management strategy and management units, identify the time and location of optimal
harvest opportunities, and determine when and where to enact conservation measures if needed.
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Photo caption: Co-managers for the Washington state Dungeness crab fishery, such as the Department of Fish and
Wildlife (WDFW, left) and treaty tribes (right) conduct research to better understand population dynamics. Photo
credit: WDFW and Swinomish Indian Tribal Community
Adaptive Management
Adaptive management is an approach to dealing with large uncertainty in a fishery and describes the
approach used to respond to problems in real time by having the necessary baseline information about
the resource and its environment (Walters 2007). This approach is often colloquialized as “learning by
doing”, meaning management needs to be implemented as an experiment and readily adjusted given
new data or situations (Halbert 1993). The process of adaptive management is often challenging,
requiring planning from the onset to define management questions and acquire adequate baseline data
(Reever Morghan et al. 2006).
Fisheries are inherently variable and prone to unexpected shocks and natural cycles with climate change
creating even more uncertainty (Cheung et al. 2010, Quentin Grafton 2010). The Dungeness crab fishery
is no exception, experiencing fluctuations in harvest from season-to-season (Botsford et al. 1982,
Armstrong et al. 2011) and spatial and temporal changes in the population (WDFW unpub. data, 2021).
Recent investigations into potential climate change impacts show deleterious effects to larval
development when exposed to increasingly acidic ocean conditions (Bednaršek et al. 2020). In order to
establish a more resilient and climate-ready fishery in the face of changing ocean conditions, managers
need to build a more holistic understanding of Dungeness populations within specific regions (e.g.,
Puget Sound sub-basins), as well as acquire real-time data on ocean and population conditions. Much of
the information necessary for designing and implementing adaptive management frameworks is also
required for population assessments and spatial and temporal management.
Habitat Conservation, Restoration, and Mitigation
Habitat conservation, restoration, and mitigation are common management considerations in
sustainable fisheries, as a healthy habitat is important for maintaining a robust stock. In order to
conserve and restore habitat for Dungeness crab, it is essential to identify critical habitats and quantify
use and importance by the species across various life stages. Habitat preference is well documented;
juveniles settle in highest abundances in shallow nearshore, estuarine environments with complex
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three-dimensional habitat, such as oyster shell or eelgrass coverage, while adults are typically found
from the intertidal up to 230m depth on sandy-mud bottoms (Holsman et al. 2006; Cleaver 1949;
McMillan et al. 1995). What is less well known, particularly within the Salish Sea, is how, when, and why
Dungeness crab move between critical habitats, and how conditions such as temperature and salinity
impact that behavior (some of these questions were addressed for hypoxia in Froehlich et al. 2013).
Understanding the patterns of crab habitat use, and the conditions that may drive those patterns, could
assist in the identification of areas where conservation or restoration/mitigation measures would best
promote a healthy and resilient Dungeness crab population, particularly in the face of rapidly changing
ocean conditions and habitat loss.
In terms of mitigation, Dumbauld et al. (1993) found enhancing habitat with oyster shell increased crab
survival. As such, oyster shell additions have been utilized for mitigating the impact of dredging on crab
habitat despite later findings suggesting that interspecific competition reduces the effectiveness of this
type of mitigation project for Dungeness crab (Visser et al. 2004). While habitat conservation is
preferred over restoration or mitigation, future studies investigating human impacts on habitat should
consider designing experimental studies such as Dumbauld’s (1993), to determine the most appropriate
design for mitigation.
Disease, Pests, and Pollution
Disease
Crustacean populations are known to suffer direct and indirect losses from several pathogens but
overall mortalities are difficult to estimate. Mortalities are the most striking feature of an epizootic,
but other disease effects such as reduced growth, fecundity, and loss of product quality can greatly
impact populations that are commercially exploited (Morado & Sparks 1988).
Microsporidians are among the most common and most pathogenic of crustacean disease agents,
and are especially well documented among the decapods (Couch 1983; Sindermann 1990; Sparks
1985). The number of known microsporidian species is now about 800 (Canning 1990), with over
140 species described from crustacean hosts (Couch 1983). There are very few diseases described in
Dungeness crabs (Meyers et al. 1985) and only three protozoan infections have been reported: a
systemic ciliate disease caused by Paranophrys sp. (Sparks et al. 1982; Armstrong et al. 1981), an
undescribed microsporidian that infects muscle tissue (Morado & Sparks 1988), and Nadelspora
canceri, a microsporidian that has unusual needle-shaped spores that are easily recognized when
muscle is viewed under a light microscope (Olson et al. 1994). Paranophrys sp. requires entry into
the crab through injury of the exoskeleton and causes destruction and dysfunction of major organ
systems and ultimately death of the host (Sparks et al. 1982). No detailed information exists on the
microsporidian that was observed infecting Dungeness crabs by Morado and Sparks (1988) except
that spores were oval-shaped and not contained within membranes, suggesting the parasite belongs
in the family Nosematidae.
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Nadelspora canceri infects the striated muscle in the Dungeness crab host and parasite spores are
found in vast numbers in the muscle tissue. In heavy infections, the muscle appears to be virtually
replaced by spores. Disease survey in the early 1990's found Nadelspora canceri infections in
Dungeness crab along the U.S. Pacific Coast from Bodega Bay, California, to Grays Harbor,
Washington, with prevalence lowest in open oceans (0.3%) and highest in estuaries (usually about
14% but up to 41% in one location) (Childers et al. 1996). Extensive surveys of Dungeness crab for N.
canceri infection north of Grays Harbor, including Puget Sound, have not found any infected crab
north of Grays Harbor (R. K. Childers Personal Communication 2021). Nadelspora canceri infections
are lethal to the crab host (R. K. Childers Personal Communication) but impacts to the crab
populations from the disease are unknown. To monitor the northward spread of Nadelspora, fishery
managers and researchers conducting crab population surveys in the Salish Sea could incorporate
visual inspections of crab for Nadelspora infections as a component to the population surveys.
Pests
One of the major ‘pests’ of concern for Dungeness crab in the Pacific Northwest is the European green
crab (Carcinus maenas), an invasive species whose presence along the West Coast has been
documented and increasing since 1989 (Grason et al. 2018, Mueller & Jefferson 2019). In Washington
state, dedicated monitoring efforts have found limited numbers of green crab in inland waters, though a
few locations consistently report very high numbers (Grason et al. 2018, Mueller & Jefferson 2019).
While the full potential of a green crab invasion, and its impacts on native Dungeness crab populations,
has not yet been realized in Washington state, evidence from other regions point to the potential for an
established green crab population to have severe consequences. For example, it is likely that green crab
could decimate critical Dungeness crab habitat due to their digging and burrowing behavior (Jamieson et
al. 1998, Hoagland & Jin 2006); or impact Dungeness crab prey availability by consuming much of the
local clam populations (e.g., Whitlow 2009). Improving our understanding of the potential ecological
impacts of an invasion would help managers better prepare for a future with green crab established in
the region.
Pollution
Decreased water quality is a stressor for Dungeness crab with ramifications for the fishery, whether via
direct anthropogenic inputs such as pesticides and trace metals (Caldwell 1977), the presence of
biotoxins (Ekstrom et al. 2020), or low oxygen or acidic conditions (Bednaršek et al. 2020, Berger et al.
2021). For example, recreational and commercial harvests may be closed or delayed due to
recommendations from state health departments monitoring for domoic acid, a biotoxin produced by a
species of algae that temporarily accumulates in crab tissue and can cause severe illness in humans if
consumed (‘Domoic Acid’, WDFW). Hypoxia (low oxygen) and ocean acidification are known to increase
mortality in adult and larval crab, respectively (Chan et al. 2008, Miller et al. 2016), but the significance
of the impacts of these ‘pollutants’ on Dungeness crab population dynamics is unclear. Since models
show the West Coast as one of the most vulnerable regions to ocean acidification in the United States,
and monitoring shows that hypoxic conditions are increasing, these issues are quickly becoming a
priority consideration for managers, though a challenging one (Billé et al. 2013; Ekstrom et al. 2015;
Klinger et al. 2017, NCCOS Project Report). In order to protect human health and promote population
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sustainability, it is essential to uncover when and where different types of ‘pollution’ hotspots occur.
This hotspot identification would allow managers to better plan and coordinate harvests and potentially
identify crucial habitat refuges for local crab populations that may be key for population resilience
(Kapsenberg & Cyronak 2019; Berger et al. 2021).
Photo caption: Local commercial crabbers are important collaborators in research and can fill knowledge gaps with
local and traditional insight. Photos by Jim Gibson and Swinomish Indian Tr ibal Community.
Fishery Impacts
To reduce risk of overexploitation, a persistent challenge of managing capture fisheries is assessing and
accounting for fisheries-related impacts such as mortality and/or injury (Juanes & Smith 1995, Uhlmann
& Broadhurst 2015). Developing a better understanding of how current management strategies impact
Dungeness crab populations can assist with identifying ways to minimize potential harvesting impacts on
the exploited population. Fisheries-related mortality can include loss due to entrainment in derelict
gear, detrimental handling of organisms, and poaching (Breen 1987, Antonelis et al. 2011). Of particular
interest is the fact that ~12,000 traps are lost annually in Washington’s inland waters (Antonelis et al.
2011). These lost traps lead to an estimated annual mortality of 170,000 legal-sized male crab, indicating
a strong need for the removal of lost traps (Antonelis et al. 2011). Additionally, harvest of one sex, as is
done under 3-S managment, can cause shifts in sex-ratios or can impact the genetic structure of a
population (Allendorf et al. 2008, Ogburn 2019). While some research on Dungeness crab reproductive
output suggests that >80 % of females can mate successfully despite the exploitation of males (Dunn &
Shanks 2012, Rasmuson 2013, Ogburn 2019), we would benefit from an increased understanding of how
reproductive output, sperm storage, and fertilization processes are affected by the fishing impacts and
the 3-S management strategy, particularly in the Salish Sea.
Research has also shown that injury in crabs can have negative effects on individual fitness, which is
especially important when studying sublegal animals that are released upon trap retrieval (Juanes &
Hartwick 1990, Juanes & Smith 1995, Barber & Cobb 2007). The Dungeness crab fishery in Washington’s
Salish Sea is currently managed to avoid harvest during molting, when crab shells are soft and most
vulnerable to handling (Kruse et al. 1994). Yet, the ecological drivers of molt timing are not well
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understood, leaving managers unable to anticipate the ideal timing for fishery closures as it relates to
shell condition. We also do not completely understand the impact of capture or injury on ovigerous
female Dungeness crabs despite the fact some crustacean species are known to mutilate their egg
masses upon capture (Darnell et al. 2010). Thus, research considering factors that influence molting and
injury to both male and female crab will be beneficial for improving future management strategies for
Dungeness crab.
Research Topics
Critical knowledge gaps regarding Dungeness crab can be categorized into four general research topics:
Population Status, Structure, and Dynamics; Land Use and Climate Change Impacts; Fishery and Industry
Impacts; and Ecology and Food Web Dynamics (defined below).
The research questions contained herein reflect how to address the PCRG-identified knowledge gaps
within each category (Boxes 1 to 4), determined during the winter 2020 workshop. During this
workshop, PCRG members were also asked to rank the priority of the research topics (Fig. 3). Note that
the majority of workshop participants were scientists and managers who work within the Salish Sea and,
as such, identified gaps in knowledge for that region specifically. Some of these knowledge gaps may
have been explored previously in other parts of the Pacific Northwest (e.g., outer WA and OR coast, AK,
BC).
● Population Status, Structure, and Dynamics (Box 1) - this category includes questions related to
Dungeness crab populations and the biological information necessary for best determining crab
abundance.
● Land Use and Climate Change Impacts (Box 2) - this category aims to address how changing
environmental conditions and land use practices may impact future Dungeness crab
populations.
● Fishery and Industry Impacts (Box 3) - this category focuses on the interactions between fishery
and industry practices and Dungeness crab populations.
● Ecology and Food Web Dynamics (Box 4) - this category includes questions about the
interactions between Dungeness crab, their environment, and other species.
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Figure 3. PCRG member ranking of research areas identified in January 2020. Note that population
status and dynamics was combined with population structure after the ranking was complete.
The boxes below contain PCRG member questions, organized by research area. Members collectively
gathered questions that, once answered, would be useful in filling important knowledge gaps. PCRG
members simultaneously ranked their top research question choices across all research areas, the 10
highest ranked are identified below:
Top 10 PCRG Research Questions
● What are the best cost-effective and robust predictors of adult Dungeness crab abundance?
● How does larval abundance correlate to adult crab abundance in a given area?
● What are the population bottlenecks (e.g., spatial, temporal, life history stage)?
● What are the source and sink dynamics along the West Coast for Dungeness crab populations?
● What biological metrics are needed to develop accurate stock assessments for Dungeness crab?
● What are the effects of climate change on each of the Dungeness crab life history phases?
● How will climate change affect different types of management strategies?
● What amendments to the 3-S management framework can we test using a management
strategy evaluation (e.g., size limits, timing to avoid molting, etc.)?
● What are the top-down vs. bottom-up impacts on Dungeness crab populations?
● What are the impacts of environmental stressors on various life history phases?
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Box 1. Population Status, Structure, and Dynamics
● What are the best cost-effective and robust predictors of adult Dungeness crab abundance?
● How does larval abundance correlate to adult crab abundance in a given area?
● What are the population bottlenecks (e.g., spatial, temporal, life history stage)?
● What are the source and sink dynamics along the West Coast for Dungeness crab
populations?
● What biological metrics are needed to develop accurate stock assessments for Dungeness
crab?
● What is the natural mortality rate of Dungeness crab?
● How can we use test fishery data in a predictive way?
● Are management areas appropriate for the population distribution?
● What are the mechanisms and extent of larval transport and distribution?
● Can we characterize the spatio-temporal variations in molting and mating patterns?
● How many populations of Dungeness crab exist throughout their range?
● What is the impact of a skewed sex ratio in the population?
● What is the connectivity of regional populations of Dungeness crab?
● What is the optimal size-frequency distribution for a sustainable fishery?
● Does the population structure change across space and through time?
● What are the migration patterns of adult Dungeness crab within and between regions?
● Can we use alternative methods for assessing population age structure?
● What is the best indicator of mating success?
Box 2. Land Use and Climate Change Impacts
● What are the effects of climate change on each of the Dungeness crab life history phases?
● How will climate change affect different types of management strategies?
● How will changes in sea surface temperature affect population dynamics?
● What are the fisheries-related socio-economic impacts associated with climate change?
● Will there be shifts in population distribution as oceanic conditions change?
● How does shoreline development and use impact population dynamics?
● What are the interactions between climate change, harmful algal blooms, and the Dungeness
crab fishery?
● Is estuarine restoration a valid tool for promoting resilience in Dungeness crab?
● How do anthropogenic stressors affect Dungeness crab populations?
Box 3. Fishery and Industry Impacts
● What amendments to the 3-S management framework can we test using a management
strategy evaluation (MSE) (e.g., size limits, timing to avoid molting, etc.)?
● What are the effects of fishing during mating or molting seasons?
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● How do management strategies influence socio-economic factors or vice versa?
● What socio-economic factors would be best utilized in a management strategy evaluation?
● What are the effects of biotoxins on the crab fishery?
● How does derelict gear impact crab populations?
● How does the act of handling crab during a fishery impact crab survival?
● What are the potential effects of skewing the sex ratio in a male-only fishery?
● What are the spatial-temporal variations in unreported catch?
Box 4. Ecology and Food Web Dynamics
● What are the top-down vs. bottom-up impacts on Dungeness crab populations?
● What are the impacts of environmental stressors on various life history phases?
● How do environmental factors influence growth rates for Dungeness crab?
● How do the bioenergetics of Dungeness crab differ throughout their range?
● Do non-native eelgrass beds provide the same nursery habitat function as native eelgrass
beds for Dungeness crab?
● What are the impacts of predators (otter, octopus, lingcod, etc.) on Dungeness crab?
● How do diseases impact Dungeness crab across space and through time?
● How will changes in phytoplankton community assemblages impact Dungeness crab survival?
● What are the temporal and spatial patterns of habitat use of juvenile Dungeness crab and do
they differ by region?
● Which species utilize Dungeness crab as a critical food source?
● What role do Dungeness crab play in marine food webs as a prey item?
Charting a Path to Information-Directed Action
Since its inception in 2018, PCRG has worked to build
relationships by reaching out and connecting with
partners interested in advancing our mission. Over
the last few years we have grown to an organization
with around 100 members, many of whom have
shared their expertise and worked to identify
knowledge gaps. This process has ultimately assisted
PCRG by helping us target specific management
priorities and determine where to focus research
efforts during our first five years as a program.
Photo Caption: PCRG light trap monitoring for larval Dungeness crab with
commercial fishing boat in background. Shaw Island, WA. Photo by Emily
Buckner.
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Moving forward, we hope this research guide will provide a foundation upon which we can advance
collaboration and build even more targeted and effective research plans. This document not only guides
PCRG and its individual members in their research, but also serves as a resource for the greater scientific
community working to address high priority research areas for Dungeness crab. While some specific
PCRG research projects are already underway (Table 1), the myriad of unanswered research questions is
large enough that researchers will benefit from a coordinated effort to continually update top priority
needs. As such, the knowledge gaps and management priorities in this guide will be regularly revisited
by the PCRG and updated, as necessary, every five years.
Although PCRG research programs are still relatively young, we believe it is prudent to continue to
develop our capacity to coordinate research efforts, build upon or create new and sustainable research
programs, and determine the best approaches for communicating our science to diverse audiences. We
suggest that during the development of the next research guide in 2026, we build off of lessons learned
during our inaugural five years and explore various future scenarios for the continual improvement of
our guided and collaborative research program.
Table 1. Summary of current/pending PCRG research projects and what questions they address.
Project Title Years Implemented Research Question(s) Addressed
Larval Crab Monitoring
(WA & BC)
2019-present ● What are the best cost-effective and robust
predictors of adult Dungeness crab
abundance?
● How does larval abundance correlate to adult
crab abundance in a given area?
● What are the population bottlenecks (e.g.,
spatial, temporal, life history stage)?
● What are the source and sink dynamics along
the West Coast for Dungeness crab
populations?
Characterizing population
connectivity of Dungeness
crab in Puget Sound
(Puget Sound)
2021-present ● What is the connectivity of regional
populations of Dungeness crab?
● How many populations of Dungeness crab
exist throughout their range?
● What are the source and sink dynamics along
the West Coast for Dungeness crab
populations?
Fishery Independent
Survey (WA)
In development ● What biological metrics are needed to
develop accurate stock assessments for
Dungeness crab?
● What is the impact of a skewed sex ratio in
the population?
● Does the population structure change over
time by region?
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● Can we characterize the spatial-temporal
variations in molting and mating patterns?
● Does the population structure change across
space and through time?
● What are the migration patterns of adult
Dungeness crab within and between regions?
● How can we use test fishery data in a
predictive way?
● Are management areas appropriate for the
population distribution?
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TABLE OF COMENTERS AND COMMENT TOPICS
RE: MLA19-00036 BDN
Name 1. PVC Tube Recovery 1. Plastics Pollution 2. Land Use – Hicks Park 3. Harvesting - Noise 3. Harvesting - Eelgrass 4 Nutrient Competition 5. Forage Fish Impact & Wildlife 6. Impact on Fishers 6. Impact on Loons 7. Carbon Release 8. Visual Effects 9. Area Type F Stream 10. Boat Moorage at BDN tracts 11. Upland Parcels 12. Updated Eelgrass Survey 13. Access to Smersh Parcel Not Commercial Area Effect on Crabs Profit Motive Stormwater Runoff Cumulative Impacts Shorelin of Statewide Signif. Bad Track Record & violations Allen, Kris
(agrees w/
Neighbors Ltr.)
Davis, Sara X X X X X X X
Dittmar, Steve X X X X X X X
Dept. of Ecology X X
Hood Canal Env.
Council X X X X X
Neighbors in
Shine X X X X X X X
Steenberg, Paul X X X
Showalter,
Marilyn X X X X X X X X X X X X X X X X X X
Wold, Jan X X X X X
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