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Rock Island Shellfish HABITAT MANAGEMENT PLAN
Prepared for:
Plauché & Carr LLP
May 2024
146 N Canal St, Suite 111 • Seattle, WA 98103 • www.confenv.com
Rock Island Shellfish
HABITAT MANAGEMENT PLAN
Prepared for:
Plauché & Carr LLP 1218 3rd Ave, Suite 200 Seattle, WA 98101 Attn: Jesse DeNike
Authored by:
Marlene Meaders and Margaret Wolf Confluence Environmental Company
May 2024
This report should be cited as:
Confluence (Confluence Environmental Company). 2024. Rock Island Shellfish: Habitat Management Plan. Prepared for Plauché
& Carr, Seattle, Washington, by Confluence, Seattle, Washington.
Rock Island Shellfish: Habitat Management Plan
May 2024 Page i
TABLE OF CONTENTS
MARLENE MEADERS ................................................................................................................................................ IV
MARGARET WOLF ..................................................................................................................................................... IV
1.0 INTRODUCTION ................................................................................................................................................... 1
2.0 SPECIES AND HABITATS ANALYZED ............................................................................................................... 3
3.0 EXISTING SETTING AND SURROUNDING LAND USE ..................................................................................... 5
4.0 PROJECT OVERVIEW ......................................................................................................................................... 6
4.1 Project Description ................................................................................................................................... 6
4.1.1 Project Timeline and Sequencing ............................................................................................. 7
4.1.2 Gear Installation ........................................................................................................................ 7
4.1.1 Operations and Maintenance .................................................................................................... 7
4.1.2 Avoidance and Minimization Measures..................................................................................... 9
4.2 Project Site ............................................................................................................................................. 11
5.0 EXISTING ENVIRONMENTAL CONDITIONS .................................................................................................... 12
5.1 Fish and Wildlife Habitat Conservation Areas (FWHCAs) ...................................................................... 12
5.1.1 Water Quality .......................................................................................................................... 12
5.1.1 Sediment Quality..................................................................................................................... 14
5.1.2 Fish and Wildlife Presence ..................................................................................................... 16
5.1.3 Kelp and Eelgrass Beds .......................................................................................................... 29
5.2 Wetlands ................................................................................................................................................. 30
5.3 Geologically Hazardous Areas ............................................................................................................... 30
5.4 Critical Aquifer Recharge Areas (CARAs) .............................................................................................. 31
5.5 Frequent Flood Areas ............................................................................................................................. 31
6.0 EFFECTS ANALYSIS ......................................................................................................................................... 32
6.1 Water Quality .......................................................................................................................................... 33
6.1.1 Water Circulation .................................................................................................................... 33
6.1.2 Contaminants .......................................................................................................................... 34
6.1.3 Suspended Sediments/Turbidity ............................................................................................. 35
6.1.4 Summary of Water Quality Effects .......................................................................................... 36
6.2 Sediment Quality .................................................................................................................................... 36
6.2.1 Culture Gear ........................................................................................................................... 36
6.2.2 Biodeposition in the Sediment ................................................................................................ 37
6.2.3 Summary of Sediment Quality Effects .................................................................................... 38
6.3 Fish and Wildlife Habitat ......................................................................................................................... 38
6.3.1 Fish Habitat ............................................................................................................................. 38
6.3.2 Bird Habitat ............................................................................................................................. 40
6.3.3 Marine Mammal Habitat .......................................................................................................... 42
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6.3.4 Summary of Effects to Fish and Wildlife Habitat ..................................................................... 43
6.4 Invertebrates ........................................................................................................................................... 43
6.5 Kelp and Eelgrass Beds ......................................................................................................................... 45
6.6 Navigation and Public Use...................................................................................................................... 46
6.7 No Net Loss and Cumulative Impacts .................................................................................................... 46
6.7.1 Hood Canal Shellfish Aquaculture .......................................................................................... 47
6.7.2 Water Quality .......................................................................................................................... 47
6.7.3 Sediment Quality..................................................................................................................... 48
6.7.4 Fish and Wildlife...................................................................................................................... 48
6.7.5 Invertebrates ........................................................................................................................... 49
6.7.6 Kelp and Eelgrass ................................................................................................................... 50
6.7.7 Navigation and Public Use ...................................................................................................... 50
6.7.8 Summary ................................................................................................................................ 50
7.0 DETERMINATION OF EFFECT .......................................................................................................................... 51
8.0 REFERENCES .................................................................................................................................................... 53
TABLES
Table 1. Species Considered in this Habitat Management Plan .................................................................................... 4
Table 2. Latitude and Longitude of Project Site Corners .............................................................................................. 11
Table 3. Effects Determinations for Federal, State, or Locally Important or Listed Species ........................................ 51
FIGURES
Figure 1. Project site location in Jefferson County. ........................................................................................................ 2
Figure 2. Example of a SEAPA basket system. ............................................................................................................. 6
Figure 3. Project site layout. ........................................................................................................................................... 8
Figure 4. Growing areas in North Hood Canal. ............................................................................................................ 13
Figure 5. Shoreforms in North Hood Canal. ................................................................................................................. 15
Figure 6. Coastal drift in North Hood Canal. ................................................................................................................ 17
Figure 7. Mean total abundance (a) and mean diversity (b) by taxonomic group. ....................................................... 28
Figure 8. Mean total abundance (a) and mean diversity (b) by functional feeding guild. ............................................. 29
Figure 9. Percent biomass of benthic invertebrates in Humboldt Bay, California. ........................................................ 44
Figure 10. Invertebrate taxa encountered with each habitat pair by season. ............................................................... 45
APPENDICES
Appendix A – Fish and Wildlife Database Information
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ACRONYM LIST
Acronym Definition
BMP(s) best management practice(s)
CARAs critical aquifer recharge areas
Corps U.S. Army Corps of Engineers
DNR Washington Department of Natural Resources
DPS distinct population segment
Ecology Washington State Department of Ecology
ESA Endangered Species Act
ESU evolutionarily significant unit
FWHCA(s) fish and wildlife habitat conservation area(s)
IBA Important Bird Area
JCC Jefferson County Code
JCPH Jefferson County Public Health
MHHW mean higher high water
MLLW mean lower low water
NMFS National Marine Fisheries Service
OHWM ordinary high water mark
PBA Programmatic Biological Assessment
PBFs physical and biological features
PHS Priority Habitats and Species
PVC polyvinyl chloride
SAV submerged aquatic vegetation
SMP Shoreline Management Program
SRKW southern resident killer whale
The Project Rock Island Shellfish Project
USFWS U.S. Fish and Wildlife Service
UV ultraviolet
WDFW Washington Department of Fish and Wildlife
WDOH Washington State Department of Health
WRIA 17 Watershed Resource Inventory Area 17
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QUALIFICATIONS OF THE PREPARER
MARLENE MEADERS
Marlene has specialized in marine and freshwater biology since 2000. She manages and
implements a variety of fisheries projects, with a focus on shellfish aquaculture. Marlene is a
certified senior author for biological assessments and has written numerous consultations for
the Endangered Species Act, Marine Mammal Protection Act, and Magnuson-Stevens Fishery
Conservation and Management Act. She has coordinated with federal, state, and local agencies
to complete environmental permitting of marine projects under the Clean Water Act, Rivers and
Harbors Act, and Shoreline Management Act. Marlene has conducted dozens of baseline
surveys that relate to shellfish aquaculture and is well versed at describing the direct
impacts/benefits that an operation or project might have on the environment. Marlene is also a
recognized expert regarding eelgrass throughout Washington State and along the West Coast.
She has completed the U.S. Army Corps of Engineers Eelgrass Delineation Guidance Workshop
and was part of a Confluence team working with the Corps to develop best practices for
applying the guidance to shellfish aquaculture projects.
EDUCATION
M.S., Fisheries Biology, Humboldt State University, Arcata, CA, 2008
B.S., Biological Oceanography, University of Washington, Seattle, 2000
MARGARET WOLF
Margaret specializes in biology, biostatistics, and geospatial analysis. She has wide-ranging
field experience in the Pacific Northwest, such as fish exclusion for construction compliance,
wetland delineations, stream habitat mapping, water testing, and soil contamination analysis.
She also has designed and conducted wildlife surveys and monitoring programs and authored
associated reports and management recommendations. Her technical work has ranged from
using statistical computing tools such as R and Python to analyzing data in RStudio, ArcMap,
and ArcGIS Pro for such tasks as noise pollution modeling, spatial analysis and mixed-effect
linear regression. Margaret is familiar with local, state, and federal environmental policies and
regulations, with a focus on climate resiliency, and she conducts regulatory research and
prepares documentation to meet local (e.g., critical areas), state (e.g., State Environmental Policy
Act), and federal (e.g., Endangered Species Act) regulatory requirements.
EDUCATION
M.S., Biological Sciences, California Polytechnic State University, San Luis Obispo, CA, 2023
B.A., Organismal Biology and Ecology, Colorado College, Colorado Springs, CO, 2018
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1.0 INTRODUCTION
This Habitat Management Plan has been prepared for the Rock Island Shellfish Project (the
Project), located in Jefferson County, Washington (Figure 1). The Project is a proposal to
continue shellfish farming activities on private tidelands in North Hood Canal owned by Robert
Carson, the owner of Rock Island Shellfish Company, on Jefferson County parcel numbers
965100009, 965100010, and 965100011. These tidelands have been subject to commercial shellfish
aquaculture since the 1950s using a variety of on- and off-bottom cultivation methods.
This document reviews the proposed farming methods per the Jefferson County Critical Areas
Ordinance (Jefferson County Code [JCC] Chapter 18.22) and Shoreline Management Program
(SMP) (JCC Chapter 18.25). The purpose of the Project is to grow oysters in intertidal waters
using a near-bottom culture system called SEAPA® baskets. The proposed Project involves
installation, maintenance, and operation of a SEAPA basket system in North Hood Canal.
SEAPA baskets will be stocked with seed oysters and raised to full growth prior to harvesting
and selling commercially.
According to JCC 18.25.270, the policy of critical areas, shoreline buffers, and ecological
protection includes “all shoreline use and development should be carried out in a manner that
avoids and minimizes adverse impacts on the shoreline environment. Uses and developments
that may cause the future ecological condition to become worse than current condition should
not be allowed. Use and development in areas that are ecologically valuable, hazardous, and/or
possess rare or fragile natural features should be discouraged.”
In compliance with the JCC, this report shall:
Demonstrate that the submitted proposal is consistent with the purposes and specific
standards of JCC Chapter 18.22 and Chapter 18.25.
Describe all relevant aspects of the development proposal and critical areas adversely
affected by the proposal and assess impacts on the critical area from activities and uses
proposed.
Where impacts are unavoidable, demonstrate through an alternatives analysis that no
other feasible alternative exists.
Consider the cumulative impacts of the proposed action that includes past, present, and
reasonably foreseeable future actions to facilitate the goal of no net loss of critical areas.
Such impacts shall include those to wildlife, habitat, and migration corridors; water
quality and quantity; and other geologic or watershed processes that relate to critical
area condition, process, or service.
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Figure 1. Project site location in Jefferson County.
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2.0 SPECIES AND HABITATS ANALYZED
The proposed Project site consists of marine portions of North Hood Canal in Jefferson County
(USGS 5th HUC 17110018 – for Hood Canal subbasin; Lat: 47.86588 N, Long: 122.64227 W). The
Endangered Species Act (ESA)-listed species under the purview of the National Marine
Fisheries Service (NMFS) and United States Fish and Wildlife Service (USFWS) that may occur
in the area are provided in Table 1. This information is compiled from the NMFS (2024) and
USFWS (2024), which is provided as Appendix A (NMFS 2024a, 2024b; USFWS 2024a). Note
that critical habitat has been designated for all of these species, but critical habitat does not
occur for all species in the Project site or vicinity (Table 1).
Jefferson County also considers fish and wildlife habitat conservation areas (FWHCAs) under
JCC Chapter 18.22. As defined by the code, FWHCAs are “areas that serve a critical role in
sustaining needed habitats and species for the functional integrity of the ecosystem, and which,
if altered, may reduce the likelihood that the species will persist over the long term” (JCC
18.22.610). Relevant species that are supported by these FWHCAs are also included in Table 1,
as identified by Washington Department of Fish and Wildlife (WDFW) in the priority habitats
and species (PHS) database (WDFW 2024a) or listed in JCC Table 18.22.630(2). Effects of the
Project are assessed below relative to these FWHCAs, rather than the species itself.
A number of west coast ESA-listed species are not known to occur in North Hood Canal, and so
were not included in this analysis: streaked horned lark (Eremophila alpestris strigata), yellow-
billed cuckoo (Coccyzus americanus), leatherback sea turtle (Dermochelys coriacea), North Pacific
distinct population segment (DPS) of loggerhead sea turtle (Caretta caretta), olive Ridley sea
turtle (Lepidochelys olivacea), green turtle (Chelonia mydas), black abalone (Haliotis cracherodii),
white abalone (Haliotis sorenseni), blue whales (Balaenoptera musculus), fin whales (Balaenoptera
physalus), gray whales (Eschrichtius robustus), Guadalupe fur seals (Arctocephalus townsendi),
Northern Pacific right whales (Eubalaena japonica), sei whales (Balaenoptera borealis borealis), and
sperm whales (Physeter macrocephalus). Due to the lack of documented occurrence and the lack
of suitable habitat in the area, the proposed action will have no effect on these species, and they
will not be assessed further in this document.
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Table 1. Species Considered in this Habitat Management Plan
Common Name Scientific Name State Status Federal Status PHS Critical Habitat Potential Habitat Use
ESA-Listed Fish Bull trout (PS/Coastal DPS) Salvelinus confluentus C T Yes* Migration and foraging, but unlikely
Chinook salmon (PS ESU) Oncorhynchus tshawytscha C T Yes Migration, juvenile rearing, foraging Chum salmon (Hood Canal summer-run ESU) O. keta None T Yes Migration, smolt rearing, foraging
Steelhead (PS ESU) O. mykiss None T Yes* Migration, smolt rearing, foraging
Bocaccio rockfish (PS/GB DPS) Sebastes paucispinis C E Yes Foraging, but unlikely (deepwater)
Yelloweye rockfish (PS/GB DPS) S. ruberrimus C T Yes Foraging, but unlikely (deepwater) Green sturgeon (Southern DPS) Acipenser medirostris None T Yes” Migration, sub-adult rearing, foraging Forage Fish Surf smelt Hypomesus pretiosus) None None N/A Spawning, foraging
Pacific sand lance Ammodytes hexapterus None None N/A Spawning, foraging
Pacific herring Clupea pallasii None None N/A Spawning, foraging
Other Marine Fish Coastal cutthroat trout O. clarki clarki None None X N/A Migration, rearing, foraging
Coho salmon O. kisutch C C X N/A Migration, rearing, foraging Fall/summer chum salmon O. keta None None X N/A Migration, rearing, foraging
Fall Chinook salmon O. tshawytscha None None X N/A Migration, rearing, foraging
Winter steelhead O. mykiss None None X N/A Migration, rearing, foraging
Birds Marbled murrelet (CA/OR/WA) Brachyramphus marmoratus E T Yes* Foraging
Great blue heron Ardea herodias M None N/A Foraging Various shorebird species and eagles Various None None N/A Foraging Marine Mammals
Southern resident killer whale Orcinus orca E E Yes Foraging, but highly unlikely
Harbor seal Phoca vitulina None None N/A Foraging Invertebrates
Oyster beds Various None None X N/A Spawning, foraging PHS - Priority Habitats and Species; DPS - Distinct population segment; ESU - Evolutionarily Significant Unit; Endangered; T - Threatened; C - Candidate; Co - Concern; M – Monitor; S - Sensitive; CA - California; GB - Georgia Basin; OR - Oregon; PS - Puget Sound; WA – Washington *Critical habitat has been identified but does not occur within the proposed Project site.
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3.0 EXISTING SETTING AND SURROUNDING LAND USE
The proposed Project is within North Hood Canal located near Port Ludlow, Jefferson County,
Washington, at Section 2, Township 27N, and Range 1E. North Hood Canal is part of the marine
shorelines of Watershed Resource Inventory Area 17 (WRIA 17) or the Quilcene-Snow
watershed. Hood Canal is a glacier-carved fjord along the westernmost portion of Puget Sound,
with approximately 84,978 acres of water surface. The intertidal zone is approximately 12%
(9,951 acres) and the subtidal zone is approximately 88% (75,027 acres) of the water surface.
Shellfish aquaculture areas – including active and fallow culture beds – occupy approximately
12% of the intertidal zone in Hood Canal. There are subtidal aquaculture areas, although these
locations represent a minor portion of the subtidal zone (~0.2%). Habitat in Hood Canal
includes native eelgrass (Zostera marina) beds (up to 3%), mudflat areas (up to 9%), and open
water (up to 88%). Major water bodies that are part of WRIA 17 include the Tarboo Creek,
Chimacum Creek, Snow Creek, Salmon Creek, Thorndyke Creek, Pheasant Creek, Duckabush
River, Big and Little Quilcene rivers – contribute to a total watershed planning area of 625
square miles (Pickett 2013).
The northern portion of Hood Canal is primarily open water, with approximately 2 miles
separating the western and eastern shorelines and inclusive of Dabob Bay, which is also
approximately 2 miles wide. The shoreline is a mixture of forested hills with the Olympic
Mountain range in the background, major estuaries, public parks and use areas, and low to
moderate residential development. A small amount of shoreline along the Bangor waterfront is
highly modified for U.S. Navy use. The primary key viewpoints in the area are from state parks
and other public beach access areas, such as Dosewallips State Park and the Duckabush River
access. The Hood Canal Floating Bridge crosses the northern portion of Hood Canal where a
shallow sill is located, and continues into the upland portions of the Hood Canal subregion as
State Route 104, which then connects to the Olympic Highway.
Hood Canal supports commercial vessel activity associated with shellfish operations, including
work boats or skiffs, harvest scows, and barges used for equipment staging and storage. There
is tribal fishing in Hood Canal, which includes beach seining, gillnetting, crabbing, and shrimp
fishing. There are also several locations for commercial and tribal wildstock geoduck harvest in
Hood Canal (WDFW 2024b). Submarine vessel traffic is associated with the U.S. Naval facility
located near Bangor on the Kitsap peninsula. Restricted marine areas surround the facility, and
are marked with floating security barriers.
Shoreline residences along the northern portion of Hood Canal do not have associated piers,
docks, or boat ramps, with the notable exception of Squamish Harbor, which provides moorage
for recreational boats. Use of the Project site is limited to beach combining and minor
recreational activities accessed primarily by boat.
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4.0 PROJECT OVERVIEW
The purpose of the Project is to grow Kumamoto (Crassostrea sikamea) oysters in intertidal
waters of North Hood Canal. The development proposal involves installation, maintenance,
and operation of a SEAPA basket system (Figure 2). The Project site is within privately-owned
tidelands and is approximately 6 acres. The SEAPA baskets will occupy a culture area of
approximately 2 acres, which includes 16.5-foot buffers from native eelgrass beds. SEAPA
baskets will be stocked with seed oysters and grown to harvestable size within two years or
less.
Figure 2. Example of a SEAPA basket system.
4.1 Project Description
This section describes technical details of project timeline and sequencing, gear installation,
regular shellfish aquaculture operations and maintenance, and avoidance and minimization
measures associated with the proposed Project.
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4.1.1 Project Timeline and Sequencing
Proposed installation of SEAPA baskets and rebar structures is anticipated within a 6-month
period. The SEPA baskets will be purchased from a supplier. The rebar structures will be
assembled at a facility or location outside of the shoreline jurisdiction; no new buildings,
staging areas, or facilities are proposed for assembly of the rebar structures. Gear is anticipated
to be brought to the site by boat. Following installation of culture gear, ongoing operations will
include maintenance of equipment, harvest and transfer of oysters, and addition of new oyster
seed to baskets.
Culture activities are generally tide-dependent but can occur year-round. During low tides,
farm crews may be on the farm site for 3 to 6 hours before the tide re-floods the area. Activities
may also occur at high tide when there is enough tidal inundation for a vessel to access farm
sites and may last up to 9 hours. The site will be accessed primarily by boat.
4.1.2 Gear Installation
SEAPA basket operations are proposed in the intertidal habitat of North Hood Canal at a depth
of approximately +4 feet to -4.2 feet mean lower low water (MLLW). The SEAPA basket system
will be supported by rebar racks (3.3 feet wide by 16.4 feet long by 3.3 feet high) and the baskets
will be attached using storm clips. Rows of rebar racks will be installed at regular intervals
(Figure 3). Gear is typically secured in the substrate 1 to 3 feet deep but may be secured up to 5
feet deep in certain areas, depending on substrate conditions. Gear installation will occur at low
tide.
4.1.1 Operations and Maintenance
Regular maintenance activities will include removal of fouling organisms (e.g., barnacles,
mussels, other invertebrates, and algae) from basket surfaces, and minor repair work. Operation
activities will include seeding of immature oysters, sorting and grading of growing oysters,
redistribution of oysters to achieve desired density, and harvest of market-size oysters.
Near-bottom culture that suspends crops off the bottom helps to minimize pressure from
predators that access on-bottom crops. Containment gear (i.e., SEAPA baskets) is used and is
secured to the substrate via rebar racks. Therefore, predator and invasive species control is
minimal or unnecessary for this culture method.
Oyster seed for SEAPA basket operations is manually placed into the ultraviolet (UV)-resistant,
reusable baskets. Seed is pre-loaded into baskets on the deck of the vessel and transported to
the farm site by boat during low tide. Farm crews secure containers to ropes during low tide.
Alternatively, farm crews may bring seed with them onto the farm site at low tide and directly
load the containers on-site.
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Figure 3. Project site layout.
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At harvest, farm crews manually remove baskets, and shellfish may then be sorted on a work
platform on the farm site or on the beach. Substrate disturbance is minimal and limited to farm
crews walking on the farm site.
4.1.2 Avoidance and Minimization Measures
Best management practices (BMPs) for floating culture, including siting and configuration, will
be employed to maintain water quality. Relevant shellfish culture conservation measures
adopted by the U.S. Army Corps of Engineers (Corps) from its programmatic consultation with
the NMFS (2016) and USFWS (2016) for shellfish aquaculture operations in Washington State
will be used for the proposed Project (Corps 2015). Avoidance of potential effects, where
possible, is the first priority.
Avoidance, conservation, and minimization measures are focused on the following
activities/interactions:
Gear Installation and Siting
Maintenance, Repair, and Work
Species-Specific Activities
Farm Plan Record-Keeping Log
Gear Installation and Siting
SEAPA baskets will be sited approximately 140 feet from the ordinary high water mark
(OHWM).
SEAPA baskets will be constructed of material that will not have a negative effect on the
aquatic environment. Gear includes synthetic and nylon lines, UV-resistant high density
polyethylene floating bags, wedge anchors, and screw anchors, all which would have no
negative effect on water quality.
SEAPA baskets are designed to have a shallow draft (i.e., less than 24 inches when fully
stocked with oysters). By design, the shallow draft will have little effect on circulation
and flow patterns in North Hood Canal.
Native eelgrass (Zostera marina) and non-native eelgrass (Z. japonica) is present in North
Hood Canal (MSA 2023). A farm plan was developed to avoid native eelgrass or mixed
beds using a 16.5-foot buffer (refer to Figure 3).
SEAPA baskets have been planned and configured to minimize effects on benthic
organisms by raising them above the sediment surface (i.e., near-bottom culture). There
is no submerged aquatic vegetation (SAV) underneath the proposed location for SEAPA
baskets and the soft substrate is not appropriate attachment habitat for kelp.
All gear installation activities will be restricted to daylight hours.
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Maintenance, Repair, and Work
Damage to substrates from boats or barges will be avoided using the following BMPs:
- Moor and operate boats and barges in deeper water to prevent potential impacts
from propeller scour.
- Store materials such as tools, bags, marker stakes, rebar, or nets in upland areas
when not in use.
Operators of vehicles or machinery will reduce contamination from vehicles and
equipment through the following practices:
- Unsuitable material (e.g., trash, debris, asphalt, or tires) will not be discharged or
used as fill (e.g., used to secure nets, create berms, or provide nurseries).
- Rock Island’s equipment (vessels, vehicles, pumps, hydraulic motors, graders)
operated within 150 feet of any stream, waterbody, or wetland will be inspected
daily for fluid leaks before beginning operations. Any leaks detected will be repaired
before resuming operation.
- No petroleum products will be stored at the proposed Project site.
Approximately once per week, farm staff will evaluate the site and culture gear. The
staff will provide any necessary maintenance. Additional maintenance activities will
occur on an as-needed basis.
Rock Island will engage in quarterly patrol of all nearby beaches for debris, including
any lines or other pieces of equipment associated with its operations. Any debris
collected will be recorded.
Equipment (e.g., work vessels) will be inspected daily to ensure there are no leaks of
hydraulic fluids, fuel, lubricants, or other petroleum products. Should a leak be
detected, the equipment shall be immediately removed from the area and not used again
until adequately repaired.
Employees are trained in meeting environmental objectives.
Species-Specific Activities
The Project will comply with all terms, conditions, and conservation measures of the
programmatic consultation to avoid and minimize impacts to listed species, critical
habitat, and essential fish habitat (Corps 2015; USFWS 2016; NMFS 2016).
The SEAPA baskets will be sited and configured to minimize effects on marine
mammals. During maintenance and harvest operations, due care would be taken to
avoid disturbance of marine mammals, particularly seals and sea lions, in compliance
with the federal Marine Mammal Protection Act.
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Farm Plan Record-Keeping Log
Surveys to retrieve any gear, equipment, or other debris that may have fallen or
naturally pushed into the area will be recorded.
Spills or cleanups conducted on the beach will be recorded and the appropriate agencies
notified.
4.2 Project Site
Project activities will be confined to the two proposed planting areas defined by the corners
described in Table 2 (refer to Figure 3). The northernmost proposed planting area is 1.3 acres and the
southernmost proposed planting area is 0.8 acre.
Table 2. Latitude and Longitude of Project Site Corners
Location* Latitude Longitude
Northern Planting Area NW corner of north planting area (A) 47.8655939 N 122.6426804 W
NE corner of north planting area (B) 47.8658005 N 122.6416940 W SW corner of north planting area (C) 47.8651881 N 122.6425215 W
SE corner of north planting area (D) 47.8656982 N 122.6416436 W Southern Planting Area
NW corner of south planting area (E) 47.8648269 N 122.6422479 W NE corner of south planting area (F) 47.8650448 N 122.6413106 W
SW corner of south planting area (G) 47.8647111 N 122.6418286 W SE corner of south planting area (H) 47.8648883 N 122.6412357 W
*Letters for the corners are identified in Figure 3.
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5.0 EXISTING ENVIRONMENTAL CONDITIONS
The Project site is in the Pacific Northwest Region 17 (USGS 5th HUC 17110018 – for Hood Canal
subbasin) and WRIA 17 (Quilcene-Snow watershed). SEAPA basket operations are proposed in
North Hood Canal at a depth of approximately +4 feet to -4.2 feet MLLW.
This section focuses on existing environmental conditions for critical areas identified at the
Project site (Jefferson County 2024a). The existing environmental conditions will then be
compared against potential Project impacts discussed in the Effects Analysis (Section 6.0). The
following topics are covered:
Fish and wildlife habitat conservation areas (FWHCAs)
Wetlands
Geologically hazardous areas
Critical aquifer recharge areas (CARAs)
Frequently flooded areas
5.1 Fish and Wildlife Habitat Conservation Areas (FWHCAs)
This section summarizes the quality of habitat important to FWHCAs at the Project site.
5.1.1 Water Quality
Hood Canal has well-established commercial shellfish and oyster aquaculture and thus has
closely monitored water quality. The Washington State Department of Health (WDOH) collects
monthly samples in areas where there is shellfish harvesting for human consumption and
identifies harvest areas based on specific water quality criteria (WDOH 2024). Based on these
measurements, WDOH classifies shellfish growing areas as approved, conditional, restricted,
and prohibited for commercial shellfish harvest. The Project site currently lies in an approved
area (Figure 4), although further west by approximately 2 miles in Squamish Harbor there are
parcels closed to commercial shellfish harvest due to contaminated freshwater stream drainage
and a small area in the south of Squamish Harbor designated as prohibited due to boating
activity (WDOH 2024a).
In January of 2007, the WDOH listed Hood Canal, among other regions, as an area of concern
for marine water contamination due to non-point source pollution. In response, Jefferson
County started Clean Water Projects and established a Clean Water District that spans eastern
Jefferson County, including the current proposed Project site (Jefferson County 2024b). More
recent water quality testing conducted by Jefferson County Public Health (JCPH) showed no
high levels of fecal coliform bacteria within the boundaries of the Project site (JCPH Location ID
SH001), although there are instances of high fecal coliform concentrations and identified
hotspots to the west along the shoreline (JCPH Location IDs SH027, SH002, SH003) (Jefferson
County 2024c).
May 2024 Page 13
Figure 4. Growing areas in North Hood Canal. Source: (WDOH 2024a)
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Harmful algal blooms happen annually in Washington marine waters and can cause illness in
those who eat contaminated shellfish. Recent water quality annual reports from JCPH reported
widespread dinoflagellate blooms in Jefferson County waters in the summers of 2020 to 2022,
with instances of local shellfish bed closures due to high Alexandrium and Dinophysis
concentrations (Dawson 2020, 2021, 2022). From 2020 to 2022 there were also multiple reported
cases of Vibrio bacteria. JCPH issues a Vibrio warning each year from June to October for Hood
Canal waters as warmer water in this area is particularly conducive to cases of Vibrio (Dawson
2020, 2021, 2022).
No part of the Project site is listed under the Washington State Department of Ecology (Ecology)
303(d) list, for which Category 5 listings are considered the highest polluted water quality
category (Figure 5). The closest listings are in Squamish Harbor located approximately 0.5 mile
to the west of the Project site, with Category 2 listings for high levels of polychlorinated
biphenyls (Listing ID 86760) and methyl mercury (Listing ID 88778) found in the tissue of
Dungeness crab (Metacarcinus magister) and a Category 5 listing for fecal coliform bacteria in a
freshwater stream that discharges into the harbor (Listing ID 82954) (Ecology 2024a). Other
nearby listings to the south and southeast of the Project site in Hood Canal include Category 2
listings for dissolved oxygen (Listing IDs 66196, 38388) and Category 1 listings for temperature
(Listing IDs 65429, 65431, 65428, 38391) (Ecology 2024a).
5.1.1 Sediment Quality
Hood Canal is a fjord-like extension of Puget Sound that is separated from the main basin of
Puget Sound by sills that rise to between 164 and 246 feet of the water’s surface, whereas areas
north and south of the sill are approximately 574 feet in depth. The substrates in Hood Canal
are glacial drift substrates. However, there are several very large glacial erratics, and the seabed
contains bathymetric surface irregularities at several locations that are due to submarine
landslides (Polenz et al. 2010). Hood Canal is a relatively narrow fjord with shorelines
descending steeply to a U-shaped channel cross-section.
The shorelines are predominantly sandy beaches with mixed coarse, mudflats, and rocky
outcroppings also occurring (Berry et al. 2001). Much of Hood Canal includes fringing intertidal
areas that are predominantly sandy, with broader flats occupying the heads of some bays (e.g.,
Dabob, Quilcene, and Belfair bays), as well as river deltas (e.g., Duckabush and Big Quilcene
rivers).
May 2024 Page 15
Figure 5. Shoreforms in North Hood Canal. Source: (Ecology 2024b)
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The Project site is located on feeder bluff with net shore drift moving from left to right
(eastward) and is in a zone of unstable slope due to a history of landslides (Figure 6). This
unstable shoreline designation continues east and west along the shoreline from the Project site,
with unstable and intermediate stability slopes upland of the Project site. To the west of the
Project site there is a region of stable slope and to the east there is a modified slope where State
Highway 104 meets the shoreline. The shorelines adjacent to the Project include a sediment
transport zone to the west and an accretion shoreform to the northeast (Ecology 2024b). Upland
above the Project site and Squamish Harbor there is a relatively large deposit of recessional
outwash, which has high permeability and water capacity (ESA Adolfson et al. 2008).
5.1.2 Fish and Wildlife Presence
The intertidal, benthic, and pelagic habitats of North Hood Canal have the potential to support
a diverse community of terrestrial and aquatic species. This section discusses potential
occurrence and habitat use of ESA-listed and other protected species within North Hood Canal.
The following information provides an understanding of how various fish species or groups of
fish use the Project site.
Rockfish
Adult rockfish habitat for the 2 ESA-listed species – bocaccio (Sebastes paucispinis) and yelloweye
rockfish (S. ruberrimus) – primarily includes deepwater (>151 feet) rocky substrates and/or
shallower eelgrass and kelp beds (Drake et al. 2010). Both species have been observed within
shallower depths and non-rocky substrates such as sand, mud, and other unconsolidated
sediments (Borton and Miller 1980), although juvenile bocaccio are the main species recognized
as utilizing nearshore habitat (Love et al. 1991). Even then, use of the nearshore is primarily in
areas with rock or cobble composition and/or in the presence of kelp species (Love et al. 1991).
Rockfish larvae are pelagic and are found in Puget Sound from August through October
(Greene and Godersky 2012).
Critical habitat for rockfish includes all areas identified by NMFS as having physical and
biological features (PBFs) essential to the conservation of the listed species (79 FR 68041).
Juvenile settlement habitats located in the nearshore with substrates such as sand, rock, and/or
cobble compositions that also support kelp (families Chordaceae, Alariaceae, Lessoniacea,
Costariaceae, and Laminaricea) are essential for conservation because these features provide
rockfish forage opportunities and refuge from predators, and enable behavioral and
physiological changes needed for juveniles to occupy deeper adult habitats. The PBFs essential
to the survival of rockfish in nearshore areas include: (1) water quality and sufficient levels of
dissolved oxygen to support growth, survival, reproduction, and feeding opportunities;
(2) quantity, quality, and availability of prey species to support individual growth, survival,
reproduction, and feeding opportunities; and (3) areas free of obstruction for fish passage.
May 2024 Page 17
Figure 6. Coastal drift in North Hood Canal. Source: (Ecology 2024b)
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NMFS has mapped the waters within the Project site as nearshore critical habitat for bocaccio
and the waters just offshore of the Project site as deepwater critical habitat for both bocaccio and
yelloweye rockfish (NMFS 2024b).
Anadromous Fish
Anadromous fish that have the potential to occur within North Hood Canal include salmonid
species that spawn in freshwater and migrate out to saltwater as adults. Species that are listed at
the federal or state levels, or are considered locally important, are discussed here.
Chinook Salmon
The Puget Sound evolutionarily significant unit (ESU) of Chinook salmon (Oncorhynchus
tshawytscha) was listed as threatened under the ESA on March 24, 1999 (64 FR 14308). This
listing was most recently upheld on April 14, 2014 (79 FR 20802). The Puget Sound ESU includes
naturally spawned Chinook salmon originating from rivers of the Puget Sound, along with 25
artificial propagation programs.
Chinook salmon require substantial cover, high water quality, abundant foraging opportunities,
and cool water temperatures. Juvenile salmon first transition from fresh water into Puget Sound
through river estuaries, and wetlands within these systems are important to survival
(Magnusson and Hilborn 2003; Simenstad et al. 2011; David et al. 2016). These fish can then be
found along shorelines, especially juveniles and fry (Myers et al. 1998; Haring and Konovsky
1999; Kerwin 1999; Haque 2008). Because of this use of nearshore areas, ESA-listed Chinook
salmon could be present in shellfish aquaculture areas on a limited basis during the ocean phase
and juvenile outmigration phase of their life-history. The use of native eelgrass beds may be
especially important for Chinook salmon fry later in the outmigration period (Hodgson et al.
2016). Chinook salmon can also exhibit a wide range of alternative migration patterns, including
juveniles that migrate right away to the ocean, fish that remain as residents in protected river
estuaries, and fish that are considered transients and return to river estuaries after migration to
the ocean but before typical freshwater migration timing (Kagley et al. 2017). This diversity of
migration patterns can create some resiliency in the population.
Critical habitat for Chinook salmon includes nearshore marine areas of the Strait of Georgia,
Puget Sound, Hood Canal, and the Strait of Juan de Fuca from the line of extreme high tide out
to a depth of 98 feet (65 FR 7764). The PBFs essential to the survival of Chinook salmon in
nearshore areas include: (1) foraging habitat, (2) areas free of obstruction, (3) natural cover,
(4) appropriate salinity levels, and (5) high water quality and suitable water quantity.
There are no Chinook salmon runs documented in rivers or streams within 5 miles of the Project
site. However, the nearshore marine environment within the Project site overlaps within habitat
used by fall Chinook salmon migrating to and from spawning sites in Hood Canal and Dabob
Bay, and may also be used for foraging (WDFW 2024c).
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Chum Salmon
The Hood Canal ESU of chum salmon (Oncorhynchus keta) was listed as threatened under the
ESA on March 25, 1999 (64 FR 14508). This listing was most recently upheld on April 14, 2014
(79 FR 20802). The Hood Canal ESU all naturally spawned populations in Hood Canal and its
tributaries and the Olympic Peninsula rivers between Hood Canal and Dungeness Bay (NMFS
2024b). Hatchery stocks are included in this ESU. Both summer-run and fall-run chum salmon
selectively spawn in areas of groundwater upwelling or groundwater-fed systems (Fell et al.
2015). Fry emerge generally from March through May and immediately head to the river
estuary where they transition from fresh to salt water (Kuttel 2002). Juveniles occur in the
intertidal zone in the late winter and early spring. Adults occur in deeper water in the summer.
Critical habitat for chum salmon includes all nearshore marine areas of Hood Canal and the
Strait of Juan de Fuca to Dungeness Bay from the line of extreme high tide out to a depth of
98 feet (65 FR 7764). The PBFs essential to the survival of chum salmon in nearshore areas are
the same as those identified above for Chinook salmon. Critical habitat overlaps with the Hood
Canal region.
Chum salmon have been documented in small streams both across the Hood Canal from the
project site on the Kitsap Peninsula, and west of the project site in Squamish Harbor such as
Criss Creek, all within 2-3 miles of the project site (WDFW 2024a). In addition, the nearshore
environment within the project site overlaps with migratory habitat used by chum salmon
migrating to and from spawning sites in Hood Canal and Dabob Bay, and may also be used for
foraging.
Steelhead
The Puget Sound DPS of steelhead (Oncorhynchus mykiss) was listed as threatened under the
ESA on May 11, 2007 (72 FR 26722). This DPS includes all naturally spawned anadromous
winter-run and summer-run populations in streams of the Strait of Juan de Fuca, Puget Sound,
and Hood Canal, along with steelhead from 5 artificial propagation programs.
Steelhead do not typically frequent nearshore areas, although they may come into shallower
locations for foraging (Shreffler and Moursund 1999). Adult winter-run steelhead migrate to
spawning grounds typically in the fall or winter and summer-run migrate from late spring and
summer (Busby et al. 1996; NMFS 2019). Steelhead fry tend to emigrate quickly to deeper waters
(Moore et al. 2015). Although migration through Puget Sound is rapid, research indicates that
mortality rates of steelhead during adult migration is high.
Critical habitat for steelhead includes all areas identified by NMFS as having PBFs essential to
the conservation of the listed species (65 FR 7764). NMFS did not designate the nearshore zone
in Puget Sound as critical habitat because steelhead move rapidly out of fresh water into
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offshore marine areas (78 FR 2729). The PBFs essential to the survival of steelhead in nearshore
areas are the same as those identified above for Chinook salmon.
Steelhead have been documented in small streams west of the project site in Squamish Harbor
(WDFW 2024a). In addition, the nearshore environment within the project site overlaps with
migratory habitat used by steelhead migrating to and from spawning sites in Hood Canal and
Dabob Bay, and may also be used for foraging.
Bull Trout
The Puget Sound/Coastal DPS of bull trout (Salvelinus confluentus) was listed as threatened
under the ESA on June 10, 1998 (64 FR 58910). This DPS includes individuals in Idaho, Montana,
Nevada, Oregon, and Washington. Critical habitat was subsequently designated in 2005 (70 FR
56212). The most recent version of critical habitat for bull trout was designated on September 30,
2010 (75 FR 63898). It includes approximately 18,795 miles of streams and 488,252 acres of lakes
and reservoirs in Idaho, Oregon, Washington, Montana, and Nevada, along with 754 miles of
marine shoreline in Washington.
Puget Sound is generally used as a migration corridor or foraging area, and anadromous bull
trout occupy territories ranging from about 33 feet to 2 miles and within 328 feet to 1,312 feet of
the shoreline. Migration provides access to more abundant or larger prey and possible
overwintering options (Brenkman and Corbett 2005). Therefore, there is potential for bull trout
to be distributed into all regions of this analysis for foraging. The majority of bull trout tend to
migrate into marine waters in the spring and return to the rivers in the summer and fall
(USFWS 2004), with a few fish overwintering in marine waters (Goetz et al. 2003).
Critical habitat for bull trout includes all areas identified by USFWS as having PBFs essential to
the conservation of the listed species (75 FR 63898). The PBFs essential to the survival of bull
trout in nearshore areas include: (1) migration areas with minimal physical, biological, or water
quality impediments; (2) an abundant food base, complex marine shoreline environments; (3)
water temperatures ranging from 26 to 59°F; (4) sufficient water quality and quantity; and
(5) sufficiently low levels of occurrence of non-native predatory or competing species.
Although there is no documented spawning in rivers and streams flowing into North Hood
Canal, bull trout may use the area as foraging, migration, or overwintering habitat.
Coastal Cutthroat Trout
Coastal cutthroat trout (Oncorhynchus clarki clarki) are not listed at the federal or state levels but
are listed in the WDFW PHS database (WDFW 2024a). Coastal cutthroat trout are distinct from
other trout in their abundance of small- to medium-sized spots of irregular shapes (WNTI 2022).
Coastal cutthroat trout generally have 1 of 3 life history strategies: (1) non-migratory,
(2) freshwater-migratory, or (3) saltwater-migratory. It is fish employing this third life history
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strategy that could potentially interact with the Project. Saltwater-migratory coastal cutthroat
trout are anadromous, starting out in freshwater habitats and migrating to marine
environments. Migration typically starts in the late winter and spring so that they can feed in
estuarine and nearshore habitats during the summer. They then return to freshwater habitats in
the winter to feed, seek refuge, or spawn (WNTI 2022).
Coastal cutthroat trout rely on a wide variety of habitats within freshwater and marine systems.
Unlike most other anadromous salmonids, coastal cutthroat trout do not remain in the ocean
over the winter and do not typically make long migrations (WNTI 2022). They spend much
longer in freshwater habitats than other salmonids (usually 2-5 years).
Coastal cutthroat trout are well-distributed throughout Puget Sound and are likely to utilize
habitats within Hood Canal. Coastal cutthroat trout have been documented west of the Project
site in Squamish Harbor (WDFW 2024d).
Coho Salmon
Coho salmon (Oncorhynchus kisutch) are not currently listed at the federal or state levels but are
considered a species of concern. The Puget Sound population is considered to be a distinct
population and has been noted for its depressed status in recent years.
The life history of coho salmon is similar to other Pacific salmonid species. However, coho
salmon tend to use a wider array of habitats than other native anadromous species, including
headwater streams, small coastal creeks, and tributaries to major rivers (Meehan and Bjorn
1991). Adult coho salmon are typically divided into 2 main categories based on habitat use:
ocean type and coastal type (Groot and Margolis 1991). Ocean type fish rely on offshore waters,
while coastal type fish rely on nearshore waters. Juvenile coho salmon spend the first 1 to
2 years of life in freshwater, relying on structured habitat for protection from high flow
environments. They feed primarily on aquatic insects (e.g., mayflies, caddisflies, and
chironomids), but also eat terrestrial insects and worms. As they grow larger, they feed on
larger invertebrates and some smaller fish (Groot and Margolis 1991; Wydoski and Whitney
2003). During outmigration, coho salmon often make use of estuarine habitats for several weeks
for feeding and rearing (Miller and Sadro 2003).
Although the distribution of coho salmon within Puget Sound is not well understood, there is
potential for coho salmon to utilize habitats within Hood Canal during migration. Coho rearing
has been documented in Criss Creek in Squamish Harbor west of the project site (WDFW
2024c). In addition, the nearshore environment within the project site overlaps with migratory
habitat used by coho salmon migrating to and from spawning sites in Hood Canal and Dabob
Bay, and may also be used for foraging.
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Forage Fish
Forage fish are an important dietary resource for higher trophic-level fish, birds, and marine
mammals. Spawning habitat and presence of forage fish eggs are resources of conservation
interest, and document spawning locations are tracked by WDFW (2024e). There are 2
spawning strategies used by the main forage fish species discussed below, and thus 2 different
potential locations for forage fish eggs to occur in association with shellfish aquaculture farms,
including:
1. Upper Beach Spawners: Surf smelt and Pacific sand lance spawn in sand to pea-gravel-
sized sediments. Surf smelt primarily spawn at elevations of +7 feet MLLW and up to
mean higher high water (MHHW).1 Pacific sand lance primarily spawn at elevations of
+5 feet MLLW and up to MHHW. Rock sole are also considered upper beach spawners,
although their habitat is not identified as a forage fish spawning habitat regulated under
State or local code.
2. Nearshore Broadcast Spawners: Pacific herring broadcast-spawn adhesive eggs in
nearshore waters (between 0 and -10 feet MLLW). Herring eggs may adhere to any
substrate within the area where spawning occurs, including vegetation, rocks, shell
fragments, sand, and other hard surfaces. Egg survival depends on the availability of
suitable substrate.
The most common forage fish species (i.e., surf smelt, Pacific sand lance, and Pacific herring)
generally spawn during the winter months, although surf smelt have a longer spawning season
(Penttila 2007). Sand lance will also spawn in the fall, although less is understood about sand
lance spawning behaviors. Herring spawn timing depends on the stock and region of origin
(Sandell et al. 2019).
Potential overlap between documented forage fish spawning areas and culture beds is relatively
low, with the possible exception of low amounts of Pacific herring spawn that are considered
spillover from documented spawning locations. According to WDFW (2024e), there are no
documented forage fish spawning locations associated with the Project site. The closest Pacific
herring spawning location is approximately 0.3 mile to the west. There is a Pacific herring
holding area offshore from the Project site.
1 Puget Sound monitoring shows that surf smelt and sand lance primarily spawn in habitat above +7 feet
and +5 feet MLLW, respectively, relative to the Seattle datum (Dionne, WDFW, pers. comm., 2016). It is
likely higher in South Sound with a higher tidal range. Moulton and Penttila (2006) report forage fish
spawning and incubation as between +7 feet and +9 feet MLLW.
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Birds
Birds that are listed at the federal or state level, or are considered locally important, are
discussed here with regards to their potential occurrence and use of North Hood Canal. These
include marbled murrelet (Brachyramphus marmoratus), great blue heron (Ardea herodias),
shorebirds, and eagles.
Marbled Murrelet
Marbled murrelets are small marine birds in the Alcidae family. Marbled murrelets range from
Alaska to California (USFWS 1992), and forage in coastal waters of the eastern Pacific Ocean
from central California to the Aleutian Islands (Miller et al. 2012). They spend most of their time
foraging at sea and use only old-growth forest areas for nesting. In the critical nesting areas,
fragmentation and loss of old-growth forest has a significant impact on the survival and
conservation of the species (Huff et al. 2006). Adult birds are found within or adjacent to the
marine environment where they dive for sand lance, sea perch, Pacific herring, surf smelt, other
small schooling fish and invertebrates.
The marbled murrelet forages in nearshore marine subtidal and pelagic habitats along the
Pacific Coast, usually within 1.2 miles of the shoreline (USFWS 1992). Speich and Wahl (1995)
observed that murrelets tend to be most abundant over eelgrass and kelp substrate, on
shorelines with broad shelves, and along shorelines with narrow shelves where kelp is present.
They reported that significant numbers of murrelets might also be found in areas of tidal
activity. “The Great Bend” area is recognized by Washington Audubon as a State Important
Bird Area (IBA) and supports significant numbers of marbled murrelet during the summer
(Pacific Flyway Council 2018). During the 2023 winter aerial seabird survey, marbled murrelets
had a density of 0.1 and 3.2 birds/km2 in nearshore areas of Hood Canal and Admiralty Inlet
basins, respectively (WDFW 2024f). Murrelets feed primarily on fish and invertebrates (Burkett
1995), and exhibit a diversity in diet composition that allows them to take advantage of
whatever fish prey resources are available in their forage areas. Nesting occurs in mature,
coastal coniferous forest, with nest cups built on large branches in tall trees (Nelson 1997).
There is no critical habitat for marbled murrelets within or close to the Project site. While
murrelets have historically been observed in Hood Canal, they’re increasingly rare in the area
due to loss of nesting habitat (e.g., old-growth forest). Murrelets could conceivably forage on
the water near the Project site.
Great Blue Heron
Great blue herons occur year-round throughout the Puget Sound, preying upon fish, reptiles,
invertebrates, small mammals, and amphibians in nearshore and intertidal habitats. Herons are
frequently observed resting and hunting atop floating artificial structures in nearshore waters
and have an established presence in North Hood Canal. During the 2023 winter aerial seabird
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survey, great blue herons had a density of 0.3 and 1.0 birds/km2 in nearshore areas of Admiralty
Inlet and Hood Canal basins, respectively (WDFW 2024f).
The breeding season extends from January to March and lasts for approximately 6 months
(July-September). Great blue herons do not typically occupy nests or colony sites (i.e., rookeries)
year-round, although individual or small aggregations may use these areas for roosting and
loafing (Eissinger 2007). The closest heron rookery to the Project site is about 1.5 miles northeast
in Shine Tideland State Park. Great blue herons are known as indicator species of
environmental health because they concentrate contaminants through biomagnification of
locally derived toxins found in small prey.
Shorebirds and Eagles
Shorebirds are commonly found along shorelines and mudflats, and are frequently observed
wading through shallow water while foraging for food in the mud or sand (eBird 2020). Most
species prey upon small invertebrates picked out of the mud or sand. Many of the species
observed along Washington shorelines are migratory and protected through the Migratory Bird
Treaty Act. Over 273 bird taxa have been documented in the southern portion of Hood Canal,
from the bend eastward. The Great Bend area is recognized by Washington Audubon as
providing an important wintering and staging area for black brant (Branta bernicla) (Pacific
Flyway Council 2018). Dunlin (Calidris alpina) and killdeer (Charadrius vociferus) are the most
observed shorebirds in the area, and dominant species that overwinter include western grebe
(Aechmophorus occidentalis), scaup (Aythya spp.), scoter (Melanitta spp.), and American wigeon
(Mareca americana). The northern portion of the Canal also provides important intertidal,
estuarine habitat, and hosts large concentrations of marine birds, including black brant,
American widgeon, and surf scoter.
Bald eagles (Haliaeetus leucocephalus) are relatively abundant in Hood Canal. As of 2005,
Washington hosted over 1,500 breeding pairs of resident eagles, and data suggest this number
has continued to rise (Kalasz and Buchanan 2016). In addition to this resident population,
Washington provides overwintering habitat for birds that nest in Canada and Alaska. During
the 2023 winter aerial seabird survey, bald eagles had a density of 0.2 and 0.4 birds/km2 in
nearshore areas of Hood Canal and Admiralty Inlet basins, respectively (WDFW 2024f). Bald
eagles nest and roost in forested areas adjacent to shorelines or large bodies of water, and
territories that contain at least 1 tall, mature perching tree that affords a wide view of the
surroundings (Kalasz and Buchanan 2016). Diet is predominantly fish, but eagles are
opportunistic and also eat birds, mammals, and carrion. Because bald eagles are protected
under the Bald and Golden Eagle Protection Act, there is an emphasis on ensuring that
shoreline activities, in general, do not disturb eagles.
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Marine Mammals
Marine mammals are protected under the Marine Mammal Protection Act. The discussion
below is broken into: (1) whales, and (2) other marine mammals.
Whales
The southern resident killer whale (SRKW; Orcinus orca) were listed as endangered under the
ESA in November 2005 (70 FR 69903). SRKW are primarily found in the Salish Sea during
spring, summer, and fall months but occur off the coast from Monterey, California, to southeast
Alaska during the winter. Their range shifts based on the availability of salmon, which is their
main food source. Olson et al. (2018) compiled SRKW sighting data in the Salish Sea from 1948
through 2017. The report provided data on a total of 49,491 sightings, including 2,113 SRKW
sightings in 2017. Sightings primarily occur within North Sound. The 2017 data follow the
standard decadal mean, with the highest number of sightings occurring during the late fall and
winter months (Olson et al. 2018). SRKW that migrate into Puget Sound typically make it as far
south as the Nisqually River (Wiles 2004). Designated critical habitat for SRKW occurs
throughout Puget Sound but excludes areas less than 20 feet deep, relative to extreme high
water (NMFS 2020). Intertidal areas commonly used for shellfish aquaculture are typically
outside of critical habitat, based on this definition.
Transient killer whales (e.g., mammal-eating whale vs. the resident salmon-eating whales) have
been reported within Puget Sound but are more unpredictable in their movements compared to
the SRKW. According to Wiles (2004), most sightings of transients in Washington occur in the
summer and early fall, with smaller numbers continuing throughout the year.
Humpback whales (Megaptera novaeangliae) were first listed as endangered on December 2, 1970
(35 FR 18319). Revision of their listing to break down the humpback whale population into 14
DPSs was finalized in 2016 (81 FR 62259) with the Central America DPS and Western North
Pacific DPS maintaining endangered status, and the Mexico DPS being adjusted to
threatened. Humpback whales often occur in Puget Sound. The Western North Pacific DPS
primarily occurs further off the coast compared to the regions analyzed in this report. The
Mexico DPS and Central America DPS comprise about 36% of the humpbacks occurring within
the Puget Sound, with the other 64% belonging to the Hawaii DPS, which is not federally listed
(Sato and Wiles 2021). During migration, humpback whales stay near the surface of the ocean
(NMFS 2024a). While feeding and calving, they prefer shallow waters. During calving,
humpbacks are usually found in the warmest waters available at that latitude. Calving grounds
are commonly near offshore reef systems, islands, or continental shores. In contrast, humpback
feeding grounds are in cold, productive coastal waters. Puget Sound is not recognized as a
calving or migration area for humpback whales, although in recent years they have been
observed in greater numbers in the Salish Sea and likely still use portions of North Sound and
South Sound for feeding where stocks of prey fish are sufficient (Falcone et al. 2015). In Puget
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Sound as a whole, the slight increase in sightings in more recent years could be a reflection of a
rebound in population status of humpback whales in the eastern Pacific, as documented in a
recent extensive census of North Pacific populations (Calambokidis et al. 2008). They have been
documented within Hood Canal (Orca Network 2021), meaning they could be present in the
vicinity of the Project site.
The other ESA-listed whales do not frequently occur within Washington’s inland waters. Rare
fin whale (Balaenoptera musculus) sightings in Puget Sound occurred in 2015 and 2016, but these
were the first in decades; the majority of reported sightings are off the coast of Washington
(Wiles 2017). Food sources and foraging habits of these whales keep them primarily in deeper
waters, and they are unlikely to come into the shallow bays and estuaries associated with
shellfish aquaculture operations.
Gray whales (Eschrichtius robustus) are an open ocean species most commonly found off the
coast from Baja California to the Bering and Chukchi seas. Aggregations occur off the coast of
Washington during winter and spring migrations but are uncommon in Puget Sound
(Calambokidis et al. 2002). A small group of gray whales was observed returning to waters
around Whidbey Island in the spring of 2013 to feed, and this is the typical southern extent of
gray whale sightings in Puget Sound (Orca Network 2021). There have been documented
sightings of gray whales in Hood Canal (Orca Network 2021).
Other Marine Mammals
Harbor seals (Phoca vitulina) are present within Puget Sound and waters of Washington State
year-round (Gustafson et al. 2000). Haul-out locations have been identified in Port Gamble Bay
approximately 2.5 miles from the Project site (Jeffries et al. 2000). Harbor seals are the only
pinniped species that also breed in Washington waters. In Hood Canal, pups are typically born
between August through January.
California sea lions (Zalophus californianus) are present in Puget Sound between late summer
and late spring (Gustafson et al. 2000). They breed in waters off the coasts of California and
Mexico. Only the males migrate north to the waters of Washington and British Columbia. Haul-
out locations have been identified within the South Sound, but this species has the potential to
occur throughout the analysis regions, depending on the time of year (Jeffries et al. 2000).
Steller sea lions (Eumetopias jubatus) occur primarily on the outer coast of Washington, although
they have been documented in the South Sound and have the potential to occur throughout
Puget Sound and in Willapa Bay (Jefferies et al. 2000). There are no breeding rookeries in
Washington and therefore densities of the sea lions vary seasonally. Peak counts typically occur
during the fall and winter months.
The harbor porpoise (Phocoena phocoena) and Dall’s porpoise (Phocoenoides dalli) typically occur
in North Sound (Gustafson et al. 2000; Palazzi and Bloch 2006). However, both species of
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porpoise are consistently sighted in South Sound (Orca Network 2021). Harbor porpoises have
become much more common within Puget Sound in recent years, after an almost complete
disappearance (The Seattle Times 2013).
Pacific white-sided dolphins (Lagenorhynchus obliquidens) most often occur offshore but
occasionally enter the Salish Sea (Cascadia Research 2020). Most sightings have been
documented within North Sound (Orca Network 2021), although there is the potential for this
species to occur in Hood Canal or South Sound.
Common dolphins (Delphinus delphi) and bottlenose dolphins (Tursiops truncatus) typically
occur in warmer waters off California but have been sighted more frequently in Puget Sound
since 2016 and 2017 (Cascadia Research 2017, 2020). Rarely, dolphins will also make their way
down to South Sound. Most of the two groups of dolphins that show up make their way back
out of inland waters. Sightings of both species have occurred in the North Sound and South
Sound, and have occurred annually since the initial sightings.
Sea Otters (Enhydra lutris kenyoni), which number just over 1,000 in Washington state, are
typically distributed between Pillar Point in the Strait of Juan de Fuca to south of Destruction
Island off the Washington state coast. However, they have been occasionally seen in Puget
Sound waters, and there is potential for the species to occur in Hood Canal (USFWS 2024b).
Invertebrates
The longest data set for Puget Sound on benthic invertebrates is through Ecology (Partridge et
al. 2018). Ecology measured benthic invertebrate communities as part of a sediment quality
analysis for Puget Sound health. Based on over 27 years of data at 10 sentinel stations, Partridge
et al. (2018) reported relationships between the benthic community and habitat, contaminants,
and other variables (Partridge et al. 2018). Occurrence, abundance, and type of invertebrates
varied considerably by station. However, the average proportions of the major taxa were similar
across the stations. The North Hood Canal station had the highest total abundance (Figure 7).
Species diversity was highest at the sandiest stations – North Hood Canal and Anderson Island
in Carr Inlet – and lowest at the northern and southern extremes of Puget Sound. Similarities of
the invertebrate communities reflect the similarities of depth and grain size in the habitats.
Changes in species composition were observed when there were also changes in sediment grain
size (e.g., more sand and less clay).
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Figure 7. Mean total abundance (a) and mean diversity (b) by taxonomic group. Source: Partridge et al. 2018
One of the most important measurements of invertebrate community structure is trophic
structure or functional feeding guilds (Figure 8). Partridge et al. (2018) commented that, “Even
though species and abundances may vary considerably over time, in stable systems ecological
functions [or trophic structures] are conserved.” In other words, the response of the invertebrate
community to an environment is integrated through time and does not depend on one species
(Partridge et al. 2018). The Ecology data indicates that there was a shift in feeding guilds from
2000 compared to about half the other years. This change showed a shift from detritivores to
deposit feeders in most of the sampling stations and the opposite at Anderson Island. For
Anderson Island, the authors indicated that this shift was likely due to the changes in substrate
composition to more sand and less clay.
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Figure 8. Mean total abundance (a) and mean diversity (b) by functional feeding guild. Source: Partridge et al. 2018
Species commonly harvested within intertidal locations near the Project site include horse clams
(Tresus capax), littleneck clams (Protothaca staminea), cockles (Cerastoderma edule), butter clams
(Protothaca staminea), and Manila clams (Venerupis philippinarum) (WDFW 2024g, 2024h). Shine
Tidelands State Park is about 2000 feet northeast of the Project site and represents a common
harvest location (WDFW 2024h). Other benthic or infaunal taxa in North Hood Canal include
various worms, other echinoderms (e.g., sea cucumbers, urchins, and sand dollars), and other
bivalves (WDFW 2024i).
5.1.3 Kelp and Eelgrass Beds
The Washington State Department of Resources (DNR) monitors the abundance and
distribution of eelgrass and other seagrass species in the Greater Puget Sound, both because of
their status as indicators of estuary health and because they serve as key species in nearshore
ecosystems (DNR 2024a). Washington DNR surveys in 2005 and 2010 in the southwest of
Squamish Harbor and near Bywater Bay identify beds of native eelgrass (Zostera marina), while
surveys in the eastern part of Squamish Harbor, directly west of the Project site, identify beds of
native eelgrass mixed with non-native dwarf eelgrass (Zostera japonica) growing closer to the
shore. This is representative of Hood Canal overall, with most surveys showing seagrass beds
of only native eelgrass or beds with a mix of native eelgrass and dwarf eelgrass. Based on data
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from 2000-2020, most surveyed native eelgrass in Hood Canal shows no trend in abundance
change over time, including the beds surveyed nearest to the Project site (DNR 2024a).
A Marine Surveys & Assessments (MSA) survey from June 2023 reported that the Project site
supports a variety of seagrass (MSA 2023). The seagrass bed closest to the shore within the
Project site is dominated by dwarf eelgrass (0-613 shoots/m2), which transitions to a mixed bed
of dwarf and native eelgrass a few hundred feet into the water (0-1,333.3 shoots/m2). At about
500 ft offshore, there is a seagrass bed composed of only native eelgrass (0-128 shoots/m2).
Laminaria and macroalgae coverage in the Project site begin about 300 feet offshore and
increase with distance from shore in the surveyed area.
5.2 Wetlands
Estuarine wetland area in Hood Canal has increased from approximately 6,170 acres to 6,350
acres since historical mapping efforts in the 1800s (Simenstad et al. 2011). This overall increase
in acreage is driven by an increase in estuarine mixing wetlands, which masks the near
complete loss of oligohaline transitional wetlands associated with Hood Canal deltas
(Simenstad et al. 2011). There are no deltas or oligohaline transitional wetlands associated with
the Project site. Hood Canal eelgrass cover is primarily composed of fringe sites along sloping
intertidal and shallow subtidal areas, whereas many other areas are dominated by a relatively
small number of large eelgrass flat sites (Christiaen et al. 2017). Eelgrass cover in Hood Canal
has increased from an estimated 4,900 acres in 2004 to 5,690 acres in 2015 (Christiaen et al. 2017).
The vast majority of eelgrass in Hood Canal occurs between 0 feet MLLW and -9.8 feet MLLW
(Christiaen et al. 2016).
The Project site falls within a continuous stretch of estuarine and marine wetland habitat
covering 386.87 acres that follows the shoreline from Squamish Harbor north to Port Ludlow
(USFWS 2024c). This habitat is characterized by having deepwater tidal habitats adjacent to
tidal wetlands, presence of ocean water mixing with freshwater runoff, substrate that is flooded
and exposed by tides daily, and an unconsolidated shore that has less than 75% areal cover of
stones, boulders, or bedrock and less than 50% areal cover of vegetation. The next closest
wetland features to the Project site are inland to the west and east. These wetland features are
two freshwater emergent wetland habitats characterized by seasonal saturation and presence of
perennial species that are present for most of the growing season, dominated by trees, shrubs,
moss, and lichen (USFWS 2024c).
5.3 Geologically Hazardous Areas
The Project site falls within some geologically hazardous areas, with identified erosion, slope
stability, landslide, and seawater intrusion risks (Jefferson County 2024a). Information from the
Soil Conservation Service marks the shoreline where the Project site is located as an area with
erosion risk. While the Project site has low liquefaction susceptibility, it has a high potential risk
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of earthquake damage through ground shaking, slope failure, settlement, or surface faulting
and the Coastal Zone Atlas of Washington marked the area within the Project site as an unstable
shoreline. The Project site is within a coastal seawater intrusion protection zone, with high risk
seawater intrusion protection zones on either side of the Project site along the shoreline
(Jefferson County 2024a).
5.4 Critical Aquifer Recharge Areas (CARAs)
Critical Aquifer Recharge Areas (CARAs) are defined in Washington’s Growth Management
Act as “areas with critical recharging effect on aquifers used for potable water.” The Project site
boundaries do not include any CARAs, although there are geologically susceptible CARAs just
inland to the north and down shore to the west from the Project site. Further to the west and to
the north there are also two CARAs designated as Special Aquifer Recharge Protection Areas
(Jefferson County 2024a).
5.5 Frequent Flood Areas
Flooding is a frequent occurrence in Jefferson County in winter months, with damaging floods
occurring every 4 years on average and the County being listed 8 times from 1982 to 2005 for
flood-caused national disasters. Floods in Jefferson County are most common at river mouths
where high river waters are held back by ocean water surges and strong winter storm wind.
(Ecology 2024c). Big Quilcene, Little Quilcene, and Dosewallips rivers, the mouths of which are
10 to 20 miles southwest of the Project site, are all flood-prone. These rivers are short with steep-
sided banks, causing water to rise and recede quickly, the effects of which are compounded by
tidal action and strong southern winds holding water against shores. The floods that result are
often short-term, but can still cause extreme damage (Jefferson County 2016). While not directly
adjacent to these large river mouths, the Project site falls within a region on the shoreline that
has a 1% or higher annual change of flooding, making it a high-risk flood zone. Specifically, it
falls within a velocity area, meaning that it is subject to high velocity wave action (3-foot
breaking waves) during coastal floods (Ecology 2024c).
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6.0 EFFECTS ANALYSIS
Based on the potential overlap with critical areas presented in Section 5.0 above, FWHCAs are
the main critical habitat potentially present in the Project vicinity. Estuarine wetlands are also
present, but potential effects are covered under kelp and eelgrass beds of the FWHCAs.
Therefore, this effects analysis addresses the potential Project-related effects to the
environmental attributes and habitat qualities important to fish and wildlife species that may be
present in the Project vicinity per the requirements identified under Articles VI (Fish and
Wildlife Habitat Conservation Areas) and IX (Special Reports) of Chapter 18.22 JCC.
In addition, the Jefferson County SMP indicates that new or expanded aquaculture shall be
located, designed, and maintained to assure no net loss of ecological functions (JCC
18.25.270(2)), including cumulative impacts (JCC 18.25.270(3)). There is at least one known
proposal for similar actions in North Hood Canal (i.e., intertidal shellfish culture), and there are
other shellfish activities that include commercial, tribal, and recreational shellfish harvest in the
area.
The information presented below is consistent with, and builds upon, the analysis and
evaluation of impacts associated with shellfish activities in Washington State inland marine
waters described in the Corps (2015) Programmatic Biological Assessment (PBA) and the
associated programmatic consultation (USFWS 2016; NMFS 2016). The programmatic
consultation covers continuing shellfish farming activities along with new shellfish farming,
commercial harvest, recreational harvest, tribal harvest, and restoration activities over an
anticipated 20-year timeline and is considered a state-wide cumulative impacts assessment.
Presented below are discussions of the direct and indirect effects of the Project, including:
Water quality
Sediment quality
Fish and wildlife habitat
Invertebrates
Kelp and eelgrass beds
Navigation and public use
No net loss and cumulative impacts
Note that much of the literature discussed below relates to near-bottom shellfish gear, including
oyster longlines in intertidal areas. While these studies provide information using best available
science, there are differences compared to the proposed Project using SEAPA basket culture
methods. For example, SEAPA baskets typically use rebar racks instead of polyvinyl chloride
(PVC) stakes and rope. These differences will be identified below when discussing effects of
shellfish culture methods that are related but may not result in the same effects.
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There are no effects to geologically hazardous areas, CARAs, and frequently flooded areas. This
determination is based on the location of the activities (below OHWM) and type of
development (shellfish aquaculture). Therefore, no additional discussion is presented below on
these critical areas.
6.1 Water Quality
It is recognized both regionally and federally that shellfish aquaculture can have both positive
and negative effects on water quality (Tallis et al. 2009; Dumbauld et al. 2009; National Research
Council and Ocean Studies Board 2010). For the most part, negative effects are short-term and
result in what Dumbauld et al. (2009) defines as “pulse disturbances.” A pulse disturbance is a
short, discrete event such as harvest of on-bottom shellfish products or gear placement,
compared to a “press disturbance” that is a longer-lasting chronic event that results in a loss of
estuarine habitat such as the installation of roadways, bulkheads, groins, or dikes. Note that
harvest for the Project include removal of baskets, so there is unlikely to be a pulse disturbance
of this activity in terms of water quality effects.
The shellfish aquaculture industry is reliant on the maintenance of good water quality
conditions to ensure the safety and survival of their product. Numerous actions have already
been taken in the Hood Canal area to improve water quality with the goal of supporting
shellfish harvesting. These include creating the Jefferson County Clean Water District (WDOH
2024b), tracking pollution and contaminants that affect shellfish farms (WDOH 2024a), and
addressing state-wide goals to improve the amount of harvestable shellfish beds (PSP 2024).
The following information is a discussion on potential impacts to water quality from the
proposed Project, including (1) water circulation, (2) contaminants, and (3) suspended
particulates/turbidity.
6.1.1 Water Circulation
Water circulation influences sediment distribution and dissolved oxygen concentrations. The
proposed Project can potentially influence water circulation due to the presence of culture gear.
Turner et al. (2019) measured current speed and water quality variables within and adjacent to 4
oyster farms in Chesapeake Bay associated with floating (i.e., caged grow-out areas) and on-
bottom culture. The authors reported statistically significant differences in current speeds
within the oyster gear. However, the magnitude of change to water quality variables were
minor. The authors indicated that differences based on natural seasonal changes were far
greater in magnitude compared to inside and outside of the farm footprint.
These results are consistent with studies associated with longline gear in Willapa Bay paired
with previous work in the region (Banas and Hickey 2005; Confluence 2016). A boat-based
Acoustic Doppler Current Profiler survey was conducted in Willapa Bay to measure current
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speed and direction up-current, down-current, and within oyster longline culture beds. The
major effects of the oyster longlines included:
Differences in current speeds and current direction within and outside of culture areas
were not significant.
Differences in current speeds and current direction up-current and down-current of
culture areas were not significant.
Current speed and direction with depth and at discrete distance intervals along each
study transect were highly variable.
Complex circulation patterns existed because of a naturally complex seabed (eelgrass,
channels, bed roughness).
The study concluded that tidal currents are one of the forces contributing to sediment transport
and sediment distribution in the area of oyster longline culture gear on the mudflats in Willapa
Bay, but they are not the most active means for sediment transport. Other studies have shown
that sediment transport within channels and adjacent to channels is more active than on
mudflats (Banas and Hickey 2005; Forrest et al. 2009).
Overall, the existing literature indicates that shellfish aquaculture gear can have a measurable
effect on water circulation but that does not translate into a significant change in water quality
parameters. Ways in which shellfish growers watch for specific patterns in water circulation is
observing whether oyster longlines (or SEAPA baskets) are working with the general pattern of
sediment movement (i.e., no significant effect) or against these patterns (i.e., noticeable
sediment accumulation/erosion). In the latter case, gear is moved to work with the general
patterns observed so that the ultimate change, with adaptive management, is minor.
6.1.2 Contaminants
North Hood Canal is an important shellfish production area, but has a history of closures in
portions of the canal from high fecal coliform levels or harmful algal blooms (Dawson 2020,
2021, 2022; Jefferson County 2024c). These occurrences are likely a result of non-point
contamination sources such as urban and industrial run-off (e.g., stormwater). A growing body
of existing literature indicates that shellfish aquaculture, or the presence of a bivalve
community, may provide some control of human nutrient loading to waterbodies (Shumway et
al. 2003; Newell 2004; Newell et al. 2005; National Research Council and Ocean Studies Board
2010; Burkholder and Shumway 2011; Kellogg et al. 2013; Banas and Cheng 2015). Bivalves
remove more nutrients from the water column than they input as feces or pseudofeces2 (also
known as biodeposits), which can have a net benefit to water quality.
2 Pseudofeces are biodeposits resulting from a specialized method of expelling materials by filter-feeding
bivalves that enables them to excrete suspended particles that cannot be used as food (e.g., particles of
silt). The rejected particles are wrapped in mucus and expelled.
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Bivalves filter large quantities of organic matter from the water column and assimilate nitrogen
and phosphorus into their shells and tissue (Newell et al. 2005). When shellfish are harvested,
the sequestered nutrients are permanently removed from the system, also known as
bioextraction. According to Newell (2004), bioextraction is one of the only methods available
that removes nutrients after they have entered a system, which can then make that system more
resilient to nutrient loading and ultimately decreases in dissolved oxygen. Kellogg et al. (2013)
also indicated that oyster reef restoration could be considered a “safety net” to reduce impacts
to water quality from urban sources.
In a more recent study by Kellogg et al. (2018), the authors quantified the ecological benefits and
impacts of oyster aquaculture in Chesapeake Bay. Water quality was one of the main
measurements to understand effects associated with shellfish culture in the bay. The results
indicated that there were few impacts, positive or negative, detected from the oyster
aquaculture operations. However, the authors calculated that there was a removal of 21 to 372
pounds of nitrogen and 3 to 49 pounds of phosphorus per farm per year. As stated by the Corps
(2020), “Oyster mariculture [aquaculture] activities may not provide identical ecological
functions and services and functions as natural oyster reefs, but cultivated oysters do provide
some of these functions and services without substantial investment of public funds (Kellogg et
al. 2018) that may be needed for restoration activities.”
The proposed Project does not contribute to potential contamination of the surrounding water
and depends heavily on maintaining good water quality conditions for the health of the
shellfish. The existing literature suggests that shellfish provide a mechanism for removing
excess nutrients from the system, which can protect a system from eutrophication. In addition,
having a commercial shellfish operation in North Hood Canal provides incentives to improve
water quality conditions. Overall, potential effects to contaminants by the proposed Project are
considered beneficial.
6.1.3 Suspended Sediments/Turbidity
Project actions include the installation of anchors, frames, and SEAPA baskets. During gear
installation, suspended sediments or turbidity is generated. The proposed Project site is within
an approved location and not associated with fecal coliform bacteria problems or areas with
sediment contamination (Ecology 2024a; WDOH 2024a). Short-term increases in suspended
sediment may occur during gear installation, but these impacts are expected to be negligible
compared to existing movement of sediments in the surrounding intertidal habitat. The Project
area is an estuarine environment that has regular short-term increases in suspended sediment
from wind-wave action, tidal movement, and longshore sediment transport (Ecology 2024b).
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6.1.4 Summary of Water Quality Effects
The need for good water quality conditions is inherent in shellfish aquaculture operations.
Presence of the proposed Project and a water quality advocate by Rock Island Shellfish are the
impetus behind monitoring and maintaining water quality such that it meets WDOH criteria.
The benefits of this can be observed through the work of multiple groups in Washington State
that track and improve water quality conditions, including: (1) the creation of the Jefferson
County Clean Water District (WDOH 2024b), (2) tracking of pollution that affect shellfish farms
(WDOH 2024a), and (3) state-wide goals to improve the amount of harvestable shellfish beds
(PSP 2024).
Potential impacts to water quality associated with the proposed Project include water
circulation, contaminants, and suspended particulates/turbidity. Overall, shellfish aquaculture
is recognized for both positive and negative effects on water quality. Negative effects are seen
as pulse disturbances that do not have lasting impacts on water quality. These negative effects
are considered to be negligible in relation to the proposed Project and well within the natural
variability in water quality parameters. In contrast, positive effects with a well-managed farm
can have lasting improvements to water quality and is seen as a way to reduce the potential for
eutrophication within an estuary. This is because shellfish harvest removes excess nutrients
from a system and can make that system more resilient to nutrient contamination concerns.
6.2 Sediment Quality
Potential mechanisms for the proposed Project to affect sediment quality include changes in
substrate accumulation or erosion due to the presence of gear and the contribution of
biodeposits to the surrounding sediment. Note that changes in the benthic invertebrate
community due to the presence of gear is discussed in Section 6.4 below.
6.2.1 Culture Gear
The Project site is a uniform mixture of sandy habitat from recessional glacial outwash and the
feeder bluff along the shoreline (ESA Adolfson et al. 2008; Ecology 2024b). SEAPA basket
culture methods use anchors and frames and are spaced at regular intervals. The culture areas
are located within 2 separate areas of the Project site (refer to Figure 3), totaling approximately
2 acres within a larger 6-acre intertidal area.
Based on various studies at existing shellfish aquaculture farms, erosion and deposition near
structures has been documented, but these small-scale processes are difficult to quantify
compared to the surrounding habitat. Rumrill and Poulton (2004) found that sediment
deposition up to 4 inches occurred in the vicinity of oyster longlines while no deposition
occurred in control areas. Sediment deposition was also noted during recent eelgrass
monitoring of oyster longlines in Humboldt Bay around PVC stakes, with soft, flocculant
material deposited on the seabed (Merkel and Associates 2020). Similarly, small changes in
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intertidal beds may occur in areas used for frequent access by workers walking across the
tideflats. These changes may result in ponded areas near oyster longline gear. Overall, these
changes are expected to be highly localized, temporary (i.e., sediment will mobilize after gear is
replaced or removed), and within the same variability compared to the natural range of
storm/wave activity throughout an estuary.
Dumbauld et al. (2015) suggested that aquaculture creates short-term “pulse” disturbances that
may alter the benthic substrate in lower intertidal areas temporarily in a manner consistent with
storm events and that the magnitude of these temporary effects is within a range where natural
recovery is anticipated to occur. As noted above, there is unlikely to be a pulse disturbance of
harvest activity in terms of water quality effects because it only involves the removal of baskets.
Placement of gear during initial installation is the only pulse disturbance associated with this
Project. While sediment dynamics respond to a variety of influences over time, existing data
suggests that sediment changes due to aquaculture gear are likely minor in relation to natural
sediment dynamics that drive the functions of nearshore habitats (Forrest et al. 2007, 2009).
Because the existing substrate where the proposed Project will occur is primarily sandy
substrate, potential sediment effects are expected to return to existing conditions quickly or will
only result in a nominal change in sediment movement that will not be measurable compared to
existing conditions.
6.2.2 Biodeposition in the Sediment
Shellfish aquaculture has been reported to result in increased biodeposition that may lead to
changes in sediment characteristics (Cranford et al. 2009). For example, sedimentation rates
under floating mussel farms in Quebec, Canada, were measured as 2 to 5 times more than
reference sites (Weise et al. 2009). The degree of environmental impact is related to site-specific
conditions, such as water depth, current velocity, sediment movement, and intensity of culture
practices. The proposed Project is a small culture operation within a well-mixed estuary, and
the amount of oysters that release biodeposits from the proposed SEAPA baskets would be
magnitudes lower compared to examples from mussel culture operations.
While there are identified sediment quality concerns in Hood Canal, especially within the
Suquamish Harbor, there are also improvements and positive contributions over time (WDOH
2024b). Shellfish aquaculture operations are a relatively minor portion of Hood Canal. In
addition, the proposed Project is considered a continuation of shellfish activities at an historic
farming location using the Corps (2015) PBA definition and was considered part of the existing
baseline. Overall, the proposed Project is unlikely to result in increased sediment organic
enrichment due to biodeposition in the sediment.
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6.2.3 Summary of Sediment Quality Effects
The Project site is dominated by sandy substrate. The intertidal habitat in North Hood Canal is
not a static system; there is ongoing erosion, transport, and deposition of sediments. While the
SEAPA baskets may cause short-term impacts to the substrate, it is a limited effect over a short
period of time. Longline culture methods results in the transfer of organic matter to sediment,
which can increase organic sediment content in areas with low flushing rates. Near-bottom
culture methods result in a much lower amount of sediment enrichment compared to floating
mussel culture, and even mussel culture has not been shown to result in enrichment of
sediments in Puget Sound. Both the low amount of added shellfish aquaculture to Hood Canal
(0.2%) and the limited influence of a SEAPA basket culture system makes this potential impact
minor to negligible.
6.3 Fish and Wildlife Habitat
There are various fish and wildlife species identified in Section 5.0 above. These species use
North Hood Canal in a variety of ways. The ways in which the proposed Project may affect this
habitat is discussed below.
6.3.1 Fish Habitat
Shellfish in Washington have been farmed for over 150 years. Although shellfish aquaculture
activities can be described as a pulse disturbance – or a short, discrete event – the overall impact
to FWHCAs varies on the type of fish, location in the water column, and habitat changes that
result from the addition of shellfish aquaculture gear or products. The response associated with
shellfish aquaculture operations from the majority of fish species includes either increased
abundance or no significant differences between culture and other intertidal habitats
(Magnusson and Hilborn 2003; Pinnix et al. 2005; Dumbauld et al. 2009, 2015; Kalson and
Kramer 2015), although there are exceptions and trade-offs for bottom-oriented fish in areas
with in-substrate culture methods (McDonald et al. 2015). Potential adverse impacts are
managed through avoidance measures and monitoring. There is a new study that is starting to
track fish use of culture beds within Hood Canal (NMFS 2022), and a diversity of fish have been
reported within oyster longline culture areas.
Migration along the shoreline is a major component of management concerns associated with
ESA-listed fish (Schlenger et al. 2011; USFWS 2016; NMFS 2016). This is primarily due to
shoreline development. Access to mid-sized and smaller streams have often been compromised
by various human activities such as roads, railroad crossings, dikes, and shoreline armoring.
Culverts under roads and railroads, among other human caused changes, are often a passage
barrier to anadromous fish (Schlenger et al. 2011).
The proposed Project does not constitute a barrier to fish during their migration, or impacts to
spawning areas, foraging areas, or rearing habitat. This is based on several reasons:
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The proposed Project is sited away from the upper portions of the shoreline at depths
ranging from +4 feet to -4.2 feet MLLW and includes rows of gear where fish can swim
through. Documented impacts to migratory fish are associated with structures that
extend out from upland into intertidal areas – such as docks and piers (Ward et al. 1994;
Burdick and Short 1999) – rather than gear that is in intertidal areas that do not
significantly change the ultimate functions or use of the area for fish.
Adult salmon and green sturgeon typically remain in deeper water and the deepest
portion of tidal channels where they are unlikely to encounter activities or gear related
to shellfish aquaculture (Kelly et al. 2007; Dumbauld et al. 2015; Kagley et al. 2017).
Chum salmon and juvenile salmonids use shallow intertidal areas where shellfish farms
are located where the gear can provide structured habitat that is used as a nursery area.
For example, multiple studies have reported higher densities of important salmonid
prey items in areas with oyster culture compared to bare mudflats (Simenstad et al.
1991; Brooks 1995; Suhrbier et al. 2017).
There is no documented forage fish spawning habitat associated with the Project site
(WDFW 2024e). There are conservation measures in place that identify and avoid Pacific
herring spawn if it occurs on culture gear. The proposed Project is below spawning
elevations for surf smelt and sand lance.
Benthic foraging species, such as flatfish, crabs, and sea stars, will congregate below
oyster longline culture gear due to the additional structured habitat (D’Amours et al.
2008). One of the ancillary benefits of a higher abundance of crabs in farm areas is the
presence of crab larvae, which is an important prey resource for salmonids (Wild and
Tasto 1983; Brodeur et al. 2007; Bollens et al. 2010; Duffy et al. 2010). For example,
Bollens et al. (2010) reported that crab larvae become especially important for juvenile
Chinook salmon in nearshore areas in the summer.
The Project site is an intertidal location with sandy substrate that does not contain
habitat likely to support ESA-listed rockfish (e.g., rocky, deep water). For example,
Grove and Shull (2008) identified rockfish around Lummi Island in areas with vertical
walls and steeper slopes (i.e., 70 degrees). Observed rockfish densities dropped to zero
where bottom slopes flattened out and the substrate was primarily gravel and sand.
Habitats with SAV support the greatest number of juvenile rockfish (Matthews 1990;
Carr 1991; Carr and Syms 2006; Hayden-Spear 2006; Springer et al. 2010). The larval
stages of rockfish are often observed floating under detached algae, seagrass, and kelp
within the water column (Love et al. 2002; Palsson et al. 2009). The Project avoids SAV
using a 16.5-foot buffer.
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A diet analysis of rockfish concluded that their diet preference is similar to salmonids,
which includes gammarid amphipods, hyperiid amphipods, crab larvae, and copepods
(Baird 2010; Tonnes 2012; NMFS 2017). This indicates that the salmonid prey resources
supported by shellfish aquaculture gear would also support rockfish.
The available evidence suggests that fish will encounter, and may feed, in the proposed Project
site in North Hood Canal. However, negative interactions are largely avoided because of the
type of gear and avoidance of SAV areas. While there may be some short-term disturbances
(i.e., pulse disturbances) associated with human presence, ultimately the areas have similar
functions compared to the same habitats without shellfish aquaculture gear. Overall, the effects
to habitats associated with fish are considered minor.
6.3.2 Bird Habitat
Although marine birds feed at shellfish aquaculture farms, the farms themselves do not
necessarily attract larger numbers of birds compared to non-cultured areas (Hilgerloh et al.
2001). For birds that tend to avoid areas with humans, the presence of staff tending a farm
would be expected to temporarily reduce marine bird use. These interactions would be seasonal
when birds are present (i.e., during winter and early spring), short-term, and limited. Culture
gear may also provide perching and resting areas for local birds (especially cormorants and
gulls) when not occupied by personnel performing shellfish aquaculture activities.
The following information is a discussion on potential impacts to habitat for specific bird
species and habitat areas, including: (1) marbled murrelet, (2) great blue heron, and (3) seabird
habitat areas.
Marbled Murrelet
Marbled murrelets forage in shallow marine waters and had an at-sea density in Admiralty
Inlet basin during the 2023 winter aerial seabird survey of 3.2 birds/km2 (WDFW 2024f). Noise
associated with human presence and boat motors during shellfish operations could result in
temporary displacement of marbled murrelet. Strachan et al. (1995) commented that marbled
murrelets that are found around heavy boat traffic do not appear to be adversely affected by the
ambient noise of an urban area, suggesting that birds acclimate to the noises in their vicinity.
Given that a shellfish farm does not represent heavy boat traffic, murrelets are not likely to be
affected by farming activities. Therefore, effects on foraging and communication for marbled
murrelets would be temporary and minimal, especially considering the low density of birds.
Great Blue Heron
Great blue herons occur year-round throughout the Puget Sound. Distances from potential nests
and the proposed Project also provide adequate separation. For example, Carney and Sydeman
(1999) reported that a distance of 164 feet from great blue heron rookeries provided enough
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protection from negative interactions with humans. The closest heron rookery is located
approximately 1.5 miles northeast from the Project site in the Shine Tideland State Park
(Eissinger 2007). While potential overlap during foraging behaviors is expected, the only
anticipated potential effect to these birds is disruption when staff are present at the farm. There
is plenty of foraging habitat in adjacent areas, and this effect is expected to be minor.
Shorebird and Eagle Habitat Areas
Based on existing literature and anecdotal observations, shorebirds and eagles are known to
occur near shellfish aquaculture farms and associated gear without incident. Shellfish
aquaculture areas may increase potential prey opportunities for shorebirds (Kelly et al. 1996;
Hilgerloh et al. 2001). Connolly and Colwell (2005) and HTH (2015, 2018) looked at shorebird
use of oyster longline culture beds in Humboldt Bay, California. No behavioral differences in
shorebird use within the culture beds were observed (e.g., shorebirds readily foraged under the
lines). Larger marbled godwits were observed to arrive before small species (i.e., small
sandpipers), as the smaller birds can only access the sites when fully exposed or in very shallow
water. The observations from HTH (2015, 2018) confirm the previous findings of Connolly and
Colwell (2005) and suggest that shorebird foraging occurred irrespective of the presence of
longlines. Shorebird presence in or out of oyster longline culture beds was primarily dependent
on water depths and access to food resources in shallow water or exposed mudflat.
Bald eagles tend to forage evenly throughout the day regardless of the presence of aquaculture-
related activities. Watson et al. (1995) studied the frequency of eagle foraging during geoduck
harvesting activities and found no statistically significant difference in foraging between
geoduck harvesting days and days when no aquaculture activity was present. Given these
results, coupled with the rising trend in bald eagle populations seen over the last decade, which
have resulted in the delisting of species in Washington (Kalasz and Buchanan 2016), it is highly
unlikely existing and future aquaculture would affect the foraging success of bald eagles in
aquaculture adjacent areas in the regions and subregions analyzed in this report.
There is the potential to negatively affect behavior and foraging through disturbance (e.g.,
noise) related to farm activities. However, these effects are temporary and not expected to
impact species on a population level (Carney and Sydeman 1999; Borgmann 2010). Based on
over 150 years of aquaculture in Washington state and observations in and around aquaculture
gear, the potential for shorebird and eagle disturbance appears to be an insignificant risk.
Given the frequency of culture activities, avoidance measures established at shellfish
aquaculture farms, and natural timing of activities in relation to seasonal bird use of shellfish
aquaculture areas, only temporary and minimal effects to birds are expected. If there are
interactions between birds and shellfish aquaculture operations, the literature supports a
conclusion that shellfish activities would result in a minor negative effect (i.e., likely avoidance)
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but also positive effects from the potential to increase foraging habitat. Therefore, the Project
would have minor to negligible impacts on shorebird and eagle habitat areas.
6.3.3 Marine Mammal Habitat
The primary potential impact mechanism identified by the Corps (85 FR 57332) of existing
shellfish aquaculture activities or future similar actions on marine mammals is entanglement.
The following information is a discussion on potential impacts to habitat for specific marine
mammal habitat areas, including: (1) southern resident killer whale, and (2) other marine
mammals.
Southern Resident Killer Whale
Effects from the proposed Project to SRKW are expected to be negligible due to the infrequent
use of shallow areas by the whales and no potential for entanglement. This is consistent with
the review of potential impacts from NMFS (2016) during the programmatic consultation effort,
especially when considering conservation measures to maintain and monitor gear on a regular
basis. Waters with depths less than 20 feet based on extreme high water are excluded from
critical habitat for SRKW due to the lack of use and access to such shallow areas (71 FR 69054).
Even at the very bottom of the culture area (-4.2 feet MLLW), there is no overlap with SRKW
critical habitat.
Research presented by the Corps in the recent proposal to reissue and modify nationwide
permits (85 FR 57298) identified entanglement in suspended or floating culture, specifically
lines or nets, as the main potential impact. The proposed Project includes racks and SEAPA
baskets without the use of lines. A review of entanglements within aquaculture gear
(specifically gear for longline mussel culture) found just 19 occurrences globally since 1982
(Price et al. 2016). It is notable that these examples were associated with offshore longline
operations in deep water habitat. By contrast, global annual entanglements and bycatch of
marine mammals within fishery gear (e.g., gill nets, trawl nets) numbers in the hundreds of
thousands (Read et al. 2006). Given the lack of potential for overlap with SRKW critical habitat
and lack of gear that could result in entanglement, the expected effects to SRKW by the
proposed Project is considered to be negligible.
Other Marine Mammals
Potential for entanglement impacts of other marine mammals is consistent with the analysis
provided above for SRKW. While some species more commonly use shallow waters (e.g.,
harbor seals, sea lions), the potential for entanglement is still considered to be negligible. The
few documented occurrences of entanglement within shellfish aquaculture gear are limited to
offshore, longline operations within deep waters (Price et al. 2016). Intertidal racks with SEAPA
baskets do not pose an entanglement risk to marine mammals. In addition, the proposed Project
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will not affect the haulout area, which are located approximately 2.5 miles to the southwest.
Overall, the proposed Project will not affect other marine mammals or their habitat.
6.3.4 Summary of Effects to Fish and Wildlife Habitat
The proposed Project is located away from upper shoreline areas, although there is potential
overlap with nearshore habitat used by smaller fish such as chum salmon and juvenile
salmonids. Rock Island Shellfish will use conservation measures and BMPs to avoid and
minimize impacts to fish such as maintaining gear and using 16.5-foot buffers from SAV. If
there are interactions, the literature supports a conclusion that shellfish activities would result
in a minor negative effect (i.e., likely avoidance) but also positive effects from the potential to
increase prey items that are important to fish.
Birds use intertidal habitats, like North Hood Canal, but the proposed location of the Project is
located far away from nesting habitat. Based on existing literature, there is the potential for
minor adverse behavior impacts to foraging through disturbance (e.g., noise) related to farm
activities. However, these short-term disturbances are within the range that birds can handle,
are far away from sensitive areas such as nesting habitat, and do not exceed behavioral
thresholds that would result in adverse impacts to bird populations.
The primary impact mechanism identified by the Corps (85 FR 57332) of shellfish aquaculture
activities on marine mammals is entanglement. However, there is no potential mechanism for
entanglement with the proposed gear (i.e., racks) associated with the Project.
6.4 Invertebrates
Based on full build-out, the SEAPA basket culture will use frames for SEAPA baskets, which
would result in approximately 2 acres of benthic habitat. Rumrill and Poulton (2004)
investigated differences in the benthic invertebrate community between oyster longline culture
beds, eelgrass control plots, and eelgrass reference sites in Humboldt Bay, California. Results of
the study showed that invertebrate biomass was highest in the oyster longline culture beds and
lowest in some of the eelgrass reference sites.
The composition of invertebrate communities was also not significantly different between the
oyster longline culture beds and eelgrass control plots in the Rumrill and Poulton (2004) study
(Figure 9). This study provides evidence that oyster longline aquaculture in eelgrass habitat
does not significantly change the species composition compared to eelgrass habitat. This same
conclusion was also noted in Dumbauld et al. (2009), indicating that the similarity of benthic
infaunal abundance in the culture beds compared to eelgrass plots: “may have arisen not
simply due to flow dispersing biodeposits, but because both aquaculture and control areas
included eelgrass, which has characteristic effects on sediment.” In other words, the presence of
eelgrass was the primary determinant in benthic invertebrate abundance and not the added
structure related to the longline gear.
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Figure 9. Percent biomass of benthic invertebrates in Humboldt Bay, California. Source: Rumrill and Poulton 2004
A study in Chesapeake Bay, Virginia, looked at benthic invertebrates as an indication of
ecological health associated with floating and on-bottom culture gear (Kellogg et al. 2018). The
study found no significant negative impacts on the benthic invertebrate community structure
from the presence of gear or oysters, and number of invertebrates inside the farm sites were
higher compared to outside.
Finally, two partner studies – a study within three estuaries along the West Coast (Hudson et al.
2018) and a study in Humboldt Bay, California (Confluence et al. 2019) – looked at invertebrate
assemblages inside and outside of oyster longlines. Hudson et al (2018) evaluated invertebrate
communities across a gradient from oyster longline aquaculture through edge habitats to
eelgrass habitats. Overall, eelgrass had higher total densities of benthic invertebrates compared
to oyster culture beds. Confluence et al. (2019) expanded upon the conclusions of Hudson et al.
(2018) within Humboldt Bay. Benthic invertebrate taxa abundance was analyzed by habitat pair
and season. The results suggested that there were not significant differences in mean number of
taxa, with and without aquaculture for eelgrass habitat (Figure 10). In the winter, there was
slightly higher total taxa in areas without aquaculture, but this relationship was not significant.
There were larger differences in mean number of taxa within habitat pairs for mudflat habitat,
with higher numbers of taxa sampled from areas with aquaculture compared to areas without
aquaculture. This information suggests that longline aquaculture potentially has positive
changes associated with the addition of gear in mudflat habitat and limited changes for eelgrass
habitat. The overall functions of habitat with and without gear are maintained for the benthic
invertebrate communities.
Overall, the literature supports the conclusion that shellfish aquaculture and gear provide
similar foraging habitat and species composition as found in other structured environments
(e.g., eelgrass), and may provide more benthic invertebrates and epibenthic invertebrates
compared to mudflat habitat because of the additional surface area for colonization by
organisms. This conclusion is consistent with NMFS (2016), which stated that: “studies suggest
that the forage-related impacts of disturbance to and suppression of eelgrass resulting from
0%10%20%30%40%50%60%70%80%90%100%
Zostera marina Reference Sites
Oyster
Zostera marina
Malocostraca Oligochaeta Polychaeta
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shellfish culture have very limited impacts on forage, because managed shellfish sites are
themselves inhabited by forage species.”
Figure 10. Invertebrate taxa encountered with each habitat pair by season. Source: Confluence et al. 2019
6.5 Kelp and Eelgrass Beds
SAV is important as both food and critical habitat for salmonids. Floating structures can
adversely affect primary production for SAV in the area shaded by solid structures. Shading can
negatively impact seagrass biomass, density, and growth (Shafer 2002). The Project works to
avoid eelgrass beds using a 16.5-foot buffer from existing eelgrass resources. This buffer is
based on a conservation measure identified in the programmatic consultation (Corps 2015) and
a buffer distance from eelgrass and kelp identified under JCC 18.22.630(5)(b)(iii) with buffer
reduction identified under JCC 18.22.640(1)(b). Effects reviewed by the federal resource
agencies to determine an appropriate buffer distance included activities such as mechanical
harvest of shellfish and disturbance of sediment that are not part of the proposed Project. There
is only a nominal amount of sedimentation anticipated from the proposed shellfish aquaculture
gear, as described in Section 6.2 above. The proposed Project site will also not affect existing
macroalgae in North Hood Canal and provides additional surfaces for attachment of
macroalgae and kelp holdfasts.
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Overall, there would be no effects to SAV from the proposed Project because of the avoidance
measure of using 16.5-foot buffers between proposed shellfish aquaculture gear and mapped
native eelgrass areas based on the MSA (2023) survey.
6.6 Navigation and Public Use
Shellfish farming is subject to federal, state, and local safety laws and regulations, including
compliance with Washington Department of Labor and Industries and U.S. Coast Guard
requirements. Generally, intertidal shellfish farming activities avoid impacts to navigation. Per
U.S. Coast Guard aids to navigation requirements (33 CFR Parts 62 and 66), intertidal
aquaculture facilities require buoys to warn mariners of potential navigational hazards. Farm
equipment is made of durable materials suitable for use in the marine environment and is
properly secured, maintained, and regularly inspected by farm crews.
The farm is also located in areas that are not frequented by the public either in terms of beach
combing in the upper intertidal or by boats in the shallow intertidal. Proposed farm elevations
ranges from +4 feet to -4.2 feet MLLW. Major navigational routes are located outside of shellfish
aquaculture farms, and occur primarily in North Sound. Avoidance and minimization measures
are used to avoid potential conflicts. These include buoys, channel and bed corner markers, and
responsible use of farm areas in terms of placement and orientation of gear. There are additional
ancillary benefits from the presence of shellfish aquaculture operations within a region,
including boater assistance, shellfish seed for private or community use, beach cleanups, and
donated materials or land for restoration efforts. Rock Island Shellfish is highly incentivized to
avoid conflicts with navigational and recreational activities since there are also negative
consequences to their gear and shellfish products should conflicts occur.
6.7 No Net Loss and Cumulative Impacts
Shellfish aquaculture is a preferred, water-dependent use of Jefferson County shorelines (JCC
18.25.440). The County should support aquaculture uses that:
Protect and improve water quality;
Minimize damage to important nearshore habitats;
Minimize interference with navigation and normal public use of surface waters; and
Minimize the potential for cumulative adverse impacts, such as those resulting from in-
water structures/apparatus/equipment, land-based facilities, and substrate
disturbance/modification (including rate, frequency, and spatial extent).
The information above provides an understanding of how the Project will protect and improve
water quality, minimize damage to important nearshore habitats, and minimize interference
with navigation and public use of surface waters. The information below will provide
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additional information related to minimization of cumulative adverse impacts and a no net loss
analysis.
6.7.1 Hood Canal Shellfish Aquaculture
Shellfish farming in Washington State began in the late 1800s and primarily depended on
natural set of Olympia oysters (Waller 2013; WSG 2015). Several laws from the late 1800s to the
present have been used to encourage the development of the shellfish industry, including
purchase of tidelands specifically for the development of culture activities. These laws (Session
Laws, first State Legislature) allowed for up to 80 acres of tidelands to be purchased for oyster
culture.
In 1895, the Bush and Callow Acts were made into law (DNR 2024b). These acts allowed for sale
of state-owned tidelands into private ownership with the goal of increasing shellfish
aquaculture in Washington State. Many ongoing farms were from this original push to increase
oyster culture through the Bush and Callow Acts. Historical methods developed to raise Pacific
oysters resulted in the creation of predecessors for many of the existing shellfish companies in
Washington State.
There are approximately 1,351 acres of continuing3 shellfish aquaculture in Hood Canal based
on values presented in the Corps (2015) PBA. Intertidal culture in Hood Canal includes up to
12% of available intertidal areas (a total of 9,951 acre), including fallow culture areas. Most of
the culture activities are in the North Hood Canal region with mostly on-bottom culture
methods, in-substrate Manila clam culture, and a small amount of near-bottom culture. The
Corps (2015) also estimated reasonably foreseeable commercial shellfish aquaculture activities,
or new4 culture, as 438 acres in Hood Canal. The proposed Project is included in this “new”
culture estimate already assessed by the Corps (2015), notwithstanding that the Project is within
an historic shellfish farming location, due to apparent lack of coordination between the prior
operator and the Corps.
6.7.2 Water Quality
Shellfish aquaculture is recognized for both positive and negative effects on water quality. Most
of Hood Canal is considered approved for shellfish harvest activities by WDOH (WDOH
2024a), indicating good water quality conditions. There are prohibited sections at Port Ludlow,
3 “Continuing” is defined by the Corps (2007) as “Commercial shellfish activity that had been granted a
permit, license, or lease from a state or local agency specifically authorizing commercial shellfish
activities and which were occurring within a defined footprint prior to March 15, 2007. Acreage total
includes both cultivated and fallow acreage for previously permitting projects and pending applications.”
4 “New” is defined by the Corps (2007) as “Commercial shellfish activity that was undertaken after
March 15, 2007. Acreage total includes projects previously permitted by the Corps with completed
individual ESA consultation, pending applications, and estimates of future applications.”
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Hoodsport, Lynch Cove, and estuaries of small tributaries, but no prohibited areas occur near
the Project site. Even in areas like the southern arm of Hood Canal, where there is also shellfish
aquaculture, there have been no reports or analyses to date that indicate shellfish aquaculture in
these areas is causing problems with respect to water quality. Shellfish growers are also heavily
involved in water quality projects, which creates lasting improvements such as reducing the
potential for eutrophication within an estuary. There are several avoidance and minimization
measures identified in the PBA (Corps 2015) used to improve and maintain water quality within
Washington state. Cumulative impacts to water quality, when combined with impacts from
past, present, and reasonably foreseeable projects and actions, would result in minor impacts
within Hood Canal. There would not be a net loss of ecological functions associated with water
quality impacts, and in fact there may be a net benefit to water quality
6.7.3 Sediment Quality
Nearshore habitats throughout Washington are influenced by historic glaciation and substrate
materials are a product of the glacial outwash during the ice age. Beaches and intertidal areas
used for shellfish aquaculture are not static systems; they are dynamic with ongoing erosion,
transport, and deposition of sediments. While on-bottom shellfish aquaculture activities are not
proposed for Rock Island’s project, they do occur elsewhere in Hood Canal and may disturb
surface sediments to a depth of several inches for most cultured clam species or a few feet for
geoduck, these disturbances are short-term and temporary. Studies have reported a small
percentage of fine materials transported by waves and currents after a harvest event, but the
sands and larger materials will typically be transported within only a short distance from the
harvest location (Short and Walton 1992; Liu et al. 2015). Sandy substrates or areas that have
been slightly enhanced with gravel or shell can recover faster compared to areas with fine
substrates. Changes from adding gear are minor and well within the range of natural changes
experienced by the system (e.g., sediment movement within Hood Canal from the large rivers
that drain into the system). In addition, there are several avoidance and minimization measures
identified in the PBA (Corps 2015) used to maintain sediment quality within Washington state.
Cumulative impacts to sediment quality, when combined with impacts from past, present, and
reasonably foreseeable projects and actions, would result in minor impacts within Hood Canal
and this Project itself would not result in a net loss of ecological functions.
6.7.4 Fish and Wildlife
The nearshore waters of Hood Canal support a diverse community of fish and wildlife,
including ESA-listed species, forage fish, marine seabird communities, and marine mammals.
Designated critical habitat for rockfish, Puget Sound Chinook salmon, Hood Canal summer-run
chum salmon, bull trout, Puget Sound steelhead, and SRKW occurs in Hood Canal. The Great
Bend in the southern portion of Hood Canal is noted as a state IBA, and over 273 bird taxa have
been documented in the southern portion of Hood Canal (Pacific Flyway Council 2018). Deeper
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portions of Hood Canal are habitat for SRKW and other whales, but more common marine
mammals in intertidal areas include harbor seals.
Although shellfish aquaculture activities can be described as a short-term disturbance, the
overall impact to fish present in the area varies on the type of fish, location in the water column,
and habitat changes that result from the addition of shellfish aquaculture gear or products.
Impacts to migration are not expected to be significant for species present. There is some
overlap with forage fish spawning areas and shellfish aquaculture locations in Hood Canal
(WDFW 2024e), but these are relatively limited and there are conservation measures used to
avoid or minimize potential impacts (Corps 2015). Conservation measures and standard
practices limit shellfish aquaculture impacts on eelgrass and salmonid use of eelgrass,
specifically to protect Hood Canal chum salmon. For example, the Project will use a 16.5-foot
buffer from eelgrass to avoid impacts. Other conservation measures are used to avoid or
minimize impacts to fish and wildlife (Corps 2015), which will be adhered to by Rock Island
Shellfish. Finally, SEAPA baskets do not represent an entanglement concern for marine
mammals. Overall, noise, entanglement, or foraging impacts to fish and wildlife are considered
to be temporary, infrequent and/or rare, and minimal in light of avoidance and minimization
measures. Cumulative impacts to fish and wildlife, when combined with impacts from past,
present, and reasonably foreseeable projects and actions, would result in minor impacts within
Hood Canal and this Project itself would not result in a net loss of ecological functions.
6.7.5 Invertebrates
Invertebrate communities are used as a measure of ecological health within a system. Shellfish
aquaculture operations affect invertebrate communities in both negative and positive ways.
Most literature indicates that, while there are changes to communities, these changes are
considered to be temporary negative changes (i.e., pulse disturbance with a short-term
recovery) and longer positive changes in terms of the functions that are provided to higher
organisms (e.g., prey for fish and wildlife) (Kaiser et al. 1998; Ferns et al. 2000; Hosack et al.
2006; Ferraro and Cole 2007, 2011, 2012; Dumbauld et al. 2009; Kellogg et al. 2018). These
positive changes may also include increased species diversity and species abundance as
compared with similar habitats without shellfish aquaculture. The literature supports the
conclusion that shellfish aquaculture and gear provide similar foraging habitat and species
composition as found in other structured environments (e.g., eelgrass), and may provide more
benthic invertebrates and epibenthic invertebrates compared to mudflat habitat because of the
addition of surface area for colonization by organisms. This conclusion is consistent with NMFS
(2016) and USFWS (2016) related to shellfish aquaculture activities in Washington State.
Cumulative impacts to invertebrates, when combined with impacts from past, present, and
reasonably foreseeable projects and actions, would result in minor impacts within Hood Canal
and this Project itself would not result in a net loss of ecological functions.
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6.7.6 Kelp and Eelgrass
There are 16 marine protected areas, wetlands, mudflats, and SAV areas in Hood Canal (Van
Cleve et al. 2009). Estuarine wetlands have increased by 3%, but oligohaline transitional
wetlands have decreased compared to historical values; mostly due to road density (Simenstad
et al. 2011). Eelgrass and mudflats overlap with existing shellfish aquaculture operations in
Hood Canal, but these areas recover quickly based on the dynamic intertidal environment.
Eelgrass may have short-term impacts from shellfish aquaculture operations, but the overall
distribution of eelgrass in Hood Canal is stable or even increasing (Christiaen et al. 2017). As
noted above, conservation measures such as a 16.5-foot buffer from eelgrass identified in the
Corps (2015) PBA provides appropriate avoidance and minimization measures for SAV areas.
Cumulative impacts to kelp and eelgrass, when combined with impacts from past, present, and
reasonably foreseeable projects and actions, would result in minor impacts within Hood Canal
and this Project itself would not result in a net loss of ecological functions.
6.7.7 Navigation and Public Use
Navigation and recreation in regions with shellfish aquaculture operations are not mutually
exclusive. Hood Canal is a relatively deep body of water (88% subtidal), but shellfish
aquaculture is predominantly located in shallow, intertidal areas. There are several public
access points through state and local parks, marinas, and resorts (Ecology 2024b). However,
there are no examples of navigational conflicts, even with the U.S. Navy vessels in the northern
end. Ensuring communication about culture bed locations and channels helps to minimize
potential adverse interactions. Conservation measures, low-profile gear, and responsible
farming effectively avoid and minimize potential conflicts. Cumulative impacts to navigation
and public use, when combined with impacts from past, present, and reasonably foreseeable
projects and actions, would result in minor impacts within Hood Canal and this Project itself
would not result in a net loss of ecological functions.
6.7.8 Summary
The proposed Project is consistent with the policies of the Jefferson County SMP, incorporates
effective avoidance and minimization measures, and will result in a no net loss of ecological
functions. There are other shellfish activities in Hood Canal. There are no interactions with
these other activities for water quality, sediment quality, fish and wildlife habitat, invertebrates,
kelp and eelgrass, or navigation and public use that would result in cumulative impacts. While
there are minor impacts that can occur during shellfish aquaculture operations, these impacts
are well within the natural variability of the system and still maintain the natural functioning of
that system. Standard BMPs and the conservation measures in the Corps (2015) PBA, which the
Project will follow, help to avoid or minimize potential impacts, thereby eliminating the need
for further mitigation. Overall, the proposed Project in North Hood Canal would result in no
cumulative impacts and a no net loss of ecological functions.
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7.0 DETERMINATION OF EFFECT
The following is a determination of effect for each species presented in Table 1, their critical
habitat, and FWHCAs, if applicable. The determination is based on the information presented in
the effects analysis (Section 6.0).
The proposed action will not significantly affect the viability, persistence, or distribution of each
species presented in Table 1 or habitat present at the Project site. There may be temporary
avoidance during installation of the floating culture and future shellfish aquaculture operations
in North Hood Canal, but there are no anticipated reductions in numbers or quality of habitat
available. Overall, the proposed action is determined to have a minor or even no effect impact
(Table 3).
Table 3. Effects Determinations for Federal, State, or Locally Important or Listed Species
Species Determination of Effect Basis of Determination
ESA-Listed Fish
Bull trout (PS/Coastal DPS) Discountable Unlikely to occur in Project site; discountable exposure.
Otherwise, similar potential effects as for salmonids.
Chinook salmon (PS ESU) Minor to Discountable
There may be some short-term displacement during gear installation or maintenance and operations.
Migration, foraging, or rearing habitat would not be substantially affected by the proposed actions.
Water quality effects are anticipated to be of such a small magnitude and in such a small area as to be considered discountable.
The Project is not anticipated to negatively affect forage fish species and may have a beneficial effect to forage fish prey availability. Chum salmon (Hood Canal ESU) Minor to Discountable Same conclusions as for Chinook salmon.
Steelhead (PS DPS) Minor to Discountable Same conclusions as for Chinook salmon.
Bocaccio (PS/GB DPS) Minor to Discountable Unlikely to occur in Project site; discountable exposure.
Otherwise, similar potential effects as for salmonids.
Yelloweye rockfish (PS/GB DPS) Minor to Discountable Unlikely to occur in Project site; discountable exposure.
Otherwise, similar potential effects as for salmonids.
Green sturgeon (Southern DPS) Minor to Discountable Unlikely to occur in Project site; discountable exposure.
Otherwise, similar potential effects as for salmonids.
Forage Fish
Surf smelt No Effect to Discountable No overlap with spawning areas.
Otherwise, similar potential effects as for salmonids.
Pacific sand lance No Effect to Discountable No overlap with spawning areas.
Otherwise, similar potential effects as for salmonids.
Pacific herring No Effect to Discountable No overlap with spawning areas.
Otherwise, similar potential effects as for salmonids.
Other Marine Fish
Coastal cutthroat
trout
Minor to
Discountable Same conclusions as for Chinook salmon.
Coho salmon Minor to Discountable Same conclusions as for Chinook salmon.
Rock Island Shellfish: Habitat Management Plan
May 2024 Page 52
Species Determination of Effect Basis of Determination
Fall/summer chum salmon Minor to Discountable
Same conclusions as for Chinook salmon.
Fall Chinook salmon Minor to Discountable Same conclusions as for Chinook salmon.
Winter steelhead Minor to Discountable Same conclusions as for Chinook salmon.
Canary rockfish Minor to Discountable Unlikely to occur in Project site; discountable exposure.
Otherwise, similar potential effects as for salmonids.
Various rockfish Minor to
Discountable Same conclusions as for canary rockfish.
Birds
Marbled Murrelet
(WA/ OR/ CA DPS)
No Effect to
Discountable
Murrelets that use Hood Canal may be exposed to boat activity.
Exposure to activities will be short-term, intermittent, and low-intensity.
Disturbance by ongoing activities is unlikely to elicit more than a mild behavioral response.
No effect to murrelet nesting, foraging, or migratory habitat is anticipated.
Great blue heron No Effect to Discountable
Exposure to activities will be short-term, intermittent, and low-intensity.
Disturbance by ongoing activities is unlikely to elicit more than a mild behavioral response.
No effect to great blue heron nesting, foraging, or migratory habitat is anticipated.
Various shorebird species and eagles No Effect to Discountable
Exposure to activities will be short-term, intermittent, and low-intensity.
Disturbance by ongoing activities is unlikely to elicit more than a mild behavioral response.
No effect to nesting, foraging, or migratory habitat is anticipated.
Marine Mammals
Southern resident killer whale (SRKW) No Effect to Discountable
Boats will avoid approaching, if SRKW present.
In-water work will be delayed if SRKW present near the Project site.
No overlap with critical habitat.
No potential for entanglement
Harbor seal No Effect to Discountable
Likely to avoid Project site when boats and/or workers are present.
Boats will avoid disturbing harbor seals in Project vicinity.
No overlap with haul out areas.
No potential for entanglement.
Invertebrates
Oyster beds No effect The SEAPA basket culture gear or operations would have no impact on oyster beds within the intertidal zone.
North Hood Canal meets the definition of an FWHCA (JCC 18.22.610). The Project may have
minor to discountable effects to these species and their habitat. The effects of the Project are
largely short-term and localized. Long-term effects due to the presence of SEAPA basket gear
are expected to be limited and potentially beneficial for species that would utilize the gear as
resting or foraging habitat.
Rock Island Shellfish: Habitat Management Plan
May 2024 Page 53
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Penttila, D. 2007. Marine Forage Fishes in Puget Sound. Puget Sound Nearshore Partnership
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Davis, J. Fung, P. Bloch, K. Fresh, S. Campbell, D. Myers, E. Iverson, A. Bailey, P. Schlenger,
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May 2024 Page 65
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Appendix A
Fish and Wildlife
Database Information
05/31/2024 16:25:32 UTC
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Washington Fish And Wildlife Office
510 Desmond Drive Se, Suite 102
Lacey, WA 98503-1263
Phone: (360) 753-9440 Fax: (360) 753-9405
In Reply Refer To:
Project Code: 2024-0097918
Project Name: Rock Island Shellfish
Subject:List of threatened and endangered species that may occur in your proposed project
location or may be affected by your proposed project
To Whom It May Concern:
The enclosed species list identifies threatened, endangered, proposed and candidate species, as
well as proposed and final designated critical habitat, that may occur within the boundary of your
proposed project and/or may be affected by your proposed project. The species list fulfills the
requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the
Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.).
New information based on updated surveys, changes in the abundance and distribution of
species, changed habitat conditions, or other factors could change this list. Please feel free to
contact us if you need more current information or assistance regarding the potential impacts to
federally proposed, listed, and candidate species and federally designated and proposed critical
habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the
Act, the accuracy of this species list should be verified after 90 days. This verification can be
completed formally or informally as desired. The Service recommends that verification be
completed by visiting the IPaC website at regular intervals during project planning and
implementation for updates to species lists and information. An updated list may be requested
through the IPaC system by completing the same process used to receive the enclosed list.
The purpose of the Act is to provide a means whereby threatened and endangered species and the
ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the
Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to
utilize their authorities to carry out programs for the conservation of threatened and endangered
species and to determine whether projects may affect threatened and endangered species and/or
designated critical habitat.
A Biological Assessment is required for construction projects (or other undertakings having
similar physical impacts) that are major Federal actions significantly affecting the quality of the
human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)
(c)). For projects other than major construction activities, the Service suggests that a biological
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evaluation similar to a Biological Assessment be prepared to determine whether the project may
affect listed or proposed species and/or designated or proposed critical habitat. Recommended
contents of a Biological Assessment are described at 50 CFR 402.12.
If a Federal agency determines, based on the Biological Assessment or biological evaluation, that
listed species and/or designated critical habitat may be affected by the proposed project, the
agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service
recommends that candidate species, proposed species and proposed critical habitat be addressed
within the consultation. More information on the regulations and procedures for section 7
consultation, including the role of permit or license applicants, can be found in the "Endangered
Species Consultation Handbook" at:
https://www.fws.gov/sites/default/files/documents/endangered-species-consultation-
handbook.pdf
Migratory Birds: In addition to responsibilities to protect threatened and endangered species
under the Endangered Species Act (ESA), there are additional responsibilities under the
Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act (BGEPA) to
protect native birds from project-related impacts. Any activity, intentional or unintentional,
resulting in take of migratory birds, including eagles, is prohibited unless otherwise permitted by
the U.S. Fish and Wildlife Service (50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)). For more
information regarding these Acts, see https://www.fws.gov/program/migratory-bird-permit/what-
we-do.
The MBTA has no provision for allowing take of migratory birds that may be unintentionally
killed or injured by otherwise lawful activities. It is the responsibility of the project proponent to
comply with these Acts by identifying potential impacts to migratory birds and eagles within
applicable NEPA documents (when there is a federal nexus) or a Bird/Eagle Conservation Plan
(when there is no federal nexus). Proponents should implement conservation measures to avoid
or minimize the production of project-related stressors or minimize the exposure of birds and
their resources to the project-related stressors. For more information on avian stressors and
recommended conservation measures, see https://www.fws.gov/library/collections/threats-birds.
In addition to MBTA and BGEPA, Executive Order 13186: Responsibilities of Federal Agencies
to Protect Migratory Birds, obligates all Federal agencies that engage in or authorize activities
that might affect migratory birds, to minimize those effects and encourage conservation measures
that will improve bird populations. Executive Order 13186 provides for the protection of both
migratory birds and migratory bird habitat. For information regarding the implementation of
Executive Order 13186, please visit https://www.fws.gov/partner/council-conservation-
migratory-birds.
We appreciate your concern for threatened and endangered species. The Service encourages
Federal agencies to include conservation of threatened and endangered species into their project
planning to further the purposes of the Act. Please include the Consultation Code in the header of
this letter with any request for consultation or correspondence about your project that you submit
to our office.
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▪
Attachment(s):
Official Species List
OFFICIAL SPECIES LIST
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the
requirement for Federal agencies to "request of the Secretary of the Interior information whether
any species which is listed or proposed to be listed may be present in the area of a proposed
action".
This species list is provided by:
Washington Fish And Wildlife Office
510 Desmond Drive Se, Suite 102
Lacey, WA 98503-1263
(360) 753-9440
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PROJECT SUMMARY
Project Code:2024-0097918
Project Name:Rock Island Shellfish
Project Type:Aquaculture
Project Description:The Project is a proposal to continue shellfish farming activities on
private tidelands in North Hood Canal owned by Robert Carson, the
owner of Rock Island Shellfish Company, on Jefferson County parcel
numbers 965100009, 965100010, and 965100011. These tidelands have
been subject to commercial shellfish aquaculture since the 1950s using a
variety of on- and off-bottom cultivation methods. The purpose of the
Project is to grow oysters in intertidal waters using a near-bottom culture
system called SEAPA® baskets. The proposed Project involves
installation, maintenance, and operation of a SEAPA basket system in
North Hood Canal. SEAPA baskets will be stocked with seed oysters and
raised to full growth prior to harvesting and selling commercially.
Project Location:
The approximate location of the project can be viewed in Google Maps: https://
www.google.com/maps/@47.865839199999996,-122.63897102403662,14z
Counties:Jefferson County, Washington
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1.
ENDANGERED SPECIES ACT SPECIES
There is a total of 6 threatened, endangered, or candidate species on this species list.
Species on this list should be considered in an effects analysis for your project and could include
species that exist in another geographic area. For example, certain fish may appear on the species
list because a project could affect downstream species.
IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA
Fisheries , as USFWS does not have the authority to speak on behalf of NOAA and the
Department of Commerce.
See the "Critical habitats" section below for those critical habitats that lie wholly or partially
within your project area under this office's jurisdiction. Please contact the designated FWS office
if you have questions.
NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an
office of the National Oceanic and Atmospheric Administration within the Department of
Commerce.
1
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BIRDS
NAME STATUS
Marbled Murrelet Brachyramphus marmoratus
Population: U.S.A. (CA, OR, WA)
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/4467
Threatened
Yellow-billed Cuckoo Coccyzus americanus
Population: Western U.S. DPS
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/3911
Threatened
REPTILES
NAME STATUS
Northwestern Pond Turtle Actinemys marmorata
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/1111
Proposed
Threatened
FISHES
NAME STATUS
Bull Trout Salvelinus confluentus
Population: U.S.A., coterminous, lower 48 states
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/8212
Threatened
Dolly Varden Salvelinus malma
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/1008
Proposed
Similarity of
Appearance
(Threatened)
INSECTS
NAME STATUS
Monarch Butterfly Danaus plexippus
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/9743
Candidate
CRITICAL HABITATS
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.
YOU ARE STILL REQUIRED TO DETERMINE IF YOUR PROJECT(S) MAY HAVE EFFECTS ON ALL
ABOVE LISTED SPECIES.
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IPAC USER CONTACT INFORMATION
Agency:Private Entity
Name:Marlene Meaders
Address:146 N Canal St.
City:Seattle
State:WA
Zip:98103
Email marlene.meaders@confenv.com
Phone:2067245781
Critical Habitat Report
Area of Interest (AOI) Information
Area : 0.07 km²
May 31 2024 9:09:39 Pacific Daylight Time
5/31/24, 9:11 AM about:blank
about:blank 1/2
Summary
Name Count Area(km²)Length(m)
All Critical Habitat Polyline 0 N/A 0
All Critical Habitat Polygon 6 0.23 N/A
All Critical Habitat Polygon
#Scientific Name Common Name Listed Entity Area(km²)
1 Sebastes ruberrimus Rockfish, yelloweye Rockfish, yelloweye [Puget
Sound-Georgia Basin DPS]< 0.01
2 Orcinus orca Whale, killer Whale, killer [Southern
Resident DPS]0.02
3 Sebastes paucispinis Bocaccio Bocaccio [Puget Sound-
Georgia Basin DPS]0.07
4 Oncorhynchus tshawytscha Salmon, Chinook Salmon, Chinook [Puget Sound
ESU]0.07
5 Oncorhynchus keta Salmon, chum Salmon, chum [Hood Canal
summer-run ESU]0.07
5/31/24, 9:11 AM about:blank
about:blank 2/2
Chinook Salmon (Protected)
Chinook Salmon
(Protected)
Oncorhynchus tshawytscha
Protection Status
ESA ENDANGERED
Sacramento River winter-run
Upper Columbia River spring-run
ESA THREATENED
California coastal
Central Valley spring-run
Lower Columbia River
Puget Sound
5/31/24, 9:39 AM Chinook Salmon (Protected) | NOAA Fisheries
https://www.fisheries.noaa.gov/species/chinook-salmon-protected 1/21
Snake River fall-run
Snake River spring/summer-run
Upper Willamette River
ESA EXPERIMENTAL POPULATION
Central Valley spring-run in the San Joaquin River
XN
Upper Columbia River spring-run in the Okanogan
River subbasin XN
Central Valley spring-run XN Shasta
Sacramento winter-run XN Shasta
Central Valley spring-run XN Yuba
ESA CANDIDATE
Upper Klamath-Trinity River
Oregon Coast
Southern Oregon and Northern California Coastal
Quick Facts
WEIGHT 40 pounds but can be up to 120
pounds
LENGTH 3 feet
LIFESPAN Up to 7 years, typically 3 to 4 years
THREATS Climate change, Commercial and
recreational fishing, Habitat
degradation, Habitat impediments
(dams), Habitat loss
REGION West Coast
5/31/24, 9:39 AM Chinook Salmon (Protected) | NOAA Fisheries
https://www.fisheries.noaa.gov/species/chinook-salmon-protected 2/21
Chum Salmon (Protected)
Chum Salmon (Protected)
Oncorhynchus keta
Protection Status
ESA THREATENED
Columbia River ESU
Hood Canal summer-run ESU
Quick Facts
WEIGHT 8 to 15 pounds on average, but can
weight up to 45 pounds
LENGTH Up to 3.6 feet
5/31/24, 9:43 AM Chum Salmon (Protected) | NOAA Fisheries
https://www.fisheries.noaa.gov/species/chum-salmon-protected 1/11
LIFESPAN About 4 years
THREATS Climate change, Commercial and
recreational fishing, Habitat
degradation, Habitat impediments
(dams), Habitat loss
REGION West Coast
Chum salmon. Credit: NOAA Fisheries
About the Species
5/31/24, 9:43 AM Chum Salmon (Protected) | NOAA Fisheries
https://www.fisheries.noaa.gov/species/chum-salmon-protected 2/11
Steelhead Trout
Steelhead Trout
Oncorhynchus mykiss
Protection Status
ESA ENDANGERED
Southern California DPS
ESA THREATENED
California Central Valley DPS
Central California Coast DPS
Lower Columbia River DPS
Middle Columbia River
Northern California DPS
Puget Sound DPS
5/31/24, 9:40 AM Steelhead Trout | NOAA Fisheries
https://www.fisheries.noaa.gov/species/steelhead-trout 1/8
Snake River Basin DPS
South-Central California Coast DPS
Upper Columbia River DPS
Upper Willamette River DPS
ESA EXPERIMENTAL POPULATION
Middle Columbia River XN
ESA CANDIDATE
Olympic Peninsula DPS
Quick Facts
WEIGHT Up to 55 pounds
LENGTH Up to 45 inches
LIFESPAN Up to 11 years
THREATS Climate change, Commercial and
recreational fishing, Habitat
degradation, Habitat impediments
(dams), Habitat loss
REGION Alaska, West Coast
5/31/24, 9:40 AM Steelhead Trout | NOAA Fisheries
https://www.fisheries.noaa.gov/species/steelhead-trout 2/8
Bocaccio (Protected)
Bocaccio (Protected)
Sebastes paucispinis
Also Known As
Bocaccio, Rock Salmon, Salmon Rockfish, Pacific
Red Snapper, Pacific Snapper, Oregon Red
Snapper, Oregon Snapper, Longjaw, Merou, Jack,
Snapper, Rock Cod, Rockfish
Protection Status
ESA ENDANGERED
Puget Sound/Georgia Basin DPS
Quick Facts
5/31/24, 9:41 AM Bocaccio (Protected) | NOAA Fisheries
https://www.fisheries.noaa.gov/species/bocaccio-protected 1/16
WEIGHT Up to 21 pounds
LENGTH Up to 3 feet
LIFESPAN Approximately 50 years
THREATS Bycatch, Derelict fishing gear,
Habitat degradation, Habitat loss,
Overfishing
REGION West Coast
About the Species
5/31/24, 9:41 AM Bocaccio (Protected) | NOAA Fisheries
https://www.fisheries.noaa.gov/species/bocaccio-protected 2/16
Yelloweye Rockfish
Yelloweye Rockfish
Sebastes ruberrimus
Protection Status
ESA THREATENED
Puget Sound/ Georgia Basin DPS
Quick Facts
WEIGHT Up to 40 pounds
LENGTH Up to 3.5 feet
LIFESPAN Up to 150 years
5/31/24, 9:41 AM Yelloweye Rockfish | NOAA Fisheries
https://www.fisheries.noaa.gov/species/yelloweye-rockfish 1/17
THREATS Bycatch, Derelict fishing gear,
Habitat degradation, Overfishing
REGION Alaska, West Coast
Yelloweye rockfish. Credit: Alaska Department of Fish and Game
About the Species
Yelloweye rockfish are among the longest lived of rockfishes, with maximum age reported to be up to
150 years. This species also is very slow growing and late to mature. Although conservation
measures like fishing bans have been put in place in Puget Sound, recovery from threats such as
5/31/24, 9:41 AM Yelloweye Rockfish | NOAA Fisheries
https://www.fisheries.noaa.gov/species/yelloweye-rockfish 2/17
Green Sturgeon
Green Sturgeon
Acipenser medirostris
Protection Status
ESA THREATENED
Southern DPS
CITES APPENDIX II
Throughout Its Range
Quick Facts
WEIGHT Up to 350 pounds
5/31/24, 9:42 AM Green Sturgeon | NOAA Fisheries
https://www.fisheries.noaa.gov/species/green-sturgeon 1/20
LENGTH Average 4.5 to 6.5 feet
LIFESPAN 60 to 70 years
THREATS Bycatch, Chemical contaminants,
Climate change, Habitat
degradation, Habitat impediments
(dams), Habitat loss
REGION Alaska, West Coast
Adult green sturgeon in Klamath River, CA. Credit: Thomas Dunklin
About the Species
5/31/24, 9:42 AM Green Sturgeon | NOAA Fisheries
https://www.fisheries.noaa.gov/species/green-sturgeon 2/20
Killer Whale
Killer Whale
Orcinus orca
Also Known As
Orca
Protection Status
ESA ENDANGERED
Southern Resident DPS
MMPA PROTECTED
Throughout its Range
MMPA DEPLETED
AT1 Transient stock
5/31/24, 9:44 AM Killer Whale | NOAA Fisheries
https://www.fisheries.noaa.gov/species/killer-whale 1/36
CITES APPENDIX II
Throughout its Range
SPAW ANNEX II
Throughout the Wider Caribbean Region
Quick Facts
WEIGHT Up to 11 tons
LENGTH Up to 32 feet
LIFESPAN 30 to 90 years
THREATS Chemical contaminants,
Disturbance from vessel traffic and
noise, Entanglement in fishing gear,
Food limitations, Oil spills
REGION Alaska, New England/Mid-Atlantic,
Pacific Islands, Southeast, West
Coast
5/31/24, 9:44 AM Killer Whale | NOAA Fisheries
https://www.fisheries.noaa.gov/species/killer-whale 2/36
PHS Species/Habitats Overview:
Occurence Name Federal Status State Status Sensitive Location
Oyster Beds N/A N/A No
Estuarine and Marine Wetland N/A N/A No
Priority Habitats and Species on the Web
Buffer radius: 500 Feet
Report Date: 05/31/2024
PHS Species/Habitats Details:
5/31/24, 9:28 AM PHS Report
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Oyster Beds
Priority Area Presence
Site Name Not Given
Accuracy NA
Notes Not Given
Source Dataset Shellfish_Summary
Source Name Not Given
Source Entity WDFW
Federal Status N/A
State Status N/A
PHS Listing Status PHS Listed Occurrence
Sensitive N
SGCN N
Display Resolution AS MAPPED
Geometry Type Polygons
5/31/24, 9:28 AM PHS Report
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Estuarine and Marine Wetland
Priority Area Aquatic Habitat
Site Name N/A
Accuracy NA
Notes Wetland System: Estuarine and Marine Wetland - NWI Code:
E2USN
Source Dataset NWIWetlands
Source Name Not Given
Source Entity US Fish and Wildlife Service
Federal Status N/A
State Status N/A
PHS Listing Status PHS Listed Occurrence
Sensitive N
SGCN N
Display Resolution AS MAPPED
ManagementRecommendations http://www.ecy.wa.gov/programs/sea/wetlands/bas/index.html
Geometry Type Polygons
DISCLAIMER. This report includes information that the Washington Department of Fish and Wildlife (WDFW) maintains in a central computer database. It is not an attempt to provide you with an official agency response as to the impacts of your project on fish and wildlife. This information only documents the location of fish and wildlife resources to the best of our knowledge.
It is not a complete inventory and it is important to note that fish and wildlife resources may occur in areas not currently known to WDFW biologists, or in areas for which comprehensive
surveys have not been conducted. Site specific surveys are frequently necesssary to rule out the presence of priority resources. Locations of fish and wildlife resources are subject to
variation caused by disturbance, changes in season and weather, and other factors. WDFW does not recommend using reports more than six months old.
5/31/24, 9:28 AM PHS Report
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Maxar | Washington Department of Natural Resources Aquatics Division | These data were collected by WDFW staff with contributions from the North
Olympic Salmon Coalition and the Friends of the San Juans. | Washington Department of Fish and Wildlife | County of Kitsap, Esri, HERE, Garmin
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.
ForageFishSpawningData
Sand Lance Spawning
Smelt Spawning
Herring Spawning
Pre-spawner Herrring
Holding Areas
WADNR Aquatic Reserves
Forage Fish Survey Data
Sand Lance Spawning
Smelt Spawning
0.4mi
5/31/24, 9:37 AM Forage Fish Spawning Map - Washington State
https://wdfw.maps.arcgis.com/home/webmap/print.html 1/1
Rock Island Fish Migration
County of Kitsap, Island County, Bureau of Land Management, Esri Canada,Esri, HERE, Garmin, INCREMENT P, USGS, METI/NASA, EPA, USDA,
WDFW
All SalmonScape Species
May 31, 2024
0 0.4 0.80.2 mi
0 0.65 1.30.33 km
1:36,112