SALISH SEA BIOLOGICAL
MEMO
DATE: March 24, 2012
SUBJECT: Discussion Points for ACOE Meeting, March 27, 2012
Following are discussion points regarding the Longbranchgeoduck farm proposal in particular, and
industrial shellfish aquaculture in general, pertinent to the conservation of marine forage fishes (Pacific
herring (Clupea), surf smelt (Hypomesus), and Pacific sand lance (Ammodytes), in the near-shore waters
of Washington State.
1. Conservation of “critical” spawning habitats of special concern.

All documented forage fish spawning sites have enhanced regulatory protection measures.
o


In WA GMA, SMA, Hydraulic Code Rules, and federal “EFH” rules for ESA salmonids.
Longbranch site is coincident with sand lance habitat, and near surf smelt habitat.
o
Upper intertidal sand-gravel (silt-free) spawning substrates
o
Siltation during harvest activities a concern
Many aquaculture sites are coincident with forage fish spawning beaches throughout WA.
o
Special concern for cumulative impacts from various activities

Siltation of spawning substrates

Vehicular/foot traffic on spawning beaches

Application of pesticides near spawning habitats and larval nursery grounds

Damage of eelgrass beds used by spawning herring.

Damage to incubating herring spawn deposits by harvest activities

Lack of policing of industry for potentially-damaging practices

Lack of mitigation for cumulative damaging practices
2. Zooplankton impacts:

Zooplankton ingestion impacts to prey base for forage fishes and salmonids.
o
Shellfish farms coincident with fish rearing areas and migratory pathways.
o
Published evidence indicates shellfish eat zooplankton/fish prey base.

Literature indicates ingestion is certain death for zooplanktonic organisms.
o
Longbranch SEPA document ignored ESA-listed salmonids known to be present.
o
Local data base on shellfish diet/zooplankton ingestion seems to be lacking.
3. Forage fish larval ingestion by cultured shellfish:

Surf smelt and sand lance larvae continuously produced for months each year
ACOE Notes, p. 2
o
Immediately adjacent to shellfish farms and densely-concentrated shellfish.
o
5-6 mm in length as yolk sac larvae
o
Little swimming ability for first 1-2 weeks of life
o
Appear to be of a size ingestible by a variety of cultured shellfish species
o
No data on potential for this form of larval mortality

Should be amenable to lab investigations

Wild spawn deposits easily sampleable

Forage fish larvae would be easy to produce in labs

Larval-Ingestion-mortalities may explain reported disappearances of forage fishes in heavilyfarmed areas.

Entire subject of forage fish impacts ignored by recent UW-Sea Grant investigations.
o
Given the species group’s ecological value, why?
4. Recommendations:

Moratorium of expansion of shellfish aquaculture industry prior to Industry-wide EIS.
o
EIS to cover all present and proposed industry practices
o
EIS to cover all anticipated expansion of the industry in scale and methods.
o
EIS to include acceptable investigations of shellfish diets
o
EIS to include acceptable investigations of industry impacts to all forage fish species
in all their life history stages.
o
EIS to include cumulative impact analysis of industry in all its forms and practices.
o
EIS should be undertaken by a neutral party not linked financially/culturally to the
industry.
Dan Penttila
Salish Sea Biological
5108 Kingsway
Anacortes, WA 98221
Tel: (360) 293-8110
e-mail: depenttila@fidalgo.net