June 11th 2019
OAH Action Plan Webinar #1
Speaker: Dr. Caren Braby
Location: Remote / Newport ODFW
Participant List –
Parker Gassett – online
Paul Katen – online
Rhonda Black – online
Francis Chan – online
Jim Carlson – online
Catherine Dunn – online
Geoff Wilkie – in person
Steve Rumrill – in person
June 14th 2019
OAH Action Plan Webinar #2
Speaker: Dr. Jack Barth
Location: Remote / Corvallis OSU
Participant List –
Ana Spalding – online
Andrea Celentano – online
Beth Tuner – online
Boby Mayden – online
Caren Braby – online
Christen Don – online
Dan Brown – online
David Vanderschaaf - online
Emily Kenish - online
Hayley Cater - online
Jonathan Fram - online
Mark Healy - online
Maxine Sugarman - online
Simone Alin – online
Gregory McMurray – in person
Ed Dever – in person
111 SW Columbia Street, Suite 200 Portland, Oregon 97201
pewtrusts.org
July 9, 2019
Drs. Caren Braby and Jack Barth, Co-Chairs Oregon Council on Ocean Acidification and Hypoxia Oregon Department of Fish and Wildlife, Marine Resource Program 2040 Marine Science Drive Newport, OR 97365
RE: Oregon Ocean Acidification and Hypoxia Action Plan
Dear Drs. Braby and Barth, Council Members and Staff,
The Pew Charitable Trusts is submitting public comment on behalf of 370 respondents in support of protecting eelgrass for fish, wildlife, coastal communities and the climate through a strong Action Plan from the OAH Council. All submissions as of 2:00 pm pacific on July 9, 2019 are posted below.
Thank you for your time and consideration. We appreciate the opportunity to work with you to maintain sustainable fisheries and healthy ocean ecosystems.
Bobby Hayden Principal Associate, U.S. Oceans, Pacific The Pew Charitable Trusts [email protected]
July 9, 2019
Drs. Caren Braby and Jack Barth, Co-Chairs Oregon Council on Ocean Acidification and Hypoxia Oregon Department of Fish and Wildlife, Marine Resource Program 2040 Marine Science Drive Newport, OR 97365
RE: Please ensure the final Action Plan provides clear direction to protect eelgrass and SAV
Dear Drs. Braby and Barth, Council Members and Staff,
Thank you for your ongoing work at the Ocean Acidification and Hypoxia Council to find solutions that protect Oregon’s coastal communities, fish and wildlife.
While the Council’s draft Action Plan is a great start, I encourage you to provide strong recommendations to decision-makers that can meet the challenges facing the coast and ocean. Eelgrass and other submerged aquatic vegetation (SAV) are critical to this broader set of solutions. Please ensure that the final Action Plan provides clear direction for protecting eelgrass and other submerged aquatic vegetation. This should include the following:
1) In general, prioritize policies that do better than “no-net loss” of habitats or ecosystem function found in many current management processes. The urgency of the issue requires thinking and acting for the near- and long-term recovery of damaged coastal ecosystems. 2) Work with the National Oceanic and Atmospheric Administration to develop science-based standards for mitigating adverse impacts similar to California’s Eelgrass Mitigation Policy. 3) Direct Oregon’s Department of State Lands to develop consistent, enforceable standards for protecting SAV and its role in estuary and watershed function. 4) Local jurisdictions on the Oregon coast are charged with crafting Estuary Management Plans. Many of these plans are outdated and insufficient for addressing the suite of issues facing local communities. Please direct all local coastal jurisdictions to update estuary management plans and concretely address submerged aquatic vegetation. 5) Please clearly identify potential protective zones (designations) within estuaries to conserve eelgrass and other SAV.
Thank you again for your work on Oregon’s Ocean Acidification and Hypoxia Council. I look forward to a strong final Action Plan for coastal communities and our treasure wildlife.
Sincerely,
We the undersigned Dianne Ensign Danny Dyche Emilie Marlinghaus Portland, OR 97219 Hillsboro, OR 97123 Bend, OR 97702
Lester Hoyle Walt Mintkeski Suzanne Kindland Cave Junction, OR 97523 Portland, OR 97202 Cannon Beach, OR 97110
Jan Stone Jennifer Abernathy roy adsit Aloha, OR 97007 Bend, OR 97709 Portland, OR 97228
Anthony Albert Samuel Aley Linda Alstad Corvallis, OR 97330 Coos Bay, OR 97420 Salem, OR 97304
John Altshuler billie ambrose Marc Anderson Eugene, OR 97408 Gresham, OR 97080 Tualatin, OR 97062
Joan Bailey Ute Baker Terry Barber Portland, OR 97229 Lake Oswego, OR 97035 Springfield, OR 97477
Gery Bargen Gery Bargen Linda Barnett Beaverton, OR 97008 Beaverton, OR 97008 Ashland, OR 97520
Pete Barron Ben Basin Robert Bassett Eugene, OR 97401 Portland, OR 97214 Sandy, OR 97055
Judith Basye Cherine Bauer Kim Beeler Mcminnville, OR 97128 Eugene, OR 97404 Lake Oswego, OR 97034
Robert Beilin Cathie Bell Adrian Bergeron Depoe Bay, OR 97341 Portland, OR 97218 Halfway, OR 97834 linda berry Danika Bevirt Danika Bevirt Bend, OR 97701 Eugene, OR 97405 Eugene, OR 97405
Gina Bilwin Linore Blackstone Dana Bleckinger Coos Bay, OR 97420 Portland, OR 97213 Yachats, OR 97498
Cathy Bledsoe Linda Bolduan Denise Bolzle Portland, OR 97225 Lake Oswego, OR 97034 Beaverton, OR 97007
Diana Boom John Borland Patrick Boyd Lake Oswego, OR Williams, OR 97544 Tigard, OR 97224 97034
Kristina Bradwell Thomas Brandes Mike Brinkley Eugene, OR 97405 Grants Pass, OR 97527 Eugene, OR 97405
Lyle Broschat Robert Brosius p bryer Portland, OR 97211 Grants Pass, OR 97526 Eugene, OR 97405
Deb Buitron Sharon Burge Michael Burmester Port Orford, OR 97465 Salem, OR 97306 Happy Valley, OR 97086
Leslie Burpo sofie buschman Jean Butcher Eugene, OR 97405 Corvallis, OR 97330 Portland, OR 97225
Shirley C Rachel Cairns Mary Callison Portland, OR 97233 Hermiston, OR 97838 Bend, OR 97701
KAY CAREY Nancy Carl Michelle Casey Beaverton, OR 97008 Carlton, OR 97111 Portland, OR 97214
Rita Castillo Ron Cavin MICHAEL Springfield, OR 97478 Eugene, OR 97401 CHAMBERLAIN Gaston, OR 97119
Ann Clarkson Marci Cochran Mary Collier Portland, OR 97202 Portland, OR 97203 Central Point, OR 97502
Shirley Collins Tom Cooney Clivonne Corbett Eugene, OR 97402 Portland, OR 97219 Roseburg, OR 97471
Marilee Corey Sandi Cornez Joan Costelow Salem, OR 97302 Portland, OR 97219 Lebanon, OR 97355
Scott Crockett Laura Cuccia-nilsen Debra Culwell Florence, OR 97439 Elmira, OR 97437 Gresham, OR 97030
Oceanah D'amore E. Darby Edward Davie Talent, OR 97540 Portland, OR 97209 Forest Grove, OR 97116
Randy Davis Adele Dawson D. Deloff Portland, OR 97218 Florence, OR 97439 Aloha, OR 97007
Karol Dietrich Belinda Dodd Meaghan Doherty Corbett, OR 97019 Eugene, OR 97404 Portland, OR 97206
Kacey Donston Jennifer Doob David Dragavon , OR 97493 Portland, OR 97214 Milwaukie, OR 97267
Gwen Dudley Stacie Dullmeyer Don Dumond Dallas, OR 97338 Keizer, OR 97303 Eugene, OR 97403
Thomas Durst Robert Duval Gretchen Dysart Ashland, OR 97520 Portland, OR 97219 Lake Oswego, OR 97035
J E Pat Edley Elizabeth Edwards Portland, OR 97225 Nehalem, OR 97131 Cloverdale, OR 97112
Isaac Ehrlich marian ellette Benton Elliott Rhododendron, OR Hillsboro, OR 97124 Eugene, OR 97401 97049
Alfred Epding Paula Eppler CHERYL ERB Port Orford, OR 97465 Happy Valley, OR 97086 Salem, OR 97301
K f Melanie Feder Jamie Fillmore Salem, OR 97306 Philomath, OR 97370 Portland, OR 97224
Gloria Fisher Laurie Fisher Jan Fitcha Portland, OR 97220 Tigard, OR 97224 Neskowin, OR 97149
Laura Fleming Jeremy Foisy Dawn Foss Eagle Point, OR 97524 Mcminnville, OR 97128 Albany, OR 97321
Harry Freiberg Ann Gaidos-Morgan Steve Garrett Brookings, OR 97415 Corvallis, OR 97330 Bandon, OR 97411
Jim Geear Mika Gentili-Lloyd Rose Gerstner Medford, OR 97504 Hillsboro, OR 97124 Jacksonville, OR 97530
Otis Gillis Janice Gipson Margaret Glass Oregon City, OR 97045 Falls City, OR 97344 John Day, OR 97845
Jacqueline Glyde Ben Goodin Ben Goodin Portland, OR 97220 La Pine, OR 97739 La Pine, OR 97739
Jenny Goodnough Richard Gorringe Robin Gotfrid Eugene, OR 97405 Portland, OR 97212 Ashland, OR 97520
Ruby Grad Wanda Graff Elizabeth Grant Portland, OR 97213 Canby, OR 97013 Salem, OR 97303
Linda Gray Matthew Gray Victoria Groshong Silverton, OR 97381 Corvallis, OR 97330 Waldport, OR 97394 michelle guthrie Michael Halloran Gary Hamblin Portland, OR 97202 Salem, OR 97305 Ashland, OR 97520
Bob Hannigan Linda Hansen Merriann Harbert Corvallis, OR 97330 Portland, OR 97227 Coos Bay, OR 97420
Donna Harlan Randy Harrison john hathaway Springfield, OR 97477 Eugene, OR 97402 Redmond, OR 97756
Melissa Hathaway Jennifer Hauge Bobby Hayden Portland, OR 97230 Salem, OR 97302 Portland, OR 97220
Susan Haywood Susan Heath Bruce Hellemn Portland, OR 97210 Albany, OR 97322 Portland, OR 97227
Jim Hemmingsen David Henderson Linda Hendrix Eugene, OR 97403 Portland, OR 97211 Bend, OR 97702
Michael Herbert Tori Herbst David Hermanns Florence, OR 97439 Portland, OR 97217 Portland, OR 97203
Char Hersh Yola Hesser Wendy Hinsberger Ashland, OR 97520 Florence, OR 97439 Aloha, OR 97007
Bradley Holmes Michael Hoover Karen Horton Portland, OR 97214 Tigard, OR 97223 Independence, OR 97351
Celeste Howard Fran Howse Lise Hull Hillsboro, OR 97124 Beaverton, OR 97005 Bandon, OR 97411
Diane Hunter David Ibbotson Christina Irwin Lake Oswego, OR Portland, OR 97206 Lake Oswego, OR 97034 97034
Tim Jeffries Sally Jennings Cindy Jensen Bend, OR 97701 Siletz, OR 97380 North Plains, OR 97133
Jovy Jergens Bonnie Jerro Terry Jess Beaverton, OR 97008 Portland, OR 97215 Albany, OR 97321
Stephen Johnston Jane Jones Richard Jones Eugene, OR 97405 Milton-freewater, OR Florence, OR 97439 97862
Mary Joyce Mary Joyce Betty Kang Portland, OR 97215 Portland, OR 97215 Eugene, OR 97401
Bob Karcich Schleich Kathleen Joel Kay Medford, OR 97504 Beaverton, OR 97006 Milwaukie, OR 97222
Dustin Kearns Wayne Kelly Kaetlin Kennedy Portland, OR 97202 Ashland, OR 97520 Portland, OR 97211
Scott Kennedy Dayna Keough Catherine keys Keizer, OR 97303 Portland, OR 97221 Medford, OR 97501
Petr Khlyabich Jody Kim-Eng Glenn Koehrsen Beaverton, OR 97006 Portland, OR 97230 Mulino, OR 97042
Steven Konopacki Rheama Koonce Gay Kramer-Dodd Portland, OR 97214 Beaverton, OR 97007 Eugene, OR 97404
Nina Kristiansen M.A. Kruse Charles Lange Bend, OR 97702 Bend, OR 97701 Eugene, OR 97402
Charles Langford Pam Larsen Carolyn Latierra Corvallis, OR 97330 Hood River, OR 97031 Portland, OR 97212
Marcy Lauer Richard Lauer Richard Lauer Independence, OR Independence, OR Independence, OR 97351 97351 97351
Ruba leech Alicia Liang Mr. Liberge Portland, OR 97211 Portland, OR 97214 Grants Pass, OR 97527
Mr. Liberge Rebecca Lippmann Lexi Loch Grants Pass, OR 97527 Albany, OR 97322 Portland, OR 97216
Clyde Locklear John Long Carol Loomis Portland, OR 97221 Redmond, OR 97756 Portland, OR 97233
Valerie Lovejoy Diane Luck Debra Lutje Williams, OR 97544 Portland, OR 97212 The Dalles, OR 97058
Tisa Lynch Gilly Lyons Erin M Sherwood, OR 97140 Portland, OR 97211 Salem, OR 97301
David Maceira David Macon Sally Maish Keizer, OR 97303 Rogue River, OR 97537 Roseburg, OR 97471
Kathleen Malan- Lorraine Markoff Jeanne Marple Thompson Eugene, OR 97405 Portland, OR 97225 Portland, OR 97219
Heather Marsh Nikki Martin Richard Martin Lake Oswego, OR Mount Angel, OR 97362 Corvallis, OR 97330 97035
Richard Martin Sheila Martin Carol May Corvallis, OR 97330 Astoria, OR 97103 Bend, OR 97701
Mauria McClay Kelly McConnell Claudia McCracken Portland, OR 97218 Portland, OR 97223 Happy Valley, OR 97086
Bruce McCullough Wendy McGowan LARY MCKEE Estacada, OR 97023 Eugene, OR 97404 Gervais, OR 97026
Patrick McLaughlin Martha Metcalf Christopher Michaels Portland, OR 97209 Grants Pass, OR 97527 Eugene, OR 97402
Janis Miesen Lily Mitchel Anne Mitchell Portland, OR 97211 Portland, OR 97213 Portland, OR 97206
Bonnie Mitchell Susan Moore Audrey Morgan Portland, OR 97231 Portland, OR 97210 Tualatin, OR 97062
John Murphy Kris N. jurissah naive Hood River, OR 97031 Portland, OR 97213 Beaverton, OR 97006
Grace Neff James Nelson Shel Neu Albany, OR 97322 Grants Pass, OR 97527 Beaverton, OR 97006
Arthur Noble Charlotte Nuessle Bill O'Brien Bandon, OR 97411 Ashland, OR 97520 Beaverton, OR 97005
Maureen O'Neal Stephen Oder Jeanie Ogden Tigard, OR 97223 Corvallis, OR 97330 Sisters, OR 97759
Gail Ohara Shaina Okalani Rita Olson Portland, OR 97213 Ashland, OR 97520 Portland, OR 97211
Mary OMalley Barbara Parliman Christina Pasillas Yamhill, OR 97148 Williams, OR 97544 Klamath Falls, OR 97603
Eugene Perkins William Pickens Rebecca Picton Portland, OR 97202 Portland, OR 97216 Corvallis, OR 97330
Ramona Ponessa Dean Pryer Margaret Quentin Bandon, OR 97411 Eugene, OR 97401 Portland, OR 97213
Philip Ratcliff leslee Ray Nicola Reddwoodd Salem, OR 97302 Eugene, OR 97401 Brookings, OR 97415
Marney Reed Andrew Reilly Christopher Reisner Florence, OR 97439 Ashland, OR 97520 Portland, OR 97233
Kaitlyn Reisner Casey Remy Pam Rensch Springfield, OR 97477 Days Creek, OR 97429 St. Helens, OR 97051
Jonathan Rettmann B Richards Julie Richards Portland, OR 97232 Beaverton, OR 97005 Clackamas, OR 97015
Nancy Richardson Shelley Ries Diane Rios Phoenix, OR 97535 Corvallis, OR 97333 Portland, OR 97214
Will Ritter Susan Rives-Denight Amy Roberts Astoria, OR 97103 Pendleton, OR 97801 Albany, OR 97321
Rolando Rodriguez Laurel Rogers Laurel Rogers Port Orford, OR 97465 Portland, OR 97212 Portland, OR 97212
Laurel Rogers maureen rogers Eric Ross Portland, OR 97212 Newberg, OR 97132 Sweet Home, OR 97386
Frank Rouse Kathleen Ruiz Michael Russell Colton, OR 97017 Seaside, OR 97138 Gresham, OR 97080
Dave Ruud Darla Sadler Georgeanne Samuelson Portland, OR 97231 Bend, OR 97701 Oakridge, OR 97463
Deon Saraceno Diana Saxon Sandra Schomberg Eugene, OR 97405 Salem, OR 97301 Corvallis, OR 97330
Linda Schwartz Peter Sergienko Steve Sheehy Cannon Beach, OR Portland, OR 97210 Klamath Falls, OR 97603 97110
Ian Shelley Paul Shively Mark Siemens Portland, OR 97225 Portland, OR 97203 Eugene, OR 97402
Jennifer Siler Karen Sinclair L. Sinclair Portland, OR 97220 Jacksonville, OR 97530 Portland, OR 97229
Margo Slaughter Jan Slobin Bryan Smith Eugene, OR 97401 Portland, OR 97209 Portland, OR 97236
Leslie Smith Sagen Smith valerie snyder Grants Pass, OR 97526 Ashland, OR 97520 Forest Grove, OR 97116
Debra Sohm Clifford Spencer Sheila Spencer Portland, OR 97206 Portland, OR 97207 Gresham, OR 97080
William Stenberg Emlyn Stenger Margaret Stephens Bandon, OR 97411 Portland, OR 97202 Salem, OR 97301
Laura Stice D Stirpe Amanda Sweet Eugene, OR 97402 Portland, OR 97214 Tigard, OR 97224
David Sweet Daisy Sweetland Avalyn Taylor Portland, OR 97213 Gresham, OR 97030 Portland, OR 97215
Colleen Taylor Mary Thiel Bob Thomas Portland, OR 97229 Portland, OR 97202 Myrtle Creek, OR 97457
Sandy Thompson Hillary Tiefer A. Todd Bend, OR 97703 Portland, OR 97219 Eugene, OR 97404
Tamara Townsend Joan Turner David Tvedt Brookings, OR 97415 Tigard, OR 97224 Eugene, OR 97404
Michelle Unger Karen Varney Karen Varney Portland, OR 97209 Portland, OR 97219 Portland, OR 97219
Estelle Voeller M. W. Carol Wagner Medford, OR 97501 Brookings, OR 97415 Canby, OR 97013
Marie Wakefield Heather Walker-Dale Dona Ward Newport, OR 97365 Wilsonville, OR 97070 Eugene, OR 97403
Peter Ware Jennifer Weaver-Neist Susan Wechsler Medford, OR 97504 Hillsboro, OR 97123 Corvallis, OR 97330
Debbi Weiler Virginia Weisman Heidi Welte Salem, OR 97305 Eugene, OR 97402 Beaverton, OR 97007
Michael Wherley Rodney Whisenhunt Jeffrey White Eugene, OR 97402 Roseburg, OR 97471 Forest Grove, OR 97116 gm whiting Kim Wick Joan Wikler Lake Oswego, OR Buxton, OR 97109 Waldport, OR 97394 97034
Mark Wiley Carla Williams Kyenne Williams Tigard, OR 97224 Cottage Grove, OR Portland, OR 97220 97424 shirley williamson Albert Wilson Niki Wise Mcminnville, OR 97128 Brookings, OR 97415 Eugene, OR 97405
Michele Wittig Gail Worrell Katherine Wright Aloha, OR 97007 Portland, OR 97211 West Linn, OR 97068
Lu Wwang Bridget Wyatt marguery zucker Corvallis, OR 97330 Portland, OR 97209 Eugene, OR 97403
Barbara Arlen Corvallis, OR 97330
July 9, 2019
Oregon Coordinating Council on Ocean Acidification and Hypoxia Oregon Governor’s Office Salem, Oregon
Re: Comments on Draft Ocean Acidification and Hypoxia Action Plan
Dear Coordinating Council:
The Nature Conservancy of Oregon (TNC) is a non-profit conservation organization dedicated to the preservation of biological diversity through actions to conserve the lands and waters in which all life depends. One of our top priorities is to address climate change. On our coast, the impacts of climate change are acute and being felt via ocean acidification and hypoxia (OAH) and other oceanographic changes. The draft Oregon Ocean Acidification and Hypoxia Action Plan follows the 2018 Oregon Biennial OAH Council Report (2018 OAH Report) and is an important milestone in driving progress on this important issue. Our comments on the Action Plan reflect the importance that TNC places on this critical issue.
Overall, we find that the draft Action Plan is an approachable document to anyone who is interested in the subject. The layout of the document, the abundance of graphics, quotes from persons who are involved in OAH and the frequent cross-references to the 2018 OAH Report and relevant literature contribute to the readability of the Plan. While attractive, the draft Action Plan is high-level and opaque, and could benefit from more specificity in the five priority actions. In fact, in many places, the 2018 OAH Report provides more specific actions and sub- actions listed under the five priority “Themes.”
Priority 1 – Advance Scientific Understanding: There are numerous monitoring efforts (e.g. OA monitoring in marine reserves) that began prior to the dates listed in this plan. These efforts should be acknowledged. Additionally, the co-location of oceanographic monitoring in the marine reserves should start immediately and not wait until 2021. Lastly, the vulnerability assessments conducted in selected communities and/or sectors should be prioritized as they can be used to develop tangible examples of why OAH action is necessary.
Priority 2 – Reduce Causes: Beyond regular communication and identifying pathways, state agencies should be required to identify strategies and actions to address excess emissions and OAH stressors.
Priority 3 – Create Resilience: TNC supports actions to promote adaptation and resilience. A good addition to Step 2 would be developing incentives or promoting estuary restoration such as eelgrass plantings.
Priority 4 – Expand Public Awareness: Communicating about OAH demands a thorough set of communication strategies to meet the needs of diverse stakeholders. The identified Steps provide broad communication needs but they lack the specificity identified in the 2018 OAH Report (see Text Box on page 19). We recommend that a communication strategy be drafted that lays out a multi-year plan with messages targeting specific audiences and includes feedback loops for evaluating effectiveness.
Priority 5 – Build Sustained Support: Mobilizing agencies to address OAH is a key issue for the OAH Council and it should include some mandatory actions for the relevant agencies. Step 1 calls for agencies to “consider work” but what is needed is more than mere consideration, it should require some action to reduce the root causes and/or make Oregon more resilient.
Lastly, while the OAH Council has been focused on what the State of Oregon can do in response to OAH, there is a continuing need to include the private sector in the issue and the solution(s). The not-for-profit sector could also be referenced in the draft Action Plan as their work can be a catalyzing force within several of the listed Priority Actions. Specifically, non-profits can be effective at communications (Priority 4), promoting adaptation and resilience (Priority 3), and promoting strategies to reduce emissions (Priority 2).
Thank you for giving The Nature Conservancy the opportunity to comment on the draft OAH Action Plan.
Sincerely,
Dick Vander Schaaf Associate Conservation Director, Coast and Marine Program [email protected]
July 9, 2019
Drs. Jack Barth, Caren Braby, Co-Chairs & Dr. Charlotte Whitefield Oregon Council on Ocean Acidification and Hypoxia Oregon Department of Fish and Wildlife, Marine Resource Program 2040 Marine Science Drive Newport, OR 97365
RE: Oregon Ocean Acidification and Hypoxia Action Plan
Dear Drs. Barth, Braby, Whitefield, and Council, Portland Audubon and its over 16,000 members across Oregon thank you for the opportunity to comment on the draft Oregon Ocean Acidification and Hypoxia (OAH) Action Plan. Overall, we are pleased with the draft plan in its level of detail, clarity in goals and activities to accomplish those goals and clear timeline. Below we provide some additional comments that we hope you will consider to improve the plan. Portland Audubon is greatly concerned about OAH and its negative impacts on bird species and their habitats. Oregon is an incredibly important place for avifauna that depend on a healthy ocean ecosystem. The Audubon network has identified 37 Important Bird Areas (IBAs) along Oregon’s coast (see map below). Bird species of conservation concern in Oregon that depend almost entirely on ocean shellfish like the Black Oystercatcher and Harlequin Duck, both listed as “strategy species” in Oregon’s nearshore strategy1, are vulnerable to OAH impacts. A growing body of evidence indicates that OAH poses threats and challenges for Oregon’s seabirds including the Endangered Marbled Murrelet2. Hypoxic events may have played a role in recent massive seabird mortality events (some events documenting tens of thousands of mortalities)3. Submerged Aquatic Vegetation (SAV), including eelgrass, that have been identified in combating the impacts of OAH are very important to migratory shorebirds as well as Black Brant.
1 http://oregonconservationstrategy.org/oregon-nearshore-strategy/ 2 USFWS. 2009. Marbled Murrelet (Brachyramphus marmoratus): 5-year review. U.S. Fish and Wildlife Service, Washington Fish and Wildlife Office, Lacey, Washington 3 https://phys.org/news/2017-02-pacific-vast-seabird-die-off.html
Below are some specific comments on the draft OAH Action Plan that we ask the Council to consider:
Under #1 Advance scientific understanding – Step 2, we are pleased to see a directive for ODFW Shellfish Assessment Team to “increase frequency and spatial scale of shellfish and submerged aquatic vegetation (SAV, e.g. eelgrass, kelp) observations.” It is a bit unclear as to what “observations” means. There is currently a paucity of new information on the extent of eelgrass in Oregon so we would think that “observations” in this context refers to “monitor for presence and extent of SAV”. A recent review of eelgrass on the West Coast4 indicates that 34 of 50 sites in Oregon that potentially could support eelgrass beds currently have not been surveyed and there is no data to indicate status (See page 21 of report). The OAH Action Plan draft should cite this recent report and use it to provide more detail on how the Shellfish Assessment Team (or others) should prioritize SAV assessment surveys. Also, is it within the capacity of ODFWs Shellfish Assessment Team to cover all of these sites? Is the biennium estimate of 400-500K enough for this team (or other group) to survey all of these sites? These questions should be carefully considered and plan adjusted if necessary.
We encourage the State of Oregon and the OAH Council to provide specific mechanisms in the plan as to how the strategies to maintain SAV in Oregon’s estuaries will be implemented. We recommend that the plan take the additional step beyond identifying strategies to include language that outlines developing polices and regulatory actions that protect SAV. These should be delineated in Priority Actions #3 and #5 of the plan.
We encourage the draft plan to specifically mention the example of the California Eelgrass Mitigation Policy (CEMP)5 as something that Oregon should consider. The State of California agencies and NOAA fisheries have developed the CEMP with the goal of “no nest loss of eelgrass habitat function in
4 Sherman, K. and L.A. DeBruyckere. 2018. Eelgrass habitats on the U.S. West Coast. State of the knowledge of eelgrass ecosystem services and eelgrass extent. A publication prepared by the Pacific Marine and Estuarine Fish Habitat Partnership for The Nature Conservancy. 67pp. 5 NOAA Fisheries. West Coast Region. California Eelgrass Mitigation Policy and Implementing Guidelines. October 2014. https://www.westcoast.fisheries.noaa.gov/publications/habitat/california_eelgrass_miti gation/Final%20CEMP%20October%202014/cemp_oct_2014_final.pdf California.” Oregon agencies should consider similar partnerships and goals as the CEMP.
Thank you for considering our comments and recommendations. We are appreciative of the efforts and work of the OAH Council to develop the Action Plan. We look forward to further opportunities to be part of the process to address this important issue.
Sincerely,
Joe Liebezeit, MS
Staff Scientist and Avian Conservation Manager Portland Audubon [email protected] 971-222-6121
To the OAH Council and Staff July 9, 2019
The Oregon Shores Conservation Coalition applauds Gov. Brown and the Oregon Legislature for promoting the development of a state strategy for addressing the grave problem of ocean acidification and hypoxia, one of the many climate-related impacts looming over our coast and ocean, and one that is already evident in our waters. And we commend the members of the OAH Council for developing the State of Oregon Ocean Acidification and Hypoxia Action Plan.
The plan clearly lays out the nature and gravity of the concerns raised by OAH, and creates a solid general framework for addressing them. It calls appropriately for monitoring, research, coordination, and public education and awareness. It acknowledges the need to engage in abatement as well as promote resilience and adaptation. It provides a good framework for developing specific initiatives. There is little that we would criticize about what is in the plan.
We do wish to comment on what is not in the plan. While it is labeled an “Action Plan,” in too many areas the action called for is study. There is always need for more research—we never know all that we could know. There is nothing inappropriate about calls for study of this or that aspect of the problem. We understand that a call for research is often the position for which consensus can be achieved. However, the threats posed by OAH, and by climate change generally, are too serious and too immediate to allow for deferring to future studies the crucial questions of which actual actions to promote, in situations where action is needed now.
The plan as drafted ignores three very large elephants in the room—or, given the topic, perhaps the metaphor should be altered to three cetaceans beaching themselves on our shore.
First, there is the status of marine reserves. The plan mentions them in passing, as sites for needed research, and this is all to the good. However, there is no real reason to doubt that reserves are both important to the study of OAH impacts, and a key method of promoting the resilience of marine ecosystems. Oregon’s all-too-limited set of marine reserves should have a more prominent role in the plan. At the least, there should be a much more forceful call for increased research funding targeted toward marine reserves for the purpose of studying not just OAH impacts but the role of the reserves in supporting the resilience of nearshore ocean ecosystems. But we would argue that even this would be too timid. No one really doubts that intact habitats are more resilient, not even those who are dubious about or hostile toward marine
reserves based on short-term economic interests. We would suggest that a call for expanding our set of marine reserves so as to better preserve the full range of coastal and nearshore habitats as an obvious step toward promoting resilience is fully justified.
Second, while the plan mentions water quality as a factor to be addressed in dealing with OAH, there is only the slightest hint of a mention of a major cause of degraded water quality. Agriculture is one source of the chemicals and sedimentation that affect nearshore ocean water quality and acidification, and we see that the Department of Agriculture is represented on the panel. But we also note that the Department of Forestry is not represented (we wonder if they were invited to participate and declined, given that department’s egregious denial of the impacts of forestry practices on the coast and ocean). Oregon’s woefully inadequate forestry regulations allow for practices that severely degrade coastal water quality. The Department of Forestry’s dereliction also has another consequence—our failure to meet water quality benchmarks due to the agency’s negligence has led to federal penalties that deprive our Coastal Management Program of funds needed to plan for climate change adaptation (see comments below regarding blue carbon and marsh migration). While we appreciate that the language of the plan would be more diplomatic than the words we would be inclined to use in reference to the Department of Forestry and the Board of Forestry, nevertheless, the plan should vigorously address the need for improved forest practices, including dramatically wider protected riparian zones and severely curtailed if not eliminated herbicide and pesticide use, in order to reduce the acidity of Oregon’s ocean waters. (Note: Yes, we see that these matters are very gently alluded to in Appendix D, but the issues should be brought front and center as key actions needed now, not timidly introduced in an appendix that the Department of Forestry will cheerfully ignore.)
Third, the White Whale that threatens to plow into any effort to reduce Oregon’s contribution to the greenhouse gases that drive climate change and OAH is the proposed Jordan Cove LNG export terminal. If built, this facility would become Oregon’s largest emitter of greenhouse gases. Aside from emissions at the site, it would facilitate the consumption of fossil fuels. Moreover, it would encourage extraction of natural gas through “fracking,” which releases large amounts of methane, a potent greenhouse gas, into the environment. (As an aside, the plan is flawed in referring only to carbon dioxide as a greenhouse gas, when there are in fact other contributors to global warming, including methane.) No study whatever is needed to acknowledge the reality that Jordan Cove would be a significant contributor to climate change, overwhelming efforts the state might make to reduce its carbon footprint. The threat here is immediate. If this “Action Plan” is at all serious about countering the impacts of OAH, it should explicitly call for the state to do everything possible to block development of the Jordan Cove LNG terminal.
We would also point to another gap in the plan. There is discussion of blue carbon storage, which we are pleased to see, and discussion of submerged aquatic vegetation (SAV) in this connection, but no discussion of marshes, both salt and fresh, that we detect, although this might fall under the heading of estuary resilience. We certainly endorse the goals of mapping SAV and other estuarine and nearshore resources, and conducting research on estuarine resilience, but we would argue that marshes are important to estuarine water quality and resilience, and also have a potential for blue carbon storage. We would suggest that the plan address explicitly what we all know to be the case—that sea level rise threatens both marshes and SAV (particularly eelgrass), which could lose habitat as sea level rises unless marshes and mudflats are allowed to migrate upslope. We realize that this is a less immediate issue, and more complicated than blocking a development or changing regulations to require wider riparian
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zones. The kind of adaptive planning that would allow for the migration of estuarine (and other intertidal) habitats with sea level rise would require an extensive effort at the state, county, and city level over many years. This would be an “action” that would roll out over a long period of time, but we would argue that the plan should point to this need and call for the fostering of such an effort. There is much in the plan concerning state agencies and other entities, and allusions to “communities,” but the need to educate and engage local jurisdictions in planning efforts leading to enhanced estuarine resilience isn’t clearly addressed. We recognize that this is addressed elsewhere in the state’s climate adaptation planning, but it should be brought forward under the rubric of OAH, which after all threatens resources on which many coastal cities and counties depend.
One other point we would like to make, which in one sense may seem tangential, but in another is a quite direct potential action promoting both resilience and blue carbon storage. The plan refers to the potential for kelp farming. Oregon Shores does not take a position on this—we simply don’t know enough. This is indeed an arena in which study is needed to determine whether an action is appropriate. Meanwhile, though, there exists the potential for natural expansion of kelp forests in Oregon’s nearshore waters. Oregon Shores is a founding member of the Elakha Alliance, which promotes study of the possibility of reintroducing sea otters to Oregon’s coast. Sea otters prey on sea urchins and other kelp consumers, keeping these populations in check and thus enabling the spread of kelp forests. We understand that it may seem like a leap from ocean water chemistry to charismatic megafauna, and actually calling for reintroduction would perhaps be a step too far for an OAH plan, but we would strongly suggest that this be included as an area for research into both marine ecosystem resilience and ocean carbon storage.
Thank you for your consideration of these views.
Sincerely,
Phillip Johnson, Executive Director
In Oregon, the beaches belong to the people PO Box 33, Seal Rock, Oregon 97376 • (503) 754-9303 • oregonshores.org 3
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111 SW Columbia Street, Suite 200 Portland, Oregon 97201
pewtrusts.org
July 9, 2019
Drs. Jack Barth and Caren Braby, Co-Chairs Oregon Council on Ocean Acidification and Hypoxia Oregon Department of Fish and Wildlife, Marine Resource Program 2040 Marine Science Drive Newport, OR 97365
RE: Oregon Ocean Acidification and Hypoxia Action Plan
Dear Drs. Barth and Braby, and Council Members and Staff,
Thank you for the opportunity to offer public comment on the draft Oregon Ocean Acidification and Hypoxia (OAH) Action Plan. We appreciate Oregon’s leadership in addressing this direct threat to the health of our marine ecosystem and the coastal communities that depend upon it. The recently released draft OAH Action Plan lays out a set of discrete actions that, if properly implemented, can help the state adapt to and mitigate the impacts of OAH, while building resilience for coastal communities.
The Pew Charitable Trusts’ main interest relative to OAH is to promote and maintain healthy marine ecosystems. While Oregon’s nearshore marine and estuarine ecosystems are directly threatened by OAH, they also provide opportunities to ameliorate and build resilience to the adverse impacts of OAH. In particular, protecting and restoring submerged aquatic vegetation (SAV) such as eelgrass has the potential to both combat the impacts of ocean acidification, while at the same time ensuring that our nearshore and estuarine environments continue to provide the ecosystem services that drive healthy coastal communities.1
While we support the state in its efforts to undertake all five priority actions described in the draft plan, in this letter we offer specific comments on priority actions 3 and 5 related to promoting ecosystem adaptation and resilience, and mobilizing those state agencies with the appropriate regulatory jurisdiction. Specifically, we ask that the state of Oregon ensure that its action plan goes beyond identifying “strategies to maintain SAV in Oregon’s estuaries,”2 to also include developing and enacting policies and regulatory actions that protect and restore SAV such as eelgrass.
1 Nielsen, K., Stachowicz, J., Carter, H., Boyer, K., Bracken, M., Chan, F., Chavez, F., Hovel, K., Kent, M., Nickols, K., Ruesink, J., Tyburczy, J., and Wheeler, S. Emerging understanding of the potential role of seagrass and kelp as an ocean acidification management tool in California. California Ocean Science Trust, Oakland, California, USA. January 2018. 2 Oregon Governor’s Natural Resource Office. Oregon’s Ocean Acidification and Hypoxia Action Plan. August 2019. URL: https://www.oregonocean.info/index.php/ocean-acidification Page 3 Below we discuss our recommendations in further detail, and provide examples of how the state can take the critical step from identifying strategies, to implementing actions that protect Oregon’s coastal ecosystems.
Priority Action #3 – Create Resilience
This priority action seeks to promote adaptation and resilience to OAH in management decisions. As part of this vision, the Action Plan directs state agencies to “identify strategies to maintain sustainable native shellfish stocks and SAV in Oregon’s estuaries and nearshore waters,” and proposes a grant program to help identify how to restore and protect “SAV and native shellfish that provide ecosystem services.”3 We support the state of Oregon undertaking the steps included in Priority Action #3, but believe that there must be a further commitment to actually implementing identified strategies and enacting policies that protect and restore these highly productive habitats that are so crucial to ensuring ecosystem resilience along Oregon’s Coast.
There are multiple regulatory pathways and policy options that the state could pursue to better ensure the protection and restoration of SAV in Oregon’s estuaries and nearshore waters. For example, the Oregon Department of State Lands’ (DSL) removal/fill permitting process could be revised to better ensure that adverse impacts to eelgrass are mitigated according to the best available science and restoration practices. Currently, Oregon’s Removal/Fill Guide includes a section describing the conditions best suitable for eelgrass mitigation, but does not include clear and rigorous standards for the design of compensatory mitigation plans that will achieve full replacement of ecosystem services and function.4
In addition to developing robust science-based mitigation standards for eelgrass, the state could also direct local jurisdictions to update the 22 estuary management plans that constitute the regulatory framework for managing estuaries on the Oregon coast.5 Updating the state’s estuary management plans with the latest data on SAV presence/absence, abundance, and distribution would better enable state and local governments to protect and conserve existing SAV resources. Having updated data on SAV can also help inform restoration and compensatory mitigation efforts in the future, such as establishing eelgrass acreage goals for each estuary and/or cumulatively across the coast. Up-to-date data and monitoring of eelgrass could also inform designation within estuaries of SAV protected areas, buffer zones, and other spatial management tools intended to protect eelgrass, ameliorate the localized impacts of OAH, and help build resilience for Oregon coastal communities and ecosystems.
3 Ibid. Page 16 4 Oregon Department of State Lands. A Guide to the Removal/Fill Permit Process. April 2019. Page 17 5 Oregon Department of Land Conservation and Development. Assessment of Oregon’s Regulatory Framework for Managing Estuaries. March 2014 Priority Action # 5 – Build Sustained Support
This priority action directs relevant governmental agencies to develop “clear, defined goals to address projected ecosystem and economic impacts from OAH.” As part of this effort, priority action #5 calls for the Governor to issue a policy directing relevant state agencies to “consider work they are doing and their plans to address OAH priorities...”6 We support the vision for undertaking this action and feel it is a necessary step towards achieving the goal of resilience as explicated in Priority Action # 3. However, the ultimate success of the OAH Action Plan will require that those activities - regulatory and otherwise - described in earlier priority actions are implemented; in particular those activities intended to build resilience for coastal communities and ecosystems.
Building sustained support for those state agencies that have a role in protecting and restoring SAV will be critical to the OAH Action Plan’s goal of building resilience. Developing strong partnerships with relevant federal agencies can also help create efficiencies and build capacity at the state level for protecting critical habitat such as SAV. For example, the state of California’s natural resource agencies have partnered with the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NOAA Fisheries) to develop the California Eelgrass Mitigation Policy (CEMP). This policy affords protection to eelgrass through state and federal agencies permitting processes by developing science-based standards for avoiding, minimizing, and mitigating adverse impacts resulting from activities conducted in California’s coastal zone. In doing so, the CEMP provides clarity and consistency to coastal managers, communities, and developers on how proposed activities must achieve “no net loss of eelgrass habitat function in California.7”
Additionally, as a participant in the National Coastal Zone Management Program, the state of Oregon can ensure that any federal action that may have an impact on its coastal zone, is consistent with the state’s coastal management program (OCMP). Specifically, the OCMP incorporates all of Oregon’s enforceable policies (i.e. regulations) relative to coastal resources; and federally permitted activities (i.e. dredging, oil/gas exploration, energy facility siting, clean water act compliance, etc.) are required to adhere to those enforceable policies. With respect to the OAH Action Plan, we encourage to the state to assess the current regulatory landscape for protection of SAV, and work to ensure that not only do state-level regulations promote the protection and restoration of SAV, but that regulations are incorporated into the OCMP to ensure those protections extend to federal activities as well.
6 Oregon Governor’s Natural Resource Office. Oregon’s Ocean Acidification and Hypoxia Action Plan. August 2019. URL: https://www.oregonocean.info/index.php/ocean-acidification Page 20 7 NOAA Fisheries. West Coast Region. California Eelgrass Mitigation Policy and Implementing Guidelines. October 2014 Conclusion
As stated in a recent report by the California Ocean Protection Council and Ocean Science Trust:
“Investing in the protection and restoration of SAV is a ‘no regrets’ coastal management strategy for maintaining functional, resilient ecosystems in the face of OA and other stressors.”8
We wholeheartedly concur with this finding. Oregon’s OAH action plan, if properly implemented, has the potential to greatly enhance resilience on Oregon’s coast, for both the marine ecosystem and the communities that depend upon it. In particular, advancing protections and restoration efforts for SAV such as eelgrass can help Oregon adapt to and reduce the impacts of OA, while also expanding provision of the many other ecosystem services derived from SAV. Among other things, these habitats provide nursery and foraging ground for commercially and recreationally valuable species, buffer against storms and floods, and help improve water quality and clarity. As Oregon proceeds with adoption and implementation of the OAH Action Plan, it should seek to advance protection and restoration of SAV as a tool to help ensure resilience and adaption to ocean acidification.
Thank you in advance for your consideration of these comments. We greatly appreciate the work of the Council and Action Plan Working Group, and look forward to participating in the statewide discussion of how best to address OAH.
Sincerely,
Steve Marx Officer, U.S. Oceans, Pacific [email protected]
8 Nielsen, K., Stachowicz, J., Carter, H., Boyer, K., Bracken, M., Chan, F., Chavez, F., Hovel, K., Kent, M., Nickols, K., Ruesink, J., Tyburczy, J., and Wheeler, S. Emerging understanding of the potential role of seagrass and kelp as an ocean acidification management tool in California. California Ocean Science Trust, Oakland, California, USA. January 2018. Page iv Charlotte M RegulaWhitefield
From: DAUGHERTY Peter * ODF
Caren,
It was nice talking to you about submitting changes. I have attached suggested edits to the document under ODF. They occur on pages 27 and 29 and are done in tracked changes. I was trying to follow cross references to the 2018 report, in particular, trying to find more specificity on OHA stressors. As I was doing that I noticed an incorrect reference in the 2018 report. Under recommendation 2.2, there is a parenthetic, as identified in Action 1.3.c, but I cannot find such an action (maybe meant to be Action 1.3.a). I did find “Multiple Stressor Considerations” by Hale and others, 2015, California Ocean Science Trust. And that provide the background I needed.
A brief summary of suggested changes follows: p. 27. “riparian watersheds” seems an odd phrasing, replaced with “ forested watersheds.” Forests also play a significant role in carbon offsets and mitigation; added that role. ODF has a general responsibility for non-point source pollution on forestland, not just the coastal zone plan. p. 29, first bullet. As written bullet was vague. Provision of timber / wood fiber is an ecosystem service; recreation benefits are a cultural ecosystem service. I assumed the document was referring to regulatory ecosystem services. Added specificity. p. 29, two added bullets. Added a bullet for our role in carbon offsets and climate mitigation. Added a bullet to consider OAH stressors in our annual Forest Practices sufficiency meeting with agencies. p.29, second original bullet. We would prefer that this bullet be deleted. According to DEQ’s Water Quality Index (https://www.oregon.gov/deq/FilterDocs/WQI2018DataSummary.pdf, p. 5) the forest land use type continues to have the highest percentage of excellent and good status sites, while the urban and agriculture land use types have the highest percentage of sites in fair to very poor status. The specificity about funding, rather than actually addressing OAH, seems out of place. In deference to drafters, I edited it to a phrasing acceptable to ODF.
Thanks for your consideration and feel free to contact me if you have any questions.
Regards, Peter
Peter Daugherty, Oregon State Forester Mobile: 503-689-6884
From: Caren Braby [mailto:[email protected]] Sent: Wednesday, June 05, 2019 10:43 AM To: DAUGHERTY Peter
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Hi Peter,
Since we brought the OAH Council’s DRAFT Action Plan to the Climate Cabinet on 5/22/2019, we have made modifications to incorporate feedback from agencies in particular. The near-final public comment draft is attached, for ODF review, if desired. We will be finalizing the draft this Friday (6/7), so any comments prior to about noon would be appreciated. Comments that come in later than that will be integrated into our next draft (July) as we finalize the Action Plan for submission to the Governor. The new Appendix D is included in the attachment, which is the one that describes each agency’s nexus with the 2018 Report, and by reference this Action Plan.
Feel free to give me a call on my cell phone, if you’d like to have a quick chat, rather than email back.
Thank you,
Caren
Caren Braby, PhD Marine Resources Program Manager Oregon Department of Fish and Wildlife 2040 SE Marine Science Drive Newport, Oregon 97365 (541) 867-0300 ext. 226 (541) 961-5352 (cell) MRP: http://www.dfw.state.or.us/MRP/ OAH Council: http://www.oregonocean.info/index.php/ocean-acidification OAH YouTube Video: https://www.youtube.com/watch?v=7h08ok3hFSs
2 Charlotte M RegulaWhitefield
From: Calvanese, Thomas
Hi Charlotte, I am writing to express my support for the draft OAH Action Plan, and my thanks to you and everyone who worked so hard to bring it to fruition. As we both know, and was emphasized at the “Carbon Camp” we attended last year in Newport, time is of the essence regarding the pace at which we must act. And so, I suggest that those actions identified in the report that target direct actions to reduce CO2 and OAH stressors should receive top priority. I recommend that we work with affected communities as much as possible. In my experience living in a small, ocean- dependent community, there is a great deal of willingness to act, and of human potential to help address the problem. I am encouraged by the inclusion of a “what you can do” section, and hope this will continue to develop as the identified actions are rolled out in the coming months and years. You can count on me to do my part, and please don’t hesitate to reach out to discuss opportunities to collaborate and to tap into the great human resources here in our community. Keep up the great work, and congratulations! Cheers, Tom 415.309.6568 (mobile) -- Tom Calvanese, MSc | Station Manager Port Orford Field Station | Marine Studies Initiative 444 Jackson St. | PO Box 143 Port Orford, Oregon 97465 541.366.2500 [email protected] research.oregonstate.edu/port-orford marinestudies.oregonstate.edu
1 Comments on OAH action plan D. Fox, 7/8/2019
1) Page 15, Step 3: There needs to be some sort of explanation of measures under step 3. Will there be a process to identify specific measures? You may want to distinguish “reducing excess CO2” from “reducing OAH stressors”. There appears to be overlap between this step and action 3 (protecting, resorting SAV, water quality, etc.).
2) Page 17-18: There seems to be an emphasis on SAV and no mention of estuarine tidal marshes. Tidal marshes also play a large role in sequestration and have many opportunities for increased restoration and protection actions.
3) There seems to be a lot of overlap among actions 2, 3, and 5. The spreadsheet below breaks down what each action does in a very general sense. The issue is that there appears to be quite a bit of overlap among the types of research, strategies, and implementation measures identified among the actions. The research steps also appear to have some overlap with Action 1.
coord. state support identify implement Action agencies research strategies measures 2 x x x 3 x x x 5 x x x
I hesitate to suggest an alternative since a great deal of thought went into this organization and any alternative may have equal overlap issues. One possible alternative would be to organize the steps as follows: Action 1 – support/conduct monitoring and research Action 2 – identify and develop measures and strategies Action 3 – implement the strategies/measures (including state agency coordination) Action 4 – communication and outreach
4) Minor typo – Page 28, last line in table: should say “…and do not…” rather than “…and does not…”