AGS Marine Net Pen Relocation Project: Port Angeles-East- Biological Evaluation | 15-260 | American Gold Seafoods | USA

Final Report

AGS Marine Net Pen Relocation Applied Science Associates Project: Port Angeles-East A member of the RPS Group plc Biological Evaluation 55 Village Square Drive AUTHOR(S): South Kingstown, RI 02879 USA RPS ASA: Tel: +1 (401) 789-6224 Alicia Morandi Fax: +1 (401) 789-1932 Jill Rowe M. Conor McManus Zachary Singer Leavitt www: www.rpsgroup.com Richard Balouskus www: www.asascience.com Melanie Gearon

Shoal’s Edge Consulting: Danielle Reich

PROJECT NUMBER: VERSION: Final RPS ASA 15-260 DATE: 21 January 2016

Prepared for: American Gold Seafoods

Applied Science Associates a member of the RPS Group plc

Location End Client Internal Reviewer(s) Clallam County, Washington American Gold Seafoods Vicki Morris (Vicki Morris Consulting Services; SEPA/NEPA Document Preparation and Permit Specialist), Danielle Reich (Shoals Edge)

Date Release File Name Notes Submitted Final RPSASA_PortAngeles_BioEval_2016Jan21.doc 1/21/2016 Biological Evaluation

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1/21/2016 Executive Summary

American Gold Seafoods (subsidiary of Icicle Seafoods) has contracted with RPS ASA for preparation of a Biological Evaluation to address relocation of an existing marine aquaculture operation from within Port Angeles Harbor to a new site east of the harbor. The marine net pen relocation project is driven by a US Navy proposal to build a pier on the harbor side of Ediz Hook that will expropriate a portion of the Aquatic Lands Lease area used by the existing AGS Port Angeles Harbor farm, and result in significant construction impacts and operational risks to the existing operation. This document includes a summary of the benthic, pelagic, and shoreline habitats in the vicinity of the proposed project area; a description of the threatened and endangered species and critical habitats that may be present in the project action area, and an effects analysis of the potential impacts of net pen construction and operation on the species and habitats most likely to occur within the project action area.

Following the analysis of species and habitats of concern, Table E-1 provides the summary of effects findings for each species or group.

Table E-1. Summary of effects analysis findings for protected and priority species that may occur within or near the project action area.

Species Effects Analysis Determination

Marine Mammals

Gray whale may affect, not likely to adversely affect

Humpback whale may affect, not likely to adversely affect

Killer whale a may affect, not likely to adversely affect

Dall’s porpoise may affect, not likely to adversely affect

Pacific harbor porpoise may affect, not likely to adversely affect

Harbor seal may affect, not likely to adversely affect

Northern elephant seal may affect, not likely to adversely affect

California sea lion may affect, not likely to adversely affect

Stellar sea lion may affect, not likely to adversely affect

Marine Fish

Bull trout a may affect, not likely to adversely affect

Dolly varden may affect, not likely to adversely affect

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Species Effects Analysis Determination

Chinook salmon (Puget Sound ESU) a may affect, not likely to adversely affect

Chum salmon (Puget Sound/Strait of may affect, not likely to adversely affect Georgia ESU)

Coho salmon may affect, not likely to adversely affect

Cutthroat may affect, not likely to adversely affect

Pink salmon (Odd Year DPS) may affect, not likely to adversely affect

Steelhead trout (Puget Sound DPS) may affect, not likely to adversely affect

Bocaccio (Puget Sound/Georgia Basin may affect, not likely to adversely affect DPS)

Canary rockfish (Puget Sound/Georgia may affect, not likely to adversely affect Basin DPS)

Yelloweye rockfish (Puget may affect, not likely to adversely affect Sound/Georgia Basin DPS)

Other rockfish species b may affect, not likely to adversely affect

Eulachon (Southern DPS) may affect, not likely to adversely affect

Green sturgeon (Southern DPS) a may affect, not likely to adversely affect

Green sturgeon (Northern DPS) may affect, not likely to adversely affect

Pacific cod may affect, not likely to adversely affect

Pacific hake may affect, not likely to adversely affect

Pacific herring may affect, not likely to adversely affect

Walleye pollock may affect, not likely to adversely affect

Marine Invertebrates

Geoduck may affect, not likely to adversely affect

Birds

Bald eagle may affect, not likely to adversely affect

Common loon may affect, not likely to adversely affect

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Species Effects Analysis Determination

Brandt’s cormorant may affect, not likely to adversely affect

Brown pelican may affect, not likely to adversely affect

Tufted puffin may affect, not likely to adversely affect

Marbled murrelet may affect, not likely to adversely affect

Clarke’s grebe may affect, not likely to adversely affect

Western grebe may affect, not likely to adversely affect

Common murre may affect, not likely to adversely affect

a Critical habitat for this species is designated within the project area. b Black rockfish, brown rockfish, copper rockfish, quillback rockfish, tiger rockfish, yellowtail rockfish, green-striped rockfish, widow rockfish, red-stripe rockfish, china rockfish.

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Table of Contents

1 Introduction ...... 1 1.1 Proposed Action ...... 1 1.2 Project Action Area ...... 2 1.3 Document Objectives ...... 4 1.4 Clallam County Critical Areas Code Habitat Management Plan and Mitigation Plan ...... 4 1.5 Clallam County Floodplain Management Code ...... 6 1.6 Regulations Applicable to this BE ...... 7 2 Habitats near the Project Action Area ...... 8 2.1 Benthic Habitats ...... 8 2.2 Pelagic Habitats ...... 8 2.3 Shoreline Habitats ...... 8 2.4 Critical Habitats ...... 9 2.5 Essential Fish Habitat ...... 9 2.6 Environmental Baseline Conditions ...... 10 3 Priority Habitats and Species near the Project Area ...... 11 3.1 Marine Mammals ...... 16 3.1.1 Gray Whale ...... 16 3.1.1.1 Status and Description ...... 16 3.1.1.2 Distribution and Habitat Use ...... 16 3.1.1.3 Threats and Occurrence within the Project Action Area ...... 17 3.1.2 Humpback Whale ...... 17 3.1.2.1 Status and Description ...... 17 3.1.2.2 Distribution and Habitat Use ...... 18 3.1.2.3 Threats and Occurrence within the Project Action Area ...... 18 3.1.3 Killer Whale ...... 19 3.1.3.1 Status and Description ...... 19 3.1.3.2 Distribution and Habitat Use ...... 19 3.1.3.3 Threats and Occurrence within the Project Action Area ...... 19 3.1.4 Dall’s Porpoise ...... 20 3.1.4.1 Status and Description ...... 20 3.1.4.2 Distribution and Habitat Use ...... 21 3.1.4.3 Threats and Occurrence within the Project Action Area ...... 21

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3.1.5 Pacific Harbor Porpoise ...... 21 3.1.5.1 Status and Description ...... 21 3.1.5.2 Distribution and Habitat Use ...... 21 3.1.5.3 Threats and Occurrence within the Project Action Area ...... 21 3.1.6 Harbor Seal ...... 22 3.1.6.1 Status and Description ...... 22 3.1.6.2 Distribution and Habitat Use ...... 22 3.1.6.3 Threats and Occurrence within the Project Action Area ...... 22 3.1.7 Northern Elephant Seal ...... 23 3.1.7.1 Status and Description ...... 23 3.1.7.2 Distribution and Habitat Use ...... 23 3.1.7.3 Threats and Occurrence within the Project Action Area ...... 23 3.1.8 California Sea Lion ...... 23 3.1.8.1 Status and Description ...... 23 3.1.8.2 Distribution and Habitat Use ...... 24 3.1.8.3 Threats and Occurrence within the Project Action Area ...... 24 3.1.9 Steller Sea Lion ...... 24 3.1.9.1 Status and Description ...... 24 3.1.9.2 Distribution and Habitat Use ...... 25 3.1.9.3 Threats and Occurrence within the Project Action Area ...... 25 3.2 Marine Fish ...... 25 3.2.1 Pacific Salmon Species and Bull Trout Critical Habitat Area ...... 25 3.2.1.1 Status and Description ...... 25 3.2.1.2 Distribution and Habitat Use ...... 26 3.2.1.3 Threats and Occurrence within the Project Action Area ...... 28 3.2.2 Rockfish Species ...... 28 3.2.2.1 Status and Description ...... 28 3.2.2.2 Distribution and Habitat Use ...... 29 3.2.2.3 Threats and Occurrence within the Project Action Area ...... 30 3.2.3 Eulachon ...... 30 3.2.3.1 Status and Description ...... 30 3.2.3.2 Distribution and Habitat Use ...... 30 3.2.3.3 Threats and Occurrence within the Project Action Area ...... 30 3.2.4 Green Sturgeon ...... 31

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3.2.4.1 Status and Description ...... 31 3.2.4.2 Distribution and Habitat Use ...... 31 3.2.4.3 Threats and Occurrence within the Project Action Area ...... 31 3.2.5 Pacific Cod ...... 32 3.2.5.1 Status and Description ...... 32 3.2.5.2 Distribution and Habitat Use ...... 32 3.2.5.3 Threats and Occurrence within the Project Action Area ...... 32 3.2.6 Pacific Hake ...... 32 3.2.6.1 Status and Description ...... 32 3.2.6.2 Distribution and Habitat Use ...... 33 3.2.6.3 Threats and Occurrence within the Project Action Area ...... 33 3.2.7 Pacific Herring ...... 33 3.2.7.1 Status and Description ...... 33 3.2.7.2 Distribution and Habitat Use ...... 33 3.2.7.3 Threats and Occurrence within the Project Action Area ...... 34 3.2.8 Walleye Pollock ...... 34 3.2.8.1 Status and Description ...... 34 3.2.8.2 Distribution and Habitat Use ...... 34 3.2.8.3 Threats and Occurrence within the Project Action Area ...... 34 3.3 Marine Invertebrates ...... 35 3.3.1 Geoduck...... 35 3.3.1.1 Status and Description ...... 35 3.3.1.2 Distribution and Habitat ...... 35 3.3.1.3 Threats and Occurrence in the Project Area...... 35 3.4 Birds ...... 35 3.4.1 Bald Eagle ...... 35 3.4.1.1 Status and Description ...... 35 3.4.1.2 Distribution and Habitat Use ...... 36 3.4.1.3 Threats and Occurrence within the Project Action Area ...... 36 3.4.2 Common Loon ...... 36 3.4.2.1 Status and Description ...... 36 3.4.2.2 Distribution and Habitat Use ...... 37 3.4.2.3 Threats and Occurrence within the Project Action Area ...... 37 3.4.3 Diving Birds ...... 37

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3.4.3.1 Status and Description ...... 37 3.4.3.2 Distribution and Habitat Use ...... 38 3.4.3.3 Threats and Occurrence within the Project Action Area ...... 38 3.4.4 Marbled Murrelet ...... 39 3.4.4.1 Status and Description ...... 39 3.4.4.2 Distribution and Habitat Use ...... 39 3.4.4.3 Threats and Occurrence within the Project Action Area ...... 39 3.4.5 Waterfowl ...... 40 3.4.5.1 Status and Description ...... 40 3.4.5.2 Distribution and Habitat Use ...... 40 3.4.5.3 Threats and Occurrence within the Project Action Area ...... 41 4 Effects of the Proposed Action ...... 41 4.1 General Effects of Off-Coast Mariculture Activities ...... 41 4.2 Effects of the Proposed Action within the Project Action Area ...... 43 4.2.1 Potential Construction Phase Impacts ...... 43 4.2.1.1 Seafloor Disturbance ...... 43 4.2.1.2 Noise ...... 43 4.2.1.3 Potential for Accidental Hydrocarbon Spills ...... 44 4.2.1.4 Marine Mammal Interactions ...... 44 4.2.2 Potential Operational Phase Impacts ...... 44 4.2.2.1 Seafloor Disturbance ...... 44 4.2.2.2 Noise ...... 45 4.2.2.3 Potential Accidental Hydrocarbon Spills ...... 45 4.2.2.4 Water Quality ...... 45 4.2.2.5 Marine Mammal Interactions ...... 45 4.2.2.6 Additional Mariculture-Related Impacts ...... 46 4.3 Species-Specific Effects Analysis ...... 47 4.3.1 Effects on Marine Mammals ...... 50 4.3.1.1 Gray Whale ...... 50 4.3.1.2 Humpback Whale ...... 51 4.3.1.3 Killer Whale and Designated Critical Habitat ...... 51 4.3.1.4 Dall’s Porpoise ...... 52 4.3.1.5 Pacific Harbor Porpoise ...... 53 4.3.1.6 Harbor Seal ...... 54

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4.3.1.7 Northern Elephant Seal ...... 55 4.3.1.8 California Sea Lion ...... 56 4.3.1.9 Stellar Sea Lion ...... 57 4.3.2 Effects on Marine Fish ...... 57 4.3.2.1 Pacific Salmonids and Designated Critical Habitat ...... 58 4.3.2.2 Rockfish Species and Designated Critical Habitat ...... 59 4.3.2.3 Eulachon ...... 60 4.3.2.4 Green Sturgeon and Designated Critical Habitat ...... 60 4.3.2.5 Pacific Cod...... 61 4.3.2.6 Pacific Hake ...... 62 4.3.2.7 Pacific Herring ...... 63 4.3.2.8 Walleye Pollock ...... 64 4.3.3 Effects on Marine Invertebrates ...... 65 4.3.3.1 Geoduck ...... 65 4.3.4 Effects on Birds ...... 66 4.3.4.1 Bald Eagle...... 66 4.3.4.2 Common Loon ...... 67 4.3.4.3 Diving Birds ...... 67 4.3.4.4 Marbled Murrelet ...... 68 4.3.4.5 Waterfowl ...... 69 4.4 Conclusions ...... 70 5 References ...... 72 Appendix A: AGS Wildlife Interaction Plan ...... 88 Appendix B: Author Qualifications and Resumes ...... 95 Appendix C: Essential Fish Habitat (EFH) Analysis ...... 118 Appendix D: Common Questions about Atlantic Salmon Net Pen Aquaculture (with References) ...... 124

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List of Figures

Figure 1. Map of proposed project action area, Clallam County, Washington, USA...... 3

List of Tables

Table E-1. Summary of effects analysis findings for protected and priority species that may occur within or near the project action area...... ii

Table 1. Critical marine habitats for proposed, candidate, threatened, and endangered species in the project action area...... 9

Table 2. Justification for determinations of ‘No Effect’ on protected species related to the AGS Port Angeles-East marine net pen relocation project...... 11

Table 3. Protected and priority species that may occur within or near the project action area...... 15

Table 4. Salmonid species found in the creeks along the coast in the vicinity of the project action area. 27

Table 5. Characteristics of different types of aquaculture, adapted from Holmer (2010)...... 41

Table 6. Summary of effects analysis findings for protected and priority species that may occur within or near the project action area...... 48

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1/21/2016 1 Introduction

American Gold Seafoods has contracted with RPS ASA to provide a Biological Evaluation (BE) in support of a Joint Aquatic Resources Permit Application (JARPA) for relocation of an existing Atlantic salmon (Salmo salar) marine net pen aquaculture operation from within Port Angeles Harbor to a new site location east of Ediz Hook in the Strait of Juan de Fuca. The proposed action is necessitated by a US Navy proposal to build a pier on the harbor side of Ediz Hook that will expropriate a portion of the Aquatic Lands Lease area used by the existing AGS Port Angeles Harbor farm, and result in significant construction impacts and operational risks to the existing farm. This document describes potential effects of the proposed action on endangered and threatened species listed under the Endangered Species Act, includes information on the Washington State status of species based on the Washington Department of Fish and Wildlife Priority Habitats and Species program, and discusses impacts to species under the Marine Mammal Protection Act. Essential Fish Habitat (EFH), regulated under the Magnuson- Stevens Fishery Conservation and Management Act (MSA) (Public Law 94-265, as amended), is discussed in BE Appendix C. The US Fish and Wildlife Section 7 Consultation Guidelines were used to prepare this evaluation (USFWS 2015a). 1.1 Proposed Action

The proposed action will involve two construction phases, an installation phase, and permanent operation of the relocated net pen facility. A separate JARPA, SEPA Checklist, and Biological Evaluation will be prepared for decommissioning the existing net pen operation within Port Angeles Harbor.

Phase 1 involves the installation of the mooring grid anchors. Up to 60 steel wedge plow-type anchors weighing between 4,000 and 8,000 pounds each will be placed on the sea floor using a crane barge over the Aquatic Land Lease area of approximately 52 acres. The anchors will quickly penetrate the seafloor substrate and be set into place using a tug boat to tension each mooring line. The anchors will extend approximately 350 ft from the perimeter of the net pen array. Refer to the JARPA drawings for details. This phase will involve the work of a support barge, crane, tugboat, and smaller vessels and is expected to occur over approximately 14 to 21 days.

Phase 2 will consist of constructing the circular net pen cages at an existing land-based construction yard or shipyard in the highly-developed Port Angeles Harbor area. The net pen cages will be assembled using high density polyethylene (HDPE) plastic pipe that has been proven to work well in high energy offshore mariculture. This phase is expected to require approximately 25 days.

Phase 3 is the installation phase during which 14 circular net pen cages will be installed into the mooring grid in a 2 x 7 rectangular array (see the JARPA drawings). Each 126-ft diameter cage will be towed out to the mooring grid, fitted with a fish containment net surrounded by a predator exclusion net, and installed with a distance of approximately 72 ft separating it from neighboring cages. The entire array will measure approximately 1,308 ft x 324 ft and cover a surface area of approximately 9.7 acres. The nets will be weighted so that they form tightly-tensioned walls that maintain a rigid structure during strong tidal currents, as well as maintaining a physical separation between the fish containment net and predator exclusion nets. A lightweight net to discourage bird predation and feeding on fish feed pellets will be suspended over the top of each circular cage. A crane barge, tugboats, and smaller support

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vessels will be used during the installation phase. Phase 3 may occur concurrently with Phase 2, and is expected to occur over 6 to 8 weeks. A feed containment and distribution barge measuring approximately 100 x 40 ft will be attached to the eastern end of the net pen array. The barge will house 350 tons of fish feed, the fish feeding system, electrical generator and fuel supply, crew shelter, and other support equipment for operation. The fish feeding system will include air blowers, feed metering valves, a computer-controlled feed distribution system, and 3-inch HDPE plastic feed pipes that will run from the barge into each cage.

A fourth phase of activity will occur during Phase 4: transport of Atlantic salmon smolts from the AGS- owned hatchery near Olympia to the relocated marine net pen farm. All fish destined for the marine net pen rearing facility will be first vaccinated at the hatchery against disease. After transfer to the marine site, the fish stocks will be carefully monitored by aquaculture technicians. The first “wave” of smolts would be transferred over a period of 3 to 4 weeks, onboard a specially-outfitted marine vessel. The vessel would make approximately 6 vessel trips between Olympia and the relocated marine net pen site over the 3- to 4-week time period. The second “wave” of smolts would be entered approximately 2 to 3 months later, with the same sequencing (6 vessel trips between Olympia and the Port Angeles area over a 3- to 4- week time period).

During net pen operation, the amount of feed for each pen will be calculated daily based on the size of the fish, the total biomass in the pen, water temperature, and dissolved oxygen levels. Underwater cameras installed 40 feet below the water surface will monitor feed pellet distribution and feeding response in each fish pen to ensure feed is not wasted. The salmon will be raised for 16 to 18 months before harvest, after which the net pen area will undergo a 2- month fallowing period.

The operational phase of the project will involve vessel trips between Port Angeles Harbor and the net pen relocation site. Two to four times per day, a crew vessel will transport employees and equipment to and from the marine net pen farm. A marine supply vessel will be used to supply the farm with fish feed, freshwater, other supplies and to remove waste materials. Diesel fuel deliveries to operate the generator will likely occur approximately once per month. The diesel engine that will operate in the feed support barge and an electrical generator will be a new piece of machinery, constructed to meet all current US EPA emission standards, and equipped with accidental spill containment measures. The double-walled tank will have a capacity of approximately 3,000 gallons. Other hazardous materials that would be kept on the feed barge include small quantities of motor oil and antifreeze for operation of the diesel engine. Quantities of these products will be kept at a minimum. 1.2 Project Action Area

The location for the proposed fish pen site is 48˚08’15” latitude and -123˚19’00” longitude in approximately 90 to 110 ft of water, 3.8 miles east of Port Angeles Harbor and 1.5 miles offshore from the Morse Creek / Green Point area in the Strait of Juan de Fuca (Clallam County, Washington) (Figure 1). The net pen array will occupy approximately 9.7 acres of surface water (1,308 ft x 324 ft, see JARPA drawings for details).There will be up to 60 anchors that attach the mooring grid to the seafloor beneath the net pens and extending approximately 350 ft out from the net pen array, resulting in a benthic footprint of approximately 52 acres.

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Figure 1. Map of proposed project action area, Clallam County, Washington, USA. The green rectangle represents the net pen array (1,308 ft x 324 ft, 9.7 acre surface area). The pink border represents the extent of the mooring grid anchors (350 ft from net pen array, 52 acre benthic footprint). The pink line indicates the probable vessel route between the net pen array and Port Angeles, measuring approximately 5.5 miles.

According to the US Fish and Wildlife Service Section 7 Consultation Guidelines,

“For determining whether a species or critical habitat “may be present,” it is necessary to delineate the “action area.” Action area is defined as all areas that may be affected directly or indirectly by the… action and not merely the immediate area involved in the action. It encompasses the geographic extent of environmental changes (i.e., the physical, chemical and biotic effects) that will result directly and indirectly from the action. Action area is typically larger than the area directly affected by of the action.” (USFWS 2015a)

Therefore, the action area considered in this BE encompasses all areas of the project: the existing onshore construction yard in Port Angeles Harbor, the likely vessel traffic route between Port Angeles Harbor and the net pen relocation site, the benthic footprint of the mooring grid anchors, and the surface waters occupied by the net pen array. The vessel route traveled during the transport phase

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(Phase 4) is not included in the action area because the fish are aboard the ship and the number of trips is minimal compared to the timespan of the project. This action area definition covers potential temporary, permanent, direct, and indirect effects of the construction and operation phases of the proposed project. 1.3 Document Objectives

The objectives of this document are to:

1. Summarize the benthic, pelagic, and shoreline habitats in the vicinity of the project area; 2. Identify and describe the threatened and endangered species and critical habitats that may be present within the action area; 3. Summarize the likely impacts of the proposed action on species and habitats of concern within the action area, and 4. Describe proposed mitigation measures to avoid or minimize potential impacts to listed species and critical habitats.

This Biological Evaluation has also been prepared to satisfy the requirements of the Clallam County Critical Areas Code (Chapter 27.12) for preparation of a Habitat Management Plan and Mitigation Plan, as described in Section 1.4 below. 1.4 Clallam County Critical Areas Code Habitat Management Plan and Mitigation Plan

Clallam County Pre-Application Conference Notes (December 18, 2015) regarding the Icicle Seafood Fish Net Pen Proposal (County File No. PSD 2015-04) identify the following requirements for compliance with Clallam County Code (CCC):

Section 35.01.040(3) CCC of the Shoreline Management review criteria states that all developments proposed on the shorelines of the County shall be consistent with the Chapter 27.12 CCC, Interim Critical Areas Code, as it applies, as amended.

This proposal is located within a Class I Wildlife Habitat Conservation Area. Section 27.12.320 CCC states that all development permits shall be withheld without the filling and approval of a Habitat Management Plan (HMP). The requirements of a Habitat Management Plan are found in Section 27.12.830 CCC. A Mitigation Plan is also required because this proposal is located within designated critical habitat associated with a threatened or endangered species under ESA (per Section 27.12.835(1)(b)CCC). The requirements for a Mitigation Plan are found in Section 27.12.830, 840 & 850. The Biological Evaluation that will be prepared for the Federal Agencies should meet our requirements for a HMP & Mitigation Plan.

The Clallam County Critical Areas Code defines the following requirements for the Habitat Management Plan (CCC 27.12.830). Locations within the Biological Evaluation (BE) where these requirements are provided are described below each Code requirement.

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(1) This report shall identify how the development impacts Class I or II wildlife habitat conservation areas. The Washington Department of Wildlife Priority Habitat and Species Management Recommendations (1991) may serve as guidance for this report …

BE Chapter 4, Effects of the Proposed Action, describes potential impacts of the proposed marine net pen relocation project within the action area. All of the Strait of Juan de Fuca within Clallam County jurisdiction (to the international boundary with Canada) is designated a Class I wildlife conservation area. Species that may be present within the project action area and their critical habitat were identified from database queries submitted to the US Fish and Wildlife Service (USFWS) Information for Planning and Conservation (IPaC) program, and the Washington Department of Fish and Wildlife (WDFW) Priority Habitats and Species program. The National Oceanic and Atmospheric Administration (NOAA) National Marine Fisheries Service (NMFS) website was also used as reference to determine the species protected under the Marine Mammal Protection Act. Regulations applicable to this BE include the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act, and Marine Mammal Protection Act. Refer to Section 1.6 for details.

(2) The habitat management plan shall contain a map prepared at an easily readable scale, showing the location of the proposed development site; the relationship of the site to surrounding topographic, water features, and existing and/or proposed building locations and arrangements; a legend which includes a complete legal description, acreage of the parcel, scale, north arrows, and date of map revision.

The BE is prepared to accompany the Joint Aquatic Resources Permit Application (JARPA) to Federal, State, and local permitting agencies. The JARPA drawings that accompany the application provide the information requested above.

(3) The habitat management plan shall also contain a report which describes the nature and intensity of the proposed development; an analysis of the effect of the proposed development, activity or land use change upon the wildlife species and habitat identified for protection; and a plan which identifies how the applicant proposes to mitigate any adverse impacts to wildlife habitats created by the proposed development.

The proposed action is described in BE Section 1.1 (above). Additional information is provided in the SEPA Checklist and JARPA prepared for the marine net pen relocation project. The analysis of effects on wildlife species and habitat is provided in BE Chapter 4. Mitigation measures for potential effects to marine mammals, fish, invertebrates and birds are also described in Chapter 4. The applicant's Wildlife Interaction Plan is provided as Appendix A to the BE.

(4) This plan shall be prepared by a person who has been educated in this field and has professional experience as a wildlife biologist.

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The Clallam County Critical Areas Code requires preparation of a Mitigation Plan for any alteration within 200 ft of a Class I wildlife habitat conservation area, or within a designated critical habitat associated with a threatened or endangered species listed under the Endangered Species Act (CCC 27.12.835(1)(b). The objective of the Mitigation Plan is no net loss of critical habitat (CCC 27.12.840[3]). Mitigation measures for the proposed action are described in BE Chapter 4, in the JARPA and SEPA Checklist prepared for the Port Angeles-East marine net pen relocation project, and in the applicant's Wildlife Interaction Plan provided in BE Appendix A. 1.5 Clallam County Floodplain Management Code

Clallam County Pre-Application Conference Notes (December 18, 2015) regarding the Icicle Seafood Fish Net Pen Proposal also state that:

All developments proposed on the shorelines of the County shall be consistent with the Chapter 32.01 CCC, Floodplain Management Code, as it applies, as amended.

Clallam County Frequently Flooded Areas Protection Standards are found in Section 27.12.515 CCC. This proposal would also be subject to the National Marine Fisheries Service (NMFS) Biological Opinion to FEMA for development located within critical habitat for ESA species (including floodplains). The county has two methods to comply with this requirement. The first method is to submit the Habitat Management & Mitigation Plan to FEMA and NMFS for review. The second method is to place the permit on hold until the federal permit is issued.

The Washington Department of Ecology Coastal Atlas shows that the proposed site for the AGS Marine Net Pen Relocation Project: Port Angeles-East, 1.5 miles offshore between Morse Creek and Green Point, is not within a Flood Hazard Area.1 The County's intent in citing the Floodplain Management Code is to implement requirements of the National Flood Insurance Program (NFIP) Model Ordinance to comply with the National Marine Fisheries Service (NMFS) Biological Opinion (BiOp) for the NFIP in the Puget Sound Basin (FEMA 2013). Communities in Puget Sound have the option to: 1) adopt the Model Ordinance, 2) prepare a checklist or programmatic habitat assessment approach to comply with the NMFS 2008 BiOp, or 3) review individual permit applications for compliance with the requirements of the BiOp and NFIP regulations. Clallam County is exercising the third option. The objective is to avoid adverse effects to ESA-listed species that utilize habitats in flood-prone areas, including areas associated with stream, lake, and marine waters by protecting the natural functions and processes that support the habitats of these species, and requiring mitigation for any adverse impacts to the maximum extent practicable. The NMFS 2008 BiOp for the NFIP in Puget Sound (NMFS 2008) applies to fish species and marine mammals that are listed as threatened or endangered, administered by NMFS. The Model Ordinance may also help guide assessment of potential impacts of project actions to bull trout, administered by USFWS.

The AGS Marine Net Pen Relocation Project: Port Angeles-East will be reviewed under NMFS and USFWS ESA Section 7 consultation with the US Army Corps of Engineers while the Corps processes the Rivers

1 https://fortress.wa.gov/ecy/coastalatlas/tools/FloodMaps.as

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and Harbors Act Section 10 permit application. Each of the Services will prepare a Biological Opinion for the proposed marine net pen relocation project, to assess the potential for adverse effects to species listed under the Endangered Species Act and their critical habitat. Listed species that utilize habitat in rivers and streams that discharge to the Strait of Juan de Fuca in the vicinity of the project action area include Puget Sound salmonids and eulachon. These species are discussed in BE Chapters 3 and 4, Sections 3.2.1 and 4.3.2.1 (Puget Sound salmonids), and Sections 3.2.3 and 4.3.2.3 (eulachon). The effects analysis for these species is may affect, but not likely to adversely affect.

This Biological Evaluation will satisfy Clallam County Floodplain Management Code requirements for preparation of a Habitat Management Plan and Mitigation Plan to address FEMA NFIP responsibilities as well as the County's Critical Area Code requirements under the Endangered Species Act (ESA), discussed above in Section 1.4. The County will withhold its decision on the local Shoreline Substantial Development permit pending issuance and review of the BiOps prepared by the Services for the protection of listed species and critical habitat. 1.6 Regulations Applicable to this BE

Federal agencies are required by Section 7 of the Endangered Species Act (ESA, 19 USC § 1536(c)), as amended, to ensure that any actions authorized, funded, or carried out by the agency do not jeopardize the continued existence of a Federally-listed endangered or threatened species, or result in the destruction or adverse modification of the designated critical habitat of a Federally-listed species. The action agencies are required to consult with the U.S. Fish and Wildlife Service (FWS) and/or the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NMFS) to determine whether Federally-listed endangered or threatened species or designated critical habitat are found in the vicinity of the proposed project, and to determine the proposed action’s potential effects on those species or critical habitats.

The Magnuson-Stevens Fishery Management and Conservation Act of 1976 (MSA) was established to promote conservation of marine fishery (shellfish and finfish) resources. This included the establishment of eight regional fishery management councils that develop fishery management plans to properly manage fishery resources within their jurisdictional waters. The 1986 and 1996 amendments to the MSA recognized that many fisheries are dependent on nearshore and estuarine habitats for at least part of their lifecycles, and included evaluation of habitat loss and protection of critical habitat. The marine environments important to marine fisheries are referred to as essential fish habitat (EFH), defined to include “those waters and substrates necessary to fish for spawning, breeding, feeding, or growth to maturity.” The act further mandates the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NMFS) division to coordinate with other Federal agencies to avoid, minimize, or otherwise offset adverse effects on EFH that could result from proposed activities.

The Marine Mammal Protection Act of 1972 (MMPA) was the first act of the United States Congress to call specifically for an ecosystem approach to natural resource management and conservation. MMPA prohibits the taking of marine mammals, and enacts a moratorium on the import, export, and sale of any marine mammal, along with any marine mammal part or product within the United States. The Act defines "take" as the act of hunting, killing, capture, and/or harassment of any marine mammal or the

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attempt at such. The MMPA defines harassment as any act of pursuit, torment or annoyance which has the potential to either injure a marine mammal in the wild or disturb a marine mammal by causing disruption of behavioral patterns, which includes, but is not limited to, migration, breathing, nursing, breeding, feeding, or sheltering. The MMPA provides for enforcement of its prohibitions, and for the issuance of regulations to implement its legislative goals. 2 Habitats near the Project Action Area

The Strait of Juan de Fuca is a dynamic marine environment in which offshore aquaculture methods and equipment must be capable of withstanding the high-energy wind, wave, and current environment. The technical feasibility of finfish aquaculture in western, central, and eastern regions of the Strait has been previously investigated and found to be possible (Rensel and Forster 2002, Rensel and Forster 2003, Rensel and Forster 2004, Rensel and Forster 2005, Rensel et al. 2007). The BE review focuses on habitat characteristics present within or near the project action area. 2.1 Benthic Habitats

An Environmental Impact Statement conducted for a trans-boundary pipeline that terminated in Port Angeles Harbor described the benthic habitats near the project action area as consisting primarily of coarser sand, gravel, and sandwave bottom types (DOE 2007). The site of the proposed net pen relocation site is in approximately 90 to 110 ft of water, which is at the deepest point of the photic zone and precludes the growth of macroalgae or eelgrass. 2.2 Pelagic Habitats

Most of the habitat in the proposed project action area is open water habitat classified as a marine subtidal system with unconsolidated bottom, which “includes all wetlands and deepwater habitats with at least 25% cover of particles smaller than stones (less than 2.5 in), and a vegetative cover less than 30%” and salinities exceeding 30 ppt (USFWS 2010a). The waters of the Strait are well-mixed, cold, and nutrient-rich due to the influence of deep oceanic water, strong wind and current mixing, and seasonal riverine influx (Shaffer 2001). This deepwater pelagic habitat type supports a variety of fish, invertebrates, larvae, and phytoplankton. 2.3 Shoreline Habitats

The shoreline surrounding the project action area (from the harborside tip of Ediz Hook to east of Green Point) is composed of different habitat types. Approximately 360 acres are comprised of marine intertidal habitats that are typically under water, exposed only during periods of extreme low tide. These consist of unconsolidated shore, defined as “all wetland habitats having two characteristics: (1) unconsolidated substrates with less than 75% areal cover of stones, boulders or bedrock, and (2) less than 30% areal cover of vegetation. Landforms such as beaches, bars, and flats are included in the Unconsolidated Shore class” (USFWS 2010a). Another 254 acres consist of marine intertidal unconsolidated shore that is regularly flooded, experiencing tidal flooding at least once daily. A small

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area (< 8 acres) of shoreline has been classified as estuarine intertidal unconsolidated shore (USFWS 2010a). Finally, fewer than 20 acres of nearby habitats are classified as upper perennial riverine with unconsolidated bottom, characterized by “a high gradient and fast water velocity… [with] no tidal influence, and some water flows throughout the year. This substrate consists of rock, cobbles, or gravel with occasional patches of sand” (USFWS 2010a).

The nearshore region between Morse Creek and Green Point ranks low to moderate on the forage fish habitat suitability index with patchy kelp in the nearshore waters and patchy surfgrass and dunegrass on land (NSC 2015). Kelp beds are important feeding habitats for a variety of organisms (sea otters, salmon, forage fish, invertebrates), and are preferentially used by juvenile salmon and surf smelt (Shaffer 2000). These kelp beds extend into waters approximately 30 ft deep and therefore do not fall within the action area. 2.4 Critical Habitats

Critical habitats are defined within Section 7 of the Endangered Species Act (ESA) as:

“(1) specific areas within the geographical area occupied by the species at the time of listing, if they contain physical or biological features essential to conservation, and those features may require special management considerations or protection; and

(2) specific areas outside the geographical area occupied by the species if the agency determines that the area itself is essential for conservation” (NOAA 2015a).

Potential impacts to critical habits should be considered in addition to impacts to threatened and endangered species themselves. Table 1 below lists the marine critical habitats located near the proposed fish pen relocation site, which are discussed within the Marine Mammal and Fish subsections that correspond to the relevant species (see Sections 3.1 and 3.2 of this Biological Evaluation).

Table 1. Critical marine habitats for proposed, candidate, threatened, and endangered species in the project action area.

Critical Habitat Bull Trout Chinook Salmon Green Sturgeon Killer Whale Rockfish 2.5 Essential Fish Habitat

Essential fish habitat (EFH) is defined in the Magnuson-Stevens Fishery Conservation and Management Act (MSA) (Public Law 94-265, as amended), as those waters (e.g., aquatic areas and their associated physical, chemical, and biological properties used by fish) and substrates (e.g., sediment, hard bottom, underlying structures, and associated biological communities) necessary for the spawning, feeding, or

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growth to maturity of managed fish species. There is EFH designated for a total of nine species or species groups near the project action area. These species and a summary of potential impacts are described in the EFH Analysis appended to this BE (Appendix C). 2.6 Environmental Baseline Conditions

The environmental baseline conditions pertinent to this project are those associated with the Port Angeles Harbor, including vessel traffic and anchorages associated with the Port of Port Angeles, other Port activities and commercial and recreational fishing.

Port Angeles Harbor is a semi-enclosed embayment with no-through access and a high volume of vessel traffic that include tankers, dry bulk cargo carriers, barges, tugs, fishing boats, leisure craft, Puget Sound Pilots craft, ferry service, and USCG and Navy vessels (Department of Navy and USCG 2015). Port Angeles is the busiest and most requested anchorage area in Puget Sound (Glosten Associates 2014). It is often used because it supports bunkering and is where pilots depart to meet a vessel traveling east through the Strait of Juan de Fuca and return to after piloting the outbound voyage. However, Port Angeles only reaches capacity about 10% of the time (Glosten Associates 2014). The port has three deepwater terminals with berthing facilities that can accommodate up to five vessels of up to 1,200 feet (366 m) long at one time with a maximum stay of 10 days per vessel (Glosten Associates 2014, Port of Port Angeles 2016). The depth at the berths can accommodate vessels with a draft of up to 35 feet (10.7 m; Port of Port Angeles 2016). Of these anchorages supported by the port, only three can be petroleum ships (DOE 2007). About 70 percent of the ships anchoring in the Harbor are transporting petroleum, and most of those are waiting for their turn to approach the oil refinery in Anacortes (DOE 2007). Port of Port Angeles is also well-known for its handling of forest products as logs and lumber and its servicing of mills throughout the northwest US (Port of Port Angeles 2016).

Port Angeles was historically home to a relatively large commercial fishery industry with approximately 200 vessels moored in the Harbor (DOE 2007). The Port Angeles fishing fleet harvested abundant returns of salmon migrating through the Strait of Juan de Fuca to natal watersheds in Puget Sound, Hood Canal, British Columbia, and tributaries near Port Angeles (DOE 2007). A trawl fishery was supported by healthy stocks of ground fish including rockfish, halibut, cod, lingcod, and pollock and the Dungeness crab market has benefited the local economy (DOE 2007). However, commercial landings in the area have been impacted by the decline of salmon and groundfish populations; the closure of the salmon fishery to non-treaty fishers and only treaty tribal members being allowed to fish for salmon; the Federal listing of Puget Sound Chinook salmon, and changes in fishery management policies (DOE 2007). The remaining fisheries in Port Angeles include crab, shrimp, geoduck clams, sea cucumbers, and sea urchins, with increasing landings for Dungeness crab (DOE 2007).

Recreational fishing for salmon and shellfish also has a minor contribution to the local economy surrounding Port Angeles (DOE 2007). In general, with the decrease in fish harvests, shellfish harvesting has increased (DOE 2007). Species fished recreationally in the Marine Area 6 (East Juan de Fuca Strait) include cabezon, chinook salmon, coho salmon, lingcod, Pacific halibut, pink salmon and sockeye salmon (WDFW 2016a).

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3 Priority Habitats and Species near the Project Area

Lists of threatened and endangered species, as well as priority habitats and species of concern, were compiled from four primary resources:

1. US Fish and Wildlife Information for Planning and Conservation database (USFWS 2015b); 2. Washington Department of Fish and Wildlife priority habitats and species (PHS) list (WDFW 2008, WDFW 2015a); 3. Washington Department of Fish and Wildlife (WDFW 2015b) PHS mapper, and 4. National Oceanic and Atmospheric Administration West Coast Region (NOAA 2015a) species lists.

Information from these sources was compiled into two tables. Table 2 (below) provides the justification for determinations of no effect on protected species. These are species for which no interaction between the Port Angeles-East marine net pen relocation project and their primary habitat, prey, or breeding areas are expected within the action area.

Table 2. Justification for determinations of ‘No Effect’ on protected species related to the AGS Port Angeles-East marine net pen relocation project.

Common Name Project Assessment Scientific Name Marine Mammals Blue whale Species uses waters off California for feeding areas in summer and fall and most Balaenoptera musculus of the stock migrate south to winter and spring in Baja, California, the Gulf of California and off Costa Rica and Nicaragua. The proposed project will not affect this species as it does not enter the inner marine waters of Washington State. Fin whale Species is present off Oregon and Washington for most of the year, but sightings Balaenoptera physalus of fin whales in the inner marine waters of Washington State are very rare. NOAA Fisheries (2014) had no fin whale sightings in the inner marine waters of Washington State between 1991 and 2008. Sei whale This species occurs over deep waters and rarely appear off US west coast. NOAA Balaenoptera borealis Fisheries (2011) had no sei whale sightings in Washington state’s inner waters between 1991 and 2008. Sperm whale Species is present in deeper waters off Washington in all seasons except winter Physeter macrocephalus (December to February). NOAA Fisheries (2015) had no sperm whale sightings in the inner marine waters of Washington State between 1991 and 2008. North Pacific right whale The North Pacific right whale is the most endangered species in the world. Eubalaena japonica Nearly all records of these whales in the eastern North Pacific stock (including Washington) are now restricted to Alaskan waters, especially in the Bering Sea and adjacent areas of the Aleutian Islands. The proposed project will not affect this species as it does not enter the inner marine waters of Washington State.

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Common Name Project Assessment Scientific Name Minke whale This species is ‘resident’ and has an unknown stock abundance trend in Balaenoptera acutorostrata California, Oregon, and Washington. Recent research (2005 to 2011) has reported minke whales predominantly foraging on the banks in the Strait of Juan de Fuca near the San Juan Islands, about 25 miles north of the project area. The species is unlikely to enter the project action area. Sea otter During the 2012 state monitoring survey, no otters were sighted in the Strait of Enhydra lutris Juan de Fuca. Although sightings of scattered individual sea otters have come from the San Juan Islands and Puget Sound in recent years, annual surveys do not extend east of Tongue Point (which is west of Ediz Hook), suggesting that the species is unlikely to occur within the project action area. Marine Invertebrates Dungeness crab This species occurs throughout Washington waters, including the outer coast Cancer magister (mostly in coastal estuaries) and inland marine waters. Dungeness crab utilize different habitats throughout their life cycle: larvae are planktonic, juveniles are found in intertidal mixed sand or gravel areas with algae or eelgrass, and adults are found in subtidal or intertidal areas on sand, mud, or associated with eelgrass beds. WDFW Priority Habitat & Species mapper identified an area of Dungeness crab presence in the western portion of the action area, where vessels would transit between Port Angeles Harbor and the proposed net pen relocation site. Given the volume of existing marine traffic in this area, no effect is expected on Dungeness crab from vessel transit activities associated with the proposed project. Hardshell clams Hardshell clams include Manila and native littlenecks, butter clams, cockles, Various spp. macomas and a few others of little harvest interest. These clams are found on beaches of mixed sand, gravel, and mud. The proposed project will not affect shoreline habitats. Pandalid shrimp Pandalid shrimp are found primarily on or near the bottom, but make daily Pandalus spp. migrations through the water column in search of food. They are most frequently captured at depths of 30 to 300 ft. WDFW Priority Habitat & Species mapper identified an area of Pandalid shrimp presence in the western portion of the project action area, where vessels would transit between the Port and the proposed net pen location. Given the volume of existing marine traffic in this area, no effect is expected on Pandalid shrimp from vessel transit activities associated with the proposed project. Pinto (Northern) abalone Pinto abalone is identified in the WDFW Priority Habitat & Species mapper as Haliotis kamtschatkana occurring in the township that encompasses the project area. However, it is typically found associated with kelp beds and rocky reef habitat between water depths of 10 to 60 ft in Washington state. These habitats do not occur within the project action area, thus no effect is expected.

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Common Name Project Assessment Scientific Name Red sea urchin This species occupies shallow waters from the mid-low intertidal zone to depths Strongylocentrotus greater than 160 ft, and have been found as deep as 400 ft. Red sea urchins franciscanus prefer rocky substrates, particularly ledges and crevices, and are often found in and around stands of the giant kelp, Macrocystis spp., and other brown algae. WDFW Priority Habitat & Species mapping identified an area of red sea urchin presence in the western portion of the action area, where vessels would transit between Port Angeles Harbor and the proposed net pen relocation site. Given the volume of existing marine traffic in this area, no effect is expected on red sea urchin from vessel transit activities associated with the proposed project. Birds Northern spotted owl Prefers mature conifer or mixed forests. Typical habitat characteristics include Strix occidentalis moderate/high canopy closure; large trees with large cavities, broken tops, and large snags; and heavy accumulations of logs/woody debris on the forest floor. The proposed project will not affect upland habitats. Yellow-billed cuckoo This species utilizes wooded habitat with dense cover and water nearby, Coccyzus americanus including woodlands with low, scrubby vegetation, overgrown orchards, abandoned farmland, and dense thickets along streams and marshes. The proposed project will not affect upland habitats. Streaked horned lark Habitat consists of large expanses of bare or thinly vegetated land, including Eremophila alpestris fields, prairies, dunes, upper beaches, airports, and similar areas with low/sparse strigata grassy vegetation. The proposed project will not affect upland habitats. Short-tailed albatross This species is pelagic and spends the majority of its life at sea. Short-tailed Phoebastria albatrus albatross are extremely rare off the outer coastline of Washington, and are extremely unlikely to occur within the project area. American white pelican This species has a very localized distribution in eastern Washington, nesting on Pelecanus erythrorhynchos Crescent and Badger Islands in the Columbia River, and at Sprague Lake. American white pelican are rarely observed in the Strait of Juan de Fuca, and are unlikely to occur in the project area. Marbled godwit Marbled godwit are a shorebird species that nests in native prairie habitats and Limosa fedoa forages on mudflats, salt marshes, estuaries, and coastal pools. The proposed project will not affect upland or shoreline habitats. Pink-footed shearwater This species is found in the open ocean, well offshore in the waters over the Puffinus creatopus continental shelf. Pink-footed shearwaters are extremely unlikely to occur in the project area. Rufous hummingbird This species is typically found at edges and in open areas within coniferous Selasphorus rufus forests. They may also be found in sub-alpine shrubby habitats and in residential areas. The proposed project will not affect upland habitats. Short-eared owl This species inhabits shrub-steppe, grasslands, agricultural areas, marshes, wet Asio flammeus meadows, and shorelines. The proposed project will not affect upland or shoreline habitats. Cassin’s auklet Cassin's auklet is a pelagic species that nests along islands of Washington’s outer Ptychoramphus aleuticus coast. They feed far offshore and are seldom seen near shore. They are unlikely to occur in the project area.

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Common Name Project Assessment Scientific Name Purple martin The main nesting and foraging habitat of purple martin in Washington is open Progne subis land near water. They can be found in developed areas, along waterfronts, and in fields, wetlands, and clearings. The proposed project will not affect upland or shoreline habitats. Peregrine falcon This species hunts in open areas, especially along coast and near other bodies of Falco peregrinus water and next on cliffs, near mountainous, rocky areas of man-made structures. They prey mostly on other birds and would likely not be hunting or found in the area of the proposed project. Reptiles Green sea turtle Green sea turtles occur in the eastern North Pacific, but primarily south of San Chelonia mydas Diego, rarely extending northward to southern Alaska. They have been rarely recorded in Washington, with only four recorded strandings on outer coast beaches between 2002 and 2012. The proposed project will not affect this species as it does not enter the inner marine waters of Washington State. Leatherback sea turtle This species occurs off the coast of Washington (especially off the Columbia River Dermochelys coriacea mouth) during summer and fall, to feed. Critical habitat as designated by NMFS in offshore Washington extends to the 6,500 ft depth contour. The proposed project will not affect this species as it does not enter the inner marine waters of Washington State. Loggerhead sea turtle There have been occasional sightings of this species from the coasts of Caretta caretta Washington and Oregon, but most records of juveniles are off the California coast. Rarely recorded in Washington, with no strandings on outer coast beaches between 2002 and 2012. The proposed project will not affect this species as it does not enter the inner marine waters of Washington State. Terrestrial Mammals Grey wolf This species occupies a variety of upland habitats, including temperate forests, Canis lupus mountains, tundra, taiga, and grasslands. The proposed project will not affect upland habitats. Fisher This species inhabits mature conifer and mixed conifer/hardwood forests Martes pennanti characterized by dense canopies and abundant large trees, snags, and logs. They generally avoid areas with little forest cover or significant human disturbance. The proposed project will not affect upland habitats. Sources: FWS, NMFS, NatureServe, BirdWeb, eBird, WDFW, Encyclopedia of Puget Sound, and northeastpacificminke.org

Table 3 contains a list of protected and sensitive species that may be affected by the project due to their potential occurrence within the action area. Detailed life history, habitat use, and distribution information about each of these species is provided throughout subsections of Chapter 3, and an effects analysis of potential impacts and mitigation measures is provided for each species or group in Chapter 4.

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Table 3. Protected and priority species that may occur within or near the project action area.

Common Name Scientific Name Federal ESA State Status a Status a

Marine Mammals Gray whale Eschrichtius robustus None S Humpback whale Megaptera novaenglia E E Killer whale Orcinus orca E, CHb E Dall’s porpoise Phocoenoides dalli None M Pacific harbor porpoise Phocoena phocoena None C Harbor seal Phoca vitulina None M Northern elephant seal Eumetopias jubatus None None California sea lion Zalophus californianus None None Stellar sea lion Eumetopias jubatus SC None Marine Fish Bull trout Salvelinus confluentus T, CHb C Dolly varden Salvelinus malma None P Chinook salmon (Puget Sound ESU) Oncorhynchus tshawytscha T, CHb C Chum salmon (Puget Sound/Strait of Oncorhynchus keta T C Georgia ESU) Coho salmon Oncorhynchus kisutch SC P Cutthroat Oncorhynchus clarki None P Pink salmon (Odd Year DPS) Oncorhynchus gorbuscha None P Steelhead trout (Puget Sound DPS) Oncorhynchus mykiss T None Bocaccio (Puget Sound/Georgia Basin Sebastes paucispinis E, CH C DPS) Canary rockfish (Puget Sound/Georgia Sebastes pinniger T, CH C Basin DPS) Yelloweye rockfish (Puget Sebastes ruberrimus T, CH C Sound/Georgia Basin DPS) Other rockfish species c Various None C Eulachon (Southern DPS) Thaleichthys pacificus T C Green sturgeon (Southern DPS) Acipenser medirostris T, CHb None Green sturgeon (Northern DPS) Acipenser medirostris SC None Pacific cod (S&C Puget Sound) Gadus macrocephalus SC C Pacific hake (Pacific-Georgia Basin Merluccius productus SC C DPS) Pacific herring Clupea pallasii None C Walleye pollock (So. Puget Sound) Theragra chalcogramma None C Marine Invertebrates Geoduck Panopea abrupta None P Birds Bald eagle Haliaeetus leucocephalus SC S Common loon Gavia immer None S Brandt’s cormorant Phalacrocorax penicillatus None C

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Common Name Scientific Name Federal ESA State Status a Status a

Brown pelican Pelecanus occidentalis SC E Tufted puffin Fratercula cirrhatat None E Marbled murrelet Brachyramphus marmoratus T, CH T Clarke’s grebe Aechmophorus clarkii None C Western grebe Aechmophorus occidentalis None C Common murre Uria aalge None C a E = Endangered, T = Threatened, CH = Critical Habitat, PCH = Proposed Critical Habitat, S = Sensitive, SC = Species of Concern, C = Candidate Species, M = Monitored, P = Priority Species b Critical habitat for this species is designated within the project area. c Black rockfish, brown rockfish, copper rockfish, quillback rockfish, tiger rockfish, yellowtail rockfish, green- striped rockfish, widow rockfish, red-stripe rockfish, china rockfish.

3.1 Marine Mammals 3.1.1 Gray Whale

3.1.1.1 Status and Description

The Washington Department of Fish and Wildlife lists gray whales as “sensitive” (WDFW 2015a). This status refers to species that are vulnerable or declining, and likely to become endangered or threatened in significant portions of their range if threats persist or if cooperative management does not occur. While the western Pacific population is Federally-listed as endangered, the US Fish and Wildlife Service delisted the eastern Pacific population in 1994; therefore, it does not currently have a Federal listing status (Richardson 1997). However, gray whales, like all marine mammals, are protected under the Marine Mammal Protection Act (MMPA).

Gray whales are large, mottled baleen whales. They can grow to 15 m (50 ft) long and weigh over 36,000 kg (80,000 lbs). They lack a dorsal fin and instead have a "dorsal hump" located about two-thirds of the way back on their body. A series of 8 to 14 small bumps, known as "knuckles,” appear between the dorsal hump and the tail flukes. Barnacles and whale lice appear on their bodies, with higher concentrations found on the head and tail (NOAA 2013a).

Gray whales roll on their sides and swim slowly along the sea floor to feed. They filter amphipods from bottom sediments using their baleen plates. Gray whales reach sexual maturity at an average of 8 years old and give birth to single calves after 12 to 13 months of gestation. Calves are born dark gray and lighten as they age (NOAA 2013a).

3.1.1.2 Distribution and Habitat Use

Gray whales are only found in the North Pacific (NOAA 2014a). Genetically distinct Eastern North Pacific (ENP) and Western North Pacific (WNP) populations are recognized. The ENP population feeds mostly in

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the Chukchi, Beaufort, and Bering Seas. A small number of whales (~200) known as the “Pacific Coast Feeding Group” (PCFG) summer and feed between Kodiak, Alaska and Northern California. The minimum population estimate for the ENP is about 18,000 (NOAA 2014a).

Gray whales are found mainly in shallow coastal waters and feed among bottom sediments during the summer. Calves are born in shallow lagoons and bays from early January to mid-February. Wintering and breeding occurs primarily along the west coast of Baja California, Mexico.

3.1.1.3 Threats and Occurrence within the Project Action Area

The ENP population of the gray whale migrates through Washington waters when traveling between its Alaskan feeding waters and its Mexican breeding waters. Usually, fewer than 20 gray whales visit the inner marine waters of Washington and British Columbia (WDWF 2015a). They typically arrive in January and some stay until summer. According to the WDFW Priority Habitats and Species mapper (WDWF 2015b), gray whales are “regularly occurring” in a nearshore region southeast of the project action area. General nearshore threats to gray whales include vessel collisions, entanglement in fishing gear, and disturbance from ecotourism, noise, and whale-watching. Because of their annual migration along the heavily-populated west coast, members of the ENP stock are vulnerable to commercial/industrial development (NOAA 2013a). There are also concerns regarding a proposed hunt of the PCFG population by the Makah Tribe off the northwestern end of the Olympic Peninsula (WDFW 2015a). NOAA recently released a draft EIS in response to this proposal (NOAA 2015b). 3.1.2 Humpback Whale

3.1.2.1 Status and Description

Humpback whales (Megaptera novaeangliae) are State-listed as an endangered species. This assignment indicates that the species is seriously threatened with extinction throughout all or a significant portion of its range within Washington State. Similarly, the US Fish and Wildlife lists humpback whales as “endangered” and in danger of extinction throughout all or a significant portion of their range. Humpback whales were listed as an endangered species in 1970, and like all marine mammals, are protected under the Marine Mammal Protection Act.

Humpback whales are one of the larger whale species, ranging up to 60 ft in length. Females tend to be larger than males, and newborns are about 15 ft in length. Their long pectoral fins provide increased maneuverability in moving forwards and backwards. Body coloration tends to be grey, but individuals vary based on the amount of white they have on their pectoral fins and belly (NOAA 2015c). The white coloration on the underside of their fluke (or tail) is so distinctive that it allows scientists to identify individual whales. The species provides a number of aerial displays, from breaching (jumping out of the water), to slapping their tails, fins and heads at the surface of the water.

A baleen whale, the humpback feeds primarily on small crustaceans (i.e., krill), plankton, and fish. Humpback whales use several distinct tactics in feeding, including “bubble netting”. This technique uses bubbles to herd and disorient fish prey, while multiple whales contributing to the effort either through bubble making or herding, before striking the prey swarm (NOAA 2015c).

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Breeding usually occurs once every two or three years. During mating, males will claim dominance for mating grounds by using bubble or vocal displays, or chasing and thrashing at other males. These vocalizations, also known as whale songs, can last up to 20 minutes and occur over distances as far as 20 miles. Gestation lasts up to 11 months, with weaning occurring 6 to 10 months after birth. Mothers provide maternal support by staying close and physical contact, whereas males provide little paternal support (NOAA 2015c).

3.1.2.2 Distribution and Habitat Use

North Pacific populations of humpback whales reached 18,000 to 20,000 individuals by 200 to 2006, roughly 15 to 17 times higher abundance than the estimated population in 1966 (Calambokidis et al. 2008). Humpback whales feeding along the US west coast are members of the California/Oregon/ Washington stock; however, there is some mixing with the British Columbia stock in northern Washington. Mixing between these two stocks suggests that there could be a third stock in this region (Calambokidis et al. 2008, Carretta et al. 2013).

The California/Oregon/Washington stock was estimated at 2,043 whales in 2007 to 2008 (Calambokidis et al. 2009). Humpback whales perform the largest migration pattern of any animal (longest record is 5,160 miles in the Atlantic). The California/Oregon/Washington stock spends winters south in waters off Mexico and Central America, with most whales occurring in Washington waters between July and September (Green et al. 1992, Calambokidis et al. 2000). During summer months, the whales spend most of their time feeding and building blubber to be utilized in the winter. In the winter grounds, the whales congregate for mating activities.

Humpback whales are the most common whale species off northern Washington, with numbers increasing; however, the population size is still historically low compared to years prior to whaling. Once common in the inner marine waters of Washington and British Columbia, the whale population has been decimated so that the whales rarely visit the more coastal waters (Scheffer and Slipp 1948, Calambokidis and Steiger 1990). In 2012, a humpback whale was spotted in Hood Canal during January and February (WDFW 2015a).

3.1.2.3 Threats and Occurrence within the Project Action Area

Entanglement in fishing gear and inadvertent vessel strikes are two of the greatest threats to whales, with potential of injury or death (NOAA 2015c). Humpbacks can get entangled in fishing gear and either swim off with it or be anchored by it. Between 2004 and 2008, 16 humpback whales (14 seriously injured, 2 killed) from the California/Oregon/Washington stock were recorded entangled in fishing gear. Over the same period, an additional two humpbacks were killed by ship strikes in California, Oregon, and Washington (Carretta et al. 2013). There is additional concern about tourism (primarily whale watching) interfering with whale aggregations during feeding, or increasing vessel strike incidents. Prior to 1966, whaling was the largest contributor to population declines and death. The International Whaling Commission prohibited commercial whaling of humpbacks that year. Since then, the species has been listed as endangered and much work has gone into identifying distinct populations for better management.

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3.1.3 Killer Whale

3.1.3.1 Status and Description

The Washington Department of Fish & Wildlife lists killer whales as “endangered” (WDFW 2012a). This status refers to species that are seriously threatened with extinction throughout all or a significant portion of their range within the state. Similarly, the US Fish and Wildlife Service lists killer whales as “endangered”, in danger of extinction throughout all or a significant portion of their range. Additionally, killer whales (like all marine mammals) are protected under the Marine Mammal Protection Act.

Killer whales have black coloring on their dorsal side with iconic white patches near their eyes. They belong to the dolphin family but are considered whales due to their size. Females can live as long as 100 years and weigh up to 7,500 kg (8.25 tons), while males can live as long as 60 years and weigh up to 9,900 kg (11 tons; NOAA 2015d). Their diet can include fish, marine mammals, sharks, and sea birds but varies with location. These highly social creatures live within fairly stable matrilineal groups (“pods”) that typically range in size from 2 to 15 animals, although larger groups occasionally form. Their gestation period varies from 15 to 18 months, with no distinct calving season. Killer whales rely on underwater sound for communication, orientation, and feeding. Their diet consists primarily of salmonids, particularly chinook salmon in the summer and coho, chum, and steelhead in the fall and spring (NWFSC 2014).

3.1.3.2 Distribution and Habitat Use

Killer whales are the most widely distributed marine mammals and are abundant in colder waters, including those of Antarctica, Norway, and Alaska, but have also been sighted at lower densities in temperate, tropical, subtropical, and offshore waters. Populations of killer whales sighted in the US include Transient (Bigg’s) Killer Whales, AT1 Transient killer whales, Offshore Killer Whales, and Southern Resident Killer Whales (SRKW). These populations rarely interact and do not interbreed (Wiles 2004). The SRKW population is the only population listed as a distinct population segment under the ESA, but AT1 Transients are listed as “Depleted” under the Marine Mammal Protection Act (MMPA).

The SRKW population is the only known resident population in the US, estimated at 80 individuals (NOAA 2015d). It is considered a single stock under the MMPA, and a single species under the ESA. This population is comprised of three distinct pods: J, K, and L. Each pod possesses a distinct set of calls and whistles, akin to a local dialect. In spring, summer, and fall, the SRKW population inhabits the inland waterways of Washington State and the transboundary waters between the US and Canada. In winter, these whales may range as far south as central California and as far north as Southeast Alaska, but their complete range is unknown.

3.1.3.3 Threats and Occurrence within the Project Action Area

Most sightings of the SRKW population have occurred in the summer in inland waters of Washington and southern British Columbia (NOAA 2014b), including the eastern portion of the Strait of Juan de Fuca. Of the J, K, and L pods which comprise the SRKW population, the J pod is most commonly sighted in

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inshore waters and numbered 25 individuals in 2012 (WDFW 2012a). Transient whales also enter coastal waters of the State (Wiles 2004).

The SRKW population was heavily harvested for aquaria display in the 1960s and 1970s. Present threats include declines in chinook salmon (their primary food source), chemical/oil contamination, and boat noise. Due to PCBs and DDT residues, both SKRW and transient populations are considered the most highly contaminated marine mammals in the world (Wiles 2004). Finally, killer whales are a frequent object of whale watching in and around the San Juan Islands on the north side of the Strait of Juan de Fuca. Thus, regulations implemented by NOAA in 2011 require vessels to stay at least 200 yards from the whales and forbid vessels from intercepting the whales or stopping in their path. These regulations are designed to reduce the risk of vessel strikes and mitigate potential impacts from anthropogenic noise on echolocation and behavior. Recent research has indicated that survival and birth rates of the SRKW population are correlated with coast-wide abundance of salmon and that prey availability has a greater stress effect on the population than vessel traffic (NWFSC 2014).

Critical habitat was designated for the SRKW population in November 2006, covering 2,560 square miles of inland waters in Washington State (NOAA 2015b). Their critical habitat includes the project action area since it encompasses all waters of the Strait of Juan de Fuca and Puget Sound beyond 20 ft deep (relative to extreme high water). A petition was made in February 2015 to increase the SRKW critical habitat designation to include Pacific Ocean marine waters that constitute essential foraging and wintering areas. A special report on 10 years of research concluded that killer whales are particularly vulnerable to increased vessel traffic and water column contaminants, and forage less frequently when vessels are present (Lusseau et al. 2009, NWFSC 2014). The AGS Wildlife Interaction Plan (Appendix A) requires company crew vessel operators to slow down and avoid killer whale trajectories by 400 yards in accordance with NOAA regulations. 3.1.4 Dall’s Porpoise

3.1.4.1 Status and Description

The Washington Department of Fish and Wildlife lists Dall’s porpoise as “monitored” (WDFW 2015a). This status refers to species that are managed to prevent them from becoming endangered, threatened, or sensitive. Dall’s porpoise are not federally-listed but are protected under the Marine Mammal Protection Act.

Dall’s porpoise weigh up to 220 kg (480 lbs), and measure about 10 ft long (NOAA 2015e). They are a fast-swimming member of the porpoise family, and are common in the North Pacific Ocean. Dall’s porpoises have a small, triangular head (relative to other porpoises), with minimal beak and a thick body form. Their diet consists of fish (e.g., anchovies, herring, smelt) and invertebrates (e.g., squid octopus, shrimp), which they hunt by diving. Dall’s porpoises become mature in 3.5 to 8 years, and females give birth to a single calf per year during the summer months. Their lifespan ranges from 15 to 20 years.

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3.1.4.2 Distribution and Habitat Use

Dall’s porpoises are found throughout the North Pacific Ocean basin, ranging east to Puget Sound and Baja, south to Baja and South Korea, and north to the Bering Sea. Although the species is most commonly found in temperate and boreal waters that are in excess of 600 feet (180m), they are also found inshore and along nearshore oceanic waters.

3.1.4.3 Threats and Occurrence within the Project Action Area

Dall’s porpoise abundance along the west coast of the United States was most recently estimated at 42,000 individuals (NOAA 2011b). The most recent estimate for abundance of the species in the inland waters of Washington is 900 individuals, but this study is almost 20 years old (Calambokidis et al. 1997).

Threats to Dall’s porpoise include incidental capture in fishing gear, Japanese hunting, and pollutant and contaminants in the marine environment (NOAA 2015e). Mortalities have been recorded in the California drift gillnet fishery, domestic groundfish trawl fisheries, Pacific hake trawl fishery, and the swordfish fishery. The Japanese hunting fleet takes approximately 18,000 individuals each year (NOAA 2015e). 3.1.5 Pacific Harbor Porpoise

3.1.5.1 Status and Description

The Washington Department of Fish and Wildlife lists Pacific harbor porpoises as a “candidate” species (WDFW 2015c). This status refers to species that are to be reviewed by the State for possible listing as endangered, threatened, or sensitive. NOAA has not listed harbor porpoises, but they are protected under the Marine Mammal Protection Act.

Harbor porpoises may weigh up to 77kg (170 lbs) and measure 5 ft in length. The species has a small, robust body shape, with a minimal, blunt beak. Harbor porpoise markings include a dark grey back, with white bellies and throats. Their diet includes schooling fish (e.g., herring, capelin) and invertebrates (e.g., cephalopods). The species general travels in small groups of one to eight individuals. Sexual maturity is reached in 3 to 4 years, and females may give birth every year for several years in a row. Lifespan is approximately 24 years.

3.1.5.2 Distribution and Habitat Use

In the eastern North Pacific Ocean, harbor porpoises range from Point Barrow in northern Alaska south to Point Conception in California. The species is distributed in coastal and inland waters. Harbor porpoises are known to occur year-around in the Strait of Juan de Fuca and Puget Sound (NOAA 2011b). The species is most commonly found in bays, estuaries and harbors less than 200m (650 ft) deep.

3.1.5.3 Threats and Occurrence within the Project Action Area

The 2003 estimated abundance of the inland Washington waters stock of harbor porpoises was 10,682 individuals, with a minimum population estimate of 2,545 (NOAA 2011b). There is no more recent

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abundance estimate available for this stock, and there are no reliable data on long-term population trends on the harbor porpoise.

Threats to harbor porpoises include by-catch in fishing gear (particularly gillnets, trawls, and herring weirs) and boat strikes. Additionally, Unusual Mortality Events (UME) have been recorded for this species in Puget Sound, including 114 standings in 2006 (NOAA 2011b). 3.1.6 Harbor Seal

3.1.6.1 Status and Description

The Washington Department of Fish and Wildlife lists harbor seals as a “monitored” species (WDFW 2015c). This status refers to species that are managed to prevent them from becoming endangered, threatened, or sensitive. The US Fish and Wildlife Service has not listed the harbor seal under the ESA, but harbor seals are protected under the Marine Mammal Protection Act.

Harbor seals weigh about 111 kg (245 lbs) and measure about 2 m (6 ft) long. They appear blue-gray with light and dark speckling, and are typically observed “hauled out” on land, with head and flippers elevated (NOAA 2015f). Hauling out allows harbor seals to rest, regulate their temperature, socialize, avoid predators, and give birth. Their diet consists of fish, shellfish, and crustaceans, which they hunt by diving. Harbor seals mate at sea and females give birth during the spring and summer. Their lifespan ranges from 25 to 30 years.

3.1.6.2 Distribution and Habitat Use

Harbor seals are generally non-migratory and occur on the east and west coasts of the US. On the west coast, harbor seals inhabit coastal and estuarine waters from British Columbia, Canada to Baja California, Mexico. Their range also extends westward through the Gulf of Alaska and into the Bering Sea (NOAA 2015f). Harbor seals haul-out on rocks, reefs, beaches, logs, and drifting glacial ice.

3.1.6.3 Threats and Occurrence within the Project Action Area

Harbor seals are the most abundant marine mammal species in Washington State (Calambokidis et. al. 1999). Their abundance in the Strait of Juan de Fuca was estimated at 11,800 individuals in 1994 (Calambokidis and Baird 1994). According to the WDFW Priority Habitats and Species mapper (WDFW 2015b), a log boom on Ediz Hook is a major harbor seal haul-out near the project action area, with another site or two along the southern shore of Port Angeles Harbor.

Threats to harbor seals include incidental capture in fishing gear, ship strikes, oil/chemical exposure, power plant entrainment at coastal power plants, and harassment by humans (NOAA 2015f). According to the Northwest Marine Mammal Stranding Network, non-natural mortality and injury of harbor seals in Washington Northern Inland Waters (including the Strait of Juan de Fuca) between 2007 and 2011 included six fishery-related incidents, eight shootings, nine boat strikes, two oiling incidents, three dog attacks, and 13 marine debris entanglements, while mean annual mortality for this period was only 6.4 individuals (NOAA 2014c).

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3.1.7 Northern Elephant Seal

3.1.7.1 Status and Description

Northern elephant seals have no State- or Federal-listing status; however, they are protected under the MMPA.

Northern elephant seals are the largest phocid seal in the Northern Hemisphere. Fully-grown males may weigh up to 2.2 tons (2,000 kg) and reach 13 ft (4 m) in length. Females may reach 1,300 lbs (600 kg) and 10 ft (3 m) in length (NOAA 2015g). Adult elephant seals have dark brown or grey fur. A key identifying feature of male elephant seals is a large inflatable nose, or proboscis. Lifespan ranges from 13 to 19 years, with females living longer than males. The diet of elephant seals primarily consists of fish and squid, but may also include rays and sharks. The species does not feed during its time on land.

3.1.7.2 Distribution and Habitat Use

Northern elephant seals only occur in Washington waters for a portion of the year. The species migrates from California and Mexico to their northern Pacific feeding areas. Adult males feed primarily in the Gulf of Alaska, while females tend to feed farther south (between 40 and 45°N latitude) in deep offshore waters (Seal Conservation Society 2005). Solitary individuals are occasionally seen in Washington marine waters. Only one site in the Strait of Juan de Fuca has been identified as a regular haul-out site for this species: Race Rocks on the southern tip of Vancouver Island. However, the WDFW Priority Habitats and Species data identified the seal haul-out area at the Port Angeles Rayonier mill as having documented identifications of northern elephant seals utilizing the area (WDFW 2005b; Jeffries et al. 2000). This haul- out location is primarily utilized by harbor seals.

3.1.7.3 Threats and Occurrence within the Project Action Area

Northern elephant seals were nearly hunted to extinction in the 1800s along the US Pacific coast. Populations have subsequently recovered (Stewart et al. 1994). A complete population count is not possible because all age classes are not found ashore at the same time. A recent population estimate has put abundance at approximately 179,000 individuals (Lowry et al. 2014).

Numerous fisheries, including the Washington domestic groundfish trawl fishery, are known to result in human-caused mortality of Northern elephant seals (NOAA 2015h). Other threats include shootings, debris entanglements, hook-and-line fisheries, vessel strikes, and power plant entrainment at coastal power plants. 3.1.8 California Sea Lion

3.1.8.1 Status and Description

The California sea lion has no State- or Federal-listing status; however, this species is protected under the MMPA.

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Male California sea lions may exceed 1,000 lbs (455 kg) and 7.5 ft in length. Females are considerably smaller, weighing up to 240 lbs 110 kg) and reaching 6 ft in length (NOAA 2015i). The species has broad foreflippers and a long, narrow snout. Their coats are generally dark brown, with females being slightly lighter in shade than males. California sea lions are social animals and may form groups up to several hundred individuals at haul-outs, most commonly on sandy beaches. The species feeds mainly in upwelling areas on invertebrates (e.g., squid) and fish (e.g., anchovies, mackerel, rockfish). They have also been known to take fish from commercial fishing gear, sport fishing lines, and at fish passage facilities. Sea lions reach sexual maturity at 4 to 5 years old. Their breeding season lasts from May to August, and most pups are born between May and July. Lifespan is approximately 20 to 30 years.

3.1.8.2 Distribution and Habitat Use

California sea lion inhabit the Eastern North Pacific Ocean in shallow coastal and estuarine waters. The species ranges from the Pacific coast of Central Mexico to British Columbia, Canada. They utilize a variety of habitats for haul-out zones, including sandy beaches, docks, jetties, and navigation buoys. Male California sea lions migrate from the southern portion of their range to Puget Sound and Canada during non-breeding months. They remain until late spring when they return south. All age classes of males are present in the Washington area. California sea lions have been spotted at haul-out sites in the project vicinity. Within Port Angeles Harbor, there are two known seal haul-outs that have been noted to include California sea lions. These locations include the log booms off the Rayonier pulp mill site, and the log booms inside Ediz Hook (WDFW 2005a; Jeffries et al. 2000).

3.1.8.3 Threats and Occurrence within the Project Action Area

Approximately 3,000 to 5,000 California sea lions move into the Washington area during the fall, only to return south in the late spring (Jeffries et al. 2000). The minimum population size of the entire US stock is 153,337 (NOAA 2015i).

California sea lions are killed by a variety of fishing activities, including trawls, purse seines, and gillnets along the US west coast (NOAA 2015i). The species is also subject to mortality due to ingestion of fishing hooks from commercial and recreational fisherman. Minimum total annual mortality due to commercial fisheries is estimated greater than or equal to 331 individuals per year (NOAA 2015i). Other threats include boat collisions, car collisions, entrainment in coastal power plants, shootings, debris entanglement and ingestion, and dog attacks. Exposure to anthropogenic sound has been found to negatively impact individual sea lions (Houser et al. 2013). 3.1.9 Steller Sea Lion

3.1.9.1 Status and Description

The Stellar Sea Lion is Federally-listed by NOAA as a Species of Concern, but carries no Washington State designation. The species was Federally-delisted in 2013.

Stellar sea lions are considerably larger than California sea lions with males reaching 2,500 lbs (1,100 kg) and females reaching 770 lbs (350 kg). Males may reach a length of up to 11 ft, and females up to 9.5 ft.

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Adult Steller sea lions have light blonde to reddish brown fur that is slightly darker on the chest. Pups tend to have darker fur. The species is known to live and breed in Washington waters. Stellar sea lions forage in nearshore and pelagic waters for a variety of fish (e.g., capelin, cod, herring, mackerel, salmon) and invertebrates (e.g., clams, squid, octopus). They use land as haul-out sites for periods of rest, molting, and rookeries. Sexual maturity occurs at 4 to 6 years of age, and most females are capable of giving birth to a single pup each year. Lifespan ranges from 20 to 30 years (NOAA 2105k).

3.1.9.2 Distribution and Habitat Use

Steller sea lions prefer cold temperate to sub-arctic waters of the North Pacific Ocean. The population in the United States and Canada is divided into Western and Eastern distinct population segments (DPS) (NOAA 2015k). Steller sea lions in Washington are part of the Eastern DPS. Washington haul-out sites are located primarily along the outer coast from the Columbia River to Cape Flattery. Haul-out sites are primarily beaches (gravel, rocky, or sand), ledges, and rocky reefs. The WDFW Priority Habitats and Species data identified the seal haul-out area at the Port Angeles Rayonier mill as having documented use by Steller sea lions (WDFW 2005a; Jeffries et al. 2000). The species is not known to migrate, but will disperse widely outside of the pupping season.

3.1.9.3 Threats and Occurrence within the Project Action Area

Steller sea lion populations vary in Washington State waters, with peak abundances of approximately 1,000 individuals present during their summer breeding season (Jeffries et al. 2000). There are no known pupping areas within the Strait of Juan de Fuca.

There are numerous threats to Steller sea lions due to human-related forms of mortality (NMFS 2008). The species is susceptible to many of the same fishing mortality issues as California sea lions, including getting caught in net gear and ingesting hooks. There is a subsistence harvest for Steller sea lions in Alaska and British Columbia. Other forms of human-induced mortality include shootings, disturbance, entanglements in debris, and contaminants. Total fisheries-related mortalities for the entire stock of Stellar sea lions are estimated at about 46 individuals per year (Allen and Angliss 2013). 3.2 Marine Fish 3.2.1 Pacific Salmon Species and Bull Trout Critical Habitat Area

3.2.1.1 Status and Description

Many salmonid species are found in the Strait of Juan de Fuca and occur in the waters in and near the project action area. The Washington Department of Fish and Wildlife lists the following salmonids, which occur in riverine and nearshore waters of Clallam County, as either candidate species that will be reviewed for status assignment of threatened or endangered at some point in the future, or recognizes them as priority species for conservation and management: coho salmon, chinook salmon, chum salmon, pink salmon, steelhead trout, bull trout, dolly varden, and cutthroat (WDFW 2015a, 2015b).

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Several species of west coast salmonids are managed and listed according to distinct population segments (DPSs) or evolutionarily significant units (ESUs). To qualify as a DPS, a population must be mostly reproductively isolated from other populations of that species. If the DPS represents an important component in the species' evolutionary legacy, it can be considered an ESU. Chinook salmon (Puget Sound ESU), chum salmon (Hood Canal summer run ESU), coho salmon (Puget Sound/Strait of Georgia ESU), pink salmon (odd year DPS), and steelhead trout (Puget Sound DPS) are the specific sub- populations of the species aforementioned occurring in the coastal waters of the Strait of Juan de Fuca and in the project action area. Chinook salmon (Puget Sound ESU), chum salmon (Hood Canal summer run ESU), and steelhead trout (Puget Sound DPS) are Federally-listed as threatened populations, as well as bull trout. Coho salmon (Puget Sound/Strait of Georgia ESU) is a Federally-recognized species of concern.

Salmonid species typically live from 3 to 6 years (NOAA 2014d, 2014e), except for steelhead trout, which can live up to 11 years (NOAA 2014f). During their anadromous life cycles, they spend between a few months and up to 2 years in freshwater, and 2 to 4 years in the Pacific Ocean (NOAA 2014g). Bull trout, chinook salmon, and coho salmon can grow to more than 3 feet and 30 pounds, but mature sizes usually reach only half of these values (NOAA 2014h). Salmon adults spawn in river and stream systems where larvae and juveniles live for some time, over a year in the case of coho salmon, before migrating out to the ocean (NOAA 2014g). Prey availability and secure habitats to hide from predatory birds and fish are critical during the larval and juvenile stage. Prior to leaving freshwater habitats, some species, such as the chinook salmon, will undergo coloration changes. Coloration will change from dark vertical bars and spots to a light underbelly and dark dorsal side. This coloration change provides beneficial camouflage at different life stages (NOAA 2014g). Larval and juvenile salmonids typically prey on plankton and insects, while occasionally consuming small crustaceans and fish. As adults at sea, salmon feed on larger amphipods, crustaceans, and fish species. Adults lay eggs after returning to their homing ("natal") river. The eggs hatch within 2 to 5 months after fertilization, and adults guard nests for a short time afterwards, as salmon are often semelparous2, dying within a few days to a month after spawning.

3.2.1.2 Distribution and Habitat Use

The distributions of Pacific salmonids cover a wide range of the northeast Pacific, from northern California through Alaskan waters. Some salmonid species also have DPSs and ESUs associated with the Puget Sound region adjacent to the Strait of Juan de Fuca, such as chinook salmon (Puget Sound ESU), chum salmon (Hood Canal summer run ESU), coho salmon (Puget Sound/Strait of Georgia ESU), and steelhead trout (Puget Sound DPS).

Ocean migrations of juvenile salmonids vary in length both within and across species, with some stocks remaining in coastal waters near their natal freshwater river systems while others migrate over a thousand miles. Both juveniles and adults require cool temperatures for survival (USWFS 2015c). Pacific salmon migrations back to their natal freshwater grounds, termed “runs”, are driven by local temperature and water flow regimes and occur over all seasons, likely reflecting salmon groups of

2 A species is considered semelparous if it is characterized by a single reproductive episode before death.

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varying maturation stages. Nest site selection of females returning to rivers to spawn is influenced by gravel size, water flow near nests (or “redds”), temperature, and water quality (NOAA 2013b).

The Washington Department of Fish and Wildlife Priority Habitats and Species database reports priority fish presence in several streams along the Clallam County coast east of Port Angeles that discharge into the Strait of Juan de Fuca (WDFW 2016b). Moving east from Port Angeles harbor, the coastal streams include: Peabody Creek, Ennis Creek, Lees Creek, Morse Creek, Bagley Creek, and Siebert Creek. Table 4 lists the species known to occur in these creeks or use them for migration or breeding (WDFW 2015b). The creek nearest the proposed fish pen relocation site is Siebert Creek, approximately 1.7 miles away.

Table 4. Salmonid species found in the creeks along the coast in the vicinity of the project action area.

Creek Name Salmonid Species and Priority Habitat Use Peabody Creek cutthroat – occurrence/migration coho salmon – occurrence/migration Ennis Creek steelhead – occurrence/migration/breeding area cutthroat – occurrence/migration chum salmon - occurrence/migration/breeding area coho salmon – occurrence/migration/breeding area chinook salmon –occurrence/migration dolly varden - occurrence/migration bull trout - occurrence/migration Lees Creek steelhead – occurrence/migration/breeding area cutthroat – occurrence/migration chum salmon - occurrence/migration coho salmon – occurrence/migration/breeding area dolly varden - occurrence/migration bull trout - occurrence/migration Morse Creek steelhead – occurrence/migration/breeding area cutthroat – occurrence/migration chum salmon - occurrence/migration/breeding area coho salmon – occurrence/migration/breeding area pink salmon – occurrence/migration/breeding area chinook salmon - occurrence/migration/breeding dolly varden - occurrence/migration bull trout - occurrence/migration Bagley Creek steelhead – occurrence/migration/breeding area cutthroat – occurrence/migration chum salmon– occurrence/migration coho salmon – occurrence/migration/breeding area pink salmon – occurrence/migration/breeding area Siebert Creek steelhead – occurrence cutthroat – occurrence chum salmon – occurrence coho salmon - occurrence

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Critical habitat for the threatened chinook salmon (Puget Sound ESU) has been designated in the project action area (NMFS 2005). Critical habitat is defined as the water and substrate in the nearshore marine areas of the Strait of Georgia, Puget Sound, Hood Canal, and the Strait of Juan de Fuca from the extreme high tide line out to a depth of 98 feet (NMFS 2005). Chinook salmon (Puget Sound ESU) critical habitat occurs in Port Angeles Harbor, along Ediz Hook and extends east along the coastline (out to a depth of 98 feet) overlapping the project action area. Along the shoreline, Ennis Creek is a known migratory pathway for chinook salmon (Puget Sound ESU), while Morse Creek is utilized for spawning and rearing by this sub-population (NMFS 2005).

Critical habitat is designated for the threatened bull trout along the Clallam County coastline, but does not overlap the project action area. The shallow marine habitat close to shore is where bull trout are known to occur (USFWS 2010b).

3.2.1.3 Threats and Occurrence within the Project Action Area

Freshwater systems are essential for salmon spawning, rearing, and growth during larval and juvenile stages. Thus, anthropogenic impacts to freshwater systems, such as water conveyance and divergence, obstruction, logging, road construction, urban development, and agriculture pose the greatest threat to salmon species (NOAA 2014i). Fisheries impacts and changes in predator and prey populations also influence salmonid populations. Because most salmonids are dependent on both inland, coastal, and offshore environments, at various stages of their life cycle, their populations are particularly susceptible to stock decline. Therefore many species, and ESUs and DPSs, have priority conservation status, critical habitat designations, and/or are currently listed as threatened or are of special concern.

Many of the salmonid species known to occur in the project action area are most likely utilizing these waters for migration purposes. Species may be passing through the area on migration routes to reach and enter natal streams for breeding purposes. In particular Morse Creek provides critical breeding habitat for pink salmon odd year, coho salmon (Puget Sound/Strait of Georgia ESU), and fall chinook salmon (Puget Sound ESU). Other threatened species such as the chum salmon (Hood Canal summer run ESU) may utilize this region of the Strait of Juan de Fuca as a migratory pathway on their journey inland to Puget Sound. 3.2.2 Rockfish Species

3.2.2.1 Status and Description

Several rockfish species reside in northwest Washington State waters. Of these species, the canary rockfish and yelloweye rockfish are Federally-listed as threatened, and the bocaccio rockfish is listed as endangered. The Washington Department of Fish and Wildlife currently identifies all three species as candidates for listing. This status refers to species that are to be reviewed by the State for possible listing as endangered, threatened, or sensitive.

Bocaccio rockfish grow to a maximum size and weight of 3 ft (1 m) and 15 lbs (7 kg), respectively, and can live up to 50 years (Andrews et al. 2005). Younger fish are light bronze with speckling over the body, while adult coloration varies between pink-brown, grey, and red (WDFW 2015d). The spines of bocaccio

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rockfish can be mildly poisonous, as with most rockfish. These rockfish feed primarily on fish species, including other rockfish (Eschmeyer et al. 1983). The species is ovoviviparous3, with internal fertilization and live birthing. Once abundant in the region, the bocaccio rockfish is now very rare.

Canary rockfish grow to 3 ft, and have been reported to live for at least 84 years (Cailliet et al. 2001). Adults are yellow and orange, with gray mottling over various portions of the body and orange stripes along the head (WDFW 2015e). These rockfish are viviparous4, birthing live larvae (Moser 1996). Adults will eat small fish and krill species (Eschmeyer et al. 1983).

Yelloweye rockfish are one of the largest rockfish species, reaching maximum weights and lengths of 25 lb (11 kg) and 3 ft (0.9 m). They are distinguishable from other rockfish species due to their orange-red bodies and yellow eyes (WDFW 2015f). This species has been found to live up to 118 years, and is more solitary than the others, living in rocky areas with crevices and caves. Yelloweye rockfish feed on various fish and crustacean species (Armstrong 1996), and like the canary rockfish, are viviparous.

3.2.2.2 Distribution and Habitat Use

Bocaccio rockfish can be found from the Atepovak Bay, Alaska Peninsula region down through Baja California. Traditionally, this species is located on steep walls in portions of Puget Sound at depths of 39 to 1,568 ft (12 to 478 m), and is most abundant from 160 to 800 ft (NOAA 2014j, Kramer and O’Connell 1995). Larvae are planktonic at release and can drift in open water for several months. Juveniles spend time in the pelagic environment and in shallower waters before settling in demersal5 nursery areas. After settlement and with age, the fish move to deeper waters (Moser 1996). Adults are found by both rocky reefs and open bottoms (Eschmeyer et al. 1983).

Similar to the bocaccio rockfish, canary rockfish also range from the Gulf of Alaska to Baja California. Younger fish are found in shallower waters than adults (Lamb and Edgell 1986), with adults typically inhabiting waters of 260 to 650 ft (80 to 200 m). Canary rockfish are associated with rocky areas and high relief rocks in areas with higher currents, but can also inhabit open mud flats. They can also be found near other structured habitat, both natural and artificial (e.g., piers, oil platforms).

Yelloweye rockfish range from Prince William Sound and Unmak Island in Alaska, to Mexican waters. In Puget Sound, adults are typically found in 290 to 590 ft (90 to 180 m) waters with juveniles in shallower waters (WDFW 2015f); however, they are currently very rare in the region.

In November 2014, critical habitat was declared for yelloweye, bocaccio, and canary rockfish in the Puget Sound / Georgia Basin region (NOAA, 2014k), east of the proposed marine net pen relocation site in the Strait of Juan de Fuca. The critical habitat area covers approximately 377,824 acres (1,529 km2 or 446 nm2) of nearshore habitat and 265,020 acres (1,073 km2 or 313 nm2) of deep water habitat to protect the three rockfish species.

3 Oivipary is a mode of reproduction in which embryos develop inside eggs within the mother’s body until they are ready to hatch in a live birth. There is no placental connection to the mother; instead, the embryos feed off yolk sacs. 4 Viviparity is a mode of reproduction in which embryos develop within and derive nourishment from the mother’s body. 5 Demersal habitats are those found near or on the seafloor.

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3.2.2.3 Threats and Occurrence within the Project Action Area

Threats to rockfish species include their low recovery ability due to slow growth rates and low productivity. The water depth in the project action area is fairly shallow compared to the habitat preferred by rock fish, with sand and gravel benthic habitats compared to the rocky terrain preferred by rockfish species. Distribution maps indicate that rockfish species are primarily located in Puget Sound and do not extend quite as far west as Port Angeles Harbor (NOAA 2015f). This range coupled with low population abundance suggests that occurrence of rockfish in the project action area is rare. 3.2.3 Eulachon

3.2.3.1 Status and Description

Eulachon (also known as Columbia River smelt or hooligan) are Federally-listed as threatened. They are State-listed as a candidate species for further status designation at a later time. Eulachon are a small anadromous fish, typically weighing 2.4 oz (0.07 kg) with a length of 8.5 in (0.22 m; NOAA 2014k). The species has contrasting colors over the body, with blue and brown dorsal patterning, silver sides, and a white belly. The maximum reported age for the species is 5 years, spending 3 to 5 years at sea before returning to rivers for spawning (Hugg 1996, NOAA 2014k). Most eulachon are semelparous6, dying soon after spawning. Eggs hatch in 20 to 40 days, and larvae are transported downstream for dispersion in estuary and ocean bottom waters (NOAA 2011c; NOAA 2014k). Larvae feed on phytoplankton, copepod eggs, mysid shrimp, barnacle larvae, and worm larvae (NOAA 2011c). They also feed on large zooplankton, krill, and small crustaceans. Adults will not feed while they are spawning (Hart and McHugh 1944).

3.2.3.2 Distribution and Habitat Use

Eulachon live in nearshore waters over the continental shelf (up to a maximum depth of 980 ft (300 m) but often shallower), except for when the species returns to its natal river to spawn (NOAA 2014k). Spawning area temperatures range from 39 to 50°F and occur over sand or coarse gravel substrates. The species is anadromous but spends 95 to 98% of its life at sea (NOAA 2011c). Eulachon occur along the eastern Pacific Ocean, extending from northern California to the southeast Bering Sea (Gustafson et al. 2010). In US waters, most eulachon originate from the Columbia River basin and its tributaries (NOAA 2011c); however, there are several areas with regular and irregular runs from California through Washington. Eulachon have been occasionally reported in coastal Washington rivers. The Elwha River is considered an irregular run location (Gustafson et al. 2010).

3.2.3.3 Threats and Occurrence within the Project Action Area

The greatest threat to eulachon is reduction in suitable habitat availability, particularly in the Columbia River basin (NOAA 2014k). The major threats to eulachon habitat include damn construction, which prevents spawning runs and degrades demersal spawning habitat, and dredging, which exposes the

6 A species is considered semelparous if it is characterized by a single reproductive episode before death.

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water column to sediment particulates. Global climate change is likely to pose a threat to eulachon, with increasing water temperatures making presently-occupied spawning grounds and rivers unsuitable habitat. While fishing pressure has been reduced, bycatch and specific fishing methods may still pose a threat to eulachon. 3.2.4 Green Sturgeon

3.2.4.1 Status and Description

Green sturgeon is an anadromous fish with olive green dorsal coloring and yellowish green-white coloring underside. Sturgeon skin is covered with body plates (called “scutes”) that run along the sides and back. They are more marine-oriented than salmonids or any other sturgeon species (Adams et al. 2002), and live primarily at sea or in estuaries, except when spawning. Unlike salmon, they can spawn several times within their lifetime and will return to natal rivers every 2 to 5 years to do so (Moyle 2002). They are a long-lived, slow-growing species, reaching maturity around age 15, with a reported maximum rage between 60 and 70 years old. Prey items include shrimp, mollusks, amphipods, and small fish. The only known spawning locations are the Klamath, Rogue, and Sacramento Rivers along the US west coast. Within rivers, adults will spawn in cool waters with deep, turbulent flow and hard clean substrate (Moyle et al. 1992). While green sturgeons do not have a priority species status in Washington State, they are Federally-listed as threatened.

3.2.4.2 Distribution and Habitat Use

Green sturgeon range from nearshore Mexico waters north to the Bering Sea, with the majority of green sturgeon occurring in US waters located from Monterey, California north to Puget Sound. The species is separated into two distinct population segments. The northern distinct population segment (nDPS) includes sturgeon that spawn from the Klamath River in Northern California through the Rogue River in Oregon (NOAA 2015l). This nPDS has been listed by NOAA as a species of concern. The southern distinct population segment (sDPS) consists of sturgeon that spawn in the Sacramento River. These are Federally-listed as threatened (NOAA 2015l). Green sturgeon use both marine and freshwater habitats throughout their life cycle and are believed to migrate long distances after leaving estuarine waters.

3.2.4.3 Threats and Occurrence within the Project Action Area

Some of the greatest threats to green sturgeon are impediments to migration up or down rivers, and larval survival in river systems. Some of these threats include low freshwater flow from dams, contaminants introduced to river waters, poor water quality, entrainment from water projects, and impassable barriers. Bycatch and fishing mortality are other sources of concern, as historical overfishing of a small population has contributed to their low population numbers today. With changes in climate, increased water temperatures and introduction of invasive exotic species to natal grounds could also be detrimental. Reduction in spawning area within the Sacramento River has been a great concern for the sDPS stock.

The northern range of green sturgeon critical habitat includes the southern portion of the Strait of Juan de Fuca and coastal Port Angeles waters. While the Puget Sound region is not a spawning area for green

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sturgeon, the species spends significant time in coastal regions of Washington and open ocean waters (NOAA 2014l). Thus, the project action area may be located in an important region for green sturgeon feeding and migration. 3.2.5 Pacific Cod

3.2.5.1 Status and Description

Pacific cod are Federally-listed as a species of concern, and State-listed as a candidate species. An Endangered Species Act status review for Pacific cod (Gustafson et al. 2000, NOAA 2011d) stated that the population structure for this species included a distinct population segment (DPS) along the West Coast of North America including Puget Sound and coastal British Columbia north to at least Dixon Entrance.

Pacific cod are brown or gray fish with brown spots are their back and sides. The average size of adults is approximately 20 to 25 inches (50 to 60 cm), and they reach a maximum size of approximately 45 inches (114 cm) (Gustafson et al. 2000, Love 1996). Pacific cod are a commercially important fish species in some parts of their size range (NOAA 2011d). They feed on krill, shrimp, sand lance and crabs and are prey for seals, halibut and other fishes (Love 1996, NOAA 2011d).

3.2.5.2 Distribution and Habitat Use

The Salish Sea population of Pacific cod is found in Puget Sound, the Strait of Juan de Fuca, and the Strait of Georgia in the northwestern US and southeastern Canada (NOAA 2011d).

Pacific cod are schooling fish that live near the ocean bottom (NOAA 2011d). In the Salish Sea, they can be found over sand and mixed coarse bottom substrates (Palsson 1990, NOAA 2011d). Adult Pacific cod occur as deep as 2,870 ft (875 m), but the vast majority occurs between 160 and 980 ft (50 to 300 m) (WDWF and NMFS 2005).

3.2.5.3 Threats and Occurrence within the Project Action Area

The primary threats for Pacific cod within the project action area, and within the Salish Sea as a whole, include small population size due to past overfishing (NOAA 2011b). While they were once an abundant species important in the sport and commercial fisheries in the Salish Sea, they became overfished in the early 1990s and the population has still not rebounded (Palsson 1990, NOAA 2011d). Other treats to this population of Pacific cod include global climate change and predation (Gustafson et al. 2000, Beamish 2008, NOAA 2011d). 3.2.6 Pacific Hake

3.2.6.1 Status and Description

Pacific hake are Federally-listed as a species of concern, and State-listed as a candidate species. They are a groundfish of the order Gadiformes that with a silvery back grading to a white color on the ventral site.

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They can reach up to 36 inches (91 cm) in length and 15 years of age (NOAA 2009). Pacific hake larvae prey on calanoid7 copepod eggs, nauplii8, and adults (McFarlane and Beamish 1986, Sumida and Moser 1984, Gustafson et al. 2000). Juveniles and small adults mostly prey on euphausiids9 (NOAA 1990, Gustafson et al. 2000). Large adults also eat amphipods, squid, Pacific herring, smelt, crabs, shrimp, and sometimes juvenile Pacific hake (Dark and Wilkins 1994, McFarlane and Beamish 1986, NOAA 1990, Gustafson et al. 2000).

3.2.6.2 Distribution and Habitat Use

There are three recognized stocks of Pacific hake, one of which is the Georgia Basin DPS, which include both the Puget Sound and Strait of Georgia stocks (NOAA 2009). They are found near the bottom or in the water column to depths of 3,000 ft (914 m); however, they are most common in water shallower than 750 ft (229 m) (WDWF 2016c). There are several spawning locations for Pacific hake found in Puget Sound (Gustafson et al. 2000).

3.2.6.3 Threats and Occurrence within the Project Action Area

One of the major factors for the decline of Pacific hake within the Puget Sound area is overfishing (NOAA 2009). Other threats for this species include pinniped predation, habitat alteration or loss, and environmental changes (Gustafson et al. 2000). Though the potential effects of habitat loss or degradation are unknown, it has been speculated that juvenile hake survival could be reduced through loss or degradation of nearshore nursery habitats (West 1997, Gustafson et al. 2000). 3.2.7 Pacific Herring

3.2.7.1 Status and Description

Pacific herring are not Federally listed, but are State-listed as a candidate species. They use countershading for protection from predators by being dark blue to olive on their backs shading to silver on their sides and belly, making them hard to see from above and below. They can reach 18 inches (46 cm) in length, weigh up to 1.2 pounds (550 g), and can live up to 19 years (NOAA 2015m).

3.2.7.2 Distribution and Habitat Use

Pacific herring is a coastal schooling species that is found in large schools in depths from the surface to 1,300 ft (400m) (NOAA 2015m). Adult Pacific herring migrate inshore, entering estuaries to breed once per year, with timing varying by latitude. The herring spawn in shallow areas along shorelines, between the subtidal and intertidal zones. Eggs are deposited on kelp, eelgrass (Zostera marina), and other available structures (NOAA 2015m). Documented spawning grounds nearest to the project action area are in Dungeness Bay and Sequim Bay to the east (WDFW 2014).

7 Calanoid copepods are a kind of zooplankton in the order Calanoida. 8 Nauplii are the first larval stage of many crustaceans, with an unsegmented body and a single eye. 9 Euphausiids are a type of small, shrimp-like crustaceans (e.g., krill).

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3.2.7.3 Threats and Occurrence within the Project Action Area

Threats for Pacific herring include destruction of herring spawning grounds, juvenile and feeding habitat and rearing/foraging habitat. None of these habitat requirements occur directly within the project action area. Global climate change, recovering populations of predators and fishing exploitation of Pacific herring in Southeast Alaska are also threats to Pacific herring (NOAA 2015m). 3.2.8 Walleye Pollock

3.2.8.1 Status and Description

Walleye pollock are not Federally listed, but are State-listed as a candidate species. Walleye pollock adults are generally a semi-demersal species. Quinnell and Schmidtt (1991) found that the mean length of walleye pollock collected in North Puget Sound was approximately 5.5 inches (14 cm), suggesting they were largely young-of-the-year (Gustafson et al. 2000). Walleye pollock collected in South Puget Sound had a mean length of 6.3 inches (16 cm), which suggests the presence of a spawning population in or near South Puget Sound (Gustafson et al. 2000). Early-stage walleye pollock feed on copepod nauplii (Nakatani 1988, Canino et al. 1991, Gustafson et al. 2000), and juveniles mostly feed on euphausiids, copepods, decapod10 larvae, and larvaceans11 (Grover 1990, Merati and Brodeur 1996, Brodeur 1998, Bailey et al. 1999, Gustafson et al. 2000). Predators of walleye pollock eggs and larvae include a variety of invertebrates and fish. Juvenile walleye pollock are preyed upon by seabirds (e.g., common murre) and marine mammals (e.g., harbor seals; Bailey et al. 1999, Hunt et al. 1996, Lowry et al. 1996, Gustafson et al. 2000).

3.2.8.2 Distribution and Habitat Use

Various life stages of walleye pollock inhabit nearshore areas, large estuaries (including Puget Sound), coastal embayments and open ocean basins (Gustafson et al. 2000). Adults occur as deep as 1,160 ft (366 m), but the vast majority occurs in depths between 330 and 980 ft (100 to 300 m; Gustafson et al. 2000). Juvenile pollock have been found in a variety of habitat types, including eelgrass (over sand and mud), gravel and cobble; however, because of their pelagic mode, they are not thought to consistently associate with many types of substrates (Gustafson et al. 2000). The nearest known spawning ground to the project action area is to the east in Port Townsend, Jefferson County (Gustafson et al. 2000).

3.2.8.3 Threats and Occurrence within the Project Action Area

The threats for walleye pollock are similar to those for Pacific cod and include destruction of herring spawning grounds, juvenile and feeding habitat, and rearing/foraging habitat, which do not directly occur within the project action area. Global climate change, recovering populations of predators, and fishing exploitation are additional identified threats.

10 Decapods are an order of crustaceans including many familiar groups, such as crayfish, crabs, lobsters, prawns and shrimp. 11 Larvaceans are solitary, free-swimming tunicates (transparent marine invertebrates) found throughout the world's oceans.

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3.3 Marine Invertebrates 3.3.1 Geoduck

3.3.1.1 Status and Description

Geoduck are not a Federally-listed or State-listed species; however, their occurrence is mapped in the Washington Department of Fish and Wildlife Priority Habitats and Species database in an area 1,000 ft south of the Port Angeles-East marine net pen anchor footprint. Thus, geoduck are addressed in this evaluation.

Geoduck are a long-lived, large burrowing clam. They are synchronous broadcast spawners, and fertility is reportedly as high as 10 million eggs per year per spawner. They are known to be “trickle spawners,” releasing gametes over a season extending from early spring to early autumn. When eggs are fertilized, they transform into planktonic larvae, drifting for approximately 3 to 5 weeks before settling into the benthic habitat (WDFW 2016). At a shell length of less than 0.6 to 0.7 in (1.5 to 2.0 mm), the siphons are well developed and the juvenile clams burrow into the substrate, leaving only the tips of the siphons exposed. Upon reaching adult size, geoducks become poor diggers and transition to a completely sedentary lifestyle (Goodwin and Pease 1989). They are sedentary suspension feeders.

3.3.1.2 Distribution and Habitat

Geoduck are found at shallow lower intertidal and subtidal depths of more than 360 ft (110 m) in soft substrates, including mud, mud/sand, and sand (Goodwin and Pease 1989, WDFW 2016b). They are abundant in Puget Sound and British Columbia, and have supported subsistence and commercial fisheries for decades.

3.3.1.3 Threats and Occurrence in the Project Area

As sedentary suspension feeders, one of the largest threats to geoduck is the risk of water column pollution and benthic habitat disturbance (Goodwin and Pease 1989). 3.4 Birds 3.4.1 Bald Eagle

3.4.1.1 Status and Description

Bald eagles are State-Listed as a “sensitive” species (WDFW 2012b), vulnerable or declining and likely to become endangered or threatened throughout a significant portion of their range within the State without cooperative management or removal of threats. The US Fish and Wildlife Service removed the bald eagle from the ESA threatened species list in 2007, but it remains a species of concern under the protection of the Bald and Golden Eagle Protection Act and the Migratory Bird Act, which prohibit the killing, selling, or otherwise harming of eagles, their nests, and their eggs (USFWS 2011a).

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Bald eagles acquire their characteristic white head and white tail feathers when they are 4 or 5 years old. Females may weigh 14 lbs (6.4 kg) and have a wingspan of 8 ft (2.4 m), whereas males may weigh 10 lbs (4.5 kg) and have a wingspan of 6 ft (USFWS 2007). Eagles mate for life, and typically building their nests in the tops of large trees. They typically lay one to three eggs per year and live 15 to 25 years in the wild.

3.4.1.2 Distribution and Habitat Use

Bald eagles live throughout northern Mexico, the US and Canada. As fish are their main food source, their habitat includes estuaries, large lakes, reservoirs, rivers, and some seacoasts. In western and northeastern Washington, they nest primarily along marine shorelines and major rivers (WDFW 2005a). There are 700 resident pairs in Washington, but up to 4,000 birds migrate south to the State in winter to feed on salmon returning to spawn in area rivers.

3.4.1.3 Threats and Occurrence within the Project Action Area

The bald eagle population has made a dramatic recovery in Washington (and the US) in recent decades after its listing under the Endangered Species Act in 1978 and the banning of the pesticide DDT (WDFW 2012b). From 1981 to 2005, the nesting population in the State increased 707%. Nonetheless, bald eagles are affected by shoreline development, clearcutting, chemical pollution, loss of prey, and illegal killing. The WDFW Priority Habitats and Species database search for Section 5, Township 30, Range 5 West maps five bald eagle nests near the shoreline between Lees Creek and Morse Creek, recorded in 2005 and 2007 (WDFW 2016b). The WDFW Priority Habitats and Species mapper identifies two bald eagle nests in the Green Point area, also observed in 2005 (WDFW 2015b). 3.4.2 Common Loon

3.4.2.1 Status and Description

The common loon is State-listed as a “sensitive” species (WDFW 2012c), vulnerable or declining and likely to become endangered or threatened throughout a significant portion of their range within the state without cooperative management or removal of threats. Loons are a rare breeding species in Washington and require special management to breed in proximity to humans. The common loon is not Federally-listed.

The common loon is a large bird with a 4 ft wingspan, and weighs 8 to 19 lbs (3.6 to 8.6 kg) (WDFW 2012c). Their black and white breeding plumage gives way in winter to a duller gray. Their iconic vocalizations include hoots, wails, yodels, and tremolo calls. Loons feed mainly on fish, and due to their large size and diving adaptations, loons cannot walk on land. To take flight, they must run across the water (Tischler 2011). Common loons are serially monogamous and exhibit high fidelity to breeding territories.

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3.4.2.2 Distribution and Habitat Use

Common loons breed throughout northern North America, Greenland, and Iceland, and winter along both the Atlantic and Pacific coasts of the continent. The global population of loons is estimated to be more than 600,000 individuals, the vast majority of which breed in Canada (Tischler 2011) due to the availability of isolated lake habitats. Post-breeding loons that migrate to Washington probably do so in late August and remain through November (WDFW 2012c). In Washington, loons inhabit lowland lakes, reservoirs, and nearshore marine waters. In autumn, most loons move to coastal marine locations, where they remain through the winter. Only a small number of loons actually breed within Washington (13 confirmed nests in 2012), although historic numbers may have been higher.

3.4.2.3 Threats and Occurrence within the Project Action Area

Puget Sound and the Strait of Juan de Fuca host 3,000 to 4,000 wintering loons (WDFW 2012c). According to the WDFW Priority Habitats and Species mapper (WDFW 2015b), the project action area hosts a regular concentration of loons on Ennis Creek at the eastern side of Port Angeles Harbor.

Lead poisoning is a lead cause of common loon death in Washington (WDFW 2012c). Shoreline development (e.g., homes, roads, powerlines) and drastic changes in reservoir water levels have eliminated some loon nesting habitat (Richardson et al. 2000). Predation and oil spills constitute additional threats. 3.4.3 Diving Birds

Several diving bird species use Washington State waters. Species that may occur within the project action area include: brown pelican, tufted puffin, and Brandt’s cormorant.

3.4.3.1 Status and Description

The brown pelican and tufted puffin are State-listed as endangered, and Brandt’s cormorant is a State candidate for listing. The brown pelican is also Federally-listed as a species of concern.

Brown pelicans are a dark-plumaged pelican found in marine habitats. These birds are known for their plunge dives to capture fish and their roosting habit to dry their feathers. In addition to diving for their prey, they will seize prey while on the water surface, particularly in shallow water. They feed primarily on schooling marine forage fish, such as Pacific mackerel, Pacific sardines and Northern anchovies (USFWS 2009, Stinson 2014).

Tufted puffin measure 14 to 16 inches (35 to 40 cm) in length and weigh on average 1.7 lb (775 g). They are among the largest of the alcids12 (Piatt and Kitaysky 2002, Hanson and Wiles 2015). While they have rapid wing strokes and a lack of maneuverability in the air, they move gracefully while diving through the water. Their diet consists of a wide range of prey. Wintering and breeding birds foraging over deep

12 An alcid is a bird species within the Alcidae family.

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oceanic habitats exhibit a broad diet made up mostly of invertebrates, especially euphausiids (i.e., krill, shrimp-like crustaceans). Breeders foraging near coastlines and over the continental shelf feed more on fish (Piatt and Kitaysky 2002, Hanson and Wiles 2015).

Brandt’s cormorant is a large diving bird with a long slender neck. This species has a shorter tail than any of the other cormorants found in Washington. They fly in long lines, low over the water surface. They roost together and feed in offshore flocks, often mixed with other seabirds and sometimes even foraging together with sea lions. They catch most of their food underwater by diving up to 150 ft (46m). The diet of the Brandt’s cormorant consists of a wide variety of fish with some shrimp and crabs. They forage at all depths within the water column, with most foraging occurring near the bottom (Seattle Audubon Society 2015a).

3.4.3.2 Distribution and Habitat Use

Brown pelicans occur primarily on the shores and waters of Washington’s outer coast from the Columbia River, north to Cape Flattery. Small numbers occur in the Strait of Juan de Fuca and Puget Sound from April through November (Stinson 2014). Brown pelicans forage in shallow (< 490 ft [150 m] deep) waters, typically within 12.5 miles (20 km) of shore in areas of upwelling that are rich in prey (Briggs et al. 1983, Shields 2002, Stinson 2014). They nest on the ground, on cliffs or in low trees. Important habitat for brown pelican includes communal roosting and loafing sites, such as piers, breakwaters and jetties on islands and offshore rocks and on beaches at the mouths of estuaries (Shields 2002, Jacques and Strong 2003, Stinson 2014). They seasonally roost in large numbers in the Columbia River, Willapa Bay and Grays Harbor estuaries (Jaques and O’Casey 2006, Stinson 2014), and at many Olympic Peninsula sites off the coast (Stinson 2014).

Tufted puffins have breeding colonies mainly along the Washington outer coast from Point Grenville north to Cape Flattery (Hanson and Wiles 2015). Nesting colonies in Washington inland marine waters are now restricted to Protection Island and Smith Island in the eastern Strait of Juan de Fuca (located more than 15 miles east of the project site; Hanson and Wiles 2015). During breeding season, they can range as far as 62 miles (100 km) from their breeding colonies, utilizing open water foraging habitats from the nearshore to the open sea. No breeding colonies were ever detected in Puget Sound. During the winter months, tufted puffin migrate far offshore (Hanson and Wiles 2015).

Brandt’s cormorants are always found in salt or brackish water and inhabit rocky shorelines and open oceans. Their nesting colonies are typically on slopes rather than cliff ledges, although in Washington, some colonies are on steep cliffs. This species is common along rocky outer coast and coastal islands of Washington, from Cape Flattery to Oregon. They are rarely seen in Puget Sound or other inland waters during the breeding season, but are common, especially in the upper Puget Trough (which includes the Port Angeles area) and Strait of Juan de Fuca at other times of the year (Seattle Audubon Society 2015a).

3.4.3.3 Threats and Occurrence within the Project Action Area

Potential threats to the diving birds include prey availability, loss of habitat, disturbance of nesting and roosting sites, pesticides, oil spills, injury and entanglement by fishing gear and harmful algal blooms. Reductions in prey abundance and timing of prey availability are a concern for these diving bird species.

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The timing and abundance of these prey populations are often dependent on ocean temperature and climatic conditions (Hanson and Wiles 2015). 3.4.4 Marbled Murrelet

3.4.4.1 Status and Description

In 1992, the marbled murrelet was declared a threatened species in California, Oregon and Washington under the Endangered Species Act by the US Fish and Wildlife Service. Marbled murrelet are State-listed as threatened (Pearson et al. 2014). They are a small bird species of the northeast Pacific. The breeding plumage of males has a brown and white “marbling” appearance, hence the name. Their small size, dark coloration, and fast flight speed make the bird hard to track over land. The murrelet preys primarily on nearshore forage fish that constitute 60 to 70% of their diet (Nelson 1997). Major forage fish prey for murrelets include Pacific herring, northern anchovy, Pacific sand lance, and capelin. In the absence of fish, the murrelets will also feed on krill (WDFW 2012d). During nesting, the species is typically solitary or semi-colonial (WDW 1993).

3.4.4.2 Distribution and Habitat Use

In Washington, murrelets are found in nearshore marine areas (within 1.2 mi [2 km] of shoreline), with the greatest concentrations in northern Puget Sound (WDW 1993). Murrelets spend most of their lives in or near marine waters, except during nesting. Nests are located in large branches or other large platforms in conifer trees, but the species prefers mature, old-growth forests (Nelson et al. 2006, WDFW 2012f). Most murrelet observations are within 39 miles of the coast, with the farthest inland observation in Washington reaching 52 miles (WDW 1993). The first nesting site in North America was confirmed in 1987 (Leschner and Cummins 1992). Parent murrelets will travel between the nests sites and coastal marine forage areas to exchange incubation or chick-rearing duties.

In 2000, Federal researchers began estimating murrelet abundances as part of a monitoring program to provide data for informing management on the population trends of this species. Five marbled murrelet conservation zones are monitored as part of this initiative, covering coastal areas of Washington State (bordering British Colombia) down south to San Francisco Bay (WDFW 2016e). Over the five zones, the 2013 murrelet population was estimated to be 19,617 birds, with a slight decreasing trend in population size between 2001 and 2013 (WDFW 2016e). The population estimate for the Puget Sound and Strait of Juan de Fuca region (Zone 1) in 2013 was 4,395 birds, with a -3.88% annual average decrease in the population size during the 2001 to 2013 period (a greater decline than the overall population). The Zone 2 (Washington outer coast) 2013 estimate was 1,257 individuals with a -7.37% annual average population decline between 2001 and 2013 (Pearson et al. 2014).

3.4.4.3 Threats and Occurrence within the Project Action Area

The largest threat to the marbeled murrelet populations is deforestation and loss of old-growth forests used for nesting habitat. Fragmented forests are more vulnerable to excessive wind at the edges, which often leads to increased predation from jays, ravens and crows, making the loss of thickly settled forests unfavorable for the murrelets (WDW 1993). In 1993, old-growth forest in western Oregon and

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Washington had been reduced to 80% of pre-logging forest levels. Oil pollution has also posed a threat to the murrelet and their coastal environment, with the Seagate (1956), Arco Anchorage (1985), Nestucca (1988) and Tenyu Maru (1991) oil spills resulting in oiled murrelets (WDW 1993). Murrelet entanglement and mortalities in gill nets and hook-and-line fisheries have been observed but not quantified. Irrespective of the risk, the low reproductive rate of the murrelet species limits the ability of the population to recover after an episodic or chronic threat. 3.4.5 Waterfowl

Several waterfowl species reside in northwest Washington state waters. Of these, western grebe, Clark’s grebe, and common murre are State-listed as candidate species, likely to meet criteria for State-listing as endangered, threatened, or sensitive upon further review.

3.4.5.1 Status and Description

Western and Clark’s grebes are closely-related, fish-eating aquatic birds that once were considered different color phases of the same species, and which do occasionally interbreed and are often found in mixed flocks (Konter 2011, WDFW 2012e). These species winter in large flocks and nest in colonies (Seattle Audubon Society 2015b). Western and Clark’s grebes feed on a wide variety of fish, and will also prey on salamanders, crustaceans, worms and insects (WDFW 2012e). Both grebes are candidates for State listing.

Common murres are a less chunky large alcid with a short neck and long, straight bill (Seattle Audubon Society 2015c). They are almost always found in the water. On land, they sit upright. They can swim and dive well, and have been observed diving to more than 150 feet below the water’s surface (Seattle Audubon Society 2015c). Their diet includes small fish and a wide variety of invertebrates including crustaceans, marine worms and squid (Seattle Audubon Society 2015c). The common murre is a candidate for State listing.

3.4.5.2 Distribution and Habitat Use

Western and Clark’s grebes are found on inland freshwater lakes and marshes in eastern Washington in the summer (WDFW 2012e). They build a floating nests made of emergent anchored to emergent vegetation in shallow areas of a marsh (WDFW 2012e, Seattle Audubon Society 2015b). During fall, Western and Clark’s grebes move to the Pacific coast (WDFW 2012e). In winter, western grebes are found in nearshore waters of Washington, while Clark’s grebes are largely further offshore (WDFW 2012e). Clark's grebes tend to forage farther from shore and in deeper water than western grebes (WDFW 2012e).

Common murres have extremely dense nesting colonies. They generally nest on wide, open ledges on rocky cliffs, though only few in Washington nest on cliffs (Seattle Audubon Society 2015c). They spend most of their time on the open ocean and in large bays. Their breeding colonies are found closer to rocky shorelines with their non-breeding colonies farther offshore (Seattle Audubon Society 2015c). Common murres nest at 18 recorded locations along the outer Washington coastline, and they can be seen in these areas year around. They are also found in deep-water and inland-marine habitats in the

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fall and winter. They are fairly common on inland waters at other times of the year (Seattle Audubon Society 2015c).

3.4.5.3 Threats and Occurrence within the Project Action Area

Potential threats to diving waterfowl include water level changes, and declining forage fish populations affecting wintering populations (WDFW 2012e). For the grebes, their nesting habitat is tied closely with reservoirs directly influenced by surrounding waters. Therefore, water level changes can contribute to egg loss and nest failure as anchored nests tip over and spill eggs (WDFW 2012e). 4 Effects of the Proposed Action 4.1 General Effects of Off-Coast Mariculture Activities

Aquaculture is a fisheries component that will become more important as standing stocks of wild fish continue to decline. As of 2009, more than 87% of global fish stocks were estimated to be either fully or over-exploited (FAO 2011). Globally, both freshwater and marine aquaculture have been increasing in recent decades, now comprising more than 50% of annual fisheries production (FAO 2011). An increase in the use of aquaculture to fulfill fishery needs allows wild stocks and natural habitats to recover from overfishing, but also raises questions for some stakeholders regarding the potential environmental impacts of aquaculture activities (Holmer 2010, Nash et al. 2005, Price and Morris 2013).

The proposed marine net pen relocation site east of Port Angeles Harbor straddles the definitions of off- coast and offshore fish farming (Table 5). While the site is located 1.5 miles offshore in 90 to 110 ft of water, the relatively strong tidal currents and wind-driven hydrology of the Strait of Juan de Fuca contribute to a physical setting similar to the offshore fish farming definition (Rensel et al. 2007). Thus, the proposed fish pen site will be considered an ‘off-coast’ fish farm for the purposes of this evaluation. The general environmental effects of off-coast fish farming are discussed in the following paragraphs, while potential impacts specific to habitats and species within the project action area are addressed in Section 4.2.

Table 5. Characteristics of different types of aquaculture, adapted from Holmer (2010).

Coastal fish farming Off-coast fish farming Offshore fish farming < 0.3 mi from shore 0.3 to 2 mi from shore > 2 mi from shore < 33 ft water depth 33 to 164 ft water depth > 164 ft water depth waves < 3 ft waves < 10 to 13 ft waves up to 16 ft local winds and currents localized winds and currents ocean winds and swell strong tidal currents weak tidal currents no tidal currents sheltered somewhat sheltered exposed

A physical and biological effect of fish farming is the release of dissolved and particulate nutrients due to additions of pellet food and fecal matter to the water column. Water quality is less of a concern at off-

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coast and offshore sites due to faster currents and higher dispersal rates of waste products; nevertheless, nutrient enrichment could cause phytoplankton blooms in areas where nutrients are limiting (Dalsgaard and Krause-Jensen 2006), or change the size distribution and community structure of phytoplankton in the area (McAndrew et al. 2007).

Kalantzi and Karakassis (2006) conducted a large review of papers dealing with the benthic effects of fish farming. The papers used for the review covered a wide range of farmed species, geographic regions, management practices and site-specific characteristics (e.g., depth, exposure and sediment type). Kalantzi and Karakassis (2006) concluded that benthic impacts vary between geographic locations since they are determined by a complex interaction of different factors such as bottom type, latitude, and sediment type. In general, further models coupling current measurements (Henderson et al. 2001, Cromey et al. 2002) and settling velocities of fish farming wastes could assist in a more accurate prediction of benthic effects from fish aquaculture. Sedimentation rates directly below fish cages will be lower in off-coast farms than in coastal farms due to larger dispersion rates of particulate matter, but off-coast sites could have a larger area of benthic impact due to the distance travelled by nutrients before settling out of the water column (Kutti et al. 2007). The tidal flushing rate is the key physical parameter affecting sedimentation rates, independent of location (i.e., coastal or off-coast sites).

Interactions between wild and cultured fish are a possibility in finfish mariculture. Artificial propagation of fish populations has been conducted for centuries, and thus the genetic risk associated with accidental releases of salmon (e.g., loss of fitness, loss of diversity within and among populations) has been characterized for several decades. The key determinant of these genetic risks is that they are proportional to the fraction of successful spawners in nature that were produced in captivity (Waples et al. 2012). In order for genetic effects to occur, three conditions would have to be met:

1) individuals reared in captivity must enter the marine environment; 2) some of these individuals must survive to sexual maturity, and 3) some of the mature adults must successfully reproduce involving some level of interbreeding with wild fish (Waples et al. 2012).

These conditions would be detrimental outcomes in fish aquaculture; therefore, measures are taken to avoid them. One such measure is the use of non-native Atlantic salmon stocks, which is proposed in the AGS Net Pen Relocation project, since there is little to no risk of genetic interface with native stocks of Pacific salmon from Atlantic salmon. Research and historic experience has shown that Atlantic salmon pose a low risk of competing with or diluting the Pacific salmon gene pool. Previous laboratory experiments attempting to hybridize Atlantic salmon with the Pacific salmon species were unsuccessful. Those attempts revealed that very few eggs survived to hatching after fertilization, and the few fish that did survive to hatch, died shortly afterwards. This may be explained by the fact that Atlantic salmon (classified under the genus Salmo) are genetically distant from the Pacific salmon species (classified under the genus Oncorhynchus). Past historic attempts were made to establish Atlantic salmon outside their native range (e.g., the Atlantic Ocean) for sport and commercial fisheries in Washington, Oregon, California and British Columbia. None of these efforts were successful (Nash 2001). Over the past 40 years, Atlantic salmon stocks used in commercial marine aquaculture farms have become increasingly domesticated to thrive in the man-made environment of a freshwater hatchery and marine net pen

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farm. As domestication advances, survival and reproductive success in the wild decreases. The domestication of the cultured stocks, coupled with the failed attempts to establish Atlantic salmon outside their native range indicate the species is a low risk for survival in the wild.

Appendix D provides additional information on the subject of accidental release and other commonly asked questions about marine net pen aquaculture, along with citations for widely-accepted scientific studies that have investigated these issues.

Socio-economic effects of mariculture could include competition with existing fisheries, interference with navigation lanes and fishing areas, and aesthetics for nearby shoreline property owners (Rensel et al. 2007). These effects are minimized in off-coast and offshore fish farming with sites further away from productive, intensely-used coastal areas. 4.2 Effects of the Proposed Action within the Project Action Area

Mariculture sites can be classified by water depth and current speed into different ranks. According to Borja (2002, cited in Riera et al. 2015), the proposed marine net pen relocation site falls within the ‘good’ category as its water depth is near the 98 ft threshold and mean current speeds at other sites in the Strait of Juan de Fuca are near 0.32 m/s (0.72 mph; Rensel et al. 2007), much higher than the 0.15 m/s (0.34 mph) required to be classified as ‘good’ for aquaculture. Effects of the project are described below in subsections based on distinctions between construction and operation phases. 4.2.1 Potential Construction Phase Impacts

4.2.1.1 Seafloor Disturbance

The mooring grid installation (Phase 1) will disturb benthic sediments in the immediate vicinity of each of up to 60 anchors that will penetrate the substrate and be tensioned into position. The installation process is estimated to take 1 to 2 hours per anchor; therefore, direct impacts will be relatively short- term. The design of the anchors and the tension on the mooring lines will maintain the lines in an upright position with no lateral movement, so prolonged disturbance and sediment resuspension impacts to the benthic environment around the anchors should be minimal (personal communication with Kevin Bright, Permit Coordinator, American Gold Seafoods, December 2015a). Sediment resuspension would be temporarily generated in small, isolated areas from anchoring and movement of construction vessels. It is expected that motile species would readily avoid areas that cause them discomfort or harm. However, the feeding ability of subtidal filter-feeding shellfish species could be temporarily affected by a potential increase in turbidity.

4.2.1.2 Noise

Potential impacts during the onshore construction phase (Phase 2) could be caused by in-air noise. However, Port Angeles Harbor is a highly developed port, with high levels of ambient noise; therefore, noise associated with cage construction or crane operation at the shipyard would be negligible. The project will involve vessel traffic during mooring grid construction (Phase 1) and net pen cage installation (Phase 3). Potential impacts from increased vessel traffic along the 5.5-mile route to the

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marine net pen relocation site include short-term increases to both in-air and in-water noise., These effects are expected to be a negligible in the context of ambient noise associated with the large amount of vessel activity that presently occurs within and on approaches to the busy harbor.

4.2.1.3 Potential for Accidental Hydrocarbon Spills

Increased vessel traffic during construction phases 1 and 3 could increase the chances of minor releases of hydrocarbons (e.g., fuel and lubricants). However, release from an accidental spill would likely be small. In addition, appropriate agency spill notifications, spill prevention plans, containment equipment and clean-up measures will be implemented onboard work vessels. For these reasons, the potential for water quality impacts due to hydrocarbon spills is expected to be low.

4.2.1.4 Marine Mammal Interactions

Increased vessel traffic during construction phases 1 and 3 could increase the chances of disturbing marine mammals in transit. Any potential adverse effects of vessel traffic should be mitigated by actions detailed in the AGS Port Angeles Wildlife Interaction Plan provided in BE Appendix A). These actions include avoiding marine mammals and slowing down or altering course to maintain a minimum distance of 400 yards from the travel direction of whales. In addition, acoustic harassment devices are not used by AGS at any of their marine net pen facilities. 4.2.2 Potential Operational Phase Impacts

4.2.2.1 Seafloor Disturbance

Since the anchors and taut mooring lines are designed to prevent lateral movement of the equipment, disturbance to the seafloor from the anchors will be negligible during the operational phase. In fact, the permanent presence of anchors may provide structure that encourages colonization by benthic fauna (Rensel and Forster 2007).

A common concern about marine net pen aquaculture is the potential for benthic impacts to occur due to nutrient loading in sediments caused by fish farm effluent, with a resultant increase total organic carbon (TOC) accumulation and reduction in oxygen availability (Pusceddu et al. 2007). If nutrients accumulate in the benthos and associated geochemical changes occur, changes to the micro and macrofauna that live on and in the sediments can occur (Price and Morris 2013). However, impacts to benthic organisms can be avoided by siting farms in deep, well-flushed areas over erosional seafloor (Price and Morris 2013). Operational practices implemented by American Gold Seafoods at their eight existing Puget Sound mariculture operations include carefully monitoring the application of fish feed to achieve less than 1% waste (personal communication with Kevin Bright, Permit Coordinator, American Gold Seafoods, December 2015a) so that particulate matter settling out of the water column onto the benthic environment should be minimal.

Nutrient loading within a 100 ft Sediment Impact Zone (SIZ) established around the net pen area will be monitored in accordance with a Clean Water Act Section 402 NPDES waste discharge permit to be issued by the Washington Department of Ecology to ensure that organic enrichment does not exceed

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standardized trigger levels for marine sediments in the area. In the event that an exceedance were to occur, corrective actions would be required and implemented in compliance with conditions of the permit. Also see the response to SEPA Checklist Question B.1.h.

4.2.2.2 Noise

The operational phase of the project will involve vessel trips between Port Angeles Harbor and the net pen relocation site. Two to four times per day, a crew vessel will transport employees and equipment to and from the marine net pen farm. Approximately once per week, a marine supply vessel will visit the floating net pen operation to deliver consumables and to remove wastes for disposal at existing, permitted land-based facilities. Diesel fuel deliveries to operate the generator will likely occur approximately once per month. This additional vessel traffic represents a negligible increase in existing vessel activity that occurs within the project action area.

4.2.2.3 Potential Accidental Hydrocarbon Spills

Minor releases of hydrocarbons during project operation could result in short-term, minor effects in the water column. Spills would likely be small; however, appropriate agency spill notifications, spill prevention plans, containment equipment and clean-up measures will be required at the facility. The diesel engine that will operate in the feed support barge and an electrical generator will be a new piece of machinery, constructed to meet all current US EPA emission standards, and equipped with accidental spill containment measures. The double-walled tank will have a capacity of approximately 3,000 gallons. Other hazardous materials that would be kept on the feed barge include small quantities of motor oil and antifreeze for operation of the diesel engine. Quantities of these products will be kept at a minimum.

4.2.2.4 Water Quality

High current speeds and tidal flushing at the net pen relocation site indicate that water column impacts are likely to be minimal and that dissolved oxygen levels should be favorable (Rensel and Forster 2002). With the site located 1.5 miles off the coast, the strong currents paralleling the shore will naturally replenish the oxygen levels of the fish. Low numbers of harmful phytoplankton species exist in the area and are not nutrient-limited, due to high ambient levels of nitrogen in the waters of the Strait of Juan de Fuca, so harmful blooms are not expected from any nutrient enrichment that might occur (Rensel and Forster 2002).

4.2.2.5 Marine Mammal Interactions

As during the construction phases, increased vessel traffic during operation could increase the chances of disturbing marine mammals in transit; however, there are mitigation measures in place to reduce adverse effects (see Section 4.2.1.4 above and BE Appendix A).

Seals and sea lions can be attracted to the fish pens and might interact with the cage structures. The proposed predator exclusion nets will be weighted to provide a rigid barrier between predators and the fish containment cages. Occasionally, seals or sea lions can find chafe holes in the nets after strong tides or storms. However, when this occurs, the animals can usually swim back out with little adverse effect.

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Over 30 years of net pen operation at various sites in Puget Sound, AGS has not had any incidents of marine mammals becoming entangled in the predator exclusion nets. Whales in particular do not appear to be attracted to the floating structures (personal communication with Kevin Bright, Permit Coordinator, American Gold Seafoods, December 2015a).

4.2.2.6 Additional Mariculture-Related Impacts

Other typical concerns associated with the operational phase of the project include antibiotic impacts on the microbial community, disease and parasite transfer between farmed and wild fish, and accidental release of Atlantic salmon into the environment. BE Appendix D addresses these issues in more detail with references cited.

All juvenile Atlantic salmon will be vaccinated at the AGS-owned hatchery near Olympia before being transported to the net pen site. If disease is identified after transport, fish will be provided with medicated feed for 5 to 10 days. As fish age, their immune systems improve and less intervention is needed. On average, fish are reared in the net pens for approximately 600 days, and during that time a maximum of about 30 days of medicated feed treatment might be needed. Antibiotic usage is reported to State authorities that would require sediment antibiotic resistance monitoring if abnormally high usage levels were detected. AGS has never been required to conduct such monitoring (personal communication with Kevin Bright, Permit Coordinator, American Gold Seafoods, December 2015b).

Due to the vaccination and antibiotic use on juvenile fish, disease transfer between farmed and wild fish stocks is uncommon. There is no evidence that disease transmission occurs between wild Pacific salmon species and cultured Atlantic salmon fish, as pathogens infecting cultured fish appear to come from the wild fish (WDWF 2015g). See additional information in BE Appendix D.

Sea lice is a parasite that is commonly found on wild salmon in Washington State. Sea lice infestations of farmed salmon are not usually an issue due to reduced salinity in areas of net pen operation (Nash et al. 2005). Salinity levels in Puget Sound and the Strait of Juan de Fuca are typically lower than oceanic salinity levels, as a result of the seasonal influx of snowpack runoff from large river systems and average rainfall amounts in the Puget Sound basin. See additional information in BE Appendix D.

Accidental release of Atlantic salmon from the net pen operation has the potential to impact native fish stocks if the escapes are large and occur on a regular basis. Accidentally-released Atlantic salmon could potentially interact with wild Pacific salmonid species through competition, predation, genetic hybridization, or colonization. Atlantic salmon is known to be a poor colonizer outside of its native range (Thorstad et al. 2008); thus, it is unlikely that individuals would have a major impact on wild stock or native habitat if they escaped. Numerous years of stream surveys throughout the British Columbia province and Washington State found no evidence of a self-sustaining population of feral Atlantic salmon (WDFW 2015g). It is also unlikely that escaped genetic material will have an impact on wild populations as hybridization is difficult between Atlantic and Pacific salmon species and usually results in functionally sterile offspring (WDWF 2015g). See additional information in BE Appendix D.

Due to farm management practices implemented by AGS, these potential mariculture-related impacts are unlikely to adversely affect species and habitats within the action area.

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4.3 Species-Specific Effects Analysis

The level of effect determined in this analysis is based on definitions provided by the US Fish and Wildlife Service as follows:

 “‘No effect’ means there will be no impacts, positive or negative, to listed or proposed resources. Generally, this means no listed resources will be exposed to action and its environmental consequences. Concurrence from the US Fish and Wildlife Service is not required.

 ‘May affect, but not likely to adversely affect’ means that all effects are beneficial, insignificant, or discountable. Beneficial effects have contemporaneous positive effects without any adverse effects to the species or habitat. Insignificant effects relate to the size of the impact and include those effects that are undetectable, not measurable, or cannot be evaluated. Discountable effects are those extremely unlikely to occur. These determinations require written concurrence from the US Fish and Wildlife Service.

 ‘May affect, and is likely to adversely affect’ means that listed resources are likely to be exposed to the action or its environmental consequences and will respond in a negative manner to the exposure” (USFWS 2015c).

Additional guidance for appropriate definitions of effects designations was obtained from NMFS (2014), as follows:

 "'Beneficial' effects have an immediate positive effect without any adverse effects to the species or habitat.  'Discountable' effects are those plausible adverse effects that are extremely unlikely to occur. The chance of effects increases with the frequency and duration of the action.  'Insignificant' effects relate to the size or severity of the impact and include those effects that are undetectable, not measurable, or so minor that they cannot be meaningfully evaluated. Insignificant is the appropriate effect conclusion when plausible effects are going to happen, but will not rise to the level of constituting an adverse effect. That means the species may be expected to be affected, but not harmed or harassed" (NMFS 2014).

Additionally, 'direct' impacts are those that directly affect individuals, 'indirect' impacts are those that affect an individuals' habitat or prey, and 'both' indicates that both direct and indirect effects are plausible.

A summary of the effects findings for the AGS Marine Net Pen Relocation Project is presented in Table 6, below. BE Sections 4.3.1 – 4.3.4 provide additional details on each species or group and the determination of effect.

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Table 6. Summary of effects analysis findings for protected and priority species that may occur within or near the project action area.

Species Effects Analysis Determination

Marine Mammals

Gray whale may affect, not likely to adversely affect

Humpback whale may affect, not likely to adversely affect

Killer whale a may affect, not likely to adversely affect

Dall’s porpoise may affect, not likely to adversely affect

Pacific harbor porpoise may affect, not likely to adversely affect

Harbor seal may affect, not likely to adversely affect

Northern elephant seal may affect, not likely to adversely affect

California sea lion may affect, not likely to adversely affect

Stellar sea lion may affect, not likely to adversely affect

Marine Fish

Bull trout a may affect, not likely to adversely affect

Dolly varden may affect, not likely to adversely affect

Chinook salmon (Puget Sound ESU) a may affect, not likely to adversely affect

Chum salmon (Puget Sound/Strait of may affect, not likely to adversely affect Georgia ESU)

Coho salmon may affect, not likely to adversely affect

Cutthroat may affect, not likely to adversely affect

Pink salmon (Odd Year DPS) may affect, not likely to adversely affect

Steelhead trout (Puget Sound DPS) may affect, not likely to adversely affect

Bocaccio (Puget Sound/Georgia Basin may affect, not likely to adversely affect DPS)

Canary rockfish (Puget Sound/Georgia may affect, not likely to adversely affect Basin DPS)

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Species Effects Analysis Determination

Yelloweye rockfish (Puget may affect, not likely to adversely affect Sound/Georgia Basin DPS)

Other rockfish species b may affect, not likely to adversely affect

Eulachon (Southern DPS) may affect, not likely to adversely affect

Green sturgeon (Southern DPS) a may affect, not likely to adversely affect

Green sturgeon (Northern DPS) may affect, not likely to adversely affect

Pacific cod may affect, not likely to adversely affect

Pacific hake may affect, not likely to adversely affect

Pacific herring may affect, not likely to adversely affect

Walleye pollock may affect, not likely to adversely affect

Marine Invertebrates

Geoduck may affect, not likely to adversely affect

Birds

Bald eagle may affect, not likely to adversely affect

Common loon may affect, not likely to adversely affect

Brandt’s cormorant may affect, not likely to adversely affect

Brown pelican may affect, not likely to adversely affect

Tufted puffin may affect, not likely to adversely affect

Marbled murrelet may affect, not likely to adversely affect

Clarke’s grebe may affect, not likely to adversely affect

Western grebe may affect, not likely to adversely affect

Common murre may affect, not likely to adversely affect

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4.3.1 Effects on Marine Mammals

The overall impact of off-coast marine net pen aquaculture on marine mammals is expected to be minimal with planned mitigation members; however, since several listed and priority species are known to occur and have critical habitat designated near the project action area, they are discussed in the following subsections.

4.3.1.1 Gray Whale

i. Level of Use

A small number of gray whales (< 20 individuals) regularly occur in coastal waters near the project action area. They concentrate in a nearshore region just east of Green Point which is approximately 2 miles from the proposed net pen relocation site.

ii. Effect on Prey Species

Gray whales feed primarily on amphipods in the benthos. Potential nutrient enrichment due to fish pen discharges is not expected to alter the benthic community due to the high-energy environment of the relocation site. Long-term monitoring of organic enrichment of the substrate within the Sediment Impact Zone (100 ft perimeter around the fish pen array) will be conducted to comply with NPDES permit regulations. In addition, farm management practices will include a 2-month fallow period after each 18-month grow-out period.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to benthic prey or habitat from anchor installation = insignificant, indirect.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Disturbance to prey in benthic environment from nutrient loading = insignificant, indirect.  Water quality effects from net pen operation on prey and/or self = discountable, both.  Chance of disturbance by vessels traveling to and from Port Angeles = discountable, direct.  Interaction with fish pen cages or predator exclusion nets = discountable, direct.

Gray whales are unlikely to interact with the net pen array and can avoid vessels in transit if disturbed. Their prey may be affected during anchor installation within the 52-acre Aquatic Land Lease area, but these effects will be short-term and insignificant.

iv. Determination of Effect

May affect, but not likely to adversely affect.

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4.3.1.2 Humpback Whale

i. Level of Use

The California/Oregon/Washington stock of humpback whales is estimated to include more than 2,000 individuals, and humpback is the most common whale species off the coast of northern Washington. They are present in the region from July to September.

ii. Effect on Prey Species

As a baleen whale, the humpback feeds primarily on krill, plankton, and fish. These pelagic prey could be affected by changes in water quality, but such changes would not be expected to be caused by this project.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, both  Chance of disturbance by vessels traveling to and from Port Angeles = discountable, direct.  Interaction with fish pen cages or predator exclusion nets = discountable, direct.

Humpback whales are unlikely to interact with the net pen array and can avoid vessels in transit if disturbed. A reduction in water quality is not expected; therefore, neither they nor their prey are likely to be significantly affected by net pen operation.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.1.3 Killer Whale and Designated Critical Habitat

i. Level of Use

The only known resident population of killer whales in the US resides in Washington State waters during spring, summer, and fall. The Southern Resident killer whale (SRKW) pod nearest the project action area numbered 25 individuals in 2012 (WDFW 2012a) compared to a total of 83 in the 2003 population (NOAA 2014b). Southern Resident killer whale critical habitat is defined as the US side of the Strait of Juan de Fuca, Puget Sound, and regions around the San Juan Islands to the Canadian border. These critical habitat areas are considered to be killer whale ‘hotspots’ from May to September. Whales are rarely seen in their critical habitat area in late fall (October to December), and are almost never sighted in winter (January to March; Hilborn et al. 2012).

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ii. Effect on Prey Species

Killer whales prey primarily on salmonid fish, particularly chinook salmon. The proposed project may affect, but is not likely to adversely affect Pacific salmon species (see Section 4.3.2.1 below).

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

Activities related to the proposed project are not expected to have significant long-term adverse effects on killer whales. Increased vessel traffic is likely to have the greatest potential effect; however, the NOAA Whale Wise Rules prevent vessels from approaching within 200 yards of individuals. The AGS Wildlife Interaction Plan (provided in BE Appendix A) requires crew vessel operators to slow down and avoid a killer whale trajectory by 400 yards, which should help mitigate potential impacts of vessel traffic on foraging behavior and echolocation.

Following 30 years of experience raising Atlantic salmon in Port Angeles Harbor and elsewhere in Puget Sound, AGS has reported no observations of killer whale attacks on fish pens and states that whales might not associate a net pen structure with a food source; thus, it is unlikely that there will be direct interactions between killer whales and the fish pen structures (personal communication with Kevin Bright, Permit Coordinator, American Gold Seafoods, December 2015a).

Killer whale critical habitat is vulnerable to increased chances of oiling and pollution from unintentional releases (spills, accidents) as vessel traffic increases, but spills are unlikely to occur from the marine net pen relocation project. This potential effect of the project on killer whale critical habitat would be discountable and direct.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.1.4 Dall’s Porpoise

i. Level of Use

The most recent abundance estimate for the species in the inland waters of Washington was 900 individuals in 1997. The species is most commonly found in temperate and boreal waters that are in

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excess of 600 ft, but they are also found in nearshore oceanic waters. No specific information was found regarding the occurrence of Dall's porpoise within the project action area.

ii. Effect on Prey Species

Dall’s porpoise prey consists of fish (e.g., anchovies, herring, smelt) and invertebrates (e.g., squid octopus, shrimp), which they hunt by diving. Pelagic prey such as these species could be affected by changes in water quality, but these are not expected to be caused by the project. iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, both.  Chance of disturbance by vessels traveling to and from Port Angeles = discountable, direct.  Interaction with fish pen cages or predator exclusion nets = discountable, direct.

The most probable impact to Dall’s porpoise could be the potential for a higher rate of boat strikes from increased vessel traffic in the region; however, due to their echolocation and agile swimming capabilities, this is unlikely to occur. iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.1.5 Pacific Harbor Porpoise

i. Level of Use

The most recent abundance estimate for the Pacific harbor porpoise in the inland waters of Washington was 900 individuals in 1997. The species is most commonly found in temperate and boreal waters that are in excess of 600 ft, but they are also found in nearshore oceanic waters. Pacific harbor porpoise are known to occur year-round in the Strait of Juan de Fuca and Puget Sound.

ii. Effect on Prey Species

Pacific harbor porpoise prey includes schooling fish (e.g., herring, capelin) and invertebrates (e.g., cephalopods). Pelagic prey such as these species could be affected by changes in water quality, but these are not expected to be caused by the project. iii. Degree of Predicted Effects

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Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

The most probable impact to Pacific harbor porpoise could be the potential for a higher rate of boat strikes from increased vessel traffic in the region; however, due to their echolocation and agile swimming capabilities, this is unlikely to occur. iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.1.6 Harbor Seal

i. Level of Use

A sizeable population of harbor seals occupies waters in the Strait of Juan de Fuca (11,800 individuals). Because there are two major haul-out locations inside Port Angeles Harbor, harbor seals are likely to be present in the project action area.

ii. Effect on Prey Species

Harbor seals prey on squid, crustaceans, mollusks, and various fish species, but are generalist hunters. Their pelagic prey (fish and squid) could be affected by changes in water quality, which are not expected to be caused by this project. Their demersal prey (crustaceans and mollusks) could potentially be affected by actions that impact the seafloor (e.g., anchor installation, nutrient-loading); however, anchor-related impacts will be short-term and nutrient-loading impacts during operation are not expected to be significant.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to benthic prey or habitat from anchor installation = insignificant, indirect.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Disturbance to prey in benthic environment from nutrient loading = insignificant, indirect.  Water quality effects from net pen operation on prey and/or self = insignificant, both.

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 Chance of disturbance by vessels traveling to and from Port Angeles = insignificant, direct.  Interaction with fish pen cages or predator exclusion nets = insignificant, direct.

The most probable impacts to harbor seals could be the potential for a higher rate of boat strikes from increased vessel traffic in the region and interactions with the predator exclusion nets around the fish pens. While seals can occasionally break through holes in the predator exclusion nets, entanglement with the predator exclusion nets does not typically occur. Transit of harbor seals to and from their primary haul-out site in Port Angeles Harbor is not likely to be significantly affected by project-related vessel traffic since harbor seals are accustomed to heavy vessel traffic in and around the harbor.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.1.7 Northern Elephant Seal

i. Level of Use

Solitary individuals are occasionally seen in Washington marine waters. Only one site in the Strait of Juan de Fuca has been identified as a regular haul-out site for Northern elephant seal: Race Rocks on the southern tip of Vancouver Island. However, the WDFW Priority Habitats and Species data identified the harbor seal haul-out area at the Port Angeles Rayonier Mill as having been used by Northern elephant seals, as well, which is near the project action area.

ii. Effect on Prey Species

The diet of Northern elephant seals consists of fish and squid, but may also include rays and sharks. Pelagic prey such as these species could be affected by changes in water quality, but these are not expected to be caused by the project.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, both.  Chance of disturbance by vessels traveling to and from Port Angeles = insignificant, direct.  Interaction with fish pen cages or predator exclusion nets = discountable, direct.

Despite reports of Northern elephant seal use of a haul-out site near the action area, this species is not likely to interact with vessels in transit or with the marine net pen array, and their prey should be unaffected by water quality impacts.

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iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.1.8 California Sea Lion

i. Level of Use

Male California sea lions migrate from the southern portion of their range to Puget Sound and Canada during non-breeding months. About 3,000 to 5,000 individuals move into Washington waters from fall to spring. Because there are two major haul-out locations inside Port Angeles Harbor, California sea lions are likely present in the project action area.

ii. Effect on Prey Species

California sea lions feed mainly in upwelling areas on invertebrates (e.g., squid) and fish (e.g., anchovies, mackerel, rockfish). They have also been known to take fish from commercial fishing gear, sport fishing lines, and at fish passage facilities. The proposed project may affect, but is not likely to adversely affect, their demersal prey (rockfish; see Section 4.3.2.2below). Their pelagic prey (other fish, squid) could be affected by changes in water quality, but these are not expected to be caused by the project. iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to benthic prey or habitat from anchor installation = insignificant, indirect.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

The most probable impacts to California sea lions could be the potential for a higher rate of boat strikes from increased vessel traffic in the region and interactions with the predator exclusion nets around the fish pens. While sea lions can occasionally break through holes in the predator exclusion nets, entanglement with the predator exclusion nets does not typically occur. Transit of California sea lions to and from their primary haul-out site is not likely to be affected by project-related vessel traffic since California sea lions are accustomed to heavy vessel traffic in and around Port Angeles Harbor.

iv. Determination of Effect

May affect, but not likely to adversely affect.

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4.3.1.9 Stellar Sea Lion

i. Level of Use

Stellar sea lions are known to live and breed in Washington waters. Because there are two major haul- out locations inside Port Angeles Harbor, and because they forage in nearshore and pelagic waters, Stellar sea lions are likely present in the project action area.

ii. Effect on Prey Species

Stellar sea lions feed mainly in upwelling areas on a variety of fish (e.g., capelin, cod, herring, mackerel, salmon) and invertebrates (e.g., clams, squid, octopus). Their pelagic prey (fish and squid) could be affected by changes in water quality, which are not expected to be caused by this project. Their demersal prey (clams) could potentially be affected by actions that impact the seafloor (e.g., anchor installation, nutrient-loading) but anchor-related impacts will be short-term and nutrient-loading impacts during operation are not expected to be significant. iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to benthic prey or habitat from anchor installation = insignificant, indirect.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

The most probable impacts to Stellar sea lions could be the potential for a higher rate of boat strikes from increased vessel traffic in the region and interactions with the predator exclusion nets around the fish pens. While sea lions can occasionally break through holes in the predator exclusion nets, entanglement with the predator exclusion nets does not typically occur. Transit of Stellar sea lions to and from their primary haul-out site is not likely to be affected by project-related vessel traffic since Stellar sea lions are accustomed to heavy vessel traffic in and around Port Angeles Harbor.

iv. Determination of Effect

May affect, but not likely to adversely affect. 4.3.2 Effects on Marine Fish

The overall impact of off-coast marine net pen aquaculture on marine fish is expected to be minimal; however, since several listed and priority species are known to occur and have critical habitat designated near the project action area, they are discussed in the following subsections.

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4.3.2.1 Pacific Salmonids and Designated Critical Habitat

i. Level of Use

Many salmonid species are found in the Strait of Juan de Fuca and occur in the waters in and near the project action. Species having priority conservation status, critical habitat designations, and/or are currently listed as threatened or are of special concern include coho salmon, chinook salmon, chum salmon, pink salmon, steelhead trout, bull trout, dolly varden, and cutthroat (WDFW 2015a, 2015c). Several species of west coast salmonids are managed and listed according to distinct population segments (DPSs) or evolutionarily significant units (ESUs). These include chinook salmon (Puget Sound ESU), chum salmon (Hood Canal summer run ESU), coho salmon (Puget Sound/Strait of Georgia ESU), pink salmon (odd year DPS), and steelhead trout (Puget Sound DPS). There are freshwater stream systems near the project action area that drain into the Strait that are utilized by salmonids for migration and spawning. Adult salmonids utilize the project action area for migration into these nearby streams. In addition, sub-populations of certain salmonids may have migratory routes leading towards Puget Sound that intersect with the action area. Juvenile salmonids may use the nearshore areas for feeding and cover during migrations back out to sea. The project action area does not fall within the designated critical habitats for bull trout (shallow marine habitat close to shore); however, it does overlap with critical habitat of the chinook salmon (Puget Sound ESU), which is along the coastline out to a depth of 98 feet (NMFS 2005). ii. Effect on Prey Species

Juvenile salmonids prey on invertebrates and small fish. The proposed project is not expected to have significant long-term adverse effects on prey species, and there is no forage fish spawning within the project action area.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, both.  Effects of project activities on migration pathways = insignificant, direct.  Interaction with fish pen cages or predator exclusion nets = discountable, direct.

Since salmonids migrate over long distances, and their most sensitive habitats are the riverine systems in which they spawn, the off-coast marine net pen operation will likely have little direct impact on their physical habitat. There could be an adverse effect if the fish pens decrease dissolved oxygen in the region, but due to the fast currents and vast expanse of the Strait of Juan de Fuca, water quality impacts

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are unlikely to be an issue. The fish pen could act as an attraction to juvenile salmon during their migration out to sea, but this effect can be mitigated with the careful feeding practices already employed by AGS. Additional common concerns about potential interactions between wild Pacific salmon and farmed Atlantic salmon are addressed in BE Appendix D.

The critical habitat designated for bull trout should be unaffected by relocating the Port Angeles marine net pen operation to the site east of Port Angeles Harbor, as the proposed location is 1.5 miles off-shore and designated critical habitat for bull trout is within the nearshore environment.

The bounding edge of the critical habitat for chinook salmon does potentially intersect the project action area as it includes coastal waters up to 100 ft deep; however, no major impacts on chinook salmon critical habitat are expected from project activities. The most important sectors of the chinook critical habitat are the creeks that the species uses for migration and breeding, which this project will not affect.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.2 Rockfish Species and Designated Critical Habitat

i. Level of Use

Rockfish species (particularly bocaccio, canary, and yelloweye) are particularly rare in the region, and have been Federally-listed as threatened and endangered. Critical habitat areas for distinct population segments have been designated in the Puget Sound / Georgia Strait region east of the project action area, and do not directly overlap this area.

ii. Effect on Prey Species

Anchor lines can become colonized with invertebrate communities which could enhance the habitat for demersal rockfish species.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to benthic prey or habitat from anchor installation = insignificant, direct.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Anchor lines providing structure for prey colonization = beneficial, indirect.  Water quality effects from net pen operation on prey and/or self = insignificant, both.

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Because rockfish are demersal, they may be displaced during construction of the fish pen mooring grid, but the disturbance would be relatively brief. Over time, they could potentially benefit if the anchor lines promote colonization from prey species.

Since rockfish critical habitat is primarily located in the waters of Puget Sound east of the marine net pen relocation site, it is unlikely that the project will affect rockfish critical habitat.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.3 Eulachon

i. Level of Use

Eulachon occupy nearshore waters approximately 1,000 ft (< 300 m) deep for 3 to 5 years and then migrate into freshwater river systems during late winter and early spring to spawn.

ii. Effect on Prey Species

Eulachon feed primarily on phytoplankton and zooplankton, which could be affected by changes in water quality from nutrient enrichment. However, currents in the region are fast enough and background nutrient levels high enough that operation of the marine net pen at the relocation site should have no effect on phytoplankton levels in the area.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, both.  Effects of project activities on migration pathways = insignificant, direct.

Fast currents and frequent tidal flushing should prevent water quality impacts on prey and eulachon migration pathways to spawning areas within freshwater river systems are unlikely to be impacted by project activities.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.4 Green Sturgeon and Designated Critical Habitat

i. Level of Use

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Green sturgeon is a marine-oriented, anadromous species that occupies coastal waters (< 330 ft from shore) much of the time. The southern distinct population stock of green sturgeon is Federally listed as threatened and has had critical habitat designated that includes portions of the Strait near Port Angeles. The only known spawning site for the southern population segment of green sturgeon is the Sacramento River. Their habitat ranges along the Pacific coast from southern California to Alaska. They aggregate in the Columbia River basin and Washington estuaries in late spring and summer (NOAA 2014m).

ii. Effect on Prey Species

Green sturgeon feed on benthic shrimp, clams, amphipods, Dungeness crabs, sand lances, and other small fishes. Since the site is located in an area with excellent tidal flushing, benthic impacts on prey species will likely be insignificant in the vicinity of the fish pens and mitigated by regular fallow periods.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to benthic prey or habitat from anchor installation = insignificant, direct.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Disturbance to prey in benthic environment from nutrient loading = insignificant, indirect.  Chance of disturbance by vessels traveling to and from Port Angeles = insignificant, direct.  Anchor lines providing structure for prey colonization = beneficial, indirect.  Water quality effects from net pen operation on prey and/or self = insignificant, both.  Effect s of project on migration pathways = insignificant, direct.

The greatest potential impact to green sturgeon is a reduction in dissolved oxygen from net pen operation; however, this is unlikely due to good tidal flushing at the net pen site. Benthic prey could be affected but as discussed above, effects are expected to be minimal and mitigated by fallow periods.

Green sturgeon critical habitat could be impacted if vessel traffic impedes migration routes, since green sturgeon use multiple water depths in coastal areas for migration; however, this impact is not likely to be significant due to the relatively small footprint of the project action area.

Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.5 Pacific Cod

i. Level of Use

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The Salish Sea population of Pacific cod is found in Puget Sound, the Strait of Juan de Fuca, and the Strait of Georgia with the majority of the adults in 160 to 980 ft depths. They can be found over sand and mixed coarse bottom substrates.

ii. Effect on Prey Species

Pacific cod feed on krill, shrimp, sand lance and crabs and are prey for seals, halibut and other fishes. Their demersal prey (crustaceans) could potentially be affected by actions that impact the seafloor (e.g., anchor installation, nutrient-loading) but anchor-related impacts will be short-term and nutrient-loading impacts during operation are not expected to be significant.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to prey in benthic environment from anchor installation = insignificant, direct.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.

Since Pacific cod primarily occupy deeper waters than the marine net pen relocation site, it is unlikely that the project will have a significant impact.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.6 Pacific Hake

i. Level of Use

Pacific hake are found in Puget Sound and the Strait of Georgia. They are found near the bottom or in the water column to depths of 3,000 ft (914 m); however, they are most common in water shallower than 750 ft (229 m). There are several spawning locations for Pacific hake in Puget Sound, which is not in the immediate vicinity of the project action area.

ii. Effect on Prey Species

Pacific hake larvae feed on calanoid copepod eggs, nauplii, and adults. Juveniles and small adults mostly prey on euphausiids. Large adults also eat amphipods, squid, Pacific herring, smelt, crabs, shrimp, and sometimes juvenile Pacific hake. Their pelagic prey (zooplankton, fish, and squid) could be affected by changes in water quality, which are not expected to be caused by this project. Their demersal prey (crustaceans) could potentially be affected by actions that impact the seafloor (e.g., anchor installation,

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nutrient-loading) but anchor-related impacts will be short-term and nutrient-loading impacts during operation are not expected to be significant.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance to prey in benthic environment from anchor installation = insignificant, direct.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.

Since Pacific hake primarily occupy deeper waters than the marine net pen relocation site, it is unlikely that the project will have a significant impact.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.7 Pacific Herring

i. Level of Use

Pacific herring are a coastal schooling species that is found in large schools in depths from the surface to 1,300 ft (400 m). Herring spawn in shallow areas along shorelines, between the subtidal and intertidal zones. Eggs are deposited on kelp, eelgrass, and other available structures. The nearest documented spawning grounds to the project action area are in Dungeness Bay and Sequim Bay to the east. Thus, while herring are not expected to spend much time in the immediate vicinity of the marine net pen project, it is possible they might be found there temporarily.

ii. Effect on Prey Species

Pacific herring feed seasonally on phytoplankton and zooplankton. Young herring feed mainly on crustaceans but will also eat mollusk larvae. Adult Pacific herring eat large crustaceans and small fish. Their pelagic prey (zooplankton, fish, and larvae) could be affected by changes in water quality, which are not expected to be caused by this project. Their demersal prey (crustaceans) could potentially be affected by actions that impact the seafloor (e.g., anchor installation, nutrient-loading) but anchor- related impacts will be short-term and nutrient-loading impacts during operation are not expected to be significant.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

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 Disturbance to prey in benthic environment from anchor installation = insignificant, direct.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.

Since Pacific herring would only be expected to be in the proposed project area temporarily as a schooling coastal fish, it is unlikely that a direct impact would occur.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.2.8 Walleye Pollock

i. Level of Use

Walleye pollock inhabit nearshore areas, large estuaries (including Puget Sound), coastal embayments and open ocean basins with adults occurring as deep as 1200 ft. The vast majority occurs in depths between 320 and 980 ft. Juvenile pollock have been found in a variety of habitat types, including eelgrass (over sand and mud), gravel and cobble; however, because of their pelagic mode, they are not thought to consistently associate with many types of substrates. The nearest known spawning ground to the project action area is in Port Townsend to the east, in Jefferson County.

ii. Effect on Prey Species

Walleye pollock feed on zooplankton like copepod nauplii, euphausiids, copepods, decapod larvae, and larvaceans. These pelagic prey could be affected by changes in water quality, which are not expected to be caused by this project.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.

Since walleye pollock prey upon larvae and invertebrates, the only potential impact would be from water quality affecting their prey. However, currents in the region are fast enough and background nutrient levels high enough that operation of the marine net pen at the relocation site should have a neutral effect on phytoplankton levels in the area.

iv. Determination of Effect

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May affect, but not likely to adversely affect.

4.3.3 Effects on Marine Invertebrates

There are several priority marine invertebrate species that occur within the region (hard shell clams, geoduck, red abalone, Pandalid shrimp, Olympia oyster, pinto (Northern) abalone), but the only species that occurs near the net pen relocation site and might possibly be affected by project activities is the geoduck. Thus, they have been considered in this evaluation.

4.3.3.1 Geoduck

i. Level of Use

Geoduck are found in the lower intertidal and subtidal up to depths greater than 360 ft (110 m) in soft substrates, including mud, mud/sand, and sand. They are abundant in Puget Sound and British Columbia. The Priority Habitat Species mapper indicates that they are present in benthic habitat located 1,000 ft south of the anchor footprint / project action area.

ii. Effect on Prey Species

Geoduck are sedentary suspension feeders that prey on phytoplankton and zooplankton, which could be impacted by changes in water quality. However, the site is in a well-flushed area with background nutrient levels high enough that operation of the marine net pen at the relocation site should have a no effect on phytoplankton levels in the area.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Disturbance benthic prey or habitat from anchor installation = discountable, direct.  Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.

Long-term, operational phase potential impacts:

 Disturbance to the benthic environment from nutrient loading = insignificant, direct.  Water quality effects from net pen operation on prey and/or self = insignificant, both.

The greatest potential impact to the geoduck would be changes to the benthic habitat it occupies. It is highly unlikely that anchor installation effects will extend 1,000 ft south of the anchor installation footprint; therefore, impacts to benthic habitat during the construction phase are discountable. Effects to the benthos due to possible nutrient loading during net pen operation will be mitigated by monitoring the area for organic enrichment from fish pen effluent over time and by regular fallow periods. Monitoring will be a requirement of the Clean Water Act Section 402 NPDES waste discharge

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permit for the project. Additionally, current speeds and frequent tidal flushing should prevent water quality impacts in the area.

iv. Determination of Effect

May affect, but not likely to adversely affect. 4.3.4 Effects on Birds

The overall impact of off-coast marine net pen aquaculture on coastal birds and waterfowl is expected to be minimal; however, since several priority species are known to occur in the shoreline region nearest the project action area and warrant discussion in this evaluation.

4.3.4.1 Bald Eagle

i. Level of Use

There are approximately 700 resident pairs of bald eagle in Washington State. In western and northeastern Washington, they primarily nest along marine shorelines and major rivers. The Washington Department of Fish and Wildlife Priority Habitats and Species database identifies seven nest trees near the shoreline between Lees Creek and Green Point, recorded in 2005 and 2007. Since they occupy shoreline areas near the project action area, it is possible that bald eagles use portions of the action area marine environment for hunting.

ii. Effect on Prey Species

Bald eagles hunt a wide variety of prey, including fish species, waterfowl, and bird eggs. The terrestrial prey will not be affected by the proposed project. Waterfowl and fish species could be impacted by changes in water quality, which are not expected to be caused by this project. Waterfowl could also be impacted by shoreline oiling during an accidental spill, which is unlikely to occur.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of shoreline oiling from accidental hydrocarbon spills = discountable, indirect.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.  Interaction with fish pen cages or predator exclusion nets = insignificant, direct.

The most likely impact to bald eagles from marine net pen aquaculture could be increased risk of shoreline oiling and pollution from increased vessel traffic. In general, for bird species, the interaction with fish pen cages and predator exclusion nets is likely to be insignificant, as the nets will cover the pens themselves in order to reduce potential bird interactions with the fish in rearing cages.

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iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.4.2 Common Loon

i. Level of Use

Winter breeding sites of common loons are present along the shoreline near Morse Creek. Post- breeding migration occurs between late August and November, and subadults often remain in the marine environment all summer. Washington is the only state in which common loons are known to overwinter on both saltwater and freshwater (WDWF 2012c).

ii. Effect on Prey Species

Common loons feed on a wide variety of fish species and nearshore invertebrates in the surface 15 ft (5 m) of the water column. Surface-dwelling fish and invertebrates could be impacted by changes in water quality, which are not expected to be caused by this project.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.  Chance of shoreline oiling from accidental hydrocarbon spills = discountable, both.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.  Disturbance of nest or breeding area due to vessel traffic = discountable, direct.

The most likely impacts to common loons from the marine net pen aquaculture project could be increased risk of shoreline oiling and pollution as well as breeding area disturbance from increased vessel traffic. However, chances of a spill are low, and common loons in the Port Angeles area are accustomed to regular vessel traffic in the harbor so established breeding sites should remain unaffected.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.4.3 Diving Birds

i. Level of Use

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Brown pelicans, tufted puffins and Brandt’s cormorants are all diving bird species that occupy Washington inland marine waters. While their nesting sites are not in the immediate vicinity of the project action area, it is possible they would forage and swim near the area.

ii. Effect on Prey Species

Brown pelican feed mainly on schooling marine forage fish, such as Pacific mackerel, Pacific sardines, and Northern anchovies. Tufted puffin foraging near coastlines feed more on fish than invertebrates. Brandt’s cormorants feed on a wide variety of fish with some shrimp and crabs. As most of these prey species are pelagic, they could be affected by changes in water quality, but such changes are not expected to be caused by this project.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.  Chance of shoreline oiling from accidental hydrocarbon spills = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.  Interaction with fish pen cages or predator exclusion nets = insignificant, direct.

The most likely impact to these species of diving birds from marine net pen aquaculture could be increased risk of shoreline oiling and pollution from increased vessel traffic. Diving birds are not expected to be significantly affected by the bird exclusion nets covering the tops of the fish pens.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.4.4 Marbled Murrelet

i. Level of Use

In Washington, murrelets are found in nearshore marine areas (within 1.2 mi [2 km] of shoreline), with the greatest concentrations in northern Puget Sound (WDW 1993). The population estimate for the Puget Sound and Strait of Juan de Fuca region (Zone 1) in 2013 was 4,395 birds (Pearson et al. 2014). Therefore marbled murrelets are likely to occur within the project action area.

ii. Effect on Prey Species

The main forage fish for marbled murrelets include Pacific herring, Northern anchovy, Pacific sand lance, and capelin. In the absence of fish, the murrelets will also feed on krill (WDFW 2012d). The proposed project may affect, but is not likely to adversely affect Pacific herring (see Section 4.3.2.7). Other prey

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species could be affected by changes in water quality, but such changes are not expected to be caused by this project.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.  Chance of shoreline oiling from accidental hydrocarbon spills = discountable, direct.

Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.

The most likely impacts to marbled murrelet from marine net pen aquaculture could be increased risk of shoreline oiling and pollution from increased vessel traffic. Critical habitat and breeding areas are not found within the waters of the project action area.

iv. Determination of Effect

May affect, but not likely to adversely affect.

4.3.4.5 Waterfowl

i. Level of Use

Western grebe, Clark’s grebe and common murre are all waterfowl species that utilize Washington inland marine waters. The grebes build floating nests in nearshore waters of Washington, and common murres nest along the outer Washington coast; however, both species are also common on inland waters throughout the year. It is possible that they would occur in the project action area.

ii. Effect on Prey Species

Grebes feed on a wide variety of fish and will also prey on salamanders, crustaceans, worms, and insects. Common murres feed on small fish and a wide variety of invertebrates (e.g., crustaceans, marine worms, and squid). Their pelagic prey (fish) could be affected by changes in water quality, which are not expected to be caused by this project. Their demersal prey (crustaceans and worms) could potentially be affected by actions that impact the seafloor, but waterfowl forage areas are so nearshore that they will not be impacted by seafloor activities within the project action area.

iii. Degree of Predicted Effects

Short-term, construction phase potential impacts:

 Chance of accidental hydrocarbon spill from vessel traffic = discountable, direct.  Chance of shoreline oiling from accidental hydrocarbon spills = discountable, direct.

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Long-term, operational phase potential impacts:

 Water quality effects from net pen operation on prey and/or self = insignificant, indirect.  Disturbance of nest or breeding area due to vessel traffic = discountable, direct.

The most likely impacts to waterfowl species from marine net pen aquaculture could be increased risk of shoreline oiling and disturbance of floating nests from increased vessel traffic. However, chances of a spill are low, and waterfowl in the Port Angeles area are accustomed to regular vessel traffic in the harbor so established breeding sites should remain unaffected.

iv. Determination of Effect

May affect, but not likely to adversely affect. 4.4 Conclusions

The Strait of Juan de Fuca is one of the most promising areas for the development of off-coast aquaculture in the US (Rensel et al. 2007). There is a lack of sensitive habitats directly beneath the proposed net pen relocation site, and the fast currents, frequent tidal flushing, high ambient nutrient presence, and sufficient dissolved oxygen levels will likely prevent phytoplankton blooms or other water quality impacts from occurring.

The largest potential impact to the benthos is disturbance of the area within the anchor footprint. Benthic habitat will be disturbed during anchor installation in the construction phase, but this disturbance will be temporary and the presence of the anchors may result in habitat enhancement for colonizing species. Benthic fauna in the prevalent sand and gravel substrates that are accustomed to minimal organic inputs and higher oxidation levels could be affected by nutrient loading from excess feed or fish waste. However, potential adverse impacts will be mitigated with careful feeding practices that minimize sedimentation and fallowing practices that allow the benthic communities to recover between periods of use. The Sediment Impact Zone (SIZ) around the net pen site will be monitored through regular sampling, in accordance with the Clean Water Act Section 402 NPDES waste discharge permit for the project.

An increase in vessel traffic to and from the pen site could increase the chance of boat strike injuries for marine mammals and could potentially add pollutants to the environment in the event of an unanticipated fuel oil spill. These effects could be mitigated by avoiding priority habitat areas with vessel traffic, and following Whale Wise Rules to stay 200 yards away from individuals and 400 yards form a marine mammal trajectory. The operational phase of the project will involve vessel trips between Port Angeles Harbor and the net pen relocation site. Two to four times per day, a crew vessel will transport employees and equipment to and from the marine net pen farm. Approximately once per week, a marine supply vessel will visit the floating net pen operation to deliver consumables, and to remove wastes for disposal at existing, permitted land-based facilities. Diesel fuel deliveries to operate the generator will likely occur approximately once per month. This additional vessel traffic represents a negligible increase in existing vessel activity that occurs within the project action area.

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Interactions between wild fish populations and marine mammals and the cultured fish stock are not likely to be a concern (see BE Appendix D). Cultured Atlantic salmon are unlikely to either hybridize with native Pacific salmon or compete in the surrounding habitat, and disease transmission is not expected. Interactions between marine mammals and the fish pens may occur, but will be mitigated by continuing to use taut mooring lines that prevent entanglement and by continuing best practices to repair holes in the predator exclusion nets as they occur.

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5 References

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Appendix A: AGS Wildlife Interaction Plan

Author: Kevin Bright, American Gold Seafoods, Inc. A.1 WILDLIFE INTERACTION MANAGEMENT

American Gold Seafoods (AGS) conducts its operations in a manner that is intended to minimize wildlife impacts and meet or exceed relevant regulatory requirements for the protection of the surrounding environment. The Wildlife Interaction Plan describes the AGS requirements related to wildlife management and meeting BAP standards.

A.2 RELEVANT REGULATORY REQUIREMENTS The American Gold Seafoods farming facilities operate within the framework of numerous state, federal and local rules and regulations, and compliance with the rules and regulations is of paramount importance to the company.

“Plans of Operations” and “Project Plans” are submitted by AGS to the various regulatory agencies charged with protecting the environment, endangered and listed species, and other natural resources. These “Best Management Plans” specify a variety of practices and equipment used by AGS to minimize wildlife interaction and potential impacts to the surrounding environment. For instance, AGS uses only passive, non-lethal wildlife and predator controls as a means of protecting the fish stocks and minimizing negative wildlife interactions. The company has described the methods and materials used in accomplishing this during the environmental permitting process of obtaining the farm’s operational permits and numerous project approvals. The regulatory process and the farm’s project approvals themselves are a site specific environmental approval of the farming operations at the site and the farm’s compliance with state, federal and local environmental laws.

For all major work projects at the net pens sites, a JARPA application (Joint Aquatic Resources Permit Application) is submitted to the state, federal and local regulatory agencies and nearby Tribal natural resource agencies. For the farm sites, the lead agency is the local County or City Planning and Development department- through the Shoreline Substantial Development Permit process governed by the local Shoreline Master Program. Additionally, permits must be obtained from the U.S. Army Corps of Engineers (USACE), as well as approvals from the Washington Department of Ecology. WDOE reviews and has ultimate authority over all shoreline permits issued by the local planning departments.

USACE issues a Federal permit, and any Federal permit requires a review of the project with respect to Federal Listed and Endangered species. The USACE and other agency typically require a Biological Evaluation (BE) be prepared by a professional wildlife biologist who reviews the project with respect to the project area, the scope of the project and evaluation of potential impacts to any critical habitats

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and/or listed wildlife species. The BE is reviewed by the USACE in consultation with National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) who have authority for protecting listed and endangered species and habitats. The JARPA application material and the BE are reviewed and sent out to the other state, local and Tribal agencies for public and agency comment. After the review period, the Army Corps permit is either issued in a letter of permission (LOP) or denied. Work windows and other conditions are set in this permit to protect and minimize impacts to ESA or listed species.

Each farm site is also covered by a Washington Department of Fish and Wildlife Finfish Aquaculture permit (letter of approval of the “Plan of Operation”). This is an operational permit that approves the growing of Atlantic salmon in nets pens by the State of Washington. The Washington Department of Fish and Wildlife (WDFW) takes into consideration the risks and mitigating procedures spelled out in the “operational plans” of each facility with respect to impacts on the wildlife and habitats of the state when issuing their permission. The WDFW Finfish Permit is considered a review and approval of compliance practices with government regulations designed to protect the natural resources of the state.

The environmental permitting process for siting, operating and maintaining a net pen complex creates a rigorous regulatory risk assessment of the farming operations and managing wildlife interactions for the benefit of protected species and habitats.

A.3 NON-LETHAL PREDATOR BARRIERS

The goal of American Gold Seafoods (AGS) aquaculture operations is to minimize interactions with the local wildlife while growing fish at each farming location. The farms are required by local, state and federal regulations to use non-lethal methods to deter protected wildlife from trying to enter the net pens. The AGS farms have developed passive predator barrier nets that prevent marine mammal predation and avian predators from interacting with the fish stocks at the farms. These passive barriers have been very successful at reducing the attraction of the net pen facilities as a food source for both marine mammals and avian scavengers. A.3.1 OPERATIONAL PROCEDURES USED TO MINIMIZE WILDLIFE INTERACTIONS

The following are used to minimize and manage wildlife interactions at AGS finfish aquaculture operations:

 Avian scavenger and predator barrier nets or “bird nets” are tightly suspended over the top of each net pen.  Underwater barrier nets are deployed and maintained while fish stocks are being reared at the marine facility.  Mesh size of secondary all barrier nets is of proper size to deter predators, while avoiding entanglement.

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 Jump fencing panels are installed and maintained around the perimeter walkway in order to prevent marine mammals from entering the fish containment areas by climbing up and over the walkways.  Holes caused by chaffing or breaches in the secondary predator barrier netting are promptly repaired by farm staff.  Repairs and maintenance of predator net breaches are documented on the net maintenance records. A.3.2 ACCIDENTAL ANIMAL MORTALITY REPORTING

AGS maintains a record of the species and number any avian, mammalian and reptilian predator mortalities, including accidental mortalities.

The occurrence of any accidental marine mammal entanglements and drowning is required to be promptly reported to the Washington Department of Fish and Wildlife (WDFW) and the National Marine Fisheries Service (NMFS). AGS uses the Accidental Marine Mammal Death Report to report these incidents within 48 hours of the occurrence.

The AGS Accidental Marine Mammal Death Report must include the following information and copies are to be sent to both WDFW and NMFS:

Example: American Gold Seafoods Accidental Marine Mammal Death Report

Date of Incident: April 1, 2012 Common name of animal harmed: Harbor seal Number of animals harmed: 1 Probable cause of mortality: Animal became entangled in a chafe hole in the predator net and drowned. Has the problem been corrected: Yes. The hole was found by divers the next day and sewn shut. Was a report submitted to the proper agencies: Yes, a report was submitted to the WDFW and NMFS. Name of person completing this report: Jane Doe Date of Report: April 2, 2012

In addition, a separate report must also be submitted to the NMFS using the following NMFS Marine Mammal Mortality Report form. A copy of the report can be emailed to [email protected]

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Example: NMFS Marine Mammal Mortality Report:

A.3.3 PASSIVE PREDATOR CONTROL – MARINE MAMMALS Each farm site has installed an external marine mammal predation barrier net that is tied to a heavily weighted and rigid pipe frame suspended under the surface. This system has been developed and improved upon for the past 15 years. The pipe frame holds taught the barrier net and helps maintain a physical separation between the exterior barrier net and the interior fish containment nets. Additionally a jump barrier net is suspended from the walkway surface by poles to a height of approximately 6 feet. This prohibits marine mammals from climbing onto the cage floats and accessing the area inside the barrier nets where the fish containment nets are located.

The bird nets are lashed down with twine to the fish containment jump net around the entire perimeter of the pen. This is an additional measure taken by the farms to prevent predation of the fish stocks by River Otters. River Otters have been known in the past to be able to find small openings between the fish containment net and the bird netting, and to climb in and out of the fish pen through these openings. By sewing the bird netting tight to the hand railing and the jump panel around each containment net this type of predation has been virtually eliminated. Again, once the food source is removed the amount of interaction between the farm and predatory wildlife is greatly diminished.

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A.3.4 PASSIVE PREDATOR CONTROL – AVIAN Avian predation deterrence nets (bird nets) are primarily used to prevent marine birds (seagulls, terns) and other scavenger type birds (crows, pigeons) from attempting to consume the fish feed pellets as they are distributed into the fish pens. The bird netting also protects the small juvenile fish stocks from avian predation by Blue Herons, Cormorants, Osprey and other birds of prey that could attack the cultured fish stocks from the surface. Bird netting is used on all pens to deter bird predation on the smaller fish. The netting acts as a passive visual deterrent as well as a physical barrier that prevents this type of predation from occurring. A.3.5 ACOUSTIC HARASSMENT DEVICES

AGS does not use acoustic harassment devices to control predators at any of the marine net pen facilities.

A.4 INTERACTION WITH CRITICAL OR SENSITIVE HABITAT A.4.1 SITE LOCATION IN RELATION TO CRITICAL OR SENSITIVE HABITAT

The Port Angeles farm is located adjacent to the Ediz Hook spit inside of Port Angeles Harbor area. The main water body adjacent to Port Angeles Harbor is the Strait of Juan de Fuca which feeds into the Pacific Ocean. The farm is located within the borders of Clallam County, Washington. The Port Angeles net pen site was originally permitted for installation around 1985. The facility has been in continual operation ever since. Over the years many site specific Biological Evaluations (BE) have been carried out during routine cage replacement and maintenance projects. The Biological Evaluations are considered a third party risk assessment of the proposed project and of the possible environmental impacts of the project and operations. The BE’s are reviewed during by the proper regulatory authorities before approval of any environmental permits and demonstrate that critical and sensitive habitats, and endangered and listed species are taken into consideration during the environmental permitting process and project review. The BE’s and subsequent permits can be made available upon request.

Reviews of the local area habitats and protected species were carried out using agency public database information. The database reports were used in helping to develop the AGS Wildlife Interaction Plan and set up the employee training program.

The Port Angeles farm also complies with the following operational and environmental licenses and permits issued by state, federal and local regulatory agencies charged with protecting sensitive habitats and species.

 Washington Department of Ecology-National Pollution Discharge Elimination System (NPDES permit)

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 Washington Department of Fish and Wildlife Finfish Aquaculture Permit  Washington Department of Natural Resources – Aquatic Use Authorization (WDNR Aquatic Land Lease)  US Army Corps of Engineers- Section 10 Permit and LOP (ESA Review and NMFS/USFWS consultation)  County Shoreline Substantial Development Permit/Conditional Use Permit  State Environmental Policy Act (SEPA review and determination)  Joint Aquatic Resource Permit Application (JARPA for specific project permits or agency actions)  WDOE Coastal Zone Management Act Compliance  WDFW Transport Permit (Finfish reportable disease regulations and controls)

A.4.2 FARM EMPLOYEES AND SITE STRATEGIES FOR MINIMIZING WILDLIFE INTERACTION Avoidance of Killer Whales and all other whales and porpoise-  All whales and porpoise are Federally protected animals and employees will not approach them if they are spotted while transiting to and from the farm in work vessels.  If whales are spotted in the path of the crew vessel, slow down and alter course to maintain a distance of at least 400 yards away from the direction of travel of the whales.  If necessary and safe, and it will not result in the crew boat stopping in the pathway of the transiting whales, stop the vessel and wait for the whales to move through the area unencumbered.  The employee driver of the crew vessel is responsible for taking a path that will go behind the direction of travel of any whales spotted. It is illegal to stop a boat in the anticipated pathway of the whales and as the driver of the vessel, you will be responsible for any violations and fines.

Routine and timely fish mortality removal-  Removing fish mortality on a frequent basis will eliminate underwater attractants to marine mammals or other scavengers.  Fish mortalities that are removed will be stored in leak proof plastic containers. Mort containers are to be removed from the farm site on a routine basis.

Underwater and jump panel predator barrier nets are to be properly maintained throughout the growing cycle-  Barrier netting is to be installed and in excellent working condition at the beginning of each year class.  Any indication that there has been a breach in the barrier net protection will be investigated at the earliest time possible by divers or underwater cameras. Necessary repairs will be made upon the location of a chaff hole or tear in the netting.  Repairs to the barrier net will be logged in the net log journal.

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 Jump panels above the surface shall be maintained in proper working conditions at all times.

Bird and River Otter deterrence netting-  Bird netting shall be of the proper size mesh to not entangle birds or other wildlife.  Bird netting is to be stretched tight and tied down to the hand railing and jump panel around each fish containment net to deter River Otters access to the fish stocks.  Large chaff holes in the netting are to be mended quickly to deter access and/or entrapment of birds or animals.  When not in use (at harvest time) bird netting is to be rolled up and properly stored in containers to avoid entanglement by birds or animals.

Disposal and/or recycling of used netting material-  Netting materials that are not destined to be reused are to be properly disposed of or recycled at land based facilities that accept this material.

Solid waste material, fish feed and other wildlife attractants-  All solid waste material is to be properly stored in garbage cans or other containment devices that are properly marked.  Waste materials are to be stored and routinely removed from the site in a timely manner  All waste materials generated by the farm are disposed of at land based recycling or disposal facilities that are approved for handling this waste.  Fish feed stored on site is to be kept the necessary amount in order to maintain the weekly diet of the fish stocks.  Feed is to be properly protected from scavengers by plastic barriers or tarps.

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Appendix B: Author Qualifications and Resumes

The authors from RPS ASA and Shoal’s Edge Consulting have been involved in preparing numerous Environmental Impact Statements (EIS), Environmental Assessments, and Biological Assessments both for applicants and as third-party representatives to Federal and State governments. Examples of relevant projects include EISs for Beacon Port LNG, Pearl Crossing LNG, Texas Offshore Ports System, the BOEM EA for Commercial Wind Lease Issuance and Site Assessment Activities on the Atlantic Outer Continental Shelf of Offshore Massachusetts, the BOEM EA for New York, an EIS for a proposed offshore LNG terminal in the Caribbean, and the EIS for a proposed natural gas pipeline lateral in the New York Bight. For these EIS’s, RPS ASA was responsible for preparing the Resource and Impact Sections for benthic invertebrates, benthic habitats, ecosystems, fish, plankton, birds, marine mammals, threatened and endangered species and species of special concern, recreational and commercial fishing, water quality, vessel traffic, geology and oceanography. Shoal’s Edge Consulting has also been the lead author on several Biological Assessments and EFH EIS sections for many previously proposed projects.

This appendix includes the resumes of the authors of this Biological Evaluation.

Appendix B: Author Qualifications and Resumes

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rpsgroup.com | asascience.com | 122 AGS Marine Net Pen Relocation Project: Port Angeles-East- Biological Evaluation | 15-260 | American Gold Seafoods | USA 1/21/2016 Jill Rowe – Director of Environmental Risk Assessments M.S. Marine Biology, College of Charleston - 2001 B.A. Biology, DePauw University - 1996 East/West Marine Biology Program, Northeastern University - 1997 [email protected]

Areas of Expertise: Jill Rowe specializes in biological and environmental data gathering, analysis and management; natural resource damage assessment (NRDA) modeling and analysis of pollutant fates and effects; ecological risk assessment; impact assessment of dredging and development projects, preparing sections of Environmental Impacts Statements; providing NEPA support, and GIS mapping and analysis. Ms. Rowe has applied her marine biological and GIS expertise to biological data set development, as well as mapping habitats and biological resource distributions that could ultimately be affected by oil/chemical spills and development projects. She performs quantitative assessments and modeling of aquatic ecosystems and populations, pollutant transport and fates, and biological response to pollutants. The populations to which she applies these models include plankton, benthic invertebrates, fisheries, birds and mammals. She has analyzed data and has applied water quality, food web and ecosystem models to case studies in freshwater, marine and wetland ecosystems. Ms. Rowe is involved in the on-going NRDA for the Deepwater Horizon oil spill, and is assisting in the lead of the Offshore Water Column Technical Working Group of scientists evaluating the impacts of the spill. Experience Includes: RPS ASA 2001-present

NEPA Support and Environmental Impact Statements

 Currently managing a contract to BOEM’s Alternative Energy Program to prepare sections of the Environmental Assessments (EA) for alternative energy development on the Outer Continental Shelf (OCS) of New York.  As a subcontractor to the federal third-party representative, supported the development of an EIS for a proposed offshore LNG terminal in the Caribbean.  Managed a contract to Bureau of Ocean Energy Management (BOEM)’s Alternative Energy Program to quantify environmental sensitivity of the marine habitats and ecosystems contained in BOEM’s Outer Continental Shelf (OCS) Planning Areas in response to the expansion of BOEM regulation to include renewable energy development.  Managed a contract to BOEM’s Alternative Energy Program to prepare sections of the Environmental Assessments (EA) for alternative energy development on the Outer Continental Shelf (OCS) of Massachusetts.  Assessed potential impacts of ichthyoplankton entrainment in seawater intakes and impacts from offshore LNG terminal construction and operation for Environmental Impact Statements for proposed LNG projects off the coast of Puerto Rico.  Assessed potential impacts of ichthyoplankton entrainment in seawater intakes and impacts from pipeline and LNG terminal construction and operation, for Environmental Impact Statements for (3

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separately) proposed LNG projects off the coast of LA in the Gulf of Mexico and in MA.  Assessed potential impacts of oil spill response alternatives for a Programmatic Environmental Impact Statement, as part of the US Coast Guard rulemaking on response equipment regulations.  Assessed potential impacts of oil spills for two El Segundo Marine Technical Lease Renewals.

Oil and Chemical Spill Fate, Impact and Natural Resource Damage Assessment

 Provides technical support and modeling to federal and state trustees to estimate fates, injuries and natural resource damages resulting from spills: more than 30 cases, for spills that occurred in areas such as San Francisco Bay, Florida waters, Guanabara Bay, Brazil, Rouge and Detroit Rivers, MI, Galveston Bay, Texas, Calcasieu River and Estuary, Louisiana, Puerto Rico,  Provides training to federal and state trustees, industry, and private parties on use of modeling for NRDA, impact and risk assessment.  Used modeling to estimate potential worst-case natural resource damages resulting from hurricane induced oil spills in Louisiana for the Trustees. Assisted in development of risk assessment modeling approach  Providing technical support and modeling to federal and state trustees to estimate fates, injuries and natural resource damages resulting from the Deepwater Horizon oil spill of April-2010; assisting leads for NOAA for Offshore Water Column Technical Working Group

Modeling and Analysis of Pollutant Fates and Effects, Ecological Risk Assessment

 Managing a contract to BSEE, as a subcontractor to Booz Allen Hamilton, to assess the evolving risk trends for worst case discharge scenarios due to emerging industry drilling practices in order to provide BSEE with an updated context to inform the Bureau’s regulatory development process.  Managed a contract to BOEM, as a subcontractor to RPI, to perform a literature review and assessment of the environmental risks, fate and effects of oils and chemicals associated with wind turbines in the Atlantic Outer Continental Shelf.  Worked on oil modeling analysis as part of the development of the Environmental Impact Assessment for the El Segundo Marine Technical Lease Renewal.  Assisted in modeling analysis of potential spills resulting from groundings in San Francisco Bay in an ecological risk assessment and cost analysis for natural resource damages, response costs and socioeconomic costs (client: Army Corps of Engineers, San Francisco District).  Worked on modeling analysis of potential spill impacts and costs in Washington state waters as part of a cost-benefit analysis for the Washington Department of Ecology’s rulemaking regarding spill response requirements  Worked on modeling of spills in US waters with and without dispersant use, for use in an Programmatic Environmental Impact Statement, US Coast Guard rulemaking on response equipment regulations  Worked on a study to evaluate the potential biological effects of dredging a channel and turning basin for a proposed LNG facility in Mount Hope Bay and the Taunton River in Massachusetts. The study included a month-long field program and applications of a hydrodynamic model to predict the currents, a dredged sediment transport model to estimate water column sediment concentrations and deposition patterns, and a biological model to calculate doses and effects to categories of marine species and their life stages. RPS ASA was responsible for writing key pieces of the Resource Reports, including Essential Fish Habitat (EFH) report and a Biological Characterization report, for the

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subsequent filing of the EIS.

Fisheries Modeling and Impact Assessment

 Worked on a study to assess possible impacts of the entrainment of ichthyoplankton as a result of seawater heating from regasification facilities and assessed impacts from pipeline and LNG terminal construction and operation as part of a team developing an Environmental Impact Statement for a proposed LNG project off the coast of Louisiana in the Gulf of Mexico.  Assessed potential impacts of ichthyoplankton entrainment in seawater intakes and impacts from pipeline and LNG terminal construction and operation, for Environmental Impact Statements for proposed LNG projects: two off the coast of Louisiana in the Gulf of Mexico, one in Mount Hope Bay, Massachusetts, and one in Puerto Rico.  Project Manager for a technical review of a benthic monitoring program for a region of Lake Erie affected by thermal discharge from a coal burning plant on Lake Erie.

Impact Assessment for Dredging and Development Projects  Worked on a study to evaluate the potential biological effects of dredging a channel and turning basin for a proposed LNG facility in Mount Hope Bay and the Taunton River in Massachusetts. The study included a month-long field program and applications of a hydrodynamic model to predict the currents, a dredged sediment transport model to estimate water column sediment concentrations and deposition patterns, and a biological model to calculate doses and effects to categories of marine species and their life stages. ASA was responsible for writing key pieces of the Resource Reports, including Essential Fish Habitat (EFH) report and a Biological Characterization report, for the subsequent filing of the EIS.  Evaluated potential biological impacts of dredging in Mount Hope Bay and the Taunton River for LNG terminal permit support (Weavers Cove Energy)  Evaluated potential biological impacts of dredging in a proposed maritime yard project at Ras Al-Khair, Saudi Arabia.

National Ocean Service (CCEHBR) 1999-2001

 Compiled and analyzed fishery-independent trawl data collected by the South Carolina Department of Natural Resources to determine the relationship between ecological functions of Cape Romain National Wildlife Refuge (CRNWR) and the nearshore and offshore fishery. Developed methods for mapping spatial data using ArcView GIS as a visual tool for Cape Romain resource managers. Assessed the importance of fish biomass, diversity and abundance to coastal and nearshore habitat protection and management by resource managers. Aided in fieldwork for a water quality project in CRNWR.  Participated in NOAA Ocean Explorer : Islands in the Stream Expedition – South Atlantic Bight Mission. Refer to the summary of the submersible dive in which Ms. Rowe was involved at: http://oceanexplorer.noaa.gov/explorations/islands01/log/sep10/sep10.html University of Charleston 1998-1999

 Thesis research: Spatially analyzed approximately 30 yrs of fisheries-independent data from the Marine Resources Monitoring, Assessment and Prediction (MARMAP) program of the South Carolina Department of Natural Resources in the continental shelf and upper slope of the southeastern Atlantic coast for trends in fish abundance, biomass, and diversity.

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 Participated in summer cruises aboard the R/V PALMETTO to sample reef fish for stock assessment and life history studies in the South Atlantic Bight (NC to FL).  Assisted in laboratory fisheries research, consisting of fecundity and otolith sample preparation for further staging and analysis, at the South Carolina Department of Natural Resources (Marine Resources Division). Assisted in port sampling of fish caught by commercial vessels.

Selected Publications and Conference Proceedings Related to Oil and Chemical Spill Assessments

French McCay, D., D. Reich, J. Rowe, M. Schroeder, and E. Graham. 2011. Oil Spill Modeling Input to the Offshore Environmental Cost Model (OECM) for US-BOEMRE’s Spill Risk and Costs Evaluation. In Proceedings of the 34th AMOP Technical Seminar on Environmental Contamination and Response, Emergencies Science Division, Environment Canada, Ottawa, ON, Canada. French-McCay, D.P, CJ Beegle-Krause, J. Rowe, W. Rodriguez, and D. S. Etkin, 2009. Oil Spill Risk Assessment – Relative Impact Indices by Oil Type and Location. In: Proceedings of the 32nd AMOP Technical Seminar on Environmental Contamination and Response, Emergencies Science Division, Environment Canada, Ottawa, ON, Canada, pp. 655-681. French-McCay, D.P, J. Rowe and D.S. Etkin, 2008. Transport and Impacts of Oil Spills in San Francisco Bay – Implications for Response. In: Proceedings of the 31th AMOP Technical Seminar on Environmental Contamination and Response, Emergencies Science Division, Environment Canada, Ottawa, ON, Canada, pp. 159-176 D.S. Etkin, French-McCay, D.P, and J. J. Rowe, 2007. Using Analytical Models to Assess the Benefits of Oil Spill Response technology. In Proceedings of the 30th Arctic and Marine Oil Spill Program (AMOP) Technical Seminar, Emergencies Science Division, Environment Canada, Ottawa, ON, Canada, pp.657-680. Rowe, J., D. French McCay, and N. Whittier. 2006. Estimation of Natural Resource Damages for 23 Florida Cases Using Physical Fates and Biological Modeling. Conference Proceedings, Contaminated Soils, Volume 12. 22nd Annual International Conference on Soils, Sediments and Water, University of Massachusetts Amherst, October 17-19, 2006. Rowe, J.J., and G.R. Sedberry. 2006. Integrating GIS with Fishery Survey Historical Data: A Possible Tool for Designing Marine Protected Areas. In Proceedings of the 57th Annual Gulf and Caribbean Fisheries Institute Conference, St. Petersburg, FL, November 2004, p. 9-3 French-McCay, D.P., J.J. Rowe, N. Whittier, S. Sankaranarayanan, D. S. Etkin, L. Pilkey-Jarvis. 2005. Evaluation of the Consequences of Various Response Options Using Modeling of Fate Effects and NRDA Costs of Oil Spills into Washington Waters. Paper 395, Proceedings of the 2005 International Oil Spill Conference, American Petroleum Institute, Washington, D.C., May 2005. French McCay, D.P., and J.J. Rowe, 2003. Habitat restoration as mitigation for lost production at multiple trophic levels. Mar Ecol Prog Ser 264:235-249.

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Alicia Morandi (née Landi) – Biologist B.S. Biological Sciences, with Distinction in Research – Cornell University - 2007 M.S. Natural Resources and the Environment – University of Connecticut - 2011 [email protected]

Areas of Expertise: Alicia Morandi is a Biologist with RPS ASA. She has a broad background in ecological science and specializes in environmental data collection, literature review, and spatial data analysis. Her work and education have provided experience in geographic information systems (GIS), statistics, laboratory methods, and field work in estuarine, freshwater, wetland, and terrestrial environments. Ms. Morandi’s graduate work involved creating and analysing geospatial data to determine coastal landscape characteristics with which she developed a predictive model of spawning habitat use by horseshoe crabs in the Long Island Sound estuary. At RPS ASA, she applies her quantitative skills and GIS expertise to research on marine species life history and behaviors for the on-going Deepwater Horizon Oil Spill Natural Resource Damage Assessment.

Experience Includes: RPS ASA 2012-present Biologist  Conducting research on marine species life history and behaviors.  Analysis of large databases of long-term biological surveys.  Creating figures of exposure and toxicity using SIMAP.  Creating spatial data layers and maps for a variety of projects using ArcGIS.  QA/QC of model inputs and output.  Literature review, summary, analysis, and reporting.

Connecticut Department of Energy and Environmental Protection 2012-2012 Marine Fisheries GIS Seasonal Assistant . Produced ArcGIS data layers, analyses, and maps utilizing Long Island Sound Trawl Study data. . Created maps intended for the CT DEEP website and organized and managed GIS file database. . Assisted with water quality cruises and trawl survey sampling of marine species aboard the 50-foot R.V. John Dempsey.

University of Connecticut 2009-2011 Graduate Research Assistant

. Thesis research: “Selection of spawning habitats by horseshoe crabs (Limulus polyphemus) along the complex Connecticut coast.” . Characterized spawning habitat of horseshoe crabs using remotely sensed spatial data and various ESRI ArcGIS products and ERDAS IMAGINE software. . Conducted spawning abundance surveys in beach and marsh habitats. . Developed polytomous logistic regression models in SAS to predict habitat use by horseshoe crabs in the Long Island Sound estuary for the CT Dept. of Energy and Environmental Protection. Appendix B: Author Qualifications and Resumes

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University of Central Florida 2007-2008 Lab Manager . Managed datasets and supervised daily lab activities for a professor in the Biology department. . Conducted greenhouse and field germination experiments with invasive plant species in Florida. . Utilized herbaria resources to investigate patterns of flowering phenology in relation to climate change.

Cornell University 2005-2007 Undergraduate Research Assistant

. Sampled and counted freshwater algae and zooplankton populations cultured in chemostats. . Prepared chemical growth media and maintained database. . Taught local high school groups about plankton communities in Cayuga Lake.

Cornell University 2005-2007 Independent Honors Research Project

. Thesis: “Relaxation of microhabitat restriction through ontogeny of Itea virginica in cypress-tupelo swamps.” . Conducted field transect surveys in an old growth cypress-tupelo swamp. . Investigated flooding tolerance of swamp shrub Itea virginica at different life stages: seed germination, seedling establishment, and seedling vs. adult growth rates.

Professional Memberships: . Member, American Fisheries Society . Member, Coastal and Estuarine Research Federation . Member, The Ecological Society of America

Peer-Reviewed Publications: Landi, A.A., J.C. Vokoun, P. Howell, and P. Auster. 2014. Predicting use of habitat patches by spawning horseshoe crabs (Limulus polyphemus) along a complex coastline with field surveys and geospatial analysis. Aquatic Conservation: Marine and Freshwater Systems (in press).

Anderson, J.T., A. Landi, and P. Marks. 2009. Limited flooding tolerance of juveniles restricts the distribution of adults in an understory shrub (Itea virginica; Iteaceae). American Journal of Botany 96(9): 1603–1611.

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[email protected] Danielle Ameen Reich http://www.linkedin.com/in/dreich

Danielle is a certified Associate Fisheries Professional with a wide range of experience in the marine sciences. Since entering the environmental consulting field in 2007, Danielle has supported a wide variety of complex projects in both marine and terrestrial environments, specializing in risk assessment, oil spill modeling, fisheries science, marine spatial planning, protected species issues, environmental permitting, and the preparation of environmental impact statements pursuant to the National Environmental Policy Act (NEPA). EDUCATION Master of Science, Marine Fisheries, 2007, University of Rhode Island, Kingston, Rhode Island . Thesis research: developed a spatially-explicit, age-based projection model in MATLAB to simulate the effects of gear selectivity and complex population structure on Gulf of Maine and Georges Bank Atlantic cod. Bachelor of Science, Biology and Society, 2004, Cornell University, Ithaca, New York . Focus in Marine Biology. Graduated with Distinction. School for Field Studies, Centro Para Estudios Costeros, Baja California Sur, Mexico Summer Study Abroad Program 2002, Conserving Coastal Diversity . Objective was to lay the groundwork for the establishment of a marine protected area in critical sea turtle habitat. Conducted turtle ecology research, habitat assessments, and public surveys, and developed environmental education programs for local schools.

PROFESSIONAL EXPERIENCE Principal Consultant/Owner June 2014-Present Shoal’s Edge Consulting, Port St. Lucie, FL . Provides scientific support and technical editing services for a variety of projects related to marine science, oil spill risk and impacts, and environmental permitting. Senior Biologist/Project Manager June 2010 – May 2014 Applied Science Associates, Inc. (dba RPS ASA), South Kingstown, RI . Worked as a project manager and technical specialist in environmental risk assessment, oil spill modeling, marine spatial planning, and marine science. Selected Project Experience: . Project manager for an assessment of marine oil spill risk in Alaska (client: NOAA). Developed a new spatial model of environmental vulnerability that was combined with probability of oil spills by region to determine geographic areas of highest risk. Also managed the development of a software tool to calculate, view, and export risk results.

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. Co-managed the development of a conceptual framework and approach for cumulative environmental impact evaluation of offshore renewable energy development (client: BOEM). Included the development of a new software tool for marine spatial planning and siting evaluation. . Modeled and analyzed surface and subsurface blowout oil spills in support of oil spill contingency planning for offshore oil and gas wells (Various projects). Has managed or conducted studies for more than 20 countries in Europe, Africa, South America, the Caribbean, and the Middle East. . Project manager for a modeling study of sea turtle hatchling dispersion in eastern Africa. . Co-managed the modeling and analysis of subsurface oil spills from more than 80 World War II-era shipwrecks to assess risks to ecological and socioeconomic resources of concern (client: NOAA). Areas modeled include the Gulf of Mexico, U.S. Atlantic and Pacific coasts, Hawaii, Alaska, the Caribbean, and U.S. Pacific Territories. . Project manager for an oil spill modeling study of potential future oil spills from a damaged platform in the Gulf of Mexico. Main objectives were to support the development of a response cost estimate and to estimate potential injuries/natural resource damages. . As a subcontractor to the federal third-party representative, supported the development of an EIS for a proposed offshore LNG terminal in the Caribbean. Managed RPS ASA staff and authored marine-science related sections. . As a subcontractor to the federal third-party representative, supported an EIS for a proposed natural gas pipeline lateral in the New York Bight. Managed RPS ASA staff. . Assisted in the application of a model to quantify relative environmental sensitivity of the marine habitats and ecosystems of the 26 U.S. Outer Continental Shelf planning areas (client: BOEM). . Assisted in the modeling of surface oil spills for the 26 U.S. Outer Continental Shelf planning areas, including the Gulf of Mexico and Arctic. The results are used as the basis for estimating oil spill- related costs in an Offshore Environmental Cost model used by BOEM. . As a subcontractor to the federal third-party representative, authored Essential Fish Habitat section of an EIS for a proposed offshore LNG terminal in the New York Bight. Managed RPS ASA staff. Environmental Consultant May 2007-June 2010 Natural Resource Group, LLC, Providence, RI . Worked as a protected species and marine resource specialist supporting the development and assessment of large energy infrastructure projects. Tasks included preparing state and federal permits, conducting feasibility studies and facility siting analysis, authoring resource sections of Environmental Impact Statements, survey planning and management, agency consultation, and stakeholder outreach. Selected Project Experience: . Environmental advisor for a proposed offshore facility south of Long Island and an associated offshore/onshore pipeline into the New Jersey/New York City area. Work included a multi-year siting assessment to identify environmental resources, regulatory requirements, issues and

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schedules, and survey requirements. The study also included a characterization of existing resources that would be affected by or influence pipeline siting. Project responsibilities included resource evaluations, development of offshore and onshore biological survey plans, hiring and management of subcontractors, and coordination with state and federal resource agencies. Also managed several studies relating to fisheries resources and stakeholders. . As a federal third-party representative, conducted stakeholder outreach at pre-filing open house and public scoping meetings and authored land use and Essential Fish Habitat (EFH) EIS sections for a natural gas pipeline and associated facilities in Connecticut and Massachusetts. . Project team member responsible for assisting with state protected species consultations and Native American tribal consultations for a compressor station in Michigan. . Project team member responsible for assisting with federal and state agency consultations regarding threatened and endangered species for a 50-mile-long pipeline through Connecticut, Long Island Sound, and New York. . Project team member supporting the permitting for the installation of three permanent coastal erosion control devices in Delaware. Specific project responsibilities included conducting wetland delineations, conducting protected species and EFH consultations, and preparing state and federal permit applications. . Designed and managed a field program for surveying boat traffic patterns for a proposed offshore LNG terminal in Massachusetts. Analyzed survey data and prepared reports. . As a federal third-party representative, authored marine mammal and sea turtle impact sections of a Biological Assessment for a proposed onshore LNG terminal in the Columbia River, Oregon. . As a federal third-party representative, authored water resources and fisheries sections of an Environmental Assessment for a 129-mile-long natural gas pipeline in Pennsylvania and New Jersey. The project included a pipeline crossing of a national wildlife refuge. Technical Assistant February 2009 Marine Research Institute, Yoh Yai Island, South Thailand . Provided diving and technical support to a marine aquaculture facility and breeding program being implemented by the Sustainable Development Research Foundation. Teaching Assistant August 2005-May 2007 University of Rhode Island, Fisheries Department, Kingston, RI . Assisted with teaching fisheries and marine science-related classes, tutoring students, and proctoring exams. Fish husbandry of aquaculture facilities. . Assisted with a study of cetacean interactions with midwater trawl fishing gear, with the goal of reducing bycatch. Involved working collaboratively with mid-Atlantic fishermen, both during workshops and time at sea on commercial fishing vessels. Field Research Assistant January-May 2005 Cornell University Bioacoustics Research Program, Isla Socorro, Mexico

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. Worked as a field research assistant for a behavioral study of breeding ground humpback whales on the remote island of Isla Socorro, Mexico. Monitored whales via photographic mark and release, collected tissue samples via biopsy, conducted acoustic sampling with boat-based and submerged hydrophones, and installed and retrieved underwater sensors via SCUBA. Developed proficiency in small boat handling. Research Diver July -August 2003 Guana Island, British Virgin Islands . As a scientific research diver, assisted in various aspects of marine epidemiology research on a species of reef fish. Mapped substrate distribution, conducted predator surveys, and carried out behavioral observations. Captured fish for tagging, along with other underwater tasks. CERTIFICATIONS . Associate Fisheries Professional (American Fisheries Society, 2009) . Rescue Diver (PADI, 2005) . Scientific Diver (American Academy of Underwater Sciences, 2003) . Open Water Diver (PADI, 2003)

ADDITIONAL TRAINING . Fundamentals of Successful Project Management (SkillPath, 2014) . Introduction to R for Fisheries Scientists (American Fisheries Society, 2010) . FERC Environmental Compliance Seminar (2007) . FERC Regulatory Overview and Guidance Seminar (2007) . Wetland Delineation with Field Practicum (Wetland Training Institute, 2007) . GIS for Field Scientists (Shoals Marine Lab, 2006) PROFESSIONAL AFFILIATIONS . Treasurer, International Fisheries Section, American Fisheries Society, 2014-present . Board of Directors Member-at-Large, American Fisheries Society Southern New England Chapter, 2008-2011 . Member, American Fisheries Society, 2007-present . Member, American Institute of Fishery Research Biologists, 2010-present . Member, American Academy of Underwater Sciences, 2003-present

SELECTED PUBLICATIONS Reich, D.A., Balouskus, R., French McCay, D., Etkin, D.S., Michel, J., and Lehto, J. 2014. An environmental vulnerability model for oil spill risk analyses: examples from an assessment for the State of Alaska. Proceedings of the 37th Arctic and Marine Oilspill Program (AMOP) Technical Seminar. Canmore, Alberta, Canada. Reich, D.A., Balouskus, R., French McCay, D., Fontenault, J., Rowe, J., Singer-Leavitt, Z., Etkin, D.S., Michel, J., Nixon, Z., Boring, C., McBrien, M., and Hay, B. 2014. Assessment of marine oil spill risk and environmental vulnerability for the state of Alaska. Prepared by RPS ASA, Environmental Research Consulting, Research Planning, Inc., and The Louis Berger Group, Inc. for the National Oceanic and

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Atmospheric Administration. Symons, L., Wagner, J., Delgado, J., Helton, D., Varmer, O., Gongaware, L., Michel, J., Weaver, J., Boring, C., Priest, B., Holmes, J., Early, W., Etkin, D., French McCay, D., Reich, D., Balouskus, R., Fontenault, J., Isaji, T., Mendelsohn, J., and McStay, L. 2013. Risk assessment for potentially polluting wrecks in U.S. waters. National Oceanic and Atmospheric Administration, Silver Spring, MD. French McCay, D., Reich, D., Michel, J., Etkin, D., Symons, L., Helton, D. and Wagner, J. Oil spill consequence analyses of potentially-polluting shipwrecks. 2012. Proceedings of the 35th Arctic and Marine Oilspill Program (AMOP) Technical Seminar. Vancouver, British Columbia, Canada. French McCay, D., Reich, D., Graham, E., Schroeder, M., and Shumchenia, E. 2012. Report on the framework for cumulative impact evaluation (Task 2.3). Pp 485-622 in: Developing Environmental Protocols and Modeling Tools to Support Ocean Renewable Energy and Stewardship. J. McCann. OCS Study BOEM 2012-082. U.S. Department of the Interior. Herndon, VA. French McCay, D., Reich, D., Rowe, J., Schroeder, M., and Graham, E. 2011. Oil spill modeling input to the Offshore Environmental Cost Model (OECM) for US-BOEMRE’s spill risk and costs evaluations. Proceedings of the 34th Arctic and Marine Oilspill Program (AMOP) Technical Seminar. Ottawa, Ontario, Canada. Reich, D. and DeAlteris, J. 2009. A simulation study of the effects of spatially complex population structure for Gulf of Maine Atlantic cod. North American Journal of Fisheries Management, 29:116-126. DeAlteris, J., Suyada, I., Reich, D., and Bennett, J. 2009. Spatial distribution of fishing activity in the New York Bight Apex: an analysis and interpretation of recreational and commercial fishing effort data. URI Fisheries Technical Report No. 09-013.

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1/21/2016 Melanie Gearon - Biologist M.S. Fisheries Science – University of Rhode Island - 2006 B.S. Marine Science – Long Island University - 2000 [email protected]

Areas of Expertise: Melanie Gearon has a broad scientific background which includes experience with fisheries ecology, stock assessment, benthic and shoreline ecology, ecological modeling, coastal alteration impacts and recovery, database management, statistics, biological oceanography, and aquatic resource management. While at RPS ASA she has gained 9 years of experience in biological modeling evaluating transport, spatial recruitment patterns, and fate and exposure of biota to oil and other chemical releases. Using these models she has performed impact, risk, and natural resource damage (NRD) assessments related to pollutants and development, as well as studies of the dynamics of aquatic biological populations and ecosystems. She has written several technical reports and EIS sections as part of the regulatory permitting and NEPA process for offshore energy development projects. Topic areas have included benthic impacts, EFH and fisheries impacts, ESA and marine mammal and turtle characterization and impacts. Ms. Gearon is a Biologist and Senior Project Manager at RPS ASA.

Experience Includes: RPS ASA 2006 to present

Marine Resource Characterization and Impact Analysis

 Project manager of a third party NEPA review of resource reports and writing EIS sections for a proposed LNG pipeline in Alaska.  Designed and managed field program for mapping benthic subtidal and intertidal habitat characteristics and quality pertaining to fish and shellfish for proposed remote LNG ship berth site and pipeline in Mount Hope Bay and the Taunton River, Massachusetts. Synthesized, mapped, and assessed habitat data for impacts of dredging and recovery time of resources removed.  Prepared Resource Reports of the marine affected environment submitted to FERC for the subsequent filing of permits for a proposed remote LNG ship berth site and pipeline in Mount Hope Bay and the Taunton River, Massachusetts.  Designed and managed field program that characterized the coastal habitat (shoreline and subtidal areas) of eastern Rhode Island and assessed potential impacts of lead emissions from a sporting activity club into the marine environment. Compiled environmental assessment document from using field data and literature. . Technical reviewer of a benthic monitoring program for a region of Lake Erie affected by thermal discharge from a coal burning plant on Lake Erie.  Third party NEPA review of biological resource reports and ecological risk assessment reports, compiled data gap requests for a proposed offshore oil offloading platform and pipeline in the Gulf of Mexico.  Wrote synthesis chapters characterizing the habitats and fish populations, and potential impacts to via gas and oil exploration/development, for the Southern California Bight in support of the MMS PEIS.

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Environmental Sensitivity and Ecological Evaluation for Marine Spatial Planning and Development Siting Assessments  Assisted in the development of a framework for modeling ecological values of marine biological resources, applied to the marine offshore area considered by the Rhode Island Ocean Special Area Management Plan (RI Ocean SAMP). The model was used to assess vulnerability of sites proposed for energy development projects. Conducted literature review on existing ecological valuation methods, including approaches applied in Marine Protected Area (MPA) assessments.  Under funding from Bureau of Ocean Energy, Management, Regulation and Enforcement (BOEMRE), and in partnership with the University of Rhode Island, assisted in the development of a conceptual framework and approach for cumulative environmental impact evaluation of offshore renewable energy development, as part of a larger framework for a site evaluation tool for decision makers. This extends the work on the RI Ocean SAMP to include consideration of cumulative impacts and a framework for application to offshore waters of the US.

Natural Resource Damage Assessment

 Provided technical support to NOAA’s Office of Response & Restoration / Assessment & Restoration Division and state trustees in on-going natural resource damage assessment cases including the Deepwater Horizon oil spill of April – July 2010. Designed and managed field programs to collect ephemeral biological data for all life stages of fish and invertebrates.  Used modeling to estimate potential worst-case natural resource damages resulting from an oil spill in the Calcasieu River and Estuary, Louisiana for the Trustees. Analyzed Louisiana state fish trawl data to attain biomass measurements for input to biological fates model. Researched benthic ecology and production rates for input to biological fates model.  Used modeling to estimate potential worst-case natural resource damages resulting from oil spills in the Eastern Caribbean for the Trustees. Analyzed Caribbean seabird and neuston density data to attain biomass measurements for input to biological fates model.  Used modeling to estimate potential worst-case natural resource damages resulting from an oil spill along the southwest coast of Puerto Rico for the Trustees. Analyzed Caribbean seabird, shorebird, reef fish, coral larvae, and neuston density data to attain biomass measurements for input to biological fates model.  Used modeling to estimate potential worst-case natural resource damages resulting from hurricane induced oil spills in Louisiana for the Trustees. Assisted in development of risk assessment modeling approach.

Oil Spill Fates and Effects Modeling

 Modeled worst case scenarios of hypothetical oil well blowout in the Chukchi Sea using stochastic component of SIMAP.  Carried out and assisted in the design of an oil spill risk assessment for an offshore oil unloading platform and pipeline in the Gulf of Mexico.

U.S. Environmental Protection Agency, Atlantic Ecology Division 2006  Assisted in design and set up of experiments investigating the effects of environmental stresses such as PCB exposure, low salinity, and low dissolved oxygen on the fish F. heteroclitus and the mysid A. bahia.

New York State Department of Environmental Conservation 2001 to 2003  Participated in the Peconic Bay fine mesh trawl survey, Port Jefferson Harbor beach seine survey, and the Great South Bay recreational party boat flatfish survey. Field duties encompassed operating and maintaining Appendix B: Author Qualifications and Resumes

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fishing gear and fishing vessel, species identification, counts, length measurements, and otolith/scale removal.

Publications

Ms. Gearon has authored and co-authored numerous technical reports and publications.

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1/21/2016 M. Conor McManus – Fisheries Scientist Ph.D. Oceanography – University of Rhode Island, Graduate School of Oceanography (in progress) M.S. Oceanography – University of Rhode Island, Graduate School of Oceanography - 2012 B.A. Marine Science – Boston University, College of Arts and Sciences - 2010 [email protected]

Areas of Expertise: Mr. McManus is a biological oceanographer for the environmental risk assessment group at RPS ASA. He specializes in database management and statistical analysis of long-term fisheries, environmental and meteorological surveys. As of late, much of his work as has been managing fisheries databases (for various fish life stages), calculating their presence against varying effort metrics and investigating how their populations’ growth varies with time and changes in the environment. He also aids in oil spill modelling development through oil’s exposure to various marine organisms. He has a strong background in marine science including marine fisheries and estuarine ecology, climate-oceanic interactions and physical-biological oceanographic dynamics. Prior to joining RPS ASA, Mr. McManus received his M.S. from the University of Rhode Island’s Graduate School of Oceanography, studying long-term oceanographic impacts on primary production rates in Massachusetts Bay. His bachelor’s research focused on understanding the life histories and trophic dynamics of various fish species in Stellwagen Bank. He has direct training in collecting, processing and analyzing various marine biological, climatologic, and oceanographic data. He has experience using ArcGIS, R, SAS, SigmaPlot and Matlab softwares in presenting, managing and analyzing data. Experience Includes: RPS ASA September 2012-Present Fisheries Scientist . Conducting research on marine species life history and behaviours in various ecosystems . Managing and performing statistical analyses on long-term fisheries, plankton, oceanographic (both in situ measurements and satellite derived) and sediment type datasets using various software platforms (Matlab, R, SAS). . Assisting in oil and chemical spill modelling projects and development. . Calculating marine organisms’ sensitivity to potential impacts of oil, gas and renewable energy developments in United States continental shelf waters using vulnerability assessment models. . Using non-linear modeling and statistical techniques to determine fish species’ life histories and catchability to various gear types.

University of Rhode Island, Graduate School of Oceanography Narragansett, RI June 2010- August 2012 Graduate Research Assistant . Estimated primary productivity in Massachusetts Bay using radioisotope tracer . Modeled water column metabolism rates in Narragansett Bay . Assisted in sampling and analyzing nutrient samples of coastal Rhode Island and Narragansett Bay . Collected and maintained long term chlorophyll, nutrient and water quality datasets Appendix B: Author Qualifications and Resumes

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. Performed over 40 scuba diving excursions for various scientific and technical projects . Participated in a Bermuda Atlantic Time Series Study cruise aboard the R/V Atlantic Explorer, assisting in primary production, sediment deposition, and plankton sampling

The Kaufman Lab, Boston University Boston, MA 2009-2010 Undergraduate Research Assistant . Conducted research on sand lance, Ammodytes sp., morphometry and trophic dynamics using stable isotope analysis Awards 2015 Alumni Award, University of Rhode Island, Graduate School of Oceanography 2015 Nature Conservancy Global Marine Initiative Student Research Award Program, University of Rhode Island 2012 Henry S. Farmer Award in Biological Oceanography, University of Rhode Island, Graduate School of Oceanography 2011 Alumni Award, University of Rhode Island, Graduate School of Oceanography 2011 Fillmore Memorial Scholarship Award, University of Rhode Island, Graduate School of Oceanography 2010 College Prize for Excellence in Marine Science, Boston University College of Arts & Sciences 2008 Capstone Award, Boston University College of General Studies

Selected Oral/Poster Presentations Oviatt, C., Smith, L., McManus, M.C., and Hyde, K. Decadal patterns of temperature, circulation, upwelling and fish: a conceptual framework. The Scott W. Nixon Symposium: Science Worth Noticing. Narragansett, RI. August 2013. McManus, M.C., Smith, L.M., Krumholz, J.S. and Oviatt, C.A. Using in situ metabolism estimates to identify ecosystem responses to environmental change in Narragansett Bay, RI. Association of Science for Limnology and Oceanography (ASLO) Aquatic Sciences Meeting, New Orleans, LA. February 2013. McManus, M.C. and Oviatt, C.A. Coastal current effects on primary production and implications for ecosystem dynamics in Massachusetts Bay. New England Estuary Research Society (NEERS) Fall Meeting. Block Island, RI. October 2012. McManus, M.C. & Oviatt, C.A. Investigating the potential causes and ecological impacts of reduced primary production in Massachusetts Bay. Coastal and Estuarine Research Federation (CERF), Daytona Beach, FL. November 2011.

Publications: McManus, M.C., Oviatt, C.A., Giblin, A.E., Tucker, J., and Turner, J.T. 2014. Western Maine Coastal Current reduces primary production rates, zooplankton abundance and benthic nutrient fluxes in Massachusetts Bay. ICES Journal of Marine Science 71 (5): 1158-1169. Libby, P.S., Borkman, D.G., Geyer, W.R., Turner, J.T., Keller, A.A., McManus, M.C. and Oviatt, C.A. 2011. 2010 Water Column Monitoring Results. Boston: Massachusetts Water Resources Authority, Report 2011- 12:1-36.

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McManus, M.C., Licandro, P., and Coombs, S.H. 2015. Is the Russell Cycle a true cycle? Multidecadal zooplankton and climate trends in the western English Channel. ICES Journal of Marine Science (in press) Oviatt, C., Smith, L., Krumholz, J., Coupland, K., Stoffel, H., Keller, A., McManus, C., and Reed, L. 2015. Managed nutrient reduction impacts on nutrient standing stock concentrations, metabolism and hypoxia in Narragansett Bay. Estuaries and Coasts (in review)

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1/21/2016 Richard Balouskus – Biologist B.S. Environmental Science (concentration: water resources) – University of Vermont -2005 M.S. Marine Studies (concentration: marine biosciences) – University of Delaware - 2012 [email protected]

Areas of Expertise: Mr. Richard Balouskus specializes in biological and environmental data collection, analysis and assessment, natural resource damage (NRD) assessments, GIS mapping and analysis, the study of watershed change impacts on estuarine, marine and freshwater environments and the development and application of environmental sensitivity and vulnerability models for oil spill risk and OCS development analyses. He has a strong background in quantitative assessment of biological and environmental data from a diverse range of ecosystems. He holds a M.S. degree from the University of Delaware, College of Earth, Ocean, and Environment, where his research focused on how watershed characteristics and shoreline development in salt marsh estuaries effect fish and invertebrate communities, estuarine dependent fish spawning, and water quality (particularly diel-cycling hypoxia). Prior to graduate school he worked for the Vermont Cooperative Fish and Wildlife Research Unit where he worked on a variety of riverine and lacustrine research projects including investigating sea lamprey control, trout population dynamics, invasive alewife expansion, and mudpuppy population assessment.

Experience Includes: RPS ASA 2011-Present Natural Resource Damage Assessments (NRDA)  Compiled literature and historic biological datasets to establish the pre-spill biological conditions in the Northern Gulf of Mexico for Deepwater Horizon Oil Spill NRDA.  Analysed historic datasets for fish and invertebrate density distributions over time and space for Deepwater Horizon Oil Spill NRDA.  Developed detailed life table model for analysis of fish and invertebrate species and subsequent calculation of production foregone.  Prepared datasets for biostatisticians, biologists, programmers, modellers, and managers to assist in analyses to determine the effects of the oil spill of fish and invertebrate populations for Deepwater Horizon Oil Spill NRDA.

Environmental Impacts – Environmental Sensitivity Evaluation . Assisted in research, development, and application for an Alaska/Arctic Oil Spill Risk Analysis for NOAA. The novel relative environmental risk model incorporated probabilities of spills occurring with respect to geographic location, source type, oil type and season as well as the impacts from an oil spill considering oil toxicity, persistence, and the vulnerability of the State’s marine and aquatic resources (marine, shoreline, and ice habitats, and species) at particular locations and times of year.  Under funding from Bureau of Ocean Energy Management (BOEM), assisted in research, development and application of a model to quantify relative environmental sensitivity of the marine habitats and ecosystems contained in BOEM’s Outer Continental Shelf (OCS) Planning Areas, including all Alaskan regions, in response to the expansion of BOEM regulation to include renewable energy development.

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Oil Spill Fates, Effects Modelling, and Risk Assessments

 Modelled subsurface oil spills from more than 20 World War II-era shipwrecks to assess risks to ecological and socioeconomic resources of concern. Areas modelled include the Gulf of Mexico, U.S. Atlantic and Pacific coasts, and U.S. Pacific Territories. Project received a NOAA Administrators Award for developing and implementing a groundbreaking approach to address the greatest pollution threats from undersea wrecks before spills occur.

University of Delaware 2008-2012 Graduate Research Assistant

 Thesis: "Natural and altered shorelines in tributaries of the Delaware Bay and Delaware coastal bays: Effects on marcofauna and diel-cycling hypoxia"  Examined the influence of shoreline type, diel-cycling hypoxia, and watershed landuse on the shore zone fish assemblage and blue crab abundance in estuarine tributaries of the Delaware Coastal Bays.  Responsible for collection and analysis of weekly estuarine macrofaunal samples. Marine biological community and related environmental conditions multivariate statistical analyses.  Investigated relationship between shoreline type and intertidal spawning of estuarine dependent fish species.

Vermont Cooperative Fish and Wildlife Research Unit, Burlington, Vermont 2004,2007-2008

Research Technician

 Aided in research investigating sea lamprey control and assessment utilizing pheromones. Setup and maintenance of experimental field sites, responsible for care, tagging and stocking of experimental fish. Additional responsibilities: fish trawling, mudpuppy collection, CTD operation, and hydroacoustic equipment support.  Member of research team investigating predation effects of avian fish predators and large salmonids on population structure of salmonid species in streams.  Additional responsibilities included electrofishing, ornithological field observations, and diet analysis.

Vermont Agency of Natural Resources, Burlington, Vermont 2005 Research Assistant

 Member of research team conducting stream geomorphic assessment with regards to storm water impacts. Completion of official stream geomorphic assessment forms (RSGA, RHA).  Analysis of watershed development impacts on the geomorphology and habitat condition of associated streambeds using ArcGIS.

Publications and Presentations

 Reich, D., R.G. Balouskus, D. French McCay, D.S. Etkin, J. Michel, and J. Lehto. 2014. An environmental vulnerability model for oil spill risk analyses: Examples from an assessment for the state of Alaska. Proceeding of the 38th Arctic and Marine Oilspill Program Technical Seminar (AMOP). In press.  Balouskus, R.G. and T.E. Targett. Fish and blue crab abundance along a riprap-sill hardened shoreline: comparisons with Spartina marsh and riprap. Submitted- Journal of Experimental Marine Biology Appendix B: Author Qualifications and Resumes

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 Balouskus, R.G. and T.E. Targett. 2012. Egg deposition by Atlantic silverside, Menidia menidia: Substrate utilization and comparison of natural and altered shoreline type. Estuaries and Coasts 35: 1100-1109.  Mr. Balouskus is author of over 5 articles in conference proceedings

Professional Memberships:

 American Fisheries Society  The Coastal Society

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1/21/2016 Zach Singer-Leavitt – Environmental Scientist M.S. Aquatic Science – University of Michigan B.A. Geography – Middlebury College [email protected]

Areas of Expertise: Zach Singer-Leavitt is a scientist at RPS ASA with a background in ecological statistics, spatial data analysis, aquatic biology, and seagoing surveys. At RPS ASA he supports environmental impact assessments and spatial data management. Prior to RPS ASA, he developed human use maps, habitat suitability models, and other seascape-scale data products for New York State’s marine spatial planning efforts through a NOAA Coastal Management Fellowship. His M.S. thesis focused on modelling habitat quality and water quality in Michigan lakes as a function of landscape variables. He recently received a certificate in statistical programming from the University of Washington. Experience Includes: RPS 2/2013 - present Environmental Scientist

 Assemble and process environmental datasets  Provide GIS and data analysis support to consultancy projects  Author technical guides, literature reviews, and reports on pollution modelling and damage assessment

NOAA/New York Department of State 8/2011 – 1/2013 Coastal Fellow

 Synthesize maritime human use data (e.g. commercial and recreational fishing, tribal uses) into spatial products  Assist in participatory GIS workshops with stakeholder groups (e.g. Shinnecock Indian Nation)  Develop spatially-explicit, geostatistical habitat models, multivariate community analyses, and visualizations of cetacean & benthic fish datasets in support of marine spatial planning  Communicate analytical methods to both scientific and general audiences  Compile existing research on environmental impacts of renewable energy projects  Manage GIS software acquisition contract

University of Michigan 1/2010 – 5/2010 and 1/2011 – 5/2011 Graduate Student Instructor

 Help teach GIS course to 40 undergraduates  Advise students on class projects and develop handouts and exams  Guest lecture on marine science applications of GIS  Grade homework, handle administrative issues

NOAA Biogeography Branch 9/2007 – 5/2009 Geospatial Analyst Appendix B: Author Qualifications and Resumes

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 Collect and classify video of coastal benthic habitats with underwater camera systems on 2-4 week research cruises  Integrate biological and physical habitat data in a GIS and deliver online to project partners and the public  Assist with collection of ground control points for positioning of satellite imagery  Write communication materials in Spanish and English explaining relevance of work to media and public  Supervise and train summer intern

Awards

 Wheeler Family Memorial Fellowship – $7,500  Sustainable Ecosystems Scholarship Fund – $7,500  Rackham Graduate Student Research Grant – $1,500  SNRE Thesis Funding Grant – $1,000

Presentations

 “Spatial Predictive Models of Summer Flounder Abundance in the New York Bight” NOAA NEFSC Flatfish Biology Conference (2012)  “Extending GIS with Statistical Models to Predict Marine Species Distributions” Northeast Arc Users Conference (2012)  “Modeling Groundfish Habitat in the NY Bight: A Tool for Marine Spatial Planning”  The Coastal Society (2012)  “Indicators and Drivers of Habitat Quality and Water Quality in Inland Michigan Lakes” American Museum of Natural History Student Conf. on Conservation Science (2012)

Volunteer

 Help run the National Ocean Science Bowl for the Michigan region (Spring 2011)  Contribute to student newsletter for the Aquatic Science graduate program (Spring 2011)

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Appendix C: Essential Fish Habitat (EFH) Analysis

The Magnuson-Stevens Fishery Conservation and Management Act (MSA) (Public Law 94-265, as amended), was established, along with other goals, to promote the protection of Essential Fish Habitat (EFH) in the review of projects conducted under Federal permits, licenses, or other authorities that affect or have the potential to affect such habitat. EFH is defined in the MSA as those waters (e.g., aquatic areas and their associated physical, chemical, and biological properties used by fish) and substrate (e.g., sediment, hard bottom, underlying structures, and associated biological communities) necessary for the spawning, feeding, or growth to maturity of managed fish species. The objective of this EFH evaluation is to describe potential adverse impacts to designated EFH for Federally-managed fish species within the action area of the proposed American Gold Seafoods (AGS) Marine Net Pen Relocation Project: Port Angeles-East. This appendix includes a description of EFH within the project action area, and a summary of the potential project impacts on EFH within the action area.

A full description of the proposed action and action area is provided in Chapter 1 of the AGS Marine Net Pen Relocation Project: Port Angeles-East Biological Evaluation (RPS ASA, January 2016). C.1 EFH Description

The NOAA Essential Fish Habitat (EFH) Mapper13 and supporting documents (PFMC 2005, PFMC 2014) were used to determine which managed fish and invertebrate species have designated EFH within the project action area. The EFH Mapper was also used to determine that there are no designated Habitat Areas of Particular Concern (HAPCs) in the vicinity of the project. The project action area has designated EFH for a total of 9 species/species groups (Table C-1).

TABLE C-1 Summary of Managed Fish and Invertebrate Species with Designated EFH in the Project Action Area Species Scientific Name Eggs Larvae Juveniles Adults Chinook Salmon Oncorhynchus tshawytscha - - X X Coho Salmon Oncorhynchus kisutch - - X X Pacific Coast Groundfish - X X X X Jack Mackerel Trachurus symmetricus - - - X Market Squid Loligo opalescens N/A N/A N/A X Northern Anchovy Engraulis mordax X X X X Pacific Sardine Sardinops sagax X X X X Pacific (Chub) Mackerel Scomber australasicus X X X X Puget Sound Pink Salmon Oncorhynchus gorbuscha - - X X Notes: “X” = Life stage has designated EFH in the NOAA EFH Mapper13 “N/A” = There are no EFH data available for this life stage of the species.

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Of these managed species with EFH in the project action area, chinook salmon (Puget Sound Evolutionary Significant Unit [ESU]) and chum salmon (Puget Sound/Strait of Georgia ESU) are Federally- listed as threatened species under the Endangered Species Act, and State-listed as candidate species. C.2 Potential Impacts to EFH

Potential impacts on each specific type of EFH are summarized at the end of this appendix in Table C-2. C.2.1 Potential Construction Phase Impacts

C.2.1.1 Seafloor Disturbance

Seafloor disturbance caused during construction could result in short-term, insignificant, direct adverse impacts on EFH. The mooring grid installation (Phase 1) will disturb benthic sediments in the immediate vicinity of each of the up to 60 steel wedge Danforth-type net pen anchors that will penetrate the substrate and be set into position. It is estimated that the installation process will take 1 to 2 hours per anchor, so direct impacts will be short-term. Sediment resuspension would be temporarily generated in isolated areas from the anchoring process. It is expected that motile fish species would readily avoid areas that could cause them discomfort or harm.

C.2.1.2 Noise

Construction and construction vessel operation would result in short-term increases in in-water noise. However, given the amount of existing vessel activity that presently occurs within the project action area, the impacts of construction noise on EFH are not likely to be significant.

C.2.1.3 Accidental Hydrocarbon Spills

Minor releases of hydrocarbons (e.g., fuel and lubricants) during construction of the proposed project could result in short-term, direct and indirect, adverse impacts on EFH and EFH species. These impacts would depend on the type and volume of the spill. These spills could originate from accidental spills from construction vessels; however, the likelihood of an accidental collision resulting in a fuel spill is very low, as vessels will be operating at slow speeds or complete stop during construction. The AGS Port Angeles-East marine net pen relocation project’s estimated construction period is 3 to 3.5 months, which would represent a negligible increase in fuel spill risk in the project action area, given the existing presence of a large number of U.S. Coast Guard vessels, U.S. Navy vessel, ferry vessels, fishing vessels, tow boats and other work boats, and recreational vessel traffic, all of which could be sources of hydrocarbon spills.

If minor releases of hydrocarbons were to occur, appropriate agency spill notifications, spill prevention plans, containment plans and clean-up measures will be implemented onboard work vessels. For these reasons, EFH impacts due to hydrocarbon spills are extremely unlikely and discountable. C.2.2 Potential Operational Phase Impacts

C.2.2.1 Seafloor Disturbance

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Anchor design and tension on the net pen mooring lines will maintain the lines in an upright position with no lateral movement, so prolonged impacts to the benthic environment around the anchors should be minimal (personal communication with Kevin Bright, Permit Coordinator, AGS, December 2015). As such, sediment resuspension impacts on EFH during operation are expected to be insignificant.

C.2.2.2 Noise

Operational vessel traffic associated with the proposed project will be on the order of 2 to 4 trips per day between Port Angeles Harbor and the net pen relocation site. This additional vessel traffic represents a negligible increase in the existing vessel activity present and ambient noise in the area; therefore, the impacts of operational noise on EFH are not likely to be significant.

C.2.2.3 Water Quality

Impacts to water quality during the operational phase of the project will be insignificant because the relocation site is in deep water (90 to 110 feet) that is well-flushed with fast tidal currents. Fish feed is carefully monitored with less than 1% waste (personal communication with Kevin Bright, Permit Coordinator, AGS, December 2015), so particulate matter settling out of the water column should be minimal.

Nutrient loading has the potential to cause impacts on benthic EFH, particularly within the 100-ft Sediment Impact Zone that will be established by the NPDES waste discharge permit around the net pen area. However, AGS will follow a sediment monitoring plan consistent with the terms and conditions of the NPDES permit issued by the Washington Department of Ecology within this zone to ensure that organic enrichment does not exceed standardized levels for marine sediments in the area. In the event that an exceedance of the State Sediment Management Standards were detected, active mitigation would be required. These measures may include additional sediment monitoring, possible reduction in feeding amounts, reduction in fish stocking biomass, fallowing the site to allow sediment recovery time, possible reorientation/relocation of the site to change the hydrodynamics of a farm, or removal and closure of the farm if mitigation measures do not alleviate the exceedance of sediment standards. Given the proposed monitoring and mitigation practices, adverse impacts on benthic EFH are expected to be insignificant.

C.2.2.4 Accidental Hydrocarbon Spills

Minor releases of hydrocarbons during project operation could result in short-term, minor, direct and indirect, adverse impacts on EFH species and EFH. These impacts would depend on the type and volume of the spill. The operational phase of the project will involve vessel trips between Port Angeles Harbor and the net pen relocation site. Two to four times per day, a crew vessel will transport employees and equipment to and from the marine net pen farm. Approximately once per week, a marine freight vessel will visit the floating net pen operation to deliver fish feed and water, and to remove wastes (sewage and trash) for disposal at existing, permitted land-based facilities. Diesel fuel deliveries to operate the generator will likely occur approximately once per month. The diesel engine that will operate in the feed support barge and an electrical generator will be a new piece of machinery, constructed to meet all current US EPA emission standards, and equipped with accidental spill containment measures. The double-walled tank will have a capacity of approximately 3,000 gallons. Other hazardous materials that would be kept on

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1/21/2016 the feed barge include small quantities of motor oil and antifreeze for operation of the diesel engine. Quantities of these products will be kept at a minimum.

If minor releases of hydrocarbons were to occur, appropriate agency spill notifications, spill prevention plans, containment plans and clean-up measures will be implemented. For these reasons, EFH impacts due to hydrocarbon spills are discountable.

C.2.2.5 Additional Mariculture-Related Impacts Commonly asked questions about the effects of mariculture in the marine environment include topics such as antibiotic impacts on the microbial community, disease and parasite transfer between farmed and wild fish, and accidental release of Atlantic salmon into the environment. Due to management practices implemented by AGS, these impacts are unlikely to occur, and are expected to have a discountable long-term impact on EFH. Additional information on these subjects, with citations for independent scientific studies that have been performed, is provided in Appendix D to the BE, titled Common Questions about Atlantic Salmon Net Pen Aquaculture. C.3 EFH Assessment Conclusions

The primary impacts on EFH species and EFH from construction activities include temporary displacement of EFH species and temporary habitat degradation associated with seafloor disturbance and temporary sediment resuspension. However, these effects would be very short in duration and highly localized, and thus the potential effects on EFH and EFH species are expected to be insignificant. Inadvertent spills of hydrocarbons could have direct and indirect adverse impacts on EFH; however a hydrocarbon spill is extremely unlikely to occur and these effects are discountable. Impacts of underwater construction noise on EFH are expected to be insignificant.

The primary impacts on EFH species and EFH from operation of the proposed project would include mariculture-related impacts and water quality impacts for benthic EFH. However, given AGS’ management and mitigation practices, these impacts are considered to be discountable to insignificant. Seafloor disturbance is expected to be insignificant and underwater noise impacts on EFH are expected to be discountable.

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TABLE C-2 Summary of the Proposed Action Impacts on EFH Impact Water Column EFH Benthic EFH CONSTRUCTION Seafloor disturbance  Short-term, insignificant, direct adverse impacts.  Short-term, insignificant, adverse direct impacts.  Temporary displacement of EFH species.  Temporary displacement of EFH species.

Noise  Short-term, discountable, direct impacts from  Short-term, discountable, direct impacts from construction and vessel noise. construction and vessel noise. Hydrocarbon spills  Short-term, discountable, direct and indirect adverse  Short-term, discountable, direct and indirect adverse impacts impacts OPERATION Seafloor disturbance  Long-term, insignificant, direct impacts  Long-term, insignificant, direct impacts. Noise  Long-term, insignificant, direct impacts  Long-term, insignificant, direct impacts Water quality impacts  Long-term, insignificant, direct impacts  Long-term, insignificant, direct and indirect adverse impacts. Hydrocarbon spills  Short-term, discountable, direct and indirect adverse  Short-term, discountable, direct and indirect adverse impacts impacts Additional mariculture-related  Long-term, discountable, direct and indirect adverse  Long-term, discountable, direct and indirect adverse impacts impacts. impacts.

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1/21/2016 C.4 References

Bright, Kevin. 2015. Permit Coordinator, American Gold Seafoods, Anacortes, WA. Personal communication by telephone with Alicia Morandi of RPS ASA, re: the use of vaccines and antibiotics on Atlantic salmon in marine net pen aquaculture and net pen array design and installation. December 2015.

National Oceanic and Atmospheric Administration (NOAA). 2016. EFH Mapper. Available online at: http://www.habitat.noaa.gov/protection/efh/efhmapper/. Accessed January, 2016.

Pacific Fishery Management Council (PFMC). 2005. Amendment 18 (Bycatch Mitigation Program), Amendment 19 (Essential Fish Habitat) to the Pacific Coast Groundfish Fishery Management Plan for the California, Oregon and Washington Groundfish Fishery. Available online: http://www.pcouncil.org/wp- content/uploads/fmpthru19.pdf.

Pacific Fishery Management Council (PFMC). Appendix A to the Pacific Coast Salmon Fishery Management Plan. Identification and Description of Essential Fish Habitat, Adverse Impacts and Recommended Conservation Measures for Salmon. Available online: http://www.pcouncil.org/salmon/fishery-management- plan/adoptedapproved-amendments/amendment-14-to-the-pacific-coast-salmon-plan-1997/

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Appendix D: Common Questions about Atlantic Salmon Net Pen Aquaculture (with References)

Supplemental Information Provided with Permit Applications for the American Gold Seafoods Marine Net Pen Relocation Project: Port Angeles ̶ East January 2016

Author: Kevin Bright, American Gold Seafoods, Inc.

This document provides an overview of environmental concerns that typically surround salmon net pen aquaculture in the Pacific Northwest, and includes citations to aid reviewers in finding relevant papers, studies and risk assessments that have studied these issues and report current findings.

Fish diseases, sea lice, fish escapes, water quality effects and benthic impacts are some areas of concern that have commonly been raised since the beginning of the net pen aquaculture industry in British Columbia and Washington State. Research and development of salmon net pen aquaculture in Washington State began in the 1960s and 1970s (Amos and Appleby 2001). During the past 40+ years, volumes of new scientific information, environmental monitoring data, and evolving regulatory performance standards have focused on addressing these environmental concerns. At the same time, progress has been occurring through the development of new fish farming technologies, improvements in fish culture techniques and new fish vaccines, refinements in fish diets and feed monitoring that have advanced the environmental performance of the marine aquaculture industry.

The issues of fish health and diseases, sea lice, escapement (accidental release), water quality effects and benthic impacts are discussed in four sections below, followed by citations for scientific papers that have investigated these potential concerns.

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D.1 Fish Health, Disease Control, and Applicable Regulations

The Washington Department of Fish and Wildlife (WDFW) has regulatory authority for disease prevention and control in the fish and wildlife in Washington State. WDFW regulates the movement of private sector cultured aquatic products through a Finfish Import and Transfer Permit (RCW 75.58.010). Private fish hatcheries are required to maintain health records and routinely test their cultured stocks for viral and bacterial disease. Fish Transport permits are only issued for stocks of fish shown to be negative for reportable fish pathogens. Licensed veterinary services and accredited veterinary labs are used by aquatic farmers to certify that brood stock fish and resulting fry are free of viral disease. The movement of live salmonids or gametes across state or international borders is strictly controlled by additional Federal regulations enforced by the U.S. Fish and Wildlife Service (USFWS) under Title 50 of the Code of Federal Regulations (Regulation 50 CFR, Part 16.13). These fish health regulations are management standards designed to control risk and reduce potential fish pathogens in private, public and tribal aquaculture facilities, and in wildlife in Washington State.

Since 2012, private marine salmon growers have been voluntarily working with WDFW, USFWS, and the USDA Animal and Plant Health Inspection Service (USDA APHIS) on a routine surveillance program for Infectious Salmon Anemia virus (ISAV). ISAV is a serious disease for cultured Atlantic salmon that has been found in other parts of the world. Increased surveillance and research is being conducted by both Canadian and U.S. animal health and fisheries agencies in Canada, Alaska, Washington and Oregon. To date, there have been no confirmed cases of the disease or positive identification of the virus found in any farmed Atlantic salmon or wild Pacific salmon populations.

Managers of aquaculture facilities prevent and control the risk of disease events by implementing structured disease prevention programs, technological advancements, vaccination, and best management practices. Effective programs include: 1) routine health exams by aquatic animal health specialists; 2) health inspections prior to movement of fish between regions or health management zones; 3) accurate record keeping by the farmer to include mortalities, growth, and feed conversion; 4) implementation of a bio- security plan for each farm site; and 5) use of preventative medicine such as vaccines and probiotics (Rust et al., November 2014).

Aquatic farmers have economic incentive to maintain the health of their fish stocks through the use of strict bio-security measures, disease control practices, 100% vaccination of the juvenile fish prior to transfer to marine net pens, and maintaining growing conditions conducive to healthy and fast-growing fish populations. Hatcheries use sterile water supplies and a captive brood stock program that reduce or completely eliminate potential disease vectors. All adult brood fish are screened for viral and bacterial pathogens during spawning by a licensed veterinary service to verify the disease-free status of the brood stock and the resultant gametes. Washington marine finfish farms employ full-time fish health professionals to administer bio-security protocols and routinely monitor the health status at the farm sites.

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REFERENCES RE: FISH HEALTH AND DISEASE CONTROL

Amos, K.H., and A. Appleby. September 1999. Atlantic salmon in Washington State: A fish management perspective. Washington Department of Fish and Wildlife. Amos, K.H., and J. Thomas. 2002. Disease interactions between wild and cultured fish: Observations and lessons learned in the Pacific Northwest. Bulletin of the European Association of Fish Pathologists 22:95-102. Amos, K.H., A. Appleby, J. Thomas, and D. Seiler. 2001. Atlantic salmon (Salmo salar) in the Pacific Northwest: Assessing the risk of impact on wild Pacific salmon. Pages 193-201 in C.J. Rodgers, editor. Proceedings of an international conference on risk analysis in aquatic animal health. World Organization for Animal Health. Paris, France. In Rust et al., November 2014. Amos, K.H., J. Thomas, and B. Stewart. 2001. Pathogen transmission between wild and cultured salmonids: Risk avoidance in Washington State, United States of America. Pages 83-89 in C.J. Rodgers, editor. Proceedings of an international conference on risk analysis in aquatic animal health. World Organization for Animal Health. Paris, France. In Rust et al., November 2014. Amos, K.H., L. Gustafson, J. Warg, J. Whaley, M. Purcell, J. Rolland, J. Winton, K. Snekvik, T. Meyers, B. Stewart, J. Kerwin, M. Blair, J. Bader, and J. Evered. 2014. U.S. response to a report of infectious salmon anemia virus in western North America. Fisheries 39:501-506. Moffitt, C.J. B. Stewart, S. Lapatra, R. Brunson, J. Bartholomew, J. Peterson, and K.H. Amos. 1998. Pathogens and diseases of fish in aquatic ecosystems: Implications in fisheries management. Journal of Aquatic Animal Health 10:95-100. In Rust et al., November 2014. Nash, C.E., 2001. The net pen salmon farming industry of the Pacific Northwest. National Oceanic and Atmospheric Administration, Technical Memorandum NMFS-NWFSC-49. Silver Spring, MD. Nash, C.E., P.R. Burbridge, and J.K. Volkman. 2005. Guidelines for the ecological risk assessment of marine fish aquaculture. National Oceanic and Atmospheric Administration, Technical Memorandum NMFS-NWFSC-71. Silver Spring, MD. Nash, C.E., and F.W. Waknitz. 2003. Interactions of Atlantic salmon in the Pacific Northwest. I. Salmon enhancement and the net-pen farming industry. Fisheries Research Journal 62:237–254. Normandeau Associates and Battelle. 2003. Maine aquaculture review. A review of the State of Maine’s monitoring and management system. Prepared for Maine Department of Marine Resources. Report R-19336.000. West Boothbay Harbor, ME. 54 pp. http://mainegov-images.informe.org/dmr/aquaculture/reports/MaineAquacultureReview.pdf Price, C.S. and J.A. Morris, Jr. 2013. Marine cage culture and the environment: Twenty-first century science informing a sustainable industry. National Oceanic and Atmospheric Administration. Technical Memorandum NOS-NCCOS-164. Silver Spring, MD. Rust, Michael B., Kevin Amos and April Bagwill, Office of Aquaculture, National Marine Fisheries Service (NMFS), National Oceanic and Atmospheric Administration (NOAA), Silver Spring, MD; Walton Dickhoff, Northwest Fisheries Science Center, NMFS/NOAA, Seattle, WA; Lorenzo Juarez, Office of Aquaculture,

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NMFS/NOAA, Silver Spring, MD; Carol Price and James Morris, Jr., Center for Coastal Fisheries and Habitat Research, National Ocean Service/NOAA, Beaufort, NC; and Michael Rubino, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD. November 2014. Environmental Performance of Marine Net-Pen Aquaculture in the United States. Fisheries 39: 11. www.fisheries.org. Waknitz, F.H. et al. 2002. Review of potential impacts of Atlantic salmon culture on Puget Sound Chinook salmon and Hood Canal summer‐run chum salmon Evolutionarily Significant Units. NOAA Technical Memorandum NMFS‐NWFSC 53. 98 pp. Waknitz, F.W., R.H. Iwamoto, and M.S. Strom. 2003. Interactions of Atlantic salmon in the Pacific Northwest. IV. Impacts on the local ecosystems. Fisheries Research Journal. 62:307–328.

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D.2 Sea Lice

Sea lice have varying effects on wild and farmed fish depending on geographic location, ocean salinity, temperature, and infected fish populations in the vicinity (Jackson et al. 2012, as cited in Rust et al., 2014). Sea lice are a normal parasite that can be found on wild salmon and other fish in Washington, and therefore represent nothing new or exotic to the life cycle of Pacific salmon. Within Washington State, sea lice infestations of farmed salmon have never been an issue because net pens are located in areas where the salinity is too low for lice proliferation (Nash et al. 2005 as cited in Rust et al., November 2014). Salinity levels in Puget Sound and the Strait of Juan de Fuca are typically less than the oceanic salinity levels, as a result of the seasonal influx of snowpack runoff from large river systems and average rainfall amounts in the Puget Sound basin. Research has shown that the survival of free-swimming sea lice copepodids (the larval stage) is severely compromised at salinity levels below 29 parts per thousand (ppt) (Bricknell 2006). Washington net pen salmon farmers utilize a single-generation production strategy with a fallow period for the farm sites between fish generations. The single-generation management strategy used by marine net pen operators, and the reduced salinity levels of Puget Sound and the Strait of Juan de Fuca, appear to break the successful life cycle of sea lice on Washington farmed salmon stocks.

REFERENCES RE: SEA LICE

Amos, K.H., and A. Appleby. September 1999. Atlantic salmon in Washington State: A fish management perspective. Washington Department of Fish and Wildlife. Olympia, WA. K.H. Amos, A. Appleby, J. Thomas, and D. Seiler. 2000. Atlantic salmon (Salmo salar) in the Pacific Northwest: Assessing the risk of impact on wild Pacific salmon. Proceedings of an international conference on risk analysis in aquatic animal health, World Organization for Animal Health (OIE), Paris, France. pp. 193-201. Bricknell, I.R., S.J. Dalesman, B. O'Shea, C.P. Pert, and A.J.M. Luntz. 2006. Effect of environmental salinity on sea lice Lepeophtheirus salmonis settlement success. Diseases of Aquatic Organisms 71: 201-212. Brooks, K. M. 2005. The effects of water temperature, salinity, and currents on the survival and distribution of the infective copepodid stage of sea lice (Lepeophtheirus salmonis) originating on Atlantic salmon farms in the Broughton Archipelago of British Columbia, Canada. Reviews in Fisheries Science, 13: pp. 177‐204. McVicar, A.H. 1997. Disease and parasite implications of the coexistence of wild and cultured Atlantic salmon populations. ICES Journal of Marine Science 54:1093-1103. In Rust et al., November 2014. Rust, Michael B., Kevin Amos and April Bagwill, Office of Aquaculture, National Marine Fisheries Service (NMFS), National Oceanic and Atmospheric Administration (NOAA), Silver Spring, MD; Walton Dickhoff, Northwest Fisheries Science Center, NMFS/NOAA, Seattle, WA; Lorenzo Juarez, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD; Carol Price and James Morris, Jr., Center for Coastal Fisheries and Habitat Research, National Ocean Service/NOAA, Beaufort, NC; and Michael Rubino, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD. November 2014. Environmental Performance of Marine Net-Pen Aquaculture in the United States. Fisheries 39: 11. www.fisheries.org.

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D.3 Accidental Release of Cultured Fish Stock

Atlantic salmon that accidentally escape from marine net pens have the potential to impact native fish stocks if the escapes are large and occur on a regular basis. Many factors determine whether any impact will occur and whether the impact will be significant; for example, the number, size, and location of the escape; the time of the escape; and the fisheries that are occurring in the vicinity of the escape. Of interest to fishery managers are the potential effects of Atlantic salmon on wild salmon, particularly ESA-listed species of Pacific salmon, in the form of competition, predation, disease transfer, hybridization, and the possibility of colonization. A white paper titled Atlantic Salmon in Washington State: A Fish Management Perspective prepared by staff of the Washington Department of Fish & Wildlife addresses these concerns (Amos and Appleby, WDFW, September 1999).

Competition. Because cultured Atlantic salmon stocks have been bred and reared in captivity for generations and have become highly domesticated in nature, it is likely that many Atlantic salmon quickly perish if they escape, due to their inability to find food and lack of predator avoidance traits. Escaped Atlantic salmon that have been recaptured and analyzed in Washington had empty stomachs and swollen gall bladders, indicative of not eating (Amos and Appleby, WDFW, September 1999).

Predation. Another concern is the potential for escaped Atlantic salmon to prey on other fish species, particularly juvenile wild salmon. Atlantic salmon are fed large pellets in the marine net pens, so it is not within their normal behavior pattern to capture and feed on live prey (Thomson et al., 1993-1997, as cited in Amos and Appleby, WDFW, September 1999).

Disease Transfer. Infectious diseases are caused by fish pathogens including bacteria, viruses, parasites, and fungal infections. Fish pathogens that can cause serious disease outbreaks are regulated by WDFW, requiring aquaculture managers to report occurrences. Atlantic salmon stocks in Washington are extensively screened on an annual basis for regulated pathogens. All of the fish pathogens that have been isolated from Atlantic salmon in Washington appear to have historically existed in wild fish species in the State. Evidence suggests that the source of pathogens that infect both Pacific and Atlantic salmon originated from wild fish (both salmonids and non-salmonids) that occur naturally in Washington State waters (Amos and Appleby, WDFW, September 1999; and Rust et al., November 2014).

Should escapees carry a disease agent, the risk of them being the source of an outbreak in wild fish is low for the following reasons (Amos, Thomas and Stewart 2001, as cited in Rust et al., November 2014): 1) Native pathogens are already a part of the environment where wild fish are routinely exposed and have developed some natural immunity 2) Escapees are unlikely to generate an infectious dose (or infective pressure) sufficient to result in disease in a healthy wild population 3) The mere presence of a pathogen alone will not cause disease without environmental factors that play a large role in triggering disease events (McVicar 1997; Moffitt et al. 1998; and Amos, Appleby et al. 2001 as cited in Rust et al., November 2014), and

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4) Most escaped farmed fish have low fitness for the wild and quickly become easy victims of predators such as marine mammals, other fish, and birds.

Hybridization. If escaped Atlantic salmon were to successfully mate with a Pacific salmon adult and produce offspring, there is concern that these offspring would contaminate the integrity of the gene pool of native Pacific salmon species. This has been determined to be an unlikely event. First, the process of mate selection by Pacific salmon would tend to exclude an Atlantic salmon.14 Second, laboratory studies conducted under ideal conditions have had great difficulty producing offspring from such a mating; and finally, even if a successful mating were to occur and offspring were to be produced, the offspring would be sterile and unable to reproduce themselves. For all of these reasons, the risk of escaped Atlantic salmon hybridizing with native Pacific salmonid species and causing an impact to the gene pool is considered very low (Amos and Appleby, WDFW, September 1999).

Colonization. Due to the desirability of Atlantic salmon in recreational fisheries, attempts were made by fish and wildlife agencies during the 20th century to introduce and establish this species in Washington, without success. WDFW released Atlantic salmon smolts for the purpose of establishing runs in 1951, 1980, and 1981. Many releases were also made in lakes; however, none of these resulted in the return of adult Atlantic salmon. For colonization to occur, Atlantic salmon would need to be successful in each step of a complicated life history, and complete the life history in numbers sufficient to perpetuate the stock. Attempts throughout the United States and world to introduce and establish Atlantic salmon outside the Atlantic Ocean have failed (Amos and Appleby, WDFW, September 1999). Farmed Atlantic salmon have been reared in Washington hatcheries and marine net pens since the 1970s and have become more domesticated than any salmon species in recent history. The capability of farmed Atlantic salmon to survive, reproduce and colonize in the wild is significantly diminished.

REFERENCES RE: ACCIDENTAL RELEASE OF CULTURED FISH STOCK

Amos, K.H., and A. Appleby. September 1999. Atlantic salmon in Washington State: A fish management perspective. Washington Department of Fish and Wildlife. Olympia, WA. Amos, K.H., A. Appleby, J. Thomas, and D. Seiler. 2001. Atlantic salmon (Salmo salar) in the Pacific Northwest: Assessing the risk of impact on wild Pacific salmon. Pages 193-201 in C.J. Rodgers, editor. Proceedings of an international conference on risk analysis in aquatic animal health. World Organization for Animal Health. Paris, France. In Rust et al., November 2014. Amos, K.H., J. Thomas, and B. Stewart. 2001. Pathogen transmission between wild and cultured salmonids: Risk avoidance in Washington State, United States of America. Pages 83-89 in C.J. Rodgers, editor. Proceedings of an international conference on risk analysis in aquatic animal health. World Organization for Animal Health. Paris, France. In Rust et al., November 2014.

14 Pacific salmon species develop distinctive coloration and morphological changes prior to spawning that facilitate selection of the same species during spawning. In the Pacific Northwest, multiple species of Pacific salmon occur in the same river systems during the same spawning periods, and hybridization between the different Pacific salmon species is extremely rare to non-existent. The same natural selective process inhibits the successful pairing of Atlantic salmon and Pacific salmon. Appendix D: Common Questions about Atlantic Salmon Net Pen Aquaculture

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Environmental Assessment Office (EAO). 1997. British Columbia salmon aquaculture review. Environmental Assessment Office, Government of British Columbia, Canada. http://www.eao.gov.bc.ca/epic/output/html/deploy/epic_project_doc_list_20_r_com.html

Nash, C.E. 2003. Interactions of Atlantic salmon in the Pacific Northwest VI. A synopsis of risk and uncertainty. Fisheries Research Journal 62:339-347. Summary of several journal publications arising from the NOAA technical memorandum including: Nash, C.E. (editor). 2001. The net-pen salmon farming industry in the Pacific Northwest. NOAA Technical Memo. NMFS-NWFSC-49. 125 p. http://www.nwfsc.noaa.gov/publications/techmemos/tm49/tm49.pdf

Nash, C.E., and F.W. Waknitz. 2003. Interactions of Atlantic salmon in the Pacific Northwest. I. Salmon enhancement and the net-pen farming industry. Fisheries Research Journal 62:237–254.

Rust, Michael B., Kevin Amos and April Bagwill, Office of Aquaculture, National Marine Fisheries Service (NMFS), National Oceanic and Atmospheric Administration (NOAA), Silver Spring, MD; Walton Dickhoff, Northwest Fisheries Science Center, NMFS/NOAA, Seattle, WA; Lorenzo Juarez, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD; Carol Price and James Morris, Jr., Center for Coastal Fisheries and Habitat Research, National Ocean Service/NOAA, Beaufort, NC; and Michael Rubino, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD. November 2014. Environmental Performance of Marine Net-Pen Aquaculture in the United States. Fisheries 39: 11. www.fisheries.org. Stickney, R.R., and J.P. McVey (Eds). 2002. Responsible marine aquaculture. CAB International, New York, NY. 391 pp. Recent work with examples of integrated aquaculture. Thomas, A.J. and S. McKinnell. 1993 ̶ 1997. Summary of reported Atlantic salmon (Salmo salar) catches and sightings in British Columbia and adjacent waters. Canadian Manuscript Report of Fisheries and Aquatic Sciences. Public Works and Government Services Canada, Publishing and Depository Services. Ottawa, Ontario. In Amos and Appleby (September 1999). Waknitz, F.H. et al. 2002. Review of potential impacts of Atlantic salmon culture on Puget Sound Chinook salmon and Hood Canal summer‐run chum Salmon Evolutionarily Significant Units. NOAA Technical Memorandum NMFS‐NWFSC 53. 98 pp. Waknitz, F.W., R.N. Iwamoto, and M.S. Strom. 2003. Interactions of Atlantic salmon in the Pacific Northwest. IV. Impacts on the local ecosystems. Fisheries Research Journal 62:307–328.

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D.4 Water Quality, Sediment Chemistry and Regulatory Performance Standards

Marine net pen operations discharge nutrients directly into the ocean from the metabolic waste products of the captive fish stocks and any uneaten fish feed. Negative effects can occur if the nutrient input exceeds the natural assimilative properties of the surrounding environment. The Washington Department of Ecology (Ecology) has regulatory authority over the discharges from marine salmon net pen facilities. State guidelines require net pen sites to be located in strong current locations that facilitate the biological, mechanical and chemical assimilation of these nutrients. Since 1996, Ecology has required finfish aquaculture operations to obtain a National Pollutant Discharge Elimination System (NPDES) permit. This Clean Water Act waste discharge permit requires monitoring, reporting, operational guidelines, Best Management Practices (BMPs), and Best Available Technology (BAT) at each aquaculture facility to minimize or eliminate pollution. A key component of the NPDES permit is definition of a Sediment Impact Zone (SIZ) and Total Organic Carbon (TOC) monitoring. Organic carbon compounds (from uneaten feed and fish wastes) are the main discharge of nutrients from a salmon net pen operation. The NPDES permit requires that carbon level readings of the sediment sampled at the 100-ft perimeter around a net pen facility (i.e., at the SIZ boundary) be at the ambient organic carbon levels found in similar sediments at pristine reference locations in Puget Sound. These standards are in place for the protection of benthic organisms and the marine environment, and demonstrate that nutrient wastes are being monitored and managed properly. The NPDES Individual Permit incorporates site-specific conditions, limitations, ongoing water quality and benthic monitoring and reporting procedures designed to protect public health and safety, and meet State Surface Water Quality Standards (Chapter 173-201A WAC), and State Sediment Management Standards (Chapter 173-204 WAC).

REFERENCES RE: WATER QUALITY, SEDIMENT CHEMISTRY, REGULATORY PERFORMANCE STANDARDS

Brooks, K.M., and C.V.W. Mahnken. 2003a. Interactions of Atlantic salmon in the Pacific Northwest. II. Organic wastes. Fisheries Research Journal 62:255–293. Brooks, K.M., and C.V.W. Mahnken. 2003b. Interactions of Atlantic salmon in the Pacific Northwest. III. Accumulation of zinc and copper. Fisheries Research Journal 62:295–305. Normandeau Associates and Battelle. 2003. Maine aquaculture review. A review of State of Maine’s monitoring and management system. Prepared for Maine Department of Marine Resources. Report R-19336.000 West Boothbay Harbor, ME. 54 pp. http://mainegov-images.informe.org/dmr/aquaculture/reports/MaineAquacultureReview.pdf Parametrix, Inc.. 1990. Final programmatic environmental impact statement: Fish culture in floating net- pens. Prepared by Parametrix, Inc., Rensel Associates, and Aquametrix, Inc. for the Washington State Department of Fisheries. Olympia, WA. 161 pp. Price, C.S. and J.A. Morris, Jr. 2013. Marine cage culture and the environment: Twenty-first century science informing a sustainable industry. National Oceanic and Atmospheric Administration. Technical Memorandum NOS-NCCOS-164. Silver Spring, MD.

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Rensel, J.E., and J.R.M. Forster. 2007. Beneficial environmental effects of marine finfish mariculture. Final report to the National Oceanic and Atmospheric Administration (NOAA). Washington, D.C. NA040AR4170130. Available at www.wfga.net Rensel, J.E. and J.R.M. Forster. 2002. Strait of Juan de Fuca, offshore finfish mariculture: Literature review and preliminary field study results. Prepared for National Marine Fisheries Service. National Marine Aquaculture Initiative. 87 pp. Rensel, J.E., D.A. Keifer, J.R.M. Forster, D.L. Woodruff, and N.R. Evans. 2007. Offshore finfish mariculture in the Strait of Juan de Fuca. Bulletin of the Fisheries Research Agency 19:113-129. Rensel, J.E. 2001. Salmon net pens in Puget Sound: Rules, performance criteria and monitoring. Global Aquaculture Advocate 4(1):66-69. http://www.wfga.net/sjdf/reports/regulations.pdf A brief overview and review of the Washington State regulatory system for net pens. Rensel, J. E. and J.N.C. Whyte. 2003. Finfish mariculture and harmful algal blooms. Second Edition. pp. 693-722 In: UNESCO Manual on Harmful Marine Microalgae. D. Anderson, G. Hallegaeff and A. Cembella (eds). IOC monograph on Oceanographic Methodology. Rensel Associates and PTI Environmental Services. 1991. Nutrients and phytoplankton in Puget Sound. Peer-reviewed monograph prepared for the U.S. Environmental Protection Agency (EPA), Region X. Seattle, WA. Report 910/9-91-002. 130 pp. Rust, Michael B., Kevin Amos and April Bagwill, Office of Aquaculture, National Marine Fisheries Service (NMFS), National Oceanic and Atmospheric Administration (NOAA), Silver Spring, MD; Walton Dickhoff, Northwest Fisheries Science Center, NMFS/NOAA, Seattle, WA; Lorenzo Juarez, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD; Carol Price and James Morris, Jr., Center for Coastal Fisheries and Habitat Research, National Ocean Service/NOAA, Beaufort, NC; and Michael Rubino, Office of Aquaculture, NMFS/NOAA, Silver Spring, MD. November 2014. Environmental Performance of Marine Net-Pen Aquaculture in the United States. Fisheries 39: 11. www.fisheries.org. Soto, D. and F. Norambuena. 2004. Evaluation of salmon farming effects on marine systems in the inner seas of southern Chile: a large-scale measurative experiment. Journal of Applied Ichthyology 20: 493- 501. In Rust et al., November 2014.

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