Experts Question Coast Oyster Expansion Plan
Has Coast done enough to demonstrate that vulnerable species will remain strong and healthy? With the Bay in recovery from various damaging practices of the past, is it possible more oysters could actually lead to improved conditions in the Bay?
The proposed expansion described in the Draft Environmental Impact Report, which received 222 comments from government agencies, non-governmental organizations and private citizens, provoked concerns that inadequate mitigation of impacts was demonstrated by the report and would be costly to the environmental and recreational integrity of Humboldt Bay.
Coast Seafood prepared its 400+ page FEIR, responding to the comments and grouping some of the responses into “Topical Responses” when concerns were raised by numerous commenters. The document which includes all of the comments can be found here.
Permits granted in 2006 for Coast Seafood’s current 300-acre operation have expired, and it now seeks to expand its operating area to as much as 509 acres in two phases. After the initial proposal for a 600+-acre expansion resulted in an EIR that met with such strong resistance that even Coast’s own advisors decided to withdraw it and recirculate a new draft EIR, two subsequent reports have given the impression that concerns have been addressed, but that is not how all local wildlife and hunting advocates see it. Nevertheless, the Harbor District has indicated that it intends to certify the document, allowing Coast to proceed with applying for permits needed from the various government agencies required to sign off on the project.
Greg Dale, who is both Operations Manager for Coast Seafoods and a member of the Harbor commission is confident that the science shown in the FEIR adequately demonstrates that no significant impacts to the species of concern or the overall bay environment will occur, and that “we are going to monitor the heck out of it” to ensure that is the case.
The 300 acres already farmed by Coast will remain intact with the original style of 2.5 foot spacing between growing structures. According to Dale, this area has actually seen an increase in the presence of eelgrass, one of the crucial species of concern, due to the plant’s recovery from the devastating effects of past practices of dredge-style farming that destroyed the vital plant.
In Phase 1 of the proposed expansion, Coast will add 165 acres of growing area and will seek to mitigate any negative effects on eelgrass in these new areas by spacing the equipment at 9-16 feet apart. Should monitoring over roughly five years show that there has been no significant impact on eelgrass and associated species, phase 2 may be implemented, adding another 90 acres to the growing operation. Phase 1 also includes removal of 42 acres of oyster operations in a particularly sensitive area.
Several sensitive and vital species, as well as overall environmental quality are addressed by the FEIR, but doubts remain among local experts whether water temperature fluctuation, rise of sea level, natural and unpredictable population fluctuation, and other factors have been addressed in a holistic way. Even where scientific research has been cited on both sides, there appear to be conflicts in accuracy of information.
The sensitive species in question include the Pacific “black” Brant, a migratory goose that relies on feeding in Humboldt Bay on its journey to Arctic breeding grounds from its wintering home in Mexico each year. The Brant is a species that can be hunted on Humboldt Bay, providing not only recreational enjoyment to local families, but also considerable income to local outfitters who bring in as much as $500 per day to guide hunters to the geese, as well as to restaurants and motels serving the hunters. Several commenters on the DEIR stated that they and their families have been enjoying goose hunting on the bay for generations and that the deep connection to the Bay environment was an important part of Humboldt life. The geese are also part of the world class birdwatching for which Humboldt Bay is known.
The health of a sizeable brant population is also important to many recreational users of the bay, especially waterfowl hunters who have generations of experience observing brant behavior and reaction to oyster farming structures. Stan Brandenburg, local brant hunter, contributed the following comment to the REIR:
Another species likely to be negatively affected is the Pacific Herring, an important food and bait fish that spawns in the bay. The Pacific Fisheries Management Council, which is not obliged to weigh in on this proposal has written to the Harbor District expressing objections to the Coast expansion. Local commercial fisherman, Ken Bates, fished herring for many years before the local ice business closure forced him to stop eight years ago. He said herring is critical to migrating bird populations because spawning takes place in the winter months directly onto eelgrass beds, especially in the East Bay and Gunther Island areas. For example, if 100 tons of herring spawn in a single event, they deposit twelve and a half tons of eggs, 50-60% of which is consumed by northbound migrant birds who need the rich food to prepare for travelling onward to and breeding in the Arctic.
To allow this plan to proceed would remove all gains to the health of our magnificent estuary over the last 20 years and would be an egregious violation of the Public Trust. I am a former local commercial fisherman and logger and I know from personal experience that the ones who suffer from the aftermath of collapse are not the ones with fat bank accounts from extraction; it is always the land, the fish, wildlife and the people who work it.
Remember the consequences of poor farming practices in the Prairie States? History remembers it as the Dustbowl. Let’s not turn North Humboldt Bay into a Mudbowl by allowing this proposal to succeed. It must be remembered that the primary management objective for north bay is the preservation of the eelgrass and the bays other environmental values.(ch. 5.1 hbhrcd management plan) Humboldt Bay is the only estuary left in OR and CA with significant eelgrass left for the brant, whose successful migration and breeding in far northern arctic areas is dependent on getting enough fat reserves from the high nutrient value eelgrass they are dependent upon, as well as not being disturbed during their spring staging.
Bates said that Coast is required by law to stop operations when herring are spawning, but to his knowledge Coast has never reported any required cessation during this sensitive time in the fish’s life cycle. He is also discouraged by the amount of oyster farming debris he pulls out of the water as well as that which washes up onshore. “Coast has 40 miles of 3/4 inch PVC pipe in north bay mud, and 60-80 miles of yellow polypropylene rope in the water,” he said.
When this material breaks loose from the farming infrastructure it pollutes the bay. and the beaches around it. Bates frequently finds it in his fish nets, along with black ABS pipe, plastic culture trays, plastic tags, and vexar bags. The DEIR’s response is that Coast will improve its monitoring and recovery of debris. However, Bates is skeptical and feels Coast Seafood doesn’t care, in contrast to small growers whose growing areas are “immaculate.”At the bottom of this vital chain lies the humblest but most important link, eelgrass. The aquatic plant grows in a variety of densities in Humboldt Bay and provides necessary food for the Brant, and spawning material for the herring. Even after it has expired, eelgrass washed up on shore provides all kinds of creatures food and foraging opportunities. The importance of Humboldt’s eelgrass population is augmented by the fact that it now represents nearly half of all eelgrass beds in the state since Morro Bay’s devastating crash, which depleted its beds from 346 acres to just 10 acres between 2007 and 2013. Eelgrass has suffered devastating global depletion through environmental neglect. For more on Eelgrass, go here.
That oyster farming can degrade Eelgrass and the web of life dependent on its vitality, is not disputed by anyone. What is up for discussion is whether or not the Harbor District Commission has adequately considered the effects of Coast Seafood’s proposed expansion. At least one local wildlife biologist, California Waterfowl Association representative and Brant hunter, Scott Frazer, does not think it has.
Despite language in the most recent EIR stating that “mitigation” of negative effects will adequately protect the eelgrass, Frazer disagrees. “The proposed expansion is too large, it still puts oysters on top of dense eelgrass beds, and the impacts are not fully mitigated,” he said.
Steve Rumrill, shellfish program leader for the Oregon Department of Fish and Wildlife was the lead contributor to the 2004 study cited throughout the EIR, and used by Coast Seafood as scientific evidence that eelgrass can thrive under oyster farming structures placed at greater gaps between structures. Rumrill feels the EIR took his study out of context in that the scope of the work was to look at the recovery of eelgrass in the wake of dredging techniques that were employed by Coast up until 1996 but since banned due to negative impacts.
Rumrill’s study did demonstrate that oysters placed at greater spacing afforded better recovery for the eelgrass, but it was not the purpose of the study to show results of spacing in a context other than that of recovery from dredging. “I’m neutral about growing oysters or not growing oysters,” he said, “but I am in favor of obtaining relevant field experiments and we should not rush into any decision in the absence of appropriate science.”
Neither is Rumrill convinced the science is adequate when it comes to the double lines that Coast is proposing to grow on. “My study was on single lines and there is no science I am aware of to show the effects of double decker lines of oysters.” Rumrill suggests that water currents, amount of light and oyster inundation time are just some of the factors not studied but likely to be affected by the two-tiered technique. Rumrill also feels the 2015 quote used in the EIR was taken out of context (see Topical Response #2 in the FEIR) in that its intention was to state that single line spacing of 5-10 feet was preferable to the industry standard of 2.5 feet. “I would advocate new science to investigate the double decker technique.”Unfortunately for Coast, whose parent company is the giant producer Pacific Seafoods, most of its total holdings in Humboldt Bay are on eelgrass beds. Additionally, a number of much smaller locally owned oyster farmers have requested permits to operate in areas of the bay not previously used for oyster cultivation. These growers are subject to the “pre-permitting” process adopted by the district and funded by the $230,000 Headwaters grant given to the commission to promote local business endeavors.
According to harbor district executive director Jack Crider, the pre-permitted inter-tidal areas were drastically reduced to avoid eelgrass beds, but about 200 acres will still be able to be farmed by local applicants who, Crider says, are taking somewhat of a risk that oysters may not take to the new unproven areas. Coast does not run the same risk because its new areas are adjacent to its current successfully productive areas.
In the sub-tidal areas covered by the pre-permitting process, seed development is underway over approximately eight acres where existing structures are used by Coast, three growers from Tomales Bay and five local growers.
It is not only the biological impacts that are in question for the project, but also the way in which the district has conducted the process.
Anna Weinstein, Seabird and Marine Program Director for Audubon California, said the Harbor District showed an “absolutely stunning lack of transparency” by engaging in closed-door meetings on the topic and that “it has failed on many other fronts including providing the public even a basic summary in one place, on one map, of all the proposals it appears to be supporting.” She states that the District, by indicating it intends to approve Coast’s proposal is ignoring input from several agencies as well as numerous local citizens. “They are undermining their own duty” as outlined in the 2007 Humboldt Bay Management Plan to be responsible to their constituency through transparency.
Weinstein said, “We need to research what would be a good balance for Humboldt Bay. It is a small bay and it is critical to manage it well and provide fair opportunity to all growers.”Audubon and Frazer agree that state-led, holistic oversight of Humboldt Bay’s aquaculture projects and a reasonable cap on oyster farming that allows small local farmers a fair share of the operations would be best for the community and the environmentally sensitive wildlife. Weinstein points to Tomales Bay as a successful example of sustainable oyster farming that in 2011, on only 152 acres, brought in $8 million in revenue to small growers. “The Harbor District does not have the capacity or expertise to manage aquaculture in the way the state does,” said Weinstein.
Greg Dale does not agree. “Audubon wants to take away local control, and people around here don’t like to give up control,” he said. He is confident that Coast Seafood will comply with all current environmental laws as well as the specific mitigations of impacts outlined in the FEIR. Dale also disagrees that some kind of bay-wide cap on oyster growing is needed. He reiterated the necessity to monitor operations thoroughly saying,
As long as you’re not harming the bay or any species, there’s no reason to limit oyster farming. If you look at bays up and down the coast that are called pristine and healthy, you will find that all of them include mariculture. It is in the interest of Coast to keep the bay as clean as possible. It’s an economic incentive to have good water quality. Coast and Pacific have been good stewards of the environment for 100 years.
As a Coast employee, Dale will have to recuse himself from the vote to certify the FEIR, but he is confident the vote will be in Coast’s favor.
Dale is also pleased with some of the unexpected results of the process of preparing the proposal: “We are always learning from new science and learning requires change. The introspection required in this process has been a positive experience for us.” According to him, the science has shown that in order to mitigate negative effects the project must take up more space by placing the growing apparatus at greater distances apart.
Ken Burton, author and local wildlife biologist of 30 years, while acknowledging he is not familiar with every detail of the FEIR, is concerned about potential cumulative effects of the project which he says “are often not given adequate coverage” in this type of report. Burton says, “it is impossible to unearth everything that is going on” and that even “insignificant” impacts add up to something significant. Factors such as rise in sea-level and water-temperature increase are likely to produce additive effects not accounted for in the report. Having a long time association with the Redwood Region Audubon Society, Burton, echoing Weinstein’s comments, asserts that Audubon is not opposed to oyster cultivation or expansion per se, but that for him, the line in the sand must be drawn at preventing any net loss of eelgrass.Dr. Jeffry Black , wildlife management professor at HSU, takes this stance one step further. He states,
I do not think the eelgrass community in Humboldt Bay (i.e. the soil, plants, and animals), including our cherished brant population, should have to endure any further disturbance of any kind from increased human activity.
Eelgrass is a threatened habitat type on a global scale. I for one, do not want to compromise any more than ‘we’ (meaning the broader community living here) already have (as outlined in my letters on this issue). I wish the authorities that oversee our bay ‘valued’ the eelgrass community (in all its glory) for its own sake (primarily) and what it already provides us (secondarily) by enhancing our lives at the local and global scale.
Rob Hewitt, wildlife biologist and organizer of Godwit Days, the highly successful local birdwatching festival held every spring for the last 21 years, says that about 60% of the festival’s nearly 600 registered participants each year come from out of town and spend nearly $500 per day in local businesses while in the area. “We are growing into the big leagues and stand in a prominent position among birding festivals,” he adds. An oyster enthusiast himself, Hewitt is quick to note that the tasty shellfish’s cultivation should not touch the eelgrass.
Among the five alternatives outlined in the final report, Coast Seafood is recommending the East Bay Management Avoidance (EBMA) plan as well as designating it the “Environmentally Superior Plan.” The other alternatives include: 1.removal of all of Coast’s oyster-growing operation, 2.implementing only Phase 1 of the EBMA, 3.leaving the operation as it currently is or 5. implementation of the original 622 acre expansion rejected early on in the process.
For Jennifer Kalt, director of Humboldt Baykeeper, a conservation program of the Northcoast Environmental Center, Coast has responded to serious issues. Regarding the FEIR, she said, “I was pleased to see that they have shrunk the project to less than its original size, will stay out of the East Bay Management Area as requested to avoid impacts to eelgrass, brant, and herring in that part of the bay, and that they will remove existing culture in the Sand Island area to avoid impacts to green sturgeon per NMFS [National Marine Fisheries Service] recommendation.
“Humboldt Baykeeper views shellfish growers, including Coast Seafoods, as important partners in protecting water quality, since their businesses depend on it. Drastic improvements to their culture methods since Coast’s last permit was issued in 2006 means there will be far fewer impacts to eelgrass, and although that is not considered the baseline for the current EIR, it’s important to remember how far they’ve come.”
While Coast employs some 70 local people, with a few more jobs to be added through the expansion, and brings in approximately $10,000,000 a year, which is expected to increase by about 30% if projections are correct, the question before the Harbor District board is whether the expected economic gain sufficiently offsets the potentially devastating risk of environmental loss. With science and business interpreting the issues differently, the decision will not be easy.