STATE OF CALI FORNI A—NATURAL RESOURCES AGENCY

EDMUND G. BROWN, JR., G OVE R NOR

CALIFORNIA COASTAL COMMISSION
45 FREMONT, SUITE 2000
SAN FRANCIS CO, CA 94105- 2219
VOICE AND TDD (415) 904- 5200
FAX ( 415) 904- 5400

January 14, 2016

Elizabeth Sablad
NPDES Permits Office
U.S. EPA Region 9
75 Hawthorne St. (WTR-2-3)
San Francisco, CA 94105

Re:

Notice of Scoping for the Rose Canyon Sustainable Aquaculture Project

Dear Ms. Sablad:
Staff of the California Coastal Commission (“Commission”) appreciates this opportunity to
comment on the U.S. Environmental Protection Agency’s Notice of Scoping for the Rose
Canyon Sustainable Aquaculture Project’s Environmental Assessment (“EA”). This proposed
project would result in the installation and operation of the first ever commercial open-ocean
marine finfish cultivation facility off the coast of California.
In addition to seeking authorizations from the U.S. Army Corps of Engineers (“USACE”) and
U.S. Environmental Protection Agency (“EPA”), the applicants of the Rose Canyon Sustainable
Aquaculture Project (“Rose Canyon”) have also committed to submitting a consistency
certification to the Commission so that it may expedite the evaluation of the proposed project
under the federal consistency review authority provided to the Commission through the Coastal
Zone Management Act. As development of the EA proceeds, Commission staff will coordinate
with Rose Canyon on the appropriate timing of this submittal so that the Commission’s review
can consider the EA’s discussion and analysis of the project’s potential environmental impacts
and reasonable alternatives. We hope to be able to make use of the project EA as a key source of
information during the Commission’s evaluation of the project’s conformity with the resource
protection and use policies of the Coastal Act. We also hope to continue coordinating this
review with the USACE, EPA, U.S. Coast Guard, National Marine Fisheries Service and the
Commission’s state resource agency partners, including the California Department of Fish and
Wildlife and Regional Water Quality Control Boards.
As the first of its kind in California, this project presents an opportunity to use this inter-agency
coordination to establish a model review process that can be used for other similar projects in the
future. Commission staff therefore looks forward to working closely with EPA staff both on the
development of this model process and evaluating the project’s potential environmental impacts.
Along those lines, we want to draw particular attention to Senate Bill No. 201, California’s

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Sustainable Ocean’s Act. This forward-thinking legislation was authored in 2005 by formerState Senator Joe Simitian and signed into law in 2006 to provide guidance and structure for
finfish aquaculture in California so that the development and growth of this industry may be
achieved in an environmentally sustainable manner.
Among its provisions, the Sustainable Oceans Act calls for the environmental review of coastal
marine finfish projects to consider, at a minimum, the following ten specific factors: (1)
appropriate areas for siting marine finfish aquaculture operations to avoid adverse impacts, and
minimize any unavoidable impacts, on user groups, public trust values, and the marine
environment; (2) the effects on sensitive ocean and coastal habitats; (3) the effects on marine
ecosystems, commercial and recreational fishing, and other important ocean uses; (4) the effects
on other plant and animal species, especially species protected or recovering under state and
federal law; (5) the effects of the use of chemical and biological products and pollutants and
nutrient wastes on human health and the marine environment; (6) the effects of interactions with
marine mammals and birds; (7) the cumulative effects of a number of similar finfish aquaculture
projects on the ability of the marine environment to support ecologically significant flora and
fauna; (8) the effects of feed, fish meal, and fish oil on marine ecosystems; (9) the effects of
escaped fish on wild fish stocks and the marine environment; and (10) the design of facilities and
farming practices so as to avoid adverse environmental impacts, and to minimize any
unavoidable impacts.
Although this law applies only to finfish aquaculture facilities in state waters – and thus the Rose
Canyon project is exempt from its requirements, we nevertheless believe the common sense
baseline it presents for evaluating the potential impacts of such projects in the marine
environment is worth the EPA’s consideration. Building off of the Sustainable Oceans Act’s ten
factors listed above, Commission staff therefore recommends that the proposed EA identify and
evaluate the following potential environmental impacts associated with the construction and
operation of the Rose Canyon offshore marine aquaculture facility:
1. Escape of Cultured Organisms
Despite a variety of engineering and management solutions that have been tried, most floating
fish pens have resulted in the escape of some cultured organisms. Please therefore evaluate in
the EA the following issues associated with the escape of reared fish:
o Genetic Pollution - Escaped organisms can interbreed with and undermine the
genetic integrity of wild populations. Many organisms used in aquaculture are
raised from a limited number of broodstock, which therefore results in captive
populations with limited genetic diversity. In addition, the selection pressures
placed on aquaculture organisms differ substantially from those placed on their
wild counterparts. Inter-breeding between escaped organisms and wild
populations has the potential to undermine the genetic diversity of wild stock, and
can reduce the fitness of wild populations through the loss of adaptations and the
breakup of beneficial gene combinations.
o Disease Vectors - Escaped organisms can come into contact with wild
populations, leading to the transfer of disease and parasites. Caged fish or

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cultured invertebrates (imported from other areas) may be infected with pathogens
to which wild stocks have not previously been exposed, and to which they have
no natural immunity or resistance. Additionally, because many aquaculture
operations maintain target organisms at high densities and low diversities,
parasitic and pathogenic organisms can thrive in and around these operations.
Offshore aquaculture operations in areas of strong ocean current activity can
allow pathogens and parasites to extend their ranges and be distributed over large
areas, which can negatively affect non-cultured species and populations.
Aquaculture operations in areas with less water movement can serve as reservoirs
of parasites and pathogens, allowing them to reach levels of local abundance that
can begin to negatively affect non-cultured organisms within the same area.
o Exotic Invasive Species - California law currently prohibits raising non-native finfish species and transgenic freshwater and marine fishes, invertebrates,
crustaceans or mollusks in State waters (Fish and Game Code 15007 as amended
in 2003 by Senate Bill 245). Commercial rearing of exotics is a serious concern
as escaped exotics can become an invasive species that could potentially outcompete native species for habitat and food resources and irreversibly change
local and regional ecosystems. Because the Rose Canyon project proposes to
include the cultivation of striped bass (Seriola lalandi), a fish species that is not
native to California, please consider the particular environmental impacts
associated with its escape from cultivation. Although striped bass has been
present in northern California since its introduction many decades ago and it is
cultivated and intentionally released to the wild as part of a recreational fishing
enhancement program there, the presence of this species in the project area and
wider southern California region has not been well documented. Due to its
anadromous nature and known ability to feed on young salmonids (for example,
studies on both east and west coasts have found that trout and salmon fry and
fingerlings can make up a substantial portion of the diet of wild striped bass 1), if
this species were to escape from cultivation and establish a viable population in
southern California, it may have deleterious effects on other anadromous species
such as steelhead and could alter the ecological state of coastal streams.
2. Ecosystem Concerns
Many industrially cultured marine finfish species are carnivorous and consume large amounts of
fish meal and fish oil. For example, between two and five pounds of wild fish are typically
required to produce one pound of farmed marine finfish (including seabass, cod, haddock,
halibut and flounder). 2 Therefore, the ecological footprint of culturing some commercial fish
may be large. Raising these fish may potentially deplete wild stocks of low-trophic level species
that are used as feed for the cultured species. Increased fishing pressures may be directed
towards these low-trophic level species (such as krill, menhaden, sardines, mackerel, anchovies
Morgan, M.D., and A.R. Gerlach. 1950. Striped bass studies on Coos Bay in 1949 and 1950. Report of the
Oregon Fish Commission and Oregon Game Commission to the Forty-sixth Legislature; Blackwell, B. F.,
and F. Juanes. 1998. Predation on Atlantic salmon smolts by striped bass after dam passage. N. Am. J.
Fish. Manage. 18:936–939.
2 Naylor et al. 2000. “Effect of aquaculture on world fish supplies.” Nature, Volume 405, pgs. 1017-1024.
1

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and herring) which may result in adverse impacts to the wild populations of fish, seabirds and
marine mammals that rely on these species for high quality forage. Please therefore include in
the EA an evaluation of the potential ecological footprint of the proposed project, in particular
the source(s) of feed for the finfish facility and the direct and indirect environmental effects of
providing this feed.
3. Organic Pollution and Eutrophication
Discharges of waste and excess feed can cause impacts to the benthic environment underneath
and down-current of fish pens and grow-out facilities. The amount of waste and unconsumed
feed depends not only on the digestibility of the food, but also on a range of other environmental
and husbandry factors such as water temperature, current speed, disease status of cultured
organisms and feeding frequency, timing and amount.
Fish feeds are often fish meal/oil based, but they also contain a wide range of components
including wheat, soy meal, crustacean meal, vitamins, amino acids, minerals, pigments and
nutrients. Fish and shellfish wastes often contain plant nutrients such as nitrogen and
phosphorus. The accumulation of these discharges has been shown to result in extensive
bacterial mats, to cause anaerobic “dead zones” around fish pens due to the chemical
requirements of the decomposition process, and to contribute to plankton and algal blooms in
surrounding waters. Nutrient pollution around aquaculture pens can alter the species
composition and density of benthic and planktonic organisms and trigger cascading ecosystem
health effects. Species of toxic diatoms and dinoflagellates can increase in abundance due to
nutrient pollution and as a result, the health of both humans and marine life that consume these
organisms can be negatively affected.
Please include in the EA an evaluation of the amount of organic pollution resulting from the
operation of the proposed facility and the potential adverse environmental impacts associated
with this pollution.
4. Use of Chemicals
Antibiotics, anti-fouling treatments for fish pens, and other chemicals such as parasiticides
(parasite-killing drugs), pesticides, hormones, anesthetics, pigments, minerals, and vitamins are
routinely used and discharged into the marine environment during aquaculture operations. The
use of these chemicals has raised concerns centering on both their potential effects on human
health and on natural ecosystems. Therefore, please evaluate in the EA the effects of chemical
use associated with the proposed project.
Regarding the use of antibiotics, if such use is proposed, please specifically include in the EA an
assessment and analysis of the environmental consequences of the presence of antibiotics in
sediments and aquatic biota, the presence and prevalence of antibiotic-resistant organisms in
sediments and indigenous species, and the presence and prevalence of antibiotic residues in fish
and non-target aquatic organisms. In addition, please also evaluate in the EA how the
accumulation of antibiotics in sediments may potentially interfere with bacterial communities
and affect the mineralization of organic wastes. Furthermore, although there is yet no direct
evidence that demonstrates antibiotic use in aquaculture significantly threatens the marine
environment, the use of antibiotics presents a potential health risk for people and farmed fish,

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since it promotes the spread of antibiotic-resistance in both human and fish pathogens. Several
strains of bacteria associated with fish, including Streptococcus, can also be pathogenic to
humans and if strains of these bacteria develop higher levels of resistance to antibiotics,
infections may be more difficult to treat. Also, due to the gene transfer abilities of bacteria,
antibiotic resistance can potentially spread to other types of bacteria, including human pathogens.
The growing and potential use of toxic parasiticides including cypermethrin and ivermectin to
control parasites such as sea lice in finfish aquaculture operations can negatively affect benthic
communities in surrounding areas. Because these treatments are often administered to fish in the
water, they can remain within the water column and (depending on current conditions) drift up to
several miles from the point of discharge, thereby affecting large numbers of non-target
organisms.
The use of anti-fouling chemicals, such as copper, on aquaculture pens, nets and other structures
often results in elevated concentrations of these chemicals in sediments under and around
aquaculture facilities. Changes to benthic community structure and diversity may be attributed
to anti-fouling leaching and pollution and anti-fouling chemicals may remain at elevated
concentrations within benthic sediments for long periods of time, resulting in long-term
ecosystem affects.
5. Space/Use Conflicts
The physical presence of aquaculture operations can conflict with existing uses, such as
shipping, commercial and recreational fishing and boating, and naval exercises. Poorly sited
aquaculture operations can also interfere with marine life migratory routes and aggregation areas.
Please evaluate existing use patterns at the proposed project site and how these uses may be
affected by the long-term presence and operation of the proposed facility. In particular, please
evaluate the proposed project location in relation to the various impact and control sampling sites
associated with the Point Loma Ocean Outfall facility (including those water quality, fisheries,
and benthic monitoring locations in the immediate vicinity of the project site) and analyze how
inputs and discharges from the proposed project may affect the continued use of these
monitoring sites and the relevance of the data collected at them.
6. Physical Impacts to the Seafloor
The physical presence of net pens and other equipment can cause physical impacts to sensitive
seafloor habitat, such as rocky reefs. The mooring and anchoring requirements of many
aquaculture operations can result in the disturbance of substantial amounts of benthic habitat and
can also reduce habitat values and displace non-cultured marine organisms. Please evaluate in
the EA the amount and type of anchoring devices proposed for the facility and the impacts to
seafloor habitats associated with the installation and presence of these devices.
7. Anti-predation
Natural predators, such as seals, sea lions, dolphins, porpoises and birds can be attracted to
aquaculture facilities, where they can become a nuisance to facility operators. Anti-predation
measures such as acoustic deterrent devices, aerial and underwater netting, and vessel chases can
harm both targeted and non-targeted marine life. In addition, please also evaluate in the EA the
potential conflicts that may arise between the protections provided to seals, sea lions and other

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marine mammals under the Marine Mammal Protection Act and the operational and economic
needs of the proposed aquaculture operation.
8. Marine Mammal Entanglement
Entanglement with ropes, fishing gear and other lines in the ocean is increasingly acknowledged
as a significant source of injury and mortality for some marine mammal populations. Off the
coast of California, Oregon, and Washington, there have been 308 large whales documented as
entangled in such gear from 1982 through 2012 with gray whales (Eschrichtius robustus) and
humpback whales (Megaptera novaeangliaes) the most frequently reported species. 3 Please
evaluate the entanglement risk posed to marine mammals from the proposed placement of lines,
ropes, and nets associated with the project facility.
9. Marine Debris
The proposed size and location of the aquaculture facility as well as the cultivation equipment
that it would include suggests that it would likely be subjected to powerful and destructive ocean
forces. Accordingly, it appears likely that a large amount of the proposed facility would be
susceptible to damage, deterioration, and breakdown over time. These processes may result in
the release of project materials into the environment as marine debris. Debris from the facility
such as plastic materials, nets, lines, ropes, and cables, would present additional sources of
entanglement risk for marine wildlife throughout southern California and may also adversely
affect recreational and fishing activities. In addition, given the proposed size of the facility,
significant storm damage or a catastrophic failure of its anchoring or buoy system could cause
the entire facility or large sections of intact infrastructure to drift, resulting in a substantial threat
to marine life and habitats both at the project site and along its drift trajectory. Due to its size,
uncontrolled shoreward movement of large parts of the facility in such an event would be likely
to put at risk coastal marine habitats and species as well as coastal recreational resources such as
boating facilities, beaches, piers, and marinas. Clean-up and emergency response to such an
event would be difficult, complex, and expensive. Please therefore include in the EA an
evaluation of the potential small- and large-scale release of marine debris from the facility and
the impacts associated with such events.
10. Ship Strikes
Given the proposed size of the aquaculture facility and its anticipated production levels, an
assumption of daily visits by multiple project vessels would appear to be reasonable. Marine
wildlife species with surface oriented behavior such as the sea turtles and marine mammals that
inhabit and/or travel through the project area are known to be vulnerable to ship strikes and many
ship strike related injuries and deaths to these types of animals have been documented in the
southern California region. Please evaluate in the EA the increase in vessel traffic in the project
area that would be associated with the proposed project as well as the changes in existing traffic
patterns that the siting of the facility may result in and the resulting risk of ship strikes to marine
wildlife associated with this increased and altered marine traffic.

Saez et al. 2013. Understanding the co-occurrence of large whales and commercial fixed gear fishieres off
the west coast of the United States. National Oceanic and Atmospheric Administration's National Marine
Fisheries Service, Southwest Regional Office. Technical Memorandum. NOAA-TM-NMFS-SWR-044.
3

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11. Clean-up and Removal
Commercial endeavors in the marine environment should include adequate end-of-life
contingency planning and funding to address the risk and impacts of incomplete removal,
dereliction, and abandonment in place. Please evaluate how removal and clean-up of the facility
would be achieved at the end of the project life or if it is abandoned or unsuccessful.
Commission staff appreciates the opportunity to comment on the proposed EA for the Rose
Canyon Sustainable Aquaculture Project. Please contact me at (415) 904-5502 if you have any
questions or need clarification on any of the points in this letter.

Sincerely,

CASSIDY TEUFEL
Senior Environmental Scientist
Energy, Ocean Resources and Federal Consistency Division