I

llJJ
u.s.DEP,~~~~£,, F COMMERCE, UNITED STATES DEPARTMENT OF COMMERCE,~~~-~NIC AND ATMOSPHERIC ADMINISTRATION, NATIONAL MARINEFISHERIES SERVICE
From: Sam Wright (petitioner), 2103 Harrison NW, Ste. 2126, Olympia, WA.
(Phone: (360) 943-4424)
Subject: Petition the Secretary of Commerce to list as threatened or
endangered eighteen ( 18) "species/populations" or evolutionary significant
units of "Puget Sound" marine fishes and to designate critical habitats.
(Note: for the purposes of this petition, a species/population is defined as
an important, existing (but severely depressed) native fish resource which
is currently at-risk (threatened or endangered) and has no reasonable
expectation of being able to recover over time by itself and/or from thesurplus production of an adjacent or nearby population of the same
species. · Puget Sound is defined as all of the inland U. S. marine waters
within the State of Washington that are east of the Bonilla-Tatoosh Lineat Cape Flattery. As such, the definition includes the U. S. portion of theStrait of Juan de Fuca, U. S. parts of the San Juan Archipelago and Straitof Georgia, and all of Hood Canal. Puget Sound "proper" is defined as "To
the east of Deception Pass, and to the south and east of Admiralty Head(and south of Point Wilson on the Quimper Peninsula)" (Dethier 1990, p.
10). This area has a unique set of geographic and oceanographic conditions
which commonly limit gene flow between marine fish populations of thesame species.
BASIS FOR THE PETITION
Petitioner files this petition under the Endangered Species Act ( the"ESA"), 16 U. S. C. section 1531-1543 (1982) (ESA), its implementing
regulations, 50 C. F. R. part 424, and the Administrative Procedure Act, 5
U. S. C. section 553 (c). The National Marine Fisheries Service ("NMFS") has
jurisdiction over this petition under 16 U. S. C. section 1533 (a) and theAugust 26, 1974, Memorandum of Understanding Between the U. S. Fish andWildlife Service and National Marine Fisheries Service Regarding
Jurisdictional Responsibilities and Listing Procedures Under theEndangered Species Act of 1973.
The petitioner is a scientist and Certified Fisheries Professional (CFP,
American Fisheries Society). The conservation, ecological, recreational,I

research and commercial interests of the citizens of the United States. (including the petitioner) will be adversely affected if the requested
petition is not granted.
Seventeen of the 1 8 species of concern were included in a July 1998
publication by the American Fisheries Society (Musick 1998). All of theentries were provided to the author by the petitioner, along with thesupporting technical data needed to justify their inclusion. This draft AFS
List of Marine Fish Stocks at Risk in North America (Musick 1998, p. 30)
had the following entries for Puget Sound, including the primary cause forconcern:
Pacific herring, Clupea harengus pal/asi - other
Pacific cod, Gadus macrocephalus - slow growth/late maturity, otherwalleye pollock, Theragra chalcogramma - other
Pacific hake, Merluccius productus - otherbrown rockfish, Sebastes auriculatus - slow growth/late maturity
copper rockfish, Sebastes caurinus - slow growth/late maturity
greenstriped rockfish, Sebastes elongatus - slow growth/late maturity
widow rockfish, Sebastes entomelas - slow growth/late maturity
yellowtail rockfish, Sebastes f/avidus - slow growth/late maturity
quillback rockfish, Sebastes ma/iger - slow growth/late maturity
black rockfish, Sebastes me/anops - slow growth/late maturity
China rockfish, Sebastes nebulosus - slow growth/late maturity
tiger rockfish, Sebastes nigrocinctus - slow growth/late maturity
bocaccio, Sebastes paucispinis - slow growth/late maturity
canary rockfish, Sebastes pinniger - slow growth/late maturity
redstripe rockfish, Sebastes proriger - slow growth/late maturity
yelloweye rockfish, Sebastes ruberrimus - slow growth/late maturity
The 1 3 rockfish species listed above were designated as "important
species of bottomfish in Puget Sound" by Palsson et al. (1997) and in an
early 1,998 draft of the Puget Sound Groundfish Management Plan. In the
final version of this· plan (Bargmann 1998a), the blue rockfish, Sebastes
mystinus, was added to the list as "import'ant".
In addition, alarming declines in populations of plant and animal species
in the inland marine waters of British Columbia and Washington haveprompted collaboration of scientists and managers from the twojurisdictions. The 1994 .British Columbia/Washington Symposium on the
Marine Environment identified species and species groups that hadsuffered significant anthropogenic stresses and were in need of special
consideration for their protection (Wilson et al. 1994 cited in West 1997).
The fish species identified were Pacific herring, Pacific cod, walleye
pollock, Pacific hake, three species of demersal rockfish (brown, copperand quillback), and lingcod ( Ophiodon elongatus).
Petitioner, as well as Washington Department of Fish and Wildlife (WDFW)
professional staff members, have also nominated all of these same 1 8
species (except blue rockfish) as candidates for the Washington State listof endangered, threatened or sensitive species. In addition, WDFW has
established a "Priority Habitats and Species List" which is intended to
identify species and habitats of special concern in Washington (WDFW
1996). Priority species are those that require protective measures fortheir perpetuation due to population status, sensitivity to habitat
alteration, and/or recreational, commercial or tribal importance. Ten
species of groundfish were included on the Priority Habitats and Species
List (WDFW 1996) and seven are addressed in this petition (Pacificherring, Pacific cod, walleye pollock, Pacific hake, copper rockfish,
quillback rockfish, and yelloweye rockfish). In state regulations, certain
areas have been declared "saltwater habitats of special concern", andthese include herring spawning beds (WAC 220-110-250).
DEFINITION OF AT-RISK PUGET SOUND MARINE FISH STOCKSIn principle, "stock" is a biological term which refers to a population offish which is reproductively isolated, or partially isolated, from othersuch populations of the same species. In terms of basic resource
conservation or "viewing the resource as your client" (WDFW 1997), an "at­risk stock" should be defined as a population of an important, existing (butseverely depressed) native fish resource which is currently at-risk(threatened or endangered) and has no reasonable expectation of being able
to recover over time by itself and/or from the surplus production of an
adjacent or nearby population of the same species. The "burden of proof"
for this expectation must not fall on the resource.
The northern and southern regions of Puget Sound are geographicallydistinct and have characteristics that are unique to each. A narrowpassage at Deception Pass and a sill in Admiralty Inlet separate the northand south "Puget Sound" areas from each other as different oceanographic .
water bodies. The north is more exposed to storms, receives more oceanic'water, and contains abundant, often contiguous, rocky reef habitat. The
southern area (or Puget Sound proper) is generally more protected,
influenced more by freshwater, and contains much less, often isolated,rocky reef habitat. It has been designated as an Estuary of National
Significance and ranks with Chesapeake Bay and Long Island Sound inregional importance.
Genetic differentiation might be expected among basins where gene flowis restricted within each basin due to sills forming barriers to movement,water masses and circulation entraining pelagic life history stages, anddeep basins forming barriers to the dispersal of shallow water fishes.
Within the south Puget Sound area, there are other basins and steep­
walled fjords which could influence genetic differentiation and population
structure. In north Puget Sound, three bodies of water include the Straitof Juan de Fuca, the Strait of Georgia, and the San Juan Archipelago. The
latter may form a barrier to gene flow and may affect population genetics
in north Puget Sound.
It is logical to expect to see greater population subdivision in Puget Soundbecause it is a large, highly subdivided estuarine system comprising a
number of discrete basins separated from each other by sills andconstricted entrances between peninsulas and islands. The complex
physiographic and hydrographic features of Puget Sound suggest thepotential for limited intraspecies mixing among basins. In genetic studiesof three closely-related rockfish species, Seeb (1998) found abruptchanges in allele frequency over a relatively short geographic distance(approximately 70 km). It is significant that this change occurred
between fish samples that were taken on opposite sides of theconstrictions at Deception Pass and Admiralty Inlet.
For all of the populations discussed in this petition, the greatest danger
with a small stock size occurs when predation, parasites and/or disease(i.e., any natural mortality cause) leads to a situation where the highest
percent mortality occurs at low abundances of juveniles and/or adults.
Peterman ( 1977) stated that populations with two or more "domains ofstability" must be managed accordingly. In these cases, two or moredifferent mortality processes combine in a series to create a stock­recruitment curve with more stable points t-han the single one exhibitedby the standard Ricker model. In one case, an unfished population would bestable a point A, and could be continuously exploited without permanent

Iharm as long as it never dropped down to point B. Below this point, thepopulation would move toward extinction, even if harvesting wascompletely stopped. In a second case, a critical spawner abundance would
also exist, but a population falling below point B would not go towardextinction but toward a lower stable equilibrium (point C), which would bevery unproductive for harvesting. Elimination of all harvest :would still
not permit the population to return to the higher abundance near the upper
stable point.
Even in the absence of the situation described above, ecologists often
identify the concept of a ·"critical threshold" or a population level below
which reproduction and survival are impaired, limiting the ability of a
population to sustain itself. Unfortunately, all of these potential threats
are commonly identified after-the-fact when populations have alreadycollapsed and scientists can only debate the causative agents.
Puget Sound marine fish populations present a unique situation since they
are probably younger in an evolutionary sense than those of the Pacific
Coast. Much of Puget Sound and the Strait of Juan de Fuca (including the
San Juan Islands) was covered with ice during the ·maximum extent of
Wisconsin glaciation approximately 15,000 years ago (McPhail and Lindsey
1986 cited in Seeb 1998). Seeb (1998) believed that genetic bottlenecks
and drift could have occurred during re-colonization of the Puget Soundfish populations. She found evidence of introgression between all three ofthe rockfish species involved in her study and suggested that Puget Sound
may represent a rare case of active evolutionary processes in marine fish
populations.
STATUS OF AT-RISK PUGET SOUND MARINE FISH RESOURCES
PUGET SOUND PACIFIC HERRING
Pacific herring (along with Pacific sandlance, Ammodytes hexapterus) are(and were historically) the most abundant forage fishes in Puget Sound,providing (as juveniles and adults) a source of food for many fish, bird,
and marine mammal populations. They are a pelagic, schooling species
that preys primarily on zooplankton. In Puget Sound, herring spawn fromJanuary to June, depositing adhesive eggs ori blades of eelgrass (Zostera
marina) and a variety of other marine vegetation. Eggs hatch in about two
weeks, after which pelagic larvae are found in nearshore plankton. Larvae

aggregate in protected bays, and after their first year they mix withadults in more pelagic habitats. Following the attainment of sexual
maturity at age two to four, the herring migrate back to the spawning
grounds. Typically, each stock has a pre-spawner holding area where
ripening adult herring aggregate prior to spawning. The holding patternusually begins 3 to 4 weeks prior to the first spawning event.
In Puget Sound, individual stocks are considered to be those fish which
utilize specific spawning grounds, and eighteen ( 18) stocks have been
identified (Bargmann 1998b). This conclusion was reached based on the
combination of differences in spawning timing and growth rates by fish
which utilized different spawning grounds (Trumble 1983). Thus, likesalmon, herring generally return to their natal spawning grounds.
However, straying rates between spawning grounds can be significant (upto 20%, Bargmann 1998b). Unlike salmon, herring do not all die following
spawning, and individual fish can spawn annually for several years.
West (1997) and Bargmann (1998b) reported that four herring stocks werein "depressed" or "critical" condition and that estimated annual natural(non-fishery) mortality of this species in Puget Sound has increased fromabout 30 to 40% ( considered normal for healthy herring populations world­wide) before 1982 to 60-70% at the present time. As a consequence of
this, the number of age classes comprising the bulk of the herring stocks
in Puget Sound has decreased from five to two or three, with losses
predominately from the oldest age classes. Clearly, the fish are now
smaller and younger, on average, and carry fewer eggs per fish. The
historic or evolutionary buffer against recruitment failure has been
considerably diminished. Herring formerly lived to ages in excess of 10
years in Puget Sound. However, fish older than age 6 are now rare
(Bargmann 1998b).
A further problem for the herring resource has been increased night-timesightings by herring-survey biologists of harbor seals near schools of
herring and concurrent changes in the schooling behavior of herring,supporting the perception that predation by harbor seals has risen inrecent years (Norm Lemberg WDFW, personal communication cited in West1997).
The Cherry Point herring stock is the largest- in Puget Sound and is unique
because of its exceptionally late spawning timing. The Cherry Point fish
also exhibit relatively rapid growth rates after age one, therefore, it isbelieved that this may be a "migrant" stock, possibly summering off of thecontinental shelf. There have been directed adult fisheries on this stockin the past, primarily by purse seines and gill nets or for spawn-on-kelp.
The run size in 1998 was assessed at 1322 tons, the lowest ever seen forthis stock in 22 years of record (1977-1998). The amount in 1998 was
16% lower than the spawning run in 1997, which was the lo\\'.est amountever seen until that year. Since 1985, this stock has been declining at an
average rate of 6.5% per year. All of the fish that are currently too young
to spawn (age 2 or less) came from small parental spawning populations.
It will take an unusually high survival rate of the immature fish to evenstabilize stock size in the next few years. In addition to the record low
size of the spawning biomass, extent of the area actually used for
spawning has been reduced to a small fraction of that used historically.
The limited area still used is, unfortunately, centered in an area ofexisting and proposed industrial developments (see enclosed figures).
WDFW records show the following spawning biomass estimates (in tons)
as determined by spawn deposition surveys for the years 19 77 through1997: 11097, 10973, 9957, 9329, 6219, 5342, 8063, 5901, 5760, 5671,
3108,4428,4003,4998,4624,4009,4894, 6324,4105,3095,and 1530,
respectively. Spawning biomass estimates made from acoustic/trawl
surveys are also available for the same years as well as estimates ofrecruitment (also in tons).
The Discovery Bay herring stock is the major Strait of Juan de Fuca
population in U. S. waters and 22 years of quantitative populationassessments have been made. Historically, it was believed to be one of
the largest stocks in Washington, but is currently at a critically low levelof abundance. The reasons for this are unknown. There are no known
fishery interceptions, and the spawning ground is among the most pristinein Washington. The run size in 1998 was zero - surveyers were unable todetect a single herring egg in Discovery Bay. This stock has been declining
at a rate of 7.8% annually since 1985. However, the 1996 spawning stock
was relatively abundant and the progeny should be fully recruited as
adults this year. The fish that spawned in 1996 represent the lastreasonable hope for stock rebuilding. WDFW records show the following
estimates of spawning biomass (in tons) as determined from spawn
deposition surveys for the years 1978 and 1980 through 1997: 1305,
3220,3070, 2356, 2578, 3144, 1447, 1566; 1593,853, 1225,855,925,
727, 737, 375, 261, 747, and 199, respectively.

Cherry Point Herring Stock
Spawning Biomass and Distribution
12000 - . - - - - - - . . : - - - - - - - - - - - - - - - - - 10000 + - - - ~ - - - - - - - - - - - - - - ­8000
C 6000-t-----~-:7---..~-----~~-0
I- 4000+---------~~C3ootc.---==-'------------'~(fJ

2000--+---------------------0 --+-.---.---,----,-----r-----.----~~-----r---.---.-.-------,.-----.-------.---r--.----,----r--,---,~roTT~~oo~~~MM~~M000091~~M~OO~

Year

Pre-1983-

1983-89

1990-92--

1993-95...
-aSpawning Habitat Used
Spawning Habitat Not Used

Source: DNA Aquatic Resouroes Div.
interpretation of WDFW Cherry Point herring
stock assessment data and trends (MarkO'Toote pers comm 1997). Prepared 11/97.

Existing and Proposed
Facilities Around Cherry Point

2 Miles0
Facilities
Existing Structures
Proposed Structures
i,=!i,i= Chicago Bridge and Iron Lease,1,1;;;; ARCO Lease=*=* INTALCO Lease
i::;i:i; Belllngham Sand & Gravel Lease,,,,,;,, TOSCO Lease·e·rrlng Spawn Habitat
1997 Habitat Used•
Historic Habitat
Ownership of Land
11[\,1 Private

t:/ Publlc

111111 Tribal Reservation~
Produced by DNR Aquatic
Resources using DNR ownership
information and analysis of
WDFW herring stock
assessment information(Mark O'Toole, personalcommunication, 1997).
11/20/97

The two additional at-risk herring spawning stocks identified by West( 1997) utilize spawning grounds in the Port Susan and Port Orchard/Port
Madison areas, respectively. Spawning biomass estimates for the twostocks were presented graphically by West (1997) and show the same typeof distinct downward trends exhibited by the Cherry Point and Discovery
Bay herring stocks. Of the fourteen remaining Puget Sound herring stocks,
9 are currently classified as "healthy" or "moderately healthy" and thestatus of 5 is "unknown" (Bargmann 1998b). However, it is difficult tocall any Puget Sound herring stock healthy in view of the alarming
increase in annual natural mortality rates and concurrent decline in
number of age classes available to carry the resource forward on asustainable basis. (Note: the only additional Pacific herring stock in theentire state is found in Willapa Bay on the Washington coast - status"unknown").
Many marine ecosystems share an important aspect in the structure of
their biological communities. They contain a large number of species,
typically plankton, at low trophic levels. They also contain a substantial
number of species such as large fish, seabirds and mammals at hightrophic levels. However, in many of these ecosystems, there is a crucial
intermediate trophic level which is occupied by only a few species ofsmall pelagic fishes (Bakun 1996 cited in Bargmann 1998b). This
community structure, with many species at the bottom of the food web aswell as at the top, but with only a few species at mid-level, has beencalled a "wasp-waist ecosystem" (Rice 1995 cited in Bargmann 1998b).
Pacific herring in Puget Sound can be considered a dominant species at the
wasp-waist. A recurring theme in Bakun (1996 cited in Bargmann 1998b)
is the decadal-scale shifts in abundance that may occur in wasp-waist
species; often, but not always, due to replacement by other forage fishes.
Puget Sound herring appear to be one of the exceptions to thisgeneralization.
PUGET SOUND PACIFIC COD
Palsson (1990) distinguished three stocks of Pacific cod in Puget Sound
based upon fishery patterns, location of spawning grounds, parasitic
markers, and tagging studies. These included a northern stock found in the
Gulf-Bellingham area and in southern British Columbia, a western stock
found in eastern Strait of Juan de Fuca and in Port Townsend Bay, and asouthern stock found south of Admiralty Inlet and including fish spawningI

in Hood Canal, Agate Passage, and Daleo Passage near Tacoma. The tagging
data were the primary determinant of this stock structure. Fish weretypically tagged on the spawning grounds. In most cases, tags wererecovered during the same spawning season on the same spawning grounds,
indicating a high fishing mortality rate. However, for the tagged fish
escaping the fishery, the majority remained within the respe~tive stockarea. Some fish (generally less than 10%) moved out of their stock area
but were usually caught in the adjacent stock area. At least two of thethree Puget Sound Pacific cod stocks are currently at-risk.
The overall Pacific cod resource is widely distributed in relatively
shallow marine waters ( 50-200 m) along the shoreline of the northern arcof the Pacific Ocean, from Japan to western North America. Cape Flattery
at the entrance to Juan de Fuca Strait and the inland waters of Washington
are considered the southern limit of fishery-exploitable populations of
this large demersal carnivore ( exceeding 140 cm in its northern range, butless than 100 cm in Puget Sound).
Palsson et al. (1997) reported that the Puget Sound Pacific cod stocks
have some of the highest growth and egg production rates of any cod
stocks on the Pacific Coast. Palsson (1990) stated that a former
commercial cod fishery targeted spawning cod that used the waters of
Killisut Harbor and Port Townsend Bay during the winter. The fisherybuilt-up in the late 1970's and early 1980's, the cod stock and fisherydeclined in the mid-1980's, and the fishery was closed in 1987. This codstock has not recovered. Cod were seldom harvested by trawl fisheries
which continued in Admiralty Inlet until 1994 nor did experimental
trawling find cod in Port Townsend Bay in 1988.
The next cod stock to collapse was the southerly population. This stock
supplied the fish once harvested in a popular wintertime recreational
fishery on spawning cod in Agate Passage. It was not uncommon to see
several hundred boats floating above the spawning area with many fishers
catching their limit of 1 5 fish. WDFW developed a special survey tomonitor this fishery in the mid-1 980's but was only successful indocumenting rapidly diminishing catches. By 1988, few fish were being
harvested and a complete closure of the area during every winter began in1991 . Daily bag limits for the remaining open season were decreased
from 15 to two fish in 1991 and then to zero prior to the 1997 fishery.
Palsson et al. (1997) stated that the recreational fishery catch rate is theprimary stock indicator for south Puget Sound cod. It has continuously
declined since 1977. WDFW also began special surveys of the Agate
Passage cod using scientific echosounding equipment. Biologists foundsome acoustic aggregations during 1987 and 1988, but recent surveys
during the traditional spawning period failed to reveal any similar
acoustic targets. These results clearly identify a stock at a critical ornear extinct level.
Recreational catch rates (fish per angler trip) provided by Palsson et al.
( 1997) and WDFW records for the years 1977 through 1996 were as
follows: 0. 78, 1.02, 0.42,. 0.65, 0.57, 0.59, 0.34, 0.56, 0.28, 0.42, 0.30,
0.16, 0.08, 0.01, 0.02, 0.05, 0.00, 0.01, 0.0, and 0.0, respectively. The
stock decline was further confirmed by the following commercial trawl
catch rates (pounds per hour) for 1970 through 1993: 37.3, 66.9, 107.3,
84.5, 121.8, 136.3, 124.6, 95.3, 63.6, 27.7, 25.4, 60.6, 29.0, 21.7, 32.9,
21.2, 20.2, 27.2, 39.2, 17.7, 9.1, 21.4, 14.9, and 6.6, respectively (thefishery was closed in 1994). A third source of evidence comes from trawl
surveys conducted in 1987, 1989, and 1991. The estimated abundance (N x1000) was 1606, 208, and 47, respectively. The estimated biomass (mt)was 1280, 152, and 44, respectively.
·
SOUTH PUGET SOUND (PUGET SOUND PROPER) WALLEYE POLLOCK
The walleye pollock is a carnivorous, midwater schooling codfish and isconsidered a northern, colder-water species, occurring along the shorelineof the northern arc of the Pacific Ocean from Japan to western North
America. Like Pacific cod, Puget Sound represents the southern extent offishery-exploitable populations. Walleye pollock grow at different rates
between north and south Puget Sound and demonstrate spatial separation
during spawning periods, indicating that they are discrete stocks (WDFW
unpublished data cited in Palsson et al. 1997). The at-risk stock occurs in
the latter area.
Palsson et al. (1997) reported that walleye pollock in south Puget Soundare on the extreme southern end of their Pacific Coast distribution butthat a unique recreational fishery near Tacoma once made pollock themost ,common bottomfish harvested in Puget Sound recreational fisheries.
Anglers harvested the great majority of their pollock in south Puget Soundand catches exceeded 400,000 pounds per year from 1977 to 1986. After
1986, catches diminished and the fishery collapsed after 1988. The

primary stock indicator used by WDFW is the recreational catch rate andPalsson et al. (1997) and WDFW records report the following values (infish per angler trip) for the years 1977 through 1996: 0.71, 1.31, 1.37,
0.97, 0.88, 0.85, 0.59, 0.99, 0.52, 0.49, 0.26, 0.25, 0.02, 0.1 and 0.0 for
1991-1996, respectively (the zero fish bag limit took effect in 1997).
The trawl catch rates (pounds per hour) show the following values for theyears 1970 through 1993: 0.9, 1.0, 0.8, 6.0, 3.3, 4.7, 4.3, 3.6, 2.5, 9.1, 8.0,
2.7, 2.1, 1.2, 0.4, 0.1, 2.1, 1.1, 0.9, 0.2, and 0.0 for 1990-1993,
respectively (the commercial trawl fishery has been closed since 1994).
Trawl survey were conducted in 1987, 1989, and 1991. The abundance
estimates (N x 1000) wer:e 3537, 172, and 99, respectively, while theestimated biomass (mt) was 452, 50, and 17, respectively. Palsson et al.
(1997) state that another secondary indicator, the population of pollock
estimated from cohort analysis, details the decline of the population in
the early 1980's. The cohort analysis also showed that the resource wasbeing over-utilized in the 1980's. In any case, the available dataconclusively demonstrate that the population is at a c~itical, possibly
extinct status.
SOUTH PUGET SOUND (PUGET SOUND PROPER) PACIFIC HAKE
In common with walleye pollock, the Pacific hake is a carnivorous,
midwater, schooling codfish. However, Pacific hake is considered to be asouthern or warm-water species, with abundant populations occurring off
the coasts of California and Baja. These populations undergo feeding
migrations northward in the summer to as far as Washington and British
Columbia, returning to spawn in southerly waters in the winter. A
smaller, genetically distinct, resident population occurs in south Puget
Sound which migrates seasonally between Port Susan and Saratoga
Passage. Utter and Hodgins (1971 cited in Palsson et al. 1997)
demonstrated that Puget Sound Pacific hake were genetically distinct
from coastal populations and Goni (1988 cited in Palsson et al. 1997) used
growth information to separate Pacific hake from north and south Puget
Sound. The growth differences plus the distinctive spawning areas
indicate that there are separate stocks of Pacific hake in north and south
Puget Sound. It is this latter population whose numbers have experienced
a severe decline in recent years and is now at-risk. (Note: Jagielo et al.
(1996) found lingcod from Puget Sound differed genetically from othercoastal samples, including those from Alaska and California.)

Palsson et al. ( 1997) reported that most south Puget Sound Pacific hake
spawn in Port Susan where a commercial midwater trawl fishery once
harvested up to 1 5 million pounds of spawning hake per year. The catch
declined rapidly after a 1983 peak and, by 1 991, low abundance resulted ina closure of the directed fishery. The primary stock indicator is a fishery·
independent acoustic and midwater trawl survey conducted during thewinter in Port Susan. Spawning hake in Port Susan once had an estimatedadult biomass of over 40 million pounds, but this biomass steadily
declined between 1982 and 1993 when barely one million pounds were
estimated. The survey biomass estimates provided by Palsson et al.
(1997) and WDFW record~ were as follows (in millions of pounds) for theyears 1983 through 1998: 45.1, 27.1, 16.0, 16.0, 11.9, 12.8, 12.1, 13.5,
11.7, 8.9, 1.1, 1.3, 0.9, 7.3, 2.4, and 1.1, respectively. The stock status is
at a critical level. The midwater trawl catch rate, a secondary stock
indicator, mirrored the survey population trend. For the years 1970
through 1991, the midwater trawl catch rates (in 1000's of pounds perhour) were as follows: 6.0, 3.3, 3.0, 3.5, 6.5, 7.8, 17.0, 10.6, 18.0, 22.6,
21.8, 12.1, 9.6, 6.4, 4.7, 5.4, 3.3, 7.2, 9.3, 2.4, 0.3, and 10.0, respectively(there has not been a fishery since 1991 ). The fishery definitely over­utilized the stock in the 1980's when the annual exploitation rate reachedas high as 40% of the adult population. In addition to the overall biomass
decline, average fish has become noticeably smaller (and younger) andmany would not now be usable for commercial purposes. High predation bymarine mammals is probably preventing recovery of the population.
Schmitt et al. (1995) believed that marine mammal predation was animportant factor affecting the numbers of some marine fish species in
Puget Sound. They estimated that harbor seals and sea lions consume3488 to 4645 mt of food annually. Although these marine mammals also
prey on other species such as squid and salmon, marine fish species
constitute the majority of their diets. As a result, predation may be twoor three times the total of marine fish taken by the combination of sportand commercial fisheries in Puget Sound. Schmitt et al. (1995) estimatedthat California sea lions consumed between 286 and 573 mt of Pacifichake in Puget Sound. Although estimates of the amount of hake consumed
by harbor seals were not available, they believed that seals may beconsuming similar amounts, or perhaps more. For the other stocks
presented in this petition, the authors estimated that California sea lions
in Puget Sound had annual consumption rates of 51 to 102 mt for Pacificherring (3rd overall behind spiny dogfish), 34-69 mt for Pacific cod ( 4thIoverall), and 16-32 mt for walleye pollock (6th overall behind shiner
perch).
Olesiuk (1993) found that the diet composition of harbor seals in theStrait of Georgia varied seasonally. Pacific hake was dominant during
April-November and Pacific herring was dominant during December-March.
Combined, hake and herring accounted for 75% of the diet in terms of both
energy and biomass. Total annual consumption was estimated at 9892
(range 6432-13359) metric tons, which included 4214 (2215-6664) mt ofhake and 3206 (1679-5818) mt of herring.
ROCKFISHES IN PUGET SOUND
Over twenty species of rockfishes inhabit Puget Sound and this is a casewhere virtually an entire genus (Sebastes) is at-risk. The only exception
is the diminutive, plankton-feeding Puget Sound rockfish (Sebastes
emphaeus) whose small size makes it immune to significant fishery
exploitation. At the present time, only five species are commonly caught
in the commercial and sport fisheries. The others have largely
disappeared from catch samples and are rarely seen during fishery-independent stock assessments. The most noticeable declines have beenwith tiger, canary and yelloweye rockfish. (Note: not much is k~own
regarding the tiger rockfish, but they may be the most extreme example ofsmall home ranges. They are extremely cryptic and only inhabit very rocky
reefs.) In the mid-1960s, canary rockfish was named by Holmberg et al.
(1967) as one of the three "principal species" taken by trawling in Puget
Sound waters (along with copper and quillback rockfish). The species
which are now the most common tend to be those with the greatest
productivity and/or the greatest resistance to fishery exploitation. For
example, Palsson and Pacunski (1998) categorized brown rockfish as"light" for their "fishing intensity" rating. This species has asignificantly lower presence in recreational catches than would be
expected from their dominant presence in many south Puget Sound reef
habitats (as confirmed by fishery-independent population assessments).
In salmonids, it is recognized that closely-related species have different
susceptibilities to harvest. For example, Behnke (1985) cites a casewhere cutthroat trout were seven times more likely to be harvested thancomingled brook trout. Behnke also stated'that the vulnerability factor ofbrook trout is probably 5 to 10 times greater than that of brown trout.
This may be what caused Palsson and Pacunski (1998) to find higher

Idensities of brown rockfish at fished sites. The lack of "normal"interspecies competition from other rockfish species (as would be foundin an unfished community of fishes) may have contributed to the
population compositions that were actually observed.
Rockfishes are the most difficult group to manage since their life history
characteristics make them extremely vulnerable to overfishing. They areslow growing, late maturing, long lived, and some species demonstrateextreme site fidelity. In addition, rockfishes (as well as Pacific cod)cannot compensate for the change in hydrostatic pressure when brought
quickly to the surface by_ fishers. Hence, they typically die when caught(West 1997). This creates two resource management problems. First,
traditional fishery management tools such as minimum size limits andspecies selective retention become useless. Even daily bag limits are oflittle use in mixed species fishery situations. Second, as the size
distribution of the population is depressed and truncated due to fishing,more and more fish are discarded by anglers because they are too small.
This new non-catch fishing mortality is virtually impossible to estimate
with any degree of accuracy.
As adults and juveniles, rockfishes inhabit rocky and artificial reefs,
nearshore vegetated habitats, and other habitats with vertical relief.
Eggs hatch internally in the female and are released as larvae during thespring. Parental care in this genus is mainly lecithotrophic, characterized
by primitive, unspecialized viviparity at an evolutionary stage when only
eggs, embryos, and early larval stages are protected inside the female
body (rather than born live as fairly advanced young). The more advanced
matrotrophic viviparity has been demonstrated in at least four species.
They occupy planktonic environments as larvae for several months (theprimary opportunity for effective dispersal and gene flow) and settle on
to marine vegetation and nearshore reef habitats. In general, rockfishes
are mid-level consumers feeding on shrimp, crabs, and small fishes.
There are differences in growth rates for some species between north andsouth Puget Sound. Growth differences have also been detected between
two areas within south Puget Sound.
Copper, quillback, and brown rockfishes are demersal or sedentary species
and the most common species currently caught by Puget Sound fishers.
Quillback rockfish have been shown to have small home ranges(approximately 30 square meters for high-relief reefs, Matthews 1990)

and different growth rates between north and south Puget Sound. Growthstudies also suggest that quillback rockfish grow at different rates
between two sites in south Puget Sound. There is some anecdotal
evidence that quillback rockfish from north Puget Sound have different
color patterns from fish in south Puget Sound. Copper rockfish have
similar life history traits and home ranges as quillback rock_fish(Matthews 1990), but tend to inhabit shallower depths. Matthews ( 1990)
also found that these two species (quillback and copper) not only maintainsmall home ranges but also return to their home sites whenexperimentally displaced by up to 6.4 km. Thus, factors leading toward
reduced gene flow, such as homing behaviors and small home ranges inadults, will act to counteract those that increase gene flow, such as
pelagic larval stages (Seeb 1998). Black and yellowtail rockfishes are
pelagic, schooling species and were once common in sport catches but
their occurrence dramatically decreased during the early 1980's. Bothspecies have wider home ranges and make longer movements than thesedentary species.
The primary stock indicator for both north and south Puget Sound is therecreational catch rate in terms of fish per angler ·trip. Both of theseareas show long-term downward trends. Available data through 1994 arepresented by both West (1997) and Palsson et al. (1997), while Palsson
and Pacunski (1998) provide statistics for the most recent years (infigures only, not tabular form - see Figure 1 from their report).
Unfortunately, even though definite downward trends are obvious, thesedata provide an unrealistic sense of security or optimism concerning
stock status. Fish resource managers often find that catch rates or othersimilar fishery-dependent indexes significantly underestimate the declineof a population. This is usually discovered when newer, fishery-independent indexes become available. This is exactly what has happened
with Puget Sound rockfishes. Newer fishery-independent assessments
have estimated that the present populations are only producing 10% ( orless) of the larvae that were produced as recently as the 1970's. The
populations are now considered to be critically depressed in terms of both
numbers of fish and the average size of individual fish. One of the most ·compelling statements was the following by Palsson and Pacunski ( 1998,
p. 1 3 ): "Many vacant habitats have been observed throughout Puget Sound
during the VAT surveys" (VAT is the acronym for Video-Acoustic
Technique). In many cases, the only genus member observed was thefishery-immune Puget Sound rockfish.

ROCKFISH
~

1.8
~ 1.6
I ~ 1.4
~ 1.2
~ 1.0
~ 0.8

0 0.4
0.6

'\~"\I\..-,\__

~

< 0;2

U 0.0
1975

1980

1985

1990
Year

1995

. - NORTH -:r:- SOUTH

Figure I. Recreational catch rates ofrockfish (catch per trip) ofbottomfish anglers in No11h and South Pugel Sound.

2000

I

Recreational fishery catch rates over time in Puget Sound have proven tohave some utility as a relative measure of population abundance since
WDFW generally lacks the age information needed to do catch-at-age typeanalyses. Palsson and Pacunski ( 1998) used available fish length
information, catch rates and fecundity estimates to assess the conditionof copper rockfish in the San Juan Islands area. Their analysis revealed
that rockfish larger than 40 cm constituted a quarter of the catch in the
mid-1970's. Presently, only 5% of the catch is comprised of large fish.
The size truncation and decline in catch rates have resulted in a recent
reproductive output that is estimated at only 10% of historic levels (seeFigure 3 from their report). This level of reproductive output falls far
short of the 40% level (or F40%) that is now being recommended toprevent overfishing and assure stable recruitment and populations (Clark
1993).
In many forums, "overfishing" has been defined as fishing rates whichcause the spawning biomass to decline below a level which achieves thelargest level of maximum sustainable yield. These levels have beensuggested as F20%, F30%, and F40% which represent fishing mortality
rates to achieve respective preservation of 20%, 30%, and 40% of theunfished spawning stock biomass. These are increasingly moreconservative population thresholds and overfishing levels. This isintended to prevent low spawning stock biomass and related variability inrecruitment. Many fishery management organizations have adopted F30%
or more conservative guidelines, including the Pacific Fishery Management
Council and the North Pacific Fishery Management Council. Available
quantitative data demonstrate that Puget Sound rockfishes are far below
any of the standards cited above. (Note: even the mid-1970's data used asa surrogate for an unfished population probably represents a significant
reduction from "virgin biomass".)
One good thing has happened to Puget Sound rockfishes. In 1970, a
fortuitous decision was made to establish a refuge from fishing at asmall, 27-acre site now known as the Edmonds Underwater Park (EUP).
This now 28-year-old no-take site currently provides unambiguous
empirical evidence of true rockfish capabilities. Palsson and Pacunski(1998) found a mean density (fish per transect) of 30. 7 copper rockfish at
EUP. Four heavily fished central Puget Sound sites at Port Blakely, Blake
Island, Boeing Creek and Orchard Rocks had mean copper rockfish densities

SPAWNER OUTPUT
COPPER ROCKFISH-SJI
100 - - - - - - - - - - - :E
::>

80

~ 60

~
:E

u.
0
'cf!.

I

F40%

.. JIit

40
20

-

I

0 ■
1975

1980

1985

Figure 3. Historical reproductive output of copper rockfish in the San Juan Islands.

_...
1990

1995

of 4.2, 1.8, 2.4, and 0.6, respectively. For large copper rockfish (greaterthan 40 cm), EUP had a density of 26.1, while the other four areas haddensities of 1.1, 0.5, 0.1, and 0.2, respectively. Palsson and Pacunski( 1998) estimated that the reproductive potential of copper rockfish at
EUP exceeded the potential of the average fished site in central Puget
Sound by a ratio of 55 to one. The difference due to the diff~rent length
frequency distributions between no-take and fished sites accounted for a
four-fold increase in estimated egg production while the difference due todensities accounted for almost a fifteen-fold increase in estimated egg
production.
Palsson and Pacunski (1998) recommended that an extensive system of no­
take refuges be established to rebuild depressed populations and maintainthem in perpetuity. They also acknowledged that recent regulation
changes - mainly reduced daily bag limits - have completely failed to halt
population declines. Their project results indicated that one-third of all
rocky reef habitat should be placed in no-take status to rebuild the levelof reproduction to assure a suffici~nt level of recruitment to maintain the
populations. The primary benefit of the no-take refuges will be to produce
eggs and larvae within the refuges that will be exported to vacant or
depressed reef habitats in remaining fished areas. Other benefits include
fishery benefits from movement of large fish to fished areas, maintaining
genetic integrity, maintaining natural age and size distributions,establishing baseline areas for research, preserving ecosystem function
and others suggested by Bohnsack and Ault (1996).
However, the current situation is far from what is needed. WDFW
established two new small no-take areas in 1998 that will benefit
rockfishes. Previously, three other areas had been established - San Juan
Marine Preserves in 1990, Sund Rocks in Hood Canal in 1994, and Titlow
Beach near Tacoma in 1994. In addition, the County of San Juan recently
created (in 1997) eight small Voluntary No-Take Bottom Fish Recovery
Areas in recognition of the depressed status of marine fish populations.
The perception exists that these types of efforts can, by themselves, be
successful in resource restoration. In aggregate, they involve less than
1% of the habitats utilized by rockfishes.
Leaman and Beamish (1984) discussed the biological advantages of
longevity and the implications to population dynamics from management
policies that ignore these evolved advantages. They defined "longevity"

I( 1 5-50 yr) and "extreme longevity" (> SO yr) in fishes in reference tospecies that have life spans that are long when compared with all fish
species. Rockfishes certainly fit these categories, since Leaman andBeamish ( 1 984) gave maximum Canadian age records for five of thespecies listed in this petition (widow rockfish, 58 years; yellowtail
rockfish, 64 years; bocaccio, 36 years; canary rockfish, 75 years; andredstripe rockfish, 41 years). They also stated that maintenance of unique
age compositions among geographically proximate stocks of Pacific ocean
perch (Sebastes alutus) implied little mixing of adult fish among stocks.
Leaman and Beamish ( 1984) found that the most obvious potential benefitof a relatively long life was a long reproductive life. The extension of theperiod of reproduction reduces the risk that a long period of unfavorable
environmental conditions will result in loss of a stock. When the period
between favorable environmental conditions for a species was relatively
long (5-15 yr), it appeared that the life span was also relatively long.
Extreme life spans appeared to be an adaptive feature for ensuring
evolutionary persistence under reproductive uncertainty rather than for
maximization of population growth rate. There are additional ecologicalconsiderations such as the importance of continuously occupying a space,
the importance of dispersed spawning, or the selective advantage of
specific reproductive products. It has been shown that the viability ofeggs and larvae of many fishes is dependent on maternal condition,
including size (Ellertsen and Solemdal 1990 cited in West 1997). Extreme
longevity in fishes can also allow adults to exist in low productivity
environments where the probability of regular recruitment is very low.
The production and growth-oriented contemporary management strategies
derived for shorter-lived species can result in rapid over-exploitation of
accumulated biomass and a prolonged period of rehabilitation for the long
-lived fishes. Worse yet, a competing species can capitalize on vacant
space or resources and prevent the over-exploited species from everregaining its former abundance.
Thus, the genus Sebastes in Puget Sound faces a multitude of at-riskfactors. Species diversity has been markedly reduced, abundance of thegenus has declined precipitously, and the average fish size has becomemuch smaller. The last factor adds the further problems of fewer mature
females (as a percentage of the population)· and lower fecundity per
female. South Puget Sound, with its characteristic isolated "islands" ofsuitable rocky reef rockfish habitat, has experienced numerous localizedpopulation extinctions (the pet1t1oner personally contributed to one
Sebastes "extinction" at the Steamboat Island "hole" near Olympia, WA.).
The consequences can be serious since Allendorf et al. ( 198 7, p. 2) warnthat "Differential survival and reproduction of fish with different
genotypes will change the genetic composition of the harvested
population." This should be a source of concern since "high e_xternally-imposed adult mortality, such as from fishing, selects for increased
reproductive effort at younger ages, resulting in early maturity, shorter
life spans, smaller sizes, and semelparity (single reproductive episodes)"(NMFS 1990, p. 9). According to Allendorf et al. (1987), all populations offish that are included in a sport and/or commercial fishery will inevitably
be genetically changed by harvesting. Shortened life spans because offishing pressures can void protection against long-term environmental
fluctuation provided to species by long life spans achieved through eons ofevolution (Leaman and Beamish 1984).
Genetic studies using conventional techniques have not consistently
shown substantive population differentiation or structuring for Puget
Sound rockfishes. However, it is not clear whether these species haveundifferentiated populations or whether the conventional approach is not
the correct technique to answer the question. Various biochemical
approaches to species and population identification, including allozyme
and mitochondrial DNA (mtDNA), have been employed on rockfishes but
each of the approaches suffer some drawbacks. It is possible that future
work should focus on different techniques. A new approach, genetic
profiling of microsatellite DNA markers, may help clarify the influence of
local Puget Sound hydrographic and bathymetric features on population
structures of rockfishes.
Allozyme studies have shown some Pacific Coast rockfish species to be
divided into northern and southern populations, or that variation isclinally distributed (Wishard et al. 1980, Seeb 1986, and others).
However, in other rockfish species, allozymes and mtDNA RFLPs failed toindicate any obvious separation. Conventional techniques have sometimes
failed to even separate closely-related rockfish species. For example,
Heusch (1995) was unable to show differentiation between three
populations of quillback rockfish from Puget Sound but was also unable toseparate two closely-related species (copper and quillback rockfish).
Gove (1996) also failed to show differences for quillback rockfish but wasable to demonstrate population structuring for copper rockfish. Thisstructuring has also been demonstrated for coastal black rockfish
populations and the different groups paralleled results gained
independently from tagging studies (WDFW Genetics Unit, unpublisheddata). In a preliminary (small sample size) survey of population
subdivision in quillback rockfish in Puget Sound using one microsatellite
locus, heterozygosities for two populations from different a~eas wereslightly greater than 80% (Paul Bentzen, University of Washington,
unpublished data). In addition, he detected four alleles in central Puget
Sound that were not present in the San Juan Islands, suggesting
differentiation and population structuring. In the most recent pertinent
published report on the subject, Seeb (1998) supported the case forgenetically isolated populations of brown, copper, and quillback rockfish.
Geographic differentiation was detected within each species incollections ranging from California to Alaska. In addition, significant
shifts in allozyme frequencies were noted for copper rockfish in going theshort distance (about 70 km) from south Puget Sound to the San Juan
Islands. Alleles characteristic of the two other species were absent fromsamples of copper rockfish taken outside of Puget Sound but wereconsistently observed within Puget Sound. Seeb (1998) believed that
introgression may be occurring between all three species in Puget Soundand that it may be an important source of diversity in rockfishes.
Another compelling argument for the uniqueness of Puget Sound rockfishes
comes from the species composition of the genus. In the early 1960s,
Holmberg et al. ( 1961 ) stated that six species constituted "the great
majority" of ocean trawl fishery landings (Sebastes alutus, S. brevispinis,
S. pinniger, S. flavidus, S. rubrivinctus, S. dip/oproa). They also named
four species that were commonly caught but usually discarded at sea (S.
paucispinis, S. entomelas, S. saxico/a, S. elongatus). Only half (5 of 10) of
these species are even listed as "important" species in Puget Sound(Bargmann 1998a). More importantly, none of the ten are among the five
most common species currently found in Puget Sound and Holmberg et al.
( 1961, p. 43) stated that "The rockfish catch in Puget Sound is composedof two species not caught in the offshore grounds, namely S. caurinus andS. ma/iger." (copper and quillback rockfish).
Longevity can also come into direct conflict with adverse anthropogenic
stressors. Some of the highest levels of contaminants such as mercury
and polychlorinated biphenyls (PCBs) found in Puget Sound fishes havebeen !lleasured in quillback rockfish (multiple references cited in West1997). Because this species is long-lived, relatively high in the foodchain, and non-migratory, it tends to accumulate persistent pollutants
when present in their environment. The effects of these contaminants is
unknown; however, reproductive impairment documented in English sole
(Pleuronectes vetulus) occurred at lower contaminant concentrations, so
it is likely that impairment exists in demersal rockfishes. (Note:
relatively high levels of PCBs have also been observed in Pacific herring.
Although this species is short-lived, its tissues contain naturally highlevels of lipids, so lipophilic compounds such as PCBs are more likely tobe retained after ingestion.) This is one of many problems that justify
the designation of critica~ habitats, which is addressed in the next
section.
CRITICAL HABITA TS FOR AT-RISK PUGET SOUND FISHES
Any designation of critical habitat should encompass all marine andestuarine areas. Both of these habitats in turn have intertidal andsubtidal elements, and can be soft or hard bottom, vegetated or
unvegetated (Dethier 1990). The designation zone should begin 200 feetupland of the ordinary high-water mark and go seaward. For tributaries,
upstream extent of the zone should be the uppermost point of tidal
influence. While these parameters are somewhat artificial in an
ecological sense, intent is to keep the designation proposal focused on adiscrete and definable zone. The upland is included to recognize theimportant habitat functions of these adjacent areas. The 200 feet figure
is given because it represents the state's current Shoreline Management
Act jurisdiction, and allows some accounting for physical activities thatcan effect nearshore habitats.
It is significant that the zone encompasses an upland buffer. For example,
the substrate temperature-moderation effects of intact bordering forests
and water seeps have values to marine fishes analogous to the "riparian"
habitat situation for salmonids. A buffer will also encompass many
sediment "feeder" bluffs. Thus, the zone would recognize the importanceof continued sediment supplies to shorelines for habitat maintenance. The
continued maintenance of free-flowing streams from the adjacent uplands
will also be essential for the maintenance of sediment inputs,
particularily in areas susceptible to beach sediment "starvation" fromheavy shoreline armoring. Even tiny seasonal streams often have sizeableintertidal sand-gravel deltas at their mouths, replenishing beachesdowndrift.
There are a myriad of laws and actions that currently affect habitat
protection and restoration. However, without continued modification andsignificant improvement in management programs, marine life habitats
will continue to decline in extent and productive capacity, c~ntributing to
reductions in marine life populations and changes in other important
ecosystem parameters. It will be important to recognize the inter­
relationships between habitat components. Inadequate attention to one ormore habitat components can reduce, or eliminate, the benefit ofachieving the performance measures of another. For example, copper
rockfish use pelagic habitats as larvae, submerged marine vegetation
habitats as juveniles, and rocky reef habitats as adults. Many fish andwildlife resources indirectly rely on a number of different habitats
because their primary forage species use these habitats as spawning
and/or rearing substrates.
It is important to focus on the fundamental importance of habitat function
versus habitat presence, even though the latter is typically the only
measurable surrogate. For example, recent work on juvenile rockfish
recruitment pathways and processes (Buckley 1997) highlighted thespecific temporal and spatial partitioning of some habitats critical tosuccessful recruitment and survival of juveniles - habitats not only need
to be present, they need to be free of impacts that affect their functionsat specific times.
There are three general areas of marine and estuarine habitat: ( 1 ) tidally
influenced (intertidal) lands and estuaries; (2) nearshore (subtidal) marine
habitats; and (3) open water habitats. Levings and Thom (1994) describednine ·categories of "nearshore" habitats in Puget Sound and Georgia Basinthat actually encompass the first two categories listed above:
Marshes
Riparian vegetation
Sandflats
Mudflats
Rock-gravel habitats
Unvegetated subtidal
Kelp beds
Intertidal algae
Eelgrass

I

Levings and Thom ( 1994) reported estimates of significant changes inareal extent on a Puget Sound-wide basis for only three categories: A
75.9% loss in tidal marshes and riparian habitat, as a direct result of
infilling, diking, and other shoreline development, and a 52. 7% increase inareas of bull kelp, probably as a result of shoreline armoring .. This
generally consists of changing unconsolidated, soft substrate toconsolidated, wave and erosion-resistant substrate, including installationof bulkheads and jetties (Note: while this seems to sound positive, thesekelp beds could be in inappropriate juxtapositions with essential
recruitment habitat pathways, and thus create "recruitment traps" that
result in reduced survival of juvenile rockfishes (Buckley 1997)).
Mumford (1990) did indicate that regional losses of bull kelp forests haveoccurred in areas such as south Puget Sound. Losses of other habitat
types have proven to be more difficult to measure even though there is a
general concern that seagrass habitats have suffered major losses ordegradation in recent years (Wyllie-Echeverria 1994 cited in West 1997).
An additional emerging problem in recent years has been a greatly
increased recreational harvest of kelps and other nearshore macroalgae.
Aquaculture operations have also been cited as a potential source ofhabitat loss or degradation in Puget Sound. For example, loss of nearshore
vegetative habitat occurs in areas where Pacific oysters are cultured.
Potential conflicts between "wild" marine fish resources and the massive
public and private aquaculture of salmonids are often suspected (West1997) but never pursued to a meaningful conclusion. Critical issues suchas carrying capacity, competition and predation are very difficult to
study, much less resolve. Unfortunately, the "burden of proof' continues
to be placed on marine fish resources.
West ( 1 99 7) stressed the importance of submerged marine vegetation(SMV) which he defined as marine vegetation which is submerged duringsome part of the tidal cycle, including seagrasses, overstory andunderstory kelps, and turf algae. West (1997) reported that a number ofmarine life species rely on SMV for successful completion of their life
cycle and, in addition, SMV habitats support a high diversity and abundanceof organisms, and provide (1) a source of energy (through primary
production), (2) refuge and foraging habitat for myriad organisms, (3)substrate for attachment of sessile organisms, ( 4) dissipation of wave
and current energy, (5) stabilization of sediments, and (6) transfer ofenergy to deep or other habitats. He also stated that if the location ofnursery habitat beds are changed through mitigation (e.g., transplanting
eelgrass) or other human activities, then existing patterns of supply ofjuveniles may not match the altered habitat distribution.
Thus, essential habitats can be lost or damaged by:
Shoreline armoring, which can lead to beach erosion, interrupt sedimentflow, adversely affect biotic systems dependent on those sediments,
physically displace (and destroy) high intertidal habitats (e.g., forage fish
spawning habitat), eliminate riparian habitat (e.g., overhanging
vegatation).
Land filling, which can cover spawning habitat and physically displace anddestroy algae and other marine vegetation.
Diking and channeling, which can change salinity and water regimes andresult in the complete loss of natural habitats.
Dredging, which can destroy marine plants and animals (during dredging),
remove habitat (e.g., by deepening dredged areas beyond species' ability tosurvive), adversely affect water quality by releasing toxins (whensediments are contaminated), or by removing sediment-trapping
vegetation.
In-water structures, which can shade algae and marine vegetation andreduce species abundance.
Clearing and grading, which can result in increased sediments in the watercolumn (from runoff) that can smother or shade marine plants and sessile
or slow-moving invertebrates, and can remove overhanging riparianvegetation.
Nutrient enrichment from point and non-point pollution, which can lead toproliferation of algae that can shade or smother eelgrass or other marine
plants.
Exotic species, such as Spartina, which can displace native plants andadversely affect ecosystem function.
Water pollution from storm water runoff, malfunctioning septic systems,
agricultural practices, point source discharges, and oil spills, which cancontaminate and degrade nearshore habitats.
Shifts in water flow regimes, which can result in changes in salinity andadversely affects estuarine systems.
Recreational harvest of algae (e.g., kelp) which can result in loss of foodsource and cover for marine species.
Aquaculture, which can affect habitats by beach graveling, spraying ofpesticides, removal of attached vegetation, or competing with indigenous
species for a finite primary productivity.

At least some of these observable adverse physical impacts can bequantified. By analyzing sampling data for Puget Sound habitats, Bailey etal. ( 1997) made the following point estimates for percentage of shoreline
length with human modifications:South Puget Sound - 34.4%
Central Puget Sound - 52.1 %North Puget Sound - 3 5. 7%
Hood Canal - 32.4%
San Juan/Straits - 20.2%
The loss of nearshore habitat was identified as the most significant
threat to the health of marine waters in the Puget Sound and Georgia Basin(British Columbia/Washington Marine Science Panel 1994 cited in West1997).

I

REFERENCES
Allendorf, F. W., N. Ryman, and F. M. Utter. 1987. Genetics and fishery
management: past, present, and future. Pages 1-19 In N. Ryman and F.
Utter, eds. Population genetics and fishery management. Washington Sea
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Bailey, A. H., H. Berry, B. Bookheim, and D. Stevens. 1997. Probability­
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Bargmann, G. 1998a. Puget Sound groundfish management plan.
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Bargmann, G. 1998b. Forage fish management plan. Washington
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Behnke, R. J. 1985. About trout - greenback cutthroat. Trout 26(1 ):42-46.
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Buckley, R. M. 1997. Substrate associated recruitment of juvenile
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Juan Archipelago, Washington. Washington Department of Fish andWildlife Technical Report RAD97-06, Olympia, WA.
Clark, W. G. 1993. The effect of recruitment variability on the choice of atarget level of spawning biomass per recruit. Pages 233-246 In
Management strategies for exploited fish populations. Alaska Sea Grant
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Dethier, M. N . . 1990. A marine and estuarine habitat classification system
for Washington. Washington Natural Heritage Program, Department of
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Gove, C. E. 1996. A molecular comparison among Sebastes species andpopulations along the West Coast and within Puget Sound. Senior thesis,
University of Puget Sound, Tacoma, WA.

Heusch, W. 1995. Molecular relationships among three rockfish(Sebastes) species in Puget Sound. Senior thesis, University of Puget
Sound, Tacoma, WA.
Holmberg, E. K., D. Day, N. Pasquale, and B. Pattie. 1967. ResE:arch reporton the Washington trawl fishery, 1962-1964. Washington Department of
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