National Marine Fisheries Service: Cumulative Impacts Not Considered by Nationwide Permits

Cumulative impacts: The impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such other actions. (40 CFR 1508.7).

(click here to read the Bilogical Opinion)

A Biological Opinion written by National Marine Fisheries Service (NMFS) has told the Army Corps their 2012 Nationwide Permits are not able to determine whether cumulative impacts  are adversely impacting the environment.  NMFS has told the Army Corps they will now need to take specific steps with NFMS's Regional or Branch Office to ensure cumulative impacts are in fact considered (beginning on page 225).

NMFS's Northwest Regional Office, including the Southwest Washington Habitat Branch covering Mason, Thurston, Pacific, Pierce and Grays Harbor Counties, are now responsible for overseeing the Army Corps' implementation of Nationwide Permit 48 which covers existing shellfish farms as well as proposed new farms or expansion of existing farms.  They will be responsible for determining whether, in fact, cumulative impacts from shellfish farming can be determined and whether they are occurring.

Will the "Shellfish Initiative" and "streamlined permitting" being promoted by NOAA, the department overseeing NMFS, allow for objective oversight?  As it relates to Puget Sound and aquaculture, it borders on the fox guarding the hen house.  Especially in light of the recent lobbying by the shellfish industry to minimize the Army Corps' oversight of their activities.

(Shellfish industry lobbying paper on

minimizing Army Corps' oversight)

(Click to enlarge)