Permitting The Pothole and Reversing an Area Plan: From Crab Pots, To Log Rafts?

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Where: The Pothole of Alexander Bay indents the eastern shore of Woewodski Island, just to the south of Kupreanof Island’s Lindenberg Peninsula, 20 miles south of Petersburg.  The Pothole lies north of the southern entrance of the heavily trafficked Wrangell Narrows, a labyrinth of over 60 channel markers in a shallow ribbon of water over 20 miles long.  This scenic waterway functions like a river that divides Mitkof Island from Kupreanof Island and Woewodski Island.  It is one of southeast Alaska’s most logistically important, and popular segments of Alaska’s Inside Passage.

A Concern

As its name implies, The Pothole is a good place for setting Dungeness crab pots.  But the Forest Service now proposes to replace those crab pots with log rafts as part of its Tonka Timber Project.  In November of 2011, the Forest Service released the Draft Environmental Impact Statement (DEIS) for the project and proposed the removal of up to 53.4 million board feet of old growth timber from the Lindenberg Peninsula.  As part of this project, the Forest Service is applying for a 5 year renewable permit from the State of Alaska to use the Pothole for log storage.  The proposal to proceed with using the Pothole is simply unfair to the many local residents and commercial fishermen, southeast Alaskans and others who use the area for subsistence, personal use and commercial crab fishing.  Permitting the Pothole would obviate the intent of Alaska’s Forest Resources and Practices Act codified in the Alaska Administrative Code (AAC):

11 AAC 95.150. LOG TRANSFER AND STORAGE FACILITIES,

 (a) Where feasible, preference must be given to onshore storage and barging of logs.

If the Forest Service obtains its permit,  Alexander Bay would be dominated by a 9 acre floating sort yard within which tugs would assemble and store millions of board feet of old growth timber into gigantic log rafts.  Tugs would then tow the large rafts to a distant mill.  This proposal ignores industry best management practices and Alaska regulations that express a strong preference for barging logs rather than towing log rafts and storing them in marine habitats.  The reason for this preference is that in-water log storage leads to degradation of marine habitats through the deposition of bark and other detritus on the bottom.  In addition to degradation of marine habitat, these activities would not only displace crab fishing activities, but preclude all vessels from using this popular anchorage.

Ignoring the Issue: The Forest Service Ignores the Rules Governing Log Storage at the Pothole and Impacts of Log Storage on Fishery Resources

The Forest Service has repeatedly downplayed the known risks associated with using the Pothole for log storage.  There have been only a few cursory dive surveys to measure bark accumulation levels.  The Forest Service did not conduct scientifically credible baseline assessments in the area nor did it provide for opportunities to do so in the future.  This information is important to meas- ure what changes to habitat might occur — or have already occurred — over the years as a result of log storage there.

This cavalier attitude is particularly disturbing because using the Pothole for log storage breaks nearly every guideline established to ensure that log storage facilities occur in areas where timber operators can reduce risks to marine habitat.  The Alaska Timber Task Force log storage facility siting guidelines are for the purpose of controlling adverse impacts to water quality and aquatic habitat and recommend the following: (1) avoid shallow waters 40 feet deep or less; (2) avoid proximity to salmon streams; (3) avoid productive marine habitats and (4) limit the area of bark deposition to one acre.  But here, most of the Pothole is less than 40 feet deep, two salmon streams empty into the bay, the state has specifically recognized the Pothole’s productive habitat, and the Forest Service wants permission to deposit bark across a 9.2 acre area in that habitat.

By ignoring these guidelines and using the Pothole for log storage, the Forest Service would force fishermen to bear the costs of making log transportation more affordable.  Boyer Towing had previously obtained a temporary permit to use the Pothole after insisting that other permitted sites were too costly to use.  Alaska’s Division of Mining, Land and Water (DMLW) issued the temporary permit explicitly to allow a transition from outdated log raft transportation to the use of log barges, while also acting on the necessity of avoiding — from then on — impacts from log storage to marine habitats of the Pothole and similar locations.  That permit expired in 2008.

This refusal to abide by the siting guidelines is just one example of bending the rules for timber operators at the expense of fishery interests.  Because of the importance of the area for crab habitat and for crab fisheries, the State of Alaska designated this area for crab harvest and crab habitat in the Central Southern Southeast Area Plan (CSSAP) finalized in 2000.  Local governments and the public helped to develop the CSSAP and participated in the decision to prioritize fishery uses of the Pothole.  It is true that the timber industry had previously used the Pothole for log storage during the pulp mill era which ended after the passage of the Tongass Timber Reform Act in 1990.  But at the time the CSSAP was finalized in 2000, the timber industry had transitioned to the more environmentally responsible method of barging logs and there was no interest in continuing the obsolete practice of in-water log storage at the Pothole.  In sum, the Forest Service’s proposed use of the Pothole is a reversal of the State-recognized public process and public decisions about appropriate uses of local resources.

The Forest Service’s refusal to recognize impacts to crab and fisheries is worrisome to many commercial crab fishermen, the fishing organizations which represent them, and ADFG Crab Management biologists charged with overseeing the fishery.  The Dungeness crab fishery contributes millions of dollars annually to the local economies of Petersburg and Kupreanof, but the fishery faces many threats.  In particular, the fleet faces marginalization as effort has become increasingly concentrated into fewer and fewer areas.  This is due to rapidly expanding sea otter populations depleting crab and shellfish resources, multiple area closures, degraded habitats, and reduced funding of Alaska Department of Fish and Game (ADFG) crab management, all of which result in an increasing future uncertainty for this commercial fishery which has provided viable livelihoods for generations of local residents.

A Real Issue: Permitting Log Storage Activities Known to Damage Pothole’s Productive Marine Habitat

Female crab carry fertilized egg clusters on their exterior abdomen and the eggs then hatch into free-swimming crab larvae known as “zoea”.  The zoea initially hatch into the water column and ultimately metamorphose into tiny versions of adult crab.  Alexander Bay and the Pothole provide high quality habitat vital to all stages of the Dungeness crab life cycle.  The extensive shallow waters associated with estuarine habitat and two salmon streams provide rich crab grounds.  The bay faces southeast and is protected from the heavy tidal forces of the Narrows.  Because the bay faces the direction of the prevailing winds and lies within a natural back eddy of tidal currents in the Narrows, it is a natural collector of wind and current-driven larvae and an excellent nursery for crab larvae development.

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Female crab carry fertilized egg clusters on their exterior abdomen and the eggs then hatch into free-swimming crab larvae known as “zoea”.  The zoea initially hatch into the water column and ultimately metamorphose into tiny versions of adult crab.  Alexander Bay and the Pothole provide high quality habitat vital to all stages of the Dungeness crab life cycle.  The extensive shallow waters associated with estuarine habitat and two salmon streams provide rich crab grounds.  The bay faces southeast and is protected from the heavy tidal forces of the Narrows.  Because the bay faces the direction of the prevailing winds and lies within a natural back eddy of tidal currents in the Narrows, it is a natural collector of wind and current-driven larvae and an excellent nursery for crab larvae development.

The quality of the marine environment at these early life stages is crucial in determining whether they will survive into maturity as adult crab.  The south facing, extensive subtidal shallows which make up most of the Pothole, allow sunlight to reach eelgrass and macroalgae over large areas, which in turn, provides beneficial habitat.  The nutrient rich waters of the Pothole feed zooplankton, and phytoplankton, which is food for dungeness zoea along with a panoply of other marine species which abound there, including herring and juvenile salmon.

Log storage degrades marine habitat and threatens sensitive juvenile and other crab life cycle stages in critical marine habitats.  The mechanism of lingering impacts is not so much the depth of the bark accumulation under the rafts that cursory dive surveys typically measure.  Rather, the longterm and serious problem pertains to the changes in chemical conditions and oxygen levels within the substrate where crab burrow, feed and reproduce.  The result of bark deposition is an acidic, anoxic environment that is frequently inhospitable to crab and other marine species.  Often, diseased crab are encountered where no bark is present.

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How degradation occurs is a straight forward process.  The millions of board feet of logs from the Tonka Timber Sale (and possibly other timber sales) will deposit bark and organic debris into the waters of the Pothole.  Due to insufficient currents and shallow waters, this detritus can overwhelm the natural capacity to disperse the waste products of aerobic decomposition.  This results in depletion of dissolved oxygen (anoxic) bottom conditions which cause significant changes to plant and animal communities.  This is also the formula for “dead zones” which are often referenced in the media these days.

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When byproducts of anaerobic decomposition prevail on site, they produce hydrogen sulfide which is a highly toxic, acidic substance which reeks of rotten eggs.  This creates highly acidic substrate which then chemically attacks living organic matter such as egg clutches and body parts of crab which come into direct contact with the toxic substrate.

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Besides egg mortality, dactyls (toes) are the first body parts to be affected starting with discoloration, then leading to necrosis, and ultimately ulcerating lesions proceeding to joint capsules, then upper leg sections.  These crab continue to live even as their body parts decompose.  The physically compromised and weakened crabs cannot adequately feed or grow to the extent they might escape their predicament by successive molting to regenerate new body parts.  A closeup of the diseased gravid female shows that the eggs with the most direct contact to anoxic substrate are the first to turn black, and as research shows, are often rendered non-viable.  Affected crab are in essence, the living dead, within which diseases might find a weakened host to possibly mutate and migrate to other population segments.

Crab, of course, are not all that get impacted.  Several marine species, including those which crab depend upon for food, are also impacted.

Conclusion

There is a significant body of research which demonstrates degradation of marine habitat resulting from log storage can be expected in sites such as the Pothole.  A state-sanctioned, two year long deliberative process involving municipalities and the larger public identified The Pothole in the Central Southern Southeast Area Plan for the priority uses of crab habitat and crab harvest.

There is strong evidence that state and federal agencies seem more than willing to succumb to political pressure to make decisions that reverse the prior decisions of the Area Plan in order to benefit an export-driven, heavily subsidized timber industry at the expense of existing and self-supporting resource based local economic sectors like the commercial crab fishery.

After-the-fact monitoring of impacts to previously healthy, productive marine habitat does little more than measure bark deposition and note the presence of pollution-tolerant marine worms, etc.  Such monitoring means very little if there is no baseline assessment of site productivity.  Over time, the state may find that impacts exceed regulatory thresholds and issue a declaration of an impaired waterbody.  By then, it may be too late to ensure that The Pothole will have enough habitat left to support commercially viable populations of Dungeness crab.  The Forest Service’s refusal to consider the needs of economic sectors other than the timber industry is an anachronism best left to the pulp mill era along with the practice of in-water log storage.

Partial Bibliography and selected quotes

Faris, T. L., Vaughan, K.D. 1985. Log transfer and storage facilities in southeast Alaska: a review. Gen. Tech. Rep. PNW-174. Portland, OR: U.S. Dept. of Agriculture, Forest Service, Pacific Northwest Forest and Range Experiment Station, 1985. 24 p.

Kirkpatrick, B., T.C. Shirley and C.E. O’Clair. 1998. Deep-water bark accumulations and benthos rich- ness at log transfer and storage facilities. Alaska Fishery Research Bulletin, vol 5(2): 103-115.

Morado, O’Clair & Sparks. 1988. Preliminary Study of Idiopathic lesions in the Dungeness crab, Cancer magister from Rowan Bay, Alaska.

O’Clair, C.E. and L. Freese. 1985. Responses of Dungeness crabs, Cancer magister, exposed to bark debris from benthic deposits at log transfer facilities: Survival, feeding and reproduction. Pages 227-229 in B.R. Melteff, Symposium Coordinator. Proceedings of the symposium on Dungeness crab biology and management. Univ. of Alska Sea Grant Rep. 85-3.

O’Clair, C.E., and J.L. Freese. 1988. Reproductive condition of Dungeness crabs, Cancer magister, at or near log transfer facilities in Southeastern Alaska. Marine Environmental Research 26:57-81.

Sedell, J.R., F.N. Leone and W.S. Duval. Water Transportation and Storage of Logs. IN: Meehan, W.R. 1991. Influences of Forest and Rangeland Management on Salmonid Fishes and Their Habitats. Ameri- can Fisheries Society Special Publication 19. 751. p.

Triton Environmental Consultants, Ltd. An Overview of Water Based Log Handling on the North Coast of British Columbia.

Washington Dept. of Fish and Wildlife. 2008. Management Recommendations for Washington’s Priority Habitats and Species: Dungeness Crab.