PPF & OEC Comment on Hood Canal Shellfish Plans
Olympic Environmental Council
PO Box 2664 Sequim WA 98382
Protect The Peninsula’s Future
PO Box 1677 Sequim WA 98382
10 November 2020
Nate White
Hood Canal Coordinating Council
Watershed Projects Coordinator
nwhite@hccc.wa.gov
RE: Draft Hood Canal Shellfish Initiative Action Plan
The Olympic Environmental Council and Protect the Peninsula’s Future have multiple concerns about the Hood Canal Coordinating Council (HCCC) moving forward with its plan.
First, we want to see the total number and acreage commercial shellfish projects will cover in the Hood Canal. Cumulative impact needs serious reflection. According to a DOH map, <https://fortress.wa.gov/doh/oswpviewer/index.html>, 5800 Hood Canal acres have been approved for shellfish projects. This is well out of proportion and damaging to the tidelands. Cumulative impacts looking at all aspects of the industry need to be studied for the health of the Canal environment. Enabling this amount of acreage, given the various impacts this industry induces into the system, is counter to cleaning up Puget Sound and net gains.
Second, this industry heavily adds to the plastic content in the marine environment—macro, micro and chemicals, and these travel up the food chain to humans who excrete in their feces back to the sewage and indirectly back into the waters. The plastics can break down into their molecular constituents. There are 30,000 published studies just on bisphenol A (BPA). Plastics circulate back into the air and onto the soil and are absorbed by crops. We breathe and eat them. These are linked to hormonal disorders as well as coronary heart problems, costing the health industry $3Billion/annually. (1)
Plankton, an essential food for marine animals, have been scientifically shown to imbibe plastics in the marine system, causing them to eat less – even by 40% — and transfer these up the food chain, including to crabs and bivalves (including mussels and oysters) and more. Copepod egg sizes are smaller when plastic has been ingested, equating to less eggs hatched and less food for marine animals up the food chain. These same plasticized-copepods are molting earlier and reaching adult stage too soon. Plastics can aggregate in different areas of these and other animals and change their behaviors. Behavioral changes have been shown in metabolic energy, fecundity and early mortality. Animals can be abnormally smaller and not advance to adulthood. Plastic loads have been found to be highest in oyster and oyster larvae per tissue gram. Some surface waters are used for potable water; hence, plastic is showing up in the drinking water. (2)
The result is harm to wildlife and to humans. These plastics end up on beaches, too, causing harm here and amplifying the amount of beach cleanups needing to be done.
This industry is not being responsible to the protection of the marine life and the higher food chain. It is passing financial and other costs elsewhere.
Third, PFAS is in our marine waters. Will HC shellfish project owners be responsible for testing for levels in the marine areas in which they plan to raise shellfish and in their animals? These appear to weaken the immune system, cause obesity, lower resistance to infectious diseases, cause cancer, reduce, COVID-19 vaccine effectiveness, and may inhibit the formation of antibodies. (3-10)
Fourth, what is the long-term plan for raising shellfish in warming waters and rising water/flood levels.
In sum, raising shellfish in the above conditions, moving blindly without the above data – plastics, PFAS and other, is a short-term benefit to the growers and long-term harm to the marine ecosystem, wildlife and human health.
We would like to see your scientific studies on the above.
Respectfully submitted,
Darlene Schanfald,
Secretary Olympic Environmental Council
Steve Koehler,
President Protect the Peninsula’sFuture
CITATIONS:
1. https://munin.uit.no/handle/10037/16566 Microplastics; occurrence, levels and implications for environment and human health related to food. Opinion of the Steering Committee of the Norwegian Scientific Committee for Food and Environmen
2. Cole M, Coppock R, Lindeque PK, Altin D, Reed S, Pond DW, Sørensen L, Galloway TS, Booth AM (2019). Effects of Nylon Microplastic on Feeding, Lipid Accumulation, and Moulting in a Coldwater Copepod. Environ Sci Technol, 53(12), 7075-7082
- Grandjean P, Andersen EW, Budtz-Jørgensen E, et al. Serum vaccine antibody concentrations in children exposed to perfluorinated compounds [published correction appears in JAMA. 2012 Mar 21;307(11):1142]. JAMA. 2012;307(4):391-397. doi: https://jamanetwork.com/jour- nals/jama/fullarticle/1104903
4 Granum B, Haug LS, Namork E, et al. Pre-natal exposure to perfluoroalkyl substances may be associated with altered vaccine antibody levels and immune-related health outcomes in early childhood. J Immunotoxicol. 2013;10(4):373-379. doi: https://www.tandfonline.com/ doi/full/10.3109/1547691X.2012.755580
- Abraham K, Mielke H, Fromme H, et al. Internal exposure to perfluoroalkyl substances (PFASs) and biological markers in 101 healthy 1-year-old children: associations between levels of perfluorooctanoic acid (PFOA) and vaccine response. Arch Toxicol. 2020;94(6):2131-2147. doi: https:// link.springer.com/article/10.1007/s00204-020-02715-4
- Timmermann CAG, Jensen KJ, Nielsen F, et al. Serum Per- fluoroalkyl Substances, Vaccine Responses, and Morbidity in a Cohort of Guinea-Bissau Children. Environ Health Perspect. 2020;128(8):87002. doi: https://www.ncbi.nlm.nih. gov/pmc/articles/PMC7416537
- Stein CR, McGovern KJ, Pajak AM, Maglione PJ, Wolff MS. Perfluoroalkyl and polyfluoroalkyl substances and indica- tors of immune function in children aged 12-19 y: National Health and Nutrition Examination Survey. Pediatr Res. 2016;79(2):348-357. doi: https://www.nature.com/articles/ pr2015213
- Looker C, Luster MI, Calafat AM, et al. Influenza vaccine response in adults exposed to perfluorooctanoate and perfluorooctanesulfonate. Toxicol Sci. 2014;138(1):76- 88. doi: https://academic.oup.com/toxsci/arti-cle/138/1/76/1671296
- Kielsen K, Shamim Z, Ryder LP, et al. Antibody response to booster vaccination with tetanus and diphtheria in adults exposed to perfluorinated alkylates. J Immunotoxicol. 2016;13(2):270-273. doi: https://www.tandfonline.com/ doi/full/10.3109/1547691X.2015.1067259
- Pilkerton CS, Hobbs GR, Lilly C, Knox SS. Rubella immunity and serum perfluoroalkyl substances: Sex and analyt- ic strategy. PLoS One. 2018;13(9):e0203330. Published 2018 Sep 24. doi: https://journals.plos.org/plosone/arti- cle?id=10.1371/journal.pone.0203330
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