Delaware, New Jersey Issue Joint Position Opposing
Introduction of Asian Oyster
December 28, 2004
Delaware Division of Fish and Wildlife Fisheries Administrator
Roy Miller announced today that Delaware and New Jersey have issued
a joint position statement opposing the proposed introduction of the
Asian oyster, Crassostrea ariakensis, on the U.S. Atlantic coast at
Todays announcement follows recent statements
by Maryland Gov. Robert Ehrlich, reported in the December, 2004 Bay
Journal, indicating that Maryland was petitioning EPA to conclude
work on an environmental impact statement by March, clearing the way
for an introduction of the non-native oysters into Chesapeake Bay
in early 2005.
Officials in Delaware and New Jersey consider this announcement
premature and oppose introduction at this time due to inadequate knowledge
of the biology and ecology of the Asian oyster. If Asian oysters are
introduced into the Chesapeake Bay, it could eventually result in
active or passive introduction of the oyster into Delaware Bay, where
emphasis is being put on restoration of native oysters.
The joint policy statement issued by Delaware Division
of Fish and Wildlife Director Patrick Emory and New Jersey Division
of Fish and Wildlife Director Martin McHugh addresses the need for
regional consensus on the adequacy of supporting research rather than
adhering to an arbitrary timeline. The two states recommend that Maryland
give additional consideration to the traditional management measure
of reducing fishing mortality, and also advocate a more active
role for the Atlantic States Marine Fisheries Commission, recommending
that it convene the Shellfish
Transport Committee in a series of meetings to review the proposed
introduction throughout the environmental impact statement process.
The National Academy of Sciences and the Chesapeake
Bay Program Scientific and Technical Advisory Committee have both
recommended projected time spans of five years for research needs
on this oyster.
Scientists have struggled for approximately 15 years
with the issue of introducing non-native species to offset the decline
of the American oyster in the Chesapeake Bay. Another Asian native
oyster, Crassostrea gigas, has been introduced extensively around
the world, but, as noted in
the position paper, it took more than a decade of field studies to
conclude that the species would fare no better than the American native
oyster in the Chesapeake Bay.
There are too many unknowns surrounding this newest
Asian oyster proposed for possible introduction, said Emory.
Some of the recent research studies appear inconclusive and
highlight the need for a more regional approach.
The joint position paper is attached:
Joint Position of the States of New Jersey and Delaware
on the Proposed Introduction of Crassostrea ariakensis on the U.S.
Atlantic Coast and the E.I.S. Process Supporting That Introduction
Since 1989, the states of New Jersey and Delaware have
been continuously involved in Asian oyster research issues in Delaware
and Chesapeake Bays. On an annual basis, we have been involved in
review of research proposals and commented on research permit applications.
New Jersey has issued permits for experimental field deployment of
Crassostrea gigas on several
occasions. Delaware, as a signatory of the Chesapeake Bay Exotic Species
Plan, has provided technical input to annual ad hoc exotic oyster
panels, convened to review field research proposals and commercial
trials, focusing on bio-security issues. In the mid-1990s, both
the International Council for the Exploration of the Seas (ICES) Workgroup
on Transfers of Marine Organisms regarding bio-security issues involved
in exotic oyster research, the only U.S. states to do so. Initially
on opposite sides of the exotic oyster issue, New Jersey and Delaware
have been in agreement on this issue since 1995.
When the concept of using non-native species to offset
the decline of American oyster in Chesapeake Bay arose approximately
15 years ago, the primary candidate was Crassostrea gigas. This oyster
is a native of Asia, where it is the major commercial oyster. It has
extensively around the world, including Europe, North America and
Australia and its biology and ecology are well documented in the scientific
literature. Despite this, it took almost a decade of field
experiments to conclude that its growth and survival was no better
than that of the native oyster in the moderate and low salinity waters
of Chesapeake Bay. Furthermore, its thin shell and susceptibility
to the commensal polychaete, Polydora websteri, as well as various
it a poor choice for introduction in the mid-Atlantic region.
In marked contrast, the current exotic oyster of interest
is a virtual unknown. There has been very little published regarding
the biology and ecology of Crassostrea ariakensis. To make matters
worse, the historical literature on the species, which might have
served as input information
for predictive population models, has been cast into doubt. Recent
genetic testing indicates that more than a single species was used
in these studies, making their value questionable (King, personal
communication, 2004). In addition, recent trips to Asia, by oyster
researchers to study
C. ariakensis in Asian habitats, which form the basis of current opinions
of reef building characteristics, are now in doubt. On-going genetic
testing of 210 oysters collected at two sites has shown that over
94% of putative C. ariakensis are actually C. gigas, a known reef
(Luckenbach et. al, 2004). This work, conducted, in part, to determine
whether C. ariakensis is a reef builder, failed to make that determination,
at this time. The reef building characteristics of C.
ariakensis remain unknown.
Although the use of triploid oysters is not a major
issue in this proposed diploid introduction, the issue provides a
good example of how long it can take to learn about biological issues,
even when we think we know all the facts at the outset. In the early
1990s, chemically-induced triploids
were proposed as a means of inducing sterility and ensuring bio-security.
Triploid oysters were thought by some researchers to be 100% stable.
Reversion from triploid to the normal diploid was said to be unknown
in the animal kingdom. (Allen, personal communication,(1994).
1995, in an in situ study in Virginia, 26.5% of triploid oysters were
found to have begun the reversion process, seven months after deployment.
Six percent had become virtual diploids. (Outten, personal
communication, 1995) As a result, chemically-induced triploids were
replaced as a bio-security measure with mated triploids.
These tetraploid-diploid crosses were also thought to be 100% triploid
and 100% stable. Subsequent research has shown that neither of these
presumptions is true (Kern, personal communication, 2000, 2003). Mated
triploids revert at a lower rate and each batch contains an undetectable
level of normal diploid individuals. The characteristics of triploidy
are among the most important issues impacting bio-security during
the work over the last 15 years, yet it has taken over 10 years to
get to our current, imperfect level of understanding and important
questions remain. It is not unrealistic to expect that it may take
a similar amount of time to adequately examine the biology and ecology
of C. ariakensis. This process may reveal fatal flaws in the candidacy
of C. ariakensis for introduction, as was the case with C. gigas.
Certainly the extreme susceptibility of C. ariakensis to Bonamia,
a naturally occurring parasite on the Atlantic coast, is one example
of an unanticipated risk associated with introducing
an exotic species into a new habitat. How Bonamia will affect C.
ariakensis and, in turn, how C. ariakensis may serve to spread Bonamia
if the proposed exotic oyster introduction is carried out in the mid-Atlantic
is completely unknown at this time. Answering this question with the
confidence necessary to prevent a potential ecological disaster would
certainly take several years.
In the past several years, a number of high level expert
panels have grappled with the problem of the introduction of a non-native
oyster species. Each has developed recommended research needs and
a projected timeline for their completion. The National Academy of
recommended studies over a five year period (2003). In 2003, the Chesapeake
Bay Program Scientific and Technical Advisory Committee (STAC) has
made specific research recommendations, also covering a five year
time span. The federal cooperating agencies have recommended research
needs for a defensible environmental impact statement (E.I.S) which
extend through 2007, the end point of a five year federally-funded
research effort which began in 2003. Maryland alone proposes another
timeline, proposing to review its single year of studies in December
2004, with a possible decision to unilaterally introduce the non-native
in February 2005.
STATEMENT OF POSITION
The states of New Jersey and Delaware oppose the proposed
diploid introduction of Crassostrea ariakensis on the U.S. Atlantic
coast, at this time, for two reasons. First, in our view, there is
inadequate knowledge of the biology and ecology of this oyster. A
responsible decision to
introduce this exotic species should not be made under these circumstances.
Second, we believe that no single state has the right to impose the
introduction of an exotic oyster on neighboring jurisdictions Public
policy issues which have interstate ramifications call for overriding
federal or regional approval, as is the case in pollution-related
situations where there are interstate impacts. In
addition, given its role in interstate fishery management issues,
the Atlantic States Marine Fisheries Commission must play a more active
role in this matter and convene the Shellfish Transport Committee
in a series of meetings to review the proposed introduction throughout
the E.I.S. process. The states of New Jersey and Delaware oppose any
departure from the research framework outlined by the Federal Cooperating
Agencies in support of E.I.S. development. Moreover, we believe the
decision to conclude the E.I.S. process should be made when there
is consensus that adequate supporting research has been conducted,
rather than being tied to an
arbitrary timeline. It is possible this process may take more than
five years. Maryland officials have been quoted in recent press releases
as saying that the reasons for considering an exotic oyster introduction
are disease and over fishing. The states of New Jersey and Delaware
Maryland enhance and expand efforts to employ traditional fisheries
management techniques, such as total allowable catch (quotas) and
area closures when stock assessment information collected by the state
indicates that spawning stock biomass is critically low on particular
oyster beds, as suggested in Jordan and Coakley (2004). The authors
modeling efforts suggest that a 40% reduction in fishing mortality
over a period of a decade would virtually assure stock restoration
and an enhanced fishery.
The states of New Jersey and Delaware are concerned
about recent statements by Maryland officials and Corps of Engineers
personnel regarding the N.E.P.A. process. It would appear that these
individuals may have pre-judged the issue and are not considering
all E.I.S. alternatives,
but rather are moving to expedite the introduction of the non-native
oyster with an abundance of optimism and a relative dearth of information.
The N.E.P.A. process must remain an objective, data-based, professional
decision making process.
Allen, S.K., Jr., 1993. Personal Communication. (Virginia
Marine Sciences, Gloucester Point, Va.).
Chesapeake Bay Program STAC, 2003. Identifying and Prioritizing
Required to Evaluate Ecological Risks and Benefits of Introducing
Crassostrea ariakensis to Restore Oysters to Chesapeake Bay. Report
STAC Workshop December 2-3, 2003 Annapolis, Md.
Federal Cooperating Agencies (EPA, FWS, NOAA), 2004.
Summary of Research
Needs for a Defensible EIS on the Non-native Oyster. August 31, 2004.
Jordan, S. J., and J. M. Coakley, 2004. Long-term Projections
Oyster Populations under Various Management Scenarios. Journal of
Shellfish Research vol. 23(1): 63-72.
Kern, F., 2000, 2003. Personal Communication. Discussions
Chesapeake Bay Program ad hoc Oyster Panels. (Oxford Cooperative
Laboratory, Oxford, Md.)
King, J., 2004. Personal Communication regarding NOAA-funded
Ximing Guo (Rutgers University. (NOAA Chesapeake Bay Program Office,
Luckenbach, M., L.D. Wright, K. Paynter, J. Lin, H.
Que, and C.
Richardson., 2004. Investigation of a Crassostrea ariakensis reef
Laizhou Bay, China. Interim Progress Report.
National Academy of Sciences, 2004. Nonnative Oysters
in the Chesapeake
Bay. 231 pp.
Outten, W., 1995. Personal Communication regarding correspondence
VIMS to Md. DNR regarding rates of reversion in triploid research
(Md, DNR Annapolis, Md.)