From time to time I drive across this island, in one direction or another, and I notice a new clearcut that hadn’t been there - not like that, anyhow — on my prior drive through. It always seems to happen fast, almost out of nowhere. How did it get here, this new cut, this gone old forest? Where did all that was here go, what liveliness, what life, to what end?

I notice the logging trucks going in this direction or that, loaded or unloaded, and I wonder: where from, this time? where to, why for? Who did the cutting, under what permissions and agreements and authorities, issued when, on what basis? Who benefits? How do I? Who suffers, how, when, for how long, from these practices, and how can the practice be worth the consequences? Hard questions to get to the bottom of; I don’t have the answers. But I sure love happy healthy rainforest, and I know that such forests are far easier to destroy than create.

I’ve made this map as a tool for thinking about those questions, and as a way of situating the damage done to ancient life systems on an island that I’m trying to get to know better.

In the course of the post, we’ll travel from the northern tip to the southern extent of the island through 5 images scaled similarly to the one above, with a little bit of larger-scale imagery in-between in order to better show detail. As a navigational aide as you read the post, the grey rectangles in the small-scale imagery indicate the location of the larger-scale images which follow. Along the way, I’ll tell you about the map — how I designed it, why I made it, and a bit of what I noticed along the way.

How to Download And Browse the Map

This post is a map delivery vessel. If you’d like to browse the map or see it in higher resolution, you can find it on archive.org — you can go to the info page with a pdf viewer at this link, or you can download the .pdf file (150mb) directly at this link (*at the time of this posting, archive.org has been having a spell of uncharacteristic downtime issues; if the links don’t work, that’s likely why). It is a georeferenced pdf file, meaning that if you turn on geo-referencing tools with this file in Adobe Acrobat, you can get coordinates off of the pdf, measure distances, etc. Or you can just look at it. It’ll take a moment to load at first and as you move around, but zooming in makes it worth it.

The viewing experience of this post will be best on a larger screen; please take your time with it and read the captions!

The legend for the map — same in the download version as in the below — is as follows (you may want to refer back to it):

Data & Choices

In making this map my goal was to convey the history and present state of logging on Vancouver Island. In seeking out the relevant data to use, I knew that I was looking primarily for (1) spatial data about historical logging and (2) data from assessments of forest stand age.

BC provides both within their data catalogue. For the first I accessed a data set called Harvested Areas of BC (Consolidated Cutblocks); for the second I used a rather amazing provincial data set called VRI — 2024 — Forest Vegetation Composite Rank 1 Layer (R1); it consists of 259 different fields applied to just shy of 8.9 million polygons together representing crown land of British Columbia. I’ll refer to those two layers as the cutblocks dataset and the vegetation dataset. Together, these two data reveal patterns of forest age and logging history, and are the foundation of the map, though a few other layers enter into it as well — I describe a bit more about them at the bottom of the post.

As I experimented with the data symbolized in the map, I compared the results of my symbolization choices with satellite imagery from Google Earth.

Vegetation Layer

The 259 fields of the vegetation dataset describe a range of the vegetative characteristics of each polygon, and the map I’ve made draws attention to only few of them, which I’ll briefly describe:

• Each section was shaded according to the assessed age of the dominant tree species in that area — information provided by the proj_age_1 layer — to represent the forest stand age. I then divided the forest ages into 4 classes (1–71 years; 72–171; 172–278; 279–634 years) using a statistical method that groups similar ages together while maximizing differences between groups. The three older groups were shaded with increasingly dark greens. The youngest group is shaded with a peach-yellow colour.
• This peach-yellow tone shows up a lot on the map; this colour is meant to bridge the vegetation data set and the cutblocks data set, which I’ll describe in the next section below. Generally where you see this colour, some historical industrial intervention — usually involving logging and roadbuilding — has occurred but hasn’t been registered as a cutblock in the historical Consolidated Cutblocks database for whatever reason.
• After symbolizing old growth areas with deepening greens, I needed a way to distinguish areas less productive of timber (regardless of how old the vegetation is), including alpine, wetland, and rock faces. After experimenting with a few approaches, I settled (for now) on 1) coding provided by the BCLCS_LV_2 and BCLCS_LV_3 fields to indicate if a polygon is alpine (represented with grey), wetland (represented with brown), or if the polygon in question features less than 10% tree cover (represented with diagonal hatching through which the vegetation age layer can be seen); 2) coding provided by the EARLIEST_NONLOGGING_DIST_TYPE field to indicate places where wildfires or burns have occurred (represented with brown and tan diamonds); 3) coding provided by the NON_PRODUCTIVE_CD field allowing me to indicate a variety of different sorts of low productivity landscapes, including swamp and rock, etc, sometimes redundant with the above. I’m satisfied that this approach does an adequate job of differentiating timber from not.

Cutblocks Layer

To symbolize the cutblocks dataset, which overlays the forest age layer, each cutblock parcel was shaded according to the year that commercial harvest began on the cutblock (1900–1945 cuts appear in yellow, progressing through two orange tones through to 1995, with two red tones since).

Additionally, each cutblock parcel (so long as it is large enough to fit the text) was labeled (if you zoom in real close) with the calendar year of the mid-point of the harvest of that cutblock.

Tenure / License Layers

I’ve used a few other layers in the map in order to set the context of what sections the timber license holders have the most immediate access to.

One of those layers is the Forest Tenure Timber Licence database, which offers “A spatial representation of the Map Blocks for Timber Licences” — on this map, I show the active and pending license areas wherever clearcutting hasn’t yet occurred. That layer is symbolized with a neon green vertical hatch pattern and a hot pink border.

I also use the Forest Tenure Cutblock Polygons layer to provide “operational activities for cutblocks contained within harvesting authorities”. That layer features the same neon symbolization as the licenses, except the hatching is horizontal.

The tree farm license boundaries are also in there as dashed yellow outlines.

Ongoing Forest Landscape Planning Processes

Maybe you feel the same way I do: It’s been hard to understand what’s happening with forestry in the province. A few years ago — in a gesture that seemed exciting and promising — BC passed the Declaration on the Rights of Indigenous Peoples Act in response to the recommendations of the Truth and Reconciliation Commission. The Act enshrines the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) as the framework for reconciliation in the Province, and an early expression of that Act was the Forest Statutes Amendment Act in 2021, which set the intention for forestry to be brought into the consent-based standard of UNDRIP. In the midst of all that, the Old Growth Strategic Review established the need for a paradigm shift in forestry practice. It seemed for a moment that timber harvest practices might move towards eliminating or strictly reducing pressure on now-scarce old growth systems.

That rhetoric has shifted, lately: 1.2 billion dollars were recently committed by the federal government to support the timber industry, and meanwhile a directive has come down from the BC Ministry of Forests and their BC Timber Sales Agency to increase “fiber production”. Along the way, leaked documents revealed that old growth deferrals were being ignored.

The timelines of the reconciliatory planning processes are colliding with those new timber production mandates, as the planning practices launched with the Forest Statutes Amendment Act are just getting rolling now. There are 28 different land and water planning processes up at BC’s Planning In Partnership website, among them the West Central Vancouver Island Forest Landscape Planning and the East Vancouver Island Forest Landscape Planning processes, as well as the Gwani Project and the Tree Farm Licence 37 Forest Landscape Plan Pilot Project. I went to an Open House which represented the second phase of a five phase process for my regional process, but there wasn’t much, at that point in the process, to learn or respond to. Mostly, that phase was about letting people know that there’s a landscape process happening, and we’re in it.

I don’t claim special expertise about forests and forestry; I’ve only made a map. But I found this map helpful as I looked at and tinkered with it and thought about forests and learned a little about the past and present of logging in BC, and I hope it might be helpful for others, too.

I worry that one way or another all too much of the remaining old and ancient forest — the last of the healthiest, most generative and resilient forests, the best habitat and roaming grounds for wild things — will remain subject to the short-range imagination of industry.

In researching this map I came across a few good resources. One is the Closer To The Brink Report written by Karen Price and Dave Doust with mapping by David Leversee. Came out just a couple months ago. That report contains lots of good information and a set of recommendations to (I paraphrase) follow through on the findings of the Old Growth Strategic Review and to immediately enhance old growth protections so that there will be the same old growth to protect at the end of a careful, thoughtful planning process as at the beginning. Recently, Drs. Suzanne Simard and Rachel Holt have authored a petition along similar lines, specifically calling for the following actions by the Province British Columbia:

1. Overhaul stewardship through implementation of Old Growth Strategic Review recommendations, including implementation of an ecosystem health law.

2. Direct a smaller, sustainable harvest into local, value-added producers that creates more jobs for less harvest, keeps profits and jobs in BC, and puts the control back in local hands.

3. Permanently protect the last irreplaceable old-growth forests.

4. Direct conservation financing so no First Nation is forced to choose between survival and stewardship.

5. Invest in restoration, carbon, and nature-based economies that heal rather than deplete the land. [source: www.protectbcforests.ca]

Again, you can find the large-format version of the map to browse in higher resolution at archive.org — you can go to the info page with a pdf viewer at this link, or you can download the .pdf file (150mb) directly at this link.

Thanks for reading; please share. Reach me at warmerworld@proton.me.

For several years now, these sorts of stories have been bubbling up for Alaska’s largest seafood processors:

“Trident Seafoods has agreed to pay a $300,000 penalty and remove an underwater pile of seafood waste near Sand Point in a settlement with the federal government involving Clean Water Act violations…”
- Alex DeMarban for Anchorage Daily News on March 1, 2018.

“Federal regulators have fined a Sitka seafood processor for allowing its waste pile on the seafloor to balloon to more than double the size allowed by its permit. […] The federal agency accused Silver Bay Seafoods of violating the Clean Water Act by dumping excess blood, oily waste and foam into the water. […] It now appears to have addressed the problem. The company paid a $82,500 penalty and is opting to put a screen on its waste pipe to reduce the volumes it discharges.”
- Jacob Resnick, Coast Alaska (Juneau), on Nov 6, 2019

Both stories linked above, and others besides, were about the underwater piles of fish waste that had accrued in waters beneath the outflow pipes from the processing plants. As far as the rules for these things have stated for years, the seafloor waste isn’t supposed to occupy more than an acre, the annual discharge into that acre isn’t supposed to exceed 10,000,000 pounds, and the chunks that go down are supposed to be 1/2" or smaller. For some processors, those constraints would have been limiting, had they been adhered to at all. But the constraints are important because the hazards of piling up fish waste have been known for many decades. In a notice on Alaskan Seafood Processing Effluent Limitations Guidelines in 2013, the EPA partially described the problem:

“Fish processing waste piles from land-based facility discharges cover large areas of the seafloor and contain large quantities of solids that negatively affect receiving water quality. These piles range in area, sometimes covering tens of acres. They can grow to many feet thick. (DCN 00201). The waste piles smother benthic (bottom) communities, deplete dissolved oxygen, and cause other harmful impacts on the aquatic ecosystem. In some cases, large waste piles at outfalls (both active and inactive) do not dissipate, even with flushing from tides and strong channel currents. Where discharges have stopped, fish waste piles and their effects can remain for 10 years or more.”

Stories of oversized fish piles beneath plants left me wondering: where do you remove an underwater pile of seafood waste to? and, what happens to the stuff that doesn’t make it through the new screen of the waste outfall pipe?

Where I looked for information

Towards answering the above questions, I used:

• EPA’s Enforcement and Compliance History Online (ECHO) facility search tool
• Alaska DEC’s Environment Data Management System (EDMS) Site Map Explorer
• The Alaska DEC Seafood Processing webmap and
• The database of AKG523000 permittees (a bit more on this in a moment).
• I corroborated some of what I learned with vessel movements on Global Fishing Watch, and include several images from that resource below.

I was pretty astonished at what I learned: many of Alaska’s largest processors, in several locations, have responded to running out of room for fish waste below their plants by securing an Alaska General Permit for Offshore Seafood Processors Wastewater Discharge (AKG523000) — allowing them to use “gut boats” (also known as gurry boats) to ferry fish waste solids away to designated spots at sea, through a self-monitoring system. The permit links a processing facility to a designated permitted gut boat and a patch of sea to be dumped in, and opens up a new 10,000,000 pound annual dumping allotment for the processor.

So… What’s Happened?

Trident Relocated the Fish Waste Pile at Sand Point

When Trident was asked to clean up the outfall pile by their plant at Sand Point, the agreement that they came up with — as I learned in this waste remediation workplan filed with Alaska DEC — was to dredge up the pile over the course of 45 days and transport it over the course of weeks to a designated area in the center of Popof Strait, right between the 1-mile and 3-mile line:

I corroborated that work-plan with Global Fishing Watch, and located the tracks for the Tug Waldo operating through the summer of 2018, as seen below.

Meanwhile, Silver Bay Seafoods Left Their Waste Pile Intact, and Began to Dump New Waste At Sea

The pile of fish waste has been dealt with differently in Sitka, according to documents attached to the recent June 2023 wastewater permit renewal.

The permit documents indicate that a seafloor survey “completed on 10/16/2022 found 2.20 acres of Zone of Deposit coverage”. The oversized pile wasn’t shrinking. Included in the permit application was the Seafood Wastewater Source Control Proposal for the plant outfall, including the plan for the oversized pile. Their approach, in practice as in the plan, is to leave the pile as it is, and use gut boats — they call them gurry boats — during peak season. Outside of peak season, waste may be avoided by operating a pet food line for parts of the year, but that will be shut down for peak seasons. They explain: “The material that would normally become the pet food product will be downsized to less than ½” and diverted directly to the gurry vessel, bypassing the facility waste conveyance system and screen plant.”

As they tell it in the Seafood Wastewater Source Control Proposal, Silver Bay Seafoods started using the gut boats in Sitka in 2019, when “A Compliance Order on Consent was issued by the EPA prohibiting the discharge of solid waste through Outfall 001 and requiring annual seafloor monitoring within 90 days of the completion of the salmon processing season until the reduction of the ZOD to less than or equal to 1.0 acres for two consecutive years.” Since then, many thousands of tons of waste have been transported by gut boats under multiple Alaska DEC permits to changing locations in Eastern Channel, and now, farther out, with permission from the EPA.

And so to those questions — where do you remove an underwater pile of seafood waste to, and what happens to the stuff that doesn’t make it through the new screen of the waste outfall pipe at the plant? Well, it turns out that in Alaska, the answer to both questions has become the same: you expand the territory for dumping.

Gut Boats Working Elsewhere in Alaska

These are some of the gut boats that have been working in Alaska in recent years.

The above images are not exhaustive, and it appears that more processors are electing to acquire AKG523000 permits to begin dumping waste by boat. The Kodiak Fishmeal Company — which receives the waste from several Kodiak processors — Trident Seafood, Pacific Seafood, Silver Bay Seafoods, Ocean Beauty Seafoods, and North Pacific Seafoods plants — has lined one up that they haven’t used yet. In the Outfall Narrative of their permit application, they wrote it would be used “on a contingency basis in the event that the KFC facility is offline (i.e., unable to process fish wastes), or does not have the capacity to process all of the fish by-products produced during fish processing season”.

It’s an important trend to pay attention to, as many of Alaska’s fish processors are running out of dumping grounds at their current spot. The processors are failing to use the whole product, especially at peak times, and are intensely polluting with fish waste as a result. To highlight the risks of doing this, I’ll quote at length from a 2021 article in the Journal of Environmental Chemical Engineering:

“The environmental concerns associated with disposal of fish wastes into ocean waters include reduced oxygen levels in the seawaters at the ocean bottom; burial or smothering of living organisms; and introduction of disease or non-native and invasive species to the ecosystem of the sea floor. During rainy season, seepage of water through the landfill dump causes additional problems. Nutrients, suspended solids, disinfectants and possible coliform bacteria from the seafood industry effluents affect coastal water quality and hence human life, particularly in the coastal regions. Hypoxia is a condition of low oxygen in the water than can kill fish and other aquatic animals. High level of BOD may cause hypoxia in a receiving environment, leading to anoxia, a condition characterized by an absence of oxygen supply to an organ or a tissue of living organisms. The high levels of nitrogen, phosphorus and FOG may lead to shortage of drinking water, eutrophication (growth of unwanted biota), biotic depletion, algal blooms, habitat destruction, water acidification, disease outbreaks and possible extensive siltation of corals.” — from Venugopal, V., & Sasidharan, A. (2021). Seafood industry effluents: Environmental hazards, treatment and resource recovery. Journal of Environmental Chemical Engineering, 9(2), 104758. https://doi.org/10.1016/j.jece.2020.104758

To illustrate the scale of the issue, a search of EPA’s ECHO tool for facilities belonging to a grouping of major seafood processors in Alaska returns 83 facilities, 55 of them with current violations.

Many of those violations have to do with things like exceeding permitted seafloor area, exceedences of (usually) 10,000,000 lb dumping allowances, outflow lines breaking near shore, or problems and gaps with self-reporting. I’m writing this to flag that many major processing plants appear to be running in a near-chronic state of violation of regulations… and gut boats are increasingly part of it.

After diving deep into the recesses of the EPA and Alaska DEC websites this week, I’ve realized that regulatory practice around this has changed — without a whisper — to more totally accommodate processors in extreme wasting during peak season, and to make allowances for violations.

Instead of one permit for one outfall pipe, a processor can now have multiple permits for multiple gut boats. Suddenly, a new immensity of fish waste is being allowed to be produced and dumped, farther from the plants but still in nearshore waters, sapping oxygen from surrounding waters while adding other chemical byproducts to the mix, spreading ill effects, promoting new zones of oxygen depleted waters.

This emergent dumping practice begs the question: is it really bad, or simply offal?

I never looked for diesel from the spill, and so never saw any; I never had a conversation about the spill. If I remember right, it was sort of like this one (March 2022, Western Mariner Tug in Neva Strait)… not really something people talked about.

But a few days ago, I came across the incident page for Tug Powhatan and the NOAA-produced “Final Damage Assessment and Restoration Plan and Environmental Assessment” (FDARPEA) from January 2020.

I’d like to share a few observations related to that spill and the FDARPEA Report in the context of the March 2022 spill:

1. Regarding the impact on herring, the two circumstances can be differentiated by timing — the 2017 spill occurred a few weeks later in the year than the 2022 spill, at a time when herring eggs and larvae were already in the water
2. The following chart provided by ADFG appears in the FDARPEA Report, and illustrates the peak-day of sheen reported in 2017, four days after the spill:

Early reports indicated that the 2017 spill was a few hundred gallons of diesel and other oils, but informed estimates in the 2020 report based on sheen size suggest that perhaps it may have been somewhere around the range of 4,507 - 6,358 gallons. The following image comes from a comment and response included in the FDARPEA Report:

3. ADF&G has this set of maps set indicating shoreline where the Department has located herring spawn in recent decades. You’ll notice that only twice in the last 50 years of study has there not been herring spawning activity on the shoreline between Katlian Bay and Silver Bay — 2018; 2019. The area where herring conspicuously did not spawn for those two years matches the trajectory of the diesel sheen detected in 2017. Here is a side-by-side look at spawning distribution from 2016–2019:

4. 2018 and 2019 were terrible years for subsistence roe-on-branch harvesters and commercial fishermen alike. Never since comprehensive aerial surveying began in 1981 have so few miles of spawn been reported as in 2018. Could it be that the 2017 spill was toxic to herring in ways previously unaccounted for?

5. Age, weight, and length samples of herring in 2020 and 2021 indicate that 2017 ended up being an unsuccessful brood year in Sitka Sound. Is there evidence that the 2017 brood year — in larval form at the time of the spill — were particularly affected by the spill? A closer look at where the 2017 brood year herring were and were not sampled in 2020 and 2021 suggests the possibility of localized recruitment failure where diesel was present near the surface of the water.

6. In the days since the March 21, 2022 diesel spill in Neva Strait, I have personally seen extensive diesel sheen in Neva Strait, Nakwasina Sound, Krestof Sound, Salisbury Sound, and Sukoi Inlet. I have heard of a lot of sheen in Katlian Bay and Olga Strait. I believe that DeGroff Bay may have received a lot of diesel sheen, based on a distant look at it from the plane. This is likely a bigger spill than the one in 2017, at something in the range of 9,000 gallons. Who knows what the effects of a serious spill during spawning season might be?

7. Some of the clues about possible effects are outlined by NOAA in their literature review in the FDARPEA Report about the 2017 incident:

• Barron et al. (2003) analyzed mortality of larval Pacific Herring from Sitka Sound from different exposure regimes of weathered crude oil water accommodated fractions and sunlight. They found that herring larvae exposed to various concentrations and UV scenarios experienced mortality
rates ranging from 24% to 39%.

• As reported in NOAA (2016), 85% to 100% of bay anchovy, red snapper, and spotted seatrout eggs exposed directly to crude oil sheens from the Deepwater Horizon incident and UV in a laboratory setting died. When integrated over the upper water column (zero to 20 meters) to account for sheen toxicity and oil entrainment below the sheen, NOAA (2016) estimated a mortality rate of 21% to 45% for eggs and larvae in the open water.

• Incardona et al. (2008) reported mortality to herring eggs collected from oiled vs. non-oiled sites after the Cosco Busan oil spill (bunker fuel) in northern California and reared in the laboratory in clean seawater with a typical ambient light-dark exposure regime. The authors found that egg mortality for herring collected at oiled sites ranged from 56% to 76% and was statistically different relative to mortality from non-oiled sites at 16%. Additionally, of those that survived the egg stage, the authors reported larval mortality rates of 23% for exposed larvae compared to 12% for control.

• Incardona et al. (2012) exposed Pacific herring eggs to bunker oil and UV and found that mortality ranged from 6% to 91% in eggs exposed to a range of concentrations of effluent from weathered oil gravel columns, which was higher compared to controls (4% to 26%).

• Following the Exxon Valdez oil spill (crude oil exposure), McGurk and Brown (1996) compared egg-larval mortality rates for Pacific herring at oiled and non-oiled sites and found that mortality was greater at oiled sites than non-oiled sites.

• Following the North Cape oil spill (diesel fuel oil), Hughes (1999) compared egg mortality for Winter flounder at sites where there had been oiling to laboratory control egg mortality. After adjusting for the mortality in controls, Hughes found an average of 51% mortality (range 22% to 86%) of Winter flounder eggs from sites with diesel fuel oil exposure.

• Schein et al. (2009) investigated the toxicity of diesel to rainbow trout. Differences in toxicity between floating and chemically enhanced water accommodated fractions were observed but when TPH concentrations were measured a median lethal concentration to rainbow trout of 6 mg/L was
reported.

8. The FDARPEA report also contains (p36) this brief explanation of why fuel oil like diesel might actually be more harmful than crude oil for herring larvae:

“As described above, numerous studies estimate toxicity of oil to fish larvae, including Pacific herring larvae. Based on NOAA’s review of available information, they determined the most applicable toxicity estimates are those that expose larvae to oil sheens directly and/or to water with TPAH and oil droplet concentrations analogous to water that would be found beneath a sheen, irrespective of the source of the oil being crude or fuel oil. As such, NOAA has determined that NOAA (2016) and Barron et al. (2003) are the most applicable sources of information. For the purposes of injury quantification for this NRDA only, NOAA applies a 31% mortality rate derived from Barron et al. (2003), which evaluated the toxicity of oil with UV to herring from Sitka Sound. This estimate is lower than the mid-point of the range reported in NOAA (2016) and is likely to under-estimate toxicity because crude oil acute toxicity is known to be lower than that for fuel oil.”

9. Testing from 2017 was not particularly encouraging. The FDARPEA Report also (on page 22) contains this brief outline of the shellfish sampling which occurred near the spill site, indicating the bio-availability of the spilled oil to organisms and subsistence resources:

10. As of this writing (April 3), the commercial fleet has been allowed to harvest 14,300 tons of spawning herring in the days since the spill. ADF&G is allowing the fleet to pursue a record harvest level in conditions where known harms of diesel exposure to herring are extreme. I believe that this is deeply irresponsible fisheries management.

A Partial Review of Some Dangers Posed to Spawning Herring by Spilled Oil // Call For Precautionary Herring Fisheries Management

On the early hours of March 21, a serious diesel spill — likely amounting to upwards of 9,000 gallons — occurred in Neva Strait (see DEC response page here; updates may also become available through the US Coast Guard Alaska fb page here). It has spread significantly in the 5 days since. I have assembled this partial literature review to illustrate the dangers that oil/diesel spills can pose to spawning herring and herring embryos, and to identify the need for precautionary approaches to aggressive fishery harvests in the midst of such spills. Herring are aggregating in Sitka Sound for spawning, and Alaska Department of Fish and Game appears prepared to conduct a large-scale sac roe herring fishery without first studying the ecosystem effects of the spill.

Scientists know that even low amounts of the diesel compound polycyclic aromatic hydrocarbon in marine environments can cause intense harm to herring of all life stages, but particularly in early life. It is understood that herring embryos do not form properly when exposed to low-level PAH contamination. Extensive studies by the Northwest Fisheries Science Center indicate that “the heart fails to pump properly and fluid accumulates in this space [which the heart normally fills] (a condition called edema), ‘inflating’ the overlying skin and displacing the yolk mass.” (from Incardona et al, 2010). An oil spill in San Francisco bay in 2007 is the known cause of massive herring embryo mortality there in that year.

A study by Langangen et al., from the Marine Pollution Bulletin in 2017, cited a number of good reasons for caution when oil spills near herring spawning grounds:

Fish stocks may be especially vulnerable to oil spills close to the spawning grounds or egg and larval drift areas (Hjermann et al., 2007, Rooker et al., 2013). Fish eggs and larvae are typically vulnerable to toxic oil compounds due to their small size, poorly developed membranes and detoxification systems as well as their position in the water column. A number of laboratory studies have shown that oil or oil compounds (mainly polycyclic aromatic hydrocarbons, PAHs) at low concentrations can kill or cause sub-lethal damage to fish eggs and larvae (Carls et al., 1999, Hicken et al., 2011, Meier et al., 2010, Scott and Sloman, 2004, Sørhus et al., 2015). Sub-lethal effects include, e.g., morphological deformities, reduced feeding and growth rates, and are likely to increase vulnerability to predators and starvation. The few existing in situ studies of fish mortality at spill sites indicate sub-lethal effects or elevated mortality of eggs and larvae (deBruyn et al., 2007, Hose et al., 1996, Incardona et al., 2012, McGurk and Brown, 1996). (from Langangen et al, 2017)

It is important to note that ADF&G herring studies lose track entirely of larval & juvenile herring (age 0–3). After egg deposition surveys occur, ADF&G has no way of knowing how those young herring are doing. In the wake of the 1989 Exxon Valdez spill, ADF&G allowed fishing to continue despite this knowledge gap, and was caught by surprise by successive recruit failures throughout the 1990’s, contributing to cascading ecosystem effects. PWS herring have not recovered.

A 2008 paper by Thorne and Thomas in the ICES Journal of Marine Science reviewed some of what went wrong in Prince William Sound:

Behaviour of adult herring makes them especially vulnerable to damage from oil spills, something that was either unknown or misunderstood at the time of the spill. […] Acoustic observations made 17 years ago suggest that Pacific herring make routine migrations to the surface at night to gulp air (Thorne and Thomas, 1990). Subsequently, this behaviour has been comprehensively documented using infrared and visual technologies (Thomas and Thorne, 2001). Recent research shows that herring also release gas bubbles and break the water surface in response to predation (Thomas et al., 2007). These behaviours make herring highly vulnerable to contact with a surface toxicant such as an oil spill. Adult herring are also highly aggregated during late winter, although juveniles are more cosmopolitan (Stokesbury et al., 2000; Thomas and Thorne, 2003). The 13 years of survey data reveal occasions where 90% of the adult herring population was in a few large aggregations distributed within a total area of 10 km2. Such behaviour places the adult herring in a situation where even a small oil spill could affect most of the spawning stock. (From Thorne & Thomas, 2009)

Diesel does not evaporate nearly so quickly as some believe. Studies have shown that in controlled circumstances, just 35–40% of diesel will evaporate in the first ~4 days (Fingas 1996). Studies on Rainbow Trout published by the Society of Environmental Toxicity and Chemistry indicate that dispersion, including via “stirring” as can happen via wave action, current, and wind, increases the chronic toxicity of diesel:

Diesel spills are often considered an acute toxicity risk to aquatic organisms, with most volatile components evaporating or breaking down rapidly in the environment. However, the present study showed that the constituents of diesel remaining after 18 h of stirring (subjected to processes of weathering and solubilization) were chronically toxic to rainbow trout, in particular when chemically dispersed. Exposure to the remaining water soluble components of diesel caused EROD induction in juvenile trout (the present study; [8]) and all hallmark signs of BSD in embryonic trout. These effects were accompanied
by a significant reduction in growth of embryos, a cessation of development, or both, as indicated by a smaller size and reduced absorption of yolk. Such responses are consistent with the toxic effects observed in an array of fish species exposed to various crude oils [1,2,7,14,15] and suggest that diesel contains similar toxic components. (from Schein 2009)

Herring are aggregating in Sitka Sound for spawning, and Alaska Department of Fish and Game appears prepared to conduct a large-scale sac roe herring fishery without first studying the ecosystem effects of the spill. The department has indicated that they will continue to pursue fishing opportunities in northern Sitka Sound in coming days so long as diesel is not present at the time and place of fishing. That approach insulates consumers and fishermen from the spill, but it does nothing for the herring. I don’t believe it is a reasonable application of the precautionary principle. Rather, it is reckless, cavalier, entirely the wrong way to approach this local disaster.

We now know beyond a doubt: cautious management is essential when this sort of thing happens. Please urge local ((907) 747–6688) and statewide ((907) 465–2376) ADF&G staff to stand down the fishing effort for at least 3–5 days or until a serious and legitimate risk assessment can be conducted, and make sure your political representatives are taking the issue seriously as well.

write: peterbradleypeterbradley@gmail.com

CITATIONS:

Citations for the excerpted papers:

Fingas, M. (1996). The evaporation of oil spills: variation with temperature and correlation with distillation data. Proceedings of the nineteenth arctic and marine oilspill program (AMOP) technical seminar, (p. 914). Canada: Environment Canada.

Herring and the “Exxon Valdez” oil spill: An investigation into historical data conflicts | ICES Journal of Marine Science | Oxford Academic. (n.d.). Retrieved March 22, 2022, from https://academic.oup.com/icesjms/article/65/1/44/613524

Incardona, J., Collier, T., & Scholz, N. (2010). Oil spills and fish health: Exposing the heart of the matter. Journal of Exposure Science & Environmental Epidemiology, 21, 3–4. https://doi.org/10.1038/jes.2010.51

Incardona, J. P., Vines, C. A., Anulacion, B. F., Baldwin, D. H., Day, H. L., French, B. L., Labenia, J. S., Linbo, T. L., Myers, M. S., Olson, O. P., Sloan, C. A., Sol, S., Griffin, F. J., Menard, K., Morgan, S. G., West, J. E., Collier, T. K., Ylitalo, G. M., Cherr, G. N., & Scholz,

Incardona et al (2012). Unexpectedly high mortality in Pacific herring embryos exposed to the 2007 Cosco Busan oil spill in San Francisco Bay. Proceedings of the National Academy of Sciences, 109(2), E51–E58. https://doi.org/10.1073/pnas.1108884109

Langangen, Ø., Olsen, E., Stige, L. C., Ohlberger, J., Yaragina, N. A., Vikebø, F. B., Bogstad, B., Stenseth, N. C., & Hjermann, D. Ø. (2017). The effects of oil spills on marine fish: Implications of spatial variation in natural mortality. Marine Pollution Bulletin, 119(1), 102–109. https://doi.org/10.1016/j.marpolbul.2017.03.037

Raubenheimer, M.-C. (2020). An analysis of the effects of crude and fuel oil on the mortality of herring eggs using Bayesian meta-analysis techniques. https://helda.helsinki.fi/handle/10138/322575

Schein, A., Scott, J. A., Mos, L., & Hodson, P. V. (2009). OIL DISPERSION INCREASES THE APPARENT BIOAVAILABILITY AND TOXICITY OF DIESEL TO RAINBOW TROUT (ONCORHYNCHUS MYKISS). Environmental Toxicology and Chemistry, 28(3), 595. https://doi.org/10.1897/08-315.1

The 2021 Sitka sac roe herring fishery was allocated a massive “Guideline Harvest Level” on the strength of low quality data, and the disproportionate slaughter of older herring likely resulted. A lack of elder herring is bad news for herring and humans alike.

This piece is an exploration of apparent implications of ADFG’s decision to arbitrarily base assumptions for the 2021 fishery on outdated weight-at-age and fecundity information. What does it mean if the herring are smaller-at-age than ADFG has assumed, and is it likely that that’s the case?

This is a modified version of “Fishy Numbers: An Inquiry”, originally posted on March 28, 2021. It has been shortened and reorganized for clarity. The original version includes more charts and details in case you’re looking for more background after reading this.

Introduction

I am writing this to raise pressing questions about certain elements of ADFG’s arcane herring management methodology as it applied to this year’s fishery. This year, ADFG authorized an aggressive “Guideline Harvest Level” (GHL) based on poor quality information. Management approaches to the 2021 fishery — permissible via current regulations — represented unacceptable risk to population resilience.

My concerns relate significantly to a regulatory deficiency identified by Sitka Tribe of Alaska in Proposal 157, which is up for consideration at the 2021–22 BoF meeting in Ketchikan (Jan 4–16, 2022):

From Proposal 157 (Sitka Tribe of Alaska): Theoretically, under current regulations, the entire guideline harvest level (GHL), or even 100% of the older population, could be taken with the largest most fecund herring leaving few large fish to spawn, if the fishery was efficient when selectively harvesting large herring. This is an obvious, unintended deficiency in the current regulation.

My concerns also go beyond this obvious regulatory deficiency; I find that ADFG’s model has not been fed data of adequate timeliness and quality at a time when population dynamics are unusual. There’s a data science term for what happens in these situations: “garbage in, garbage out”. This year, the situation — combining deficient regulations with garbage data and a lack of historic perspective — was unusual and risky enough that some scrutiny of ADFG herring management and modeling is necessary.

What I’m worried about is that if age-5 herring came in smaller than arbitrarily forecast at 109g, and if the average herring catch did indeed suit the market desire for 110g herring, then that means that a disproportionate chunk of the catch was from ages 6 and above, and those age classes could be nearly decimated.

In this piece, I will:

• outline the elements of the forecast which defined the 2021 Sitka Sound sac roe herring fishery
• explain how the department forms assumptions, determinations, and forecasts around biomass, population structure, and fecundity
• describe why this year’s forecast was unusually speculative, and will point to in-season management implications of erroneous forecasts
• share some of the signals in current and historic data which indicate that this year’s assumptions and forecast may have been off mark, with major implications for herring age structure in Sitka Sound for years to come [for now, the initial version of Fishy Numbers has a little more of this context than this version does]
• refer to the most recent information provided by the Department, much of it from the March 12, 2021 Sitka Herring Informational Meeting, including the “Sitka Sound Herring Forecasts 2020+2021” presentation by ADFG biometrician Dr. Sherri Dressel, the “ADF&G Herring Survey and Sampling Results 2019 and 2020” presentation by Kyle Hebert, along with the recent Stock Assessment Surveys including the 2019 Stock Assessment Surveys, and ADFG’s map set of observed nautical miles of spawn in Sitka Sound dating back to 1964.

The Forecast

The slide to the left with heading “2021 forecast biomass and weight at age” was shown on March 12, 2021 at the Sitka Herring Informational Meeting.

It represents the departmental forecast for the 2021 Sitka Sound Sac Roe fishery, and indicates that:

• A forecast 210,453 tons of mature (age 3+) herring would be spawning in Sitka Sound in Spring 2021. That’s among the very highest ADFG estimates ever.
• Given the high biomass, the “Guideline Harvest Level” — the maximum amount of herring available for the sac roe seine fishery, at 20% of biomass — would be a record high 33,304 tons. [Ultimately the fishery brought in 16,000 tons— an immensity , even at half the GHL— of the largest herring they could locate.]
• The vast majority (175,731 tons) of Sitka Sound herring would be age-5, with lower numbers of age 6–15+ herring (30,799 tons combined) and very low numbers (3,923 tons combined) of age 3+4 herring. While dominant age cohorts of herring can occur rarely does one cohort represent nearly 90% of the population at age-5.
• That the forecast average weight of mature herring would be 112 grams. (It was established in advance of the fishery that the market needed herring hauls averaging 110g or above.)
• That those age-5 herring would weigh, on average, 109 grams. That forecast is highly problematic, given the caption that it is based not on any observation of the fish in question but instead on an “Average of 2017 and 2018 spring commercial purse seine weights at age”. I believe that the best available evidence in advance of the fishery suggested that the age-5 herring would be smaller than that, averaging well below market needs.

Three Process Problems with the Forecast

The biomass forecast (at 210,453 tons going into the 2021 season) is arrived at indirectly; the foundation of the estimate is (now) the estimated herring egg deposition in Sitka Sound. A total egg deposition estimate for Sitka Sound is arrived at by tracking spawning in the area daily via aerial surveys and then conducting dive samples assessing egg deposition at intervals along areas where spawning was seen.

In 2020, ADFG reported 58.5 nautical miles of spawning, and from their dive surveys along those miles, determined that there were 23 trillion eggs in Sitka Sound- more than the department has ever registered before. This metric is highly dependent on survey effort, efficiency, and area; each parameter has increased steadily over the last 50 years.

Problem 1: Egg deposition surveys in Sitka Sound have become more extensive and thorough as the years have gone on, making older biomass estimates appear low. Historic biomass numbers should be considered unsuitable for comparison. The newest example of the ever-expanding survey area is Outer Kruzof; Outer Kruzof wasn’t considered to be within the scope of the survey area 25 years ago. Additionally, a great proportion of which were counted at depths that the department wouldn’t have dived to in previous generations of study.

From a count of 23 trillion eggs, it is with a combination of surveying, deduction and conjecture that the age structure and biomass of fish required to produce those eggs.

The Department collects age/weight/length samples that establish weight-at-age (size on average for each age-class) and proportion-at-age (what proportion of the biomass consists of the different age classes).

For several years ending in 2016, that data was collected using three different methods of sampling herring each year: active spawning cast nets, commercial seining in the spring, and a purse seine test fishery in winter.

Problem 2: The winter test fisheries have been dropped since 2015–2016, and an over-reliance on data from the selective commercial fishery has resulted. Winter test fishing has not happened since 2015–16, in 2019/2020 there were no commercial fishery data to reference. Despite survey bias and selectivity problems, the department has favored data generated by the commercial fishery in recent years.

After becoming aware of a massive incoming age class in 2019, the Department made the unusual decision to base the forecasts for 2020 and 2021 on weight-at-age samples collected in the commercial fishery back in 2017 and 2018, rather than using the cast net samples which indicate herring which could be rather smaller than the forecast.

Once the Department has information on age-class proportions and average weight-at-age, ADFG needs a framework to determine the fecundity:weight relationships which describe how many eggs a herring of a certain size will carry.

ADFG has not done a new fecundity study or changed the weight:fecundity relationship since 2005.

Before that, there were studies in 1971, 1988/89, 1996, 1998. The results were substantially different each time.

The image to the left comes from the 1996 study, and illustrates the fecundity to weight relationship from that year.

In 2005, there was a diverse age structure with a generally high condition factor (bigger fish). Now, all ages are coming in small and the population is dominated by one age group.

Problem 3: Using that data as a key point in extrapolating biomass is sort of like budgeting a road trip using the 2005 price of fuel. Some years it’ll match up, some years it won’t.

At one time, the goal for the fecundity study was to “promote estimates of fecundity-at-weight at the extremes of the weight range that are within +/- 30% of the predicted fecundity, 90% of the time”. In how many years between 2005 and now has that goal been achieved? We have no way of knowing.

And so that is how the biomass is reached — by counting eggs using ever shifting methodology, sampling herring using ever shifting methodology, maintaining a static assumption about herring fecundity from 2005, and running it all through a computerized model that assumes it has all of the information it needs.

Recap: How the biomass is determined:
Step 1. Estimate the number of eggs in Sitka Sound through aerial surveys and follow-up dives to assess egg deposition. [Problem 1: survey effort and efficiency has increased with time, and ADFG dives deeper and has flown surveys on more days across a wider area as the years have gone on]
Step 2. Sample herring to figure out age composition and weight-at-age using one or more methods. [Problem 2: Increasing reliance on commercial catch data instead of less biased sources over time; in ‘20/’21, ADFG may have overestimated weight averages by referring to obsolete commercial data]
Step 3. Apply fecundity relationship [Problem 3: from 2005] to determine how many herring of those proportions it would take to produce that many eggs.
Step 4. Voila! Biomass 2021.

Long version:
See the most recent stock assessment for full methodology.

High GHL, High Risk:

The upshot of all of this is that if the fishery successfully pulled in 16,000 tons of herring averaging 110-g, and if the cohort of age-5 herring were on average smaller than forecast (which appears highly possible from 2020 cast net surveys), then the relatively small populations of herring over age-6 were disproportionately slaughtered. Historically, it was not at all uncommon for herring in Southeast Alaska to live to 12–15 or older; this fishery systematically annihilates elder herring. It is a poor practice for ecosystem resilience and healthy maritime cultures.

That’s bad for everybody.

Some questions:

1. What was the average weight from the 2021 Sitka Sound sac roe fishery, and what was the average weight from the 2021 active spawn cast net surveys?
2. What was the average weight of age-5 herring in the 2021 Sitka Sound sac roe fishery? In the 2021 active spawn cast net surveys?
3. What were the proportions-at-age in the active spawn cast net surveys, in particular of the pre-2016 brood years? How do those numbers compare to the commercial harvest numbers?
4. By what mechanism did Outer Kruzof become part of the Sitka Sound sac roe fishery, and thus, part of the egg deposition count from which the biomass of Sitka Sound herring is reached? It was not part of the fishery in 1996. What has changed and when, exactly, did that change occur? How does ADFG account for expanding study area when making biomass comparisons over time?
5. How does ADFG account for bias in sample types and why have commercial test sets have become a favored metric? How does ADFG account for changes in sample methodology over time?
6. What was the deepest that dive surveys for eggs went in 2021? In 2020? In 2008? In 1989? How does the department account for inflation in biomass numbers from counting more eggs, deeper, as time goes on?
7. Why does ADFG believe that the 2005 fecundity data is appropriate for application to the dominant 2016 age cohort of herring and the small-at-age herring currently in Sitka Sound? What are the implications if the real fecundity was substantially different in 2021 than in 2005?

I joined Djerassi Resident Artists Program in September 2019, worked to do well by artists and the Program as Deputy Director Of Programs, and resigned in disappointment at the end of October 2020 as the organization’s trajectory became more clear. In the time since, all of the people I worked with have left or been forced out of what became a very toxic workplace. Andrew, Art, Carolyn, Chris, Cynthia, Dan, David, Kay, Margot, Michelle, Traci, Wade: all gone from the organization since the start of the pandemic. Since then, many of a new wave of staff has come and gone as well.

In brief: the Board of Trustees of the Program used the pandemic as an opportunity to tear the Program down. Many people — artists, co-workers, volunteers, donors — were hurt or exploited in the process. I found the organization’s behavior disturbing in 2020, but I chose at the time not to say anything in public. I hoped that somehow the organization might change its behavior or find a path that I wasn’t seeing. But now, a year later, I regret that I didn’t speak up sooner.

I am certain that variations of what happened at Djerassi Resident Artists Program during the pandemic have been experienced as harm by arts workers and constituencies of other arts nonprofits. Organizations like Djerassi Program which cultivate an outward projection of kindness and care while enacting harm and cruelty leave their trusting constituencies vulnerable, and must be held to account in order to do better. I hope this essay helps.

Djerassi Resident Artists Program is situated on a wilded old ranch in the redwoods south of San Francisco,

on a seaward shoulder of the Santa Cruz Mountains. At 583 acres it is surely one of California’s largest land-holding arts nonprofits.

On the Djerassi Program’s Artist’s Ranch are 5 studio cottages, a large ranch-house with 6 suites, and an artist barn rigged up with studios and gear for a diversity of artists, including visual artists and sculptors, composers, and choreographers. Plus the Director’s house, administrative offices, and the “Old Barn” multi-use space. Until COVID-19, 11–13 artists came to the Artists’ Ranch at a time, a month at a time, to do their thing.

A few of the best known qualities of a residency at Djerassi Program: No work expectations, few social or social media obligations or public facing activities, no fee, nice studios, inspired good company, extraordinary setting, wild country: mountain lions, bobcats, owls, hawks, deer, mice, redwoods, oak, coyote brush. Great trails. Wildflowers and wildfires. Chef Dan Tosh’s beautiful meals 5 evenings a week, fridges well stocked and by request. Quiet. Freedom. Magic.

“Just be”, we told the artists. “We trust artists”, we told the world.

Sometime in September, somebody at the Program did or said something to somebody else, causing some kind of harm or alienation, of a sort that generated some sort of aftermath involving further harm. In the aftermath of the aftermath — which is to say, in a written statement to the “Djerassi Community” — the board noted their acceptance of the resignation of the individual who had functioned remotely as the Executive Director of the Djerassi Program for one year. In the same letter to stakeholders, Djerassi Program wrote, “While we realize that there is much more work ahead, we are dedicated to prioritizing and continuing our organization’s DEI efforts.”

I have seen this organization grandstand around statements before; for a number of reasons, I worry that this statement is more about image-preservation than actual accountability. The trustees who I credit with making Djerassi Resident Artists Program a toxic workplace have not resigned and are guiding the organizational response to the recent events.

For decades, Djerassi Program has functioned in IRS standing and in all day to day actions as a 501(c)(3) public arts nonprofit, where the work was left to staff but guided by board-defined strategic plans. The effect of the last year has been a restoration of familial control over an organization that has has not been a family foundation for decades. This assertion of control and entitlement over the program isn’t appropriate, isn’t a good thing for artists, and happened cruelly in a year where the organization really needed to step up, support artists, and be good to people.

Cut to the Bone

It was April 23, 2020. A meeting of the Program’s “Future Task Force”. Staff were present.

One trustee reasonably asked: “The unknown is where we could ‘cut to the bone’ further and to what level, as it seems like we’re near that already”.

Another trustee asked: “yes, what would cutting to the bone look like and what would it save?”.

They were reflecting on Dale Djerassi’s suggested path forward through the pandemic: cut to the bone. Dale is one of ~12 or so trustees with authority no different from the rest. Even so, he will readily admit a feeling of entitlement — to the land and to the Program — and I heard him enact it loudly and insistently. The organization was formed in the memory of his sister, Pamela Djerassi, who as a young poet and artist died by suicide. In her memory, Diane Middlebrook and Carl Djerassi — Dale’s father - together established a residency program for female artists.

Dale Djerassi has the distinction of being a Founding Trustee, and with that distinction he takes and is given an immensity of space in the culture of Djerassi Resident Artists Program. And so when he repeatedly said the words “cut to the bone”, it became Djerassi Program’s drumbeat. It wasn’t reflected in any approved budget, and wasn’t adopted via any board resolution in the time I was there. It wasn’t necessitated by an immediate shortfall, either; the Program’s individual donors and funders all stepped up early in the pandemic, and our fundraising year was way ahead of pace even before the PPP money came in. But outside of any regular budget process, the board was insistent, and pressured us to slash our expenses to $800,000 per year, a nearly 50% cut from the prior year budget. That would mean offering artists experiences crummy and few — the wrong way to serve artists and attract donors in the first pandemic year.

The first PPP loan came in at $144,818 and was meant to contribute to a payroll of 13 people. The organization also received $50,000 from the National Endowment for the Arts, via their CARES Act funding. I remember feeling surprised by the tepid reaction from trustees to all of that good news. Those loans allowed us to maintain staffing levels and focus on doing the mission through much of 2020. By the time the second PPP application went out in early ’21, several staff were already out the door, most without replacement. For the second PPP application, Djerassi Program appears to have exploited an available PPP loophole and built the PPP application around payroll numbers from 2019 — claiming 14 staff members — rather than their staff levels at the time of the application. The second PPP loan came in at $149,000. At no point in this year have more than 7 staff members been listed on the website. Even so, in the end, the reporting will look OK: Between my departed colleagues and newer staff who have come and gone, there’ll be at least 13 names on the staff manifest for the year. What will likely be less clear in grant reports and future audits and 990 forms — what will be erased by time and bureaucratic evasion — is how very little most of those mistreated individuals were paid in comparison to the top few salaries and contracts.

All the while, the staff were trying to do the work.

Lacking an alternative mandate from the indecisive and capricious Board of Trustees, staff used the mission as our guide. The mission of the Djerassi Resident Artists Program is to support and enhance the creativity of artists by providing uninterrupted time for work, reflection, and collegial interaction in a setting of great natural beauty, and to preserve the land on which the Program is situated.

We all believed that Djerassi Program had the capacity to provide a hugely important service to artists during the pandemic. We were embarrassed by the prospect — and then the reality — of the Artists’ Ranch going largely unoccupied for many months. We focused on being ready to welcome artists.

The first artist residency session of 2020 started on March 11th, and in those days when American grocery lines were longest and handwashing technique widely improved, COVID-19 reared its head at the Djerassi Program Artists’ Ranch— three people connected to the Program became sick with symptoms consistent with the novel coronavirus. Ineligible for testing at the time, they quarantined immediately upon onset of symptoms, and none of the other staff or artists became symptomatic in the days and weeks to follow. With each day we took in the day’s news and information and guidelines and we adjusted and adapted our practices and improvised our way towards making things a little safer. Half of the artists chose to return to family and home early — our staff determined that the only reasonable thing to do was to help artists have an untroubled decision — they could go home and have their residency honored later, or they could stay if that felt better and we would adapt and adapt and adapt together to make the space as covid-safe as possible.

Half of the artists stayed, some for an extra month beyond their scheduled time; three were international artists with unready pathways home. Those who stayed reported extraordinary relief from the stuttering daily uncertainty, fear, and worry which awaited them back home, which they heard in the voices of their friends and family. They found their time on the ranch to be healing in a time where healing feelings were hard to come by, and seeing that happen made me really believe in the work; I think it gave us all a greater belief that we could provide a safe and healing space for artists who needed it, even in — especially in — the midst of world emergency. Our buildings and grounds and practices left us uniquely poised to provide safe isolation amid safe socializing for artists.

As the weeks passed, we figured we could radically reduce the risk of COVID spread at the Djerassi Program by doing a few key things. We dropped our maximum occupancy to 7 from 11 to 13, ensuring that artists could make it through a week or two without sharing indoor spaces with anybody else. We decided to reduce travel variables by focusing on regional artists from within a short day’s drive. We rebuilt meal protocol, established staff bubbles, and studied and matched the evolving regulations and updates. We would use COVID-testing to whatever degree was practicable at the time. We figured that we had the resources to make it so that a month spent at the Djerassi Program would be less risky for artists and for our staff than navigating life at home. We worked to stay in compliance with ever-changing county regulations, we consulted an infectious disease expert and an attorney, but even so every month’s board meeting meant the cancellation of the next session — but only the next session. The Board of Trustees catastrophized at every turn, and we responded in good faith by playing whack-a-mole with their concerns to no avail, even as other residency programs were safely open and adapting.

We wanted to give clear assurances to all of the artists invested in the Program — the 66 artists scheduled for 2020 and the 1100 or so artists who applied to our March 2020 deadline for 2021 residencies, among others — that we would honor our commitments to them as soon as possible. As a staff, everything hinged on the board making that commitment. We couldn’t move forward in any direction without first answering that question: will we or won’t we honor our commitments to these artists? We couldn’t get the board to vote on that. It happened more than once in 2020 that the Trustees waited until the week before a session was scheduled to start before voting to cancel it, having wrested those decisions away from staff, destroying work efficacy at the Program and causing tumult and uncertainty in artists’ lives.

Our Platform

Imagine for a moment what you might have done in 2020/2021 if you were the administrator of a 583 acre ranch, with several spacious buildings, a substantial cash reserve, and a mission to serve artists by offering uninterrupted time and space. Do you let it sit empty? For how long, exactly? What do you do instead?

From the early days of the pandemic through the end of summer, a particularly persistent idea kept coming up from a number of individual board and committee members. I first heard it in April 2020, around the time cut to the bone was gaining steam, when one of the Trustees wrote insisting that I get in touch with his friends high up in Marketing at Airbnb to quickly build a program of online experiences. I gently demurred at first, but he asked again: “Could you provide more info on a timeline for when we think we could get this up and running? It should be fairly low-barrier as an experiment — and time is of the essence if we want to try to maximize the opportunity during [shelter-in-place] and with my contacts at Airbnb.”

His insistent request left me confused and startled: Our staff days were full as we navigated the new complexity of the pandemic; this idea was undeveloped, unproven, and sent off alarm bells about mission creep. Our mission had nothing to do with satisfying audiences — a rarity among arts organizations — but was instead all about offering generative time & space for artists. Many artists experience a constant tension between working for their audiences and working for themselves, and one of the things that I treasured about my work at the Program was the chance to help artists do their own work knowing that audiences would likely benefit some way or other, one day. I used the exchange as a learning opportunity to convey a few things to the Trustees that were important to me:

AirBnB is an interesting platform and as with any platform we have the opportunity to use it to take our programming and revenue generation in a variety of different directions. The platform that I’m focusing my energy on these days is a 583 acre ranch in the Santa Cruz mountains. We use this platform to deliver our primary product : time and space for artists.

Six artists left here prematurely but happy with Djerassi’s response and care. A seventh left yesterday, very grateful. And there are still four artists here, also happy, productive, and feeling safer here than they would elsewhere. That’s an accomplishment; it is not a coincidence.

Please present [ideas] as ideas and not as tasks in order to be respectful of staff time and expertise as you do it. Casually tasking staff members with novel work over email isn’t an appropriate thing for an individual board member to do, as board members may not have the intimate running organizational knowledge to know what a staff member’s short-term priorities are or should be. Generally tasking is best done through the executive director. It can also sometimes be accomplished through committee structures. Those limitations might seem old-fashioned, but the rationale runs deep and helps prevent staff from burning out and nonprofits from imploding.

A Family Foundation Reversion?

My prickly email didn’t change things. As the summer of 2020 went on, my concerns mounted about the liberties that the Trustees seemed prepared to take with the nonprofit, about a shocking lack of empathy for staff and for artists, and about the seeming disinterest in our very clear organizational mission.

In particular, I became astonished at the degree to which Dale and Alexander Djerassi wielded their influence and asserted over the organization.

Dale and Alexander are two Djerassi family members among a dozen or more other trustees. According to the bylaws, the only special perk for family members is that a member of the family can have a seat in the boardroom. More precisely:

So long as there is at least one member of the family of Dr. Carl Djerassi that is able and willing to serve as trustee, the Board shall elect at least one family member to serve as a trustee. Family members shall enjoy 3-year renewable terms in perpetuity as long as they are willing and able to serve.

That bylaw is a result of the organization’s long-ago transition from a private family foundation into a public 501(c)(3) non-profit. The land that Djerassi Program sits in is no longer Djerassi family land, just as the Djerassi Program itself is no longer a Djerassi family program; both were given away in fabulous acts of generosity. Public non-profits can’t be family heirlooms… can they?

Under New Management I

At the time of her departure, Margot H. Knight had been running the Djerassi Program for nearly a decade, putting her heart and soul into the place and accomplishing a great deal while keeping the worst instincts of the Trustees at bay. I watched as her working relationship with the Trustees became untenable; she was put in an impossible situation by their collective desire to take programmatic hold. In the hopes of saving employee jobs, the last of several budget scenarios Margot prepared for the Board excluded her own salary. She then negotiated an exit agreement. Her last day was the last of July, 2020. She left the Program in a good position to succeed. A second development professional left on the same day. The Trustees named me Acting Executive Director and took a two week break despite many open questions. Alexander Djerassi reported to his fellow Trustees on August 20, 2020: “[Peter] has the immediate running of the Program in hand, and is managing the staff, and those signs are very encouraging and very welcome”. I hoped that the organization would be able to use the time to settle down, take a breath, and come together to lay the groundwork for new leadership.

Smoke and Mirrors

August was a tricky time of good faith and big hope for our remaining staff and for the artists who were waiting for us to be clear about what we were going to do. Djerassi Resident Artists Program had just issued a strong Black Lives Matter statement that we hoped the organization would be ready to act on through programming and hiring. We were ready to work with whoever the trustees might bring in and we were ready to do work to support artists and steward the land in ways aligned with the mission.

The night of August 15th was sleepless, scary, and beautiful; dry lightning danced the sky. The fires which emerged from that night became known as the CZU Complex. The fires got to be pretty close to us, one big road and one big chunk of land away; we were about as close as you can get to being evacuated without being evacuated — police actually started evacuations on Bear Gulch Road, before realizing it wasn’t yet called for. It was scary for on-site staff as individuals, and we were worried for the Program as well. With smoke intense and another wave of dangerous fire weather coming, in coming days we brought the important Program history, art, and documentation off site while we could. One trustee was generous enough to open up her home in the city to us. From the rest of the trustees, our staff received a staggering indifference. It was as if the Program, located as it is on a major fault, in fire country, far up a one lane mountain road, was fine so long as the Instagram account stayed on. We didn’t have help from our neighboring Trustees Dale and Alexander as we tried to keep the records from their old Family Foundation — along with newer records — fire-safe.

Instead, during that time, we were daily hounded by Trustees to execute on a strange vision for the 2020 virtual edition of Artful Harvest, the program’s annual gala. In 2020, absent our two development professionals, absent clear direction or messaging for the event or the Program, absent interaction with donors, absent thoughtfulness about how to surrender the right jobs to the right people at the right times, the Executive Committee asserted the hiring of Dale’s wedding planner to produce the event. Put simply, it wasn’t strategic or focused and involved exploiting, rather than supporting, artists.

It was the second week of September 2020 when Marcelle (Marcy) Hinand showed up on Zoom as our Interim Executive Director. When Artful Harvest came up in our first staff call together, she quickly told our staff team to “stop bitching”. We were talking about concerns and proposing alternative approaches. She said “stop bitching” again in similar circumstances in another call days later.

I was not impressed; I quickly resigned. I wrote, “With the introduction of Marcy and [Board Chair] Anna [Sidana]’s respective leadership approaches, things became downright toxic. In July there were three people on staff who had substantial experience directing artist residency programs through transition; now there are zero. In consideration of the remaining staff I am sure I have been treated with the most kindness and respect of all.”

The resulting event was an ostentatious drain on the good faith of staff. It cost nearly as much — tens of thousands of dollars — as it raised. The whole thing depended intensely on 3 of my very underpaid colleagues who were suddenly carrying the gala-making work of a development & media team in a virtual space under the direction of a wedding planner according to an incoherent but very firm vision that had very little to do with supporting artists. It hurt to be part of.

The job had totally lost a sense of grounding in the mission. I wondered if Djerassi Program would ever feel like a safe space for staff or artists.

Under New Management II

Marcy had joined Djerassi Program as Interim Executive Director via a reference from Terra Fuller, who had had a successful and effective 3–4 years at Djerassi Program until moving on to a different workplace in 2019. It was there that she became acquainted with Marcy, who was working as a consultant.

Once Marcy had cleared out the rest of the programmatic staff at Djerassi Program, she hired Terra as the new Program Director. There was no formal hiring process or public competition for Marcy and Terra’s positions, nor for the new Facilities Manager position, nor for a fundraising contract which was awarded. Many of the entry-level positions have been filled and quickly vacated in the past year. Every few weeks this year I have heard an ugly story out of Djerassi Program — partner organizations mistreated, artists misled, staff members experiencing an abusive workplace, programs canceled, donors left in the dark. It has been a bumble at the very best of times, and the apparent nepotism of hiring practices for leadership has been part of that.

Judging only from her accomplishments of the year, one might think that the primary tasks that Marcy was hired for were to seek funding, short-circuit institutional memory by preventing staff from sticking around for more than a few months, and keep up appearances through it all. That happened steadily, over the course of months, and somewhere along the way the “Interim” tag was removed, indicating the Board’s satisfaction with the Executive Director’s progress.

In retrospect, it appears that Djerassi Program’s former Zoom-based Interim-turned-Executive Director was the executor of cut to the bone, the quiet objective which the Board of Directors aggressively pursued. The process was toxic and abusive. Judging from the recent statement from Djerassi Program, problems remain.

Under New Management III

The former Executive Director’s work in deconstructing the staff team paved the way for Alexander Djerassi to become the new Interim Executive Director, a shift which was announced last week.

I wonder: how long will it be before a national search for an appropriate director begins? I hope: mere days.

After leaving the ranch last year, I wrote a letter to the Board of Directors, in which I said:

It was not my hope to leave Djerassi Program so soon. I left because it was clear that the organization was reverting to sycophantic habits and patterns typical of a family foundation rather than of a nonprofit. I left because the mission has been out of focus all year. I left because I found the collaborative context at Djerassi Program tedious where it should be extraordinary. I left because of transparent and embarrassing falsehoods promulgated in our audit. I left because I felt unwanted and was left without space to be effective. I left because the organizational rock bottom seemed closer every day.

Alexander replied to my departure letter on Nov 17, 2020:

As you have sought to stimulate reflection among trustees to consider different paths and approaches, I assume you are also engaging in self-reflection and seeking to understand ways in which you may have contributed to some of the ill-feeling or dysfunction you report having experienced. I believe that this will be a positive and important next phase for the artist program, including an intensive and strategic approach to protecting its land and fundamentals.

Believing in Magic

When things are going well, what the Program does is simple: the staff, docents, trustees, and artists take good care of the place and of one another so that artists can experience wildness and vulnerability and peace and quiet and comfort alternately and at will. Some call it “Djerassi Magic”.

The magic relies on trust; the trust has been broken.

One common consequence of nonprofit Board structures is that an organization can come to be controlled almost entirely by people who aren’t aligned with the needs of the people that their organization serves and with the dailiness involved in the service. I saw that happening at Djerassi Program, where members of the board often seemed more jealous of other similar organizations — Yaddo, Headlands, MacDowell — than proud of Djerassi Program, its features, and its limitations. There was a corrosive desire — for greater cache, more visibility, more famous people on the ranch more often — that struck me as detached from the work.

While I was at the Program, I witnessed a long year of Trustees failing to hold one another accountable to the mission and to nonprofit norms and best practices. The result was erosion, from a lack of restraint, humility, teamwork, empathy, trust, and good faith.

Trustee entitlement has been a long crisis for Djerassi Program; it is the reason that the Board of Trustees long ago suggested that Carl Djerassi step away from the Board (he did).

What will the organization do to respond to this entitlement crisis? One way would be to take seriously the possibility that the organization is stuck in founder’s syndrome, and to take steps to treat the problem as such. Another might be a thoughtful and committed land acknowledgement which reverberates through the organization and frays familial feelings of ownership. Other essential steps include a strong apology, an organizational re-centering around mental health and empathy, deliberate hiring practices that result in diverse and empowered leadership, and a pathway to follow-through on the BLM statement. But whatever the solutions, the Djerassi Program Board of Trustees must find ways to redirect entitlement to form something stronger based on the intense privilege of stewardship, generosity, and the gift of the offering. Until that happens, the Program will not be its best as a regenerative gift, a restorative respite, a possible site of reconciliation. When it happens, the Djerassi Resident Artists Program might again — more than ever — be a safe space for great risks.