Ecology denies petition to begin rulemaking to establish nutrient wasteload allocations for a Puget Sound TMDL

Puget Sound

On Oct. 10, 2017, Ecology received a rule petition from Northwest Environmental Advocates for us to engage in rulemaking to place wasteload allocations in a rule for a Puget Sound nitrogen Total Maximum Daily Load (TMDL) – or official water cleanup plan.

Some important things to know to understand this petition

Washington state law (RCW 34.05.330) provides a pathway for any person to petition an agency to request the adoption, amendment, or repeal of any rule.

A wasteload allocation is a TMDL term that refers to numeric limits placed on point source discharges of pollution. Point source pollution most commonly refers to the permitted discharge of polluted water out of the end of a pipe.

Denying the petition

We denied the petition in a letter responding to Northwest Environmental Advocates on Dec. 8, 2017. We decided to deny the petition on the grounds that we are not immediately ready to develop a Puget Sound TMDL, and adopting a wasteload allocation into a rule is not necessary to implement a TMDL.

We agree with the petitioner that Puget Sound is impaired by nutrient pollution and that a TMDL may be necessary to address this impairment. However, we do not agree with NWEA's statement that we have all the data and analysis necessary to immediately and effectively develop a TMDL for nutrients in a system as complex and vast as Puget Sound. A TMDL can be a useful tool for water quality improvement, but it isn’t the only tool in our toolbox.

Using sound science to shape our actions

We began the technical work to understand the dissolved oxygen issue in South and Central Puget Sound back in 2008. That work included a water quality model for South and Central Puget Sound, however, scientists and decision-makers learned from that work that human impacts need to be evaluated on the larger scale of the Salish Sea.

This is when scientists expanded our scientific model to the Strait of Juan de Fuca and Canadian waters to develop the Salish Sea Model. A circulation and water quality model of this size and complexity takes time to build correctly. It has been through extensive peer review by other scientists and engineers to make sure it gives us accurate results. We and Pacific Northwest National Labs have worked hard to build the technical tool to grapple with and understand the nutrient issue in Puget Sound.

Working to address the nutrient problem in Puget Sound

We finished several pieces of the Salish Sea Model in 2017. These pieces improve the model’s skill and predictive power. We also spent the year communicating what we know and understand about the nutrient problem from current data analysis using the Salish Sea model.

We have scoped the issues by talking with stakeholders, scientists, and the regulated community. We are looking at nutrient management examples from around the country, and have begun building a project implementation framework to reach our water quality goals and help Puget Sound.

Tackling nutrients in 2018

As we continue technical analyses in the coming year, we will begin developing a strategy that can be implemented to address nutrients in marine water quality.

Washington state and the U.S. Environmental Protection Agency (EPA) have invested nearly a decade of time and money developing the Salish Sea Model to give us the power to answer one big question:

What impacts are humans having on dissolved oxygen and water quality in the Salish Sea?

We are now ready to apply that model to figure out what actions are needed to reduce nutrients and improve Puget Sound water quality.

Denying the petition but still addressing the problem

While we are denying this petition to put wasteload allocations from a Puget Sound Nutrient TMDL into rule, we will continue to:

• Use the Salish Sea model to determine where treatment technologies that remove nutrients will have the greatest impact on reducing nutrient inputs to Puget Sound.
• Use the Salish Sea model to determine which nutrient reductions are necessary to avoid impaired water quality.
• Evaluate where reducing nutrient inputs from the watersheds that contribute to Puget Sound are necessary.
• Continue our work to reduce non-point sources of nutrient pollution.
• Continue working with agricultural communities to reduce nutrient runoff from farms that can adversely impact shellfish harvest areas.

Our work to reduce nutrients in Puget Sound

Follow this Puget Sound Nutrient Watch blog series to stay current and learn about our work to reduce nutrients in Puget Sound.

Earlier blogs:

• Salish Sea Computer Model
• Puget Sound's Growing Nutrient Problem

Visit our website and join our email list to get up-to-date information on the nutrient problem in Puget Sound.

We want this to be a collaborative effort that brings all of the technical work that is happening on Puget Sound nutrients together. We need all hands on deck to find the best solutions for meeting water quality goals for Puget Sound.

Contact information

Dustin Bilhimer

Puget Sound Nutrient Source Reduction Project Manager

dustin.bilhimer@ecy.wa.gov

360-407-7143

Calling all lovers of the Puget Sound!

Are you interested in regional efforts to keep Puget Sound healthy and resilient? Join us in Auburn, Wed., July 19 at Green River Community College to attend our Puget Sound Nutrient Dialogue. This all-day meeting will bring together those working to understand and protect Puget Sound to discuss what we’re learning from our most recent science.

Fort Lawton West Point Lighthouse, Discovery Park, Seattle, Washington (Courtesy of Kenny Rowe)

After a decade of development, we have the state-of-the-art Salish Sea environmental computer model to help us understand changes in Puget Sound and evaluate the best solutions to reduce human impacts. This model shows us that land-based human sources of nutrients are leading to cases of low dissolved oxygen levels in the Sound. We are using this tool – in combination with ongoing field monitoring data and broad stakeholder input – to develop options to reduce nutrients in the Sound.

Join the conversation and learn how an over-abundance of nutrients affect our beloved Puget Sound. A healthy balance of nutrients is essential for a healthy food web, just as we require a balanced diet for good health. But excess nutrients from human sources can cause problems in Puget Sound just as over-eating can lead to health problems in your body. The over-enrichment of nutrients is diminishing dissolved oxygen levels that fish and other species in the Sound need to thrive.

 

Click here to register!

Join us in person

When	July 19
Time	8:30 a.m. to 4 p.m.
Where	Green River Community College, Lindbloom Student Union Center
Address	12401 SE 320th St. Auburn, WA, 98092

Register by July 5 to secure your seat!

Parking and the event are free. Coffee and light refreshments will be provided. Lunch will be available for purchase at the college’s newly remodeled cafeteria.

 

How can nutrients be negative for Puget Sound? 

A healthy Puget Sound is integral to our identity and our future. There is a growing body of science and evidence that shows increasing nutrients are adversely affecting the Sound. 

This dialogue is meant to bring together stakeholders, decision-makers, scientists, and the interested public to:

• Talk about the current state of the knowledge
• Discuss the effects of excess nutrients in Puget Sound
• Make connections between different areas of research
• Identify new studies that will improve our knowledge and understanding
  

Just like your human body, our Puget Sound ecosystem needs balance to be healthy. Too many nutrients in the Sound can also lead to undesirable changes in the food web, over-growths of algae that wash up on our beaches, increases in jellyfish populations, and more harmful algae blooms. Beyond changing what is considered normal for Puget Sound, these problems could reduce the Sound’s ability to be resilient to increasing pressures from climate change and the growing human population in the region.

 

Stay involved! 

Learn more about the project on our website where you can also find updated information on the Puget Sound Nutrient Dialogue as it becomes available.

Subscribe to our project listserv to receive email updates. 

By: Jenny Robertson, water quality environmental specialist