Draft Action Agenda Comments - Federal Agencies

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02:02 ← 01 Jul 2011

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Draft Action Agenda Comments Federal Agencies Nov. 6 - 20, 2008 Set 4 of 8 Draft Action Agenda Comments - Federal Agencies 1 of 60 Draft Action Agenda Comments - Federal Agencies 2 of 60 Draft Action Agenda Comments - Federal Agencies 3 of 60 Draft Action Agenda Comments - Federal Agencies 4 of 60 Draft Action Agenda Comments - Federal Agencies 5 of 60 Draft Action Agenda Comments - Federal Agencies 6 of 60 From: Paul Kluckner, Environment Canada Comment: Thank you for the opportunity to review and provide comments on the Draft 2020 Action Agenda for Puget Sound. This is a very comprehensive document with significant and achievable actions in each of the priority areas.

Many of the priority areas identified in the Draft Action Agenda are of course priorities for Environment Canada and other agencies north of the border. Given that the Puget Sound and Georgia Basin share a common airshed, common watersheds, a common home for migratory birds and fish, and common urban growth pressures, we recognize the importance of continued transboundary collaboration in addressing our shared challenges. To this end, we are pleased to see that one of the actions under Priority ... more. less.

D is to cwork cooperatively with Canada on management and scientific investigations to increase collaborative problem solving and information sharing d (D.3.8). A good example of this collaboration is the Joint Statement of Cooperation on the Georgia Basin and Puget Sound Ecosystem, signed in 2000 by Environment Canada and the US Environmental Protection Agency (Region 10). We are also encouraged by the efforts to engage other cpartners d (cities, state agencies, Puget Sound tribes, etc.) in implementing Action Agenda priorities and look forward to exploring opportunities to share information and lessons learned with agencies and groups on this side of our shared transboundary ecosystem. The upcoming 2009 Puget Sound Georgia Basin Ecosystem Conference presents one such opportunity. We are looking forward to co-hosting the conference and contributing to ongoing engagement and action on shared priorities. Attached, for your consideration, are comments on specific areas of the Draft Action Agenda that we hope you will find useful. Please don 9t hesitate to contact me if there are any areas where we can provide further information. Again, thank you for the opportunity to review the Draft 2020 Action Agenda. We look forward to its successful implementation and the opportunities it presents for continued transboundary collaboration in the Puget Sound-Georgia Basin. Draft Action Agenda Comments - Federal Agencies 7 of 60 1 Question 1 3 Indicators of a healthy Puget Sound " The theme of indicators as metrics to measure success toward legislated goals and to support adaptive management from an ecosystem perspective is a theme that permeates the draft Action Agenda. It is significant that these indicators are strongly tied to ecosystem targets with specified dates as well as benchmarks to gauge progress and adjust management strategies in the interim toward targets. " Six indicators are proposed for each of the targets, including shellfish growing areas, areas of farmland, toxics in pelagic fish, eelgrass status and trends, instream flows and salmon and steelhead status and trends. Overlap with the current Puget Sound-Georgia Basin transboundary ecosystem indicators, both in many metrics and the timing of reporting, may facilitate coordination of planning and implementation for both initiatives, and possibly transboundary decision making, which is the ultimate goal of transboundary indicators. " The PSP website posts a provisional indicator chart updated on November 7, after the date of the November 6 draft. The following comments reflect the more current indicator chart: " The benchmark for shellfish growing areas is a net increase of 1,000 acres open for direct harvest each biennium and a net increase of 10,000 acres open by 2020. However, meeting the benchmarks state for each biennium will not yield 10,000 acres open by 2020. " Many studies have shown that once impervious surface area exceeds a threshold of about 10% to 15% of a watershed's area, serious ecological degradation can occur (Limburg and Schmidt, 1990; Imhof et al., 1991; Weaver and Garman, 1994; Wichert, 1994,1995; Moscrip and Montgomery, 1997; Wang et al., 1997, 2000). The target by 2020 for imprevious area below 1000 feet is less than 120% of the 2001 level. It is unclear whether this target would yield impervious areas greater than 10% of the watershed's area. " ESU should be added to the list of acronyms as "Evolutionarily Significant Unit". " Increased flooding (as well as increased drought) events are expected to occur with climate change in the Puget Sound-Georgia Basin. A benchmark or target for instream flows to exceed minimum low flow levels during wet years does not seem strongly associated with ecosystem health if associated with climate change. " Environment Canada released an ecological screening assessment report on PBDE in June 2006 which revealed that PBDE levels in Canadian biota are rising with dramatic increases in tissue concentrations particularly evident over the last two decades. A benchmark reflecting 2004 PBDE levels in Georgia Basin herring and a target that PBDE levels in herring from south and central Puget Sound are not higher than levels in herring from the Strait of Georgia may not be associated with ecosystem health. Draft Action Agenda Comments - Federal Agencies 8 of 60 2 Priority A 3 Protect Intact Ecosystem Processes, Structures and Function Question 3 I Page 6 " We encourage Puget Sound partners to become familiar with the work of the Intergovernmental Partnership in BC and Alberta on the issue of land use patterns on aquatic habitats as described at www.waterbalance.ca. A.1.3.1 " Mapping ecosystem function at multiple scales is an approach that has been applied in the Georgia Basin as well. The shore zone mapping now available in BC and Washington is a good starting point but it might need to be a finer resolution in some priority areas and needs to be updated on a regular basis in order to provide trend statistics. A.2.1 " There is a great deal of related Canadian experience to draw on, both in terms of effective management of individual Marine Protected Areas (MPAs) and joint efforts by the Governments of Canada and BC to develop a coast-wide network or system of MPAs. There may be opportunities to link up the networks and consider a transboundary approach to MPAs in the Puget Sound-Georgia Basin ecosystem. The recent workshop on MPAs organised by the BC-Washington Coastal and Ocean Task Force provided an opportunity for Washington to learn from Canadian experience on the Pacific coast and will presumably contribute to the actions in this area. " There are now two complimentary databases in BC of Crown and NGO conservation areas ( www.naturetrust.bc.ca/conservation_g.php#c5 ). The BC Conservation Land Forum provides efficient coordination of land securement and land management efforts of provincial and NGO agencies. " The Pacific Coast Habitat Joint Venture ( www.pcjv.org ) is actively engaged in establishing population targets for bird species and linking these to quantitative habitat targets, including acres of farmland. It is worth remembering that it is not just the extent of farmland that determines its habitat value, but also the type, timing and intensity of agricultural activities taking place (e.g. pasture vs. greenhouses). A.2.2 " PSP may be interested in looking at the experience and tools developed in BC around shoreline protection ( www.greenshores.ca ). As in Washington, BC faces the challenge of shoreline armouring especially in light of sea level rise. " National Wildlife Federation and Ducks Unlimited Inc (both US-based) are both actively engaged in modeling sea level rise and resulting impacts on coastal habitat using the US EPA SLAMM Model, Version 5.0 (Sea Level Affecting Marshes Model). The Model and preliminary results are available at www.nwf.org/sealevelrise and www.spea.indiana.edu/wetlandsandclimatechange/SLAMM-View.htm . A.2.2.5 " PSP may want to look at the Green Bylaws Toolkit ( http://www.greenbylaws.ca/ ) developed in BC as a resource in the development of their model ordinances. While the regulatory framework is different the concepts could be shared. Draft Action Agenda Comments - Federal Agencies 9 of 60 3 A.3 " The introductory remarks to this agenda item highlight concerns over impacts to surface water flow and groundwater in watersheds within the Puget Sound region, however the proposed action items focus primarily on instream flows (surface water) rather than the interaction of groundwater and surface water. Environment Canada has been engaged in regional aquifer studies in the Lower Fraser Valley for several decades and has an extensive aquifer monitoring program in the transboundary Abbotsford-Sumas aquifer, where land-use activities (primarily agricultural) have contributed to a degradation of groundwater quality with potential implications for surface water quality in streams that are hydraulically linked to the aquifer. More recently, Environment Canada has also been involved in the review of large-scale groundwater supply proposals, with a strong interest in the evaluation of potential impacts to instream flows. " Some additional considerations for this section of the Action Agenda include: o Implementation of concurrent groundwater and surface water management strategies/plans rather than separately managing both parts of the hydrologic system. o Water balance studies for watershed should include both groundwater and surface water terms in order to effectively understand overall water availability o Source water protection for aquifer areas is important in the context of protecting groundwater users but also with respect to stream quality. o Engage in educational outreach on groundwater protection and the linkages between aquifers and surface water flows. " Environment Canada hydrologists have conducted considerable work on how landscape and landscape changes affect streamflow characteristics. While much of this work is now national in scope, we are updating the detection of change in streamflow in the Georgia Basin-Puget Sound. These methods developed would be useful in predicting streamflow in watersheds where no data exists, and in validating projections made by others. Information and models developed would contribute to actions A.1.2 and A1.3 at a coarse scale. A.3.1 " EC has partnered with an academic research group in the study of stream and riparian zone conditions and influences on water quality and groundwater/surface water interaction in the Lower Fraser Valley. EC is engaged in monitoring of transboundary aquifers and characterization of groundwater flow and groundwater/surface water interaction. A.3.1.1 " An area that merits additional consideration is the assessment of instream flow rules within projected scenarios of climate change to see how they can continue to function as part of an overall watershed management framework that allocates water among several users. PSP may want to consider adding c&ensure instream flow rules are based on the most complete science pertaining to hydrologic processes, including the potential impact of climate change, and assessment of effectiveness of drought management and climate change adaptation measures d to this section/action. A.1.3.2 " Consider the rare elements (species and ecosystems) as entities in addition to the on-the- ground occurrences of those elements to determine priorities for action. BC 9s Conservation Framework (in development) uses clearly defined scientific criteria to determine priorities and the most appropriate management actions for species and ecosystems of conservation Draft Action Agenda Comments - Federal Agencies 10 of 60 4 concern ( http://www.env.gov.bc.ca/conservationframework/whatis.html ), and may provide some ideas for establishing priorities for action, and defining what those actions should be. IUCN also has a classification scheme for conservation actions at http://conservationmeasures.org/CMP/IUCN/browse.cfm?TaxID=ConservationActions . A.3.2 " Environment Canada is active in understanding impacts to groundwater quality in the Lower Fraser Valley (primarily in the Abbotsford area) and is working with stakeholders at provincial, municipal and industrial/agricultural sectors to reduce water quality impacts through improved land management in affected areas. " An example of work in the Georgia Basin that may be of interest to PSP is the BC Ministry of the Environment Pilot Study in the Township of Langley. Under recent amendments to the BC Water Act, area-specific water management regulations are being implemented in an area of the Lower Fraser Valley that is experiencing declining groundwater levels in several key water supply aquifers with projected impacts to instream flow availability. Measures are being considered to improve regulations around groundwater use to help ensure the sustainability of the groundwater resources as well as the instream flows that are sustained by groundwater. " Watershed stewardship programs are active in some areas of the Lower Fraser Valley, including educational outreach and water conservation incentives to improve action, awareness and public buy-in with respect to source water protection and conservation. " Protecting instream flows through Puget Sound wide water conservation strategies may be challenging in the climate of the Pacific Northwest where there are no water shortages in most areas for most of the year. Addressing water shortages in a manner specific to the time and place they occur may be a more sellable solution with the public. " British Columbia 9s Living Water Smart Plan( http://www.livingwatersmart.ca/ ) is an additional resource to consider in PSP 9s work on protecting freshwater resources. A.5 " The Spartina Driftcard Study (a BC-WA study) clearly illustrated that there is considerable movement of water between Puget Sound and Georgia Basin and outside of Juan de Fuca Strait. This is an area where increased transboundary cooperation on strategies may be beneficial in addressing invasives in the shared waters of the Georgia Basin-Puget Sound. Priority B 3 Restore Ecosystem Processes, Structures and Functions B.3 " A recent initiative in the East Kootenays might be of interest. Recently, Columbia Valley residents voted in favour of creating a Local Conservation Fund, a dedicated fund for the Upper Columbia Valley of up to $230,000 annually through a $20/parcel property tax. The East Kootenays Conservation Program is working with the Regional District of East Kootenay in the Upper Columbia Valley to establish this fund, with three proposed themes: fish and wildlife habitat conservation, watershed conservation, and open space conservation including family ranches and forested land ( http://www.ekcp.ca/EKCP_LCF.html ). Draft Action Agenda Comments - Federal Agencies 11 of 60 5 " Also, see http://www.islandstrustfund.bc.ca/naptep.cfm for information on the Natural Area Protection Tax Exemption Program, which provides landowners with a 65% reduction in property taxes when they protect through conservation covenant (easement) sensitive ecosystems or other special features on their land. " Environment Canada is interested in learning what methods are effective (and not) at expanding landowner participation in incentive programs. Priority C 3 Reduce the Sources of Water Pollution " Environment Canada carries out long term water quality monitoring and we are looking at water quality trends in some Georgia Basin waterways. We also report on the status of water ways, using the Canadian Council of Ministers of the Environment (CCME) Water Quality Index. This is not something being used in the US; however, it does comment on water quality condition, relative to protection of aquatic life so may be useful. We also employ the CABIN (Canadian Aquatic Biomonitoring Network) approach to assess the biological condition of waterways. These approaches may be of interest to PSP for your work in the freshwater environment. Information and data on this work is available on the web at: http://waterquality.ec.gc.ca/EN/home.htm . C.1.1 " The actions in this section could benefit from an approach that sees science /biology /toxicology move forward as one. Human waste will continue to be the major input into sewage treatment plants and any reductions in pharmaceuticals and personal care product inputs to this will require not only outreach with the public, but also work with the pharmaceutical industry to design products that are non-biologically active to aquatic organisms. Infrastructure research and engineering new technology for sewage treatment of pharmaceuticals and other emerging chemicals (nanomaterials) is also needed. " Recommend that a cbiological d bioassay using comic d technologies and relevant species for each trophic level be developed to provide a ccanary in the mine d detection to alert regulators of potential problems with drugs and their metabolites that will cause food chain level toxicological effects. C.1.2.1 " While transboundary mechanisms for dealing with emergency oil spill response are in place (CANUS-WEST and CANUSPAC), cooperating with research on chronic oiling such as through the Birds Oiled at Sea program (BOAS) is also necessary to better understand and address impacts on water quality in our shared waters and the fish, birds and mammals that inhabit them. C.1.2.4 " Environment Canada has carried out work estimating the benefits associated with air quality improvements. This work has benefitted greatly from partnerships formed through the BC Lung Association. C.2 " Metro Vancouver is currently planning an ambient monitoring program for Boundary Bay and has already approached PSP with regards to collaboration opportunities. Details of the ambient monitoring program are not yet known, however stakeholders from across the Draft Action Agenda Comments - Federal Agencies 12 of 60 6 region are meeting in December to discuss the program in more detail. This initiative could potentially contribute to some of the action items under this section of the Action Agenda, or at least have related outcomes. C.3.1 " Not discussed in this section are the bio-solids (sludge) from the wastewater treatment facilities. These are prime sources for estrogenic compounds. Greater investigations are warranted in this area to prevent potential contamination from land based applications and eventual leaching of the chemicals into water ways. This is particular relevant to the Pacific Northwest with the huge amounts of rainfall we get. " The section acknowledges that wastewater treatment facilities are outdated. Puget Sound has an opportunity to invest in innovative science and engineering to build and treat for not only the conventional issues of BOD, low dissolved oxygen and nutrient but also the low level concentrations of the estrogenic compounds that are making their way into the receiving waters of Puget Sound. Priority D 3 Work effectively and efficiently together as a coordinated system to ensure that activities and funding are focused on the most urgent and important problems facing the region. D.1 " Environment Canada is interested to learn about PSP 9s experience, after the action agenda is in place and some analysis is done on realigning programs, what was most effective (and not) in realigning existing programs. D.2 " Environment Canada conducts studies that address detection and projection of the impacts of climate and land use changes on hydrology as part of the national Water Cycle Prediction program. Statistical and dynamic downscaling from GCM and RCMs are being developed to improve assessment of future impacts of climate, and studies and research on land use change can also contribute. In the Georgia Basin-Puget Sound, it is critical that these are not separated as the scale of the effects of urbanization and other land use conversions may be greater than the climate driven impacts. D.2.2 " There is an opportunity to consider the integration of the West Coast Governors' Agreement with the Action Agenda more broadly than just with respect to climate change adaptation, as there are many areas of overlapping or complementary interest (e.g. combating pollution and marine debris, improving oil spill prevention and response, improving coastal air quality, and marine and estuarine habitat protection and restoration). D.2.3 " Engineers Canada recently did a national engineering assessment of the vulnerability of Canadian public infrastructure to changing climate conditions. One of the case studies was the vulnerability of the Vancouver Sewerage Area Infrastructure to Climate Change ( http://pievc.ca/e/Appendix_B.3_Metro_Vancouver_British_Columbia.pdf ). " To meet the climate change challenge, Engineers Canada and its partners have established the Public Infrastructure Engineering Vulnerability Committee. Co-funded by Natural Draft Action Agenda Comments - Federal Agencies 13 of 60 7 Resources Canada (NRCan) and Engineers Canada, the Vulnerability Committee is a major Canadian initiative involving all three levels of government and non-governmental organizations. It is looking broadly and systematically at infrastructure vulnerability to climate change from an engineering perspective. The Committee's work will result in the First National Engineering Vulnerability Assessment. D.3.8 " The EC-EPA Joint Statement of Cooperation on the Georgia Basin and Puget Sound Ecosystem has provided a vehicle for transboundary information sharing and problem solving. The 2008-2010 Action Plan: Initiatives for the Salish Sea outlines some specific actions that will be undertaken over the next couple of years, including ongoing work on transboundary indicators, aligning of work plans with the Coast Salish Gathering and the BC and Washington Coastal and Ocean Task Force and facilitating transboundary demonstration projects. We look forward to PSP 9s ongoing participation on the Statement of Cooperation Working Group and as co-host of the Puget Sound Georgia Basin Ecosystem Conference. " Suggest changing Puget Sound Georgia Basin cResearch d Conference to cEcosystem d conference to reflect the change in title. " One area that could benefit from improved transboundary coordination is climate change. There is an opportunity for this currently fragmented community to build greater cohesion through a workshop or network, as is being developed by the Climate Impact Group out of the University of Washington. Priority E. Build and implement the management system to support the implementation and continual improvement of the Action Agenda. E.1.3 " This section calls for the development and implementation of an information management system to support ecosystem management decision making. The transboundary indicators group is also currently examining possibilities for an information system that will facilitate future updates and stronger linkages to decision making. The intent is to facilitate timely information exchange among scientists and policy makers. E.3 " It would be interesting to explore monitoring efforts that are consistent on both sides of the border. The Coastal Waterbird Survey is being run by Bird Studies Canada on the BC coast using volunteer citizen monitors, and there has been some talk of Audubon running the program in the Puget Sound region. If the two programs could be run so that data could be consolidated and compared across the border, it would help facilitate communication. E.3.1 and E.3.3 " These sections recognize the value of strong linkages among indicators, monitoring and reporting. Specific references to the transboundary indicators are not made, however these should play a key role in reporting on the State of the Sound. Consistent between PSP and transboundary indicator initiatives are near term plans to develop projections of future scenarios based on historical data and conduct spatial analyses to evaluate current ecosystem status, threats and drivers to inform management decisions. Draft Action Agenda Comments - Federal Agencies 14 of 60 8 E.4.3 " This section talks about strengthening K-12 environmental programs. PSP has the opportunity to involve young people in many aspects of the plan and its implementation. Today 9s youth will be implementing the action agenda in the decades to come, so we need them on board and engaged at all ages. Another important group to be considered are young adults (post grade 12 3 college and university students). " The Implementation Table lists no near-term actions for Priority E, where Environment Canada and EPA may be identified as partners for their role in transboundary indicators (through the EC-EPA Joint Statement of Cooperation). Draft Action Agenda Comments - Federal Agencies 15 of 60 Draft Action Agenda Comments - Federal Agencies 16 of 60 Draft Action Agenda Comments - Federal Agencies 17 of 60 Draft Action Agenda Comments - Federal Agencies 18 of 60 Draft Action Agenda Comments - Federal Agencies 19 of 60 Draft Action Agenda Comments - Federal Agencies 20 of 60 Draft Action Agenda Comments - Federal Agencies 21 of 60 Draft Action Agenda Comments - Federal Agencies 22 of 60 From: Elizabeth Babcock, NOAA Comment: We will be submitting a letter to the Partnership that reflects input from several line offices of NOAA, not just the National Marine Fisheries Service. As such, the comments are at a more general or thematic level, rather than a specific and comprehensive one. We offer suggestions for improving the 2020 Action Agenda measures related to habitat restoration and nearshore protection, instream flows, adaptive management, and the salmon recovery plan. We offer NOAA's technical and management expertise to the Partnership as implementation proceeds. I wanted to propose some additional ideas for your discussion with the RC on Thursday: NOAA recognizes that the Recovery Council and watershed leads, in coordination with the tribal governments and watershed partners, are uniquely positioned to implement the recovery plan and monitor progress toward salmon recovery goals. We believe it will be important for the Partnership to continue to support to the watersheds and the Recovery Council as implementation proceeds. We believe that completion and implementation of a scientifically-based monitoring and adaptive management program for the recovery plan is absolutely critical and needs to be a high priority for both the Recovery Council and the Partnership in 2009-11. NOAA will help you as you and your team continue your effort to complete this work. As I said at the retreat, NOAA is not as well positioned to develop and implement this work as your team is. We do, however, have a responsibility to ensure that a monitoring and adaptive management program gets implemented and assists in the evaluation of the status of the species and habitat in Puget Sound. This is a fundamentally important part of the overall recovery approach, and NOAA likely would need to step in to develop the specifics of such program if it were not produced through the existing technical teams at the watershed and regional level. Finally, there were a few specific statements in the draft 2020 Action Agenda that I want to be sure your members are aware of, should they choose to comment on them. Under Species and Food Webs, Question 2, the Action Agenda measure states "....The target is to have two to four viable populations in five regions by 2055." Clearly, the RC would expect the target for this measure to be two to four populations in each of fve regions. Also, if the agenda is striving for recovery by 2020 and the salmon recovery plan aims at 2055, some reconcilliation of the goals is needed. We don't want to be at the year 2020 and be on a trajectory that would not lead to success by 2055, but have to wait 35 years to confirm that reality. Interim targets are needed to make this section of the Action Agenda more useful and credible. NOAA made some specific comments about the instream flow protection section of the 2020 Action Agenda as well. The language under Question 2 pertaining to Freshwater resources states that the Action Agenda measure is "...to have instream water flows in wet years that Draft Action Agenda Comments - Federal Agencies 23 of 60 exceed established minimums in all watersheds." What about dry years? We suggest the Action Agenda measure consider the full range of hydrologic and climatic factors the watershed may experience. We also recommend the target and benchmark for instream flow be modified to be more precisely worded and thus protective of listed species. The current wording is based on flows set by rule or agreement rather than based on flow levels that are protective of species and habitat. Draft Action Agenda Comments - Federal Agencies 24 of 60 Seattle District Corps of Engineers Comments to Draft 2020 Action Agenda Submitted November, 19, 2008 1 Topic: Comments to Draft 2020 Action Agenda for Puget Sound To: Puget Sound Partnership From: Seattle District Corps of Engineers General Comments We recognize that the Draft Action Agenda provides a starting point for restoring the health of Puget Sound by 2020 and include in this section general suggestions that may serve to improve the overall plan. While we acknowledge that the state legislated deadline constrained the available time for review, we had difficulty reviewing the document due to the short review period and to Action Agenda version changes made after the initial Nov. 6 th release. We identified that different versions were posted on the website for review between November 6-13, 2008, which made it difficult to respond to specific sections of the document. We responded to the November 13 version unless otherwise noted in the comments. " Proposed federal actions in the draft Action Agenda will require that NEPA requirements be satisfied prior to implementation of those actions. We suggest that the Federal Caucus or participating federal agencies could be charged with preparing the necessary NEPA documentation with reviews prior to implementing the proposed programs, projects, and activities. " Individual Action Agenda recommendations are loosely organized around very broad objectives with weakly explained rational for selection. An objective reviewer can not determine what trade-offs were considered before the recommendations were determined. Also, if all recommendations are fully implemented, it is unclear what outcome will result. While there are some simple indicators in the introduction, the individual Action Agenda recommendations are not linked back to the overall indicators. Please revise to note whether all recommendations each support all indicators or, whether some individual recommendations support a subset of the overall indicators. " The Action Agenda appears to focus on restoration opportunities in lieu of restoration planning (e.g. Priority B introduction found on Q3, page 16- and Priority B.1.3 found on Q3, page 17). Suggest that by shifting the emphasis to planning efforts which shape restoration, significant progress can be achieved. If we keep working only where opportunities exist we will perpetuate the "random acts of kindness" approach that characterizes so many current restoration actions. " We suggest that briefly discussing the lessons learned from previous Puget Sound restoration plans and applying those lessons to the current situation would be useful. For instance, the Puget Sound Estuary Plan as adopted by the Draft Action Agenda Comments - Federal Agencies 25 of 60 Seattle District Corps of Engineers Comments to Draft 2020 Action Agenda Submitted November, 19, 2008 2 EPA national estuary plan as a Comprehensive Conservation and Management Plan was developed under a similar process as the Action Agenda with many of the same threats or concerns identified. In fact it contained many of the same programs and action items that this plan contains. We suggest that identifying barriers to implementation from past plans will result in a more robust Action Agenda. " The many existing environmental regulatory laws at the local state and federal level with an enforcement component are an important component for a robust regulatory program. However, existing enforcement programs are often hindered by lack of personnel and funding. We suggest partnering with regulatory agencies to develop a comprehensive approach to enforcement, establishing specific goals, to leverage limited agency resources. This, paired with a strong educational program that underscores the importance of regulatory efforts would support the PSPs message of the need to restore Puget Sound by 2020. " Current economic incentives (i.e., property taxes, flood insurance) to develop in sensitive areas of Puget Sound should be addressed in the Action Agenda. We suggest that once economic incentives are removed the trend to exploit these important habitats will diminish. Specific Comments 1. Question 1, page 4, provisional indicators, Toxics in pelagic fish. This section appears to have a narrow focus on both pelagic fish and PBDE. There are health advisories in both the Duwamish and Commencement Bay for Salmon and shell fish. Some of these are forage fish for the endangered Orca and have bioaccumulation concerns as well. Chemicals such as PCBs and mercury are of real concern and tissue concentrations would make excellent indicators as well as excellent goals. Reference your discussion on Question 2, page 2 current condition under human health. 3. Question 3, Page 5 Protect Intact Ecosystem Processes, comprehensive protection strategies. Please identify mechanisms for protection, which appears to be the focus here. 4. Question 3, Page 6, A.1 We suggest increased involved with GMA plans as they are meant to address many of these issues. 5. Question 3, page 8, A.2 The Plan discusses protection but does not explain a strategy or method to achieve protection. It would help to identify the mechanism (i.e., legislation, purchase) for protection. 6. Question 3, Page 34, D.4.1.5 Draft Action Agenda Comments - Federal Agencies 26 of 60 Seattle District Corps of Engineers Comments to Draft 2020 Action Agenda Submitted November, 19, 2008 3 There currently exists a streamlined permit process for habitat restoration projects. For the Clean Water Act there is a Nationwide permit and a programmatic ESA consultation. There is also a coordinated JARPA process that ensures all of the regulatory agencies are talking to each other. One word of caution, you still need review and provide oversight for restoration since not every project identified as a restoration project is beneficial to the environment. Sometimes near-shore development comes in the guise of crestoration d. 7. Question 1, page 3, table and Question 2, page 2, Human Health, Action Agenda Measure. Suggest including Tribal and recreational shellfish growing areas are they are equally as important and are an indicator of the health of Puget Sound. 8. Question 3, page 5, Priority A, Current situation. The concept of looking at ecosystem processes fits in quite well with the Corps and EPA 9s new mitigation rule for a watershed approach to assessing and approving mitigation proposals. 9. Question 3, page 7, A.1.3. Suggest partnering with the Mitigation that Works 9 initiatives in developing and using watershed characterizations. 10. Question 3, page 7, A.1.3.1. This work needs to also be performed in collaboration with Federal, state, and tribal entities. 11. Question 3, page 7, A.1.3.4. Using the phrase cIncorporate the findings into federal & regulations d makes this sound like a foregone event with no input required and/or desired from the federal agencies, even with the caveat cas appropriate d. We suggest making this a collaborative effort and as the comment above states, include all parties in the development and analysis of the watershed characterization studies. 12. Question 3, page 9, A.2.2. Please discuss Federal regulatory programs as they will influence the PSP 9s ability to make the changes as shown. 13. Question 3, page 21, C.1. In item 7, need to also list tribal shellfish areas. 14. Question 3, page 33, D.4.1.1. Amending, realigning, or eliminating the Clean Water Act or the Rivers and Harbors Act may prove to be very difficult and time consuming, at best. We suggest that we first use the new tools (e.g., mitigation rule), and existing programs such as those listed in D.4.1.3 to support the needed changes before seeking reauthorization of existing national environmental legislation. Draft Action Agenda Comments - Federal Agencies 27 of 60 Seattle District Corps of Engineers Comments to Draft 2020 Action Agenda Submitted November, 19, 2008 4 15. Question 3, page 33, D.4.1.3. The description of the different types of general permits as written is incorrect. Both types of general permits require the actions to be authorized be similar in nature and minimally impacting both individually and cumulatively. Both also could require mitigation. Regional general permits (RGPs) are very similar to the Nationwide permits proposed by Corps HQ, the geographic scope is just smaller, a region. This allows them to take into account more of the local issues when putting together the terms and conditions. The programmatic general permits (PGPs) are used to avoid duplication with an existing Federal, state, or local agency 9s regulatory program. For example, King County has a very strong regulatory program that is protective of aquatic resources, including wetlands. The Corps could issue a PGP to King County to avoid the duplicative review of both King County and the Corps. The advantage of RGPs and PGPs when compared to NWPs is that the Corps will complete at least the ESA consultation and at least set up the process for the Section 106 consultation as a part of the authorization. This greatly speeds up the review of permit applications. Please revise this section for accuracy. 16. Question 3, Page 35, D.4. In Item 3 please include Section 10 of the Rivers and Harbors Act in the list of permits required from the Corps. As much of the work could take place in Puget Sound proper and other designated navigable waters Section 10 authorization will be required in addition to any 404 authorization. In Item 6, the in-lieu fee program needs to look at more than just restoration projects. Creation, enhancement, and preservation can also be components of a viable in-lieu fee mitigation program. Also, discussions are still on-going regarding the appropriate sources of money to pre-capitalize the program. Care needs to be taken to not use funds that would cause cdouble dipping d to occur. The new Mitigation Rule has some restrictions related to Federally funded restoration projects. Suggest changing the wording to cpre-capitalized with appropriate funding sources d. 17. Question 3, page 38, Rationale for Action. If the last sentence of the first paragraph is meant to imply that the cimplementers d (the regulatory agencies) will need to align their reporting requirements to meet PSPs standards, regardless of what programs or agency requirements are in place, then this action appears unrealistic. For the Corps, we have a nationally mandated tracking program that we are required to use and therefore, we can only provide the information available in that system. Additionally, the Corps does not have staffing to enter information into another system. Reporting requirements need to be developed in collaboration with the regulatory agencies and take into account their constraints. This comment also applies to E.1., Item number 13. For the US EPA Data Exchange, which is not widely understood or explained in the Action Agenda, to be used, then legacy data from existing systems must be able to be electronically transferred into the Exchange across agency databases. Draft Action Agenda Comments - Federal Agencies 28 of 60 Seattle District Corps of Engineers Comments to Draft 2020 Action Agenda Submitted November, 19, 2008 5 18. Question 3, page 51. The number of geographic action areas in the first and second paragraphs does not match. Please clarify whether it is 7 or 8 geographic areas. 19. Near-term Action D.3.1 (Question 3 page 32 of 6 Nov 08 draft version). Please revise to read as follows: cIntegrate the work of the Puget Sound Nearshore Partnership (PSNRP), including the Estuary and Salmon Restoration Program, into the Puget Sound Partnership to focus sufficient state, federal, tribal and non-profit organizational resources on Priority A and B sites identified during the investigation. d 20. Near-term Action B.2 (Question 3, page 17). Suggest Deschutes Estuary (Capitol Lake) Restoration or Bremerton Waterfront Improvements would also be good candidates for revitalizing waterfront communities in the near-term. 21. Near-term Action A.4.1 (Question 3, Page 13). Please replace "conversation" with "conservation." 22. Question 3, page 16, Priority B, Rationale for action, Improving strategies and actions over time, second paragraph of bulleted section. The sentence should begin: "The ability to model future ecosystem impacts &" 23. Prior ity D, Current Situation, 1st bullet (Q3, page 27). Suggest the first sentence would be more accurately stated by adding "sole" before "mission", so it would read in part &."until the Partnership was created, no single entity had the sole mission to protect and restore Puget Sound." Draft Action Agenda Comments - Federal Agencies 29 of 60 Draft Action Agenda Comments - Federal Agencies 30 of 60 Draft Action Agenda Comments - Federal Agencies 31 of 60 Draft Action Agenda Comments - Federal Agencies 32 of 60 Draft Action Agenda Comments - Federal Agencies 33 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 1 EPA Detailed Comments on the Draft 2020 Puget Sound Action Agenda November 21,2008 Supplemental to EPA 9s letter to the Partnership dated November 21,2008 General Comments A comprehensive statement of the condition of the Sound should be provided. A factual, concise summary of the actual state of the Sound could powerfully set the stage for the importance of the actions the Action Agenda calls for. ASAP Appreciate the breadth of scope of the initiatives and categories of actions proposed. However, many of the actions identified do not have adequate information or detail to be actionable. There needs to be more information regarding specific action outputs and how those outputs will lead to identified environmental outcomes. (who what when where 3 priorities and funding) The agenda needs to establish stronger connections with the indicators listed in Question 1 and each of the Question 3 topics 3 which indicators are affected by the proposed actions? Proposed Actions to Improve Dissolved Oxygen Conditions should reference scientific assessments underway and acknowledge that the results would be factored into plans as they become available. Lack of Context for Priority Action Items - For many actions, there is little or no mention of efforts currently underway, making it hard to put some of the suggested actions in context. Given that the Action Agenda needs to make the case for establishing and achieving ambitious priorities for ecosystem protection, the document needs to include references to support and document the basis of the recommendations. Examples of Undocumented Generalities . Number one contributor to the decline of Puget Sound is all the harmful and toxic chemicals we add to the water . . . (Introduction, page 6); we have also categorized the threats facing the region and have identified two critical threats . . . (Question 2, page 1); The Partnership has identified six broad categories of threats . . . (Question 2, page 4); overriding problems of habitat alteration and loss (Question 2, page 7); identify the five strategic priorities (Question 3, page 2) . So what is the priority for action? The 2020 action agenda should be explicit in stating that part of the agenda is to identify and prioritize the issues having the largest adverse effects on Puget Sound based on scientific evaluations, rather than making broad generalizations regarding what is adversely affecting the Sound. We strongly support A.1 (focus growth away from ecologically important areas), A.2 (permanently protect intact areas that function well), and C.2 (comprehensive, integrated approach to stormwater) and applaud foresight to identify both growth and climate change as key factors to address through a long term ecosystem protection approach. Draft Action Agenda Comments - Federal Agencies 34 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 2 Strategic objectives expressed as benchmarks or environmental outcomes are still lacking for many key topics (e.g. nutrient source control, watershed scale habitat protection and restoration, water quality protection, etc&). EPA would like to see a more systematic approach for identifying targets for each key objective and also a set of indicator metrics that track the driver/pressure-state/condition-response relationship for each key objective. This was our understanding of the role of the Integrated Ecosystem Assessment and Ecosystem Indicator work tasks that EPA funded NOAA/NWFSC to help accomplish. Even providing some of the basic elements of a conceptual model linking actions to outcomes would be helpful (e.g. Chesapeake Bay program uses such a conceptual model for organizing and linking different actions to outcomes.) Water quality at recreational beaches and shellfish growing areas should be added as a provisional water quality indicator as it relates directly to outcome targets and is very responsive. Ecosystem scales are not distinguished in the document. Not clear what actions are initiated across the basin, across the respective action areas or within local watersheds. At the local level, watersheds should be recognized as the basic unit for protecting ecosystems, both large and small. asap It must be clear how these many tasks and actions come together and result in attainment of environmental outcomes. Actions are spread throughout the document and cannot easily be grouped to see how they are related and work together, through time and across the various Action Area geographies to achieve specific targets, milestones, or protection or restoration objectives. asap EPA urges the Partnership to, in future development of the Action Agenda, to develop a working conceptual model of the ecosystem. Such a model could be used to graphically diagram/flowchart the relationships between Agenda actions and anticipated ecosystem responses to those actions and could be an extremely useful communication tool. It could also potentially be useful in helping prioritize among actions by the extent to which they reduce ecosystem threats or preserve ecosystem characteristics and services. now Clearer recognition of Tribes 9 roles in Puget Sound efforts . Tribes within the Basin have long been formally involved in specific efforts to restore and protect Puget Sound. The Partnership should ensure that the Agenda development facilitates appropriate reflection of the roles, responsibilities, and resources that Tribes bring to past, current and future work on Puget Sound recovery and protection. EPA urges the Partnership to continue to work with Tribes to appropriately reflect their knowledge, data, work products, responsibilities, and authorities in the development of the Action Agenda. Introduction now The "What can people do..." on pages 6-7 could use some boldness. What are the cbig d things people can do? Choose to live closer to work. Don 9t build in a flood plain. Don 9t armor shorelines. Don't fill wetlands on your property. Buy local products. Consume less. Question 1 Draft Action Agenda Comments - Federal Agencies 35 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 3 The provisional targets and benchmarks for evaluating ecosystem recovery (Question 1, page 3) could be significantly improved if these were to specify adoption and implementation of an index of biologic, chemical and physical measurements. Such measurements may be combined to provide the best information about current status and trends in the health of these waters. The rationale for the instream flows targets applying only during wet years should be explained. Dry years would seem to be the critical condition. We have a concern that the proposed land cover indicator target and benchmark represent additional degradation to local watersheds. Question 2 Question 2, pages 2 & 3 The Action Agenda discusses using lower levels of contamination in herring as one measure of success. While this is a good measure we would also suggest using other indicators such as lower levels in english sole, crab, clams, and/or geoducks as measures of success. now Question 2 Page 5 For the following statement cEmerging contaminants from medication and personal care products often pass through sewage plants without treatment d requires some clarification. It would help to clarify that the issue is with primary versus secondary treatment or that the sewage treatment does not remove PPCPs. I believe studies have shown that treatment plants reduce the concentrations of PPCPs in waste water. Providing a more succinct statement will result in a more attainable solution. Q2/p2 3 Human Well Being Measures To be discerning across geographic areas and to be able to show any significant change from baseline conditions, most of the land use indicators (impervious cover, forest cover, etc.) should be presented as a % of local watershed area. Q2/p3 3 Land Use and Habitat Measures The basis for the eelgrass target and the complement of necessary actions and investments needed to attain the target need clarification and reference or more detail. It is also not clear if we have the baseline or routine methods to monitor and distinguish change in this habitat type from baseline across so much of the sound. Causes of extensive eelgrass loss are also not clearly understood and may be the result of many different factors. Q2/p3 3 Freshwater Resources Measures Is there a technical basis that can be provided for this target based on river basin flow statistics? Please clarify and provide reference. Q2/p3 3 Water Quality Measures Not sure which toxic compounds in herring would be monitored as source reduction target at this time. Pathogen levels affecting recreational beaches and commercial and recreational shellfish beds would be a more direct and locally responsive water quality metric to include and links directly to 2020 target. Q2/p6 3 Harvest Also consider derelict gear and ghost fishing implications through lost pots and nets, particularly in certain locations. Question 3 Draft Action Agenda Comments - Federal Agencies 36 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 4 The cGuiding Principles for Ecosystem Management& d on p. 4 is well done. For each strategic priority (A-E) it should be explained how that strategy inter-relates with the others. Question 3A Please clarify the relationship of B & C to protection: Watershed assessments need to drive B & C so that protection is effective. A.1.1. &.must result in science-based watershed scale land use plans A.1.3 GIS maps should be developed at both the WRIA scale (broad view) and the basin-scale for basins near population areas. It's really important for cities and counties to understand how the land they protect (critical areas, etc) fits into the broader picture of the basin and WRIA. This will be very helpful in garnering the political support to protect these areas. The Next Steps should include the completion of a specified number of maps. Q3/p5 3 Rationale for Action Land cover must be protected at the catchment or watershed scale to protect water quality . Ad hoc protection at site scale is of marginal benefit. A.1. Perhaps more quickly adopted and focused changes to SMA and GMA should be considered given that updates to these programs are currently supposed to be completed by 2013. Q3/p8 3 A.1 #1 There are many ecosystem scales. An ecosystem perspective across the basin 9s jurisdictions is important and A.1.1could help support this. Emphasis should be on building local capacity for protecting important local watersheds and sub-basins. A.5 Ballast water 3 The near term actions listed seem to imply that there are no current state ballast water discharge standards. The WDFW web site at: http://wdfw.wa.gov/fish/ballast/ballast.htm describes current standards. Question 3B 3B This section could also be strengthened by discussing and addressing hydrologic alteration as a specific theme or linking to the discussion in A.3. Draft Action Agenda Comments - Federal Agencies 37 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 5 Q3/p15 - Establishing watershed based restoration priorities (link to "A") would be a good point to list in the bullets of this section, particularly related to water quality restoration and upgrade of shellfish beds. Q3/p16 3 B.1.2 Please add the Lower Elwha watershed restoration work to this list of major near term projects requiring completion. Q3/p17 3 B.2. Please add Duwamish source control and toxic remediation to this list of important urban bay implementation efforts being initiated in the near term. Question 3C C. Page 19 3 Improving Actions Over Time There is discussion of a watershed-scale study of stormwater management strategies on pollutant loads. Such a study would advance the understanding of stormwater and its contribution to pollutant loads. However, none of the near-term actions focus on funding or initiating/completing this study. If stormwater runoff is a major source of pollutants into Puget Sound 3 this study would help ensure cleanup efforts are focused in the right area. C.1., C.2., or C.4. The Kitsap Co. Pollution Identification and Control (PIC) program is a well- regarded local program to address nonpoint pollution in an integrated and cost effective manner. An action should be added to promote its use as a model local program with potential applicability for other areas. C.1.1. and C.3. Pharmaceuticals and personal care products (PPCPs) include a wide range of substances that we commonly use in everyday living. PPCPs disposed into water when we flush toilets and wash our bodies account for a majority of the PPCPs that reach wastewater treatment plants and septic systems. Note: very little is contained in stormwater runoff as implied in C.1, page 21 (CSO 9s excluded, of course). Drug take back programs are a positive step but could at most reduce PPCPs in wastewater by about 20%. Depending on the compound, PPCPs and their breakdown products are not completely removed by the secondary treatment which is routinely used by municipalities in the Puget Sound area. Literature from various studies has documented that advanced treatment for reducing nutrients in wastewater can also significantly reduce the amount of PPCPs in the treated effluent. The focus of concerns about potential environmental or human health effects of PPCPs should be focused on improving treatment of domestic wastewater and eliminating CSOs. C.1.1.2 This is unclear. If the reference is to TSCA, there are already national authorities for regulating new and existing chemicals 3 with different regulatory approaches for each category (new or existing as of the effective date of TSCA). The agenda should be more specific in describing this action item. There is also a national PBT strategy under TSCA. Draft Action Agenda Comments - Federal Agencies 38 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 6 C2 Given the multiple planning processes and laws available to local governments in Puget Sound, implementation of watershed permitting may not be the most effective tool to address stormwater. In October, 2008 the National Research Council published a comprehensive analysis of the CWA NPDES stormwater permitting program. Over the next couple of months EPA will be evaluating the recommendations. At that time we will be better able to comment on the stormwater watershed permit related recommendations in the action agenda. C.2.? Or D.4.? Ecology 9s reliance on conventional pollutants for Section 303(d) listing results in a significant number of waterbodies impaired by stormwater being excluded from the list. This reliance creates a gap in coverage for Ecology 9s water quality program and its ability to protect salmon uses. EPA recommends that in the next Section 303(d) that in the next Section 303(d) listing cycle, Ecology assess and list waterbodies as impaired based on biological and toxic information under its current water quality standards. We encourage Ecology to target watersheds that are important to salmon habitat. These listings and subsequent Total Maximum Daily Loads (TMDLSs) will provide important feedback to guide stormwater management implementation. C.2. #1 WQ monitoring is critical to accomplishing items C.2.1-C.2.3. Near term action C.2.1 appears to address the WQ monitoring issue to some extent, but it is not clear whether the thrust of this is monitoring coordination, or expanded monitoring efforts. C.2.2.2 (Question 3, page 22) The Action Plan clearly articulates the contribution of pollutants to Puget Sound from urban stormwater discharges; therefore, rather than cinvestigate expansion of NPDES permit coverage, d the Partnership should require expansion of the NPDES permit program to include such additional discharges as necessary. Through this Action Plan, it is reasonable to designate jurisdictions within the Puget Sound watershed as csignificant contributor(s) of pollutants, d and require the implementation of comprehensive stormwater control programs consistent with Ecology 9s Phase I and Phase II MS4 permits for Western Washington. C.2.2.3. and C.2.2.4. LID provides site scale and neighborhood scale solutions that local implementers need to place into the watershed framework to protect and restore watershed processes. The Partnership needs to promote the full range of LID techniques including infiltration, evapotranspiration and capture and reuse in Puget Sound. The Partnership should aggressively support the actions in C223 and C224 to set the stage for successful implementation of LID in Puget Sound, with target dates for completing training and education that line up with changes to NPDES stormwater permits. Note that LID may not actually lead to a healthy Puget Sound, we may have to get closer to cNo-impact Development d C.2.2.5 and C.2. Near-term action #5 should be removed or changed (similarly the action for PSP to convene a CSO group specifically for King County and Seattle and EPA that is included in the implementation table). EPA is currently in negotiations with both the County and City, under signed confidentiality agreements, regarding CSOs. There isn 9t an appropriate role for PSP as convener at this time. Draft Action Agenda Comments - Federal Agencies 39 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 7 C.2.3.2 & near term C#2 Recommend adding an action item to focus on pesticide reduction in Puget Sound. Oregon DEQ is leading efforts to reduce pesticides in water and fish tissue in the Columbia River through pesticide stewardship efforts with the agricultural community in Oregon. There are excellent opportunities to expand this type of work into Washington. The work could include expanding legacy pesticide collection events, doing outreach to reduce pesticide use near waterways, and making better pesticide choices to reduce impacts to aquatic resources. For example, EPA could partner with Washington Department of Agriculture, watershed councils, Tribes, and NRCS to do the work. (C.2.3.2 and C.2 Near-term Actions, page 23 hints at this action but in a more general way.) now C.2.3.3. Enforce CAFO permits (added action) C.3 Many studies have cited the lack of wastewater treatment infrastructure as a critical national problem, with significant funding shortfalls identified as a critical issue. The PSP agenda should identify funding needed to accomplish this task, perhaps in the manner of a GAP type analysis similar to what has been done at the national level: http://www.epa.gov/waterinfrastructure/infrastructuregap.html A GAP type analysis should also be considered as a way of managing and prioritizing some of the other tasks listed in this section, including those storm water and septic system tasks described in C.2 and C.4 that would require funding support to local governments. C.3. Municipal discharges into south and central Puget Sound contribute a large amount of the nitrogen that is causing low dissolved oxygen levels and algae blooms. Improving wastewater treatment should be clearly highlighted as an important immediate need. C.4 #3 Prepare proposals for possible funding with economic stimulus funding that may be added to CWSRF C.4. The number and density of septic systems installed in many Puget Sound watersheds exceed the loading capacity of the soils in some areas. The result is not only septic systems which cfail d (defined by most local health departments as surfacing septage) but which increase the amount of nitrates and pollutants in septage reaching shallow ground water. Nitrates in some Puget Sound aquifers already exceed or are approaching concentrations that are a concern to human health. Impacts on aquatic organism occur at lower concentrations than those of concern to humans. A more immediate concern is that these vulnerable aquifers also provide most of the water in Puget lowland streams during the critical warm season. Higher concentrations of nitrates from septic systems are being carried to marine waters of Puget Sound where they cause or contribute to low dissolved oxygen and algae blooms. C.5 The agenda should consider recommending ccumulative effects d type analyses for high priority clean-up decisions on the Sound. At present most clean-up decisions are done on a site specific, piecemeal basis. C.5. near term action The plan should reflect here EPA's sediment cleanup goal for 2009-2013 (200 acres of "construction complete" at Superfund sites). Draft Action Agenda Comments - Federal Agencies 40 of 60 EPA Comments on the Draft 2020 Puget Sound Action Agenda November 20, 2008 8 C.6 Near-term Actions, lists: 1) Fund the swimming beach monitoring program, and 2) Fund the shellfish and fish advisory monitoring programs. This leaves the reader with the impression that these are not funded now. If these programs are currently being funded, these near-term actions should be re-worded to reflect this (e.g., cContinue to fund& d). C.6 Near Term actions The following Near Term Action should be included: cEvaluate existing contamination of Puget Sound shellfish, and based on this evaluation, develop a sampling and analysis plan to quantify chemical contaminants levels in Puget Sound shellfish. d Question 3D now D.3.5.6. and D.3. near-term #4 Actions D.3.5.6 and Near Ter

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