North Central Puget Sound GRP Response to Public Comments

The Washington Department of Ecology is updating the North Central Puget Sound (NCPS) Geographic Response Plan (GRP). An important part of the update process was hearing from the people that live, work, and play in the GRP area. To facilitate this, we opened the plan to public comment from September 18th  to October 18th, 2020.
Below, you will find an overview of comments received and Ecology’s response. Ecology appreciates everyone who took the time to provide comments on this GRP. GRPs are improved by this community’s input and we appreciate your ongoing efforts in protecting Washington’s environment. Feel free to reach out to  darcy.bird@ecy.wa.gov or 360-480-2084 with any questions.
 

North Central Puget Sound GRP Responsiveness Summary to Comments

Ecology post plans for public review for 30 days. After the 30 day public review period ends, Ecology addresses all comments received. The following is a responsiveness summary to your comments submitted to Ecology.

GRP Section

Public Comment

Ecology Response

General Updating GRPs is a critical, pro-active step in oil spill preparedness and response. Thank you for supporting Ecology’s effort to update Geographic Response Plans in Snohomish County.
General Changing the format of the GRP to a web-based one with downloadable sections and embedded links substantially increases the utility of the document, and facilitates a more effective, timely response, when implementation of the plan is necessary. Thank you for your feedback on the online platform we are migrating to in the upcoming year.
General Revisions of the Site Description and Resources at Risk sections are significant improvements. We greatly appreciate the inclusion of much of the county-specific information that we previously provided in writing during the 2017 Stillaguamish GRP update as well as with those we discussed with you in-person during our meeting last year (Sept.2019). On behalf of Ecology and the Spills Program, I would like to thank the Snohomish Marine Resources Committee for going above and beyond in the review of this GRP. Thanks to your tireless work in preparedness, this plan is clearer and will be more effective in a potential spill.
General Recommend acknowledging and cross-referencing between adjacent GRPs, when applicable, given the hydrologic connectivity of the region, the widespread distribution and mobility of the area’s sensitive natural resources, and the significant importance of the local cultural and economic resources. Such cross-references would allow spill responders to be better informed and potentially help them more effectively minimize regional spill-related impacts. As Ecology moves GRPs to an online platform, there will be cross referencing on the JETTY site that will assist responders in identifying resources at risk across GRP boundaries.
Site Description 2.6 RISK ASSESSMENT 2.6 ? Are other sections numbered? Please check for consistency. This was an error in numbering- the 2.6 has been removed from the GRP.
Site Description Aircraft: The Whidbey Naval Air Station and Payne Paine Field (Everett) … note spelling correction The spelling error has been corrected in the GRP.
Site Description Recreational Boating: Accidents involving recreational watercraft in the planning area have the potential to result in spills of a few gallons of gasoline up to hundreds of gallons of diesel fuel various petroleum products (e.g., gasoline, diesel, lubricants). Thank you for your recommended edits to this paragraph- the sentence has been updated in the GRP and reads much clearer now.
Response Contacts Sheet Thanks for sending the response contact page for the NCPS GRP.  The only addition that I would suggest is to consider  including the Snohomish Conservation District. It works very closely and collaboratively with farmers, agriculture folks, and rural landowners throughout the county and may be a valuable asset to contact in the event of a spill response. Due to the general role of conservation districts, it seems inappropriate to include them in the emergency contacts sheet. However, conservation districts do represent significant economic resources, and their contact information is now included in the economic resources at risk section of the plan.
Non-Floating Oils Response Options Water turbidity The use of the term “sedimentation” in multiple contexts is somewhat inaccurate and misleading. Suggest replacing text with: Turbulence can result in increased sediment loads in the water column that, if entrained with spilled oil, may increase the oil’s density and cause it to submerge or sink. The corresponding section was updated to include the clarifications surrounding sedimentation/turbulence. This change will be made in all GRPs with a corresponding non-floating oil section.
Non-Floating Oils Response Options In the “Conditions And Considerations For Non-Floating Oil” table: If “Open Public Shellfish Harvesting” and “Open Commercial Shellfish Harvesting” include Dungeness crab harvesting, then these categories are present in Port Gardner/Possession Sound. Spawning Areas are present in the Port Gardner/Possession Sound area.
o A Recreational Dive Area is present in Port Gardner/Possession Sound (i.e., the Mukilteo T-dock dive site near the ferry/Silver Cloud Hotel)
Thank you for identifying additional information for this new section of the GRP. The grid has been updated to reflect the information you shared in your comment, except for the open public shellfish harvesting in Port Gardner. I used the Department of Health’s shellfish harvesting map layer to determine the absence or presence of public shell fishing. The only beach mapped in the general area has been closed to public shellfish harvest.
Response Strategies and Priorities Given the significant ecological, tribal, and recreational/economic resources at risk in the Port Susan area, it would be advisable to consider a response strategy for the Kayak Point region of Sector NC-4. Kayak Point County Park is located there. It has a boat ramp and a large parking lot, and could be used as a response staging area. The protection of resources at risk during an oil spill are not limited to what is contained in a Geographic Response Plan. Due to the feasibility and accessibility of the Port Susan area, it would be difficult to design an effective response strategy in this area without better defining a specific resource at risk to protect. However, during a spill ad hoc strategies should and would be developed to keep oil out of Port Susan. Kayak Point County Park will be included in the plan as a more localized staging area for Port Susan, per your comment.
Response Strategies and Priorities There is a NCPS GRP response strategy and option for the railroad crossing of the Stillaguamish River near West Pass (NC-14), but not for the nearby railroad crossing over the Stillaguamish River just west-north-west of Silvana (near the intersection with South Slough). The ecologically and economically sensitive resources in that area, coupled with the large quantities of oil transported by rail in Snohomish County, warrant further consideration for a response plan at this location. COOKS-0.2, within the Stillaguamish River GRP, serves as a collection strategy at the railroad crossing near South Slough. Additionally, downriver of the railroad crossings in this vicinity is HATS-1.75, another collection strategy designed to prevent oil from entering Port Susan. Also, NCPS-15 is a collection strategy downstream of another railroad crossing that would prevent oil from entering Port Susan. No additional GRPs will be added to NCPS at this time, however a note will be added to the Stillaguamish GRP, where the railroad crossings exist, to look into more protection strategies, as needed.
Resources at Risk Eelgrass beds Delete last sentence of the paragraph The kelp beds present near Deception Pass and the northern part of Skagit Bay serve as important fish rearing areas. This sentence was deleted per your request, it duplicates information that is gone into at greater depth in a later paragraph.
Resources at Risk Revise paragraph on kelp beds as follows: Scattered kelp beds occur in the northern portions of the region, near Deception Pass and the northern part of Skagit Bay, as well in the southern portion of the region, near Gedney (Hat) Island. These habitats perform ecological functions similar to eelgrass beds, and serve as important fish rearing areas. The paragraph on kelp beds was revised, per your recommendations.
Resources at Risk Restoration sites are areas where significant efforts have occurred to restore natural functions in a degraded habitat. The missing verb was added to this section.
Resources at Risk Rock reefs Sentence revision: Macro algae, and including kelps, also widely utilize the structure that this type of habitat provides. Addition: The crevices and overhangs associated with these reefs serve as valuable habitat for a wide variety of other species such as crabs, shrimp, octopus, wolf eel, rockfish, cabezon and lingcod. The language in this section was updated to include kelp as a macro algae, thank you for the correction. Additionally, cabezon were added to the list of species in this section.
Resources at Risk Marbled murrelets occur throughout the region, especially near Deception Pass, within Saratoga Passage, and in the southern portion of Port Susan and Port Gardner/Possession Sound. Port Gardner and Possession Sound were added to this section of the plan.
Resources at Risk Small numbers of gray whales are commonly found in Saratoga Passage, and Port Susan, Port Gardner and Possession Sound from spring through late fall. Port Gardner and Possession Sound were added to this section of the plan.
Resources at Risk 8. Old Stillaguamish River Channel: Eelgrass, wetland, salt marsh and slough habitats. Salmonid spawning and rearing habitat. Presence of federally threatened bull trout, Puget Sound Chinook, and Puget Sound steelhead. Waterfowl and shorebird concentrations.). Harbor seals. Leque Island and zis a ba restoration sites. The unnecessary “)” has been removed from the plan.
Resources at Risk 13. Possession Sound, Gedney (Hat) Island and vicinity: Forage fish spawning. Juvenile salmonids and rearing habitat. Dungeness crab and shellfish. Bald eagle nesting and marbled murrelet. Orca, humpback whales, and gray whale feeding area (spring through fall). Possession Sound was added to the title of number 14, and the additional species were updated per your recommendation.
Resources at Risk 14. Cultus Bay: This area is not within the boundary of the NCPS GRP. It is in the adjacent Admiralty Inlet GRP. Recommend deleting from the document’s text and Geographic Areas of Concern Figure 3. A clarifying statement was added to this paragraph, directing the reader to the Admiralty Inlet GRP for more information.
Economic Resources at Risk Please add Edgewater Beach Park and the Mount Baker Terminal Shipping Facility. Both are located in Mukilteo/South Everett and are owned by the Port of Everett (check to see if Mukilteo will be the manager/point of contact for the Edgewater Beach Park as part of the city’s Waterfront Landing Plan/Project currently in progress). Both locations represent economic resources potentially impacted in the event of an oil spill in the area and should be identified in the GRP. Thank you for identifying these additional economic resources at risk for addition in the NCPS GRP. Both Edgewater Park and the Mount Baker Terminal have been added to the economic resources at risk portion of the plan.

San Juan Islands GRP – Open for Public Comment

My name is Max Gordon, I’m an Oil Spill Preparedness Planner with Ecology, and I am happy to announce that the San Juan Islands (SJI) Geographic Response Plan (GRP) is now open for public comment!

GRPs aim to protect the sensitive natural, cultural, and economic resources in a specified geographic area. A key part of this process is gathering input from the people who work, live, and play in this community. I would appreciate hearing your thoughts over the next several weeks (November 9– December 9).

Ecology last fully updated the San Juan Islands GRP in 2011, and obviously much has changed since then. That version of the plan was tied to the North Puget Sound planning area.  It was decided in this planning cycle to divide the joint plan into two separate plans.

Description of the Planning Area

The San Juan Islands is bounded by the Strait of Georgia to the north, Rosario Strait to the east, the Strait of Juan de Fuca to the south, and Haro Strait to the west.  The marine waters surrounding the San Juan Islands are among the most biologically rich and sensitive areas of the State.  A wide diversity of shoreline and marine habitats (rocks, reefs, and islands), abundant food resources, and exceptional water quality all contribute to making this area especially valuable to wildlife.  The communities of Friday Harbor, Eastsound, and Lopez are located within the boundaries of this planning area, as well as all of San Juan County.

Requesting comments during a pandemic

I am excited to report that this plan is available for review, but not that it is happening during a pandemic.  To make sure that everyone has a full opportunity to contribute, comments will be requested again in 2021.

GRPs are vital to our state’s preparedness in the event of an oil spill. Please follow the links below to review the draft of the updated GRP or provide comments. You may also submit comments by mail or email. Feel free to reach out to me with any questions or concerns at max.gordon@ecy.wa.gov or 360-972-4890.

Review the draft GRP: https://fortress.wa.gov/ecy/ezshare/sppr/Preparedness/SJICoverPage.pdf

Comment online:

Use our online comment form: http://cs.ecology.commentinput.com/?id=buTBa

Comment by mail:

Max Gordon
Department of Ecology, Spills Program
PO Box 47600
Olympia, WA 98504-7600

Central Puget Sound GRP – Open for Public Comment!

Deployed boom outside the Shell Harbor Island facility in Seattle, WA.

My name is Wendy Buffett, I’m an oil spill preparedness planner with Ecology, and I’m so excited to announce the Central Puget Sound (CPS) Geographic Response Plan (GRP) is now open for public comment!

GRPs aim to protect the sensitive natural, cultural, and economic resources in a specified geographic area. A key part of this process is gathering input from the people who work, live, and play in this community. I hope to hear from you during this public comment period (November 5th– December 10th).

Ecology last fully updated the Central Puget Sound GRP in 1994, and obviously much has changed since then. This area includes ten bulk oil facilities, two railroads now moving crude, two petroleum pipelines, and several bulk oil shipping companies. All are regulated by Ecology and are required to test GRP strategies twice per year during deployment drills. After 25 years of these tests, people had a lot to say about this GRP.

Why this update took 5 years

The update for this plan actually started in 2015. Harry Chichester was originally assigned to this update, and from the start he worked with Tribes, the US Navy, the US Coast Guard, oil facilities, spill response contractors, state and local agencies, environmental organizations, and other non-governmental groups. Based on those conversations and field visits, he added over 150 potential new strategies to the existing 82 sites, with the intention of removing many of them during a quality control process. However he retired just after fieldwork was completed, leaving nearly 250 strategies to be evaluated.

Around the time Harry retired, our team was meeting a legislative order that doubled the amount of GRPs in the state. When we finished in June 2017, there were 42 GRPs to be maintained by three planners. Over time, our process has changed, we added some more people to our team, and the Central Puget Sound GRP was reassigned to me.

So I reviewed hundreds of strategies, using notes and photos, to whittle the list down. I focused on whether the strategies could be effectively deployed, and if they fit the criteria in the Northwest Area Contingency Plan, based on input from Tribes, state agencies, and oil spill response contractors. The changes are summarized in a spreadsheet, linked in the below PDF.

Between training, oil spill contingency plan maintenance, drills, GRP site visits, data entry, meeting with experts, and writing chapters, it took two years until the draft was ready. I shared a portion of it with resource agencies and tribes – right as our COVID lockdown started. So again, the draft was paused while we figured out what the pandemic meant for meaningful outreach and our own workloads. Over the summer, we created a tool to add non-floating oil information to GRPs, so that we can update plans in time to meet an upcoming legislative deadline.

Requesting comments during a pandemic

Now, 5 years after the Central Puget Sound GRP was opened, an updated draft is available. I am so pleased that this plan is finally available for review, but not that it is happening during a pandemic.  To make sure that everyone gets a chance to contribute, comments will be requested again in 2021.

These geographic response plans are vital to our state’s preparedness in the event of an oil spill. Please follow the links below to review the draft of the updated GRP or provide comments. You may also submit comments by mail or email. Feel free to reach out to me with any questions or concerns at wendy.buffett@ecy.wa.gov or 360-791-4385.

Review the draft GRP: https://fortress.wa.gov/ecy/ezshare/sppr/Preparedness/CPS-GRP/CPS-PublicReviewCoverPage.pdf

Comment online:

Use our online comment form: http://sppr.ecology.commentinput.com/?id=jpUJb

Comment by mail:

Wendy Buffett
Department of Ecology, Spills Program
PO Box 47600
Olympia, WA 98504-7600

North Central Puget Sound – Open for Public Comments

Howdy, OilSpills101 Blog Reader!

Image: Penn Cove from the air, looking at Kennedy Lagoon (NC-18.1). Photo Credit: Darcy Bird
Image: Penn Cove from the air, looking at Kennedy Lagoon (NC-18.1). Photo Credit: Darcy Bird

I am Darcy Bird, an oil spill preparedness planner with Ecology, and excited to announce the North Central Puget Sound (NCPS) Geographic Response Plan (GRP) is now open for public comment!

GRPs aim to protect the sensitive natural, cultural, and economic resources in a specified geographic area. The geographic areas in Washington State with GRPs have associated risks from oil spills; industry may transport, store, refine, or transfer oil in these regions. The North Central Puget Sound area, bounded by Mukilteo to the South, Fidalgo Island to the North, Mainland Washington to the East, and Whidbey Island to the west, has unique risks, logistical concerns, and sensitive resources that I researched, conducted fieldwork on, and updated the strategies for during the plan update. A key part of this process is gathering input from the people who work, live, and play in this community. I hope to hear from you during this public comment period (September 18th– October 18th)!

Ecology last updated the North Central Puget Sound GRP in 2011, and much had changed in the region since then. For instance, two restoration projects in the Stillaguamish River Delta had made one strategy obsolete (NC-15). The Stillaguamish Tribe and the Washington State Department of Fish and Wildlife (WDFW) had both completed projects to reconnect the Stillaguamish Delta to tidal influence. Removing dikes to restore estuarine habitat allowed water to flow around the boom configuration identified in the plan. During this update, I changed the location of this exclusion boom to further up-river on the Stillaguamish (NC-15.1) to protect these restoration projects. A plan is only as good as the maintenance of that plan, which is why Ecology tries to regularly update GRPs.

Additionally, work done on the FV Deep Sea spill response led me to add strategies to the plan. Penn Cove, on Whidbey Island, has a number of public recreation shellfish beaches, privately owned shellfish aquaculture, and sensitive lagoon habitats. A fishing vessel fire and sinking in 2012, releasing 5,000 gallons of diesel into the environment, threatening these resources. During this incident, responders identified resources not included in the plan at the time. I have added NC-18.1, NC-18.2, NC-18.3, and NC-18.4 as a result of lessons learned from this incident to protect three lagoons in Penn Cove.

I grew up in Anacortes, WA, due north of this planning area, and many of the sites I visited in the course of my fieldwork were beaches and boat launches I had visited regularly as a child. Updating this GRP allowed me to view an area I had grown up in through a different lens and to help protect resources I loved dearly. The maintenance of these geographic response plans are vital to our state’s preparedness in the event of an oil spill. Please follow the links below to review the draft of the updated GRP or provide comments. You may also submit comments by mail or email. Feel free to reach out to me with any questions or concerns at darcy.bird@ecy.wa.gov or 360-480-2084.

Review the draft GRP: https://fortress.wa.gov/ecy/ezshare/sppr/Preparedness/NCPS-GRP/NCPS_PublicReviewCoverPage.pdf

Comment online:

Use our online comment form http://sppr.ecology.commentinput.com/?id=dDcFp

Comment by mail:

Darcy Bird
Department of Ecology, Spills Program
PO Box 47600
Olympia, WA 98504-7600